I assume I'm the Matt you're referring to
As
@AIRwin says, I am planning to make a submission on behalf of AFF. However, you are absolutely more than welcome to make your own submission as well. In fact, I would encourage you to do so. The more, the merrier!
This Green Paper, and the current increased scrutiny on airlines in this country, could be a rare opportunity to get some positive change if enough people raise their voices.
Matt - best of luck with this, at the very least in your position you should be able to bury the government in numerous specific details about airlines:
1. One sided, legally dubious and hidden T&C's/fare classes and other "gottcha's".
2. Poor performance in customer communications at all levels (call centers and woeful IT & lack of follow-up with complaints).
3. Complete lack of respect of passengers' time in fixing issues caused by airlines and lack of flexibility
4. Slot hoarding/squatting and "consolidation of flights" especially in the golden triangle routes for yield management but making up excuses about the weather.
5. Predatory competitive conduct with low fares on competitive routes & high fares on monopoly routes
6. Airport monopolist behavior.
7. A pointless and useless Airline Customer Advocate.
8. Lack of capital investment in capacity and "race to the bottom" on wages and conditions = lack of staff
9. Attempted exclusion of competitors by incumbents.
10. Federal government's lack of funding for the ACCC to monitor competition concerns.
Among many others! I expect the airline's submissions will also push back on many of these problems as being related to Covid and the various state and federal government responses to Covid, so some trends in flight cancellations and prices and statistics "precovid" and "post Covid" might be enlightening and might bypass the attempts by all to just blame all these problems on Covid. I think you're in a position to clearly show that the pattern of behavior was already there before Covid, but Covid and its responses certainly did have an effect.
One thing for sure, we now have a dysfunctional uncompetitive airline industry with high barriers to entry, dismal performance on nearly every metric able to be measured, and higher fares, and very low quality service levels and customer satisfaction than nearly every other market.