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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.

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.

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.

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.

Recognising the impact and growing importance that ESG Rating Agencies have on the market, particularly when it comes to investment decisions, Ryanair believes further regulation is needed to manage this burgeoning industry. Therefore, Ryanair calls on the Commission to establish clear, enforceable and unambiguous regulation governing ESG Rating Agencies.

T&E welcomes the proposal put forward by the Commission to substantially improve the ESG ratings market in the context of the EU renewed sustainable finance strategy. However, T&E also considers that the significant improvement proposed in the governance and transparency of the sector is not enough to make it a reliable indication of sustainability.

While every other sector’s climate emissions have decreased since 1990, on average, aviation emissions have more than doubled. If the European Green Deal is to radically reduce the EU’s climate impact, it has to reshape European aviation by using all necessary carbon pricing tools at its disposal, including revising the Emission Trading System (ETS).

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.

The Commission is proposing to reform the EU ETS rules for aviation to try and address some unfair privileges the sector was benefiting from and start applying a more effective price on aviation emissions. But it unfortunately continues to implement Corsia, ICAO’s carbon offsetting scheme despite its confirmed lack of economic and environmental integrity.