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Europe Air Sports

EAS

Europe Air Sports (EAS) is the voice of sports and recreational aviation at the European level.

Lobbying Activity

Meeting with Erik Bergkvist (Member of the European Parliament, Rapporteur)

5 Jul 2023 · Möte (APA level)

Response to Countering the potential threat from Unmanned Aircraft Systems

22 Mar 2023

Established in 1988 as a non-profit organisation, and since 1994 affiliated to the global Fédération Aéronautique Internationale (FAI), the objective of Europe Air Sports (EAS) is the long-term promotion and protection of sports and recreational aviation in Europe. Membership comprises the National Aeroclubs of most European countries and the European air sports organisations for the different types of flying activities (gliding, hang gliding and paragliding, microlights, model flying, powered flying, instrument flying, light and experimental aircraft). Together these activities represent the interests of approximately 700.000 European recreational airspace users. As a highly affected stakeholder by the emergence of drones in airspace typically used by our members, EAS has been fully engaged in the EUs policies regarding drones (UAS). EAS would like to recall recital 34 of the EASA Basic Regulation (1139/2018/EU) which recognises the outstanding safety record of model flying in clubs or model aircraft associations: (34) Model aircraft are considered to be unmanned aircraft for the purposes of this Regulation and are used primarily for leisure activities. Delegated and implementing acts concerning unmanned aircraft, adopted on the basis of this Regulation, should take into account that such model aircraft have so far had a good safety record, especially those operated by members of model aircraft associations or clubs which have developed specific codes of conduct for such activities. In addition, when adopting those delegated and implementing acts, the Commission should take account of the need for a seamless transition from the different national systems to the new Union regulatory framework so that model aircraft can continue to operate as they do today, as well as take into account existing best practices in the Member States. Despite these good intentions aeromodelling has increasingly come under severe pressure from European, national, regional and local rules concerning airspace use, spatial planning as well as nature protection. New restrictions, including height, weight and pilot age limits, as well as no-fly zones, but also registration, training and permitting requirements for pilots, aircraft and flying sites have made it difficult, expensive or impossible to further exercise the sport in many parts of Europe. The disproportionate impact on aeromodelling is usually unintended. EAS strongly advises that the Commission takes the utmost care to rule out unintended negative consequences on the model flying community when touching upon security threats from drones. There are no known threats from model aircraft operations in the framework of clubs and associations and this should be recognised in the envisaged Communication regarding potential security threats from drones. EAS and our member organisation EMFU are available for a dialogue with DG HOME to work towards a meaningful and reasonable policy.
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Response to Evaluation of the European Union Aviation Safety Agency’s performance in relation to its objectives, mandate and tasks

16 May 2022

Europe Air Sports, the organisation representing sports and recreational aviation at EU-level, has been working with EASA since its establishment in 2002. The community represented, comprises approximately 700.000 European airspace users in the full range of powered and non-powered flying activities. The role of EASA encompasses a wide field of activities, including rulemaking, standardisation, international cooperation and gathering data or devising studies on aviation safety. It is a crucially important regulator for our members. Its rulemaking encompasses many aspects of sports and recreational aviation, including in the areas of licensing, maintenance, operations and certification. Over time EASA has evolved very positively from a regulator with apparently little interest in - or ambitions for - the needs and the promotion of the light, non-commercial segment of General Aviation, to a knowledgeable and highly constructive body, willing and able to address the needs of our sector. The Agency has become a true partner to light aviation, promoting and implementing a successful GA Roadmap, which is aimed at boosting the sector and regulating it in a proportionate and risk-based approach. EAS congratulates EASA for this development and thanks the GA-team and top-level management for their dedicated work. Forward-looking, we recommend that GA will be given an even more prominent role in the internal organisation of EASA. Our community, and a world-leading light aircraft manufacturing industry in Europe, should be reflected in a dedicated Unit or Directorate in EASA's organisational structure. Through its rulemaking, the Agency has already recognised that GA requires an approach that is quite different to the one appropriate for Commercial Air Transport. However, this is not yet fully reflected in its organisational structure and this should be corrected. With regard to future rule-making tasks, it is important to stick to the well-established rulemaking and consultation processes, so as to ensure the widest possible input from experts and the wider aviation community alike. More recently, the Agency has increasingly made use of accelerated or focused-type consultations, so as to speed up processes (e.g. 201910 High Level framework for the U-Space, 201912 EASA FCL revision RMT_194, 20210906 BIS Language Proficiency Assessment, 202009 BIS Road Gyroplane). While this has some benefits (mainly speed), we recommend that the utmost care is taken to involve the widest possible stakeholder community in the future. Thus, more restricted consultations should be limited to very specific cases, only.
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Response to Draft amendment of Annex XIV to the REACH Regulation

22 Jul 2021

Our constituency would be directly impacted by the inclusion of Tetraethyllead (TEL) in Annex XIV as this substance is a key component in 100LL aviation gasoline which is the only fuel that is currently certified and approved for use in over 16,000 General Aviation aircraft registered in the EU. This represents around one third the EU´s aviation fleet. We fully support the efforts of the EU and ECHA in support of the European Environmental objectives in general, and also more specifically in the case of TEL. Obviously, it needs to be ensured that hazardous substances are carefully controlled, and that citizens are always protected. Our industry, on a global level is already fully working towards finding a replacement high octane aviation gasoline without the additive TEL. However, such a replacement fuel without TEL has not been approved and we would therefore request the European Commission to postpone the inclusion of TEL in Annex XIV until such times as a replacement fuel has been successfully made available on the European market. It should be worth noting that over time TEL-consumption is already in a strong and continuing decline: understanding that only a few decades ago, Avgas 100LL containing TEL was the only aviation fuel available. This situation has clearly improved, and the trend is still continuing: Lower power piston-engines up to approx. 180 hp mainly run on lead-free aviation or automotive fuels, while larger piston engines over 400hp are gradually being replaced by turbine-engines consuming Jet A1. The first electric aircraft was already certified by EASA and entered the market with high success, with many more are expected to come soon. The agreed objective of our industry is to significantly further reduce the TEL consumption until it is no longer used for aviation fuel at all, and our efforts show positive results. We also fully support the PAFI programme in the United States with the objective to find a lead-free replacement for TEL. The PAFI-project has made good progress to date, but has not yet come to the desired result of phasing out TEL. In this context we would strongly suggest proper funding for a European research activity on a TEL-replacement. Over time such an activity could be complemented by research for a carbon-free piston-engine fuel. We are aware that this recommendation is clearly supported by the EASA. A promising interim solution worth consideration would be the use of Avgas 100VLL, “Very Low Lead”, with a substantially reduced maximum allowed TEL content by 20%, which is covered by the pertinent fuel-specifications. As a penultimate point we would strongly like to suggest revisiting the REACH risk assessment. After Brexit the relevant TEL-quantity should be around 90% below the magnitude of the 2018 figures in the current risk assessment. The reason is that the only remaining TEL-producer worldwide, “Innospec”, is based in the UK, and consequently the TEL-risk assessment of 2018 was still based on the figures of the UK company Innospec producing TEL for the world-market. The EU´s TEL-market only has a share in the order of 10% of the world-market. Finally, we would like to draw your attention to the need to avoid a foreseeable economic reaction, in which an authorisation for TEL is either not requested or granted: all Avgas 100LL supplied to aircraft in the EU would have to be made by shipping TEL from the UK to the USA, blending it, then importing it back from the USA into the EU, damaging the business of the current EU blending facilities and leading to significant environmental costs as well as additional shipping costs that would have to be borne by EU citizens. In conclusion, we see the risk that by the inclusion of TEL into the Annex XIV, the EU´s citizens would not benefit and the EU´s General Aviation industry, in most cases SMEs and private individuals would suffer from uncertainties and increased cost. Even the ecological cost for longer distribution channels would increase.
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Response to A Drone Strategy 2.0 for Europe

29 Jun 2021

Europe Air Sports, the European umbrella organisation of the National Aerclubs and the Air Sports Unions has been closely following the EU’s policy-making regarding drones and keeps contributing to the technical rulemaking at the level of EASA. As the European association representing sports and recreational aviation, Europe Air Sports represents a segment of aviation which is at risk of being negatively affected by the emergence of drones in airspace that is typically used also by our members. We commend the Commission and EASA for the thorough consultation processes around its drones policy and ask to be approached as part of the targeted stakeholder consultation pertaining to the study mentioned in the roadmap. Europe Air Sports agrees that - if regulated properly - drones have the potential to generate societal and environmental benefits. A fair and safe co-existence of manned and unmanned aviation will be an important prerequisite for this to work in the future.”
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Response to Revision of Regulation on performance and interoperability of surveillance for the single European sky

10 Feb 2020

Europe Air Sports welcomes this opportunity given to airspace users to comment the draft revision of the SPI regulation. We are pleased to see that aircraft of less than 5700 kg MTOM and 250 KTAS remain excluded from the ADS-B and EHS requirements of the regulation. Nonetheless, some of our aircraft flying IFR are affected by the requirement to be fitted with ELS transponders. This leads us to recall the need to ensure consistency among ICAO, EC and EASA relevant technical rules to the users' benefit. In this respect, we fully support detailed comments made so far by other affected stakeholders.
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Response to Detailed rules on unmanned aircrafts

3 Nov 2018

Europe Air Sports, the association representing the interests of sports and recreational level at EU level, has been following the EU's activities in the field of drones for many years. Our constituency encompasses a large variety of airspace users, ranging from aeromodelling, to non-powered flying activities such as gliding and hang-gliding, up to smaller powered General Aviation aircraft. These aircraft are frequent visitors in the lower uncontrolled airspace (class G) where drones will operate. Our members' activities are non-commercial. They have chosen aviation as their sport and hobby and pay for their flying activities out of their own taxed income. Together EAS represents approximately 650.000 European airspace users and European citizens. Our members are also heavily affected by the EU's activities in the field of aeromodelling including the Draft Implementing Regulation which is the subject of this consultation. In this context we want to recall the wording of recital 34 in the New EASA Basic Regulation, which is intended to guide the European legislator in this field: ”... when adopting those delegated and implementing acts, the Commission should take account of the need for a seamless transition from the different national systems to the new Union regulatory framework so that model aircraft can continue to operate as they do today, also by taking into account existing best practices in the Member States". In this context, Europe Air Sports fully supports the comments submitted by the European Model Flying Union. Please see the detailed attachment from EMFU.
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Response to Detailed rules on unmanned aircrafts

11 Apr 2018

Europe Air Sports, the association representing the interests of sports and recreational level at EU level, has been following the EU's activities in the field of drones for many years. Our constituency encompasses a larger variety of airspace users, ranging from aeromodelling, to non-powered flying activities such as gliding and hang-gliding, up to smaller powered GA aircraft with typically no more than 2-4 seats and using a single engine. Our members ' activities are non-commercial. They have chosen aviation as their sport and hobby and pay for their flying activities our of their own taxed income. Together EAS represents approximately 650.000 European airspace users and European citizens. As many of our flying activities take place in the so-called non-controlled airspace (class G) we expect to be among the most affected stakeholders related to the insertions of drones in such airspace. Safety is our number one priority and safety risks originating from drones are a major concern. We therefore insist that the insertion of drones in shared airspace requires the protection of existing manned airspace users. This means that the drones must be able to see and avoid other participants. As a non-profit sector we insist that any costs related to possible equipment requirements for our aircraft must be borne by the drones manufacturer and/or operator. Furthermore, such requirements must be limited to the bare minimum and the technologically feasible. For example, it is unimaginable that a hangglider should be required to carry a transponder. Furthermore, we want to recall that airspace is a common good. It must not be restricted to favour one group of airspace users over the other. Our members are also heavily affected by the EU's activities in the field of aeromodelling. In this context we want to recall the wording of the revised EASA Basic Regulation (pending formal adoption) inserted by the European Parliament, which is intended to guide the European legislator in this field: Recital 20(c) "Model aircraft are considered as unmanned aircraft within the meaning of this Regulation and are used primarily for leisure activities. The delegated and implementing acts adopted on the basis of Regulation and concerning unmanned aircraft should take into account that such model aircraft have so far had a good safety record, especially those operated by members of model aircraft associations or clubs which developed specific codes of conduct for such activities. In addition, when adopting those delegated and implementing acts, the Commission should take account of the need for a seamless transition from the different national systems to the new Union regulatory framework so that model aircraft can continue to operate as they do today, also by taking into account existing best practices in the Member States" Europe Air Sports has been proactively involved in the development of the Draft EASA Regulations for Unmanned Aircraft and was represented on the Expert Group. The current Draft EASA Regulations recognise the excellent safety record established over the last century by those model flyers who operate within the framework of organised Associations and Clubs and include provisions which allow model aircraft to be removed from some of the requirements intended for drones. This is entirely consistent with the terms of Recital 20(c). We wish to ensure that the recognition for model aircraft and associations/clubs within the Recital and the provisions for model flying within the EASA regulations are retained and respected. When working with EASA and at the later stage the EASA Committee in the field of the EU's technical rules on drones Europe Air Sports will continue to insist that the above mentioned principles are respected. We are committed to continue to contribute to these processes in a constructive yet targeted way.
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