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A “book and Claim”-Approach to account for sustainable aviation fuels in the EU-ETS – Development of a basic concept
Since 2012 aviation is included in the EU Emissions Trading Scheme (EU-ETS). The EU-ETS requires emission
allowances for CO2 emissions, except if they result from the combustion of Sustainable Aviation Fuels. These
fuels are drop-in fuels, i.e., they are fully compatible with conventional aviation turbine fuel, supply infrastructure
and aircraft. However, the current EU-ETS regulation to account for the use of sustainable fuels requires
their designated /separate logistics to the airport tank farm. This is technically unnecessary, and both environmentally
and economically disadvantageous. It thus represents a barrier for the widespread use of Sustainable
Aviation Fuels. Against this background, criteria for an advanced accounting methodology are defined and three
different chain of custody concepts are evaluated against them. The most suitable solution is based on a book and
claim principle, an approach approved by EU institutions in other industries facing similar circumstances. It
balances the fuel’s technical potential, the administrative burden for the aviation industry and fundamental EUETS
requirements, like fraud protection. The latter is ensured by the uniform excise tax supervision in the EU.
Finally, a holistic layout of a book and claim concept to account for the use of Sustainable Aviation Fuels in the
EU-ETS is proposed.
1. Introduction
The use of Sustainable Aviation Fuel (SAF) is seen as an important
option to mitigate greenhouse gas (GHG) emissions from aviation. In
this context, the term SAF comprises several synthetic kerosene types
that meet eligible sustainability criteria certified by a so called Proof of
Sustainability. When blended with conventional hydrocarbons or conventional
aviation turbine fuel as specified, SAF are approved as “dropin”
aviation turbine fuels. This means, that they are unrestrictedly
compatible with existing supply infrastructures and aircraft systems
(ATAG, 2017; Pechstein et al., 2018). Although the suitability and
reliability of SAF has been proven, its use in commercial aviation remains
limited. Besides price differences between conventional aviation
turbine fuel and SAF (ICAO, 2017), the administrative effort associated
with its use is additionally hindering the market entry (Pelchen, 2016).
In 2012 the aviation sector has been integrated into the European
Emissions Trading Scheme (EU-ETS). Basically, aircraft operators are
obliged to surrender certificates for GHG emissions from combusting
conventional aviation turbine fuels (so called “emission allowances”).
For GHG emissions
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