EU Airport Legislation needs to be revised to better contribute to EU strategic autonomy
T&E's consultation response to the Fitness Check of the EU Airport Legislation
T&E strongly welcomes the European Commission's Fitness Check of the three pieces of EU airport legislation: the Slot Regulation, the Airport Charges Directive, and the Groundhandling Directive. To be fit for 2030 and contributing to the EU’s goals in 2035, 2040 and beyond, the legislation must be reformed to actively integrate the decarbonisation and industrial objectives of the European Green Deal and the Clean Industrial Deal, thus better contributing to EU strategic autonomy.
Slot Regulation
Sustainability considerations must be firmly embedded in the EU Slot Regulation, because the way airport capacity is defined and slots are allocated directly determines the environmental footprint of aviation. The number of slots available at an airport sets a ceiling for air traffic volume and therefore for CO₂ emissions, nitrogen deposition, noise pollution, and local air quality impacts.
The Slot Regulation should be amended in order to incentivise sustainability. This could be achieved by:
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ensuring capacity declarations effectively reflect specific environmental constraints; and / or
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integrating green criteria into slot allocation and mechanisms – such as the reservation of slots for sustainable operations – to promote zero-emissions aviation deployment and sustainable aviation fuels uptake.
This reform would improve environmental outcomes and strategic autonomy, strengthening Europe’s ability to manage its aviation system in line with the goals of the Green Deal and the Clean Industrial Deal.
Airport Charges Directive
The current design of the Airport Charges Directive for incorporating environmental costs contains fundamental weaknesses: environmental modulation of charges is optional and unevenly applied across the EU. This approach fails to systematically enforce the "polluter pays" principle, and does not create the consistent economic incentives necessary to achieve ReFuelEU targets.
The Airport Charges Directive should be revised in order to strengthen incentives for roll-out of clean technologies. This could be achieved by:
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making environmental modulation a systematic requirement for all large EU airports; and / or
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clear, robust, and mandatory provisions for providing charges modulation or specific exemptions for supporting zero-emissions aviation and operations using sustainable aviation fuels.
A revised Airport Charges Directive could harmonise key parameters and reporting obligations to ensure a level playing field across the European Union.
Groundhandling Directive
The rules of the Groundhandling Directive, designed to ensure competition in ground services, are insufficient to challenge the market power of incumbent fuel suppliers who often control key infrastructure such as hydrant systems and tank farms through long-standing consortia.
The Groundhandling Directive needs targeted clarification and strengthening to ensure fair, transparent, and non-discriminatory access to on-airport fuelling infrastructure for new and sustainable energy sources. This could be achieved by
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clarifying the regulatory treatment of centralised infrastructure, by mandating the publication of access fee methodologies, and /or
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strengthening monitoring and oversight procedures to guarantee compliance with ROTND principles - relevant, objective, transparent, non-discriminatory.
This would not only foster fair competition, but also underpin the infrastructure readiness required for zero-emissions aviation and sustainable aviation fuels deployment.
