6 Threats to Regional Aviation
Additional cost burden
Air services will be taxed
Carbon Tax proposed to be $23 per mt CO2 equiv
Rex Consumption approx. 115,000 mt CO2 pa
No shielding for regional air services
Regional air services should be shielded at 100%
En Route Scheme
Rex thin routes potentially affected once rebates stops: Taree, Grafton, Melbourne/Griffith, Bathurst, Moruya, King Island and Merimbula Security Screening
Required for aircraft above 30t (E170)
From 1 July 2012 for aircraft above 20t (Q400)
Not required for SAAB 340 unless within legislated 30 minute window Regional passengers still pay for security at airports where facilities are shared with large aircraft Cost of Security
Infrastructure costs between $1m and $5m
Capital and running costs add $20 to $30 to the airfare for regional ports Double this for thin routes making them unviable
Regional aircraft already have hardened cockpit doors to prevent hijacking Security screening should be risk based
Intl Flights and major airports do not pay although consuming considerable CASA resources Regionals are paying disproportionately
Increase to Rex alone was $300k p.a.
RAAA member airlines an extra $2.8m p.a.
Funding of Regulators should be provided out of consolidated revenue and not by industry as with the Office of Transport Security, state rail authorities and the ACCC etc CASA Proposal on New Technology
CASA Discussion Paper
Ignored industry/Air services official consultation process through ASTRA Mandates expensive new technology in older regional aircraft Prohibitive cost (Rex SAAB fleet >$12m)
Not practical for all older aircraft (Rex may be forced to retire 19 seat Metros) & may result in the closure of some regional airlines No cost/safety benefit case
Some technologies have a benefit for regional aircraft (e.g: approaches with vertical guidance, ADSB OUT) The most expensive have little or no benefit (e.g: Dual GPS receivers, new collision avoidance sys.) Due process needs to be followed to get the most cost effective solution without crippling the industry or closing down some operators 4.1 Security
The anomalies recognised in the green paper with respect to only jet aircraft requiring screening do need to be addressed. Rex supports the methodology of aircraft speed, weight, fuel load and passenger numbers being the trigger point for passenger screening. If a more simplistic model was to be adopted Rex would support the seating capacity as being an appropriate criterion with 60 seats being an acceptable cut-off. Rex would not support screening for smaller regional aircraft (less than 60 seats) as the cost per passenger of such screening would be prohibitive. Small Regional airports do not have sufficient passenger and aircraft movement rates to recover these costs at the same cost per passenger as the larger airports with greater passenger numbers. If all costs are forwarded on to the passenger, the regional passenger will pay a significantly higher cost than the passenger in the major city airport. It is noted that this fact is recognised in the green paper. Within the Rex network, we estimate that fully 30% of our routes would no longer be commercially viable if charges for security screening were to be passed back to passengers. This would represent a significant blow to these communities. Rex submits that all security measures must be employed commensurate （相称） with the associated risk to each individual locality. While broad guidelines for screening may be based on aircraft type, the requirement for screening should be location and risk specific rather than aircraft specific. For example if there was only one medium jet aircraft movement per week at a particular location it may be decided after risk assessment that screening was not required. The same logic should be applied to large aircraft charter flights. Where there is a large...