We have expanded the list of climate policies we assess company engagement with to incorporate land-use related policy, referring to legislative or regulatory measures to enhance and protect ecosystems and land where carbon is being stored. Assessments under this category are currently underweighted in terms of their contribution to the overall company metrics. This weighting will be progressively increased over the next 6 months.
We adjusted the terminology used to describe the queries running down the left-hand side of our scoring matrix and added additional explanatory text to the info-boxes. This has no impact on the scores and methodology. It has been done following user feedback to improve clarity.
Climate Lobbying Overview: European Regions Airline Association (ERA) appears to be lobbying EU climate policy with mixed to negative engagement in 2020-22. The ERA appears to have stated top-line support for net-zero 2050 emissions for European aviation, while lobbying against key policies to reach such a target, such as the full inclusion of aviation in the EU Emissions Trading System (EU ETS) and an EU tax on jet fuel.
Top-line Messaging on Climate Policy: European Regions Airline Association stated support for European aviation to reach net-zero by 2050, as part of the industry-wide ‘Destination 2050 roadmap’, published in 2021, and in response to an EU public consultation in October 2020, ERA further stated they “strongly agree” with the EU’s 2050 climate neutrality goal. Evidence suggests the ERA also supports the Paris Agreement, as part of its 2021 endorsement for the ‘Destination 2050 Roadmap’. Additionally, through their endorsement of the Toulouse Declaration in February 2022, ERA appear to support the adoption of a long-term aspirational goal through ICAO aligned with zero-emissions by 2050. However, ERA’s 2020 sustainability report suggested support for a market-based approach to climate regulation, Not fully supporting the need for climate change regulation stating that the ERA is “challenging governments on their intentions to impose further taxes on aviation”. Communications from ERA’s magazine in 2020 also stress the risks of competitive disadvantage if Europe sought climate action for aviation. Additionally, ERA’s Director General, Montserrat Barriga, argued in 2021 that “taxes are not the solution” to reducing the GHG emissions of European aviation. In a December 2021 press release, ERA further appeared to emphasize cost concerns of the Fit for 55 package on EU airlines.
Engagement with Climate-Related Regulations: The ERA in 2021 stated support for ICAO’s CORSIA emissions mitigation scheme. However, ERA in 2020 also disclosed to have “lobbied” the European Commission to support weakening the CORSIA offsetting scheme by endorsing a change to its baseline date to include only 2019 emissions compared to the previous average of 2019-20 emissions, substantially weakening the effectiveness of CORSIA.
ERA has actively advocated against the inclusion of aviation in the EU Emissions Trading Scheme (EU ETS). In August 2020 and January 2021 EU consultation responses, the ERA supported repealing the EU ETS for aviation, replacing it with CORSIA, and opposed a reduction in free emissions allowances for the sector. Website communications in 2021 also stated support for the suspension of the EU ETS and its replacement with CORSIA, while a media report from March 2021 suggests that the ERA is opposed to reducing free emissions allowances in the EU ETS. Similarly, a December 2021 position paper appeared to oppose a complete phase-out of free allowances by 2027 and a higher linear reduction factor.
Regarding a proposed EU sustainable aviation fuels (SAF) mandate, ERA appears to have a mixed position, including in a 2020 consultation submission on the ReFuelEU initiative. Additionally, while ERA in 2020 endorsed an Aviation Roundtable Report supporting the introduction of an EU mandate for sustainable aviation fuels, a 2020 article in the association’s magazine stressed the “increased financial burden” of blending mandates for European aviation. Despite stating support for EU SAF mandates and e-fuel mandates, ERA also seemed to emphasize cost and carbon leakage concerns, appearing to advocate for ‘flexible’ mandates, and against national SAF mandates, in a December 2021 position paper. Furthermore, ERA’s Director General appeared to argue in a February 2021 AIN Online article that they are “not able to support or come up with a figure a minimum blending quota because there is simply not enough supply.”
Positioning on Energy Transition: ERA appear to be negatively engaged with measures to decarbonize aviation in 2020-22. In a 2020 EU consultation response, the ERA stated opposition to an EU jet fuel tax, arguing that it “is unlikely to address the fundamental and crucial issue of the decarbonisation of aviation”. In a December 2021 position paper, ERA appeared to highlight economic and connectivity concerns to further oppose an EU jet fuel tax. Additionally, in a 2020 ERA magazine communication, the company also appeared unsupportive of fuel taxes for airlines. Furthermore, a March 2022 report on the modal shift from air to rail by Oxera, that was prepared for, and endorsed by, the ERA appeared unsupportive of short-haul flight bans in Europe. ERA Director General, Montserrat Barriga, also described banning air routes as “dangerous” in a November 2021 press release, arguing that short-haul flight bans would be ineffective to address aviation emissions.