Chapter Three

THE EFFECT OF PRICING AND SLOT MANAGEMENT ARRANGEMENTS AT KINGSFORD SMITH AIRPORT ON REGIONAL AIRLINES AND COMMUNITIES

Chapter Three

THE IMPACT OF THE SLOT MANAGEMENT SCHEME

Acceptance of the scheme by stakeholders

3.1 General acceptance of the need for the scheme was expressed in most submissions and evidence given to the Committee by stakeholders. However, concerns where raised about some details of the Slot Management Scheme.

3.2 The Local Government and Shires Association of NSW, who represent 177 general purpose councils in NSW including 135 outside the Sydney metropolitan area, indicated support for the scheme so long as it did not change with a change to a private operator:

3.3 A number of airlines that provide regional services expressed similar acceptance, with some reservations, of the Slot Management Scheme. These included:

3.4 The larger airlines, with domestic and international interests, also saw benefits in the Slot Management Scheme at Sydney Airport. For example, while not in favour of permanent, arbitrary caps and raising the issue of the scheme favouring regional airlines over other parts of the sector, Qantas indicated its acceptance that:

In giving evidence at the public hearing Mr Oldmeadow, Consultant, Qantas Airways, clarified this position, stating:

3.5 Mr Kimpton, speaking for Ansett Australia at the public hearing on 24 April 1998 indicated while Ansett was more concerned with price changes, they accepted the scheme.

3.6 The Board of Airline Representatives of Australia Inc (BARA), who represent the international airline industry with a membership of over 47 scheduled international airlines, make similar comment to Qantas:

Specific concerns raised by stakeholders

3.7 Some specific concerns were raised through submissions and by witnesses about a range of issues including current and continued access to slots. These are discussed further below.

Claims the scheme favours the regional airline industry

3.8 Qantas suggested that the scheme favoured regional carriers over any other part of the sector.

3.9 BARA, representing the interests of international carriers, raised the same concerns:

3.10 In contrast, Impulse Airlines believes that the regional ring fence does not necessarily favour regional access over other operators:

3.11 The FAC submission indicates that for the peak period 0700-0800 hours that:

In 1996/97 regional airlines, according to FAC statistics, represented 33% of all aircraft movements at KSA, with domestic airlines representing 42% and international airlines 18% [11] of movements.

3.12 In terms of aircraft movements, international flights would appear to be well represented in this slot, where they had 28% of peak movements while only accounting for 18% of all movements. Domestic airlines peak use was within plus 2% of its overall use of the airport. Regional operators appear to be under, rather than over, represented in the peak period by around 5% of movements.

The historical influence of the peak period surcharge on slot allocation

3.13 As suggested by Impulse and a number of regional airlines in submissions and evidence, this under representation in peak time is potentially due to the historical influence of the peak period surcharge that operated between 1991 and October 98. As Mr Bredereck of Tamair Airlines indicated in his evidence:

3.14 The Slot Management Scheme, as the Committee understands it, through its “grandfather clause” reinforces patterns of slot use that were in operation during 1997, including the impact of market forces as a result of peak and shoulder surcharges. From the evidence supplied and economic discussion available on the subject [12], it would seem that those airlines that could afford to pay the surcharge and in the words of the Productivity Commission:

are those who will have gained peak time slots as a result of the Schemes grandfather clause.

If those who have the peak time slots operate the slot according to the rules of the Scheme, they will maintain access to the slot regardless of the segment of the industry.

Possibility that the priorities of the scheme may discriminate against regional airlines without the ring fence provisions.

3.15 The Committee believes that it is unlikely, given the priorities of the scheme and degree of competition for peak slots, that a regional operator would gain access to a domestic or international slot even if became free. This means that at least 70% of peak time slots, and 60% of all slots are unlikely ever to “fall” into regional hands.

3.16 Clauses 21 to 23 of the Slot Management Scheme set out the rules for ranking applications for a slot. Clause 22 covers new operators and clause 23 sets out the order of priority for incumbent operators as follows:

3.17 These clauses clearly favour larger carriers in the international and domestic sectors of the industry. Without the protection of regional slots through the regional ring fence concept the scheme would otherwise discriminate against regional carriers on the basis, if an incumbent, of not being an international or interstate carrier and on the basis of seating capacity.

3.18 For new entrants, without a regional ring fence the Scheme discriminates against smaller aircraft, and hence regional airlines. Clause 22 (a) and (c) have fairly generic application, but clause 22(b) states:

Allocation of slots to regional airline industry not commercially unfair.

3.19 In the Committee's view, the argument that the number of regional slots allocated and their exclusivity in peak time is somehow commercially unfair to other parts of the industry does not automatically follow from the information at hand.

3.20 As discussed above, the occupants of peak slots gained access to them as a result of an economic competition (ie via a peak surcharge) on an open playing field lasting from 1991 to 1997. The regional airline industry represents 33% of Sydney Airport's air movements “business”, but uses only 28% of the peak period, while interstate and international airlines use 70% of the peak period, but account for only 60% of movements. The Slot Management Scheme priorities for allocation of slots, outside the ring fence, favours international and interstate airlines. Focusing for the moment on “equal rights” to run a business, and ignoring other policy matters, safeguards have been provided for regional operators in a scheme that has restrictions that would otherwise make it difficult for the regional airline industry to maintain access to slots at the most desirable times of day. The Committee cannot see this as discriminating against other parts of the industry.

3.21 On balance, the Committee believes that the regional ring fence is necessary to maintain a level of equity of treatment within the scheme.

Possible leakage from the “ring fence”

3.22 Some concerns where raised in other submissions about possible leakage from the ring fence in the longer term. For example, Hazelton indicated specific concerns in this area which it believed had not been adequately addressed by the Department of Transport and Regional Development during consultation concerning the scheme:

3.23 In follow up information provided by Sydney Airports Corporation it was indicated that:

3.24 The Committee believes, from the evidence, that the regional ring fence provides many safeguards against loss of slots to regional operators. However, the Committee's reading of the legislation and scheme, combined with the evidence it has collected indicates to it that it is nonetheless possible and quite foreseeable to lose a slot from the regional ring fence.

3.25 This view was confirmed at the public hearing on the 24 April 1998 by Ms Alroe from the FAC who confirmed that leakage was possible:

3.26 The Committee acknowledges that a slot may be precious to an operator. This presumes, however, that an operator remains in business or cannot be otherwise influenced to give up a slot. Given the tenuous position of some regional airline businesses (illustrated by Tamair's failure in 1998), the complex nature of operating a regional airline and external competition for a scarce resource, it is not hard to imagine the circumstance where a slot could “leak” from the ring. It is very positive that Impulse Airlines was able to step in and take over Tamair's slots, however there is no guarantee that this will occur on every occasion.

3.27 Once a peak or shoulder slot is lost from the ring fence by the regional airline industry it is unlikely, given the priorities of the scheme, that regional operators will regain access to that slot. Regaining a slot would only occur in the unlikely event that there is no domestic or international competition for the slot.

3.28 The Committee is of the opinion that this is an area that warrants careful monitoring and, if needs be, review and remedial action by the Minister for Transport and Regional Affairs and the Slot Manager.

Continued rural and regional community access to peak time slots.

3.29 The Committee also notes with interest the interim report published in September 1998 by the NSW Parliamentary Standing Committee on State Development. A number of the organisations representing regional communities indicated concerns to the Standing Committee that not only might slots be lost from the regional ring, but also, given the combination of the Slot Management Scheme and changes to pricing arrangements at KSA, that communities would lose easy, affordable and convenient access to KSA

3.30 A second issue raised in the Standing Committee's report is the question of what say regional communities have in continuing access to their traditional slots. In this scenario, regional airlines could divert peak slots to other routes, leaving a community with a less service or no service. While the Standing Committee acknowledged the consultation of communities by Department of Transport and Regional Development and that route specific slots had been considered but seen as making the scheme far too complex, it went on to say:

3.31 This Committee did not have the opportunity to explore this issue in depth itself due to time constraints. However, the evidence collected by the NSW Parliamentary Standing Committee is sufficient to convince the Committee that there is reason to monitor closely the movement of slots within the regional ring fence and its impact on regional access to KSA, as well as any leakage from the regional ring fence.

Recommendation

Safety issues raised concerning the compliance scheme

3.32 In their submission [20] and evidence given at the public hearing on 11 May 1998 Tamair Airlines raised concerns that the penalty system and lack of information about the scheme had the potential to compromise safety. In their submission Tamair state:

They go on to say, after giving an example of a possible scenario involving a minor defect with a coffee maker that could turn into a major fault:

The submission gives a further example:

3.33 At the time of preparing their submission Tamair was also concerned that they had not received a full copy of the Slot Management Scheme and its rules. The Company felt that:

Tamair recommended that an education program be developed for the industry to overcome this problem.

3.34 Speaking in support of the compliance scheme, Mr Harris from the Department of Transport and Regional Development stated:

3.35 While the Department did acknowledge the possibility that if aircraft management had a different view to the pilot about safety coming first, before commercial concerns, this could place pressure on pilots. Mr Harris stated:

3.36 With regard to Tamair's evidence, in a follow up letter, Impulse Airlines disagreed that safety was an issue

3.37 The Committee accepts that at this stage there is no evidence that the Slot Management Scheme and Compliance Schemes are intrinsically unsafe. It can see the need for a compliance system to ensure that there is incentive to comply with the Slot Management Scheme. However, it is concerned that the scheme was introduced, it would seem, with less than perfect documentation and initially without the systematic education of affected pilots by the bodies responsible for the piloting and implementation of the program.

Loss of Capacity for growth at the most desirable times

3.38 Sydney Airports Corporation raised as a negative aspect of the scheme:

3.39 Kendell also raised this as an issue in correspondence on 22 February 1999:

3.40 This would appear to be a problem not just with operating a slot system, but rather resulting from the overall framework of restrictions placed on operations at KSA through the movements cap and curfew arrangements. Growth at KSA will inevitably be restrained by the need to balance a wide range of stakeholder interests, including the Community surrounding the airport.

Claimed improvements as a result of the slot management scheme

3.41 In their 1997/98 annual report, Department of Transport and Regional Affairs made the following claims:

3.42 At the initial hearings of this Committee in April/May 1998 some anecdotal evidence was available to support the view that fewer delays where being experienced. However, no hard data was available due to the limited time of the Scheme's operation. For example, Mr McGrane, Mayor of Dubbo City council in his evidence provided 24 April 1998 indicated:

This period would appear to correspond to the “trial” period leading up to the Scheme's introduction and the fist month of its operation. He goes on to say:

3.43 On the other hand, while improvements seemed apparent from the personal experience of several of the witnesses, Mr Russell, General Manager, Hazelton Airlines indicated that:

3.44 This suggests to the Committee that at its public hearings in April it was too early to assess the impact of the new scheme.

3.45 The Committee notes with interest the findings of the NSW Parliamentary Standing Committee on State Development who reported in September 1998. They found that:

3.46 To gain more up to date information, a request for further information concerning the impact of the Slot Management Scheme was sent in January 1999 to airlines who gave evidence at the public hearings. BARA, Qantas and Ansett declined to add anything to their evidence. Further information was received from Yanda Airlines, Kendell Airlines and Sydney Airports Corporations which suggests that there is some division on the benefits of the Scheme.

3.47 On 17 February 1999 Yanda Airlines, in the follow up letter to their submission, indicated that their comments on the Slot Management Scheme where primarily negative, they state:

3.48 Kendell Airlines in correspondence dated 22 February 1999 indicated they had no concerns with the Slot Management Scheme as it currently stands. Sydney Airports Corporation saw benefits emerging from the Scheme, their response to the initial two seasons of operation is outlined below.

3.49 With regard to the Departments claim that less fuel will be wasted and less emissions produced under the new scheme, witnesses agreed that if the Slot Management Scheme worked as intended less time would be spent in holding patterns over KSA and consequently less fuel would be consumed. As Mr Kimpton, Manager Aviation Policy, Ansett Australia indicated in his evidence on 24 April 1998:

In response to a question on notice, Hazelton Airlines wrote:

3.50 With regard to the Departments claim of guarantees of access for regional communities in NSW, see the discussion and Committee recommendation above concerning the possibility of losses from the regional ring fence and how slots are allocated to airlines, not communities, allowing possible loss of slots in peak times.

Trends in the operation of the Slot Management Scheme March 98 to February 99

3.51 The Slot Management Scheme has now been in operation for two “seasons”, Summer 98 (29/2/98 to 24/10/98) and Winter 98 (25/10/98 to 27/3/99) with a third now scheduled by the ACA for the period 28/3/99 to 30/10/99.

3.52 While there remains some criticism of the scheme for a range of reasons, Sydney Airports Corporation in their correspondence dated 19/2/99, indicates that there are some positive results being seen:

3.53 Sydney Airports Corporation's evidence supports the claim in the Department of Transport and Regional Affairs' annual report for 1997/98 that the Slot Management Scheme was delivering less clustering of flights.

3.54 It is difficult from the evidence to hand to estimate to what degree improvements have been made in flights being on time, only that there has been improvement. Sydney Airports Corporation indicated that:

3.55 The compliance system began its operations in October 98, at the beginning of the Winter 98 season. According to Sydney Airports Corporation, a review of off-slot operations by the Compliance Committee has commenced. While no fines have been applied to-date, the review will determine if fines should be levied. The Corporation saw this in a positive light:

3.56 The Corporation also suggests that the analysis of the impact of other factors on the off-slot movements will enable those involved to minimise the impact of these factors.

Conclusions on any benefits derived from the Scheme

3.57 It would seem from the evidence that the scheme is having a positive impact on the management of aircraft landings at KSA, particularly with regard to cluster scheduling and arrival and departure times. This would appear, as claimed by the Department of Transport and Regional Affairs, to have flow ons to the airline industry in savings in operating costs produced simply by less time circling KSA in the air and waiting for departure on the ground.

3.58 In the first two seasons of the scheme's operation there appears no evidence of any “significant” loss of regional and rural access to KSA. However, as expressed in the Committee's recommendation, the Committee believes the guarantees of protection of regional community and airline access are not all encompassing. There is still a possibility that events could lead to the loss of access by communities with less profitable routes. It is the Committee's belief that rural and regional community access will need careful monitoring by the Minister to ensure there is no creep of slots toward more profitable routes, with a consequent loss to some communities of slots, particularly at peak times.

Footnotes

[1] Submission, Local Government and Shires Association of NSW. p 3.

[2] Submission, Impulse Airlines Pty Ltd, p 2.

[3] Evidence, Hazelton Airlines, p. 37.

[4] Submission, Qantas, p3.

[5] Evidence, Qantas, p. 90.

[6] Submission, Board of Airline Representatives of Australia Inc., p. 2.

[7] Submission, Qantas, p3.

[8] Submission, Board of Airline Representatives of Australia Inc., p. 2.

[9] Submission, Impulse Airlines Pty Ltd, p 2.

[10] Submission, Federal Airports Corporation, p. 8.

[11] Submission, Federal Airports Corporation, p. 4.

[12] International Air Services Productivity Commission pp 157-159.

[13] International Air Services Productivity Commission p. 159.

[14] Slot Management Scheme 1998, p. 19.

[15] Slot Management Scheme 1998, p. 19.

[16] Correspondence (19/2/99), Sydney Airports Corporation.

[17] Evidence, Federal Airports Corporation, p. 71.

[18] Interim report on Provision and operation of rural and regional services in New South Wales, Parliament of New South Wales, Legislative Council, Standing Committee on State Development, Vol 1, p. 39.

[19] Interim report on Provision and operation of rural and regional services in New South Wales, Parliament of New South Wales, Legislative Council, Standing Committee on State Development, Vol 1, p. 40.

[20] Submission, Tamair Pty Ltd, p. 2.

[21] Submission, Tamair Pty Ltd, p. 3.

[22] Evidence, Department of Transport and Regional Development, p. 165

[23] Evidence, Department of Transport and Regional Development, p. 165

[24] Correspondence, Impulse Airlines.

[25] Correspondence (19/2/99), Sydney Airports Corporation, p.3.

[26] Correspondence, Kendell Airlines (Aust) Pty Ltd.

[27] Annual Report 1997-98, Department of Transport and Regional Development, p. 33.

[28] Evidence, Dubbo City Council, p28.

[29] Evidence, Dubbo City Council, p29.

[30] Evidence, Hazelton Airlines, p 37.

[31] Interim report on Provision and operation of rural and regional services in New South Wales, Parliament of New South Wales, Legislative Council, Standing Committee on State Development, Vol 1, p. 33.

[32] Correspondence, 17 February 1999, Yanda Airlines.

[33] Evidence, Ansett Australia, p. 75.

[34] Correspondence 22 May 1998, Hazelton Airlines, p. 1.

[35] Correspondence 19 February 1999, Sydney Airports Corporation, p. 2.

[36] Correspondence 19 February 1999, Sydney Airports Corporation, p. 2.

[37] Correspondence 19 February 1999, Sydney Airports Corporation, p. 2.