Aviation Initiative for Renewable Energy in Germany
aireg e.V.
aireg - Aviation Initiative for Renewable Energy in Germany e.V.
ID: 436486644751-11
Lobbying Activity
Response to Sustainable transport investment plan
3 Sept 2025
aireg welcomes the STIP. Projects for production facilities for SAF especially but not only of non-biological origin (eSAF) face major challenges. Despite sustainability targets and ReFuelEU Aviation quota commitments in the EU, the regulatory framework has not yet provided sufficient incentives for investment in eSAF and advanced biofuels from innovative processing methods and previously untapped biomass potential. FIDs for eSAF production need to be reached by the middle of next year at the very latest to guarantee the availability of eSAF at the market in 2030. To overcome those challenges the development of a STIP with (e)SAF as a strategic priority is both timely and essential. The following issues should be addressed: -Supporting climate protection in aviation through (e)SAF financing instruments-The STIP must provide effective momentum for the supply of eSAF. These measures should include a market intermediary that enters into auctioned contracts with eSAF producers and offtakers (SkyPower). Germany has set up the H2Global import instrument. However, the first tender for a SAF tranche failed. The second, improved tender is also progressing slowly. aireg would welcome a corresponding instrument at EU level to create more mass and to use the high creditworthiness of an EU backed market intermediary. The experiences from Germany should also be taken into account. The electricity costs for eSAF production should not be prohibitively high due to taxes and further charges such that the EU becomes an attractive and competitive region of production. SAF Allowances have proven themselves as a valuable instrument to support the market ramp-up of SAF but will most likely be used up by 2028. The option to extend the programme and create specialized eSAF allowances, which is already provided for in the EU ETS Directive, should therefore be pulled and the quantitative cap and time limit on SAF allowances should be lifted. For capital intensive and less technologically developed SAF pathways of biological origin a targeted supply-side policy support is needed. Measures need to be put in place asap to address the high first of a kind plant capital cost premium, increasing the chance of the first projects remaining competitive over time. The commission might consider, a revenue certainty mechanism for early stage industrialized advanced biofuels. To support the market ramp-up of advanced biofuels further, new Annex IX feedstocks certification guidance by the EC needs to be published in a timely manner to support 2030+ targets, including reliable and pragmatic rules. To finance the necessary instruments and ensure a level playing field between European and non-European airlines, introducing a SAF levy based on the final destination could be an effective measure. In addition, revenues generated from the aviation sector under the EU ETS 1 should be allocated to this purpose. -Securing investments through a reliable roadmap for ramp-up, grandfathering rights and funding approaches for first movers- Given the duration of planning, approval and construction, as well as typical investment periods of 20 years for production facilities for SAF, a long-term, resilient regulatory framework is needed to trigger investment in and for Europe, allowing also fair competition without distortive aspects since mandates are an important prerequisite for investors. They must remain as they are. The RED III targets are currently valid until 2030. New plants for the production of (e)SAF require a regulatory framework that extends well beyond 2030. The review of RED III in 2027 should therefore be used to ensure long-term, consistent and harmonised continuation. This must be done in a manner that ensures consistency with ReFuelEU Aviation. To reduce investment risks in a still-developing market for advanced biofuels and eSAF, investors in pilot plants should be granted grandfathering rights for the necessary operating period of 20 years.
Read full responseResponse to Net Zero Industry Act
24 May 2023
Renewable fuels technologies should be an indispensable element of the Net Zero Industry Act Europe has reached a critical turning point in terms of its attractiveness as a business location: In view of the energy crisis and the tough global race for best climate technologies (Inflation Reduction Act (IRA), Belt and Road Initiative), the risk of replacing dependence on fossil fuels with industrial and technological dependence is real: aireg e.V. therefore welcomes the publication of the proposal for a Net-Zero Industry Act (NZIA) as an urgently needed measure to the EU's Green Deal ambitions. In particular, aireg e.V. considers the inclusion of renewable fuels (sustainable aviation fuels) as net-zero technologies as indispensable element of the NZIA. Replacing the present, fossil-based energy carrier by renewable fuels is central for the defossilation of the aviation industry, alongside with further improvements in operational and technological efficiency. In order to keep the availability of sustainable aviation fuel (SAF) in line with the global and European climate targets, the use of all sustainable feedstock and conversion options is essential and should be supported (technology openness). Hence, aireg supports the inclusion of renewable fuels of non-biological origin (RFNBO) and all other (SAF) options as defined in the ReFuelEU Aviation proposal. To ensure equality and consistency with other technologies, those fuels should also be included in the regulations annex listing strategic net-zero technologies. The ramp up of production capacities for SAF is largely constrained by capacities for feedstock provision, approval processes for plant construction and regulatory uncertainties regarding sustainability criteria. This can be enabled by ensuring harmonized sustainability criteria for SAF in Europe. aireg e.V. strongly supports the proposals goal to reduce administrative burdens, streamline approval procedures and to shorten process durations. Support for measures to enhance the development of innovations (net-zero regulatory sandboxes) is also highly welcome. The climate change mitigation targets for the aviation sector can only be reached if a steep ramp-up of SAF production and use materializes within the next decade. This will require the design of incentives for SAF production and use in a way that SAF made in Europe is globally competitive. As long as the framework conditions incur higher cost for SAF being made in Europe, production capacities in these regions will not increase sufficiently. In contrast, a globally competitive SAF production in Europe could even allow for higher SAF usage shares beyond the mandatory levels of the future EU blending mandate under ReFuelEU Aviation. Achieving aviations climate goals will hence require more than just the consideration of SAF as strategic net-zero technology, but rather specific measures to enhance the feedstock provision (biogenic, non-biogenic and combinations of both), the development of production capacities and the use of SAF within Europe, complemented by continued operational and technological efficiency improvements.
Read full response17 Jun 2022
aireg e.V. begrüßt die Veröffentlichung des Entwurfes eines delegierten Rechtsaktes zur Festlegung eines Treibhausgas- (THG-) Emissionsgrenzwertes für Recycled Carbon Fuels (RCF) und einer Methodik zur Bestimmung der THG-Minderungen durch Renewable Fuels of Non-Biological Origin (RFNBO) und RCF. Gleichzeitig sehen wir einige wichtige Punkte wichtig, um einen erfolgreichen Markthochlauf dieser Kraftstoffe zu gewährleisten. Eine ausführliche Erläuterung dieser Punkte befindet sich in der angehängten Datei.
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