The EESC does not share the Commission's reasoning that the aviation market is returning to 'normal'. The EESC believes that the Commission should review the proposal with the objective of minimising modifications to the existing provisions to maintain their character as 'emergency legislation'. The current emergency has by no means abated, and thus the emergency provisions should be prolonged at least for the period envisaged by the Commission. It appears premature to plan modifications such as those suggested by the Commission.
The EESC welcomes however the Commission's proposal to extend the scope of justified non-use of slots (JNUS) to also cover political unrest and natural disasters. However, the procedures envisaged by the Commission add an unnecessary level of complexity. The EESC supports moreover the proposal to enhance the transparency of slot allocation by strengthening the role of the European Airport Coordinators Association, and by introducing an obligation for coordinators to publish the destinations to which the exceptions apply.
The EESC emphasises, at the same time, that EU measures should be closely coordinated with the Worldwide Airport Slot Board (WASB) to avoid different approaches to the same issue in different regions of the world. The EESC believes that, notwithstanding the support of the Commission's intentions, despite the evident time constraints, an impact assessment would have been warranted to better assess the implications of the proposed changes to the existing Slot Regulation.