C 486/196
EN
Official Journal of the European Union
21.12.2022
2.2 These slot relief measures will expire on 29 October 2022, with the Commission’s delegated powers having already expired on 21 February 2022.
With respect to the basic use-it-or-lose-it rule, the Commission now proposes re-establishing the standard slot use rate of 80 % as of 29 October 2022.
The reasoning given was that in June 2022, EUROCONTROL forecast that in the 2022-2023 winter season, traffic volumes would return to 90 % of 2019 levels.
2.3 The EESC is not convinced by this reasoning.
As a consequence of the Russian military aggression against Ukraine, military flights have increased significantly, as have re-routed overflights, neither of which are relevant for slot allocation.
Furthermore, it is necessary to differentiate between the air cargo movements, which have not decreased significantly over the crisis period, and passenger traffic movements, which did decrease.
Within this passenger market, a further differentiation is required: as a result of the EU COVID-19 pass, intra-European traffic has recovered far more quickly to pre-pandemic levels, however domestic air traffic and long-haul traffic are in different stages of recovery.
Business traffic is expected to recover far more slowly than leisure traffic (4).
It is by no means a given that leisure traffic will recover consistently; some of this growth can be attributed to pent-up demand for vacations after two years of COVID-19.
The major European network carriers have not yet reintroduced their large long-haul aircraft Airbus 380 into their respective fleets, precisely because airlines are faced with high fuel costs and because they do not expect significant and consistent increases in traffic demand.
Data provided by the stakeholders indicate that traffic movements are expected to increase to 90 % of 2019 levels, but passenger demand only to 78 %.
If the aircraft occupancy rate is lower, it can be expected that airlines will, for instance, combine multiple flights a day in order to maintain profitable flights (5).
Demand will be affected by rising inflation rates and increasing risks of recession in several countries.
Forecasts should therefore not be based on the regions of best recovery, but should reflect particularly hard-hit sub-markets as well.
2.4 These factors lead the EESC to believe that the aviation market recovery may be more arduous than assumed by the Commission.
Market segments are still recovering at different speeds: cargo 6 % relative to 2019 levels; low-cost carriers 9 %; and network carriers at 21 %.
This is all the more relevant as the thresholds refer to entire slot series, meaning that the series of slots (such as peak fights) need to be above the 80 % threshold.
In pre-pandemic periods, the slot use rate was at 95 %, with the lowest slot use rate at 80 %.
If EUROCONTROL forecast an average slot use rate of 90 %, then it must be assumed that the slot series will not (on average) reach 80 %.
For these reasons, it is much too premature to return to the 80:20 thresholds.
It appears more appropriate to adopt a 70:30 ratio until more robust data is available to substantiate a sustainable market recovery.
It should also be noted that the problems facing European airports clearly demonstrate that the effects of the COVID-19 pandemic have not yet been absorbed.
Major EU hubs such as Frankfurt, and non-EU hubs such as London Heathrow, have capped flights to and from these airports, leading to massive flight cancellations in an attempt to ease the strain on airline operations at these airports.
Such strains have been caused by a number of different variables, such as staff shortages.
This is indicative of the fact that pre-pandemic thresholds for the slot use rate cannot yet be reached (6).
2.5 A level of 70:30 would be in line with the thresholds and rationale adopted by the UK government (7).
Although it was heavily criticised by the airline sector, the EESC feels that it would strike a substantiated balance between returning to the status quo ante, while acknowledging that an (albeit reduced) level of slot protection is still required in light of the ongoing severe challenges facing the sector.
Furthermore, it aligns the EU Slot Regulation threshold with that of neighbouring countries’ policies, and levels the playing field for EU carrier hubs and London Heathrow Airport, Europe’s largest international hub.
(4) (5) (6) (7)
https://www.airliners.de/prognose-globaler-geschaeftsreiseverkehr-erholt-deutlich/65958 Publication of passenger numbers and forecasts at Munich Airport indicating that recovery to pre-pandemic traffic volumes will take longer than previously assumed: https://www.airliners.de/wachsendes-passagieraufkommen-bayerns-flughaefen-weit-entferntcorona-niveau/65950 The labour shortage at key airports is mentioned by the Commission in the explanatory memorandum, however the Commission considers this to be a short-term phenomenon.
This is questionable, as the labour shortage affects many economic sectors and not only aviation.
There is no reason to believe that this will be resolved in aviation in the near future.
On 24 January 2022 the UK government adjusted the slot use ratio to 70:30 beginning 27 March 2022 as a step toward normal rules, while protecting the sector against future uncertainty, as stated by UK Transport Secretary Grant Shapps.