Position Paper on Revision of Regulation 261 / 2004

Airport Regions Council (ARC), the organization of cities and regions hosting an airport in their territories, on one hand, recognizes and supports that airports are vital nodes in Europe’s connectivity and economic competitiveness and, on the other, considers noise as the most important environmental impact to population living nearby. Therefore, we would like to express our concerns and proposals regarding the current course of the revision of Regulation 261/2004.

ARC believes that the goal of the revision of EU261 should be to rebalance elements of that protection, supporting the consumer while meeting the needs of a modern and competitive air transport network for Europe. 

Airlines, airports, airport regions and the whole European sector (from planes makers to passengers) have a shared vision: a strong aviation network that offers connectivity, value for money, performs as promised becoming a key aspect of a cohesive Europe. Therefore, we consider that adding further financial and operational burdens without addressing the roots causing travel disruption – such as infrastructure, air traffic management (ATM) constraints and others – it’s not the way to deal properly with the topic -it’s like just given pills to low fever to a patient without looking for the reason of the fever-. This approach can threaten the present affordability of air travel and the reasonable levels of choice and competitiveness of transport to, from and across the EU. 

Airport Regions Council would like to highlight the following critical concerns: 

• No impact assessment: Proposing additional cost burdens on airlines and consumers without assessing their impact on ticket prices and route viability is reckless and it never should be the procedure to deal with any topic.

• Disregard for operational realities. All proposals relating should have to be developed with realistic analysis of the impact of airline operations.

• Lack of definition. Proposals regarding aviation can never be vague in any aspect as it can create a great confusion and unnecessary problems for all, including passengers.

It’s the opinion of ARC that main priority of the revision should be to clarify the rules, keep flying accessible to all and keep Europe connected taking in consideration that are many different types of routes (long-haul, short-haul, regional, public service obligations) with distinct characteristics but also many interdependencies within the European aviation network. The times for ‘one-size-fit-all’ approach are gone with the wind long time ago.

Last but not least, Airport Regions Council is deeply concerned about the potential huge negative impacts on regional routes what are key for European connectivity and to guarantee the cohesion of remote European zones. The negative impacts will hit too regional airports and will unnecessary the risk of closure for ever.