Public positions

L’investissement dans d’autres projets sur la connaissance et la conservation de la biodiversité contribue également à comprendre le dilemme associé aux services écosystémiques comme à la production des biocarburants durables. Si certains types de biocarburants destinés au transport routier peuvent avoir un impact négatif sur la biodiversité, le groupe Air France - KLM veut garantir l’utilisation de carburants aéronautiques durables qui ont l’impact le plus faible sur l’approvisionnement en nourriture, la biodiversité et un impact positif sur le développement local.

ORGANIZATION

Air France and KLM have public affairs delegates working directly with their respective authorities and declared in the lobbying registers of the French and Dutch parliaments, complying with the relevant legislation. Air France-KLM has two Brussels-based representatives to the European Institutions  registered in the EU Transparency Register.

All Air France-KLM expenditure for policy influence accumulates in 2020 to a total of €3,27 million (including staff costs for lobbying activities). The majority of these costs relate to memberships of national and international trade associations. A minor part is spent for the services of consultancies. Air France-KLM, Air France and KLM did not spend money for other policy influence activities such as support to political campaigns, individual politicians or any other political organizations or activity.

Air France-KLM is member of several national and international bodies that represent the air transport sector and advocate its public positions. We participate in major international associations such as IATA, Airlines for Europe, of which we are a founding member, the Airline Coordination Platform, Europeans for Fair Competition, European Regional Airlines Association and BusinessEurope. At national level we participate in general industry associations, specific aviation bodies and sustainability initiatives.

With these participations, we aim to provide (political) decision makers with the information necessary to understand the issues facing the airline industry (especially during the Covid-19 crisis), to drive the changes that we believe are crucial, and to advocate the effective implementation and application of national, European and international regulation to avoid any competitive disadvantage.

Covid-19 crisis and recovery measures

Immediately when the gravity of the crisis for our sector and the uncertainty of its duration became clear, we started to work with our partners to make sure alleviation of financial and operational pressure was achieved. We remained fixed on supporting aviation’s short and long-term recovery strategy, with strong policy wins such as deferring of ATM charges, securing airport slots relief for summer 2020, winter 2020/2021 and summer 2021 (avoiding the need to fly nearly empty planes to secure valuable slot positions), giving input on the EASA/ECDC Health Safety Protocol (on sanitary measures), EASA Guidelines on the use of passenger aircraft for cargo,  the use of refundable vouchers as an alternative to reimbursements within 7 days after request, development of an EU-wide Testing Protocol for travel and better coordination on EU travel restrictions.

We welcome the proposal for a Digital Green Certificate as an initiative that can support the restoration of the freedom of movement, once it is safe to do so and Air France-KLM will contribute as much as possible to the development of its technical specifications.We also call on the Commission to make sure the Digital Green Certificate is compatible with certificates developed elsewhere in the world.. We ask the Commission for continued support and leadership for a coordinated approach between Member States to border reopenings, ensuring an improved and effective European coordination of travel restrictions and requirements.

COMPETITIVENESS OF EUROPEAN AVIATION

The COVID-19 outbreak has an unprecedented impact on the airline industry. Air France-KLM works together with other network airlines and unions to protect the jobs in the industry and to safeguard the future of European aviation.

We call on the European Commission and the Member States to safeguard the European airline industry and our workers and to guarantee fair competition following the crisis:

  1. The European Commission and the co-legislators (Council of the EU and the European Parliament) should ensure that legislations stemming from the Green Deal presented by the European Commission on 11 December 2019, will not result in putting European airlines at a competitive disadvantage vis-à-vis third country carriers.
  2. In order to ensure fair competition conditions for EU carriers that operate globally, and thereby to safeguard connectivity for Europeans, we advocate for comprehensive and consistent regulatory frameworks for the internal and external EU aviation markets.
  3. Providing financial stability during these difficult times is critical to sustain the industry until there is a sufficient return in demand for air travel and cargo services. Naturally this support has to be provided in accordance with EU rules.
  4. We welcome the support measures granted by Member States for combatting the economic and social impacts of the crisis. But we call on the Commission to adhere to the principles laid down in its Communication on social standards in the aviation sector1[1] and make sure all European airlines adhere to these social standards.
  5. The COVID-19 crisis should not lead to certain air carriers gaining competitive advantages by circumventing applicable social law and disrespecting social rights. The European Commission should monitor airlines’ activities to ensure that employees are treated in accordance with the respective national labour laws.

[1] https://ec.europa.eu/transport/sites/transport/files/legislation/com20190120.pdf

Smart and Sustainable Mobility Strategy

We have welcomed the European Commission’s Sustainable and Smart Mobility Strategy. The Strategy is aligned with and reinforces the sector’s commitments towards a sustainable post-crisis future for aviation.

While the aviation industry is thus perfectly aligned with the objectives of the Commission’s new strategy, we have warned that our decreasing resources as a result of the COVID-19 crisis stand in the way – presenting a major obstacle to achieving the required goals. This will need to be factored in and fully addressed in the implementation of the strategy – both at EU and national levels.

The Commission will need to work closely with the aviation industry in executing its strategy. This will ensure continued alignment between the industry’s own efforts and the accompanying regulatory framework.

Air Traffic Management

The Commission launched the Single European Sky (SES) initiative in 1999 to improve the performance of air traffic management (ATM) and air navigation services through better integration of European airspace. The latest updated Commission proposals (SES2+) date from 22 September 2020. Although there has been a drastic reduction in traffic due to the COVID-19 pandemic, the key objectives of the European ATM system – improvement of safety, capacity, cost-efficiency and environment – remain valid today. Accordingly, the Commission identified the revision of SES 2+ as an enabler to achieve the goals of the European Green Deal. In addition, the crisis has shown that the EU ATM system should improve its resilience in order to better adjust to traffic developments.

Schiphol Airport capacity

It is essential for the Group that additional growth possibilities remain possibleat Schiphol airport to allow for the development of KLM. The limit to the number of aircraft movements at Schiphol is a much-debated topic, certainly for neighbours near the airport. In 2008, all parties involved agreed on a ceiling of 500,000 flight movements until 1 November 2020. This ceiling was reached in 2018. Recently, the Minister of Infrastructure and Water Management indicated that Schiphol may grow in small steps after 2020, provided that the noise pollution for the surrounding area decreases. What this precisely means and how it will be tested, is a subject of discussion and decision-making in The Hague.

Consumer rights

The Group contributes to the European institutions’ work on a revision of the EU consumer rights, regrets that progress is lacking so far and calls upon these institutions to finalize their work. It remains vigilant that the rules are proportionate to their objective and are applied equally to all airlines operating to, from and within the European Union. In this respect, Air France and KLM continue to do their utmost to prevent any inconvenience to passengers, e.g. with a flexible rebooking and cancellation policy in case a passenger needs to change or cancel his travel plans because of the coronavirus.

French environmental taxation

In the context of the current debates on fuel taxation and the possibility of taxation of kerosene for domestic flights, it seems important to take into account that French air transport is already heavily taxed.

In order to continue to be a major economic actor in the development of countries and territories, air transport must be able to rely on a coherent, comprehensive and incentive regulatory and fiscal framework, facilitating and accompanying its necessary energetic transition.

Aeronautical kerosene is indeed not taxed, for historical reasons, but the tax contribution of air transport related to its activity (civil aviation tax, solidarity tax, EU-ETS) amounts 1 billion euros annually in France.

From 2021, for its international flights, air transport has also committed to reducing its greenhouse gas emissions via a global carbon offsetting system (CORSIA), concluded within the framework of the United Nation’s aviation organization International Civil Aviation Organization (ICAO).

As per January 2020, airline tickets issued by all airlines now attract a tax on all flights departing from France (but not on flights arriving), except connecting flights. This tax will raise funds for investment in other transportation infrastructure, including rail. Such legislation may have a significant negative impact on the Group’s operations and growth, which could be reflected in more substantial costs, and could lead to competitive distortions between airlines when applied solely to a specific geographical area.

The Group regrets that such additional taxation will not serve the environmental transition of the sector through a contribution to a Sustainable Aviation Fuel fund.

Dutch aviation tax

A national air passenger tax has  been introduced on January 1, 2021. The revenues of this tax are channeled back to the general government’s budget and will therefore not benefit the environment. This takes away finances from the aviation sector, that could otherwise have been invested in cleaner aircraft, the development of sustainable aviation fuels or other sustainable initiatives.

It goes without saying that Air France-KLM is in favor of more sustainable aviation, but the Group is against any national air passenger tax, that does not help the environment. Travelers will then be tempted to take the car to fly from abroad. Also a study done by CE Delft in 2018 concluded that an aviation tax will have no positive environmental impact. Especially with the COVID-19 crisis further impacting the liquidity of airlines and investments foreseen to make the sector more sustainable, the introduction of the Dutch ticket tax is questionable.

SUSTAINABLE AVIATION

Air France-KLM welcomes the renewed focus on sustainability in Europe brought by the European Green Deal. The Group supports initiatives and proposals that enable the sector to decarbonise effectively.

As early as 2009, air transport, through IATA, committed itself proactively to concrete climate objectives[1]: a yearly improvement in fuel efficiency of 1.5% from 2009 to 2020, carbon-neutral growth from 2020, and reducing CO2 emissions by 50% by 2050 compared to 2005.

In November 2020, in the Aviation Round Table Report on the Recovery of European Aviation[2], European associations representing the entire aviation sector, as well as environmental NGOs, called “for all stakeholders and all policy-makers to work together to achieve net zero CO2 emissions from all flights within and departing from the EU by 2050“, while “achieving significant emission reductions by 2030”.

In February 2021, European airlines, airports, manufacturers and ANSPs published the Destination 2050 roadmap[3], which shows a possible pathway to net-zero emissions in 2050 for all flights within and departing from the EU, with a yearly passenger traffic growth of 1.4%, based on four main pillars:

  • Aircraft and engine technology
  • Air Traffic Management and aircraft operations
  • Sustainable Aviation Fuels
  • Smart economic measures

The industry’s commitments under Destination 2050 are subject to securing the required supporting policy and financing framework at EU and national levels.

Aircraft and engine technology

Air France-KLM calls for research and development on new propulsion technologies such as electric and hydrogen to be supported.

However, electric or hydrogen aircraft will not be available until the mid-2030s and for short flights only. Existing new-generation aircraft such as the Airbus A350, Boeing 787 or Airbus A220 burn 25% less fuel on average than those they replace, but are difficult to finance in the current context. The Group considers that support should be provided for renewing fleets with such aircraft, e.g. in the form of a “green stimulus” subsidy scheme, and should at least be allowed in the context of the EU Taxonomy for sustainable activities, which is meant to guide public and private investors, and of the lending policy of the European Investment Bank.

Sustainable Aviation Fuels

Sustainable Aviation Fuels (SAFs) are a key lever for decarbonising aviation in the short and medium term as they emit up to 80% less CO2 than regular kerosene. Air France-KLM calls for a predictable, coherent and long-term EU framework to be put in place, in particular in the context of the European Commission’s RefuelEU proposal, in order to support the ramp-up of affordable SAF supply in Europe. The feedstock available in Europe must be oriented in priority towards the aviation sector, as it is harder to decarbonise than other modes of transport.

The Group considers that sustainability must be at the heart of any proposal. Feedstock used to produce SAF must meet high sustainability criteria. Those criteria should be standardised and verified through an independent assessment, such as done by the Roundtable on Sustainable Biomaterials (RSB) or through International Sustainability and Carbon Certification (ISCC). SAF production must have a minimal impact on biodiversity, not compete with food production or access to food resources, be high quality (for instance no palm oil and first generation feedstock), have a positive impact on local development, and lead to a minimum CO2 reduction of 75%.

Unfortunately, the price of SAFs is still six to eight times more expensive than regular kerosene, depending on the price of oil and the type of SAFs considered. It is crucial to close this price gap, not only by upscaling production, but also by using EU funds, e.g. from the EU ETS revenues through the EU ETS Innovation Fund, or through national plans and the 750 billion euro NextGenerationEU recovery fund.

 

Smart economic measures

Air France-KLM supports the implementation of CORSIA (Carbon Offsetting and Reduction Scheme for International Aviation), a global market-based measure agreed in 2016 by ICAO countries to address emissions from international aviation and achieve carbon-neutral growth from 2020. To date, 80 countries (including the U.S., China and Gulf countries), representing 77% of international emissions, are to participate in the voluntary first phase of the agreement (2021-2026). The Group calls for any changes to the EU ETS to allow for a full and proper implementation of CORSIA, as emissions are a global issue which must be tackled at global level.

Additionally, in its 40th General Assembly in October 2019, the ICAO resolved that “CORSIA is the only global market-based measure applying to CO2 emissions from international aviation so as to avoid a possible patchwork of duplicative State or regional MBMs, thus ensuring that international aviation CO2 emissions should be accounted for only once.” This principle should be abided by, meaning that the future EU ETS should only address emissions that are not mitigated by CORSIA.

Air France-KLM also considers that new taxation must be avoided, as it would deprive airlines of the means to invest in fleet renewal and SAFs, and would fail to preserve the socio-economic benefits of air connectivity. Aviation, it should be noted, pays for almost all of its infrastructure (mostly, airport and air navigation infrastructure), contrary to other modes of transport. If taxes were put in place nonetheless, their revenues should at least be earmarked to projects and measures that effectively contribute to decarbonising aviation.

CITIZENS' CLIMATE CONVENTION

The citizen’s climate convention, instigated by the French President Mr. Macron, gathered 150 citizens, drawn by lot and representative of the diversity of the French society, in October 2019 and June 2020. Its mandate was to define a series of measures to achieve a 40% reduction in greenhouse gas emissions by 2030 (compared to 1990) in a spirit of social justice.

In June 2020, the Citizens’ Climate Convention issued a report on its work, including 149 proposals, several of which concern air transport. As some of these proposals require legislative translation, a bill called “Climate & Resilience” has been presented by the Government and is currently being debated in Parliament.

Five articles concern air transport:

  • Article 35, which establishes a target for air transport of a sufficient carbon price from 2025, with a preference for the implementation of a European mechanism. If this European mechanism proves insufficient, the Government will have to submit a report to Parliament on the implementation of national measures, in particular by increasing the solidarity tax. These proposals can only be made once air traffic to, from and within France reaches the number of passengers in 2019.
  • Article 36, which prohibits scheduled air transport services within France on any route that is also operated by rail in less than two and a half hours and without connections. Adjustments to the ban will be set by decree in the Council of State, in particular for flights that mainly carry connecting passengers or flights that offer predominantly carbon-free air transport.
  • Article 37, which prohibits projects to create or increase airport capacity from being declared in the public interest with a view to expropriation if they result in a net increase, after compensation, in greenhouse gas emissions generated by the airport activity in relation to the year 2019. A few exceptions are provided for certain airports (Nantes, Basel-Mulhouse) and for necessary work to bring them up to standard, for reasons of security or national defence.
  • Article 38 introduces mandatory annual compensation by carriers (whose GHG emissions are subject to the ETS) for GHG emissions resulting from flights within the national territory. This offsetting must be done through carbon absorption projects located in France and in other EU Member States. Carbon credits cannot be used both for national offsetting and for another mandatory offsetting scheme (such as ETS or CORSIA).

The parliamentary work should be completed in July 2021 at the earliest.

© AIR FRANCE KLM