Revision of the Commission Guidelines on State aid in the aviation sector (airports and airlines)

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.

Dear Sir/Madam, please find attached the opinion of the AUSTRIA Commercial Airports (AÖV) working group. Thank you for taking our points into account in the further reflections! Best regards [name removed] General of AÖV

Filed in German · English published by the European Commission

The Conference of Presidents of the Outermost Regions thanks the European Commission for giving it the opportunity to contribute to the public consultation on the guidelines on state aid to regional airports and airlines.

Filed in French · English published by the European Commission

Wizz Air welcomes the initiative to revise the 2014 Aviation Guidelines (the Guidelines), in particular as the aviation market has changed drastically over the last ten years in light of the impact from the global pandemic, economic and political factors, technological advancements, and sustainability efforts.

Electric Aviation provides an opportunity to continue to connect and move goods around inline with decarbonisation goals. The nature of aviation, the strict cyber security requirements and lengthy certification timelines however make electrification of this industry particularly challenging.

Air transport is a key infrastructure for island regions' citizens and businesses in order to ensure territorial continuity and partially bridge the gaps related to the distance from economic and administrative hubs in the mainland, as well as from health service providers.

Executive Summary daa welcomes the opportunity to engage in the public call for evidence about the need for revision and a potential prolongation of the European Unions guidelines for State Aid (public support) to airports.

Erfurt Weimar airport asks the European Commission to take note of the comments of Erfurt Airport (see Annex) and to take it into account when it plans to amend the Guidelines on State aid to airports and airlines (Air Transport Guidelines).

Filed in German · English published by the European Commission

Mr LUAF thanked the European Commission for the opportunity given to stakeholders to control the evolution of the rules on State aid in air transport. This regulation is essential and structuring for European aviation, as it sets the conditions for preserving undistorted competition in this economic sector, and will have to meet the requirements of decarbonisation and preservation of air connectivity in all…

Filed in French · English published by the European Commission

With regard to the invitation to submit data for an impact assessment in connection with the revision of the Commission’s Guidelines on State aid to airports and airlines, we would like to draw your attention, as the national State aid authority, the Ministry of Finance, which is required by the competent authority at national level, the Ministry of Transport and Communications of the Republic of Bulgaria.

Filed in Bulgarian · English published by the European Commission

Given the current economic and legal situation in the aviation market, and in particular the changes caused in recent years by external factors such as the Sars Cov-2 pandemic and Russia’s military aggression in Ukraine, and taking into account the need for the aviation industry to adapt to the rapidly changing economic, political and environmental realities (including the green transition), Poznań Ławica Airport…

Filed in Polish · English published by the European Commission

Avinor is the main airport operator in Norway, wholly owned by the Norwegian Ministry of Transportation. The development of technology in the coming years is crucial for achieving the goals set out in the EUs Green Deal. For new technologies to be adopted, they need to be both developed and facilitated, which are both costly.

The Aviation sector is currently under transformation. New and innovative modes of transportation like VTOL (vertical takeoff and landing) aircraft as well as new technologies, like electric or hydrogen propulsion systems and energy storage systems for aircraft, are currently under development and certification is imminent.

Assaeroporti, the Italian airports association, welcomes the opportunity to provide its contribution to the Call for Evidence for the revision of the Aviation State Aid Guidelines. Over the last years, the aviation sector has been significantly impacted by market structural changes, severe geopolitical threats, and an unprecedented global pandemic.

The Association of Regional Airports in Poland, as an organisation representing 11 out of 15 international airports in Poland, submits its position in connection with the public consultation on the revision of the Aviation State Aid Guidelines, pointing to the need to carry out a revision in view of economic and political changes, as well as the change in the market environment of airports following the COVID-19…

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In relation to the call for reviewing and adapting the EU guidelines on state aid for airports, the Ministry of Transport welcomes the need for a flexible approach, especially considering the diverse challenges faced by different Member States.

Dear Sir/Madam, please find in the attached document our opinion on the revision of the Commission’s guidelines on airports and airlines. Yours sincerely, Claus-Dieter Wehr Flughafen Friedrichshafen GmbH, Managing Director/CEO

Filed in German · English published by the European Commission

ACI EUROPE welcomes the opportunity to respond to the call for evidence review of the European Commission (EC) Guidelines on State Aid to airports and airlines (hereinafter the Aviation Guidelines). The role of airports for the EU economy and society is highly important in an age of intense economic competition, increasing inequality, unchecked industrial policy from Europes economic competitors, and growing hostile…

State aid in the aviation sector/Commission guidelines on airports and airlines (revision) Dear Sir/Madam, Flughafen Paderborn/Lippstadt GmbH supports the Commission’s plan to revise the Guidelines on State aid to airports and airlines (Air Transport Guidelines). In the context of the public consultation, we would like to comment as follows: 1.

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EVIA AERO is a sustainable aviation company with an end-to-end concept; we invest already now in renewable power generation and storage at regional airports to operate our zero-emission aircraft fleet in the future. Our mission is to build a sustainable regional airport network using state-of-the-art hydrogen and electric aircraft technologies taking the sky by the end of this decade.

Response from UECNA Generally, we do not agree with calls for state aid for air traffic. Aviation is a for the climate harmful industry; its emissions should be reduced by reducing air traffic.Air transport has the opportunity to organize itself in such a way that it can manage without state aid. It is often regional and national egoisms that lead to a race for aid.

Stuttgart Airport, as a provincial airport, is an important infrastructure connecting the economic area and the region of Baden-Württemberg to the world. Current developments in the air transport market, with lower competition in airlines in Europe due to high regulatory costs of location, undermine the need for planning certainty for long-term investments by airports.

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On behalf of Danish Aviation, an aviation trade association under the umbrella of The Confederation of Danish Industries, we have the following comments to the consultation regarding revision of the Aviation State Aid Guidelines. Danish Aviation count most Danish-based airlines, airports, and GA-companies as members. The consultation basically touches on 4 key questions, i.e. 1.

AEROPORTI 2030 - the italian association rapresenting the airports of Rome Fiumicino and Ciampino, Venice, Verona, Treviso, Brescia, Bari, Foggia and Taranto - welcomes the call for evidence launched by the European Commission in view of the revision of the Guidelines on State aid to airports and airlines. Find attached our detailed feedback.

We welcome the Commission’s intention to revise the guidelines on state aid to airports and airlines. The previous guidelines primarily reflect the competitive situation of airlines. They do not take sufficient account of the fact that aerodromes are primarily infrastructures for mobility and connectivity, rather than for competition.

Filed in German · English published by the European Commission

State aid for investment aid to airports, the financing of activities carried out by the airport which normally fall within the competence of the State in the exercise of its public powers (maintenance of airport firefighters, medical care, airport safety and security control, customs and passport control, etc.

Filed in Polish · English published by the European Commission

As a player fully committed to promoting and developing hybrid-electric solutions (regional aircraft and propulsion system) to decarbonize and decentralize the air operations, we are convinced that these guidelines should frame the airlines and airports ecosystems towards: - The opening up of remote areas, today suffering from a lack of connectivity with the other regions, through the development of a more dense…

Elysian is grateful for the opportunity to respond to this Call for Evidence for an Impact Assessment on the revision of the 2014 Guidelines on State aid to airports and airlines (the Aviation Guidelines). We support the aim of the Call for Evidence, to revise the guidelines on state aid in the aviation sector an align them with the objectives of the Green Deal, while preserving connectivity and supporting…

Regions of France represent the French regions vis-à-vis the public authorities. This contribution was adopted by its Mobility Committee on 2 October 2024. France has more than 300 public aerodromes, the result of a century of aeronautical development. Around 60 airports operate there on a regular basis, with traffic of a few thousand to several million passengers per year.

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Summary For Sweden and the EU, it is of utmost importance that there is the possibility to provide operating aid to our airports. The General Block Exemption Regulation (GBER) is an effective basis for it, but the forms of aid need to be modernised and developed. In view of increased safety and availability requirements, smaller airports need a higher limit on when operating aid may be granted.

Filed in Swedish · English published by the European Commission

Flughafen München GmbH is happy to provide a statement supporting the EU Commissions revision of state aid guidelines for airports and airlines. In general Munich Airport recommends adjusting the aid thresholds and reducing administrative burdens to better support airports.

We believe the European aviation sector requires more attention on the development of SAF capacity and feedstock supply chain behind it, given the size of the European Jet Fuel demand, and the expected growth in the future.

Swedavia welcomes the review of the guidelines on state aid to airports and airlines and would like to submit the following. From the European Commissions call for evidence, it is clear that the provisions on operating aid to regional airports in the guidelines have seldom been used.

Reply to the European Commission's Call for evidence for an impact assessment - revision of the Commission guidelines on airports and airlines The Danish Ministry of Transport welcomes the Commission's plans on reviewing and possibly amending the 2014 Guidelines on State aid to airports and airlines with the purpose of ensuring the effectiveness and efficiency of the Guidelines in light of the current aviation…

Almost all types of subsidies distort the competition. There are so many airlines on the EU market that supporting anybody is no longer necessary. We may allow for free competition. Airlines like legacy carriers or so called "low-cost" carriers enjoy privileged position thanks to subsidies coming from central or local governments. This is against market rules. The distortion of the market was huge during pandemic.

As the operator of Karlsruhe/Baden-Baden Regional Airport (EDSB/FKB), we are in favour of a revision of the EU guidelines on State aid to airports, as it is essential for us to have planning certainty beyond 2027. State aid covers both operating aid and investment aid.

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The Federal Chamber of Labour (BAK) is the statutory representation of the interests of around 3.9 million workers and consumers in Austria. It represents its members in all social, educational, economic and consumer policy matters, both at national and EU level. In addition, the BAK is part of the Austrian social partnership. The BAK is registered in the EU Transparency Register with number 23869471911-54.

Filed in German · English published by the European Commission

Regarding this Guidelines Revision, Airport Regions Council: . welcomes the initiative as State aid to airports and airlines is key aspect of the EU Aviation policy . considers that even if its not the concrete goal of the Guidelines Revision and that is a really difficult task, EU should deep on the idea of connectivity, especially of the level of connectivity.

In practice, the current 2014 Guidelines on State aid to airports and airlines are almost unusable in the area of start-up aid to airlines (start-up of new routes from regional airports and airports located in remote regions). This is also shown by experience from the previous application of the guidelines.

Filed in Czech · English published by the European Commission

With reference to the public consultation launched by the European Commission on the revision of the guidelines on State aid in the aviation sector, it should be stressed that measures should be taken to assess, verify and adapt the Guidelines to the rapidly changing economic, political, industrial and environmental realities.

Filed in Polish · English published by the European Commission

In the light of current developments in the air transport market, airports need planning certainty beyond 2027. The ADV airport association therefore supports the Commission’s plan to amend the Guidelines on State aid to airports and airlines (Air Transport Guidelines). This concerns both operating aid and investment aid. Our detailed opinion can be found in the attached document.

Filed in German · English published by the European Commission

The Bavarian State Ministry for Housing, Construction and Transport has the following comments on the Commission’s State aid survey on airports and airlines (revision): We support the European Commission’s objective of adapting support for investment in air transport to the current situation in aviation and, above all, to simplify it in order to reduce the administrative burden on airports and competent authorities…

Filed in German · English published by the European Commission

Please find attached the comments from the Confederation of Swedish Enterprise and the Swedish Confederation of Transport Enterprises. Aviation plays a crucial role for Swedish businesses by facilitating international trade and business travel. Airports serve as important hubs for companies' logistics and supply chains, contributing to regional economic growth.

Consultation on a possible future revision of the Aviation Guidelines Concerned to the European Commission, DG Competition Unit F2, State Aid Transport Aviation, has a huge problem of its climate impact in relation to both CO2e per passenger-kilometre and tonnes of kilometres in relation to other greener means of transport, and because very often a huge distance is flown.

Filed in Danish · English published by the European Commission

What is regrettable with State aid rules is that it is difficult, if not impossible, to run an efficient company while being dependent on State aid as the State aid rules are designed today. It is necessary to make it easier for the owners to make temporary capital contributions so that the company can build up equity capital and thus meet its own investments for its own business.

Filed in Swedish · English published by the European Commission

When considering any financial support for regional airports, the initial justification should consider the estimated wider economic benefits in the region, the need to achieve regional balance, growth potential, ground transport infrastructure and local geography.