Closing the infrastructure gap for EU aviation and maritime

Introduction

The SASHA Coalition responded to the EU call for evidence on the Alternative Fuels Infrastructure Regulation (AFIR), highlighting that while the AFIR has been a critical piece of the EU’s transport decarbonisation framework, significant gaps persist in maritime and aviation.

The current regulation does not sufficiently cover key enablers to ambitiously decarbonise these sectors, namely electric recharging and renewable hydrogen infrastructure. The current AFIR justifies the absence of binding infrastructure requirements for aviation and maritime on the basis of technology maturity that could be expected post-2030, zero-carbon emission solutions are developing, with industrial actors across Europe reaching critical investment and certification milestones.

Waiting for full market maturity without enabling infrastructure through regulatory certainty risks creating a self-fulfilling delay: without early infrastructure signals, investment, deployment and scale may take longer to materialise and perpetuate a polluting and volatile dependence on fossil solutions. While FuelEU Maritime and ReFuelEU Aviation set demand-signals for alternative fuels, and the Sustainable Transport Investment Plan aims to mobilise investment and scale deployment, the AFIR becomes the missing link to provide a corresponding supply-side regulatory framework for these technologies.

Our recommendations:

To meet the sectors’ needs and to deliver on the EU’s climate objectives, strengthen the TEN-T decarbonisation dimension, and fulfil the ambition to accelerate the deployment of alternative fuels infrastructure through the AFIR as recently outlined in the EU Ports Strategy, the SASHA Coalition strongly recommends to:

1. Move forward with binding deployment for renewable hydrogen infrastructure.

2. Include electric recharging infrastructure, not only stationary supply.

3. Accelerate routes’ interoperability.