Bundesvereinigung gegen Fluglärm e.V.

We warmly welcome the promotion of renewable energies. We recognise that a huge effort and investment is needed to replace fossil energy with renewables; The availability of renewable energy is also limited. When using renewable energy, priority should therefore be given to applications with a high specific CO2 reduction potential.

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Aviation is an industry with high greenhouse gas emissions (CO2, NOx and other harmful substances) .We propose a reduction of air traffic . The share of air traffic of the CO2-emissions is about 2.4i% (Ref. 1)- But the total greenhouse impact is about 3-times higher. It is forecasted that air traffic will grow further with 3%-5% p-a-.

It is reasonable to reduce energy demand and thus greenhouse gas emissions through financial incentives. On the one hand, emissions trading and, on the other hand, energy taxes are being discussed. The first argument in favour of emissions trading is that it makes it possible to define definitive limits for emissions.

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We suggest to introduce a taxation of fuels for aviation. A taxation of kerosene is necessary to generate equal competition rules for all kinds of traffic and to give an incentive to save fuel used for air traffic.

EU Consultation ARES (2026) 54206208 Please find attached the statement of the "Bundesvereinigung gegen Fluglärm e.V." (BVF). The BVF is an organization based in Germany and regulated under Section 32b of the German Air Traffic Act (LuftVG); its purpose is to protect the environment from the adverse impacts of air traffic.

Please find enclosed the opinion of the Bundesvereinigung gegen Fluglärm e.V. (BVF – Federal Association against Aircraft Noise). BVF is an organisation established in Germany and regulated by the Luftverkehrsgesetz (LuftVG) § 32b, which aims to protect the environment from air traffic pollution.

Filed in German · English published by the European Commission

Aviation is an industry with high greenhouse gas emissions (CO2, NOx and other harmful substances) . The share of air traffic of the CO2-emissions is about 2.4% [1]. But the total greenhouse impact is about 3-times higher. It is forecasted that air traffic will grow further with an annual rate of 3%-5%. The engines may become more efficient, but also the greenhouse gas emissions will increase.

This initiative addresses passenger rights in the event of delays and cancellations, as well as protection in the event of insolvency. A very significant obstacle to the use of rail when travelling to airports is the cancellation of transport entitlements in the event of a delay by rail or (on the return journey) of the aircraft.

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We consider it very important to inform consumers about the climate-damaging GHG emissions associated with their consumption in order to encourage them to change their behaviour, and have repeatedly called for it in feedback and consultations. We therefore expressly welcome the intention to record emissions from transport and to inform consumers about emissions.

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Access to justice in environmental matters is unsatisfactory in many respects in Germany. Problem of model procedure In the case of large-scale procedures such as airport upgrades, sample proceedings are conducted with selected claimants; However, they may validly put forward only those points which concern themselves.

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It-for-55 calls for a reduction in air traffic. It should be borne in mind that, although alternative fuels can reduce CO2 emissions, other greenhouse gas emissions, which account for approximately 2/3 of the total climate-effective emissions, are not. We therefore suggest that rules be put in place not to allocate unused slots elsewhere, but rather to collect unused slots.

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The Bundesvereinigung gegen Fluglärm is a NGO, which is engaged against the negative impacts of air traffic. We appreciate this initiative of an European Year of Rail. It is important, to communicate the advantages of travel by train especially compared to air traffic.

The current Slot Regulation was based on the assumption that airports were constantly growing. Accordingly, the rules governing the receipt of slots and the allocation of new and released slots were laid down, not the withdrawal of slots. In summer 2022, it became apparent that some airports had allocated more slots than they could handle with acceptable quality.

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