Kiri
| Dokumendiregister | Transpordiamet |
| Viit | 3.3-6/25/9085-1 |
| Registreeritud | 30.05.2025 |
| Sünkroonitud | 02.06.2025 |
| Liik | Sissetulev kiri |
| Funktsioon | 3.3 Sise- ja väliskommunikatsiooni korraldamine |
| Sari | 3.3-6 Teabenõuded, märgukirjad ja selgitustaotlused |
| Toimik | 3.3-6/2025 |
| Juurdepääsupiirang | Avalik |
| Juurdepääsupiirang | |
| Adressaat | Normec |
| Saabumis/saatmisviis | Normec |
| Vastutaja | Üllar Salumäe (Users, Lennundusteenistus) |
| Originaal | Ava uues aknas |
Failid
Dear Sir/Madam,
I hope this email finds you well.
My name is Rayanveer Katoch, and I am an Aviation Auditor with Normec Verifavia, an ISO 14065:2020 and ISO 17029:2019 accredited verification body. We are currently engaged in verification activities related
to the ReFuelEU Aviation Regulation (EU) 2023/2405.
As the first reporting cycle under the ReFuelEU Aviation Regulation concludes, we would like to seek clarification on a few points regarding the interpretation and reporting requirements of the regulation:
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We would appreciate clarification to gain a deeper understanding of the data gaps, specifically which flights are considered data gaps and how the percentage is calculated. Since the arriving flight is only relevant in case of 'yearly tanked quantity for fuel safety rules' (column H) having values, will the arriving flight still be a data gap in case the requirements in Article 5(1) of the ReFuelEU Aviation Regulation are met, or if an operator does not wish to justify any non-tanked quantities.
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We would appreciate further clarification regarding the treatment of data gaps, particularly in cases where the missing data relates to planned fuels, block fuels, or fuel uplift. Could you kindly clarify whether the Estonian Transport Administration intends to request aircraft operators to use a specific methodology to fill in data gaps, and if so, which one(s)?
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We would also appreciate your clarification on the treatment of justified fuel quantities in cases where one or more flights departing from or arriving at a Union airport are classified as data gaps. Specifically, if an operator justifies a 'yearly non-tanked quantity' for a Union airport, but one or more flights from that airport are classified as data gaps, should all justified fuel from that airport be disregarded? Or should the justified fuel still be taken into account based on flights for which complete and valid data is available?
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If the primary data source (operational flight plans) is unavailable, could you please clarify which secondary data sources you consider acceptable to obtain the planned and safety fuel values (trip, taxi, contingency, extra, destination alternate, final reserve, discretionary, etc.)?
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Article 4.3 of the COMMUNICATION FROM THE COMMISSION C/2024/5997 states that "Aircraft operators should ideally keep the justifying documents for a minimum of 4 years (i.e., reporting year + 3 years of data retention). This period may vary between Member States as national rules on enforcement applicable to the sector may prescribe different timelines". Could you kindly let us know whether the Estonian Transport Administration intends to have any specific requirements related to data retention?
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We would also appreciate it if you could inform us whether national legislation related to the implementation of the ReFuelEU Aviation Regulation 2023/2405 (EU) will have any specificities which are different from the ReFuelEU Aviation Regulation.
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Has the Estonian Transport Administration decided on the penalty for non-compliance with Article 5(1) of the ReFuelEU Aviation Regulation, additionally, does the authority intend to penalise non-compliance with Article 8(1) of the ReFuelEU Aviation Regulation, that is, in case the operators fail to meet the deadline of 31st March of the reporting year?
Please let us know if there will be any specific forms, portals, or national guidance documents to be released by the Estonian Transport Administration in the coming months.
Thank you for your time and support. We look forward to your response.
Best regards,
Rayanveer Singh
Verifier
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Aviation & SAF
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T. +91 7657 889 134
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