Discussion of issues not covered by EU legislation Andrew Kelly European Regions Airline Association

The Regional view... The airline associations have been given less than two weeks notice of the topic to be presented. Consequently it has not been possible to prepare coordinated presentations agreed by all associations. This presentation represents the views of the European Regions Airline Association

About ERA 67 airline members 1.8 million flights per year 73 million passengers per year 72 minute average sector time 73 seat average seating capacity 1,100 aircraft 1,300 routes 30 countries across Europe

Are airlines consumer friendly? We need to be consumer friendly to keep our customers But consumer friendliness takes many forms Price Product Route network Loyalty schemes Safety ???

A deregulated market.... Within Europe the market is fully deregulated. This means the consumer has a choice of product and price the product (and contractual rights) will vary when things go well and when things go wrong This is what happens in a free market...

What needs to be regulated? Dont constrain a free market without a clear justification that regulation actually benefits the consumer Looking at two examples where the Commission raises the possibility of regulation in its consultation Seat pitch Cabin baggage policy

Seat pitch Regulate or leave the market to decide? Already regulated for safety Constrains the ability of companies to compete through product Increases the per seat costs raising the price of air travel For smaller aircraft operators potentially could result in 10% reductions (or greater) in seating capacity and associated operating/safety problems Does the consumer really benefit overall?

Cabin baggage policies Regulate or leave the market to decide? Already regulated for safety Constrains the ability of companies to compete through product Limits the choice for the consumer How do you create a rule that takes account of different aircraft types – for example, some regional aircraft have no cabin baggage storage space! Impacts hold baggage policies, airport baggage capacity and security screening Does the consumer really benefit overall?

Buyer beware or Regulate Ensure that the passenger knows what they are buying (for example: seat pitch, baggage allowance, check in rules, additional unavoidable costs, no show policy, on line reservation policies) Ensure the passenger knows what rights they will receive when things go wrong (for example: mishandled baggage, delays, cancellations, denied boarding, force majeure) The compromise is better transparency - BUYER AWARE

Equality across modes A key issue for regional airlines competing with high speed rail If travelling by air, EU Regulation 261/2004 provides for unlimited liability for care (meals, hotel accommodation) during force majeure events If travelling by rail, the carrier is relieved of any liability for care by EU Regulation 1371/2007 during force majeure events

Safety is the 1 st right It is easy to forget that air travel is a safety critical business A safe journey must remain the fundamental right of every air passenger and crew member No regulation on passenger rights must ever jeopardise safety

Regulations affect real people All consumer rights legislation affects consumers and employees Interference in the market will potentially result in the loss of routes, mobility and jobs The EC must respect its own rules on better regulation ensuring that the full impact of any proposal is properly assessed before it is proposed

Conclusion Do we need more regulation? Airlines need to be consumer friendly to attract business Consumer friendliness takes different forms including product and price Do we want to limit the choice for consumers? Leave the market to set the product and price but ensure that the consumer is protected by enabling them to be aware of what they are buying Do not over-regulate as regulation, by definition, limits personal choice