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Sustainable Aviation Fuels: Latest Updates & Reporting of SAF under CORSIA and EU ETS

12/09/2021



Since the introduction of schemes such as CORSIA and EU ETS, airlines have started to invest in a range of measures to make aviation greener. One such measure is the use of Sustainable Aviation Fuels (SAFs), which offer the potential for large emissions reductions as compared to the conventional jet fuel

The aviation industry and the environmentalists agree that the use of SAFs can be an important factor for reducing the environmental impact of air travel and since our latest article in January 2021, there has been a variety of updates on SAFs including news related to SAFs, legislative changes affecting the use of SAFs, and the use of SAFs for reducing surrendering/offsetting obligations in the EU ETS and CORSIA schemes.

First, in 2021, many airlines announced their (increased) commitments to the use of SAFs:

 
  • Delta Airlines has signed an agreement with Deloitte, where the former will procure enough SAF to “represent a lifecycle emissions reduction of approximately 1,000 metric tons of carbon dioxide”. The airline says this is “equivalent to the carbon sequestered by 1,306 acres of U.S. forests or 756 football fields in one year”.
  • Airlines for America (A4A) have committed to help the aviation industry reach 2 billion gallons of SAF by 2030.
  • SpiceJet unveiled a blueprint for a sustainable aviation fuel initiative in India.
  • A new milestone in international aviation was achieved recently when a rescue helicopter flew on sustainable aviation fuel (SAF) for the first time.
  • International Airlines Group (Aer Lingus, British Airways, Iberia, and Vueling) has committed to operating 10 percent of its flights with sustainable aviation fuel (SAF) by 2030.
  • Japan Airlines conducted a flight with a blend of two different types of SAF, becoming the first airline to do so.
  • Airbus performed a test flight on an A350 aircraft using 100% sustainable aviation fuel for the first time.
Several notable initiatives and commitments were announced by engine/aircraft manufacturers too:
 
  • Rolls-Royce partnered with oil company Shell to work on the development of sustainable aviation fuels (SAFs) in line with both their plans for net-zero emissions by 2050
  • Rolls-Royce has also announced that all its engines will have the ability to operate with a 100% SAF (i.e., without “conventional” fuel) by 2023
  • Airbus Helicopters has invited all major stakeholders to join its recently established SAF User Group
  • Embraer has announced a range of sustainability initiatives that include electric and hydrogen propulsion research, and a go-ahead for its regional fleet to use 100% sustainable aviation fuels
The commitments to increase the production/use of SAF have also seen significant legislative support:
 
  • A Sustainable Aviation Fuel (SAF) Ambassadors group was launched by cabinet ministers from Kenya, the Netherlands, the United Arab Emirates, and the United Kingdom which will work with and advise the World Economic Forum’s broader Clean Skies for Tomorrow (CST) initiative.
  • The White House introduced the Sustainable Aviation Fuel Act in May, which aims to incentivize the production of sustainable aviation fuels (SAFs)
  • A SAF Blending Mandate was proposed as a ReFuelEU Aviation initiative under the ‘Fit for 55’ Package.
Reporting of SAF under CORSIA/EU ETS

A steady increase in the availability of SAFs and a decrease in their costs comes at a time when carbon allowances/offsets see significant increases in prices. It is only natural that aircraft operators will seek to leverage the situation to benefit from the use of SAFs in reducing their obligations in the CORSIA and EU ETS schemes.

In CORSIA, the reporting of the use of SAFs and claiming of the associated emissions reductions will be governed by the rules set out in the CORSIA SARPs and the accompanying Environmental Technical Manual (ETM). As is the case with all other CORSIA documents and data, the SARPs require the operators to retain all pertinent information on SAF use for a period of at least 10 years.

In the EU ETS, SAFs are typically referred to under the term “biofuels”. The reporting of the use of biofuels shall be based on the rules set out in the MRR, Guidance Document 2, and Guidance Document 3. As is the case in CORSIA, procedures related to the use of biofuels shall be included in the AEM Plan, followed throughout the monitoring period, and then reported using the latest EU ETS AEM Report template. Again, just like in CORSIA, all pertinent documents shall be retained for a period of at least 10 years.

Key steps to reporting the use of SAF in EU ETS/CORSIA

 
  • (Emissions) Monitoring Plan should be updated to include procedures related to the monitoring of flights with SAFs.
  • Flights that were operated with SAFs should be clearly identified in the raw flight/fuel data file provided to your verification body.
  • Please note that in case of CORSIA, only the SAFs which have the proof of sustainability from the two sustainability certification schemes recognized by ICAO will be eligible for Emissions Reductions. However, there is no such limitation currently for EU ETS.
  • All the following documentation should be prepared and made available to the verifier to prove the use of SAFs, noting that most if not all the documents are typically obtained from the fuel supplier:
    • Sustainability Certification/Proof of Sustainability
    • Purchase and uplift* records
    • Production batch details
    • Conversion process details
    • Neat fuel details
    • Blend details
    • Life cycle emissions values
    • In case of CORSIA Eligible Fuel the following details will be additionally required:
      • Details of the shipper
      • Details of the blender
      • Blending process documentation
      • Date of receipt of neat CORSIA Eligible Fuel
*Uplift records are not necessary if reporting in EU ETS using the “biofuel determination based on purchase records” approach.
 
Please feel free to contact us at corsia@verifavia.com if you have any questions about the use of SAFs in EU ETS and CORSIA or on any other topic.
 
Further readings
 
1. An IATA guidance document for SAF Management

2. Click here to review the ICAO’s set of reference documents on CORSIA Eligible Fuels can provide an insight to key factors of SAF use under CORSIA such as sustainability criteria, life cycle emissions values and sustainability certifications 

3. ICAO SAF center provides various technical, legislative and research documents to help better understand the major role being played by SAFs in reducing GHG emissions

 
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