Position paper of the Netherlands on the public consultation for the planned revision of Council
Regulation 95/93, as amended, on common rules for the allocation of slots (“the EU Slot Regulation”)

BACKGROUND
Airlines that want to operate at coordinated airports within the European Union need to have slots allocated by an
independent coordinator for each arrival and departure to do so. The EU rules on slot allocation which govern the
process of slot allocation at Community airports have not changed substantially since the current EU Slot
Regulation was adopted in 1993, except for example some revisions made in response to the Covid-19 pandemic.
However, differences between airports are significant and the market has changed substantially in that period.
Furthermore, a gradual shift in the public opinion on aviation has taken place in the last decades. Unconditional
support for further growth of air traffic is not a given, and the call for a decrease in air traffic due to
environmental and climate reasons is gaining momentum in our society. A reduction of available capacity will have
a profound impact on the slot allocation process with the current slot regulation lacking the clarity for coordinators
how to act in a situation where historic slots need to be withdrawn from air carriers. Less available capacity also
means that the already existing scarce capacity will become even scarcer in the future . That will put an intense
pressure on the future developments of the three coordinated airports (Amsterdam, Airport Schiphol, Rotterdam
The Hague Airport and Eindhoven Airport) in the Netherlands, especially for Amsterdam Airport Schiphol.
Before the Covid-19 pandemic Amsterdam Airport Schiphol was one of the busiest and most congested airports in
Europe, serving 71.7 million passengers, 332 direct (inter)continental destinations and handling 1.57 million
tonnes cargo (figures of in 2019)1. The network of destinations served via Amsterdam Airport Schiphol is of great
importance for the Netherlands and Europe. Capacity at Schiphol airport has become ever more scarce and will
become even scarcer due to environmental reasons. That scarcity has also made the drawbacks of the current slot
allocation regime increasingly visible. For example, the current slot regulation does not provide the flexibility the
cargo market needs for their full freight operations due to demands of their business model.
New incentives and ways of thinking are therefore needed to guarantee that the remaining scarce capacity can be
used as efficiently as possible to guarantee that Schiphol airport can maintain its important role as a gateway to
(North-West) Europe. Obviously, this same holds true for all other airports in the EU that face similar capacity
crunches and challenges to the development of their networks. The Netherlands therefore welcomes this initiative
to revise the current EU slot regulation and would like to give its position on a number of topics which we believe
should be addressed.

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Annual Report 2019 Royal Schiphol Group
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One important way forward to help mitigate the described pressures on the network of airports is by providing
Member States with more opportunity to implement more tailormade additional national slot allocation criteria
that should be taken into account by the independent coordinator. It is thereby important that the slot rules
proceed from an optimal capacity allocation considering an airport’s function to society. The specific criteria that
are relevant for the Netherlands in this context lie in the areas of sustainability, network quality/ connectivity and
the retention of full freight operations.
POSITION
The Netherlands believes it is important (1) to give coordinators clarity how to withdraw historic slots in case
there is less capacity available and (2) to use the remaining scarce airport capacity as effectively and efficiently as
possible from a socio-economic point of view. For the second element the Netherlands calls for more leeway for
Member States to put forward additional slot allocation criteria that should be taken into account2 in the capacity
determination or in the slot allocation procedures at individual highly congested airports. The Netherlands
considers three of such additional criteria to be particularly relevant in order to be able to guarantee a
sustainable, well-connected and future-proof aviation sector in the EU. These additional slot allocation criteria are
also in line with article 8.4 of the Worldwide Airports Slot Guidelines (WASG):
1.

Sustainability

At highly congested airports, coordinators need to have the possibility and instruments to allocate slots with
priority to air carriers that use aircraft with lower emissions and noise levels. Such an explicit allocation criterion
will also contribute to the realization of the sustainability goals for aviation in line with the European ’Fit for 55’
goals, resulting in better health and livability for residents around airports and reducing the impact on the
environment and climate.
2.

Network quality/ quality connectivity

Especially for hub airports it is necessary to have an optimal mixture of long haul, medium -haul and short-haul
routes to serve a large number of destinations. At highly congested airports, coordinators need to have the
possibility and instruments to, for example, allocate slots to serve a particular (new) route or market (e.g. capital
cities, economic hotspots and promising upcoming markets) that help to improve the overall quality of the
network by prioritizing slot requests for destinations based on objective, unambiguous and transparent criteria.
3.

Full freight operations

Before the covid-19 pandemic full freight operations comprise approximately 3 percent of the number of
movements at Schiphol and cargo represented around 25 percent of the economic added value at the airport3. As
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For two equivalent scheduling periods, like slots that are allocated to a new entrant
Decisio (2019), Economische betekenis luchtvracht Schiphol
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such, full freight operations compose a strategic traffic segment at Schiphol, positively affecting the accessibility,
business climate and employment opportunities in The Netherlands and sustaining vital trade flows between the
Netherlands and Europe with intercontinental air freight hubs . The EU Slot Regulation, unfortunately, does not
provide the much-needed flexibility to this economically strategic segment (mainly due to the 80/20 “use it or lose
it” rule that is difficult to achieve for most full freight carriers because cargo and passenger flights work
differently). This continues to result in the loss of vital trade connections and inefficient or non-existent use of
scarce airport infrastructure uniquely designed for the handling of freighters. The Netherlands would therefore
want the Commission to acknowledge the needs of the different traffic segments – especially full freight operators
– by explicitly leaving room for Member States to legitimately and proportionately prioritize certain traffic
segments in the determination and allocation of capacity on an objective, unambiguous and transparent manner 4.

FINAL REMARK
This position paper sets out the two main ambitions of the Netherlands for the revision of the EU Slot Regulation:
(1) clarifying the allocation of (historic) slots in case of a decrease of the available capacity and (2) the possibility
of introducing additional allocation criteria at an individual highly congested airport. The Netherlands would like to
take this opportunity to call upon the European Commission to incorporate these two ambitions in the revision of
the Slot Regulation.
The Dutch position will also consist of other elements which the Netherlands will share with the European
Commission and the Member States after having had the opportunity to study the findings of the 2019/2020 fact
finding study on slots, the study on the impact of Covid-19 on aviation as well as the proposal by the European
Commission for the revision of the EU Slot Regulation.

October 2022

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Or giving the coordinator the possibility to reserve a certain number of slots (at SAL) for ad hoc use for full freighter
operations.
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