- A unique worldwide off-setting scheme to address airlines’ CO2 emissions
The airline sector is the only industry having volunteered to set up a very ambitious scheme tackling its CO2 emissions. The agreement within ICAO to set up CORSIA represents an unprecedented decision with respect to a worldwide mitigation of an entire sector’s CO2 emissions. The agreed Global Market-Based Measure takes into account that CO2 emissions have a global impact.
Moreover, it is part of a basket of tangible measures adding improvements in technology, operations and infrastructure.
AIRE acknowledges the instrumental role played by the European Union in the design of CORSIA.
AIRE is confident that the European Commission recognises the high level of ambition of CORSIA and that it backs the idea that CORSIA will replace the EU-ETS for aviation.
AIRE also considers that any national “green” tax on aviation CO2 emissions or such tax at EU level would create a dangerous precedent for a patchwork of systems and potentially negatively affect the competitiveness of European airlines on a global level.
- An accelerated defragmentation of the European Single Sky and a solution to the current inefficiencies
In addition to the current ETS and the future CORSIA replacing it, airlines are fully financing the aviation infrastructure through user charges (airports, air traffic control). These costs, including the costs of inefficiencies, should not be ignored as they are adding to the costs of off-setting.
The lack of ATC capacity and continuing fragmentation of airspace is responsible for flight inefficiencies and unnecessary and unacceptable fuel burn and CO2 emissions.
- An economic regulation at European level on airports having Significant Market Power (SMP)
Airport charges represent a very significant percentage of an airline’s operating costs. These charges are constantly increasing throughout Europe.
The aviation sector is still missing a proper legal framework that would address the significant market power that airports have due to the inherent lack of competition in this sub-sector.
AIRE has been advocating for years that the only effective legal tool would be the robust economic regulation of airports meeting a number of defined criteria evidencing their market power (airports implementing Dual Till, congested airports, network airports, hub airports).
This regulation and its economic regulator must be established at the European level to ensure a harmonized system and a genuinely independent economic oversight.
- A worldwide slots distribution system providing legal certainty
Airport slot allocation is governed globally by the IATA Worldwide Slot Guidelines which are reflected in the currently applicable EU slot Regulation. AIRE does not support the 2011 Commission’s proposal to revise the EU slot Regulation by introducing deep changes in the current system that conflict with globally set standards.
AIRE considers that European rules on slot allocation must be kept aligned with the rest of world as to provide legal certainty for airlines that rely on stable and globally agreed slot rules for their investments in aircraft and routes.
- A coherent, convergent and simplified regulatory framework
- An empowered Network Manager
AIRE supports the Network Manager to expand its role to manage the Airspace, the Capacity and the Infrastructure subject to a new regulatory framework providing for:
- An adequate industry governance of the functions with a prominent role for airlines and devoid of conflict of interests
- A genuine performance scheme driving the right behavior and delivering the capacity required at an agreed cost, with penalties for the non-performers.
- An accelerated implementation of new airspace design and new technology.
There should a full convergence between the ATM Master Plan, the Airspace Architecture Study and the Network Strategy Plan. This convergence must be translated right away in a concrete action plan with measurable deliverables including quick wins.
Airspace Usage Requirements must be based on a positive Cost Benefit Analysis, the technical requirements and exemption criteria need to be clear and timely available. The poor experience with the Data Link Services and Surveillance Performance and Interoperability (ADS-B) should not be duplicated.
- The utmost scrutiny in monitoring Member States performance plans.
ATM charges constitute a very significant cost to airlines. The inefficiencies of the European ATM system, both cost-wise and operations-wise, have been established, evidenced and quantified by the Performance Review Body (PRB).
AIRE relies on the Commission and the PRB to reject Performance plans that would not be fully consistent with the letter and the spirit of the newly adopted Performance and Charging Regulation.
- A more seamless customer experience at borders for passengers
Innovation and digitalisation will continue to be a key tool in supporting the growth of the industry over the coming years, by delivering a more seamless customer experience and enhancing organisational efficiency. AIRE advocates for greater clarity and legal certainty, particularly in addressing concerns related to privacy and data protection, as well as security and immigration controls when looking at digital developments. In particular the EU should implement an encompassing iAPI solution for border control, which reduces administrative burden on airlines and provides clarity to passengers. Support of investments in safety and security technology and innovation are also vital in this respect.
International liberalisation of Air Service Agreements
- More connectivity and choices for passengers
The EU should continue to pursue liberal aviation agreements for the benefit of a wider and well-connected European market. When the UK departs, the Commission should ensure that an ambitious aviation agreement between the EU and this crucial third country is concluded at the earliest possible moment, thereby ensuring the mutual protection of investments in the aviation sector and continued reciprocal access to airspace.
- A balanced system and legal certainty
Clear rules on air passenger rights would benefit airlines as well as their passengers. A lack of clarity in the current provisions results in unnecessary tensions between passengers and staff at the airports when irregularities occur, as well as in contacts afterwards between passengers and airlines’ customer service departments.
AIRE has always stated that EU Regulation 261/2004 is an inadequate piece of legislation in its current state. The fact that the European Court of Justice was called upon at numerous occasions to provide interpretation on key design elements of EU Regulation 261/2004 is the best evidence that the law was written imprecisely.
AIRE believes that:
- It is high time for the European decision-makers to bring forward clear rules which cannot be misinterpreted.
- As passenger rights rules usually relate to incidents which result in discomfort for travelers, passengers should have access to easy-to-understand information about their applicable rights. This can only be ensured when robust rules are established which, after their publication, cannot be interpreted in ways which diverge from what they were intended for.
- Air passenger rights rules should be balanced in taking into account the interests of both the passengers and airlines.
AIRE has welcomed the European Commission’s legislative proposal from 2013 as it presents a balanced concept with a well-designed trigger point structure for delay compensation and furthermore includes the principle of a list of extraordinary circumstances and limits the obligation on carriers to provide care and assistance.
This proposal is still fit for purpose and remedies the lack of clarity of the current Regulation.
- An improved standardisation at national aviation authorities
The differences in implementation by Member States and the lack of standardisation create an unnecessary burden for organisations operating in different Member States, but also difficulties to obtain the necessary approvals from the competent authority.
- An improved cooperative support between national aviation authorities
The common-sense proposal to remove the prior approval for intra-EU leasing can be addressed by a better cooperative oversight between NAAs.
- An extended application of EU safety regulations relating to Ground Handling
Ground Handling service providers are the only major safety-critical stakeholders that are not directly subject to EU aviation safety regulations. In addition, smaller and seasonal airports are prone to be exempted by the Member States from the EASA New Basic Regulation. Common EU training standards could reduce costs and number of safety audits. There is merit for EASA to harmonise the variety of airline operational procedures, both on safety and costs.
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