6 April 2022: On 30 March, the European Commission published the Platform on Sustainable Finance’s report with recommendations on technical screening criteria for the four remaining environmental objectives of the EU taxonomy.

You will find the relevant documents in the following links:

• Platform on Sustainable Finance’s report [1]
• Annex [2] to the report

The relevant chapters to the aviation sector are:

• 7.2 Manufacturing of aircraft
• 7.3 Leasing of aircraft
• 7.4 Passenger and freight air transport
• 7.5 Air transportation ground handling operations
• 6.1-6.7 Emergency services

In particular, under chapter 7.4 it is stated that aviation can be included in the taxonomy as a transition activity pursuant to Art. 10 (2) to the extent that “it supports the transition to a climate-neutral economy consistent with a pathway to limit the temperature increase to 1,5°C above preindustrial level”. The objective is to contribute to mitigating GHG emissions from the sector before transformative technologies become market ready, ensuring a minimum aggregated emission reduction of 20% in the first decade.

Therefore, screening criteria for aviation as a transition activity need to achieve three things:

1. incentivise the replacement of old, less efficient aircraft with new, more efficient ones without contributing to fleet expansion.
2. accelerate the development and market introduction of increasingly efficient aircraft without compromising the development of zero exhaust CO2 emission breakthrough technologies.
3. incentivise the replacement of fossil jet fuel with sustainable aviation fuels, including the technical readiness of the aircraft fleet to operate with high blending ratios.

As a result, the following screening criteria were agreed:

1. A rule to ensure taxonomy criteria does not contribute to increasing aircraft fleets and therefore emissions.
2. Aircraft efficiency requirements based on the ICAO new type (NT) CO2 standard to define which new aircraft can be considered as ‘best-in-class’ for the purpose of the taxonomy.
3. The requirement for aircraft to be certified to run on 100% sustainable aviation fuel certified from the beginning of 2028 is aimed at to giving the assets included in the transition activity a long-term decarbonisation perspective, as most aircraft have a lifetime going above 20 years.
4. On the operator side, a progressive increase in the use of SAF was set as a pathway to stimulate further CO2 emissions reductions.
5. The taxonomy compliant revenue of air passenger transport should take into account efforts to improve the energy performance of fleets but also ensure that fleet expansion and overall growth in CO2 emissions that has occurred before the entry into force of the criteria is not considered as taxonomy compliant.

Due to the uncertainty involved, it was agreed not to define screening criteria for aviation as a transition activity for the time after 2032.

You can find more information on the above criteria in the annex [3] from page 522 to 529.

Next steps

The Commission will now analyse this report and start its work on the preparation of the Delegated Act, defining technical screening criteria for activities contributing to the climate and four remaining environmental objectives.

7 September 2021: Following the launch of the public consultation, which closes on 24/09, DG MOVE has hosted a call for association representatives to go over the DRAFT Taxonomy proposal [4]. Here are some of the main points of the call:

• The screening criteria have to be science based, based on existing standards, dynamic (updated every 3 years), easy to use and operational.
• They will have to substantially contribute to at least one of the six environmental objectives AND do no significant harm (DNSH).
• Timeline: the EC has published a DRAFT proposal for consultation (i.e. it is not an official EU document). The technical expert group will take the feedback received and publish a report with recommendations for technical screening criteria in November ’21, which will then be adopted by mid ’22 and will apply as of ’23.
• The draft report consists of
  • Description of the activity - NACE code
  • Technical Screening Criteria
  • DSNH (do not cause significant harm)
  • Rationale
• The relevant activities to aviation are:
  • Aviation specific:
    • 8.9 Manufacturing of aircraft
    • 8.10 Passenger air transport
    • 8.11 Air transportation ground handling operations
  • Other:
    • 7.6  Emergency services – Firefighting
    • 2.16  Manufacture of other transport equipment
• In the powerpoint and report you will find more details on these activities

Attached is the presentation the EC used (do not distribute outside your organisation) where you will find more detailed information. In light of the call and deadline for feedback, ERA would like to organise a call with members in the next two weeks to go over the relevant proposals to aviation and discuss our proposal for changes where necessary you deem necessary.

Please let martina.dipalma@eraa.org [5] know ASAP if you are interested to take part in the call.

Deadline for feedback is 24 September. Feedback should consist of concrete proposals and rationale behind it.

12 March 2021: The European Commission contracted consultancy Steer to undertake a study on Sustainable Finance Taxonomy for the aviation [6] sector. The results of the study were published on 12 March 2021. These will help the European Commission and the Technical Expert Group on sustainable finance to design a methodology to assess the likely green impacts of investments in the aviation ecosystem.

As a first step, the report identifies the following as the aviation activities (from aviation and supporting sectors) that should be considered for inclusion in the EU Taxonomy:

• Aircraft related: air transport (passenger and freighter aircraft) and aircraft manufacturing, maintenance and technology development;
• Fuel production, storage and distribution: sustainable aviation fuels (SAFs) including advanced biofuels and electro fuels (in line with REDII);
• Air traffic management (ATM):
  • any activities or investments that are categorised by SESAR as consistent with the ATM Master Plan scenarios and solutions delivering environmental benefits; 
  • any activities or investments that are in line with the implementation of Free Route Airspace (FRA) and cross-border FRA.
• Airport related: airport operations and ground handling and construction of airport infrastructure (if directly supporting low-carbon aviation activities, for example, the storage and delivery of SAF for aircraft or solutions to electrify taxiing without engine running).

These economic activities can be included if they make a substantial contribution to one of the six objectives of the Taxonomy Regulation, such as climate change mitigation and adaptation, sustainable use and protection of water and marine resources, transition to circular economy, pollution prevention and protection and restoration of biodiversity and ecosystems. Climate change mitigation is the most relevant goal for the aviation sector, followed by pollution prevention and control.

The activities listed above can qualify as contributing substantially to climate change mitigation if they meet the criteria set out under Articles 10 and 16 of the Regulation and if they are considered either a low-carbon activity, a transition activity or an enabling activity.

When it comes to aviation, the following are proposed to be included as low-carbon activities:

• the sale, lease or operation of any aircraft powered by 'clean' fuels, including electric batteries, hydrogen fuel cells or liquid hydrogen (LH2) turbines;
• the sale, lease or operation of any aircraft powered by advanced biofuels or electro fuels following the approach set out in the Renewable Energy Directive (RED II).

As an enabling activity for climate change mitigation relevant for the sector, the report includes:

• The manufacture of aircraft powered by 'clean' fuels, including electric batteries, hydrogen fuel cells or liquid hydrogen (LH2) turbines.

However, when it comes to transition activities, the report states that it is more difficult to define because current aircraft does not support zero or low-emission flying (likely to be the case for at least the next 10 years) while Article 10 requires these activities to be consistent with the Paris Agreement targets and, for the aviation sector, with the European Green Deal’s 90 per cent GHG reduction from the transport sector by 2050.

What can be included under the transition activities are financial investments supporting investments or activities which are consistent with following pathways towards major reductions in aircraft emissions can be included in the EU Taxonomy as transition activities, so long as the principle of following the 'leading edge' (the best technology available at any given point in time) of available improvements is applied.

The report proposes that thresholds for the allowable levels of CO2 emissions be defined for each category, with these thresholds becoming more stringent over time, consistent with following the leading edge approach. As the technology develops through time, the permissible levels of emissions on the leading edge will fall, so that the manufacture, purchase, lease or operation of aircraft on that leading edge at a particular point in time is “not at risk of hampering the development and deployment of low-carbon alternatives”, nor is it at risk of leading to a “lock-in of carbon-intensive assets”.

Proposed thresholds for each aircraft category: 

Other relevant environmental objectives:

Sustainable use and protection of water and marine resources:

• Activities to reduce the adverse environmental impact of de-icing fluids, which contain chemicals which can mix with and contaminate the surface and groundwater in the vicinity of airports should be included in the taxonomy.
• Criteria: reduction of VOC.

Transition to a circular economy:

• Activities to improve aircraft decommissioning practices.

Pollution prevention and control:

• Aircraft: activities that can reduce particulate matter (PM) and NOx air pollution as well as aircraft noise.
• Airport operations: activities which can reduce airport noise.

Should you have any questions, please do not hesitate to contact martina.dipalma@eraa.org [5]

9 December 2020: EU Taxonomy public consultation. The European Commission has opened the public consultation on EU Taxonomy for sustainable finance criteria on climate change.

The Commission seeks feedback on the draft Delegate Regulation supplementing Regulation (EU) 2020/852 of the European Parliament and of the Council by establishing the technical screening criteria for determining the conditions under which an economic activity qualifies as contributing substantially to climate change mitigation or climate change adaptation and for determining whether that economic activity causes no significant harm to any of the other environmental objectives, accessible: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12302-Climate-change-mitigation-and-adaptation-taxonomy [7]

This draft regulation is open for feedback for four weeks, 20 November 2020–18 December 2020 (midnight Brussels time). Feedback will be taken into account for finalising this initiative.

Note the specific references to aviation, such as recital (22) on the need for criteria for aviation, and activities on low carbon airport infrastructure. Refer also to other activities of relevance, e.g. biofuels and renewable energy production.

It is now the time to have your say. If you support rapid inclusion of aviation in the taxonomy, and/or have any suggestions, do respond to this consultation.