Swedavia AB
Swedavia har uppdraget att driva och utveckla de tio flygplatser som ingår i svenska nationella basutbudet av flygplatser och ska bidra till en god tillgänglighet för Sverige och landets regioner.
ID: 309454430916-12
Lobbying Activity
Response to Revision of the Commission Guidelines on State aid in the aviation sector (airports and airlines)
4 Oct 2024
Swedavia welcomes the review of the guidelines on state aid to airports and airlines and would like to submit the following. From the European Commissions call for evidence, it is clear that the provisions on operating aid to regional airports in the guidelines have seldom been used. Swedavia assumes that one reason behind this may be the transitional period as such and the requirement for a business plan paving the way towards full operating cost coverage at the end of said period. Achieving full cost coverage was difficult (or impossible) for many regional airports when the guidelines were first adopted. Swedavia does not consider that the prospects have improved to any notable extent since then. Hence, operating aid pursuant to the guidelines is probably a tool that is difficult to use in many cases, which means that the importance of these provisions for ensuring connectivity is likely limited. Considering the difficulties for many regional airports to achieve full cost coverage, Swedavia considers that it would be more suitable to expand the exemption for operating aid to regional airports under the General Block Exemption Regulation (GBER) to include airports of up to 1,000,000 passengers. Swedavia does not consider that operating aid to such airports would be likely to affect competition in general. If safeguards are deemed necessary in respect of regional airports above a certain size (for instance 700,000 to 1,000,000 passengers), one option may be to include limitations in terms of e.g. distance/travel time to other airports for such categories. In addition to the above, Swedavia would like to refer to the observations to be submitted by ACI Europe.
Read full responseResponse to Fitness Check of EU airports legislation
5 Jun 2024
Airport Charges The current Airport Charges Directive (the ACD) serves its purpose well. Importantly, it has established a framework for consultations that ensures transparency and non-discrimination as well as a complaints procedure. In Sweden, since the introduction of the ACD and implementing Swedish legislation, the consultation process has matured and improved in collaboration with the airport users. A possible contributing factor to the constructive Swedish consultation climate may be what we call the Stockholm Forum on airport charges consultation, where we sit down several times per year with airport users and the independent supervisory authority (the Swedish Transport Agency) to discuss and agree on how to conduct consultations, such as the scope of information to be provided in cases where this is not set out in detail in regulations. Through the Stockholm Forum, we have been able to agree with the airport users on a number of points which used to be areas of conflict. In our experience, airport users have buying power and competition between airports is fierce. Airport users regularly threaten to move capacity to competing airports (often in other Member States). Therefore, the product as well as the airport charges (and visit cost) are of utmost importance when speaking to current and prospective airport users. We also consider that the ACD is well suited for the EUs Green Deal. For instance, since 2022 we have CO2 modulated airport charges in place at Stockholm Arlanda Airport and Göteborg Landvetter Airport, which were consulted and introduced within the framework set by the ACD. We also have separate NOx and noise charges since many years as well as measures to promote SAF. Since the end of 2020, Swedavias own operations are free from fossil CO2, and we now also have ACA 5 certified airports. Slots While the Slot Regulation generally works quite well for us from a Swedish perspective, our airports are not nearly as congested as some of the main hubs on the continent. Thus, we do see that the single European aviation market would benefit from certain changes and support the position set out in ACI Europes response to the Call for Evidence. In particular, we would like to see stricter rules on slot misuse and non-use, through a slot reservation system combined with requirements for timely handback of slots (which is an issue in Sweden). Also, we would welcome a broader take on airport capacity and the optimisation thereof. Often, the available capacity is not just a product of what the runway, terminals and airspace can accommodate, but of political or regulatory decisions on e.g. curfews or other external factors, such as limitations relating to border control (which is the responsibility of the Police Authority in our case). Groundhandling We consider that the Groundhandling Directive provides for a fair and balanced framework, not least with regard to market access. While it may be desirable for airport operators to define and enforce for instance minimum service levels, quality standards and decarbonization measures, we consider that this is generally possible within the framework provided by the directive.
Read full response