Fitness Check of EU airports legislation

Schiphol has a major impact on Amsterdam and the region. The airport creates international connectivity, creating prosperity for its users and employment for the city and the region. However, the airport’s operations are also detrimental to prosperity: through direct and indirect land take, noise pollution, nuisance, nuisance, adverse effects on the health of local residents and on the environment.

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The Swedish Aviation Industry Group (SAIG) is a non-profit making industry association which promotes, protects, and ensures that its member companies are not neglected with respect to political issues and lobbies for the continued survival and well-being of the Swedish air transport industry.

Airport charges The current ACD serves the right purpose and is appropriate for the economic regulation of airports. Market dynamics drives the outcome of charge consultations and pricing agreements. Using the ACD as guidance for Transparent, Non-discriminatory and cost-related consultations and price settlements works. It has supported commercial agreements in CPH for the past 15 years.

The Direction des Aéroport Régionaux Français of Vinci Airports welcomes the EC initiative and opportunity to provide feedback. Considering the preparatory work to revise the Council Directive 96/67/EC of 15th October, the following topics should be subject to discussion with the European Commission: Small regional airports are entrusted with the responsibility of providing local public services and infrastructure…

In Avianca we believe that the Slot Rules has been effective overall in supporting connectivity and competition for the EU aviation industry. We believe that the time is now ripe for the EU to refresh the SR to both align with the WASG and add additional provisions to ensure that the obligations of airports and coordinators are also fully addressed alongside those of the airlines and to enhance flexibility in the…

Nestes Input on the Fitness Check of EU Airport Legislation pertaining the Groundhandling Directive 96/67/EC Neste welcomes the Commissions initiative to carry out a fitness check of EU airport legislation to determine if it is still fit for purpose and delivering on its objectives.

Introduction: Aéroports de Lyon welcomes the fitness check conducted by the European Commission on airport legislation. Airports are crucial in the development of both regional and national economy. That is why its of an utmost importance for the regulators of all levels to ensure that the airports are not only offering a competitive level of charges, but also that the level of airport charges is sufficient for the…

Airport Charges Directive: the ACD is an efficient form of EU legislation, the proof being that it did not require a revision during COVID-19 crisis. It has produced a stable regulatory framework since its implementation, enabling Groupe ADP to successfully deliver an investment of over 460 M per year on the regulated scope since 2011, on behalf of passengers, airlines and other stakeholders.

VINCI Airports welcomes the fitness check conducted by the European Commission on airport legislation. Airports play a vital role in the aviation industry, with responsibilities extending far beyond simply providing infrastructure.

TCR, headquartered in Brussels, is one of the worlds largest independent asset managers of airport ground support equipment (GSE). Through our expertise in fleet optimisation, pooling initiatives and the transition to green GSE, TCR plays a key role in the decarbonisation of airport ground operations - as envisaged in the European Commissions political priorities.

Long recognized as an essential service, especially during the COVID-19 pandemic, express transport contributes to the competitiveness of the European industry by connecting European businesses and citizens to more than 90% of the world economy within 24 to 72 hours.

Fluko Flughafenkoordination Deutschland GmbH (FLUKO) appreciates the opportunity to comment on the Call for Evidence for an evaluation / Fitness Check as of 25 April 2024 In addition to our response we would particularly also like to refer to the responses given by the European Airport Coordinators Association EUACA to this CFE, which FLUKO fully supports.

Europeans For Fair Competition (E4FC) welcomes the European Commissions initiative to assess the current EU airport legislation through a fitness check. E4FC, a unique coalition of European airlines and unions representing airline employees, believes this review is needed to ensure comprehensive and consistent regulatory frameworks that remains effective in the rapidly evolving aviation landscape.

The European Airport Coordinators Association EUACA refers to the Call for Evidence for an evaluation / Fitness Check as of 25 April 2024 and would like to thank the Commission for the opportunity to comment. For the full comments please see attached document.

As the operator of Karlsruhe/Baden-Baden regional airport (EDSB/FKB), we are opposed to a revision of the EU Directive on airport charges (the Charges Directive). At our site, a large European low cost carrier dominates the market offering only point-to-point connections. Because of the market power of these and other airlines, we are already unable to impose cost-covering charges on the market.

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Elysian Aircraft (Elysian) is a European aircraft manufacturer reimagining the potential of battery-electric flight. Our E9X aircraft is designed for regional routes, transporting 90 passengers over distances up to 800 kilometres. Electric flying can only become economically viable and scalable with dedicated airport infrastructure and ground operations, backed up by a regulatory framework supportive of innovation.

Airport Charges Directive The ACD has a functional oversight in terms of market procedural contributions but the net benefit to the industry and travelling public questionable. The Directive places significant obligations on airports and has accompanied a downward trajectory to aeronautical charges in an Irish context.

Cargolux Airlines International S.A., Europe's leading all-cargo airline, would hereby like to share its recommendations for potential improvements to the Groundhandling Directive 96/67/EC, the Airport Charges Directive 2009/12/EC, and the Slot Regulation (EEC) No. 95/93.

The International Air Transport Association (IATA) is the trade association for the worlds airlines, representing more than 320 airlines and 83% of global air traffic. IATAs member airlines include many based both within and outside of the EU - that operate flights to/from or within Europe. We welcome the opportunity to comment on the fitness check of EU airport legislation carried out by the European Commission.

ERA welcomes the opportunity to comment on the European Commissions call for evidence on a Fitness Check of EU airport legislation. For regional airlines, any change to the Slot Regulation No 95/93 is likely to be detrimental to regional connectivity.

As a matter of principle, the Association of German Airlines (BDF) strongly advocates better and effective regulation of monopolies in the field of aviation and the liberalisation of ground handling services. More effective regulation and better ground handling services are essential for the competitiveness of the European air transport industry in its competitive relations with non-EU airlines.

Airlines for Europe (A4E) welcomes the opportunity to provide comments on the European Commissions fitness check of EU airport legislation. EU airport legislation should be able to contribute to an efficient and competitive EU-wide market for airport services.

While evaluating effectiveness, efficiency and coherence of the EU airport legislation, the Commission should aim to strengthen the competitiveness of the European aviation industry, to meet the increasing air transport demand and support the development of the sector, strongly committed in achieving decarbonisation goals.

AEROPORTI 2030, the Italian association that represents the airports of Rome Fiumicino and Ciampino, Venice, Verona, Treviso and Brescia - Italy's first and third largest airport systems, respectively - welcomes the opportunity to respond to the Commissions fitness check of EU airport legislation.

Aeroporti di Roma S.p.A. welcomes the opportunity to provide its views on the issues covered under the airport fitness check as per the attached file; at the same time, it communicates its availability to be involved in the planned targeted consultation activities as indicated in the consultation strategy.

Cologne/Bonn Airport’s comments on the fitness check of EU airport legislation on groundhandling services: Cologne/Bonn Airport refuses to tighten up European legislation on groundhandling services. The revision of the AAD Directive and in particular the planned further opening of the market would be counterproductive in terms of quality, efficiency and safety.

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Summary The Dutch Royal Schiphol Group (RSG) opposes a tightening of the European Airport Charges Directive (ACD) and the Ground Handling Directive (GHD). Extensive regulatory requirements are not appropriate against the background of the current market conditions and competitive environment.

Athens International Airport: The key concerns related to a potential revision of the Airport Charges Directive (ACD) include: 1. Regulatory Stability: Maintaining regulatory stability to encourage continued investment in airport infrastructure is key.

easyJet welcomes the opportunity to respond to the Commissions fitness check of EU airport legislation and supports the European Union's efforts to create a thriving aviation market. We acknowledge the EU's proposed objectives of fairness, transparency, and efficiency, but we believe one crucial element is missing: addressing the market power wielded by airports.

Flughafen Wien AG (FWAG) is directly concerned by the three above-mentioned legislative acts (the Fees Directive, Ground Transport Services Directive, Slots Regulation) and participates in the Call for Evidence. Background: The situation of European aviation has changed significantly in recent years. The COVID-19 pandemic and international conflicts (in particular the Russian invasion of Ukraine) have led to this.

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The member airports of the Association of Austrian Traffic Airports (AÖV) are strongly affected by the three above-mentioned legislative acts (the Fees Directive, Ground Transport Services Directive, Slots Regulation) referred to in the Call for Evidence (Ref. Ares(2024)3052573). As a matter of principle, it should be noted that: The situation of European aviation has changed significantly in recent years.

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The changes in the situation of European aviation in recent years (COVID pandemic, international conflicts, climate change, inflation, etc.) are particularly affecting many smaller regional airports such as Graz. Revision of the Airport Charges Directive (2009/12/EC) The Airport Charges Directive was transposed in Austria via the Airport Charges Act.

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CLECAT, the European association for forwarding, transport, logistics and customs services, is the leading voice on freight forwarding and logistics at the EU level in Brussels. We represent and are supported by 25 member organisations, working to promote a sound approach to transport and logistics across Europe, in support of the competitiveness of our industry.

Portway's contribution to the topic Fitness check of EU airport legislation Considering that European Airports face problems of lack of capacity and flight delays due to problems on the ground, not in the air, Portway, as a Portuguese handler, understands that there is an urgent need to improve the quality and efficiency of ground handling services.

In general, we support the views of ACI Europe. In addition, we would like to make the following clarifications: 1. Airport charges. In general, it seems important to better define the framework for the tasks of the regulator and the need to recognise the priority of the return on capital invested for the infrastructure manager.

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The pandemic has put Europe’s regional airports in an even more difficult economic situation. It is therefore particularly urgent and important for the EU to strengthen the position of smaller airports as an important location factor for their respective regions. Innsbruck airport therefore needs in particular two measures from the EU: 1.

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Dear Sir/Madam, Dear ladies and Gentlemen, please find our reply herewith. Thank you for being able to participate in the process. Please do not hesitate to contact us if you have any questions or provide more detailed feedback. Please find attached the response of Berlin Airport.

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Air Cargo Netherlands (315 members / forwarders, air cargo truckers, airlines, ground handlers and service providers) is the air cargo industry association in the Netherlands. ACNs primary goal is to develop the Dutch air cargo industry in the broadest possible way. We believe that the EU Slot Regulation which was adopted in 1993 no longer meets the times.

Continue to Incentivize Investments While Fostering Competition and Efficiency AviAlliance welcomes the European Commission's initiative to conduct a fitness check of EU airport legislation. It is a critical measure to advance the efficiency and competitiveness of European air travel and the aviation industry. Airports play a fundamental role in economic growth, connectivity, and regional development.

Airport Charges Directive Wizz Air would support an airport fee setting system which is as free as possible,and airports are able to offer incentives to airlines depending on their local priorities and strategy.Regulating these matters in a strict manner could mean that airports would become less autonomous to decide what and how they would like to incentivize.It could therefore result in the Airport Improvement…

Düsseldorf Airport is very critical of the tightening of the European legal framework for airport charges and the intended liberalisation of ground handling services (BVD). However, we see a need for reform with regard to the rules for the allocation of slots as well as the liberalisation of market access for non-European or destination airlines to German airports.

Airport charges In a European airport industry that is privately financed, to guarantee that airports can put in the investment required, the regulatory stability for the aeronautical business is paramount. This means that the economic regulation rules at European level need to remain consistent and in place.

Airport Charges The current Airport Charges Directive (the ACD) serves its purpose well. Importantly, it has established a framework for consultations that ensures transparency and non-discrimination as well as a complaints procedure. In Sweden, since the introduction of the ACD and implementing Swedish legislation, the consultation process has matured and improved in collaboration with the airport users.

Flughafen Stuttgart GmbH takes a very critical view of increasing regulation of airport charges and ground handling services (ramp site) and therefore rejects a stricter definition of the European legal framework.

ACI EUROPE key asks for the Fitness Check of EU airport legislation Airport Charges The Airport Charges Directive (ACD) is the right form of EU legislation for the economic regulation of airports. The 2019 EU evaluation indicates market forces, not the Directive, drive efficient outcomes, minimising the need for stringent regulation.

Airport charges Directive - Over-regulation must be avoided when revising the Directive. National legislation regulates this sufficiently and we do not see any changes at the EU level. Slot Regulation - when reviewing this regulation, please note the following: this regulation does not ensure the efficient use of airport infrastructure, as airlines do not always use their slots (slot mis-use or non-use).

Opinion/fitness check on EU airport legislation/Airport Salzburg Baseline: The current market and competitive situation is characterised by high regulatory location costs, market power of airlines and restrictive access to airport slots. — Although regional airports are often below the thresholds for regulation and seem not to be affected, there is often a scaling effect from larger airports to smaller ones.

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Airport Charges European airports, and especially regional airports with high seasonality such as those operated by Fraport Greece, have strong competition and little power when it comes to the setting of charges, with the airlines being the driving force and the decision-maker of the market.

The Hessen Ministry of Economic Affairs, Energy, Transport, Housing and Rural Affairs has the following opinion on the fitness check of the EU Airport Regulation Directive 2009/12/EC of the European Parliament and of the Council of 11 March 2009 on airport charges: The current legal framework on airport charges has proved its worth.

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Flughafen Zurich AG opposes a tightening of the European legal framework for airport charges and groundhandling services. Reforms in the area of slot allocation rules are necessary for efficient operations at airports and are therefore to be welcomed. Airports have to meet many infrastructure requirements, which require high levels of investment in safety, punctual operations and sustainability.

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Directive 96/67/EC of the Council of the European Union of 15 October 1996 on access to the market in groundhandling services at Community airports is applied in the Federal Republic of Germany and is implemented in the form of a national regulation. While it is generally welcomed that access to the groundhandling market is subject to certain requirements, it must be noted that those are too general.

The Ministry of Infrastructure and Water Management of the Netherlands has taken note of this "call for evidence" and intends to participate in both the public consultation (activity 2) and the planned targeted consultation (activity 3) as mentioned under the heading consultation strategy.

The Swedish Regional Airport, SRF, represents 32 non-state airports in Sweden and is grateful to receive the opportunity to give the following feedback back: SRF member airports are very small from an international perspective, but play a vital role in ensuring accessibility throughout the country.

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I am responding on behalf of UECNA - www.uecna.eu EC air traffic policy The THG-emissions of air traffic should be cut by lower traffic. Air traffic should become more expensive to give incentives to avoid traffic or to use more eco-friendly means of transport. We recommend to introduce kerosene tax and VAT to all flights. The directive 2009/12/EC should be modified.

The German Airports Association (ADV) is opposed to a tightening of the European legal framework for airport charges (ACD) and ground handling services (GHD). Extensive regulatory requirements are not appropriate against the background of the current market conditions and competitive environment.

The position taken by Geneva Airport on Fitness-Check of the European legislation on Geneva Airport Airport is opposed to a tightening of the European legal framework for groundhandling services. However, it seems important to complement the Airport Charges Directive to give airports greater capacity to guide their users towards the climate transition.

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The Bavarian State Ministry for Housing, Construction and Transport points out the following with regard to the fitness check of EU airport legislation: (a) Directive 2009/12/EC of the European Parliament and of the Council of 11 March 2009 on airport charges The current legal framework on airport charges is sufficient.

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