Climate Policy Engagement Analysis
Climate Policy Engagement Overview: Airlines for America (A4A) is strategically and negatively engaged with climate policy in 2022-24. While A4A states top-line support for net-zero emissions for US aviation by 2050, it opposed the EU Emissions trading scheme, a flight cap at Schiphol airport and ambitious low carbon fuel standards, while supporting US sustainable aviation fuel tax credits.
Top-line Messaging on Climate Policy: A4A supported net-zero CO2 emissions by 2050 from US aviation in August 2024 regulatory comments and in an April 2024 blog. In June 2022 regulatory comments, A4A appeared to advocate for incentives over other regulatory measures, while its webpage, accessed in September 2024 supported government regulation if it is ‘productive’ and ‘practical’. InfluenceMap found no evidence of a position on the Paris Agreement.
Engagement with Climate-Related Regulations: In 2022-24, A4A appeared to support SAF tax credits, while advocating against other climate regulations for aviation. In a December 2022 joint submission A4A supported the US Clean Fuel Production Credit and the SAF blenders tax credit. A4A similarly “strongly supported” both tax credits in a December 2022 regulatory comment. A4A echoed its support for the tax credits and appeared supportive of Hawaii’s renewable fuel tax credit in a January 2024 testimony and supported Colorado’s tax incentive in April 2023 regulatory comments.
Regarding state low-carbon fuel standards (LCFS), in February 2024 and March 2023 comments, A4A opposed the mandatory inclusion of intra-state jet fuel and the legality of integrating intra-state jet fuel into California’s LCFS on a mandated basis. In August 2024 comments, A4A praised the revised proposal that maintained jet fuel inclusion on a voluntary basis. In June 2022 comments on Oregon’s Clean Fuel Program, A4A appeared to advocate for less ambitious carbon intensity benchmarks for SAFs. In July 2022 comments, A4A supported Oregon’s amended carbon intensity benchmarks and further advocated for increased carbon intensity values for SAFs for 2023-24.
Regarding measures to protect land-based carbon stores, through the ‘SAF BTC Coalition’, A4A appeared to advocate for weaker sustainability criteria for SAFs to protect land-based carbon stores under the SAF blenders tax credit and Clean Fuel Producers Credit in February 2023 and December 2022 regulatory comments. A4A opposed a cap on crop-based biofuels under California’s LCFS in March 2023 and August 2022 consultation responses and appeared unsupportive of guardrails for crop-based feedstocks in February 2024 comments. A4A also opposed a cap on Hydrotreated Esters and Fatty Acid-derived SAFs and the exclusion of crop-based feedstocks under the UK SAF mandate in a June 2023 consultation response.
In the EU, in a June 2022 response to the EU Parliament’s proposal A4A argued the extension to departing flights is “in violation of international law”, while A4A CEO, Nicholas Calio, asserted it “directly undermines the…CORSIA agreement” in a June 2022 press release. Additionally, in December 2022 meeting notes between A4A and DG MOVE, obtained via Freedom of Information (FOI) request, A4A stated that extending the EU ETS to non-EU flights would “create problems with the US”. A4A further opposed a monitoring, reporting and verification (MRV) scheme for non-CO2 under the EU ETS that includes extra-EEA flights in a July 2024 consultation response. Similarly, A4A opposed the non-CO2 MRV framework and appeared to suggest it cannot legally be applied to US operators in notes from a May 2024 meeting with DG MOVE, accessed via FOI request.
In a June 2023 UK consultation response, accessed via FOI request, A4A opposed a UK SAF mandate and power-to-liquid sub-mandate, questioning the legality of a mandate imposed on A4A members.
Positioning on Energy Transition: A4A questioned the legality of Hawaii’s aviation fuel tax in a February 2023 regulatory submission. In June 2022 comments on California’s 2022 Scoping Plan Update, A4A supported the proposed non-binding projection scenario for aviation decarbonization of 10% of emissions reductions from electric and hydrogen propulsion, alongside 90% from SAFs. However, in July 2022 comments on New York’s Climate Action Scoping Plan, A4A appeared supportive of non-binding decarbonization scenarios dependent on SAF deployment, while opposing scenarios reliant on zero-emissions technologies.
In a September 2023 joint letter sent to DG MOVE, accessed via FOI request, A4A questioned the legality of a flight cap at Schiphol airport and requested the EU Commission conduct a formal review into the measure. Similarly, in a September 2023 legal complaint A4A urged the US Department of Transport to act against the Schiphol flight cap. A4A echoed its opposition to the flight cap in July 2024 and November 2023 press releases.
InfluenceMap collects and assesses evidence of corporate climate policy engagement on a weekly basis, depending on the availability of information from each specific data source (for more information see our methodology). While this analysis flows through to the company’s scores each week, the summary above is updated periodically.This summary was last updated in 2024.