Striking a balance: addressing the impact of jet fuel disruption on Europe’s airport slots
The debate over airport slot alleviation has returned to the forefront of European aviation policy following the conflict in the Middle East and its knock-on effects on fuel prices. As airlines demand greater operational flexibility through wider slot waivers, airports are warning against broad measures that could undermine connectivity, distort competition and shift financial burdens across the aviation ecosystem.
In this interview, Gunter Heinrich, the Chair of the ACI EUROPE Slot Task Force, explains all you need to know about the slot situation today: including why Europe’s airports support the targeted use of the Justified Non-Use of Slots (JNUS) mechanism rather than blanket waivers, the risks wider alleviation measures could pose for passengers and regional connectivity, and how policymakers should prepare for potential future disruption while ensuring slot regulation remains proportionate, evidence-based and resilient.
Within the context of the fallout from the conflict in the Middle East, the issue of airport slot usage has once again come into focus. ‘Across the aviation ecosystem, we all agree that the conflict in the Middle East constitutes an extraordinary situation. This is an important distinction to make, and we all agree that special consideration is justified for slot handling,’ notes Gunter. ‘But this is something already within the EU Slot Regulation. The European Airport Coordinators Association (EUACA) have established how they want to use this provision, and as the ACI EUROPE Slot Task Force, we strongly support that.’
EUACA’s Recommendation, recently endorsed by European Commission Guidance, provides much needed clarity and certainty as regards the extent to which airlines are required, in the current circumstances, to effectively use at least 80% of the airport slots allocated to them. The Recommendation allows airlines to derogate from the 80% usage requirement on an individual case-by-case basis in the event of flight cancellations being the direct result of capacity restrictions at affected airports or of jet fuel shortages at airports – with such a cancellation qualifying as Justified Non-Use of Slots (JNUS).
However, they have indicated that jet fuel cost inflation does not in principle qualify. ‘We believe it’s appropriate in the current situation to follow EUACA’s recommendation – including the six-week rolling interval,’ Gunter continues. ‘That gives airlines and airports certainty for at least the next six weeks on how coordinators will handle the situation. While we can’t predict the future, for the moment, we fully support the proposed JNUS application by EUACA and don’t see the need for further relief such as waiving or reducing the usage rate without conditions.’
Why is it necessary to clarify how such measures should apply in the current context? ‘Waivers constitute a very significant intervention in the market,’ Gunter explains. ‘It’s a very big derogation on the safeguard of the 80% usage requirement. It is a strong measure that means airlines can decide at short notice to not operate flights. But while airlines may reduce their own financial exposure, the airport infrastructure and operational resources remain in place – and the associated costs remain uncovered.’
He notes that the financial burden does not stop with airports themselves. ‘Other stakeholders, such as border police and ground handling service providers, must still provide the necessary infrastructure and staffing. If flights are cancelled, those costs do not simply disappear. The airline can cancel from its own financial perspective, but airports and other aviation stakeholders are then left to shoulder the burden.’
According to Gunter, the implications for passengers and connectivity are equally significant. ‘For passengers, this means fewer flight options, fewer connections and potentially higher ticket prices. In particular, it is often short-haul and medium-haul routes – especially those serving regional airports – that are most affected. Airlines will naturally focus on what is financially viable from their own perspective, but that does not necessarily take into account the wider impact on connectivity or on other parts of the aviation ecosystem.’ For that reason, he argues, any slot alleviation measures must remain proportionate and carefully targeted. ‘This is why waivers should be used cautiously and remain as limited as possible.’
Gunter believes the current JNUS framework strikes the right balance between supporting airlines and protecting the wider aviation ecosystem. ‘We recognise the significant impact of the conflict in the Middle East, and we agree that relief measures are justified,’ he says. ‘But at the moment, the effects remain regional, which is why a targeted, flight-specific approach is more appropriate than a blanket waiver.’
The key distinction, he explains, is accountability. Under the JNUS mechanism, airlines must demonstrate that cancellations are directly linked to the extraordinary circumstances caused by the conflict, rather than commercial considerations. ‘With JNUS, there must be a clear connection between the cancellation and the current situation.’
While traffic demand in the Middle East has declined sharply, Gunter points out that demand across most other markets remains strong. ‘We are not seeing a widespread collapse in demand across the industry,’ he says. ‘That is why broader waivers are not currently justified.’
For the ACI EUROPE Slot Task Force, one of the most important aspects of the current debate is the distinction between fuel shortages and rising fuel prices – two issues that ae fundamentally different.
‘If there is a fuel shortage, airlines simply cannot operate flights,’ Gunter explains. ‘That is entirely beyond their control, and in those circumstances they should not suffer any disadvantage. If fuel is unavailable, there is no choice for the airline, and relief measures are therefore justified.’
Higher fuel prices, however, are a very different matter. ‘This is part of how a free market operates,’ Gunter says. ‘Airlines manage fuel purchasing in different ways. Some carriers may already have secured fuel prices months in advance, while others are more exposed to market fluctuations. These are commercial decisions.’ As long as fuel remains available, he argues, airlines still retain flexibility in how they respond to rising costs. ‘They can choose to absorb the additional expense, pass it on through ticket prices, or decide that certain routes are no longer commercially viable,’ he explains. ‘If an airline chooses to cancel a flight because it is no longer profitable, it must also accept the potential consequences for the slot series .’
Ultimately, the distinction comes down to whether airlines have a genuine ability to act. ‘That is the key difference,’ Gunter concludes. ‘When airlines have no choice, relief measures are appropriate. But when they still have commercial options available, that falls within the normal framework of free competition – and that is why fuel price inflation is deliberately excluded from JNUS.’
At the same time, the Task Force does not rule out stronger measures if the situation deteriorates further. ‘This could change if the disruption expands,’ Gunter notes. ‘At that point, coordinators would need to assess whether the current approach remains practical. Managing a limited number of JNUS requests is very different from dealing with thousands of cancellations across the network.’
‘At the moment, the impact remains regional, so any relief measures should remain regional as well,’ he explains. ‘That does not mean broader waivers can be excluded in the future, but we simply do not believe the conditions are there right now.’ For now, however, he maintains that the existing framework remains the most proportionate solution. ‘It is not a question of “never”, Gunter concludes. ‘It is simply not necessary at this stage. Before any wider waiver could be justified, the conditions for introducing it would need to be clearly defined.’
Gunter is particularly critical of the UK Government’s decision to introduce slot waivers for both the Summer and Winter 2026 seasons, arguing that the measure lacks a sufficiently clear justification. ‘Waivers are very powerful tools,’ he says. ‘They provide significant alleviation for airlines, but that comes at a cost for airports and passengers.
The difficulty is that nobody can predict what the situation will look like months from now – including during the Winter season. That is why these kinds of measures should always be based on clearly defined conditions and evidence. At the moment, those conditions have not been established.’
He argues that the UK waiver lacks the objective criteria needed to justify such extensive relief. ‘There is no specific trigger attached to the decision,’ he notes. ‘For example, there is no defined threshold linked to a drop in demand or a confirmed fuel shortage. Instead, it is effectively a blanket waiver covering a long period of time, and that is something we cannot support.’
Beyond the immediate impact on UK airports, Gunter also raises concerns about the international implications of unilateral waivers. ‘A slot waiver does not only affect the airport where the flight arrives or departs,’ he says. ‘It also affects the airport at the other end of the route. If a flight from Heathrow to Brussels is cancelled under a UK waiver, what happens to the slot in Brussels?’
According to Gunter, this creates pressure on other jurisdictions to align with UK policy decisions, regardless of whether they share the same assessment of the situation. ‘There is an expectation that airports and coordinators elsewhere will follow the UK approach,’ he explains. ‘But that is not necessarily straightforward, because cancellations create financial and operational consequences on both sides of the route and highlight the limitations of a one-size-fits-all approach. The burden is not limited to UK airports alone.’
Looking ahead, Gunter believes that effective policymaking will depend first and foremost on a shared understanding of the crisis itself. ‘It is essential that everyone involved in these discussions has the same understanding of both the current situation and where it may be heading,’ he explains. ‘That is particularly important when it comes to fuel availability. If stakeholders are working from different assumptions, they will inevitably come to different conclusions about how the situation should be handled.’
For that reason, he says, clear and reliable information from policymakers will be critical. ‘The European Commission has been asked to provide greater clarity on developments relating to fuel supply and availability so that decisions can be based on a common set of facts,’ Gunter notes.
He also emphasises the importance of recognising that disruption and relief measures affect different parts of the aviation ecosystem in very different ways. ‘Airports, airlines and other stakeholders do not experience these impacts equally,’ he says. ‘That is why communication with the European Commission needs to take place in a timely fashion, so there is enough time to properly assess and balance the consequences for everyone involved.’
At the same time, Gunter argues that the current situation has exposed the need for a more agile regulatory framework. ‘This is a very good example of why the EU Slot Regulation needs to become more resilient,’ he explains. ‘At the moment, formal processes can take month or even years, but in an emergency situation the industry often needs to respond much faster. We should have mechanisms already built into the regulation that allow relief measures to be introduced more quickly when genuinely necessary.’
According to Gunter, this will become an important focus for the ACI EUROPE Slot Task Force going forward. ‘The discussion is not about whether relief measures should exist,’ he concludes. ‘The real challenge is finding the right balance between the current situation, the likely future developments, and the interests of all stakeholders. Relief measures can be necessary, but they must remain proportionate, targeted and evidence-based.’
