National Policy Statement on Airport Charges Regulation

National Policy Statement on Airport Charges Regulation

Summary Minister for Transport, Tourism and Sport is proposing legislative amendments to the Aviation Regulation Act, 2001 to give effect to changes to the current regulatory regime for setting airport charges at Dublin airport. These changes are informed by a review of the current regime, which included an independent assessment of its effectiveness and industry and public consultation. The key points are: Dublin Airport will continue to be subject to price regulation in recognition of its significant market power. Shannon and Cork airports face effective competition and therefore there is no basis for applying economic regulation of charges at these two airports. The primary purpose of the regulation shall be to protect and advance the best interests of current and future customers who use Dublin Airport. The Regulator shall no longer be mandated to have specific regard to the financial sustainability /viability of the regulated entity in making a Determination. There will be a single stage appeals process which will involve taking appeals directly to the High Court or Commercial Court. The statutory basis for Ministerial Directions in relation to the price determination process will be removed and replaced with a requirement on the Regulator to have regard to current Government aviation and airport policy. 3

Contents Introduction 5 Policy Statement 7 Continued Rationale for Regulation of Airport Charges 8 Enhancing Regulatory Independence, Performance and Oversight 11 Structural Reforms: Strengthening Governance and Regulatory Capacity 14 Competiveness and Competition 16 Sustainability: Responding to Climate Change 18 4

1. Introduction This Policy Statement meets a commitment contained in the National Aviation Policy (August 2015) to review and restate Government policy on airport charges regulation in Ireland. The primary objective of the Policy Statement is to provide clarity on the Government s position regarding the regulation of airport charges in Ireland over the medium term and in doing so to refresh key elements of the existing regulatory framework. The Policy Statement is crafted within the overarching Strategic Framework set out in Regulating for a Better Future: The Government Policy Statement on Sectoral Economic Regulation (July 2013), which provides the national strategic policy context for sectoral economic regulation. This revised Policy Statement on Airport Charges Regulation draws on an independent expert assessment by Indecon International Economic Consultants, on input from a public consultation process and on a working group report from the National Civil Aviation Development Forum (the Forum). 1 The independent expert assessment by Indecon provided a sound basis for an informed, evidence-based policy review and helped shape the public consultation and the Department s engagement with industry stakeholders. In finalising the Policy Statement, the Minister for Transport, Tourism and Sport has sought to anchor it in the independent economic analysis and give due regard to the expert industry knowledge shared through the Forum and the public consultation. There are differing views about the merits of economic regulation, about the appropriate strategic objectives and about the best regulatory model, all of which were apparent from the consultation process. Notwithstanding these differences, the independent review and public and industry consultation that informed the finalisation of the policy also revealed a high level of common ground. It is on this common ground that the revised regulatory policy is mostly founded, with the Minister focusing on accentuating the common interest of airport users, the airport company, the airlines that serve it and the needs of the broader economy. 1. The Forum is an industry wide consultative body, chaired by the Department of Transport, Tourism and Sport, which brings together key stakeholders in pursuit of a common interest to develop the Irish aviation sector. 5

CONSUMER INTERESTS Choice Value Quality Service Safety & Security SECTOR INTERESTS Profitability Growth Competition/Access Regulatory Stability ECONOMY INTERESTS Competitiveness Connectivity Capacity 6

2. Policy Statement The overriding strategic objective of the economic regulation of airport charges in Ireland is to ensure that current and future airport customers are presented with choice, value and quality services which also meet the highest international safety and security standards. 2 Customers interests shall be the primary concern of price regulation. Regulation policy also recognises the importance of the timely provision of capacity, enhanced connectivity, strong competition and the financial sustainability of the aviation sector more generally, each of which is key to ensuring that the primary interests of the customer are served and that national economic competitiveness is advanced. 2. In the context of airport charges regulation, customers are departing/arriving airline passengers and businesses/individuals who use cargo services provided at the airport. 7

3. Continued Rationale for Regulation of Airport Charges The primary purpose of effective economic regulation is to recreate the benefits to the consumer of a competitive market in circumstances where there is not sufficient competition because of the market dominance of one or a small number of service providers. In the absence of competition or economic regulation to replicate competition, consumer interests are not best served and prices are more likely to be higher than they should be and service levels are likely to be lower than they should be. In circumstances where there is competition between service providers and where this results in choice and good value for the consumer there is no legitimate basis for independent economic regulation. This has been the principal theoretical context for the review. 3.1 Current Regulatory Framework Airlines are charged by airport operators to use airport facilities and services as a way of the operators making a commercial return on their investment, including recovering the capital cost of the infrastructure (including runways, terminal buildings) and the operating costs of terminal services (including processing passengers, safety checks). Although such charges are levied on airlines, the cost is ultimately borne by the passenger. Since 2011, the EU Airport Charges Directive (2009/12) has provided a baseline EU-wide framework for regulating the essential features of airport charges at all EU airports with annual passenger numbers in excess of 5 million. The rationale for this EU-level intervention was to put in place a framework for the regulation of airport charges because it was found that not all Member States had a functioning, nondiscriminatory procedure for calculating airport charges. The EU Directive mandates a process of direct consultation between airport operators and airlines in finalising airport charges, with disputes arising from this consultation process referred to an independent, supervisory body for final decision. The specified objectives of the Directive are: i. Fairness - to improve the countervailing bargaining power of airport users, especially when dealing with airports with market power; ii. Fair competition - between EU airports by the introduction of common charging principles; iii. Transparency - in the charging systems applicable to users of airport infrastructure; and iv. Capacity provision - ensuring that sufficient revenues are generated to maintain and complete airport infrastructure at an optimal level. 8

In the absence of such rules, the EU considered that the market power of some airports could be reflected in unduly high prices for their services or in unduly low quality and range of services offered. Indeed, the regulatory impact assessment that accompanied the EU Directive found that there was limited airport competition among EU airports and that taking no action at EU level might have led airports with market power to increase charges. 3 In Ireland, airport charges have been subject to economic regulation since 2001, as prescribed in the Aviation Regulation Act, 2001. Implemented by the Commission for Aviation Regulation (the Regulator), the Irish regulatory framework for airport charges is more stringent than the model set out by the EU Airport Charges Directive. 4 Currently, Dublin Airport is the only airport in Ireland subject to price capping by the Regulator, on the basis of its market dominant position. Under the Act, the Regulator issues periodic regulatory determinations that cap the maximum price on a per passenger basis - that Dublin Airport can charge airlines for use of and access to airside infrastructure and terminal facilities. These determinations which can be appealed under the law to a Ministerial appointed Appeals Panel - take account of the airport operator s cost base, future development and investment plans and its income streams, including from commercial operations in and around the airport. In determining the maximum price for airport charges under the law, the Regulator is currently required to take into account three statutory objectives, namely: the efficient development of Dublin airport; the interests of current and future users; and the continued financially sustainability of the regulated entity. It is also required to take account of Ministerial Directions issued by the Minister for Transport, Tourism and Sport. 3.2 Outcome of the Review and A Future Regulatory Framework The Review represented the first assessment of economic regulation of airport charges in Ireland since the transposition of the 2009 EU Directive, and so the Directive s implications for how airport charges should be set and agreed at Dublin Airport into the future formed part of the Department s deliberations. The current price cap regulatory regime for airport charges in Ireland that applies to Dublin Airport is a fairly common form of economic regulation that is applied across Europe - for example at London Heathrow, Amsterdam Schipol, Paris Charles de Gaulle, Rome Fiumicino and Copenhagen. It is a stronger form of regulatory intervention than the baseline model prescribed by the EU Directive. Having regard to the conclusions of the expert, independent economic review by Indecon, to the majority consensus from the public consultation process (including the Forum) and to other international expert studies (most notably by the OECD), the Minister for Transport, Tourism and Sport accepts that Dublin Airport retains significant market power to a degree that makes continued economic regulation in excess of the minimum standards required by the 2009 Directive in the best interests of the consumer. The Indecon analysis concludes that with a two-thirds market share of airport users on the island of Ireland, Dublin Airport holds significant market power which is not sufficiently offset by the countervailing buying power of the two major anchor airlines Aer Lingus and Ryanair to warrant a reduced level of regulatory oversight. 3. Roadmap for the Evaluation of the Directive 2009/12/EC on Airport Charges, September 2016, European Commission 4. The Directive allows Member States to apply more stringent regulatory requirements for airport charges if they deem it necessary. 9

OECD analysis suggests that this reflects the picture across Europe, where the intensity of competition amongst primary or hub airports is limited (OECD 2010). 5 In an Irish context, previous expert analysis by the Economic Intelligence Unit (March 2009 6 ) and the Review Group on State Assets and Liabilities (2011 7 ) also found in favour of continued economic regulation at Dublin Airport. 3.3 Key Principles of Airport Charges Regulation Deriving from this finding in favour of the continuation of economic regulation of airport charges at Dublin Airport, the key principles of the revised policy on airport charges are: The primary strategic objective of the regulation of airport charges is the protection of customer/consumer interest in the form of good value, choice, quality services and safe and secure facilities. The timely provision of safe and secure airport capacity, more competition, increased connectivity and a financially robust aviation sector are in the best interests of the customer/consumer and in the national interest with regard to competitiveness and continued economic development 5. Airport Regulation Investment and Development of Aviation, 2010, OECD Publishing, Paris. 6. Review of the Regulatory Environment in Ireland, 2009, Economist Intelligence Unit (London) 7. Report of the Review Group on State Assets and Liabilities, April 2011 (Dublin) 10

4. Enhancing Regulatory Independence, Performance and Oversight In circumstances where there is a compelling case for economic regulation - which the Review concludes there is for Dublin airport - it is important that the regulatory framework and the supporting institutional arrangements are effective and efficient and that the decision making process is consultative and transparent. The Review process examined the current regulatory regime, including the determination process, the public consultation element of that process, the role of the Minister for Transport, Tourism and Sport in the context of issuing Ministerial directions and the existing appeals process. Overall, the current system was found to compare favourably with international practices, that it benefitted from clarity in the legislation on the strategic objectives of the regulatory regime and that it was carried out in a transparent and open manner. However, the Indecon report, the public consultation and the report of the working group of the Forum suggested there was scope for improvement and enhancement of the current regime. In particular, improvements were proposed regarding the scope of Ministerial directions issued during regulatory reviews, the effectiveness of the current appeals process and the level and nature of consultation/engagement between the Regulator, the airport and the airlines. 4.1 Regulatory Reform: Building from a Position of Strength Ireland has a statutory based regulatory regime for airport charges that provides legal clarity for the regulation of airport charges. The Aviation Regulation Act establishes the Regulator as a stand-alone independent body, prescribes the strategic objectives of airport charges regulation, sets the timeframe for making a determination and imposes a four year time limit on the applicability of a regulatory determination. The law also requires that the Regulator engages in extensive and transparent public consultation in finalising its regulatory determination and that it makes annual reports to the Minister and the Oireachtas. These components provide certainty and transparency as to how the regulatory system works. As stated in the Government s 2013 policy statement on economic regulation, The independence of regulators provides regulator certainty, facilitates stability and helps promote investor confidence. These outcomes in turn should contribute to a better overall outcome for the consumer. 11

A key challenge in price cap regulation is to strike the appropriate balance between the integrity and incentives of a multi-year price determination and the level of flexibility necessary to enable the regulated company to respond to changing conditions within the determination period. To date, the Regulator has assigned volume risk to Dublin Airport - which gives Dublin Airport the flexibility and motivation to meet operating costs with growing revenues - and for capital expenditure, the Regulator gives Dublin Airport the flexibility to reassign a significant amount of its planned capital investment from one project to another to respond to changing service and capacity pressures. There is broad consensus that regulatory certainty is important for all stakeholders - including consumers, investors (current and future), and companies (and their shareholders) operating in the regulated market and the challenge is to strike a balance that provides a stable trading and commercial environment but which is also flexible to respond to market developments and changes in market dynamics. Achieving this balance is a constant theme of research and expert commentary on economic regulation, whereas on the one hand regulatory uncertainty discourages investors and raises the cost of capital and hence prices to consumers 8 and on the other hand a lack of flexibility could affect new business models and emerging markets. 9 The review process has suggested that there is an opportunity to improve on existing arrangements to enhance performance oversight, strengthen the independence of the regulator and develop some flexibilities within the regulatory system to the mutual benefit of consumers and service providers. Regarding flexibilities, there is need for further engagement between the Department, the Regulator and industry to work through specific measures and their legal implications. 4.2. Reform Measures Measures are already in train to improve regulatory oversight. In keeping with the Government s national policy statement on economic regulation and with requirements in the revised Code of Practice for the Governance of State Bodies, the Regulator recently finalised a three-year Strategy Statement which sets out its priority actions and delivery targets for the period 2017 to 2019. This includes agreed performance indicators, progress against which shall be reported on an annual basis to the Minister for Transport, Tourism and Sport and the Oireachtas. Moreover, in the time since the completion of the Indecon report and public consultation, the Regulator has also amended its regulatory model and introduced a new accelerated process to allow Dublin Airport to get regulatory agreement for additional capital investment in response to changes in circumstances. This new formal process, for example, allows for a much speedier response by the airport to service pressures arising from passenger volume growth shown to be significantly higher than the forecasts contained in the original regulatory determination. This enhancement has been possible within the existing legal framework. 8. Report of the Review Group on State Assets and Liabilities, April 2011 (Dublin), page 18 9. The Role of Economic Regulations in the Governance of Infrastructure (OECD 2017), OECD, Paris. 12

In addition to these measures already underway, the following enhancements will be made to the regulatory regime: The Regulator shall no longer be mandated to have specific regard to the financial sustainability /viability of the regulated entity in making a Determination. The need for an efficient, commercially viable airport company is intrinsic in the primary objective of protecting the interests of current and future customers. In keeping with the Government s policy statement on economic regulation, the appeals process as provided for in the Aviation Regulation Act, 2001 will be amended to provide for a single stage appeals process that involves taking appeals directly to the High Court or Commercial Court. There will be a statutory basis for the periodic review of the regulatory regime in accordance with national policy directions set out in Regulating for a Better Future: A Government Policy Statement on Sectoral Economic Regulation (July 2013). The requirement for the Regulator to produce Strategy Statements and to report annually on progress against agreed performance indicators will be put on a statutory footing. The Department will establish and chair a working group of key stakeholders to examine and report on options to allow the regulated entity and its airline customers to reach price agreements amongst themselves, subject to Regulatory oversight. The statutory basis for policy directions by the Minister for Transport, Tourism and Sport to the Aviation Commission as provided for in Section 10 of the Aviation Regulation Act, 2001 will be repealed. In its place will be a requirement for the Regulator to have due regard to current Government aviation policy. 13

5. Structural Reforms: Strengthening Governance and Regulatory Capacity There are currently two State organisations with a role in aviation regulation: the Commission for Aviation Regulation (CAR) and the Irish Aviation Authority (IAA). The CAR s primary regulatory function is to set airport charges and oversee the independent allocation of landing slots at Dublin airport, and it also has responsibility for regulating ground handling agents and passenger rights (including persons with reduced mobility). The IAA is responsible for the regulation and oversight of civil aviation safety and security in Ireland, and it has a commercial mandate to provide air traffic control for flights landing at Irish airports and for en route over flights using Irish airspace, within an EU regulated charging framework. As outlined in the National Aviation Policy, the Government is committed to restructuring the functions of the IAA and the CAR to reflect best international practice and developments at EU level. 5.1 CAR - Capacity Issues The CAR manages a technically complex regulatory process from an economic, commercial, financial and legal perspective which has far-reaching implications for the aviation sector generally, airport capacity development, international connectivity and national competiveness. Its regulatory determinations on airport charges and regulatory oversight of airport slots have a huge impact on competition at Dublin airport, on commercial activity at the airport and across the sector and on the long term development and well-being of the aviation industry in Ireland. All the while it is required to respond to wellresourced industry players with competing needs and demands. In addition, the CAR also has responsibility for licencing IATA travel agencies operating in Ireland and for ancillary consumer protection issues related to air passenger rights. This is a considerable responsibility on what is a relatively small organisation in terms of personnel, and it underscores the need to retain a critical mass of relevant expertise and experience from one regulatory period the next. As currently configured, the CAR s dependence on a small number of expert staff makes it quite vulnerable, and this is a matter of concern given the importance of its role. 5.2 IAA Dual Mandate - Safety Regulation and Commercial Interests Under current arrangements, the IAA has a dual regulatory/for-profit mandate. It has built up a high performing safety/security regulatory and inspection capacity and has been diligent in putting in place appropriate internal corporate structures to separate this 14

function from the for-profit interests. There are robust international and national audit regimes in place administered by ICAO, EASA and the Department of Transport, Tourism and Sport. Combined, these serve to provide extensive external oversight and assurance of the IAA s regulatory/safety system and its performance. In international terms, the IAA scores very highly under the ICAO and EASA audits in regard to its safety-related responsibilities. It is shown to be well resourced, with technical expertise and industry experience that is amongst the best in Europe. The Department s own, most recent audit of the IAA s functions in 2015 - carried out by independent experts under Section 32 of the Irish Aviation Authority Act, 1993 - underscores this high performance level. However, there is inherent conflict in IAA s dual role which requires it to have, on the one hand, a commercial relationship with airports and airlines, and on the other hand be an independent safety inspectorate and regulator of the same companies. Moreover, the IAA s safety remit which is implemented by its safety division - extends to regulating the company s own for-profit air traffic control operations. The Department has for some time considered this dual mandate as sub-optimal, a position that is reinforced by the most recent Section 32 audit, which highlighted the lack of legal separation between the IAA s regulatory and service provider functions as an anomaly, with potential conflicts. Having reflected on this, the Minister for Transport, Tourism and Sport is of the view that there is an opportunity to create a stronger, legal separation of these functions. 5.3 Building Regulatory Capacity In light of the capacity and governance issues arising from the current institutional arrangements in the sector presented by the CAR and the IAA, the Minister sees clear legal and strategic synergies between the aviation safety and security function of the IAA and the airport regulation and consumer protection function of the CAR. These have been examined by the Department of Transport, Tourism and Sport and are well understood. It is therefore proposed that the regulatory and safety functions of the IAA will be merged with the regulatory and consumer protection functions of the CAR to form a new aviation regulatory authority. The residual for-profit functions of the IAA will be retained as a regulated State-owned enterprise. This level of structural reform has complex legal, financial, operational and industrial relations components, and so the Minister is mindful of the need to manage the transition to the new arrangements carefully. The following next steps will be taken toward the reconfiguration and incorporation of aviation functions currently carried out by the IAA and the CAR: There will be consultation with the IAA board and the management and staff of both organisations to inform an implementation plan and to ensure that the process is managed effectively and in a timely manner whilst maintaining operational integrity. Proposals for the necessary legislative amendments will be brought to the Government for final approval 15

6. Competiveness and Competition As a key driver of national economic competitiveness, properly functioning competitive markets help drive efficiency, innovation and investment for the ultimate benefit of customers and the broader economy. Competition in the aviation industry, particularly amongst airlines, has been hugely beneficial for the Irish economy over the last three decades. It has delivered lower prices and greater connectivity, which in turn have helped drive growth and jobs creation within aviation and also more widely across the economy, particularly in tourism and in the multinational sector. The Government s National Aviation Policy (NAP), which was agreed in 2015, sets out the competitive framework for the aviation industry in Ireland. The NAP reaffirms the Government s commitment to supporting competition between airlines currently based in and serving Ireland and also underscores its commitment to facilitate a market which is open to new entrants that offer enhanced connectivity and competition. With regard to competition between and within airports, current Government policy as set out in the NAP is that the public interest and the interest of the economy as a whole are best served by having three State airports at Dublin, Cork and Shannon in full state ownership, whilst operating on a commercial basis within a regulatory framework. This agreed ownership and operational structure is subject to periodic review, arrangements for which are being made with a view to completing such a review in the second half of 2019. As stated at the outset of this policy statement, the overriding strategic objective of the economic regulation of airport charges in Ireland is to ensure that current and future airport customers are presented with choice, value and quality services. Accordingly, the overarching strategic objective of airport charges regulation is to ensure that current and future passengers have access to good quality airport facilities and services at a competitive price point. The regulatory regime is designed to determine what is a fair and competitive price point by balancing off short term gains (low prices) with long term needs (future capacity expansion) and by ensuring appropriate investment in safety and security systems is also made. In ensuring that the interests of the passenger is put first, it falls to the Regulator to find fair and balanced middle ground between the competing interests of the main service providers, i.e. the airport operator and the airlines. As is the case in airport regulation the world over, airports and airlines positions differ regarding economic regulation of airports, with airlines typically arguing that airports have market power and the ability and incentive to exercise it and therefore they support a general strengthening of [regulation], while airports point notably to the growing competition among European airports and among European and non-european airport hubs, to justify a less rigid legal [regulatory] framework. 10 10. Roadmap for the Evaluation of the Directive 2009/12/EC on Airport Charges, September 2016, European Commission 16

Under current Irish law, part of the Regulator s remit in determining airport charges is to ensure that there is sufficient capacity provision in the short and medium term to meet expected traffic volumes. Separate from the airport charges regime, the Regulator is also responsible for overseeing the allocation of slots at Dublin Airport. These two separate but interlinked responsibilities are central to protecting and promoting competition. At certain times of the day, for example in the early morning, demand for slots (i.e. access to the runway, stands and terminals) at Dublin Airport exceeds availability and, as is the case in many airports (including London Heathrow for example) access to slots at peak is a key dynamic in determining the level of competition amongst airlines and the extent of choice for consumers over the short term. Where new infrastructure or changes in processes allow for additional capacity the CAR will declare additional slots. To promote competition between airlines, the coordinator (appointed by the CAR) allocates 50% of the new slots to new entrants. Over the longer term, the airport charges regime is also critical to promoting competition by ensuring that sufficient and appropriate additional capacity (provided through additional piers, terminal, runway) is brought on stream to meet growing demand and to provide additional access points for expansion by incumbent service providers and opportunities for new entrants. A key theme arising from the regulatory review and the public consultation was the need for an explicit reference to the promotion of competition in the legislation underpinning the regulatory regime. The Department s view is that the principle of promoting competition has been an inherent, founding principle of the regulatory regime since its introduction. The high level of competition at Dublin airport amongst airlines is a strong indicator of this. However, the Minister for Transport, Tourism and Sport accepts that there is merit in providing an explicit reference to competition in revised legislation. 17

7. Sustainability: Responding to Climate Change Ireland recognises that it is necessary to reduce aviation emissions in order to ensure the sustainable development of international air transport. As this is not a policy challenge that Ireland can meet acting alone, given the global nature of the aviation industry, it continues to pursue an agenda in favour of climate action as a member of the EU and international community. Therefore, with regard to climate change commitments, Ireland s aviation and airports regulation policy is shaped by developments and initiatives at EU level and by its membership of the International Civil Aviation Organisation (ICAO). The EU has already put in place strong regulatory tools, including the Emissions Trading Scheme, to address greenhouse gas emissions including from aviation. 11 In addition, there is strong commitment under the EU Energy Union agenda to invest in research and development opportunities targeted at reducing aviation s environmental impact, including in the area of biofuels. Within Single European Sky, the environmental performance of air navigation services is now a key performance metric, with steps already taken to shorten flight paths and further research under way to try to reduce fuel use and avoid up to 50 million tons of CO2 emissions. At a national level, Ireland s Action Plan for Aviation Emissions Reduction 2015-2019 outlines the measures to be taken to reduce aviation emissions. For instance, Ireland s registered airlines are fully committed to reducing emissions through investments in next generation aircraft and engine technologies. In addition, by engaging with Enterprise Ireland and the relevant public bodies, Ireland facilitates research and development in the areas of sustainable and renewable fuels in the aviation sector. Operational improvements in air traffic management, such as the introduction of Point Merge to Dublin Airport in 2012, are also contributing to a reduction in energy emissions. 12 Further impactful, sustainable and meaningful policy interventions in this area are only possible in the context of EU wide or global agreements. The Department is firmly of the view that the aviation industry has more to do in terms of making a contribution to the global effort to offset the impact of climate change and it will continue to advocate for this at EU and ICAO level. The obligation to deliver is clearly understood by aviation policymakers. As stated in the European Aviation Environmental Report 2016 drawn up on a joint basis by the European Aviation Safety Agency, Eurocontrol and the European Environment Agency future growth in the European aviation sector will be inextricably linked to its environmental sustainability. 13 In the context of airport charges regulation, which affects capacity provision and operations at Dublin Airport, it is proposed to insert a new provision in the revised legislation that shall require the Regulator to have regard to Government policy on climate change and sustainability as part of the regulatory determination process. This is to ensure that future airport capacity development is advanced in accordance with the broad objectives of the National Mitigation Plan, which aims to enable transition to a low carbon, climate-resilient and environmentally sustainable economy by 2050. 11. EU Directive 2003/87/EC, establishing a scheme for greenhouse gas emission allowance trading within the Community 12. An Aviation Strategy for Europe, Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions, December 2015, Brussels. 13. European Air Transport Environment Report, EASA, February 2016. 18

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