Revision of EU rules on air services

Appreciation to the officials at DG MOVE for setting forward a public commenting opportunity over the proposed structural changes to the EU internal aviation market rules. 1. Commercial drone services should continue being regulated in drone legislation. Regulation 2019/947 covers licensing for specific category drones (operational authorization or light UAS operator certificate).

Europeans for Fair Competition (E4FC) welcomes the European Commissions call for evidence on the revision of Regulation (EC) 1008/2008, particularly the acknowledgement that EU airlines and their employees face numerous new challenges that need to be addressed.

The European Network Airlines Association (ENAA) believes that the Air Services Regulation, Regulation (EC) 1008/2008, has served well to further the EU internal market for air services. Its provisions remain fit for purpose until today and a comprehensive review as concluded by the 2019 evaluation of the Regulation is unnecessary.

Airbus commends the Commissions historical commitment to establishing the EU internal market for air services. This market has brought substantive economic and social benefits to EU citizens, including enhanced mobility routes, greater economic development, and the creation of a more competitive EU aviation sector. Additionally, Airbus welcomes the Commissions commitment to updating the Air Services Rules.

Consultation on Regulation (EC) 1008/2008 The shifting geopolitical landscape demands stronger aviation resilience. Airports must be able to invest rapidly in cyber-security, insider-threat defences and dual-use capacity; State financing for such measures should sit outside normal State-aid rules. The European Commission should clarify which public-interest operations qualify. Network resilience.

IATA is the trade association of the worlds airlines, comprising over 350 members in more than 120 countries, including 91 member airlines in the EU, and representing approximately 83% of the worlds total air traffic. We work with our airline members around the world and the air transport industry as a whole to promote safe, reliable, secure, and sustainable air travel.

Please find attached the response from the Swedish Aviation Industry Group (SAIG) (Transportföretagen Flyg, Svenska Flygbranschen) to this important consultation regarding EUs rules for air services. 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…

Pls find attached the slightly revised feedback from Air France-KLM on the call for evidence in the revision process of Reg. 1008/2008. I kindly ask you to disregard the feedback we sent last Monday June 9. The reply said: "To make corrections, you can unpublish your feedback and send a new one, if the feedback period is still open". That did not work, hence this new submission.

Please find enclosed the comments of the Directorate-General for Civil Aviation of Spain on the various specific objectives raised in the European Commission’s consultation on the possible specific revision of the Air Services Regulation, Regulation (EC) No 1008/2008 of the European Parliament and of the Council of 24 September 2008 on common rules for the operation of air services in the Community.

Filed in Spanish · English published by the European Commission

AESA, the Spanish national supervisory authority, would be in favour of relaxing the requirement of ownership and control of companies with operating licences in accordance with Regulation 1008/2008 (or perhaps it would be sufficient to introduce this flexibility by means of new Commission guidelines to replace the current ones).

Filed in Spanish · English published by the European Commission

HelvetiCA firmly opposes the European Commissions proposal to ensure overflight continuity during air traffic controller (ATCO) industrial actions, as outlined in its initiative to revise Regulation (EC) No 1008/2008. HelvetiCA considers this a direct threat to the fundamental right to strike, particularly in centres where overflights represent the majority of operations.

easyJet is one of Europe's largest airlines, offering a unique and winning combination of the best route network connecting Europe's primary airports with great value fares and friendly service. The airline operates over 340 aircraft on more than 1,000 routes to over 160 airports across 35 countries. Over 300 million Europeans live within one hour's drive of an easyJet airport.

Executive summary of the proposal: In order to maintain scheduled air services on routes which are deemed vital for the economic development of the region they serve, Member States may opt for Public Service Obligations (PSOs) on these routes. The framework for imposing PSOs is set out in Articles 16-18 of Regulation 1008/2008 on common rules for the operation of air services in the Community.

Transport systems are essential infrastructure for citizens and businesses in island regions in order to ensure territorial continuity and to address, at least in part, the problems arising from the competitive disadvantage associated with their particular geographical situation.

Filed in Italian · English published by the European Commission

eu travel tech welcomes the Commissions call for evidence for an impact assessment regarding the upcoming revision of Regulation 1008/2008 on Air Services. This revision is an historic opportunity to ensure full price comparability, reinforce passenger rights and advance the Green Deal by closing key gaps that have emerged since 2008. We therefore recommend: 1.

The ADP Group mainly endorses the proposals of ACI Europe in the context of this consultation and welcomes the initiative of the European Commission. The ADP Group calls for the future revision of Regulation 1008/2008 to make it possible to better adapt to the economic, environmental, social and geopolitical challenges surrounding the aviation sector in Europe, to the benefit of the competitiveness of the EU, its…

Filed in French · English published by the European Commission

BDL believes that Regulation 1008/2008 has worked quite well and sees no urgent need for a revision of the Regulation. Instead, European Commission should prioritize promoting the competitiveness of EU aviation.

The Carbon Capture and Storage Association (CCSA) is pleased to provide a response to the call for evidence for an impact assessment for aviation - EU air services rules (revision). The CCSA brings together a wide range of specialist companies across the spectrum of Carbon Capture, Utilisation and Storage (CCUS) technology, as well as a variety of support services to the energy sector.

LOT Polish Airlines' Position on the Revision of the Air Services Regulation (Regulation 1008/2008) LOT Polish Airlines welcomes the opportunity to contribute to the ongoing discussion on the possible revision of the Air Services Regulation, which remains the cornerstone of the EUs internal air services market. See attached file with our position.

ERA calls on the European Commission to prioritise regional connectivity in the revision of the EU Air Services Regulation No. 1008/2008 (Reg. 1008/2008). - Supporting consumers to better informed choices ERA strongly supports the need for a high level of price transparency when it comes to disclosing what is included in the ticket price (airport taxes, air fare, luggage, extras, etc.) in a standard, clear and…

IAG welcomes the opportunity to contribute to the European Commissions Call for Evidence on the revision of Regulation 1008/2008. The single market for aviation, underpinned by this Regulation, remains one of the European Unions most significant achievementsdelivering increased competition, lower fares, and greater connectivity for EU citizens.

Elysian calls upon the Commission to recognize battery-electric aviation in the revision of the Air Services Regulation as a means to promote environmentally sustainable connectivity with the following measures: Require the deployment of zero-emission aircraft on routes operated as Public Service Obligation (PSO); Maintain the possibility for environmental restrictions extending the scope to address not only CO2…

T&E welcomes the opportunity to give feedback to the EU Air Services Regulation. In view of the preparatory work to revise Regulation 1008/2008, T&E stresses the importance of using this revision as an opportunity to build on the Regulation to promote environmentally sustainable connectivity.

— Cost-shared Flights should be exempted from the requirement for an operating licence; Article 3(3) of the Regulation should be adapted accordingly in the interests of legal certainty. — Powered sailors should not be covered by the Regulation. — Article 8(3)(b) should be adapted to include the word sequence of operations instead of operations.

Filed in German · English published by the European Commission

Royal Schiphol Group (RSG) welcomes the European Commission call for evidence for an impact assessment of Regulation 1008/2008. Schiphol is among Europes major hubs, providing direct connectivity to over 300 destinations worldwide. Our extensive route network is of great importance for access to the EU and the Netherlands. Many of these destinations would not be sustainable if there was no hubbing at Schiphol.

Transparency and comparability of ticket prices are essential for consumers to make informed decisions when purchasing flight tickets. However, the consumers freedom of choice is hindered by fragmented policies of air carriers concerning hand baggage. A widespread trend in this context has been the gradual limitation of the cabin baggage size included in the basic fare.

Avinor AS welcomes the opportunity to provide input to the revision of the Air Services Regulation (ASR). We wish to call attention to Article 16(9) of the ASR which limits the contract period for PSO routes to four years (or five years under special conditions). The limited contract period is potentially impeding the need to replace existing aicraft operating Short Take-Off and Landing (STOL) airports in Norway.

EurECCA welcomes the call for evidence for an impact assessment with the aim to revise Regulation (EC) 1008/2008 on common rules for air services, aiming to make aviation more sustainable, resilient, and socially responsible, while preserving fair competition and high quality employment.

Skyscanner welcomes the European Commission's initiative to revise the Air Services Regulation and strongly supports modernisation efforts that enhance consumer choice and market competition. As a leading metasearch platform serving millions of European travellers, we understand the critical role that online travel intermediaries play in the air travel ecosystem by enabling consumers to compare prices transparently…

I attach the submission of members of the COST Action Air Transport and Regional Development, the European Aviation Institute and the German Aviation Research Society. Best regards Prof. Dr. [name removed] Director of the Institute for Transport and Development University of Applied Sciences [address removed] / Germany Email address: [email removed] Telephone [phone removed]

This joint submission has been prepared on behalf of International Airlines Group, S.A., Ryanair DAC, easyJet Airline Company Limited and Wizz Air Hungary Ltd. (all together, the Airlines). The Airlines hereby welcome the Call for evidence in relation to the potential revision of Regulation (EC) 1008/2008.

In the context of the public consultation launched by the European Commission for the revision of Regulation 1008/2008 by the CEAV: — To regulate the requirement for airlines to have insolvency protection for the benefit of passengers; and – to ensure greater transparency as to how ticket prices are shown by airlines, as well as to the ancilliary services offered on the various sales channels, from the start of any…

Filed in Spanish · English published by the European Commission

The Air Services Regulation (ASR) is currently failing aviation workers, passengers and responsible airlines in Europe. On behalf of thousands of European aviation workers, including aircrew, ground and air traffic management staff, the European Transport Workers Federation (ETF) welcomes this Call for Evidence as a step towards the much-needed revision of the ASR.

The Swedish Transport Agency has previously replied to questionnaires concerning the revision of Regulation 1008/2008 and refers in the first place to what has been stated there. We largely share the problem picture set out in the Invitation to submit comments in the context of an impact assessment, but would like to highlight two further areas of concern which should be addressed in a future revision of this act.

Filed in Swedish · English published by the European Commission

It is necessary to review the rules on the applicability of the emergency procedure set out in Article 16(12) of the EU Air Transport Regulation in order to ensure scheduled air services also in situations of sudden disruption of air services currently not covered by the emergency procedure.

Filed in Swedish · English published by the European Commission

ATCEUC firmly opposes the European Commissions proposal to ensure overflight continuity during air traffic controller (ATCO) industrial actions, as outlined in its initiative to revise Regulation (EC) No 1008/2008. ATCEUC considers this a direct threat to the fundamental right to strike, particularly in centres where overflights represent the majority of operations.

The Federal Chamber of Labour, representing almost 4 million workers and consumers in Austria, expressly welcomes the revision of the Air Services Regulation. Studies show that air transport workers and consumers need more effective protection and clear definitions and binding rules are needed to prevent unfair competition. The promotion of environmentally sustainable connectivity is strongly supported.

Filed in German · English published by the European Commission

This opinion is submitted by UILTRASPORTI Cabin Crew Section (PNC), an Italian trade union historically and currently among the most representative in the transport sector, with a strong presence in the National and International Civil Aviation. UILTRASPORTI is affiliated with the European Transport Workers Federation (ETF) and the International Transport Workers Federation (ITF).

Filed in Italian · English published by the European Commission

This contribution is submitted by UILTRASPORTI, Cabina Navigante Personnel Section (PNC), a national representative trade union in the transport sector in Italy, with a structured presence in the national and international air transport sector.

Filed in Italian · English published by the European Commission

U.di.Con. APS Union for Consumer Defence, member of the National Council of Consumers and Users (CNCU) and representative association at national level within the meaning of Article. 137 of the Consumer Code, expresses its appreciation for the European Commission’s aim of revising Regulation (EC) No 1008/2008 on air services, considering that an update of the legal framework for the protection of passengers’ rights…

Filed in Italian · English published by the European Commission

BDL believes that Regulation 1008/2008 has worked well and sees no urgent need for a revision of the Regulation. Instead, the European Commission should prioritize promoting the competitiveness of EU aviation. In case the European Commission moves ahead with a revision a few elements should be considered: 1.

The Air Services Regulation (Regulation No 1008/2008 on common rules for the operation of air services in the Community) is one of the EUs major success stories and remains vital for European airlines. The creation of the EU internal market for air services has benefited both the aviation industry and European consumers for years.

ATR welcomes the initiation of the revision process for Regulation No 1008/2008 and appreciates the opportunity to contribute its perspectives to the European Commission (DG MOVE). Our feedback is detailed in the attached PDF file. Sincerely, [name removed]

The Government of the Canary Islands considers it necessary to provide greater protection for airlines that are managed on the basis of solvency and economic liquidity, so as to limit access to public funding for those that do not comply, by means of restrictions on access to public funds, so that commercial growth operations are not carried out before they have returned the public funding.

Filed in Spanish · English published by the European Commission

The European Business Aviation Association (EBAA) submits its views for the Air Services Regulation revision. Business aviation generates 100 billion annually and supports 449,000 jobs. Serving 1,451 airports900 solely reliant on business aviationit accounts for 7% of European air traffic with over 4,100 based aircraft, ensuring vital point-to-point connectivity in underserved regions.

On behalf of the Confederation of Industry of the Czech Republic, we would like to submit the following comments and recommendations regarding the revision of Regulation (EC) No 1008/2008. We appreciate the opportunity to contribute to the consultation process and hope that our input will be helpful in refining the final version of the proposal. 1.

For the European Passengers' Federation (EPF), the revision of the Air Services Regulation should address the following priority topics: 1. Price transparency. To safeguard and enhance price competition and price transparency, specific provisions are needed with regard to ancillary services.

European pilots welcome the launch of the revision of the Air Services Regulation and aspire for the process to result in a tangible hard law that addresses the loopholes that currently exist in the provision of air services.

UILTRASPORTI, with regard to the amendment of the legislation in question, takes the view that: 1- national management and pre-existing legislation: UILTRASPORTI considers that air traffic disruption management is predominantly a matter of national competence. Many Member States have already adopted highly restrictive legislation to the point of almost questioning the right to strike.

Filed in Italian · English published by the European Commission

The AFU thanks the European Commission for the opportunity for stakeholders to express their views on the evolution of air services rules. This regulation is essential and structural for European aviation, since it lays down the conditions for preserving undistorted competition in this economic sector, and will have to meet the requirements of decarbonisation and the preservation of air connectivity in all…

Filed in French · English published by the European Commission

With regard to the need to revise Regulation No 1008/2008, you will find below specific elements and proposals from the SNPL, in order to remedy the grey areas left in European legislation and to combat social dumping and abuse. As these proposals date from 2021 or 2022, the numbering of the articles is no longer accurate, but these proposals remain up-to-date.

Filed in French · English published by the European Commission

1. Airline insolvencies:We support the adoption of a measure to better protect consumers in the event of airline insolvencies, by guaranteeing at minimum the reimbursement of tickets for unused flights or the value of unused travel vouchers.

Technical Contribution from the Canary Islands EU Air Services Regulation Review As Founder of Global3CCS and technical contributor from the EUs outermost region, I submit this input based on field-tested solutions and institutional interoperability practices.

Filed in Spanish · English published by the European Commission

Statement by BIG Fluglärm in Hamburg e.V. on the initiative Aviation EU rules for air services (revision) As an environmental organisation officially recognised under §3 of the German Environmental Legal Remedies Act (UmwRG), with a focus on aircraft noise protection and aviation ecology, we welcome the European Commissions initiative to revise Regulation (EC) No. 1008/2008.