by Viola Raffaeli
On 14 July 2021, the European Commission presented a set of proposals for EU legislation aimed at tackling climate change. This package is called “Fit for 55” because of the aim to reduce net greenhouse gas emissions by 55% in 2030 in comparison to the levels of 1990 [1, 2]. Among this set of proposed legislation, there are elements which focus on the promotion of alternative fuels, such as the Renewable Energy Directive (RED II), FuelEU Maritime and the ReFuel EU Aviation proposal . The latter sets targets for sustainable aviation fuel (SAF) and synthetic aviation fuels from 2025 to 2050, and will be the focus of this article .
The Commission presented a policy option which imposes a blending mandate for SAFs on the fuel supplies and jet fuel uplift on airlines. This option was chosen following an extensive impact assessment, the conclusions of which are outlined in detail in the following paragraph. In general, the selected policy proposal safeguards competitiveness in the air transport industry while ensuring that CO2 emissions linked to fuel in the aviation sector may be reduced by circa 60-61% by 2050 compared to the baseline year, i.e. 1990. Furthermore, according to the impact assessment, it is estimated that air pollutant emissions could fall by 9% in the same timeframe. On the whole,
if the proposed legislation were adopted, the environmental costs of aviation could be reduced by around €87-88 billion compared to the baseline.Proposal for a regulation. European Commission 
The impact assessment estimates that SAF production capacity would increase by an additional 25.5-25-6Mt by 2050. The emergence of SAFs on the market would lead to a dramatic decline in the reliance of aviation on fossil jet fuel, leading to a 65% reduction in use of the latter by 2050. It is also worth noting that, according to the impact assessment, the energy security of the EU would improve, since SAF production takes place primarily in the EU. As a consequence, the EU would place greater reliance on its own fuel, thereby decreasing the EU’s dependence on fossil fuels imported from third countries. Moreover, the adoption of this policy would speed up the development of SAF technologies compared to a policy-free scenario, thus helping to reduce the gap between the price of fossil jet fuel and SAFs. Furthermore, through the introduction of this policy, an estimated 202,100 additional jobs could be created in the EU . Lastly, the impact assessment notes that a shrinkage of air pollution would have general positive effects. It estimates that the external costs of air pollution, i.e. the uncompensated social and environmental effects, could fall by €1.5 billion between 2021 and 2050 .
The proposed policy includes many requirements for aircraft operators, fuel suppliers and more, after establishing which elements fall within the scope of the regulation. In particular, Article 3 defines the term SAF as covering those drop-in aviation fuels which are either synthetic aviation fuels, advanced biofuels or biofuels produced from feedstock, which comply with the sustainability and greenhouse gas emissions criteria established in RED II. Article 6 establishes that Union airports would be required to provide the infrastructure necessary to ensure that aircraft operators have access to aviation fuels which contain shares of SAFs. According to Article 9, by 31 March of each year, aviation fuel suppliers are required to report in the European Union database the volume of aviation fuel and volume of sustainable fuel supplied at each Union airport plus the lifecycle emissions and feedstocks of the SAFs supplied.
Furthermore, Article 11 establishes the rules regarding enforcement. Article 13, instead, introduces a period of transition of 5 years during which aviation fuel suppliers are permitted to supply the minimum amount of SAF as an average across all the aviation fuel which they provide to Union airports. According to Article 15, the draft regulation will enter into force from 1st January 2023. Annex 1 of the draft regulation includes a timetable which sets minimum reduction obligations for all fuel suppliers. The minimum share of SAFs supplied should be 2% in 2025, 5% in 2030, 20% in 2035 and 63% in 2050. Sub-targets for synthetic aviation fuels are 0.7% in 2030, increasing to 28% in 2050 .
It is worth noting that the proposed legislation took the form of a regulation. The importance of this lies in the power which the Union can yield following regulations, as opposed to directives. In particular, regulations adopted by the EU do not require transposition into national legislation, and are directly and immediately binding. For this reason, following the adoption of this proposal, failure to comply would lead to the imposition of fines, applied by the Member States themselves . These fines, according to the proposal, shall be collected in the InvestEU Green Transition Investment Facility .
All in all, it is clear that, if this policy proposal were to be adopted, significant changes could be made. This is because it would not only impact the aviation fuel industry, but also the European population as a whole. In particular, as mentioned above, the adoption of this legislation could speed up the development of SAPs, the use of which decreases air pollution.
References: ReFuel Aviation – Sustainable Aviation Fuels, European Parliament https://www.europarl.europa.eu/legislative-train/theme-a-european-green-deal/file-refueleu-aviation, last accessed 3 November 2021.
 European Green Deal: Commission proposes transformation of EU economy and society to meet climate ambitions, European Commission, https://ec.europa.eu/commission/presscorner/detail/en/IP_21_3541, last accessed 21 November 2021.
 Fit for 55 – The EU’s plan for a green transition, European Council 2021, https://www.consilium.europa.eu/en/policies/green-deal/eu-plan-for-a-green-transition/, last accessed 22 November 2021.
 Searle, Stephanie, Alternative transport fuels elements of the European Union’s “Fit for 55” package, https://theicct.org/publications/alternative-fuels-fit-for-55-eu-sept21, last accessed 7 November.
 Proposal for a regulation. European Commission, https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12303-Sustainable-aviation-fuels-ReFuelEU-Aviation_en, last accessed 20 November 2021.