President of the Council of Ministers
of the Republic of Poland
Minister of Infrastructure
of the Republic of Poland
OPEN LETTER OF THE AVIATION INDUSTRY
ON THE DRAMATIC INCREASE IN CHARGES RELATED TO THE PROVISION OF AIR NAVIGATION SERVICES IN POLAND, AND IN PARTICULAR AT POLISH REGIONAL AIRPORTS
The Civil Aviation Authority has submitted to the managing bodies of airports in Poland and to air carriers operating in Poland the revised „Performance Plan for Air Navigation Services 2020-2024”.
The provisions of this document came as a great surprise to all stakeholders in the aviation industry and are in flagrant contradiction to the declarations of support for rebuilding the aviation market in Poland as a result of the COVID-19 pandemic, as well as support for Polish regional airports. They also undermine the fundamental principles of the European Union's cohesion policy, which has the objective of levelling out economic and social playing field in the regions of the Community.
The Polish Air Navigation Services Agency (PANSA) collects two charges related to the provision of air navigation services in Poland. These are: Terminal Navigation Charge, i.e. the fee charged by PANSA for handling aircraft during take-off and landing at each airport.
The second one is Enroute Navigation Charge collected for each flight of an aircraft in airspace controlled by air traffic control services (this charge depends on the distance covered in the airspace).
In Poland, there have been two terminal charging zones for several years:
a) the first one for Warsaw main airport - the Frederic Chopin Airport in Warsaw;
b) the second for all other thirteen certified Regional Airports.
The tabled proposal dramatically, unevenly, and in a manner contrary to competition, proposes to increase the following charges from 1 January 2022:
1. Terminal Navigation Charge (for a single flight operation):
a) for the Frederic Chopin Airport in Warsaw, from PLN 343.08 in 2021 to PLN 58 - an increase of PLN 181.50 (by 53%);
b) for Regional Airports from PLN 791.12 for 2021 to PLN 1,347.76 - an increase of PLN 556.64 (by 70%);
2. Enroute Navigation Charge – from PLN 195.70 for 2021 to PLN 245.81 - an increase of PLN 50.11 (by 26%).
Such a drastic increase affects the competitiveness of the Polish aviation market within the single European sky, and will also result in Polish Regional Airports becoming uncompetitive. This in turn will cause their capacity to be underused, and will also directly contribute to blocking recovery of aviation and passenger traffic in the period after the COVID-19 pandemic.
Already before that (ahead of the COVID-19 pandemic), the applicable charges in Poland basically discriminated against Polish Regional Airports, as in 2019 the average Terminal Navigation Charge rate in Europe was EUR 166, when for the Frederic Chopin Airport in Warsaw, it was EUR 90 and for Polish Regional Airports, it was EUR 181.
We would also like to draw your attention to the fact that the prevailing system in Europe is ONE ZONE for Terminal Navigation Charge for all airports in a specific country (83% of countries), which increases the competitiveness of the domestic aviation market against other (mainly neighbouring - Germany, Czech Republic, Baltic States) national systems. A comparison of the situation from before the COVID-19 pandemic of three (out of 5) countries with more than one terminal charging zone shows that:
a) in Italy, the difference in the charge between the first and the second zone was approximately EUR 7;
b) in France, the difference in the charge between the first and the second zone was EUR 40;
c) w in Poland, the difference in the charge between the first and the second zone was EUR 91.
Under the new proposal, the difference in charges between the zones will be 823.18 PLN or 185 EUR which is the highest in Europe!
Not only will this deprive Poland's Regional Airports of the possibility of recovering from the enormous losses in the post-pandemic period, but it will also diminish the competitiveness of our aviation market in general.
The suggested increase in charges will not only cause a reduction in airline services from Polish Regional Airports, but is also likely to be passed on to the passengers through higher air fares.
Do you really want to additionally "tax" passengers of Polish Regional Airports in these times?
The airlines, airports, tour operators and other stakeholders in the Polish aviation market, signed below, also representing millions of our passengers, PROTEST against the repeated passing on to us of the costs of the COVID-19 pandemic and against the particular discrimination against Polish Regional Airports.
Counting on the support of the recovery of the aviation sector in Poland and the understanding of the specific situation of the aviation market stakeholders, we declare our will of close cooperation in the preparation of new, amended rules, which will act as a development factor not only of regional, but above all national importance.
Signatories of the Appeal:
- Tomasz Kloskowski – CEO Gdańsk Airport
- Leszek Chorzewski – Acting CEO Modlin Airport
- Anna Midera – CEO Lodz Airport
- Dariusz Kuś – CEO Wrocław Airport
- Tomasz Moraczewski – CEO Bydgoszcz Airport
- Maciej Dziadosz – CEO Szczecin-Goleniów Airport
- Tomasz Kądziołka – CEO Olsztyn-Mazury Airport
- József Váradi – CEO Wizzair Group
- Michał Kaczmarzyk – CEO Ryanair Sun S.A. (Ryanair Group)
- Andrzej Kobielski - Commercial Direcctor Enter Air
- Ton Jochems - Senior Manager Groundservices KLM Cityhopper
- Grzegorz Polaniecki - General Director Enter Air
- Jan Szczepkowski – CEO SprintAir
- Jarosław Chłopecki – Vice President SprintAir
- Piotr Henicz - Deputy President ITAKA Tours / Deputy President Polish Tour Operators Association / Deputy President Polish Chamber of Tourism
- Maciej Nykiel - CEO Nekera Travels
- Grzegorz Baszczyński – CEO Rainbow Tours
- Wojciech Piotr Skwirowski – CEO Polish Airspace Foundation
- Tomasz Buraś – CEO DHL Express (Poland)
- Jan Szczepkowski – CEO SprintAir Cargo
- Jarosław Chłopecki – Deputy President SprintAir Cargo