The role of airports in the European Green Deal.
Date: 2021-03-08
Institutions: European University Institute
Subjects: airport, atmospheric pollutant, environmental impact, intelligent transport system, noise pollution, public financing, quality of the environment, reduction of gas emissions, sustainable mobility, transport regulations

EUROPEAN TRANSPORT 
REGULATION OBSERVER

Issue 2021/02 
January 2021

BRIEFPOLICYThe Role of Airports in the European Green DealMatthias Finger, Teodora Serafimova, and  Juan Montero, EUI HighlightsThe European Green Deal sets the objective of making Europe the first climate neutral continent by 2050: a commitment which places a particular responsibility on the aviation sector. In addition to calling for a reduction of the sector’s climate footprint, the Green Deal stresses the importance of ‘improving air quality near airports by tackling the emissions of pollutants by airplanes and airport operations’. Though important advances have been made in mitigating noise pollution from aircraft, noise levels continue to pose a serious health risk for communities living close to airports and, thus, also need to be further addressed. The Commission’s more recent Sustainable and Smart Mobility Strategy reiterates the urgency of transitioning to zero-emission airports, whereby ‘the best practices followed by the most sustainable airports must become the new normal and enable more sustainable forms of connectivity’. Against this backdrop, the 14th Florence Air Forum examined the contribution of European airports and the wider aviation ecosystem, through technological and regulatory measures, in supporting the attainment of the European Green Deal and Climate Law objectives.When it comes to technological solutions, measures to boost airports’ energy efficiency, as well as the electrification of aircraft during taxiing, of ground handling, shuttle buses and other vehicles transporting passengers to-, from- and within the airport premises, for instance, are increasingly examined and implemented. In fact, the European airport industry has shown firm commitment to becoming net zero for carbon emissions by no later than 2050. Airports, however, do not operate in isolation, thus, any regulatory and financing measures to improve their environmental performance, will have to take into account the broader aviation ecosystem, including airlines, air traffic management and ground handlers, among others. Besides the roll out of greening measures at their own premises, airports are important interfaces between various operational stakeholders and can thus act as ‘enablers’ for broader aviation sector decarbonisation. To this end, the 14th Florence Air Forum sought to discuss how existing EU legislation (e.g., the Airport Charges Directive, the Slot Regulation, and the Ground Handling Directive), but also public funding opportunities (research funds, Recovery and Resilience Facility) can stimulate the greening of airports.Airports as ‘Enablers’ for the Aviation 
Sector’s Take-off Towards Net Zero 
Carbon Emissions 

A comment by Matthias Finger and Teodora 
Serafimova, Florence School of Regulation – 
Transport Area

About a year ago, the European Commission adopted its 
European Green Deal, which sets the ambition of making 
Europe  the  first  carbon-neutral  continent.  To  this  end, 
a  90%  reduction  in  greenhouse  gas  emissions  by  mid-
century  would  need  to  be  delivered  by  the  transport 
sector collectively, with all modes contributing their fair 
share. While in the meantime, the onset of the COVID-19 
pandemic  has  brought  about  unprecedented  challenges 
for most sectors of the economy, it has also become clear 
that the Commission’s level of climate ambition remains 
unchanged.  The  recovery  phase  has  been  framed  as 
an  opportunity  to  accelerate  the  shift  towards  a  more 
sustainable,  smarter,  and  resilient  mobility  system.  In 
its  recently  published  Sustainable  and  Smart  Mobility 
Strategy,  the  Commission  lays  the  foundation  for  how 
the EU transport system can achieve its green and digital 
transformation while becoming more resilient to future 
crises. 

Aviation,  in  particular,  has  been  among  the  most 
challenging sectors to decarbonise. This can be, at least 
partially,  attributed  to  the  sector’s  fragmented  nature, 
whereby the pieces that make up the sector are pursuing 
their own efforts to decarbonise and, at times, pulling in 
different directions. Unlike the other network industries, 
notably  railways,  electricity,  and  telecommunications,  
aviation  has  never  been  vertically  integrated  into  one 
single  State-owned  company.  Consequently,  a  systemic 
view has never been as pronounced in the aviation sector. 
A key message that resonated among participants at our 
14th  Florence  Air  Forum  was  the  need  for  a  systemic 
approach  to  regulating  the  air  sector.  This  becomes 
especially paramount when addressing the greening of air 
transport, where the efforts of the actors that constitute 
the  aviation  ecosystem  will  need  to  be  coordinated, 
especially at its interfaces, to place the sector on a path 
towards  net-zero  emissions  by  mid-century.  Below  we 
take a closer look at one of these interfaces, namely the 
airports,  and  share  some  reflections  on  their  role  in 
aviation greening. 

2 ■  Robert Schuman Centre | January 2021

Low-Hanging Fruit for the Greening of the Aviation 
Sector

While it is well known that the actual flight is responsible 
for  the  vast  majority  of  the  aviation  sector’s  carbon 
footprint, airports themselves offer significant untapped 
potential for further and rather easy greening, especially 
when compared to airlines. Airports can make a sizable 
contribution to reducing aviation emissions by resorting 
to  readily  available  technologies  and  practices.  ACI’s 
Airport  Carbon  Accreditation  program,  which  has 
been  in  use  for  over  a  decade  now,  manifests  airports’ 
commitment to greening their assets in line with the net 
zero carbon objectives. 

Greening efforts can touch upon many different aspects of 
an airport’s construction and operation. The discussions 
revealed 
that  numerous  airports,  amongst  which 
Hamburg  airport,  are  undertaking  measures  to  boost 
their buildings' energy efficiency, renovating ventilation 
and lighting systems, and installing photovoltaic facilities 
onsite.  On  the  other  hand,  others,  such  as  Geneva 
airport,  are  financially  supporting  ground  handlers  in 
their operations' electrification to reduce both emissions 
and  operational  costs.  Airports  are,  moreover,  seeking 
to improve public transport connections to city centers 
while  promoting  multi-modality  and  cleaner  mobility 
forms. The AENA-operated Spanish airports, for instance, 
are electrifying shuttle bus fleets, installing the necessary 
charging infrastructure, and reinforcing electrical power 
grids. Schiphol airport is testing its taxi bot pilot, which 
allows aircraft to be towed from the runway with engines 
off, thereby saving kerosene and emissions. 

Role Models and Enablers for Sector-Wide Greening  

But  there  is  more  to  airports.  Unlike  airlines  and  air 
traffic  management  (ATM),  airports  are  locally  rooted, 
often  locally  owned,  and  generally  subject  to  higher 
local  pressures  than  airlines  and  ATM.  In  addition  to 
mitigating the CO2 impact of their assets and activities, 
airports  have  to  manage  local  issues,  including  air  and 
noise  pollution,  waste  generation,  and  the  potential 
damage to local wildlife habitats and water bodies. The 
above  constitute  good  reasons  why  airports  can  and 
should act as role models and enablers for the greening 
of the entire aviation sector.  

higher initial costs of newer technologies, such as electric 
vehicles.  

Additionally,  airports  need  to  be  encouraged  and 
supported  to  act  as  enablers.  Airports  have  several 
instruments  at  their  disposal  to  stimulate  cleaner  and 
quieter  aircraft,  including  airport  charges,  incentives, 
operational rules, and slot regulations. Many airports are 
already  modulating  the  charges  paid  by  airlines  based 
on  environmental  criteria,  for  example,  by  reducing 
charges  for  aircraft  producing  less  noise  and  emitting 
less air pollutants such as NOx. However, airports’ ability 
to  modulate  charges  largely  depends  on  the  applicable 
legislation, which varies from country to country. 
Given their global impact, CO2 emissions from aircraft, 
on the other hand, are not considered under the direct 
control of the airport operator. Notwithstanding, because 
of  their  revenue-neutral  nature,  the  modulation  of  air-
port  charges  could  be  examined  for  the  CO2 emissions 
from aircraft to potentially provide an incentive for air-
lines to replace older fleets with newer and greener air-
craft  powered  by  SAFs.  This  possibility  for  airports  to 
incentivise cleaner aircraft based on CO2 emissions could 
be explored in the context of a revision of the EU’s Air-
port Charges Directive and the Slot Regulation. 

All  in  all,  some  fine-tuning  and  revision  of  the  EU 
regulatory  framework  will  be  needed  going  forward. 
The  challenge  will  be  to  ensure  a  systemic  approach 
and  coherence  across  the  different  legislation  pieces, 
from  airport  charges  and  slots  to  the  Single  European 
Sky's  implementation,  State  aid,  the  internalisation  of 
the  external  costs,  and  the  EU’s  Sustainable  Finance 
workstream (e.g., EU taxonomy for sustainable activities, 
EU  Green  Bond  standard),  among  others.  All  of  these 
are interrelated and contribute in one way or another to 
the  advancement  of  the  European  Green  Deal  agenda. 
Last but not least, the future regulatory framework needs 
to  reflect  the  fact  that  airports  are  complex  systems  of 
interrelated  facilities  and  assets,  which,  in  turn,  has 
implications  for  the  measurement  and  management  of 
their sustainability performance. 

Schiphol airport’s experience of electrifying its bus fleet 
back in 2011 is an illustrative example of how airports rely 
on the actual products available on the market to green 
their  operations  and  services.  We  have  seen  from  the 
discussions that ‘early mover’ airports have several ways 
of responding to technological bottlenecks in the supply 
chain, from boosting their research and innovation efforts 
to reaching out to suppliers outside Europe, and actually 
co-developing the demanded products themselves. What 
is  more,  larger  airports  are  taking  greening  measures 
beyond  their  premises  by  supporting  renewable  energy 
projects  and  partnering  with  sustainable  aviation 
fuels  (SAFs)  producers.  Airports  can  leverage  their 
unique  position  as  an 
interface  between  airlines, 
aircraft  manufacturers,  and  developers  of  smart  energy 
management  systems  to  scale  up  SAFs  production  and 
deployment.  Airports  can  accelerate  the  uptake  of  new 
aircraft technology related to electrification or hydrogen 
by  securing  the  appropriate  airport  infrastructure, 
associated services, and, not least, set incentives.

What is more, we have seen that airports are increasingly 
becoming  involved  in  the  broader  energy  transition  by 
procuring  or  self-generating  carbon-neutral  energy 
onsite. The enhanced cooperation between stakeholders 
from across the entire supply chain is key to enabling the 
uptake of SAFs and greening aviation. Of course, these 
possibilities will also depend on regional contexts. 

A Conducive Regulatory Framework for Airports to Act 
as Enablers

While  it  is  encouraging  to  see  a  handful  of  best 
practices  today,  shifting  towards  a  more  consistent 
effort  across  the  airport  community  towards  greening 
will  necessitate  enacting  a  conducive  EU  regulatory 
framework.  One  apparent  market  failure,  and  thus  the 
need for intervention, was identified in ground handling: 
an  industry  marked  by  very  low  margins,  rendering 
high  upfront  investments  and  greening  considerations 
difficult.  Greater  involvement  on  the  part  of  airports, 
through  minimum  CO2  requirements  in  licensing  calls 
for  tenders,  could  accelerate  greening  in  the  sector.  An 
overarching  regulatory  framework  could  also  help  to 
mobilise  a  collective  effort  towards  greening,  which 
is  key  to  creating  economies  of  scale  and  lowering  the 

3 ■  The Role of Airports in the European Green Deal

Main Takeaways From the Discussion

By Teodora Serafimova, Florence School of  
Regulation – Transport Area 

The  14th  Florence  Air  Forum  took  place  in  the  midst 
of  the  COVID-19  pandemic,  which  has  brought  about 
unprecedented  challenges  for  the  entire  aviation  value 
chain,  from  airports,  to  airlines,  ground  handlers  and 
retailers,  among  others.  In  fact,  the  Airports  Council 
International  (ACI)  estimates  that  almost  200  airports 
could be faced with the risk of insolvency in the coming 
months if air traffic does not pick up. This, in turn, would 
result in considerable job losses and an overall reduction 
of  connectivity  in  Europe.  While  airports  are  largely 
focused  on  their  immediate  survival,  it  is  crucial  that 
their recovery plans for the post-COVID-19 period align 
with the EU’s climate neutrality objectives as laid out in 
the  European  Green  Deal.  European  airports  have,  in 
fact, already demonstrated their commitment to tackling 
the climate challenge by collectively pledging to achieve 
net  zero  carbon  emissions  by  2050.  More  recently,  in 
November  2020,  over  20  associations  representing  the 
entire  European  aviation  ecosystem  along  with  civil 
society,  signed  a  joint  statement  for  a  post-COVID-19 
recovery,  which  targets  net  zero  CO2  emissions  for  the 
aviation sector by 2050. 

The emissions that airports directly operationally control 
(i.e.,  the  emissions  stemming  from  airport  buildings, 
infrastructure, ground vehicles, etc.) account for ca. 2% of 
total global aviation emissions. Though for many of these 
airport-related emission sources, technological solutions 
for  decarbonisation  already  exist,  their  implementation 
requires significant upfront investments, something that 
has  been  further  complicated  by  the  current  context  of 
COVID-19.  Beyond  these  direct  emissions,  airports, 
as  important  interfaces  between  various  operational 
stakeholders, have an increasingly important role to play 
in  driving  broader  sector-wide  emission  reductions.  To 
put  things  into  perspective,  the  rollout  of  new  aircraft 
technology related to electrification or hydrogen will be 
difficult to achieve in the absence of the appropriate airport 
infrastructure  and  associated  services.  Airports  will, 
thus, be key enablers of broader sector decarbonisation. 

Reducing  CO2  emissions  from  transport  by  90%  by 
2050, as set out in the European Green Deal, will require 

all  transport  modes  as  well  as  all  actors  in  the  aviation 
ecosystem to do their fair share in this collective effort. In 
addition  to  significant  reductions  in  aircraft  emissions, 
investments will also need to be channeled into airport 
infrastructure  and  operations  in  order  to  optimise  air 
traffic performance on the airside as well as to improve 
the integration of airports into multimodal networks on 
the landside. The greening of airports is also among the 
key elements of the Commission’s Sustainable and Smart 
Mobility  Strategy,  which  came  out  in  early  December 
2020.  The  Strategy  will  shape  the  von  der  Leyen 
Commission’s  agenda  in  terms  of  the  concrete  actions 
that  will  be  implemented  to  render  the  entire  aviation 
ecosystem more sustainable, resilient and competitive.

The 14th Florence Air Forum was welcomed as a timely 
opportunity  to  discuss  the  concrete  technological  and 
regulatory solutions to stimulate the greening of airports 
in a holistic manner. These include measures to boost the 
energy efficiency of the airport premises, the generation 
of clean energy on-site, efforts to reduce emissions from 
airside activities, ground handling and ground operations 
of  aircraft  themselves,  as  well  as  efforts  to  secure  the 
appropriate  supplies  and  infrastructure  for  the  uptake 
of  SAFs.  The  regulatory  and  incentives  framework  are 
equally  important,  whereby  the  key  objective  will  be 
to  identify  how  existing  European  legislation,  notably 
Directive  2009/12/EC  on  airport  charges  (‘Airport 
Charges Directive’), Regulation 95/93 (‘Slot Regulation’), 
but  also  the  Directive  96/67/EC  on  the  provision  of 
ground handling services (‘Ground Handling Directive’), 
can stimulate the greening of airports.

As regards the financing aspects, whereas the bulk of the 
investments will stem from private actors, EU and national 
public funds, such as the Recovery and Resilience Fund 
and  InvestEU,  will  also  have  an  important  role  to  play. 
Though  the  latter  are  non-sectoral  and  demand-driven 
funds, it is clear that the transport sector, as one of the 
most severely hit sectors by the pandemic, will be a prime 
beneficiary of these funds. The greening of airports will 
be among the eligible segments within the Recovery and 
Resilience Fund, whose total budget amounts to €672.5 
billion of loans and grants, and which will be rolled out 
on the basis of national plans. Not the least, the European 
Investment  Bank  (EIB)’s  recently  adopted  climate 
policy is also set to provide financing opportunities for 
investments into the greening of airports. 

4 ■  Robert Schuman Centre | January 2021

What Are The Various Technological Options Involving 
Aircraft Ground Movements, Airside Operations 
and Ground Handling Solutions to Accelerate the 
Achievement of Net Zero Carbon European Airports By 
2050?

The  European  Green  Deal’s  objectives  are  not  limited 
to  climate,  but  address  broader  environmental  issues 
including biodiversity, water management, air and noise 
pollution.  A  broader  vision  of  sustainability,  which 
revolves  around  striking  the  right  balance  between  the 
environmental, social and economic sustainability, is also 
reflected in numerous airports’ strategies. 

The  sustainability  strategy  of  Schiphol  airport,  for 
example, is rooted in the idea of optimising performance 
across  the  four  thematic  areas  of  sustainable  aviation, 
energy  positive,  communities,  and  circular  economy. 
Whereas  the  circular  economy  and  energy  positive 
milestones are in the airport’s direct sphere of influence, 
sustainable aviation and communities are in its indirect 
sphere  of  influence.  Schiphol  Airport  has  set  itself 
2050  goals  and  intermediary  2030  milestones  for  these 
four themes, thereby closing the loop between the four 
milestones.  For  instance,  the  ‘plus’  in  energy  positive 
could be used to produce SAFs, or alternatively, it could 
be shared with the airport’s neighboring communities. 

More  specifically  when  it  comes  to  its  energy  positive 
milestone,  Schiphol  aims  to  achieve  net  zero  emissions 
by 2030, which is 20 years ahead of the recommendations 
by  the  Intergovernmental  Panel  on  Climate  Change 
(IPCC).  The  scope  of  this  target  includes  all  airside 
operations (i.e., handlers, cleaning activities etc.), except 
for aircraft emissions. The phasing out of fossil fuels has 
been considered as an important win-win strategy to not 
only reduce CO2 emissions, but also to improve local air 
quality  and  thereby  the  working  conditions  for  airport 
employees. 

The switch to electric buses at Schiphol airport was met 
with some frictions back in 2011, when the airport first 
started investigating electric solutions. Initially, many of 
the buses running from Schiphol airport to the aircraft 
were  autonomously  operated  diesel  buses.  However, 
because  of  the  30  kilometers  per  hour  speed  limit  at 
airside, the bus engines were not heating up sufficiently, 
thereby exacerbating emissions. This, in turn, prompted 

the airport to embark on the gradual electrification of its 
airport  vehicle  fleets.  Despite  interest  from  the  airport 
to green its operations, there were certain technological 
bottlenecks in the European supply chain back in 2011-
2012,  which  meant  that  electric  solutions  could  not  be 
easily delivered for four-wheel drive cars, which in turn 
were  a  requirement  for  airside  operations.  Schiphol 
responded  to  this  by  reaching  out  to  suppliers  from 
outside of Europe and a Chinese supplier was eventually 
selected. 

technologies  have  matured 
Since  2011,  electric 
significantly,  and  there  is  now  a  better  understanding 
of the supplier communities among airports. Schiphol’s 
experience  is  an  illustrative  example  of  the  fact  that 
airports  rely  on  the  actual  products  available  on  the 
market  in  order  to  green  their  operations  and  services. 
A  conducive  regulatory  framework  can  stir  a  collective 
effort towards greening, which in turn, could help to create 
economies  of  scale  and  render  product  development 
more 
to  manufacturers. 
attractive 
Currently, Schiphol is testing out its taxi bot pilot, which 
is  demonstrating  that  aircraft  can  be  towed  from  the 
runway  with  engines  off,  thereby  saving  kerosene  and 
emissions. This is just one example of how airports can 
act as enablers for the decarbonisation of airlines. 

economically 

Discussions also focused on the reduction of emissions 
from  the  ground  handling  industry,  and,  in  particular, 
sought to address the root causes behind its suboptimal 
progress  with  regards  to  greening.  To  put  things  into 
perspective, the total amount of CO2 emitted by ground 
handling  activities  amounts  to  approximately  4  million 
tons  of  CO2  annually,  which  is  a  small  proportion 
as  compared  to  the  wider  aviation  picture.  Ground 
power  units  are  responsible  for  almost  half  of  the  total 
ground  handling  emissions,  so  phasing  them  out 
constitutes  an  important  first  step  in  rendering  ground 
handling  operations  more  sustainable.  What  is  more, 
the electrification of ground handling equipment, using 
electricity from non-fossil sources, is a readily available 
solution  today  to  reduce  the  sector’s  emissions.  The 
total market value of ground support equipment (GSE) 
is  estimated  at  $15  billion  every  year.  Electric  ground 
handling  equipment  today,  however,  only  accounts  for 
roughly  10-15%  of  the  total  stock.  Numerous  studies 
show  that  if  all  the  operational  costs  (e.g.,  fuel  costs, 
maintenance  costs,  battery  change,  etc.)  are  factored  in 

5 ■  The Role of Airports in the European Green Deal

over  a  period  of  15  years,  the  electric  solution  would 
almost always emerge as the more economically attractive 
one for the ground handler. So why are we not seeing a 
more rapid uptake of electric GSEs? 

Despite  their  lower  operational  costs,  electric  GSEs 
cost  on  average  15-20%  more  than  their  current  diesel 
counterparts.  Here  it  is  also  particularly  important 
to  note  that  airline  contracting  and  ground  handling 
is  a  business  characterised  by  low  margins,  whereby 
achieving  5%  of  margin  on  average  is  considered  to  be 
a  good  financial  year,  whereas  the  majority  of  ground 
handlers are barely achieving breakeven for years. Prior 
to the pandemic, ground handing was making an annual 
contribution  of  $90  billion  to  the  economy,  though  the 
drastic  reduction  in  air  traffic  has  resulted  in  massive 
disengaging from ground handling contracts and layoffs 
across  the  industry.  As  a  very  low  margin  industry, 
upfront  investments  into  greening  solutions,  such  as 
electrification, are particularly challenging for the ground 
handling industry. Stakeholders were in agreement that 
new regulatory approaches will be needed to rectify this 
market failure, and that it should be seen as an opportunity 
for airports to take on a more active role. In view of this, 
Geneva airport has implemented a programme, whereby 
the airport shares up to 50% of the investment costs for 
electrification  with  the  ground  handlers.  As  a  result, 
their  main  ground  handler  has  already  electrified  50% 
of their equipment. Schiphol airport, on the other hand, 
has had a different approach as regards the deployment 
of  their  mobile  electric  ground  power  units.  Because 
technological solutions were not available on the market, 
Schiphol has heavily invested in research activities, and 
has co-developed the electric ground power unit, which 
is now in testing phase. 

The current EU regulatory framework governing ground 
handling is focused on the purely economic relationship 
between the airlines and the ground handlers, which in 
turn  is  dictated  by  the  service  level  agreements.  In  the 
absence of legal obligations or incentives to choose their 
contractor  on  the  basis  of  CO2  emissions,  airlines  will 
continue  prioritising  financial  objectives.  Participants 
appeared  to  agree  on  the  need  for  greater  involvement 
from  airports,  which  today  are  constrained  in  their 
ability  to  interfere  in  prescribing  the  type  of  ground 
handling  equipment  to  be  used.  A  number  of  airports 
are already introducing minimum CO2 requirements in 
their licensing call for tenders, with the notable examples 

of  Oslo  Gardermoen  and  the  AENA-operated  Spanish 
airports. 

At  AENA’s  airports,  for  example,  ground  handling 
licenses  are  awarded  through  tenders  for  the  duration 
of  five  years,  whereby  each  tender  includes  conditions 
for CO2 reduction. Prior to each tender, workshops are 
conducted  with  stakeholders  from  the  sector  including 
ground handlers, manufacturers and regulators so as to 
define  tenders  compatible  with  the  current  market  and 
regulatory  realities.  The  pooling  of  ground  handling 
equipment was brought up as another possible solution to 
overcome the lack of investment funds needed to embark 
on electrification. In sum, a ‘push’ would need to come 
from the airports in order to stimulate a more consistent 
approach among the ground handling community when 
it comes to greener solutions. To this end, a change in how 
the  market  works,  and  especially  in  how  contracts  and 
licenses are awarded, will be needed. A recommendation 
was put forward for greening conditions to be included 
in  the  tender  requirements,  which  in  turn,  could  be 
achieved  through  a  revision  of  the  Ground  Handling 
Directive. 

Airports,  however,  do  not  operate  in  isolation.  Thus, 
any  regulatory  measures  aimed  at  improving  their 
environmental  performance,  would  have  to  take  into 
account  the  broader  aviation  ecosystem,  including 
airlines  and  air  traffic  management  (ATM).  A  systemic 
approach, which relies on a combination of technological 
and  operational  measures  to  deliver  emission  cuts 
throughout the different phases of the flight, will be key to 
ensure the aviation sector emerges from the COVID-19 
crisis on a path to climate neutrality by 2050. The targets 
set out in the European ATM Master Plan, published at 
the end of 2019, remain fully valid today. 

The  current  regulatory  framework  places  a  strong 
emphasis  on  the  management  of  capacity  in  the  air.  To 
illustrate this, in response to the capacity crisis of 2018-19 
and  the  resulting  huge  flight  delays,  it  was  decided  to 
redirect  traffic  to  where  there  was  spare  capacity,  even 
if  this  translated  into  inefficient  and  more  polluting 
flight  paths.  To  put  things  into  perspective,  while  air 
traffic  only  increased  by  3%,  CO2  emissions  increased 
by  7%  during  that  period.  This  is  a  clear  illustration  of 
how the regulatory environment can shape the behavior 
of  the  various  actors  and  undermine  environmental 
objectives. Improvements in the scalability and capacity 

6 ■  Robert Schuman Centre | January 2021

of the whole network can help to improve environmental 
performance. 

While many airlines have been making efforts to increase 
load factors of their aircraft, there is still a prevalence of 
fuel  tankering  practices,  whereby  aircraft  deliberately 
carry excess fuel in order to reduce or eliminate refueling 
at  their  destination  due  to  higher  fuel  prices.  This,  in 
turn, acts to undermine the climate effects of increased 
load factors. Participants argued that COVID-19 can be 
turned into an opportunity to rebuild the aviation system, 
so  as  to  ensure  consistency  and  embed  environmental 
principles into regulation.

Realising  the  full  potential  of  SAFs  uptake  onboard 
aircraft  will  require  measures  to  ensure  that  aircraft 
follow  the  most  efficient  trajectories 
in  the  sky. 
Continuous Climb and Descent Operations (CCOs and 
CDOs),  whereby  aircraft  are  allowed  to  follow  flexible, 
optimum flight paths, for instance, can deliver important 
environmental  and  economic  benefits,  in  the  form 
of  reduced  fuel  burn,  emissions,  noise  and  fuel  costs. 
Similarly, avoiding holding patterns before landing (i.e., 
aircraft  flying  in  circular  patters  before  they  can  land), 
can lead to significant fuel and CO2 savings. 
While the bulk of the CO2 emissions evidently stem from 
the flight and fuel burn, the discussions showed that there 
is a significant potential for action also on the ground. A 
set of tools and functionalities at the disposal of air traffic 
controllers  at  airports  can  support  them  in  handling 
complex  operations  and  optimising  phases.  Improved 
airport operations, optimised taxiing and runway usage 
can  help  to  avoid  unnecessary  fuel  burn.  Not  the  least, 
the  airport  plays  an  important  role  as  an  enabler  for 
the  decarbonisation  of  the  entire  aviation  value  chain 
and  can  offer  synergies  for  various  actors,  including 
the ground handlers, airlines, but also the suppliers and 
manufacturers of the necessary equipment to make that 
greening possible.

Greening Airports: From Construction to Electricity 
Generation, Availability Of Sustainable Aviation Fuels 
and Transit to The Airport. How to Build and Operate 
Airports in a Sustainable Way?

On the one hand, airports can be viewed as buildings or 
factories, and thus not much different to the rest of the 
economy and other fixed infrastructures when it comes to 
their greening. The way in which airports are constructed 
and operated to a large degree determines their carbon 
footprints.  On  the  other  hand,  we  should  note  that 
airports  are  located  between  two  other  categories  of 
emissions,  namely  those  that  passengers  emit  to  reach 
the  airport,  and  these  emitted  during  the  actual  flight. 
Airports  have  an  important  role  to  play  in  driving 
reductions  from  both  of  these  emissions  categories. 
However,  the  airport  sector  should  not  be  approached 
as a monolith, given that different airports have different 
sizes  and  capabilities.  Some  of  the  bigger  airports, 
for  instance,  who  are  the  largest  fuel  suppliers  and  are 
often  connected  to  pipelines,  would  have  an  especially 
important role to play when it comes to deploying SAFs. 
A  uniform  standard  for  airports  in  regards  to  greening 
may thus be a challenge due their heterogeneity. 

The  experience  of  Hamburg  airport  illustrates  how  the 
implementation of environmental management practices 
can help to reduce an airport’s carbon footprint. Notably 
the airport has reduced its footprint from around 38 000 
tons of CO2 back in 2009 to roughly 14,000 tons of CO2 
in 2019. A major source of CO2 for Hamburg airport has 
been the building sector and facilities, and in particular 
their energy demand and efficiency. Therefore, as a first 
step, the airport has changed its ventilation and lighting 
systems,  and  implemented  a  new  energy  management 
software. New, more energy efficient, buildings were built 
to  replace  older  ones.  Important  emission  savings  were 
achieved  through  the  procurement  of  carbon  neutral 
electricity from wind power. 

Ground support equipment (GSE) accounts for ca. 25% 
of  Hamburg  airport’s  emissions.  To  reduce  these,  the 
airport has exchanged diesel-powered vehicles by electric 
vehicles, especially where these run over shorter distances. 
Compressed natural gas (CNG), on the other hand, has 
been used for buses and for luggage handling tractors for 
longer  range  deployment.  Notwithstanding,  Hamburg 
airport  aims  to  replace  the  latter  with  hydrogen-fueled 

7 ■  The Role of Airports in the European Green Deal

vehicles in the near to mid-term future. These measures 
have  been  followed  by  the  installation  of  charging  and 
fueling  stations  on  the  air-  and  on  the  landside.  In  the 
more  immediate  term,  the  airport  will  be  constructing 
a new baggage handling system, which will be equipped 
with a photovoltaic (PV) facility to produce hydrogen for 
the next generation of hand luggage tractors.

Electricity  supply  has  been  implemented  on  all  aircraft 
stands (also on remote stands) to replace both auxiliary 
power  units  (APU)  and  ground  power  units  (GPU). 
Hamburg  airport’s  apron  was  also  refurbished  and 
equipped  with  a  modern  LED-based  lighting  system. 
The  creation  of  parallel  taxiways  has  helped  to  avoid 
aircraft  congestion.  While  there  are  plenty  of  measures 
that  airports  can  undertake  on  their  own  premises 
to  cut  emissions,  as  underlined  earlier,  they  are  also 
crucial  when  it  comes  to  SAF  deployment,  given  their 
role  as  a  link  between  the  suppliers  and  the  airlines. 
In  recognition  of  this,  a  new  project  called  Kerosyn, 
founded on a cooperation between Hamburg airport and 
a local refinery, plans to use wind power and atmospheric 
CO2 to produce climate neutral jet fuel to be supplied to 
airlines in future.

The Spanish airport operator AENA, on the other hand, 
has announced plans to achieve net zero carbon emissions 
by 2040, which is 10 years ahead of the joint ACI Europe 
commitment. To this  end, last  year  AENA  launched its 
PV plan, which foresees 100% of self-supplied electricity 
from renewable sources in AENA airports by 2026. The 
facility has an annual production of 950GW, which is the 
equivalent to the annual consumption of 280,000 homes. 
This project will entail an investment of €350 million and 
will cover the surface of 740 hectares in 14 airports. 

The  main  decarbonisation  actions  currently  executed 
by AENA include the construction of self-consumption 
renewable  energy  facilities,  the  purchase  of  100% 
renewable  energy  with  guarantees  of  origin  in  all  the 
airports of the network, energy efficiency actions mainly 
in  electricity  and  air  conditioning,  and  the  promotion 
of  inter-modality  and  sustainable  mobility.  In  the  short 
term,  AENA  is  focusing  on  the  replacement  of  diesel 
vehicles with electric vehicles, promoting the deployment 
of a network of electric charging points in the car parks 
for passengers and employees, and the reinforcement of 
the  electrical  network.  In  the  medium  term,  AENA  is 
planning for the development of hydrogen technology as 

8 ■  Robert Schuman Centre | January 2021

fuel and as an electrical energy storage. AENA airports 
also have a close relationship with aviation fuel logistics 
operators, as they manage the construction and operation 
of the fuel infrastructure at its Spanish airports. 

As  mentioned  earlier,  greening  efforts  must  go  beyond 
the  airport  operator's  emissions.  When  it  comes  to  the 
technological solutions, there is growing consensus that a 
combination of SAFs and aircraft design will be necessary 
to  achieve  significant  emission  cuts  from  the  sector. 
When  it  comes  to  fuels,  an  emphasis  has  been  placed 
on  advanced  biofuels  and  synthetic  kerosene,  whereas 
electrification could play a role for short haul flights.

Current production of SAFs is low, but the share can be 
increased with coordinated regulatory support. Airports 
can leverage their unique position as an interface between 
airlines, aircraft manufacturers and developers of smart 
energy management systems, to scale up SAF production 
and  deployment.  Cooperation  of  stakeholders  from 
various parts of the supply chain is key to enable uptake of 
SAFs, though the possibilities will very much be shaped 
by regional contexts.

In  addition  to  regulation,  voluntary  industry  initiatives 
have an important role to play in stirring the greening of 
airports through the provision of reputational incentives. 
The  ACI  Airport  Carbon  Accreditation  programme, 
launched  in  2009,  is  a  particularly  interesting  example 
of  such  an  initiative,  based  on  existing,  cross-industry 
standards 
this 
programme  was  based  on  four  increasingly  stringent 
levels of accreditation (from 1 to 3+). On the first level 
of  accreditation,  an  airport  conducts  a  mapping  out  of 
its  own  emissions,  defines  action  plans  and  sets  CO2 
reduction  targets.  Subsequently,  the  airports  gradually 
expand the scope of their efforts to also cover third party 
emissions. 

for  carbon  management. 

Initially 

In order to support airports’ path to net zero emissions by 
mid-century,  ACI  recently  announced  the  introduction 
of  two  new  levels  of  accreditation,  namely  level  4,  also 
called  ‘transformation  level’,  and  level  4+  or  ‘transition 
level’. In order to be accredited at ‘transformation level’, an 
airport needs to define emission reduction targets only in 
absolute terms (i.e., the setting of CO2 reduction targets 
per  passenger  do  not  suffice),  whereby  the  level  of  the 
target needs to be aligned with the Paris Agreement (i.e., 
consistent  with  the  IPCC  scenarios  defined  for  the  1.5 
and 2 degrees pathways). Another novelty as compared 

to  the  previous  levels  is  that  airports  accredited  at 
‘transformation level’ will, under certain conditions, have 
the possibility to include third party emissions into their 
target scope. Level 4 accreditation includes a requirement 
for an extended carbon footprint in particular in relation 
to third party emissions, and a strengthened requirement 
as regards stakeholder engagement. ‘Transition level’ 4+, 
on the other hand, includes all of the above-mentioned 
requirements, plus the offsetting of residual emissions. In 
light of its global scope, the Airport Carbon Accreditation 
programme  has  had  to  balance  the  needs  and  contexts 
of different airports from around the world in  defining 
the  different  accreditation  levels.  Notwithstanding,  the 
programme is aligned with the EU’s climate targets, and a 
total of 329 airports worldwide, accounting for ca. 45% of 
global air passenger traffic, are carbon accredited today. 

The proper accounting of airport emissions was another 
key  element  brought  up  during  the  discussions,  as  not 
all  EU  Member  States  are  fully  integrating  the  climate 
impact of airport expansion into their plans today (e.g., 
currently  ongoing  legal  case  on  London  Heathrow). 
Participants  expressed  support  for  the  need  to  ensure 
that airport expansions are preceded by comprehensive 
environmental impact assessments. 

What are the Various Regulatory Options (E.g., 
Airport Charges- and Slot Regulation) Supporting the 
Shift Towards Greener Airports? What are the Funding 
Possibilities to Enable Greening of Airports? 

Airports have a number of instruments at their disposal 
to stimulate cleaner and quieter aircraft, including airport 
charges, incentives, operational rules and slot regulations. 
Airport charges, for instance, can be adapted to the noise 
or emission type of the plane. Alternatively,  charges can 
also  be  adapted  to  the  time  of  flight  (night  or  day),  in 
particular to tackle the issue of late night flights caused 
by delays. In Geneva airport, for instance, noise charges 
were increased for noisier aircraft three years ago. As a 
result, several companies have changed their planes from 
A330 to B787, A320 to Neo, or to A220.

Incentives,  on  the  other  hand,  can  be  used  to  favour 
airlines with higher load factors. Prior to the pandemic, 
in  Geneva  airport  load  factors  of  above  90%  had  been 
reached for both of their main airlines, which in turn has 
helped to reduce emissions per passenger. Furthermore, 

incentives can be given on the basis of airplane type, so 
as to incentivise airlines to bring into operation the last 
generation of planes which are linked to benefits in terms 
of  both  noise  and  emissions.  Lastly,  incentives  can  be 
used to support new fuel use, for which the price remains 
higher  than  that  of  conventual  jet  fuel.  Operational 
rules  can,  similarly,  be  used  to  regulate  noise  levels  by 
prohibiting take offs after a certain evening hour, and to 
introduce night bans for planes other than last generation. 
Slot limitations, on the other hand, can be introduced on 
the basis of plane types and other objectives. 

Whereas airport charges have a primary purpose of cost 
recovery  for  airports  to  cover  their  internal  costs,  the 
modulation  of  charges,  be  it  on  the  basis  of  CO2,  NOx 
or  noise,  must  be  revenue  neutral,  meaning  that  no 
additional revenue is generated for the airport as a result 
of  these  modulations.  Therefore,  while  modulations 
cannot be used to generate revenue for a low carbon fund 
for  instance,  they  can  help  to  incentivise  the  uptake  of 
cleaner and quieter aircraft. 

While  there  was  general  consensus  over  the  usefulness 
of  modulating  airport  charges  in  order  to  stimulate 
airlines to invest in quieter aircraft and tackle local issues 
such as noise pollution, there was disagreement among 
stakeholders about the question of whether modulation 
of  airport  charges  on  the  basis  of  CO2 emissions  is  an 
appropriate  instrument  to  stimulate  SAFs  uptake  by 
airlines.  What  is  more,  there  was  disagreement  as  to 
whether the modulation of airport charges on the basis 
of CO2 can effectively lead to a change in airline behavior 
in terms of uptake of cleaner aircraft. 

Proponents of a charging system based upon individual 
emissions  of  aircraft  argued  that  aircraft  that  emit 
more  should  pay  more,  as  long  as  airports  also  enable 
possibilities  for  airlines  to  reduce  their  emissions,  by 
providing  the  necessary  infrastructure  for  example. 
Furthermore, it was noted that modulations on the basis 
of CO2 can act as a nudge for airlines to accelerate fleet 
renewal  and  uptake  of  SAFs-powered  aircraft.  What  is 
more, there is a risk that if an obligation is imposed on 
airlines  for  the  deployment  of  SAFs,  airlines  may  take 
legal  action  against  the  application  of  the  fuel  mandate 
(e.g.,  US  airlines  have  a  track  record  of  litigation  in 
Europe). In view of this, some stakeholders argued that 
an  obligation  may  be  better  placed  on  the  level  of  the 
airport and the fuel supplier.

9 ■  The Role of Airports in the European Green Deal

According to airlines, however, the airport level is not the 
appropriate  level  to  regulate  CO2  emissions,  and  it  was 
thus  argued  that  airport  charges  should  remain  strictly 
consistent with the cost of infrastructure. Instead, it was 
cautioned that aviation regulations on CO2 need to be set 
at the highest level possible in order to mitigate the risk of 
carbon leakage (i.e., the risk of merely shifting emissions 
and  air  traffic  from  countries  with  more  stringent 
environmental  regulations  to  ones  with  weaker  or  no 
regulations,  as  opposed  to  reducing  emissions). This  in 
turn, opens up competition concerns among air carriers 
operating  in  jurisdictions  with  different  regulations.  A 
Europe-wide strategy to increase and facilitate the uptake 
of  SAFs  will  thus  be  key.  Airlines,  furthermore,  argued 
that airport charges modulated on the basis of CO2 will 
only have a marginal impact on airline behavior and on 
global climate. Even in the absence of regulations, airline 
stakeholders insisted that their behavior is influenced by 
natural economic incentives to become more efficient in 
terms  of  aircraft  type  and  engines,  given  that  these  are 
less consuming and enable cost-savings. 

Drawing  on  the  above,  a  message  that  emerged  from 
the  discussions  was  that  the  decision  as  to  whether 
modulated charges are to be applied is best determined at 
the local level by each individual airport in consultation 
with the airlines. Given that there is no solution that fits 
all, flexibility will need to be maintained in the regulatory 
environment. What is more, it was noted that the pursuit 
of  flight  route  optimisation  may  sometimes  lead  to 
inconsistencies  or  trade-offs  between  environmental 
objectives.  To  illustrate  this,  obtaining 
lower  CO2 
emissions through a more direct route can result in higher 
noise levels for local communities, which are no longer 
avoided.  This,  of  course,  underlines  the  need  to  ensure 
the right balance is stricken, whereby the role of charge 
modulations  was  particularly  stressed  for  addressing 
local environmental impacts. 

As regards the EU financing opportunities, the European 
Commission has recently launched a combined European 
Green  Deal  call  for  ports  and  airports,  whose  primary 
objective is to reduce the amount of emissions generated 
by  transport,  and  stimulate  the  shift  to  smart  and 
sustainable mobility. The call is organised along several 
clusters,  including  sustainability  (e.g.,  the  uptake  of 
SAFs), smart operations (e.g., using appropriate IT tools), 
multimodality (e.g., integrating multimodal connections 

to  city  centers  or  to  other  modes  of  transport  such  as 
rail), and ‘other’ aspects relating to the built environment 
(e.g., energy efficiency). The overarching objective of this 
call is to pool together different actors, also from outside 
Europe, with a view to test solutions locally, scale them up 
and adapt them to different contexts in terms of airport 
sizes and traffic volumes. 

Conclusion 

Aviation can be viewed as a fragmented system, whereby 
the  pieces  that  make  up  that  system  are  pursuing  their 
own  efforts  to  decarbonise  and,  at  times,  pulling  in 
different  directions.  It  is  clear  that  these  individual 
pieces  and  efforts  need  to  be  coordinated,  in  particular 
at the interfaces. The 14th Florence Air Forum focused on 
one  of  these  interfaces,  namely  the  airports.  Two  main 
takeaways  emerge  as  regards  airports’  role  as  interfaces 
in  achieving  the  European  Green  Deal  objectives. 
Firstly, airports can enable the decarbonisation of other 
stakeholders  in  the  aviation  value  chain,  notably  by 
providing  the  necessary  infrastructure  and  supplies  for 
SAFs  uptake  by  airlines.  Another  key  role  for  airports 
as  interfaces  is  the  provision  of  incentives  to  the  other 
parties (e.g., charges modulation for airlines and tender 
specifications  for  ground  handlers)  to  incentivise  the 
greening of their operations. 

The  airports  themselves  offer  important  ‘low  hanging 
fruit’  when  it  comes  to  decarbonisation.  Drawing 
on  the  experiences  of  airports  and  other  aviation 
stakeholders, however, some important bottlenecks need 
to be addressed. Firstly, there are operational bottlenecks, 
which  pertain  to  technological  challenges  with  regards 
to deploying electric vehicles at the airport premises for 
instance. Secondly, there are investment bottlenecks which 
are also particularly visible in the case of electrification, 
which  only  displays  its  cost  savings  potential  in  the 
longer term. This has been clearly illustrated in ground 
handling,  where  the  limited  contracting  period  and 
low  margin  nature  of  the  industry  prohibit  significant 
upfront  investments.  Incentives  will  play  a  key  role  in 
bridging these investments. Some investments targeting 
greening  will  inevitably  increase  airports’  costs,  which 
in  turn,  raises  the  question  of  how  these  higher  costs 
are to be financed. One obvious approach will be for the 
customers  of  the  airports,  namely  the  airlines  as  their 
biggest  customers,  to  shoulder  these  higher  greening 

10 ■  Robert Schuman Centre | January 2021

costs of the infrastructures by paying higher charges. The 
EU taxonomy for sustainable activities will be crucial in 
helping to identify the right investments to allow airports 
and aviation more broadly to decarbonise. 

To  conclude,  the  14th  Florence  Air  Forum  provided  a 
platform for discussion on the broad range of tools at our 
disposal to stir the greening of airports. Firstly, financial 
incentives (e.g., the design of taxes and charges) or public 
funding  (e.g.,  research  funds,  Recovery  and  Resilience 
Facility)  can  be  provided.  There  are  also  reputational 
incentives, in the form of self-action from the industry, 
whereby  ACI’s  Carbon  Accreditation  programme  has 
been  one  particularly  successful  example.  Though  not 
extensively discussed during the forum, the Commission 
is  currently  exploring  the  possibility  of  introducing  an 
environmental label for the aviation sector. All of the above 
measures will need to be carefully monitored to ensure 
that  environmental  regulations  do  not  compromise  the 
industry’s  competitiveness,  and  that  there  is  no  carbon 
leakage, which in turn could undermine the effectiveness 
of the measures. 

11 ■  The Role of Airports in the European Green Deal

Who Foots the Bill?

A comment by Juan Montero, Florence School of 
Regulation – Transport Area and UNED (Madrid)

Greening  projects  do  not  always  entail  an  increase  in 
infrastructure  operating  costs.  Some  projects  reduce 
emissions just by increasing efficiency. This is the case of 
more direct air routes. Some projects might require a large 
initial investment but they bring a long term return. This 
seems  to  be  the  case  of  thermal  insulation  of  buildings 
(including airport terminals) and also of electric vehicles. 
Even  if  these  projects  do  not  increase  costs  in  the  long 
term and may, in fact, result in lower operational costs, 
the challenge will be the financing of their higher upfront 
costs in the short term.

However,  reducing  emissions  will  often  require  an 
investment which increases airports’ operating costs. In 
these  cases,  it  is  necessary  to  decide  how  to  distribute 
this  new  cost  across  the  aviation  ecosystem:  public 
authorities,  airport  managers,  airlines,  passengers,  etc. 
Furthermore,  it  is  necessary  to  ensure  productivity  in 
this  kind  of  investment,  identifying  the  right  priorities 
and  promoting  the  most  efficient  technology  and  the 
most efficient solutions to reach the emission reduction 
objectives.

The crucial question is who should foot the bill for the 
greening of airports. The trend over the last decades has 
been to pass the infrastructure cost to the infrastructure 
users,  reducing  the  share  of  the  burden  on  public 
authorities  and  tax  payers.  In  the  case  of  airports,  the 
immediate  users  are  the  airlines,  and  the  indirect  users 
are the passengers (and also the cargo shippers). 

This  principle  seems  valid  also  for  greening  costs, 
following  the  ‘polluter  pays’  principle  and  the  overall 
policy to internalise external costs. Airports’ investment 
to  reduce  emissions  would  be  passed  to  airlines  in  the 
form of higher airport charges. Such charges would then 
be  passed  to  passengers  and  shippers  in  the  form  of 
higher fares.

However, the case for state funding seems strong in some 
particular  cases  and  at  least,  to  partial  extent,  also  for 
more  profitable  airports.  Airports  with  weak  business 
cases but general interest objectives (islands, remote areas, 
regional  airports)  might  require  state  funding  to  green 

their infrastructure and operations. Even larger airports 
might struggle to fund investments that do not improve 
their  business  case  in  terms  of  increasing  capacity  or 
improving facilities for passengers. State funding would 
accelerate  investment  and  ensure  the  earliest  effective 
reduction of emissions.

in  the  European  Union 

Funds  are  available 
for 
decarbonisation,  particularly  in  the  framework  of  the 
post-COVID-19 Recovery Fund. The greening of airports 
seems particularly well-suited to attract funds. These are 
the kind of projects that the EU and the Member States 
want  to  finance  to  reduce  emissions  and  incentivise 
economic activity and growth.

A further challenge will be to ensure investment in the 
right  projects,  namely,  those  that  increase  productivity 
while  effectively  reducing  emissions,  particularly  in  a 
fragmented  and  complex  ecosystem  with  numerous 
actors, as is the case of aviation and airports.

Overinvestment  in  infrastructure  to  be  operated  under 
exclusive  rights  or  under  limited  competition  is  a  well-
known  criticism  in  aviation.  The  existing  regulatory 
framework  provides  instruments  for  airport  managing 
bodies  to  justify  the  need  of  investment,  and  for  the 
airlines to contest the airports’ plans. Directive 2009/12/
EC  on  airport  charges  imposes  on  airport  managing 
bodies the obligation to consult with airport users before 
plans for new infrastructure projects are finalised (Article 
8).  A  consultation  process  is  defined  in  the  Directive 
(Article  6).  As  described  in  the  Directive  ‘It  is  vital  for 
airport users to obtain from the airport managing body, 
on  a  regular  basis,  information  on  how  and  on  what 
basis  airport  charges  are  calculated.  Such  transparency 
would  provide  air  carriers  with  an  insight  into  the 
costs  incurred  by  the  airport  and  the  productivity  of 
an  airport’s  investments.  To  allow  an  airport  managing 
body to properly assess the requirements with regard to 
future investments, the airport users should be required 
to  share  all  their  operational  forecasts,  development 
projects and specific demands and suggestions with the 
airport managing body on a timely basis’.

The emission reduction objectives require new types of 
projects, deploying new technologies and new solutions. 
The application of the traditional regulatory instruments 
might  require  a  refinement  to  identify  priorities  and 
guarantee the productivity of an airport’s investment. The 

12 ■  Robert Schuman Centre | January 2021

ongoing works on taxonomy to measure emissions and 
to  gain  a  better  understanding  of  specific  technologies 
and  solutions  to  reduce  emissions  are  preconditions  to 
justify the objectivity, proportionality and productivity of 
the investment plans. Greening should not be inefficient, 
or a justification for non-necessary investment.

The definition of the right incentives requires to take into 
consideration  the  complex  ecosystem  around  airports. 
For  instance,  ground  handling  companies  are  subject 
to  contracts  with  airports  to  deploy  their  facilities  and 
services, and then to contracts with airlines to charge for 
their services. Both contracts have to be coordinated so 
ground handling companies have the financial resources 
and the incentives to reduce emissions.

13 ■  The Role of Airports in the European Green Deal

Reducing Emissions at Airside: 
Reflections from the Viewpoint of an 
Airport 

A comment by Denise Pronk, Royal Schiphol 
Group

Airports have a lot in common with cities: shops, traffic, 
visitors,  business  people,  but  also  sustainability  issues 
like  energy  consumption,  waste,  people  with  reduced 
mobility  or  who  need  other  forms  of  support.  Airports 
have  to  be  resilient  to  future  changes.  As  our  climate 
continues to evolve, more extreme weather and climate-
related  events  are  expected.  The  frequency,  intensity, 
spatial  extent,  duration  and  timing  of  extreme  weather 
events are expected to increase, making flight disruptions 
and cancellations more likely.

Like  cities,  the  carbon  emissions  of  airport  operators 
are covered in the 2015 Paris Agreement. Most airports 
in  Europe  are  committed  to  net  zero  carbon  emissions 
by  2050,  and  globally  many  airports  are  aligning  with 
this  long  term  goal  as  well,  despite  the  unprecedented 
challenges the sector faces due to COVID-19. 

At  an  airport,  many  activities  are  operated  by  third 
parties. This situation complicates carbon management, 
since  many  of  the  emission  sources  are  not  under  the 
control of the airport operator. Other users of airports, 
including airlines, concessionaires and ground handlers, 
play an important role in improving overall emissions at 
airside and landside. The Airport Carbon Accreditation 
of Airports Council International (ACI) is a benchmark 
to  monitor  the  emissions  in  scope  1,  2  and  3.  The 
standardisation  of  carbon  management  helps  to  share 
best  practices.  The  ACI  Europe  sustainability  strategy 
aims also to accelerate the development of strategy and 
execution at airports.  

To  decouple  growth  from  activities  level  –  number  of 
flight  movements  and  passengers  –  is  key,  but  difficult 
with large fixed infrastructure. And, it is not only their 
own  net  zero  goal  that  airports  are  working  towards. 
Airports are pushing the envelope for a net zero carbon 
aviation  sector  in  2050.  The  responsibility  of  Schiphol 
airport  goes  beyond  its  own  activities  and  focuses  on 
reducing emissions inside the aviation sector.

The reason airports are frontrunners in cutting emissions 
is  twofold:  firstly,  airports  are  motivated  to  contribute 
to  the  Nationally  Determined  Contributions  of  the 
countries they are located in. Secondly, by reducing their 
own emissions and facilitating emissions of partners in 
the value chain, airports are enablers in transforming the 
aviation sector into a sustainable one. 

A  big  step  is  to  shift  to  renewable  energy,  generated 
by  additionally  built  wind  or  solar  farms.  Electricity 
emissions  (scope  2)  are  much  higher  than  scope  1 
large  volumes  of  renewable 
emissions.  However, 
electricity  are  scarce,  and  are  an  important  element  for 
sustainable  aviation  fuels  and  hydrogen.  For  airports  it 
is  key  to  continuously  lower  their  energy  consumption 
– with a lower energy bill as a win-win outcome – and 
increase local generation and storage of renewable energy 
in facilitating the transition from fossil fuels to electricity 
or hydrogen. The Green Deal can support this transition 
by developing an overarching EU energy policy. 

An advantage of airports – especially at airside – is that 
they are closed environments. The distances are relatively 
short, maximum speed is limited, the users are familiar 
with  the  field  and  there  are  few  operations  during  the 
night.  Because  of  its  high  sustainability  ambitions, 
Schiphol  airport  looks  for  new  and  environmentally-
efficient  ways  of  working  while  conducting  its  airside 
operations. These innovations are often not immediately 
available,  so  the  airport  can  help  to  co-develop  them. 
Airside can serve as a testing ground for new innovations 
like  electric  vehicles  and  ground  equipment.  It  could 
enable  new  technologies  and  products  in  other  sectors. 
However, it is important that innovations are beneficial 
for  other  sectors  in  order  to  secure  sufficient  demand 
for  the  products  and  services  and  thereby  render  them 
financially  attractive.  Airports’  influence  can  range 
far  beyond  their  own  activities.  The  Green  Deal  can 
address  this  requirement  in  research  and  development 
projects.  Even  more  important  is  to  focus  not  only  on 
the capital expenditure but on total life cycle – and not 
solely on the costs but also the value it creates on social 
and environmental areas. An integral approach is key to 
make sustainable products and services mainstream. 

Of  course  not  all  sustainability  improvements  are 
implemented  smoothly.  During  the  financial  crisis 
Schiphol airport invested in Fixed Power Units to lower 
its  environmental  impact.  However,  Schiphol  did  not 

14 ■  Robert Schuman Centre | January 2021

sufficiently  take  into  account  the  impact  on  working 
conditions  of  the  handlers.  Furthermore,  introducing 
new  ways  of  working  requires  the  ability  of  employees 
to  adapt.  Organisations  inside  and  outside  the  aviation 
sector have to be aware of this and pay attention to clear 
communication. Safety is a prerequisite in everything that 
happens  at  an  airport,  but  in  a  controlled  environment 
with a coalition of the willing it is always more possible. 

15 ■  The Role of Airports in the European Green Deal

Airports: The missing Link between 
Aviation and its Decarbonisation 

A comment by Andrew Murphy, Transport &  
Environment 

Airports  and  aviation’s  climate  impact  are  synonymous 
with each other. Climate activists hold up planned airport 
expansion as an example of our shared unseriousness in 
efforts to address the threat of a rapidly warming planet. 
There is a truth to this accusation: if we build the runways 
and  terminals,  more  aircraft  will  land.  And  right  now, 
these  aircraft  remain  almost  exclusively  dependent  on 
fossil fuels. This means that airports indirectly contribute 
to  global  warming.  Campaigners  are  therefore  right 
to  oppose  airport  expansion,  and  even  to  call  for  some 
oversubsidied airports to close.  

But  it’s  not  just  climate  change  campaigners  who  have 
a right to be worried. All of those who want our world 
to  be  better  connected  should  be  concerned  about  the 
aviation sector’s direction of travel. While other sectors 
such  as  electricity  and  road  transport  accelerate  their 
decarbonisation,  the  aviation  sector  risks  being  left 
behind.  At  a  time  when  sustainability  is  becoming  the 
driving factor in a company’s resilience, aviation needs to 
act now lest it quickly becomes fossilised. 

Airports  will  be  especially  exposed  to  climate  change 
and  its  politics  in  the  years  to  come,  for  they  are  the 
most unmovable aviation assets. Unlike aircraft, airports 
cannot  be  moved  to  regions  where  the  warming  or 
flooding effects of climate change are less acute, or where 
the regulatory environment is more favourable. 

This, however, can turn airports into allies in our efforts 
to drive decarbonisation in the sector. To play that role, 
airports need to act on two fronts: first, not worsen the 
problem; second, start delivering new solutions.

The  first  front  requires  governments  and  airports 
themselves to accept that, at least in developed countries, 
a temporary halt to airport expansion is necessary. Don’t 
worry:  a  temporary  halt  need  not  mean  permanent 
blocking.  As  the  UK’s  Committee  on  Climate  Change 
recently recommended, ‘There should be no net expansion 
of  UK  airport  capacity  unless  the  sector  is  on  track  to 
sufficiently  outperform  its  net  emissions  trajectory  and 
can  accommodate  the  additional  demand.’  The  focus 

16 ■  Robert Schuman Centre | January 2021

should be on decarbonising the sector now, rather than 
let  the  problem  snowball.  Once  decarbonisation  has 
taken off and aviation has caught up with other sectors, 
airport expansion can again be considered. 

The  second  front  requires  airports  to  play  a  lead  role 
in  reducing  the  aviation  sector’s  emissions.  That  goes 
beyond  decarbonising  their  own  activities,  such  as 
vehicle  ground  fleet  and  terminal  energy  consumption. 
Instead, airports need to be more proactive in deploying 
technology which can help decarbonise the full scope of 
aviation emissions. At present, the most viable pathway 
is  alternative  aviation  fuel,  such  as  synthetic  kerosene 
derived  from  additional  renewable  electricity  and  CO2 
captured from the atmosphere. There is one caveat in this 
alternative fuel pathway: it is essential that airports only 
support  these  new  fuels,  and  don't  give  any  support  to 
the sort of crop-based biofuels which compete with the 
planet’s food and forestry needs. 

What  is  the  role  for  regulators  in  all  of  this,  be  they 
EU-level  or  national?  First  and  foremost,  there  should 
be  a  recognition  that  the  approach  to  date,  i.e.,  leaving 
aviation  emissions  largely  unregulated,  has  done  the 
sector a disservice. International aviation emissions have 
been  excluded  from  national  climate  plans,  which  is 
inconsistent with the economy-wide targets of the Paris 
Agreement. This ineffective position urgently needs to be 
toppled, as some are already demanding.  

Excluding international aviation emissions from climate 
targets  may  provide  short-term  relief  from  taking 
meaningful  action,  but  has  allowed  our  planet’s  long-
term climate problem to build up. All of us are already 
paying  a  hefty  price  for  the  aviation  sector’s  marriage 
of  interest  with  passive  governments.  Both  have  swept 
aviation’s burning climate problem under the carpet. 

targets,  known 

Paris  Agreement 
as  nationally 
determined  contributions  (NDCs),  should  include  all 
aviation  emissions  based  on  fuel  sales.  That  is  the  start 
of  a  more  aggressive  programme  of  support  to  help 
the  sector  decarbonise.  The  programme  needs  to  be 
combative because the sector needs to urgently step up 
its decarbonisation game. Both regulators and the sector 
need to adopt a “big bang” approach and to develop an 
ambitious industrial policy. 

What would such an industrial policy look like? It would 
of course contain funding for research and development, 
but  more  than  that,  it  would  be  a  set  of  policies  which 
would  involve  clear  targets  and  timelines  for  new 
technologies to be developed and deployed. It would also 
include end dates for the use of fossil fuel in the sector, 
starting with the shortest journeys. These policies should 
be established at European and national level. 

Airports  have  a  central  role  to  play  in  supporting  this 
game-changing policy shift, for they are the missing link 
between the aviation sector and its clean future. 

17 ■  The Role of Airports in the European Green Deal

Robert Schuman Centre for Advanced Studies
The Robert Schuman Centre for Advanced Studies, created in 1992 and directed by Professor Brigid Laffan, aims to develop 
inter-disciplinary and comparative research on the major issues facing the process of European integration, European societies 
and  Europe’s  place  in  21st  century  global  politics.  The  Centre  is  home  to  a  large  post-doctoral  programme  and  hosts  major 
research programmes, projects and data sets, in addition to a range of working groups and ad hoc initiatives. The research 
agenda  is  organised  around  a  set  of  core  themes  and  is  continuously  evolving,  reflecting  the  changing  agenda  of  European 
integration, the expanding membership of the European Union, developments in Europe’s neighbourhood and the wider world.

FSR Transport 
The Florence School of Regulation (FSR) is a project within the European University Institute (EUI) focusing on regulatory 
topics. It works closely with the European Commission, and is a growing point of reference for regulatory theory and practice. It 
covers four areas: Communications and Media, Energy (Electricity and Gas), Transport, and Water.
The FSR-Transport Area’s main activities are the European Transport Regulation Forums, which address policy and regulatory 
topics in different transport sectors. They bring relevant stakeholders together to analyse and reflect upon the latest developments 
and important regulatory issues in the European transport sector. These Forums inspire the comments gathered in this European 
Transport Regulation Observer. Complete information on our activities can be found online at:  fsr.eui.eu

18 ■  Robert Schuman Centre - Policy Brief ■ Issue 2021/02 ■ January 2021

Florence School of Regulation, Transport AreaRobert Schuman Centre for Advanced StudiesEuropean University InstituteVia Boccaccio, 12150133 FlorenceItaly Contact:FSR-Transport: fsr.transport@eui.euQM-AX-21-002-EN-Ndoi:10.2870/82710ISSN:2467-4540ISBN:978-92-9084-957-5Views expressed in this publication reflect the opinion of individual authors and  not those of the European University Institute.  © European University Institute, 2021Content © Matthias Finger, Teodora Serafimova, and Juan Montero, 2021