Letter to European Commissioners Bulc and Arias Cañete, ECAC President Cherfils, ECAC Vice President Gandil on European Civil Aviation Conference

Dear Commissioners Bulc & Arias Cañete, ECAC President Cherfils & Vice President Gandil,

We, European NGOs active in aviation environmental policy, have deep concerns about the extent and effectiveness of opportunities for dialogue between European NGOs, other civil society groups and EU member states, ECAC states and the European Commission on aviation climate change and the environment. This, for example, because at the first session of the newly reconstituted ECAC Environmental Forum, we sought to engage fully, having submitted detailed papers on supersonic aircraft and transparency in the hope that a serious discussion would ensue. In both cases we were disappointed. Discussion barely proceeded beyond the conveying of known information. Member states essentially declined to engage.

We raised our concerns about the lack of usefulness of the Forum with the meeting Chair at the time and followed up on 18 January 2018 by email to ECAC and the European Commission. There has been no response. In the runup to the second Environmental Forum and in the hope that changes can be made, we wish to reiterate these concerns which have deepened given events over recent months.

Both in ECAC and other fora, a clear trend is evident that opportunities for NGOs to engage with policymakers are not being made available and in fact diminishing. For instance, the draft agenda for the ECAC 36th plenary session in Strasbourg last July listed a panel discussion on environmental issues including representatives from member states, the European Commission and IATA. We wrote months in advance seeking a spot on the panel. This was declined because we were told participation had been fixed. But we later learnt that an FAA representative had subsequently been added to the panel. We also raised multiple times with the Austrian hosts and Commissioner Bulc’s office, the hope that the environment and civil society be given a formal voice at the Aviation Summit just held in Vienna. To no avail. We see that local groups took their own initiative.

Apart from stakeholder meetings prior to CAEP – and we believe two such preparatory meetings are needed – the reality is that there are no forums where environmental stakeholders can engage in a constructive dialogue with member states, the Commission and other European stakeholders. About European aviation policy. This, for example, is in stark contrast to the shipping sector which has the European Sustainable Shipping Forum (ESSF) where, unlike ECAC, the relevant UN agency is appropriately not present. And now we understand third countries will also be participating in the second ECAC Environmental Forum this December which will further impact on the opportunity to have direct exchanges about European policy.

We strongly believe that a dedicated forum to discuss, in the first instance EU policy, with European industry and environmental stakeholders alone is needed. The sector is facing unparalleled climate and environmental challenges which have been clearly underlined this week by the IPCC. The Commission is developing a decarbonisation strategy for Europe. Decisions about European participation in the CORSIA are drawing near. Highly polluting supersonic aircraft may return to commercial service etc. All these issues point to the urgent need for a far more robust and effective consultation process on European policies and approaches to aviation climate change and the environment.

We wish to have an open discussion about these issues and urge you to see that appropriate changes are made.

Sincerely,

William Todts – Executive Director, Transport & Environment William.todts@transportenvironment.org

Dominique Lazarski – President UECNA  dlazarski.uecna@gmail.com

Tim Johnson – Director, Aviation Environment Federation tim@aef.org.uk

Eva Filzmoser – Executive Director, Carbon Market Watch  eva.Filzmoser@carbonmarketwatch.org

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Letter on ECAC