72 citizens, 28 organisations and a handful of air crew – this is the final number of opinions that would shape the European Union’s views and position on how to organize the EU aviation market. As a result of poorly planned consultation and an ill-designed survey, the European Commission will now have to revise an important regulation – EU Reg. 1008/20008 – based on a handful of opinions.
At the launch of the consultation, ECA had alerted that the proposed survey is not an appropriate tool to identify possible loopholes in the Regulation. Neither the choice of the categories of respondents, nor the way the questions were formulated allowed for expressing properly opinions and describing accurately the acute problems in the industry. A quick glance shows the scope of the problems that were supposed to be addressed by the revision of this Regulation – atypical work, use of foreign crew on board of EU carriers, carriers with operational bases in several states thus operating through secondary establishments, Principal Place of Business of airlines, fair competition on taxation and labour, wet leasing provisions.
We don’t know who said what – was it crew or travellers, air carriers of tour operators that see a negative trend.
However, the questionnaire was primarily targeted at citizens and individual crew. Other categories of respondents - such as air carrier, airport, tour operator, travel association, passengers’ association, trade union, research organisations or public authorities - were also invited to take part in the survey or submit a contribution. As a result, the 28 organisations that filled in the survey are now a part of the total pool of answers. Their opinions – even if more relevant and well-informed – are on equal footing with any others. To illustrate: Over 45% of the respondents think that the safety of air services improved over the past 10 years, 33% see no change and 10% of the respondents are inclined to think it deteriorated. However, we don’t know who said what – was it crew or travellers, air carriers of tour operators that see a negative trend. No-one knows, no-one seems to care.
You wonder how can a multiple-choice questionnaire allow for describing the complex realities of a multibillion global industry? So do we. To illustrate – the subject of leasing provisions was covered only by two very short and simplified questions.
It does seem as if the EU Commission only checked the box “12-week long public consultation” which is required for any legislative proposal. But is also seems that just a handful of people care about European aviation.