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IACA members consider themselves as efficient airlines, as they make optimal use of scarce resources, amongst which slots. As such, they attach a high level of importance to the issue of the allocation process for airport slots.

IACA wishes to draw the consultant’s attention to the fact that the market for holiday-makers is often seasonal. Seasonality is indeed a feature of the tourism industry, resulting from nature (the climate) and the organisation of society (school holidays).

Air transport, like any other business, is driven by market demand. When market demand for certain destinations is seasonal, the only efficient operational and economic response is therefore a seasonal offer. IACA hence concludes that slot allocation should serve the travel market through the requests of operators.It is a technical process and should in no case be used as mechanism to manipulate markets and policies.

Apart from some implementation problems mentioned in our replies to the questions, IACA considers that there is no reason for a major overhaul of the current EU slot rules. IACA holds the opinion that there is room for a more consistent interpretation and application of the existent slot rules.

IACA wishes to remind the consultant of the fact that the real issue to be solved is the “capacity crunch” and not slot mobility as such. Redistribution of existing slots will indeed not create additional capacity. IACA hence hopes that the wrong instrument is not used for solving a concrete problem.

Also, the principle of grand-fathering of series of slots, enshrined in the EU slot rules, is the only system that allows for efficient long-term fleet planning and scheduling.

Finally, some of the questions in the questionnaire can only be answered adequately with specific commercial data from carriers. IACA as industry association however does not collect statistical data from its airline members on the matter of slot usage.As such, IACA can only reply by using information known by the association.

For a full copy of IACA’s response can be viewed here.