Annex E - Consultation Response Form - Air Transport Users Council

More documents

Recommendations

Info

Please explain your reasons and add any additional comments you wish to make: The AUC questions whether the IRA’s decisions would be binding. If airlines or airports were able to seek judicial review, the extra burden on all parties might undermine the object of the arbitration. 9. Will the transparency requirements affect your normal commercial relationships? N/A Please explain your reasons and add any additional comments you wish to make: 10. a) Do you believe that these transparency requirements are required at all airports with over 1 million passengers per annum? b) What costs and benefits would ensue? YES NO Please explain your reasons and add any additional comments you wish to make: a) It is often in the commercial interest of both airports and airlines to provide each other with certain financial data and information. It is therefore not immediately obvious what benefits transparency requirements would bring to airports, airlines or, indeed, passengers. b) Transparency requirements might potentially jeopardise favourable deals for some airlines from airports. Such hidden deals have helped lower fares for passengers on some routes and helped airlines introduce some services which otherwise might not have been viable, thus increasing the choice of routes available to passengers from some airports. However, transparency requirements might also have a side-effect of ensuring that airlines publicise per passenger charges on airlines. 11. How do the proposals compare with current arrangements at UK and other Member State airports? N/A Please explain your reasons and add any additional comments you wish to make: 12. a) Do you think that compulsory service level agreements are needed to guarantee quality YES NO
agreements are needed to guarantee quality standards effectively? b) How should any trade-off between higher standards and the cost of quality improvements be taken into account? Please explain your reasons and add any additional comments you wish to make: The proposed Directive does not specify which services at an airport would be covered by Service Level Agreements (SLAs). Nor does it suggest how the agreements would be enforced. SLAs at the four regulated airports in the UK have benefited passengers as they have held to account the airport operators at these airports over the quality of service standards provided to passengers. At other airports, SLAs would help uphold quality standards, which is in the interest of passengers. However, quality control measures are likely to have already been put in place by airport operators on the service levels provided by contracted ground handling agencies at an airport. It is not clear what value compulsory SLAs would add to the process of setting charges on a commercial basis. 13. Do you have any other ideas on how quality standards could be maintained between airports and airlines? YES NO Please explain your reasons and add any additional comments you wish to make: 14. a) Do you agree that airports should be able to differentiate charges based on the quality of service offered? b) Will the proposals affect any charging policies you currently have? YES N/A NO Please explain your reasons and add any additional comments you wish to make: Competition between terminals could be in the interest of passengers if it were to result in lower airport charges, and if these were passed on to passengers in lower fares. But there is no guarantee that lower charges would lead to lower fares. And, as far as the AUC is aware, the suggestion that passengers using no-frills airlines would accept significantly lower levels of service at UK airports has not been extensively tested. Nevertheless, if airlines consider there to be a market for varying levels of service with airports, and if it is practically possible, then airports should be able to tailor services, and therefore charges, to different airlines (and therefore different types of services to consumers). But this must be determined on the basis of non-discriminatory criteria to ensure fair competition between airlines at the airport.
Page 1 and 2: Consultation on European Directive
Page 3: Please explain your reasons and add
Page 7: Please explain your reasons and add

Annex E - Consultation Response Form - Air Transport Users Council

Create successful ePaper yourself

Delete template?

Save as template?