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Joint Airline Associations position paper on the revision of the Aircraft Noise Directive: No specific reference to night operations necessary

Joint position of the European Express Association (EEA), the European Low Fares Airlines Association (ELFAA), the European Regions Airline Association (ERA), the International Air Carrier Association (IACA) and the International Air Transport Association (IATA) on the establishment of rules and procedures with regard to the introduction of noise-related operating restrictions at Community airports.

As the European Commission is about to finalise the internal decision procedure on the revision of Directive 2002/30 on aircraft noise, our associations strongly urge to reconsider adding specific references to night flights restrictions in the revised Directive for the following reasons:

Night flights restrictions create an unreasonable operational burden on airlines. They are particularly damaging to cargo operations (including express services) but also to passenger airlines, for their long-haul flights’ network and if their efficient business model requires the highest daily use of aircraft (e.g. airlines active in the tourism sector and short-haul operators).

The impact of aircraft noise in and around an airport is a highly local issue. As such, a “one size fits all” approach to night flights is not a practical means of addressing any local problems.

The balanced approach to aircraft noise management already provides a mechanism for the introduction of partial operating restrictions, including at night. Specific provisions on night flights would therefore bring no benefits or added-value.

By facilitating night-time restrictions, the proposal would threaten the competitiveness of airlines operations in the EU, particularly cargo and charter airlines.

Night flights restrictions lead to significant detrimental operational effects for airlines, both cargo and passenger. As an airline links two or more points to each other, such restrictions have a sequential impact on airline operations elsewhere than at the restricted airport, as well as on other airports and other communities. Because airlines schedule their flights by means of aircraft rotations, night flight restrictions have indeed a penalising effect on services during the rest of the day. Night-time restrictions also prevent passenger airlines from using the late evening period as a buffer to ‘soak up’ delays accumulated during the day. Network effects can also be very significant for regional airlines, for which late evening and night flights play an essential role in ensuring the overall viability of a route. Many regional airlines also operate night freight and express services to complement their daytime passenger operations.

Airlines often rely on late evening and early morning departures and arrivals to run a sustainable business model and to have access to off-peak slots. Without night capability, airlines may in practice have to abandon their entire operations. This is particularly true for leisure carriers, which are able to offer air travel at affordable fares, thanks to an efficient use of aircraft, crew and slots. Night restrictions usually come in addition to other constraints relating to night operations (working conditions, extra labour costs) and lead to scheduling constraints elsewhere. Many regions in Europe heavily rely on tourism activities. In the current challenging economic times, these destinations (often in Southern Europe) cannot afford yet another hit on their economy.

Night flights constitute the very life blood both for the express industry itself and for its customers, many of whose businesses are reliant upon the availability of guaranteed overnight door-to-door delivery services. Express companies provide a next-day delivery network for the entire EU internal market (even for the most remote regions) and connect EU businesses, both large and small, with the rest of the world. By facilitating night-time restrictions, the proposal would therefore threaten the role of express as a trade facilitator within the EU single market (85% of EU origin express shipments are delivered within the EU). Citing night flights explicitly is contrary to the essence of the balanced approach

The essence of the balanced approach to aircraft noise management as agreed within the International Civil Aviation Organisation (ICAO) is to enable individual airports to tailor restrictions to the specific and demonstrable noise issues that they face.

In line with the balanced approach, the existing definition of “operating restrictions” in Directive 2002/30 already embraces the ability of competent authorities to propose partial restrictions “according to time period”.

We see no practical benefit arising from highlighting just one partial restriction in any revised legislation. Singling out night flight restrictions would present them as the only type of partial restriction that should be used by competent authorities. This would serve to not only adversely impact our operations but also the competitiveness of all customers across the European Union who rely on services that require night flights, such as businesses using next-day delivery services, or people travelling for business or leisure.

Our associations are also opposed to any definition of “night”, as it would effectively establish the period(s) during which any such restrictions must apply, in contradiction to the airport-by-airport rationale of the balanced approach.

Conclusion

By adding an explicit reference to ‘night flights’ in the revised proposal, the European Commission encourages competent authorities to use night restrictions rather than other forms of partial restrictions. This is against the accepted principle of the balanced approach, which recommends a series of solutions for dealing with aircraft noise, including, but not limited to, operating restrictions on an airport-by-airport basis. It also presents a serious threat to the competiveness of European airlines and their customers.

Notice: This paper is without prejudice to views which the signatory associations may wish to express — individually and/or collectively – on other articles of the proposal for a Regulation.