Annex E - Consultation Response Form - Air Transport Users Council

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15. In your view, will the provisions ensure that airlines get fair access to the terminals they want to use if demand for a particular facility exceeds its capacity? YES NO Please explain your reasons and add any additional comments you wish to make: In principle, relevant, objective, transparent and non-discriminatory criteria would ensure airlines get fair access to the terminal if demand for a particular facility exceeds its capacity. But the Proposal does not specify what these criteria might be. 16. We would be grateful to receive from airlines in writing any examples where they consider that they have been treated unfairly at Member State airports with respect to airport charges. N/A Please explain your reasons and add any additional comments you wish to make: 17. Do you think it is reasonable for security charges to meet security costs exclusively? YES NO Please explain your reasons and add any additional comments you wish to make: It is reasonable for security charges to meet security costs. To help achieve this, and to eliminate a possibility that passengers are charged twice, security charges should be included in airport charges to airlines and not directly imposed on passengers by airport operators. 18. Do you think the Commission's proposals to regulate airport charges are targeted at, and proportionate to, the problems it has identified? YES NO
Please explain your reasons and add any additional comments you wish to make: The AUC believes that the principal passenger interest in airport charges lies in their relationship with the timely investment in additional facilities in line with demand, and with the service quality within the airports. The <strong>Council</strong> does not know whether there has been a significant market failure in competition between airports in the EU. It therefore is not in a position to comment on whether the proposed EU Directive is the only solution to perceived market failures or to conclude whether the proposed Directive is necessary to protect the principal passenger interests identified above. However, in the UK, most airports, especially away from the Southeast of England and Scotland, appear to operate in a relatively strong competitive environment. Passengers have a choice between airports in many regions of the UK, particularly for short haul European routes. Moreover, if there was to be a perceived market failure between UK airports, then passengers’ interests are protected by the system of general safeguards in place, which allow the CAA to take action against airports with a turnover of more than £1m if they act in an abusive way. In addition, they are protected by the higher level of regulation of the charges at the BAA London airports and Manchester airport (though the AUC notes there is discussion in Government on the possibility of de-designating Stansted and Manchester). The AUC agrees, in general, with the Government’s view, as set out in the Regulatory Impact Assessment, that competition is preferable to regulation. Additional regulation is likely to be in the interest of consumers only where it can be expected to deliver a clear net benefit. And an assessment of the benefit to consumers of additional regulation should take into account that passengers are likely to ultimately fund any extra regulatory burden through increases in fares. 19. Are there any other issues in connection with airport charges which you think need to be addressed within the scope of this Directive? YES NO Please explain your reasons and add any additional comments you wish to make: The Directive should address the issue of airport charges levied directly on passengers, such as the airport development fees at Newquay and Norwich <strong>Air</strong>ports in the UK. The AUC would have concerns that if airport operators levy charges direct on passengers (with whom they have no contract) and also collect passenger charges from airlines, passengers may, in effect, be paying twice for facilities at the airport. 20. Do you have any other comments you wish to make? YES NO
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Annex E - Consultation Response Form - Air Transport Users Council

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