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UN aviation agency has an opportunity to bolster sustainable flight by adopting critical fuels criteria

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By Guest Author

This blog post was authored by Pedro Piris-Cabezas, Director of Sustainable International Transport & Lead Senior Economist at Environmental Defense Fund, and Anna Stratton, Consultant

ICAO building, Montreal

This month, the International Civil Aviation Organization, the United Nation’s aviation agency, is holding its 222nd Council meeting. On the agenda: an opportunity for ICAO Council to signal its commitment to a sustainable future for aviation by adopting an expanded set of sustainability criteria for sustainable aviation fuel (SAF).

SAF provides a distinct opportunity to put aviation on a pathway to net-zero climate impact by 2050, provided the SAF deployed actually reduces emissions, meets a high standard of environmental integrity, and is accurately accounted for. In 2017, ICAO’s Committee on Aviation Environmental Protection (CAEP) recommended a set of sustainability criteria to the Council, which adopted a portion of the criteria for its emission reduction program and delayed a decision on the rest. Environmental NGOs have called on members of the Council, who are 36 elected members from ICAO’s 193 Member States, to adopt CAEP’s full set of recommendations ever since.

ICAO’s emissions reduction program, the Carbon Offsetting and Reduction Scheme for International Aviation, or CORSIA, includes a comprehensive SAF framework. CORSIA’s design incentivizes the deployment of SAF that supports decarbonization. If ICAO Council adopts the full set of sustainability criteria recommended by CAEP, it will further strengthen the CORSIA SAF framework and help ensure that CORSIA SAF (1) promotes rather than undermines the achievement of the UN Sustainable Development Goals and (2) mitigates the emissions, ecosystem and community risks otherwise present in alternative fuel production and use.

EDF is a member of the International Coalition for Sustainable Aviation (ICSA), the group of environmental NGOs with observer status at ICAO. ICSA sent a letter to all Council Members calling for the adoption of the sustainability criteria as originally recommended by CAEP. In ICSA’s view, not only does the full set of criteria provide clear environmental benefits, adopting the criteria now will provide much needed certainty to SAF producers, as they make investments in the sustainability of their supply chains. Postponing the adoption of the sustainability criteria poses the risk of delaying investments in SAF production capacity, the scale-up of which is critical to the decarbonization of civil aviation.

What’s in the sustainability criteria?


CAEP approved the full set of CORSIA SAF sustainability criteria in 2017 (see Table 1 below¹). The criteria cover 12 themes that encompass the three pillars of sustainability: social, environmental, economic.

Table 1: Sustainability Themes, Principles, Criteria and guidance recommended by CAEP.

ThemePrincipleCriteria
1. Greenhouse Gases (GHG)Principle: Sustainable Alternative Jet fuel should generate lower carbon emissions than conventional kerosene on a life cycle basis.Criterion 1: Sustainable alternative jet fuel shall achieve net greenhouse gas emissions of at least 10% compared to fossil jet fuel on a life cycle basis.
2.
Carbon stock
Principle: Sustainable alternative jet fuel should not be made from biomass obtained from land with high carbon stock.Criterion 1: Sustainable alternative jet fuel shall not be made from biomass obtained from land converted after 1 January 2008 that was primary forests, wetlands, or peat lands and/or contributors to degradation of the carbon stock in primary forests, wetlands, or peat lands as these lands all have high carbon stocks.

Criterion 2: In the event of land use conversion after 1 January 2008, as defined based on IPCC land categories, direct land use charge (DLUC) emissions shall be calculated. If DLUC greenhouse gas emissions exceed the default induced land use change (ILUC) value, the DLUC value shall replace the default ILUC value.
3. WaterPrinciple: Production of sustainable alternative jet fuel should maintain or enhance water quality and availability.Criterion 1: Operational practices shall be implemented to maintain or enhance water quality.

Criterion 2: Operational practices shall be implemented to use water efficiently and to avoid the depletion of surface or groundwater resources beyond replenishment capacities.
4. SoilPrinciple: Production of sustainable alternative jet fuel should maintain or enhance soil health.Criterion 1: Agricultural and forestry best management practices for feedstock production or residue collection shall be implemented to maintain or enhance soil health, such as physical, chemical and biological conditions.
5. AirPrinciple: Production of sustainable alternative jet fuel should minimize negative effects on air quality.Criterion 1: Air pollution emissions shall be limited.
6. ConservationPrinciple: Production of sustainable alternative jet fuel should maintain or enhance biodiversity, conservation and ecosystem services.Criterion 1: Sustainable alternative jet fuel shall not be made from biomass obtained from areas that are protected for their biodiversity, conservation value, or ecosystems services, unless evidence is provided that shows the activity does not interfere with the protection purposes.

Criterion 2: Low invasive-risk feedstock shall be selected for cultivation and appropriate controls shall be adopted with the intention of preventing the uncontrolled spear of cultivated non-native species and modified microorganisms.

Criterion 3: Operational practices shall be implemented to avoid adverse effects on areas that are protected for their biodiversity, conservation value, or ecosystem services.
7. Waste and ChemicalsPrinciple: Production of sustainable alternative jet fuel should promote responsible management of waste and use of chemicals.Criterion 1: Operational practices shall be implemented to ensure that waste arising from production processes as well as chemicals used are stored, handled and disposed of responsibly.

Criterion 2: Operational practices shall be implemented to limit or reduce pesticide use.
8. Human and labour rightsPrinciple: Production of sustainable alternative jet fuel should respect human and labour rights.Criterion 1: Sustainable alternative jet fuel production shall respect human and labour rights.
9. Land use rights and land usePrinciple: Production of sustainable alternative jet fuel should respect land rights and land use rights including indigenous and/or customary rights.Criterion 1: Sustainable alternative jet fuel production shall respect existing land rights and land use rights including indigenous people’s rights, both formal and informal.
10. Water use rightsPrinciple: Production of sustainable alternative jet fuel should respect prior formal or customary water use rights.Criterion 1: Sustainable alternative jet fuel production shall respect the existing water use rights of local and indigenous communities.
11. Local and social developmentPrinciple: Production of sustainable alternative jet fuel should contribute to social and economic development in regions of poverty.Criterion 1: Sustainable alternative jet fuel production shall strive to, in regions of poverty, improve the socioeconomic conditions of the communities affected by the operations.
12. Food securityPrinciple: Production of sustainable alternative jet fuel should promote food security in food insecure regions.Criterion 1: Sustainable alternative jet fuel production shall, in food insecure regions, strive to enhance the local food security of directly affected stakeholders.

This 222nd ICAO Council Session will be the fourth time since CAEP’s approval that Council has discussed the adoption of the full set of criteria. The first was in November 2017, and last in November 2020. The CORSIA Pilot Phase (2021-2023) will only apply criteria from Theme 1 (Greenhouse Gases) and Theme 2 (Carbon Stock). If Council decides to take decisive action and adopt the full set of criteria, they will be applied Phase 1 (2024-2026) of CORSIA onward.

Don’t delay action
ICAO Council’s 222nd session presents a unique but rapidly fleeting opportunity for Council to send a clear signal on its commitment to a sustainable future. ICAO Council Members must seize the opportunity to act now and adopt the sustainability criteria for SAF that will deliver the sustainability safeguards and the certainty necessary to put aviation on a pathway to net-zero impact by 2050.

¹ During its 2017 Steering group Meeting. Published in “Committee on Aviation Environmental Protection Report of its Eleventh Meeting, Montreal, 4-15 February 2019 (approved by the Committee on Aviation Environmental Protection and published by decision of the Council)” (ICAO Doc 10126, CAEP/ 11 (2019)).

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