UNION EUROPEENNE CONTRE LES NUISANCES AERIENNES
UECNA
UECNA is the Europe-wide organisation representing airport communities before the European institutions and at the International Civil Aviation Organisation.
ID: 894548050960-89
Lobbying Activity
Response to ReFuelEU Aviation environmental labelling scheme
18 Oct 2024
From UECNA We appreciate this initiative. Anyway, it should be mandatory.We see some problems if labels are issued to the aircraft operators. In some cases airlines orderflights by other operators (Wet-lease, charter). In many cases customers buy package tours withoften unknown airline. We suggest that the sellers of tours should be labeled. We think, themethodology developed for aircraft operators is applicable also in this cases (Averaging of alloffers).We recommend to develop a labeling system also for all-cargo air transport services. Eitherpurchaser of air transport services and consumers bying products transported by planes should beinformed. We point to the fact that the specific CO2 emissions of cargo planes are about eight tonine times as much than of trucks(https://ibir.deutschebahn.com/2022/fileadmin/pdf/db_ib22_e_web.pdf , p. 71). Redeploying freightfrom plane to truck, train or ship has a large climate protection impact. Itr should be considered, thata relevant time advantage of air transport at shorter distances (at least up to 2000 km) is often notgiven. At least ware transported by plane should be labeled as flightware (without emission data).It is not sufficient to consider only the emissions of CO2, CH4 and N2O. Also the steam emissionsare a greenhouse gas which produce contrails; they must be included. The factor CO2eq/CO2 is not1.2, but about 3 (https://www.transportenvironment.org/articles/airline-contrails-warm-planet-twice-much-co2-eu-study-finds).
Read full responseResponse to Revision of the Commission Guidelines on State aid in the aviation sector (airports and airlines)
7 Oct 2024
Response from UECNA Generally, we do not agree with calls for state aid for air traffic. Aviation is a for the climate harmful industry; its emissions should be reduced by reducing air traffic.Air transport has the opportunity to organize itself in such a way that it can manage without state aid. It is often regional and national egoisms that lead to a race for aid. This hinders the positive development of European air traffic and the European economy. Subsidies that foreign suppliers receive should not be combated by European counter-subsidies, as this only leads to a race to the bottom. Instead, there must be air traffic restrictions in these cases. We see very critically the following subsidies and grants: - Airport discounts for selected airlines. Favoring airlines with high traffic volumes can be cost-related. However, it can also be a measure to hinder competition. - Ground handling. We do not support monopolistic ground handling services. Airport operators should not support this operations. - Support programs; Aairport incentives for more growth or for new flight connections. Often discontinue the new flight connections after the incentives expire. - Cargo services. The fees for freight at the airport are often very low and are cross-subsidized by passenger services. It should be noted that the THG emissions of cargo transportation by aircraft are about 25 times higher than those of trucks. Within Europe air freight services do not need to be subsidized, as there are sufficient alternatives in the form of truck transport. Why air freight from outside Europe should be subsidized does not make sense to us - Use of SAF. The use of waste-based SAF makes sense, but it is not necessary to subsidize it. E-fuels currently have no benefit for the climate. Their production requires much electricity from renewable sources, which is currently in short supply and only displaces other applications. - Hubs. New or expanded hub airports are under discussion at several locations in Europe. They should be profitable and must not be subsidized. Cross-subsidization of connecting flights by local passengers can also be critical. - Night flights; the cross-subsidization of night flights with fares below cost by day flights of local passengers because this steers air traffic in the wrong direction. - Noise protection; subsidization of air traffic through inadequate noise protection regulations, particularly at night (active and passive), or through the financing of noise protection by the state. Scientific literature has been pointing out for years that external effects must be internalized by the originator. - Regional airports. Industrialized nations derive their prosperity from the trying to achieve the maximumefficiency in their structures. The demand for airtraffic should also be met in the most efficient way. Whether this is via major airports or smaller regional airports is a matter of fair competition. - Outbound vacation flights, particularly at regional airports. - Interest rates on loans to the aviation industry by state development banks. If for example, countries such as China support certain companies in this way, usually this is branded as an unfair subsidy. Often, it is punished with increased customs duties. We believe: Subsidizing the cost of capital leads to the creation of false economic structures. - Capital cost. State-owned airports often do not generate a return on capital employed. All airports should not only generate an operating profit, but also give an acceptable return on capital. What measures can we accept? - New aircraft with ecological improvements. Subsidizing the purchase of new aircraft can be acceptable if, in return, aircraft that are more harmful to the environment (in particular noise) are scrapped before their normal decommissioning period. - Remote regions. We see exceptions to the ban on aid in the case of islands and very remote regions. John Stewart President UECNA
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