Aer Lingus has expressed serious concerns about the move by the Irish Aviation Authority to impose a seats cap on the winter schedule at Dublin airport.
Extracts from their correspondence read:
“This inconsistency in approach by the IAA now risks causing significant and irreparable harm to Aer Lingus by impeding its growth plans for summer 2025 and beyond (which are well known to the IAA and daa). “
“The Draft W24 Decision, if implemented, will have very significant financial operational and reputational impact on Aer Lingus. “
“In addition, the imposition of an artificial constraint on supply will inevitably result in significant price increases for consumers given the high level of demand for travel to/from Dublin Airport.”
“Being able to secure historic precedence from the slot pool for new slot series has provided the critical stability that is needed for airlines to make long term investment decisions which allow for growth and route development.”
“Implementing a radical change to that process (as is proposed in the Draft W24 Decision) at such short notice, puts that investment and growth opportunity at risk making forward planning impossible. “
“Aer Lingus has openly and consistently communicated to the IAA and daa our planned investment in modernising and expanding our Dublin based fleet”
“To this end, we have made investments in the order of hundreds of millions of dollars. Aer Lingus has already taken delivery of eight A321 NEO-LRs and four A320 NEOs aircraft. We also have orders for four further A320 NEO aircraft for delivery in 2024 and 2025 and for six A321 NEO-XLR aircraft for delivery between late 2024 and summer 2025”
“We are therefore extremely concerned about the potential impact of the Draft W24 Decision on this planned growth”
“Even if this is the case, the Draft W24 Decision if implemented will likely have a significant impact on the availability of ad-hoc slots which have historically formed a core part of the Aer Lingus flying programme. Ad-hoc slot flying programmes during the winter season would typically include, for example, Christmas operations to Lapland, flights for high profile sporting events such as the Six Nations Championship, international soccer fixtures and the Cheltenham festival, as well as additional flights.”
“Aer Lingus aircraft based at Dublin Airport can only be sustainably flown to and from Dublin whereas other operators, not based at Dublin, have alternative options to deploy aircraft on other routes. “
“We therefore consider the Draft W24 Decision to be discriminatory in nature as it will disproportionately affect Aer Lingus’ operations.”
A separate submission by Emerald Airways:
“This Draft Determination will result in airlines unwinding their Winter schedules, driving up fares and decreasing choice for the consumer”
“Emerald Airlines as the largest regional airline and one of the biggest contributors of transfer passengers at the Dublin Airport hub emphasises its position that it does not agree with the implementation of any measure to restrict growth at Dublin Airport while the ambiguous 32mppa Conditions referenced in the draft decision awaits a court ruling.”
“The proposed mechanism for estimating an appropriate seat cap has been established without any consultation or input from The Coordination Committee or specific member airlines.”
“The draft determination notes that the total incoming historic seat count from W23 is just under 14.3m seats, however we respectfully point out that airlines are still reviewing their Slot Historic Listings (SHL).”
“Specifically in the case of Emerald Airlines, our internal SHL review noted 132 slots which were eligible for JNUS- Justified Non-Utilisation of Slots under Article 10.4 of the EU Slot Regulation 95/93. These 132 slots amount to 9,500+ extra seats being allocated to the Emerald Airlines SHL by the airport coordinator.”
“Furthermore the Draft Determination fails to recognise the unfair penalising a Seasonal Terminal Seat Capacity constraint will have on year-round operators at Dublin Airport. For an airline such as Emerald Airlines with a low seasonality index, our operations fluctuate little between the Summer and Winter months. “
See more at
https://www.iaa.ie/commercial-aviation/economic-regulation/slot-allocation/documents—slots
