Environmentally sustainable and socially responsible connectivity in Europe - T&E consultation response

Restrictions of flight traffic on environmental grounds can play a key and complementary role as an effective and swift tool for CO₂ mitigation, providing a necessary and immediate decrease in aviation emissions. The full scope of Article 20 must be maintained and reinforced, recognising its role in promoting more sustainable transport modes including rail and zero-emission aviation, as well as multimodality. Adding unnecessary procedural requirements risks undermining the article’s effectiveness and potential as a tool rooted in national democratic processes.

The Public Service Obligations framework must be strategically leveraged to achieve

environmentally sustainable connectivity and to play a role as a test bed for zero-emission aircraft and sustainable aviation fuels (SAF). The Interpretive Guidelines must be updated to fully integrate environmental considerations, and the environmental award criterion must focus on quantifiable and verifiable metrics that guarantee emissions reduction.

Market distortions stemming from carbon leakage are marginal, if not minimal. Where some routes may be exposed, three potential policy tools could mitigate this risk: targeted SAF allowances, targeted carbon pricing between airport pairs, and a requirement for airlines routing via third-country hubs to buy certificates compensating for avoided ReFuelEU obligations (SAF-BAM).

A key aspect to be considered is the ability of passengers to make fully informed choices when it comes to the so-called ‘green fares’. Stronger guidelines should be ensured to provide better clarity for customers on the benefits of what they are buying, and green fares should promote the use of sustainable and scalable options, such as e-SAF.