The ongoing reform of the European Union’s Air Traffic Management (ATM) performance and charging framework has become a central issue in the debate on aviation sustainability and system resilience. In , we highlighted the need for a more balanced and realistic approach to reform – one that safeguards the operational integrity, financial stability, and workforce of the ATM system while contributing meaningfully to environmental objectives. The ETF continues to caution against reforms that prioritise cost-efficiency and traffic growth at the expense of capacity, staffing, and long-term investment, as such an approach risks weakening the very system it seeks to optimise.
At the same time, the push for greener aviation is accelerating across Europe, with policymakers exploring new instruments to reduce emissions and incentivise more sustainable operations. Among these, the environmental modulation of air navigation service (ANS) charges has emerged as a potential tool. However, any such measures must be carefully designed within a stable and coherent framework that recognises the structural role of ATM and avoids unintended consequences through extensive prior research.
Against this backdrop, the question is not whether ANS charges can contribute to sustainability, but how they can do so without undermining the financial and operational foundations of the ATM system.
Balancing sustainability with ATM system stability
Any environmental modulation of ANS charges must remain revenue-neutral to ensure stable and predictable financing for ANSPs and protect the resilience of the ATM system. Environmental modulation can support more efficient routing and emissions reductions, but only as part of a broader, system-level approach to coordinated European airspace management, such as a centralised European authority capable of optimising routing.
Modulation should also not be used as a tool to balance capacity and demand without extensive prior analysis. Ensuring stable system financing should remain the primary focus of ANS charges, and modulation should therefore not be used as a principal tool to address issues beyond ATM control, such as sustainable aviation fuel uptake or congestion. Congestion is driven by factors largely outside ANSP control, thus modulation of charges may only minimally influence demand. A more effective approach would first focus on improving network capacity through realistic operational planning, adequate staffing and coordination at the system-level.
The current charging system, based on distance multiplied by the square root of maximum take-off weight (MTOW), was never designed to address environmental performance. The introduction of an ecological charging basis through a revised model reflecting actual CO₂ emissions per flown distance, could better align incentives with sustainability goals, while preserving revenue neutrality. Such a model could have a beneficial effect on European CO₂ targets without undermining the economic competitiveness of European airlines against Gulf or Asian carriers.
This would also address another issue in the current system, namely business aviation operations which pay less because aircraft are lighter, despite representing the same workload for Air Traffic Controllers (ATCOs). A more balanced charging framework would better reflect the environmental and operational realities.
A balanced approach to environmental incentives
We support a balanced and pragmatic approach to environmental modulation of ANS charges. When carefully designed, modulation can play a useful role in encouraging more efficient routing and reducing aviation emissions. However, it must operate within a framework that protects the stability and operational integrity of Europe’s ATM system.
Three principles should guide any reform:
- Revenue neutrality for ANSPs, ensuring stable ATM financing.
- System-level coordination, ideally through a centralised European route allocation mechanism.
- Environmentally meaningful incentives, focused on areas where ATM can genuinely influence outcomes.
Crucially, such reforms must not shift any financial pressure via ANSPs onto the ATM workforce and staff-related costs should not be treated as adjustable variables in the implementation of such a system.
If these principles are respected, environmental modulation can become a constructive component of aviation’s broader decarbonisation strategy – without undermining the infrastructure and workforce that keep Europe’s skies safe and efficient.
You can find more on our position on RP5 here.
