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Civil Aviation Policy – Consultation with stake holders
Civil Aviation sector in India has soared to great heights in the last few
years. However, the aviation industry’s growth will need proper policy
orientation to ensure systematic, sustainable and orderly development. Hence, it
is imperative that a clearly defined, long term civil aviation policy is formulated.
Such policy while addressing issues related to safety, security, infrastructure
development, revenue models, private sector participation etc. must also provide
for a safe and comfortable yet affordable air travel to passengers.
The Ministry of Civil Aviation, Government of India, is in the process of
formulating a Civil Aviation Policy. The civil aviation sector has many complex
areas, which need to be addressed in formulation of the policy; some of them are
indicated below.
Organizations and individuals are requested to give their inputs, views and
suggestions on aspects given below (or any other related issues), for facilitating
the Ministry of Civil Aviation in drafting the proposed Civil Aviation Policy. These
may be sent to the DT section, Ministry of Civil Aviation, Rajiv Gandhi Bhawan,
New Delhi, India; or e-mailed to Dtsec.moca@nic.in
Views of some stake-holders already received are placed below for
reference and cross fertilization of ideas. While giving your views, please mention
specifically if you have any objection in keeping your views in public domain. Your
views may be sent before 20th February, 2012.
A core group will deliberate on these inputs received and the draft policy
formulated will be put up for further consultations.
( G. Asok Kumar )
Joint Secretary
asok.kumar@nic.in
Tel.: 24617692
1. INFRASTRUCTURE 2. AIR CONNECTIVITY
View Suggestions View Suggestions
Airports Role of the National Carrier
a) Green Field Route Dispersal Guidelines
b) Brown Field Regional Scheduled Operation Permit (RSOP)
c) Heliports Code Sharing
d) Role of Govt. agencies like AAI Essential Air Services Fund
e) Private participation in Airport development Regional Air Connectivity Fund
f) Low cost, no frill airport with adequate
functional infrastructure
g) Energy efficient, power and water saving
airports designs
h) Need for restructuring of AAI 3. AIR OPERATION REGULATIONS
View Suggestions
Connectivity to airports Requirements for Air operators
a) Role of State Govts a) Schedule/Regional Scheduled
b) Local/Sub-State Agencies b) Non-Scheduled
c) Private/General
Use of IT d) Helicopter Operations
e) Seaplane Operations
MROs (Maintenance, Repairs & Overhauling) of f) Aerial Work
aircraft
a) India as MRO Hub Aero-sports Activities
b) 3rd Party MROs Dangerous Goods
c) Warehousing of spares
4. SUB POLICIES
5. HR & TRAINING
View Suggestions
Cargo Policy
View Suggestions
Hubs Policy Licensing of Pilots, Engineers and other personnel
General Aviation Policy Development of Commanders
Slot allocation Policy Manpower for ATC & ANS
Relations with ICAO Flying Clubs
Bilateral Arrangement, Degrees of Freedom AME Training
Regulatory philosophy Availability of skilled , trained personnel
Regulator for Air Transport Sector Training Infrastructure
FDI – extent permissible – strategic investment by
foreign airline 6. PASSENGER/USER RELATED
International Market Access View Suggestions
OFFSET Policy – its use in development of Ombudsman for the aviation sector
infrastructure and skills Stake holders Grievance Redressal mechanisms
Ground handling policy Facilities for persons with reduced mobility
Acquisition of Aircraft
a) Leasing of Aircraft and Capacity allowed
7. SAFETY, SECURITY & SOVEREIGN 8. ECONOMIC REGULATION
POWERS View Suggestions
View Suggestions
Setting up of CAA Fares:
ANS/ATM – Modernization of Airspace a) Appropriate and adequate fares to cover
management operational costs
Setting up of Aviation Security Force to handle b) Issues related to excessive, predatory and
airport security discriminatory pricing
Customs/Facilitation (Annex 9, ICAO) c) Issues related to unbundling of services and
Roll of State/Sub-State Agencies their pricing behaviour
Flexible use of Airspace
AERA
Meteorological facilities
9. ATM 10. ENVIRONMENTAL ISSUES AND
View Suggestions RESEARCH & DEVELOPMENT
Satellite Navigation View Suggestions
GAGAN ETS (Emission Trading Scheme)
Financing of ATM services Developments for
Autonomy to ATM regulator (Functional and a) Noise Reduction
Financial) b) Emission Reduction
c) R&D for alternate fuels
d) Fuel efficient engines
11. MISCELLANEOUS
View
11. MISCELLANEOUS Suggestions
11. MISCELLANEOUS
11. toMISCELLANEOUS
Need set up a separate Air-navigation
Service Entity
Need MISCELLANEOUS
11. for legal frame work
11. MISCELLANEOUS
Consolidation- Merger / acquisition
Fiscal Issues of Aviation
Aero Space
Need to Strengthen Economic Regulatory
Frame for Tariff (Excluding Tariff Fixation by
Govt.)
Any Other Matter to promote competition
Related Documents-
a) Naresh Chandra Committee Report Part-1
b) Naresh Chandra Committee Report Part-2
c) Consultation Paper on Air Connectivity in regional, remote & inaccessible areas of the
country
Comments received from Stake Holders/Organizations-
a) CAPA
b) KPMG
c) ASSOCHAM
d) AAI
e) APAO
f) CII
g) Blue Dart
h) IATA
i) Futura Travel (ESSAR Group)
j) Nathan Economic Consulting India Pvt. Ltd.
k) Go Air
l) IGRUA
m) NIFTI, Gondia CAE
n) Rahul Cherian Inclusive Planet for Disability Law and Policy
o) Aero Club of India
1. SUGGESTION FOR INFRASTRUCTURE
Suggestions received from KPMG:
1 Airports
The growth in the passenger and cargo traffic requires significant investments in terms of
construction of new airports, expansion and modernization of existing airports, improvement in
connecting infrastructure (road, metro, sea link, etc.) and better airspace management. The
passenger handling capacity has risen two-fold from 72 million (FY 06) to 143 million (FY 11)1.
Notwithstanding this growth, there are challenges facing this sector and initiatives are needed to
make India a leading hub for passenger traffic. Key enablers to achieve the projected growth
are as follows:
a) Allow ‗no-frills‘ airport model to lower the fixed cost of airport development and improve
the financial viability of tier II/III airports
b) Enable stable, transparent, predictable and investor-friendly regulatory regime with a
mechanism for time-bound resolution of issues
c) Upgrade Air Traffic Control (ATC) infrastructure and allow all weather operations
including night landing facility at Indian airports, to provide impetus to tourist traffic
d) Introduce fiscal incentives and innovative funding solutions are needed to overcome the
funding constraints, being faced by airport operators
2 Maintenance, Repair and Overhaul (MRO)
Indian MRO industry is expected to triple in size from Rs 2,250 crores in 2010 to Rs 7,000
crores by 20202. India has the potential to be an MRO hub due to the growing aircraft fleet,
1
Source: AAI
2
Source: Ascend
location advantage and availability of talent. However, this future size may still be small
compared to the present MRO industry size of other countries such as UAE (Rs 8,000 crores
per annum) and China (Rs 10,000 crores per annum). The following key enablers would be
imperative for India to become a preferred MRO hub:
a) Eliminate discriminatory taxation policy for domestic MROs, as there is nearly 40% tax
differential between domestic and foreign MROs
b) Incentivize airlines to set up their dedicated MRO hubs in India through three-way joint
ventures with MRO service providers and airport companies
c) Consider abolishing import duties on spare parts
Suggestions received from CAPA
New policy must be practical and implementable, with agreed milestones
A new policy must be practical and implementable, with agreed milestones towards achieving a
viable industry. There are so many dysfunctionalities in Indian aviation today that moving
directly to this new order is not feasible. We therefore proposed a staged approach with an
initial period during which the industry must be set in order, followed by the introduction of a new
liberal policy from 2015/16 providing all stakeholders – including government - with three years
to prepare for a new open environment.
Stage 1, between now and 2015/16, marks a period during which we remove the
distortions in the sector to create a level playing field, by establishing new regulatory,
legal and fiscal frameworks, and strengthening our institutional capacity by creating
competencies at the government level.
Stage 2, post 2015/16, will be characterised by an open, efficient and liberal aviation
sector, which is supported by a clear, formalised long-term plan, is professionally
regulated and where competitive dynamics will determine market outcomes.
Objective by 2015/16
A proposal to permit airlines to directly import fuel is being discussed. It is seen as being
easier to implement than categorising aviation turbine fuel as a declared good due which
would be resisted by state governments due to the potential loss of sales tax revenue.
However if direct imports are successful, state governments will face the same loss of
revenue, but we will in the process have created an inefficient duplication of the supply
chain of fuel to the aircraft. It would therefore make more sense to adopt a front door
policy by engaging directly with state governments.
AAI‘s airport operations divisions should pursue a clear commercial objective and
establish a cycle of developing value in its airport assets, privatising them to raise capital
and then re-investing in new projects. However, all capital expenditure should be within
the framework of a defined business plan which is based on developing and operating
viable airports and which has been cleared by our proposed Airports Approval
Commission. State governments should be involved to provide viability gap funding
where required;
Airports Objective 2015: We need to have developed a 30-40 year Masterplan for Indian
airports, with national and regional perspectives. It is imperative that airports be considered
within a multi-modal context which requires a national transport plan. This would also allow us to
develop a system that most appropriately meets the nation‘s requirements. Investments in new
airports must be carefully considered based on viability principles and with greater goal
orientation than in the past. Private and PPP models will be the way forward rather than relying
on purely government funded projects, but in order to attract private capital, a transparent and
equitable economic regulatory framework must be defined. A long term planning horizon must
be adopted with respect to securing land for the development of future airports through to 2050.
Furthermore, if India‘s airports are to develop as global hubs, India‘s carriers must be provided
with an environment in which they can thrive. Without strong home carriers Indian airports will
always remain as the spokes of offshore hubs. Hub development also requires a very high level
of government support of airlines and airports, with Dubai and Singapore being excellent
examples of what can be achieved through close coordination.
In the Indian context this means that state governments will need to become more involved with
strategies to promote hub development. This will require a change in mindset to accept that it is
permissible for a state government to pursue initiatives which might benefit a private airport
operator but where the benefits for the local economy are far greater. Unnecessary politicisation
of such issues prevents us from seeing the bigger picture. When Sydney Airport, a 100% private
airport, recently met with Air India to encourage the airline to operate to the city, the Chief
Minister of the State government attended the meeting to offer public funds to provide marketing
support for the new route. The state government recognised that any private benefit to the
airport operator would be dwarfed by the trade and tourism opportunities that the service would
generate for the state.
Post 2015/16
Airports & Airspace
Encouraging investment: World class cities require world class airports and the development
of such infrastructure can only be achieved by embracing private capital. Significant steps have
already been taken in this direction, but there have been some lessons to learn along the way.
Critically amongst these is the fact that the award of concessions at Delhi and Mumbai in the
absence of a defined economic regulatory framework is responsible for the ongoing debate
between the airport operators and AERA on the appropriate level of charges. The permissible
structure for charges should have been made known at the time of the tender so that consortia
could have bid accordingly and the appropriate level of investment could have been expended
on the airport development. In order to attract investors to make the large scale investments that
are required, there must be a predictable environment with respect to potential revenue
streams.
Airport viability: Developing airports is an important objective, but this should be carried out
within the framework of a national Masterplan which identifies clear economic reasons for
building a new airport. At present it appears that new projects are being announced with
overlapping or insufficient catchment areas and without regard for airspace issues or the
potential for airlines to operate there. In certain cases airport plans appear to be exercises in
securing land for non-aeronautical activity, but ultimately a series of unviable airports will deter
future investment in viable ones. We proposed the establishment of an Airports Approval
Commission within MOCA to review the business plans of proposed airports prior to granting
clearance. At present the thresholds for clearance are largely technical nature and do not take
viability into consideration. Approved airports could then be referred to the Aviation Finance
Corporation if additional funding is required by the promoters.
Land use and planning: There must be greater transparency on the use of non-aero land at
airports. It is counterproductive to develop residential and commercial communities on land
adjacent to airports and to then see activism from residents seeking to curtail airport operations
because of noise pollution. There must be careful masterplanning to ensure that different land
uses can co-exist. Furthermore, a long term perspective must be taken with respect to land
requirements for airport infrastructure. The projected rate of growth of aviation will require metro
cities to develop second, and in some cases third, airports within the next 20 years. Land
scarcity in India means that there is likely to be significant politics around this issue and
therefore we need to take a very long term view, looking ahead 30-40 years to plan for land
requirements for future airports from now.
State governments: State governments much also play a much more active role in the airport
sector since aviation is a key enabler of local economic development. Indeed the Centre should
gradually withdraw from airport operations. However this requires a process of education to
make state governments understand the impact of airports on local economies. At present
states are clinging on to sales tax revenue of around US$700-800 million per annum which is
stifling the airline industry. The potential economic contribution of a viable aviation sector is
manifold greater in a US$1.7 trillion economy, however state governments are jeopardising
much greater returns due to a misplaced focus on revenue in the hand. Economic growth is
being held hostage to such short term thinking because of a failure to understand the
repercussions. MOCA needs to take a leadership role in educating the States on the potential
benefits of establishing a more conducive fiscal environment for the aviation sector.
Airports Authority of India: The AAI‘s complex business model which includes managing the
largest portfolio of airports in the world under a single operator, investing huge capex in airports
which are largely loss-making and the provision of air navigation services, will come under
increasing pressure. There is a need for a clear structural and commercial reorientation of the
authority.
The airport operations division currently has no clear commercial goal and is involved in a
multiplicity of projects, many of them economically unviable. The unwieldy business needs to be
broken down into smaller business units. For example, airport construction should be separated
from airport management, and these operations could further be divided into regions. Budget
accountability – which is only possible by creating these more manageable units – is essential if
the AAI is to avoid becoming another Air India. As value is created in the AAI‘s assets, a rolling
program of privatisation would see airports transferred out over time.
Efficiency: Low productivity of India‘s strategic infrastructure assets such as runways and
airspace has a major impact on airline efficiency. Mumbai Airport is only able to achieve 32
movements per hour, compared to Gatwick‘s 60 movements from a single runway operation.
Delhi can only support 55 movements from 3 runways. Meanwhile, airports such as Mumbai
and Pune are approaching their capacities and will be virtually choked and unable to handle
additional services for several years before new airports are opened. The fact that the Mumbai
Metropolitan Region, the commercial and financial capital of the country is expected to face a
period (from approximately 2014-2017) during which air connectivity to the city will quite literally
be saturated has severe economic repercussions which state and central governments do not
appear to have acknowledged.
Congestion, holding patterns and extended turnaround times all serve to increase costs. In
addition, low efficiency of infrastructure means that available capacity is exhausted early, capex
needs to be invested in building new airports earlier than should otherwise be the case and
these costs will ultimately be passed on to the airlines. Significant investment is therefore
required to enhance the efficiencies not only of Indian airports but also critically of airspace.
Airspace coordination: There is a need for greater coordination between civil and defence
entities with respect to the flexible use of airspace as occurs in most markets. Even historically
restrictive airspace such as China is gradually opening up to support the needs of civil and
general aviation.
Maintenance, Repair & Overhaul (MRO)
India has limited in-country third party MRO facilities. With a couple of exceptions, Indian
carriers do not have in-house capabilities beyond line maintenance, which means that they rely
on offshore providers for MRO services. With its relatively low labour costs and pool of basic
science and engineering graduates, with investment in skills and training India in theory has the
potential to emerge as a competitive MRO destination. However, it is hampered by a fiscal
environment that imposes additional taxes on third party operations. Until this is resolved Indian
airlines will continue to send aircraft overseas for maintenance, representing a loss of foreign
exchange for the country and lost employment opportunities for Indian engineers. Furthermore,
the regulatory requirement for airlines to conduct line maintenance in-house also increases
costs with no clear benefit.
Suggestions received from Airports Authority of India (AAI)
Marketing of Airports
AAI has been in fore front in creation of world class infrastructure in India. Now to
fully utilize the facilities created there is a need to market them to prospective airlines,
create new routes, and create openings for new airlines to come to Indian airports.
Creating an environment to convert the passive airport into business centers will go a
long way, towards aviation growth. New routes not only enhance aeronautical revenue
but bring in non-aeronautical revenue by way of facility utilization by commercial players.
Domestic Airports
Domestic airports revenue is largely dependent on flight related activities. Airlines
base their plans on anticipated profitability and look for every opportunity to increase
their market share. Airport operator with all the resources and capabilities want airlines
to operate at his airport, increasing the connectivity results in decongestion of existing
metro airports.
Existing Policy
Incentive to domestic airlines by not charging landing & parking charges if they
are operating with aircraft with a maximum certified capacity of less than 80
seats.
Discount of 25% of current rates in landing and parking charges to those airlines
who are operating in North-Eastern region, Jammu & Kashmir, A&N Island and
Lakshadweep.
Night parking charges between 2200 and 0600 hrs. at 50% of the existing
parking charges at all airports except Chennai & Kolkata airport.
New Initiatives
To promote selected airports related to tourism, religions places, state capitals,
industrial/business centres, a discount of 25% of landing & parking charges,
for two years on following airports
Sl. Name of Airport Aircraft No. of Parking Watch Hour
No. Operating Stands (IST)
1. Ahmedabad B 747 4 (Code A Type) 24 hrs.
5 (B 747-34)
8 (ATR)
7 (A 320 & B 737 – 9)
Int’l Apron
2 (A 321)
3 (B 747)
1 (A 380)
2. Amritsar B 747 1 (767-4) 24 hrs.
8 (A 340-5) & B 744
3 (AB 321/B 737-9)
2 (B 757-4)
3. Aurangabad A 321 4 (A 320) 0700-1000
1 (B 737-400) 1600-2100
1 (ATR)
4. Bhopal A 320 4 (old apron) 0630-2200
A 320 13 (new apron)
5. Bhubaneswar B 767-400 2 (B 767-400) 0630-2030
A 321 4 (A 321)
6. Chandigarh A 321 2 (A 321) 0800-2000
1 (ATR)
7. Coimbatore A 320 2 (B 737-8/A 320) 24 hrs.
4 (B 737-9/A 321)
1 (ATR)
8. Guwahati A 300 2 (B 737-9/A 321) 0600-2000
(Daily)
3 (A 320)
2 (B 737-2)
9. Indore A 320 12 0630-1245
(except Sat)
0615-2145
(Sat)
10. Jaipur A 300/ 1 (B 737-2) 24 hrs.
B 757-200 5 (A 320)
4 (B 767-4)
3 (B 737-9/A 321)
1 (A 300)
3 (B 747-4)
3 (ATR)
11. Lucknow A 300 5 (A 320) 24 hrs.
1 (B 767-4)
12. Mangalore A 310 8 (A 321) 0600-2200
1 (ATR)
1 (Dornier)
13. Patna A 320 1 (Dornier) 0630-2030
4 (A 320) (St. 3
occupied St. 4 cannot
be allotted)
14. Ranchi A 321 2 (A 321) 0630-2010
1 (ATR)
15. Surat A 320 4 (A 320 & 319) 1300-1700
(except Sat) Sat
no watch
16. Trichy A 320 6 (B 737-8/ A 320) 0700-1420
2200-0145
(1,2,3,5,7)
0700-1710
2200-0200 (4,6)
17. Trivandrum B 747 6 (B 737-8/ A 320) 24 hrs.
1 (B 747-4)
4 (B 767-3)
18. Varanasi A 320 6 (A 320) 0930-1730
.
Further, to encourage night parking, domestic airlines to be exempted from paying night
parking charges for five years at selected airports.
A rebate of 50% on existing landing and parking charges to domestic airlines for
operating at non-peak hours at non-metro airports, in 1st year and rebate of 25% in the
2nd year.
Land use issues
Land is a natural and precious resource with AAI. It is incumbent on the part of
airport owner/operator AAI to get all land records organized property.
Mutation of land belonging to AAI should be done and completed by 2015.
Required measures to safeguard land i.e. Construction of boundary wall, fencing,
boundary pillars with notice boards be put up.
All encroachments should be identified and decisive action initiated to get the
premises vacated from encroaches.
Annual check report on encroachments be filed by Airport Director with all
details.
At present land available with AAI at airports is used for aviation and aviation related
activities for discharges of functions by the Authority as prescribed under section 12 of
AAI Act. Keeping in view of the above provisions, land for aviation purposes can be
allotted.
Hanger for housing and maintenance of aircrafts
Hanger/land for establishing aircraft engineering facility, Ground support
equipment
Mobile Refueller parking
Aviation fuel station/Depot
Cargo Warehouse
Cargo Agents
Other aviation related activities for which land can be allotted are
Meteorological office and space for their equipments
Regulatory and facilitating agencies like Customs, BCAS, Drug Controllers, Plant
& Quarantine
Cargo handling agencies
Custom Hose agents
Banks, Post Office, Travelers Requisite shops
Hotels, Flight Kitchen etc.
Maintenance Repair and overhaul (MRO)
Maintenance, repair and overhauling of aircrafts is a legitimate requirement
related to aviation. Facilitating MRO facility at an airport is a win-win situation for airport
operator as well as airline operator. AAI has been allotting land to airlines for
construction of hangers for housing and maintenance of their aircrafts. However,
developing a strategy for having more MRO facilities at various airports (where land is
available), is a challenge and needs to be addressed.
Viability of Small and remote airports
Development of new or sustaining the existing small/remote airports is becoming
increasingly unviable as significant investment in creation of new or improvement of the
existing infrastructure is required. It should be appreciated if such capital expenditure is
to be sustained it should adequately remunerated. Airports should make reasonable
returns not just to cover the cost of capital for the investors/lenders but also should allow
the provision of high quality of service to passengers and airline while also having the
funds available for investment in future growth. In this context, in India most of the small
and remote airports are mostly unviable from revenue point of view. The revenue
generated out of operating these airports will not be even sufficient to meet the
operational expenditure, let alone making profits out of the business. Therefore, funding
to make such airports viable, must include Government grant for putting up infrastructure
and State Government assistance by sharing operational cost, as they are the direct
beneficiaries.
Suggestions received from APAO
AIRPORT:
Airports are a critical part of the transport infrastructure. It is important that Airport
Infrastructure gets developed in anticipation of meeting the future growth in demand for air
travel. Therefore, well planned, efficiently operating, modern world class airports are important
national assets. There is a vital need for the government to come up with the long term policy for
the Airport Sector. The policy issues highlighted for discussion by FICCI do not contain Airport
as one of the topic. It is very essential that a policy on the Airport must be part of the National
Civil Aviation policy particularly the policy on issues of private participation, Greenfield policy,
Brownfield policy, Cargo Policy, Hub Policy, development of non-metro airports and at Hilly
and Remote areas etc. The Policy must, most importantly, address the economic viability issues
of airports.
1.1 Civil Aviation Policy must ensure that airports are offered fiscal benefits similar to
industries, which includes benefits for certain number of years e.g. exemption from
Income Tax, Property Tax, Non Agricultural Tax (N.A. Tax), Electricity duty, Royalty on
minor minerals etc. Additionally, open land should be exempted from N.A. Tax and post
exemption period electricity duty should be as is applicable for industries and N.A. tax
should also be based on rates applicable on industries.
1.2 The policy objective must be to ensure sustainable airport capacity to meet the demand
forecasted for Passengers and Cargo traffic.
1.3 Ensure total safety and security of air transportation by introduction of state-of-art air
traffic technology, equipments and training facilities.
1.4 Develop Airport as a Multi-modal Transportation Hub, by integrating the Airport with
other modes of transport like Railway, Highway and Seaports to enable seamless
transportation across the country
1.5 Policy should consider granting infrastructure industry status to Airport sector.
1.6 A forward looking Greenfield Airport policy which encourages the investors and
developers to set up more and more Greenfield Airports in the country.
1.7 There should be a clear PPP policy on the airports.
1.8 Air Traffic control service may be allowed to be provided by licensed private operators.
1.9 More transparency needs to be on ATC/ANS pricing by incorporating international best
practices.
1.10 There is a need to have a clear and forward looking policy on Ground Handling services
by enhancing competition in the service by allowing professional ground handlers with
international experience.
1.11 Policy to improve Cargo handling facility at Airport is essential and also to develop cargo
handling capacity at all airports.
1.12 A clear policy to encourage the commercial activities in the airport for optimization of
revenue from Non-Aeronautical Services.
1.13 Policy to upgrade the airport security system by systematically assessing aviation security
threats, risks and vulnerabilities at the airport by adopting modern technology
mechanism.
1.14 Clear policy on financing of Airport Infrastructure by incentivizing private participation,
making easy the source of finance such as debt, equity, external assistance, public bonds,
external commercial borrowing and also making easily available loans from
government/institutions.
1.15 Policy on commercialization of all the non-metro airports by allowing private
participation in both aero and non-aero activities.
1.16 Policy to have an unambiguous legislative framework for privatization of airports
allowing total flexibility and avoiding any intervention by any agency.
1.17 Approval policy for the Greenfield Airport, Brownfield Airport should be made easy for
private developers to take up the project work. Single Window concept to be
implemented.
1.18 The policy should clearly define the role of central and state government and civil
military cooperation.
1.19 Policy to develop human resources in the airport management. Civil Aviation industry
requires well trained and highly skilled workforce on a continuous basis.
1.20 Policy to have easy clearance of all environmental issues.
1.21 Policy to develop a forward looking investor friendly regulatory mechanism.
1.22 Policy to encourage and support the Indian Industry to acquire airports development and
operations abroad.
1.23 Clear land acquisition policy should be in place for setting up of airports in the country.
1.24 The policy should aim at facilitating continued investment by ensuring economic viability
of the Airport sector.
1.25 Progressive tariff regime – Dual Till for all Airports.
LAND USE ISSUES
Land Policy should be aimed at balancing and facilitating land acquisition for various public
purposes including infrastructure development, industrialisation and other urbanisation but at the
same time meaningfully addressing the concerns of land owners. The land acquisition should be
aimed at infrastructure development in the country. Land acquisition and resettlement and
rehabilitation policy for infrastructure development must not be cumbersome and should not be
expensive. The scheme of compensation should not act as a barrier and burdensome to the extent
discouraging future infrastructure development activities. In PPP model infrastructure
development the responsibility of acquiring the land must be with the government and there
should not be any procedure of seeking consent of the inhabitants and exorbitant price and
cumbersome procedures. State/Central Government must acquire land and hand over the same to
developer at reasonable terms. Civil Aviation Policy should address all these issues.
MAINTENANCE REPAIR AND OVERHAUL (MRO)
Available forecasts indicate that India will have a huge fleet strength of aircraft by 2020 i.e.
approx. 1200+ aircrafts for Scheduled flights, 1000+ Helicopters, 2000 General Aviation aircraft
etc. India has therefore the potential to become a global MRO hub due to its low cost, favourable
geographical location, availability of technically skilled/certified aviation personnel. Also,
considering that India‟s share is only 1% of global MRO market, developing MRO facility in all
the major airports in India is essential. The policy should address this issue of setting up of MRO
facility by facilitating investment in this sector and also making available the land near the
airport. The policy should also address the issue of the present high tax regime which is causing
a major detriment for the growth of MRO industry.
CIVIL MILITARY CO-OPERATION
There are numerous areas of interaction/coordination between the Civil Aviation department and
the defence authorities in order to meet the requirement of air traffic. There is a necessity to
optimise the utilisation of restricted air space by adopting latest radar and data systems. There are
issues of non availability of additional slots for civilian flights for military airports and sharing of
revenue from non-aeronautical revenue from these airports with defence and civil aviation. The
Civil Aviation Policy should address this issue.
Dual Till Accounting
The Airport Infrastructure policy should clearly spell out dual-till that would not warrant any
cross-subsidization of non-aero revenue for encouraging investment by private entrepreneurs.
Aeronautical revenue and non-aeronautical revenue should be accounted separately. Otherwise,
investors will shy away from this sector.
Aerotropolis Development
In order to make the highly capital intensive Airports commercially viable, Aerotropolis
development with appropriate zoning around the Airport should be encouraged. The
Metropolitan City Master Plan developments should be integrated with the Aerotropolis
development. Land use policy should incentivize development of Aerotropolis in the airport area
which will bring tremendous multiplier effect in the whole metropolitan city.
Airport- Collaborative Decision Making (A-CDM)
Implementation of A-CDM at national level as enforced by US and EU, should be a priority. It
will improve the operational efficiency, ensure efficient use of scare resources and minimize the
flight delays. The collaborative data sharing and decision making by all the stakeholders in the
aviation industry like Airlines, Airports, ATC, Ground Handlers, Customs, Catering and the
passengers will be benefited substantially by A-CDM.
Sharing of Load Distribution Message (LDM) with Airports.
Sharing of LDM, which contains the details of the passengers, with the respective Airports
before landing of the Aircraft should be made mandatory for any scheduled flight operation.
Suggestions received Confederation of Indian Industries (CII)
Maintenance, Repair and Overhaul (MRO) / Offset : Indian carriers together have
a fleet nearing 1000 aircraft, comprising Boeing, Airbus and ATR models. Another
1000 Commercial Aircraft are forecast to be purchased in next two decades. MRO
constitutes a vital element of aviation infrastructure. At present, airlines in India
currently outsource major checks and aircraft servicing to MRO hubs like Singapore,
Malaysia, South Korea, China, Japan and Dubai. The MRO space is a $45-billion
market globally, of which India constitutes only 1%. To increase MRO business in
India, following are suggested:
Rationalization of taxes / customs duties: The high tax regime in India is a major
deterrent. This makes aircraft servicing about 50% more expensive in India than
internationally. Servicing an aircraft in India would entail service tax of 12.36%
(there is no such service tax overseas). Importing spares involves customs duties
of 25.40%. This unfavourable tax regime makes it cheaper for airlines to
undertake MRO checks out of the country. Customs duties and tariffs need to be
at par with the Airliners for spares, rotables, special tooling and test equipment
which are an integral part of any third party dedicated MRO facility.
Manpower: There is a perceived shortage of institutions which can produce
skilled/technical manpower required to handle MRO operations and this should
be duly addressed.
Infrastructure Status: In order to ensure economic viability and cost
competitiveness, it is essential that the MRO segment is given the ―infrastructure
status‖ with its accompanying fiscal benefits and incentives.
Deemed Export Status: It is also essential for the MRO business to get the status
of ―deemed export‖.
Support Infrastructure: Infrastructural constraints have acted as a major deterrent
towards development of MROs. Government needs to take proactive steps to
ensure allocation of land for hangars. Greenfield projects and modernization
projects of existing airports should ensure hangars and space for MROs.
Suggestions received from IATA
Land use issues
Safeguarding land is critical to the continuous development/expansion of airports.
Modular build provides airports to expand on a basis of ‗‘when needed‘‘, is less
disruptive to passengers during works and keeps operating costs in control.
Land should also be safeguarded beyond the perimeter fence line to cater for growth
of infrastructure and the development of support facilities. Key to this, is the
production of a 10 year Airport Master Plan which should be based on key factors
such, projected growth, capacity demand and government policy. The plan should
be reviewed annually in line with the aforementioned and should be a rolling 10yr
plan with periodic major reviews e.g. 5yr basis.
Suggestions received from Nathan Economic Consulting India Pvt.
Infrastructure Development
In order to protect the interests of the private sector – users of transport services – the
policy should set out clear rules and procedures governing the award of concessions
and other competitive bids. To attract the private sector to infrastructure rehabilitation
and creation, a government should apply a rationalized approach – that is, applying the
business perspective to capital investment – the investment necessary to serve the
customer in a competitive environment. Based on experiences of other developed and
developing country aviation sectors, the civil aviation policy should set out a framework
through which government procurement of goods and services will be centralized into a
searchable database with public access, which will bring additional transparency into
the bidding process.
Airports
In order for India to translate its strategic geographic location as a potential major
transfer hub between Europe/Middle East and Asia, the civil aviation policy needs to
create incentives for private and public market participants to work together to upgrade
available and create new infrastructure. Therefore, the policy should include an investor
friendly regulatory regime which is transparent and predictable. The policy should
distinguish between specific needs of large and busy airports, as well as smaller tier II
and III airports. Lastly, the policy should move away from the notion that airports are
natural monopolies and allow more than one developer build multiple airports within
large metropolitan areas such Delhi and Mumbai, thereby enhancing airport
competition. This policy will both help enhance India‘s competitiveness in developing
international transfer hubs and foster competition between India‘s airports.
Access to Infrastructure
In order to promote healthy and sustainable growth of India‘s civil aviation sector, the
policy should help promote open access to on-site (on the grounds of an airport)
infrastructure to all market participants. Furthermore, the civil aviation policy should
provide policymakers with a framework for cooperation between government institutions
and regulators overseeing access to connecting and off-site (outside of an airport)
infrastructure to all market participants. Allowing open access to on-site, connecting,
and off-site infrastructure would ease entry of new market participants into the sector,
resulting in enhanced competition within the sector. For example, in light of the recent
decision by the Government of India to allow direct import of ATF by airlines, access to
aviation fuel related infrastructure – off-site, connecting, and on-site - is needed to make
this new policy feasible.
Fees
India‘s civil aviation policy should also aim to reduce high airport fees, such as add-on
(made up of land rent, throughput, taxes, and infrastructure fees) and into-plane fees
(charged by the service provider for fuelling and de-fuelling aircraft). For example, when
compared to other regional international hubs, India‘s add-on fees, which are added to
the cost of ATF, make up a much more significant percentage of the international
benchmark ATF price. India‘s high add-on fees are one of the major contributors to the
high price of ATF, which negatively affects the ability of India‘s airlines to grow
individually, raises the cost of air carrier services to consumers, and reduces the pace
of overall growth of the sector. Furthermore, high add-on fees also deter foreign airlines
from re-fuelling in India, thus limiting the ability of India‘s airports to compete as
international hubs. Therefore, reducing the add-on fees will help India‘s civil aviation
sector grow. Furthermore, reducing add-on fees to reflect fee levels in other regional
hubs such as Kuala Lumpur, Hong Kong, Singapore Bangkok, and Seoul will also help
India compete for international airline business with the abovementioned regional hubs.
Suggestions from Go Airlines
Connectivity of airports - INTERMODALITY: All airports and specifically metro
airports should be well connected with road, rail, rapid transit network and ports (cargo).
The planning and development of airports should be in tandem with development of
transportation corridors under a single empowered body.
Development of airports should be based on traffic density. For example
development of airports such as Patna, Srinagar, Jammu and Leh should be prioritised.
Equipment standardisation: Provisioning and availability of equipment and
technology levels should be standardised and made available in accordance with the
category of the airport.
Airport, navigation and parking charges to be reduced to set off the additional
costs due to unavailability of infrastructure and inefficiencies.
The IT platform at all airports should have a common platform thus, allowing
users to build their technological growth consistently across the country. This shall help
facilitate maintenance, provide ease of training, reduce operational costs and provide
consistency of application and usage
Improve weather forecasting tools and techniques. Ensure 24x7 forecast
availability for all airports in the country.
Infrastructure capacity in accordance with demand, ensuring maximum utilization
of available capacities and efficiently managing the airport infrastructure by increasing
involvement of private sector.
Government shall encourage and come up with facilities for setting up
educational & training centers for all aviation related services including repair,
maintenance engineers, ground staff, cabin crew, pilot trainings, etc.
Impetus should be given for setting up repair & maintenance facilities in India.
The policy shall include measures to encourage investments in training and education in
various streams of activities involved in the aviation sector
2. SUGGESTION FOR AIR CONNECTIVITY
Suggestions received from KPMG:
1 Airlines
Airline landscape has changed dramatically during the past decade. Indian carriers catered to
54 million domestic and 13 million international passengers in FY 20113. The last few years saw
an increasing trend among domestic carriers to embrace the Low Cost Carrier (LCC) model. In
spite of this enormous growth, the Indian carriers incurred operational losses of more than Rs.
20,000 during the last three years4. Some key enablers that can facilitate the growth are as
follows:
a) Rationalize ATF charges with international benchmarks thorugh policy changes
b) Connect less lucrative Tier II/III cities through government incentives
c) Allow more Indian carriers to fly overseas by utilizing full quota of bilateral agreements
Suggestions received from CAPA:
Objective by 2015/16
AAI and Air India must be managed independently from MOCA with a profit objective
and be prepared for privatisation over 3-4 years;
An Aviation Finance Corporation should be established to provide dedicated capital for
the industry;
Objective Post 2015/16
3
Source: DGCA
4
Source: Annual report of the air carriers
Route Dispersal Guidelines: The requirement to operate social obligation routes creates a
distortion for the airlines and at the same time does not appear to be achieving the ultimate
objective of delivering greater connectivity to remote and less developed regions. Airlines are
being forced to fly services which often have poor loads, a situation which benefits neither the
industry nor the regions which are being served. A new approach needs to be considered which
better matches the nature of air operations (routes operated, size of aircraft) with the
connectivity needs of the remote regions, which could include reverse auctions for subsidies, as
occurs in the US, Canada and Europe.
Suggestions received from Airports Authority of India (AAI)
Route Dispersal Guidelines
According to Route Dispersal Guidelines formulated in 1994 by DGCA, all routes
were divided into three categories viz. Category – I, II and III. Route categorization was
based on traditionally surplus generating routes (Category – I), loss making routes
(Category – II) and the remaining routes (Category – III). The Category – I routes were
largely inter-metro routes and generated surplus that cross subsidized losses largely on
Category – II routes that served regions of difficult terrain and destination in remote
areas.
Category – II routes included routes connecting airports in North-Eastern region,
Jammu and Kashmir, Andaman & Nicobar and Lakshadweep. Category – III routes were
routes other than those included in Category – I and Category – II.
The guidelines also mandated a category within Category – II, referred to as
Category – IIA region, Jammu & Kashmir, Andaman & Nicobar and Lakshadweep.
It was obligatory on the part of scheduled airlines to deploy on Category – II, IIA
and III routes, a specified percentage of capacity deployed in Category – I routes as per
the following :
i) On Category – II routes, at least 10% of the capacity deployed on routes in
Category – I.
ii) On Category – IIA routes, at least 10% of the capacity deployed on routes in
Category – II.
iii) On Category – III routes, at least 50% of the capacity deployed on routes in
Category – I.
It is noticed that passenger and aircraft traffic is heavily loaded towards 17
International airports as compared to 55 Domestic airports.
Pax Traffic A/c movement
International airports - 90.67% 83.33%
Domestic airports - 9.33% 16.67%
With a view to maximize utilization of infrastructure at 55 airports, there is a need to
relook at Route Dispersal Guidelines.
New Policy
Recategorization
The Route Dispersal Guidelines (RDG) which is in force was formulated in the
year 1994 by DGCA and the criteria applied for defining Category – I route is now
fulfilled by another 10 to 12 airports which are present in Category – III routes.
Therefore, these airports may also be brought under Category – I route. Airports
like Pune, Goa etc. which were earlier in Category – III Routes should be
included in Category – I Route so that as per RDG airline operator will be made
to fly additional flights on Category – II Routes and Category-III which are at
present under utilized.
Creation of Essential Air Services Fund (EASF)
For development of low cost airport and to improve air connectivity to remote
cities of the country, Essential Air Services Fund (EASF) may be created with the
help of Central Govt., State Govt. & Airport Operators. The fund can also be
collected from passengers who are flying on Category – I & III routes. The fund
so collected can be used on routes which are commercially unviable for
3 - 5 years till they reach a level of maturity. Also EASF fund can be used for
promotion of air operations on routes identified by Ministry of Tourism as
destination of high tourism potential. Further, airports like Pantnagar, Kangra,
Dehradun, Gaya etc. may be brought under a separate Category route say
Category - IIB of RDG so that air connectivity and traffic growth at these airports
can be improved.
Other Initiatives
11 states have comparatively less air connectivity vis-à-vis population – Bihar,
Chhattisgarh, Gujrat, Jharkhand, Madhya Pradesh, Meghalaya, Orissa, Punjab,
Rajasthan, Uttar Pradesh and Uttrakhand. Their capitals are on airmap but other
towns remain unconnected. To improve air connectivity, new initiatives are
required.
- Underwriting of seats by State Government.
- Reduction in Sales Tax on ATF.
- Certain identified routes and routes which are having Passenger Load Factor
(PLF) less than 50%, be given assistance from Essential Air Services Fund
(EASF).
- State Governments to play active role in development of low cost airports.
- Concept of code sharing between Regional & Non-Scheduled Operators and
Scheduled airlines.
- Airlines be encouraged to have more direct flights between non-metro towns.
Suggestions received from APAO
CONNECTIVITY ISSUES
a. Route Dispersal Guidelines (RDG): It is a fact that route dispersal guidelines have
offered only a partial solution to issue of regional connectivity and was not a successful
model. The policy formulation should address the requirement of innovative mechanism
to achieve maximum connectivity with rural and inaccessible areas. New civil aviation
policy should address the issue to make the most efficient and economical use of routes
permitted by adopting market discovered pricing mechanism and also to help improve
connectivity to all the regional airports.
b. Regional Scheduled Operator Permit (RSOP): With the growing need for air
connectivity, it is essential to support and encourage regional players to enter into the
aviation sector. However, keeping in view the past record of the regional carriers, it
becomes crucial to review their performance and keep in place stringent checks relating
to their financial performance and safety & security standards.
These carriers are essential for regional connectivity but at the same time they also lead
to congestion at metro airports. This will put pressure on the infrastructure like terminal
building, airside capacity and most importantly on ATC. Though connectivity to the
regional airports is very essential, we cannot overlook the infrastructural constraints
being faced by the airports today. Therefore, the civil aviation policy must be designed to
ensure regional connectivity but also prevent unnecessary burden on airport
infrastructure.
c. Code Sharing: With the growing need for global and domestic connectivity, it is vital for
airlines to add new routes. Though it might not be feasible for one airline to fly on
multiple routes, thus Code share is a significant tool for airlines to develop their route
network and provide better connectivity with less time & cost.
It is essential for airports to have connectivity to multiple destinations (domestic &
international) hence code share amongst the carriers is crucial.
Keeping in view the above, Code-share agreements between Indian Carriers (including
Private Carriers) and foreign carriers should be liberalised. This will boost the overall
international & domestic connectivity and restrict foreign airlines to enter into the
regional markets. This will help in minimizing leakage of passengers from the catchment
areas of Indian Airports.
ESSENTIAL AIR SERVICES FUND (EASF)/REGIONAL AIR CONNECTIVITY FUND
(RACF)
Development of rural and remote areas have a direct bearing on the air connectivity between
these places ensuring essential air services to the remote and inaccessible areas of the country. In
order to set up the required infrastructure in such remote areas, it is essential to establish non-
lapsable essential air service fund to provide explicit and direct subsidies to airport operators and
airlines to meet the shortfall of viability gaps in line with USO fund in telecom. A policy should
consider setting up of such a funding mechanism for the civil aviation sector.
Suggestions received Confederation of Indian Industries (CII)
Route Dispersal Guidelines : As per the Ministry of Civil Aviation guidelines divided all
aviation routes in the country into three categories: Category I (CAT I) comprising of
Metros, Category II (CAT II) of North Eastern region, Jammu & Kashmir, Andaman &
Nicobar and Lakshadweep whereas Category III (CAT III) routes comprise all routes
other than those in CAT I and II. Further to the policy, any operator which operates
scheduled air transport services on one or more than one routes under Category I, will
be required to deploy on Category II routes at least 10% of the capacity it deploys on
Category I routes. Moreover, the operator has to deploy on Category III routes at least
50% of the capacity he deploys on Category I routes. Up to 2009, national airlines
could opt to buy an equal number of seats from regional or other carriers that have
operations on CAT – II, IIA and III routes to comply with existing norms. However in
2009 Directorate General of Civil Aviation (DGCA) banned this ―seat-miles‖ trading.
Non-compliance would lead to scrapping of the operating license.
There is a need to review, update and revamp existing route disbursal guidelines,
considering the present day situation where several airlines are flying. The following
is recommended
Rather than scheduled-carriers alone bearing the entire burden of providing air-
connectivity to the remote parts of the country, the state governments, which
stand to benefit the most should also partake their share of responsibility and
contribute
States to notify one airport each as CAT II (to enable enhanced CAT II options;
with 0% sales tax on ATF; and waiving off of landing and route navigation
charges by AAI on the designated airport)
Reduce CAT IIA to 5% (A North East regional airline would be able to provide the
thrust for intra-north east connectivity);
Regional Scheduled Operator Permit (RSOP) : This concept is, more or less, already
in existence. The existing airlines are providing connectivity to smaller cities wherever
there is a demand and in fact are creating newer routes, connectivity cities in their
respective geographical areas. Moreover, the route dispersal guidelines ensure enough
connectivity to cities other than major metros. For further deepening of air services to
smaller cities, the scheduled airlines may be encouraged to create feeder services
Essential Air Services Fund / regional Air Connectivity Fund : The objective of the
fund should be to compensate airlines which would fly on uneconomical route (Category
II and III routes). If this fund is created then there should not be any need for Route
Disbursal Guidelines. Any airlines flying willing on those routes should be compensated
through this fund. This fund should be created primarily through a contribution of
Central and State Governments and a marginal contribution of airlines
Suggestions received from IATA
Essential Air Services Fund (EASF)/Regional Air Connectivity Fund (RACF)
Essential Air Services Fund (EASF) / Regional Air Connectivity Fund (RACF) needs
to be looked at holistically while also taking into consideration the Route Dispersal
Guidelines (RDG) which currently exist and necessitate domestic airlines having to
fly on non-trunk routes based on their trunk routes volumes.
Funding of air services to ensure connectivity to various regions of the country which
would otherwise not be economically viable for the airlines, should be provisioned in
the Union Budget separately. The Central and the State governments need to
contribute resources to allow airlines to operate such uneconomical routes and aid in
providing regional air connectivity.
Suggestions received from Nathan Economic Consulting India Pvt.
Airlines
India‘s civil aviation policy needs to address the following competitive issues affecting
the health and growth of the nation‘s airlines; competitive neutrality in the treatment of
the national carrier vis-à-vis private airlines with respect to finance, take-off and landing
slots, and flying rights. Furthermore, the policy needs to address capital and fleet
requirements which create artificial barriers to market entry and make it difficult for
India‘s airlines to grow. Finally, the policy should set out to include market based tools in
ensuring service to all of India‘s airports and the distribution of take-off and landing
slots.
The policy needs to replace airline fleet and equity requirements with a framework for
financial disclosures with respect to both incumbent and new airlines. This framework
would allow regulators to see financial information that will help analyze the financial
viability of a particular airline. Replacing airline fleet and capital requirements with
financial disclosure requirements will help remove artificial barriers to entry for new
airlines, allowing the entry of additional service providers, leading to enhanced
competition within the sector.
The policy should replace current route dispersal regulations with an incentive or
subsidy based program for providing adequate service to all airports. Removal of route
dispersal regulations would reduce artificial barriers to entry and limits on the
participants‘ ability to respond to changes in demand for air transport, thus promoting
growth and enhanced competition. Based on experiences of Brazil, United States, and
European Union, route dispersal regulation may be replaced by a subsidy based
program, where airlines are provided with financial incentives for providing adequate
service to underserviced airports. However, the policy should institute a periodic review
clause for the financial incentive program, thus creating a catalyst for initial carrier
activity, but allowing market forces to take over once an economically viable route is
established.
The policy needs to expand its slot allocation system to include more market based
tools such as allowing slot trading and auctioning off a fraction of underutilized slots by
an independent authority, modeling the process after the UK. The policy should expand
the slot allocation system to include more market based tools such as; allowing slot
trading and auctioning off a fraction of underutilized slots through an independent
auction authority. Proceeds of the auction can be used to financially incentivize airports
to improve and expand available airport infrastructure.
The policy should also end preferential treatment granted to Air India, the national
carrier, with respect to allocation of traffic rights and access to government funding, by
amending Circulars No. 08 of 2009 and the Air Corporation Act of 1953. The
government‘s move to potentially eradicate Air India‘s privilege to the ‗right of first
refusal‘ of all seat capacity agreed to between India and another country is a step in the
right direction. International flying rights and other privileges make it difficult for private
airlines to fully compete with the national carrier. Furthermore, preferential treatment
creates disincentives for the national carrier to become a more efficient and financially
leaner service provider.
Lastly, the policy should allow foreign airlines to invest in Indian airlines. Since the
companies that are in the business of air carrier services, are in the best position to fully
understand the risks of the sector, excluding foreign air carrier service providers from
investing into Indian air carrier service providers, negatively impacts the growth of
India‘s civil aviation sector. Allowing foreign direct investment by foreign air carrier
service providers into India‘s civil aviation sector would create the possibility of code-
shares, optimal utilization of a carrier‘s fleet, and an expansion of consumer choice.
Suggestions from Go Airlines
Airlines should be given incentives for operating to tier 2 and 3 cities as they help
build connectivity with India (mutuating from US and/or EU Public Service
Obligations regulations).
3. SUGGESTION FOR AIR OPERATION REGULATION
Suggestions received from CAPA:
Objective by 2015/16
A new regional airline policy should be established which better supports the desirable
objective of enhancing connectivity to Tier 2 and Tier 3 cities;
Objective Post 2015/16
Airlines
Taxation: The highly punitive fiscal regime in India is the primary problem for the aviation
sector. The cost of Aviation Turbine Fuel in India is almost 60% higher than international
benchmarks. Combined with a high base price, fuel now represents 40-50% of a carrier‘s
operating costs. The volatility of such a significant cost input on this scale makes it extremely
difficult to plan cashflow and working capital requirements. In additional to taxation on fuel there
are several other fiscal imposts including service tax and withholding tax. The negative fiscal
environment must be addressed to provide a structure which keeps viability in mind.
Rationalisation of sales taxation on fuel to a flat rate of 4% would immediately result in a cost
saving of US$700-800 million. If the government is prepared to consider allowing direct
importation of fuel, it would appear to be far more logical to instead seek consensus on sales
taxation with state governments
Cost of Operations: Aside from fuel, Indian aviation is facing an increasing cost environment.
With almost US$10 billion of investment in airports over the last 5 years, airport charges are
expected to increase in the coming months, particularly at the major metros. Delhi and Mumbai
Airports, which together account for 40% of traffic in India, will completely pass through US$5
billion of expenditure to passengers. An additional 9 airports are expected to see increases in
charges. The proposed passenger fees will result in an increase in fares of a quantum that is
likely to impact demand and traffic volumes. The need to upgrade ATM infrastructure is also
expected to result in higher charges. The question of airport and airspace viability needs to be
addressed in a manner which does not further destabilise the airline sector.
The high cost structure and punitive fiscal environment make it difficult for Indian carriers to
compete with foreign competition and limit the potential to establish India as a global hub.
Addressing this could positively transform India‘s role in international aviation.
Suggestions received from BLUE DART Aviation Ltd.
Air Operations Regulations
a. Wet Lease Operations
Wet lease operations are undertaken by foreign registered aircraft in India operated by
foreign pilots who do not fall under the ambit of Foreign Aircrew Temporary Authorisation
(FATA). However, the other government authorities involved apart from the MoCA and
the DGCA, such as the Ministry of External Affairs and the Bureau of Civil Aviation
Security, are not aware of this distinction. Consequently, visas are not issued to the flight
crew, registration at the local Foreign Registration Office cannot be undertaken and
Airport Entry Passes are not provided to enable operations of the wet leased aircraft.
This results in lengthy procedural delays, increased costs, inability to utilize the aircraft
and nullifies the urgency of this entire exercise.
It is recommended that the new Civil Aviation Policy defines the wet lease operations
requirements unambiguously so that all concerned government authorities are aware of
the non-requirement of FATA for operations of foreign registered aircraft, and accelerate
the approval processes.
Suggestions from Aero Club of India
AERO SPORTS ACTIVITIES
Aero Club of India(ACI) was established in 1927 for promotion of flying and aerosports in our country.
ACI is a member of Federation Aeronautique Internationale(FAI), Switzerland, the international body
governing all Aerosports world over. Aerosports are at their infancy in India even after 65 years of
Independence. It is not only the western countries, even South Eastern Asian countries and Countries in
the Middle East have moved ahead of India in the field of aero sports.
In India, Armed Forces are able to pursue aero sports because they have abundant resources including
funds, manpower and have not to follow the rigid civilian regulations etc. This is good for services but
being unfair to civilian masses particularly the youth of our country.
Not withstanding the above, aerosports are not popular in India for variety of reasons like :-
i. High Cost of participation,
ii. lack of awareness,
iii. non-availability of facilities,
iv. rigid or no regulations.
v. Regulator lacking professional and operational knowledge on aerosports.
vi. Insufficient government support in terms of subsidies and financial schemes to encourage
aerosports.
vii. Stringent regulations to import certain Aerosports like Aeromodels, microlights, etc.
Inherently Aerosports are expensive, need greater professionalism, involvement, medical fitness and
bring up challenges which could risk one’s own life and life of others. We understand the concerns and
responsibilities of security agencies, air traffic controllers and regulators. Working of all of the above
need to be regulated in such a manner that aerosports are encouraged to broad base and promote
larger objectives rather than having narrow perspectives to stop activities. All concerns could be
appropriately addressed by bringing in awareness and right training for all concerned.
Aerosports are often mixed up and confused with conventional sports or Adventure Sports. This is a big
dichotomy. Aero sports are altogether a separate subject and need to be dealt with differently. Different
departments and ministries of the government issue instructions for different activities of aero sports.
It is felt that recreational hobby flying and aerosports for fun need to be promoted and encouraged.
Everyone cannot be hard-core professional. Everyone may not be interested in becoming a commercial
pilot or a commercial operator.
Distinction between profit making commercial business enterprises and non profit making sports
institutions need to be treated differently. Those who have different professions and earn their
livelihood but make efforts and spend money in aerosports to pursue their passions need to be
respected and encouraged. In India we have many such individuals and enthusiasts.
Opening up of the Safdarjung Airport for promotion of Aero Sports is essential. Undersigned also
volunteers to make a presentation to any security agencies in support of the argument that allowing
aerosports activities at Safdarjung Airport are not Security threat or a compromise. We need to bring in
awareness and education amongst one and all on this issue.
Undersigned also believes that we in India must have our own India specific regulations. We should not
follow any other country’s regulations. We are competent to formulate and follow regulations by
ourselves.
Undersigned has no objection to my views being put in public domain. I shall be happy to have any
deliberations on the subject to exchange views or contribute to Aero Sports. It is also recommended
that for the purposes of drafting the Civil Aviation Policy, a suitable aerosports person be taken on the
committee.
4. SUGGESTION FOR SUB POLICES
Suggestions received from KPMG
1 Air Cargo
India‘s impressive growth in international and domestic trade over past few years has augured
well for the air-cargo industry in India. Total freight traffic handled by Indian airports increased at
a CAGR of 10.9% in last five years to reach 2.33 mmtpa by FY -115. Still, the current share of
air-cargo compared to other modes of cargo-transportation is fairly low in India. The present
operating parameters (daily throughput, dwell times) at most air-cargo terminals of the country
are far from international best-practices. Some key enablers for growth of air cargo industry are
as follows:
a) Augment air cargo complex infrastructure through higher automation, increasing number
of screening machines, 24X7 security etc.
b) Make India a transshipment hub for east-west cargo through creation of dedicated
transshipment hub and streamlining customs procedures for the same
c) Mandate CBEC to switch over to multiple shifts of customs operations and augment the
number of customs personnel to cater to the increasing trade requirements
d) Make suitable amendments in EDI ver. 1.5 for efficient information flow between different
stakeholders
2 General Aviation (GA)
The General Aviation (GA) market in India is expected to grow at 10% per annum to cross Rs
1,600 crores by FY176. The key enablers required to achieve the projected growth are as
follows:
a) Review the existing regulatory and operational framework for equitable treatment to GA
operators
b) Develop the supporting infrastructure at airports in tier II/III cities, including night-landing
facilities and provision of heliports, to boost the GA industry.
3 Slot Policy
Airport coordination is mostly done at the Level 3 airports where demand for airport
infrastructure significantly exceeds the airport‘s capacity, necessitating slot allocation process.
In India, there are six designated Level 3 airports at Mumbai, Delhi, Hyderabad, Bengaluru,
Chennai and Kolkata.
5
Source: AAI
6
Source: DGCA
Key guiding principles of slot allocation process, as followed in India are –
• Slots are only allocated for planning purposes by a duly appointed coordinator at a Level 3
airport.
• IATA‘s WSG guidelines establish grandfather rights for runway slots, which permit airlines to
use those slots in the future which they have already used in the past.
• Airlines lose grandfather rights if they do not operate them for at least 80% of the time of the
respective flight period (use-it-or-lose-it)—one flight period is six months
• Slots may be freely transferred or exchanged between airlines, or used as part of a shared
operation, subject to the provisions of these guidelines and applicable regulations.
However, current administrative method of slot allocation suffers from several inefficiencies. It
denies newcomers the opportunity to enter the market and compete against major carriers. The
key enablers to achieve the required growth are:
a) Move towards market determined slot determination process. Slots could be better
allocated through market mechanisms, including alternative primary trading (eg,
auctions) and secondary trading mechanisms (barter or inter-airline trading), rather than
through purely administrative criteria. Indian airports should also consider the current
slot mechanism and move towards market determined process.
4 FDI by foreign carriers in Indian aviation
The proposal to allow 49% FDI by foreign airlines has been moved to the cabinet, which will
take it up shortly. Then it will be debated in the Parliament, before finally being legislated.
FDI by foreign airlines is a significant decision and can play a crucial role in improving the
aviation landscape in India. Apart from the much needed fund infusion, it would also provide
access to global routes, managerial expertise and synergy benefits. For global airlines, it is a
great opportunity to enter one of the fastest growing aviation markets in the world. The low air
penetration in India (4%) indicates the potential for growth.
5 Hub policy
Government wants India as emerge as a major regional aviation hub. However, infrastructure
has been a major handicap in the way of India emerging as a regional hub for aviation. Other
major obstacles to having a hub in India include an inability to attract passengers, saturated
airports and the poor health of Indian airlines. There is also a lack of efficient connectivity
between the domestic and international terminals made transfers from domestic to international
flights (and vice versa). Some of the enablers required to make India global aviation hub are:
a) Enable an open bilateral regime to stimulate competition and traffic growth as shown by
the global hubs of Singapore and Dubai. It can be instrumental in bringing down the
overall cost of travel and promoting economic growth.
b) Initiate broader partnership involving alliance partners, regulators, airport operators and
local authorities to overcome the hurdles.
c) Embark on a marketing overreach program by attracting airlines and freighters to set up
base in India.
Suggestions received from CAPA:
Objective by 2015/16
Foreign airline investment of up to 49% in Indian carriers should be permitted, we hope
that Cabinet approval for this proposal will be granted. This should be followed by
permitting 100% FDI in cargo airlines;
Bilateral rights should be allocated equitably amongst Indian carriers and not reserved
for Air India. A use-it-or-lose-it policy should apply;
Objective Post 2015/16
Slot allocation: Slot allocation at airports must also be conducted transparently by an
independent slot coordination committee with clearly defined and published criteria for allocating
slots, otherwise distortions are created that impact competition between airlines.
Foreign Direct Investment: India is unique in maintaining a distinction between foreign
investors and foreign airline investors. For 20 years we have grappled with this issue, with no
clear rationale as to why the investor class that would bring the most expertise to the sector and
offer higher valuations due to strategic synergies, is barred from participating. Foreign airlines
should be permitted to take equity stakes of up to 26% (and ideally 49%). Lower limits which do
not allow the investor to block special resolutions or to take a seat on the board will limit interest
– given the fragile state of the airlines, any significant investor will understandably want to have
some say in key decisions. Strategic investment by airlines will provide confidence to further
institutional capital to follow and will strengthen management capability.
It is important not to simply consider the foreign airline investment issue from the prism of the
incumbent carriers. If the government is open to issuing new licences, joint ventures between
leading international carriers and large Indian corporations could arise (similar to the earlier
Tata/Singapore Airlines project which was not approved), bringing a new level of capital and
professionalism that would be highly positive for the sector. Without new players, we would
have to ensure the survival of the existing airlines, which may ultimately be at a cost to the
taxpayer.
5 Year / 20 Aircraft Rule: There is no logic for this discriminatory regulation which applies to
Indian carriers and not foreign airlines. It has prevented Indian carriers from claiming their
rightful share of international traffic. Despite the fact that as of this year there are no longer any
incumbent airlines with international ambitions that are being prevented from operating, the
existence of the regulation is unnecessary. In addition to which it presents an obstacle to the
establishment of potentially viable start-up airline models such as a low cost longhaul operation.
International Traffic Rights: Most Indian carriers are now eligible to operate international
services and wish to do so, but are facing delays in obtaining rights to launch new routes due to
Air India‘s first right of refusal. National assets - in the form of bilateral entitlements – are thus
being viewed through the prism of a seriously bankrupt company. Air India has limited capability
to operate new routes, meanwhile blocking private carriers from doing so. For the private
carriers this results in sub-optimal utilisation (and higher costs) of narrowbody aircraft as they
are unable to conduct back-of-the-clock flying. And if aircraft cannot be deployed overseas,
domestic capacity will increase putting further downward pressure on fares. Pending
applications should be approved immediately.
Market Expansion and Entry: Oversight of the industry must take into account an in-depth
structured analysis of airline financials. Airlines should not be permitted to expand if they are
burdened with huge debts, negative net worth and limited cash. In addition, it is a concern that
airlines that have previously closed have been able to obtain an NOC to re-launch even though
previous debts to banks and suppliers have not been cleared.
New airlines should not be permitted to enter, in fact it should be actively considered for
operators with strong business plans and which are well capitalised. MOCA must develop the
capability to critically evaluate business plans for which it must remain at the cutting edge of
airline strategic thinking. For example, in 2004 the most commonly heard view in Indian aviation
was that LCCs were not suited to the market because of various issues such as the Indian
passenger being
Given the financial weakness of incumbent operators, we should not be reliant upon them to
deliver additional capacity. And in particular new attention needs to be paid to the regional
airline policy which has not been successful even though the objective of increasing connectivity
to Tier 2 and Tier 3 cities is an important one.
Alliances: The process of Indian carrier accession to membership of Star Alliance and
SkyTeam has become Air India-centric and is holding up the integration of Indian aviation into
the global system. A more rational approach should be adopted as alliance membership could
provide valuable passenger feed both in terms of volumes and yields. Airlines should also be
permitted to codeshare to maximise the commercial viability of their operations and to offer
greater options to passengers.
Commercial Flexibility: The restrictions on airlines being able to adjust their forward schedules
in response to market demand limits their commercial flexibility. As does micro-intervention on
issues such as the ability to charge additional fees for exit row seats or extra baggage. Since
these ancillary charges allows passengers to benefit from lower base fares and to customise the
product to better suit their requirements and budget, whilst allowing airlines to develop a more
sustainable operation in an environment of wafer thin margins, there appears to be no rationale
for prohibiting them.
Legal Framework: Aviation is subject to acts of parliament which date from the 1930s with
limited relevance to today‘s environment. This structure imposes archaic procedures higher
costs.
Airline Objectives 2015: Over the next 3 years the negative fiscal environment must have
been addressed, this would be the most significant contribution that could be made to the
sector. Additional distortions, such as the 5 year rule, restrictions on foreign airline investment,
route dispersal guidelines, allocation of bilaterals to private carriers and limitations on ancillary
revenues must be dismantled. Most of these restrictions are arbitrary with no clear rationale.
Moving forward, the focus for the Ministry should be on ensuring a safe, secure and competitive
industry, with new licences granted to applicants with sound business models and adequate
capital. Encouraging skills development will require particular attention as this is one of the most
critical but overlooked supply side challenges for the industry in the future, not just in India but
globally.
Freight
An efficient air cargo and logistics sector is vital for competitive trade and investment. In many
ways it is already more liberal than passenger services (India follows an open skies policy with
respect to all-cargo operations), however there remain areas for further progress. The fact that
air cargo is lower profile than passenger operations means that there should be fewer political
obstacles to reform in this area. Successful air cargo operations are based on global transport
and logistics infrastructure. If India is to integrate into these international networks the leading
global operators must be allowed to establish their operations in the country either in terms of all
cargo-air services or the establishment of infrastructure such as warehousing and high volume
throughput systems.
However, if such infrastructure is to be developed it will require the support of dedicated air
cargo capacity. The opportunity should therefore be taken to unilaterally dismantle barriers to
entry, including 100% foreign direct investment. The cooperation of other government agencies
is also required – particularly quarantine, customs and excise to expedite cargo processing and
to reduce dwell times at Indian airports which are well below international benchmarks.
Ultimately an efficient air cargo environment will support inward investment in manufacturing in
India due to the ability to seamlessly integrate with global supply chains.
General Aviation (GA)
With a clear vision, general aviation could emerge as a key driver of regional connectivity and
economic development. The paradox of Indian GA is that this sector which has massive growth
potential has no dedicated policy or regulatory frame nor infrastructure or services to support it.
There needs to be a realisation that the GA sector is already large with close to 750 aircraft
(larger than the scheduled fleet), and could grow to a fleet size of around 2,000 by 2020. This is
a sector which must be acknowledged, incorporated and supported. Failure to pay attention to
GA could impede the development of an important component of the aviation value chain and
have worrying safety and security implications.
At a policy level GA has largely been ignored and operates in the shadow of commercial
airlines. There has been limited consideration for GA requirements in air traffic management
planning, or in the development of dedicated infrastructure at airports other than Delhi and
Mumbai. The government recognises the need to extend the aviation network beyond
scheduled operations between metro cities, as demonstrated by the fact that it has introduced
incentives for regional operators operating aircraft seating less than 80 passengers. Under the
regional airline policy, a flat rate sales tax of 4% applies on fuel in every state (the rate
otherwise varies by state and can go as high as 30%). This sales tax concession on fuel should
be extended to GA.
A national airport masterplan should seek ways to increase capacity and flexibility for GA. This
will include ensuring adequate parking and hangar space, allowing MRO/FBO activities on the
airport, and developing ATC procedures capable of accommodating increased small aircraft
movement. Second, serious consideration should be given to the development of disused or
low traffic secondary airports for GA. This can provide seedbed opportunities for aviation in
areas where it is not yet significant. State governments could become active in reviving smaller
airports, particularly for air taxi operations for business, tourism and freight, which could benefit
regional development.
Access to airspace should be equitable and ensure that GA can operate effectively. There also
needs to be recognition that not all airspace needs to be controlled, and with appropriate
regulations and facilities this in itself could facilitate GA movements.
Scant regard is paid to GA in the current regulations. Limits on imports of aircraft and especially
parts do not recognise differences between helicopters and fixed wing aircraft. The multiplicity of
aircraft types, fragmentation of operators and evolving technology will undoubtedly create
headaches for the regulator. There is a shortage of personnel to develop, monitor and enforce
regulations in GA. Quality and safety audit systems are seen as deficient. The sheer resource
requirements to address this issue may necessitate the establishment of a dedicated division
within the regulator or even a restructuring of the Directorate General of Civil Aviation (DGCA).
There are too many agencies involved in the acquisition of an aircraft. Lax or inappropriate
standards increase accident risk, reducing the appeal of the sector for investment and
increasing the cost of capital. However, there is an opportunity at present to take a clean-sheet
approach and structure a new regulatory framework that would allow India to develop a safe,
modern and efficient GA sector.
The Ministry of Civil Aviation must push ahead with its plans to appoint a Director for GA so that
there is a dedicated bureaucrat responsible at a policy level for addressing the wider
infrastructure, fiscal or technical problems faced by the GA industry.
Suggestions received from Airports Authority of India (AAI)
Slot Allocation Policy
Prior to 2007, the Airports Authority of India (AAI) was allocating slots to
international & domestic airlines which were operating from all airports in India.
AAI allocated slot to airlines according to International Air Transport Association
(IATA) scheduling guidelines. Ministry of Civil Aviation had nominated Chairman, AAI for
allocation of slots to international airlines for their operations to/from India in consultation
with representatives of Director General of Civil Aviation (DGCA), Air India, Bureau of
Civil Aviation Security (BCAS), Departments of Customs and Bureau of Immigration.
After leasing of Delhi and Mumbai Airports to JVCs, and setting up of the
Greenfield Airports at Hyderabad & Bangalore, the situation has changed. Following
suggestions are made for inclusion in the slot allocation policy.
i) Airline who has better On-Time performance record may be considered for
allotting additional slots.
ii) Weightage may be given to consistency in utillisation of slots vis-à-vis
cancellation of allocated slots to an airline.
iii) Weightage may be given to the payment record of an airline. No dues certificate
from airport operator may be considered for allocating of unused slots.
iv) If an existing airline proposed a new flight to connect new stations, the same may
be given priority over other airlines for allocation of unused slots. The airline must
operate the same sector throughout the season and should not cancel such
flights otherwise slots related to this flight are liable to be cancelled.
v) Airline who plans to operate to an airport within restricted ‗watch hour‘, priority
may be given to such airline for allocation of slot.
vi) If an airline who has been allocated slots and fails to start its operations within 15
days from the state date, then its slots should be cancelled. Such airline will be
required to reapply for slots which will be processed based on availability.
vii) The historicity of slots should be linked with On-Time Performance i.e. operation
of flight within + 15 minutes of the allocated slot. In case any airline looses its
historic slot and if there is a demand of this vacant slot by more than one airline,
the same may be allowed to be auctioned by the Airport Operator.
viii) Amendments to approved slots needs to be minimized. Only when airlines are
inducting new aircraft or due technical reason, the amendment may be
considered. If an airline makes amendments on regular basis, without any
convincing technical reasons, to an existing schedule, then suitable penalty
should be imposed on such airlines.
Airport Hub Policy
To improve regional connectivity and to develop regional hubs, a committee was
formed a under the Chairmanship of Jt. Secretary for drafting policy on creation of
Airport Hub. Under this policy, Regional Airlines will be encouraged, by providing
suitable regulatory & fiscal incentives. In this regard, State Government will also be
requested to provide suitable incentives to Regional Airlines.
CARGO
1. Introduction
Establishment of integrated cargo Terminals at Metro airports
AAI has developed modern integrated cargo terminals at four metro airports at
Kolkata (1975), Mumbai (1977), Chennai (1978) and Delhi (1986).
While the Operations, Management and Development of Delhi and Mumbai
airports has already been taken over by JVC w.e.f. 3.5.2006, the cargo facilities
established at Chennai and Kolkata are being managed departmentally.
Establishment of interim/integrated cargo Terminals at Non-Metro airports
Having established air cargo complexes at metro airports, AAI has also
developed interim/integrated cargo handling facilities at Non Metro airports at
Nagpur(1997), Guwahati(1999), Lucknow(2000), Coimbatore(2001), Indore &
Amritsar in 2007 to handle international cargo and courier business. Out of these
airports, AAI is managing cargo facilities departmentally at Coimbatore, Amritsar,
Lucknow & Guwahati in addition to Chennai & Kolkata Airports.
The facility established at Nagpur has been handed over to M/s MIHAN India Pvt.
Ltd. w.e.f. 7.8.2009. The AAI staff has been deployed on 100% absorption basis
at Nagpur to manage the cargo operations. However, the customs custodianship
remains with AAI.
The facility at Indore has been outsourced during 2007 to M/s GSEC in terms of
Cargo Business Plan w.r.t. ‗Development of Domestic Airports for International
Cargo Handling‖.
Establishment of interim domestic cargo/Couriers Terminal
An Interim Domestic Cargo / Courier Terminal has been commissioned at
Kolkata Airport w.e.f. 10.9.2008. The domestic carriers have been allotted space
on common user basis to carry out their domestic cargo/courier business.
2. Policy initiatives by AAI
(a) Policy on setting up of cold storage facility
AAI has developed a ‘policy for establishment of Centre for Perishable
Cargo at Airports’ (CPC), in consultation with APEDA and Ministry of
Agriculture. The salient feature of the policy;
If Centre for Perishable Cargo (CPC) is created with the assistance of
Agricultural & Processed Food Products Export Development Authority
(APEDA) and run by AAI
- Special terminal charges @ Rs. 0.70/kg at par with general cargo
rates
- APEDA has agreed to provide X-ray machine for future projects
(AAI X-ray usage charges will be not applicable).
where the CPC is created by Central/State Govt. Org by leasing
land / space from AAI or CPC is created by Central /State govt. Org by
leasing land / space from AAI and where it is proposed to enter into a JV
with Pvt. Participation as long as Central / State Govt. Enterprise holds
not less than 51% in the equity of JVC
- Nominal license fee @Rs.1/- p.a. to be charged for 7 years &
Special. terminal charges @Re.0.70/kg. at par with general cargo
rates
If the CPC is created and run by Private party by leasing land from AAI
- Land / space allotment on priority and on AAI commercial terms
(b) Development of Domestic Airports for international cargo handling
AAI has also formulated a policy during June, 2006 for ‘development of
domestic airports for international cargo handling’ by leasing space/land to
interested organizations through open tenders on AAI commercial terms i.e.
applicable licence fee + percentage share of Gross Turn Over (GTO),
maintaining the standards of international level.
3. Initiatives by Govt. of India
(a) Open Sky Policy
The policy of ―open skies‖ for air cargo was adopted in 1990, initially for a three-
year period, and extended in 1992 on a permanent basis (Aeronautical
Information Circular AIQ No. 18/1992). Under this new policy, any airlines,
whether Indian or foreign carriers which meet specified operational and safety
requirements, are allowed to operate scheduled and non-scheduled cargo
services to/from any airports in India where custom/immigration facilities are
available. In addition, regulatory control over cargo rates for major export
commodities has been abolished so that carriers are free to set their own rates.
(b) Parallel Air Cargo Terminal Operations
Unlike at Indian Airports some of the major airports like Flughafen at Frankfurt ,
Changi at Singapore and Hong Kong Airports etc. have the concept of dual
agencies performing Cargo Terminal functions in competitive environment.
Airports in Middle East like Dubai and Sharjah have the Airports Authority
functioning as a sole Terminal Operator.
In order to bring healthy competition, MoCA during November, 2002 had decided
for parallel air cargo terminal operation at Mumbai ACC to be run by Air India and
AAI from ETV warehouse and existing cargo terminal respectively.
Similar decision has been taken in respect of Trivandrum Air Cargo Complex that
while the existing arrangement of KSIE, the custodian may be allowed to
continue at Thiruvananthapuram airport being one of the 24 non-metro airports
where city side development is proposed to be done through PPP, as such
another operator could be appointed through PPP mode.
The Govt. is committed to have the competitive atmosphere to provide the best
of the services to the ultimate users at the air cargo terminals across India.
(c) Reduction in free period of cargo
To reduce congestion at airport and to increase the cargo capacities, directives
were issued to all airport operators to reduce the free period to 72 hours from 5
working days granted to exporter / importer / airlines in clearance of their cargo.
Suggestions received from APAO
CARGO POLICY:
1 Trade in Airports/Aviation Sector is affected on account of several factors such as custom
clearance, warehousing issues and intervention of many agencies. Indian Air Cargo industry
is at an inflection point. Air Cargo through put has more than doubled in the last decade. Air
Cargo policy should focus on making India a preferred transhipment hub for global air cargo
movement. The right vision, road map, forward looking policy and regulatory framework is
essential for taking India to the rightful place in global air cargo industry.
2 The processing time for major export handling activities / import cargo clearance are far
below the international standards. Restricted working hours for cargo clearance affects piling
up of cargo and puts tremendous pressure on the capacity and cargo operations and requires
24x7 cargo clearance working by all agencies such as Customs dept. and Customs house
agents etc. Hence a clear policy to streamline the regulatory procedures in all the airports in
order to reduce the dwell time and to have 24*7 cargo clearance working/customs operations
in all airports is essential.
3 Policy to minimize/eliminate manual intervention in all clearing process.
4 Policy to make all the custom activities free for the operators. Recent issue of imposing
Customs cost recovery on Greenfield Airports adversely affects the import / export business
to be withdrawn as any additional cost will adversely affect the trade. Moreover, Customs
being a sovereign function of the Govt. and the cost of that should be borne by the
Government and not be charged from the Operators.
5 Policy to enhance the efficiency of all the agencies working at the airports. Apart from
Customs, several other agencies are also responsible for clearance of goods at Airports and
they must improve their processes for easy and fast clearance. The clearance process being
extremely slow the capacity as well as throughput of Perishable cargo is greatly impacted,
besides inconvenience to the Importers.
6 Policy should be to improve efficiency through automated material handling system and
IT system, making paperless environment, e-freight etc.
7 There should be a clear policy on land acquisition near all the airports for expanding
cargo handling capacity.
8 Policy to improve road and rail connectivity of the air cargo terminal to have easy
transportation of goods, low cost of logistics and minimal wastage of perishable cargo.
9 Container Corporation (CONCOR) of India and other Integrated Container Depots
(ICDs) need to be encouraged to tie up with Airports to develop the latter to Multi-modal
Transportation Hub.
HUB POLICY
1. Policy should be framed to make all strategically located Indian Airports as Hub and
Spoke model to make them most efficient, cost effective, liable, safe, secure and comfortable
air travel to passengers. There are substantial economic gains which can be derived from a
Hub airport including improving employment opportunities.
2. The policy should be to have an integrated transport model connecting Seaport, Road and
Rail Transport and to certain extent Public Road transport utilities to make hub-spoke model
most efficient and cost effective by utilizing economies of both scale and scope and provide
passengers and cargo seamless connection and more efficient services.
3. The policy needs to position India as a global hub by effectively utilizing world class
airport infrastructure capacity to handle large movement of aircraft and augment trade and
tourism opportunities and to ensure seamless transition for the passenger and the airline.
4. Policy should be to facilitate a collaborative approach between both airports and airlines
to work in tandem to handle the international competition and the growing air passengers and
cargo movements. Hub-Spoke model provides both cost and demand advantage over smaller
networks.
5. Policy should be to coordinate various agencies including Immigration, Customs, CISF
etc. to make available the passenger convenience, connectivity/network etc. matching
international benchmarks/standards.
6 Plan for scheduled optimization by utilizing bilateral traffic rights available for all Indian
air carriers for expanding their global foot print.
7. A policy to allow visitors from all the friendly countries the facility of Visa on Arrival on
arrival in all the Indian Hub airports.
8. Policy to discourage direct connections to the foreign airlines to the non-hub airports
because it will be difficult to promote Indian airport as Hub specially when the rights are
being granted to foreign carriers to over fly the Indian Hub.
9. A series of taxes and duties are levied on the ATF that makes it expensive compared to
international industry average. As a result, ATF accounts for nearly 40% of the operating cost
of Indian Carriers. The Policy should aim to minimize taxes on ATF to promote financial well
being of airlines which will result in the overall growth of Aviation industry.
10. India is one of the few countries imposing service tax on air tickets, due to which air
travel becomes a luxury rather than an integral mode of transport. The civil policy must
abolish this tax to promote air transport in India.
SLOT POLICY
1. As per OMDA and SSA, the Airport operator is solely responsible for the management
and allocation of both domestic and international slots.
8.5.4 of OMDA agreement mentions:
“The JVC (Airport Operator) is responsible for the management and allocation of aircraft
landing and timetable slots at the Airports, for both domestic and international traffic. JVC shall
allocate slots at the Airports in consultation with Airlines, in accordance with IATA Slot
Allocation Guidelines as issued and updated from time to time in a fair, reasonable and
equitable manner”
8.11 of SSA Agreement mentions::
“Airport Operator shall have the final right to allocate slots at the Airports, subject to the same
being allocated fairly and not arbitrarily and shall use reasonable endeavors to accommodate
the relevant airline operators the slots allocated at the Existing Airport at the time of its closure.
Accordingly, slot allocation should be the prerogative of the airport operator.
2. Presently slots allocation is done as per the IATA Worldwide Slot Guidelines and also
various guidelines issued by MOCA/DGCA from time to time.
3. Civil Aviation Policy to be framed to protect the legitimate right of airports to allocate on
a fair, transparent and user friendly basis.
The slot policy must address the following issues:
a. The slot of those Airlines that are not operating flights continuously or irregularly for
7 days in a month must result into cancellation and no historicity to be given for
cancelled slots for the next season. The Airport Operator would however give a fair
opportunity to the carrier by seeking reasons for the non operation of the flight by that
carrier prior to the cancellation of the slot.
b. To prevent misuse of slots, a high penalty should be imposed on the Airlines, which
will ensure scarce resources are used most efficiently.
c. The Slots of the airlines who are regular defaulters in payments should be withdrawn.
d. In congested airports such as CSIA, where slots are a scarce resource, 95-5 rule
should be applied for grandfather rights, provided that the flights are operated within
+/- 15 minutes of STA/STD. It is advisable that when Airlines file slots they should
be taking into account the real block time and inherent constraints and delays in their
operational system. For instance, the European airports are migrating from 80-20 to
85-15 rule for better utilization of capacity. However, 80-20 rule may continue for all
other airports which are not congested.
e. The 95-5 rule should be applied on the size of the aircraft at congested airports like
CSIA. Therefore, the carrier should operate minimum 95% of the time the same size
as approved or bigger size of aircraft as filed.
f. Any changes by the airlines in the slots allocated for specific sectors with specific
aircraft type without the due approval of the airport operators should be considered as
a gross violation of approved slots. This will attract high penalty and result into
cancellation of slots.
Airlines operating any flight without the due approval of the airport operators shall result into the
imposition of high penalty. And the airport operator should have the right to stop such
operations.
BILATERAL POLICY
Excessively liberal bilateral towards Middle-East, Singapore and Sri-Lanka allow the respective
carriers to leak traffic from non-metro airports. Most of the Bilaterals allow “All” Airports as
“point of call” thus do not support funneling of traffic from Metro Airports. So foreign Airlines
should be allowed to operate To & Fro Metro Airports only. A review on the bilateral therefore
is in the national interest. Also, the domestic carriers of Indian origin should be allowed to
operate to international sectors availing the unutilized seats granted to the national carrier (Air
India).
Majority of traffic rights granted to the designated carriers of India are either unutilized or
underutilized and those granted to foreign carriers are either fully utilized or are being
sufficiently utilized. This disparity in the usage of traffic rights is on account of various reasons
like:
Our national carrier is not in a position to fly on various sectors due to its financial
condition & aircraft availability.
Restrictive approach towards granting traffic rights to Indian Private carriers
Past allocation of traffic rights to foreign airlines
The Civil Aviation policy must focus on:
1. Liberalizing our current policies and enabling the Indian Private carriers to utilize the
available traffic rights granting additional rights on the sectors which are fully utilized by
both countries.
2. Restriction on granting of additional traffic rights to foreign carriers (especially from
Middle East).
3. No additional point of call in India to be granted to foreign carriers
4. Airport operator should be a part of the Bilateral Air Service negotiations.
5. Liberalization of code share agreements between Indian carriers (including private
carriers) and foreign carriers.
MARKET ACCESS POLICY
Civil Aviation market contributes significantly to the process of development of the country. It
also contributes to GDP substantially. All this demonstrate the significant footprint the Civil
Aviation sector has on the Indian economy. Considering the importance of this sector there
should be an easy entry and exit policy for the Civil Aviation sector. The policy must encourage
investment for both Indian and foreign investors. It must also ensure removal of all the
bottlenecks for easy access.
The market access policy in India is governed and monitored by Ministry of Civil Aviation,
Government of India. Market access to the designated carriers of foreign countries in India is
dealt through bilateral Air Service Agreements. Domestic market for Indian carriers is fully
liberalised, however DGCA has laid down Route Dispersal Guidelines to ensure route
connectivity Pan India.
India has witnessed tremendous growth in air traffic for the last 5-7 years. This growth has been
due to the economic growth and emergence of LCC in India. However there are limitations for
India carriers (Private) to expand their network in international market. Government should
liberalise traffic rights for Indian carrier to access international markets.
FOREIGN DIRECT INVESTMENT (FDI)
The FDI policy should be to attract foreign investment in Indian Civil Aviation market. As far as
airport sector is concerned, the existing policy allows 100% funding through FDI whereas in
many of the segments of the Civil Aviation sector there are restrictions in allowing FDI. By
facilitating free flow of FDI, the industry will be able to meet the requirements of funds, get the
technical knowhow and also facilitate global access. The new Civil Aviation policy must address
the issue, if any and facilitate flow of FDI to the maximum extent possible.
REGULATORY PHILOSOPHY
1. The concession/project agreements already signed should be adhered to, to maintain the
investor confidence. Ministry of Civil Aviation (MoCA) should issue directions to AERA in case
of deviations in the policy.
2. MoCA should have unequivocal/absolute power to issue Directions to the regulator.
Regulatory philosophy should be predictable and should not be subject to frequent changes to
ensure regulatory certainty of the sector.
3. The policy should support in establishing a forward looking investor friendly regulatory
environment which will ensure a level playing field for competing suppliers and also ensure
credibility in the ability of the regulatory establishment to safeguard the interest of both the
seekers and providers of service.
4. Policy should ensure setting up of independent regulatory mechanism to position between
legislator, executive and judiciary on one hand and market on the other hand.
5. Policy should ensure to maintain independence of the regulator from the executive.
Regulatory agency is given functional autonomy in its day to day functions.
6. The government should rest with the power to amend or to repeal law or rules in order to
remove or reduce regulatory burden in the industry.
7. The policy should also ensure appointment of regulator who possesses the competence
and integrity in order to inspire public confidence of the regulator. The regulator should be
appointed on a fair and transparent basis with a view to ensure that the regulatory system remains
insulated from political interferences.
8. The policy should ensure that the regulatory institution remain independent and
autonomous.
9. Policy should ensure a reasonably long fixed tenure say 3-4 years for a regulator. The
members of the regulatory body should ideally be drawn from different sectoral/subject field
experts.
10. Policy should also clearly focus on fostering competition rather than on regulation.
11. In a supply-lacked scenario like India, regulations should seek to bring in investments by
creating incentives for the operator to create additional capacity or efficient usage of the facilities
to maximise the number of passengers (or freight volumes).
12. The return on capital employed should be in line with the risks involved with operating
an airport and ensure that investor confidence is maintained enabling development of the airports
in line with the vision of the Indian Government.
REGULATOR FOR AIR TRANSPORT SECTOR
1. We believe that competition is the best regulator for a sector like air transport. Setting up
of a regulatory mechanism for air transport should be the last priority rather the government
should ensure a competitive market which will only give the desired result. However taking into
account the present situation of airlines sector, there is a requirement to streamline the process
and procedures in the airline market and to discipline the sector. It may be considered that this
will also be subject to regulation and monitoring by AERA instead of setting up separate
regulator for air transport sector.
2. There should be a separate Appellate Tribunal exclusively for the Civil Aviation Sector
to ensure settlement of disputes speedily.
POLICY FOR GENERAL AVIATION
There should be a clear policy for encouraging the growth of general aviation in the country. The
policy should address to have a regulatory framework to enable the growth of general aviation.
The policy should also address to encourage investors for developing the supporting
infrastructure at all airports, to enhance the passenger amenities and to boost General Aviation
industry. Policy should also address for improving and upgradation of non-operational airstrips
to make it a full scale operation in future. The policy should also address the importance of
creating a reliable and regularly updated database of all airports and airstrips in the country. It is
also important to develop heliports to support the growth of general aviation in India. Policy
should also address the option of setting up of a separate monitoring and facilitation agency for
general airlines in the country. Aeronautical charges for General Aviation should be out of the
purview of regulator and the airport operator must be given the right to fix the same.
Suggestions received Confederation of Indian Industries (CII)
Cargo : The Logistics Performance Index (LPI) study by the World Bank indicates
that a country that promotes an efficient and cost-effective transport and logistics
sector achieves 1% - 2% higher GDP growth compared to other countries at the
same level of development. Better logistics performance is strongly associated with
trade expansion, export diversification, ability to attract foreign direct investment and
economic growth. Considering the above, the Civil Aviation Policy should lay a
special focus on cargo aviation by
Providing Non-discriminatory access and charges: Access to airports, allocation
of parking bays and slots should be accorded the same priority as passenger
airlines, and charges (and discounts) should be proportionately applicable.
Providing Dedicated Self-handling facility: Any forced move to a common-user
facility would severely cripple service quality and destroy the business model.
User- Friendly Air Cargo/Air Express Zones: Designated cargo bays at close
proximity and situated close to the air side/city-side operations facilities, allotted
at specific areas of the airport would greatly enhance connectivity of transit loads
and reduce turnaround time which, in turn, would increase productivity at the
airports.
Hub Policy : While the airport infrastructure has been spruced-up over the last
couple of years, it alone may not be suffice to make India a civil aviation hub. For
India to be a civil aviation hub, domestic airlines need to be equally support to
expand to become truly international. On one hand this would require airports and
airlines, including cargo airlines, to work together and on the other hand
government‘s support in terms of a investor and business friendly regime.
Regulatory Philosophy & Regulator for Air Transport Sector : At present, there
are two regulators in the aviation sector viz. Airports Economic Regulatory
Authority to determine the tariff for the aeronautical services and various other fees
such as development fee, passenger fee, etc. and set performance standards. ( for
airports ) and Directorate General of Civil Aviation has been playing a role of a
regulator in terms of safety, airworthiness of civil aircraft, licensing of pilots, air traffic
controls, etc.
The Government may consider creating a full fledged regulator for Air Transport
Sector on the line of CAA with the following role :
Air Safety
Economic Regulation – looking at predatory pricing though not fixing air fares
Airspace Regulation
Consumer Protection
Environmental Issues
Policy for General Aviation : While general aviation has been growing at a rapid pace,
there is hardly any support in the existing policy framework. Rather, it is subject to
several restrictions. A separate policy needs be drawn for general aviation recognizing
its role and growing importance in the country. The policy should identify steps required
to be taken up to create a conducive environment for general aviation.
Bilateral : The traffic rights exchanged under bilateral agreements seem to be far in
excess of the true 3rd/4th freedom market requirements in respect of several countries.
As a result, in most of the cases, the capacity deployed under the bilateral is also in
excess of the market requirements. The following are suggested :
The access to a point of call in India should be granted primarily if there is
justification for true 3rd/4th freedom traffic from that point to the concerned
country.
Even if there is significant traffic potential from a point of call in India to a
concerned country, before granting access to such a point of call, it must be
considered if the Indian carriers are already providing enough capacity – so as to
prevent the situation of excess capacity in that market.
For determining the requirement of the market, true 3rd/4th freedom traffic - based
on the origin/destination (O&D) data only should be considered.
The existing bilateral provisions/markets should be reviewed on a regular basis
between the Ministry and the Indian carriers.
Review bilaterals and allow Indian Carriers, Greater utilization so that the Share of
Indian Carriers in International Traffic rises considerably.
Foreign Director Investment : At present, 49% FDI in allowed in the civil aviation
sector with a complete bar on foreign airlines to invest. While there is a restriction on
FDI, Non-resident Indians are allowed to pick up 100% equity in airlines. For airport
sector, FDI policy is quite open and liberal. In the case of greenfield airport projects,
100 per cent FDI is allowed under the automatic route.
There is a need to take a liberal view as far as FDI in aviation sector is concerned.
There seems to be no rational of restricting foreign airlines investing in Indian
aviation sector whereas 100% FDI is allowed in shipping. Foreign Airlines to be
permitted to Invest up to current permissible FDI limit of 49 % and not restricted to
26% only. It is believed that getting foreign airlines involved directly will also instill
more confidence by foreign investors in domestic carriers, with overseas hedge
funds and private equity groups more likely to join in supporting strategic
investments into Indian airlines.
Suggestions received from IATA
REGULATORY PHILOSOPHY
1. The AERA Act passed by the Parliament of India empowers the independent
regulator to regulate aeronautical tariffs for major airports in India. In its capacity,
AERA set in process a very comprehensive and thorough study of the philosophy
for economic regulation of Indian airports which involved extensive consultation
with all industry stakeholders, including consumers, airports and airlines. This
resulted in an appropriate philosophy for economic regulation in the context of
India which guarantees regulated airports a fair rate of return on their investment,
while also safeguarding consumer interest.
2. AERA has opined in great depth on the technical matter of single till versus
dual/hybrid till and arrived at the conclusion that single till is the most appropriate
approach in the Indian context.
- Guaranteeing investors a fair rate of return would be an attractive proposition
for all current and future investors in the airport sector in India.
- Moving away from single till with fair returns already guaranteed to airport
investors is akin to allowing airports to earn disproportionately higher returns
(above the Weighted Average Cost of Capital). This will add to the cost
burden on the consumer and therefore would be against consumer interest.
3. The Civil Aviation Policy should record the position arrived at by the Independent
Regulator as the consistent guiding regulatory philosophy for Indian airports, both
brownfield and greenfield ones.
IATA‘s suggestions related to Regulatory Philosophy are listed as under:
I. Till: IATA supports the implementation of the single till. The concept of the single till
is widely understood within international aviation regulation. ICAO provides a simple
explanation of the single till in Paragraph 30 i) of ICAO Document 9082/8: ―The cost
to be shared is the full cost of providing the airport and its essential ancillary
services, including appropriate amounts for cost of capital and depreciation of
assets, as well as the cost of maintenance, operation, management and
administration, but allowing for all aeronautical revenues plus contributions from
non-aeronautical revenues accruing from the operation of the airport to its
operators.‖ IATA supports implementation of Single Till for the following reasons:
- Interdependency: There is a very strong symbiotic relationship between
airlines and airports as each needs the services provided by the other.
Economic activities at airports are generated by the presence of airlines. It is
reasonable to assume that in the absence of aeronautical services there
would be no market for non-aeronautical services such as retail concessions
and car parking. In this context it is also useful to note the UK Competition
Commission‘s findings, which states “Against those, at most, limited benefits,
we see significant disadvantages from the dual-till approach. We believe it is
difficult sensibly to separate commercial and aeronautical activities. BAA's
rental and other commercial revenues at the three London airports would not
be generated without aeronautical facilities-commercial and aeronautical
facilities are better, therefore, in our view, and more realistically regarded as
one business. Since the successful development of commercial revenues
requires airlines to attract passengers to the airport, the benefits of
commercial activities should also in our view be shared with airlines and
airline users.”
- Absence of a competitive environment for airports: Airports are natural
monopolies, thus their pricing behaviour is tempered by the lack of formal
competition. It is IATA‘s strong belief that hypothetically, if airport
management companies were in a competitive environment (e.g. if they had
to regularly tender to provide airport services to airlines), as a rational
business, they would not treat aeronautical and non-aeronautical services as
two distinct income streams.
- Simplicity: The single till has long been recognised as a simple system to
administer, as there are no complex or contentious cost allocation issues
between aeronautical and non-aeronautical activities to deal with. A dual
pricing till system will need to be detailed and robust oversight by a regulator
required to ensure that aeronautical activities are not unjustly burdened with
costs that are not attributable to the services provided and to ensure that the
costs of common use space and resources are allocated reasonably.
- Under-investment in aeronautical resources: Under a dual till approach,
airports would have had to make continued capital investment decisions,
given there is an implicit scarcity of financing resources within all companies,
capital will be allocated to fund resources that provide the highest economic
return. Non-aeronautical investment as an unregulated source of income will
generate higher returns when compared to aeronautical investment. Thus
future investment decisions under a dual till environment will be weighted to
non-aeronautical infrastructure.
- IATA‘s Pragmatic Approach to Single Till Pricing: Recognising that the airport
is an indivisible enterprise, a common sense approach to pricing aeronautical
services with analytical merit is the single till approach. Under the single till
approach, aeronautical charges are effectively set to recover the costs of
providing aeronautical services less any excess profits the airport operator
achieves from non-aeronautical services. In this way, it treats the airport
business as an indivisible enterprise and recognises the interrelationships
between aeronautical and non-aeronautical investments, operating costs and
revenues.
II. Fair Rate of Return: IATA accepts that airport investors should receive a fair rate of
return provided:
the airport delivers an efficient operation
the airport delivers minimum quality standards
the rate of return properly reflects the lower risks of a monopoly
III. Capital Investment: Capital investments by airports or ANSPs have a significant
impact on users and costs to passengers. Without effective open communication
between all parties, there is a real danger that individual strategies will result in
unnecessary and expensive investments, resulting in over-capacity issues and
unnecessary cost increases for airlines and passengers. It is important that airlines
are consulted early in order to share the same vision with the airport/ANSP
regarding investment planning.
IV. Operating Expenditure: The price cap regime has inherent incentives for
airports/ANSPs to push to reduce operating expenditure and that a compromise on
service levels can be minimized by incorporating a parameter linked to service
performance in the price cap regime formula. Costs incurred because of mandates
by regulatory authorities should be treated like any other investment costs and not
simply passed through. Cost pass-through would not incentivize airports/ANSPs to
seek cost-efficient solutions to meet regulatory requirements.
V. Service Quality Monitoring: In order to ensure that the service to be provided by
an airport will not be compromised for the sake of pursuing higher or even
excessive profits, there must be some protection against deterioration of service
standards. An airport should commit to a service charter that sets out the general
performance principles, criteria and measures to be adopted.
VI. Pre-funding: IATA opposes pre-funding as a form of financing for airport/ANS
development projects as it contradicts with the ‗user pays‘ principle. It is unfair for
passengers or airlines to pay for facilities that are not yet available and that they
may never use. IATA agrees that pre-funding should absolutely be the ―last resort‖
after all available financing options have been explored. These options include
borrowing from commercial banks; borrowing from financial institutions such as
ADB and World Bank; floating commercial papers to raise funds from the
commercial market; securitise revenue stream for a given period; direct assistance
from Government as the aviation industry creates wider economic benefits; public
private partnership (PPP).
VII. Individual Tariffs versus Aggregate: IATA accepts setting of tariffs based on a
specified aggregate. For establishing individual tariff/fees based on this aggregate,
IATA prefers the regulator to play the determining role after information gathering
and consultations with stakeholders. This would be a more efficient process given
the familiarity of the regulator with the out-of-bounds markers for tariff setting
particularly with the need to comply with ICAO‘s principles on cost-relatedness, non-
discrimination, effective user consultation and full transparency. IATA is fully
opposed to setting of charges based on ―ability to pay‖ as it contravenes the
fundamental ICAO principle of cost-relatedness and non-discrimination, and has a
high degree of arbitrariness inherent in it. Airlines and passengers should not be
charged differently for using the same facilities. If the State chooses to apply an
―ability to pay‖ policy, it should subsidize the charges directly and not put the burden
on international flights/passengers.
VIII. Passenger Charges versus Airline Charges: Where possible and practical, IATA
will seek to ensure that airport charges are set on a per passenger basis rather than
through other charges, subject to necessary legal and regulatory issues to be
addressed. The key benefits of charging on per passenger basis are:
- Transparency - Passengers would have increased visibility of the charges
they are paying. This may encourage airports to maintain or reduce the level
of charge through cost reduction and cost efficiencies.
- Risk Sharing - Passenger fees are a means for sharing the risks and
benefits of changes in passenger traffic between airports and airlines.
Slot Policy
1. Coverage: The Policy for Slot coordination should apply to all Indian airports (Levels
1, 2 & 3) regardless of ownership of airport.
2. Independent Coordinator: The Policy should establish an Independent Single
Coordinator which will be responsible for coordination and facilitation of slots activity
at all airports in India. The Policy should identify and prescribe roles and
responsibilities of all the key stakeholders in the slots management process –
Government (Ministry of Civil Aviation), the Independent Coordinator, the Airports
and the Airlines.
3. Coordination Committee: It should be ensured that in an airport that has been
designated as fully coordinated, a Coordination Committee is set up to assist the
Independent Coordinator in a consultative capacity. Participants in this committee
should include the air carriers and/or their representative organizations using the
airport(s) regularly, the airport authorities concerned and representatives of the air
traffic control. The same coordination committee could be designated for more than
one, or all airports.
4. Designation: The Independent Slot Coordinator should be appointed by the Ministry
of Civil Aviation – functioning in line with the rules and guidance prescribed.
5. Capacity Analysis: At an airport where slot allocation takes place, a competent
authority should determine the capacity available for slot allocation twice yearly in
cooperation with representatives of air traffic control, customs and immigration
authorities and air carriers using the airport and/or their representative organizations
and the airport coordinator, according to commonly recognized methods. The results
of this exercise should be provided to the airport coordinator in good time before the
initial slot allocation takes place for the purpose of scheduling conferences. The
results of the demand and capacity analysis should also be made available to all
interested parties.
6. Being a part of the international aviation community, the Slot Policy should follow
agreed global policies, processes and best practices for Slot Allocation – specifically
the Worldwide Slot Guidelines (WSG). The WSG lists the following as the key
principles of Slot Allocation:
i. Slots are only allocated for planning purposes by a duly appointed coordinator at
a Level 3 airport.
ii. Slots are only allocated to airlines and other aircraft operators.
iii. An airline or other aircraft operator must have a slot allocated to it before
operating at a Level 3 airport. Certain types of flight (for example, humanitarian
or state flights) may be exempt or subject to special local procedures.
iv. A series of slots is at least 5 slots requested for the same time on the same day-
of-the-week, distributed regularly in the same season, and allocated in that way
or, if that is not possible, allocated at approximately the same time.
v. An airline is entitled to retain a series of slots on the basis of historic precedence.
vi. Historic precedence applies to a series of slots that was operated as allocated by
the coordinator at least 80% of the time during the period allocated in the
previous equivalent season.
vii. Historic slots may not be withdrawn from an airline to accommodate new entrants
or any other category of aircraft operator. Confiscation of slots for any reason
other than proven intentional slot misuse is not permitted.
viii. Slots may be freely transferred or exchanged between airlines, or used as part of
a shared operation, subject to the provisions of these guidelines and applicable
regulations.
ix. Coordinators must be functionally and financially independent of any single
interested party and act in a neutral, transparent and non-discriminatory way.
x. The allocation of slots is independent from the assignment of traffic rights under
bilateral air service agreements.
xi. Slot times are based on the planned on-block (arrival) and off-block (departure)
times. Actual times of arrival and departure may vary due to operational factors.
Hub Policy
There has been impressive development of world-class airport infrastructure at
many of India‘s important gateway airports – which positions India to operate hub
airports which can support growth of both O-D traffic as well as transfer traffic.
Airlines are critical players in making a strong hub. India needs strong and
efficient carriers which have the scale, reach and financial strength to feed the
traffic needed to build strong hubs. Indian carriers need to also be plugged into
the major global airline alliances and have a network of interline and codeshare
arrangements.
Costs will be a key factor which will bring new transfer traffic to India. Indian
aviation cannot continue to have a high cost environment. Airports need to focus
on costs; while the high price of ATF continues to be a deterrent for growth as a
serious aviation hub. There is a need to make India competitive also on account
of costs for ground handling, cargo, MRO operations among others.
Tourism is an anchor which needs to be developed further. India has been
unable get past the 5-6 million annual tourist inflow figure. The potential in India
far exceeds this figure given its diverse and varied product offering. Destination
marketing, extension of visa on arrival schemes and other specific tourism
related initiatives need to be embarked upon.
Foreign Direct Investment
IATA fully supports the liberalization of both the market access as also the foreign
Ownership and Control Liberalisation. IATA believes that the Airlines need to be allowed
to function as normal businesses which have the same commercial freedoms as any
other business entity. In a study commissioned by IATA in 2009 on the impact of
liberalization of market access and foreign ownership and control liberalization, Inter
VISTAS-EU Consulting Inc made the following projections:
Liberalisation of market access (ASAs) is forecast to increase international traffic
to/from India by 11.8 million passengers, an increase of 42% from 2007 levels.
Ownership and control liberalisation is projected to increase international traffic by
6.6 million passengers, an increase of 23%. Liberalising market access and
ownership and control in combination is expected to stimulate an additional 18.5
million international passengers, an increase of 65%.
Liberalisation would also provide considerable benefits for passengers. Average
fares are forecast to decline by 31% with market access liberalisation, by 19% with
ownership and control liberalisation and by 50% when both forms of liberalisation
are undertaken. These fare reductions provide increases in consumer surplus of
between INR 20.8 Billion and INR 62.3 Billion.
The increase in air service and passenger traffic is forecast to generate employment in
a number of ways:
o Aviation Sector: additional economic activity in the aviation sector is generated
by the servicing, management and maintenance of the additional air services.
o Tourism Sector: air service facilitates the arrival of larger numbers of tourists to
a region or country; this includes business as well as leisure tourists. The
spending of these tourists can support a wide range of tourism related
businesses: hotels, restaurants, theatres, car rentals, etc.
o Catalytic Impacts: includes the role of air transportation in facilitating growth and
productivity in the general economy by increased trade, business activity and
greater personal productivity.
In total, liberalisation of market access was forecast to generate 584,400 full-time
equivalent (FTE) jobs, while ownership and control liberalisation is expected to generate
a total of 325,700 FTE jobs. The two forms of liberalisation in combination are forecast
to generate 910,100 FTE jobs in total. In addition to employment, liberalisation is also
forecast generate incremental GDP of between INR145 Billion and INR405 Billion.
Cargo Policy
Focus on E-freight: E Freight is an aviation industry initiative which focuses on
removing paper from the air cargo industry to increase efficiency and reduce cost for
all partners in the supply chain. While the main freight lanes and global air hubs are
already part of the e-freight network, India has lagged behind.
Promote Encourage use of EDI (information flow) between airports, airlines and
operators.
E-freight is aligned with the e-Commerce initiatives of the government. With the
XML message and document development by Indian Customs Authorities, there is
an ability to receive these documents online from airlines, freight forwarders and
shippers.
Development of a security program (e.g. Known Shippers/Regulated Cargo Agent
program) where bottlenecks surrounding insufficient screening equipment and lack of
associated manpower should be alleviated as screening can be done upstream in the
logistics chain.
Suggestions received from BLUE DART Aviation Ltd.
Indian Air Cargo Growth Trend
Airport statistics segregating air cargo and air express are not available for Indian airports.
However, the size of India‘s express industry in 2006 was pegged at Rs: 7100 crores (CARE
Research Estimates & Market Survey) and is today estimated at 10,000 crores. India has one
scheduled domestic air cargo (air express) airline which has carried 33.5% of the total domestic
cargo of 493,400 tonnes at the 7 airports to which they operate – Ahmedabad, Bangalore,
Chennai, Delhi, Kolkata, Hyderabad, Mumbai – for the period Jan – Nov 2011. (Source: DGCA
Statistics & BDA Statistics).
Regrettably, the tonnages are low compared to uplift in airports of countries at the same level of
development as India. India‘s true potential, with its edge of a vast geography and large
population, can be achieved only if due recognition is given to the air express airline segment
for its contribution to trade, commerce and to the economy of the country. Appended are our
inputs for a civil aviation policy to support the growth of this segment. In our
recommendations, the terms Air Express and Air Cargo are used interchangeably since
airline operators are issued with an Air Operator Permit for Scheduled Air Transport
Services (Cargo):
1. Sub Policies
a. Air Cargo & Air Cargo Hub Policy
There is a desperate lack of an aviation policy that recognizes the criticality of air
express to economic progress and one that is conducive to support and stimulate
growth. Current practices are skewed to benefit only passenger airlines.
i. Discriminatory Policy against Scheduled Air Express Operators. As per Circular
Ref: AV.11014/22/2002-Rev/ dated 11 February 2004, a discount on landing charges
of 15% is applicable on domestic flights subject to the condition that airport charges
are paid within the credit period of 15 days. However, scheduled cargo operators are
exempted from the discount even if the fleet type in operation is similar. No rationale
has been given for this decision. This is contrary to the spirit of ICAO document 9562
that states very clearly that access and charges should be non-discriminatory.
ii. Inconsistent policy in the allotment of facilities. Dedicated express facilities are
a proven, successful model worldwide. However, there is no consistent policy for
allotment of dedicated facilities at any of the airports, and air express operators are
dependant on the arbitrary benevolence of the airport operator. Since the business is
not customer facing, facilities allotted to air express operators are often in old
dilapidated, rat-infested buildings in some airports. These are difficult to maintain and
result in damage to shipments and subsequent claims, as well as pose a health
hazard to employees. The facilities are often inadequate, entailing some of the
shipment processes having to be performed in the open without any protective cover,
and damaging shipments in adverse weather conditions. Requests for alternative
facilities remain dormant for years.
A clear policy is required, making it obligatory on the part of the airport operators to
allot space to Air Express operators on a dedicated basis at all major airports within
a time bound manner, and in accordance with the projected growth requirements.
The involvement of all express operators in assessing growth projections and future
needs is necessary in framing a Master Plan which meets the needs of the industry.
Approvals to the master plan are to be given by the MOCA only after proper
consultation with the users and operators in a transparent manner. This allocation
should be based on the specific requirements of the industry which are unique – ie
landside and airside access, proximity to cargo bays and adequate connectivity to
arterial city side roads with adequate parking space and docking stations for trucks.
b. Operations Infrastructure that would support high quality services to benefit the
customer by giving him speedy market access and a fast reliable supply chain.
Lack of facilities for Express Airlines at airports with scope for adequate
expansion. As there is no clear cut policy on the obligations of the airport operators to
provide for dedicated facilities for air express, facilities that are provided, except for Delhi
and Bangalore, are inadequate to support any long term growth. Moreover, facilities
leased are for a short time frame of one to three years. In Chennai, Blue Dart Aviation‘s
lease rentals have been valid for one year at a time for the past 15 years. Such
uncertainty inhibits long term planning as large investments are required to make such
facilities functional and suitable for air express requirements. Operators are burdened
with huge costs on wastage when obliged to re-locate, as they are often directed to,
within a short period after spending much time, effort and cost in building and
refurbishing these facilities. Our Delhi, Mumbai and Hyderabad facilities are prime
examples of re-locations within a short time frame (1 to 2 years) of allocation, building
and furbishing. Optimizing utilization of available, unused infrastructure at airports by
allocating them to serious operators would go a long way in alleviating this challenge
and would benefit both the airport operator and the user. A comparison of air express
facilities available at some of the Asian hubs, such as Singapore, Hong Kong, Bangkok
and Shanghai, indicates that Indian airports are grossly inadequate to attract the
volumes experienced at these airports.
i. Lack of parking bays and parking facilities at close proximity to each other and
to the cargo warehouses. There are no designated cargo parking bays, either at
remote parking stands or at cargo terminals, which are the norm in any important,
major cargo hub globally. As a result, parking bays are difficult to come by, and are
allocated at a distance from each other. Often, one aircraft will be allocated a
domestic bay and the other directed to the international terminal end. Air express
operations entail ramp transfers of loads between aircraft. The long time taken to
traverse the distance and having to cross live taxiways result in a chain of delays,
impacting turnaround of flights and delays or missed surface connections that are
ultimately detrimental to the customers‘ business, increase the requirement of
ground handling equipment at airports, and lower the efficiency of airport utilisation.
As India‘s economic importance grows, it would become inevitable to create one or
more air cargo hubs to facilitate trade and commerce through efficient logistics. Hubs
entail the handling of a number of cargo aircraft at a single airport from various
origins simultaneously with a quick interchange of loads. This can only happen if
there are sufficient cargo bays that are positioned practically. As all air express flight
operations occur at night, it is necessary to allocate bays for day parking of the
aircraft.
For issues related to airside infrastructure bottlenecks for air express, it is recommended
that an air express policy (as a subset of air cargo) distinct from a passenger airline policy
be evolved with regard to presence at airports. Airport operators, in consultation with
express operators, must ensure that all serious express operators who are optimizing space
at the airports are provided with dedicated facilities. All future airport expansion plans should
include dedicated air express dedicated facilities and freighter parking bays at express
terminals/facilities, and operators should be consulted during the planning phase.
Suggestions received from Futura Travels (ESSAR Group)
POINTS FOR GENERAL AVIATION OPERATIONS- AEROPLANE
1. Approval of Acquisition Committee -- Indian registered aircraft owned by
an Indian company which is being sold to an Indian company still requires a
clearance from Acquisition Committee.
Suggestion – this should be reviewed as the asset is already in India. Direct
sale should be allowed with intimation to the MoCA and DGCA.
2. Approval of Manufacturer’s facility – Presently DGCA approval is required
by the manufacturer to maintain their own manufactured aircraft. For instance
to maintain a Gulfstream V aircraft by GAC, Savannah or Luton, approval of
DGCA is required.
Suggestion – This procedure appears dichotomous and needs to be reviewed.
3. There are few airports like Surat and Thirupati where IFR and ILS are
installed but the ‘watch hours’ are restricted, hindering the General
Aviation Operations in particular
Suggestion – Watch hours for the airports like these should be made 24hrs.
4. Fuel Duty – With Ministry allowing all the scheduled airlines to import fuel
directly, this should be made applicable to NSOP aircraft too or NO fuel duty
to be levied on the NSOP aircraft returning from overseas flights.
5. Operations from Defence Airports: - As per the existing practice AOR/NOR
request is required to be submitted well in time, during working hours to
Defence HQ if the G.A. operator has to operate with an Expat Crew or
passenger even if the Airfield has a separate enclosure and parking bay for
the non-military aircrafts and there is no such rule for the scheduled airlines.
Also it is pertinent to mention that expat crew flying under FATA has already
undergone through security clearance.
Suggestion:- Requirement of AOR/NOR clearance for Expat Crew and
Passengers to be waived off while operating from a Defence Airfield having a
separate Civil flight enclosure
6. Cross utilization of Pilots: - Cross utilization of Pilots have been permitted
vide CAR Section 3 Air Transport Series C Part III issue II Dated 01 June
2010 for Non Schedule Operators. However this needs to be made more
flexible and in fact should be encouraged. Presently any pilot can fly for
maximum two operators other than his own and no operator can borrow pilots
for more than 03 months. In General Aviation, where pilots get very minimal
flying hours, and mostly on the ground waiting for a flight, keeping a similar
type of aero plane of another operator on ground due to absence of their own
pilot is a retrograde step for keeping a pilot proficient and current.
Suggestion:- No restriction to be imposed on cross utilization of pilots subject to
he/she possessing all requisite valid licences for the type of aircraft.
7. Expeditious processing of YA No.:- Presently 24 hrs notice in working
hours for an Indian Registered and 7 days notice for a foreign registered
aircraft is mandatory for obtaining of YA number. This needs to be made
quicker and should be available on 24X7 hourly bases.
8. Removal of Mumbai Airport Closure for G.A. Operations: - Presently
there is curfew hours at Mumbai Airport for G.A. Ops from 0800-1000, 1730-
1930 and 2115-2315. This impinges heavily on G.A operations resulting
avoidable delay in return to base and loss of scarce Flight Duty Hours for the
crew.
9. Qualification Requirement for Check Pilot/Instructor/Examiner for G.A. is
too complicated and appears to be totally airline based. This needs relook to
cater for G.A. Operations
10. Route Check Requirements: - This could be made as annual practice in lieu
of six monthly routine currently being followed. Route Checks also to be
permitted to be carried out in Level D simulator like IR/LR, CA-40 checks etc.,
where different weather, pitch dark night conditions could be simulated for
better training value.
11. Cabin Crew Training Facilities: - Owing to G.A. operators having a fleet of
different types of aircraft, the type trainers for the cabin crew are not available
in Mumbai. DGCA is suppose to promulgate list of approved training institute
for Cabin Crew, but it hardly caters for all type of aircraft in G.A. It is
suggested that Cabin Crew training for G.A. operators be made more flexible
and operators be empowered to get them trained by PIC and AME of the
aircraft.
12. BCAS Issues: - BCAS is issuing two years AEP to Schedule Airlines and one
year for G.A. Operators. Two years of AEP validity be extended to GA
operators also.
13. BCAS should issue type of passes according to the requirement and the
designation of the individual as how it is given to schedule Airlines
14. BCAS should amend the NCASTP accordingly so that the security training for
NSOP can be done on need basis. Also BCAS should amend the templates
of Security Programme to meet the GA Requirements
15. MIAL Issues:-MIAL is not issuing vehicle permit even for bare minimum
requirements also charges Rs 2000 for one day permit for cars through gate
No 08 but MIAL charges only rupees Five hundred for other gates, which is
discriminatory.
16. Increase in number of Handlers for GA operators at different Airports:-
We are facing problems from Handlers at different Airports.
Generally, there is only one (may be two at some places) Handler at Airports. This
results in high Handling charges with poor service output. If the numbers of handlers
are increased at the airport, we will have better options to select. This will improve
quality, competitive attitude, customer oriented services and aviation business
growth. Also, Airline Handling does not meet GA requirements and always ends up
in poor Customer satisfaction. Recently our PD's complained poor handling services
at Jaipur, but there are few options available.
Quality services at the airport should be the main criteria for GA Handlers as they
are dealing with elite groups. But this takes a back seat if it is monopolized by one
handler at the airport. Hence, It is suggested that number of handlers for GA may be
increased at Airports.
17. Rationalization of Air Field Minima:-
For all General Aviation operations in India, the DGCA imposes "Restricted Minima"
for approach and landing into Instrument Airfield, which are usually higher than the
normal minima. General Aviation Aircraft today are as sophisticated and well
equipped as Commercial Aircraft, if not more and the pilots are also trained as per
the same standards. As such, it would be very good and convenient if the General
Aviation Aircraft are also allowed to operate on Standard Minima, more so because
we don't carry passengers for hire or remuneration.
More Flexible FDTL regulations for GA Operations: The Flight Time Limit
(FTL) and Flight Duty Time Limit (FDTL) for General Aviation Operators could be
made a little wider and more flexible. Here also it must be appreciated that we're
mostly flying the owners of the aircraft themselves, and not for hire or remuneration.
18. Credit Card Facilities at Airports: All the airports should accept credit/debit
cards for airport charges as presently carrying large amount of cash by G.A.
Operators/Pilots for such payments are inconvenient.
19. Implementation of Flow Control System to avoid prolonged holding at
destination airfield:- There should be coordination between departure and
destination aerodromes. Slot for takeoff be only given when slot for landing is
available at destination airfield. This will avoid prolonged holding and save a large
amount of fuel and machine hours.
POINTS FOR GENERAL AVIATION - HELICOPTERS
1. Licensing.
(a) All licenses be issued as Smartcard with all details in record. Consider
outsourcing like is done for passport.
(b) License validity be for lifetime with the onus of ensuring all checks,
medical etc are done on the incumbent. This would reduce work load on DGCA ,
practice is common in most countries internationally.
2. Rationalisation of Checks.
The number of checks for a pilot be limited to 02 Prof checks per year. This
should encompass route, mountainous terrain, offshore as the case maybe in the
pertinent flying environment of the operator. For pilots flying more than one type of
helicopter there should be one check on each type once a year. At present a pilot
qualified on 3 types of helicopter is required to undertake 6 proficiency checks in a year.
3. Helicopter VFR Routes.
Delineation of VFR routes in Delhi and Mumbai in the form of Kilo routing is an excellent
initiative, we further need to encompass the whole country in a phased manner to
ensure smooth and safe helicopter operations and this would play an important role to
have expeditious and safe flow of helicopter traffic.
3. Helicopter GA Operations from Airfields. The helicopter is an extremely
versatile machine and needs to be exploited to its potential. Operational
management/handling of helicopters in the same envelope as fixed wing aircraft leaves
the helicopter bereft of its advantages. To prohibit helicopter Operations from Mumbai is
a step in the wrong direction and would defeat the objective of seamless travel for
people investing in expensive multiengine IFR helicopters.
The following is proposed:-
(a) Short Term. Helicopters more often than not operate from helipads and
seldom have the luxury of having a runway. However, unlike other countries in the world
we in India insist that helicopters take off and land from Runways whilst operating from
airfields. This philosophy needs to be relooked by an expert team. It is recommended
that helipads be identified at suitable spots which do not interfere with fixed wing traffic
and thus there would be no need to close an airfield for helicopters.
(b) Long Term.
- Helicopter enclaves be developed in major cities within the main airport.
Future airport designs should cater for these areas in their blue prints.
- Existing facilities for helicopters such as Juhu should have better
infrastructure and safety. There should be proper parking and lounge facilities for
passengers. The airfield facilities should be augmented to provide night landing
capability to helicopters
4. Flight Planning and Air Traffic Services.
Submission of flight plans online is at its nascent stage and would be soon
fully operational. Following is proposed in the interim:-
(a) Flight plans should be accepted by FAX as helicopters routinely operate from
remote areas.
(b) Helicopters undertake numerous short hauls in a single day from uncontrolled
airspace and each leg needs a separate flight plan (FIC and ADC. It is understood that
the present system software does not allow multiple legs to be logged in the system, the
software needs to be tweaked to allow such multiple leg plans to be filed and avoid
unnecessary workload for the Pilots/ FIC/MLU.
5. Controlling of Helicopters outside Control Area / Uncontrolled Airspace.
It is routinely observed that ATC controllers especially from small airports ask
helicopters to hold at 25 nm or more from airfields due to fixed wing traffic. This distance
more often than not is way beyond the control zone of the airfields, the airspace beyond
the control zone is uncontrolled airspace and not within the jurisdiction of the ATC, this
point needs to addressed and better training needs to be provided to the controllers to
avoid avoidable delays and holding.
6. Use of Transponders.
Transponders are very useful especially in VFR operations for collision
avoidance. Helicopters fitted with TCAS will be able to keep clear of each other. It is
observed more often than not that ATC controllers are averse to helicopters transmitting
squawk. All helicopters fitted with Transponders should be encouraged to transmit code
2000 at all times when they are operating 10nm or more away from the airfields. This
would ensure that their transmissions do not interfere with the fixed wing TCAS.
7. VFR Criteria Controlled Airspace. Presently, minimum criteria for VFR
flights is 5 Km. Below this minima helicopters operate with SPECIAL VFR clearance
which results in inordinate delays due to coordination of traffic by the ATS. In stations
such as Mumbai the vis is more often than not less than 5km. It is proposed that the
VFR minima be reduced to 2.5kms. ICAO regulations in Doc 4444 have a provision for
the same enabling states to promulgate lower minima should they so desire.
8. IFR. At present the minimum flight level for IFR flights in India is FL70 including
for helicopters. Considering the dynamic instability of helicopters the vibratory loads
increase exponentially at higher altitude, therefore in the interest of safety, lower flight
levels should be permitted for helicopters when route safety altitude permits. ICAO
permit IFR from FL035. It is proposed that IFR flights maybe cleared for helicopters at
the lowest flight level above the established MOCA. Further direct routing may also be
permitted considering the limited endurance of helicopters.
9. Meteorological Information.
(a) Information regarding METAR and airfield forecast be made available on
telephone as a recorded message, this would provide latest information
for helicopter pilots operating from remote areas. This is in force in Delhi but not
installed in other places.
(b) Installation of webcams en-route, on routes that are routinely traversed
and prone to bad weather would facilitate provision of real time low cost weather
info for pilots. This is used very effectively in Europe especially in Switzerland.
(c) Helicopters need low level weather info in perhaps steps of 1000 feet.
Provision of logging in the current AMSS site for weather for Flight Levels below
FL 100 and provide forecasted weather above 1000 ft AGL in increments of 1000
feet upto 10,000 feet needs to be looked into.
10. State Govt and District Administration.
(a) It is proposed that rooftop helipads in cities be given its due importance
and encouraged. This would bolster the governments capabilities duringdisaster
management. Various emergent situations could be better handled if the flexibility
of rooftop helipad is available. Some instances are casualty evacuations, medical
emergencies/evacuations, accident site evacuations from rail/ road highways and
during unforeseen eventualities for use by Police and Armed forces. This would
be line with the social responsibilities of the Government towards its citizen.
(b) District Administration. Helicopters routinely operate from helipads
under control/ clearance from various District Collector Administrations, this
involves dealing with multiple agencies like Director of Aviation of the state, the
District Collector, Police authorities, fire safety services etc. The Governments should
be encouraged to set up Nodal agency at District level which could be a one point
contact for Operating agencies.
The following is proposed:-
(i) Establishing suitable helipads for use within districts at religious sites, spots of
interest to tourist. This would enhance tourism and revenue and also improve the
infrastructure.
(ii) Provision of single window clearance of helicopter operations within the district
which would co-ordinate with police, Fire fighting agency and provide the
minimum wherewithal required to operate helicopters as per CAR.
(iii) Such facilities could be set as a private /Govt partnership, suitable charges could
be levied so that its not a drain of resources for the State Government. Facilities
provided by the Race Course in Mumbai could be taken as an example
11. Helicopter Satellite Tracking.
Fitment of aircraft tracking system system such as Indigo would provide constant
update of the aircraft position. The history of fatal helicopter crashes reveal that locating
the wreckage has been a major challenge and has taken days in most cases.
Installation of tracking device which comes at a fraction of the cost of the helicopter
provides real time tracking and eliminates the SEARCH from SEARCH & RESCUE. The
Indigo Sat trials were very successful and it uses the INMARSAT satellites which are
also used by the Merchant Navy in their SAR system of GMDSS.
12.. Helicopter Operations from Ships/ Yachts
At present there are no guidelines regarding private helicopter operations from Yachts/
Ships. These could be within the territorial waters or from International waters. Further,
any attempt to fly such sorties involves multiple clearances for the operators, namely
from DGCA, MOD, Navy/Airforce. This needs to be streamlined to provide a one
window clearance.
Suggestions from GO Airlines
Rationalize airport charges and efficiently monitor fees charged by the private
airport operators. Rationalize UDF, PSF, landing and parking charges at the
Airport. Rationalize cargo handling charges levied at Common User Terminal
(CUT) in order to facilitate increase in air freight volumes.
Airline operators shall be free to deploy ancillary revenue policy so long as the
operators are making valid disclosure of such charges.
Policy should envisage measures to encourage investments and use of alternative
fuel including Bio fuel.
Allow access to international routes for private carriers without placing
qualification criteria. Indian airlines should be encouraged to benefit from
underutilised access through Air Services Agreements.
Allow airlines in India to undertake ground handling activities on their own.
Handling standards and statutory requirements maybe set by DGCA for
adherence. This shall allow individual carriers to operate at lower costs and
rationalise their manpower needs.
At present, airlines, flight crew, engineers and other personnel have to go to
various ministries for issuance of various operational licenses. New policy should
also consider single window handling of all such subjects.
Private airlines should be allowed to fly the routes of their choice and if mandated
to fly certain routes, should be provided incentives or subsidies.
Investment in infrastructure to allow more efficient and increased use of slot
capacity at key airports. Transparent rules and approaches in slots allocations
and consistent monitoring of slot utilization.
Clarity should be brought in regard to permits to be sought for in principle
approval from Ministry of Civil Aviation prior to purchase/import of aircraft.
Foreign airlines shall be permitted to invest in the aviation sector, this would bring
not only the required financial resources but also expertise from best practices.
The aviation policy shall aim to incentivize the foreign direct investments not only
in the airline operations but also in the development and maintenance of aviation
infrastructure.
5. SUGGESTION FOR HR & TRAINING
Suggestions received from KPMG
1 Aviation Training Infrastructure
The impressive growth in Indian aviation has resulted in a similar growth in employment
opportunities in the sector. However, the supply of available skilled manpower has not been
able to match the growth of traffic or aircraft movement and hence the sector faces shortage of
skilled and trained manpower. These include pilots, engineers, air traffic controllers, cabin crew,
trainers, and security personnel. With passengers and aircraft fleet likely to triple by 2025, the
need to augment the skilled manpower supply is immediate. Some of the key enablers are:
a) Increase the number of pilot training institutes and expand their capacities through
government support, as capital subsidies.
b) Encourage foreign investment in pilot training academies. The success of CAE at Rae Bareli
and Gondia should be replicated at other locations also. Certificates issued by leading flying
academies in the developed world should be made acceptable in India, subject to adequate
checks by DGCA.
c) Collaborate with Indian Air Force (IAF) for training infrastructure. The Indian Air Force (IAF)
has one of the finest pilot training infrastructures in the country. There is a need to
collaborate with them to explore ways in which their facilities and staff can be used for
producing civilian pilots without affecting IAF‘s operational requirements.
d) Give immediate priority to ATCO training and capacity building. Partnership options with
international ATC training institutes should be explored to enhance capacity of CATC. The
enhanced capacity can also help CATC, in the long run, earn additional revenue by training
foreign ATCOs and
e) Consider the option of allowing private players to set up ATCO training facilities, subject to
adequate supervision by AAI. This may be started in a PPP mode first and thereafter be
made fully open to private sector in the long run.
f) Addressing the shortage of aircraft engineers, technicians and cabin crew through opening
more number of institutes offering courses related to aerospace engineering and cabin crew.
Options of collaborating with the Indian Air Force to build capacity should be explored.
Suggestions received from CAPA:
Objective by 2015/16
Development of skills and expertise is essential
The key is to develop the skills and expertise so that the institutions are run professionally by
experts in their field, in a manner that is scalable to support the expected growth in passenger
and cargo traffic, which will be transformational in terms of size, investment, technology and
regulation.
Furthermore global regulation will become increasingly integrated and regulators will need to
develop a greater understanding of international and cross-border issues, the environment and
emissions trading being one of them but others including airline ownership and alliances. This
will require a restructuring of the regulatory framework which will have to cope not only with a
dramatic increase in the size of the industry, but simultaneously handle multiple external
developments. Given the task at hand and the rapid pace of change key functions within the
Ministry and the CAA should have FIXED tenures of 5 years, especially during the restructuring
phase.
Objective Post 2015/16
Education & Training
The ability to bring India in line with the global aviation community will hinge upon the skills and
competency of the workforce. However, education and training has virtually been an
afterthought in Indian aviation. The industry has muddled through by deploying ad hoc
measures to fight fires. This approach must be changed if we are to deliver a professional,
sustainable and safe industry. CAPA estimates that an additional 300,000-350,000 skilled staff
will need to be trained by 2020 to support the projected growth of Indian aviation.
There is a need for a fundamental overhaul of the quality of training in India and it must happen
quickly and in a cost effective manner. But if India succeeds in this mission, it will in the process
create a massive export opportunity. There exists the potential for India to become a low cost,
outsourced aviation education and training centre for the world, provided that international
quality standards can be established.
The government took a positive step in January 2008 when the foreign direct investment cap in
flying schools and training institutes was increased to 100%. However, international training
providers still report frustration with very slow and ambiguous approval processes. The
government must adopt a more pro-active, fast-tracked and encouraging stance with respect to
the establishment of new institutes. Furthermore, although the foreign university bill is beyond
the purview of MOCA, an initiative could be taken to convince the Ministry of HRD that aviation
is a new and specialist discipline of national interest which warrants exemptions for the
participation of foreign universities as there are no established Indian centres of learning in the
subject.
Suggestions received from APAO
AVIATION UNIVERSITY/TRAINING INFRASTRUCTURE
Various forecasts suggest that India will require additional 3 - 3.5 lakhs employees in aviation
sector to meet the demand in the coming years. There is a need to increase capacity of current
training facility. Skill shortage is also more serious in aviation sector. There is also an
opportunity for demand for skilled personnel in Civil Aviation sector across the world. There is
clear absence of qualitative and duly recognised formal educational programs. It is therefore
necessary to establish a National Aviation University to cater to the growing educational and
training requirements of Civil Aviation sector in India. The Civil Aviation Policy should address
the issue of setting up of Civil Aviation University in the country.
Suggestions received Confederation of Indian Industries (CII)
Aviation University / Training Infrastructure : Considering the prevailing shortages of
trained workforce and pilots for the aviation sector, setting up an Aviation University /
Training Infrastructure is a must. However, instead of setting up a world class Aviation
University by itself, Government should explore Public Private Partnership. There is an
immense opportunity to leverage private sector expertise & financial wherewithal to set
up a university for aviation sector in India.
Suggestions received from IATA
Human Resource Development
India‘s aviation growth can be orchestrated into a larger opportunity for the country.
There is a need to build capacities and capabilities in Aviation; and to invest in
training a larger pool of professionals in the public and the private sector.
India‘s external engagement on aviation and related disciplines is expected to
increase substantially over the next 5-years and beyond.
India needs to invest in creating and expanding its pool of civil aviation professionals
who are well versed with critical global aviation issues in the domains of safety,
operations, liberalization, aviation law, economics, climate change, among others.
Investment in capacity building of its civil aviation professionals would go a long way
in building a critical mass of air transport leaders in India and instill relevant aviation
related skill sets. Towards this end, the Civil Aviation Policy must:
o Address the training needs for Indian civil aviation officials
o Address the need for building skill foundation for Indian CAA / DGCA
personnel, training them in the domains of Safety Management, Regulatory
compliance, Airport operations, Air Navigation Systems Management,
Dangerous Goods Regulation, Security Management among others.
Invest in impartation of skill based training and capacity building in aviation and related
disciplines, like cargo, ground handling, tourism etc.
Suggestions received from BLUE DART Aviation Ltd.
FATA for Expat Commanders
The aircraft type operated by domestic freighter operators/express airlines are quite
different from the aircraft type operated by passenger airlines in India, which are mainly
either the B737 NG or A320. Consequently, there is no pool of available commanders for
induction into express airlines. Training is a long drawn process as the flying hours for a
typical air express operator are lower than for a passenger airline. Such restrictions
constrain the augmentation of capacity to meet demand because of the non-availability
of trained commanders to operate freighters. This is a barrier to the Open Skies Policy
for Air Cargo.
FATA for Expat Commanders has been extended by the DGCA till December 2013.
Training will only serve to replace the current expat crew and would not suffice for any
augmentation of capacity. Every prudent airline would prefer to utilise Indian pilots and
would only resort to expat support when they face a crunch because of the higher cost
impact. Further, the more expensive wet lease option permits the utilisation of expat
pilots in the Indian environment.
It is recommended that the Civil Aviation Policy withdraw the restriction on FATA and
provide the flexibility to operators to induct expat pilots when required. Current
regulations already encompass more stringent safety measures for expat crew.
Suggestions from Aero Club of India
HR AND TRAINING:
Aero Club of India (ACI) is concerned with the topic HR and Training contained in
the Ministry of Civil Aviation Note on Civil Aviation Policy – Consultation with
Stake Holders. Since ACI is associated with Promotion & Development of Flying
Training in the country and associated training infrastructure to make available
appropriately trained and skilled personnel – both Pilots and
Engineers/Technicians, the following issues need to be addressed in the Civil
Aviation Policy :
1. Service Tax Levied on Flying Training Institutes and AME Training
Institutes :
The Central Board of Excise and Customs (CBEC), Ministry of Finance
through Commissioner of Service Tax had issued a circular on 20th January
2009 which states “that Institutions created or recognised in terms of
Power conferred by statues fall in the category of institutes which issues
Diploma or Certificate recognise by Law.” The CBEC vide their letter 11th
May 2011 while interpreting the above has termed the Flying training
schools and the AMEs institutes as Coaching Centres. Furthermore, Vide
Notification No.33/2011-ST of CBEC, exemption of Service Tax is available
to any pre school coaching or training and any coaching or training leading
to grant of Certificate, etc. or any educational qualification recognised by
Law. The CBES vide their letter of 11th May,2011 has also interpreted that
the Flying Training Schools and Aircraft Maintenance Engineering Institutes
would not come under the scope of the exemption.
The Flying training institutes and AME training institutes in the country both
from government sector and those registered under the Co-operative
Society Act and also private sector all of whom are DGCA approved are
receiving notices from the authorities for payment of Service tax even from
retrospective date amounting to huge amounts thereby the survivalability
of these institutes are threatened. Many of them have appealed to the
authorities and President-ACI had also written to the Finance Minister on
12-05-2010 which have been turned down. Even DGCA had also clarified to
the Member, Service Tax of CBEC on May 2011 that Flying Training and
AME Institutes are approved by DGCA for undertaking the training
experience for obtaining a Pilot’s and AME license and that the proviso for
such training from such approved organisations are embodied in Schedule II
Section A and Rule 133 B of Aircraft Rules, and that these institutes are
issuing necessary certificates which are recognised by DGCA for issuing
licenses which is a professional qualification recognised by statue.
The Civil Aviation Policy needs to focus on the above issue or otherwise
these institutes which are the only avenues for Pilot and AME training in
the country and presently some of them running at losses will be forced to
close down as the ultimate burden will be to the trainees. This will lead to
flight of capital from India to many other countries, particularly those in
South East Asia including China where such training would be available at
cheaper rates.
2. Airport Lease Charges
Many flying training institutes are operating from aerodromes long before
present Airport Operator (AAI) was formed whence these aerodromes were
handed over to AAI. Incidentally some of the flying training institutes were
the original allottee of land at many of these located aerodromes. Earlier
the flying clubs/institutes imparting flying training at no profit was being
charged Re.1/- p.a as a token licence fee.
Appreciating the cost incurred by AAI as an operator of these aerodromes,
while the lease charges may be increased nominally, the Civil Aviation
Policy should address this issue that while permitting a nominal increase in
the Licence Fee, this should not be at a prohibitive higher rate from
commercial point of view.
3. Introduction of Light Sports Aircraft for Pilot Training :
World over there is serious thinking of making flying training a more
economical business and many aircraft manufacturers producing Light
Trainer Aircraft have brought into the production next generation Light
Aircraft which would be nearly 50% less of the operational cost of the
earlier types and with AFTN fuel and /or automotive fuel for the engines
would remove difficulty of acquiring AVGAS.(LIMITED AVAILABILITY AND
HIGH COST)
There had been discussions at ICAO 37th Session of the Assembly, wherein
it was brought out that full recognition of training , flight and maintenance
time on these aircraft would be more economical for new Pilots and
Technicians to progress towards Commercial Aviation Licenses. USA has
brought out in 2005 such aircraft termed as LSA followed by European
Union in their ELA. These Light aircraft are two seater with maximum take
off mass not more than 600 kgs. and speeds below 120 knots. The cockpit
equipment and egronomics of these aeroplanes are available with modern
technology and design and are also capable of night flying. The FAA has
introduced Special Certificate of Airworthiness with their State (N)
Registration to these type aircraft and so also by EASA. Several hundreds of
such aeroplanes have been built in more than 60 countries including those
from Cessna and Piper. These type of aeroplanes are being used for flying
training in USA and European countries.
In India to tide over the prohibitive cost of Pilot training such type
aeroplane LSA and ELA needs to be introduced in Pilot training particularly
in the initial hours of ab-initio flying training.
The Civil Aviation Policy needs to include the concept of introduction of
such Light Aircraft to impart ab-initio flying training for promotion of flying
training in the country and for training of Technicians because of its low
investment cost as well as low operating cost. Necessary requirements
need to be developed in line with other countries, including ICAO, for
setting up standards with regard to its effectivity for issue of Commercial
Aviation Licences.
4. Shortage of CFIs in the Country
The shortage of CFIs in the flying training institutes had been felt from long
as earlier trainees on completion of flying requirements required for issue
of licence and on obtaining the licences would venture for greener pastures
in the Airline. Also a monopolistic attitude was adopted by the existing CFIs
not to encourage/motivate trainees to take up careers in flight instructions.
Now that the intake in the Airline and General Aviation sector cannot
consume the large number of CPL, flying training institutes need to
encourage the trainees to take up AFI and FI qualifications. The salary of
AFIs/FIs and also CFIs today are quite compatible with that of a fresh entry
pilot in the Airline.
The Civil Aviation Policy may include making mandatory the requirement of
AFI/FI for Airline entry like Multi Engine rating. The requirement for
eligibility for ATPL can also include AFI/FI ratings. This would enable a more
mature and knowledgeable professional for Airline/General Aviation flying,
besides larger number of candidates available for up-gradation to CFI.
5. Use of Simulators in Flying Training
At present the Regulator permits only 20 hours on the Simulators (FNPT)
for Instrument Rating (IR) which is being considered within the requirement
of 200 hours for issue of CPL. Incidentally in Regulators (EASA) in some of
the advanced countries are adopting 40 hours on FNPT-II and 20 hours on
FNPT-I as part of the Flying Credit Requirement (FCR) for Commercial Pilot
Licence (CPL).
Modern day aircraft flying requires a high degree of proficiency in
Instrument Flying which is much more affordable in cost on an appropriate
rated Simulator than on an actual aircraft. Moreover these Simulators
having Audio, Actual Visual Motion Capabilities as that of a real type
aircraft in flight, provides the trainee the necessary skills for mastering the
art of Instrument Flying which is restricted in actual training flights for an
ab-initio trainee. Furthermore to develop the confidence of a trainee in
handling various emergency in flight situations, like, engine failure, control
failure, bad weather, radio & navigation failure etc. which can be simulated
in such Simulators enables the trainee to acquire not only skill but
confidence to handle such flying emergencies more proficiently. These
simulators also have Recording Systems of the Flight profile for reference
purposes to determine the degree of competency of the trainee.
The Civil Aviation Policy may include encouragement in the use of
appropriate level Simulators for flying training to supplement the training
on actual aircraft to enhance the degree of competency of a flying trainee.
Suggestions from NIFTI, GONDIA
The following suggestions from NFTI, Gondia may be given due consideration for
inclusion in the comprehensive Civil Aviation Policy.
1. Fuel used for training flying be treated as a consumable & be exempted from
Service tax. Training could be considered as a service provided with some
minimal service tax.
2. All benefits extended to Educational & Professional training organizations like
IIT/IIM be also extended to Flying Training Organizations that are involved in
Nation Building with skilled professionals. Such FTOs can be identified through
DGCA audits for Quality & Safety & Ministry of Finance for financial stability.
3. Sales tax flat rate @4% could be charged on fuel supplied by IOC to training
organizations.
4. IT Industry to join hands with Flying Training Organizations that have the
potential & infrastructure to become DGCA Online Examination Centers. Since
the exams are part of regulatory requirements all funding of
Hardware/Software/Networking etc should be borne by IT Industry. The FTO
can provide space & other infrastructure at actual costs [Govt. Rental ]
5. Current day simulators are excellent tools for training. More usage of
simulators needs to be encouraged and recognized as such. Customs duty
imposed on Simulators may be reconsidered. Also DGCA should consider giving
credit for SIM time towards licensing issue & renewals in line with FAA & EASA.
6. All training flights up to CPL level could be exempt from Landing/Parking/RNP
charges. Parking fees be charged only if Night halts are involved.
7. AAI should permit off site operations of limited number of ac for limited
periods from airports that support commercial operations to enable realistic
training of trainee pilots.
8. In the absence of MET Offices at airports that support training flying with a
specified turnover; the Communications/IT Industry should provide links at no
cost to nearest MET centers.
9. Education Ministry to approve Flying Training Organizations that have
adequate infrastructure & faculty for BSc. Aviation on completion of CPL
course.
10. All imports from aircraft OEMs & through Govt. approved agents could be
exempted from import duty as essential for professional training.
11. Trainees who take bank loans to meet flying training costs be given tax relief
once repayment is started.
12. Loans taken from Nationalized Banks for flying training be charged minimal or
no interest or every suitable FTO be granted limited number of financial aid
packages at nil interest rates to support deserving candidates to meet training
costs.
Suggestions from IGRUA
A)TAXATION POLICY : FLYING TRAINING
B)PILOT TRAINING : CIVIL AVIATION
C)ENHANCEMENT OF KNOWLEDGE LEVEL
A)TAXATION POLICY
1. Service Tax : Service Tax has not been levied on any educational or vocational
institute that is regulated by a professional body and awards recognized
degrees/diplomas etc. All medical / engineering and other such vocations thus do not
fall under the purview of service tax.
Flying clubs/institutes also provide professional training, award licence and
regulated by DGCA. Unfortunately, this process is not institutionalized legally. DGCA is
an attached office to MOCA. Licence it awards is not recognized like a MBBS or BE and
flying clubs are considered coaching centres. The flying clubs are doing exactly what
medical and engineering colleges do, that is, prepare school leaving students to enter a
profession.
The recent Finance Bill 2010 has proposed in Section 75(A)(5)(b) to amend the
definition of ―commercial training or coaching centre‖ to include any centre/institute,
whether commercial or not, by whatever name called, with/without profit motive. The
service tax authorities have imposed service tax on Flying Clubs/Institutes and Aircraft
Maintenance Engineering colleges effective from 1st April, 2005 treating these institutes
as ―Commercial Training Centre‖. Ministry of Finance has also issued a Notification
No.03/2010 ST dated 27.02.2010 whereby the expression ―vocational training institute‖
has been restricted to industrial training institutes and centres affiliated to the National
Council for Vocational Training offering courses in designated trades as notified under
the Apprentices Act, 1961 and the said amendment has been brought into force
retrospectively w. e. f. 01.07.2003.
Flying Clubs / Institutes are not a Commercial Coaching Centre. They are flying
training Institutes and are regulated by the Aviation Regulator (DGCA) and are fulfilling
the nation‘s need to provide vocational training for obtainment of pilot‘s training. Flying
Clubs / Institutes are non-profit making Organization which runs on grants-in-aid
received from the Government. The main reason for this is that levying full charge
would make it possible only for the rich students to go for this career to the exclusion of
many promising and talented young students having parents from the middle income
and salaried group.
Flying Clubs / Institutes are regulated by DGCA and DGCA performs a function
similar to UGC, AICTE, DCI & NCI etc. As per the prevailing law, Flying Training
Institutes / Aircraft Maintenance Engineering Colleges comes under the purview of
Service Tax and liable to pay service tax. This law needs to be changed. Otherwise
aviation training will become too expensive and will lead to massive manpower
shortage.
2. Sales Tax : As is well know growth in aviation sector is an extremely important
element of our national endeavor to achieve its rightful place in the world. To make
strides in the aviation sector, it is imperative to promote aviation training. Aviation
training is an extremely expensive proposition. A large chunk of expenditure incurred in
aviation training is the cost of fuel. Almost all the basic training aircraft use AV Gas as
fuel. Each state levies its own rate of sales tax. The minimum rate is levied by
Maharashtra which is at 10%. Majority of states including Uttar Pradesh have a sales
tax regime around 20%. Some southern states and Madhya Pradesh levy much higher
rates at 28% to 29%. While Bihar, Orissa and Jharkhand levy only 12.5%, Gujarat
levies 13% and Rajasthan 14%.
Rising fuel price is a major source of concern threatening to adversely affect the
viability of flying training institutes in the country. Pricing regime and the taxation
regime governing aviation fuel in the country are distortionary and thus they need to be
reviewed urgently by providing a positive fiscal environment. The total tax collected
annually in the country on AV Gas by all the states amounted to meager Rs. Seven
crores only. To survive the aviation training institutes and promote the aviation training,
the sales tax on AV Gas should be abolished or a reduction to 4% is necessary.
3. Custom Duty on Simulators/Training Equipments : There is a shift in global
air traffic in favour of Asia Pacific region and India besides China would be the major
gainers of this shift giving economic growth in the country. The forecasts of air traffic
suggest that passenger traffic by the end of the decade would be about four times the
existing traffic.
Aviation is a sunrise industry in Asia Pacific region. The infrastructure at the
flying training institutes is in-adequate to meet the growth and requires up-gradation.
The flying training institutes are required to up-grade the infrastructure by importing
technologically latest simulators, training aircraft and other related equipments to impart
flying training at par with European countries. The aircraft and spare parts are
exempted from custom duty for all training institutes. Any move to introduce custom
duty on simulators and other training equipments will definitely hamper the functioning
the flying training institutes. It is imperative that this sunrise industry be supported by
providing it incentives like tax holidays so that the impetus provided to the economy by
this industry fulfills its promise.
B)PILOT TRAINING : CIVIL AVIATION
1. Pilot Entry in Airline Vs Experience Levels : In the developed world mere
Commercial Pilot Licence (experience 200 hrs) does not get you into airlines. You
need around 1500 hours experience before any airline takes you in. This experience is
obtained on General Aviation aircraft. The low numbers of General Aviation aircraft in
India does not allow the CPL holders to get this experience. Thus airlines in India have
little choice but to pick pilots with very low experience.
2. Infrastructure at Flying Clubs and Quality Control : Flying Clubs have very
minimal infrastructure. Most have 2-3 aircraft, 10-15 students, very less instructional
staff and are mostly located at uncontrolled airfields. They lack ground school,
simulators, nav & landing aids, proper dedicated airspace needed for training, etc. The
experience of 200 hours obtained in these clubs is of poor quality. A lot of CPL holders
are trained abroad. Scrutiny by DGCA has shown that very often even these are of
dubious standards specially those that are located in the neighbouring countries.
Shortage of staff at DGCA and large number of flying clubs (42) combine to make the
task of monitoring and ensuring quality an impossible task. Thus our airlines are forced
to recruit pilots who have only 200 hours of flying experience and that too from flying
clubs which do not provide quality training. Consequently aviation safety suffers.
3.Infrastructure needed for Good Quality Training for CPL : It is with such insight
that Shri Rajiv Gandhi set up Indira Gandhi Rashtriya Uran Akademi. It has all the
facilities needed for good quality flying training. It has good quality aircraft, associated
simulators, ATC, dedicated airspace, landing and navigational aids (ILS, VOR, DME)
night flying facilities, good maintenance infrastructure, a very good ground school, good
instructors (both air and ground) and good engineering staff. It has good hostels and
good sports facilities. IGRUA provides an all round development of a trainee pilot. It is
the IGRUA model of flying training institute that can improve quality in aviation training.
4. Scaling up Vs Quality of Flying Training : If proper quality of flying training is to
be given then large infrastructure is essential (as evident at IGRUA). The IGRUA
product is keenly awaited and absorbed by the industry and appreciated by all airline
pilots. Therefore, for a country of our size and a growing aviation industry what is
needed are four to five IGRUAs situated zonally. IGRUA is in the North and Central
India has NFTI at Gondia with similar attributes like IGRUA. One each is needed for
Western, Eastern and Southern regions. Each should produce around 100 pilots a
year. Many suitable AAI airfields are available that have low traffic and the necessary
aids, airspace and infrastructure to host such institutes. Gaya in East, Udaipur in West,
Madurai, Mysore, Vijayawada, Trivandrum, etc in South can accommodate such
institutes.
5. Financial Viability and Mergers and Acquisition : Such large infrastructure for
mere 2-3 aircraft that flying clubs have makes flying training financially unviable. Only
scaling up to have 8 aircraft or more with this large infrastructure has hopes of financial
stability. However, persisting with current model produces poor quality output that may
result in affecting the safety of our airlines. Therefore, it is suggested that region-wise
flying clubs be encouraged to merge to form big entities. Mergers and acquisitions
amongst the 42 existing flying clubs should produce 5-6 big IGRUA like institutes. The
balance flying clubs should be permitted to provide training upto PPL level only. This
can happen when DGCA amends its regulations concerning setting up of Flying
Training Institutes and demand much larger assets and infrastructure for CPL training.
6.Recommendation:
1) The current model of small scale flying clubs providing CPL training is the
basic cause of poor quality. DGCA should revise its orders which spell out
minimum facilities needed for training. For CPL training 8 aircraft, associated
FNPT simulators, dedicated airspace, nav and landing aids, night flying
facilities, a dedicated ground school and associated qualified personnel must
be termed as minimum essential requirement. Any flying school with lesser
assets be permitted flying training upto PPL level only.
2) The existing flying clubs be encouraged to follow the merger and acquisitions
route to combine resources and result in forming 4-5 big flying institutes spread
zonally across the country.
7. CPL syllabus Vs specialized Training for Airlines (MPL) : ICAO syllabus for
CPL has been adopted by India. Initially 250 hours of flying training was needed for
CPL. Later, ICAO reduced it to 200 hours. India too followed this without
understanding that ICAO changes its CPL syllabus based on the requirements of its
General Aviation segment which invariably is five to ten times larger than its airlines
segment. Today ICAO syllabus for CPL is already reduced to 160 hours. In most
countries abroad, mere CPL does not get you into an airline cockpit. A pilot needs to
have almost ten times the CPL experience (1500 hours) to be admitted in the co-pilot
seat. Even after such experience each airline has its own training plans and training
modules to changeover the General Aviation pilot to its airline culture and milieu. We
instead put our CPL straight into an airliner. Thus our current model is inherently
flawed. A sound solution exists. Today many regulators abroad have accepted the
Multi Crew Pilot License (MPL) scheme. In MPL the pilot is trained from ab-initio stage
specifically for airline flying. Initially the pilot is taught basic flying in an aircraft and then
trained in different types of simulators till he is flying the advanced full motion
simulators. His simulator training periods have bursts of flying spaced in between. The
MPL syllabi is more focussed on multi crew training under supervision. There is very
less solo flying. Foundation of airline piloting is laid in him from the word go and the
complete programme revolves around two pilots together in the cockpit in an airline
environment. Such a system has been accepted and recognized by many regulators
the world over. Canada, Germany, France, England, Holland, Malaysia are some of the
prominent countries wherein their regulators have accepted this programme. Malaysia
in our neighbour hood faces a similar dilemma like ours where they too have very small
component of General Aviation. They have found this route to be the best and their
regulator encourages the airlines to adopt this route. Air Asia is a leading airline which
primarily recruits MPL holders. Another good aspect of the MPL programme is that
each airline choosing MPL does its own selection of aspirants and then sponsors their
MPL training and thus their employment with the airline is guaranteed at the end of the
programme. This methodology will infuse more quality and safety in the Indian Civil
Aviation Environment. Therefore, all that is needed is for DGCA to grant recognition to
this programme and encourage the airlines to accept it. Both CPL and MPL can run
concurrently.
8 .Recommendation :
1) DGCA grant recognition to MPL programme and encourage Airlines to accept it.
C) ENHANCEMENT OF KNOWLEDGE LEVEL
1. Aviation University :Today air transportation has already begun to be seen as
the bridge between the rich and the poor. Very soon, as economies of scales surface
and consolidation happen, air transport will appear, in India too, just another mode of
transport. As this process is unfolding, it is already throwing up challenges galore.
The biggest challenge is of skilled manpower. All relevant studies in aviation indicate
more than doubling of the number of aircraft in all categories by 2020. Given the
exponential growth of air traffic services in the country and the likelihood of this trend
in the next two decades, the need to address issues relating to allied services like
Aviation Education and Training in India is significant. It has been estimated that the
requirement of skilled personnel for various categories of skill sets required in the Civil
Aviation Sector would be enormous and several times the current level of deployment
of skilled personnel. That means the pressure on the education and training capacity
is immense. The existing infrastructure is insufficient to meet even today‘s
requirements. It is also seen that there is a near absence of qualitative and duly
recognized formal Educational programmes; leading to award of Diploma/Degree/Post
Graduate Degree in the field of Civil Aviation in the country. As a result of this, all
major as well as minor agencies/organisations in the sector have to mostly recruit
generalist and invest considerable resources in post recruitment training. The focus of
the available training institutes so far has been in conducting the programmes to meet
the immediate need of the industry.
Therefore, it becomes obvious that setting up of a National Air University is of
paramount importance. It has also been identified as one of the objectives to be
accomplished during the current Centenary Celebrations of Civil Aviation In India.
Indira Gandhi Rashtriya Uran Akademi, already a known provider of quality output in
pilot training with an established skill set in aviation skills has already been selected to
be the nucleus of an Air University. Rs. 100 Crores as a token start have been
earmarked for it in the Twelfth Five Year Plan. The process of setting up the university
needs to be hastened.
6. SUGGESTION FOR PASSENGER/ USER RELATED
Suggestions received from APAO
OMBUDSMAN
1. Merely setting up of world class infrastructure alone will not ensure availability of world
class service to the consumers. Appropriate regulatory framework to protect the interest of
consumers at large is one of the crucial areas.
2. The proposed Civil Aviation Policy should address the feasibility of setting up of an
Ombudsman for Civil Aviation Sector.
Suggestions received Confederation of Indian Industries (CII)
Ombudsman : If one of the responsibilities of the regulator is to protect the consumers
interest, there is no need to have a separate ombudsman for the same purpose.
Suggestions from Inclusive Planet Centre for Disability Law and
Policy
The Requirements of Persons With Disabilities
At the outset we thank you for extending the deadline for submission of these inputs to February 27,
2012. We, the disabled people‟s organizations and organizations representing and/or working with
persons with disabilities named at the end of this Memorandum, would like to bring to your attention our
comments and input with respect to the formulation of a new Civil Aviation Policy for the country, from
the perspective of persons with disabilities who account for nearly ten percent of the Indian population.
We believe that the time is right for formulating a new Civil Aviation Policy which includes specific
emphasis on passengers with disabilities. Recent incidents such as the one relating to Jeeja Ghosh where
she was forced to deplane from a Spice Jet aircraft and Anjlee Agarwal who was asked by the Jet Connect
flight supervisor to be bodily lifted by four male loaders, highlight that even though air travel has become
ubiquitous, persons with disabilities continue to face most of the barriers that we faced 10 years ago.
While some positive steps such as the introduction of Civil Aviation Requirements on Carriage by Air of
Persons with Disability and/or Persons with Reduced Mobilityi (“CAR PWD”) were taken, the
experience on the ground remains at an unacceptably low level. We believe that a strong disabilities
section in the Civil Aviation Policy will be the starting point to remedying the issues faced by persons
with disabilities. After India‟s ratification of the United Nations Convention on the Rights of Persons with
Disabilities in 2007, India is now obliged to take the necessary steps to ensure that air travel is accessible
by persons with disabilities on an equal basis with others. We give below our comments and input to
assist in formulation of an inclusive disability policy on air travel by persons with disabilities to be
included in the Civil Aviation Policy (“Disability Policy”).
1. Beneficiaries of the Disability Policy
The Disability Policy must cover all persons with disabilities. Point 3.1 of the CAR PWD defines
a “disabled person” as any person whose mobility when using transport is reduced due to physical
disability, intellectual disability or impairment, or any other cause of disability, or age. It must be
recognized that not all persons with disabilities who require assistance in relation to air travel are
persons with mobility impairment. Some such examples are people who are hearing impaired,
people who have low vision, people with autism, etc., who have no mobility impairment but still
require assistance. The Disability Policy must therefore cover all persons with disabilities and not
only those who have mobility impairments. The Disability Policy must also recognize that
persons with different types of disabilities often require different types of assistance.
2. Underlying Principles of the Disability Policy
The Disability Policy must be based on the following principles:
Equality and non-discrimination, not only between persons without disabilities and persons
with disabilities, but also between persons with different disabilities;
Accessibility, not only at the airport and allied facilities, but also with respect to services
including but not limited to the ticket reservation system, whether online, at kiosks or offline;
and
Individual autonomy and independence of persons with disabilities, including the freedom to
make their own choices.
3. Steps required to be taken to accommodate passengers with disabilities
The Disability Policy must recognize that the steps required to be taken to accommodate
passengers with disabilities must be on par with internationally recognized best practices in this
area. The CAR PWD, which is loosely modeled on the European Union‟s 2006 regulations
concerning the rights of disabled persons and persons with reduced mobility when travelling by
air, is intended to serve this purpose. However, our analysis of the CAR PWD finds that the CAR
PWD is wholly inadequate in many respects and must be entirely revised. The Disability Policy
must recognize this. We must point our here that the European Union regulations mentioned
above were drafted in 2006 before the United Nations Convention on the Rights of Persons with
Disabilities was drawn up and it is our firm belief that those regulations are outdated. While the
CAR PWD may have some utility as a “vision document” we observe that it is not detailed
enough, which therefore leads to ambiguity in interpretation particularly by ground staff, pilots
and others. Some of the specific issues highlighted by persons with disabilities are provided in
Annexure 1. There are many other issues that the CAR PWD does not envisage while there are
several other issues covered in the CAR PWD which are substantially ambiguous thereby leaving
room for misinterpretation to the detriment of disabled passengers. We recommend that the CAR
PWD is revised, in consultation with all stakeholders including persons with disabilities. Some
subsequent regulations such as the US Department of Transportation‟s Title 14 CFR Part 382
“Nondiscrimination On the Basis of Disability in Air Travel”ii must be studied and suitable
clauses from there must be modified for the Indian scenario. We would like to highlight here that
the CAR extends to state owned airlines and private airlines and the revised CAR should also
have the same coverage.
4. Emphasis on Training and Sensitization
The Disability Policy must stress on the importance of proper training and sensitization of all
relevant personnel, including pilots, ground staff and airport employees including check-in and
security staff with respect to the nature of various disabilities and the accessibility issues face by
persons with different types of disabilities. This is critical to ensure barrier free, safe and
dignified air travel for persons with disabilities. While the CAR PWD does provide for some
form of sensitization programs to be run by airlines, the CAR is silent about the exact nature of
sensitization programs to be run by airlines thereby leaving the scope of the training to the
discretion of individual airlines. As is evident from Jeeja‟s experience the training given, if any, is
sorely inadequate. It is critical that standardized training programs must be prescribed by the
DGCA for all airlines. These training programs must be prepared by the DGCA in consultation
with a body recognized by the Government such as the Rehabilitation Council of India.
5. Putting in place an effective grievance redressal and enforcement mechanism
Another important aspect to be prescribed by the Disability Policy is an effective grievance
redressal and enforcement mechanism under which a swift and speedy remedy is available to
persons with disabilities in the event their rights are violated. Moreover, sufficient penalties must
be prescribed on airlines and airports for each instance of violation and passengers must be
adequately compensated. While vide Notification G.S.R.686(E) dated 17th September 2009,
Ministry of Civil Aviation, non-compliance with directions issued under Rule 133A of the
Aircraft Rules, 1937 is a Category III offence punishable with imprisonment for a term not
exceeding six months or fine not exceeding Rs.2 lakhs or with both, this provision is not being
enforced effectively as a result of which airlines are not deterred from preventing violations of the
CAR. The complaints mechanism must be easily accessible for persons with disabilities and all
airports must have an assistance booth which provides live assistance, sign language interpreters
etc. to help passengers file complaints. This will ensure that airlines and airports comply with
applicable guidelines. The CAR is wholly inadequate in this respect also.
6. Importance of timelines for implementation
It is important that the Disability Policy prescribes concrete timelines for achievement of the
objectives of the Policy. We proposed that by the end of 2012:
The CAR is revised in consultation with persons with disabilities;
all necessary steps are taken to ensure that air travel is completely barrier free;
a simple, effective and quick complaints mechanism should be in place; and
the system of imposing penalties on erring parties and payment of compensation to
passengers should be in place.
Conclusion
We believe that the lack of strong policy guidelines in the Civil Aviation Policy is the single biggest
cause for the shoddy treatment of disabled passengers and the lack of effective accommodation in relation
to air travel. Any guidelines such as the CAR must flow from the disability policy and if the disability
policy is comprehensive, it is only natural that the downstream guidelines will be effective. We urge you
consider the concerns of persons with disabilities when formulating the new Civil Aviation Policy. We
place on record our willingness to assist in formulation of a disability policy as part of the new Civil
Aviation Policy.
Annexure 1
Specific Issues and Suggestions to Improve the CAR PWD
Below are suggestions for some specific provisions that should be made a part of the CAR PWD. This is
not a comprehensive list but is based solely on the personal experience of some of the contributors to this
note and is intended as an illustrative list of issues for inclusion in the CAR PWD.
1. The CAR PWD must focus on, and provide for assistance to all persons with disabilities and not
only persons with mobility issues. In addition to persons with mobility issues, the CAR PWD
must provide for assistance to hearing impaired passengers; passengers with low vision, blind
passengers, passengers with developmental disabilities such as autism, intellectual
disabilities/mental retardation etc. as well. The CAR PWD should therefore address not just
„mobility‟ issues but also recognise and provide for specific accommodation appropriate for
different kinds of disability.
2. The CAR PWD and the Aircraft Rules, 1937 should be so amended to as to remove
discrimination particularly against those suffering from mental disorders and epilepsy.
3. The CAR PWD must provide for the provision of curb side assistance for people who cannot
walk all the way to the entrance of the terminal.
4. The CAR PWD must provide for non-negotiable accessibility standards in the airport
infrastructure, facilities and services.
5. The CAR PWD must mandate that the websites of all airlines and all ticketing websites must
comply with the Web Content Accessibility Guidelines 2.0 and the web accessibility guidelines
of the NIC in the case of state controlled airlines, as a result of which persons with disabilities
using screen readers and other assistive technologies are able to purchase tickets online.
6. The CAR PWD must mandate the steps to be taken by airlines to make in-flight entertainment
accessible to persons with visual impairment and persons with hearing impairment.
7. A clear escort policy should be laid down.
8. All airports must have a procedure laid out on the use of ambulifts and staff deputed to assist
PWDs should be trained to handle ambulifts.
9. Minimum standards should be prescribed for equipment made available at airports for PWDs as
wheelchairs, aisle chairs etc. that are made available are of very poor quality and inappropriate in
many cases. For instance, while accessible toilets are made available, the wheelchairs PWDs are
made to use at airports cannot access these toilets, thereby making the efforts at accessibility an
eye wash,
10. The CAR PWD should include provisions to allow PWDs to carry their own assistive devices on
board within the cabin. These devices are highly customized. For instance, it could be electric
wheelchairs for persons with mobility issues, augmentative communication devices for persons
with communication disorders etc.
11. The CAR PWD should recognize the rights of PWDs to receive the same relief and insurance
coverage as other persons who are flying. Currently, to allow PWDs to fly, airlines randomly
force PWDs to sign indemnity bonds waiving their all rights including right to insurance. This
practice should be prohibited and clear norms should be laid down for circumstances in which
airlines can demand such bonds from PWDs.
12. The CAR PWD should lay down protocols to be followed by security personal vis-à-vis PWDs
and these protocols should respect the right of PWDs to be treated with dignity. The security
personnel should be sensitized as to the differing needs of PWDs should be emphasized. For
instance, some PWDs have braces which are sometimes worn under their clothes. In airports that
do not have facility for a full body scanner, PWDs are made to undress as part of the security
check. Protocols should be prescribed for ensuring security without humiliating PWDs.
13. Facilities for air travel – for booking tickets, at the airports and in-flight - should be made
available accessible to PWDs. For example, the online booking systems should be accessible to
the visually disabled. Airport facilities should be made accessible. Boarding announcements must
not be made only through audio announcements but should be displayed at the counter and on
displays for the benefit of people with hearing loss. Functional aisle chairs and wheel chairs (in
proper condition) should be made available. Seat numbers must be large in size for the benefit of
people with low vision and elderly. On-board safety instructions cards should be made available
in alternate formats including large print and Braille. In-flight entertainment systems must be
accessible to PWDs.
14. Airlines/airports should be required to ensure that some of its staff members are familiar with
sign language and communicating with people who have any kind of communication difficulties
and atleast one such staff member should be available at hand in every shift. Alternatively,
provision could be made for using video interpretation facility so that an interpreter from another
location can be called remotely in as and when required.
15. Persons with psychosocial and intellectual disabilities suffer sensory attacks, bewilderment,
confusion and loss of reality (of space and time) as a result of use of textured surfaces and glass /
reflective surfaces in airports; the long tunneling passageways without any kind of signage or
direction etc. Therefore, signage in passageways, use of dull non-reflective surfaces and personal
assistance at airports should be mandated under CAR PWD.
16. The CAR PWD should have an effective grievance redressal and enforcement mechanism that is
readily accessible to PWDs. Airlines and airports should make information readily available on
whom and how to report a complaint of violation of CAR PWD. The duty officer at each airport
could be made responsible to enforce the CAR PWD and the airlines could be required to have a
facilitation desk at each airport where the telephone number of the DGCA duty officers are
prominently displayed. A help line that a PWD can call immediately and seek redressal should be
established. A legal officer who knows the regulations should be appointed in every airport or
should be available through the help line. A mechanism for web based complaints and online
redressal should be established. The redressal system should be connected to civil aviation
ministry and ministry of law. The Ministry should track and report on complaints against airlines
for violation of the CAR PWD and corrective action taken etc. Airlines must be penalized for
violations, they should be required to compensate PWDs who suffer discrimination in violation of
CAR PWD and they should be required to issue written apologies to the concerned persons. The
CAR PWD should place special emphasis on training and sensitization of staff. Airlines should
be required to undertake periodical training of staff handling issues of persons with disabilities.
Instead of leaving assistance to PWDs to be left to persons handling luggage, staff who are
deputed to assist PWDs should be staff who are specifically trained for this. Airlines must be
mandated to provide the details of the training they have provided on a yearly basis to the DGCA.
The DGCA must conduct routine checks to ensure that proper training is imparted. Where lifting
of wheelchair becomes as a last resort, only trained staff should be allowed to handle the
passenger and airlines should be required to engage and make such staff available. With the
increase in number of flights, staff being in hurry leaves person in wheelchair stranded and
unattended. Staff are forcing persons with disabilities to use airport wheelchairs, which are rarely
in good condition. Most of the staff do not know where the accessible bathroom is, where to
report for the grievances etc. All of these and other aspects should be addressed as part of the
training process.
17. Access audit and reviews and attitude audits of airlines and airports should be periodically
undertaken by experts in the disability sector and the reports should be made available to the
public.
7. SUGGESTION FOR SAFETY, SECURITY & SOVEREIGN POWERS
Suggestions received from KPMG
1 Airspace Management and Flexible Use of Airspace (FUA)
The civil and military are the prime users of the national airspace which is a finite asset and
under the existing system the airspace is used by both in isolation from each other. However,
with increased demand from both military and civil aviation sector of the available airspace
needs to be effectively optimized to enhance the airspace capacity and to facilitate the demands
of both the sectors. Some of the key enablers to achieve this vision are:
a) Introduce Flexible Use of Airspace (FUA) in the country‘s airspace. There is a need to
segregate different types of traffic by airspace organization through setting the size,
shape and time regulation of that airspace to minimize the impact on operations.
Airspace sector boundaries should be adjusted to cater traffic flows and should not be
constrained by sector boundaries.
b) Set up efficient airspace management processes to accommodate dynamic flight
trajectories and provide optimum system solutions. Airspace use will be coordinated and
monitored in order to accommodate the conflicting legitimate requireme can be planned
in advance with changes made dynamically whenever possible. The system can also
accommodate unplanned requirements.
2 Air Traffic Flow Management (ATFM)
With the present and forecast growth at Indian airports and airspace, ATFM system is
necessary to optimize the capacity vs. demand both strategically and dynamically by integrating
various operational constraints and weather parameters. Some of the key enablers are:
a) Collaborative decision making (CDM): Mitigating measures and alternate actions to
avoid congestion and delay both in terminal and en-route airspace and airports can be
achieved through collaborative decision making process involving all stakeholders.
b) Implement Centralized ATFM system: AAI has accordingly decided to implement Central
ATFM system for India which will integrate various subsystems for collaborative decision
making and to ensure regulated flow of traffic to minimize delays and congestion. ATFM
system being new and complex for Indian environment, the system development is
being undertaken through technical support from FAA, USA.
Suggestions received from CAPA:
Objective by 2015/16
MOCA should be restructured to allow it to lead, develop, implement and
manage new thinking
Relieved of its regulatory responsibilities, MOCA‘s focus should remain on macro-issues,
namely long-term planning towards achieving a stated vision for how aviation can
provide connectivity, choice and support national economic development. During Stage
1, the CAA will need to focus on building competencies so that it can manage the
significant internal and external challenges that it will face. In due course, post 2015/16
when its expertise is sufficiently developed, the CAA will become the adviser to the
government on aviation issues.
An interim council of full-time aviation experts should be appointed to support
Joint Secretaries
CAPA proposes that during this period an interim council of aviation experts should be
appointed to support the Joint Secretaries with policy formulation and execution. This is
not an Advisory Committee; these Council members would be engaged on full time 3
year contracts on regular commercial terms and empowered appropriately. These steps
are necessary to enhance MOCA‘s capabilities prior to embarking upon any major
changes.
The other vital task for the government is to clarify the future role of the public sector
entities, namely Air India and the Airports Authority of India. With strong private sector
interest in the aviation sector there is no reason for the government to continue to
operate an airline and airports, particularly when they are a huge drain on government
funds. Furthermore, government participation in the industry has influenced policy in a
manner that has been negative for the entire sector. In the case of Air India an untenable
situation has arisen where public funds are being used to support predatory pricing that
is contributing to financial weakness at private carriers.
Air navigation services should be established as a separate entity from the AAI,
remaining as a government responsibility but managed independently along
commercial principles;
The Bureau of Civil Aviation Security must be recast with a new focus on
upgrading management, technology, training and intelligence, conforming to
international standards.
A new legal framework should be established to replace the archaic Aircraft Acts
which date from the 1930s and are increasingly unsuited to a modern aviation
operation.
Suggestions received from Airports Authority of India (AAI)
ANS infrastructure at small and remote airports
It is true that there is considerable buoyancy in air services which requires
matching creation of Airport/ANS infrastructure of global standards. But creation of world
class infrastructure or facilitation standards on part with other major airports at these
small airports will be a huge dent on the monetary position of the investors. Hence a
mechanism should be devised in the new Aviation Policy to re-define the standards
consistent with the expected returns on these small and remote airports. A simple rule
of thumb would suggest that the standards on airports/ANS infrastructure should be
directly proportional to the size/frequency of the aircraft operations and the passengers
making use of the airport services.
Security infrastructure at small and remote airports
Another area of concern is the security-related expenditure on these small and
remote airports. Civil aviation security is an integral part of national security and the
government is making earnest endeavour to insure that the state of the art technology
and security equipment of world class standards are used by all the agencies involved in
civil aviation security. At the same time, provision of such modern high-tech security
equipment and deployment of large number of security personnel results in huge
financial burden, particularly, when the airport caters for just a few aircraft operations or
when the Airport is available for a few hours in a day. This calls for rational view on
provision of high-tech security infrastructure and number of security personnel to be
deployed at such airports. Provision of security being an important and sensitive subject,
state support to meet the cost is essential.
Need for cohesive planning among the stakeholders
There is also a need for cohesive planning among all the stakeholders like airport
operator, airline operator, ANSP and others for arriving at a mutually acceptable decision
on CNS/ATM infrastructure and airport infrastructure requirement. This will ensure that
the provision of facilities/services meets the expectations and requirements of all the
stakeholders. This will also ensure that infrastructure/ technology that is essentially
required will be provided, will be put to optimal use by all the stakeholders and paid for
by the passengers. This is particularly relevant in Indian context, as there have been a
number of instances where the incompatibility among the stakeholders has resulted in
unutilized infrastructure or unavailability of the required infrastructure.
While efficient and extensive air transport services both domestic and
international as well as world class aviation infrastructure make a significant contribution
to overall development, involvement of State Governments is essential.
Airspace Management Policy
Keeping in view the current and future traffic growth in Indian airports and
airspace, there is a need for developing a comprehensive airspace management policy
to optimize the airspace usage and provide maximum benefits for all the airspace users
as per their legitimate requirements. Airspace Management Policy would not only be
applicable for sovereign airspace but also the commitment of India as a State for
provision of efficient Air Traffic Management services across the oceanic airspace
delegated to India by ICAO for such provision of services. It is therefore, necessary that
the Airspace Management functions should rest with Civil Aviation Authorities, that is,
Ministry of Civil Aviation, as an executive authority to administer the Airspace
Management functions and also to develop Airspace Management Policy guidelines and
administration. Policy guidelines should also take into account the various user
requirements primarily the military and develop detailed guidelines for Flexible Use of
Airspace. Necessary coordination mechanism may be considered through proper
representation by user departments like Ministry of Defence, Indian Air Force, Space
Research Organization, General Aviation, etc.
Civil Air Traffic Flow Management (CATFM)
Air traffic in the recent past at Indian Airports and in the airspace has grown
exponentially and is likely to grow further in the immediate future. Airports Authority of
India has taken initiatives to implement Central Air Traffic Flow Management system to
optimize the capacity versus demand both strategically and dynamically by integrating
various operational constraints and weather parameters. Mitigating measures and
alternate actions to avoid congestion and delay for Air Traffic both in terminal /en route
airspace and airports will be achieved through collaborative decision making process
involving all stake holders including Airlines.
The ATFM project will be implemented by AAI through the US India Aviation
Cooperation Program (ACP) and the US Trade Development Agency (USTDA) is
providing a grant partially funding the project.
The implementation of ATFM will not only benefit the Indian Aviation Industry in
terms of enhancement in ATM capabilities for improving Safety, Efficiency, Capacity of
the Airspace/Airports and environmental benefits but also will contribute to Regional and
Global ATM harmonization .
Implementation of Air Traffic Flow Management covering all airports and Indian
Air Space is planned in the first phase and will be completed by July 2012. In the
second phase, the interfacing of the system will be done with other ATFMs and will be
completed by July 2013.
A regulatory process for overseeing the CDM process including the adherence to
slots by Airlines/ swapping slots when required/ effective monitoring of ‗On-time
performance‘ etc. should be devised.
Need for a Dedicated Aviation Meteorology Division
Airports Authority of India (AAI) is entrusted with the responsibility of providing Air
Traffic Management (ATM) services over the vast Indian airspace measuring over 2.8
million square nautical miles by the International Civil Aviation Organization (ICAO).
Dissemination of timely and accurate meteorological information to aircraft is a
mandatory requirement of ICAO. The ATM Services at defence airfields and in the
airspace above them are provided by either the IAF or the Indian Navy.
The Aviation Meteorological Services (AMS) at civil airports are being provided
by the India Meteorological Department (IMD) and at the Defence airports by the
IAF/Indian Navy to all the civil as well as defence flights.
The provision of Aviation Meteorological Services at civil airports is governed by
Annex-III of ICAO and various requirements issued from time to time by the Dte. General
of Civil Aviation which is the regulatory body for all the aviation related activities at civil
airports in India. However, since the provision of AMS at civil airports is under the
control of IMD the timely implementation of certain urgent issues by DGCA requires
concurrence from DG, Met also thus involving two regulators for one entity.
AAI has developed a comprehensive master plan for the augmentation of
Communication, Navigation Surveillance (CNS)/ATM infrastructure with a time bound
schedule of implementation. AAI has also drawn the concept of Future Indian Air
Navigation (FIAN) and has submitted a paper in this regard to ICAO.
While there is a significant focus on the development of CNS/ATM infrastructure
across the country, it is essential that the meteorological equipments and appropriate
infrastructure to match the new technology of CNS/ATM systems is also installed at the
airports to ensure the optimum compatibility and the desired level of quality.
The failure of any equipment necessary for the safe air navigation of aircraft
poses serious implications on the operations of the concerned airport as well as the
adjoining airports. Therefore, in the over all interest of aviation industry, there is a need
to integrate the responsibility for the provision of AMS also with the organization
responsible for the provision of ATM Services.
Since the meteorological services at defence airports are being provided by the
IAF/Indian Navy, purely on its own with the help of equipment installed at these airports,
the meteorological services at civil airports can also be provided in the similar manner.
Whenever additional met information, met data and forecast is required from the
observatories located outside the airports, such information can always be obtained from
the Met Dept. by the agency providing Aviation Met Services at the civil airports.
In view of various new airports (govt./private/greenfield) coming up in near future,
the requirement of meteorologists at the airports is bound to increase manifold. The
Aviation Meteorological Services can always be provided at the airports in coordination
with the other non-aviation related services of IMD, even while remaining as separate
entities.
It is proposed to create a dedicated aviation meteorological division under the
ambit of air navigation services in AAI. This division will function as per the provisions of
ICAO and as per the directions of the DGCA / Regulatory Authority on aviation
meteorology. However, the aviation meteorological division shall essentially require to
function in co-ordination with IMD, especially for the exchange of meteorological data,
modern technology and requirements prescribed by WMO. This will facilitate the
provision of harmonized meteorological services and will meet the national and global
requirements.
It is worthwhile to mention that until the 1970s, the Indian Meteorological
Department [IMD] used to be a part of the Ministry of Civil Aviation. Naresh Chandra
Committee had also suggested that in recognition of the importance of meteorological
services in providing effective ATC services, the IMD should depute trained
meteorological personnel to the proposed ATC Corporation.
Note : A detailed proposal in this regard was submitted by AAI to the Ministry of Civil
Aviation and presently the proposal is under the consideration of the Cabinet
Secretariat.
Suggestions received from APAO
CENTRAL AIR TRAFFIC FLOW MANAGEMENT (CATFM) - ATC AUTOMATION
1. ATC automation is of paramount importance to ensure a safe and secure Air
Transport service.
2. Since management of air space being a sovereign function, the policy should
consider hiving off this function from Airport Authority of India which is an airport
operator itself.
3. Since Airport Authority of India is undertaking multiple functions there is always a
possibility of cross subsidisation of one service with another, which will be applicable in
the case of ATC/ANS service also. Policy should formulate remedial measures to
identify and eliminate such possibility of cross subsidisation by mandating
maintenance of separate accounting records.
4. Policy should also address the short, medium and long term investment
requirements and ensure timely investment in ANS infrastructure facilities. Also
modernise the entire ATC systems and procedures.
5. Policy should also address the feasibility of offering the ANS service by other
airport operators to eliminate monopoly of single operator.
FLEXIBLE USE OF AIRSPACE (FUA)
Airspace is a scarce resource of the country and efficient and economical use of air
space must be addressed in the policy. Restrictions on the use of airspace could lead to
wastage of this national resource hence policy should address the maximum flexible
use of airspace at the same time eliminate the misuse or under utilisation of airspace.
Therefore, airspace should not be designated as civil or military but should be
considered as a continuous entity and should be allocated to users on actual
requirement basis. This will ensure increase in capacity of airspace and will result in
reduction in operating cost of airlines and lesser carbon emission into the environment.
CUSTODIAN OF AIRSPACE
Ideally the government (the sectoral ministry i.e. Ministry of Civil Aviation) must be the
custodian of airspace.
DEVELOPMENT OF AEROSPACE/ AIR SPACE MANAGEMENT POLICY
Considering the growth prospects of air traffic in the country and the competitive
advantages arising out of growing pool of scientific and technical manpower, it is
necessary to consider initiating activities for the development of aerospace industry in
the country. This will also help in reducing the import cost.
With the privatisation of airports in India, the JVC airports are separate entities who are
required to generate their own revenue and make themselves financially viable by using
the airside resources of the airport. Therefore, it will be prudent to handover the control
and management of Aerodrome control tower and Terminal airspace to the JVC so that
they are in effective control over the utilisation of their resources.
Prior Immigration Clearance
Prior immigration Clearance facility from the originating country to the Hub Airport in
India will be a right step in attracting tourists and Hub development.
Suggestions received Confederation of Indian Industries (CII)
Central Air Traffic Flow Management – ATC Automation : With airspace
infrastructure already constrained at India‘s current levels of traffic, managing the
expected future growth clearly requires a continued and comprehensive increase in
capacity at key locations, coupled with simultaneous modernization of technology and
practices to handle en-route and arriving/departing aircraft. The following is
recommended :
Incorporate principles of the Manual of Global Performance of the Air Navigation
System (DOC9883) into the planning and management process of AAI and
DCGA. This provides a structure for development of a performance regime to
draw performance to a level where future needs can be accommodated safely
and efficiently.
Appoint a Network Manager: To take a State wide view of all airspace to ensure
consistent planning and transition to future infrastructure upgrades, besides
separate service provision from regulation.
Aerodrome: Review aerodrome capacity and conduct engineered performance
standard to determine theoretical capacity; Tailor the practical capacity taking
account of specific aerodrome characteristics; Use this information to improve
capacity, specifically focusing on determinants of runway capacity, namely -
Runway occupancy time, Separation on final & Mix of traffic.
RNP: Introduce RNP arrivals and departure procedures separated at the system
level to augment airspace capacity. RNP procedures enable more aircraft into
the TMA and RNP procedures combined with continuous descent arrivals,
improve safety and reduce the chance of runway excursion.
ENROUTE: Review en-route route structure to provide separated one-way routes
– introducing RNP4 initially with the objective of reducing to RNP2 (for
International as well as Domestic Route Network).
Flexible use of Airspace (FUA): Large portion of Indian airspace is reserved for
Military purpose that can be made available for civil flights whenever unutilized.
This flexible use of airspace can help in shortening of ATS routes besides
optimizing flight profiles in the terminal area. FUA mechanism can be
implemented only with improved coordination between Civil and Military
authorities.
Suggestions from Go Airlines
Security management of airports needs to be brought under one umbrella with the
objectives of creating efficiency and controlling; Airport periphery incursions; Access
control to airport and operational areas; and Active management and offering of a
security cover to personnel and equipment
Outsourcing of the Security, engineering, ground handling and cargo handling shall be
permitted and there shall not be any royalty on such outsourced services.
Many airports in India are civil enclaves. Through the Ministry of Defence, prioritisation
of civil aviation needs to be agreed with Air Force and Navy marking clear corridors for
usage by civil aircraft. This shall result in avoidance of unnecessary delays in departure
processing, additional fuel burn due to holding and inconvenience to passengers.
Airport operators must inform airlines of planned runway and equipment maintenance
work so that schedule changes can be made in advance prior to release of summer and
winter schedules. Currently, a lot of work in being undertaken at short notice, thus
impacting schedules of airlines and causing significant inconvenience to travellers.
Cross utilization of resources including the security, ground handling staff, cargo
handlers shall be permitted.
8. SUGGESTION FOR ECONOMIC REGULATION
Suggestions received from Nathan Economic Consulting India Pvt
Fares
The civil aviation policy should include a framework for monitoring anticompetitive
pricing behaviour with respect of the calculation of fares. The framework would define
predatory and excessive pricing within the context of India‘s civil aviation sector. This
monitoring framework would set out the types of data that the regulator needs to collect
in order to analyze the pricing behaviour of airline operators. Lastly, this framework
should provide strong disincentives to discourage airlines from indulging in
anticompetitive behaviour. This type of monitoring will protect the civil aviation sector
and most importantly consumers, from economic damages resulting from
anticompetitive behaviour.
Suggestions received from BLUE DART Aviation Ltd.
2. Economic Regulations
a. Unreasonable non-transparent increase in lease rentals
Lease rentals at some airports have increased astronomically in the past few years.
Moreover, express airlines with their dedicated facilities invest in constructing and
furnishing their own facilities. Unlike the passenger segment, the facilities provided for
air express are very basic and there is no extra service to justify such increases.
Dedicated facilities also do not come under the purview of AERA. There is a requirement
for transparency to determine lease rentals that are commensurate with services
provided by the operator. It is recommended that lease rentals be regulated by AERA
with a transparent mechanism provided by the airport operator on arriving at standard
lease charges and the proposed increases.
9. SUGGESTION FOR ATM
Suggestions received from Airports Authority of India (AAI)
Satellite Based Navigation (GAGAN) : Policy on User requirements & Service
Liability
India is the fourth country in the world to deploy Satellite based
augmented systems - the GPS Aided Geo Augmented Navigation (GAGAN) to
provide precision navigation services that will serve both Aviation and Non
Aviation Users. Deployment of GAGAN systems is a joint venture programme by
and Indian Space Research Organization (ISRO) and Airports Authority of India.
The GAGAN Signal-in-Space is expected to meet the requirements for high level
precision position and Navigation services by augmenting the GPS signals
through a system of ground monitoring stations and master control stations
located suitably and relaying correction and integrity messages to users through
GEO satellites forming the space segment.
The system ensures meter level accuracies, 99.99% availability, integrity
and continuity of service within a defined GAGAN service volume over India, as
required by international standards specified by ICAO. GAGAN will provide
seamless navigation services, compatible and interoperable between European
SBAS on the west and Japanese SBAS on the east.
Introduction of GAGAN based services will:
Promote the transition from Ground Based Navigation services to Satellite
based Navigation services over Indian Airspace.
Provide service expansion capabilities beyond Indian borders extending
upto Australia and Africa.
Provide opportunities for Indian Industries to develop appropriate certified
SBAS receivers and GAGAN based applications to Non-Aviation users.
Provide opportunities for Indian Research institutions for research and
development in the field of geo spatial studies.
Provide an opportunity for higher education (Masters degree) in a
specialised field of navigation technologies
Provide several value added services like the NAVCOM technology
serving several applications like disaster management, GIS, location
based systems, intelligent transportation systems etc.
The return on investment from GAGAN is envisaged to be derived over a
period of time through the indirect cost benefits in fuel savings, non-installation of
ground based navigation aids at new regional airports, capabilities of airport
operating at lower visibilities leading to lesser diversions, better airport operability
and reduction in carbon emissions with shorter and more efficient routings. With
the advent of ADS-B technology coupled with GAGAN positional accuracies, will
have a larger impact in enhancing airspace and airport capacities.
In order to achieve the above objectives, the following plan initiatives need
to be considered to be incorporated in the draft Civil Aviation Policy:-
- Mandating regional airlines with the equipage of certified SBAS receivers
on their aircraft operating into or from GAGAN enabled airports.
- Requiring helicopter and General Aviation operators to use suitably
equipped on-board certified SBAS receivers.
- Developing a GAGAN registered user data base.
- Encouraging Indian industry to develop certified SBAS receivers.
- Coordinating with neighbouring countries for expansion of GAGAN
services in their area of jurisdiction.
Similar strategy should be adopted for exploiting the Ground based
Augmentation System (GBAS) which is currently under implementation in India.
Policy guidelines for user requirements and service level and liability etc.
may be considered.
Suggestions received from APAO
SATELLITE BASED NAVIGATION SYSTEM - SERVICE TO OTHER SECTORS
Since satellite based navigation system is an essential ingredient of safe and secured
air transport system, the policy should address the issue of availability of an efficient
satellite based navigation system for the Civil Aviation Sector. It can also be developed
as a business model so that the service can also be offered to other sectors on cost
plus basis.
Suggestions received from IATA
Air Traffic Management (ATM)
In order to improve upon existing infrastructural constraints in Indian Civil aviation, there
is an imminent need to introduce changes which can be expressed in a practical and an
actionable manner, namely:
Incorporate principles of the Manual of Global Performance of the Air Navigation
System (DOC9883) into the planning and management process of AAI and DCGA.
Appoint a Network Manager to take a State wide view of all airspace to ensure
consistent planning and transition to future infrastructure upgrades.
Aerodrome: Review aerodrome capacity and conduct engineered performance
standard to determine theoretical capacity.
- Tailor the practical capacity taking account of specific aerodrome characteristics;
- Use this information to improve capacity, specifically focusing on determinants of
runway capacity, namely
o Runway occupancy time,
o Separation on final &
o Mix of traffic.
TMA: Introduce RNP arrivals and departure procedures separated at the system
level to augment airspace capacity;
- RNP procedures enable more aircraft into the TMA,
- RNP procedures combined with continuous descent arrivals, improve safety and
reduce the chance of runway excursion.
ENROUTE: Review en-route route structure to provide separated one-way routes –
introducing RNP4 initially with the objective of reducing to RNP2 (for International as
well as Domestic Route Network).
Flexible use of Airspace (FUA): Large portion of Indian airspace is reserved for
Military purpose that can be made available for civil flights whenever unutilized. This
flexible use of airspace can help in shortening of ATS routes besides optimizing
flight profiles in the terminal area thereby saving fuel and reducing carbon emission.
FUA mechanism can be implemented only with improved coordination between Civil
and Military authorities.
Civil Military Co-operation:
o Use of Aeronautical facilities: Large aeronautical infrastructure viz Military
Airports can be planned as notional alternates for flights (at least when the
chances of diversion are extremely minimal). Airlines are required to uplift
extra fuel for alternate civil airport which are distant. Aircraft especially over
long-haul burn considerably higher quantity of fuel just to carry the diversion
fuel. Authorising near by Military airport thus can save fuel burn and be in
sync with the environmental objectives of the Aviation Policy.
o Aeronautical documentation: Indian Civil enclave airports documentation is
under military authorities control. From safety as well as efficiency point of
view, this documentation needs to be under AIS (Aeronautical Information
Services) of the Government of India.
o Air Defense Clearance (ADC): Aviation is growing all across the country and
traffic is expanding in multifold from various small airports. Airlines are
struggling to co-ordinate ADC clearance as there is no centralized
mechanism between the ATC and Military authorities for this process.
o Globally ATC co-ordinates with military authorities as ATC is solely
responsible for issuance of instructions to aircraft, thus Civil-Mil Co-ordination
for issuance of ADCs and making it centralised will enhance operational
efficiency. This will also assist proposed C-ATFM.
Satellite based navigation system - service to other sectors: IATA supports Aircraft
based augmentation over satellite based navigation. Services to General Aviation,
Helicopter operations, Search and Rescue operations can certainly find usage of
Satellite based navigation (SBAS).
AAI-ATM as Custodian of Airspace: Airspace is a limited national resource and it is
imperative that Civil ATM authorities need to be designated as custodian of the
airspace. The Military does not utilize airspace on a 24 X 7 basis and in the absence
of extended control over the airspace, there is inefficient usage of the resource. In
Europe for example, Eurocontrol publishes Route Availability Document (RAD)
meeting AIRAC cycle dates. This provides an excellent opportunity for Civil ATC
catering to the needs of Military – opening / closing of routes based on the hours on
the days when required for Military activities – on a 28 days basis.
Central Air Traffic Flow Management (CATFM) - ATC automation: CATFM and ATC
automation should cater to:
o Regulating Arr/Dep flow to improve operational efficiency of the expanding
domestic traffic
o Facilitate efficiently managing the Increasing Intlernational Arr/ Dep traffic,
o Facilitate and lead Single Asian Skies (India‘s Geographical position in South
Asia) for smoothing the primary traffic flows (Europe-Asia, Gulf- Asia)
10. SUGGESTION FOR ENVIRONMENTAL ISSUES AND RESEARCH
& DEVELOPMENT
Suggestions received from CAPA:
Objective Post 2015/16
Environment
Sustainability issues are increasingly prominent in the global aviation industry. India
needs to develop a roadmap for addressing issues such as carbon emissions in line
with IATA‘s targets. India also needs to establish targets of its own that are appropriate
for the market. Investment in new technologies and enhancing the efficiency of airports
and airspace will make an important contribution. The industry needs to be prepared as
we expect a significant increase in activism in relation to emissions and noise. As stated
earlier, careful planning with respect to land use can mitigate potential noise pollution
before it arises. As an emerging aviation power, that is likely to be the third largest
market in the world by the end of this decade, India needs to be seen to be responsible
and to be taking a leadership role in the challenges that face the industry. But strategies
also need to be developed for how to respond to situations such as the European
Emissions Trading Scheme.
Suggestions received from Airports Authority of India (AAI)
The following issues may also be considered in the Draft Civil aviation Policy
1) Policy guidelines for effective Search & Rescue establishment and services
Aeronautical Search & Rescue activity is a primary function of Civil
Aviation which needs to be given due consideration in the Civil Aviation Policy.
Being a humanitarian service, the policy guidelines should adequately cover
various functions of Search and Rescue activity and also the functional
responsibilities of various service organizations and also resource organizations
to extend search and rescue services as a national service for the Civil Aviation.
As a sovereign State, the search and rescue responsibility not only is restricted
within the national boundaries but also extend beyond territorial waters as a
coordinated service with adjacent States in providing effective Search & Rescue
services. Therefore, detailed policy guidelines on this vital function is essentially
considered necessary.
2) Policy on Town Planning Guidelines around the Airports for effective control on
obstacles for ensuring safe aircraft operations.
As Air Traffic is growing exponentially, more and more airports are likely
to come up in the near future and mushrooming of human habitation around the
airport in the close proximity is unavoidable. Such developments of township
around the airports not only pose a serious problem for the airport/aircraft
operations for an efficient flight path from the safety point of view but also leads
to increased noise pollution and environmental pollution which results in public
litigations and other issues. In order to curtail growth of such townships in close
proximity to the airports, a comprehensive town planning policy guidelines is
considered necessary for effective implementation. This will facilitate safe and
smooth operations and also enable future expansion of the airport and airport
infrastructure to cope up with the traffic demand at a later stage.
Suggestions received from APAO
Aircraft Manufacturing
As Indian Aviation is poised to grow substantially, the policy should address the need to
establish an Aircraft Designing and Manufacturing Centre, with the support of ISRO,
DRDO, Airlines, Airports, MROs and Aerospace Industries in the national level through
PPP model.
Ancillary industries
The policy should encourage setting up of Airport related ancillary industries such as
manufacturing of Aircraft sheets, baggage trolleys, x-ray scanning machines etc., which
will help indigenous production of such critical items that will also avoid draining foreign
exchange, besides generating large scale employment.
Green Airport Initiatives
The policy should provide for rewarding and incentivizing the "Green Airport Initiatives"
like harnessing Solar, Wind energies; Rain Water etc.
Noise Abating Policy
A 'Noise Abating Consultation Committee' has to be formed with the involvement of
local community. Rewarding the noise abating initiatives of Airlines and Airports is a
right step in this direction. Metropolitan development plans should not permit residential
zones in Landing and take-off paths.
Environmental Protection
Rewarding 'Air pollution reduction Methods' , Forest/ green belt cultivation initiatives,
Landscaping etc with appropriate ―carbon credit‖ provision may be dovetailed into the
policy.
R&D in Civil Aviation
The policy may spell out the modalities of setting up of an 'R&D Centre for Civil Aviation'
in line with ISRO, DRDO, IISc, IITs etc.
Local Community Development
As part of Corporate Social Responsibility, ear-marking a portion of the profit of Aviation
entities should be mandated in the policy for Local Community Development.
Suggestions received from BLUE DART Aviation Ltd.
Environment Issues
a. Restrictions on Night Operations of Chapter 2 Aircraft
Noise restrictions are implemented at Delhi Airport between 2200 to 0600hrs for Chapter
2 aircraft. While there may be a public outcry, it is inevitable that urban growth will stray
into what should be airport zones in major commercial centres and people living in these
areas would be impacted by noise. It is important to note that most cargo freighters are
drawn from the secondary market and converted. As such, these are old aircraft some of
which may be noisy. It would be cost-prohibitive to introduce a young fleet, similar to the
norms followed by passenger airlines, and these are neither required nor recommended
as these aircraft are subjected to stringent regulatory oversight to ensure safe
operations.
While framing noise abatement measures, the DGCA should compare airports in
countries at the same level of development as India. The emerging economies in our
part of the world, including countries like China, Russia, Taiwan, South Korea, Thailand
and the UAE have not implemented any restrictions or ban on Chapter 2 aircraft.
Emerging economies like ours have need for cost-effective air transportation, which
would be different from developed nations, to support their economic growths. Where
restrictions have been implemented, a phase out plan of 15% - 20% of the affected fleet
per year has been the industry practice. The MCA should frame a practical policy,
keeping in mind that we are a developing economy and there will be an increasing
demand for air cargo transportation to fuel growth. Chapter 2 noise restrictions should
not be imposed at any other major airport. Any restrictions or ban on Chapter 2 aircraft
should be done in a phased manner providing sufficient time for freighter operators to
induct new capacity in a staggered manner so as not to impose any crippling cost
burden on the operators or be detrimental to the competitiveness of Indian business.
Suggestions from Go Airlines
Policy required to address matters related to aviation emissions, noise and environmental aspects.
11. SUGGESTION FOR MISCELLANEOUS
Suggestions received Confederation of Indian Industries (CII)
Market Access Policy : To ensure healthy competition, Regulatory Authority should
put in place a mechanism to stop predatory pricing of Air Fares.
i
CAR Section 3 Series M Part I Issue 2, Dated May 1 st, 2008
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