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ICRA RESEARCH SERVICES

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National Civil Aviation Policy

“Flying to tier-II cities to get affordable, subject to implementation hurdles; New airlines to gain a space in international skies faster”

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ICRA Limited P a g e | 2

What’s Inside

I. The Policy: Who is gaining?

II. Regional Connectivity: Affordable regional flying through fiscal support to airlines and development of no-frills airports

III. Scheduled Commuter Airlines: New category of airlines to boost remote connectivity

IV. The 5/20 rule: New airlines can fly international earlier than previously anticipated timeline

V. Route Dispersal Guidelines: Balanced remote connectivity plans of the government to impact profitability of airlines

VI. Airports: Positive intentions about policy level support

VII. Maintenance, Repair and Overhaul: A high potential industry to get a boost from policy reforms

VIII. Code-share agreements: Enabling seamless connectivity for passengers, without making investments in operating own aircraft

IX. Other key policies: Air Cargo and Ground Handling

X. Other key policies: Helicopters and Aviation Security, immigration and Customs, Bilateral traffic rights

XI. Other key policies


Glossary & Definitions

AAI: Airports Authority of India

ASKM: Available Seat Kilometers – A measure of a flight’s passenger carrying capacity. It is calculated by multiplying the number of seats on

an aircraft by the number of kilometers flown

ATF: Aviation Turbine Fuel

Codeshare: A term used to describe an arrangement where one airline sells seats (the marketing carrier) on a flight operated by another

airline (the operating carrier). Both airlines display their respective flight numbers.

DFC: Domestic Flying Credits

GHA: Ground Handling Agency

MoCA: Ministry of Civil Aviation

MRO: Maintenance, repair and overhaul

RCS: Regional Connectivity Scheme

RDG: Route Dispersal Guidelines

SCA: Scheduled Commuter Airlines

VGF: Viability Gap Funding

Yield: Revenue per unit. E.g. Revenue per passenger.


The Policy

NATIONAL CIVIL AVIATION POLICY

Regional connectivity is the key focus; new airlines to fly international earlier than anticipated Special Comment June 2016

Positives

Easier international flying norms for new airlines

Fiscal support for flying on regional routes

Better infrastructure

Lower airport and other related charges

Positives

Strong regional connectivity at affordable prices –

target fare of Rs. 2500 for one hour flight

Improved options for international flying

Higher safety standards

Positives

Regulatory clarity with hybrid-till to be adopted

uniformly for tariff

Fiscal support for strategic airports

Regional connectivity to boost performance of

more number of airports

Positives

Policy level support and ease of doing business for

MROs

Improved ground handling services

Policy level support for cargo operations

Negatives

Increased competition for international routes

Changes in RDG1 – marginally higher capacity

requirement on Cat II/ IIA routes

Negatives

Levy on Cat-I and Cat-III routes to increase fares;

however, would not materially impact demand

Negatives

Viability of airports in the context of hybrid-till

model and lower airport charges

Challenges

Speedy no-frills airport

development

Participation of states in

RCS

Timely receipt of fiscal

funding support for RCS

Financial viability of

airports

Negatives

Impact on profitability of GHAs with increased

competition and no rationalisation of royalties and

other charges levied

Airports Support Services

Airlines

Passengers

National Civil

Aviation Policy -

Who is gaining?

1 Route Dispersal Guidelines (RDG), current clauses, proposed changes and their impacts are explained in subsequent sections

The Ministry of Civil Aviation (MoCA) released the National Civil Aviation Policy (NCAP) on June 15, 2016, after incorporating feedback from the various

stakeholders on the Draft policy which was released on October 30, 2015. The NCAP is aimed at providing a favourable eco-system and a level playing field

to various stakeholders like Airlines Airports, Cargo, Maintenance Repairs and Overhaul (MRO) services, and to make flying affordable for the masses.


Regional Connectivity: Affordable regional flying through fiscal support to airlines and development of no-frills airports

One of the prime focus areas of the NCAP is improving regional connectivity. The MoCA proposes a Regional

Connectivity Scheme (RCS) to be implemented from Q2 FY2017 in order to boost penetration into remote places.

Impact:

•Viability gap funding (VGF) indexed to ATF prices and inflation based on competitive bidding and necessity of the route - shared between MoCA and State Governments in 80:20 ratio (90:10 for north eastern states)

•Regional connectivity fund (RCF) will be created to provide VGF, to be funded by a levy on domestic routes except Cat II, IIA and RCS routes and aircraft below 80 seats

•Service tax on 10% of the taxable amount, excise duty on ATF at 2% for three years

Central Government

•Reduce VAT on ATF to 1% or less for 10 years

•Provide free land, multi-nodal connectivity, free police and fire services, concessional power, water and utilities

State Governments

•Revival of unserved/underserved airstrips with an indicative cost of Rs. 50-100 crore

•Explore possibilities of PPP route for airport development Infrastructure

•No airport charges; no landing, parking and terminal navigation landing charges for 10 years

•Nominal route navigation facilitation charges for 10 years Stakeholders

Gainers:

Regional Passengers

Losers:

State Governments

Cat-I Passengers

Target Fare Rs.

2500

Central Support

State Support

Infra-structure

Stake-holders

TARGET: An all inclusive fare (indexed to inflation) of

Rs. 2,500 for a distance of 500 kms to 600 kms

(equivalent to about one hour of flight) on RCS routes.

The target is proposed to be implemented by a

comprehensive plan involving support from central

and state governments, new infrastructure

development and financing support.


Regional Connectivity: Affordable regional flying through fiscal support to airlines and development of no-frills airports

Impact:

Proposed policy level support is a positive for enhancing the reach

Development of existing air strips into no-frills airports will play a crucial role in success of the scheme

Levy on other domestic routes is expected to be minimal and would not materially pricing of other routes

Challenges:

? Requirements from states for lower taxes, free land and VGF support might hinder the broad based

acceptance of the scheme by States. Also, lack of unanimity amongst contiguous States, especially in regions

like North East, may impact implementation

? Success of the scheme hinges on timely implementation of no-frills airports development

? Enthusiasm from the airlines to participate considering the low target fares and timely implementation of

mechanism to achieve the target fare

? Dependence of airlines on government support and possible impact on liquidity position due to delayed

receipt of funding


Scheduled Commuter Airlines: New category of airlines to boost remote connectivity

The MoCA has proposed a new category of airlines which are essentially lower capacity carriers connecting remote

locations. The airlines are expected to be low cost carriers given that they would benefit from relaxed guidelines, fiscal

support and probable subsidy support. Key requirements and incentives for the SCAs are given below.

Shall have aircraft having maximum All Up Weight (AUW) not exceeding 40 tons

The minimum equity capital requirements would be on the basis of number and size of aircraft in the fleet

There would be a prescribed minimum number of aircraft to maintain regularity of operations

The operators may additionally carry out domestic charter operations

Permitted to have code share with other domestic and international airlines

Impact:

Expected low paid-up capital requirement may increase interest of participants

Improved commercially viable operations due to potentially higher capacity utilization levels with small sized

aircrafts

To improve remote connectivity in the country

Challenges:

? Adherence to safety guidelines by comparatively smaller airlines

? Nuances of the policy (primarily about route dispersal guidelines, RDG2) will have to be understood before

private players start investing

Gainers:

Regional Passengers

2 Taking into account the need for connectivity to remote regions in the country, the MoCA has laid down Route Dispersal Guidelines. According to these guidelines, all

scheduled operators are required to deploy in the North Eastern region, Jammu & Kashmir, Andaman & Nicobar Islands and Lakshadweep (Category-II routes) at least 10% of their deployed capacity on trunk routes (Category-I routes, explained in subsequent sections). Further, at least 10% of the capacity on Category-II routes is required to be deployed for connectivity exclusively within these regions. 50% of the capacity deployed on Category-I routes is to be deployed on routes other than Category-I and Category-II routes i.e. Category-III routes.


The 5/20 Rule: New airlines can fly international earlier than previously anticipated timeline

Gainers:

New Airlines

The NCAP has modified the 5/20 rule3 with a new one i.e. 0/20. Details of the new rule are given below.

All airlines can commence international operations provided that they deploy 20 aircraft or 20% of total

capacity, whichever is higher, for domestic operations. No restriction on number of years of operations

The capacity will be calculated in terms of average number of seats on all departures put together

Schedule of airlines will be the basis for monitoring, assuming six departures per day for an aircraft

Impact:

A positive for new airlines as they can commence international operations earlier than five years, provided

they can ramp up the fleet rapidly; expected to take atleast two to three years

Earlier rule required airlines to have a fleet of 20 aircraft to fly international routes, without any riders on

deployment of fleet for domestic operations. The new rule has requirement of deploying minimum 20 aircraft

on domestic routes; hence, the carriers can start meaningful international operations only after achieving

sizeable fleet over and above 20 aircraft.

New Airlines Fleet as on

FY2016

Proposed

addition in

FY2017

Expected

fleet as in

FY2017

Expected start of

international

operations

Expected Start of

international

operations

Before NCAP Before NCAP Before NCAP After NCAP

AirAsia India 6 2 8 June 2019 2-3 years from now

Vistara 9 4 13 January 2020 2-3 years from now

Source: ICRA research

3 The 5/20 rule required domestic airlines to complete five years of domestic flying and have a fleet of 20 aircraft before they can operate on international routes


Route Dispersal Guidelines: Balanced remote connectivity plans of the government to impact profitability of airlines

Taking a note of increased traffic on major routes, the policy suggests addition of more routes in Cat-I4, which in turn

will increase the capacity deployed on remote locations i.e. Cat-II and IA routes. The details of changed clauses are

given below.

Earlier clause New clause

Cat-I routes3 Predefined 12 routes Addition of new routes having flying distance of 700

kms or more, average seat factor of 70% and annual

traffic of 5 lakh passengers

- Rationalization of Cat-I routes every five years

Cat-II routes 10% of Cat-I routes 10% of Cat-I routes

- New routes for Uttarakhand and Himachal Pradesh

added to Cat-II

Cat-IIA routes 1% of Cat-I routes 1% of Cat-I routes

Cat-III routes 50% of Cat-I routes 35% of Cat-I routes

Impact:

Increase in Cat-I routes will adversely impact airlines’ performance as there would be proportionately

increased requirements for flying on less profitable (Cat-II & IIA routes) category routes

Reduced requirement for Cat-III routes will be beneficial for the airlines as they can discontinue operations on

some of the loss-making routes in Cat-III (provided the reduction in percentage requirement is irrespective of

the airline’s participation in RCS)

Overall, these proposed changes in RDG would be marginally negative for the airlines – with capacity

deployment on loss-making/ less profitable Cat-II & IIA routes increasing from current 6.8% to 7.5%

Gainers:

Cat-II cities

Losers:

All the airlines

4 Category I routes earlier covered 12 city pairs connecting metropolitan cities (Mumbai-Bengaluru, Mumbai-Kolkata, Mumbai-Delhi, Mumbai-Hyderabad, Mumbai-Chennai,

Mumbai-Thiruvanathapuram, Kolkata-Delhi, Kolkata-Bengaluru, Kolkata-Chennai, Delhi-Bengaluru, Delhi-Hyderabad and Delhi-Chennai); Category II routes earlier covered routes connecting the North-Eastern Region, Jammu and Kashmir, Andaman and Nicobar Islands and Lakshadweep with cities in Category I and Category III routes; Category IIA routes earlier covered city pairs within the North-Eastern Region, Jammu and Kashmir, Andaman and Nicobar Islands, Lakshadweep, and Cochin-Agatti-Cochin; and Category III routes cover any city pair that does not fall in Categories I, II and IIA.


Airports: Positive intentions about policy level support

The MoCA has articulated the need to reduce airport charges in order to make aviation industry viable. Key provisions

regarding airport policies are mentioned below.

MoCA will coordinate with stakeholders to identify ways to bring down airport charges, while abiding by

existing agreements; it will endeavour to achieve cost efficiency of future airport projects

Tariff determination on hybrid-till model5, cross subsidization of aeronautical revenue with 30% of non-

aeronautical revenue

If tariff comes out to be excessive, then ways to keep the tariff reasonable and spread the excess amount over

a longer period in the future will be explored

Explore ways to unlock the potential of airport land by liberalizing end use restrictions

MoCA will coordinate with ministries and state governments to provide multi-modal connectivity

Minimum level and standard of cargo facility to be ensured in future airport developments

AAI will take up new airport projects subject to:

Non-zero IRR for non-RCS projects

State/central government providing VGF for strategically important projects

Free land from state government without equity treatment

Availability of sufficient land for commercial use

AAI may be suitably compensated by the Central government and/or State governments or the private airport

operator in case a new greenfield airport is approved in future within a 150 km radius of an existing AAI

airport, provided the AAI airport is not reaching the saturation point

AAI may be given the right of refusal or equity participation (26% to 49%) in the new airport or AAI may be

allowed to form a JV with the respective State government

Impact:

Reduced regulatory uncertainty with uniform adoption of hybrid-till and policy level support The policy shows intention of reducing charges and fees at airports, thereby benefitting the airlines

Hybrid-till model of tariff determination for new airports to help balance the interests of airport operators as well as passengers

Challenges:

? Clarity on whether the hybrid-till model, coupled with lower airport charges would make the airport operations viable, or whether the same would be subsidized by the State/ Central Governments

? No clarity on dispute redressal mechanism for conflicts between AAI and private players

Gainers:

Airlines

5 Under the hybrid till model, the airport operator adds a part of the non-aeronautical (duty-free shops, hotel, restaurant, among others) revenue and the total revenue

from the aeronautical (landing, parking and ground handling charges) side to compile total earnings.


Maintenance, Repair and Overhaul: A high potential industry to get a boost from policy reforms

The MRO business of Indian carriers is estimated to be around Rs. 5000 crore, 90% of which is currently spent outside

India – in Sri Lanka, Singapore, Malaysia, UAE etc. Thus, with a view to develop India as an MRO hub in Asia, attracting

business from foreign airlines, the following steps are proposed.

No VAT on MRO services

No Customs Duty on aircraft tools and tool-kits

Storage of duty-free spare parts imported by MROs extended to three years from the current one year

Advance exports of serviceable parts enabled for providing exchange/ advance exchange of imported

unserviceable parts

Prompt visas to be provided to foreign MRO experts, especially in cases of an Aircraft on Ground (AOG)

situation where temporary landing permits shall be issued

Provision for adequate land for MRO service providers to be made in all future airport/ heliport projects

having potential for MRO services

No levy of airport royalties and additional charges on MRO service providers for a period of five years from

June 15, 2016

Impact:

Elimination of various taxes and duties would facilitate developing India as an MRO hub, not only servicing

Indian airlines, but also foreign airlines

Simplification of approval process will help fast track the services

Growth in the domestic MRO industry will have the dual effect of augmentation of revenues of airport

operators as well as reduction in costs for the airlines


Code-share agreements: Enabling seamless connectivity for passengers, without making investments in operating own aircraft

Code share agreements A Code-share agreement between two airlines allows one airline (the marketing carrier) to sell seats on a flight operated by another airline (the operating carrier), to enable seamless connectivity for passengers. Both airlines display their respective flight numbers.

Domestic codeshare points in India shall be liberalized with Air Service Agreements (ASA) framework

Indian carriers will be free to enter into code share agreements with foreign carriers for any destination within

India available under ASA

International codeshare between Indian and foreign carriers will be completely liberalized subject to ASA

No prior approval from MoCA will be required – Indian carriers just need to inform MoCA 30 days prior to

starting the codeshare flights

Impact:

The airlines will be able to expand their offerings in terms of number of destinations, and in some cases, the

flight timings that they can offer potential customers, without having to operate their own aircraft


Other key policies: Air Cargo and Ground Handling

Gainers:

Airlines

Losers:

Ground Handling Agencies

Airport Operators

Air Cargo Given its importance from a ‘Make in India’, e-Commerce and exports perspective and the high employment potential

of the segment, the policy aims at promotion of both domestic and international Air Cargo.

Air Cargo co-located with an airport will be accorded ‘infrastructure’ status

Dwell time of domestic air cargo to be reduced to 48 hours by December 31, 2016 and 24 hours by December

31, 2017; dwell time for exports to be reduced to 12 hours and 8 hours by December 31, 2016 and December

31, 2017, respectively

Paper-less processing of air cargo; customs procedures to be simplified

Endeavour to have all relevant Central Government authorities under one roof, at the cargo terminals; single

window clearance system at cargo terminals for prompt clearances

Low user charges to be levied on cargo facility so that it does not become an entry barrier

Airport operators to be encouraged to provide space on 10-year lease to operators of express cargo and

freighters who may then develop dedicated infrastructure

Impact:

According infrastructure status will help speedy movement of cargo on the back of single-window clearance

Increased revenues from air cargo will help airlines subsidize the cost of passenger tickets and thus take flying

to masses

Ground Handling All major airports to have atleast three Ground Handling Agencies (GHAs), including Air India’s subsidiary/ JV

at an airport to ensure fair competition

Air India’s subsidiary/ JV to match the lowest royalty/ revenue share offered by other third-party GHAs

Domestic airlines and helicopter operators will be free to carry out self-handling themselves or through their

own subsidiaries

Hiring of equipment from outside agencies permitted; hiring of employees through manpower suppliers not

allowed

Impact:

While the airlines will benefit from increased competition, it will have a negative impact on the revenues of

GHAs as also the airport operators

With no rationalisation of royalties and other charges levied on GHAs, the profitability of GHAs will be

impacted


Other key policies: Helicopters and Aviation Security, immigration and Customs, Bilateral traffic rights

Helicopters Development of atleast four heli-hubs across the country

Helicopters under Helicopter Emergency Medical Services (HEMS) operations to not require any operational

clearance, including landing at accident and emergency sites; no landing and Route Navigation and Facilitation

Charges (RNFC) will be levied for HEMS operations

Liberalised flying of helicopters below 5000 feet – no prior ATC clearance required

Airport charges for helicopter operations will be suitably rationalised

Impact:

Infrastructure development and rationalisation of airport charges for helicopter operations will promote

helicopter usage, which will in turn enhance remote area connectivity, tourism, disaster relief and emergency

medical evacuation operations

Aviation Security, Immigration and Customs Performance norms to be developed for speedy passenger processing and grievance handling

Indian carriers allowed to mobilise their surplus capacity to provide security services to other domestic airlines

Private security agencies to be employed for non-core security functions

Impact:

Implementation of global best practices will ensure faster turnaround of passengers at the airports, thereby

benefiting everyone in the chain of operations

Bilateral traffic rights

The Government will enter into an ‘Open Sky’5 Air Service Agreement on a reciprocal basis with SAARC

countries and countries located entirely beyond 5000 km radius from New Delhi

Open skies agreement with countries lying partly or fully within 5000 km radius from New Delhi, where the

designated carriers in India have not fully utilized 80% of their capacity entitlements, but foreign carriers have

utilized their bilateral rights; a method will be recommended for the allotment of the additional capacity

entitlements

Impact:

Liberalisation of bilateral rights will facilitate greater ease of doing business and wider choice to passengers


Other key policies

Aeronautical ‘Make in India’ Fiscal and monetary incentives and fast-track clearances to be provided to global OEMs and their ancillary

suppliers

An incentive package to be considered to nullify the cost differential of made-in-India aircraft and components

Sustainable Aviation Roll-out of Airport Collaborative Decision Making (CDM) to reduce on-ground and aerial congestion

All equipment operating within the airport environment to be in compliance with latest emission norms by

April 01, 2017

Ground handling vehicles to use alternate fuels, including LPG/ CNG vehicles, low emissions vehicles, hydrogen

vehicles and electric vehicles to provide significant local air quality (LAQ) emission benefits

Impact:

Above listed energy efficiency and conservation plans are aimed at creating an eco-system for developing a

sustainable Indian aviation industry

Other key points After a detailed skill gap analysis, MoCA to facilitate training and skill development, with an attempt to bring

down the overall cost on a self-sustaining basis

MoCA to provide financial support for Type-rating of pilots having a commercial pilot licence (CPL) with effect

from FY2018

Promote the use of sea planes for growth of tourism and regional connectivity

Ground handling, Catering and Aircraft fuelling to be included under Essential Services Maintenance Act, 1968


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