27th November 2015
Ms. Gargi Kaul
Joint Secretary and Financial Advisor
Ministry of  Civil Aviation
Government of India  
Room no. 354
Rajiv Gandhi Bhawan, Block B
Safdarjung Airport
New Delhi - 110003 
Dear Ms. Gargi Kaul,  
Subject:  IATO Recommendation for Draft Civil Aviation Policy 
We compliment you for the progressive thinking and attempt to introduce a National Civil Aviation Policy which is tourist friendly. 
At the outset, it is stated that Indian authorities have issued very stringent regulations on International Charters including Tourist Package Charter Regulations. This is unheard of in other countries. In fact in many countries, Governments do not interfere in any manner in the operation of ITP charters, and the approval of such tour operators is controlled by Stakeholder associations on a voluntary basis, and all operators follow a code of conduct. 
The Tour operators are approved by Ministry of Tourism, Govt. of India and not by DGCA or the Ministry of Civil Aviation.  National Civil Aviation Policy should be such that it encourages tourist flights to India. Ministry of Tourism, Govt. of India should be requested to issue guidelines which would encourage international tourists to come to India. Simultaneously, the Aeronautical Information Circular issued by DGCA on the subject should be cancelled. 
There should be no concern about safety of flights. All operators that come to India have the Air operators’ Certificate issued by their respective authority, and DGCA’s safety and security concerns are only as are applied to foreign airlines. 
DGCA role should be only to give flight clearance of a series of non-scheduled flights for tourist charters, and normal oversight as applicable to foreign airlines aircraft. 
Some of the provisions proposed in the Policy are welcomed and must be implemented which include the following:- 
1.There should be no restrictions in terms of number of international charter flights by an operator and passengers flown into India as long as they do not follow a fixed schedule and are in compliance with the relevant ASA.
2.The passengers on charter flights will not be restricted to those that have bought an Inclusive Tour Package (ITP).
3.Incoming charter aircraft will be free to land at any Indian airport that has Customs and Immigration facilities.
4.Charter operators do not need to take any prior permission from DGCA, as long as they have filed the flight plan with ANS and have a confirmed landing slot at the relevant airport.
5.Passengers coming on an inbound charter flight will be free to shift to scheduled carriers for travel within India or abroad and vice versa, without seeking permission from DGCA as required in the present regulations.
6.There should be no restriction on the number of observers of the principal tour operators who come with the charter flight to oversee the arrangements. This is the prerogative of the principle tour operator.
7.Online filing of applications should be introduced with automatic clearance within three days for both incoming and outgoing charter flights.
8.Self-ground handling by the tour operators or its nominated GHA must be allowed at all airports, including PPP and AAI airports. At airports under joint use of Defense and civil purpose, self-handling in the terminal building limited to baggage handling and passenger facilitation must be allowed to provide economy and efficiency,
Besides the above, we would like to give following recommendations for including in the Civil Aviation Policy which will encourage international tourist arrivals to our country through charter operations:-
1.All international airports and immigration counters in India should have the facility of biometric facility and it should not be mandatory for the tourists to have biometric formalities at the Indian Embassies/consulates abroad so that tourists are not harassed and e-Tourist Visa and normal Visa holders do not waste time.
2.There should be rule of Uniform Parking Charges/fees at the airports whether run/managed by Airport Authority of India or Private Operators. Fee should be controlled by the government for tourist coaches and cars. Proper parking area should be designated which should be dedicated for tourist vehicles and minimum inconvenience to foreign tourists and no additional pick up charges should be levied at any airport on tourist vehicles. Tourist should be able to board the vehicle without crossing the roads.      
3.Unutilized air strips in tourist circuits and the Himalayan ranges and these are to be made operational for religious and adventure tourism.
4.Air ambulances to be kept at all the major airports and also in the North East and all remote air fields for the safety of tourists.
5.Entry passes at the airport should not be more than Rs. 5000 to 10000 for six months for all the Ministry of Tourism, Govt. of India recognized tour operators.
6.IATO as the apex body of tour operators, should be provided free counter at the major airports to help and facilitate international tourists.
7.There should be a separate area earmarked for local tour operators/ travel agents to receive foreign tourists and welcome them. By providing correct signages to direct the foreign tourists to this area will increase their safety and they will not be fleeced by the touts.
8.Welcome to India signage to be placed in major international languages at all the international airports.  
9.To ensure total safety & security of air transportation by introduction of state of art air technology, equipment and training facilities.
10.There is a need to have a clear and forward looking policy on ground handling services by opening this sector for enhancing competition in the services by allowing professional ground handlers with international experience.
11.A forward looking Green Field Airport Policy, which encourages the investors and developers to setup more green field airports in the country.
12.A clear sky policy to encourage the commercial activities at the airport for optimization of revenue from Non-Aeronautical Services.
13.Just like the government have regulated cab/taxi fares from airports and other places, similarly UPPER capping of air fare has to be fixed so that during the peak season tourist and passengers are not overburdened with high air fare.
14.The baggage allowance on domestic flights for all international tourists should be at least 20 kgs. so that tourists are encouraged to buy Indian Handicrafts and Souvenirs and do not face hardship when they connect from international flight to domestic flight and put to any inconvenience. 
15.Special incentives should be given to regional airlines who link up remote tourist destinations.     
16.In Goa, AAI is forcing Charter Airlines to be handled by Air India only. Even charter flights of Schedule Operators are asked to be handled by Air India, who do not have proper services and also charge two times the handling rate of Private Handling Companies. This is discouraging Charter Airlines to come to Goa. The charter policy must give freedom to Aircraft Operator to choose its ground handling agency from the available GHAs at the airport of call and not create monopoly of any single airline.
17. It is high time, that the Indian government liberalizes Air Charter Policy and the charter flight should be allowed to carry Indian passengers both ways to make these flights commercially viable and this will be beneficial to Indian traveller also financially. Charter landing fee for charter flight should be less then schedule flights because they are taking risks to encourage charters. 
18. Airports Authority of India has increased the Security Deposit of Rs. 1 Crore against Slot allotment at Dabolim Goa. This has adversely affected Tourist Charter operators as well as airlines. This should be withdrawn. This year the charters have gone down due to this reason  
19.Tourist Charter guidelines needs to be amended in line with Government of India efforts to promote tourism to India including e- Tourist Visa. 
FDI and Taxes
20.Tax exemption in line with IT sector which gets tax holidays because of its potential to bring Foreign Exchange, investment in aviation sector also should get a tax holiday at least for the initial 10 years.
We hope you find our above recommendations useful and will appropriately be included in the Final Civil Aviation Policy. 
Thanking you and with best regards,
Sincerely, yours,
Subhash Goyal