There is more to sustainable aviation than merely greenhouse gases. Long before we worried about greenhouse gases, we were trying to address NOx gases. Early ICAO CAEP meetings focused on NOx and its interplay with noise. Even in 2008, the impact of NOx and contrails was known to be damaging. In fact, the non-CO2 elements contribute more to climate change than carbon emissions; fixing them is hard. At the time, suggestions included a multiplier on fuel uplift as part of the ETS’ MRV process. Instead, in 2017, when the aviation ETS was amended the first time, EASA was charged with looking at the issues. DG MOVE was required to report back in 2020, which it did, bringing a very detailed study down to less than four pages. But, those four pages packed a punch, suggesting six changes that, whilst taking five to eight years to fully verify and implement, would make a real difference.
It suggested financial measures – a NOx charge based on distance and including non-CO2 emissions in the ETS – fuel-related measures – a reduction in aromatics in kerosene fuel production, as well as promoting SAFs, (which do not have aromatics in the first place) – and then an ATM category including a requirement that ice supersaturated areas be avoided, and that a ‘climate charge’ be included in ATM charges. But, two years on, where are we? We are about to start a trialogue process on the revision of the ETS and the ReFuelEU (SAF) mandate, only. More SAFs are good but that is a collateral benefit. It will also take a decade or so to materialise, whereas cutting aromatics from kerosene now would cut contrails immediately. There has been very little, verging on no, focus on non-CO2 emissions in the recent discussions. In the middle of this, it is worth stopping and considering CORSIA, which the Council wants to implement for European carriers, but not in Europe, where the ETS will apply. Parliament on the other hand wants the ETS to apply for long-haul flights, and then reimburse the CORSIA costs as well as use the ETS allowance to subsidise SAF costs.
The Parliament did mention non-CO2 in its deliberations and suggested a trial of including it in the ETS, with financial obligations if reduction measures were not taken. The Council is silent on the matter. The Commission made no reference to it at the ICAO High-Level Long-Term Aspirational Goals meeting either, so there is little chance that it will pop up in the trialogue. The Commission’s four-pager from 2020 makes the point that both encouraging SAFs and reducing aromatics should be pursued. Reducing aromatics in the current fossil fuel will cost money – it is estimated to be between about 3 and 5 cents a litre depending on the method used – but you might think that increasing the price of fuel would help the case for increased SAF uplift in any event.
These figures come from a mysterious and getting more mysterious, paper referred to in the 2020 EASA report as ‘CE Delft, Forthcoming’. Finding out what has happened to CE Delft Forthcoming almost calls for the skills of John-Paul Sartre, existential detective. It is rumoured that it started out as part of the Horizon 2020 Jetscreen project, worth more than €7,000,000, managed by DLR. It was looking at the development and safety of new aviation fuels. The partners wanted Jetscreen renewed in 2020, but the Commission did not. Nor, on the termination of the Jetscreen project in May 2020, did CE Delft Forthcoming forthcome. This leads to regulation by stabbing in the dark.
CE Delft was first retained by Airbus to look at the question of removing aromatics from kerosene in 2018/19 and then that work was folded into Jetscreen. When Jetscreen came to an end, everyone, apart from the Commission, wanted the project to be renewed. It is a requirement under Horizon funding that a final report be issued, but so far, that report is yet to appear. Nevertheless, reading between the lines, it is clear from the long EASA report that the scientific study group considered its findings in depth. There was much debate about moving on aromatics now, or waiting for SAFs. The DG MOVE position was that Europe should wait for a global solution. Still, the final EASA report clearly signals that CE Delft Forthcoming would shortly forthcome. CE Delft, when pressed, noted that it could not publish the paper until Airbus (as commissioning body) approved its release. MIT continues to work on removing aromatics, mostly sulphur and naphthalene, from fossil jet fuel, as part of the FAA’s Ascent project. That work confirms the low incremental cost of removing them. It also confirms the benefit of removing black soot at airports – a public health priority.
So, in short, EASA, MIT, the Commission and CE Delft (Forthcoming) all confirm that whilst there is a refinery cost and about 2% CO2 penalty in doing so – which can be mitigated by using renewable energy – doing so will reduce contrails and improve engine efficiency, as well as public health around airports. But this is out of the regulators’ hands, apparently. Aviation fuel standards are set by the American Society for Testing and Materials. EASA’s certification process, for example, assumes ASTM compliance. The Commission regulates road and marine fuels but outsources aviation fuel standards. To amend the ASTM standard takes a majority of the ASTM membership of about 2,000. Or EASA acting unilaterally. The EASA report considered that option.
In the Parliament the Greens, having read the EASA study and having already proposed amendments on tackling aromatics in kerosene, pressed DG CLIMA and DG RTD (which is responsible for Horizon) for aromatics in kerosene to be considered and called for CE Delft Forthcoming to be released. EVP Timmermans replied for DGs CLIMA and RTD that they cannot move forward because DG MOVE refuses to release the CE Delft Forthcoming report as it is marked ‘Confidential’. When Airbus was pressed about the delay it started the ball rolling on finalising release. But, cutting across that, Commissioner Vălean wrote to the Parliament contradicting the Timmermans position that it was the confidentiality issue that prevented publication – and which Airbus was by then addressing. Vălean dismissed acting now on aromatic removal and focussed instead on DG MOVE’s long-term efforts on SAF.
The Greens’ amendments to tackle aromatics in kerosene survived until the plenary vote in July. DLR, as Jetscreen coordinator, released CE Delft Forthcoming for public use 36 hours before the EP plenary vote. But DLR did not release the report directly to the Parliament so that MEPs could be informed in time. Nor is the report on its website. Nonetheless, copies are available. We will happily share ours.
The cynic might argue that this is a deliberate attempt by organisations that depend on research funding to funnel as many funds as possible into ongoing SAF research, rather than take the low-hanging aromatic fruit, for which no further funding is required. Nevertheless, questions remain. Why have we ignored a solution that will immediately address the fine particulate matter question around airports, along with the contrail, black soot question? Why was such an important element of Fit for 55 shrouded in mystery? Perhaps more importantly, why were DGs MOVE, CLIMA and RTD not working in sync on this question. Finally, why did we think that we needed global cooperation, instead of taking the bull by the horns and showing global leadership?