Opinion of the Economic and Social Committee on the "Communication from the Commission to the Council, the European Parliament, the Economic and Social Committee and the Committee of the Regions on Air Transport and the Environment: Towards meeting the Challenges of Sustainable Development"

(2000/C 268/14)

On 8 December 1999 the Council decided to consult the Economic and Social Committee, under Article 262 of the Treaty establishing the European Economic Community, on the above-mentioned communication.

The Section for Transport, Energy, Infrastructure and the Information Society, which was responsible for preparing the Committee's work on the subject, adopted its opinion on 8 June 2000. The rapporteur was Mr García Alonso.

At its 374th plenary session (meeting of 13 July 2000) the Economic and Social Committee adopted the following opinion by 83 votes to three with seven abstentions.

1. Introduction

1.1. The purpose of this communication from the European Commission is to initiate a debate with the other Community institutions on the mounting impact of air transport on the environment with a view to putting forward legislative proposals in the second half of 2000 aimed at remedying or at least mitigating this trend.

1.2. The communication is important because the growth in air transport is outstripping the technological advances designed to reduce its harmful impact on the environment, such as the emission of greenhouse gases which deplete the ozone layer and cause acid rain, and noise.

1.3. Another factor, referred to only indirectly, is the global dimension of air transport and the problem of measures which cover only EU companies and airspace. This need to reach international agreements on a good number of the proposals is the third basic element to be taken into consideration.

1.4. The communication pinpoints four areas for analysis, namely:

- improving technical standards and related rules

- strengthening market incentives to improve environmental performance

- assisting airports

- advancing technological improvement.

1.5. With regard to technical standards and related rules, the following specific topics are highlighted:

1.5.1. The communication points out that the agreements on aircraft noise adopted by ICAO (International Civil Aviation Organisation), including the rules adopted unilaterally by the Community, have not been sufficient to eliminate the proliferation of local rules at numerous Community airports. More flexible solutions need to be sought which reconcile the interests of localities and regions acutely affected by noise with the need to uphold the single market.

1.5.2. Possible action is centred on phasing out, within an ICAO framework, the noisiest chapter 3 aircraft and authorising stricter regional rules where duly justified. Furthermore, if agreement is not reached in ICAO, EU rules would be considered in 2001.

1.5.3. For gaseous emissions, the current ICAO rules apply to various pollutants (smoke, HC, CO and NOx), generally based on the landing and take-off cycle (LTO). Possible action mentioned is to establish new methodologies and standards and to extend the NOx agreement to allow for the global dimension of this pollutant.

1.5.4. Improving air traffic management (ATM) could mean a reduction of 350000 hours of flight annually compared with present levels, representing a considerable saving in kerosene. The European Commission has approved another communication on this topic and wishes to lend its full technical and organisational support to the ATM system, through Eurocontrol in particular.

1.5.5. Operational measures are important because they can be put into effect immediately and therefore provide solutions in the short term. Such measures allow aircraft greater flexibility in choice of route, avoiding concentration of noise and emissions, around airports in particular.

1.6. The second area highlighted by the communication is strengthening market incentives, subdivided into the following chapters and possible actions:

1.6.1. The Commission communication(1) announces the findings of a study on taxing kerosene: under option A, a tax of EUR 245/m3 (the same as that on automotive fuels), applied on all routes departing from a Community airport, would mean a reduction of 2,4 % in kerosene consumption (and proportionately in emissions), but also a fall of 14,7 % in EU carriers' revenue and of 6,7 % in employment by 2005. Calculations were also done on the basis of a tax of EUR 185/m3 (as applied in Japan) and EUR 10/m3 (as applied in the US). It would also require legal changes at IATA level, especially the bilateral air service agreements (ASAs). The Commission therefore suggests maintaining the formula approved in 1996 pending progress on an international agreement to apply it effectively.

1.6.2. There are other possible environmental charges on air transport and ways of distributing these charges. The Commission is working through IATA which is due to debate and approve a new international system of environmental charges in 2001, which it is hoped will meet EU requirements.

1.6.3. The communication also refers to the application of the "emission trading" system, a concept still untried in this sector which could be developed at EU, Member State, company and even airport level. The possibilities opened up by carbon sinks should be included here too.

1.6.4. Drawing together all these points on market incentives, the communication proposes an action plan based on the following elements:

- continue preparing proposals for a system of environmental charges on European air transport to be presented in 2001;

- in the meantime maintain the Commission's 1996 proposal on the imposition of a kerosene tax;

- continue to study innovative concepts such as emission trading and carbon sinks which facilitate new technical and legal solutions.

1.7. In parallel with these market incentives, the Commission communication advocates encouraging industry initiatives, including environmental management schemes and voluntary environmental agreements.

1.7.1. Environmental management schemes, based on both the EMAS system and ISO-14000, enable airlines and airports to improve their own internal environmental management. The Commission proposes facilitating the exchange of experience in this field.

1.7.2. Voluntary environmental agreements are another interesting alternative. According to the Commission's communication, they would necessitate the establishment of environmental targets and conclusion of tailor-made agreements with the players involved (airlines, aircraft manufacturers, engine manufacturers, airports, etc.). The Community and global dimension of such agreements would have to be taken into consideration.

1.8. The third area is assisting airports, more specifically the search for a balance between uniform "bottom line" rules and the specific environmental situation of each airport.

1.8.1. The first step in this direction should be the establishment of a common noise classification scheme for IATA chapter 3 aircraft (the only ones which will be able to operate in the EU in the near future) and, at the same time, a system for noise measurement. This will help to standardise the noise-related environmental charges currently levied in some European airports.

1.8.2. The Commission also proposes including the situation of those living in the vicinity of airports as a selection criterion for granting Community support.

1.8.3. The third option is to establish common rules setting out, with due respect for the subsidiarity principle, the criteria for restricting air traffic on the basis of environmental conditions or factors. As part of this action, a Community system could be introduced for establishing stricter rules for particularly noise-sensitive airports.

1.8.4. Finally, as part of the revision of the trans-European transport networks guidelines, the Commission intends to press for the use of rail as an alternative to air for shorter journeys and an improvement in rail/airport connections.

1.9. The fourth and final area is advancing technological improvements, which includes the following:

1.9.1. The Commission's actions under its R& TD framework programmes have affected air transport in various ways, more especially in the areas of aeronautics, noise, climate change, emissions, etc.

1.9.2. Specifically, the Vth R& TD framework programme addresses the following areas and objectives:

- atmospheric impact of aircraft emissions

- 20 % improvement in aircraft fuel economy over the next 10 years

- significant reduction in emissions of NOx and particulates

- 10dB reduction in external noise in 10 years.

1.10. This communication follows on from the Treaty of Amsterdam which stipulates that the environmental dimension must be integrated into all Community sectoral policies. Consequently, the impact of air transport on the environment will be monitored regularly on the basis of TERM (transport and environment reporting mechanism). Cooperation with the Member States in this field will be strengthened.

2. General comments

2.1. The Economic and Social Committee wishes to congratulate the Commission on presenting this communication on the impact of air transport on the environment. It identifies the main effects and opens up various avenues of discussion in the search for solutions which reconcile the future of this sector - so important for the development of European society and the general competitiveness of the Community economy - with proper respect for the environment.

2.2. In the same constructive spirit the Committee would put forward a number of comments and recommendations, firstly of a general nature and then focusing on each of the specific aspects raised in the communication.

2.3. The general comments are as follows:

2.3.1. The present regulatory situation within the EU is more conducive to efficient flexible operation than was the case previously, which in itself eases the task of operators, individually and collectively, in working to achieve better environmental performance. However some areas remain, e.g. slot allocation, where the earlier reforms are not yet complete, while in others, e.g. airline ownership and restructuring, the elimination of old rules has not yet worked enough change. Probably most important of all, rules analogous to those which the EU has removed are still dominant in world-wide air transport operations in which EU airlines need to be competitive. In combination the above factors, in particular the regulations on structural restrictions and national LTO distribution, should be addressed as an essential and integral part of any serious review of obstacles to better air transport environmental performance. The practices whereby load capacity is improved and flight volumes, and thereby unit and overall emission levels, reduced depend in large measure on the structure of companies and their freedom to respond to demand.

2.3.2. Although in other documents the Commission has carried out an overall appraisal of the transport sector and the interaction between the various modes, the Committee considers that this communication should spell out the possible effect of other modes of transport - especially high speed trains - on the scenarios for air traffic growth. At the same time consideration should have been given to the impact of EU enlargement, which will lead not only to an increase in intra-Community traffic but also in domestic traffic in the new Member States.

2.3.3. Thought should also have been given to the impact of the new information society technologies, especially in the light of the recommendations put forward at the Lisbon Summit, concerning a potential fall in the demand for business travel by air.

2.3.4. This ties in with the compilation of precise transport statistics under the TERM project. The Committee considers that some of the proposed actions should be analysed after the actual start-up of the TERM project, the first results of which were published by the European Environment Agency after this communication was drawn up.

2.3.5. The Committee regards it as fundamental that the Commission take a close look at the subject of air safety in relation to the protection of the environment. Although a communication on this matter is to be published shortly, some environment-related aspects - such as better airspace management and land-use planning - have an obvious and direct impact on the safety of both passengers and workers and should have been assessed.

2.3.6. By the same token, in a European Union in which employment is an urgent priority, there is no appraisal of the impact - be it positive of negative - of many of the proposed measures on employment, not only in the aeronautical industry but also in direct and indirect airport services which employ hundreds of thousands of workers, many highly skilled, in the EU, or of their impact on alternative forms of transport to air travel.

2.3.7. The final comment concerns the lack of a more precise description of all the actions contemplated, all of which would seem to have the same priority, and in particular the failure to identify precisely which public authority (Community, national, regional or local) will be responsible for implementing the planned actions and the means for ensuring that an action framed at Community level is implemented effectively at each of these administrative levels.

2.4. The Committee would make the following comments on the subject of noise reduction:

2.4.1. Noise reduction requires action on three fronts: quieter engines, operating restrictions at airports, and land-use planning around airports.

2.4.2. The Committee approves the Commission proposal for more stringent noise standards, including determination of the level of low-frequency noise and the possibility of creating a new Chapter 4 at the next ICAO conference in 2001; only if this conference failed to make progress in this matter would the Commission propose Community requirements, with additional compliance periods for existing air services in less developed countries.

2.4.3. The use of noise criteria to restrict nightflights by the noisiest aircraft or to allocate new landing and take-off slots is a good solution. But first two problems need to be resolved.

2.4.3.1. The first is that aircraft noise classification differs from one Member State to another. Hence there is an urgent need for Community harmonisation of noise level classifications, based on the work already carried out by the industry and by other scientific institutions or bodies.

2.4.3.2. Secondly, these standards should be based on transparent, non-discriminatory and objective criteria which are proportionate to the end proposed and can therefore be used to report cases of non-compliance to the European Commission.

2.5. Concerning the second area of technical standards, namely gaseous emissions, the Committee has the following comments to make:

2.5.1. Here again, action needs to be taken on three fronts to reduce gaseous emissions: improve combustion technology for greater efficiency and reduced NOx emissions, improve air traffic management (ATM) systems and provide economic incentives.

2.5.2. The Committee would stress that the most urgent, cheapest and most efficient priority is an improvement in ATM, which means enlarging the airspace open to civilian traffic and reducing military airspace at the same time, and improving ATM technical resources. It is also proposed that Eurocontrol be given responsibility for setting uniform standards within the European Union for air traffic control technology and laying down uniform procedures.

The Committee would like to see a central ATM authority in Europe.

2.5.3. This would have an immediate effect not only on emission levels, but also on airport efficiency, air traffic safety and improved punctuality, with a consequent leap in the productivity of the Community economy.

2.5.4. A study should also be undertaken of ways of improving traffic management of aircraft on the ground (optimisation of movements, minimum number of engines needed for movement, etc.).

2.5.5. On the subject of improving technical standards and the efficiency of new engines, the Committee is adamant that parallel progress be made on noise levels and emissions. It is necessary to establish minimum efficiency values for engines (which means lower emissions) and not just deal with noise levels.

2.5.6. The Committee endorses the complementary communication on the kerosene tax and shares its conclusions. This possible tax will function best within the framework of an international agreement; the Commission is therefore urged to submit to the Council a common position on the matter which can be discussed in the ICAO Assembly in 2001.

2.6. The third area of action mentioned in the Commission communication is economic incentives. In this connection the Committee would repeat some of its earlier comments:

2.6.1. Economic incentives, be they in the form of environmental or other charges or positive tax incentives, can play a very important role in the future development of air traffic and its impact on the environment. They need to be drawn up in accordance with the following principles:

2.6.1.1. Assessment of their implementation should be based on objective, transparent, non-discriminatory criteria which are proportionate to the end proposed.

2.6.1.2. From the competition angle, differences between EU and third country legislation and taxation, including differences between Member States, may result in distortion of competition not only in the aeronautical and air services industry but also in other sectors of the economy.

2.6.1.3. From the employment angle, they may lead to job losses when in fact Community policies and measures should be framed and implemented with a view to a high level of employment.

2.6.1.4. From the environmental protection angle, the kerosene tax and other types of environmental charge will not increase global environmental protection as such a tax could not apply to non-Community aircraft; hence the intended environmental policy objectives would not be adequately met, the only effect being that the Community would give a lead in recruiting other countries to these rules.

2.6.2. In its document the Commission opts for an environmental charge in the form of a basic levy which is calculated as either a tax added to the ticket fare or a levy which takes into account the distance flown and the "environmental efficiency" of the aircraft.

2.6.3. The Committee has various reservations about some aspects of this preliminary Commission proposal:

2.6.3.1. Route charges are very similar to the kerosene tax rejected in the short term, although it does incorporate some valid elements such as the aircraft's "environmental efficiency".

2.6.3.2. A tax added onto the price of the ticket and not on the operation of an aircraft does not take into account the benefits of increasing aircraft occupancy rates, if this would reduce the total number of flights.

2.6.3.3. A charge calculated on distance could unduly penalise long-haul flights (more than 5000 km) where other forms of transport are not a practical alternative.

2.6.4. For these reasons the Committee considers that a possible course of action in this field could be a charge which:

2.6.4.1. Is levied on take-off and landing operations (LTO charges), to be reviewed periodically, and modulated according to the "environmental efficiency" of aircraft with regard to their pollutant emissions.

2.6.4.2. This charge would only be possible if and when it applied to all aircraft operating from an airport irrespective of their nationality (consideration could be given to as short a transitional period as possible for aircraft from less developed countries).

2.6.4.3. This charge would have to apply to all Community airports and would have various harmonised levels of charge which could take into account factors such as: airport traffic over the last year, average flight length to/from airport, degree of congestion, impact on neighbouring population and other factors such as the airport being situated on an island or not on the mainland territory of a Member State. It would have to be formulated and implemented in such a way that it acted as an incentive for operators to reduce environmental pollution rather than merely increasing costs.

2.6.4.4. The Committee considers that the proceeds from such charges would have to be used without restrictions by the beneficiaries for the necessary environmental improvements. The Commission should define some criteria for distribution between the various authorities and bodies concerned.

2.6.5. The Committee supports the trading of emission rights for greenhouse gases in the air transport sector - within the general framework of this system - in line with the recent Commission communication. It agrees with the Commission that there is a need to further assess the capacity of such measures to solve environmental problems in this sector, whilst respecting legal requirements.

2.6.6. Similarly the Committee supports the rapid application in this sector (encompassing both airlines and airports) of the eco-management and audit systems (EMAS and ISO 14000) in tandem with the application of voluntary agreements by the industry.

2.7. Under the topic of "assisting airports" the communication assesses the impact of noise on people living near airports and proposes the creation of a Community system for aircraft noise classification and for allocating slots. These aspects have already been addressed in points 2.4.3 and 2.4.3.1.

2.8. The Committee also supports the communication's proposal for some guidelines for land-use planning around airports which, with due respect for the subsidiarity principle, set out some common criteria to serve as a reference framework for local and regional authorities.

2.9. Only on this basis - standardisation of noise measurement systems, common guidelines for land-use planning and assessment of the populations affected - can thought be given to the creation of a Community framework for establishing specific environmental restrictions or slot allocation criteria in individual airports, which could be more stringent provided that the local authority and airport management demonstrate to the European Commission that such restrictions are necessary, proportionate and non-discriminatory.

2.10. The Committee welcomes the Commission's proposal for intermodality between air and other forms of transport, such as rail and clean buses. It would stress that Europe's main airports must be connected efficiently not only to the nearest city or cities by a rapid public transport system, but that intermodality with the high-speed rail network should be promoted; this network should, as far as possible, have stations in the airport itself, as is currently the case with Charles de Gaulle airport.

2.11. As regards the relationship between air transport and R& TD policy, the Committee supports the guidelines set out in the Commission document and urges that a new field be included to assess the possible influence of air traffic demand in the wake of the new professional situation brought about by the information society. This could avoid expensive increases in air traffic capacity and services which could be reduced or even made obsolete by the impact of new technologies.

2.12. Finally, the Committee would urge the European Commission to present, within two years, a new communication on this subject after the ICAO Conference and after assessment of the statistical system provided by the TERM project.

Brussels, 13 July 2000.

The President

of the Economic and Social Committee

Beatrice Rangoni Machiavelli

(1) COM(2000) 110 final.