Written evidence from Interlinking Transit Solutions Ltd (AS 115) About Interlinking Transport Solutions Ltd. Interlinking Transit Solutions Ltd (ITSL) is a small group of independent engineers and other professionals dedicated to improving transport connectivity around . Our work for the past six years has concentrated on a low environmental impact solution to London’s aviation capacity issue and railway connectivity. We have previous experience with the planning and building of elevated light rapid transit systems similar to the system we are proposing. The group also has experience of M25 construction, bridge design, building design, and airline operation, railways and automated control. For this project, we have received help in modelling this proposed light rapid transit system from one of the world’s largest designer and manufacturer of transportation systems, which are installed worldwide. Our evidence relates particularly to the Committee’s interest in making the best use of existing aviation capacity and increasing that capacity. It focuses mainly on surface access, resilience, and environmental impact.

SUMMARY

• The number of airline passengers transferring between London’s is too few to justify the cost of a rail link between the airports. However, by connecting existing railway lines crossing the M25 with a rapid transit light railway, the total number of passengers using the link would create a business case to link the airports. The special capabilities of the proposed light rail system enable it to carry baggage, cargo and mail, the extra revenue from which will justify the railway for private investment. • Given the existing airport profiles and the environmental and cost constraints, London’s aviation capacity, connectivity, convenience and efficiency can more sustainably be increased by using the facilities that London already has to maximum effectiveness by creating a multi-airport hub - for example, slots would be increased by 35% and business destinations to 212 for each airport. The best way to create an air-rail link is to use the M25, M23, and corridors as the route. • The most rapid, cost-effective, and practical technology that can cope with the steep gradients, tight bends and obstacles needed to negotiate the motorways and take passengers right up to check-in areas in the airport terminals, is a light rapid transit system, elevated where necessary, using technology proven in use over the past 26 years. • The rail link would encourage the shift from short haul flights, e.g. to Leeds or , onto the railways. It would facilitate the displacement of lower yield flights to less busy airports like Luton, Stansted and , yet enable them to be connected to Gatwick and Heathrow. It would also facilitate greater use of the existing available capacity at Luton and Gatwick. These will help Heathrow and Gatwick focus on larger intercontinental jets whilst creating surface access that could serve any possible changes in airport activity that might occur around London. • A mullti-airport hub is not a conventional solution for most cities but London has the constraints of planning, environment and the need for new infrastructure to pay its way. With access to +30% destinations for Heathrow, +106% for Gatwick from inking the airports by a 31 – 36 minute transit, the solution will suit many passengers, over 70% of whom - including business people - are travelling on a budget. • Road congestion and pollution around the M25, especially near Heathrow, can be reduced by approximately 15% if it were convenient for those who would otherwise use cars, to take trains from their local stations. For example, 71% of people from the South West drive to the airport. They could instead transfer to a light rapid transit link by taking a train to Iver, Staines or . • With access to all London runways, getting planes out of the holding stacks and onto the ground more quickly will reduce airline pollutants. The immediate savings in fuel and CO2, provide additional justification for a multi-airport hub. • This access to additional runways provides resilience in the event of weather or other contingency situations because passengers can easily be transferred back to their original intended airport destination whilst the plane remains where it landed.

• Congestion on systems will be reduced if passengers living within the M25 or beyond it, can transfer between railway lines at the M25 rather than travel on trains and underground into central London to change between termini. • We have spent six years researching the feasibility and the design for a privately financed rapid transit system that will solve London’s aviation issues and contribute to its infrastructure. The solution is the London Air Rail Transit system (LARTs), named as LARTs RapidRail A. What the proposal is - an elevated light rapid transit along the motorways

1. Air and rail strategy for improving aviation capacity. It is generally agreed that the UK benefits from being an international aviation hub but this function is being eroded by constraints on expansion at the main hub airport, Heathrow, which include runway capacity and surface access, but not terminal capacity. Other issues are the scarcity of development land for making connections, pollution and landscape conservation. Luton and Stansted, and to a lesser extent Gatwick, have runway capacity, and all four airports have terminal capacity for over 15% more passengers. An economic and sustainable way to improve capacity would be to link these existing facilities together to create a uniquely British solution of a multi-airport hub, providing that the journey time between them is acceptable to passengers. The other main solutions - Runway 3, new Estuary Airport, Express - will be more expensive, have more environmental impact and not contribute as much to London’s and the UK’s overall transport infrastructure than our proposal. Because there are insufficient airline passengers transferring between airports to justify a surface link (although these would increase if a link existed), a business case for a link can be made if other passengers can also use the link, e.g. railway travellers, airport staff and road users. 2. A new M25 light rapid transit system would be the best solution. The LARTs RapidRail system is a low environmental impact plan that can be combined with other strategic aviation measures to increase capacity and maintain London’s hub status. The plan is to construct a light rapid transit, elevated where necessary, alongside the M25, M23 and M1 (and eventually the M11 if Stansted is included). It will not only link the airport terminals to each other, but also link them to the railways where these cross the M25. Only this light transit solution, has the capability to reach into existing airport terminals and railway stations to achieve this and be cost effective enough to be privately financed, as well more acceptable in planning terms. (Appendix 1)

3. Creating capacity and convenience from linking railways to airports. The system would not only improve the capacity, connectivity, and efficiency for aviation but also for rail and road travel around London and further afield. The automated system can combine both an express service between airports and a stopping service at railway stations along the route. The capability and flexibility of the technology will also enable it to make connections with and HS2. By interlinking the railways radiating out from the centre of London with each other and with the airports, LARTs RapidRail makes London more attractive to use as a hub for those transferring between airports and those travelling into and out of, and around London. It also reduces congestion on trains and the Underground within central London. 4. Connecting airports with reliability, frequency and short journey times. The link has to be reliable and have acceptable connection times for airline passengers and employees at airports. The same technology we propose has been used in six other major cities around the world to link their populations directly to their airports. The first system was opened in Vancouver in 1985, where it has operated with 98% reliability. Other systems are in NewYork, Kuala Lumpur, Beijing, Seoul and Dubai. The system has the capability of running a train every minute in each direction for 24 hours/day along the dual track guideway, mixing express and stopping services using a precision automated control system and stations that will to allow express through trains. Trains would depart every four or five minute from the airport terminals, which is ample time needed to load and unload 100 – 150 passengers. Journey times would be 31 minutes between Heathrow Terminal 5 and Gatwick South, and 38 minutes between Terminal 5 and . With the system extended throughout Heathrow and Gatwick, the journey time from Terminals 1,2 and 3 or Terminal 4 to Gatwick would be 36 minutes. Within Heathrow, the journey time between Terminals would be 4 – 10 minutes at a frequency of about every 12 minutes. For over 70% of airline passengers who are travelling on a ‘budget’, these transfer times improve on existing journey times between or within the airports and create options and choices that are made more attractive by the frequency, predictability, and 98% reliability of the automated light rapid transit technology. No airport bound passengers will be delayed from traffic congestion or road works on the M25. (Appendix 2) 5. Capacity of the system. With 48 passenger trains and 12 baggage trains an hour, the system will have more than enough capacity to carry the predicted 23 million passengers/year as well as baggage, cargo and mail. The relative mix of passenger and baggage trains can be varied according to demand throughout the day and the total capacity of system can be increased to carry by 60 million passengers/year. The system can include airside-to-airside connections for baggage, cargo and freight, and for airline passengers if the demand exists. 6. Staged implementation for the orbital plan. The whole plan is a very large London wide infrastructure project that would be made manageable by implementing it in affordable stages and phases of construction and operation. The first proposed stage, taking four years to construct, would connect Staines and Heathrow as a replacement for the cancelled Airtrack scheme. The next proposed construction stages taking 10 years would extend the system along the M25, M23 and M1 to connect Gatwick and Luton and 11 stations on railway lines intersecting the M25. The connections would include Great Western trains to and Cardiff at Iver; West Coast trains to Birmingham at Kings Langley; to Southampton and the south west at West Byfleet; Southern trains to the south coast at Merstham; and South Eastern trains to at Sevenoaks. Further extensions northeastwards round the M25 would connect the East Coast mainline at Potters Bar, and Greater Anglia at Waltham Cross for a Stansted connection or extend up the M11 to Stansted itself. (Appendix 3) 7. Stage One - Staines to Heathrow. The first proposed stage taking four years and costing £850m would connect Staines with Heathrow Terminal 5. This would fulfil all the obligations of the cancelled Airtrack scheme, with more benefits and fewer liabilities. Revenue from this first stage makes the stage financially self-supporting, so that this short section of the project becomes a model for the wider system. Our proposal is for a six minute journey time shuttle from Terminal 5 (and between Terminals 1-2-3 and 4 at a later stage), with a peak frequency of eight per hour, which matches the number of the South West trains to Waterloo. The journey between Terminal 5 and Waterloo Station on an existing SWTrains service would take 48 mins, including a 4 min transfer. The LARTs RapidRail shuttle would generally follow the Airtrack route but would have a platform alongside the Staines down platform. Passengers with their luggage would have an easy transfer between the two because the train technology and construction of LARTs RapidRail enables its platforms to be above existing station platforms and connected to them by a bridge so there is just one vertical manoeuvre using a lift or escalator. There is also no step into the rapid transit trains because the train floor and platforms will be at the same level. 8. Enabling all mainland UK to travel by rail to London’s airports. To complete the concept of an orbital transit system, further stages would extend the rapid transit system to the north bank of the at Tilbury, and to the south bank of the Thames at Ebbsfleet International. With all stages of the plan completed, passengers from all parts of the country will be able to transfer to LARTs RapidRail to get to London’s main airport terminals from their local railway stations. Similarly passengers inside the M25 and travelling outwards will also be able to make convenient transfers from railway or stations onto LARTs RapidRail direct into airport terminals. These create a huge potential ridership for the system, whether using it to go to airports or to other rail destinations. (Appendix 4)

B. How the plan would improve London’s aviation capacity

9. Encouraging shift from plane to train. LARTs RapidRail’s ability to provide a quick direct connection between the railways and the airport terminals, means that airline passengers will find it convenient to transfer between them using LARTs RapidRail. The technology of LARTs RapidRail allows it to get close to the check-in areas at the airport terminals and to the railway platforms so making short walking distances and large time savings. Passengers between Manchester and Heathrow would have a 2hrs 30min journey by transfer to the West Coast mainline at Kings Langley. Leeds to Heathrow via the East Coast Mainline at Potters Bar would take 2hrs and Newcastle 3hrs 30 minutes. These rail connections would reduce domestic short-haul flights and they are more convenient for passengers with luggage because currently most journeys involve travelling into central London and having to cope with flights of steps etc when changing between terminii. The same LARTs RapidRail connectivity and convenience can also deliver passengers to Crossrail and HS2 to help reduce demand for domestic short-haul flights. 10. Utilising spare runway capacity to add more slots. At times when Heathrow’s holding stacks are full, Gatwick and Luton have runway capacity available that could be used for additional planned flights or for contingencies. Gatwick’s spare runway capacity is only 5%, but Luton’s is 44%. (Stansted’s is about 50%). By linking the airports, LARTs RapidRail will facilitate greater use of available spare runway capacity at busy times. If airlines know that their passengers have a quick and reliable way of transferring between airports, they should be more willing to use spare the capacity. We estimate that connecting the existing airports adds 35% more runway slots for London as a multi- airport hub. 11. Enabling rationalisation of flights. A suggested way of improving capacity for additional emerging market destinations is to move lower yield to some regional airports. LARTs RapidRail will help this by creating better links to London’s airports using the existing railways and reducing the travel time between them by removing the need to travel into central London to make the transfer. A journey from Heathrow to Birmingham International would be 90 mins instead of 140 mins now; to Southampton would be 80 mins instead of 105 mins now; and to East Midlands Parkway 120 mins instead of 163 mins now. (Appendix 4) 12. Adding more destinations to each airport. Capacity in terms of destinations can be added by linking the existing London runways. Excluding , Heathrow is the premier business destination airport with some 163 business destinations. Gatwick has 103 and Luton 49 business destinations. Linking these three airports by a light rapid transit so that they become one virtual hub enables each airport to offer 212 business destinations (227 if Stansted is included). The journey times for this ‘virtual hub’ of 31 – 36 minute between Heathrow and Gatwick and 38 – 43 minutes between Heathrow and Luton are not dissimilar to some existing transfer times between Heathrow’s terminals. (Appendix 5) 13. Improving the passenger experience with better surface access. Improving the ‘passenger experience’ is an aviation policy aimed to encourage passengers to use London as a hub. LARTs RapidRail will help by using its unique capabilities to provide connections to each terminal within 100 – 150m of check-in areas so reducing current walking distances. These convenient connections will be also between the terminals within each airport. Similar close connections to railway stations can be made, which is important for passengers encumbered with baggage. Combined with frequent express services between the airports and the main railway lines (e.g. Great Western, West Coast, and East Coast) and the stopping service for stations in between, the light rapid transit system (elevated where necessary) will provide a convenient and unique service for air and rail passengers that will be a match for or surpass any rival hub airport. We estimate that just by linking the airports, airline passenger numbers should increase by about 15% and airline yields by about 10%. 14. Baggage and airside-to-airside transfers add extra facility. The attractions of London as a hub can be further increased for users because the automated train technology of LARTs RapidRail makes possible an airside-to-airside system for carrying luggage, cargo and freight between depots. Combining baggage and passengers on the system is similar to combining stopping and express services on the main guideway. The system can also be used to carry airside-to-airside passengers if the demand exists – the financial viability for an airside system being created by the value and urgency of air cargo.

C. Why the plan is a low environmental impact one

15. CO2 emissions. By encouraging passengers, airport staff and meeters and greeters to leave their cars at home and take a train to the airports or to other rail lines on LARTs RapidRail, or for those will drive, to use a few strategically sited park & ride facilities on the motorways, we estimate that LARTs RapidRail will reduce vehicle journeys by over 10,000 /day around the busy western section of the M25 and especially on roads leading into Heathrow. This will reduce pressure for widening the M25 further - we estimate the system capacity will be equivalent to more than one lane of motorway- and help reduce CO2 emissions. Combined with the aviation fuel savings from reduced stacking in the sky and waiting on the taxiways because of the availability of extra runways, we estimate CO2 savings of 5m tonnes/yr. This also has health benefits for local communities.

16. Planning acceptability. The use of an already noisy and polluted motorway corridor, which is generally distant from housing development and involves no demolition, will be more acceptable than other routes for a new rail link. The noise level of our trains is quieter than motorway traffic: linear induction motors used for propulsion produce less wheel noise and steerable wheels, as well as helping negotiate bends smoothly and quietly, eliminate high pitched squeal noise. Visual impact will be minimised by keeping the elevated guide-way just off the ground for much of its route. This means that the trains can go under most motorway bridges. Only at stations and airports, and at some motorway junctions will the guideway need to be raised over obstructions. In sensitive locations, such the countryside near Reigate and at Wisley, short tunnels are included in the construction costs. Since the plan will benefit local communities by providing connections at local stations and by removing cars from local roads close to the motorway, there are incentives for stakeholders to support the plan. D. How does it work as a link - technology and transfer times 17. Appropriate, reliable and proven technology. The light railway technology proposed has been selected because of its suitability for the London situation. This system provides more flexibility and effectiveness than a monorail, heavy rail, maglev or buses for an application which has to surmount numerous challenges to connect existing facilities - for example to negotiate tight curves and steep gradients to get around or over existing motorway obstacles, and into railway stations, the baggage terminals, the upper floors of the airport terminals etc. The propulsion method used enables the trains to do this with an advantage over monorail because the trains can easily change tracks at the end of spur lines and at through stations, for the necessary flexibility. Headways between trains are uniquely short: the system has the capability of running a train a minute day and night in each direction along the guideway for 24 hours a day, thus adding viability for airport shift workers and freight during the night. 18. Proven construction technology. Construction methods designed to minimise disruption have been used successfully in other cities. Prefabricated pillars would be installed along the margin of the motorway upon which will sit prefabricated beams carrying the 7m wide twin track elevated guideway. The prefabricated components minimise disruption to the motorways because they can be installed from overhead using the advancing guideway. The most disruptive work, chiefly the foundations for the pillars, can be undertaken at night. 19. Proposed LARTs RapidRail stations. LARTs RapidRail capabilities include the ability to mix express trains with slower services stopping at railway stations along the same guideway. Passing is done either at the ends of spurs into existing railway stations or, at in-line stations alongside the M25 where sidings can be incorporated into the guide-way for platforms. LARTs RapidRail platforms will generally be above or close to the existing railway platforms and accessed by a short walk, and one vertical movement, by lift or escalator. 20. Safety. The system has very good reliability and safety record – in 27 years of operating the first such system, reliability has been 98% and there have been no fatalities due to operation and LARTs will use Passenger Edge Doors to enhance this record. In the event of an emergency on the guideway, passengers can be evacuated safely because the carriages have a low profile and the level difference small. The magnetic propulsion system is extremely reliable and presents no danger from electric shock if stepped on. 21. Comparison with heavy rail for speed, cost, and total journey time. The light rapid transit trains will be able to attain speed of 125 kph around the motorway following its curves and gradients. Heavy rail high speed trains would be faster but the wider turning radii need require land take well outside of the motorway corridor plus extensive tunnelling with the associated additional expense and planning concerns. Moreover, the time advantage of high speed heavy rail would be lost because its stations further from the terminals’ check-in areas than LARTs RapidRail stations. The short walks from LARTs RapidRail stations to check-in will be appreciated by airline passengers especially those with luggage. Therefore a 31– 36 minute predictable journey time on LARTs RapidRail between Gatwick and Heathrow compares very favourably with the aspirations of a high speed rail link of 15 minute journey time, with its added walking time. Additionally, by having a stopping service at railway stations combined with an airports express service, LARTs RapidRail will make a greater contribution to London’s transport infrastructure in order to pay for itself.

E. How the plan would be financed

22. Creating financial viability. Because the number of airline transfer passengers are too small to financially justify an airport-to-, the LARTs airport-to-airport link is simply part of the larger scheme interlink railways, airports and motorways, so serving passengers travelling by road, rail and air. Significant revenue is gained from services provided to some of the 100,000 employees at the airports, from meeters and greeters, from three park & rides (strategically placed to curtail many car journeys that would otherwise use the M25) and from carrying air freight as well as baggage. Contributions from local stakeholders in recognition of the economic and environmental benefits, plus carbon credits and other small revenues sources, such as advertising, all contribute towards financial viability of LARTs. (Appendix 6) 23. Cost and revenue. Under the proposed plan, the proposed first stage of would take 4 years and cost £850 million. The phased nature of the project means that revenue will commence after completion of the first phase, and thereafter increasing as stations are opened as the system is built out. The capital cost of the next stages completing an elevated light rapid transit from Heathrow to Gatwick and Heathrow to Luton, including the new stations at airport terminals and at railway stations, would be £7.2bn over 12 years with a rate of return of 8%, assuming increasing ridership of +3%/yr over 40 years. An operating profit is projected after 18 years and dividends after 10 years. Calculations have been based on a fare structure that would result in a single fare of £12 between the airports. The segregated nature of the system makes it possible to operate LARTs independently even though it integrates with existing rail and airport infrastructure. Providing there is central and local Government support for the project, the segregated operation makes it possible to attract private finance for the project so that it will not need to make a claim on the public finances. 24. Support and co-operation needed from government, airports, railways and others. The proposal needs central and local government support for planning and in negotiations with the railways, highways and airports. It would also need the active consent and co-operation of these sectors and of the airports, all of which will benefit considerably. LARTS benefit London as a whole by reducing car journeys across and round London and reducing public transport congestion whilst helping maintain London as a travel hub. The economic benefits are also for the whole UK and for the environment. This should help to gain support for the proposal. On the face of it, a multi-airport hub would be a unique compromise as far as aviation goes, yet also a brave investment in the integration of existing modes of transport, the sum of whose parts will deliver far, far more than each could do on their own. G. Recommendations to Government for action 25a. We recommend that Government policy seek to achieve the maximum use of all of London’s existing airport facilities as a means of increasing aviation capacity on the grounds of sustainability, cost effectiveness and make comparison with the Heathwick Express proposal. 25b. We recommend that Government study the London Air Rail Transit system (LARTs) proposal as a surface access means for improving connections between airport terminals and railway stations so creating a cost effective and sustainable multi-airport hub, whilst also reducing road congestion and emissions. 25c. We recommend that Government study the wider economic benefits of the London Air Rail Transit system (LARTs) proposal as an orbital transit system connecting airports and railways with the legacy contributions it makes to London's transport infrastructure and the national railway network. 25d. We recommend that Government consider how the London Air Rail Transit system (LARTs) proposal can add to the benefits of Crossrail and High Speed Rail. 25e. We recommend that if Government supports the strategy of a privately financed London Air Rail Transit system (LARTs), it provide assistance to the proposal by way of co-ordinating highway, rail and aviation authorities and of assisting with the legislative procedures necessary for the plan to be implemented.

8 November 2012

LARTs RapidRail trains on the dual track guideway along the M25

RapidRail – Connections made after first stages

LARTs RapidRail first stages would connect railways along the motorways with the three airports

APPENDIX 1

RapidRail - Total journey time comparisons

LARTs RapidRail convenient and rapid connections improve journey total times between destinations

APPENDIX 2

RapidRail – First construction phases

First phases of LARTs RapidRail plan to connect Gatwick-Heathrow-Luton and railway lines between

APPENDIX 3

RapidRail – Completed plan for M25 orbital light transit

The Buckley plan is for an orbital LARTs RapidRail elevated light rapid transit system around the M25

APPENDIX 4

RapidRail – Destinations added to airports

APPENDIX 5

RapidRail - Income

LARTs RapidRail is financially justified by revenue from a variety of sources to add to airport transfers.

RapidRail - Close up of trains on guideway

APPENDIX 6

Written evidence from TUI Travel PLC (AS 116)

Introduction:

TUI Travel PLC, the parent of TUI UK & Ireland, Thomson Holidays, First Choice Holidays and Thomson Airways welcomes the opportunity to submit a response to the Transport Committee inquiry into the Government’s aviation strategy. Thomson Airways, the UK’s third largest air carrier, operates a fleet of 65 aircraft to European, North American, Caribbean and Indian Ocean destinations a total of 85 destinations being served carrying approximately 10 million passengers per year.

Thomson Airways operates flights from 20 UK Airports and has aircraft and crews based at 15 airports, with the largest being Gatwick where we have a fleet of 15 aircraft. Such fleet disposition enables our tour operator consumers to fly from their ‘local’ to short haul and medium haul destinations. For its long-haul operations Thomson Airways flies from around 8 UK airports serving the catchment areas local to that and other nearby airports that would not, themselves, support direct long-haul flights. For example Bristol would support the , Cardiff and airport catchment areas for its long-hall operations. Newcastle likewise supports Edinburgh, Doncaster, Durham-Teesside airport catchment areas.

Summary:

TUI Travel is concerned that the current aviation debate is principally focussed upon the contribution to the economy made by business travel and inbound tourism. The significant value to the UK economy of outbound tourism also needs to be understood and considered. A recent study for ABTA shows that outbound travel directly accounts for 1.6% of UK GDP (£22 billion) with a total economic impact through the supply chain of 3.8% of GDP (£55billion)1.

The TUI UK & Ireland business model is constructed such that we provide flights from the customer’s local airport to a wide range of destinations that is driven by the demand from within that catchment area; it follows from this that our largest bases are Gatwick, Manchester and .

Thomson Airways does not operate from London’s , although our tour operators do offer holidays on flights departing from Heathrow. It follows that, for us, the debate on the UK’s hub capacity is not our central concern, save to the extent that a decision on such hub capacity may indirectly impact our operations at other UK airports.

Responses to the Committee’s questions:

1. What should be the objectives of Government policy on aviation?

We are concerned that Government, including the Department for Transport, appears too often to signal that it considers business travel to be in some way superior, or more worthy of support, than leisure travel. We reject any such notion. For example DfT officials has recently stated that the most efficient use of an airport slot is based upon the economic benefit of that slot through the revenue it generates from First and Business class passengers. Conversely we would argue that for the same aircraft type, our high density seating aligned with high load factors that also deliver a more

1 Driving Growth – The economic value of outbound travel (2012). environmentally friendly use of the slot through reducing the CO2 per passenger kilometre is the most efficient use of that scarce resource. Given what we say above about the importance of the outbound tourism industry to the UK economy, our view is that the government policy on aviation should consider all modes as equal players and policy should not favour one particular sector over another.

Further, the policy should be fully cognisant of the need for sustainable growth of the industry. TUI Travel is committed to reducing its carbon footprint and we believe that Government Aviation policy should incentivise such behaviours, as we will explain in greater detail later in this response.

a. How important is international aviation connectivity to the UK aviation industry?

We will let others make the point for connectivity for business travel and visiting friends and relatives, however for TUI Travel our businesses are providing connectivity that enables the consumer to take well-earned holiday. Thomson Airways operates from 20 UK airports to 85 overseas destinations a network that is unique to charter operations.

b. What are the benefits of aviation to the UK economy? TUI UK and Ireland is providing its 6 million customers with the experience of travel, in the majority of cases from their local airport, that broadens horizons, provides rest and recuperation for many of the UK’s citizens where ‘taking the children on holiday’ was one of the areas highlighted by in his November 2010 speech as a contributor to wellbeing. Through our diverse range of holiday products that are sold through our 700 stores, to be found on most high streets, or via the internet we provide a wide range and mix of jobs and skills across the ; These range from the highly specialised pilots, engineers and IT professionals to the specialist high street holiday advisors and our administration teams in our head offices and call centres where we have a UK workforce in the region of 17,000 colleagues. Thus demonstrating the economic value of connectivity across the UK airports.

c. What is the impact of Air Passenger Duty on the aviation industry?

In our view the levels of APD has the effect of dampening and displacing demand. We have seen this effect in our sales in Ireland where holiday sales for departures were increasing for residents of Northern Ireland as a result of the different rates of APD in place.

c. How should improving the passenger experience be reflected in the Government’s aviation strategy?

In order to manage customer retention it is incumbent upon us as a business to put the customer at the centre of our holidays and flight offerings. Since the late 1980’s Tour operators have historically led the way in providing good customer service and in particular appropriate welfare and assistance during flight disruption. We are therefore well placed to work with the government to share best practice and improve the customer experience. Most UK Airports work voluntarily with their stakeholder partners to agree service level agreements, where additionally Heathrow and Gatwick airports fall within the regulated airport sphere. The industry over recent years has worked together to improve customer service to the extent that, for example security queues, when departing an airport, are generally a thing of the past. However the same cannot be said of arrival queues at the UK Border primary line. Despite a very good record during the Olympics and Paralympics where money and resources were made available to the UK Border Force to ensure a smooth passage, we remain particularly concerned at the service quality levels at the border going forwards; in particular the current methodology of measuring queues as the average queue length as opposed to the actual. The SLA targets are not demanding enough with a 25 minute for UK/EU nationals and a 40 minute for non UK-EU nationals. We firmly believe that this should be significantly reduced. On a similar note whilst we fully recognise and accept that the need for a strong UK Border, this is not incompatible with good customer service. We refer to the Home Affairs Committee report2 where they call for a return to risk based controls based upon the evidence provided by TUI Travel into the costs and benefits of e-Borders.

e. Where does aviation fit in the overall transport strategy? We believe that aviation should fit into a national transport strategy and that strategy should include better surface access to airports. We refer in particular to our evidence provided to the transport committee3 in relation to the problems associated with severe snow in 2010 and 2011.

2. How should we make the best use of existing aviation capacity? TUI Travel supports the announcement by the Secretary of State for Transport of the implementation of the Aviation Commission headed by Sir Howard Davies, we are concerned however at the delay to the government decision of airport capacity and would welcome any moves to bring forwards the Commission’s reporting dates.

a. How do we make the best use of existing London airport capacity? Are the Government’s current measures sufficient? What more could be done to improve passenger experience and airport resilience?

We believe that the recommendations of the Aviation Commission, when published, should be adopted by both the current government plus also by cross party support thus creating a clear aviation strategy that can continue even with any change of government. It is difficult for us to make the right investment decisions when government strategy is unclear, or at worst non-existent as at present.

b. Does the Government’s current strategy make the best use of existing capacity at airports outside the south east? How could this be improved? c. How can surface access to airports be improved?

We do not believe that there is a capacity issue outside of the South East and that any growth can be accommodated within the existing framework.

3. What constraints are there on increasing UK aviation capacity?

TUI Travel believes that restrictions designed to limit climate change are the biggest constraint upon increasing aviation capacity since any increase in capacity within the UK must be made within a clear sustainable framework. We support the Commission on

2 Home Affairs Committee – Sixth Report – The work of the Border Force, paragraph 25. 3 Thomson Airways submission to the Transport Select Committee looking at the impact on transport of recent adverse weather conditions: dated 25th January 2011.

Climate Change that growth can be achieved up to 2050 within the current climate framework

a. Are the Government’s proposals to manage the impact of aviation on the local environment sufficient, particularly in terms of reducing the impact of noise on local residents? b. Will the Government’s proposals help reduce carbon emissions and manage the impact of aviation on climate change? How can aviation be made more sustainable? c. What is the relationship between the Government’s strategy and EU aviation policies?

The recent UK Department for Transport consultation on its Aviation Policy Framework stated at paragraph 3.31 “In the last 10 years, although air traffic has increased by 45 per cent, the demand for jet fuel has increased by only three per cent” This reflects the measures that airlines such as Thomson Airways have taken to reduce fuel burn and therefore emissions. Our current emissions are 73.1g CO2 per Revenue Passenger km [FY11/12] one of the lowest in the UK. Our fleet replacement programme will see Thomson Airways operating one of the youngest fleets in the UK by 2020. We do not subscribe to the view that yet more regulation or legislation is required. Airlines could be incentivised to operate more sustainably through, for example, gearing landing fees & charges to reflect airline fuel and carbon efficiency per passenger per 100kms. Government should publish an agreed method for calculating and reporting grams of CO2 per RPK

As a founding signatory of ‘Sustainable Aviation’, TUI Travel believes that the aviation industry will reduce its actual carbon emissions through a combination of:

• Technology – airframe and engine • Sustainable alternative fuels; and • Operational improvements

In its recent CO2 Road Map, SA concludes that UK aviation is able to accommodate significant growth to 2050 without a substantial increase in absolute CO2 emission. SA supports the reduction of net Co2 emission to50% of 2005 levels through internationally agreed carbon trading.

In October 2011 Thomson Airways was the first UK Airline to carry out flight biofuel trials on a commercial passenger route, The Government should play a key role in supporting research and development in aerospace technology, encouraging the introduction of sustainable biofuels, delivering on infrastructure projects such as the Single European Sky initiative and working with other countries to establish a global sectorial approach. TUI Travel does not support unilateral UK targets and measures, as they would be unnecessary and counter-productive.

Recent and future developments in aircraft and engine technology will play a major role in reducing the UK’s carbon intensity. We anticipate absolute CO2 emissions will continue to fall post-2050 due to the on-going penetration into the fleet of new wide- body aircraft types entering service from around 2035 onwards. The same technologies will also be deployed on a world-wide basis, with a correspondingly greater CO2 mitigation impact.

TUI Travel therefore supports the SA position and believes that the Government Aviation Policy should:

• Support the development of more efficient aircraft and engine technologies which will be deployed on a worldwide basis; • Support the development and large-scale deployment of sustainable aviation fuels offering very significant life-cycle CO2 savings relative to conventional fossil-based fuels; • Work with international partners to enable more efficient air traffic on non-domestic routes, within the context of increased capacity requirements; • Press for agreement on and support implementation of a global carbon-trading solution, encompassing all of aviation and ensuring a level playing field for all participants.

In late August 2012, TUI Travel launched its three-year Sustainable Holidays Plan [2012 – 2014] as well as our 2011 Sustainable Development Report. The Plan has 20 commitments including those that cover carbon management and specifically aviation. In addition, TUI UK [Thomson Airways] has a set of 20 SD Commitments, referred to as its Holidays Forever commitments, again a number of which are carbon and aviation related. Airlines are already doing their part to minimise impact- two way partnership shows government is taking the matter as seriously as the airlines are

4. Do we need a step-change in UK aviation capacity? Why?

TUI Travel will support the need for additional sustainable capacity at those airports that have demonstrated that they are capacity constrained where the only solution is to increase capacity at that airport. This situation currently only affects the South East airports. Gatwick is currently our largest aircraft base where we sustain the operation of 15 aircraft, whilst meeting the catchment area demands of our customers enabling them to fly from their local airport. It is not a feasible option to suggest that passengers living in, say, Brighton should be forced to travel to Stansted in order to catch their holiday flight. Our policy is to base aircraft where the demand is, and thus we do not believe that government policy should dictate from which airport a consumer must fly. It should be noted that previous attempts, by government, at traffic distribution between Scottish and London airports have failed either through legal challenge4 or through market forces when such restrictions were lifted.

Conclusion:

TUI Travel believes there is a need for a clear strategy that sets out a long term vision for aviation in the UK. Ideally, such a strategy should have cross-party support that would prevent the see sawing of aviation policy that we have experienced during the last fifty years. Such an aviation policy should be consistent with the UK Committee on Climate change recognition that aviation can still grow within the UK’s climate policy up to 2050. The government strategy needs to recognise each sector as equal partners and not favour one sector over another in coming to its policy and strategy conclusions.

TUI Travel welcomes the opportunity to submit this written evidence to the Committee and regrets that it was not possible on this occasion to appear during the oral hearings.

We would be pleased to supply any supplementary responses to any further questions that you may have following the submission of this response.

9 November 2012

4 Air 2000 vs Department for Transport – Scottish Airports traffic distribution legal challenge Written evidence from Dr. Mayer Hillman (AS 117)

Catering for more air travel

Agreement on a need to find the best solution to match the rising demand for air travel, especially in the South , has certainly been made very much easier by the near-unanimous support from all three of the main political parties for this aspect of policy for the future. It fits in well with the commonly-held view that governments have a responsibility to do their best to meet the demand for what people want to do, such as being able to travel further and faster, and as frequently as they wish, and that restrictions on their preferences should only have to be imposed in extremis.

This degree of support is mirrored, too, in the call from leaders within the business community, the trades union and well-informed media commentators on public policy, to invest more in ‘infrastructural projects’. In a recent Observer article, Will Hutton criticised the current Coalition for its failure to give the go-ahead to the new airports ‘we so desperately need’ to speed up the country’s return to economic growth and to create more jobs.

Very few academics, economists or consultants in this field hold dissimilar views. However, as a significant number not only rely on Government commissions but are working on them, the absence of any critical comments on the justification for more capacity for air travel should not necessarily be taken as demonstrating their support. Whatever their private doubts, they probably feel that their involvement debars them from voicing in public any concerns they have about the case for proceeding with building more transport infrastructure.

The implications of climate change

Supporters appear to be unaware of the critical contradiction between aiming to meet the growing demand for long-distance travel by air while at the same time limiting the devastating consequences of climate change. It may be that they are in denial of the scientific evidence on this; or think it insufficiently relevant to the current policy of promoting economic growth, almost at any cost.

However, no domain of policy can sensibly be determined without reference to factors that could substantially affect it. In this instance, the overriding consideration relates to the impact of climate change on the future habitability of the planet and on the quality of life of its inhabitants. Appropriate decisions on future investment generally and airport capacity in particular are a case in point.

Now that the significance and implications of climate change are becoming more widely understood, a distinction must surely be drawn between developments which are detrimental to our long-term future (such as those resulting from policies which facilitate, if not subsidise, carbon-intensive activities) and those which are not? Current patterns of fossil fuel-based transport activity alone are already way in excess of the safe level beyond which the equilibrium of the climate system can be assured.

In considering the consequences of catering for more air travel as part of a strategy aimed at establishing how best to do so, all the costs incurred, in so far as they can be calculated, should be included in the cost-benefit analysis. These should obviously include those stemming from adding further greenhouse gases from fossil fuel use to the current disturbingly high atmospheric concentrations. These gases are already the cause of the deteriorating condition of many regions around the world, and are responsible for a process leading to the enforced migration of millions of people. This is a major moral as well as an economic issue that remains to be addressed. Were these additional costs paid for in the transport sector in fares, the projected demand would clearly fall substantially, and the justification for expansion of the infrastructure to accommodate further air travel would be exposed and then seen to be highly questionable. If realised, any proposal aimed at facilitating the predicted growth in air travel, let alone maintaining it at its current level, would make an environmentally damaging contribution to a higher carbon future just at a time when the need to urgently reverse this process is becoming ever more imperative.

The spreading addiction to fossil-fuel-based lifestyles around the world, not least in the transport sector, is pointing to the very real prospect of ecological catastrophe on such a scale as to gravely prejudice the quality of life – if not life – prospects for the generations succeeding us. The time is long over for burying our collective heads in the sand on this most critical of issues for we are at a defining moment in history: it is essential that we recognise both the gravity of the situation and the necessary steps that have to be taken in light of it.

There is now near-consensus in the scientific community that human-induced global warming poses the greatest threat ever to have faced mankind. A recent IPCC (Intergovernmental Panel on Climate Change) report included the calculation that a curtailment of fossil fuel use down to zero carbon emissions must be speedily achieved – that is way beyond the widely accepted figure in the UK of an 80% reduction by 2050 which is, in any case, now widely recognised as a seriously insufficient target to prevent irreversible climate change.

What is overlooked is the fact that the planet’s atmosphere has only a finite non-negotiable capacity to safely absorb the gases from further fossil fuel use, especially those released into the upper atmosphere. The absence of suggestions as to how the ice cap in the Arctic can now be returned to its former area rather than continuing to rapidly decline provides near-indisputable evidence for believing that that capacity has already been exceeded.

Conclusions

Politicians and the public alike need urgently to realise that there is only one way of achieving the essential and early goal of close-to-zero carbon emissions. It is the adoption of the GCI (Global Commons Institute) ‘Contraction and Convergence’ framework (see the GCI website at http://www.gci.org.uk) which may well lead to the introduction of per capita carbon rationing. If we are to limit the extent of further loss of the planet’s habitability, that ration will have to be so small that little air travel will be possible. We cannot continue to deceive ourselves that long-distance journeys by air are not too profligate in fuel use and that the resultant greenhouse gas emissions can be added to their already excessive concentrations in the atmosphere.

So, one may ask, what is the logic of seeking to find the best way to cater for the growing demand for air travel?

14 November 2012 Written evidence from Why Not Manston? (AS 118)

1. Our organisation www.whynotmanston.co.uk was set up in August of 2012, and adopted a Constitution in late October. The group was established to demonstrate the importance and the ease of increasing the use of in north-east Kent. At the moment it is mainly used for cargo transport, with very few services for passengers. That situation will change in April 2013, when Air France/KLM will be running regular flights to Schiphol Airport (see our para 4 below). We also intend to show that it is quite unnecessary to build any Estuary Airport, when Manston is already there, less than twenty miles from the proposed site of the Estuary Airport.

2. We submitted evidence on the Government Consultation Document on Aviation Strategy, in time for their deadline of 31st October. We are delighted that the Commons Transport Committee is holding its own discussions on the matter, with an earlier deadline.. Unfortunately we were not aware of your separate enquiry until 19th November, when the oral evidence from your first set of witnesses was publicized. Our evidence below is based on the Government Consultation Document on Aviation Strategy. We take some of the items numbered in this Document and give our comments on those.

3. In Item 1.2 the Document refers to communities living close to an airport, and says that they must be consulted. During our first three months of existence, from August to October 2012, we acquired 300 supporters, and one third of them live in Ramsgate and Margate, right under the flight path for Manston. So despite their proximity to the airport, many locals are keen and eager to see Manston more widely used.

4. Item 1.10 refers to the importance of airports connecting in some way with a major hub. On 13th November 2012 Air France/KLM announced that KLM is going to start regular flights to and from Manston to Schiphol in Holland from April 2013. Schiphol is a major hub only 40 minutes flight time from Manston.

5. Item 1.17 The Document says how important it is to limit and reduce the number of people significantly affected by aircraft noise. One of the beauties of Manston is that it is surrounded on three sides by sea. So only a quarter of its flights are likely to affect local inhabitants by aircraft noise. However, only a quarter of that quarter of flights is likely to create noise, because of the prevailing wind patterns. In effect, the vast majority of the flights from Manston take off and land over open countryside. For more detail on this, see the Night Flights page of our current website. When it comes to flights at night, where concerns have been raised, the number of such flights likely to cause a noise nuisance would amount to just one such flight every other night: hardly a major cause for concern.

6. Item 1.24 refers to aviation safety. With so many planes queuing to land at Heathrow and Gatwick, there is the ever-present danger of a collision, or even planes running out of fuel while being forced to stack. That is a particular worry when, as does happen, an entire runway at Heathrow is out of use because of a technical problem on the ground. At Manston, with so few flights, dangers of such a collision are negligible. But even if a plane did crash to the ground, it would almost certainly fall in an empty field. This contrasts with the Heathrow area, where any such plane crash-landing within five miles of Heathrow would be likely to kill or injure hundreds of people on the ground. So greater use of Manston could substantially improve safety, both in the air and on the ground. (continued . . .) 7. Item 2.11 considers how to reduce the delays and disruption caused by things not working smoothly. That surely applies not just to delays at Heathrow itself, but delays in reaching it via the M25, which is at capacity in the mornings, when many of the flights take off and land. There are no such delays at Manston in the airport, where checking-in takes ten minutes and departure is within the hour. Nor is there any reason to expect delays in the motorway or rail connections with Manston.

8. Item 2.22 talks about connectivity with a major airport nearby. See our para 4 above, with the new service by KLM using Manston, which is only 40 minutes flight time from Schiphol.

9. Item 2.30 talks about the SE Airports Taskforce and its report, which was published in July 2011. However, this Taskforce was set up to consider only Heathrow, Gatwick and Stansted as “London airports”. No consideration was taken of other airports in the London region. In fact, it is just as reasonable to consider Luton as another “London airport”, and in that case, it is equally logical to consider Manston in the same light. Manston is situated next to a major motorway from London: the M2, and, by 2014 the High Speed Rail Line from St Pancras will reach Ramsgate in under an hour. Ramsgate is five minutes taxi ride from Manston. (For an estimated £10 million, the nearby railway could have a station right inside the Manston terminal.)

10. Item 2.65 quotes major developments and infrastructure improvements at no less than ten regional airports, but does not even mention Manston, with its major infrastructure improvements described above. However, part of the reason why Manston does not need major improvements to the airport is that it already offers so much. In fact, it has the widest runway in the country (and one of the longest), and can already accommodate the largest aircraft in the world, flying into this country.

11. So much so, that when Concorde was flying, Manston was designated as the emergency runway for Concorde, if such an emergency arose. It was also designated as the emergency runway for the Space Shuttle, if weather conditions prevented that magnificent monster from landing in California. There is a large amount of room for expansion around Manston. In fact, there is also no practical, environmental, or local population reason why Manston could not easily be provided with a second runway, if one were needed.

12. Lastly, a survey was undertaken by KLM and the Airport in the summer of 2012. Of over 9000 replies, 96% said they would be happy to fly from Manston if given the opportunity to do so. We can have no doubt that the inhabitants of East and Mid-Kent would be delighted if it were possible to fly abroad from East Kent, rather than have to drive for two hours halfway around the M25 to the other side of London, where their “nearest” airport is at the moment. Manston is within an hour’s drive from that entire area of East and Mid-Kent.

29 November 2012

Written evidence from Southend on Sea Borough Council (AS 119)

Introduction

Southend on Sea Borough Council`s interest in the development of the Aviation Strategy focuses on the proposals to build a new airport in the Thames Estuary.

This response is intended to assist and support the Committee`s examination of the Government policy proposals and the need to expedite the development of an aviation strategy.

We are aware that runway capacity in the South East and the UK’s largest and only International hub airport, Heathrow, is severely constrained. This causes delays and impacts upon the UK’s global connectivity, our ability to attract new long haul services to emerging economies and, more importantly, the economic competitiveness of UK business.

At present is the ultimate destination of 75% of customers exiting Heathrow by surface transport. This fact and the economic importance of London to the UK economy suggest that future hub capacity must directly service the capital.

The Institution of Civil Engineers and Chartered Institution of Highways and Transportation have recently published a statement documenting their thoughts on the UK Aviation Strategy and concluded that, If political support could be secured, new capacity in the form of a third runway at Heathrow is likely to be deliverable earlier than a new facility.

As we know, a range of proposals including wholly new facilities in the Thames Estuary and expansions of existing London airports, most recently a four runway facility at Stansted are at various stages of development.

Many of the points that are made in this document have already been stated by other sources, but we feel that it is important for us to put on record the position of this Council in opposing the Estuary Airport proposals. Where appropriate we have contributed to the questions posed by the Committee and then added further comments to arrive at a sensible and realistic assessment of the many ideas and proposals for aviation development more recently suggested and put forward.

For example we have significant concerns over the viability of building an airport on a man- made island, particularly as the plans are very vague. We also believe that it could take over 20 years to deliver the project. The transport links for “Boris Island” show a new connection to the east of Southend, which is neither practical or feasible. Southend already suffers from a railway line (Liverpool Street to Southend Victoria) in need of extensive modernisation and investment, which together with the problems encountered daily on the A127 and A13 rules out any form of road based access.

Bird-strike would pose a significant risk, together with the threat posed by the SS Richard Montgomery, an American wartime ship containing unexploded ammunition. Furthermore, there is strong and growing opposition from environmental groups worried about sensitive areas for EU protected winter breeding birds.

However, we do believe that well planned airport infrastructure, in the appropriate location, attracts inward investment, enables access to an international labour force and provides direct business and leisure links to growing economic and cultural centres. We have strong evidence of this in the development plans associated with the expansion of . What should be the objectives of Government policy on aviation?

Future aviation policies must ensure that the UK remains competitive within the global economy whilst ensuring that air travel remains accessible for general consumers. In addition, the role of regional airports are vital in this respect and must be afforded greater scrutiny in examining how this can be clearly identified. Ultimately the Government’s strategy must be based on practicality, affordability and common sense.

The Government should not plan to ‘solve’ the UK`s capacity shortfall by building an airport in the Thames Estuary, which can only at this stage to be seen to be a high risk strategy in respect of funding, long term support and very significant connectivity and environmental problems

As background, the South East LEP recently appointed Parsons Brinckerhoff to carry out a significant research study to identify how the airports of the Greater South East can be used more effectively and efficiently and, where possible, grown to accommodate the anticipated increasing demands of air travel. The study has concluded that airports in the south east of England make a significant contribution to the economy of the region and UK Plc. Without a doubt global companies have located in London and the greater SE, attracted by the connectivity afforded by the London Airport System.

Therefore in submitting evidence to this Committee, it is essential that it is clearly identified that the regional airports are not ignored by the Davies Commission, owing to the more detailed discussions over hub capacity.

Our regional airports have an enormous role to play in providing point to point services and a key objective of the Government’s policy going forward must be to look at ways of supporting regional airports, potentially looking at measures to incentivise a broader spread of air travel, where practical throughout the UK. These measures could be as simple as improving rail and road connectivity and as challenging as reviewing air passenger duty (APD), to potentially introduce differing levels of APD.

It is also worth noting at this stage that the research study has put forward some short term enhancements that could be introduced to increase capacity over the next decade including;

• Mixed Mode Operations at Heathrow;

• Reviewing artificial planning caps at Heathrow, Gatwick and London City;

• Incentivising airlines to move point to point services away from Heathrow to free up slots for an enlarged long haul network;

• Improved management of slot allocation at Heathrow and to a lesser extent Gatwick; and

• Developing a “two airport hub” between Heathrow and Gatwick, or Heathrow and Stansted.

More locally, the short term role of London Southend Airport is to provide an alternative for point-to-point travel for passengers with origins and destinations in London and the East of England. The availability of the runway enables a range of demands to be met including scheduled and charter passenger flights, Business and General Aviation. London Southend Airport has also been a long term home for a thriving Maintenance Repair and Overhaul (MRO) sector which has consistently provided jobs and export earning over many years.

The development of the Joint Area Action Plan (JAAP) for the airport environs includes significant employment opportunities at the new airport Business Park. The value of connectivity must reflect the economic benefit that is derived from the proximity of high value engineering and research to airports

How should we make the best use of existing aviation capacity?

It is fact that Heathrow, as the UK’s sole hub airport is currently approaching capacity and that this is already having a major impact on the UK`s ability to accommodate flights to new destinations, particularly China. It is also the case that there is capacity at the other London Airports and scope to increase this. New flights to emerging markets are being accommodated at Gatwick which demonstrates that airlines are flying to other airports outside Heathrow. For example, for the first time it is possible to fly to the USA from London Southend Airport (via Dublin).

In the recent consultation on the Draft Aviation Policy Framework, it is pleasing to see the Government’s recognition that regional airports can and must play a greater role in improving UK connectivity. It is vitally important to consider how airport development can benefit local business and local economic growth taking into account the nature of routes operated from each airport and the specific local circumstances. This is a role that the Local Enterprise Partnerships can develop further by bringing local and business expertise together.

Local regional airports, such as Southend and Manston, providing direct links to European Hubs could increase GVA to the SELEP Region. The development of Southend Airport, for example, who now offer direct links to Schiphol and Dublin (and their onward long haul networks), has opened up a range of new opportunities for South which previously did not exist. Residents who previously travelled to Stansted or across London to either Heathrow or Gatwick now have the option of using Southend Airport and connecting elsewhere.

What constraints are there on increasing UK aviation capacity?

The environmental impact of aviation must be a key consideration in the Government’s aviation strategy and should be a strong factor when considering the feasibility of proposals to build a new hub airport in the Thames estuary. We are of the view that these proposals are incompatible with the UK’s environmental commitments on both national and international levels.

The mouth of the Thames Estuary is a site listed international and national designations and special protection areas (Globally - The Ramsar Convention, at a European level - The Habitats Directive (Special Areas of Conservation) and Birds Directive) that the Government has committed to.

Altogether, the airport land and surrounding areas and waters include five separate Special Protection Areas for passing or over-wintering avocet, hen harriers, ringed and golden plovers, marsh harriers, little tern, dunlin and pintail, as well as hosting one of a new breed of marine sites, this one designated for its population of 6,000-8,000 red-throated divers. There is a Special Area of Conservation preserved for its species-rich estuaries, mudlflats and salt meadows. Much of the area is also covered by the Ramsar international convention on wetlands, recognising how crucial the estuary is for birds travelling as far afield as Siberia, Canada and north Africa.

Each of the designations would have to be significantly changed for an airport in the Thames estuary to go ahead, whilst destroying the habitat for over 300,000 migrant birds that rely on the area for feeding and roosting during the winter.

A recent quote from the RSBP states that:- “We are vehemently opposed to the construction of an airport in the Thames Estuary, including the latest proposals for a four runway airport. This world-class coastal wetland has been saved from a series of ill-thought out airport proposals over the past few decades by our campaigning alongside local communities and many others. The most recent proposal, launched in autumn 2011 by Norman Foster on the in North Kent has been catapulted to prominence by the , , who is favouring the idea in the context of forthcoming Government consultations on the UK's airport strategy. We will actively campaign to reject the plans on the grounds that they are unsustainable; because of the direct and indirect impacts on internationally recognised and protected coastal wetlands and wider concerns about the impact of increased aviation on climate change”.

Further to this, the estuary airport has been assessed to have the highest risk of in the UK (twelve times higher), even with extensive management measures.

Echoing the words from the Medway Council submission, we would reiterate the issues around the World War II liberty ship, SS Richard Montgomery:-

“In 1944 the ship sank 1km off the coast of Sheerness, and poses a significant hazard in the mouth of the Thames estuary. The ship which is packed with approximately 1,500 tonnes of unexploded ammunitions would require, what was labelled in a report by New Scientist magazine in 2004 "one of the biggest non-nuclear blasts ever and would devastate the port of Sheerness " .

Engineers who have examined the ship suggest that if the wreck exploded it would likely create a metre high tidal wave. Furthermore, Government tests on the site as far back as 1970 suggested a blast would hurl a 1,000ft wide column of water, mud, metal and munitions almost 10,000ft into the air – risking the lives of wildlife and many people.”

A new hub airport in the Thames Estuary would be three times more likely to be affected by fog than Heathrow Airport, according to the Met Office. Research commissioned by Medway Council was carried out over a five-year period. Data was analysed from two weather stations - one at Heathrow and another in Shoeburyness, Essex, which is on the Thames Estuary. Between January 2007 and December 2011 there were 762 hours of fog in the estuary compared to 247 at Heathrow.

There are also significant risk issues associated with locating the airport in the Thames estuary. Richard Deakin (Chief Executive Officer of National Air Traffic Services) has stated that the proposed airport in the Thames estuary would be in the 'very worst spot' for the south-east's crowded airspace, directly conflicting with Heathrow, Gatwick, Stansted, Luton and London City flight paths (in addition to Schiphol). This is all to be taken into account within an area that has substantial shipping lanes, fisheries, a power station, the Isle of Grain gas storage facility and existing and new port terminals.

The Climate Change Act 2008 committed the Government to a legally binding, long-term framework to tackle carbon emissions. Any new airport at the suggested size and scale as the Thames estuary proposals will have a significant effect on the UK’s carbon emissions output.

With global sea levels anticipated to rise and areas becoming susceptible to frequent flooding it is with great concern that we do not see significant research into the effects an estuary airport may have on low lying areas on the east coast.

For example, in respect of the “Thames Hub” proposal, produced by and consultants Halcrow, the bringing together of rail freight connections between the UK’s main sea ports, 150 million passengers, a tidal energy barrage and a new flood protection barrier will have enormous consequences to the tidal flows and estuarial sea levels. Although the project states that a new barrier upstream of the London Gateway port would provide effective flood protection for the capital to 2100 and beyond, the consequences further east into the wider estuary and North Sea are unknown.

Any changes to the estuary by building artificial islands will have major consequences to the land lying on both sides and impose significant and unacceptable mitigation measures to the Southend seafront, which is primarily protected by sand/shingle beaches and low lying sea defences. These are key assets to the Borough and support the tourism offer attracting over 6m day visitors every year.

Aircraft noise disturbance remains the most obvious local environmental impact associated with airports and one that has given rise to capacity constraints, limiting the ability of some airports to respond to demand when and where it arises.

As an example, noise disturbance was cited as the single greatest concern of respondents to the Department for Transport’s 2011 scoping document on aviation policy. DfT’s subsequent July 2012 consultation on a Draft Aviation Policy Framework restated government’s policy objective as “to aim to limit and where possible reduce the number of people in the UK significantly affected by aircraft noise”.

Experience suggests that airports not only need to minimise exposure to noise and visual intrusion, but should do so in consultation with local residents to secure buy-in to the process and ensure that any remedial action or commitments actually addresses local concerns.

An informed Airport management should however, already understand the noise challenge and the necessary responses to ensure sustainable growth and this should be reflected in the Noise Action Plans prepared by individual airports and should be one of the first considerations in insisting that Estuary Airport promoters develop comprehensive noise maps and are clear about the scale and magnitude of disturbance so that the public are able to understand and have a clear say in the process of formulating the Aviation Strategy.

Do we need a step-change in UK aviation capacity? Why? a) What should this step-change be? Should there be a new hub airport? Where?

We understand that an airport in the Thames Estuary will be discussed as an option, however we believe that this solution put forward, from whatever source, is not viable, is unaffordable and does not correspond with a more wider generally held view by either the industry or local authorities.

There are suggestions that an Estuary Airport could be built within twenty years. In that time there is no doubt that other countries will have continued their rapid expansion and moved ahead of Heathrow as the leading European hub, together with the loss of Heathrow and the many of thousands of jobs that it supports.

The effect on regional airports will also be significant with uncertainty over the future affecting investment decisions (predominantly from the private sector) and planning policies and strategies.

Affordability

Figures of an estimated £20bn for the proposed Foster & Partners’ multi-runway on the Isle of Grain and an additional £30bn for the required infrastructure have been put forward. These figures have been questioned, particularly in light of the projected £9bn cost for only one new runway at Heathrow Airport.

The recent research study by Parsons Brinckerhoff summarises:-

• costs ranging between £40bn and £70bn for a , associated infrastructure and the building of a "multitude of new railways lines" connecting the airport to London, but warns that "even the £70bn being discussed is a conservative estimate; • “that large UK infrastructure projects, much less technically complex than this, have suffered considerable cost overruns" - the Channel Tunnel, originally planned at £4.7bn, ultimately costing £9.5bn is only one example of that;

In addition, it is estimated that the planning for a Thames estuary airport would span a period of at least ten years. From a base figure of the estimated £20bn cost, adding 3 per cent construction cost inflation for that period would result in £600m annually increasing the cost of the airport to £26bn even before construction has started.

In March 2010, a survey carried out on behalf of Medway Council stated that 90 per cent of the international airlines using Heathrow were against the idea of building an airport in the estuary. Willie Walsh, chief executive of the International Airlines Group (including British Airways) has also rejected the idea and has claimed a new hub airport would only work if Heathrow were closed.

Analysts have further warned that current cost estimates fail to factor in the current amount of BAA’s £12.5bn debt levels which are a result of the expansion at Heathrow Airport, should it close, together with the loss of over 100,000 jobs.

This is supported by the fact that, in 2008/9, nearly 77,000 people were employed in jobs related to the airport with 45.5% of Heathrow staff (33,483) living in the five boroughs of Hounslow, Hillingdon, Ealing and Slough and Spelthorne that form the priority area for BAA’s local labour strategy. Within the five boroughs, 1 in 14 of all people in employment works at Heathrow (ranging from 1 in 26 in Ealing to 1 in 10 in Hounslow). Air cabin crew represent the largest occupational group, followed by passenger services, sales and clerical staff. Together, those categories represent 46.9% of Heathrow staff.

Economic Development Aspects of an Estuary Airport In January 2011, a scoping report into Estuary airport development from the London Mayor was published, which pointed out some of the economic difficulties. It stated that airlines and airports are commercial businesses operating in a competitive free market environment, not serving just London but the global travel community. These are significant issues that need to be understood.

All the major airports are owned and operated by non UK based private companies and the majority of movements into Heathrow are foreign-owned airlines. Therefore, encouraging airlines to leave Heathrow will be very challenging unless there is an overwhelming economic advantage which could be demonstrated.

State subsidy towards the development of any London airport is not an option due to UK and EU competition rules. Therefore the development of new capacity has to be affordable to the user. Given that BAA, comprising Heathrow, Gatwick and Stansted, was purchased by Ferrovial for around £10bn the difficulty of funding a new airport in the range of £20-£40bn cannot be understated. The issue of affordability is a critical issue to address.

More directly relevant to Southend is the investment that the Stobart Group has made in London Southend Airport.

Since they took on the lease of Southend Airport in 2008 they have invested over £120m in the site and its surroundings. This has been multiplied many times over in the local economy through local spend and recruitment. The airport now employs nearly 2,000 jobs directly and also indirectly through the Maintenance, Repair and Overhaul cluster located at the airport and through the supply chains and associated spend. A new Hotel on the site is also developing a conference and dining offer to compliment the growing appeal of Southend’s destination credentials throughout the year.

The expansion of Southend Airport has also boosted non-aviation industry with commercial agents reporting significant demand for premises in close proximity to the airport with occupiers seeking to maximise the prestige and reputation of co-location. The land to the west of the airport is planned to become a hi-tech business park and it is anticipated that the demand currently being experienced will extend to this site and see thousands of jobs created. Part of this site is earmarked for the Anglia Ruskin MedTech Campus launched in the House of Commons in May 2012 by Earl Howe.

If the Estuary Airport were to be constructed and result in the closure of London Southend Airport these benefits would be lost, with devastating effect. Southend has an unemployment rate above the national average and below average skills attainment levels so the loss of current and future employment opportunities would not only affect the workforce of today but also the aspirations of the workforce of tomorrow. The closure of London Southend Airport would also negatively impact on the wider aviation industry with many aviation businesses around the airport being reliant on the airport operation for their business and could trigger the relocation of these businesses to other sites – and potentially overseas losing the benefit to UK Plc. It would also risk stymieing the development at the proposed airport business park through the removal of a major economic driver and attractor in south east Essex.

Southend recognises six key sectors in its economy, the largest of which is tourism. Since the introduction of Aer Lingus and easyJet flights to London Southend Airport from an ever- increasing list of European destinations, and the USA via Dublin, tourism in Southend has grown. Not only that, but the airport has supported tourism in other locations in Essex and further afield – including air passengers for the Olympics given the airport’s proximity to London and ease of travel to the city by train. The boost stimulated by the growth of the airport continues to be felt within the leisure-tourism industry but also for business tourists with businesses using LSA as a port of entry for overseas colleagues, customers, specialists and sales teams.

Ford now fly from LSA to Germany and Romania from Southend Airport enabling their business to operate more effectively and thus supporting jobs along South Essex. The on-site hotel provides further opportunities to secure business tourism objectives and assist the strategic development of increase average spend in the Borough.

The economic benefits lost through a closure of LSA would not be recouped by the introduction of a Thames Estuary airport. The disruption caused by the changes would risk some airport- dependent businesses relocating overseas rather than within the south east, particularly given the limited space available adjacent to the proposed Estuary Airport. Similarly, due to the dense urban population and limited land availability along Thames Gateway South Essex, the area would not be accrue the benefits of a hub airport as seen along the M4 corridor when Heathrow was built and ample space was available.

Conclusion

If the UK is to remain competitive, then realistic options need to be considered. There is no doubt that hard, challenging, decisions will need to be made, but it would be advisable not to waste scarce resources and create decades of uncertainty by signaling that there is continued merit in developing the estuary airport proposals.

Future planning of airport and other related development should be based upon as much certainty as possible given the long lead in times and scale of investment involved. Building confidence in the business community and attracting investment is a key role for local authorities who are responsible for delivering the Local Development Documents and have significant experience in bringing forward well planned and achievable airport developments and managing the environmental consequences as far as possible within existing legislation.

For example, consistency between Airport Surface Access Strategies (ASAS) and Airport Masterplans is vital, particularly where new passenger transport services require financial backing both to start and for promotion. The ASAS can provide the strategy for investment where the airport operator is willing to make the necessary contribution.

In preparing Local Plans, Local Authorities are required to have regard to the emerging Aviation Policy Framework and aviation capacity policies and strategies. It is therefore imperative that there is consistency between the long-term policy framework for aviation and the National Planning Policy Framework (NPPF). It is also imperative that NPPF is adequate for the purpose of implementing high quality planning determinations.

For example, airport developers must be required to meet the costs of transport improvements in a proportionate manner related to the numbers of airport-related trips compared with other trips and also consistent with other developers, and note that airports are transport operators within their own right, and not simply a commercial development. In the case of Southend Airport, an investment of £16 million in a rail station, as well as support for other transport facilities and service, should be recognised.

In summary, the following points are key to understanding the case for not considering an estuary airport proposal:

• Loss of Heathrow, which would most likely be required to close with the loss of over 100,000 jobs; • Loss of employment in Southend either directly or indirectly related to London Southend Airport, with no evidence to suggest that this would be replaced with other opportunities • the proposals put forward within the SELEP Parson Brinkerhoff for both short, medium and long term solutions must be considered, including expansion at Heathrow, a system of allocating slots based upon an economic case and utilising spare capacity; • Lifting of artificial planning restrictions and government intervention could increase capacity for a period of between five and ten years.

As the debate intensifies, the number of options appears to be increasing. In September 2012, a proposal for “”, designed by architects Gensler, includes four floating runways tethered to the sea bed. The architect said the design allowed for future expansion to accommodate six runways when required.

Recently, consultant Beckett Rankine has announced a vision for a high capacity hub airport on the Goodwin Sands, 3km off the east Kent coast at Deal. This together with the London mayor announcing Stansted Airport plus a fourth unamed site would be included alongside the existing Thames Hub and “Boris Island” proposals into his £3m study into the feasibility of a new estuary airport.

The Parsons Brinckerhof report concluded that:-

A new hub airport – we believe that this could only be located in the greater SE, probably within the Thames Estuary; whilst this is a grand and ambitious scheme we do not believe that it is a viable solution to the capacity issues facing the SE.

In any event, it is clear that, despite the growing number of ideas being presented, the proposals to build an airport in the Thames Estuary are not practical, well thought through or in any sense deliverable.

4 January 2013 Written evidence from Action Group (LAAG) (AS 120)

1) LAAG is a community based action group established to oppose the large scale development of Lydd Airport. This local airport is considered inappropriate for development because of its location - less than 3 miles from the Dungeness nuclear power complex, less than 2 and 8 miles respectively from the Lydd and Hythe military ranges, surrounded by protected habitats designated under both UK and European legislation and situated under one of the main migratory bird routes in the south of England. We also believe there is no need for additional airport capacity in Kent as both Lydd and Manston airports (less than 50 miles apart) are currently (2012) operating at less than 1% of their respective terminal capacities. Lydd Airport also has operational constraints which will not be rectified by a runway extension. LAAG’s actions are entirely evidence based.

2) We would like to address the following point and summarise our views below.

What constraints are there on increasing UK aviation capacity?

3) We believe the aviation policy framework should address the Department of Communities and Local Government’s (DCLG’s) failure to incorporate one of the nuclear regulator’s main post Fukushima recommendations into the new National Planning Policy Framework (NPPF).

4) In its report to government (via the Department of Energy and Climate Change (DECC)) on lessons to be learned from the Fukushima accident the Office for Nuclear Regulation (ONR) recommended that the relevant government departments should examine the adequacy of planning controls for residential and commercial developments in the vicinity of nuclear installations. Soon after the ONR argued forcibly in its submission to the consultation on the new National Planning Policy Framework (NPPF) that there should be constraints to developments in the vicinity of nuclear facilities.

5) The need to preserve the demographic characteristics of an area around a nuclear site is a long established ONR principle but the ONR’s ability to ensure its regulatory advice is accepted in planning matters has been frustrated by the lack of external policy support - the only official guidance being a 1988 Hansard response to a Minister’s question. The situation has also been hampered by the ONR not having statutory consultee status which means its advice is not given the appropriate weight in decisions on relevant planning applications.

6) The need for the aviation industry to take compensatory action in its policy framework is crucial because airport development could lead to an accident at a nuclear facility as well as produce an unacceptable increase in the surrounding population. In other words, a new airport beside a nuclear facility could result in an aircraft accidentally crashing into a nuclear installation leading to a serious radiological release as well as result in an increase in population around the site at risk to that release.

7) By contrast, if a housing estate is built beside a nuclear facility there could be an unacceptable increase in population which could lead to extra loss of life and frustration of the emergency services in the event of an accident but the development itself would not be the cause of an accident leading to a serious radiological release.

8) While we understand the need for the government to create a policy background that helps stimulate growth - in doing so it must balance environmental and public safety considerations. It is unacceptable for government to fail to take policy action when the consequences of a serious radiological release are intolerable for both the public and the environment.

9) The situation is also politically untenable as the policy vacuum has been engineered despite the ONR being specifically asked to address lessons to be learned from the Fukushima nuclear incident by DECC and this tragic event forcing the re-appraisal of nuclear safety standards worldwide.

10) Further, Freedom of Information (FOI) requests (DECC/DCLG/ONR) show DCLG and associated government ministers blatantly refusing to incorporate the ONR’s strong recommendation to have planning restraint built into the new planning policy framework because they wanted to keep the NPPF “simple” and did not want anything to impede the government’s growth agenda.

11) In conclusion, the aviation policy framework must address this policy vacuum and introduce a simple policy statement which states that development of an existing airport or the creation of a new airport cannot take place if a nuclear facility is within a certain radius of the airport/proposed airport. The requisite radius needs investigation but a good starting point would be no shorter than the 13kms used in aerodrome birdstrike safeguarding.

Background

12) After the Fukushima accident DECC requested a report from the ONR to determine lessons to be learned from this tragedy. One of the principal recommendations made1 is below.

Recommendation FR-5: The relevant Government departments in England, Wales and Scotland should examine the adequacy of the existing system of planning controls for commercial and residential developments off the nuclear licensed site.

13) The ONR subsequently made it clear when responding to the consultation on new planning framework (National Planning Policy Framework (NPPF)) that it wanted development constraints incorporated into this policy document as

1 http://www.hse.gov.uk/nuclear/fukushima/final-report.pdf - page 145 & 146 the existing external guidance is inadequate being a 1988 Hansard entry2. The ONR stated the following to DCLG in its submission to the NPPF consultation process dated October 17, 2011 (Appendix 1, page 2):

We welcome the opportunity to provide comments on the draft NPPF, which is directly relevant to our mission: “To ensure the protection of people and society from the hazards of the nuclear industry” and, in particular, our ability to effectively deliver the Government’s policy objective of controlling population changes in the vicinity of nuclear installations and maintaining the security of nuclear facilities. ……

Recent experience at a Planning Inquiry into the proposed development at Boundary Hall near AWE (Atomic Weapons Establishment) Aldermaston has highlighted the fact that nuclear administrative arrangements for developments around nuclear installations have not been modernised and incorporated into the current national spatial planning framework. This means that appropriate weight is not given to nuclear safety and security concerns in the planning balance. This is important as it impacts on ONR’s ability to effectively deliver the Government’s policy objective of controlling population changes in the vicinity of nuclear installations. In addition, it is also important that ONR has an opportunity to advise on any security implications associated with the proposed development.

The draft framework document makes no mention of any constraint to developments in the vicinity of nuclear facilities, nor indeed other high hazard facilities (upon which HSE will be replying separately). While we recognise and accept the reasoning behind the Government’s policy presumption in favour of positive planning decisions, for these to be sustainable it is important to ensure that we do not undermine other important Government policies, such as the need to control developments around nuclear installations that are designed to ensure that people and society are properly protected, and to maintain the security of nuclear facilities.

14) The ONR also requested to be a statutory consultee for planning application consultations around nuclear power stations so that more weight would be given to its advice.

15) Despite these requests, the final NPPF failed to incorporate policies which prescribed constraints on residential and commercial developments in the vicinity of nuclear installations. DCLG also turned down the ONR’s request to be a statutory consultee.

2 Hansard, HC 11 March 1988 Vol 129, cc357-358 (Written Answers) - “I am advised by the HSE‟s Nuclear Installations Inspectorate that the current demographic criteria for assessing potential AGR sites were developed in the late 1960s. These and more restrictive criteria of a similar type are used as guidelines for controlling development in the vicinity of existing AGR and Magnox stations respectively. Once a site has been has been accepted for a nuclear station arrangements are made to ensure that residential and industrial developments are so controlled that the general characteristics of the site are preserved and therefore local authorities consult the inspectorate with regard to any proposed development which might lead to an increase in population close to the site and on larger developments further from the site. . .“

16) Material obtained from freedom of information requests (ONR/DCLG/DECC) shows the ONR making numerous unsuccessful attempts to ensure its recommendations were included in the NPPF, and on the other side, equally strong ministerial pressure to simplify and ignore their requests - simplicity and planning/development expediency taking precedence over public safety.

17) When DECC later asked DCLG for its response to the Weightman report (ONR’s post Fukushima report) the latter highlighted two paragraphs in the NPPF (paragraphs 172 and 194) plus a glossary entry (see below and Appendix 2). The NPPF’s policy guidance clearly makes no mention of restraint.

172. Planning policies should be based on up-to-date information on the location of major hazards and on the mitigation of the consequences of major accidents.

194. Local planning authorities should consult the appropriate bodies when planning, or determining applications, for development around major hazards.

Glossary Entry Hazards: Major hazard installations and pipelines, licensed explosive sites and nuclear installations, around which Health and Safety Executive (and Office for Nuclear Regulation) consultation distances to mitigate the consequences to public safety of major accidents may apply.

18) DECC is equally culpable as it has failed to ensure that there has been an adequate response to recommendation FR-5. In its implementation report (Japanese earthquake and tsunami: Implementing the lessons for the UK's nuclear industry - October 20123) it said the government response was: “ONR has included Dr Weightman's recommendation on planning controls around nuclear sites in their consultation response to the Government's proposed National Planning Policy Framework for England (NPPF). The NPPF has now been published and is available at Ref. 34.”

19) DECC’s failure to challenge DCLG over the adequacy of the NPPF’s response to recommendation FR-5 is perverse. This department commissioned the ONR to produce the report in order to take lessons from the Fukushima disaster. Moreover, it is DECC’s policy that populations around nuclear installations need to be controlled (see Appendix 3 and below)

3 http://www.hse.gov.uk/nuclear/fukushima/implementation-report-oct-2012.pdf

20) DCLG’s (and DECC’s) failure to ensure that the ONR’s recommendation on planning restraint had been incorporated into the NPPF potentially places the public and the environment at risk should inappropriate developments proceed around nuclear installations.

21) It now falls to other government departments to specifically restrict commercial and residential development in the vicinity of nuclear installations through their policy frameworks. There is additional onus on the Department for Transport and the aviation policy framework as the activity over which it presides could be the cause of an accident causing radiation exposure, in addition to increasing the population subject to that exposure.

22) In other words, the introduction of aircraft activity resulting from the development of an airport in the vicinity of say a nuclear power station could lead to an aircraft accident at that installation which creates the radiological release, as well as the airport increasing the population at risk to that radiation. By contrast, the principal risk resulting from a passive housing development is the additional population at risk to radiation exposure - the development itself would not be the cause of the radiological release.

23) The simplest and most effective manner in which to accommodate the ONR’s wishes is to introduce a policy which states that airport development is not possible when a nuclear facility is within a certain radius of the airport in question. The radius should be subject to investigation but be no shorter than the 13km used in aerodrome birdstrike safeguarding4.

24) According to the CAA: “The 13 km circle is based on a statistic that 99% of birdstrikes occur below a height 2000 ft, and that an aircraft on a normal approach would descend into this circle at approximately this distance from the runway”5.

19 January 2013

Appendix 1: The ONR’s submission to the draft NPPF consultation*

Appendix 2: Email dated May 16th, 2012 - DECC’s request to DCLG for clarification of its response to the ONR’s post Fukushima report (also called Weightman report) plus email dated, May 21st 2012 from DCLG outlining the relevant paragraphs in the NPPF*

Appendix 3:

4 In the UK, aerodrome safeguarding is the process by which major or strategically important aerodromes and all military airfields are required to have an arrangement in place with the local planning authority such that any development that might impact on flight safety is referred to the aerodrome for consultation and possible objection. In terms of the birdstrike risk, any proposed development within 13km of an aerodrome that may influence the birdstrike risk is referred to the aerodrome (or Defence Estates in the case of military airfields) and the aerodrome operator is given the opportunity to request changes or to object to the development if necessary. 5 CAP 772, Birdstrike Risk Management for Aerodromes (September 1 2008), Chapter 4, page 15, paragraph 4.4 last sentence Email dated February 22nd 2012 from HSE outlining HSE/ONR concerns and DECC’s status in relation to demographic controls*

Appendix 4: Airport Capacity - Lydd and Manston airports - see below

Lydd Airport Manston Airport Year Passengers Percentage Percentage Passengers % of White % of Current (end Dec.) (number) of White Paper Existing (number) Paper Potential Terminal Potential Terminal Capacity Capacity of Capacity of Capacity of of 6mppa 1million ppa 125,000ppa 300,000ppa

1992 4,592 3.7% 1.5% 7,385 0.1% 0.7% 1993 1,515 1.2% 0.5% 11,848 0.2% 1.2% 1994 195 0.2% 0.1% 5,123 0.1% 0.5% 1995 235 0.2% 0.1% 2,523 0.0% 0.3% 1996 303 0.2% 0.1% 941 0.0% 0.1% 1997 2,596 2.1% 0.9% 2,936 0.0% 0.3% 1998 2,370 1.9% 0.8% 2,269 0.0% 0.2% 1999 3,430 2.7% 1.1% 1,599 0.0% 0.2% 2000 1,522 1.2% 0.5% 7,594 0.1% 0.8% 2001 65 0.1% 0.0% 5,921 0.1% 0.6% 2002 3,088 2.5% 1.0% 92 0.0% 0.0% 2003 4,498 3.6% 1.5% 3,582 0.1% 0.4% 2004 4,018 3.2% 1.3% 101,233 1.7% 10.1% 2005 2,817 2.3% 0.9% 206,875 3.4% 20.7% 2006 2,754 2.2% 0.9% 10,167 0.2% 1.0% 2007 2,696 2.2% 0.9% 16,180 0.3% 1.6% 2008 1,673 1.3% 0.6% 11,657 0.2% 1.2% 2009 588 0.5% 0.2% 5574 0.1% 0.6% 2010 485 0.4% 0.2% 25813 0.4% 2.6% 2011 496 0.4% 0.2% 48450 0.8% 4.8% 2012 (e) 400 0.3% 0.1% 8304 0.1% 0.8% 2012 estimated on the basis of 10mths actual data 2004 and 2005 volumes based on unsustainable fares pre EUjet's/PlaneStation's bankruptcy Source: CAA statistics: terminal and transit passengers

*Not printed with this submission. The appendices can be viewed on the Transport Committee’s website at: http://www.parliament.uk/business/committees/committees- a-z/commons-select/transport-committee/