Navigating the ReFuelEU Aviation AO Verifier Manual: A Guide for Airline Operators

As the European Union takes strides towards sustainable aviation, the ReFuelEU Aviation Regulation (RFEUA) introduces a structured approach for monitoring, reporting, and verifying (MRV) fuel usage among commercial airline operators. Published by the European Union Aviation Safety Agency (EASA), the ReFuelEU Aviation AO Verifier Manual is an essential document for airlines looking to comply with these new standards. Here’s what airline operators need to know about the manual and the regulation.

Understanding the Scope of the ReFuelEU Aviation Regulation

The RFEUA applies to operators performing over 500 commercial passenger flights or 52 commercial cargo flights departing from Union airports. The regulation mandates that airlines track, report, and verify fuel data, aiming to reduce carbon emissions through enhanced transparency. Key sections in the manual cover:

  1. Scope of Reporting: Operators are required to report details like flight numbers, ICAO codes, and total flight hours for each Union airport. The reporting criteria apply to commercial air transport but exclude certain operations like military and humanitarian flights. Airlines should ensure that all eligible flights are documented for compliance.
  2. Fuel Categories for Reporting: The manual categorizes fuel into specific groups, such as required fuel, tanked fuel for safety, and non-tanked fuel. Notably, the RFEUA mandates that at least 90% of fuel requirements are uplifted at Union airports, with any deviations needing to be clearly justified. The fuel categories are aligned with EASA’s Acceptable Means of Compliance (AMC) and ICAO guidelines, ensuring a unified approach across the industry.
  3. Tankering Justifications: Under Article 5(2), airlines can justify lower fuel uplift percentages if related to fuel safety considerations. However, economic tankering – carrying excess fuel for financial benefits – is not permissible unless the required documentation supports it. Operators are advised to keep accurate records of fuel planning, including Operational Flight Plans (OFP) and associated fuel documentation.
  4. Monitoring and Verification Process: Effective monitoring is a cornerstone of the ReFuelEU Regulation. Airlines need to establish procedures for collecting and verifying fuel data, which should cover all flights to and from Union airports. Verification by an independent auditor, certified under EU ETS, is mandatory to confirm compliance with the RFEUA standards. By maintaining robust monitoring processes, airlines can not only meet regulatory requirements but also contribute to the EU’s sustainability goals.
  5. Implementation Timeline: The annual reporting period spans from January 1 to December 31, with a submission deadline of March 31 each year. The first reporting year, 2025, will serve as a benchmark, allowing operators to identify areas for improvement. EASA recommends early engagement with accredited verifiers to streamline the process and ensure data accuracy.

Next Steps for Airline Operators

To comply with the RFEUA, airlines should familiarize themselves with the manual and establish internal processes for effective MRV. By preparing now, operators can ensure that they meet the March 31 submission deadline and contribute positively to the aviation sector’s sustainability initiatives.

For more details, you can access the ReFuelEU Aviation AO Verifier Manual directly on the EASA website: ReFuelEUAviation Manual.

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