In a move aimed at transforming the country’s aviation landscape, the Aviation Operators Association of Bangladesh (AOAB) has submitted an extensive set of observations and policy recommendations on the draft National Civil Aviation Policy (NCAP). Submitted by Md. Mofizur Rahman, the General Secretary of AOAB, and Managing Director of NOVOAIR, the memorandum argues that the current draft serves more as a statement of intent than a practical program for action. The association emphasises that for the aviation sector to achieve its potential as an economic enabler, the government must adopt a more rigorous, evidence-based approach to governance and market management.

The critical imperative: Separating regulator from service provider

The most urgent issue identified by Md. Mofizur Rahman, who is also Managing Director of NOVOAIR, is the need for a fundamental institutional separation within the civil aviation framework. Currently, the Civil Aviation Authority of Bangladesh (CAAB) operates under a structure where it simultaneously serves as the policymaker, the safety and security regulator, the operator of airports, and the provider of air navigation services. The AOAB contends that this lack of legal separation creates inherent conflicts of interest and hampers the credibility and effectiveness of safety oversight.

To rectify this, the association recommends a clear division of responsibilities where the Ministry of Civil Aviation and Tourism (MOCAT) is defined strictly as the policymaker. Under this proposed model, an independent technical regulator would be established to focus solely on safety, security, licensing, certification, and surveillance. Meanwhile, commercial operations, including airport management and Air Navigation Services (ANS), would be transitioned to separate service-provider entities. This restructuring is presented not merely as an administrative preference but as a vital necessity for ensuring fair competition and institutional transparency within the industry.

Establishing independent economic oversight and accident investigation

Expanding on the theme of institutional clarity, AOAB calls for the creation of an independent economic oversight body. This entity would be tasked with regulating airport and ANS charges, managing monopoly concessions, and ensuring that service quality meets international standards through a transparent price-quality framework. The association argues that aeronautical charges must be transparent, cost-related, and non-discriminatory, subject to prior consultation with operators.

Furthermore, Md. Mofizur Rahman has strongly advocated for the establishment of a statutory, independent accident and serious-incident investigation bureau. While the government's draft policy proposes waiting until 2035 to form such a body, AOAB insists this timeline is far too distant and does not reflect the critical importance of investigative independence. Instead, they recommend that this bureau be established within 18 months of the policy's adoption, with a clear mandate focused on accident prevention and the public tracking of safety recommendations rather than the assignment of blame.

A cautious approach to market liberalisation and traffic rights

The memorandum also addresses the complexities of "Open Skies" and international market access. AOAB is not inherently opposed to liberalisation but cautions against rigid, date-based regional targets which may not account for reciprocity or the readiness of domestic carriers. Instead, they propose an evidence-based framework for granting additional capacity and fifth-freedom rights.

Decisions regarding international traffic rights should be based on national benefit, actual market use, and the available capacity of local airports. Md. Mofizur Rahman emphasises that the policy must ensure a fair opportunity for Bangladeshi carriers to compete effectively. Additionally, the association calls for a transparent and recordable method for allocating rights and slots, including "use-it-or-lose-it" conditions to prevent the hoarding of valuable airport access.

Addressing operating costs and enhancing fiscal competitiveness

One of the most significant hurdles identified by the AOAB is the high cost of doing business in Bangladesh's aviation sector. High jet fuel prices, unpredictable taxation, and difficulties in accessing foreign exchange for aircraft leasing and maintenance are cited as direct impediments to fleet growth and investment. To combat this, the AOAB recommends that MOCAT lead an annual aviation cost-competitiveness review in coordination with the Ministry of Finance, the National Board of Revenue (NBR), and Bangladesh Bank.

This review should benchmark local fuel prices and taxes against competing regional hubs to ensure Bangladesh remains an attractive environment for aviation operations. The association also pushes for a dedicated aviation FX facilitation mechanism to assist operators during systemic currency shortages and calls for the clarification of tax treatments for aircraft leasing and remittance.

Dismantling monopolies in ground handling and support services

In the realm of airport operations, AOAB strongly opposes the continuation of monopolies in ground handling and other essential support services. They argue that airport support services should be treated as part of the aviation value chain rather than unavoidable monopolies. At major airports, the association recommends that more than one qualified provider be licensed to ensure competitive service levels and transparent concession terms.

Crucially, the AOAB advocates for the right of airlines and helicopter operators to self-handle their ground services using their own approved staff and equipment. They believe that promoting effective competition in ground handling, refuelling, and catering will lead to better service standards and lower costs for both operators and passengers.

Strengthening consumer protection and domestic connectivity

The association also identifies a need for more robust passenger rights regulations. The current draft policy is criticised for only offering broad rights and a basic cancellation-notice requirement. AOAB recommends the issuance of detailed regulations covering duties related to information provision, delays, refunds, rerouting, denied boarding, and baggage complaints.

To improve domestic and regional connectivity, Md. Mofizur Rahman suggests the introduction of a Bangladesh Regional Connectivity or Public Service Obligation (PSO) scheme. This program would use transparent, competitive bidding to award time-limited viability-gap funding for essential but commercially unviable routes. Such a scheme would provide social and administrative benefits to underserved locations without becoming a permanent protection for poor performance.

Strategic support for specialised aviation sub-sectors

Finally, the AOAB highlights that the policy must provide specialised pathways for sub-sectors like cargo, MRO (Maintenance, Repair, and Overhaul), and emerging technologies. They propose the creation of an Air Cargo Logistics Council and a digital "single window" to streamline the logistics chain and improve trans-shipment dwell times. For the MRO sector, AOAB recommends it be treated as an export and infrastructure service, providing customs facilitation and bonded movement for parts and tools to keep maintenance expenditure within the country.

The association also calls for a risk-based regulatory framework for Unmanned Aircraft Systems (UAS), commercial drones, and eVTOL technology. To ensure the long-term success of these initiatives, AOAB demands that a costed implementation plan be published within six months of the NCAP's adoption, supported by the creation of a National Aviation Policy Council to monitor progress and coordinate cross-ministry issues.