Airports Council International Europe (ACI Europe)

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Climate Lobbying Overview: Airports Council International Europe (ACI Europe) appears to have mixed engagement on climate-related positions. While the association supports the aim to decarbonize the sector by 2050 in line with EU and Paris targets, it has more mixed engagement with European climate regulations, including supporting an EU sustainable aviation fuels mandate, while taking legal action to oppose a French climate law banning short domestic flights where rail alternatives exist.

Top-line Messaging on Climate Policy: ACI Europe’s top line messaging on climate change policy appears to be largely positive. A document published by ACI Europe in 2019 titled ‘European Airports committing to net-zero carbon emissions by 2050’ ‘supports the objectives set by the Paris Agreement’s central aim to strengthen the global response to the threat of climate change by keeping global temperature rise this century below 2 degrees Celsius above pre-industrial levels and to pursue efforts to limit the temperature increase even further to 1.5 degrees Celsius’. ACI Europe Director General Olivier Jankovec has reaffirmed this position, and in 2021 he called on the EU to support a green recovery for aviation to allow it to decarbonize in line with the EU goal of climate neutrality by 2050. Additionally, in a July 2021 press release, ACI Europe appeared to support the EU’s Fit for 55 package, but in a separate press release in the same month, the association stated that the Green Deal must safeguard the ‘economic value’ that air travel brings to society.

Engagement with Climate-Related Regulations: ACI Europe’s lobbying on climate-related regulation appears to be mixed. In its response to the EU consultation on the Emissions Trading System in August 2020, ACI Europe appeared to oppose the inclusion of international (EEA- Non-EEA) flights in the EU ETS while supporting the application of the EU ETS for intra-EU flights. In another EU consultation response in January 2021, ACI Europe appeared to repeat its position, supporting the continued inclusion of aviation in the EU ETS, while excluding international flights, and appearing to not supporting an immediate or complete phase out of free allowances in the EU ETS. Similarly, in a November 2021 position paper, ACI Europe urged the EU to delay the complete phase out date for free EU ETS allowances from 2027 to 2030, while supporting a higher linear reduction factor, and appeared unsupportive of extending the EU ETS to cover EU international flights.

However, in the same response, ACI Europe stated its support for an EU sustainable aviation fuel mandate, stating that it ‘urges the European Commission to deliver concrete means to incentivize the uptake of Sustainable Aviation Fuels (SAF) in Europe, including the possibility of an EU-wide SAF blending mandate for fuel suppliers’. This position was reaffirmed in a separate 2020 response to the ReFuel EU consultation, where it described a SAF mandate as a ‘promising solution’. In a November 2021 position paper, ACI Europe further stated support for increased the EU SAF mandate for 2030 from 5% to 6%, and for dedicated sub-targets while emphasizing some carbon leakage and competitiveness concerns.

A November 2021 ACI Europe position paper also appeared supportive of an EU carbon border adjustment mechanism (CBAM) with exceptions. ACI emphasized competitive concerns around a more stringent EU ETS for hub airports, advocating for potential measures including a CBAM to account for this, while also advocating for a more gradual phase out of aviation EU ETS aviation free emissions allowances in the EU ETS. Additionally, in March 2022, an ACI Europe press release appeared unsupportive of the modal shift from air to rail in Europe, supporting a report prepared for ACI Europe that appeared to de-emphasize the climate impacts of shifting from air to rail to argue against a European-wide low-carbon modal shift.

Positioning on Energy Transition: ACI Europe appears to have mixed engagement with measures to transition the energy mix for aviation. In October 2021, ACI Europe took legal action at the European Commission against a French law banning domestic flights where there is a rail alternative of under 2.5 hours according to a 'La Tribune' report. The report further suggested that such opposition stemmed partly from blocking potential European precedents from national governments to introduce similar regulations banning short-haul flights. Similarly, a March 2022 report on the modal shift from air to rail by Oxera, that was prepared for, and endorsed by, ACI Europe, also appeared unsupportive of short-haul flight bans in Europe. However, ACI Europe has communicated general support for a clean energy transition and zero carbon energy, without supporting specific policies, in a policy papers in 2019, June 2020 and November 2020. Additionally, ACI Europe appeared to criticize potential taxation on the aviation sector instead of applying the EU ETS in consultation responses in August 2020 and January 2021, suggesting an unsupportive position for an EU jet fuel tax. Moreover, in a November 2021 position paper, ACI Europe appeared to oppose an EU kerosene tax, appearing critical of "the blunt instrument of taxation" when discussing the EU's Energy Taxation Directive,

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