4. Manufacturing of Aircraft

Statement on the PSF report with recommendations on technical screening criteria

propulsion solutions might be available in the future, these drive systems are for short distance coastal transport and their commercial availability until 2026 is uncertain.

4. In terms of the criteria for manufacturing of ships (chapter 2.16, Annex Part

B) as well as sea transport (chapter 8.1-6, Annex Part B) the proposed criteria for emissions need to be amended and clarified or respectively deleted as they are unrealistic considering their narrow scope and unclear definition. It is proposed that manufacturing of ships (passenger, sea freight, coastal freight) must comply with the criteria "vessels with zero direct emissions fleet for SOx, NOx, PM" (chapter 2.16, Annex Part B). Yet, it remains unclear whether a shipyard only manufacture ships that comply with these criteria or whether the criteria are set for each individual vessel produced.

5. Regarding the manufacturing of ships for inland freight (chapter 2.16,

Annex Part B) as well as inland freight/passenger water transport (chapters 8.5 and 8.6, Annex Part B) it is proposed they comply with the criteria "zero tailpipe direct emissions fleet for SOx, NOx, PM during navigation, operations and at berth" (chapter 2.16, Annex Part B). The criteria do not specify the difference between this requirement (tailpipe) and the requirement for manufacturing of ships for passengers and for sea and costal freight.

6. The term "zero emissions" needs clarification. This is very critical when assessing pollutant emissions like SOx, NOx and PM. Their relative emission level per kWh power output is several orders of magnitude lower than the relative emission level of CO2 (for example around 600 g/kWh

CO2 emission for a ship powered with fossil diesel fuel compared to 2 g/kWh NOx emissions). Also, for inland waterway transport a clear definition is critical: In the EU, inland waterway vessels with engines above 300 kWh power output already must comply with PM emission limits of 0,015 g/kWh. This could already be considered as "zero" when compared to the relative (per kWh) CO2 emissions of such a vessel running on fossil fuel.

4. Manufacturing of Aircraft

7. Concerning the scope of the economic activity manufacturing of aircraft (chapter 7.2, Part B – Annex) we suggest excluding “military aviation” as it is not subject to the requirements addressed to “civil aviation”. However, as

“military aviation” should be kept in the Taxonomy as an activity we suggest developing separate TSCs for SC and DNSH.

8. We believe that the criteria listed under DNSH on pages 511 and 512 should also be applied to business aviation. Business aviation fulfils an important function as a technology pioneer, e.g. in the area of digitalization in civil aviation, and will stimulate the market ramp-up as a fuel customer of SAF.