National Civil Aviation Policy ICRA RESEARCH SERVICES

Contacts:
“Flying to tier-II cities to get affordable, subject to implementation hurdles; Subrata Ray
+91 22 6114 3408
New airlines to gain a space in international skies faster” subrata@icraindia.com

Kinjal Shah
+91 22 6114 3442
kinjal.shah@icraindia.com

Anand Kulkarni
+91 20 2556 1194
anand.kulkarni@icraindia.com
 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

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 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.

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 NATIONAL CIVIL AVIATION POLICY
Regional connectivity is the key focus; new airlines to fly international earlier than anticipated

Special Comment June 2016

The Policy
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.

Airlines
Positives
 Easier international flying norms for new airlines
 Fiscal support for flying on regional routes
 Better infrastructure
 Lower airport and other related charges
Negatives
 Increased competition for international routes
 Changes in RDG1 – marginally higher capacity
requirement on Cat II/ IIA routes
Passengers
Positives
 Strong regional connectivity at affordable prices –
target fare of Rs. 2500 for one hour flight
 Improved options for international flying
 Higher safety standards
Negatives
 Levy on Cat-I and Cat-III routes to increase fares;
however, would not materially impact demand

National Civil
Airports Aviation Policy -
Who is gaining?
Positives
 Regulatory clarity with hybrid-till to be adopted
uniformly for tariff Challenges
 Fiscal support for strategic airports  Speedy no-frills airport
 Regional connectivity to boost performance of development
more number of airports  Participation of states in
RCS
Negatives  Timely receipt of fiscal
 Viability of airports in the context of hybrid-till funding support for RCS
model and lower airport charges  Financial viability of
airports
Support Services
Positives
 Policy level support and ease of doing business for
MROs
 Improved ground handling services
 Policy level support for cargo operations
Negatives
 Impact on profitability of GHAs with increased
competition and no rationalisation of royalties and
other charges levied

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

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

Support structure Rs. 2,500 for a distance of 500 kms to 600 kms
(equivalent to about one hour of flight) on RCS routes.
Gainers:
 Regional Passengers The target is proposed to be implemented by a
Central Stake-
comprehensive plan involving support from central
Losers:
Support Target holders
and state governments, new infrastructure
 State Governments
Fare Rs. development and financing support.
 Cat-I Passengers
2500

•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
Central 80:20 ratio (90:10 for north eastern states)
Government •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

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

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

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

Infrastructure •Explore possibilities of PPP route for airport development

•No airport charges; no landing, parking and terminal navigation landing charges for 10 years
Stakeholders •Nominal route navigation facilitation charges for 10 years

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 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

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 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
Gainers:  The operators may additionally carry out domestic charter operations
 Regional Passengers  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

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.

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

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
Gainers: capacity, whichever is higher, for domestic operations. No restriction on number of years of operations
 New Airlines  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 Proposed Expected Expected start of Expected Start of

FY2016 addition in fleet as in international international
FY2017 FY2017 operations 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

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 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

3
Gainers: Cat-I routes Predefined 12 routes Addition of new routes having flying distance of 700
 Cat-II cities kms or more, average seat factor of 70% and annual
traffic of 5 lakh passengers
Losers: - Rationalization of Cat-I routes every five years
 All the airlines 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%

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.

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 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-
Gainers: aeronautical revenue
 Airlines  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

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.
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 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

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 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

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 Other key policies: Air Cargo and Ground Handling

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
Gainers:
 Domestic airlines and helicopter operators will be free to carry out self-handling themselves or through their
 Airlines own subsidiaries
 Hiring of equipment from outside agencies permitted; hiring of employees through manpower suppliers not
Losers:
allowed
 Ground Handling Agencies
 Airport Operators 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

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 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

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 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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