discussion of issues not covered by eu legislation andrew kelly european regions airline association
TRANSCRIPT
Discussion of issues not covered by EU legislation
Andrew Kelly
European Regions Airline Association
The Regional view...
The airline associations have been given less than two weeks’ notice of the topic to be presented. Consequently it has not
been possible to prepare coordinated presentations
agreed by all associations. This presentation
represents the views of the European Regions Airline
Association
About ERA
67 airline members 1.8 million flights per year 73 million passengers per year 72 minute average sector time 73 seat average seating capacity 1,100 aircraft 1,300 routes 30 countries across Europe
Are airlines consumer friendly?
We need to be consumer friendly to keep our customers
But consumer friendliness takes many forms
Price Product Route network Loyalty schemes Safety ???
A deregulated market....
Within Europe the market is fully deregulated. This means
the consumer has a choice of product and price the product (and contractual rights) will vary
when things go well and when things go wrong This is what happens in a free market...
What needs to be regulated?
Don’t constrain a free market without a clear justification that regulation actually benefits the consumer
Looking at two examples where the Commission raises the possibility of regulation in its consultation
Seat pitch Cabin baggage
policy
Seat pitch
Regulate or leave the market to decide? Already regulated for safety Constrains the ability of companies to compete
through product Increases the per seat costs raising the price of air
travel For smaller aircraft operators potentially could result in
10% reductions (or greater) in seating capacity and associated operating/safety problems
Does the consumer really benefit overall?
Cabin baggage policies
Regulate or leave the market to decide? Already regulated for safety Constrains the ability of companies to compete
through product Limits the choice for the consumer How do you create a rule that takes account of
different aircraft types – for example, some regional aircraft have no cabin baggage storage space!
Impacts hold baggage policies, airport baggage capacity and security screening
Does the consumer really benefit overall?
“Buyer beware” or “Regulate”
Ensure that the passenger knows what they are buying (for example: seat pitch, baggage allowance, check in rules, additional unavoidable costs, no show policy, on line reservation policies)
Ensure the passenger knows what rights they will receive when things go wrong (for example: mishandled baggage, delays, cancellations, denied boarding, force majeure)
The compromise is better transparency - “BUYER AWARE”
Equality across modes
A key issue for regional airlines competing with high speed railIf travelling by air, EU Regulation 261/2004 provides for unlimited liability for care (meals, hotel accommodation) during “force majeure” eventsIf travelling by rail, the carrier is relieved of any liability for care by EU Regulation 1371/2007 during “force majeure” events
Safety is the 1st right
It is easy to forget that air travel is a safety critical business
A safe journey must remain the fundamental right of every air passenger and crew member
No regulation on passenger rights must ever jeopardise safety
Regulations affect real people
All consumer rights legislation affects consumers and employees
Interference in the market will potentially result in the loss of routes, mobility and jobs
The EC must respect its own rules on better regulation ensuring that the full impact of any proposal is properly assessed before it is proposed
Conclusion
Do we need more regulation? Airlines need to be consumer friendly to attract
business Consumer friendliness takes different forms
including product and price Do we want to limit the choice for consumers?
Leave the market to set the product and price but ensure that the consumer is protected by enabling them to be aware of what they are buying
Do not over-regulate as regulation, by definition, limits personal choice