Annex E - Consultation Response Form - Air Transport Users Council

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PART 2 - Your Comments 1. a) Do you think that a passenger threshold is an effective way to establish which airports should fall within the scope of the Directive? b) If so, is the proposed 1 million passenger threshold appropriate? YES YES NO NO Please explain your reasons and add any additional comments you wish to make: a) A passenger threshold is preferable to another threshold, such as one based on profit share. It is a neutral measurement that would ensure that airports are compared on a like-for-like basis. 2. Can you suggest any alternative ways to establish which airports in a Member State should be subject to the measures proposed in the Directive? YES NO Please explain your reasons and add any additional comments you wish to make: 3. Do you agree with the requirement for a mandatory process of consultation between the airport management and airport users at all qualifying airports? YES NO Please explain your reasons and add any additional comments you wish to make: In practice, airlines and airports are likely to consult regularly over the level of airport charges. The benefits to airports, airlines or consumers of a mandatory process are likely to be disproportionate to the extra regulatory burden. The Directive is also not clear as to how a requirement for a mandatory process of consultation would be enforced 4. Do you think the proposed timescale for agreeing changes to charges would work in practice? YES NO
Please explain your reasons and add any additional comments you wish to make: 5. Would you be content for the CAA to take on the role of IRA in the UK? If not, do you have any alternative suggestions? YES NO Please explain your reasons and add any additional comments you wish to make: If there were to be an IRA in the UK then the CAA would be the obvious choice to take on this role because of its expertise and experience in airport charges regulation. 6. Do you think that arbitration by an IRA would be an effective method of resolving disagreements between airports and airlines for all or any of the Directive's provisions? YES NO Please explain your reasons and add any additional comments you wish to make: It would appear to be potentially an effective method of resolving disagreements between airports and airlines provided the IRA has adequate powers to intervene and impose a solution. 7. How do you think this would work in practice if, for example, an airport proposed a charge of x and the airport users preferred x-5? Would the IRA need to follow a process similar to a price cap review? YES NO Please explain your reasons and add any additional comments you wish to make: A process similar to a price cap review would require an additional regulatory burden for the IRA and also airports and airlines. The funding to carry out the extra regulatory burden would be charged back to airlines which may lead to higher fares for consumers. An expedited process to the price cap review, if such a process could be designed, would be more proportionate to the issue addressed. 8. Are you content that the IRA's decisions in matter of arbitration would have binding effect? YES NO
Page 1: Consultation on European Directive
Page 5 and 6: agreements are needed to guarantee
Page 7: Please explain your reasons and add

Annex E - Consultation Response Form - Air Transport Users Council

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