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T&E welcomes the Commission’s initiative to align the ETS directive with the EU’s 2030 target of at least -55% emissions reduction and to ensure that all sectors contribute, in line with the EU’s international commitment to economy-wide action under the Paris Agreement. However, T&E regrets that the Commission is considering to switch gear on tackling emissions in the road sector.

LanzaTech commends the European Commission’s ambition in its revision of the Emissions Trading Scheme (ETS). We welcome the opportunity to respond to the EU Commission’s proposal, and we look forward to working alongside the co-legislators going forward. The following outlines our feedback and recommendations on some of the specific policy mechanisms put forth in the EU Commission’s proposal.

This response is about the inclusion of 1)shipping and 2)road transport into the ETS: 1.SHIPPING Shipping accounts for around 3.5% of the EU’s total GHG emissions, but has so far avoided regulation on its climate impact. Integrating shipping into the ETS is a positive step in the right direction and will put shipping on the path towards climate neutrality in line with the Paris Agreement.

While every other sector’s climate emissions have decreased since 1990, on average, transport emissions have increased by almost 30% since 1990 (aviation emissions, for one, have more than doubled). Each mode of transport faces varying challenges to reverse this trend and reduce them in the coming decade.

LanzaTech commends the European Commission’s ambition in its revision of the Energy Taxation Directive (ETD). We welcome the opportunity to respond to the EU Commission’s proposal, and we look forward to working alongside the co-legislators going forward.

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.

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.

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.

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.

We welcome the EC initiative to develop an effective EU regulation to drive the uptake of sustainable alternative fuels in EU shipping. We agree with the EC assessment that creating a predictable demand in the shipping industry is essential for the investment and mass scale deployment of sustainable alternative fuels.

LanzaTech commends the European Commission for its proposal to boost the uptake of sustainable fuels in shipping and ports to reduce emissions from the sector. We welcome the opportunity to respond to the EU Commission's proposal and working alongside the co-legislators in the future.