SAF STATUS IN THE EU
What about SAF’s penetration in the European Union? The European Parliament has taken similar steps to boost SAF production and availability. The EU’s 2030 goal is called ReFuelEU Aviation, which is a SAF blending mandate as part of the EU’s broader “Fit for 55” goal that is focused on reducing EU emissions by 55 percent by 2030. In July 2022, the EU parliament outlined draft rules that would require EU airports to maintain a mandatory minimum percentage of SAF as part of a blending mandate. The required percentages of SAF, as a share of available fuels, would increase in stages—2 percent SAF by 2025, 5 percent by 2030, 32 percent by 2040, and 63 percent by 2050. Moreover, operators would be required to use the fuel at available airports. Economic incentives include the Emissions Trading System , the Carbon Offsetting and Reduction Scheme for International Aviation, and various tax credits. The ETS aims to reduce emissions by setting limits on emissions and allowing airlines and GA operators to buy and sell emissions allowances. Altogether, it is evident that the runway ahead is long in the EU, as in the U.S. According to European Union Aviation Safety Agency in its 2022 European Aviation Environmental Report, current SAF supply remains low at less than 0.05 percent of total EU aviation fuel use. What’s more, on both sides of the ocean, as the actual supply of SAF comes online, stakeholders will need to solve the allocation problem to ensure that the available fuel is equitably distributed between business aviation and airlines. This is currently the sticking point in the system, according to GAMA’s Kyle Martin, vice president of European Affairs. “Regulators on different sides of the Atlantic have taken a fairly different approach,” Martin points out. “The U.S. approach is a carrot, and the European approach is a stick.” While the Inflation Reduction Act enacted in the U.S. incentivizes the production and use of SAF, Martin explains, when compared to the situation in the EU— including the post-Brexit U.K.—the requirements are more onerous, especially as it relates to the business aviation community there. “From a purely business aviation perspective, we have
some concerns of the way the EU is doing the blending mandate because they are targeting large operators and large commercial airports,” Martin points out. Business aviation operators in the EU will also have to navigate the challenge of getting SAF at remote GA airports in that region that don’t serve as hubs for commercial traffic. The European Business Aviation Association, in a February 2023 update to members, said it was working with EU policymakers to ensure that they were adequately considering business aviation operators in the rule-making process so that results wouldn’t be burdensome to business aviation operators later. Part of those concerns, the EBAA indicated, was that lawmakers needed to widen the definitions of ‘airports’ and ‘operators’ that would benefit from the EU’s SAF- boosting initiative. Otherwise, business operators might be excluded from the benefits and would pay a steep price to participate. Practically, with the limited SAF infrastructure in that region, operators would need to be crafty with their flight operations technique to complete trips. “The blending mandate will apply to large airports,” Martin points out, “like Charles de Gaulle Airport in France or Frankfurt Airport in Germany, but it will not include smaller airports.” That’s because the current proposal is based on a threshold that accounts for the number of passengers or cargo that pass through that airport each year, and with each the bar is high. “It’s 1 million passengers per year or 100,000 tons of cargo per year, which superficially sounds quite smart,” Martin says, “but the problem is for business aviation, it’s not. Many business aviation operations are out of smaller airfields. The mandate would leave business aviation out in the cold.” Moreover, he says the complicated regulations are only the first problem. “Problem number two is there’s no current foreseen recognition or appreciation of a book and claims system,” he says. In advocating for some wiggle room for business operators to the proposed regulations, the EBAA has proposed that the EU allow operators to purchase a volume of SAF from anywhere worldwide and acknowledge that that fuel will be used toward sustainable
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