Sustainable aviation fuels (ReFuelEU Aviation Initiative)

Air Liquide welcomes the Commission proposal to set a minimum share of sustainable aviation fuel, including a minimum share of synthetic aviation fuel. Key recommendations include: (i)Fully recognise Hydrogen (H2) as a potential sustainable aviation fuel (ii)Facilitate the uptake of sustainable aviation through adequate funding schemes (iii)Align existing legislation with ReFuelEU Aviation.

GoodFuels position on ReFuelEU Aviation. We appreciate the EU’s efforts in leading the energy transition and, besides road transport, now also tackling GHG emissions in both the maritime and aviation sector. Given the cross-border nature of those sectors, it is the right approach to address its GHG impact on EU level and thereby set an example for the international maritime and aviation industry.

FinCo Fuel Group position on ReFuelEU Aviation We appreciate the EU’s efforts in leading the energy transition and, besides road transport, now also tackling GHG emissions in both the maritime and aviation sector. Given the cross-border nature of those sectors, it is the right approach to address its GHG impact on EU level and thereby set an example for the international maritime and aviation industry.

The Mechanical Engineering Industry Association (VDMA) is the largest European industrial association. VDMA represents around 3300 German and European companies in the mechanical engineering industry. The industry represents innovation, export orientation, medium-sized companies and employs around four million people in Europe, more than one million of them in Germany.

Bio Oil Group is a waste based Biodiesel producer in Netherlands, Germany and Austria. The Biodiesel produced in our plants is 100% Used Cooking Oil based (UCOME). Biodiesel cannot be used in aviation due to its cold flow properties but it is a perfect option for the existing car and truck fleet to also contribute to climate protection.

The European Cockpit Association (ECA) is the representative body of European pilots associations, striving for the highest levels of aviation safety and fostering social rights and quality employment for pilots in Europe. It represents 40.000 pilots from across Europe. More information at www.eurocockpit.be. Here is ECA's feed-back about ReFuelEU Aviation Commission's legislative proposal.

Ryanair Holdings plc, Europe’s largest airline group, carried 149m guests p.a. (pre Covid-19) on more than 2,500 daily flights from over 80 bases, connecting over 225 destinations in 37 countries and contributing to the building of a united Europe. Ryanair is Europe’s greenest and cleanest airline group.

Europe's airlines are fully committed to decarbonize air transport and are accelerating their efforts to make Europe the world’s first carbon-neutral continent by 2050 through the reduction of CO2 emissions in absolute terms, and through mitigation.

ECODES (Foundation for Ecology and Development) thanked the European Commission for the opportunity to comment on the proposed amendments to the regulation for sustainable fuels for ReFuelEU aviation. ECODES is an independent non-profit organisation seeking to accelerate the transition to a green, inclusive and responsible economy, framed by new governance, through innovation and building bridges and alliances.

Filed in Spanish · English published by the European Commission

The MVaK represents 21 members which pretreat suitable vegetable waste and residues, mainly used cooking oil and waste fatty acids, process them into waste-based biodiesel or trade feedstocks and finished products. Biodiesel cannot be used in aviation due to its cold flow properties but it is a perfect option for the existing ICEV fleet to also contribute to climate protection.

As the association of the network carriers of the European Union, ACP firmly supports the ambitions laid down in the Fit for 55 package and its objective to become CO2 neutral by 2050. ACP is committed to sensible environmental legislation, a better integration into a European transport network, but most importantly technological investments in solutions that will shape the future of aviation.

Sustainable aviation fuels (SAF) are one of the most direct ways to make substantial reductions in net carbon emissions for aviation across all market segments and aircraft sizes. AmCham EU members representing key players along the aviation value chain have been committed to the development and the scaling up of SAF.

Comments on Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on ensuring a level playing field for sustainable air transport The Context of the Proposal mentions that “For sustainability reasons, first generation biofuels such as crop-based biofuels Feed, and food and crop-based biofuels, which have limited scalability potential and raise sustainability concerns, should not be supported.”…

This feedback is sent in on behalf of the Advisory Council for Aviation Research and innovation in Europe (ACARE). ACARE provides a network for strategic research in aeronautics and air transport so that aviation satisfies the needs of society and secures global leadership for Europe in this important sector.

CO2 Value Europe is the European association dedicated to Carbon Capture and Utilisation (‘CCU’) and represents over 70 members along the CCU value chain, primarily industrial actors from different sectors. CCU is a broad term that covers all established and innovative industrial processes that aim at capturing CO2 – either from industrial point sources or directly from the air – and at transforming the captured CO2…

WKÖ supports the European Green Deal and stands by the climate neutrality goal by 2050. Now a concrete set of measures for a sustainable, ecological change in the EU, in line with a new growth strategy, is necessary. WKÖ will contribute to a legislative package that meets the requirements of effective climate protection and at the same time is practicable and compatible with economic prosperity.

Air transportation is an increasingly growing industry; it became a backbone of citizen’s mobility across borders and central asset for local businesses like tourism, from which several regions depend upon. With the coming of just-in-time logistics, aviation now also plays a key role on agile supply chains across the globe. Aviation currently contributes to the order of 2.4% of global emissions [1][2].

Building a fair and inclusive SAF framework ensuring a level playing field for business aviation (more details in the attached position paper) The business aviation community understands that a serious and credible legislative proposal aiming at increasing the uptake of SAF in Europe has to be realistic and based on an incremental approach so the SAF value chain has the time and the resources to develop the required…

Bellona considers that the Refuel EU strategy fails to ensure that the aviation sector pull its weight when it comes to climate action. In fact, the proposed solutions for the sector to decarbonise are likely to increase emissions since there are no safeguards in place to prevent perverse outcomes.

Norsk e-Fuel is a Norwegian company planning to industrialize Power-to-Liquid (PtL) production starting in Norway. With a strong consortium combining technology experts (Sunfire GmbH, Climeworks AG) as well as experienced EPC (Paul Wurth S.A.) and financing partners (Valinor AS) we develop a unique, modular, and replicable PtL production process to achieve our goal of carbon neutral transportation focusing on the…

Replacing fossil kerosene with SAF is the decisive lever to achieve the goal of CO2-neutral flying. A binding blending quota can help accelerate the market ramp-up of SAF/PtL, therefore Condor Flugdienst welcomes the Commission’s approach as a boost for the SAF market. The ecologically best solution are fuels that are produced from atmospheric CO2, which is why the sub-quota for PtL is rated positively.

MOL Group has a strong ambition to make improvements in its operations that facilitate the gradual transition to a low-carbon, sustainable business model, hence also welcomes the aim of the “Fit for 55” package to target a reduction of at least 55% in greenhouse gas emissions by 2030.

- Biofuels comply today with strict single EU-wide sustainability criteria. This allows all sustainable biofuels to have a role in the decarbonization of European transport. The approach to feedstocks and GHG savings calculations in the Aviation and Maritime proposals unduly deviate from the RED II (and RED III) sustainability criteria.

In principle, the European Commission’s reflections on making air transport more sustainable and, in this context, in particular a requirement for the incorporation of sustainable aviation fuels, are supported. However, we recommend using fuels that are or may be available at the required scale. Biofuels from biomass, both conventional and advanced (waste-based) are already available alternatives.

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APAG welcomes the Commission’s proposal for the ReFuelEU Aviation Regulation. We are pleased by the horizontal alignment with the Renewable Energy Directive (RED II) on sustainable transport fuels and the choice of a Regulation over a Directive. We are delighted that the European Commission’s proposal aims at promoting truly sustainable biofuels for aviation.

The Renewable Fuel Platform (PEK) welcomes in principle the European Commission’s idea of making air transport more sustainable and, in this context, in particular a requirement to include sustainable aviation fuels. In our view, there are two main points to be taken into account in air transport. 1.Aviation fuels must be available in very large quantities.

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GE Aviation has been actively involved in assessing and qualifying SAF since 2007 and works closely with SAF producers, regulators, and operators to ensure that SAF can be widely adopted for use in aviation. Sustainable Aviation Fuel (SAF) are critical for the decarbonization of the aviation sector. For smaller aircraft, SAF will be a bridging measure until zero-emission technologies are mature and market ready.

Novozymes welcomes the Commission’s proposal to implement dedicated legislations for the decarbonization of aviation through sustainable renewable fuels but strongly objects to the decision to exclude or penalize biofuels produced from food and feed crops.

Moving the aviation sector in a more sustainable direction is a major undertaking. This is why Copa and Cogeca call upon the Commission to focus on synergies rather than selecting specific winners. While e-fuels will without a doubt be important in the future, they depend on carbon molecules, which, in a decarbonised future, must come from biogenic sources.

CEPM wishes to transmit its comments on various texts proposed in the “fit for 55” package. In general, CEPM regrets that the contribution of crop based biofuels, including corn bioethanol, is not better supported. CEPM requests that the role of these biofuels be improved, and that it is reflected systematically in the various texts. Please find attached our comments.

Dear Madam or Sir Please find attached GAMA’s feedback on the Sustainable aviation fuels – ReFuelEU Aviation. Please feel free to contact me, should you require any additional information or have any questions. Best regards [name removed] R. FABIAN Director, European Affairs

As a global pioneer in the development of novel SAF supply chains, SkyNRG welcomes this proposal and would like to share the following comments: 1) Book-and-claim system for SAF: The proposed blending mandate for fuel suppliers only allows averaging of deliveries across Union airports until 2030.

Aerospace and Defence Industries Associations of Europe (ASD) thanks the European Commission for this opportunity to comment on the proposal. ASD welcomes the EU’s Refuel EU Aviation initiative; we support the intent of the initiative to boost the production and uptake of sustainable aviation fuels (SAF) to ensure their large-scale availability at low costs in the medium and long term.

This document comprises Danish Energy’s updated positions on: 1. ReFuelEU Aviation on ensuring a level playing field for sustainable air transport 2. FuelEU Maritime on the use of renewable and low-carbon fuels in maritime transport It is important to have ambitious European targets for decarbonization and the use of renewable energy and renewable fuels.

Technoolisus ry supports action at EU level to increase the use of renewable aviation fuels. The measures chosen should be implemented in a way that effectively reduces aviation emissions, prevents carbon leakage and takes into account the operating conditions of the air transport sector and the accessibility of Member States.

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We welcome the introduction of the REFuel Aviation regulation, which will create a market for SAF by setting an obligation to airlines, airport operators as well as to fuel suppliers. Together with the REDII revision, this will provide an adequate incentive to fuels based on their well-to-wing (WTWg) carbon footprint.

The International Council on Clean Transportation (ICCT) welcomes the opportunity to provide comments on the Commission’s proposed ReFuel EU Aviation regulation. We commend the Commission for its continuing efforts to promote a cleaner, lower-carbon transportation sector that uses less petroleum-based fuels. This proposal builds upon the impressive steps the Commission has undertaken to promote low-carbon biofuels.

To stay ahead in the global race for best climate and energy technology solutions, companies need a clear, reliable fit-for-55 implementation plan committing to Europe as an attractive business, investment and innovation location.

LanzaTech commends the European Commission for its consideration of policies in support of aviation greenhouse gas reductions and increased supply and offtake of sustainable aviation fuels in the EU. We welcome the opportunity to respond to the EU Commission’s proposal, and we look forward to working alongside the co-legislators going forward.

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.

Repsol is a global multi-energy company, which shares the world’s ambition to reach climate neutrality in the framework of the Paris Agreement, as well as the EU’s 2050 carbon neutrality objective. We appreciate the opportunity to provide our feedback to this Proposal and remain at Commission’s disposal for any further clarification needed.

Neste welcomes the ReFuelEU Aviation initiative. A European blending mandate for Sustainable Aviation Fuels (SAF) is timely and necessary as it will immediately reduce CO2 emissions in the hardest to abate transport sector: aviation does not have an immediate alternative to fossil fuels.

The proposed ReFuelEU Aviation Regulation aims to increase the production and uptake of SAFs in Europe in the coming years. For the foreseeable future, however, SAF will be more expensive than fossil fuels. Therefore, an unbalanced SAF mandate would distort competition with the rest of the world and shift traffic outside of the EU.

Rolls-Royce: Rolls-Royce pioneers the power that matters to connect, power and protect society. For nearly three decades, our family of turbofan aircraft engines have continued to push the boundaries of what is possible, as each new model sets new performance benchmarks for civil aviation. Sustainability is a core concern for us in our daily business, as climate change is the biggest threat to humanity.

AIRE (Airlines International Representation in Europe) representing 10 Airlines, shares its view on two documents which have a significant impact on the future functioning of aviation: Regulation on ensuring a level playing field for sustainable air transport (RefuelEU Aviation) and Energy Taxation Directive (Revision).

Boeing welcomes the Proposal for a regulation of the European Parliament and of the Council on ensuring a level playing field for sustainable air transport. We appreciate the opportunity to comment on this legislative proposal that advances key sustainable aerospace objectives in Europe. Boeing has been a part of the European aerospace community for more than 80 years.

In our view, the Regulation proposed by the European Commission is an appropriate complement to the existing Renewable Energy Directive to defossilise air transport using sustainable aviation fuels (SAF). In addition to the use of such climate-neutral liquid fuels, such as electro-based synthetic kerosene, the Regulation should therefore encourage investment in their industrial production in order to support their…

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We consider the blending rate to be an effective tool to promote sustainable aviation fuels. In order to further reduce the climate impact of aviation and to promote the market flow of SAF, we are in favour of increasing the rate to 10 % in 2030 and the PtL subquota to 2 % in 2030. We and many other industrial partners consider it realistic to develop production capacity accordingly.

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The sustainability debate for aviation is quite recent, and it is welcome to see a stronger sustainability focus on aviation. The RefuelAviation Directive is an important step. The RefuelAviation Directive is one of two new directives with a focus on strategic parts of the transport sector and are developed without any prior directives to “build on”.

Business travel is fundamental to the world economy and brings many benefits in terms of international connections and wealth creation. However, climate change is a global threat and responsible governments, industries and corporations must continue to work together to reduce carbon emissions and operate in a more sustainable manner.

The regulation points to the essential need for sustainable aviation fuels (SAF) from biomass and other renewable resources. SAF are mandatory in order to reduce the aviation sector's GHG emissions to essentially zero by 2050, as required according to the European Green Deal and in consistency with the Paris 2015 climate protection targets.

Iogen Corporation supports “Fit for 55”, the transformational changes that are required to achieve the EU’s 2030 decarbonisation goals and climate-neutrality by 2050. Indeed, we as a company are fully dedicated to using our world-leading advanced biofuels technologies to develop deep carbon-negative fuels based on green biohydrogen, a process we have successfully commercialised.

Hydrogen Europe recommends the following points regarding the recent proposal of the ReFuelEU Aviation Regulation: 1. Increase the level of ambition with a dedicated, realistic target for the adoption of RFNBO’s in the aviation sector by 2025 and, overall, higher targets and a more even growth trajectory after 2030. 2. Reconsider the practical implementation of additionality principle criteria. 3.

Dear Madam or Sir, Please find attached T&E's position paper on the ReFuelEU Aviation Regulation, which includes our recommendations for SAF targets. We believe that the text has a solid basis, especially when it comes to its scope applying to all departing flights and its exclusion of food and feed crop-based biofuels.

The Food Security Standard (FSS), a joint project from Welthungerhilfe and Meo Carbon Solutions GmbH, allows to integrate the Human Right to Adequate Food into sustainability standards and certification schemes for agricultural production.

The Swedish 2030 secretariat is an independent Think tank committed to the decarbonization of the transport sector. We are not looked into any specific technological solution, the GHG reduction is what matters. Rather sooner than later. The sustainability debate for aviation is quite recent, and it is welcome to see a stronger sustainability focus on aviation. The RefuelAviation Directive is an important step.

Substituting fossil kerosene for Sustainable Aviation Fuels (SAF) can lead to significant GHG emission reductions in the relatively short term but the development of SAF is hampered by several obstacles: • Insufficient maturity in terms of industrial development, lack of investment in production and improvements needed in process efficiency and SAF competitiveness; • limited availability of resources; • Uncertainty…

France Hydrogène welcomes the initiative Refuel Aviation whose goal is to support the uptake of renewable fuels in the air transport. Either with fuel cells or H2 turbines, hydrogen-powered aircraft are not directly targeted by the Regulation as they are considered insufficiently mature technological options within the next 10 years.

Statement: EU Consultation No. 14 on Aviation By Prof. Dr. [name removed] [name removed] of Synthetic Biotechnology, Technical University of Munich, [address removed], Germany, Director TUM-AlgaeTec Center and Member of the German National Council for Bioeconomy The EU aviation sector currently uses about 56 Mio. t kerosene p.a. (70 Mio. L/a).

The eFuel Alliance is a stakeholder initiative committed to promoting the political and social acceptance of eFuels and to securing their regulatory approval and represents more than 150 companies along the value chain of eFuel production. The ReFuelEU Aviation regulation poses a great opportunity to defossilize aviation.

Replacing fossil kerosene with SAF is the decisive lever to achieve the goal of CO2-neutral flying. A binding blending quota can help accelerate the market ramp-up of SAF/PtL, therefore the aviation industry welcomes the Commission’s approach as a boost for the SAF market. The ecologically best solution are fuels that are produced from atmospheric CO2, which is why the sub-quota for PtL is rated positively.

The ReFuel Aviation Regulation will directly constrain airline companies to gradually switch to sustainable aviation fuels (SAF) to reduce their GHG emissions. Hydrogen technologies can play a future role for the decarbonation of the aviation sector, with two main applications.

The European Commission’s Fit for 55 package sets important new goals for emissions reduction in transport. Giving a prominent role to renewable liquid fuels would create a solid foundation for reaching them. To that end, the EU should fully maximise the tools it has on hand for decarbonisation and de-fossilisation.

Under the proposal, obligations for fuel suppliers and airlines are no doubt aimed at creating demand. However, supply will still not be guaranteed without any support mechanisms to facilitate production and financial certainty. Furthermore, airlines will be hit twice, with the tankering regulation posing a significant difficulty.

Today, on the dawn of our proven knowledge of global warming, global aviation sounds hatred on people. A small part of the population spends their time on travelling in the air to distract, discover, consume, work for globalisation, while another look at the sky, climb water, etc.

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Enerkem welcomes the opportunity to provide the following comments regarding the Objectives and Policy Options put forward in the Inception Impact Assessment (IIA) of the European Commission to enable a supportive policy environment for an increase in the production and offtake of Sustainable Aviation Fuel (SAF).

The Bio Oil Group produces UCO-based biodiesel in Netherlands, Germany and Austria. We employ around 100 people within the Biodiesel sector of our group and in 2019 we produced about 175.000 t of UCO-based biodiesel with GHG reductions of up to 91 %. We are proud to make an important contribution to reducing GHG emissions of EU road transport.

Neste Sweden (see www.neste.se) supports the Green Deal’s ambition for climate neutrality in 2050 and welcomes the opportunity given by the Commission to provide input to the publication of the Inception Impact Assessment (the Document) on the ReFuel EU aviation sustainable aviation fuels.

The German Mechanical Engineering Industry Association (VDMA) is the largest European industrial association. VDMA represents more than 3.300 member companies in the SME-dominated mechanical engineering industry in Germany and Europe.

Hydrogen Europe welcomes the ReFuelEU Aviation initiative designed to increase uptake of Sustainable Aviation Fuels (SAF) and thus reduce the carbon footprint of the aviation sector. The initiative is both timely and needed. It's also commendable that the Commission sees a place for both biofuels as well as electro-fuels produced from low-carbon hydrogen.

Camelina Company is an SME created in 2010 for the development of sustainable camelina oil as feedstock for the aviation biofuel industry. Our goal is introducing camelina, a resilient oil crop, as a double crop in existing farmer rotation without displacing food or feed crops. Over 10 years we have deployed +40,000 hectares of sustainable camelina plantations in Europe, working with +1,000 farmers.

Environmental Defense Fund (EDF) welcomes the opportunity to comment on the EC’s plans to incentivize sustainable aviation fuels (SAF). The European Commission should only propose a quantitative SAF mandate if it incorporates a robust sustainability and accounting framework that addresses flaws in existing legislation. To achieve this, the EC should require that SAF policies: 1.

Neste Corporation (see www.neste.com) supports the Green Deal’s ambition for climate neutrality in 2050 and welcomes the opportunity given by the Commission to provide input to the publication of the Inception Impact Assessment (the Document) on the ReFuel EU aviation sustainable aviation fuels.

Aviation is an industry with high greenhouse gas emissions (CO2, NOx and other harmful substances) . The share of air traffic of the CO2-emissions is about 2.4% [1]. But the total greenhouse impact is about 3-times higher. It is forecasted that air traffic will grow further with an annual rate of 3%-5%. The engines may become more efficient, but also the greenhouse gas emissions will increase.

SENASA is a Spanish state-owned aeronautical company that provides services in the areas of training, consultancy, and technical assistance. It is an institution with recognized national and international prestige within the aeronautical sector and is strongly committed to the aviation environment.

The International PtX Hub Berlin recognises the EU Commission’s Initiative „ReFuelEU Aviation – Sustainable Aviation Fuels“ and is prepared to contribute to its conceptual design, implementation, management and monitoring, in particular with respect to synthetic E-fuels from sustainable Power to X (PtX) processes, both within the EU and beyond.

Use of sustainable aviation fuels is the quickest way to reduce the aviation industry’s carbon footprint today. Rapid scale-up in production of SAF, alongside other aviation developments, will be required if aviation is to meet its 2050 decarbonisation goals; at Rolls-Royce we believe SAF will be the key component of ensuring aviation is compatible with a carbon neutral EU.

Civil aviation is a major generator of EU wealth and welfare. Its health and growth will continue to bring large benefits to EU citizens. Aviation is now facing, like many other industries, environmental pressures. These pressures can be comfortably overcome with appropriate and sizeable technology investments. Much has been promised for 2050.

The German Environment Agency (UBA) supports the Commission’s initiative. The current crisis offers a unique opportunity to rethink established business models and to promote sustainable growth. It is a necessary step to achieve the Paris Agreement Climate Goals [1].

The European Business Aviation Association (EBAA) applauds the DG MOVE ReFuelEU initiative towards creating a roadmap that would widen the research and development, infrastructure, supply and use in Europe of sustainable aviation fuel (SAF). EBAA believe that this is a critical future step for aviation towards achieving both its and the EU’s climate goals.

Addressing climate protection in the field of aviation is an excellent initiative of the European Commission. So far, this mode of transport has contributed virtually nothing to decarbonising Europe. This is mainly due to a lack of regulation. In order to reduce GHG emissions in aviation effectively, a binding mandate is needed.

This SAF consultation is welcome recognition that clean fuels form a key element in reducing aviation CO2. The SAF initiative should be embedded in a coordinated and holistic policy approach to decarbonizing aviation to enable open discussion on finding the right regulatory incentives to drive SAF production and uptake while also agreeing on action to address the chronic undertaxation of aviation in Europe.

Reducing greenhouse gas emissions in a growing sector such as aviation is becoming increasingly important. While some advanced biofuels (renewable and waste derived) and electro-fuels can reduce emissions in the aviation sector, their use can also lead to an adverse effect.

Environmental Action Germany (Deutsche Umwelthilfe e.V.) welcomes the opportunity to comment on the ReFuelEU initiative. Greenhouse gas emissions from aviation must be reduced urgently. The ReFuelEU inception impact assessment, however, neglects important aspects of sustainability and availability of alternative fuels for aviation.

The International Council on Clean Transportation (ICCT) welcomes the opportunity to provide comments on the inception impact assessment for the ReFuelEU Aviation Initiative. The Commission’s suggestion in the roadmap that food and feed-based fuels have limited potential for decarbonization is sound and evidence-based.

The Brazilian Sugarcane Industry Association, UNICA, welcomes the publication of the Inception Impact Assessment on ReFuel EU Aviation and the opportunity to comment on decarbonisation pathways for the aviation sector. The global aviation industry has set a goal of carbon-neutral growth and aims to reduce net aviation carbon emissions by 50% by 2050.

Carbon Engineering supports the adoption of Sustainable Aviation Fuels (SAF) and the objectives being pursued by the ReFuel EU Aviation initiative. The use of SAFs, and in particular e-fuels produced from atmospheric CO2 and renewable electricity, have the capability to achieve emissions savings in excess of 90%, and achieve net zero with permanent negative emissions.

Bauhaus Luftfahrt appreciates the initiative of the European Commission to support sustainable aviation fuel (SAF) development. This is an important contribution to the implementation of the European Green Deal and a necessary step to make Europe the first carbon neutral continent by 2050. To achieve such ambitious goals, it is important to quantify the dimension of the challenge.

Alongside radical fleet renewal, improved air traffic management and technological advances such as hydrogen and electric power, the use of sustainable aviation fuels (SAFs) is generally considered as one of the most effective means to reduce CO2 emissions from aviation in the next decades.

SUEZ welcomes and supports the initiative of the European Commission to boost the supply and demand for sustainable aviation fuels (SAF) which will contribute to achieving EU climate neutrality ambition by 2050. SUEZ as a leader in environmental services in Europe is already engaged in several national initiatives to develop a sustainable value chain for SAF based on different waste feedstocks.

The company PS-Bioenergie GmbH & Co KG is a regional UCO-Collector and trader operating in all EU States. We employ 39 people and in 2019 we collected und trade about +/-[22.000] t of UCO to produce UCO-based biodiesel out of it by medium-sized producers.

Opinion on consultation on ResFuelEU The Swedish Aviation Industry Federation (SFB) is a business association of employers and employers in the transport companies. We have around 90 member companies with about 9400 employees. Our member companies represent airlines, air traffic services, airports, air schools, service and maintenance, and ground handling services.

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ECA is the representative body of European pilot associations, representing 40.000 pilots from across Europe. More info about ECA at www.eurocockpit.be. ECA fully supports a common European policy to incentivise and use Sustainable Aviation Fuels (SAF) for the mid- to long-term.

Avril fully supports the Sustainable aviation fuel initiative. As CO2 emissions by commercial flights rose by 32% from 2013 to 2018 and in line with Green Deal objectives of reducing transport emissions by 90%, sustainable biofuels should be used for the decarbonisation of the aviation sector. Although 2020 will see a sharp decrease, we must make sure we plan for more sustainable air travel after the crisis.

St1 welcomes the EU’s Green Deal and supports the target to achieve climate neutrality in the EU by 2050. Even though the length, depth and the recovery profile of COVID19 caused reduction in the aviation activity level is not known yet, it is fair to assume that it will reach and surpass the pre-corona levels significantly, over the coming decades.

ERA (European Regions Airline Association) is the trade association representing more than 50 airlines and 150 associate members, including manufacturers, airports, suppliers and aviation service providers, across the entire spectrum of the aviation industry. The power of one collective voice, representing multiple businesses, to promote and protect one industry sector is incredibly strong.

Total welcomes the initiative of the European Commission to boost the supply and demand for sustainable aviation fuels (SAF) which will contribute to achieving EU’s climate target. Today, SAF use is very limited due to the huge economic gap between its production costs and the cost of the fossil-based alternative.

We, the undersigned, waste-based biodiesel producers using lipid feedstocks such as used cooking oil (UCO) and animal fats would like to express our deepest concern regarding the European Commission plans to indiscriminately promote sustainable aviation fuels (SAF) as recently outlined in an inception impact assessment (IIA) with title “Sustainable aviation fuels – ReFuelEU Aviation”.

The Advanced Biofuels Coalition (LSB) welcomes the opportunity to provide comments to the inception impact assessment on ReFuelEU Aviation and the promotion of sustainable aviation fuels (SAF) in the EU. LSB recognizes the need to reduce CO2 emissions in all transport modes and therefore supports the intention to promote the use of sustainable aviation fuels.

The KFS Biodiesel GmbH & Co. KG produces biodiesel based on Used Cooking Oils at three production sites in Germany. We employ 55 people within the group and in 2019 we produced about 120.000 tons of UCO-based biodiesel with GHG reductions higher than 90%. We are proud to make an important contribution to reduce the GHG emissions in the European road transport.

NABU supports the introduction of a mandate for specific sustainable advanced fuels in the aviation sector, but only if certain conditions are met for such a mandate to provide both a clear environmental benefit and investor certainty.

CO2 Value Europe (CVE) is the European association dedicated to Carbon Capture and Utilisation (CCU) and is representing over 65 members from different sectors along the CCU value chain. CVE welcomes the European Commission ReFuelEU initiative to curb CO2 emissions in aviation by promoting the production and use of sustainable aviation fuels (SAFs). We appreciate the opportunity to provide feedback on the roadmap.

Aena is one of the leading airport operator in the world by passenger volume and strongly supports the EU’s ambition to become the first climate-neutral continent by 2050. Achieving this ambition requires transformational changes to the broader systems in which we operate.

AeroSpace and Defence Industries Association of Europe (ASD) thanks the European Commission for the possibility to comment on their inception impact assessment on ReFuelEU Aviation - Sustainable Aviation Fuels. ASD fully supports the intent of the initiative to boost the production and uptake of sustainable aviation fuels (SAF) to ensure their large-scale availability at low costs in the medium and long term.

Many thanks for the opportunity to comment on this policy initiative. I write on behalf of Elin Verd S.A., with production facilities in Greece. Our company employs 38 people (and its affiliate UCO collecting company, Prasino Ladi S.A., 23 people more, i.e.

The European Commission's presentation of the European Green Deal has raised the need for new policies within the EU, in order to realize the joint climate goals and ambitions. Within the framework of the upcoming Strategy for Sustainable and Smart Mobility, the Commission has stressed the importance of new regulation enabling a sustainable transition for the aviation industry.

The MWV (Association of the German Petroleum Industry) believes that sustainable liquid fuels are an essential building block to achieve the EU’s climate targets and welcomes this initiative. In addition to the objectives and policy options already mentioned in part B of the inception impact assessment document, we recommend considering the following aspects: ##Leveraging sector-specific advantages## It should be…

Nature & Environment is positive about stimulating sustainable fuels for aviation. On, the introduction of a blending obligation has many hurdles, which requires careful policy development. In addition, we believe that this measure should form part of a broader package of measures, which include a hard target for reducing CO2 emissions from aviation.

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The UBPM GmbH & Co.KG is a raw material Trader for the production of biofuels, based on vegetable residues and waste materials like free fatty acids and used cooking oil (UCO), operating in Germany. We have 15 employees, and in 2019 we traded about 25.000 t of these materials to produce waste-based biofuels out of it by medium-sized producers.

Muenzer Bioindustrie GmbH produces UCO-based biodiesel in Austria. WE employs 250 and in 2019 we produce about 210.000 t of UCO-based biodiesel with GHG reductions higher than 90 %. WE are PROUD to make an important contribution to reducing GHG emissions of EU road transport.

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LOT Polish Airlines welcomes the opportunity to comment on the ReFuel policy initiative. Fulcrum is currently supporting initiative to boost supply and demand of SAF. The European Commission’s role is to improve the current situation and overcome challenges to increasing SAF. The aviation industry affected by COVID-19 will face challenges in upcoming months and years.

The EBB welcomes the opportunity to respond to the EC’s consultation, and to be part of the preparatory process of the ReFuelEU Aviation - Sustainable Aviation Fuels (SAF) initiative, as well as upcoming EC activities designed to gather further stakeholder input. The EBB recognizes the importance and particular difficulties for decarbonisation of the aviation sector.

The “ReFuelEU Aviation” initiative by the EU Commission sends a positive signal for the sustained introduction and roll-out of sustainable aviation fuels (SAF) into the market in the pursuit of reducing CO2-emissions in aviation. In order to reach the ambitious CO2-emission reduction targets for the whole transport sector, the use of carbon neutral fuels (e.g.

Ryanair agrees that Sustainable Aviation Fuels (SAF), due to their potential to reduce lifecycle greenhouse gas emissions, are an opportunity for the aviation sector to decarbonise and fulfil the requirements of the EU Green Deal. We therefore call on the EU and on fuel suppliers to prioritise the development of SAFs that deliver significant lifecycle CO2 savings.

Position of the German Aviation Association (Bundesverband der Deutschen Luftverkehrswirtschaft | BDL) The German Aviation Association very much welcomes the initiative “ReFuelEU Aviation – Sustainable Aviation Fuels” of the European Commission.

Fly Green Alliance (FGA) (www.flygreenalliance.org) are pleased to be able to respond to the consultation on scaling and incentivising SAF production and supply. FGA is a climate action think tank engaged with business development, who mobilises and amplifies positive change in the aviation sector. We believe in the circular economy and work towards the energy transition in the travel sector.

Many thanks for the opportunity to comment on this policy initiative. We write on behalf of Green Fuel Extremadura, with production facilities in Spain. Our company employs 40 people and in 2019 produced more than 78.000 t of waste-based biodiesel with up to +90% GHG reductions, thus enabling “near-term decarbonisation” of the EU road transport sector.

The Swiss Federal Office of Civil Aviation (FOCA) and the Swiss Federal Office of Environment (FOEN) support the initiative “ReFuelEU Aviation- Sustainable Aviation Fuels”. Such a harmonized policy instrument is in our opinion a crucial step to foster sustainable aviation fuels (SAF) in the EU.

EUROCONTROL welcomes the Commission’s initiative on SAF. We strongly support this effort and offer cooperation in developing this strategy. It should become part of a post-COVID-19 recovery strategy. Suggested areas to focus on: - The strategy for aviation to be clarified: if the objective is to reach a full electrification of aviation, the significant set-up and launch costs of SAF could impair its take-up as a…

The Art Fuels Forum (AFF) presents the Commission our common message to the Inception Impact Assessment (IIA). This common message can be found in the attachment. The AFF has been established to discuss and support the variety of opportunities for- and challenges of- the liquid and gaseous fuels sector.

Region Nouvelle-Aquitaine welcomes the Commission’s initiative on sustainable aviation fuels. The sustainability objectives defined in our “NeoTerra strategy for the Green transition” have been integrated to the regional roadmap dedicated to aviation (S3 priority).

ZERO supports the introduction of a mandatory incorporation of advanced fuels into the aviation sector, however this should only be advanced if it brings a clear environmental benefit. It´s important the exclusion of food & feed crops and waste-based fossil fuels, key safeguards to ensure that the promised emission reductions are achievable and that the level of obligation following a serious assessment of the…

We welcome the COM’s initiative to drive the implementation of sustainable aviation fuels (SAF). We strongly support the Commission`s effort and offer cooperation in developing this strategy further. It should become part of a post-Covid 19 recovery strategy and not be postponed. Currently there is a lack of concrete measures which directly tackle CO2 caused by aviation.

Gevo welcomes the ReFuelEU Aviation initiative. Gevo is one of the few companies in the world that has worked towards producing a renewable feedstock called isobutanol for the production of sustainable low-emission fuels like gasoline, kerosene (SAF), diesel or chemicals for building a bio-based economy.

We appreciate this important initiative on sustainable aviation fuels (SAF) and the opportunity to comment. This initiative will help to achieve reductions in GHG emissions from aviation. The use of SAFs present an immediate solution with significant reduction potential.

Boeing appreciates the opportunity to comment on ReFuelEU Aviation Inception Impact Assessment. Boeing has been a part of the European aerospace community for more than 80 years. In Europe, Boeing directly employs more than 5,800 talented people and Boeing’s commercial, defence and services programmes support nearly 190,000 highly skilled jobs in Europe.

Over the last ten years, SkyNRG has been involved in the start and offtake of the Sustainable Aviation Fuel (SAF) industry. Over these years we have gained the experience and knowledge regarding the technical, logistical and financial side of the industry and we are pleased to see that the momentum is finally there to enable the sustainable growth of this sector.

The Ministry of Transport of Baden-Württemberg strongly supports the Commission’s intention to establish a long-term, stable EU policy framework to stimulate investments in SAF production. We need immediate action, if Europe wants to achieve considerable quantities of SAF by 2030 and thus tackle the greenhouse gas emissions from aviation.

The quote states that food and feed crops have a limited potential for decarbonisation, notably due to their indirect impacts on land use changes. Copa and Cogeca do not consider this statement by the Commission to be correct, since the EU has the strictest monitoring rules[2] in the world to ensure that the raw materials in question are sustainable and no change in land use occurs.

Milieudefensie - Friends of the Earth Netherlands welcomes the opportunity to give feedback on the inception impact assessment of the ReFuelEU Aviation initiative. Milieudefensie supports the objective to reduce the environmental footprint of the aviation sector. To bring the sector in line with the Paris Agreement, we believe mandatory greenhouse gas emission reduction targets are indispensable.

The Mittelstandsverband abfallbasierter Kraftstoffe e.V. (MVaK) is a Berlin based association representing 22 medium-sized members along the value chain of waste-based biodiesel production in Germany, Austria and The Netherlands.

Velocys, the sustainable fuels technology company, enables the production of sustainable aviation fuels (SAF) from municipal solid waste and waste woody biomass using the Fischer-Tropsch (FT) route. Our planned Altalto project in the UK is expected to be the first commercial solid-waste-to-fuels plant in Europe.

OHplus GmbH is a regional refiner of glycerol (a by-product from biodiesel production) operating in Germany. We have 19 employees and in 2019 we have produced about 16.000 t of refined glycerol mainly from UCO-based medium-sized biodiesel producers.

The French Association for Hydrogen and Fuel Cells (AFHYPAC) represents 160 stakeholders from the hydrogen sector in France, including major industrial groups, SME-ETI and local authorities involved in the deployment of hydrogen technologies.

Many thanks for the opportunity to comment on this policy initiative. The Norwegian Ministry of Transport welcomes the European Commission’s inception impact assessment (IIA) “ReFuelEU Aviation - Sustainable Aviation Fuels” in the context of the "Green deal" that sets out the Commission’s early thinking about a future legislative instrument to promote Sustainable Aviation Fuels (SAF).

We share the view that one of the greatest levers for achieving the aviation climate target lies in the availability of SAF, particularly in light of the fact that currently purchased aircraft have a service life of 20+ years and can therefore contribute to decarbonization exclusively through SAF.

We support the EU-SAF Blending Mandate with recommendations: a) Should come into force after min. of 3 years to enable implementation of commercial SAF projects and to allow airlines, airports, and other stakeholders time to prepare. b) To be effective, the cost of non-compliance should exceed and possibly be tied to the cost differential between SAF and conventional fuels.

FuelsEurope supports the Green Deal’s ambition for climate neutrality in 2050 and will work with the EU institutions, Member States, and stakeholders, to help create the essential enabling policy framework. The Green Deal is clearly work in progress and will require careful societal consultation and impact assessment.

Dear all, Thank you very much for the opportunity to comment on this policy initiative. I`m writing you on behalf of Envien Group, the biggest Central and Eastern European biofuels holding with production facilities in Slovakia, Czech Republic, Hungary and Croatia.

Dear Sirs, Many thanks for the opportunity to comment on this policy initiative. We write on behalf of the company BDI-BioEnergy International GmbH, with its headquarter in Austria. BDI employs 60 people and as a specialized plant engineering and construction company, we have built and retrofitted waste-based biodiesel pants since the early ‘90s.

Comment of BDLI German Aerospace Industries Association 1/ The global market launch of SAF is essential for the sustainable development of aviation in accordance with internationally agreed CO2 reduction targets. The connection between global air traffic growth and a positively developing global economy is undisputed.

The CEA is a public research organisation dedicated to low-carbon energy, the carbon cycle and climate research. It fully supports the objective of climate neutrality for 2050. This will require a drastic reduction of greenhouse gas emissions in all sectors, including the aviation sector.

Filed in French · English published by the European Commission

Overview T&E supports the introduction of a mandate for specific sustainable advanced fuels in the aviation sector, but only if certain conditions are met for such a mandate to provide both a clear environmental benefit and investor certainty.

Farm Europe’s Green Energy Platform’s reply to the public consultation on ReFuelEU Aviation - Sustainable Aviation Fuels EUROPEAN BIOFUELS MAKE AN ESSENTIAL CONTRIBUTION TO THE GREEN DEAL The transport sector poses one of the greatest challenges to the Green Deal. GHG emissions have risen fast, from 15% of total EU GHG emissions in 1990 to over 25% now. Since 1990, fossil fuel consumption in transport is up 33%.

Dear Madam or Sir We hope this note finds you, your colleagues and families in good health in these peculiar times. Please find in the attached PDF file GAMA's feedback on the ReFuelEU Aviation Initiative Roadmap. Should you require additional information or discuss any of our comments, please feel free to contact me ([email removed]). Stay safe and healthy.

We appreciate this important initiative on sustainable aviation fuels (SAF) and the opportunity to comment. Despite the huge difficulties imposed by COVID-19 we believe there must be progress on issues relating to climate change and aviation. We suggest that a policy option be included to assess the possibility for more flexible EU state aid rules to quickly establish a functioning market for SAF.

GE Aviation fully supports the widespread adoption of Sustainable Aviation Fuels (SAF) and the objectives being pursued by the ReFuel EU Aviation initiative. While technological innovation and advancement will provide foundational carbon emission reduction opportunities for the mid-to-long term, the use of SAFs present a more immediate solution with significant reduction potential (up to 80%).

The intention to promote and significantly expand the use of renewable fuels for air traffic via a European initiative based on a broad package of measures is imperative in order to achieve significant climate gas reductions in aviation in the short and medium term.

ePURE, representing the European producers of renewable ethanol from crops, waste and residues, welcomes the publication of the Inception Impact Assessment (IIA) on the ReFuelEU Aviation initiative and the opportunity to provide feedback.

We, Altfettrecycling Lesch GmbH & Co. KG, are a medium-sized family business with 90 employees and are involved in the collection and recycling of waste feed fat/oil (AVV 20 01 25). Our disposal area is southern Germany, where we currently provide our legally compliant and certified service to over 26 000 restaurants and restaurants. We collect 16 000 tonnes of old feed fat (UCO) per year.

Filed in German · English published by the European Commission

The intention to promote and significantly expand the use of renewable fuels for air traffic (Sustainable Aviation Fuel, SAF) via a European initiative based on a broad package of measures is imperative in order to achieve significant climate gas reductions in air traffic in the short and medium term.

The approach is correct and important to produce sustainable aircraft fuels (produced for example via power-to-liquid PTL). They are a future "must" if sustainability is to be taken seriously. Large aircraft will never be able to fly with batteries, so sustainably produced kerosene is needed. PTL does not require land areas such as biomass.

The approach is right and important to produce sustainable aircraft fuels (e.g. produced via Power-to-Liquid PTL). They are a future ‘must’ when one considers it seriously in terms of sustainability. Large aircraft will never be able to be brought into the air with batteries, so it needs sustainably produced kerosene. PTL does not need land, such as biomass.

Filed in German · English published by the European Commission

We write on behalf of Green Biofuels Ireland Limited, with production facilities in Ireland. Our company employs 37 people and in 2019 produced more than 33,000t of waste-based biodiesel with up to +90% GHG reductions, thus enabling “near-term decarbonisation” of the EU road transport sector.

Many thanks for the opportunity to comment on this policy initiative. EWABA represents 28 corporate members including 21 waste-based biodiesel producing companies with 30 operative production facilities in Europe transforming used cooking oil (UCO) and animal fats into waste-based biodiesel.

The ReFuelEU inception impact assessment is a solid starting point to raise EU ambition on alternative aviation fuel. The document correctly states the nature of the challenge, and that the priority at the moment is to support the early stage roll out of advanced SAF production.

The ReFuelEU inception impact assessment is a solid starting point to raise EU ambition on alternative aviation fuel. The document correctly states the nature of the challenge, and that the priority at the moment is to support the early stage roll out of advanced SAF production.

The ReFuelEU Aviation initiative can only contribute to climate change mitigation in the aviation sector by aligning finances with actions that help move the EU towards the circular economy. I. Policy Coherence - Any potential support to waste-based fuels needs to be fully in line with other environmental and climate policies.

The German Hydrogen and Fuel Cells Association supports the EU initiative to reduce aviation emissions by using renewable fuels. However, the market introduction of electricity-based renewable aviation fuels (electro-fuels including liquid and gaseous hydrogen) requires timely and reliable regulatory frameworks.

Filed in German · English published by the European Commission

With reference to Objectives and Policy options, please find Ethanol Europe feedback as follows: REDUCE ENVIRONMENTAL FOOTPRINT: Oil demand in EU transport is rising despite past Commission legislative efforts. There is no reversal of the trend in sight.