October 27, 2023

Ms. Viviane Lapointe

Member of Parliament for Sudbury

Mr. Marc Serré

Member of Parliament for Nickel Belt

Dear MP Lapointe and MP Serré

AIR PASSENGER PROTECTION REGULATIONS POSE NEGATIVE IMPACT TO AIR SERVICE CAPACITY IN SMALL AND RURAL COMMUNITIES

I am writing to express our concerns about the negative impacts of the proposed changes to the Air Passenger Protection Regulations for our business community.

We agree with other industry groups, including the Airport Management Council of Ontario and the Canadian Airport Council, that the proposed financial penalties are unreasonable and that the costs associated with this level of compensation will trickle down to Canadian consumers, further increasing already high air fare prices for travel from regional airports including Sudbury.

In addition, the proposed requirement to rebook passengers within 9 hours is unfeasible.  Small and regional airports do not have adequate flight volumes to fulfill this requirement and such a regulation will further erode flight capacity at regional airports.  As an example, Sudbury currently has one flight per day to Toronto on Porter and would be unable to comply with the proposed 9-hour rebooking requirement.  Should these proposals be instituted, they would serve as a disincentive for Porter to maintain its daily service between Sudbury and Toronto because of the high risk of significant cost penalties that would be incurred in the case of a service disruption.

Our chamber is extremely concerned that the proposed changes to the Air Passenger Protection Regulations do not reflect the realities of the competitive environment where increases in costs and regulatory burden will necessitate airlines to review their pricing, service levels and market offerings.  We urge the Federal Government to ensure that a more balanced approach is implemented that will not have unintended consequences to local air fares and service capacity.

Debbi M. Nicholson

PRESIDENT & CEO

c. Honourable Pablo Rodriguez, Minister of Transport

c. Mayor Paul Lefebvre, City of Greater Sudbury

c. Giovanna Verrilli, CEO, Greater Sudbury Airport