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Arbeitsgemeinschaft Deutscher Verkehrsflughäfen

ADV

ADV is the national association representing the interests of German airports in aviation and transport policy.

Lobbying Activity

Meeting with Jan-Christoph Oetjen (Member of the European Parliament)

14 Oct 2025 · Current situation for the German airports

German airports demand permanent aid for smaller regional hubs

29 Sept 2025
Topic — The Commission is reviewing regulations that exempt certain state aid from prior approval.
Message — ADV proposes raising the threshold for operating aid to one million passenger movements. They request that these airports be exempt from notification to ensure long-term planning security.12
Why — This would reduce administrative burdens and costs for financially struggling regional airports.34
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Meeting with Stefan Köhler (Member of the European Parliament) and eFuel Alliance

3 Sept 2025 · Politischer Austausch

Meeting with Oliver Schenk (Member of the European Parliament)

20 May 2025 · Europäischer Luftverkehr

Meeting with Jens Gieseke (Member of the European Parliament) and European Confederation of Independent Trade Unions and European Regional Aerodromes Community

20 May 2025 · Austausch zu EU Politik

Meeting with Eddy Liegeois (Head of Unit Mobility and Transport)

7 Apr 2025 · Exchange of views on challenges of German airports.

Meeting with Gzim Ocakoglu (Acting Head of Unit Mobility and Transport)

7 Apr 2025 · Discussion on international aviation market, air service agreements and the state of German airports and aviation industry.

Meeting with Jens Gieseke (Member of the European Parliament) and Mercedes-Benz Group AG

7 Apr 2025 · Austausch zu EU Politik

German airports demand flexible procurement rules and higher thresholds

5 Mar 2025
Topic — Evaluation of European Union directives governing public procurement and concession contracts.
Message — ADV calls for higher procurement thresholds to reflect inflation and procedural flexibility. They seek to exempt energy purchases and ground handling from strict rules.12
Why — Higher thresholds and simplified procedures would drastically reduce airport administrative burdens.3
Impact — Environmental and social advocacy groups lose influence if sustainability requirements are weakened.4
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Meeting with Barbara Brandtner (Director Competition)

28 Jan 2025 · Revision of the 2014 State Aid Aviation Guidelines

German airports seek permanent state aid for small hubs

27 Sept 2024
Topic — The EU is updating state aid rules for airports and airlines.
Message — The organization requests permanent operating aid for airports with fewer than one million passengers and increasing investment aid to 100 percent. They also call for exempting these subsidies from notification requirements to reduce red tape.123
Why — Smaller airports would secure long-term financial stability while avoiding costly and lengthy administrative procedures.45
Impact — Airlines would lose specific support frameworks if dedicated start-up aid rules are abolished as proposed.6
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Meeting with Norbert Lins (Member of the European Parliament)

18 Sept 2024 · Exchange on relevant topics for the new legislative period

Meeting with Hildegard Bentele (Member of the European Parliament)

18 Sept 2024 · Transport Legislation

German airports urge slot reform while opposing stricter fee regulations

30 May 2024
Topic — Evaluation of European laws governing airport charges, ground handling, and flight slot allocation.
Message — ADV opposes tightening rules for airport charges and ground handling while calling for slot reform. They argue current slot regulations are no longer up-to-date and lead to inefficient capacity use.12
Why — Maintaining current rules avoids extra regulatory costs and prevents further overcrowding of limited airport apron space.34
Impact — Dominant airlines would lose their ability to use slot rules as a protectionist tool against competition.56
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German Airport Association Urges Broader Ground Handling Inclusion

2 May 2023
Topic — The initiative defines criteria for environmentally sustainable economic activities to guide investment decisions.
Message — ADV requests adding missing operations like refueling and crew transport to the taxonomy. They advocate for including all ground handling services and vehicles using renewable fuels.123
Why — This would allow more airport operations to qualify for green financing.4
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Meeting with Jens Gieseke (Member of the European Parliament) and Repsol, S.A.

24 Jan 2023 · Austausch zur EU-Verkehrspolitik

Meeting with Rachel Smit (Cabinet of Commissioner Adina Vălean), Walter Goetz (Cabinet of Commissioner Adina Vălean)

24 Jan 2023 · EU Slot Regulation

German airport association supports extending regional airport operating aid

12 Jul 2022
Topic — Amendment to allow continued operating aid for airports with low passenger volumes.
Message — The organization supports extending the transitional period for operating aid by three years. They request an unbureaucratic process without new notification requirements and suggest expanding simplified rules to airports with up to 700,000 passengers.123
Why — This extension provides regional airports with financial planning security to survive pandemic-driven losses.45
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Response to Update of common rules for the allocation of slots at European Union airports

24 May 2022

Airports welcome the opportunity to provide comments on the European Commission’s planned update of the Slot Regulation to maintain relief measures, as appropriate, due to the COVID-19 pandemic and the Russian invasion of Ukraine. ADV has supported the slot waiver instrument and its application in principle. This ensures basic connectivity, and existing flight plans remain intact during the recovery phase. However, both the German airports and ACI have always pointed out that slot waivers can only be temporary measures. Once the market has stabilized and recovered, there must be a return to the 80/20 rule. Current forecasts for European air traffic expect traffic to be close to pre-COVID levels by fall of this year. This should be the basis to return to the 80/20 rule. At the same time, major uncertainties remain, such as a new Corona wave or the consequences of the Russian-Ukrainian war. Extending the justified non-use exceptions of Regulation 2021/250 The primary intention of the forthcoming proposal is to enable coordinators to continue to grant Justified Non-Use of Slots (JNUS) for flight cancellations caused by measures intended to address the COVID-19 pandemic. Maintaining this possibility in response to COVID-related restrictions, and as required for flights affected by the war in Ukraine, would be an appropriate measure to allow continued flexibility and avoid Europe’s airports unduly losing valuable connectivity. It is essential, however, that these provisions remain measured, targeted, and reasonable. The EUACA guidance on application of COVID-related JNUS provisions, published in February 2022, sets a strong basis for this. It has provided a common framework, and its interpretation of these provisions ensures that the circumstances in which JNUS is granted are appropriate. JNUS provides important flexibility to respond to sanitary travel restrictions during the pandemic. During the COVID-crisis, German airports advocated for a practical application of the slot waivers, but also pointed out that these can only be temporary solutions. As soon as the market has stabilized and recovered, a return to the 80/20 rule should be made. This is expected for the winter season 22/23. The German airports support the Commission's approach to stick to the planned return to the 80/20 rule in principle in W22/23. At the same time, ADV members are in favor of giving the Commission the legal option to reduce the utilization rate for slots with a slot waiver, if this is justified for W22/23. Finally, the applicable basis of JNUS should be harmonized for European coordinators. "Force majeure" should not be limited to government actions but should also consider travel recommendations from internationally recognized institutes. This ensures a uniform assessment of a flight at origin and destination based on common EU regulation.
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Meeting with Jens Gieseke (Member of the European Parliament)

18 May 2022 · Austausch zur Verkehrspolitik

Meeting with Anne Funch Jensen (Cabinet of Executive Vice-President Margrethe Vestager), Yizhou Ren (Cabinet of Executive Vice-President Margrethe Vestager)

14 Dec 2021 · State aid policy and aviation sector

Meeting with Henrik Hololei (Director-General Mobility and Transport)

17 Nov 2021 · Traffic recovery, slots

Meeting with Gaëlle Michelier (Cabinet of Commissioner Adina Vălean), Walter Goetz (Cabinet of Commissioner Adina Vălean)

12 Nov 2020 · Meeting to discuss latest developments in aviation.

Response to ReFuelEU Aviation - Sustainable Aviation Fuels

21 Apr 2020

The German Airports Association ADV welcomes the opportunity to comment on the European Commission’s initiative “ReFuelEU Aviation – Sustainable Aviation Fuels”. Please find enclosed our submission. ADV
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Meeting with Gaëlle Michelier (Cabinet of Commissioner Adina Vălean), Walter Goetz (Cabinet of Commissioner Adina Vălean)

23 Jan 2020 · • Developments in the German and EU aviation markets (competition aspects in particular), • Potential revision of the Airports Charges Directive, • Green Deal, SES, Slots, CATA

Response to Evaluation of rights of persons with disabilities and with reduced mobility (PRM) when travelling by air

5 Sept 2019

Reference: „Ref. Ares(2019)5015925 - 31/07/2019“ - Comments on Evaluation Roadmap – Rights of persons with disabilities and with reduced mobility (PRM) when travelling by air (Regulation (EC) N° 1107/2006) Dear Madam/Sir, The German Airports Association ADV welcomes the opportunity to comment on this roadmap. ADV represents 22 international airports in Germany. The international airports of Austria and Switzerland as well as Budapest airport are closely associated members. The Federal and Länder Transport Ministries are represented in ADV’s Supervisory Board. Founded in 1947, and with a permanent representative in Brussels since 1995, ADV advises responsible ministries in Germany and EU institutions about all relevant topics with respect to airports. Please find enclosed our initial comments in this consultation process. ADV and our member airports are looking forward to the further evaluation process and will be pleased to contribute any data and assessments you may need. With best regards Michael Büsing Flughafenverband ADV (German Airports Association)
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Response to Evaluation - Groundhandling services at airports

12 Mar 2019

The German Airports Association (ADV) comments on the “Evaluation Roadmap Groundhandling services at airports”:as follows: The ADV takes note that all provisions of Council Directive 96/67/EC of 15 October 1996 are being evaluated. Key suggestions for the evaluation of Directive 96/67/EC: • It is not sufficient if the pending evaluation only covers the achievement of the specific aims across all Member States which are set out in the Directive. • It is especially important that the overarching aims of EU aviation policy (such as sustainability, social standards and environmental aspects) are included in the evaluation. Key observations regarding the implementation of Directive 96/67/EC: • The rules were transposed into national law in a comprehensive and timely manner. • The market liberalisation striven by the Directive has been achieved. To this end, Germany has determined the number of services providers for the individual airports. • On this basis, Germany has a functioning system for groundhandling services. • Due to their market power, airlines have been able to achieve significant lowering of prices. • The legal form of a Directive is appropriate and should be maintained. It gives Members States the necessary leeway in light of national requirements. EASA Basic Regulation (EU) 2018/1139: The European Commission has tasked EASA to develop joint rules for a reliable provision of groundhandling services: • It becomes evident that EASA wants to take a comprehensive approach to this end. • EASA is also basing its work on the following themes: operational standards, training, ground support equipment and staff turnover. • The ADV sees an opportunity herein to tackle deficits existing with groundhandling service providers. It is equally important to be diligent so as not to achieve over-regulation. ADV recommendations as to the next steps: • Any additional steps of the European Commission regarding the review of the groundling services Directive should not be taken before EASA concludes its work.
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Response to Standard forms for procurement notices

8 Mar 2019

Sehr geehrte Damen und Herren, anbei finden Sie die Stellungnahme des Flughafenverbands ADV zum Entwurf der neuen Vergabe-Bekanntmachungsvorschriften. Mit freundlichen Grüßen i.A. Rupert Hornig Leiter des ADV-Verbindungsbüros Brüssel Flughafenverband ADV
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Response to Prolongation of State aid rules reformed under the State aid modernisation package that expire by the end of 2020

7 Mar 2019

The German Airports Association (Flughafenverband ADV) welcomes the opportunity to provide initial short comments on the evaluation of the 2014 European Commission Guidelines on State Aid for Airports and Airlines. There is a need for reform on the following points: 1. Operating aid • There is a need for clarification on which activities should be defined as “non-economic activities” so that the financing thereof does not fall under relevant rules – e.g. airport tower services. • There is a need for clarification on how financial gaps are to be calculated. The ADV is of the view that all costs for materials and personnel as well as imputed depreciation and interest costs should be included in their entirety. The European Commission is currently basing its calculations on EBITDA considerations. This does not take into account depreciation and interest costs. • An assessment should be carried out on whether the transition period (2014-2024) is sufficient, or whether an extension of the current rules should be considered. This should be especially considered in light of the changes in the aviation market that have taken place over the last 5 years. 2. Investment aid • Funding of investments in the non-aviation sector should also be possible in case of persisting losses. This allows airports to attain positive results over the long term. To date, surpluses are required to be applied to cover losses in the aviation sector. • The existing statutory rules for airports under 200.000 passengers (SGEI) should also apply to airports up to 700,000 passengers. 3. State aid for airlines • The existing provisions pertaining to state aid for airlines can be left unamended. We will be pleased to offer our expertise and views in much more detail, and supported by data, in the further evaluation process.
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Response to Evaluation of the 2011 White Paper on Transport

7 Mar 2019

The German Airports Association (Flughafenverband ADV) has been closely following EU transport policy and aviation policy in particular for the last decades, maintaining a representation in Brussels since 1995. ADV took part in numerous European Commission consultations over the years and are a member of two expert groups of the European Commission (external aviation policy; environmental noise) so far. ADV represent all international airports in Germany, working together very closely with their associated members (airports in Austria and Switzerland, and Budapest airport) and ACI EUROPE. All German Länder (state) governments are members of ADV’s Supervisory Board. We welcome the opportunity to provide initial, short comments on the occasion of the launch of the evaluation of the 2011 White Paper on Transport and are pleased to offer our expertise and views in the further evaluation process (stakeholder/public consultations; expert interviews; conferences; etc). In our view, the 2011 White Paper on Transport and the follow-up initiatives – from our perspective this is mainly, but by no means exclusively the European Commission’s 2015 Aviation Strategy – have great merits. It would go beyond the scope of this initial, short consultation to mention them all. Just to mention two where we greatly appreciate the Commission’s efforts: solving limitations in airspace (SES II+); and concluding/negotiating comprehensive air transport agreements (CATA) with third countries. Having said that, there are European Commission initiatives of which we are not convinced that they would actually add value to a sensible EU transport/aviation policy, consumers, the economy, social standards or the environment. In particular, we are firmly convinced that the potentially upcoming decisions to revise the Airport Charges Directive 2009/12/EC, the Groundhandling Services Directive 96/67/EC (their evaluations are ongoing) and the Environmental Noise Directive 2002/49/EC would most likely bring more harm than good. On the other hand, there are two important issues on which the European Commission should act upon: • The Slots Regulation 95/93 must be revised in order to take account of the important market developments which have taken place since the last evaluation almost ten years ago (followed by the meanwhile outdated 2011 proposal, frozen in the legislative process since 2014) and to finally appreciate the key role airports do play with regard to slots. The current international guidelines (WSAG) and EU rules on slots reflect an outdated, airline-centric view on the aviation sector, which the Commission has given up (to their great merit) in the 2015 EU Aviation Strategy. • In the ongoing evaluation of the 2014 guidelines on state aid for airlines and airports, the Commission should take into account the current (which has changed severely over the past five years) and future market situation for airports. There is also a need for a number of clarifications in the current Guidelines (see separate ADV submission on the roadmap published on 7 February 2019). We will be pleased to offer our expertise and views in much more detail, and supported by data, in the further evaluation process.
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Response to Charges for the use of airport infrastructure

6 Dec 2017

On behalf of the German Airports Association (ADV), please find attached our response to the Inception Impact Assessment on the charges for the use of airport infrastructure.
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Meeting with Bodo Lehmann (Cabinet of Vice-President Günther Oettinger)

3 May 2017 · aviation package

Meeting with Bernd Biervert (Cabinet of Vice-President Maroš Šefčovič)

2 May 2017 · Aviation Package

Meeting with Henrik Hololei (Director-General Mobility and Transport)

11 Oct 2016 · Airport security, airport charges, ground handling

Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc), Matej Zakonjsek (Cabinet of Commissioner Violeta Bulc)

3 May 2016 · Aviation

Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc)

10 Dec 2015 · Aviation

Meeting with Bernd Biervert (Cabinet of Vice-President Maroš Šefčovič)

26 May 2015 · Energy Union Strategy; Transport and Aviation Package