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Rolls-Royce plc

Rolls-Royce is a global engineering company producing power systems for aviation, marine, and energy.

Lobbying Activity

Response to European Critical Raw Materials Act

25 Nov 2022

We support the aims of the proposed EU Critical Raw Materials act to ensure the secure and sustainable future supply of CRMs. We recognise the importance of critical materials to the transition to NetZero and our future prosperity and security. In particular CRMs are required for strategically important sectors such as aerospace and defence. Such sectors should be considered a priority in the evolution of new sources of supply. We support the proposed focus on: 1. Robust analysis and identification of those materials most critical to our economic and strategic requirements, to target investment and mitigation actions. 2. Improved monitoring, risk management and governance of CRMs to provide consistent and accurate intelligence. 3. Strengthening the EUs critical raw materials value chain to develop domestic resources, supply chain and recycling capability. 4. Standards and certification for the sustainable and ethical production of raw materials. In particular we would encourage action on: Measures to accelerate the growth of domestic supply chains in both primary production (where resources exist) and down-stream processing. Encouragement for the growth of a resource efficient circular economy, enabling and incentivising secondary recycled sources to reduce pressures on primary supply and the energy and sustainability impacts of raw materials extraction and processing. Research and technology targeted to optimise the use of CRMs throughout the value chain, including: o The efficient and sustainable extraction and processing of CRMs, minimising waste, and environmental impact. o Optimising the application of CRMs and minimising consumption through efficient materials, manufacturing, and product design. In this context we would note that although substitution with alternative materials may be one route to reduction of CRM demand, this should not be the sole or even major focus. CRMs are employed for their unique properties and are often difficult or impossible to replace entirely without a major detriment in product performance. Instead, the focus should be on materials development to minimise the concentration of CRMs required, manufacturing developments to minimise loss or waste, and product development to ensure CRMs are deployed for maximum benefit. o Design practice to maximise product life and enable repair, reuse and recycling. o Development of recovery and recycling processes to return resources to the value chain at the high possible point. Collaboration with international partners to develop secure, diverse, sustainable, and ethical supply chains along with the development of more transparent and responsible international markets through improved data, traceability, and standards. We note that strategic stockpiling should be considered only after a thorough analysis of requirements, access arrangements and likely undesired impacts, particularly the potential for increased pressure on already strained supply chains.
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Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

25 Oct 2022 · Short bilateral with CEO before Hydrogen Week event - discuss the Electrolyser Partnership, Renewable Fuels of Non- Biological Origins (RFNBOs), and the regulatory framework for hydrogen.

Response to Interim evaluation of Horizon Europe

27 Jul 2022

Rolls-Royce pioneers the power that matters to connect, power, and protect society. Our family of turbofan aircraft engines have continued to push the boundaries of what is possible. Besides, Rolls-Royce has longstanding experience in providing power and propulsion for marine vessels, including ferries, tugboats and service vessels. Research and Innovation are key for us as we want to offer innovative solutions that play a fundamental role in enabling the transition to a low carbon global economy. We aim at delivering the next generation aviation and maritime solutions, such as engines certified for sustainable fuels, fuel cell systems, and fully electric and hybrid-electric propulsion systems. Thus, we have been coordinating research with leading academic institutions and industry partners for over 25 years. We welcome Horizon Europe as an essential funding programme for R&I. The programme facilitates collaboration with key partners and enables us to undertake key R&I projects. We would like to underline that the association of third countries to Horizon Europe and especially of the EU’s longstanding partner UK, is an essential driver of pioneering research. Without good EU-UK collaboration and uncertainty about the association of the UK, the programme’s effectiveness and hence R&I delivery are reduced. Within Horizon Europe, we particularly welcome the Clean Aviation Partnership, which is an excellent vehicle to decarbonize aviation, as it brings together the innovative power and capabilities of European aeronautics and entities from associated countries. Its predecessor Clean Sky 2 enabled ground-breaking projects like the E-Fan X demonstrator and UltraFan. Rolls-Royce Deutschland is a founding member of Clean Aviation and Rolls-Royce participated in its first call for proposals. We would like to take the opportunity to give feedback on that first call procedure. Rolls-Royce welcomes the fact that the call text was very close to the roadmaps that have been established by the stakeholders upfront, as this ensured predictability and optimal preparation for participants. The open call process that has been newly integrated for Clean Aviation, with a fixed budget and maximum number of projects per call topics triggered competition between possible applicants, such as engine manufacturers. Therefore, early consortia building supported by committees like EIMG (Engine Industry Management Group) did not happen. Instead, key stakeholders seemed to be internally defining the basic elements of their proposals with less external connections to supply chain and academic partners than in Clean Sky 2 calls. This increased uncertainty for stakeholders, which is particularly difficult for SMEs and universities. This could have been prevented with a different call design like in Clean Sky 2 with a separate call for core partners. The disadvantage of that would have been constrained freedom for industry. We also observed greater caution to collaborate with competitors due to uncertainties about the operational phase of the projects, such as on IP protection or results sharing. This reluctance can lead to a decrease in innovation, as collaboration in consortia is a key driver for innovation in Clean Aviation. More confidence and knowledge about the operational phase could have mitigated this. The separate Work Packages under Clean Sky 2 contributed to a clearer process in that regard. In addition, late consortia building resulted in a rush of proposal writing. That is a risk for the high quality of the proposals. We conclude that optimizing call procedures for future Clean Aviation calls is possible, in particular by decreasing uncertainty about the process. That could spur collaboration and hence innovation and would make the calls even more suitable for the sector and for all participants, including non-key stakeholders that are essential to carry out projects successfully and that bring important capabilities to the table.
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Response to Count your transport emissions: CountEmissions EU

16 Dec 2021

Rolls-Royce pioneers the power that matters to connect, power, and protect society. Our family of turbofan aircraft engines have set new performance benchmarks for civil aviation. On land and sea, we are the leading supplier of power for safety-critical installations and integrated drives for marine, heavy off-road, rail applications, emergency power and decentralized energy. We are exploring sustainable solutions such as engines certified for sustainable fuels, fuel cell systems, and fully electric and hybrid-electric propulsion systems. Our goals are to make all Trent engines 100% and our main non-aviation engine series compatible with sustainable fuels by 2023, achieve net zero greenhouse gas emissions in our operations and ensure our new products will be compatible with net zero operation by 2030, and be entirely carbon neutral by 2050. General remarks Rolls Royce welcomes the Commission’s initiative to provide a common framework for calculating greenhouse gas (GHG) emissions of transport operations in the freight and passenger transport sectors. Reflect the internationality of transport As transport is an inherently international sector with important cross-border activities, Rolls-Royce strongly appreciates the European approach to a GHG calculation framework. We invite the Commission to push for more work in this direction on the international level and to encourage international cooperation on a common framework across the different transport modes. Objective metric to fight misconceptions about transport modes Aviation and maritime transport are often depicted as the most emitting GHG sectors. Therefore, we would appreciate a common and objective metric to show the actual emissions of these sectors and to fight eventual misconceptions. Compare what is comparable It needs to be taken into account that the GHG framework cannot necessarily compare all modes of transport for all routes adequately. A comparison with aviation and maritime for example, is only appropriate, if there is another means of transport, such as rail or road, available for the same route. Where this is the case, infrastructure that is necessary for the same route for different means of transport needs to be considered, as the construction of roads etc. also creates GHG emissions. Rolls-Royce favours a metric that takes into account all emissions over the life cycle of the different transport modes rather than only the emissions from the use of the mode. Base the framework on existing calculators In the preparation of CountEmissionsEU, the Commission should map the already existing GHG emission calculators for the different transport modes, to make sure that the framework is based as much as possible on established instruments. The Commission should ensure coherence with other existing GHG emission calculation methodologies and legislations that include emissions reporting. Duplications and too high an administrative burden should be avoided. Take into account the complexity of emissions Furthermore, the EU framework needs to take account of the differences between the different GHG emissions and, especially for non-CO2 emissions, of their high complexity. More research to clarify these elements is needed. Therefore, for the framework, we would recommend concentrating on CO2 emissions in the first instance. Scope of the framework The GHG emission framework needs to have a broad enough scope to take account of the emissions of a maximum of the transport sector. For ships, for example many regulations, including the MRV regulation, so far only cover ships above a gross tonnage of 5000. This excludes many kinds of ships that are generally smaller, such as tugboats or yachts. Nonetheless, Rolls-Royce believes that also smaller ships need to be decarbonized in order to achieve our climate goals by 2050. For this, it is imperative to have an oversight over their emissions, as well.
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Meeting with Didier Reynders (Commissioner) and

24 Nov 2021 · Sustainable Corporate Governance

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis), Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis)

24 Nov 2021 · Sustainable finance taxonomy

Meeting with Timo Pesonen (Director-General Defence Industry and Space)

24 Nov 2021 · Introductory meeting to exchange views on the EU defence market as regards engines and power plants in both naval and land systems sectors.

Meeting with Henrik Hololei (Director-General Mobility and Transport)

23 Nov 2021 · FuelEU Maritime

Meeting with Pierre-Arnaud Proux (Cabinet of Executive Vice-President Margrethe Vestager)

23 Nov 2021 · Decarbonisation and digitalisation in marine industry

Meeting with Virginijus Sinkevičius (Commissioner) and

22 Nov 2021 · To discuss the position of Rolls Royce on the EC proposals in the context of green shipping topics, in particular Fit-for-55 proposals, FuelEU Maritime and Energy Taxation Directive.

Response to ReFuelEU Aviation - Sustainable Aviation Fuels

17 Nov 2021

Rolls-Royce: Rolls-Royce pioneers the power that matters to connect, power and protect society. For nearly three decades, our family of turbofan aircraft engines have continued to push the boundaries of what is possible, as each new model sets new performance benchmarks for civil aviation. Sustainability is a core concern for us in our daily business, as climate change is the biggest threat to humanity. It is our mission to join the fight against it. That is why we have joined the UN Race to Zero, pledging to play a leading role in enabling the sectors in which we operate reach net zero by 2050. Therefore, we are exploring sustainable aviation solutions such as engines certified for sustainable aviation fuels (SAFs), and fully electric and hybrid-electric aviation. Our goals, embedded in our own decarbonization strategy, are to make all Trent engines 100% compatible with sustainable fuels by 2023, achieve net zero greenhouse gas emissions in our operations and ensure our new products will be compatible with net zero operation by 2030, and be entirely carbon neutral by 2050. General remarks: Rolls-Royce welcomes the ReFuelEU Aviation initiative, as it supports the acceleration of availability and affordability of SAFs. The proposal is an important first step towards the decarbonization of aviation, which can be further enhanced, as SAFs have the potential to significantly reduce net aviation CO2 and non-CO2 emissions. SAF incorporation targets: Rolls-Royce welcomes the introduction of SAF-mandates for aviation. To achieve the sector breakthrough, the aviation sector needs, Rolls-Royce supports higher ambitions for the proposed mandates. We recommend that the target for 2030 be set at least to 10 % SAF incorporation instead of the proposed 5%. In addition, with an expected increasing deployment of Power-to-Liquid (PtL) and eFuels from 2035 onwards, the proposed 2050 target of 63% SAF incorporation is too unambitious. To recognize the potential opportunities presented by PtL and eFuels, we should seek higher ambition post-2040. Rolls-Royce also supports the introductions of sub-mandates on ‘e-fuels’ to take full advantage of the emerging Power-to-Liquid technologies, and the longer-term synergies with the ramp-up of green hydrogen. We again recommend that a higher target of 2,5% be set for 2030, to provide the right signals to the market. A temporary SAF accounting framework to support deployment of SAF in the early years: Requiring all airports to support SAF may be counter-productive in the short or medium term. Setting a minimum airport size in terms of passenger numbers or tons of cargo, as proposed in ReFuelEU Aviation through the definition of “Union Airports” in Article 3, is one option although use of a temporary SAF accounting framework could help resolve this issue and should thus be considered. European Sustainable Fuels Alliance: The Fit for 55 Communication makes a reference to the upcoming establishment of a Renewable and Low-Carbon Fuels Value Chain Alliance (RLCF). Rolls-Royce strongly encourages the creation of a European Industrial Alliance on SAF. As SAF deployment is a global challenge, the Alliance should remain open and inclusive. Incentives and supporting programmes (i.e. “Accompanying measures”): Whilst the proposal for a regulation is an important first step, it will not be sufficient to secure the economic sustainability of SAF. In this regard, the “Accompanying measures” under consideration should be among the first topics to be discussed in the context of the upcoming RLCF Alliance with the aim of accelerating their implementation. Links with ICAO: Rolls-Royce welcomes references in the Commission proposal to ICAO activities on SAF. The Commission's intention to maintain strong links with ICAO and intensify European efforts to raise ambition on SAF use is a very positive signal.
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Response to FuelEU Maritime

8 Nov 2021

Rolls-Royce Power Systems has longstanding experience in providing power and propulsion for commercial marine vessels, including ferries, tugboats, offshore wind farm crew boats, and service and supply vessels. That is why we are exploring sustainable shipping solutions such as engines certified for sustainable fuels, fuel cell systems, electric and hybrid propulsion systems, and methanol engines. Therefore, Rolls-Royce Power Systems has initiated the Net-Zero Program. Our goals are to make our main engine series ready for sustainable fuels by 2023, provide our customers with CO2-free energy supply with fuel cells by 2025, reduce the CO2 emissions of our new products and solutions sold by 35% compared to 2019 by 2030 and be entirely carbon neutral by 2050. General comments • Rolls-Royce Power Systems welcomes the Fuel EU Maritime proposal from the European Commission as a tool to overcome the barriers for the uptake of low- and zero carbon fuels in shipping. Hydrogen-derived fuels (e.g. e-diesel, e-methane or e-ammonia) or sustainable bio-based fuels are a key to reduce GHG emissions of the shipping sector. We are of the opinion, that the shipping sector has enormous potential to scale up and eventually open the market for zero-emission fuels, also for other sectors and industries. Hence, shipping is a suitable enabler for the RFNBO ramp-up. • Availability of low- and zero carbon fuels is a prerequisite for achieving the intended effect of the proposal. Well-to-wake approach • A well-to-wake approach is crucial for low- and zero carbon fuels to provide a clear legal framework and to ensure global net-reduction of GHG. Verification of Well-to-Tank emissions should be performed according to acknowledged international standards, be transparent regarding assumptions and sources and be based on verified documentation of feedstock and pathways. Rolls-Royce Power Systems therefore fully supports the well-to-wake approach proposed in FuelEU Maritime. To increase private investment the well-to-wake approach also needs to be reflected in the EU Taxonomy on Sustainable Finance. Pooling mechanism • Rolls-Royce Power Systems supports the possibility for pooling of compliance for fleets as one potential measure to incentivice first movers to drive the uptake of engines and propulsion systems capable of operating on low- and zero carbon fuels According our assessment, the pooling mechanism would make (net)zero fueled ships more competitive in a short-term perspective. Energy from electricity • Initiatives to incentivize the uptake of low/zero carbon fuels should be in a goal-based and technology neutral way. Setting the Well-To-Tank GHG intensity of electricity to zero cannot be considered as technology neutral and could lead to an increase in GHG intensity if the electricity used has a higher well-to-wake GHG intensity compared to the fuel used on board. Tank-to-Wake emission factors • Rolls-Royce Power Systems supports the option to use actual values for tank-to-wake emission factors for all fuels, including fossil fuels. Increase European scope (Article 4) • With a view to the goal of climate neutrality within the EU, the reduction path described in Article 4 is not sufficient. The technology needed to produce RFNBOs has now reached a level of maturity that enables industrial scaling. We therefore call for the introduction of a second, reduction path that regulates intra-EU shipping separately. • 2027: 10% GHG reduction • 2030: 30% GHG reduction • 2035: 50% GHG reduction • 2040: 75% GHG reduction • 2045: 100% GHG reduction The more and the earlier these fuels are available for shipping, the sooner a more ambitious reduction path can be adopted. To solve the “chicken-and-egg problem”, we propose a target of 4 GW for producing RFNBOs for shipping by 2030 in the Renewable and Low Carbon Fuels Value Chain Alliance.
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Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean), Rachel Smit (Cabinet of Commissioner Adina Vălean)

27 Oct 2021 · Decarbonisation and activities within Clean Sky/Clean Aviation.

Response to ReFuelEU Aviation - Sustainable Aviation Fuels

21 Apr 2020

Use of sustainable aviation fuels is the quickest way to reduce the aviation industry’s carbon footprint today. Rapid scale-up in production of SAF, alongside other aviation developments, will be required if aviation is to meet its 2050 decarbonisation goals; at Rolls-Royce we believe SAF will be the key component of ensuring aviation is compatible with a carbon neutral EU. The key requirement is to create confidence in a future European market for large volumes of SAF, reaching tens of millions of tons by 2050. This confidence will enable the industry to grow and eventually replace fossil fuels in aviation. Several measures could be introduced to accelerate the market for SAF production in the EU. Our primary recommendation is the introduction of mandated blends. Mandating Blends Rolls-Royce is confident the greatest impact can be gained from a mandated minimum percentage of SAF for flights within Europe. The investment in SAF production will need to be €100bns, whichever the technological pathway. Yet any SAF will be significantly more expensive than Jet A, regardless of production method. Potential SAF fuel producers need to know that they will be able to sell the more expensive product. The greatest confidence for producers can be gained from a mandated percentage of SAF in all within Europe increasing from 2030 to 2050. This is the highest priority and most effective action for the EU. As a variation in implementation, the EU might encourage the SAF’s with highest levels of carbon dioxide (CO2) benefit by applying blend mandates linked to overall GHG-intensity rather than a simple percentage blend. A consistent approach across European nations should be applied to avoid the possibility that an airport gains competitive advantage by providing a lower SAF ration and hence cheaper blend. Note that jet engines are already able to use much higher blends than the 50% maximum allowed by ASTM today, which will be further confirmed by test over the next few years. Investment for SAF production plants The technology for SAF production, whether from feedstock or electrolysis, is proven in pilot plants, but immature at scale. Early incentives for production plants in Europe would be a key accelerator, especially for new entrants without easy access to capital. Feedstock Prioritisation The third action of value is to prioritise municipal waste for SAF production. The technology for this exists today and the economics are favourable. However, currently sustainable diesel is the priority use, as a result of government subsidies and taxes. Prioritising these feedstocks for SAF production will accelerate decarbonisation of aviation, while encouraging alternative options of the decarbonisation of other transport modes, such as automotive, through electrification and the use of hydrogen where these technologies will be available sooner. Contact: Antoine FERAL, + 32 477 777 787 - antoine.feral@rolls-royce.com
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Meeting with Ivo Schmidt (Cabinet of Vice-President Maroš Šefčovič)

14 May 2019 · Decarbonisation, Energy and Micro-grids

Meeting with Robert Schröder (Cabinet of Commissioner Carlos Moedas)

14 May 2019 · R&I ecosystems

Meeting with Miguel Ceballos Baron (Cabinet of Vice-President Cecilia Malmström)

4 Mar 2019 · EU-US relations, WTO reform

Meeting with Cristina Rueda Catry (Cabinet of Commissioner Phil Hogan)

22 Feb 2019 · Preparation of EU-Japan Business Round table event (15/5/2019)

Meeting with Christine Mai (Cabinet of Commissioner Tibor Navracsics), Jean-Philippe Gammel (Cabinet of Commissioner Tibor Navracsics), Rodrigo Ballester (Cabinet of Commissioner Tibor Navracsics)

30 Jan 2019 · Education/STEM and Youth employment

Meeting with Christine Mai (Cabinet of Commissioner Tibor Navracsics), Jean-Philippe Gammel (Cabinet of Commissioner Tibor Navracsics), Rodrigo Ballester (Cabinet of Commissioner Tibor Navracsics)

13 Dec 2018 · Education/STEM and Youth employment

Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc), Matej Zakonjsek (Cabinet of Commissioner Violeta Bulc)

21 Nov 2018 · EU transport policies

Meeting with Andrus Ansip (Vice-President) and

21 Nov 2018 · Artificial intelligence, cybersecurity

Meeting with Risto Artjoki (Cabinet of Vice-President Jyrki Katainen)

21 Nov 2018 · Single Market

Meeting with Violeta Bulc (Commissioner) and

5 Oct 2016 · Meeting with president of Rolls Royce, Colin Smith

Meeting with Jos Delbeke (Director-General Climate Action)

4 Oct 2016 · Transport

Meeting with Pierre Schellekens (Cabinet of Vice-President Miguel Arias Cañete), Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

16 Jun 2015 · Decarbonization

Meeting with Maria Da Graca Carvalho (Cabinet of Commissioner Carlos Moedas)

16 Jun 2015 · Meeting with Mr Lochbihler and Mr Smith

Meeting with Daniel Calleja Crespo (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

12 May 2015 · Investment (Juncker Plan) and business environment in the EU as regards the Aerospace Industry

Meeting with Joao Aguiar Machado (Director-General Mobility and Transport)

16 Apr 2015 · Upcoming review of the EASA Regulation, Rolls-Royce aviation business

Meeting with Edward Bannerman (Cabinet of Vice-President Jyrki Katainen), Juho Romakkaniemi (Cabinet of Vice-President Jyrki Katainen)

16 Apr 2015 · Business opportunities in Europe

Meeting with Jonathan Hill (Commissioner)

16 Apr 2015 · Financial Services Policy

Meeting with Juho Romakkaniemi (Cabinet of Vice-President Jyrki Katainen)

16 Apr 2015 · Investment Plan

Meeting with Edward Bannerman (Cabinet of Vice-President Jyrki Katainen)

8 Dec 2014 · Industrial competitiveness