14 April 2021 - The Aerospace and Defence Industries Association of Europe (ASD) welcomes the European Commission's proposal for a regulation, dated 23rd February, establishing the Joint Undertakings under Horizon Europe (Single Basic Act). Especially, the Clean Aviation Partnership will be a key element to reach the ambitions of the EU Green Deal and implement the EU civil aviation sector's own Destination 2050 Roadmap (see www.destination2050.eu). However, the ASD members have identified key concerns on the proposed legislation for the Clean Aviation Partnership and propose high-level recommendations. The support of National Representatives, Members of the European Parliament, and key stakeholders is highly needed. We advocate for the relevant update of the legislation in order to secure the sustainable implementation of the Clean Aviation Partnership. In addition to the critical points described below, the ASD-recommended amendments on the legislation are included as an Annex.
The budget has to be in line with the Strategic Research and Innovation Agenda (SRIA) goals. The proposed share of the EC funding (€ 1.7 billion) does not correspond to the ambitions of SRIA of Clean Aviation. As such, this reduced budget is therefore jeopardizing the EU civil aviation sector ambitions to reach net-zero CO2 emissions by 2050 based on its Destination 2050 Roadmap and in line with the EU Green Deal ambitions. When defining the robust and ambitious commitments of the SRIA, the industry evaluated its contribution at € 3 billion, covering both in-kind contributions and additional activities, provided the public financing would reach €2.5 billion. As a consequence of this gap, a review of SRIA's ambitions will be necessary, and the private side contribution (€ 3 billion) need to be reassessed with the stakeholders since their contribution was based on an assumption of (€ 2.5 billion EC funding. In addition, as a general rule, funding rates for Clean Aviation should be kept at the same level as for Clean Sky 2, while the H2020 methodology for calculating private in-kind contribution (based on real costs) should also be preserved.
The number of private members representatives in the Governing Board (GB) shall be increased to 15 seats. In contrast with the previous Clean Sky Partnerships, where each Founding Member was represented in the GB, the current SBA limits the number of the Governing Board private members only to 9. The reduced number of seats reflects neither the importance of the founding member's technical responsibilities nor the commitments to deliver the expected results. This limitation will cause the exclusion of several Founding Members from the GB while contributing to the Partnership financially. A balanced representation of private members in JU bodies shall be secured.
The unconditional commitment of Founding Members (FM):
The Founding Members' clause to unconditionally accede to the Partnership via a Letter of Commitment (LoC) raises a legal and financial risk for entities. The FM will be possibly asked to sign an LoC when important rules (such as the funding rates or the UK public contribution) are not yet defined. Additionally, as the FM must also apply for EU funding (Open Calls), several FM will be obliged to contribute to the Partnership financially but potentially could not receive any EU funding.
Additional sources of funding:
A mechanism enabling budgetary adjustments shall be included in the SBA to allow for additional top-ups complementing the initial partnership budget (contributions from associated/third countries NextGenEU, fines & decommitments, Cohesion Fund and other EU programmes).
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