Coronavirus should be recognised as an extraordinary circumstance


Given the further outbreaks of Coronavirus (COVID-19) within Europe, ERA joins the collective view amongst the airline industry that the requirement on airport slots should be suspended immediately. Regulators have already been waiving the slot rules on a rolling basis during the crisis, primarily for operations to China and Hong Kong; nevertheless, the impact of COVID-19 has now spread beyond the Asian market and therefore should be recognised as an extraordinary circumstance.

Suspending the requirement for the entire season will alleviate the burden on airlines to operate 80% of their allocated slots as currently, should this quota not be met, the airline loses its right to the slot for the next equivalent season. Airlines should feel able to respond to market conditions with appropriate capacity levels, avoiding any need to run empty services in order to maintain slots – a solution that would have both an unnecessary financial burden upon the airline and an unnecessary environmental impact.

Further to this, we are clearly facing a situation where the level of employee absence is likely to reach far above normal levels. Aircraft checks and training are undertaken across the industry by a relatively small group of individuals, such as Type Rating Examiners or Part 147 Engineering Training staff. Consequently, any infection or quarantine amongst those individuals has an exponential effect on the operator’s ability to conduct the training. In light of this public health emergency, ERA encourages EASA to temporarily extend the validity of all pilot, cabin crew and engineering proficiency and recurrent training items by three months. This will provide greater resilience within the aviation sector given the potential significant difficulties ahead of us.

We also believe the current situation should fall under extraordinary circumstances as per Article 5(c) of Regulation 261/2004; therefore any related cancellations should be exempt from the obligation to compensate passengers. We urge DG MOVE to take this into consideration.

Drastic times call for drastic measures. The COVID-19 crisis has had a significant impact on the aviation industry, and this must be recognised by regulators in temporarily lowering the burden for airlines. We are without question dealing with exceptional circumstances and flexibility is essential in order for airlines to react to developments responsibly.

About ERA

Founded in 1980, ERA (European Regions Airline Association) is a non-profit trade association representing 53 airlines and 150 companies involved in European air transport and is the only association representing the entire spectrum of companies involved in European aviation. The association promotes the interests of European airlines by lobbying the European Commission and other European regulatory bodies on policy matters, promoting the social and economic importance of air transport and its environmental commitments.

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