4 minute read

5. Passenger and Air Freight Transport

Statement on the PSF report with recommendations on technical screening criteria

9. We propose as a key principle of future CO2 performance criteria that investments in the latest generation of aircraft as well as eco-efficiency improvements of in-service aircraft through retrofit and maintenance measures should always be treated positively within the Taxonomy

Regulation (chapter 7.2, Part B – Annex). It should be acknowledged that investments in the latest generation of aircrafts always have a positive effect on the specific eco-balance of the fleet. Climate protection measures and economic efficiency are drivers for technical progress in aircraft manufacturing. Thus, narrow criteria regarding timeframes to implementation and technology could prevent important investments and therefore progress as to the decarbonisation in aviation in the short term.

The proposed margins to the ICAO CO2 standard applicable until the end of 2032 could become problematic, as ICAO is likely to adapt a new CO2 standard before 2032. This would make the proposed EU-margins, referring to the current standard, outdated before 2032. In addition, with these margins, the EU would effectively be setting their own CO2 standards for the Taxonomy, diverging from internationally recognised standards for sustainable aviation. Therefore, no margins are needed with regards to

ICAO CO2 standards and once a new, more ambitious standard is set at

ICAO-level, the EU could adjust its taxonomy criteria accordingly.

10. Thresholds such as the year 2027 for meeting the “best in class” criteria for commercial aircraft (chapter 7.2, Part B – Annex) are not in line with the product strategies in the aviation industry. These strategies aim at continuous incremental product improvements as well as leap innovations in eco-efficiency occurring at large intervals with product changes.

Therefore, criteria which cannot be met will make it impossible to fund sustainable aircraft investments and in turn, will not help the sector reach its emission reduction targets. The focus must be on realistic targets considering the level of maturity of next generation aircraft, efficiencies created by maintenance, repair and overhaul to optimise performance and environmental impact of existing fleets, and the CO2 reduction opportunities provided by the uptake of Sustainable Aviation Fuels.

11. Scientific studies have shown that about two third of the climate impact of air traffic can be attributed to non-CO2 effects. In some cases, climateoptimized flight paths result in higher CO2 emissions. In this case, the green taxonomy has a climate-damaging effect.1

5. Passenger and Air Freight Transport

12. The “scrapping rule” (chapter 7.4, Annex Part B) is counterproductive. The

“one in – one out” rule neglects the fact, that despite the growth of fleet, the overall CO2 emissions will shrink, due to changes in network structure, more use of alternative fuel and higher fuel efficiency of newer aircraft. The reduction of CO2 emissions per 100 km since 1990 (minus 40 percent) is

Statement on the PSF report with recommendations on technical screening criteria

mainly based on new aircraft with less fuel consumption (e.g. reduction of the overall weight of the new aircraft, components made with composite materials, fuel reserve optimization, payload and drag reduction, installation of wing tips/winglets, new engines etc.). Passenger and Cargo airlines are investing time, money and effort in sustainability initiatives and the renewal of their fleets. Therefore, the development of the net amount of emissions must be considered as well. Furthermore, the global approach of the “scrapping rule” will lead to further carbon leakage effects: According to the proposed rule, fleet growth outside Europe (Asia) will reduce proportionally the taxonomy alignment for companies in Europe, despite the fact that neither companies in Europa nor the EU governments have any influence on the development in other parts of the world.

13. The additional margin for the definition of "Best in Class" aircraft should be eliminated. The ICAO regulation defines the latest and most fuelefficient generation of aircraft. To simplify the procedure regarding "new aircraft", it would be helpful if the European Commission and its subordinated authorities (EASA) would provide a list of the aircraft typeengine combination declared as sustainable. A list of taxonomy aligned aircraft type / engine combinations would be helpful.

14. One of the core problems with the aviation criteria is the lack of air cargo aircraft types that meet the taxonomy criteria proposed. At the present time there are no taxonomy-compliant cargo aircraft on the market; there are new cargo aircraft in the pipeline for long-haul only, but their taxonomy compliance has yet to be confirmed. As far as it is known today, none are planned for short- and medium-haul cargo. This decisively limits the possibility of taxonomy-compliant investments for air cargo companies. It is therefore necessary to adapt the criteria for cargo aircraft on the basis of the real market situation; this can be done, for example, through separate criteria for air cargo or through a transition period for air freight.

15. There is a need for clarification with regard to the way the scrapping rule is calculated "performed by an aircraft acquired before [entry into force of the taxonomy], meeting C30.3 criteria in section 7.2 multiplied by the ratio of [aircraft decommissioned / aircraft delivered] averaged over the last 10 years as evidenced by publicly available data (e.g. Cirium)".

16. Emissions trading expenditures and revenues under the EU-ETS Aviation or CORSIA should be assessed as taxonomy compliant as these are important mechanisms for transforming the aviation sector. Aviation emissions are already offset through a carbon pricing system and expenditure on this should be found to be compliant in the taxonomy. In addition, measures in the area of retrofitting or fuel efficiency programmes should be taken into account, as these can achieve CO2 reductions in the existing fleet, which is particularly important in the air freight segment, where alternative, taxonomy-compliant aircraft are only available to a limited extent.

This article is from: