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Consultation participation and their own register declarations, side by side. Counts, not judgments — participation is not influence.

Counts here are a floor, never a total: they cover the 583 consultation files tracked so far (42,224 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.

ASS
Aena SME, SA

Company · Spain

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
TE
49
files engaged
of 583 tracked
59
positions filed
in those 583 files
21.7
declared FTE
self-declared
26
EP accreditations
as declared to the register

Declared costs: not declared · in the register since 2010

Files both filed on (2)

EU taxonomy - review of the climate delegated act · Sustainable aviation fuels (ReFuelEU Aviation Initiative)

Register facts self-declared (snapshot 2 Sept 2026); cost bands are floors. Shared files are shared attention, not evidence of coordination.

What each said, in their own words

Their opening passages on the files they share, verbatim and in filing order. We do not summarize, compare, or characterize positions — read them at source.

EU taxonomy - review of the climate delegated act

Aena SME, SA · filed 14 Apr 2026 · source

Aena welcomes the European Commissions 2026 review of UE Taxonomy Delegated Regulations amending Delegated Regulation (EU) 2021/2139 and Delegated Regulation (EU) 2023/2486. The initiative addresses issues widely highlighted by stakeholders, including excessive complexity, insufficient clarity in the technical screening criteria, and challenges in practical implementation.

Transport & Environment · filed 14 Apr 2026 · source

T&E welcomes the opportunity to provide feedback on the revised draft delegated act and supports the ongoing efforts to simplify and streamline the EU Taxonomy criteria. However, we are deeply concerned that the current direction of revision risks lowering the overall level of ambition rather than improving the usability of the framework.

Sustainable aviation fuels (ReFuelEU Aviation Initiative)

Transport & Environment · filed 19 Apr 2020 · source

Overview T&E supports the introduction of a mandate for specific sustainable advanced fuels in the aviation sector, but only if certain conditions are met for such a mandate to provide both a clear environmental benefit and investor certainty.

Aena SME, SA · filed 21 Apr 2020 · source

Aena is one of the leading airport operator in the world by passenger volume and strongly supports the EU’s ambition to become the first climate-neutral continent by 2050. Achieving this ambition requires transformational changes to the broader systems in which we operate.

Transport & Environment · filed 5 Nov 2021 · source

Dear Madam or Sir, Please find attached T&E's position paper on the ReFuelEU Aviation Regulation, which includes our recommendations for SAF targets. We believe that the text has a solid basis, especially when it comes to its scope applying to all departing flights and its exclusion of food and feed crop-based biofuels.

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