This paper sets out A4E’s position on the European Commission’s planned comprehensive Strategy for Sustainable and Smart Mobility, setting a pathway for European air transport’s sustainable and digital transition and building a resilient and crisis-proof transport system for generations to come.
European Green Deal
A4E’s core objective is that aviation can grow sustainably while continuing to benefit the social and economic development of countries across Europe in the coming decades. This requires a coherent policy framework that promotes sustainability and innovation while supporting competitiveness. Carrying more than 720 million passengers each year and operating around 3000 aircraft, A4E airlines are ready and willing to contribute to making the European Green Deal a success.
European airlines are currently analysing potential pathways towards a net-zero, or low-carbon European air transport through both a reduction of CO2 emissions in absolute terms and CO2 mitigation through offsets or market-based measures. It is crucial to recognise the magnitude and the urgency of the commitment adopted by the European Commission. Airlines, too, know the importance of succeeding in turning this pledge into a future reality.
The decarbonisation of transport is a key policy objective and will be essential to reaching the EU’s climate policy objectives. Reducing emissions and moving away from fossil fuels go hand in hand. Over the next 10 years, European airlines plan to invest €169 billion in greener aircraft technologies which are on average 25% cleaner and less noisy than their predecessors.
An integrated approach is needed to enable airlines to contribute to reaching Green Deal objectives. Such an approach should improve the efficiency of Europe’s air transport network as a whole, enhance EU competitiveness, retain connectivity for EU citizens and increase growth.
In this respect, several reforms are still needed, including:
- Completing Europe’s Single Aviation market by reforming Europe’s Air Traffic Management architecture.
- Developing the right policies and investments to scale-up Sustainable Aviation Fuels (SAFs).
- Fully implementing the global aviation emissions offsetting system, CORSIA.
- Developing the right policies and investment schemes to support airlines that are willing to invest in fleet renewal, including the purchase of newer and cleaner aircraft.
- Supporting investment in research and development initiatives, such as electric and hybrid engine technologies to reduce dependency on fossil fuels.
COVID-19 and airlines
Throughout its ecosystem, the air transport industry is severely impacted by the COVID-19 crisis. The entire sector will have to reset its supply chains and search for new and lasting mobility services. Since the beginning of the COVID-19 outbreak, airlines have faced massive booking cancellations and a huge decrease in operations due to global travel restrictions.
The sudden drop in liquidity combined with high fixed costs has put the survival of many airlines at risk. The industry is now forecasting for Europe a potential 56.4% drop in air travel and loss of passenger revenue of up to €82 billion for 2020, likely to be felt throughout 2021.
The crisis has highlighted the essential nature of air transport, notably in helping to avoid shortages of essential goods and medical equipment during the initial outbreak. Air cargo has been instrumental in keeping critical value-chains active. Notably, European airlines repurposed passenger aircraft to ship medical equipment and other urgent supplies in cargo-only flights during the pandemic.
Looking beyond the COVID-19 crisis, the EU and Member States should continue to improve the functioning of the EU Single Aviation Market. Much of its success can be attributed to the EU regulatory framework which created opportunities for airlines and their partners and offered enormous benefits for passengers (including increased air connectivity and affordable prices). However, it can be expected that many of the structural issues that were preventing cost-efficient operations before the crisis will remain after the crisis — and may even prove more challenging to overcome due to changed market conditions post COVID-19.
Today’s crisis also puts the financing of aviation’s ecosystem to the test, jeopardising its capacity to invest in a much-needed digital transformation and green transition.
Moving forward, the legislative process will need to be more flexible and relevant. EU aviation legislation needs to account for future crises to ensure the sector’s resilience (slots waiver, passenger rights, economic regulation).
Proposals for a green and digital recovery for air transport
It is essential to foresee a dedicated place for the air transport ecosystem in future COVID-19 recovery plans, comprised of smart legislation and targeted financial support. This is where the policies and legislation set by the Sustainable and Smart Mobility Strategy will have a crucial role to play. The following measures could ensure a sustainable and digital return of the air connectivity offer:
- A revitalised and open single aviation market — improving connectivity, providing low fares and enabling the free movement of people and goods throughout the continent. This is the cornerstone of any European economic recovery. Eliminating restrictions at intra-EU and external borders while ensuring a uniform approach across all Member States is crucial to re-starting air transport and avoiding distortions for both passengers and cargo.
- The introduction of a digital single European sky, where modern technologies and new digital solutions are deployed to ensure the most efficient routings, whilst saving up to 10% CO2 emissions from flights within Europe. This would require completing Europe’s single aviation market by reforming the regulatory framework (Single European Sky 2+) and improving its airspace architecture and broader Air Traffic Management system.
- More effective and targeted regulation of airport market power as well as greater harmonisation in the setting of airport charges through a revision of the Airport Charges Directive. The ACD review is more important than ever and can help support the recovery phase by ensuring that charges are reasonable and cost-related throughout the EU. There is also a risk that some airports will use their market power to set excessive charges in the coming years to cover losses from COVID-19 through revenue obtained from users. This will drive up airline costs and slow the recovery further. Keeping the cost of air travel down will be necessary to stimulate the market and rebuild demand.
- Support for efforts benefitting a more environmentally sustainable air transport. These include the development of appropriate support for the deployment of sustainable aviation fuels (SAFs); deployment of low emission aircraft and other green technologies; more efficient operations and infrastructure; smart economic instruments enabling carbon pricing and cost-effective emissions reductions in other parts of the economy. Scaled-up investment programmes and adequate legislation would guarantee that air transport can contribute its best toward reaching the EU’s climate goals.
- Restoring the confidence of passengers in air travel by improving legal certainty in the area of consumer rights and prioritising the revision of Regulation (EC) No 261/2004 to make air passenger rights clear and simple to enforce. Pre-existing issues and grey areas in the current framework, already identified by the Commission in 2013, still need to be addressed. For example, the Commission’s proposal for a list of extraordinary circumstances, which determines if airlines are liable to pay compensation, would increase clarity for all. In addition, the COVID-19 crisis has shown the need to adapt the Regulations to ensure that proportionate rules can be temporarily applied during severe and prolonged mass disruption events.
Many overarching mobility strategies of the European Commission have fallen flat on their promises and prevented the sector from evolving. Air transport is a key enabler of European links — economically (investment, trade, tourism, jobs humanitarian missions and growth) and socially (facilitating free movement, providing connectivity also to Europe’s outermost regions and cross-border bonds).
It is facing major challenges in terms of the need to tackle climate change, adapt to digitalisation and the growing risks associated with cybersecurity. There is a clear need for a holistic policy approach, which considers the specificities of aviation and helps to improve efficiency, overcome capacity bottlenecks, and ensure the competitiveness of the sector. The success and the initial ambition of the EU Single Aviation Market should not be forgotten.
With every missed opportunity to act, there is also a risk that decision-makers are tempted by quick fixes or immediate political gains at the expense of more meaningful and necessary long-term policies. Further efforts are therefore required to:
- realise the principles of a seamless European sky for their citizens, allowing the EU to finally implement the Single European Sky initiative;
- improve the efficiency of airports through effective regulation of charges (revision of Airport Charges Directive ACD);
- steer clear of quick fixes (e.g. ticket taxes) to pressing and complex environmental challenges — focusing instead on helping air transport reduce dependency on fossil fuel by supporting research and development initiatives;
- protect consumers’ interests by ensuring that aviation does not become a cash cow for national governments and monopoly providers;
- revise Regulation 261/2004 on air passenger rights to establish a clear, proportionate and stable legal framework on air passenger rights — third parties such as claims management companies, should not be allowed to profit off the backs of passengers. As shown during the COVID-19 crisis, rules need to be crisis-proof.