Kiri

Dokumendiregister	Transpordiamet
Viit	1.8-3/25/19086-1
Registreeritud	11.11.2025
Sünkroonitud	12.11.2025
Liik	Sissetulev kiri
Funktsioon	1.8 Rahvusvahelise koostöö korraldamine
Sari	1.8-3 Rahvusvaheliste suhete alane kirjavahetus
Toimik	1.8-3/2025
Juurdepääsupiirang	Avalik
Juurdepääsupiirang
Adressaat	ETS Aero
Saabumis/saatmisviis	ETS Aero
Vastutaja	Üllar Salumäe (Users, Lennundusteenistus)
Originaal	Ava uues aknas

Failid

E-kiri.eml

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E-kiri.eml

Dear Estonian Transport Administration

As we support aircraft operators in most EU states, we are writing to seek clarification regarding the national implementation of the RefuelEU Aviation Regulation, and specifically how your authority is advising operators and verifiers to treat exceptions in the current reporting year.

As you will be aware, there remain several operational scenarios—particularly for ad hoc, business jet, or multi-leg operators—where RefuelEU uplift requirements cannot be met due to infrastructure constraints, commercial re-routings, or unavailable fuel supply. To date, there has been no formal, central guidance on how such exceptions should be documented or verified.

We would therefore appreciate your response to the following questions:

Has your authority issued specific guidance or clarification to operators or verifiers on how to handle exceptions to uplift obligations under RefuelEU?

If so, could you please share this guidance or any related documents?

Do you currently consider infrastructure or operational issues (e.g. last-minute re-routings, unavailable fuel supply from contracted suppliers, apron restrictions, etc.) to be grounds for valid exclusion from the uplift requirement, assuming proper documentation?

Have you formally implemented RefuelEU-specific national legislation or regulatory amendments, and if so, could you briefly outline what this means for operators under your jurisdiction?

Thank you for your support and we look forward to your guidance. We would appreciate it if you could reply by the end of this week.

Kind regards

Catherine Rowles

Carbon and Sustainability Support

Gold Sponsors of:-

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T: +44 203 603 2049

M: +44 799 015 6948

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