Condor Flugdienst
Condor
Condor operates scheduled flights to leisure destinations in Africa, the Caribbean, Europe, South Asia and North America.
ID: 103804039463-51
Lobbying Activity
Response to ReFuelEU Aviation - Sustainable Aviation Fuels
18 Nov 2021
Replacing fossil kerosene with SAF is the decisive lever to achieve the goal of CO2-neutral flying. A binding blending quota can help accelerate the market ramp-up of SAF/PtL, therefore Condor Flugdienst welcomes the Commission’s approach as a boost for the SAF market. The ecologically best solution are fuels that are produced from atmospheric CO2, which is why the sub-quota for PtL is rated positively. The German aviation including Condor Flugdienst industry supports this goal and, together with the German federal government and other NGOs, has adopted a joint PtL roadmap at the beginning of 2021 (https://www.bdl.aero/de/publikation/ptl- roadmap/).
Our concerns with the draft and the suggested solutions (see also attachment) are:
A book&claim - approach is missing and must be enabled in the regulation to keep SAF supply chains as efficient and ecological as possible. It must be possible for individual operators to buy and use more SAF than what is required through the blending mandate.
We are welcoming that bypassing tankering (Art. 5) is generally addressed in the draft. It would however be necessary to find individual agreements between Member States/EU and the relevant third country (the respective air transport agreements). If a third country would not give its binding consent under international law, supervisory authorities from EU Member States may not be in the position to oblige foreign carriers to refuel at EU airports. This would result in competitive advantages for non-EU carriers, relocation of traffic to third countries or tankering outside the EU. To the extent that Art. 5 violates (international) law, the approach on tankering regarding international flights should be adjusted.
Right now, SAF prices are 3-6 times higher than conventional kerosene. The cost of kerosene makes up around 1/3 of the operating cost for airlines. This leads to the result that EU-carriers will be facing much higher costs than non-EU carriers, that will result in a massive distortion of competition and possible relocation of traffic from the EU and an incentive for intercontinental passengers to avoid transferring in Europe. The result is not climate protection, but loss of jobs in the EU and carbon leakage.
To enable the market ramp-up of SAF and at the same time prevent the consequences of distortion of competition and carbon leakage, we consider the following to be necessary and possible:
- For intra-European traffic (approx. 75 % passengers, 50 % traffic), the quotas are set as provided for in the draft regulation. However, to prevent carbon leakage, the costs attributable to feeder/transferring passengers must be excluded.
- For ex-EU traffic (approx. 25% passengers, 50% traffic), a separate regulation for binding quotas must be made: Ideally, a binding quota for the use of SAF should be agreed upon and implemented as quickly as possible at the international level (ICAO) for all international long- haul traffic (i.e., also ex-EU traffic). If a blending quota is imposed on international traffic in
the foreseeable future, the costs attributable to feeder passengers must no longer be excluded.
If the introduction of an internationally coordinated SAF quota fails in the foreseeable future (e.g., at ICAO level or in international air transport agreements) and the EU wishes to adhere to its plan to also impose a blending quota on international traffic until such a quota has been agreed internationally, it would be essential to take precautions to avoid carbon leakage.
Read full responseResponse to Union-wide performance targets for the air traffic management network for the third reference period
15 Mar 2021
The Gerrman leisure airline Condor Flugdienst GmbH refers to the joint comment of the German Airline association BDF on the draft implementing decision on EU performance targets for the air traffic management network 2020-24.
nternational air traffic is facing unprecedented challenges as a result of the Corona pandemic. The consequences for all parties involved are not even foreseeable yet. Only in Europe, traffic figures dropped by more than half last year. The slump in passenger numbers was even higher. The air transport industry will not see a full recovery for several years.
Cost reductions from all system-partners needed
The crisis requires a contribution from all system-partners in air transport and joint efforts by all stakeholders in reducing costs. Unfortunately, this common understanding of the situation is apparently not yet evident amongst air navigation service providers.
The European ANSPs are planning cost savings of only 1% for 2020 compared to their 2019 costs despite aircraft movements will be reduced by 55%.
The BDF fully understands that ANSPs cannot reduce the scope of their services in proportion to the decrease in traffic. But the planned savings are far too low and insufficient.
I our view, a cost reduction of at least 30% should and must be feasible and is urgently needed for all ANSPs. Few examples amongst ANSPs show that such a cost reduction target is achievable.
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