Thank you, Mr. Chair, for the invitation to appear once again.
First, I want to acknowledge that we are on the traditional territory of the Algonquin Anishinabe peoples.
NACC, as you know, represents Canada's largest passenger airlines: Air Canada, Air Transat, Jazz Aviation and WestJet.
When it comes to air travel, let's acknowledge the obvious: Canada is a challenging market in which to operate an airline. We have a massive land mass, one of the lowest population densities on the planet, many scattered regional and remote communities and challenging climates. These are mostly, of course, natural conditions that are part of the reality of flying in Canada.
Then there are the challenges inherent in the system, which hinder competitiveness for all airlines. Let me give you five quick examples.
First, as you've heard from many others, is Canada's user-pay system. The list of fees, charges and taxes that passengers and airlines must pay are among the highest sets of fees in the world. Passengers must pay airport improvement fees, air navigation charges, the air traveller security charge and applicable taxes. Airlines must pay fees to NavCan, landing fees at airports and fuel taxes on aviation fuel. Many of these fees are set without consultation and without transparency in how or why they are set as they are. We don't oppose user-pay, but we are seeking a more competitive balance.
Second, it's estimated that airports pay over $400 million more in rent to the federal government per year than is received back in support. This is essentially a $400-million subsidy that passengers are paying to the federal government, which offers no return on investment since none of these funds are returned to the system.
Third, Canada's air travel regulatory framework is significantly burdensome and in need of modernization, and it puts Canada at a competitive disadvantage. As one quick example, Canada's security regulations currently require manual document checks when passengers board and check in, limiting the ability of air travel to make use of biometrics and facial recognition, which could speed up the overall boarding process.
Fourth, since the majority of Canadians live a short drive from U.S. airports and the U.S. system is much more competitive and cost-effective, it's estimated that over seven million Canadians choose to depart from U.S. airports on U.S. airlines.
Fifth, airlines from around the world, including Canadian ones, have committed to being net zero by 2050. According to Canada's aviation climate change plan, 60% of the path to decarbonization involves switching conventional jet fuels to sustainable aviation fuels, or SAF. However, to date, there is no notable production capacity in Canada because Canada is one of the few western nations that do not have an SAF incentive policy in place. Airlines will increasingly be making choices on where to fly based on where SAF is available.
The question becomes what we can do to address these elements of the overall system. Well, for starters, we suggest that the government stop seeing aviation as a cash cow and instead recognize it for what it is: an indispensable link that connects Canadians to each other and to the world, a critical component of the domestic and global supply chain and an economic enabler for a wide range of sectors.
Canada's airlines welcome competition, and as a result, to ensure that all airlines, large and small, have an equal opportunity to succeed, we request the following changes to create a more competitive business environment.
Airport rents should be reinvested into airport infrastructure. There's no reason why passengers should be subsidizing federal coffers at a time when airports need infrastructure to be more efficient, sustainable and accessible and to meet growing demand.
Let's conduct a review of all third party fees and charges with an eye to lowering overall costs and making them more transparent. One immediate example of how this principle could be implemented is to not adopt onerous APP regulations that will further drive up costs and threaten regional connectivity while doing nothing to improve air travel.
We need a full-scale regulatory modernization review. Although Transport Canada reviews certain regulations from time to time, we need a comprehensive approach to reviewing the regulatory environment in which airlines operate.
Although the 2024 federal budget did acknowledge the role of SAF and put some monies towards incentivizing the production of all biofuels, we call for a more ambitious plan and framework to incentivize SAF production in Canada, especially given our resource and skills advantages.
To conclude, this is clearly a comprehensive topic, and I want to thank this committee for devoting a number of meetings to this worthwhile examination.
With that, I look forward to the conversation.
Thank you.