Comments on the National Aviation Strategy - International Air Transport Association
The International Air Transport Association welcomes the opportunity to submit comments on the suggested National Aviation Strategy.
IATA is the trade association for the world's airlines representing some 300 airlines and 83% of global air traffic. With a mission to represent and lead the industry, IATA supports many areas of aviation activity and contributes to the formulation of policies concerning civil aviation.
Air connectivity is a key element for the competitive positioning of countries such as Norway. Aviation is a global business, still under recovery. We hence pledge the States to refrain from individual patchwork solutions that are not regionally harmonized.
Infrastructure
Airlines, passengers, and cargo need safe, functional, efficient and affordable airport infrastructure for their operations to thrive. IATA works with airports and government authorities on major airport development projects across the globe and seeks to ensure that they result in adequate infrastructure for airlines.
IATA has developed a position paper on the best practice for consultations about airport infrastructure investment (https://app.box.com/s/j4ax10jk5hp0fcsju78p85kg4o0i0tx1). Per the position paper, user consultation is key from an early stage and before any irreversible decisions. In addition, a jointly agreed airport-airline community governance structure is required ensuring a planned approach to consultation.
Norway has a duty to ensure that airport users are consulted prior to the finalization of plans for new infrastructure. There may be better and more cost-effective financing options available, which should be explored within the consultation process. Airport users should also have visibility over the proposed facilities that they have been requested to fund. Transparency is key.
IATA offers its assistance with the consultation process by sharing global best practice implementations to ensure a fit-for-purpose framework for the Norwegian airports.
IATA welcomes the creation of a committee tasked with investigating the needs and future capacity of Oslo Airport. We look forward to contributing to the investigation to ensure the future development of Oslo Airport in line with Norway’s Aviation Strategy objective to further strengthen its role as an international and domestic hub.
On EES/ETIAS, Norway should reconsider its decision of not financing the full automation, which risks damaging the sector’s recovery. Investments in border control, as a state function, should be funded by States and not the industry.
Regulatory Framework
Aviation taxes
At ICAO, States agreed to reduce taxes levied directly on passengers or shippers and committed not to apply duplicative carbon pricing instruments to aviation, recognizing that a multilateral approach is more effective than individual state measures. States also agreed that environmental taxes should not be driven by fiscal objectives, but instead be designed to recover the costs of alleviating/preventing environmental problems, thus, the imposition of taxes on air travel directly contradicts these accepted ICAO policies on taxation. Norway, a Contracting State and a signatory nation to the Chicago Convention, is bound by the agreed policies and commitments in the field of taxation and must not deviate from those.
Unfortunately, in their efforts to transition to more sustainable alternatives, governments design and implement policies that are non-compliant with the States’ global commitments at ICAO, e.g. instead of public support provided to airlines, we see many taxation initiatives on aviation that don´t have a sustainability nexus behind them.
Consumer Rights
It is vital that governments, regulators, and the flying public understand the balance between protecting consumer rights and sustainable air services. Appropriate regulations, globally coordinated, can give passengers confidence while ensuring the freedom to fly, as well as multimodality.
Rather than regulations “defending” passengers, those should be framed as a partnership between consumers and the industry, to encourage competition, consumer confidence and enhanced connectivity.
Safety and Security
Safety is the industry’s highest priority. We support a move towards performance-based regulations and performance-based oversight making full use of industry inputs, tools and programs. We share the concern regarding GNSS overreliance in civil aviation and support Norway to act towards safeguarding civil aviation safety and protection of aviation navigation infrastructure.
IATA has signed Safety Memorandums of Understanding on the IATA Operational Safety Audit and IATA's Safety Audit of Ground Operations programs with over 10 European CAAs among which Finland, Germany, UK, as well as endorsements from airport authorities in e.g. UK, Spain and Denmark.
We recommend Norway to pursue the same collaboration means on safety and security.
On Security, we welcome the provisions of moving towards a system of continuous vetting for staff to expedite background checks and combine into the aviation authority the supervision of information security and protection of critical infrastructure.
Environment & Sustainability
IATA agrees with the need to address the global challenges of climate change. In 2021, the IATA member airlines committed to achieving net-zero carbon emissions from their operations by 2050, bringing air transport in line with the Paris Agreement.
The net-zero objective, agreed upon by the airline industry and the ICAO Member States, is foreseen to be met through a combination of maximum elimination of emissions at source and the use of approved offsetting and carbon capture technologies. Success in this joint effort will require coordinated efforts of the entire industry besides a vital element: significant governmental support.
The critical elements of NetZero strategy are:
1) The use of Sustainable Aviation Fuel (SAF). Norway has the chance to lead the way in the region to drive SAF development as a tool towards net zero by looking at the SAF roll-out from a holistic perspective and providing a robust mix of several regulatory mechanisms, beyond mandates while considering schemes that boost SAF production and ensure a level playing field for air operators of Norway. It is key that Norway harmonizes its supplier mandate with the shortly upcoming ReFuelEU legislation, refraining from a non-realistic national mandate in terms of supply opportunities, leading to prohibitive pricing with high potential on increasing the ticket cost and competitive distortion. Also, there should be a set of policies and funding instruments that boost the uptake e.g. facilitating R&D, infrastructure, and production scale-up through incentives.
2) Investment in new aircraft technology, including radical new aerodynamic and alternative propulsion (electric or hydrogen) solutions.
3) Continued improvement in infrastructure and operational efficiency, with a particular focus on improved air traffic management. IATA encourages Norway to influence the European Council to find compromises on the general approach, so that the Single European Sky II++ revision could drive the reform it was intended to.
4) The use of approved offsets including carbon capture and storage technology to stabilize net emissions from international aviation.
IATA supports positive incentives that boost the green transition and thus against mandates and taxes if not applied in a broader framework of mechanisms. However, if there are environmentally based taxes, the potential revenues should be exclusively used for the green transition of aviation.
Drones
IATA recognizes the challenges and opportunities regarding safe integration and smooth operation of drones and together with other key stakeholders has developed a position paper (https://app.box.com/s/i6y2xezx9tjj07zru0siwnwdzlkzzity) on five key principles for a successful regulatory framework for unmanned aviation operations and traffic management (UTM/U-Space).