Airlines for America (A4A)

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Washington DC, United States
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Climate Lobbying Overview: Airlines for America (A4A) is negatively lobbying climate policy in 2019-21, leveraging its support for global climate regulation at the International Civil Aviation Organization (ICAO) to oppose more ambitious regional and national climate policies in the US and EU. While A4A in 2021 stated top-line support for net-zero emissions for US aviation by 2050, it has lobbied against jet fuel taxes, opposed the inclusion of aviation in the EU Emissions Trading System and rejected sustainable fuel mandates, while supporting a US blenders tax credit to promote sustainable aviation fuel.

Top-line Messaging on Climate Policy: Airlines for America’s top-line communications in 2018-21 have generally stated support for international climate policy for aviation while opposing more ambitious regional and national climate action. In March 2021, A4A communicated support for achieving net-zero carbon emissions by 2050 for US aviation as part of its ‘Climate Change Commitment’ report. However, this report does not appear to support policies with enough ambition to implement such GHG emissions reductions to reach net-zero by 2050 in the short, medium, or long-term.

A4A communications in 2019 appear to prioritize the economic growth of aviation at the expense of IPCC recommended emissions reductions, further describing the US airline industry as “an extremely GHG-efficient economic engine”. Furthermore, in a 2019 statement to Congress, A4A appeared to state opposition to regional climate measures, promoting a “worldwide approach” through ICAO that would “stave off the proliferation of unilateral emissions taxes, charges, and trading schemes”. A4A further do not appear to have communicated a position on the Paris Agreement.

Engagement with Climate-Related Regulations: Airlines for America has consistently used its support for ICAO’s global CORSIA offsetting scheme and aviation CO2 standards to actively oppose more ambitious climate regulations in the US and EU. A4A in 2021 continues to support ICAO’s CORSIA emissions mitigation scheme under which airlines must buy offsets for emissions, and/or use ‘CORSIA eligible’ fuels (a voluntary scheme until 2027). A4A frame CORSIA as “the” market-based measure applying to international aviation GHG emissions, precluding countries from imposing unilateral carbon measures on international flights from other countries”. However, A4A in 2020 also appeared to support measures to weaken the CORSIA offsetting scheme, by endorsing a change to its baseline date to include only 2019 emissions compared to an average of 2019-20 emissions, substantially weakening the emissions reduction potential of CORSIA.

A4A in 2019-21 has also actively opposed the EU Emissions Trading Scheme (EU ETS). In a 2020 EU consultation response, Airlines for America opposed expanding the EU ETS to international (non-EEA states to/from EEA states) flights, suggesting it would be illegal. In the response, A4A further advocated to repeal the application of the EU ETS to aviation and replace it with a weaker global CORSIA offsetting scheme. In another November 2021 EU consultation response, A4A similarly argued that the inclusion of international intra-EU flights in the EU ETS would be "not legally tenable" as "the international flights of an aircraft operator cannot be subject to an emissions scheme other than CORSIA absent an agreement between the concerned States covering each’s registered airplane operators".

Similarly, in a 2019 meeting with the EU Commission, A4A stated that it viewed EU and national-level taxes as undermining the integrity of the global CORSIA scheme. Furthermore, in a 2019 statement to the US Congress, A4A praised the US government for opposing EU climate measures for aviation and prioritizing global climate regulations for aviation, and stated opposition against “unilateral emissions taxes, charges and trading schemes”.

A4A has consistently supported ICAO’s global CO2 standard for aviation, including on its website in 2021. In 2019-2020, A4A vocally advocated to the US government to certify ICAO’s global CO2 standard into US law. However, this support was qualified by major exceptions, urging the US government in a 2020 consultation response not to introduce a more ambitious CO2 standard than set by ICAO, and that such standards should not apply to in-service aircraft.

In 2021, A4A's website further communicates support for Congress to “repeal the commercial jet fuel tax” to keep airlines affordable and reduce fuel prices. The A4A opposed an EU jet fuel tax in a 2020 consultation response, questioning its legality. Furthermore, in 2018 A4A directly opposed a jet fuel tax in New Jersey, arguing it would unnecessarily “raise flight costs for passengers”, and supported the repeal of the Georgia jet fuel tax.

In its 2020 report on “Sustainable Aviation Fuel”, Airlines for America stated opposition to sustainable aviation fuel mandates in the US, emphasizing costs concerns. Similarly, in a 2020 EU consultation response, A4A rejected EU mandates on sustainable aviation fuels as they are “a long way from being commercially viable at scale”. Moreover, a November 2021 EU consultation response stated clear opposition to the EU's proposed SAF mandate, further advocating that "If the EU nevertheless proceeds with a mandate: The regulation should not be applied to non-EU carriers' international flights". In 2021, A4A however states support for a "blenders tax credit" to promote US sustainable aviation fuel use in a blog post.

Positioning on Energy Transition: Airlines for America in 2021 appears opposed to measures to decarbonize aviation and transition the energy mix. In 2020, evidence suggests that A4A opposed measures to add green conditions to US COVID-related bailouts for the airline industry, arguing that such conditions may “render the loans unusable, because the process provided to businesses via U.S. bankruptcy law is more attractive”. Furthermore, in October 2019, A4A sent a letter to the Director General of the EU Director General for Mobility to oppose an increase in Germany’s aviation ticket tax. This letter further advocated against measures promoting a modal shift from aviation to rail in Germany, by arguing that the “cross subsidization of trains at the expense of airlines violates the U.S.-EU Air Transport Agreement”. Furthermore, in 2018 A4A released a “Jet Fuel: From Well to Wing Report” advocating for policies that would increase investments in, and expand infrastructure for, US oil pipelines.