On 9 October, the Council of the EU adopted a new regulation on ensuring a level playing field for sustainable aviation (ReFuelEU Aviation). This is an ambitious step towards decarbonising the aviation sector by promoting the use of green aviation fuels. However, the upcoming ‘aviation fuel revolution’ may require additional investment at airports.
The importance of fuel to the aviation industry
Fuel is one of the most significant costs in aviation. By reducing fuel consumption, airlines not only reduce their operating costs, but also their greenhouse gas emissions.
Innovation in aviation therefore aims to make flying cheaper and more environmentally friendly. These goals can be achieved at the design stage of new aircraft models, but also through the use of new types of fuel that help reduce harmful emissions.
These include synthetic fuels, hydrogen and biofuels. Studies show that burning bio-based fuels produces less carbon dioxide than traditional petroleum-based fuels[i].
Work on the wider use of green fuels in aviation has been underway for some time. In March 2022, one of the world’s largest passenger planes took to the skies using fuel made from sources including waste cooking oil[ii]. There are also plans to unveil a commercial hydrogen-powered aircraft in the near future[iii].
More green fuels at European airports
In light of the EU’s ReFuelEU Aviation Regulation:
- From 2025, at least 2% of aviation fuel at EU airports must be green
- The aim is to increase this proportion every five years until it reaches 70 % in 2050
The new legislation also clarifies what constitutes ‘green’ fuel. In particular, it includes:
- „Sustainable aviation fuels, (‘SAF’)” that are either:
- synthetic aviation fuels
- aviation biofuels; or
- recycled carbon aviation fuels[iv]
- „Hydrogen for aviation”, which includes:
- renewable hydrogen, or
- low-carbon hydrogen[v]
In principle, the fuel share requirements refer to sustainable aviation fuels (SAF), but they can also be met by ensuring an adequate share of low-emission fuels or hydrogen[vi].
Selected provisions of the ReFuelEU Aviation Regulation are expected to enter into force as early as the beginning of 2024.
Prospects for airport infrastructure
Increased pressure to ensure the availability of new green aviation fuels suggests that there will be a growing interest in expanding or upgrading airport infrastructure. The new fuels (particularly hydrogen) may present additional challenges in terms of their storage at airports, for which current airport infrastructure is not prepared. It is also possible that production of selected green fuels will be relocated to areas closer to airports, reducing transport costs and ensuring a stable supply.
At the same time, it should be noted that in addition to investing in new fuels, airport managers can contribute to the decarbonisation of aviation in other ways. These include using renewable energy sources to power the airport (as Cochin Airport in India has done)[vii], or entering into PPAs that secure the purchase of renewable energy directly from the producer (as Sydney Airport has done)[viii].
There are opportunities to optimise the emissions and environmental impact of airports both in the design and construction of these facilities and in the organisation of processes. However, in order to identify potential risks in this regard, it is necessary to understand the increasingly complex regulatory environment that spans multiple branches of law.
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 Z. Pągowski, Lotnicze paliwa i oleje, Prace Instytutu Lotnictwa, Nr 199, Wydawnictwa Naukowe Instytutu Lotnictwa, Warszawa 2009, p. 122 -123.
 First A380 powered by 100% Sustainable Aviation Fuel takes to the skies, Airbus, 28 March 2022 <https://www.airbus.com/en/newsroom/press-releases/2022-03-first-a380-powered-by-100-sustainable-aviation-fuel-takes-to-the> [access: 28.09.2023].
 ZEROe, Towards the world’s first hydrogen-powered commercial aircraft, Airbus, <https://www.airbus.com/en/innovation/low-carbon-aviation/hydrogen/zeroe> [access: 28.09.2023].
 Regulation of the European Parliament and of the Council on ensuring a level playing field for sustainable air transport (ReFuelEU Aviation), Article 3(7), <https://data.consilium.europa.eu/doc/document/PE-29-2023-INIT/pl/pdf> [access: 16.10.2023].
 Ibidem, Article 3(17).
 Ibidem, Article 4(1).
 About us, Cochin International Airport Limited, <https://www.cial.aero/About-Us> [access: 28.09.2023]
 Sydney Airport commits to net zero by 2030, Sydney Airport, 21 May 2021, <https://www.sydneyairport.com.au/corporate/media/corporate-newsroom/sydney-airport-commits-to-net-zero-by-2030> [access: 28.09.2023]