CIVIL AVIATION POLICY

Introduction
Civil Aviation Sector is of National importance as it contributes significantly to the
process of development of the country with as a result of enhanced productivity and efficiency in
the movement of goods and services by providing access to safe, secure and affordable Air
services and world class infrastructure facilities. The most important contribution Aviation
makes to the economy is through its impact on the performance of other industries by enhancing
efficiency and competitiveness by offering most efficient and fast transportation facility. This
sector also contributes substantially to the GDP. Civil Aviation sector epitomizes modern,
resurgent and fast developing Indian Economy which is moving to be a super power of the world
in the near future. The contribution of Civil Aviation sector in providing employment
opportunities directly, indirectly and induced is immense. This sector gives fascinating
opportunities to an array of industries such as Airports, Airlines, Cargo, MRO, Ground Handling,
ANS, Retail business, Real Estate etc. One of the important induced effects of air transport is on
the tourism sector of an economy. There are great opportunities and the future is even more
exciting. Setting up of world class airport infrastructure facility and offering a most modern and
reliable Air connectivity together with integrated transportation connectivity holds the key.
The vast geographical expanse and terrain of India makes air transport a necessity and not the
luxury service as it was often perceived in the past. Air transport is the fastest and safest mode of
transport for relatively long distance. Total air passenger traffic in India has increased from 109
million in 2008-09 to 143 million in 2010-11. Available forecasts suggest that by 2020 air
passenger traffic will be around 290-300 million. To meet this huge air traffic demand, the
country will require approx. 350-400 operational airports across the country. This implies that
huge private investments will have to be attracted as AAI alone will not be able to raise the funds
(Rs. 60 - 70,000 Crores). Similarly, India is likely to have a 1,000 plus fleet strength of aircraft
requiring huge investment of approx. US $ 90 billion. In this respect, the effort taken by Ministry
of Civil Aviation to notify a National Civil Aviation Policy is highly commendable as it will
provide a blueprint and a road map/clear vision to all the stakeholders including the government
in understanding their respective roles for ensuring the growth and development of the sector in
the next decade .It is also extremely important that the policy should address the discrepancies
in the existing rules/acts within the Civil Aviation sector thereby removing scope for different
interpretations and to have cohesiveness in interpretation and implementing various
rules/regulations.

Our detailed comments on various issues are furnished below:

1.

AIRPORT:

Airports are a critical part of the transport infrastructure. It is important that Airport
Infrastructure gets developed in anticipation of meeting the future growth in demand for air
travel. Therefore, well planned, efficiently operating, modern world class airports are important
national assets. There is a vital need for the government to come up with the long term policy for
the Airport Sector. The policy issues highlighted for discussion by FICCI do not contain Airport
as one of the topic. It is very essential that a policy on the Airport must be part of the National
Civil Aviation policy particularly the policy on issues of private participation, Greenfield policy,
Brownfield policy, Cargo Policy, Hub Policy, development of non-metro airports and at Hilly
and Remote areas etc. The Policy must, most importantly, address the economic viability issues
of airports.
1.1

Civil Aviation Policy must ensure that airports are offered fiscal benefits similar to
industries, which includes benefits for certain number of years e.g. exemption from
Income Tax, Property Tax, Non Agricultural Tax (N.A. Tax), Electricity duty, Royalty on
minor minerals etc. Additionally, open land should be exempted from N.A. Tax and post
exemption period electricity duty should be as is applicable for industries and N.A. tax
should also be based on rates applicable on industries.
1.2 The policy objective must be to ensure sustainable airport capacity to meet the demand
forecasted for Passengers and Cargo traffic.
1.3 Ensure total safety and security of air transportation by introduction of state-of-art air
traffic technology, equipments and training facilities.
1.4 Develop Airport as a Multi-modal Transportation Hub, by integrating the Airport with
other modes of transport like Railway, Highway and Seaports to enable seamless
transportation across the country
1.5 Policy should consider granting infrastructure industry status to Airport sector.
1.6 A forward looking Greenfield Airport policy which encourages the investors and
developers to set up more and more Greenfield Airports in the country.
1.7 There should be a clear PPP policy on the airports.
1.8 Air Traffic control service may be allowed to be provided by licensed private operators.
1.9 More transparency needs to be on ATC/ANS pricing by incorporating international best
practices.
1.10 There is a need to have a clear and forward looking policy on Ground Handling services
by enhancing competition in the service by allowing professional ground handlers with
international experience.
1.11 Policy to improve Cargo handling facility at Airport is essential and also to develop cargo
handling capacity at all airports.
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1.12 A clear policy to encourage the commercial activities in the airport for optimization of
revenue from Non-Aeronautical Services.
1.13 Policy to upgrade the airport security system by systematically assessing aviation security
threats, risks and vulnerabilities at the airport by adopting modern technology
mechanism.
1.14 Clear policy on financing of Airport Infrastructure by incentivizing private participation,
making easy the source of finance such as debt, equity, external assistance, public bonds,
external commercial borrowing and also making easily available loans from
government/institutions.
1.15 Policy on commercialization of all the non-metro airports by allowing private
participation in both aero and non-aero activities.
1.16 Policy to have an unambiguous legislative framework for privatization of airports
allowing total flexibility and avoiding any intervention by any agency.
1.17 Approval policy for the Greenfield Airport, Brownfield Airport should be made easy for
private developers to take up the project work. Single Window concept to be
implemented.
1.18 The policy should clearly define the role of central and state government and civil
military cooperation.
1.19 Policy to develop human resources in the airport management. Civil Aviation industry
requires well trained and highly skilled workforce on a continuous basis.
1.20 Policy to have easy clearance of all environmental issues.
1.21 Policy to develop a forward looking investor friendly regulatory mechanism.
1.22 Policy to encourage and support the Indian Industry to acquire airports development and
operations abroad.
1.23 Clear land acquisition policy should be in place for setting up of airports in the country.
1.24 The policy should aim at facilitating continued investment by ensuring economic viability
of the Airport sector.
1.25 Progressive tariff regime Dual Till for all Airports.
2.

CARGO POLICY:

2.1 Trade in Airports/Aviation Sector is affected on account of several factors such as custom
clearance, warehousing issues and intervention of many agencies. Indian Air Cargo
industry is at an inflection point. Air Cargo through put has more than doubled in the last
decade. Air Cargo policy should focus on making India a preferred transhipment hub for
global air cargo movement. The right vision, road map, forward looking policy and
regulatory framework is essential for taking India to the rightful place in global air cargo
industry.
2.2 The processing time for major export handling activities / import cargo clearance are far
below the international standards. Restricted working hours for cargo clearance affects
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2.3
2.4

2.5

2.6
2.7
2.8
2.9

piling up of cargo and puts tremendous pressure on the capacity and cargo operations and
requires 24x7 cargo clearance working by all agencies such as Customs dept. and
Customs house agents etc. Hence a clear policy to streamline the regulatory procedures in
all the airports in order to reduce the dwell time and to have 24*7 cargo clearance
working/customs operations in all airports is essential.
Policy to minimize/eliminate manual intervention in all clearing process.
Policy to make all the custom activities free for the operators. Recent issue of imposing
Customs cost recovery on Greenfield Airports adversely affects the import / export
business to be withdrawn as any additional cost will adversely affect the trade. Moreover,
Customs being a sovereign function of the Govt. and the cost of that should be borne by
the Government and not be charged from the Operators.
Policy to enhance the efficiency of all the agencies working at the airports. Apart from
Customs, several other agencies are also responsible for clearance of goods at Airports
and they must improve their processes for easy and fast clearance. The clearance
process being extremely slow the capacity as well as throughput of Perishable cargo is
greatly impacted, besides inconvenience to the Importers.
Policy should be to improve efficiency through automated material handling system and
IT system, making paperless environment, e-freight etc.
There should be a clear policy on land acquisition near all the airports for expanding
cargo handling capacity.
Policy to improve road and rail connectivity of the air cargo terminal to have easy
transportation of goods, low cost of logistics and minimal wastage of perishable cargo.
Container Corporation (CONCOR) of India and other Integrated Container Depots
(ICDs) need to be encouraged to tie up with Airports to develop the latter to Multi-modal
Transportation Hub.

3. HUB POLICY
3.1 Policy should be framed to make all strategically located Indian Airports as Hub and
Spoke model to make them most efficient, cost effective, liable, safe, secure and
comfortable air travel to passengers. There are substantial economic gains which can be
derived from a Hub airport including improving employment opportunities.
3.2 The policy should be to have an integrated transport model connecting Seaport, Road and
Rail Transport and to certain extent Public Road transport utilities to make hub-spoke
model most efficient and cost effective by utilizing economies of both scale and scope
and provide passengers and cargo seamless connection and more efficient services.
3.3 The policy needs to position India as a global hub by effectively utilizing world class
airport infrastructure capacity to handle large movement of aircraft and augment trade
and tourism opportunities and to ensure seamless transition for the passenger and the
airline.
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3.4 Policy should be to facilitate a collaborative approach between both airports and airlines
to work in tandem to handle the international competition and the growing air passengers
and cargo movements. Hub-Spoke model provides both cost and demand advantage over
smaller networks.
3.5 Policy should be to coordinate various agencies including Immigration, Customs, CISF
etc. to make available the passenger convenience, connectivity/network etc. matching
international benchmarks/standards.
3.6 Plan for scheduled optimization by utilizing bilateral traffic rights available for all Indian
air carriers for expanding their global foot print.
3.7 A policy to allow visitors from all the friendly countries the facility of Visa on Arrival on
arrival in all the Indian Hub airports.
3.8 Policy to discourage direct connections to the foreign airlines to the non-hub airports
because it will be difficult to promote Indian airport as Hub specially when the rights are
being granted to foreign carriers to over fly the Indian Hub.
3.9 A series of taxes and duties are levied on the ATF that makes it expensive compared to
international industry average. As a result, ATF accounts for nearly 40% of the operating
cost of Indian Carriers. The Policy should aim to minimize taxes on ATF to promote
financial well being of airlines which will result in the overall growth of Aviation
industry.
3.10 India is one of the few countries imposing service tax on air tickets, due to which air
travel becomes a luxury rather than an integral mode of transport. The civil policy must
abolish this tax to promote air transport in India.
4.

SLOT POLICY

4.1 As per OMDA and SSA, the Airport operator is solely responsible for the management
and allocation of both domestic and international slots.
8.5.4 of OMDA agreement mentions:
The JVC (Airport Operator) is responsible for the management and allocation of aircraft
landing and timetable slots at the Airports, for both domestic and international traffic. JVC shall
allocate slots at the Airports in consultation with Airlines, in accordance with IATA Slot
Allocation Guidelines as issued and updated from time to time in a fair, reasonable and
equitable manner
8.11 of SSA Agreement mentions::

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Airport Operator shall have the final right to allocate slots at the Airports, subject to the same
being allocated fairly and not arbitrarily and shall use reasonable endeavors to accommodate
the relevant airline operators the slots allocated at the Existing Airport at the time of its closure.
Accordingly, slot allocation should be the prerogative of the airport operator.
4.2 Presently slots allocation is done as per the IATA Worldwide Slot Guidelines and also
various guidelines issued by MOCA/DGCA from time to time.
4.3 Civil Aviation Policy to be framed to protect the legitimate right of airports to allocate on
a fair, transparent and user friendly basis.
The slot policy must address the following issues:
a. The slot of those Airlines that are not operating flights continuously or irregularly for
7 days in a month must result into cancellation and no historicity to be given for
cancelled slots for the next season. The Airport Operator would however give a fair
opportunity to the carrier by seeking reasons for the non operation of the flight by that
carrier prior to the cancellation of the slot.
b. To prevent misuse of slots, a high penalty should be imposed on the Airlines, which
will ensure scarce resources are used most efficiently.
c. The Slots of the airlines who are regular defaulters in payments should be withdrawn.
d. In congested airports such as CSIA, where slots are a scarce resource, 95-5 rule
should be applied for grandfather rights, provided that the flights are operated within
+/- 15 minutes of STA/STD. It is advisable that when Airlines file slots they should
be taking into account the real block time and inherent constraints and delays in their
operational system. For instance, the European airports are migrating from 80-20 to
85-15 rule for better utilization of capacity. However, 80-20 rule may continue for all
other airports which are not congested.
e. The 95-5 rule should be applied on the size of the aircraft at congested airports like
CSIA. Therefore, the carrier should operate minimum 95% of the time the same size
as approved or bigger size of aircraft as filed.
f. Any changes by the airlines in the slots allocated for specific sectors with specific
aircraft type without the due approval of the airport operators should be considered as
a gross violation of approved slots. This will attract high penalty and result into
cancellation of slots.
Airlines operating any flight without the due approval of the airport operators shall result into the
imposition of high penalty. And the airport operator should have the right to stop such
operations.
5. BILATERAL POLICY

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Excessively liberal bilateral towards Middle-East, Singapore and Sri-Lanka allow the respective
carriers to leak traffic from non-metro airports. Most of the Bilaterals allow All Airports as
point of call thus do not support funneling of traffic from Metro Airports. So foreign Airlines
should be allowed to operate To & Fro Metro Airports only. A review on the bilateral therefore
is in the national interest. Also, the domestic carriers of Indian origin should be allowed to
operate to international sectors availing the unutilized seats granted to the national carrier (Air
India).
Majority of traffic rights granted to the designated carriers of India are either unutilized or
underutilized and those granted to foreign carriers are either fully utilized or are being
sufficiently utilized. This disparity in the usage of traffic rights is on account of various reasons
like:
Our national carrier is not in a position to fly on various sectors due to its financial
condition & aircraft availability.
Restrictive approach towards granting traffic rights to Indian Private carriers
Past allocation of traffic rights to foreign airlines
The Civil Aviation policy must focus on:
1. Liberalizing our current policies and enabling the Indian Private carriers to utilize the
available traffic rights granting additional rights on the sectors which are fully utilized by
both countries.
2. Restriction on granting of additional traffic rights to foreign carriers (especially from
Middle East).
3. No additional point of call in India to be granted to foreign carriers
4. Airport operator should be a part of the Bilateral Air Service negotiations.
5. Liberalization of code share agreements between Indian carriers (including private
carriers) and foreign carriers.
6. MARKET ACCESS POLICY
Civil Aviation market contributes significantly to the process of development of the country. It
also contributes to GDP substantially. All this demonstrate the significant footprint the Civil
Aviation sector has on the Indian economy. Considering the importance of this sector there
should be an easy entry and exit policy for the Civil Aviation sector. The policy must encourage
investment for both Indian and foreign investors. It must also ensure removal of all the
bottlenecks for easy access.
The market access policy in India is governed and monitored by Ministry of Civil Aviation,
Government of India. Market access to the designated carriers of foreign countries in India is
dealt through bilateral Air Service Agreements. Domestic market for Indian carriers is fully
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liberalised, however DGCA has laid down Route Dispersal Guidelines to ensure route
connectivity Pan India.
India has witnessed tremendous growth in air traffic for the last 5-7 years. This growth has been
due to the economic growth and emergence of LCC in India. However there are limitations for
India carriers (Private) to expand their network in international market. Government should
liberalise traffic rights for Indian carrier to access international markets.
7. LAND USE ISSUES
Land Policy should be aimed at balancing and facilitating land acquisition for various public
purposes including infrastructure development, industrialisation and other urbanisation but at the
same time meaningfully addressing the concerns of land owners. The land acquisition should be
aimed at infrastructure development in the country. Land acquisition and resettlement and
rehabilitation policy for infrastructure development must not be cumbersome and should not be
expensive. The scheme of compensation should not act as a barrier and burdensome to the extent
discouraging future infrastructure development activities. In PPP model infrastructure
development the responsibility of acquiring the land must be with the government and there
should not be any procedure of seeking consent of the inhabitants and exorbitant price and
cumbersome procedures. State/Central Government must acquire land and hand over the same to
developer at reasonable terms. Civil Aviation Policy should address all these issues.
8. FOREIGN DIRECT INVESTMENT (FDI)
The FDI policy should be to attract foreign investment in Indian Civil Aviation market. As far as
airport sector is concerned, the existing policy allows 100% funding through FDI whereas in
many of the segments of the Civil Aviation sector there are restrictions in allowing FDI. By
facilitating free flow of FDI, the industry will be able to meet the requirements of funds, get the
technical knowhow and also facilitate global access. The new Civil Aviation policy must address
the issue, if any and facilitate flow of FDI to the maximum extent possible.
9. REGULATORY PHILOSOPHY
9.1 The concession/project agreements already signed should be adhered to, to maintain the
investor confidence. Ministry of Civil Aviation (MoCA) should issue directions to AERA
in case of deviations in the policy.
9.2 MoCA should have unequivocal/absolute power to issue Directions to the regulator.
Regulatory philosophy should be predictable and should not be subject to frequent
changes to ensure regulatory certainty of the sector.

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9.3 The policy should support in establishing a forward looking investor friendly regulatory
environment which will ensure a level playing field for competing suppliers and also
ensure credibility in the ability of the regulatory establishment to safeguard the interest of
both the seekers and providers of service.
9.4 Policy should ensure setting up of independent regulatory mechanism to position between
legislator, executive and judiciary on one hand and market on the other hand.
9.5 Policy should ensure to maintain independence of the regulator from the executive.
Regulatory agency is given functional autonomy in its day to day functions.
9.6 The government should rest with the power to amend or to repeal law or rules in order to
remove or reduce regulatory burden in the industry.
9.7 The policy should also ensure appointment of regulator who possesses the competence
and integrity in order to inspire public confidence of the regulator. The regulator should
be appointed on a fair and transparent basis with a view to ensure that the regulatory
system remains insulated from political interferences.
9.8 The policy should ensure that the regulatory institution remain independent and
autonomous.
9.9 Policy should ensure a reasonably long fixed tenure say 3-4 years for a regulator. The
members of the regulatory body should ideally be drawn from different sectoral/subject
field experts.
9.10 Policy should also clearly focus on fostering competition rather than on regulation.
9.11 In a supply-lacked scenario like India, regulations should seek to bring in investments
by creating incentives for the operator to create additional capacity or efficient usage of
the facilities to maximise the number of passengers (or freight volumes).
9.12 The return on capital employed should be in line with the risks involved with operating
an airport and ensure that investor confidence is maintained enabling development of the
airports in line with the vision of the Indian Government.
10. REGULATOR FOR AIR TRANSPORT SECTOR
10.1 We believe that competition is the best regulator for a sector like air transport. Setting up
of a regulatory mechanism for air transport should be the last priority rather the
government should ensure a competitive market which will only give the desired result.
However taking into account the present situation of airlines sector, there is a requirement
to streamline the process and procedures in the airline market and to discipline the sector.
It may be considered that this will also be subject to regulation and monitoring by AERA
instead of setting up separate regulator for air transport sector.
10.2 There should be a separate Appellate Tribunal exclusively for the Civil Aviation Sector
to ensure settlement of disputes speedily.
11. OMBUDSMAN
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11.1 Merely setting up of world class infrastructure alone will not ensure availability of world
class service to the consumers. Appropriate regulatory framework to protect the interest
of consumers at large is one of the crucial areas.
11.2 The proposed Civil Aviation Policy should address the feasibility of setting up of an
Ombudsman for Civil Aviation Sector.
There is a working group for examining feasibility of Ombudsman for Civil Aviation, which
has prepared a draft report on the same. APAO has already provided its comments on the
report, a copy of which is attached for ready reference.
12. CONNECTIVITY ISSUES
a.

Route Dispersal Guidelines (RDG): It is a fact that route dispersal guidelines have
offered only a partial solution to issue of regional connectivity and was not a successful
model. The policy formulation should address the requirement of innovative mechanism
to achieve maximum connectivity with rural and inaccessible areas. New civil aviation
policy should address the issue to make the most efficient and economical use of routes
permitted by adopting market discovered pricing mechanism and also to help improve
connectivity to all the regional airports.
b. Regional Scheduled Operator Permit (RSOP): With the growing need for air
connectivity, it is essential to support and encourage regional players to enter into the
aviation sector. However, keeping in view the past record of the regional carriers, it
becomes crucial to review their performance and keep in place stringent checks relating
to their financial performance and safety & security standards.
These carriers are essential for regional connectivity but at the same time they also lead
to congestion at metro airports. This will put pressure on the infrastructure like terminal
building, airside capacity and most importantly on ATC. Though connectivity to the
regional airports is very essential, we cannot overlook the infrastructural constraints
being faced by the airports today. Therefore, the civil aviation policy must be designed to
ensure regional connectivity but also prevent unnecessary burden on airport
infrastructure.
c. Code Sharing: With the growing need for global and domestic connectivity, it is vital for
airlines to add new routes. Though it might not be feasible for one airline to fly on
multiple routes, thus Code share is a significant tool for airlines to develop their route
network and provide better connectivity with less time & cost.
It is essential for airports to have connectivity to multiple destinations (domestic &
international) hence code share amongst the carriers is crucial.
Keeping in view the above, Code-share agreements between Indian Carriers (including
Private Carriers) and foreign carriers should be liberalised. This will boost the overall
international & domestic connectivity and restrict foreign airlines to enter into the
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regional markets. This will help in minimizing leakage of passengers from the catchment
areas of Indian Airports.
13. CENTRAL AIR
AUTOMATION

TRAFFIC

FLOW

MANAGEMENT

(CATFM)

ATC

13.1 ATC automation is of paramount importance to ensure a safe and secure Air Transport
service.
13.2 Since management of air space being a sovereign function, the policy should consider
hiving off this function from Airport Authority of India which is an airport operator itself.
13.3 Since Airport Authority of India is undertaking multiple functions there is always a
possibility of cross subsidisation of one service with another, which will be applicable in
the case of ATC/ANS service also. Policy should formulate remedial measures to identify
and eliminate such possibility of cross subsidisation by mandating maintenance of
separate accounting records.
13.4 Policy should also address the short, medium and long term investment requirements and
ensure timely investment in ANS infrastructure facilities. Also modernise the entire ATC
systems and procedures.
13.5 Policy should also address the feasibility of offering the ANS service by other airport
operators to eliminate monopoly of single operator.
14. SATELLITE BASED NAVIGATION SYSTEM - SERVICE TO OTHER
SECTORS
Since satellite based navigation system is an essential ingredient of safe and secured air transport
system, the policy should address the issue of availability of an efficient satellite based
navigation system for the Civil Aviation Sector. It can also be developed as a business model so
that the service can also be offered to other sectors on cost plus basis.
15. FLEXIBLE USE OF AIRSPACE (FUA)
Airspace is a scarce resource of the country and efficient and economical use of air space must
be addressed in the policy. Restrictions on the use of airspace could lead to wastage of this
national resource hence policy should address the maximum flexible use of airspace at the same
time eliminate the misuse or under utilisation of airspace. Therefore, airspace should not be
designated as civil or military but should be considered as a continuous entity and should be
allocated to users on actual requirement basis. This will ensure increase in capacity of airspace
and will result in reduction in operating cost of airlines and lesser carbon emission into the
environment.

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16. CUSTODIAN OF AIRSPACE

Ideally the government (the sectoral ministry i.e. Ministry of Civil Aviation) must be the
custodian of airspace.
17. ESSENTIAL AIR SERVICES FUND (EASF)/REGIONAL AIR CONNECTIVITY
FUND (RACF)
Development of rural and remote areas have a direct bearing on the air connectivity between
these places ensuring essential air services to the remote and inaccessible areas of the country. In
order to set up the required infrastructure in such remote areas, it is essential to establish nonlapsable essential air service fund to provide explicit and direct subsidies to airport operators and
airlines to meet the shortfall of viability gaps in line with USO fund in telecom. A policy should
consider setting up of such a funding mechanism for the civil aviation sector.
18. MAINTENANCE REPAIR AND OVERHAUL (MRO)
Available forecasts indicate that India will have a huge fleet strength of aircraft by 2020 i.e.
approx. 1200+ aircrafts for Scheduled flights, 1000+ Helicopters, 2000 General Aviation aircraft
etc. India has therefore the potential to become a global MRO hub due to its low cost, favourable
geographical location, availability of technically skilled/certified aviation personnel. Also,
considering that Indias share is only 1% of global MRO market, developing MRO facility in all
the major airports in India is essential. The policy should address this issue of setting up of MRO
facility by facilitating investment in this sector and also making available the land near the
airport. The policy should also address the issue of the present high tax regime which is causing
a major detriment for the growth of MRO industry.
19. AVIATION UNIVERSITY/TRAINING INFRASTRUCTURE
Various forecasts suggest that India will require additional 3 - 3.5 lakhs employees in aviation
sector to meet the demand in the coming years. There is a need to increase capacity of current
training facility. Skill shortage is also more serious in aviation sector. There is also an
opportunity for demand for skilled personnel in Civil Aviation sector across the world. There is
clear absence of qualitative and duly recognised formal educational programs. It is therefore
necessary to establish a National Aviation University to cater to the growing educational and
training requirements of Civil Aviation sector in India. The Civil Aviation Policy should address
the issue of setting up of Civil Aviation University in the country.
20. POLICY FOR GENERAL AVIATION

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There should be a clear policy for encouraging the growth of general aviation in the country. The
policy should address to have a regulatory framework to enable the growth of general aviation.
The policy should also address to encourage investors for developing the supporting
infrastructure at all airports, to enhance the passenger amenities and to boost General Aviation
industry. Policy should also address for improving and upgradation of non-operational airstrips
to make it a full scale operation in future. The policy should also address the importance of
creating a reliable and regularly updated database of all airports and airstrips in the country. It is
also important to develop heliports to support the growth of general aviation in India. Policy
should also address the option of setting up of a separate monitoring and facilitation agency for
general airlines in the country. Aeronautical charges for General Aviation should be out of the
purview of regulator and the airport operator must be given the right to fix the same.
21. DEVELOPMENT OF AEROSPACE/ AIR SPACE MANAGEMENT POLICY
Considering the growth prospects of air traffic in the country and the competitive advantages
arising out of growing pool of scientific and technical manpower, it is necessary to consider
initiating activities for the development of aerospace industry in the country. This will also help
in reducing the import cost.
With the privatisation of airports in India, the JVC airports are separate entities who are required
to generate their own revenue and make themselves financially viable by using the airside
resources of the airport. Therefore, it will be prudent to handover the control and management of
Aerodrome control tower and Terminal airspace to the JVC so that they are in effective control
over the utilisation of their resources.

22. CENTRE STATE CO-OPERATION

Without the active support and cooperation of state governments the development of Civil
Aviation sector is next to impossible. It is essential that the Civil Aviation Policy should address
the issue of the areas where enhanced cooperation of state governments are required.
23. CIVIL MILITARY CO-OPERATION
There are numerous areas of interaction/coordination between the Civil Aviation department and
the defence authorities in order to meet the requirement of air traffic. There is a necessity to
optimise the utilisation of restricted air space by adopting latest radar and data systems. There are
issues of non availability of additional slots for civilian flights for military airports and sharing of
revenue from non-aeronautical revenue from these airports with defence and civil aviation. The
Civil Aviation Policy should address this issue.
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24. Dual Till Accounting

The Airport Infrastructure policy should clearly spell out dual-till that would not warrant any
cross-subsidization of non-aero revenue for encouraging investment by private entrepreneurs.
Aeronautical revenue and non-aeronautical revenue should be accounted separately. Otherwise,
investors will shy away from this sector.
24. Aerotropolis Development
In order to make the highly capital intensive Airports commercially viable, Aerotropolis
development with appropriate zoning around the Airport should be encouraged. The
Metropolitan City Master Plan developments should be integrated with the Aerotropolis
development. Land use policy should incentivize development of Aerotropolis in the airport area
which will bring tremendous multiplier effect in the whole metropolitan city.
26. Airport- Collaborative Decision Making (A-CDM)
Implementation of A-CDM at national level as enforced by US and EU, should be a priority. It
will improve the operational efficiency, ensure efficient use of scare resources and minimize the
flight delays. The collaborative data sharing and decision making by all the stakeholders in the
aviation industry like Airlines, Airports, ATC, Ground Handlers, Customs, Catering and the
passengers will be benefited substantially by A-CDM.
27. Sharing of Load Distribution Message (LDM) with Airports.
Sharing of LDM, which contains the details of the passengers, with the respective Airports
before landing of the Aircraft should be made mandatory for any scheduled flight operation.
28. Aircraft Manufacturing
As Indian Aviation is poised to grow substantially, the policy should address the need to
establish an Aircraft Designing and Manufacturing Centre, with the support of ISRO, DRDO,
Airlines, Airports, MROs and Aerospace Industries in the national level through PPP model.
29. Ancillary industries
The policy should encourage setting up of Airport related ancillary industries such as
manufacturing of Aircraft sheets, baggage trolleys, x-ray scanning machines etc., which will help
indigenous production of such critical items that will also avoid draining foreign exchange,
besides generating large scale employment.
30. Green Airport Initiatives

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The policy should provide for rewarding and incentivizing the "Green Airport Initiatives" like
harnessing Solar, Wind energies; Rain Water etc.
31. Noise Abating Policy
A 'Noise Abating Consultation Committee' has to be formed with the involvement of local
community. Rewarding the noise abating initiatives of Airlines and Airports is a right step in
this direction. Metropolitan development plans should not permit residential zones in Landing
and take-off paths.
32. Environmental Protection
Rewarding 'Air pollution reduction Methods' , Forest/ green belt cultivation initiatives,
Landscaping etc with appropriate carbon credit provision may be dovetailed into the policy.
33. R&D in Civil Aviation
The policy may spell out the modalities of setting up of an 'R&D Centre for Civil Aviation' in
line with ISRO, DRDO, IISc, IITs etc.
34. Local Community Development
As part of Corporate Social Responsibility, ear-marking a portion of the profit of Aviation
entities should be mandated in the policy for Local Community Development.

35. Tourism Policy

As Civil Aviation and Tourism are very much inter-connected, the comprehensive 'Tourism
Policy' should encompass Civil Aviation aspects and ensure integrated growth of both the
sectors.
36. Prior Immigration Clearance
Prior immigration Clearance facility from the originating country to the Hub Airport in India will
be a right step in attracting tourists and Hub development.
37. Tax Exemption
In line with IT sector, which gets Tax holidays because of its potential to bring Foreign
exchange, investments in Aviation Sector also should get a tax holiday at least for the initial 10
years.
38. Periodical review
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There must be an Omni Bus Clause in the policy to review the Civil Aviation policy at least once
in 10 years.
39. Declared Goods Status for ATF
The policy should address the discriminatory treatment meted out to domestic carriers in the tax
burden on ATF that cause undue hardship to them.
To summarize, the proposed Civil Aviation Policy should address the following important
issues:
A well structured national aviation policy is need of the hour and should address the following:
1. Address the discrepancies in the existing rules/acts within the Civil Aviation sector
thereby removing scope for different interpretations. There is a need to reexamine the
regulations/rules of MoCA, AERA Act/OMDA/SSA etc. to have cohesiveness in
interpretation and implementing the rules.
2. Ensure setting up of an investor friendly Regulatory regime.
3. Ensure all future airport projects under PPP model.
4. Allowing private participation in all the areas of Civil Aviation sector.
5. Ensure financial viability of Airports Promote non-aero revenue source.
6. Ensure the freedom and flexibility of operation and management for private airport
developers.
7. Promote an integrated transport system in the country.
8. No intervention from any agency like CAG audit or application of RTI rules to the PPP
airports.
9. A well structured policy for planned development of Airports, Cargo, Hub, MRO,
Aerotropolis, R&D, General Aviation and Aviation University etc.
10. Policy should formulate a progressive tariff regime of Dual Till in the Indian Airports
Sector.
11. Review of Bilateral Policy to minimize leakage of passengers from the catchment area of
Indian Airports.
12. Granting infrastructure industry status to airports.
13. Fiscal benefits like tax exemption/tax holiday to airports.
14. Clear policy to facilitate private sector investment in airports and for Aerotropolis
development.

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