Transport Quarterly Newsletter (Q4, 2023)

December 2023


We are pleased to share the first edition of InfluenceMap's Transport Quarterly for the month of December 2023. This bulletin will highlight recent insights into the advocacy of major companies and their industry associations. This issue covers:

Recent releases from InfluenceMap:

· Sustainable Aviation Fuel (SAF) Blenders Tax Credit (US Policy Tracker, December 2023)

· US CAFE Standards (US Policy Tracker, December 2023)

· US Light- and Medium-Duty GHG Emissions Standards (US Policy Tracker, September 2023)

· US Heavy-duty GHG Emissions Standards (US Policy Tracker, September 2023)

· EU Heavy Duty Vehicle CO2 Targets (EU Policy Tracker, October 2023)

· National Electric Vehicle Strategy and Fuel Efficiency Standards (2022-2023) (Australia Policy Tracker, September 2023)

· US Sustainable Aviation Fuel (SAF) Policies and Corporate Engagement (Report, July 2023)

About InfluenceMap

InfluenceMap is a non-profit think tank providing objective and evidence-based analysis of how companies and financial institutions are impacting the climate and biodiversity crises. Our company profiles and other content are used extensively by a range of actors including investors, the media, NGOs, policymakers, and the corporate sector. InfluenceMap does not advocate or take positions on government policy. All our assessments are made against accepted benchmarks, such as the Intergovernmental Panel on Climate Change. Our content is open source and free to view and use (https://influencemap.org/terms).

Automakers and oil industry work to oppose US transport climate policies

In 2023, automakers and the oil and gas industry led opposition to US vehicle regulations, but some misalignments appear to be developing within truck and auto industry associations. Three major automotive climate regulations were proposed by the US government in 2023, focused on promoting a transition to electric vehicles (the primary IPCC recommended pathway to decarbonizing road transport). The regulations included multipollutant (GHG) standards for light- and medium-duty vehicles, and for heavy-duty vehicles, alongside fuel economy standards (CAFE) for passenger cars and heavy-duty vans and pickup trucks.

There was significant alignment between industry associations representing oil and fossil gas interests and auto and truck makers to weaken major US transport climate regulations proposed in 2023. For both light and heavy-duty GHG emissions rules, the American Fuel and Petrochemical Manufacturers and American Petroleum Institute questioned the legality of proposals and sought rules to extend the role of liquid fuels in transport and to delay the roll-out of electric vehicles. While many automakers advocated for similar points, advocacy from vehicle manufacturers included greater emphasis on details such as credit programs and other flexibilities.

The Alliance for Automotive Innovation, which represents major automakers, is leading automotive opposition to both the GHG emissions standards for light- and medium-duty vehicles and new CAFE standards in 2023. The Alliance’s position on these two regulations has focused on three major aspects: refuting the legality of proposed standards; claiming the standards are infeasible and need to be weakened; and opposing a rapid transition to battery electric vehicles. Members that stated support for the Alliance’s position in comments to the EPA on light and medium-duty vehicles include Toyota, Nissan, Mitsubishi, Honda, Mazda , Hyundai, BMW, Stellantis, Volkswagen, Volvo Cars, and Tata Motors. Members that did not explicitly support the Alliance’s recommendations include General Motors, Ford, and Mercedes-Benz, with Ford taking a more positive position.

The Engine Manufacturers Association (EMA), representing US truckers, continues to lead opposition to heavy-duty climate rules. In a May 2023 consultation on GHG rules for heavy-duty vehicles, the EMA advocated to significantly reduce the ambition of both proposed and existing standards. Daimler Truck and PACCAR also did not explicitly support the EMA’s proposal but took negative positions on the rule. In the same consultation, EMA members Volvo Group and Navistar explicitly stated support for the recommendations of the EMA, with Volvo advocating to delay the Phase 3 standards from 2028 to 2030. Daimler Truck, and PACCAR did not explicitly support the EMA’s proposal, but took negative positions on the rule. Regarding other heavy-duty manufacturers, Ford Motor left the EMA in early 2023, while General Motors remains a member. Neither explicitly supported the recommendations of the EMA in June 2023 comments on the proposed GHG emissions standards for heavy-duty vehicles. This suggests a growing potential rift between major industry associations and their members, with both the EMA and Alliance increasingly representing the interests of their most negative members.

The proposed Corporate Average Fuel Economy (CAFE) standards were met with the most negative engagement of all three regulations. InfluenceMap’s analysis indicates that the vast majority of comments by auto manufacturers opposed or advocated to significantly weaken the policy. Eleven major auto manufacturers stated support for the Alliance for Automotive Innovation’s comments, which advocated to severely weaken proposed fuel economy standards. These include BMW, Honda, Hyundai, Jaguar Land Rover, Mitsubishi, Nissan, Stellantis, Subaru, Toyota, and Volkswagen.

Japan Automobile Manufacturers Association (JAMA) extends climate policy influence beyond Japan

National automotive industry associations are often the most influential lobbyists on automotive climate rules in home markets. However, the Japan Automobile Manufacturers Association (JAMA), which represents Japanese automakers, is the first automaker association InfluenceMap has found to be actively engaged on multiple key climate policies outside of its domestic market in 2023.

New InfluenceMap analysis finds that JAMA has strategically pushed to delay or weaken climate rules to promote battery electric vehicles in key 2023 consultations in Australia, the EU, and the UK. Such advocacy appears to be aligned with many of JAMA’s key members' positions and with its domestic advocacy on climate. In Japan, JAMA has pushed for policies to promote a longer-term role for internal combustion engine (ICE) powered vehicles, including ICE-powered hybrids, over a rapid transition to battery electric vehicles. While Toyota's president, Akio Toyoda, has been chair of JAMA since 2020, the organization has announced that Isuzu Motors’ chairman will take over the leadership role in 2024.

In the UK, a recent InfluenceMap freedom of information request found JAMA’s response to a May 2023 consultation on the UK’s upcoming zero-emission vehicle (ZEV) mandate, which requires automakers to sell minimum numbers of zero-emission vehicles. In its response, JAMA advocated for 2024 to be a monitoring-only year for the mandate, which would delay the policy’s legal enforcement date. JAMA members Honda, Toyota, and Subaru also pushed for the same delay. From other JAMA members' responses, Nissan pushed for payments to not be enforced until 2026, while Isuzu disagreed with the proposed van ZEV targets, stating that they would be “incredibly difficult to achieve,” while not explicitly referencing a monitoring-only 2024 proposal.

In the EU, JAMA was the only non-European group to respond to a May 2023 feedback request on heavy-duty CO2 standards. In its response, it appeared to urge EU policymakers to either delay expanding the scope of heavy-duty vehicles covered or review the 2030 45% reduction goal, stressing numerous concerns. Alongside this, JAMA pushed for the inclusion of renewable or low-carbon fuels in the policy.

In Australia, JAMA advocated for a low-ambition Australian fuel efficiency CO2 standard in a May 2023 consultation response while supporting numerous flexibilities like multiple credits, which would likely make the policy initially amongst the weakest CO2 standards in the developed world. Moreover, InfluenceMap research found that this lobbying position was aligned with the key advocacy positions of JAMA members Mazda and Toyota.

Opposition to the Schiphol Airport’s Flight Cap

The global airline industry successfully launched a coordinated advocacy and legal campaign against the Dutch caretaker government’s flight cap at Schiphol airport.

In June 2022, the caretaker government of the Netherlands announced it would cap annual flights at Schiphol airport at 440,000, down from 500,000, citing noise and environmental concerns. Air-France KLM consistently opposed the flight cap in 2022-23 and launched a strategic campaign against the Dutch government in March 2023. Delta Air Lines and easyJet joined KLM’s lawsuit in March 2023, which stated that the flight cap would hurt them, the Dutch economy, and travelers. The International Air Transport Association (IATA) brought a second lawsuit against the Dutch government in the same month, which demanded that the measure be abandoned. British Airways and Lufthansa supported IATA’s case.

In response to the aviation industry’s legal challenge, the District Court favored the airlines’ case, a decision that was applauded by Airlines for America (A4A) in an April 2023 press release. However, Amsterdam’s Court of Appeal overturned the District Court’s decision in July 2023, ruling that the Dutch government could proceed with the cap. In response, an extensive coalition of airlines, led by Air France KLM, launched proceedings against the judgement of the Court of Appeal, claiming the Court’s judgement conflicted with “national, European and international regulations.” This coalition included Delta Air Lines, United Airlines, JetBlue, Air Canada, easyJet , IATA, and Airlines for America (A4A). Airlines for Europe (A4E) also supported the proceedings.

In September 2023, both A4A and JetBlue filed separate complaints against the Dutch government, arguing that the proposed flight cap was unlawful. JetBlue’s complaint urged the US Department of Transport to “take immediate and decisive responsive action.”

In response to the widespread opposition from the aviation industry, the Dutch government eventually scrapped the flight cap in November 2023. Subsequently, KLM and A4A both released press releases praising the decision.

Industry opposition has not been limited to the Schiphol airport flight cap. The caretaker government also proposed a tax on transferring passengers, which KLM CEO, Marjan Rintel, described as a “ridiculous idea and we totally object to it” in a November 2023 Airlines Magazine article. KLM Cityhopper CEO, Maarten Koopmans, similarly opposed the tax in an October 2023 Flight Global article.

More over, an EU-wide plan to phase out fossil fuel subsidies was proposed by the Dutch government in September 2023 impacting airlines that currently receive 3.6Bn in fossil fuel subsidies from the Dutch government. Ryanair CEO, Michael O’Leary, and Lufthansa CEO, Carsten Sphor, criticized the phase-out, stating that “train fares remained too expensive to replace air travel, and policymakers’ plans to make aviation more sustainable by cutting support would backfire.” A4E also opposed the measure.

Aviation Sector Advocacy in France

After introducing a ban on some short-haul flights in May 2023, which Air France-KLM successfully engaged with to weaken, France has continued to propose climate regulations to decarbonize aviation in line with 1.5°C. However, these new measures appear to face the same resistance from the aviation industry.

In September 2023, France’s transport minister proposed a minimum price on flights in Europe. However, according to a September 2023 Reuters article , Airlines for Europe (A4E) questioned the legality of the measure, asserting it would breach EU law. A4E further opposed the measure in a September 2023 Politico article.

Furthermore, France’s 2024 budget bill introduced a tax on large airports, intended to finance decarbonization. This tax was opposed by Air France CEO, Anne Rigail, who stated that the tax would hurt French airlines through “a new distortion of competition,” according to an October 2023 Capital article. Air France-KLM’s CEO, Benjamin Smith, further opposed the tax in an October 2023 L’Opinion article, stating that it will undermine the company’s efforts to decarbonize.