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Lufthansa Group

LHG

The Lufthansa Group is an aviation group with worldwide operations, including passenger airlines, logistics, maintenance, and training services.

Lobbying Activity

Meeting with Jens Gieseke (Member of the European Parliament)

4 Nov 2025 · Austausch zu EU-Verkehrspolitik

Meeting with Andreas Schwab (Member of the European Parliament)

4 Nov 2025 · Passenger rights

Meeting with Jan-Christoph Oetjen (Member of the European Parliament, Shadow rapporteur) and Airlines for Europe and

4 Nov 2025 · IATA working group visit - Air Passenger Rights

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

16 Sept 2025 · Air Passenger Rights

Meeting with Jens Gieseke (Member of the European Parliament)

16 Sept 2025 · Austausch zu EU Politik

Meeting with Hana Genorio (Cabinet of Commissioner Jozef Síkela)

12 Sept 2025 · Brussels Airways

Lufthansa Group urges EU to bridge green fuel price gap

4 Sept 2025
Topic — The Sustainable Transport Investment Plan provides a framework for decarbonizing aviation and waterborne transport.
Message — Lufthansa requests using EU emissions revenues to bridge the price gap between sustainable and fossil fuels. They propose a permanent book-and-claim system and extending emissions allowances to all international flights.123
Why — Bridging the price gap would protect the group from high compliance costs and competitive threats.4
Impact — Airlines currently benefiting from the 'island privilege' would lose their existing regulatory cost exemptions.5
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Meeting with Jens Gieseke (Member of the European Parliament, Rapporteur)

15 Jul 2025 · Fluggastrechteverordnung

Meeting with Magda Kopczynska (Director-General Mobility and Transport) and Brussels Airlines SA/NV

10 Jul 2025 · Exchange of views on the current challenges of the European aviation industry, including the competitiveness of the sector, the preparation of the Sustainable Transport Investment Plan and the state of play of the passenger rights proposal.

Meeting with Sabine Weyand (Director-General Trade)

10 Jul 2025 · Meeting with CEO of Brussels Airlines on impact of EU-US trade dispute on airline sector

Meeting with Angelika Niebler (Member of the European Parliament)

19 Jun 2025 · EU Defence Policies

Meeting with Jens Gieseke (Member of the European Parliament)

16 Jun 2025 · Austausch zu EU Politik

Meeting with Angelika Niebler (Member of the European Parliament)

13 Jun 2025 · EU Aerospace Policies

Meeting with Gosia Pearson (Cabinet of Commissioner Magnus Brunner)

5 Jun 2025 · EU visa policy

Meeting with Bjoern Juretzki (Head of Unit Communications Networks, Content and Technology)

2 Jun 2025 · Discussion about the state of play of the Data Act implementation at Lufthansa and the airline industry at-large

Meeting with Jens Gieseke (Member of the European Parliament) and Verband der Automobilindustrie

21 May 2025 · Austausch zu EU Politik

Meeting with Markus Ferber (Member of the European Parliament)

21 May 2025 · European economic and industrial policy

Meeting with Angelika Niebler (Member of the European Parliament)

20 May 2025 · General Exchange

Meeting with Kai Tegethoff (Member of the European Parliament, Shadow rapporteur)

29 Apr 2025 · Passenger rights in the context of multimodal journeys

Meeting with Apostolos Tzitzikostas (Commissioner) and

26 Mar 2025 · Aviation topics

Meeting with Raffaele Fitto (Executive Vice-President) and

26 Mar 2025 · Aviation sector challenges and global competitiveness

Meeting with Magnus Brunner (Commissioner)

26 Mar 2025 · Exchange of views on current and future challenges of the European aviation industry

Meeting with Anna Panagopoulou (Cabinet of Commissioner Apostolos Tzitzikostas) and Viasat, Inc

26 Mar 2025 · Presentation of services provided by VIASAT to aviation

Meeting with Magda Kopczynska (Director-General Mobility and Transport) and Airbus and

24 Mar 2025 · Exchange of views with EU aviation and land transport industry on key policy developments in Singapore and ASEAN

Meeting with Jens Gieseke (Member of the European Parliament) and Eni S.p.A. and Gerber Steel GmbH

11 Mar 2025 · Austausch zu EU Politik

Meeting with Angelika Niebler (Member of the European Parliament)

20 Feb 2025 · EU Transport Policy

Meeting with Svenja Hahn (Member of the European Parliament) and Microsoft Corporation and

14 Feb 2025 · Exchange on upcoming digital EU legislation

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

11 Feb 2025 · challenges for the aviation industry

Meeting with Birgit Sippel (Member of the European Parliament)

22 Jan 2025 · Interoperability & border management

Meeting with Filip Cornelis (Director Mobility and Transport) and

8 Jan 2025 · Exchange of views on the Lufthansa Group Resolution : "New visions for aviation to support a sovereign Europe"

Meeting with Daniel Freund (Member of the European Parliament)

7 Jan 2025 · General Exchange about Air Transport Agreement

Meeting with Magda Kopczynska (Director-General Mobility and Transport) and TotalEnergies SE and

6 Dec 2024 · Investments in sustainable liquid fuels production in the EU

Meeting with Sophia Kircher (Member of the European Parliament)

22 Nov 2024 · SAF & EU air transport agreements

Meeting with Andrey Novakov (Member of the European Parliament) and Airbus and

20 Nov 2024 · Security and Defence

Meeting with Magda Kopczynska (Director-General Mobility and Transport) and EU-ASEAN Business Council

20 Nov 2024 · SAF / Air connectivity – CATA / decarbonisation of transportation

Meeting with Tobias Cremer (Member of the European Parliament)

5 Nov 2024 · Defence industry

Meeting with Angelika Niebler (Member of the European Parliament)

5 Nov 2024 · EU Defence Policy

Lufthansa Group demands end to discriminatory aviation state aid

8 Oct 2024
Topic — Updating EU rules on state support for airports and airlines to meet climate goals.
Message — Lufthansa requests consistent rules for all airlines regardless of whether they operate from hubs or smaller airports. They urge the Commission to prevent public subsidies for non-viable airports and loss-making ground operations. Additionally, they propose new investment aid for sustainable fuels and purchasing more efficient aircraft.123
Why — Lufthansa would eliminate rivals' subsidy advantages and gain funding for green fleet upgrades.4
Impact — Regional airports and budget airlines would face higher costs without existing public subsidies.5
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Meeting with Jan-Christoph Oetjen (Member of the European Parliament) and EUROPEAN BUSINESS AVIATION ASSOCIATION

12 Sept 2024 · General exchange on current aviation topics

Meeting with Jens Gieseke (Member of the European Parliament)

2 Sept 2024 · Austausch zur Europapolitk

Lufthansa Group demands refinement of EU aviation emissions tracking

29 Jul 2024
Topic — EU regulation updating monitoring and reporting of aviation greenhouse gas emissions.
Message — The group requests alternatives to default fuel values, greater transparency in the Non-CO2 Aviation Effects Tracking System, and resolution of parallel SAF claiming issues. They argue default values overestimate climate impact and create systematic distortions.123
Why — This would reduce compliance burden and allow more flexible SAF allocation across routes.45
Impact — Environmental accuracy suffers if conservative defaults are replaced without rigorous validation.6
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Lufthansa Group urges holistic competitiveness check of aviation rules

6 Jun 2024
Topic — The European Commission is evaluating whether current airport legislation remains fit for purpose.
Message — Lufthansa Group requests a 'Competitiveness Check' to improve the global competitiveness of the sector. They advocate for effective regulation of airport monopolies and the liberalization of services in groundhandling.123
Why — Reasonable charges and effective regulation would reduce high costs for airline operations.45
Impact — Large airports lose the ability to maintain monopolistic control and maximize their revenues.6
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Meeting with Jan-Christoph Oetjen (Member of the European Parliament)

13 May 2024 · Special Lufthansa Group Livery

Response to Union-wide performance targets for the fourth reference period (RP4)

18 Apr 2024

Lufthansa Group is Europes biggest airline group transporting over 122 million passengers in 2023. Being one of the biggest payers for air traffic control charges in the Eurocontrol area, we have a high interest and depend on ambitious target that ensure that the services are provided in the most cost efficient and effective way maintaining a high level of safety and providing the relevant and necessary quality/capacity. On behalf of all Lufthansa Group Airlines (Austrian, Air Dolomiti, Brussels Airlines, Discover Airlines, Edelweiss, Eurowings, Lufthansa & Lufthansa Cargo, Swiss International Air Lines) we would like to comment on the draft EU-wide performance targets for the fourth reference period of the Single European Sky performance and charging scheme as follows: Summary: We thank the PRB and European Commission (EU COM) for considering our feedback given to the initial RP4 target ranges. The targets proposed are not ambitious enough to contribute in an ade-quate way to a more efficient and effective provision of ATC services in Europe. Safety is of utmost importance to aviation and safety standards must remain highest standards in Europe. Environment targets are not fit for purpose as the Great Circle Distance is not always and automatically the most fuel-efficient flight path. This shall be adequately addressed after having assessed the new monitoring indicators, latest in RP5. Capacity, meaning avoidance and reduction of delays, remains the biggest challenge. The RP4 target initially set at a lower level then at the end of RP3. Cost Efficiency target will only compensate for CPI and the additional resources put at ANSPs disposal will not result in a better service provision, as PRBs academic study has shown. In addition to this statement, Lufthansa Group supports the statements presented by A4E, BDF and IATA in full. Please find attached to this summary a detailed explanation for all the points mentioned above. Ultimately: Without effective and ambitious targets and penalties for not reaching them there are only three solutions: 1. States need to improve their own ANSP service provision in an effective way themselves; this has not effectively happened over the past decades. 2. Establish as national or EC regulatory authorities ensuring effective performance regulation; an option that is not pursued further in the most recent compromises for a revised SES framework. 3. States should bear their share of costs resulting from the self-caused inef-ficiencies and structural deficits of ANSPs. We also refer to the BDL posi-tion statement on Reforming the funding of air traffic control (20221123_f_BDL-position-paper-Reforming-the-Funding-of-Air-Traffic-Control-SGI.pdf) and the results from the mentioned A4E study. The Lufthansa Group thanks the European Commission to take our remarks and suggestions on board. We remain open to any discussion with you at any time, either on bilateral or multilateral exchange. If you have any questions and remarks about this statement, please do not hesitate to contact us at any time.
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Meeting with Didier Reynders (Commissioner) and

22 Mar 2024 · To discuss recent legislative proposals impacting airlines (the revision of the package travel directive and passenger rights).

Meeting with Wopke Hoekstra (Commissioner) and Airlines for Europe and

20 Mar 2024 · Aviation Summit - EU 2040 targets implication for air transport : carbon market diplomacy, and how to ensure competitiveness and prevent carbon

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

22 Feb 2024 · General Exchange on Aviation Policies

Meeting with Jan-Christoph Oetjen (Member of the European Parliament, Shadow rapporteur) and Airlines for Europe and

22 Feb 2024 · Stakeholder Meetings on Passenger Mobility Package

Meeting with Jens Gieseke (Member of the European Parliament)

13 Feb 2024 · Verkehrspolitik

Meeting with Christian Doleschal (Member of the European Parliament)

31 Jan 2024 · Aktuelle EU Themen

Meeting with Paolo Gentiloni (Commissioner)

11 Jan 2024 · Discussing the current situation and prospects of the aviation industry in Europe.

Meeting with Maroš Šefčovič (Executive Vice-President) and

11 Jan 2024 · Decarbonization of aviation

Response to Revision of the Union Customs Code

7 Nov 2023

Please find Lufthansa Group's position paper attached.
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Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean)

6 Nov 2023 · Aviation - Cargo operations and global supply chains

Meeting with Jens Geier (Member of the European Parliament)

5 Oct 2023 · Exchange on the Net Zero Industry Act (staff level)

Response to Review report on the Governance Regulation of the Energy Union and Climate Action

2 Aug 2023

GOVERNANCE REGULATION Lufthansa Group Input to Call for Evidence for an Evaluation Lufthansa Group has set itself ambitious climate goals aligned with the Paris Agreement and the EUs emission reduction targets. By 2050, Lufthansa Group aims to operate net CO2-neutrally, through more fuel-efficient aircraft, the use of Sustainable Aviation Fuels (SAF), the expansion of intermodal transport, compensation, and efficient operational and economic measures. To effectively stimulate and, consequently, to achieve the green transition in aviation, EU legislation must safeguard the competitiveness of European network airlines and hubs, maintaining their financial capacity to invest in climate transition measures and, at the same time, prevent carbon leakage. However, current EU climate protection legislation for aviation falls short in this regard. Fit for 55 measures, such as ReFuelEU Aviation and the revision of the EU Emissions Trading System (ETS), in their current design, induce carbon leakage and distort competition, putting European network airlines at a disadvantage compared to global competitors from outside the EU. This should clearly not be the aim of European climate policy. Therefore, Lufthansa Group calls on the European Commission to ensure that EU climate legislation has a competition-neutral design. This should not only apply to potential future legislation but also to the existing body of EU law. EU decision-makers must amend existing legislation that does not adequately address this issue to ensure fair competition and a global level playing field. In this context, the European Commission should assess whether an updated Regulation on the Governance of the Energy Union could be the appropriate venue to ensure that EU measures, designed to meet the objectives of the Energy Union and the EUs greenhouse gas emission reduction targets, are both carbon-leakage proof and competition-neutral in nature. If the European Commission concludes that this is the appropriate regulation for these criteria, the updated Regulation must also oblige the European Commission to complement EU legislation with corrective, competition-neutral solutions when EU regulation is not carbon-leakage proof. Only by ensuring that competitiveness and sustainability work in tandem can the EU make the European Green Deal a true success.
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Meeting with Frans Timmermans (Executive Vice-President)

28 Mar 2023 · Exchange of views on the Fit for 55 policies affecting aviation and on current and future challenges of the European aviation industry

Meeting with Valdis Dombrovskis (Executive Vice-President)

28 Mar 2023 · Aviation, green transition, level playing field, competitiveness, connectivity

Meeting with Henrik Hololei (Director-General Mobility and Transport) and KLM Royal Dutch Airlines and

28 Feb 2023 · Airlines operations in Japan

Meeting with Peter Liese (Member of the European Parliament, Rapporteur)

31 Jan 2023 · ETS Revision

Meeting with Alin Mituța (Member of the European Parliament, Shadow rapporteur) and Insurance Europe and European Alliance for Research Excellence

17 Jan 2023 · Data Act

Meeting with Sunčana Glavak (Member of the European Parliament, Rapporteur)

27 Sept 2022 · ETS Aviation and CORSIA Notification reports

Meeting with Adina-Ioana Vălean (Commissioner) and

21 Sept 2022 · Meeting CEO

Meeting with Alin Mituța (Member of the European Parliament, Shadow rapporteur) and Banco Santander, S.A. and

20 Sept 2022 · Data Act

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

7 Sept 2022 · slot relief for winter season

Meeting with Alin Mituța (Member of the European Parliament, Shadow rapporteur) and UNIFE

20 Jul 2022 · Data Act

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

25 May 2022 · Fit for 55, slots

Response to Update of common rules for the allocation of slots at European Union airports

23 May 2022

Please find attached the position of the Lufthansa Group regarding the European Slot Relief Rules. The Lufthansa Group welcomes the opportunity to provide input for an update of Council Regulation No. 95/93 (EU Slot Regulation). An updated EU Slot Regulation (e.g. temporarily for the next 2-3 seasons) should provide a mechanism to enable increased flexibility even on short notice and without further, repetitive legislative procedures, IF required by the still ongoing and unpredictable pandemic or further unexpected geopolitical events and corresponding significant collapses of passenger demand. The lessons from Omicron and other past pandemic experiences should be, that broadened and uniformly applied JNUS criteria and an optional provision to lower the usual slot usage hurdle of 80% on short notice, always depending on the extent of a renewed collapse of travel demand, will be a necessity during the (un-)foreseeable future. The Lufthansa Group therefore requests to include the following provisions in the (temporary) update of the EU Slot Regulation: a) Extension (for the next 2-3 seasons) of the mandate for COM to lower the slot usage requirement between 0% and 70% (instead of 80%) per Delegated Act if required by a correspondingly reduced EUROCONTROL traffic forecast and/or drop in industrywide forward bookings due to new waves and/ or Variant of Concern (VOC). For W22/23 we propose to leave the slot usage hurdle at 64%. b) Enhanced and expanded reasons and uniform application of JNUS due to extraordinary pandemic and/or geopolitical events, to enable airlines to react on short notice also in cases were travel/ flights are not prohibited, but official government advisory against travel is communicated/ published and traveling public acts accordingly. c) Priority for (e.g. cargo) carriers who operated ad hoc slots during the COVID crisis, if capacity is available in future seasons, so that they could gain historic rights.
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Meeting with Adina-Ioana Vălean (Commissioner) and

30 Mar 2022 · Meeting with CEO

Meeting with Frans Timmermans (Executive Vice-President)

1 Mar 2022 · Discussion on the Fit-for-55 package and the airline’s contribution to the EU’s climate goals

Meeting with Jan-Christoph Oetjen (Member of the European Parliament, Rapporteur) and eFuel Alliance

1 Feb 2022 · EU ETS Aviation

Meeting with Jakop G. Dalunde (Member of the European Parliament)

27 Jan 2022 · Fit for 55

Meeting with Barbara Glowacka (Cabinet of Commissioner Kadri Simson)

29 Nov 2021 · Online meeting with Joerg Meinke and Oliver Simonis who presented Lufthansa and SN Brussels view over the Commission proposal on the ETS, ReFuelAviation and Energy Taxation Directive.

Meeting with Didier Reynders (Commissioner) and

22 Nov 2021 · EU Digital COVID Certificate, travel restrictions

Meeting with Kadri Simson (Commissioner) and

28 Oct 2021 · Potential economic impacts of decarbonisation policies for the aviation sector. Current and future challenges of the aviation industry.

Meeting with Kyriacos Charalambous (Cabinet of Commissioner Johannes Hahn)

28 Jun 2021 · Discussion on Fit for 55 and the airline industry

Meeting with Johannes Hahn (Commissioner)

23 Jun 2021 · Discussion on the Green deal and the Fit for 55 package and the Transport policy

Meeting with Marian-Jean Marinescu (Member of the European Parliament, Rapporteur)

31 May 2021 · SES2+

Meeting with Henrik Hololei (Director-General Mobility and Transport) and Brussels Airlines SA/NV

12 May 2021 · Covid 19 impact on aviation, Sustainability

Response to Union-wide performance targets for the air traffic management network for the third reference period

15 Mar 2021

On behalf of all Lufthansa Group Airlines (Austrian Airlines, Air Dolomiti, Brussels Airlines, Edelweiss, Eurowings, Lufthansa, Lufthansa Cargo and Swiss International Air Lines), we would like to give feedback on the proposed EU performance target for the air traffic management network 2020-24 (RP3) in the attached statement. We appreciate that at least the European Commission is aware of its particular responsibility in this never-seen crisis situation and we hope that it will be able to convince the EU Member States that strict and ambitious targets are necessary for the remainder of RP3. We summarize the current proposal as follows: • The current situation is and remains volatile and the overall effect of the Covid-19 pandemic can not yet be assessed. It is very unlikely that by the time when performance plans are drafted and consulted a robust forecast for the reminder of RP3 will be available that forms the basis of a reliable performance planning. • Airspace users will for the foreseeable future not be able to offset any cost increases, regardless of nature, but especially by higher ANSP charges, with higher revenues. • The targets proposed are a first step into the right direction, but they lack ambition to finally kick-off the much needed reform of the European ATM. We can not support, that with those targets the system will “contain future financial risks, as well as achieve scalability and resilience. ANSPs will have to overcome the silos they are operating in and reform their way of working i.e. restructuring their companies and investing in new technologies, which will enhance digitalisation and enable cross-border services.” • Targets of the key performance areas capacity, cost-efficiency and environment need to be revisited and made more strict. Lufthansa Group has outlined its proposal in the respective paragraphs. The Lufthansa Group would like to thank the European Commission for taking our remarks and suggestions into consideration. We remain open to any discussion with you at any time, either on bilateral or multilateral exchange. If you have any questions and remarks about this statement, please do not hesitate to contact us at any time.
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Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans) and KLM Royal Dutch Airlines

11 Mar 2021 · Climate roadmap for aviation

Lufthansa Group Urges Fair Competition in Aviation Carbon Rules

26 Nov 2020
Topic — The European Commission is reviewing rules for the aviation emissions trading system.
Message — Lufthansa requests that airlines avoid paying twice for emissions under international and European rules. They call for tax exemptions on connecting flights and a delay in phasing out free pollution permits.123
Why — These measures would reduce regulatory costs and protect the group's financial recovery from the pandemic.45
Impact — Major non-European airline hubs would lose their current cost advantage over their European competitors.6
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Response to SESAR Common Project 1: Concluding the pilot phase of the SESAR deployment framework

11 Sept 2020

Please find attached Lufthansa Group's feedback to the CP1 consultation. This feedback includes: - Background - Impact CP1 on civil aviation - Recommendations - Lufthansa Group analysis
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Response to Possible revision of the Code of Conduct for computerised reservation systems (CRS)

3 Sept 2020

Lufthansa Group welcomes the recent publication of the Inception Impact Assessment (Ref. Ares 3635812 - 09/07/2020) on a potential review of the CRS Code of Conduct (Regulation EC 80/2009) and we appreciate the possibility offered to share comments on this Inception Impact Assessment. Lufthansa Group believes that legislation regarding computerised reservation systems (“CRS”) remains necessary to prevent abuse by market players in markets with no or little competition and to ensure the display of flight information to consumers in a transparent and neutral way. Today, effective competition between EDIFACT-based traditional CRSs, at present more commonly referred to as GDSs, is still lacking. In addition to this brief commentary, Lufthansa Group would like to provide our detailed position and comments on the preliminary identified possible policy options in the document attached. To summarize, Lufthansa Group recommends changes to the CRS Code of Conduct in support of enhanced innovation and competition in the industry. In the current commercial and regulatory environment, the dominant GDSs still have limited incentive to innovate or compete. The CRS Code of Conduct can play a key role, alongside existing competition law, data protection rules and legislation, to ensure the playing field is friendly for new entrants, whom in turn are able to drive innovation and competition benefiting everyone from consumers to agencies, airlines and the value chain as a whole. Lufthansa Group would like to stress its willingness to form part of a constructive dialogue with all relevant stakeholders throughout this review process and would like to thank DG MOVE for this opportunity to provide feedback on the Inception Impact Assessment and for its work to ensure continued advancement in airline ticket distribution.
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Lufthansa Group warns EU against double-taxing aviation emissions

28 Aug 2020
Topic — Amending the EU Emissions Trading System to align aviation with climate objectives.
Message — Lufthansa Group urges the EU to prevent double regulation and address competitive distortions. They demand that any reduction in free allowances be delayed until after the COVID-19 recovery.12
Why — This strategy would minimize compliance costs while shielding their hubs from foreign competition.34
Impact — Foreign carriers would lose the financial advantage of avoiding European carbon pricing.56
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Response to Revision of Regulation on performance and interoperability of surveillance for the single European sky

22 Jan 2020

The Lufthansa Group (LHG) representing Austrian Airlines, Brussels Airlines, Edelweiss, Eurowings, Germanwings, Lufthansa, Lufthansa Cityline and Swiss International Air Lines, welcomes the opportunity to provide comments and submits its position on the proposed changes to the Regulation. We appreciate and fully support the proposed amendments. Going beyond our full support we take the liberty to make this suggestion: The majority of not or non-OEM-supported GNSS equipped airframes will cease operation before end of 2025 due to reaching the maximum certified flight hours and/or flight cycles. Therefore, an extended date for permanent exemptions towards 31.12.2025 instead of 07.06.2023 could help to avoid disproportionate and unjustified high investment with limited return of investment without losing the momentum of the ADS-B implementation and negatively affecting first operational benefits as the modification of the remaining fleet has already started. Deliberations: On the Transitional phase until 07. June 2023 - Art. 2 (3), third para (“Operators of aircraft …..”): From LHG perspective, there had been lot of uncertainty in the past related to specification, certification and regulatory aspects, followed by late availability of certified and compliant technical products causing a late start of implementation on the airborne site. The currently set due date in June 2020 is even with best efforts hard to meet and would increase costs and significantly negatively impact aircraft availability increasing the risk of flight delays and cancellations. In the latest ADS-B implementation report, circulated by the SESAR Deployment Manager in December 2019 for Stakeholder consultation, the majority of the ANSPs reported end of 2023 as realistic date to provide separation services based on ADS-B as at least one of the surveillance layers. Concerning this timeline, a final due date in June 2023 is appreciated. On aircraft with initial C of A before 07. June 1995 exemption - Art. 2 (3), first para (b): LHG appreciates the permanent exemption for aircraft with first individual C of A before 07.June1995. Airframes of these build years are quite costly to modify due to the lack of concurrent avionics systems or non OEM-supported installations such as GPSSUs (or equivalent) as position source instead of a Multi-Mode Receiver installation which is a today’s standard on the Airbus A320 fleet. The latter affects also A320 family airplanes manufactured before mid of 1999. On permanent exemptions for aircraft that cease operation before 07. June 2023 in the SES airspaces – Art. 2 (3), second para, (iii) (“their operations will be ceased by 7 June 2023”): LHG appreciates the above general exemption. Especially aircraft close to their end of life but manufactured later than 1995 are the ones with disproportionate implementing costs, while the ground site (ANSPs) will not make use of ADS-B v2 technology before the anticipated phase-out. Additional notes: From LHG perspective, but for the moment not relevant to LHG operated fleets, EC should consider exemption clause reflecting disproportionate integration costs for A/C manufactured on or after 07. June1995. The ANSPs have to cover mixed operations anyway because of the lack of ADS-B regulations for several Airspace User groups (VFR flights, non-GAT). Therefore, the integration under disproportionate costs is not adequate. LHG would like to underline the necessity of timely adaptation to provide planning certainty for all stakeholders. For the Lufthansa Group: Rudolf Weiland, FRA L/TEC; rudolf.weiland@dlh.de; +49 69 696 90963
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Response to List of aircraft types and models exempted from meeting the requirements on data link services

5 Aug 2019

General: Lufthansa Group fully supports the initiative to exempt aircraft type/model combinations from the requirements of implementing rule 29/2009, Article 3(2) reaching the end of their production life or being produced in limited numbers or aircraft types/models combinations for which re-engineering costs would be disproportionate due to old design. Re-iterating the Lufthansa Group comments provided during the consultation cycle for COMMISSION IMPLEMENTING REGULATION (EU) 2019/1170, the drafted Annexes to the regulation should be updated as they are not exhaustive from Lufthansa Group perspective. The current version does not reflect disproportionate implementing cost due to aircraft types/models/avionics combinations and treats aircraft type/model combinations of different Airframe manufacturers unequally. Furthermore aircraft type/model combinations are exempted, althoughsolutions with acceptable re-engineering costs exist, while other aircraft type/model combinations from the first years of built with outdated avionics architecture are not listed as exempted. Two examples: 1) B737-300, B737-400, B737-500 vs. A320 Family of the first build years: Boeing changed the model name for the 737 airplanes when changing from the classic versions (737-300, 737-400, 737-500) to the NG (737-600, 737-700, 737-800). Exemptions are granted for those classic 737s. In contrast, Airbus A320 A/C in the classic version did not receive a model name change with the change from the classic to the enhanced version with changed avionics, including a major change in the datalink architecture. Following from this, Boeing 737 from the same build years as the early A320, which would be subject to the same disproportionate re-engineering costs due to the delivery with outdated datalink architecture in the same way, are exempted from the DLS implementing rule, while the A320 airframes have to be modified. 2) A340 vs. A320 of the first build years: The vast majority of the A340 airplanes have been delivered with the modern Airbus datalink architecture ATSU, similar to the later A320 family airplanes. While those are exempted permanently per Annex 1, the A320 family airplanes delivered with old datalink architecture, not supported by Airbus anymore, have to be re-engineered with multiple higher costs. Additionally, those old A320 airframes are the ones with the lowest benefits to the DLS implementation, since those are facing their planned phase-out within the next few years. A limited number will be operated beyond 2022 and therefore the automatic exemption according to COMMISSION IMPLEMENTING REGULATION (EU) 29/2009 amended by 2015/310 and 2019/1170, Article 3, Paragraph 3 (b) will not apply. For those aircraft, the retrofit costs would be disproportionate due to old design, but also due to high non-recurring costs for certification of limited number of aircraft. Request: In order to achieve equal treatment between the airframes of different manufacturers and to reflect re-engineering cost dependency on datalink architecture, as already done for other aircraft type/series/model listed in Annex 1 with its corresponding avionics related notes, Please append table presented in Draft Annex 2 with the following aircraft type/series/model and its corresponding notes: Aircraft type/series/model - Manufacturer - ICAO designation … … … A319-100 (1) - Airbus - A319 A320-200 (1) - Airbus - A320 A321-100 (1) - Airbus - A321 … … … Notes (1) aircraft equipped with Airbus ATSU datalink avionics are not exempted Final Remark: We kindly request feedback on our input to this consultation in oder to verify that it was considered and how it was evaluated. Many thanks. Dirk Zschunke, Thomas Körber
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Meeting with Henrik Hololei (Director-General Mobility and Transport)

28 May 2019 · aviation, SES

Meeting with Günther Oettinger (Commissioner)

28 May 2019 · EU transport and climate policy

Meeting with Violeta Bulc (Commissioner) and

15 May 2019 · Meeting with Annual Global Partner Council of Lufthansa Cargo

Meeting with Michael Hager (Cabinet of Vice-President Günther Oettinger)

14 May 2019 · EU transport and climate policy

Response to Clarifying the provisions for the data communication between aircraft and traffic controllers.

6 Mar 2019

On behalf of Lufthansa Group I submit the attached comment on this initiative. This comment replaces the earlier comment I submitted on 4 March (anonymous). Many thanks and kind regards Horst Bittlinger
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Meeting with Henrik Hololei (Director-General Mobility and Transport)

12 Sept 2018 · SES, CATAs, CORSIA

Meeting with Günther Oettinger (Commissioner)

30 Aug 2018 · EU Aviation sector

Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc)

4 Jun 2018 · Aviation issues

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

14 Feb 2018 · cargo issues

Meeting with Silke Obst (Cabinet of Commissioner Violeta Bulc)

8 Feb 2018 · Meeting with Mr Meinke

Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc)

25 Oct 2017 · Meeting Mr Meinke- aviation topics

Meeting with Matej Zakonjsek (Cabinet of Commissioner Violeta Bulc)

10 Oct 2017 · aviation strategy

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

5 Apr 2017 · Aviation Strategy

Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc)

1 Mar 2017 · Aviation issues

Meeting with Joshua Salsby (Cabinet of Commissioner Violeta Bulc)

9 Feb 2017 · Aviation

Meeting with Günther Oettinger (Commissioner)

7 Feb 2017 · European Air Trafic Policy

Meeting with Maroš Šefčovič (Vice-President) and

19 Jan 2017 · Aviation Strategy

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

13 Dec 2016 · GDS, A4E, drones

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

8 Dec 2016 · Aviation

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

23 May 2016 · Development cost charges, Airline ownership and control, GDS

Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union)

23 May 2016 · Current financial challenges for European airlines within the EU.

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

7 Apr 2016 · Mandates for EU Air service agreement, A4E, drones

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

16 Feb 2016 · aviation strategy

Meeting with Julie Fionda (Cabinet of Commissioner Marianne Thyssen) and Brussels Airlines SA/NV

8 Feb 2016 · EU aviation industry

Meeting with Maroš Šefčovič (Vice-President) and

22 Jan 2016 · Aviation Package

Meeting with Violeta Bulc (Commissioner) and

20 Jan 2016 · Meeting CEOs of european airline companies

Meeting with Jakub Cebula (Cabinet of Commissioner Elżbieta Bieńkowska)

2 Dec 2015 · Aviation Package

Meeting with Eric Mamer (Digital Economy)

25 Nov 2015 · Aviation package

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

25 Nov 2015 · Aviation Package

Meeting with Mathieu Fichter (Cabinet of Commissioner Corina Crețu)

16 Nov 2015 · EU Aviation Package

Meeting with Matej Zakonjsek (Cabinet of Commissioner Violeta Bulc) and KLM Royal Dutch Airlines and AIR FRANCE

7 Oct 2015 · Aviation package

Meeting with Violeta Bulc (Commissioner) and

2 Oct 2015 · Meeting representives of 5 airline companies

Meeting with Violeta Bulc (Commissioner) and

15 Jul 2015 · Meeting 4 CEO's of European airlines

Meeting with Joao Aguiar Machado (Director-General Mobility and Transport)

7 May 2015 · Aviation Strategy

Meeting with Denzil Davidson (Cabinet of Commissioner Jonathan Hill)

25 Feb 2015 · Financial Services Policy

Meeting with Violeta Bulc (Commissioner) and AIR FRANCE

20 Jan 2015 · Presentation of Deutsche Lufthansa Group and Air France / KLM

Meeting with Joao Aguiar Machado (Director-General Mobility and Transport) and KLM Royal Dutch Airlines and AIR FRANCE

20 Jan 2015 · Challenges and vision, Level playing field, Capacity: Slots & new airport infrastructure, Airport charges