Why the FIA’s case against the removal of the 5/20 rule is unjustified

25 Thursday Feb 2016

Posted by theflyingengineer in Air India, AirAsia India, General Aviation Interest, Go Air, IndiGo, Jet Airways, SpiceJet, TATA-SIA, Vistara

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20, 5, Air, Airlines, Airways, India, Indigo, Jet, justification, Rule, Spicejet, unjust

Today, India, for the size that it is, has only four airlines that fly international: Full service carriers (FSCs) Air India and its subsidiaries, and Jet Airways, and Low cost carriers (LCCs) SpiceJet and IndiGo. This is in contrast to the 10 airlines that operate domestic scheduled services in India, today. While Indian carriers flew 81 million domestic passengers in calendar year 2015 (CY2015), Indian carriers flew only 18 million passengers in the same period.

Only two airlines/airline groups operate short, medium and long haul international services: Air India and Jet Airways. Both airlines have diverse fleets: from short haul domestic ATR 72 turboprops to long haul international Boeing 777s. The LCCs in contrast have narrowbody jets that can cater only to short haul international services.

Due to the limitations of fleet and perhaps the lack of commercially attractive international destinations, LCCs IndiGo and SpiceJet deployed only 4.8% and 9.5% of their total flights on international, in CY2015. In contrast, Jet Airways (Including operations from the Jetlite AOP) deployed 22.1%, while Air India (Including Air India Express and Air India Regional (Alliance)) deployed 32.7% of its total flights on international. Air India and Jet Airways together contribute to 84.5% of all international departures by Indian carriers, while IndiGo and SpiceJet contribute to just 8.8% and 6.8% respectively.

This statistic shows IndiGo and SpiceJet are very small players in the international front, serving destinations at neighbouring countries. IndiGo operates only to five international destinations: Kathmandu (Nepal), Muscat (Oman), Singapore (Singapore), Bangkok (Thailand), and Dubai (U.A.E.), while SpiceJet operates only to six international destinations: Bangkok (Thailand), Colombo (Sri Lanka), Dubai (U.A.E), Kabul (Afghanistan), Male (Maldives), and Muscat (Oman).

Air India and Jet Airways started operations before the 5/20 rule was instated in the year 2005. IndiGo and SpiceJet started operations after the 5/20 rule was introduced. The 5/20 rule requires airlines to operate domestic services for a minimum period of five years, after which it can fly international only if the airline has a fleet size of 20 or greater.

Air India Express was the only airline to start immediate international operations (although on an AOP different from Air India) after the 5/20 rule was introduced. The first flight of the airline was an international flight.

Neither IndiGo nor SpiceJet fought the 5/20 rule at that time as the focus of both airlines then, as it is today, is to tap the potential of the domestic market. SpiceJet started international operations in October 2010, while IndiGo commenced international operations in September 2011. Despite both LCCs having started international operations nearly five years ago, when the scale of domestic operations were smaller, both airlines chose not to focus on international operations. (See IndiGo’s fleet induction, here) Both airlines always had the option of inducting larger aircraft to serve destinations beyond the surrounding Asian and Middle East countries. But such is not their business model.

As a result, the only Indian carriers to majorly serve international are Air India and Jet Airways, both of which were not ‘victims’ of the 5/20 rule, whereas IndiGo and SpiceJet, which chose to focus on domestic even though they started international operations five years ago, are ‘victims’ of the 5/20 rule, strongly opposing the removal of the a rule that means nothing, and does not impact either airline..

Go Air

Go Air started operations in the year 2005, but chose not to increase its fleet beyond 19 aircraft. It deferred its 20th aircraft, which was readied by Airbus. As a result, the airline does not fly international, and seems to have no issues remaining a domestic player. Yet, the airline opposes the removal of the 5/20 rule, though it chose not to operate international.

Wasted capacity

In the quarter ending 31st December 2015, a total of 12.6 million international passengers were carried by both Indian and international airlines. Of that number, Indian carriers flew just 4.5 million passengers, or just 36% of the total traffic.

India is underutilising its bilaterals, due to restrictions placed by rules such as the 5/20. For the purpose of this case, and for want of time, we consider only three international destinations: Singapore, Bangkok, and Kuala Lumpur.

As of late February 2016, there are three airlines from Singapore that operate to 13 destinations in India. Singapore Airlines, Tiger Airways and Silk Air together operate 134 flights per week to India, from Singapore, and an equal number of return flights. Together, the airlines deploy 30,517 seats per week between Singapore and India, in each direction, using a variety of aircraft: Airbus A319s, A320s, Boeing 737-800s, Airbus A330s, Boeing 777-200s, 777-300s, and Airbus A380.

In contrast, three Indian airlines (four if you count Air India Express separately) connect Singapore to only four destinations in India. Air India, Air India Express, Jet Airways and IndiGo together operate 63 flights per week between the two countries. Together, the airlines deploy just 13,244 seats per week between Singapore and India, in each direction, using Airbus A320s, Boeing 737-800s, Airbus A330-300s, and Boeing 787-8s.

Thai Airways, Thai AirAsia, and Bangkok Airways operate from Bangkok to eight destinations in India, flying 73 flights and deploying 19,497 seats per week, Using Airbus A320s, Boeing 747s, 777-200s, 777-300s, Airbus A330-300s, and Boeing 787-8s.

In contrast, SpiceJet, IndiGo, Jet Airways and Air India together operate 62 flights, deploying 12,474 seats per week, from four Indian destinations to Bangkok, using Airbus A320s, Boeing 737-800s, 737-900s, and Boeing 787-8s.

From Kuala Lumpur, AirAsia Berhad, AirAsia X, Malindo, and Malaysian Airlines operate 180 flights to 12 Indian destinations, deploying 32,903 seats per week between Malaysia and India, using Airbus A320s, Boeing 737-800s, 737-900s, and Airbus A330-300s.

In contrast, only Air India Express operates to Kuala Lumpur, connecting only Chennai to the Malaysian capital with 4 weekly flights and deploying 744 seats per week.

While not all destinations are commercially viable, there is a huge mismatch between the capacity deployed by foreign carriers, and the capacity deployed by Indian carriers, on the same set of routes. Infact, the superior connectivity offered by foreign carriers is not matched by Indian carriers, leaving a large scope for more Indian carriers to boost the Indian economy while also providing international passengers seamless domestic connectivity.

The 5/20 rule must go if India should see it’s own airlines connect India with the rest of the world.

What the FIA won’t tell you

The Federation of Indian Airlines (FIA), have something against the airlines of the Father of Indian Aviation (FIA), Late JRD Tata. The Tata’s have already done enough to promote connectivity within India: TATA airlines was renamed Air India.

The FIA (Federation) is shaken by the prospects of airlines such as Vistara and AirAsia India. The goal of the FIA is to restrict the operations of such airlines to within India, so that players like the market leader can use its low cost base to lower fares on every route such airlines fly, and bleed the airlines dry. Starting with the smallest and the least capitalised airlines, airlines will knock off the Indian scene, one by one, leaving only a few to operate in India, with the market player enjoying a huge monopoly in setting fares. At that point in time, India will suffer, with neither good international connectivity, nor with strong domestic competition nor worthy alternatives.

While the FIA blames consultancy firm KPMG of auditing Singapore Airlines and consulting for the government, it remains silent on consultancy firm CAPA.

CAPA India, in its Aviation Outlook 2016, stated, “Despite repeated statements by the Minister that there is no logic to the 5/20 rule and that it should be abolished, the discriminatory regulation still remains in place”.

Guess which consultancy firm’s services was sought for IndiGo’s Red Herring Prospectus? CAPA India.

What does the 5/20 or 300/600 mean to Indian Aviation?

06 Friday Nov 2015

Posted by theflyingengineer in Airline, General Aviation Interest

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20, 300, 300/600, 5, 5/20, 600, AirAsia, DFC, Domestic, Flying, Indigo, International, Jet, Rule

The 5/20 rule – allowing airlines to fly international only after completing 5 years of operation and flying a fleet of a minimum of 20 airplanes, was introduced in the year 2005. The year 2005 was the second boom in Indian civil aviation.

Today, in the year 2015, we sit upon the next boom in Indian aviation. Since later 2013, many airlines have started: Air Costa, AirAsia India, Vistara, Air Pegasus and Trujet. The government, exactly 10 years after introducing the 5/20 rule, is going to either retain it, abolish it, or replace the rule. A rule that, on the outside, was intended to both develop domestic capacity and make sure airline operations stabilize before flying international. The true story revolves around the insecurity full service Kingfisher airlines created for one particular airline. Hence, the rule was introduced just before Kingfisher started operations in May 2005.

Since then, the industry has consolidated: Jet-Sahara, Air India-Indian, Kingfisher-Deccan, and the demise of the merged Kingfisher. What has the 5/20 achieved? It has created only 4 international airlines for the world’s largest democracy. Just 4 airlines.

We invite you to read what the 5/20 has done, what its proposed replacement, the 300/600 can do, and whether we must go in for the third option: No rule at all. Please click here.

AirAsia India makes Delhi a hub, 5th aircraft arrives from Malaysia

15 Wednesday Apr 2015

Posted by theflyingengineer in AirAsia India

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5, Air, aircraft, Asia, Bangalore, Delhi, Dispersal, Guideline, RDG, Route, th

AirAsia India announced today Delhi as its second hub, after Bangalore. Delhi will also serve as a base for the airline, while Bangalore will remain the home base.

Assuming that the airline will start flying between Bangalore and Delhi, the airline will for the first time begin flying on a Category I (Cat I) route, as defined by the prevalent route dispersal guidelines (RDG). Flying on a Cat I route will now oblige the airline to deploy a minimum percentage of the Cat I route capacity on Category II, IIA and III routes. Capacity is measured on an available seat kilometer (ASKM) basis. Every 180 seat flight between Bangalore and Delhi adds approximately 3,42,000 ASKM.

This makes the choice of Delhi as a base very important.

The importance of Delhi

Category II (Cat II) routes are routes which were traditionally looked upon as ‘loss making’ routes. These are routes that connect the mainland to the ‘neglected’ north-east, far north, and the islands that make up Lakshadweep and the Andaman and Nicobar Islands. (Please note that ‘neglected’ is a harsh word, but that’s how the ministry looks upon these regions as far as air connectivity is concerned). 10% of the Cat I capacity must be deployed on Cat II routes (To be soon revised to 20%). Had AirAsia India flown to Port Blair from Chennai or Bangalore, this requirement could have easily been met. AirAsia’s Airbus A320s cannot operate into and out of Agatti’s short strip.

Category IIA (Cat IIA) routes are routes which connect airports within a ‘neglected’ region. Examples are Jammu-Srinagar, and Guwahati-Bagdogra. Unfortunately, the southern portion of India – where AirAsia India is based- has no such Cat IIA routes. 1% of the Cat I capacity must be deployed on Cat II routes (to be soon revised to 1.5%)

To cater to a Cat I route and Cat II & IIA routes, the northern part of India is a wiser hub.

All the routes AirAsia India flies today are Cat III routes, as per prevalent RDGs.

Establish the route

By having a hub at Delhi, AirAsia India can fly early morning flights from Delhi to Bangalore, which can be mirrored by early morning Bangalore – Delhi flights. Similar flights from either destinations may be flown in the evening. This requires one A320 to be based at Delhi, to start with.

If such a strategy is followed, each aircraft will fly a minimum of 2 flights on the Bangalore – Delhi/vv route. Each flight is planned for 2:45 hrs, which will total upto 5:30 hours of utilisation per aircraft on this city-pair, leaving a maximum of around 7hrs of utilisation for other stations.

We feel that the airline may fly a 3x Bangalore-Delhi one way, per day, of which at least 2 shall be direct flights.

Flights to Delhi are not expected before May 2015, and perhaps not before mid-May 2015.

Deploy Cat II & IIA capacity.

Flights between Delhi-Jammu-Srinagar or Delhi-Guwahati-Bagdogra or Delhi-Guwahati-Agartala may be flown for Cat II and Cat IIA capacity. Delhi-Jammu-Srinagar seems to be the most likely set of cities to be flown first.

If the airline is innovative enough, it may make the most of its patterns to fly underserved routes. I am obliged to not exercise my creativity in suggesting routes.

Open Vishakhapatnam as a destination

AirAsia India presently flies three aircraft, and one of the three patterns flown everyday has a poor utilisation of just 7:50 hrs (see above). It is in this pattern – the third pattern, that two flights to Vishakhapatnam may easily fit in (as published in the DGCA’s Summer Schedule), with perhaps slight schedule changes.

The necessity – 5th aircraft

Opening the Delhi-Bangalore route will require two additional aircraft: one based at Bangalore, and the other at Delhi.

Further, as per CAR Sec 3 AT series C Part II, operators “will be given one year’s time from the date of securing operator’s permit, to have the fleet size of five aircraft”. AirAsia India secured its AOP on May 7th, 2015, and a 5th aircraft is necessary to meet regulatory requirements.

Today, at around 11:00hrs IST, AirAsia India’s 5th aircraft flew into Hyderabad from Kuala Lumpur. The aircraft is a used Malaysia AirAsia A320-216 (9M-AHU) without winglets, and is around 5.5 years old. The aircraft is AirAsia India’s second, non-winglet A320, after the 7 year old A320 which was unveiled to the public on 21st March in the JRD Tata livery (see image on top). Both aircraft are yet to start flying commercially for the airline.

The first three aircraft have winglets. If the airline is prudent with its fuel burn, only the winglet equipped aircraft (VT-RED/ATF/ATB) will be deployed on the BLR-DEL vv route.

Thank you to @ATCBLR on Twitter for posting the 5th aircraft’s arrival.

Marked shift in strategy

Last year, Mittu Chandilya, CEO AirAsia India had announced Goa as the second hub, with the induction of the 4th aircraft. He had also mentioned that the airline will keep off Delhi and Mumbai.

The airline last operated flights on the Bangalore – Chennai route on 31st March 2015.

Airbus A350 MSN 5 enters FAL

06 Wednesday Nov 2013

Posted by theflyingengineer in Manufacturer

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5, A350, Airbus, Assembly, cabin, Campaign, Flight, MSN, Production, Program, test

Airbus states that the assembly of MSN5, the fifth and final member of the A350 XWB flight test fleet in the test flight campaign is now underway with the fuselage joining process. This follows the recent arrival of the three fuselage sections at the A350 XWB final assembly line (FAL) in Toulouse, France.

MSN5 is the second of the A350 flight test aircraft that will feature a passenger cabin. MSN 2 and MSN 5 will have the cabin fitted, where Airbus will put passengers on board, with cabin crew. It is for the first time in the history of Airbus that so early in the campaign 2 aircraft have been dedicated to the cabin. Earlier, aircraft would be dedicated about 2 months before the entry into service. Associated with that are delays, a lot of complaints from passengers, and a difficulty of entry into service. This was witnessed in the A320 and the A340 programs.

This aircraft will fly for the first time in Spring 2014 and will be used essentially to perform cabin related flight tests. It will also participate in the Early Long Flights where the “passengers” are Airbus employees. This allows the cabin and related systems to be submitted to near realistic operations in order to ensure a mature cabin at entry into service. In addition, MSN5 will carry out Route Proving flights to demonstrate to the certification authorities that the aircraft performs perfectly in airport operations.

To date the two A350 XWB test aircraft, MSN1 and MSN3 have clocked up over 500 flight test hours in more than 100 test flights. The A350 XWB has already won more than 760 firm orders from 39 customers worldwide. First delivery will be to Qatar Airways in the second half of 2014.

Serious Business: Mahindra Aerospace

24 Thursday Oct 2013

Posted by theflyingengineer in General Aviation Interest, Manufacturer

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-8, 10, 18, 5, Aerospace, aircraft, Australia, Commuter, GA, GippsAERO, India, Mahindra, manufacturing, NAL, NM, Normal

Mahindra Aerospace GA-8 Airvan at Aero India 2011

This article focuses only on airplane manufacturing and does not cover aerospace services or aerospace manufacturing services. In this article: Mahindra Aerospace’s story: how it was born; 8 seat piston to be manufactured near Bangalore, in 2 years time; GippsAERO brandname no longer exists, replaced by Mahindra Aerospace; Mahindra eyeing Beechcraft.

The birth and growth of Mahindra Aerospace

Mahindra’s foray into the aerospace segment was with the acquisition of 88.41% stake in Plexion Technologies (India) Limited (Plexion) in the year 2006. The main aim was to complement and help grow Mahindra Engineering Services portfolio in the automotive sector. But Plexion also offered Engineering Services to the Aerospace sector.

Plexion’s modest presence in aerospace made the Mahindra group ponder over the prospect of stepping into the aviation industry, for a year. Seeing the potential, the Mahindra group chose to focus on aircraft, and aerospace structures, creating the Mahindra Aerospace division in 2007, to expand the group’s existing automotive design and manufacturing expertise to the aerospace industry. The majority acquisition of Plexion brought to Mahindra the NM-5, a 5 seat (including the pilot’s) airplane being developed by NAL (and now with Mahindra in a 50:50 partnership) as an extension to the 2 seat Hansa aircraft.

But it was only in 2009 that Mahindra entered the aerospace manufacturing segment with the simultaneous acquisition of a majority stake in two Australian companies, Aerostaff Australia and Gippsland Aeronautics, which later became GippsAERO. While one is a component manufacturer of high-precision close-tolerance aircraft components and assemblies for large aerospace OEMs, essential to catapult M&M into the burgeoning Defence Offset and Commercial Aviation market, Gippsland Aeronautics (GA) is an established general aviation aircraft manufacturer, known primarily for its piston powered 8 seat GA-8 Airvan.

The NM-5 program got a boost with the capabilities that GippsAERO brought with it. 5 years after the preliminary design of the aircraft commenced, the aircraft took to the skies, although in Australia, on 1st September 2011 and lasted 45 minutes. The aircraft is yet to be certified.

An stretched version of the GA-8, the turboprop GA-10, with the capability to seat 10 persons, first flew in the May of 2012, and is expected to be certified in the first quarter of 2014. Prior to the acquisition, GippsAERO in 2008 had announced that it had won bidding to take over the type certificate of the Australian Government Aircraft Factories (GAF) Nomad’s design, renaming it the GA-18, and will re-engineer (the original design was problematic and resulted in 32 write-offs, claiming 76 lives) and put back into production the 18 seat airplane, once the GA-10’s certification is through.

Since the February of 2013, as part of a unified branding strategy, the “GippsAERO” name has been dropped and replaced by Mahindra Aerospace, renaming the aircraft portfolio Mahindra Aerospace GA-8, GA-10 and GA-18.

Acquisition is preferable to organic growth, especially for a starter in aerospace, today. “You cannot spend a lot of time developing three or four aircraft and getting them certified,” said Arvind Mehra, executive director and chief executive of Mahindra Aerospace, in an interview with Flightglobal, years back. “This would take forever. We looked at various targets, and finally bought GippsAERO in Australia, which gave us three aircraft (GA-8, GA-10, GA-18) on day one.”

This is no different from Bombardier’s approach. The Canadian planemaker got into aerospace in 1986 with the acquisition of Canadair, followed by the acquisition of Short Brothers, Learjet, de Havilland Aircraft: all of which produced excellent aircraft but were in the red.

According to Bloomberg, Mahindra Aerospace has now set its sights on the acquisition of Beechcraft Corporation, the aircraft manufacturer known for its popular King Air turboprops, Beechcraft Baron, and Beechcraft Bonanza, and the Hawker series of Business Jets, but had entered bankruptcy in May 2012, and exited Bankruptcy in the February of 2013, and is looking at auctioning off its business, for around US$ 1.5B.

Richard Aboulafia, an analyst at the Teal Group in Fairfax, Virginia, feels, “[Mahindra’s] own indigenous development program, which is what they’ve been looking at, has a much higher risk than acquiring Beechcraft. If you can get a good deal on an existing family of planes, that’s definitely an easier way.” Besides, it opens the doors to the North American aerospace industry.

But acquiring the troubled plane maker which is planning on shutting its business jet production and focusing only on its piston and turboprop offerings, may deter Mahindra with the US$1.5B figure.

Local Airplane manufacturing

Narsapur, 40 kilometres from the aviation capital of India, Bangalore, witnessed the setup of Mahindra Aerospace’s manufacturing facility, in technical collaboration with Aeronova, a Spanish company specialising in the design and manufacture of major airframe assemblies. In 2 years, the GA-8 is expected to be manufactured in the country, making it the first private player to build certified aircraft in the normal and commuter categories, in the country.

The inauguration of this facility helps realise the dreams of Mahindra Aerospace. In the August of 2011, while announcing the development of the manufacturing facility at Narsapur, Hemant Luthra, President – Mahindra Systech, which takes care of the group’s aero service business, and member of the Group Executive Board, expressed the group’s ambitions. “From the family of Mahindra Aerospace planes that include the NM5, we would be disappointed if in 3-5 years time we were not clocking a rate of 100 aircraft per annum in India. This rate could get accelerated if we include exports to China and other countries.”

In the same year, Mehra had said to Flightglobal that he sees Mahindra Aerospace becoming the Embraer of India, carving out a niche in a world dominated by big Western players. “Embraer grew out of a country with no aviation experience. They competed with Boeing and Airbus and made a space for themselves. Embraer is a beautiful story.”