Aviation Strategy

House of Commons Transport Committee

Aviation Strategy

First Report of Session 2013–14

Volume III Additional written evidence

Ordered by the House of Commons to be published 8 May 2013

Published on 10 May 2013 by authority of the House of Commons London: The Stationery Office Limited

The Transport Committee

The Transport Committee is appointed by the House of Commons to examine the expenditure, administration, and policy of the Department for Transport and its Associate Public Bodies.

Current membership

Mrs Louise Ellman (Labour/Co-operative, Liverpool Riverside) (Chair) Steve Baker (Conservative, Wycombe) Sarah Champion (Labour, Rotherham) Jim Dobbin (Labour/Co-operative, Heywood and Middleton) Kwasi Kwarteng (Conservative, Spelthorne) Karen Lumley (Conservative, Redditch) Karl McCartney (Conservative, Lincoln) Lucy Powell (Labour/Co-operative, Manchester Central) Mr Adrian Sanders (Liberal Democrat, Torbay) Iain Stewart (Conservative, Milton Keynes South) Graham Stringer (Labour, Blackley and Broughton)

The following were also members of the committee during the Parliament.

Angie Bray (Conservative, Ealing Central and Acton), Lilian Greenwood (Labour, Nottingham South), Mr Tom Harris (Labour, Glasgow South), Julie Hilling (Labour, Bolton West), Kelvin Hopkins (Labour, Luton North), Mr John Leech (Liberal Democrat, Manchester Withington) Paul Maynard, (Conservative, Blackpool North and Cleveleys), Gavin Shuker (Labour/Co-operative, Luton South), Angela Smith (Labour, Penistone and Stocksbridge), Julian Sturdy (Conservative, York Outer)

Powers

The Committee is one of the departmental select committees, the powers of which are set out in House of Commons Standing Orders, principally in SO No 152. These are available on the internet via www.parliament.uk.

Publication

The Reports and evidence of the Committee are published by The Stationery Office by Order of the House. All publications of the Committee (including press notices) are on the internet at http://www.parliament.uk/transcom. A list of Reports of the Committee in the present Parliament is at the back of this volume.

The Reports of the Committee, the formal minutes relating to that report, oral evidence taken and some or all written evidence are available in a printed volume. Additional written evidence may be published on the internet only.

Committee staff

The current staff of the Committee are Mark Egan (Clerk), Farrah Bhatti (Second Clerk), Richard Jeremy (Committee Specialist), Helen Agnew (Senior Committee Assistant), Adrian Hitchins (Committee Assistant), Stewart Mcilvenna (Committee Support Assistant) and Hannah Pearce (Media Officer)

Contacts

All correspondence should be addressed to the Clerk of the Transport Committee, House of Commons, 7 Millbank, London SW1P 3JA. The telephone number for general enquiries is 020 7219 6263; the Committee’s email address is [email protected]

List of additional written evidence

1 Elizabeth M. Balsom AS 01 2 Mr Ken McDonald AS 02 3 Mr Philip Greswell AS 03 4 Howard and Diane Turner AS 04 5 London Medway Airport Group AS 05 6 Peter McManners Ev 06 7 No Estuary Airport campaign AS 07 8 Dr Patrick Hogan AS 09 9 Royal Aeronautical Society AS 11 10 Mrs Caroline Tayler, Mrs Jane Vogt and Mr Stuart McLachlan AS 12 11 Professor David Metz and Dr Anne Graham AS 13 12 Belfast City Airport Watch AS 14 13 Mr Basil Hutton AS 17 14 Peter Tomlinson, Iosis Associates, Bristol AS 18 15 Mr Francis Joseph McGlade AS 19 16 Dr. Peter W. Skelton AS 21 17 Chartered Institute of Logistics and Transport in the UK AS 23 18 Dr William D Lowe AS 24 19 Mr John G Miller AS 27 20 West Windsor Residents Association AS 28 21 Bluespace Thinking Ltd AS 29 22 Rothwell Aviation Ltd AS 30 23 Save Filton Airfield Campaign Group AS 31 24 Mr Joe Watson AS 32 25 Aviation Foundation AS 33 26 Vanderlande Industries UK Ltd AS 34 27 Zac Goldsmith MP AS 35 28 Assurity Consulting AS 36 29 Marilyn Fletcher B.Sc.Ph.D. AS 37 30 IATA AS 40 31 Tim Gresty, Cognitio AS 41 32 Crawley Borough Council AS 43 33 Lagan Valley Group Residents’ Association AS 45 34 London Chamber of Commerce and Industry AS 46 35 Merseytravel AS 47 36 GATCOM AS 49 37 A Fair Tax on Flying Campaign AS 50 38 Liverpool City Region Local Enterprise Partnership AS 52 39 HS2 AS 54 40 Mr Paul Pitcher AS 56 41 British Airline Pilots' Association AS 58: AS 58A 42 Debbie Bryce AS 62

43 Unite AS 64 44 NECTAR AS 65 45 Royal Town Planning Institute AS 70 46 ADS AS 74 47 Richmond Heathrow Campaign AS 76 48 NetJets Europe AS 77 49 SPAA AS 78 50 Heathrow Hub Ltd AS 80 51 Chiltern Countryside Group AS 82 52 The Authorities' Aircraft Noise Council AS 83 53 UK Airport Consultative Committees Liaison Group AS 85 54 North Kent Marshes AS 88 55 Adams Group AS 93 56 Flybe AS 94 57 Wildlife Trusts AS 95 58 Government of Guernsey AS 96 59 Mr Terence Hughes AS 97 60 Campaign to Protect Rural England, Kent Branch AS 99 61 States of Jersey Economic Development Department AS 100 62 Yorkshire and Northern Lincolnshire All Party Parliamentary Group AS 102 63 Marinair, the Thames Estuary Airport Company Limited AS 103 64 Institution of Mechanical Engineers AS 106 65 Aberdeen Airport Consultative Committee AS 108 66 Greenpeace AS 109 67 UK Travel Retail Forum AS 112 68 The London Assembly AS 113 69 Interlinking Transit Solutions Ltd AS 115 70 Dr. Mayer Hillman AS 117 71 Why Not Manston? AS 118 72 Southend on Sea Borough Council AS 119 73 Lydd Airport Action Group AS 120 74 The Air League AS 121 75 Testrad AS 123 76 London Ashford Airport Ltd (lydd airport) AS 124 77 Mr S H Ashurst AS 125

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Written evidence

Written evidence from Elizabeth M. Balsom (AS 01) HEATHROW AIRPORT I have just watched your video on the Parliamentary website, and am writing to you as Chairwoman of the Transport Select Committee because more flights to Heathrow are back on the political agenda. Noisy, well- remunerated advocates suggest that an additional 60,000 flights a year could access this ill-sited airport via mixed-mode, despite the cataclysmic effect this would have on the lives of those of us under the flight path. I am writing to you in the hope of bringing home to decision makers just what it is like to live with unrelenting aircraft noise. I feel I am paying for the mistake I made in coming here 31 years ago, when planes were not the disturbance they are now. I would leave, but I have made a life here, and I have nowhere to go. I take the strongest exception to those expansionists whose attitude to me is: Tough put up and shut up.

1. Committee Membership It is disappointing and regrettable, indeed it is shameful, given the destructive impact of aircraft noise, that Parliament’s committee on this subject has no members whose constituents’ lives are blighted by aircraft noise. Please can you explain why this is? No doubt you know that people in Putney are troubled and confused at the treatment of Justine Greening, a decent, hard-working MP who is widely liked and respected, and whose efforts to protect us from the hell of yet more aircraft noise are valued by us, yet seem destined to be ignored. I have found media reports of briefings against her distressing. Furthermore, the “money talks” modus operandi and mentality which now permeates every pore of our society is alarming and depressing, breeding cynicism and distrust in the political process and public life. I well remember that during the Labour government’s consultation on the third runway, week after week on the Westminster House, Tom Harris, a member of your committee, would appear to proclaim that a third runway was essential for his Glasgow constituents. Why should a Scottish MP tell people under the Heathrow flight path that we must put up with even more aircraft noise for his constituents? If he’s so potty about planes, what’s wrong with Prestwick? Friends who lived opposite me moved to Sunbury in Spelthorne constituency five years ago, partly to be nearer their daughter, but principally because they could no longer bear aircraft noise in Putney. Because of the flight patterns, Spelthorne, although near the airport, does not suffer as we do, as committee member Kwasi Kwarteng, a vocal promoter of expansion, is surely aware. I was shocked by his comments in the Evening Standard, July 9, and am grateful to the Standard for allowing me the opportunity to respond. I noted Mr Kwarteng’s comments that people should be paid £500,000 to get out of their homes, so a third, fourth and heaven knows how many runways could be built at Heathrow. This sort of attitude is beyond the pale. Perhaps Mr Kwarteng can come up with a figure for compensating those of us whose lives are blighted by aircraft noise. I am serious when I suggest £1,000 a week. After all, when everyone else is on the make, getting something for nothing, why shouldn’t I get something for something: putting up with aircraft noise.

2. Advocates of Expansion We are entitled to ask just who are the people clamouring for more flights to Heathrow and why they are doing so. For some inexplicable reason, every time the then prime minister Tony Blair decreed that Heathrow must expand, particularly at PMQs, the phrase cui bono? flashed into my mind. Mr Blair has certainly done well since he left office. One of the most recent and loudest expansionists is Tim Yeo. I found the following on his website: www.timyeo.org.uk “Tim Yeo has pledged his full support to opponents of a wind farm at Chedburgh. He told a packed meeting at Hawkdeon village hall: “I fully understand why anybody in a community as beautiful as this will be concerned. On shore wind turbines are visually a very considerable intrusion on any landscape. This happens to be one of the most beautiful parts of my constituency which stretches from here to the coast.” “I can hardly think of a less suitable place to put up a series of very, very large wind turbines six and a half times the height of the village church here in Hawkdeon. They would dwarf the cathedral in Bury St Edmunds as well.”‘ Mr Yeo’s hypocrisy was further outlined in the Mail Online 16/8/12. “He’s the Tory who chairs the Commons climate committee but earns £140,000 from green firms. And he wants to carpet Britain in wind farms (except in his own backyard).” So Mr Yeo expects other MPs’ constituents to put up and shut up when they object to more aircraft noise, yet supports his own constituents’ objections to a development that will adversely affect them—despite accepting consultancy fees from “green” companies. This is contemptible. I hope your committee will consider whether MPs whose constituents are unaffected by the noise generated by Heathrow airport should have any voice in a development that will devastate the quality of life of hundreds of thousands of people in west London. We should be told whether they have any financial relationship with cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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the aviation interests demanding expansion. It really is unconscionable that any civilized society should expect a large chunk of its citizenry to tolerate the intolerable.

3. Impact of Noise How many constituents of MPs pushing for Heathrow expansion are woken by planes at 4.40am as we are? Here in Putney planes continue until 11 pm and some airlines like Emirates want to land throughout the night. Planes fly over my house every 90 seconds at 2000 ft. As soon as one has gone, another takes its place. Think Phil Spector’s “wall of sound”. I have double glazing, but they are still audible. Outside, you can’t hear what someone a few feet away is saying. Gardening is stressful; it is impossible to enjoy a summer’s day. Please don’t believe the spin that planes are getting quieter. I often wonder if Willie Walsh goes to plane makers and says: “gimme the noisiest thing you’ve got.” Has anyone affected by aircraft noise every appeared before your committee to give personal testimony of what living with the noise is like? The screech as the planes pass over my house is indescribable. You need to experience it. If you are in the garden talking to a friend, you have continually break off conversation as a plane passes over. I remember an incident when my gardener, a man in his 50s with no hearing problems, was pruning a rose in my small garden. I went to the kitchen door and shouted “David, don’t forget there’s a rose at the front.” He turned, came into the kitchen and said: “couldn’t hear you. A plane was going over.” He was all of 10 ft away from me. I remember one June afternoon in 2008 when a friend brought her then two and a half year old daughter to visit. We went outside. To my surprise the little girl suddenly pointed skywards and said: “noisy aeroplane”. She continued to repeat this as the planes kept coming. A small child, unaware of the political dimensions of Heathrow expansion, was struck by the noise of the planes. The third runway is a totemic slogan that slips easily off the tongue. What matters is that Heathrow airport should not be expanded, via mixed mode, more runways, or any other trickery the expansionists come up with. When the inspector gave the go-ahead for T5 he did so on condition that aircraft movements at Heathrow should not exceed 480,000 a year, because to go beyond this would inflict on intolerable burden on the quality of life of those under the flight path. Please could your committee get expansionists to justify why we should be expected to endure more when the devastating effect of aircraft noise has long been recognised? Please could your committee address the implications of studies by Professor Stephen Stansfeld on the deleterious impact of aircraft noise on children’s learning (eg at Munich’s airports), and against this background seek justifications from those who seek to increase the number of flights? Please could your committee explore the opposition of residents under the Frankfurt flight path (admittedly hundreds of thousands fewer than under the flight path to Heathrow) to more flights, and their objections to night flights (FAZ 27/6/12) not least when airlines like Emirates are seeking to fly into Heathrow at all hours of the night. Obviously my concern is my quality of life in Putney, but it is time for the aviation industry and its supporters to recognise the havoc that it wreaks. People are fed up with aircraft noise.

4. Regional and Other London Airports At all events, I question the need to focus so much airport expansion on Heathrow. On September 8, Radio 4 news reported that French detectives investigating the Annecy killings flew into London City Airport. On Feb. 5, the day when Heathrow cancelled hundreds of flights because of a dusting of snow, a friend’s niece flew into Manchester airport on time from Islamabad with Qatar airlines. She was on a British Council programme at northern universities and had neither need nor desire to visit London. In December I met up with English friends who live in Adelaide. Because of family business in Stafford it was convenient to fly to Birmingham, again with Qatar. Not everyone in the whole wide world wants to fly to Heathrow. I trust your committee will examine the potential for developing regional airports. Germany has important airports in addition to Frankfurt: Dusseldorf, Munich, Cologne, Berlin; I realise that Germany is both a larger land mass than the UK and a federation, but there must surely be lessons here. However, one lesson the expansionists should learn from Germany is that residents under the Frankfurt flight path, albeit hundreds of thousands fewer than under the Heathrow flight path, are no more welcoming of aircraft noise than we are.

5. Economic Case According to WTO figures (FT: 11/4/12), Germany exports eight times more to China than the UK, ten times as much to Russia, twice as much to India (which should be our own backyard). Do expansionists expect me to believe this is because Heathrow has only two runways? Did Dassault win the Indian airforce fighter aircraft contract because Cde G has more runways than Heathrow? I suspect something more fundamental is going on, and this will not be rectified by concreting over yet more of west London. Perhaps my scepticism was formed ‘in the late 1970s and early 1980s when I worked at the National Economic Development Office with responsibilities for the food and drink manufacturing sector. My colleagues covering a range of industries and I did not see our task as the much derided “picking winners” but in trying to identify why many British companies across the industrial spectrum were less efficient and competent than cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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foreign counterparts and why many, particularly in food manufacturing, seemed reluctant to get involved in exporting. Our balance of trade was negative in most sectors. Most of the companies I knew well have either folded or are in foreign/private equity hands: Cadbury, Rowntree, Bass, Allied Lyons, Courage, Scottish & Newcastle, United Biscuits, Huntley & Palmer, Unigate, Greenall Whitley, Avana. Only Unilever is still standing and independent. The passing of ICI and British Steel into foreign hands suggests this pattern may be replicated throughout British industry. It is immensely encouraging and reassuring that the CEO of Exova Group (letters 15/5) believes this situation can be rectified by building a third runway at Heathrow. and that if this is built, British exports will soar. Based on my experience and looking back over the past 35 years, my reaction is “pull the other one” ‘. (Letter published in The Times 18/5/12, reprinted in The Week.) Expansionists peddle the “hub” argument which some of us find hard to understand. I know Heathrow is a virtual shopping mall, with more shops than seats for passengers, but do people actually buy more suitcases, shoes, booze etc when their hold luggage is already in transit and cabin baggage is limited? I understand that transit passengers need cafeterias, but even seasoned travelers tend to be most concerned about getting to the gate for their next flight than getting out their credit cards. How much money do transferring fliers actually spend, and how much of this filters down to UK plc? I am not interested in the financial health of Spanish companies except in so far as that country’s dire economic plight impacts on the UK.

6. Sharing the Riches Please can your committee explore how I, as a pensioner with a small fixed annuity (I lost money in Equitable Life), whose savings are generating zilch and whose value is being eroded by QE, can share in the exponential growth in wealth the expansionists claim will result from ever more flights to the ill-sited Heathrow. After all, as we know, many of the people who take the decisions affecting our lives are on “nice little earners” from this interest or that. Why should I lose out? We’re a pathetic country if the only way of meeting its country’s aviation needs is by imposing further misery on hundreds of thousands of its citizens. We rightly despise other countries that act in similar fashion; Stalin’s collectivisation of the kulaks comes to mind. Aircraft noise is not a joke. When I came here in 1981 planes were not an issue; now they represent an ever present degradation of my quality of life. The prospect of more flights via mixed-mode is unendurable. At the very least we need our half day respite. One recent night, about 11.00 pm, I was cleaning my teeth, getting ready for bed. The planes had been overhead, non-stop since 3.00 pm. For some inexplicable reason I was suddenly jerked back to being a very small child when, as I was getting into bed, my mother would say, “say your prayers”. It occurred to me that if I still got down on my knees before getting into bed I would say, “Please Jesus, Take the noise away”. It really is that bad and the noise is getting worse. I’m not alone in feeling this. I trust your committee has the scope to reflect on this. 18 September 2012

Written evidence from Mr Ken McDonald (AS 02) I have submitted my comments to the Department for Transport on its Draft Aviation Policy Framework (DAPF). I would like you also to consider my concerns regarding the context in which long term aviation policy is being discussed. The first sentence of the executive summary of the DAPF is “The Government’s primary objective is to achieve long term economic growth”. I submit that this is an unsound premise. Sustained global economic growth was possible when the Earth’s human population was relatively few in number and the demand per capita placed on Earth’s finite resources was modest, but the industrial age and the dramatic and accelerating growth over the last two centuries in both world population and average personal consumption has brought us to an unsustainable position. Global consumption is already greater than the Earth’s capacity to renew its resources, so further global economic growth is not sustainable. The longer that global economic growth is maintained, the greater will be the resource deficit that has to be faced in due course. The longer we wait before admitting the inevitable, the bigger will be the bubble that bursts. It is like borrowing further and further beyond one’s means until there is no option but to default on the debt. Yet, there will be no banker to default on when we do come to terms with being unable to feed and warm all the human race because the Planet has insufficient resources. The bubble may not burst within the life of this Government, but this Government risks being judged by the next generation as turning its back on UN General Assembly Resolution 42/187 that defined sustainable development as “meeting the needs of the present without compromising the ability of future generations to meet their own needs”. If the Government is consciously forecasting long term global economic growth, despite the “One Planet” theory, then its rationale should be explained. If, on the other hand, it is this Government’s belief that the UK can continue to grow, against the inevitable tide of global reality, then that rationale should be explained. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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If it is accepted that economic growth is dependent on the ongoing renewal of resources, then it is only a matter of time before the inevitable turnaround from growth to contraction arrives. When this general tipping point will be reached (or perhaps, when it was reached) is a matter of conjecture, but it is certainly unsound to expect economic growth to continue long term, either globally or nationally. Within the broad picture of sustainable economic growth and availability of finite resources, aviation is at the leading edge of one of the dilemmas of finite resource, being heavily dependent on fossil fuel. The use of fossil fuel has increased dramatically over the last century and the ongoing high level of usage relative to the Earth’s diminishing and non-renewable resources indicates that availability of this particular finite resource is likely to start to decline in the foreseeable future. Given that fossil fuel has many other uses, the presumption that some degree of long term priority or parity of supply should be afforded to aviation is highly questionable, especially the majority of aviation which is leisure orientated. The opening paragraph of the Executive Summary goes on to say “The aviation sector is a major contributor to the economy and we support its growth within a framework which maintains a balance between the benefits of aviation and its costs, particularly climate change and noise”. This introduces a key factor, climate change, which we cannot afford to be treated as subsidiary to the search for the holy grail of economic growth. The second bullet of para 1.4 refers to the need for proportionate action to be taken at the international level, yet the aviation industry continues to receive the unfair and unjustified protection of the 1944 Chicago Convention and continues to benefit, to the detriment of other sectors, by the success of ICAO in retaining that protection. Until that exceptional degree of protectionism is unwound, the aviation industry will continue to operate with the uncertainty that the bubble in which it operates may one day burst. Thus it is against the background of the rather distorted and unreal world, in which the Government expects perpetual economic growth and aviation operates under a cloak of outdated and outlandish protection, that we are being asked to comment on the UK’s aviation policy. These factors are so fundamental (one might say the two elephants in the room are so huge) that I felt unable to offer further meaningful comment on the DAPF. I hope the Transport Committee may be able to ensure that these fundamental issues are addressed before the next stage of the Government’s aviation consultation, thereby providing a clear context against which I and others may comment on the Government’s proposals. 20 September 2012

Written evidence from Mr Philip Greswell (AS 03) AVIATION STRATEGY CONSULTATION In considering points for this strategy, I set out below briefly issues and facts I have been made aware of over the years which must be carefully considered by the Committee. — According to the Department for Transport (DfT), the UK has enough. — Airport capacity, even in London and the South-East, until almost 2030. — London remains the top city in the world to do business. A principle reason for this is its excellent connectivity. That’s according to global property consultants Cushman & Wakefield. — Heathrow has more flights each week to key business centres of the world than its two closest European rivals, Paris & Frankfurt, put together, according to a report from WWF and AirportWatch — A big majority of companies expect to reduce their flying over the next few decades and use video conferencing more, according to a WWF survey of the top 350 companies. The DfT expects this will reduce demand by 10%. — If Hong Kong is included, the UK has more flights to China than any other European country. The main deterrents to Chinese people coming to Britain are the cost and bureaucracy of getting visas and the fact that a bilateral agreement limits passenger flights between the two countries to 62 per week. — The Davies Commission should include consideration of how future oil prices, income levels, population growth and climate change targets will impact on the demand for air travel in both the industrialised and industrialising countries. — Aviation’s contribution to the economy is less than the aviation industry suggests. Government policy is still based on the Labour Government’s 2003 Air Transport White Paper which, in turn, is based on a report largely paid for by the aviation industry. The report, The Contribution of Aviation to the UK Economy was carried out by consultants Oxford Economic Forecasting in 1999 with an update in 2006. It ignored the tax-breaks the industry receives through tax-free fuel and being zero-rated for VAT. Nor did it factor into its calculations the huge cost aviation imposes on society and the environment, which are estimated to be around £16 billion a year. Independent experts argue that the report over-estimates the number of jobs aviation expansion would create. And it skated over the point that UK air passengers take more money of the UK on their foreign trips to spend abroad, than foreign visitors bring in on their visits. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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— The tax-breaks Airlines pay no tax on aircraft fuel and no VAT. The resulting loss of revenue is over £11 billion a year. Only just over £2.5 billion per year is brought in from Air Passenger Duty. To achieve fair tax with motorists, air passenger duty would need to be more than quadrupled! — The tourist deficit—the difference between what British people spend abroad and visitors spend in this country—was £14 billion in 2010, down from a high of £20 billion in 2008. Most of this deficit is accounted for by air travel and closely parallels the rise in low-cost flights. All regions of the country, except for London and the South East—where there is a slight surplus—are in deficit. This deficit is damaging the economy and exporting jobs. 21 September 2012

Written evidence from Howard and Diane Turner (AS 04) As a private individual, together with my wife, I would like to put on record our opposition to Air Passenger duty per se. We consider this a stealth tax which limits people’s freedom to travel by air and therefore to “broaden their horizons” and gain a greater understanding of the wider world. If one wishes to travel to visit areas of the world beyond mainland Europe one realistically has to travel by air. The additional costs of “Air Tax” severely restrict the extent to which the voting public, living on limited budgets, can afford to exercise its freedom of choice with regard to air travel. It makes it particularly difﬁcult for families living in different parts of the world to reunite on a regular basis; times of economic hardship aggravate the problem even more! With regard to the other issues covered by the committee I have no relevant knowledge as our home is many miles from the nearest civil airport and therefore cannot comment. Please abandon this unfair stealth tax. 25 September 2012

Written evidence from No Estuary Airport campaign (Essex) (AS 07) Jon Fuller is an environmental campaigner working with a number of NGOs on a voluntary basis. In December 2011 he was approached by several Essex residents and was asked to form a campaign group to fight the emerging Thames Estuary Airport proposals. It was noted that a well organised campaign was being developed by Medway Council with the support of other Kent based local authorities, but concern existed that this might focus upon short term economic factors and ignore some overriding scientific and humanitarian considerations. So a separate campaign was formed to gather the facts that would prove that an Estuary Airport was unwarranted and disseminate this information through the media and electronically to the widest possible audience. Supporters of this campaign are kept up to date with regular e-mail updates. The facts will demonstrate conclusively that no airport should ever be constructed within the Thames Estuary. Furthermore the scientific facts, and the humanitarian response to the science, demand that aviation capacity now be constrained.

Summary 1. The threat of climate change is now so great that greenhouse gas emissions must be tackled as a matter of urgency. 2. The public response to agricultural damage and disruption to the food supply associated with climate change and bio-fuel production will necessitate a dynamic response from government. 3. The DfT predictions for future growth in aviation are overly optimistic and need critical examination. 4. The economic case to connect with the north of the UK is being overlooked. 5. The case against a Thames Estuary airport: — National Air Trafﬁc Control “The very worst spot” to put an airport. — EU Habitats Directive: the law precludes an airport within the estuary. — Medway Council infrastructure/plans: the Isle of Grain schemes are not viable. — SS Richard Montgomery: WWII munitions obstacle to an estuary airport scheme. — Adverse impact upon south Essex tourism industry. — Erosion and impact upon DP World (London Gateway new port). 6. Conclusion. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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1. Aviation: The Science 1.1 The Transport Select Committee is requested to seek the input of the UK Government’s Chief Scientific Adviser, Sir John Beddington, to ensure that its recommendations take full account of the science relating to the impact of aviation on greenhouse gas emissions and climate change. It is absolutely vital that government should not cut itself off from the world of science. It must not determine policy on short term economic issues that will not withstand the scientific reality that will shortly transform all our lives. 1.2 Space constraints suggest that a limited number of references be provided, so just four are offered here to underscore the scale of the threat posed: the Intergovernmental Panel on Climate Change, the United Nations Environment Programme, the World Health Organisation and the DARA group report of September 2012:— http://www.ipcc.ch/publications_and_data/publications_ipcc_fourth_assessment_report_synthesis_report.htm http://www.unep.org/pdf/UNEP_CC_STRATEGY_web.pdf http://www.who.int/mediacentre/factsheets/fs266/en/ http://daraint.org/climate-vulnerability-monitor/climate-vulnerability-monitor-2012/ 1.3 In the light of the scale of recent climate disruption, particularly that which has caused so much damage to food production, the Transport Select Committee is requested to call Sir John Beddington to provide current scientific opinion on the scale of the threat of climate change to food production and human health. Indeed the DARA report shows that climate change is now contributing to the death of 400,000 people per annum and costing the global economy $1.2 trillion per annum. 1.4 This evidence shows that climate is changing rapidly and that the adverse impacts will necessitate a reduction in greenhouse gas emissions from all sectors, including aviation. The Transport Select Committee may well establish that the Committee on Climate Change target to see greenhouse gas emissions from aviation return to their 2005 level by 2050 does not go far or fast enough. If the UK is to avoid significant disruption to the food supply, much deeper cuts in greenhouse gas emissions will be needed, and as a matter of great urgency.

2. The humanitarian response and bio-fuels in aviation 2.1 The Transport Select Committee is requested to consider the humanitarian response to the emerging disruption to food that is now being caused by climate change. The European Union climate commissioner Connie Hedegaard has indicated that the EU will scrap its 10% target for bio-fuels used in transport, opting instead for a 5% target. “The Hunger Grains” report from Oxfam demonstrates that the humanitarian instinct in us all will ultimately stop policy makers from feeding cars and planes instead of humans:— http://policy-practice.oxfam.org.uk/publications/the-hunger-grains-the-fight-is-on-time-to-scrap-eu-biofuel- mandates-242997 2.2 In the light of these pressures the Transport Select Committee is asked to establish two facts:— (a.) How much will third generation bio-fuels, that do not impact upon the food supply (eg algae) cost in comparison to fossil fuel based aviation fuel; and (b.) How much will that extra cost impact upon the demand to fly? 2.3 Given the triple, substantial risk to expansion of the aviation industry (climate change/cost of third generation bio-fuel/the understandable humanitarian response) the Transport Select Committee should conclude that multi-£billion investments into airport infrastructure cannot be justified. Investment can only be justified if the industry is on a scientifically proven route to the use of zero carbon/carbon neutral fuels and that these fuels can be produced at a rate that does not suppress demand for aviation. 2.4 The Transport Select Committee is asked to critically examine claims made by some in the aviation industry that alternative fuels will soon be commercially viable. One scheme proposed by Solena and BA in 2010 announced, with great confidence, that aviation fuel would soon be manufactured from waste destined for landfill. However there has still been no planning application made to build the plant that was originally proposed. The committee needs to establish just what the economics are of the various alternative fuels that are regularly appearing in the media. There must be a very real risk that carbon neutral fuels will add sufficient cost to flying that it reduces demand, negating the argument for expanding airport capacity. 2.5 It cannot be emphasised strongly enough that growing any energy intensive industry, like aviation, that will cause the runaway greenhouse effect, destroys everything we stand for as human beings. It destroys our humanity just as it destroys the environment. No decent, right minded person can ever support expansion of an activity that will cause immense human suffering and death.

3. Future demand for aviation: Department for Transport projections. 3.1 The Transport Select Committee is asked to consider two crucial facts relating to the projections offered by DfT for future demand for aviation:— — What will be the likely impact upon future demand given the decline in UK GDP? cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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— What will be the likely impact upon the UK economy in the light of the scale of ﬁnancial loss from the EU of 2 trillion Euros per annum for imported fossil fuel?

3.2 Given the scale of the ﬁnancial downturn and the likely growing burden of ever higher oil prices, the evidence suggests that demand for aviation will soon decline.

3.3 In 2007 the DfT predicted demand at 2030 of 500MPPA (million passengers per annum). But the prediction issued by DfT in 2011 was down a very long way—to 343 MPPA. Given the scale of the recession and the horriﬁc wealth EU nations now export, in order to purchase oil and gas, surely demand projections must continue to fall?

3.4 The Transport Select Committee needs robust evidence on the likely cost of oil in 2030 and 2050 and determine from this whether aviation demand will decrease, stay ﬂat or if it might increase. If demand is likely to grow, but remain below current UK capacity then it would be a gross dereliction of duty to spend many £billions on infrastructure development that will not be fully used. An Estuary Airport, perhaps costing £72 billion, would be the greatest white elephant of all time, a true monument to short-termism.

3.5 The Committee should not only seek the input of DfT, explaining the various calculations and scenarios for future aviation demand but it should also seek the input of the previous government chief scientiﬁc ofﬁcer, Sir David King, to explain the calculations he gave to the ReSource conference in July. It is vital that the Transport Select Committee not only consider the implications of rising fuel prices upon the UK economy but consider the wider economic implications of the entire EU block losing ever larger revenue to purchase oil.

3.6 The Committee should also familiarise itself with the achievement associated with the WWF “1 in 5 challenge” that had huge success in reducing business flights. While it is the case that business leaders need face to face contact, to forge new partnerships and trade, once those relationships are in place, demand for flights can be reduced significantly by the use of new technology. It is vital that the Committee understands the pace with which super fast broadband and new communication technologies and tools will impact upon future business demand for flights. There is real potential here to reduce business flights, saving firms time and money.

3.7 Doubtless, when the DfT data is properly considered, the Transport Select Committee will conclude that the claims often made by the aviation industry of vast growth in demand are unrealistic and extremely optimistic.

3.8 Crucially, there is a very real possibility that existing capacity can meet demand by better regulation to ensure long haul business connections are served at Heathrow and Gatwick and short haul ﬂights are moved from these airports to others with greater spare capacity. See Page 5 of this joint WWF and AEF paper:—

http://www.aef.org.uk/uploads/WWF_AEF_airport_capacity_report_FINAL_July_2011_1.pdf

3.9 It is vital to understand that the very nature of the competition between airports means that the aviation sector does not always work in the national interest. It is a market that fails and requires intelligent regulation and direction. Government needs to regulate to ensure that the national interest to make good connections with emerging markets abroad is met. It cannot be right that BAA at Heathrow is permitted to expand short haul ﬂights at a time when it is nearing capacity. While it might be good for BAA business to serve Alicante, other Mediterranean tourism destinations and run 81 ﬂights per week to Manchester, this is not good for the UK. Short haul destinations must be moved to high speed rail and/or other airports.

4. Aviation: The economic imperative to head north.

4.1 If it were possible to make the industry carbon neutral then it follows that, baring concerns regarding noise upon residential areas, the economic beneﬁts of aviation connections throughout the UK be considered. So far the media debate relating to aviation capacity has tended to focus upon the South East, but that fails to address the need to improve business links to the north of the country. Some who oppose expansion at Heathrow, and others who oppose expansion in the Thames Estuary have suggested alternatives such as expansion at Gatwick, Stanstead or Luton, or a combination of airports into a “virtual”, high speed rail connected hub.

4.2 Yet the south east has overheated, it is too densely populated and the north has greater capacity to grow, attract business investment and business partnerships with the emerging/growing economies. The UK needs foreign investors to make a greater focus upon the north of the country and southern Scotland, and so must encourage greater aviation capacity in the north (provided this can be done without increasing greenhouse gas emissions).

4.3 The Transport Select Committee should ensure that it has evidence from business interests outside of the south east. They too must be given a voice to express their best interests. Interests that might otherwise be drowned out by the short term interests of BAA at Heathrow. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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5. No Thames Estuary Airport: Not now, not ever. 5.1 These are the main arguments against a Thames Estuary Airport:—

National Air Traffic Control “The very worst spot” to put an airport 5.2 When the CEO of NATS (Richard Deakin) was interviewed in connection with the Isle of Grain (Foster & Ptns) scheme he is said to have made the point that such an airport would cut across four of the five flight- paths of the other London airports. He is quoted as saying it would be “the very worst spot” to put an airport:— http://www.guardian.co.uk/uk/2012/apr/13/thames-hub-airport-worst-spot 5.3 When Jon Fuller put this point at the recent “Will it ever be time for T.E.A” debate hosted by Brian Donohoe MP in Parliament, a spokeswoman for NATS was present and was asked to comment. The lady was a little more cautious but advised those present that an airport in the estuary would require significant changes to the flight paths of a number of airports, possibly including Schiphol. She added that it might not necessarily require the closure of Heathrow but would require very significant analysis and change. She did not answer specifically the question about the impact upon smaller airports such as Southend and Manston but the implication was that these may have to close. 5.4 The Transport Select Committee is asked to establish from NATS whether the construction of an estuary airport would in fact serve to reduce capacity in the south east by reducing capacity at the other regional airports.

EU Habitats Directive: The Birds 5.5 Around 350,000 migratory birds use the Estuary every year. The UK has both national and international obligations to ensure their protection and the larger birds pose a signiﬁcant threat to aircraft. 5.6 Evidence given by Paul Outhwaite of RSPB at the “Will it ever be time for T.E.A” debate in Parliament showed that:— — Flying from an estuary airport would be 12 times more dangerous than ﬂying from any other UK airport (Source: International Bird Strike Committee). — The Thames Estuary provides a unique habitat of fresh warm water from rivers and cold north sea salt water. This unique habitat cannot be recreated elsewhere in the UK nor, probably, anywhere else in the EU. — The Foster & Ptns scheme involves destroying 20 km² of tidal habitat and it is suggested that this be compensated by building a 60 km² zone off the east coast of the Dengie peninsular in Essex—but this cannot replace the same habitat. — The EU Habitats Directive stipulates that for any scheme to proceed, the habitat must be compensated for elsewhere (which the scheme cannot do) and — The EU Habitats Directive requires that any such scheme can only be carried out if it is genuinely in the overriding national interest and there are no other alternatives—there are other alternatives, they may be unpalatable but there are other alternatives. 5.7 There were very good reasons why plans for a Maplin airport and another scheme at Cliffe were rejected. It is a waste of public money to have to go through the entire exercise again repeating these “killer arguments” against any estuary airport scheme.

Medway Council infrastructure/plans 5.8 From two presentations given by Robin Cooper of Medway Council the following crucial issues have emerged:— — The Medway Council new housing allocation necessitates the construction of sufﬁcient new homes on the Isle of Grain to increase the population from 20,000 to 40,000 people. If an estuary airport scheme is permitted this will double the number of homes that will have to be demolished. — The closure of Heathrow would necessitate moving around 75,000 directly employed staff and perhaps another 41,000 people employed in ancillary jobs, from the west of London to north Kent and possibly south Essex. Never before in peace time history have local authorities been asked to cope with such mass migration of population. The cost and other infrastructure implications are almost incomprehensible. — Medway Council challenges the cost of the Foster scheme, claiming that it would cost at least £72 billion (a signiﬁcant proportion of the Foster error is attributed to the failure to properly cost the scale of compensation that would have to be paid in connection with the closure of Heathrow). cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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— If just one new runway and one new terminal at Heathrow is set to cost £9.6 billion the cost of an estuary airport and associated infrastructure will clearly be far greater than indicated by Foster. — The Foster scheme has not costed the need to move the Isle of Grain gas terminal—20% of UK gas supplies are now brought ashore there and — The private sector will see an estuary airport scheme as posing too great a risk and will not invest; especially given the fact that the aviation industry does not want to move from Heathrow (in a survey, 86% of airlines indicated they want to stay at Heathrow).

SS Richard Montgomery 5.9 There is no agreed method for dealing with the threat of the 1,400 tonnes of unexploded WWII munitions, but there is common agreement that a threat this great cannot be left unattended at the end of a busy new airport runway. Media reports have suggested that if the materials were to explode, as a result of work associated with the construction of a new airport, the blast would cause very signiﬁcant damage to property either side of the estuary, including a wave of between four and 16 feet:— http://en.wikipedia.org/wiki/SS_Richard_Montgomery

South Essex Tourism 5.10 The Essex Chamber of Commerce and all but one Essex MP oppose an estuary airport. There are many reasons behind this but one signiﬁcant factor is the huge detrimental impact an estuary airport would have upon those living in south Essex and the Southend tourism industry. Very few people want to holiday or day trip to look at an airport. And that would be the spectre people would face if visiting south east Essex. The Transport Select Committee is asked to ensure it has properly costed both the adverse economic impact upon tourism and the adverse impact upon property prices in south Essex and north Kent.

Erosion and impact upon DP World (London Gateway port). 5.11 The dredging of the channels associated with DP World are already causing unexpected erosion from south Essex shores. What is becoming clear is that it might be impossible to predict the impact of major new construction projects upon tides and erosion within the Thames Estuary. It is absolutely vital that no estuary airport is constructed unless the impacts upon the newly dredged channels that service DP World are fully understood.

6. Conclusion 6.1 The arguments set out here show the enormous strength of the case against aviation expansion and against the construction of an airport within the Thames Estuary. The Transport Select Committee is urged to not only heed these but examine critically whether the case being argued by the other side represents nothing more than a ruse to serve the business interests of BAA at Heathrow. The business interests of BAA at Heathrow are not the same as the national security, humanitarian and economic interests of the United Kingdom. 4 October 2012

Written evidence from Peter McManners (AS 06) 1.0 Summary 1.1 The outcome of the current debate about airport capacity will have signiﬁcant consequences for infrastructure investment and the position of UK within the European transport network. This is an industry with long time horizons such that decisions taken now will have an impact well beyond 2020. Over this timescale, it is likely that there will be substantive action to deal with emissions from aviation as part of sustainable policy. Therefore, pragmatic policy should factor in sustainable policy requirements, whilst remaining sensitive to short-term considerations. Through the lens of sustainability, when all factors are considered, the preferred option is to commit now to a new airport in the Thames estuary, concurrent with taking a leading role in renegotiating the international aviation policy framework. Such a balanced approach will deliver a resilient strategy for UK airport capacity planning.

2.0 Introduction 2.1 Current international aviation policy is inherently unsustainable, locked into a policy framework established at the end of the Second World War. Today’s priorities are different, with concern over climate change growing and sustainability rising up the policy agenda. Aviation policy is not adapting fast enough to deal with this emerging challenge. Effective strategy for aviation should look ahead to the future when sustainable policy holds sway. A simply extrapolation of the status quo would not be sufﬁcient and would lead to policy that would not endure for more than a few years. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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2.2 Deciding strategy for aviation capacity, without further delay, is important because decisions taken now will take many years before the required infrastructure is delivered. The decision is particularly important because aviation is a global industry with long time horizons. Policy enacted now will have consequences up to the middle of this century. Getting it wrong could set the UK back in this important area but getting it right could put the UK in a leading position as the parameters of aviation in the 21st century start to take shape. 2.3 The context of the current debate makes it difficult to reach the best and most appropriate decision because discussion is highly polarised between environmentalists and other stakeholders; and the loudest voices are from those with a vested interest in maintaining the status quo. Incisive balanced analysis is in short supply, but using the overarching policy of sustainability the debate can be shifted onto a firmer basis. There can be little doubt that the influence of sustainability on policy will grow and the current debate over airport capacity should mesh with this bigger picture. 2.4 The route to formulating effective strategy for aviation is to focus on getting it right over the long-term before considering how to address immediate and near-term challenges. In the years ahead, it is expected that the consequences of climate change will become a clear and present danger to society. The strategy for airport capacity should factor in the resulting switch in people’s attitudes in favour of low-carbon aviation solutions.

3.0 Objectives of Aviation Policy 3.1 A primary objective of UK aviation policy should be to ensure that it is future-proof to the unfolding policy of sustainability and the expected shift in public attitudes towards effective emission control measures. 3.2 The reason to elevate the environmental impact of aviation from secondary to a primary issue is that the required response is deep-rooted change and a complete rethink of some aspects of aviation policy. Unless these changes are factored in at the foundation of policy, the whole strategic framework could collapse when public attitudes start to support sustainability measures. It would be better to craft a resilient strategic framework that can bend with the coming changes providing a clear and consistent policy framework to be able to make the required investment in a timely manner. 3.3 There are a number of short-term concerns, which will require a response, but these should not be allowed to drive strategy. For example, airport capacity is needed during the current period of growth in conventional aviation but this bulge in demand is unlikely to endure. Another example is policy for Air Passenger Duty (APD). One reason for this tax is as a proxy for a tax on aviation fuel which is currently tax- free through outdated international agreements. It is becoming widely accepted that tax on aviation fuel will be the most effective lever to drive change and facilitate a transformation of the industry. But resistance to this sensible policy is stiff, particularly from the United States. The government should plan for, and help to orchestrate, the change in international agreements to be able to tax aviation fuel, not assume that high levels of APD will continue to be the UK solution. 3.4 Aviation should be an integral part of the overall transport strategy leading to consequences beyond aviation. For example, short-haul capacity is likely to be squeezed particularly hard to deliver emissions reductions as there is an alternative in the rail network. Aviation capacity policy has therefore a corresponding strategic objective to improve and expand capacity on the rail network. Again, timescales are long and strategy is required without delay. Improving and decarbonising the rail network will take decades to complete but is required to support contraction in short-haul ﬂying capacity.

4.0 Best use of Existing Capacity 4.1 The current regulations for airport design are highly prescriptive to ensure all international airports can serve the current aircraft fleet. The next generation of air vehicles will require a different ground infrastructure. Which comes first, the new air vehicles or the new ground handling facilities? The UK aviation strategy has to be able to handle this dilemma. Investment in increased capacity for conventional aviation is likely to be wasted unless part of a coordinated sustainable infrastructure plan. 4.2 Strategic capacity planning requires an understanding of the likely shape and scale of aviation beyond 2020. It will depend on how quickly the world responds to concerns over the role of emissions from aircraft in climate change, but it is safe to assume that curtailing emissions will be required. Attitudes could change fast as climate change starts to have real impact on people’s lives. The infrastructure needs inbuilt flexibility to support change as a wave of innovation engulfs the industry. 4.3 The broad outline of the changing passenger and freight demands can be ascertained (McManners 2012). Conventional fast jet aircraft will continue to be required using aircraft that are an evolution from current models. The newest models now coming off the production lines—such as the Boeing 787 Dreamliner and the Airbus A380—are expected to remain flying for the next two or three decades but older aircraft will be retired early, as fast flying becomes much less affordable. Fast jets will be for people under time pressure such as senior government officials and business leaders. As ordinary people are priced off conventional aircraft the demand for cheaper alternatives will support the development and deployment of a new generation of relatively slow air vehicles where the aero engineers trade speed for fuel efficiency, and passengers trade time for money. Despite a short-term backlash against high tickets prices for jet travel, the passenger experience in this new cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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breed of relatively slow air vehicle will be much improved and become embedded as the low-cost air transport method for passengers and air freight. 4.4 This transformation in aviation could take less than one decade from the point when world leaders decided to act. Strategic airport capacity planning in the UK should accommodate the new parameters whilst continuing to be able to support the industry as it is now. The initial conclusion is that existing conventional airport capacity should be squeezed to accommodate expansion in the short-term with minimum additional investment whilst making plans to invest in the new future transport infrastructure.

5.0 Constraints 5.1 Question: 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? 5.2 Answer: Noise reduction is an important issue from a local environmental perspective but is also a potential distraction from the bigger picture. Focussing too much on noise limits could hold back development of more efficient engines, such as open-rotor jet engines. Noise limits should be set that allow the new generation of aircraft to be built with an uncompromising commitment to low emissions without excessively onerous noise reduction targets. Some flexibility with regard to noise limits should be allowed if this leads to significant efficiency improvements.

5.3 Question: 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? 5.4 Answer: This is the key question at the heart of aviation strategy. The simple answer is that current policy will not be effective in reducing carbon emissions, but the government is in a difficult position. For the UK to take unilateral action and set appropriate, effective policy for aviation emissions would impact the UK economy disproportionately hard compared with other countries. It is proposed that the UK government deploys a two-pronged approach. The first is to understand sustainable policy for aviation and formulate appropriate policy aspirations. This will then require a long-game to push for the necessary changes in the international agreements that shape aviation. Meanwhile, the second prong is to craft pragmatic policy that delivers sufficient support for UK aviation whilst the global industry remains stuck in the current policy stalemate.

5.5 Question: What is the relationship between the Government’s strategy and EU aviation policies? 5.6 Answer: The EU has made a well-intentioned move—which it believes will contribute to sustainable aviation policy—by including aviation in the EU Emissions Trading Scheme (EU ETS). This has caused an international outcry, with the United States and China particularly incensed by unilateral EU policy impacting upon their ﬂights. In reality, this is a very small step which will not lead to a more sustainable aviation industry and could even make it harder to broker sustainable aviation policy through raising the prospect that carbon trading could the source of a solution, which in aviation is unlikely (Lawson 2012). 5.7 The UK government should, of course, continue to work with the EU over aviation policy but there is a danger that policy, seen from outside Europe as primarily environmental, will be blocked in international negotiations. Environmental concerns are the prime reason to drive change but the better tactics might be to focus on transforming the industry to serve passengers better, support a sustainable economy and curtail carbon emissions. The UK is well placed to make a robust balanced case for sustainable aviation building on its heritage as a pioneer in aviation, using its close links with the United States and utilising its expertise in the technology and knowhow required.

6.0 A new Airport for London 6.1 Extrapolation of historic trends indicates that conventional aviation will continue to expand and that the South East of England will run out of airport capacity. Options being considered include a third runway at Heathrow or a new airport in the Thames Estuary. The vision of increasing demand for conventional aviation arises from a blinkered perspective that the status quo will remain unchanged. Examination of aviation through the broad lens of balanced sustainable policy delivers a vision with a much sharper focus. This perspective points towards the counter-intuitive conclusion that a new airport is the preferred long-term solution. 6.2 The argument in favour of a new airport is that it supports resilient policy that is flexible to accommodate future changes in the industry. The rough outline of 21st century aviation includes a much reduced fast jet capability (relative to now) supplemented by the development and deployment of a new type of air vehicle that is highly efficient and slow (relative to current jet airliners). These are likely to be hybrid air vehicles with the characteristics of both a plane and an airship, but the exact design will not emerge until policy changes and make such vehicles commercially viable. The ground handling requirements between these two classes of ‘aircraft’ will be different. 6.3 The UK will have a choice, to build new facilities for the new air vehicles or reconfigure existing airports to accommodate them. One option is to design London’s new airport to be the first major airport in Europe designed to the new parameters. The early stages of the planning approval process could commence without making the final decision whether to build for conventional aircraft or for new air vehicles. The decision in cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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principle could be taken now, to proceed with a new airport, whilst holding back finalising the design until there is more clarity with regard to international aviation policy. 6.4 Attitudes to aviation policy could reach a tipping point where policy change is rapid (McManners 2012: 158–160) but it is also possible that the transition to sustainable aviation remains stalled. In such circumstances, the new airport in the Thames estuary could be built for conventional fast jets, which would have the convenience that many flights would approach and take off over water. When completed, Heathrow would become available for redevelopment, perhaps as a hub for the new generation of air vehicles. 6.5 Committing now to a new airport for London, but remaining flexible over the detailed design, is proposed as resilient and sustainable aviation capacity planning strategy.

7.0 Cost and beneﬁt analysis 7.1 Many countries in Europe have invested substantially over the years in new hub airports. The UK has been saddled with Heathrow which has evolved in piecemeal fashion without the security of a long-term strategic plan. This has been a fortunate oversight because the UK now has the option to ensure that London’s airports conform to the needs of 21st century aviation—when that becomes clear. The future-proof and cost- effective strategy is to push for sustainable aviation policy on the world stage whilst designing the appropriate infrastructure for London. This would not only give the UK world-class international transport facilities but would also provide UK’s innovative aerospace sector with a launch pad to be at the forefront of a renaissance in the aviation industry. I believe that this is a golden opportunity for UK plc but will require bold action by the government to set the appropriate strategy.

8.0 Conclusion 8.1 Airport capacity planning for the UK cannot take place in a vacuum. As major investment in new infrastructure is contemplated, there should be an overall vision for transport and aviation that reaches out to mid-century. Over this timeframe, concerns over climate change will have a major impact. The government should commit now to a new airport in the Thames estuary concurrent with leading the international dialogue over sustainable international aviation policy. The UK will then be poised to reap the benefits, with the flexibility that few other countries can enjoy through what is likely to be a difficult transition. 28 September 2012

References: Lawson, C. 2012. Aviation lock-in and emissions trading, Cambridge Journal of Economics 36(5): 1221–1243. McManners, P. J. (2012) Fly and be Damned: What now for aviation and climate change? UK: Zed Books.

Written evidence from the London Medway Airport Group (AS 05) Summary — The South East of England is already critically short of airport capacity; costing the UK economy millions—potentially billions—of pounds a year. With politicians deliberating whether Heathrow needs a 3rd runway, it is clear that this would be just a short-term, quick-ﬁx solution. — Heathrow is now redundant, and will become increasingly useless in future years. Expansion does not make sense. — The answer lies away from Heathrow; London, the South East and indeed the UK, needs a new, state-of-the-art hub airport that will fulﬁll the aviation needs of Britain for centuries to come. — A site in the North Kent Marshes, north of Cliffe, is perhaps the most prime piece of land for development in Europe. We believe it is already in public ownership. — Easy connections and transport links. Up to 100,000 new jobs for Medway. A new multi-modal road/ rail/air/sea transport hub powering the UK economy.

Evidence 1 The importance of Aviation 1.1 With the level of globalisation increasing around the world, an international airport able to meet the needs of both business and leisure travelers is vital to the UK economy. Providing a crucial link between the UK and the rest of the world, a good international airport can bring massive beneﬁts to the UK. The impact of aviation on the economy cannot be underestimated, encouraging companies to locate in the UK and making it easier for UK businesses to expand into foreign markets. These links are already very signiﬁcant, but over the next few years, the role of an international airport will becoming increasingly important. With a lack of air links with the emerging economics, such as Brazil and India, the UK economy will start to suffer. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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1.2 As the gateway to the rest of the world, an international airport supports billions of pounds of exports, thousands of jobs and gives the UK a crucial advantage over other countries when businesses decide upon where to locate. With 52% of Europe’s Top 500 companies considering transport vital when deciding to locate, the access to markets is vital. The services sector, which contributes 70% of UK GDP has been heavily dependent on the air transport links provided by an international airport. Connectivity is especially signiﬁcant in London, with the City’s ﬁnancial, insurance and banking companies reliant on air services; requiring on average six times more air travel than other businesses. Without these international links, companies will consider locating elsewhere, and investment will be given to other countries, meaning that the UK will lose out. Foreign direct investment is worth more than £52 billion each year, worth 27% of London’s economy, has brought more than 500,000 jobs to the area. Although the companies choose London and the UK for a variety of reasons, transport has been seen as essential to attracting the multinational corporations as well as the small and medium enterprises. Links to places like the United States and India, the leaders in numbers of inward investment projects in London, are very important, and a lack of these will mean that the UK could lose out of future investment.

1.3 Capital and and labour can relocate quickly, especially given the single market of the European Union, allowing these factors of production to move if the UK infrastructure is seen as inadequate. With an effective hub airport, travelers can access a massive number of destinations making the UK very attractive, but this advantage is being eroded by the progress of other countries. Other competing cities, including Paris, Amsterdam, Dubai, Frankfurt and Berlin, are all investing in new capacity, hoping to gain from some of the benefits that the UK has enjoyed from Heathrow over the past few decades, including that seen with the growth of the financial services industry. This means that they have been able to increase the number of destinations they serve significantly, while the number served by Heathrow has decreased over the past twenty years. Therefore, the UK is in danger of losing its status as a world leader, losing the direct benefits of inward investment and increased exports, as well as the indirect benefits seen from the jobs and tax revenue supported by these transactions.

1.4 Economic growth and development at a regional level is also reliant on the UK having a global hub airport. As a trading nation, businesses both large and small rely on a hub airport to be able to reach worldwide destinations from their local airport by that can only be served by connecting at a hub airport. This means that a strong aviation policy not just affects London, but also supports jobs and benefits the rest of the country. No other form of transport can match aviation in speed, efficiency and the level of connectivity that a global hub provides. In business, the Department for Transport states that “faster and more reliable journeys in the course of work represent a productivity gain.” A lack of connections to a hub airport then harms businesses, as it takes longer for them to reach destinations. This has been seen recently, with Heathrow falling behind Paris and Amsterdam in terms of flights to UK regional airports, thus leading to a productivity loss and harming GDP. In the short term, the regions will start to lose out due to higher costs due to the lost productivity, while also seeing wider long term disadvantages. With problems accessing international markets, businesses will then see lower exports, leading to lower growth. Less jobs will then be created, leading to lower tax revenue and increased regional inequality as London benefits from the hub airport, leading to wider issues. A strong international hub airport connecting the rest of the UK to the rest of the world is important not just locally, but for the whole of the UK.

1.5 It is clear that aviation can clearly benefit the whole of the UK economically if there is a strong airport with wide international links. Domestic businesses will find it easier to access emerging markets, bringing the increase in export, along with international multinational firms supporting the UK with inward financial investment, supporting jobs and benefitting the wider economy. Without this, the UK will start to lose out to its international competition, having a massive economic impact that cannot be understated, with the importance of aviation going everyday due to increasing globalisation.

2 The Problem with Heathrow

2.1 Heathrow Airport has served the United Kingdom as a principle hub airport for the best part of 60 years, growing year on year to reach its busiest ever year in terms of passenger trafﬁc in 2011; handling almost 70 million passengers (69,433,230). 2011 was also Heathrow’s busiest year in history in terms of cargo; it processed over 1.4 million metric tonnes of freight. The continued growth of Heathrow shows the demand for air travel, and spare aviation capacity in the South East.

2.2 Unfortunately, Heathrow has no spare capacity. This has been apparent for some years, although the airport continues to see small single digit increases in passenger traffic each year, with the advent of larger aircraft. The “fight for flights” at Heathrow, regarding the lack of capacity and landing slots, has pushed aviation prices up dramatically for consumers. Flights from Heathrow are regularly seen to be significantly more expensive for travellers than at rival “hub” airports, such as Paris, Amsterdam or Frankfurt. Indeed, the media recently reported that a direct flight in Business Class from Heathrow to Los Angeles would cost on average £5,777. They found that it would actually be cheaper to fly via connecting flights at European hubs, costing just £3,421 when going via Amsterdam. These prices are unfair on British consumers, damaging to British business, and completely uncompetitive in a growing aviation market. Such extortionate prices at Heathrow are almost completely down to the high expense of landing slots. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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2.3 The location of Heathrow itself, is frankly bizarre. Major hub airports should be within easy reach of the city they serve, but not within the actual city limits. Heathrow’s position has ruined the day-to-day lives of millions of people; it’s congested flight paths are directly over the City, and it’s runways are nestled amongst built-up, urban areas. The noise from aircraft experienced in some residential dwellings has been recorded as a breach of basic human rights and residential law in the United Kingdom. 2.4 It is argued that point 2.2 can be easily rectified with a 3rd runway. Any 3rd runway at Heathrow would require the complete destruction of the villages of Harmondsworth, Sipson, and potentially Harlington too. Thousands of residents would have their homes bulldozed, only to be relocated elsewhere against their will. This is an abhorrent measure that could severely affect their livelihoods. Moreover, an even bigger problem would be yet further increases in the number of flights landing at and taking off from Heathrow, due to the much needed extra capacity brought by a 3rd runway. The West of London would have their misery compounded by even more unjust aircraft noise. Perhaps an even bigger problem, is that the planned 3rd runway would most likely only be a maximum of 2,200m long, which pales in comparison to the 3,900 and 3,600m length runways currently in use at Heathrow. While this would undoubtedly be beneficial in taking smaller aircraft onto the 3rd runway, allowing larger aircraft to use the original two runways, it would be of no use long-term, as more flights use bigger aircraft. 2.5 While a 3rd runway at Heathrow could be a quick, easy and (relatively) cheap fix to the problem of aviation capacity in the South East, it will not be able to fulfill the needs of future generations. In 30–40 years, we could quite easily be having the same consultations; a 4th runway will be needed, as demand continues to grow. So what would be the answer then? Continue to knock down residential areas to continue the expansion of an aged, creaking hub airport? It doesn’t make sense, long-term, to expand Heathrow any further.

3 The Future Lies at Cliffe 3.1 The UK simply needs a long-term, state-of-the-art international hub, capable of meeting the demand of air passengers for decades and indeed centuries to come. It should be multi-modal, and act as a melting pot for road, rail, air and sea logistic networks, in terms of both passengers and cargo. 3.2 As outlined by section 1 of this evidence, the economic importance of aviation to London (and the entire UK) is vast. With Heathrow increasingly losing out to the likes of Frankfurt, Paris and Amsterdam, action needs to be taken immediately by the Government, and the answer lies in a new location, East of London, with fast connections to the City. 3.3 Our proposal is “London Medway Airport” (LMA). A 4 runway multi-modal gateway to the World, this airport has the potential to transform London, the UK, and Europe. It will totally replace Heathrow, and be located on the Hoo Peninsula, just to the North of the village of Cliffe in Medway, Kent. Being an onshore location, construction costs would be dramatically reduced in comparison to offshore and partially offshore proposals, such as “Boris Island” and Foster’s “Isle of Grain” airport respectively. We believe the total cost of the project, including all the related infrastructure, would be around £25 billion, significantly less than almost all other Estuary proposals. Additionally, the vast majority of this would be funded by private investment, overseas sovereign wealth funds, pension funds and corporate partnerships. Only a small amount of tax-payer capital would be needed to directly fund the project. 3.4 The Heathrow site will be closed. The site is prime for development; 3,000 acres with extensive rail and underground links to central London, next door to the M25, and in the relatively wealthy West of London. £Billions could be raised from the sale/development of the land, creating the thousands of affordable, sustainable houses that London is crying out for, alongside one of Europe’s largest business developments. Light industry and office space could cover a large proportion of the land, creating thousands of jobs, and covering the loss of jobs suffered due to the closure of the airport. Heathrow can become a sustainable, futuristic garden city, and raise significant funds for LMA at the same time. 3.5 London Medway Airport would feature four fully operational runways. This automatically brings a doubling of Heathrow’s capacity, although unlike Heathrow, our new hub airport would not be restricted during the night. Heathrow can not operate large aircraft overnight due to nearby residential areas, but the wilderness of the Hoo Peninsula would allow 24/7 operation. 24-hour operation, coupled with four full-length runways, and a vast passenger terminal would give capacity for up to 140 million passengers per year. This would be around twice the amount that Heathrow can currently handle. In terms of cargo, an extensive logistics village with warehousing and terminals, would allow the airport to handle up to 3.5million metric tonnes of cargo per annum (in comparison to 1.5 million at Heathrow). The importance of cargo at the airport is vital, as a means of British businesses exporting to new markets, and also due to the proximity to the under construction London Gateway Port, directly opposite our proposed site. By 2016, it is estimated that around 70% of the UK’s container traffic will be processed through ports within 40 miles of our proposed airport location. 3.6 Amongst the most important parts of supporting infrastructure with regards to LMA would include the construction of a new local road network and—crucially—a new Lower Thames Crossing. Ideally a bridge, but potentially a tunnel, this would not only ease the current congestion seen on a daily basis at Dartford, but also provide direct access onto the airport site. The new crossing would be the focal point of a new local road network connecting the M25 with LMA, London Gateway Port and the M2. These new roads would enable swift access by road to the airport site, as well as good connectivity with the London Gateway Port and cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Logistics Park, just a 5–10 minute drive away from LMA via the new crossing—this is vital for the cargo sector of the airport.

3.7 The Channel Tunnel Rail Link (HS1), would be extensively upgraded as part of the plans. With a new branch leaving the main line south of Ebbsﬂeet, and going directly into the passenger terminal building, the airport would be reachable from Stratford International (zone 3) in 18 minutes, and St Pancras International (zone 1) within 25 minutes, via a regular and fast express shuttle service between these London stations and the airport. The new branch could potentially be built into a cutting, to avoid any visible destruction of the landscape as it passes relatively close to some homes in the Medway area. We would anticipate that up to 70% of LMA passengers would travel to the site by this new rail link, with the airport station capable of handling up to 80 million passengers a year. St Pancras meanwhile, will form a new national and local rail hub, along with nearby Kings Cross and Euston stations—within walking distance. The extensive availability of different London Underground lines at Kings Cross St Pancras tube station and Euston/Euston Square tube station would make the St Pancras area an ideal connectivity hub for the new airport. It is also more than possible for continental trains on HS1, such as Eurostar (Potentially also Deutsche Bahn) to call trains at the airport from cities such as Paris and Brussels.

3.8 Heathrow is redundant because of the local area; it can not expand without destroying villages. It cannot continue to operate in its current state because it causes misery for thousands. There are no current homes on the proposed LMA site, or indeed any buildings whatsoever. There are very few homes under the closest aircraft approaches. LMA makes sense because it would affect very few people. Our core objective is to “significantly improve the lives of Medway residents, without directly affecting them on a day-to-day basis”. This can be achieved by creating the world’s first community airport. The airport operators, airlines, on-site hotels and businesses would be required to take on significant numbers of staff from Medway where possible. Additionally, work-experience/apprenticeships for North Kent students will be of paramount importance, with all components of the airport having close relationships with local secondary schools, utilising the educational potential of a major international airport, in the fields of science, engineering, maths, business and tourism. The airport shall also have a large scale charitable programme, donating almost exclusively to local charities, community groups and sporting clubs.

3.9 Medway has serious pockets of deprivation in its larger towns, and a higher than normal unemployment rate. It may not automatically be considered as a deprived area by the uninformed from elsewhere in the country, but the failure of planned regeneration projects has continued to drive down average wages and employment rates during the economic downturn. The region is now suffering, and needs a huge investment to turn it around. London Medway Airport is that investment. The Thames Gateway corridor of redevelopment projects has (largely) stalled, but that would no longer be the case if LMA was to be constructed. The region would become highly desirable, vibrant and cosmopolitan. Developers would be keen to invest in stalled projects, an eventually the entire area could be regenerated into one of the most desirable parts of the UK.

3.10 Heathrow is currently the home of around 75,000 on-site jobs. In addition to this, it is estimated that it indirectly supports around 115,000 further jobs off-site, in the local area and throughout the South East. London Medway Airport would be far bigger than Heathrow, and we estimate that around 90,000 jobs would be created on-site upon opening. Of course, this would grow substantially when more passenger and cargo capacity is utilised, up to around a maximum of 120,000 employees eventually. All current Heathrow employees would be offered the chance to transfer their jobs to the new site, although it is expected that only around 60% would wish to do so. This means that in total, around 45,000 new directly supported jobs would initially be created at LMA, and priority would be given to Medway and Kent residents. At the time of writing, the latest unemployment ﬁgures show that 135,000 people are unemployed in the South East, including almost 40,000 in Kent itself. The impact of the airport on the local area would also be great in terms of indirectly supported jobs.

3.11 Wildlife on the North Kent Marshes remains of vital importance. Wildlife is a great passion of the founders of the London Medway Airport movement, although it is totally possible that an airport could be built here without a single animal being harmed. A long-term wildlife management strategy could be implemented to encourage the natural migration of the thousands of local bird species away from the site, to a new nature reserve. It is our ambition to create one of Europe’s largest conservation areas elsewhere in the South East through sizeable investment, creating up to three times the land lost by the development of the airport. Due to this long-term programme, the eventual risk of bird strike once the airport was operational, would be no higher than other major UK airports.

Further Information

Extensive details of London Medway proposals can be found on our website, as well as a useful Map, outlining our speciﬁc airport plans. The map can be seen here: http://www.londonmedwayairport.com/map/ 25 September 2012 cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Written evidence from Dr Patrick Hogan (AS 09) I would ask the committee to make the calculation as to whether any expansion at all would be required given the following scenario:— Almost all domestic flights to be scrapped as we have a perfectly good rail system. Most near and middle continent flights to be scrapped and replaced by the Eurostar and onward rail systems. The capacity thus saved would be enough to enable the additional long haul flights to Chinese cities etc that business feels are needed and would avoid the negatives of increased noise, carbon emissions and expansion costs. 5 October 2012

Written evidence from the Royal Aeronautical Society (AS 11) Summary — The objectives of policy should be to promote sustainable civil aviation operations to the benefit of the United Kingdom as a whole: a simple statement, but inevitably complicated to implement. — HMG has an opportunity to make a positive impact on the future of UK civil aviation. There are emerging technological and managerial solutions to pressing environmental challenges that should be encouraged to improve the sustainability of civil aviation and to reduce its overall environmental impact locally, nationally and internationally. — There is an urgent need for a satisfactory and timely solution to the airport capacity problem in the SE of England that will require compromise in the national interest by all concerned. — Air transport connections—both international and domestic are vital to the UK economy and to bolster political influence abroad. — Aviation generates a similar range of direct and quantifiable benefits in terms of employment and foreign earnings, as well as the more qualitative returns associated with “connectivity”. — There is little, if any, resilience at Heathrow which is essentially operating at its maximum slot capacity. The development of regional airports and improved terrestrial links should help, but this will be limited. — Given improvements in aircraft performance, and under stringent conditions, a third runway at Heathrow would help significantly to ease capacity problems. — Improvements in technology and more effective air traffic management should enable the aviation to meet the 2050 carbon targets. — In principle, there is a need for a new London hub airport; but proposed solutions may be too late, and may not reflect national requirements.

Introduction 1. The Royal Aeronautical Society is the learned society for the aerospace and aviation community. It has over 17,000 members world-wide. Its activities are supported by a number of Specialist Groups, including Air Transport, Space and General Aviation and Greener-by-Design, a group of senior academics, industrialists and aviators concerned to promote environmentally sustainable aviation.

Objectives of Government aviation policy 2. The objectives of policy should be to promote sustainable civil aviation operations to the beneﬁt of the United Kingdom as a whole: a simple statement, but inevitably complicated to implement. 3. The current state of UK civil aviation is the product of decisions and failures to act strategically over several decades. The current impasse in resolving the airport capacity crisis in the SE of England, the failure to overcome Heathrow’s evident frailties as a national hub airport stems from a failure to develop a more appropriate hub airport in the late 1960s and early 1970s. 4. The UK is a relatively “open” aviation environment in terms of inward and outward investment in infrastructure and airline competition. This is not of itself a weakness, but concern should be expressed if UK national priories and interests are vulnerable and negatively affected by investment decisions made offshore. Similarly 5. HMG has an opportunity to make a positive impact on the future of UK civil aviation. There are emerging technological and managerial solutions to pressing environmental challenges that should be encouraged to improve the sustainability of civil aviation and to reduce its overall environmental impact locally, nationally and internationally. Measures can be taken to encourage the expansion of capacity at UK regional airports that will ease the pressure on the SE of England, but more important act to stimulate regional economies. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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6. However, it should be stated from the outset, there is no easy solution to the crisis in airport capacity affecting the SE of England. This has become one of the most intractable public policy issues of the decade. In the ﬁnal analysis, a satisﬁcing rather than an optimal strategy may be the only cost-effective and publically acceptable approach. But there is an urgent need for a satisfactory and timely solution that will require compromise in the national interest by all concerned.

The importance of connectivity 7. Air transport connections—both international and domestic are vital to the UK economy and help to promote both trade and inward investment. There is also a political dimension where connectively may be interpreted as implying diplomatic importance to HMG. 8. At a simplistic level, and despite the considerable advances made in the speed and economy of land and sea connections, the multi-island geography of the UK underlines the importance of air connections. Improvements in road and especially faster rail connectivity has improved domestic connectivity, but the growing congestion of the former and the price of the latter, ensures a continuing importance attached to accessing easily the regional airports and the national hub airports at Heathrow and Gatwick. 9. A hub airport will maintain the UK’s connectivity to its main markets. It will also provide economic benefits to the airport operator and to UK airlines. It encourages the interchange between routes either by a single carrier or alliance, as well as access to other routes served by other airlines. The hub concept is enhanced by the fact that many long haul services are only feasible with traffic provided by feeder routes. While transit and transfer passengers are less important to the UK economy directly, indirectly they represent visible sign of the vitality of an airport as a hub or transfer point and help to maintain the viability of services in general. 10. A hub facilitates access directly by providing a greater range of destinations and indirectly by ensuring that most other destinations are accessible by a single overseas connection. An international hub also supports a national airline industry by affording local carriers a strategic position that underpins competitiveness and their ability to lead rather than to follow developments in the international airline industry. 11. Transfer via a foreign rather than a UK hub is likely to involve longer flight times and a greater environmental impact. It will take longer and will be perceived as more difficult, especially for non EU citizens, who may face additional visa issues. This could seriously discourage inward investors and tourists to the UK regions. 12. However, it must be emphasised that network connections are an airline responsibility. Few routes are now maintained for social reasons, although this is more common in other parts of the world. However, it is in the UK national interest to maintain and to develop strong connectivity with economically important regions, especially in the emerging economies. While airlines will reflect the changing patterns of demand and try to anticipate growth through opening new routes or changing priorities for services, HMG should ensure that it does not place unnecessary barriers to growth and where it has power to influence events, such as negotiating access rights, it should be ready to encourage new links or to expand existing services.

The benefits of aviation to the UK economy 13. There are widespread benefits to the UK from a strong and healthy aviation sector. In 2009, aviation contributed around £18 billion in UK output and represented about two% of gross value added. The sector currently employs over 250,000 workers directly and supports an estimated 250,000 additional jobs through the supply chain. 14. Aviation generates a similar range of direct and quantifiable benefits in terms of employment and foreign earnings, as well as the more qualitative returns associated with “connectivity”. Studies of the location choices of high value activities in finance, corporate head quarters and R&D refer to the importance of good international transport links, which for the UK still implies air transport for most of Western European destinations and of course for global access. As the disruption caused by the 2010 volcanic ash cloud demonstrated modern production depends on a continual flow of components and supplies. The interests of both dedicated air freight operators and freight carried by scheduled airlines should be considered as part of a national air transport strategy. These are clearly not sufficient conditions to generate economic and social return, but they are necessary. 15. In terms of airport development, current Government policy will mean that there is likely to be stronger growth at UK regional airports, particularly those with good surface access links. Whilst this will undoubtedly benefit those living in the regions, there will be a significant level of unmet demand for air travel to and from London and the South East which will have important consequences for economic growth both in London and the South East and more generally for the UK as a whole.

Making the best use of existing aviation capacity 16. There is little, if any, resilience at Heathrow which is essentially operating at its maximum slot capacity. As a major international hub, it requires sufﬁcient slot capacity for sufﬁcient point to point and feeder services in order for it to compete with other European hubs. Some increase in Heathrow’s slot capacity could be cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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achieved through mixed mode operations. Further, but limited, increases in slot capacity at Heathrow and Gatwick should be possible through improved ATM procedures. Passenger capacity will also be increased through the use of larger aircraft.

17. However, it is abundantly clear there is no spare capacity at Heathrow for large numbers of additional ﬂights, forcing the airlines to go either to other less attractive airports in the UK, or abroad. It is likely many airlines will prefer this option, causing the UK to miss out on improved air transport links with these developing countries, and to miss out on the associated tourism, business and jobs

18. There are a number of smaller airports and ex-MOD airﬁelds that could be used for commercial passenger and freight services, although clearly there will be environmental and local constraints. Whilst demand management measures are not generally desirable, it is possible that differential taxes may be used to promote the use of certain airports.

The role of other UK airports

19. Airports outside of the SE region already play an important role in increasing overall national capacity. Under current DfT trafﬁc projections, by 2050 Manchester could be handling as many ATMs as Heathrow does at present, suggesting that resilience could be an issue unless further runway capacity is provided. In principle other UK airports could absorb some of the demand pressures on the south-east airport network. However, capacity does not alone dictate attraction, and the bulk of UK demand for air travel is in the SE of England. Airline business models again shape access. A number of new services have been launched successfully from provincial airports, usually to serve other European or global hubs. Direct services on thinner routes have proven less resilient. Even if acceptable to HMG, there is little scope under EU rules for ﬁnancial incentives to encourage provincial services.

20. However, there is currently surplus runway capacity in the UK. Manchester is the only other two-runway airport other than Heathrow. Birmingham is also increasing the length of its single runway and upgrading terminal facilities. Many of the provincial airports are well served by land access, including in some cases fast inter-city services. However, growth in demand has been less than in the southeast, and most regional airports suffered more during the last down turn than Heathrow or Gatwick. The development of a “limited hub” airport will in the ﬁnal analysis depend on airline strategies and their assessment of revenue earning potential. To date much of the growth in new services has been by airlines seeking to feed their own home-hub airports. This, in the scheme of things might ease the impact of future growth on the southeast, but it may not be to the beneﬁt of UK based airlines.

21. Some demand in the south-east may therefore be met by the regional airports, although this is likely to be limited. New point to point services may emerge at the regional airports, thereby reducing the requirement for those passengers based in the regions to travel via the main London/SE airports. Similarly, improved surface access (such as the proposed HS2 rail link to Birmingham airport) could enable some London/SE based passengers to travel from a regional airport. Absolute capacity constraints on the most popular southeast airports might force a redistribution of trafﬁc through natural market forces and passenger satisfaction. However, this is most likely to affect the more northerly London airports that might lose trafﬁc to airports in the Midlands and perhaps Manchester.

22. There is a case for a limited number of protected slots for feeder services into Heathrow and possibly Gatwick—particularly from poorly served regions including the South West and Scotland. Several studies have demonstrated the value of regional connectivity to promote inward investment.

23. But Heathrow is the national global hub, and despite high costs and user charges, the major airlines have naturally sought to exploit its connectivity. Gatwick and Stansted have tended to attract the low cost carriers (LCCs) and charter business. The regionals have had some success in building local trafﬁc, but their place in the national air transport economy will always be second place to London and to Heathrow in particular by commercial natural selection.

The impact of fast rail

24. In the case of short haul trafﬁc, there will be inevitably a continuing shift towards rail travel, particularly as high speed rail networks develop. Fast rail has an economic advantage for journeys of less than 400 kilometres and has already had an impact on UK domestic air travel. But there are limits as surface access times will not be reduced for many transfer passengers. Furthermore, a combined rail-air (rather than air-air) journey may be less convenient in terms of baggage, and ticketing. Competition between air and rail should not be distorted by public subsidisation.

25. Improving the direct links between airports is of value in its own right as a means of improving connectivity and reducing the environmental impact of air travel. Strategically, this implies linking major airports to a fast rail system (which need not be HS2, but existing or proposed electriﬁed fast long distance services). cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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The constraints on increasing UK aviation capacity 26. Increasing aviation costs from rising fuel prices, environmental charges and other taxes will increase air fares in the medium to long term and will provide some constraint on demand. It is likely that the gap between the legacy airlines and the LCCs will reduce as both seek to exploit each other’s markets. 27. Clearly, the immediate impact of aviation on communities is a constraint on capacity. Noise is a particularly vexing issue. It is preferable to minimise the total number of people affected by aircraft noise. This can be achieved by careful routing and technical improvements; although routing decisions designed to lessen the average impact of noise may increase noise for some. 28. Noise Action Plans have a key role in predicting and demonstrating an actual reduction in noise levels. To give local communities conﬁdence that action is being taken to reduce the noise impact around airports, there is a need to demonstrate hard results and Government should introduce measures to incentivise airports to deliver against their statements of intent in such action plans.

EU aviation policies 29. Given the role of the EU in economic and environmental regulation, there are important links between national and European aviation policies and initiatives. In particular, there is a critical relationship between strategies designed to improve the management of European airspace. As demonstrated in the EU’s SESAR Programme, there will be some capacity improvement resulting from integrated network planning, collaborative decision-making and improved ATM procedures. 30. Europe’s investment in advanced air trafﬁc management technologies, such as navigation satellites, is critical if the easing of congestion is to be achieved. In the past, the DfT has sometimes been unenthusiastic about European investment in such systems. The Society urges the DfT to recognise that these investments are for the beneﬁt of the aviation community and will make a major contribution to reducing its carbon footprint. 31. The introduction of the EU ETS scheme should help to cap the impact of aviation emissions, although opposition from non-EU carrier and governments is causing considerable uncertainty in the airline and aerospace industries. However, HMG should continue to press for the development of global emissions standards through ICAO.

Sustainable aviation 32. Pollution and noise in the vicinity of airports are currently subject to regulation, both internationally and in some cases locally. These impacts are being progressively reduced, despite traffic growth, through the replacement of older aircraft by newer, cleaner and quieter types. Advances in technology—including low NOX combustors and higher bypass ratio engines—will reduce these impacts further. Improvements will be captured in more stringent regulation. The possible introduction of contra-rotating propellers on the next generation of short-medium-haul aircraft, in order to minimise fuel burn and CO2 emission, would result in aircraft noisier than equivalent turbofan powered aircraft but still comfortably within the current noise regulations. Stricter local regulation is unlikely to constrain traffic growth, although local political pressures may in some cases limit traffic growth at a particular location, diverting some of that growth to other airports.

33. From an environmental standpoint, there is a case for regulation to reduce fuel burn and CO2 emissions. Higher fuel prices should play a significant part in reducing CO2 emissions. New technological concepts could substantially reduce CO2 emissions. But the degree to which radical design improvements will be introduced into the world fleet will depend on airline business models and the trade-off between the cost of new equipment and the long term savings and improvement in emissions. Regulation may be required in order fully to exploit the potential full of these advances in order to increase the relative cost of operating conventional aircraft. The timescale for action is short. If the intention to regulate, at least at a European level, has not been declared by the time the key design decisions are made on Airbus A320 and Boeing 737 successors, an opportunity to influence the climate impact of this generation of aircraft will have been lost. But given likely technological improvements and operating procedures, a 60% increase in air traffic is possible whilst still achieving CO2 emissions 2050 targets.

The need for a step change in UK aviation capacity 34. Unless further capacity is provided at Heathrow, the UK will lose out in terms of key transfer traffic markets and in providing a wider range of point to point destinations. Heathrow is also the UK’s high value airport: 34% of its passengers are travelling on business compared to 18% at the other London and provincial airports. This is also shown by the high proportion of long haul tourist using Heathrow and the fact that 60% of UK freight comes in via scheduled airlines. 35. This gets to the heart of the connectivity question and the virtuous circle between airports and economic activity. And just as easily, airports can enter a cycle of decline if they fail to meet new demand and to respond to changing international economic geography. Heathrow is not able sufficiently to provide direct access to the newly emerging economic power houses in Asia and Latin America. To some extent this reflects some commercial realities, and that UK airports operate in a free market—if subject to some crucial regulative cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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constraints. There is little incentive for airlines voluntarily to give up currently lucrative routes such as North Atlantic services to the US and the Caribbean in favour of speculative, developmental routes to provincial Chinese cities.

The need for a new hub airport

36. Heathrow seemed a reasonable place to build an international airport back in the 1940s; but proximity to central London, its westerly location, and urban development (often drawn out towards Heathrow by the search for connectivity) with attendant local objections, has increasingly stymied easy expansion. Even a new terminal (T5) took years to navigate the planning process.

37. The attractions of an all-new airport in the Thames Estuary have received much attention, if only to minimise the inevitable local objections to Heathrow and other airport expansion schemes to meet equally inevitable access issues, this implies that the new airport must be at the centre of a sophisticated terrestrial transport network, preferable linked to the putative high-speed railway system. This is essential if London (East) is realistically to serve as an environmentally sustainable national hub, because to be east of London is far less convenient for most potential travellers from the north or west of England. No one doubts either that its likely cost could exceed £40 billion.

38. Significantly, several of the major carriers have been very quiet about the opportunity costs of moving. And while west Londoners might object to Heathrow as a neighbour, there is also an awareness of how much it contributes to the local economy. BAA, owners of Heathrow would also have something to say about a competitor being developed with public money. Initial reaction from BAA has been to hope that any consultancy exercise might reconsider the third runway option. This, however, seems to have already been ruled out—a very odd way to approach cost benefit analysis. It is not clear whether the proponents of an Estuary airport envisage a gradual transfer of flights or the adoption of a “big bang” close and move approach. The latter would ease the air traffic issues associated with opening a new airport under Heathrow approach paths, as well as maintain vital connectivity. It would, on the other hand, pose the most challenging problem for easing economic disruption to West London and the Thames Valley

39. Indeed, it may be too late for any all-new airport to solve the current and medium term problem of London’s “connectivity crisis”. With a new airport at least a decade away—probably nearer two—the damage of lost or declining relative connectivity may already have been done. From this perspective, a less than optimal approach may be the most realistic way forward.

40. The noisiest of the current aircraft types operating on the two existing runways will be replaced by signiﬁcantly quieter technology over the next ten years. A typical example of this is the Boeing 747 currently being replaced by the Airbus A380 and Boeing 787. It should be noted that much of this new technology has been designed and produced in this country.

41. The impact of noise from aircraft using a 3rd Runway will depend on the aircraft types using the runway and the approach pattern used. A short runway would limit the type of aircraft to the twin-engined small or medium-sized jets. Coupled with a steeper approach path and no night-time operations, the noise footprint from a 3rd Runway could be very much less than that experienced under the current runways. Some of the new capacity provided by a 3rd Runway could also reduce, if not eliminate, the queuing of arrival aircraft (known as stacking) with its attendant delays and emissions.

42. More immediate palliatives, such as mixed mode runway operation, and new approach patterns could help to ease stress on Heathrow’s capacity, but these would not create sufﬁcient additional capability to meet rising demand. Improvements in ground based connectivity such as Crossrail will also help, but the concept of a “virtual hub” linking all of London’s major airports has little credibility.

43. Whilst it is recognised that it is current Government policy that there should be no further runways at Heathrow, Gatwick or Stanstead, this constraint will severely impact how UK aviation will develop in the next 40 years. There is a strong argument for some airport development in London and the SE. Indeed it has been pointed out that an additional runway at Heathrow would produce a 10% increase in trafﬁc levels by 2050, which would be well within the carbon targets for 2050 without compromising future regional airport development.

44. This points, albeit reluctantly, to further development at Heathrow, backed by similar expansion at Gatwick. This is not the ideal solution, and in many respects, a site to the North of London, which might include consideration of a substantial upgrade to Stansted, accessing the national motorway and existing fast rail network (or one capable of further modernisation) or the putative HS2, would be a more optimal national solution than one to the east of London. If London is to claim a status as a “national” global airport, consideration of future options must include consideration of national factors as a key element in resolving the issue. 9 October 2012 cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Written evidence from Mrs Caroline Tayler, Mrs Jane Vogt and Mr Stuart McLachlan (AS 12) The following submission for consideration by the Committee is in response to question 3a in the Terms of Reference. The aim is to draw the Committee’s attention to the unintended consequences of Government policy in relation to the impact of aircraft noise on rural communities

3a. 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? 1. The Draft Aviation Policy Framework states “our overall objective is to aim to limit and reduce the number of people in the UK significantly affected by aircraft noise”. 2. The above intention might appear good, but in order to comply with the recommendation to reduce the number of people affected, airport operators are likely to preferentially route aircraft over villages and communities in rural areas with lower population density. 3. The resulting concentration of aircraft over fewer people means that these rural communities will have far higher levels of aircraft noise imposed on them than on urban communities. 4. Rural areas, particularly Areas of Outstanding Natural Beauty, have low levels of background noise making aircraft noise very intrusive. High ground compounds the problem, as arriving and departing aircraft are obviously closer, for example in the High Weald AONB and Surrey Hills AONB around Gatwick. 5. The concentration of aircraft noise over rural residents by arriving and departing aircraft following similar tracks causes great distress and despair. At times some residents endure low flying aircraft passing overhead every two minutes. There are also serious health implications associated with long term exposure to noise. 6. Many rural businesses, particularly those associated with tourism, depend on the tranquillity that is associated with the low population density in the countryside and especially within an AONB. The rural economy, particularly in an AONB where planning restrictions limit activities, is fragile and dependent on maintaining the tranquillity that attracts tourists if it is to prosper. 7. The above points demonstrate the damage that can be done to the well- being of rural communities and viability of rural businesses where high levels of noise are imposed by concentration of aircraft. Planning restrictions protect communities at ground level, but the same level of protection is not afforded to communities from disturbance over their heads. 8. Surrey Hills AONB facts, www.surreyhills.org. Designated in 1958 as a unique landscape in the UK. Over 600,000 visitors during 2009 (figures from the National Trust); the land is up to 1000 feet in elevation with many local businesses dependant on tourism particularly at weekends. On a given Sunday up to 15 take- off aircraft pass very close to the AONB between 6 and 7am. Also, over 1 million visitors go to the High Weald AONB www.highweald.org every year. 9. The Government’s overall objective to reduce the number of people affected is therefore not sufficiently robust nor properly thought out. By reducing the number of people affected, the levels of noise on those still affected would significantly increase and this is not acceptable. 10. Despite making the lives of some people a misery by concentrating aircraft movements over them, the Government would still be able to claim that it had succeeded in its objective and few would ask by what means this had been achieved. 11. The Government should therefore direct its efforts towards mitigating the effects of aircraft noise for everyone rather than being content with just reducing numbers of people affected. Concentrating aircraft over rural communities is not an acceptable solution to the problem of aircraft noise. Current Government policy does not sufficiently protect people living in the countryside from what can at times be continuous and overwhelming aircraft noise. 8 October 2012

Written evidence from Professor David Metz and Dr Anne Graham (AS 13) David Metz, visiting professor, Centre for Transport Studies, University College London Anne Graham, Reader in Air Transport and Tourism, University of Westminster

Introduction 1. We offer some observations and analysis that bear upon the Committee’s inquiry. 2. It is noteworthy that the Department for Transport’s (DfT) Draft Aviation Policy Framework of July 2012 omits projections of the future demand for air travel. Such projections were included in previous consultations on the development of airport capacity and the impact of the aviation sector on UK carbon emissions. The DfT has nevertheless published projections of aviation demand and carbon emissions, most recently in August 2011. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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3. Inclusion of aviation in the EU Emission Trading Scheme is now seen as the main means by which aviation carbon emissions can be managed, consistent with an overall carbon emission cap for all sectors and allowing aviation to purchase credits from sectors with lower abatement costs.

“Predict and provide” or demand management? 4. Omission of projections of demand for air travel from the Draft Framework raises a question about the relevance of such projections to planning future airport capacity. Previously, projections of substantial future growth were invoked to make the case for investment in further capacity, for instance a third runway at Heathrow. Such a “predict and provide” approach had in the past been used to justify investment in the trunk road system, but more recently has been rejected on account of public resistance to new road construction. Accordingly, more weight has been given to demand management measures, for instance in the form of road pricing or congestion charging, the effect of which is to reduce usage by those least able to pay and thus lessen the need for new capacity. A demand management approach to aviation would have attractions, and is indeed widely used in the form of setting fares flexibly to respond to demand, as in yield management. 5. Passengers on business trips are a minority at UK airports. Of all passengers, 12% are UK residents and 11% are foreign residents who are making journeys for business purposes. The three-quarters of airport users are travelling for leisure. Even at Heathrow, 70% of passengers are travelling for leisure rather than business. If it is the case that growth of business travel is important for growth of the economy generally, there is ample airport capacity for increased business travel by air, including at Heathrow, by displacing leisure travellers. Business travellers would generally be prepared to pay a price premium for a convenient airport. Ticket pricing based on yield management pricing allows this to happen naturally. 6. A market in landing and take-off slots, as is being developed, would facilitate preferential allocation to flights catering substantially for business travellers. BA recently acquired the BMI business, which gives it an additional 42 slots at Heathrow, to be switched to more profitable long-haul flights. Point-to-point flights for leisure purposes are shifted to airports with spare capacity, including regional airports beyond southeast England. 7. To illustrate the argument, consider scheduled flights to and from UK airports to Nice, France, a destination for both leisure and business travellers. Of the 1.5m passengers in 2011, those departing from the main originating airports are as follows: Heathrow, 536k; Gatwick, 324k; Luton, 146k; and Stansted, 91k. 12 other airports supplied a total of 430k passengers. It is likely that a large proportion of the 35% of passengers who flew from Heathrow were UK residents travelling point-to-point, and who therefore could therefore have used an alternative airport, and who indeed would have done so had a significant price differential existed.

Heathrow hub 8. BA urges the expansion of Heathrow, its main base. Of passengers using UK airports to make connections between flights, the large majority use the Heathrow hub (86% of international connections in 2010, 65% of domestic). BA would doubtless prefer to continue to operate short-haul flights, such as those to Nice (currently 13 BA outward flights a day), from Heathrow, both for operational efficiencies and to take advantage of transfer passengers coming from origins beyond London. Nevertheless, from the UK passenger’s point of view, there are generally acceptable alternatives to Heathrow for short haul point-to-point flights, and also alternative hubs for transfer to long-haul flights—at Paris, Frankfurt and Madrid, for instance. It is often significantly cheaper to fly from London to a long-haul destination via a European hub than fly direct, allowing the leisure traveller to trade off the extra travel time and inconvenience against cost-saving. Closer commercial relations between the airlines, for instance BA’s merger with Iberia, point to the possibility of making more use of European hubs. Pricing based on yield management allows use of European hubs with spare capacity to happen naturally. 9. The increased utilisation of airport capacity at the Heathrow hub for business travellers would allow the development of connectivity to new destinations in developing economies. This would be fostered by the use of larger aircraft such as the Airbus 380 (terminal capacity being easier to increase than runway capacity). However, higher fares on long-haul flights, a consequence of increased demand from business travellers, may inhibit the growth of tourism, both inward and outward, to and from more distant destinations, Asia in particular. 10. Inward tourism, currently 30m visitors a year, has doubled over the past 25 years, although spending at constant prices has remained surprisingly unchanged at about £10bn pa. Of the 30m, 7m are business travellers, 12m are on holiday, 9m are visiting family and friends, and there are 2m other. London, the most visited city in the world, has over 15m overseas visitors a year, including 7.6m on holiday, together with some 5m visitors from within the UK. 11. The Government’s 2011 Tourism Policy seeks to increase inward arrivals by 4m over the next 4 years. In a speech on 14 August, the then Secretary of State, Jeremy Hunt, went further, inviting the tourism industry to commit with the government to increasing the number of overseas visitors to the UK to 40 million by 2020. Generally, first-time visitors will want to visit the main sites of London, the capacity of which may be reaching their practical limit. There is substantial congestion in the summer season at heritage locations such as the Tower of London, and at some stations that need to be part closed, such as Covent Garden. There would cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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therefore be a good case for seeking growth from European repeat visitors who could use regional airports to travel beyond London. 12. Displacement of leisure travellers from the Heathrow hub may, depending on growth of this market segment, lead to capacity constraints at other airports. However, this seems unlikely to be a pressing problem given that the DfT’s most recent aviation forecasts project an increase in passenger numbers at UK airports of 60% by 2030 even with no new runways. If slots are tradable, fares might rise somewhat, which would in turn act to constrain the growth of demand, particular at time of peak usage. However, given the low prices currently available on the low cost carriers, public acceptability should be manageable. 13. While expansion of airport capacity at Heathrow would allow carriers based there to increase the numbers of passengers they serve, the consequence for proﬁtability is less obvious. In general, a capacity constraint in any industry allows incumbents with property rights to achieve higher returns than would occur if new entrants could take advantage of additional capacity to compete.

Demand for air travel 14. We have suggested that allowing the market to operate could substantially accommodate the likely growth of demand for air travel in the medium term, utilising existing airport capacity. There may, nevertheless, be a commercial case for building new runway capacity for the longer term, depending on how demand develops. 15. Air travel has grown hugely since the 1970s. Passengers using UK airports increased from 45m in 1976 to reach a peak of 240m in 2007, since when numbers have fallen back, to 220m a year in 2011 (see Figure). The question is to what extent this break in the long-term growth trend is a consequence of the economic recession, and to what extent it may reﬂect an approaching saturation of demand for air travel. A further question is the impact of higher fares on the growth of demand. 16.

17. Daily travel per capita in Britain and other developed economies has stabilised. In Britain, the average annual distance travelled (by all modes except international aviation) has settled at about 7000 miles per person per year since the mid-1990s.1 This has been interpreted as reflecting saturation of demand for daily travel.2 It is to be expected that air travel by UK residents will likewise at some point cease to grow. 18. Air travel growth can occur when existing passengers fly more often and/or when new passengers travel for the first time. It is usually assumed that in developed economies growth will predominately come from existing passengers, whereas in developing economies growth arises from new passengers, as the result of growing incomes and greater accessibility. For this reason the limited research concerning market maturity of UK air travel has focused on considering the amount of travel undertaken by current regular flyers in the future.3 19. An important consideration is that the time people have available limits the amount of travel. For daily travel, it is all the tasks to be done within the 24-hour day, which limits travel time to an hour a day on average. For flying, it is time that can be spent away from home or the office, and the time available for vacations. An ageing population may mean more leisure time for the retired, but the worsening prospects for pension income cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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may inhibit the growth of leisure travel. The impact of time constraints on the scope for people making more trips is researchable through both qualitative and quantitative studies. 20. Little attention has been given to people who are presently not flying, or flying infrequently, and whether they will fly more regularly in time to come. In 2010, 56 million UK residents travelled abroad by air, amounting on average to just under one return journey per person per year. However, surveys show that half the population do not fly in any one year—the “infrequent flyers”. Frequency of air travel increases from lower to higher socio-economic status group, is higher with younger people and rises with income. Nevertheless, around a quarter those in the top social group or in the highest income quintile took no flights in the previous year. The prospects for the growth of demand for air travel depend importantly on whether these “infrequent flyers” are likely to change their habit in the future. 21. The group of infrequent flyers is heterogeneous. Some people have never flown; some fly rarely; others regularly take annual holidays abroad but may have missed a year for a particular reason such as illness; and some may make a nil return in a survey because the interval between annual holiday trips is greater than 12 months. Some current infrequent flyers may have flown frequently in an earlier phase of life. Surveys of passengers using UK airports show that over the past ten years, less than one% of passengers are adults flying for the first time. This indicates that much of the UK resident growth in passenger traffic in recent years has come from existing passengers travelling more often. The implication is that of the infrequent flyers, those who have never flown may be unlikely to change their habits. 22. The future behaviour of the infrequent flyers is important for understanding future growth patterns and the degree of demand maturity that must be a central consideration in planning future airport capacity. This aspect is disregarded in conventional econometric analysis used to inform growth projections, it being implicitly assumed that attitudes and behaviour do not change except where driven by model parameters such as income. The likely future behaviour of the infrequent flyers is researchable, however, and needs to be investigated. 23. When thinking about future demand for travel, it is helpful to distinguish between per capita behaviour and population effects. It would be reasonable to allow straightforwardly for UK population growth when projecting future demand for air travel. There is also the growth of the middle classes of the developing economies who may wish to travel to the UK. Here the issue may be the capacity to cater for mass tourism at the major London locations, a topic worth investigating. 24. These considerations are relevant to the state of maturity of the UK market for air travel. The DfT’s Aviation Forecasts 2011 include a discussion of market maturity, incorporating a sensitivity in which faster maturity reduces demand in 2030 by 35m passengers pa compared to the central case, equivalent to about 10% of projected demand. The DfT recognises that maturity is hard to infer from historic data and that any conclusions that can be drawn from recent changes in the air travel market as to the existence of market maturity are subject to very high levels of uncertainty.

Low demand growth scenario 25. Given the importance of market maturity for future demand, it would be worth considering a scenario approach, as an alternative the standard forecasting with a central projection plus high and low variants. Scenarios have long been used by energy sector businesses to help address the implications of the impact of exogenous uncertainties.4 26. A low aviation demand scenario might involve earlier maturity of the various market segments considered in the DfT forecasts, informed by the findings of research on the behaviour and expectations of both regular and infrequent flyers, as discussed above. 27. Such a scenario may be important for the robustness of the business case for any new runway capacity. In this context, it is not the DfT’s forecasts that matter, but rather those made by the likely investors and their advisors, given that airports are for the private sector to develop. It is worth recalling that the private sector consortium members that built the Channel Tunnel Rail Link (now known as HS1) lost their investment when passenger numbers proved to be far lower than forecast, due to the competitive response of the low cost airlines and the ferries. Consideration would need to be given to the likely competitive response by airports in the South East under separate ownership to the opening of an additional runway at Heathrow. 28. The possibility of low demand plus a competitive response suggests the need for a significant tranche of equity finance. The CAA as regulator would need to permit charges that allow this equity to be suitably rewarded. 29. The government would need to take a view of the planning aspects of any new runway capacity, a difficult matter given the range of conflicting interests. In this context it is worth recalling the planning inquiry held in 1988–89 that led to the granting of planning consent for the controversial Hinkley Point C nuclear power station, which has not yet been built because of lack of financial viability.

Conclusions 30. New airport capacity to meet demand growth would be funded by the private sector. Because of the major planning implications of new runway capacity in the South East, government endorsement would be cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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essential. However, it would be difficult for the government to come to a view on location, given the range of conflicting interests. 31. Moreover, the uncertainty of future demand growth may make it difficult for a robust investment case to be made for new capacity in advance of clearer evidence of the state of market maturity. There is scope for market research to yield insight into expectations of existing and potential air travellers. 32. It may therefore be sensible to defer decisions until the future development of demand is clearer. In the meantime, efforts should be made to optimise the efficiency of utilisation of existing capacity, not least by allowing the market to give priority to business travellers willing to pay premium prices for the convenience of using Heathrow. 33. While this approach might be criticised as a policy of procrastination, it would make sense for the government to avoid commitment to a location for any new runway capacity until it is clear that there are investors willing to invest. 8 October 2012

References 1. National Travel Survey data. 2. Metz, D. (2010) Saturation of demand for daily travel, Transport Reviews, 30(5), 659–674. 3. DfT UK Aviation Forecasts 2011, Annex B 4. See for example www.shell.com/home/content/future_energy/scenarios/

Written evidence from Belfast City Airport Watch (AS 14) 1. Executive Summary 1.1 In this submission, we respond to two of the questions posed by the Committee in its terms of reference for the above inquiry, namely: 1.1.1 Does the Government’s current strategy make the best use of existing capacity at airports outside the south east? How could this be improved? 1.1.2 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? 1.2 We have focused our comments on the Department for Transport’s (DfT’s) Draft Aviation Policy Framework. We are extremely disappointed with this document. It is quite wrong that the Government should propose that the only real mechanism for the regulation of the noise pollution caused by non-designated airports in the UK—which form the vast majority of the UK’s airports—should be better engagement between airports and local communities. 1.3 It is inconceivable that the Government would permit the sole mechanism for the regulation of air or water pollution, or pollution from waste, to be left to a laissez faire system of “better engagement” between the polluting company or organisation in question and the local community. These forms of pollution are all subject to strict controls which are monitored and policed closely by the statutory environmental agencies in each of the UK territories. 1.4 Moreover nearly all other forms of noise pollution are subject to stricter controls through the statutory powers exercised by local authorities. 1.5 We believe that the proposals set out in the Draft Aviation Policy Framework fall far short of what is required to ensure that all airports in the UK minimise the noise pollution which they produce. The adverse impacts of aircraft noise on health, education and quality of life are well established. The DfT needs to take decisive action to produce the better balance which it claims it seeks between the commercial interests of the aviation sector and its adverse impacts on local communities. 1.6 In particular, we would like to see the following measures: 1.6.1 robust and ongoing mapping, monitoring and regulation of noise pollution caused by the all the UK’s commercial airports—carried out by the DfT (and devolved administrations, where applicable), or by the Civil Aviation Authority (CAA), rather than by the airports themselves; 1.6.2 both the monitoring and the noise regulations must properly reflect the true impact of aircraft noise on health, education and quality of life, as evidenced in the substantive relevant research, and must reflect best practice as set out by the World Health Organisation in its relevant guidance; cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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1.6.3 the Government should commit itself to a specific reduction in the number of people in the UK significantly affected by aircraft noise over the next 10 years—we suggest a 10% reduction; 1.6.4 airports should be required to reduce the level and frequency of aircraft noise within the areas which are significantly affected by noise—priority should be attached to achieving this objective at the airports affecting the largest populations, and at those which affect large populations, and also duplicate the services of an airport nearby; 1.6.5 no further growth should be permitted at airports which affect large populations in terms of noise, and which duplicate the services of an airport nearby, unless the airport operator in question can prove that any planned growth will not result in an increase in noise pollution; 1.6.6 all airports whose noise pollution affects significant populations (and/or any schools) should be required to meet specified targets for reducing those levels of noise over a five year period—there should be serious penalties for airport operators which do not meet these targets; 1.6.7 the Government should make it clear in its Aviation Policy Framework that it is abandoning its outdated guidance stating that the 57 dB LAeq,16h contour marks the approximate onset of significant annoyance, and should introduce more sophisticated guidance which better reflects the considerable body of recent international research in this regard, and which properly reflects international research on health and education impacts of aircraft noise; 1.6.8 the Government should either refine the current system of air passenger duty so that a higher rate is levied on those flights having the most serious adverse noise impact, or it should use its existing powers to enforce airports to use differential landing fees to reflect the noise impacts of flights; 1.6.9 at airports where aircraft noise affects a significant number of people (and/or affects schools significantly), any noise envelope should only be used as a device to ensure that the level and frequency of aircraft noise pollution does not get worse and/or is reduced over time— it should not be used as a device to permit any increase in the amount or frequency of noise at such airports; 1.6.10 the Government should give serious consideration to the results of the EU-sponsored MIME study, which developed a model of tradeable noise permits for airports, with a view to its possible introduction in the UK; 1.6.11 the Government should require airports to provide comprehensive and robust effective insulation (not just double or triple glazing) to all homes seriously impacted by aircraft noise, and not only those at 63 LAeq 16h; and 1.6.12 the CAA should be given an enhanced noise regulation role—but it must have a consistent, proactive and tough regulatory and enforcement role, similar to the Environment Agency.

2. About Belfast City Airport Watch 2.1 Belfast City Airport Watch (BCAW) is an umbrella organisation which represents 21 afﬁliated organisations, 20 of which are residents associations or community groups in areas affected by aircraft noise linked to George Best Belfast City Airport (see Appendix 1). BCAW also has 550 individual associate members.

3. Introduction 3.1 We warmly welcome the decision by the Transport Select Committee to hold its very timely inquiry into aviation strategy and, in particular, the fact that the terms of reference for the inquiry speciﬁcally include an investigation into the adequacy or otherwise of the Government’s proposals with regard to the reduction of the impact of aircraft noise on residents. 3.2 We are extremely disappointed with the Draft Aviation Policy Framework. In her foreword to the document, the former Secretary for State says: A better balance than in the past needs to be struck between the beneﬁts aviation undoubtedly brings and its impacts, both at a global and at a local level. 3.3 We would concur totally with the statement. However, she then goes on to say: This will require much better engagement between airports and local communities, with greater transparency to facilitate informed debate and help to build mutual trust. This is one of the key themes running through our draft framework and the Government is encouraged that some airports are already working to improve local engagement. Nevertheless more needs to be done. 3.4 “Better engagement” between airports and local communities is, indeed, the only real mechanism which this document is proposing should be used for the regulation of the horrendous noise pollution caused by the vast majority of airports in the UK which are not designated “national” airports. This is despite the fact that many of those airports already create noise pollution which affects far larger numbers of people than is the cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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case at two of the three nationally designated airports which are subject to Government noise controls. Many non-designated regional airports also have plans for expansion which are likely to increase the noise pollution they produce. 3.5 It is inconceivable that the Government would permit the sole mechanism for the regulation of air or water pollution, or pollution from waste, to be left to a laissez faire system of “better engagement” between the polluting company or organisation in question and the local community. These forms of pollution are all subject to strict controls which are monitored and policed closely by the statutory environmental agencies in each of the UK territories. 3.6 Moreover nearly all other forms of noise pollution are subject to stricter controls through the statutory powers exercised by local authorities. 3.7 Why then is the DfT proposing that this laissez faire approach, which has patently failed to minimise noise pollution associated with airports to date, should continue? 3.8 We believe that the proposals set out in the Draft Aviation Policy Framework fall far short of what is required to ensure that all airports in the UK minimise the noise pollution which they produce. The adverse impacts of aircraft noise on health, education and quality of life are well established. The DfT needs to take decisive action to produce the better balance which it claims it seeks between the commercial interests of the aviation sector and its adverse impacts on local communities. 3.9 Below and overleaf, we provide our responses to the Committee’s questions of particular relevance to the local communities which we represent ie those living under or close to the ﬂight paths from George Best Belfast City Airport, which is one of the non-designated regional airports where the current inadequate system of noise regulation and control has led to far more people being affected by what the Government deems to be a serious level of noise pollution than is the case at two of the designated national airports, Stansted and Gatwick.

4. Does the Government’s current strategy make the best use of existing capacity at airports outside the south east? How could this be improved? 4.1 The Government’s current strategy—as articulated in the Draft Aviation Policy Framework—undoubtedly fails to make the best use of existing capacity at airports outside the south east. In determining how to make the best use of existing capacity, the Government must take into account the noise impact of each airport (measured in terms of the severity of the noise impact on affected individuals and schools, and the population numbers and numbers of schools affected). We are especially concerned where there are instances of duplication of services at airports close to each other, where one of those airports is causing a serious noise impact. 4.2 The Department for Transport’s Draft Aviation Policy Framework should identify those regional airports which are affecting a large population (eg greater than 10,000) at 54>LAeq 16h and/or any schools at 57>LAeq 16h and/or which experience noise events at 35> LAeq during class time, and which are also duplicating services provided at another airport nearby (ie within one hour’s ground travel time or less). The Framework should clearly state that no further growth in trafﬁc is permitted at those airports unless the airport operator in question is able to prove that any planned growth will not result in an increase in noise pollution. 4.3 A particular instance of this issue is the current duplication of air services at George Best Belfast City Airport and at Belfast International Airport, which sit 16 miles apart and within 30 minutes’ drive of each other. At present, the former, which has a serious adverse noise impact on tens of thousands of local residents, is being permitted to grow and to become an international airport to the detriment of Belfast International Airport, which is in a greenﬁeld site, affecting a relatively small number of residents, and with plenty of existing spare capacity. 4.4 Just a few months ago, Aer Lingus announced that it was transferring its Northern Ireland operation from Belfast International Airport to Belfast City Airport. This move had two important negative strategic impacts on the competitiveness of Belfast International Airport and on the wider Northern Ireland economy: 4.4.1 It reduced the prospect that Northern Ireland will be able to host additional long haul routes; as Aer Lingus operates long haul routes from Dublin Airport, it could have commenced long haul routes from Belfast International Airport—an option not open to it at Belfast City Airport for both runway capacity and noise impact reasons. At present, Belfast International Airport has only one long haul route, compared to its competitor, Dublin Airport, which has 12 long haul routes. 4.4.2 It removed any direct link to Heathrow from Belfast International Airport which, given its geographical position, is located in a much more convenient position for businesses and individuals in much of Northern Ireland than Belfast City Airport. 4.5 The move by Aer Lingus would not have been possible if a strategy was in place which earmarked International Airport as the regional gateway airport for Northern Ireland at which the development of international air routes should be focused. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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5. 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? 5.1 As outlined previously, we believe that the proposals contained in the Government’s Draft Aviation Policy Framework are entirely inadequate with regard to reducing the impact of noise on local residents. We address below some of the main issues. For ease of reference, these are dealt with in the same order as in the Draft Aviation Policy Framework and its accompanying consultation questionnaire.

5.2 Designation of airports for noise management purposes 5.2.1 We agree that the Government should continue to designate the three largest London airports for noise management purposes. However, we believe that it is equally important to provide a robust and consistent noise management regime at all the UK’s commercial airports. Consultants’ reports commissioned by George Best Belfast City Airport show that, in 2010, 11,422 local residents suffered from aircraft noise at 57 LAeq 16h or over. By comparison, in 2010, a mere 1,400 people suffered from noise at the same level close to Stansted airport, and just 2,850 experienced this level of noise near Gatwick, according to ﬁgures from the DfT. 5.2.2 At many UK airports, there are a higher (and in some cases far higher) number of people affected at 57 LAeq 16h or over than at either Stansted or Gatwick. The relatively low numbers at Stansted and Gatwick may be, in part, a result of the Government’s noise management regime. However, they are not a reason for doing away with designation at those airports. Instead, all the UK’s commercial airports should be designated in this way so that there is the right balance between the commercial interests of the aviation sector, and the health and quality of life of local communities.

5.3 The Government’s overall objective on aviation noise 5.3.1 The wording of this objective, as stated in para. 4.22 of the Draft Aviation Policy Framework—”to limit and, where possible, reduce the number of people in the UK significantly affected by aircraft noise”— leaves open the possibility that the number could actually increase. At the very least, this objective should read: … to ensure there is no increase in the number of people in the UK significantly affected by aircraft noise. 5.3.2 However, we would like the Government to commit itself to a specific reduction in the number of people in the UK significantly affected by aircraft noise over the next 10 years. We would suggest the Government should aim for a 10% reduction. 5.3.3 At the same time, it is not sufficient to limit the Government’s approach to aviation noise to striving to ensure there is no increase in or to reduce the number of people significantly affected by aircraft noise. As the Aviation Environmental Federation (AEF) has pointed out, such a policy can act as an incentive for airports to greatly concentrate noise pollution within the narrowest possible corridor.1 This policy does nothing for those residents under a flight path and potentially increases the level of noise pollution which they suffer. The report cites the approach to noise management taken by the Australian Government which attempts to ensure that aircraft noise pollution emanating from any airport is spread more evenly over a number of communities, ensuring there are also periods of respite from noise. We commend this approach and believe that, in addition to ensuring there is an overall reduction in the number of people significantly affected by aircraft noise, airports should also be required to reduce the level and frequency of aircraft noise within the areas which are significantly affected. Priority should be attached to reducing the level and frequency of aircraft noise at the airports affecting the largest populations, and at those which affect large populations, and also duplicate the services of an airport nearby.

5.4 Mapping of noise exposure around airports 5.4.1 We believe it is imperative that the Government maps noise exposure at all commercial airports in the UK, and monitors noise exposure closely on an ongoing basis. However, it must also properly regulate noise exposure to ensure that it does not increase. Noise mapping should include: 5.4.2 noise contours, with maps and details of the affected populations, at the following noise levels: 50> LAeq 16h, 54> LAeq 16h, 57> LAeq 16h, 60> LAeq 16h, 63> LAeq 16h and 72> LAeq 16h—and which also includes measurements which allow for and properly reﬂect the greater annoyance, disruption and health risk experienced by residents in the evening, night-time and early morning, and measures which reﬂect noise pollution caused by particularly noisy individual aircraft events (using Lden, LAeq 8h and LAMax Fast measurements) [with appropriate adjustments to the 16h metric where airports, like George Best Belfast City Airport, are not fully operational for 16 hours] 5.4.3 details of all schools within the 54> LAeq 16h contours, and/or which experience noise events at 35> LAeq during class time [with appropriate adjustments to the 16 hour metric as above] 5.4.4 In Appendix 2, we outline some of the substantive body of evidence and guidance which exists which should inform the Government’s noise mapping and noise regulation. We are especially concerned about the evidence regarding the negative health and education impacts of aircraft noise which is currently being disregarded by the Government and by the Draft Aviation Policy Framework. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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5.5 The Government’s noise envelope proposal/tradeable noise permits 5.5.1 We are very concerned that the Draft Aviation Policy Framework proposes only that a noise envelope should be set at “any new national hub airport or any other airport development which is a nationally significant infrastructure project” (para. 4.41). As stated previously, the Government must monitor and regulate noise properly and effectively at all commercial airports in the UK, and not just airports deemed to be of national significance. It must also regulate noise robustly at existing airports—and not just with regard to new airports or new infrastructure at existing airports. 5.5.2 The noise envelope proposals, as set out, are too vague. The UK should be seeking to make use of its existing aviation capacity in the most efficient and noise-efficient way possible, without further expanding the number of people affected by noise at a significant level. 5.5.3 We believe the Government should give serious consideration to the results of the EU-sponsored MIME study which developed a model of tradeable noise permits for airports.2 If this was implemented by the UK, it would have the potential to act as a real incentive for airlines to take mitigation measures which would minimise or reduce the degree of noise exposure for residents. The permit scheme could also take into account the type of traffic generated by a particular route; for example, flights on “bucket and spade” routes to “sunshine” destinations outside the UK, which merely suck tourist revenue out of the local and national economy, could be subject to a higher “price” under this scheme. 5.5.4 We would strongly oppose the use of a noise envelope as a device to permit any increase in the amount, level or frequency of aircraft noise where a significant number of people are currently affected or will be affected at a level which is likely to have adverse health, education and/or quality of life impacts. The impact on schools must also be taken into account in this regard. 5.5.5 We would support the use of a noise envelope as a device to ensure that the level and frequency of noise pollution did not get worse and/or was reduced over time. 5.5.6 We believe that a noise envelope must include a mixture of both maximum noise levels and noise event thresholds, and restrictions on the number of flights and passengers (or, as with George Best Belfast City Airport) seats offered for sale. We believe it is totally unsatisfactory that airports are currently permitted to monitor and report on their own noise levels. However, while this system of self-monitoring pertains, it is essential to have in place tangible restrictions on the scale of airport operations which can be easily monitored and regulated externally. 5.5.7 It is also vital that any noise envelope contains additional restrictions on flight numbers, average noise levels and noise event thresholds for early morning, evening and night-time which properly reflect the additional negative impact on health and quality of life. 5.5.8 We believe that the following system of noise regulation should apply and should be implemented by the DfT (and by the Department for Regional Development in Northern Ireland): 5.5.9 The DfT’s Aviation Policy Framework should identify those regional airports which are duplicating services at another airport nearby, and which are affecting a significant population (eg greater than 10,000) at 54> LAeq 16h [or equivalent] and above and/or any schools at54> LAeq or more and/or which experience noise events at 35> LAeq during class time. The Framework should clearly state that no further growth in traffic is permitted at those airports unless the airport operator in question is able to prove that any planned growth will not result in an increase in noise pollution. 5.5.10 The DfT and, in Northern Ireland, the Department for Regional Development (DRD) should use their existing legal powers to require all airports which cause significant noise pollution (ie which are affecting a large population at 54> LAeq and above (eg greater than 10,000) and/or any schools at 54> LAeq or more, and/or which experience noise events at 35> during class time) to meet specified targets for reducing those levels of noise over a five year period. The precise requirements for each airport would depend on the strategic importance of that airport as measured by the indicators (routes, duplication of services, purpose of trip) as outlined previously. All airports which fail to meet these targets should be subject to significant fines, commensurate with the scale of their revenues. 5.5.11 Date collected from monitoring noise near all airports should be collated and published on an annual basis. The DfT and DRD should review this data after five years and set targets for all airports which meet the above criteria and/or which have failed to meet targets which were previously set. If an airport operator fails to meet these targets on more than one occasion, its licence should be revoked.

5.6 Respite from aircraft noise 5.6.1 We are very disappointed that the section on respite from aircraft noise in the Draft Aviation Policy Framework (paras. 4.52—4.55) refers solely to Heathrow. Most UK airports provide no such respite for residents and we would like the Government to include provision for respite within the far more robust system of noise regulation which we would like to see. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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5.7 The Government’s proposals on noise limits, monitoring and penalties 5.7.1 Paragraph 4.68 of the Draft Aviation Policy Framework states “Local communities need to have confidence that airport owners take noise impacts seriously.” That is not correct—what local communities need to have is the confidence that the Government takes noise impacts seriously. If the Government did take the impact of aircraft noise seriously, it would be designing and implementing a robust system of noise regulation which would actually address the problem properly. 5.7.2 Airports are commercial entities which exist to make a profit. It is unrealistic to expect airports to voluntarily implement an effective system of self-regulated noise management—and it is quite unfair to expect local communities to rely on the goodwill of their airport in order to have that effective regulation. As previously stated, it is the clear responsibility of the Government to regulate noise pollution effectively, just as it does with others forms of pollution, such as air and water pollution (and, indeed, other forms of noise pollution). 5.7.3 Moreover, paragraph 4.68 appears only to apply to the three designated airports as it refers to departure noise limits which do not apply, as far as we are aware, at most other airports and certainly not at George Best Belfast City Airport. 5.7.4 We would certainly welcome the introduction of a robust system of departure noise limits for all airports which have a serious noise impact which affects a significant number of people. However, the system should be completely transparent and should be implemented by the Government rather than the airports. 5.7.5 Similarly, the Government should carry out its own monitoring and reporting of noise in affected areas around commercial airports. However, this should be carried out at all airports—whether or not they appear to affect significant numbers of people, and whether or not they are nationally designated. This is because only a transparent and fully independent system of monitoring is reliable. It may well be the case that some airports do not have sufficiently accurate systems of noise monitoring and modelling, and under-reporting of the full extent of noise pollution may occur as a result. Airports and airlines should pay for the costs of the monitoring.

5.8 Differential landing fees/APD 5.8.1 We are aware that some airports, such as Luton and Stansted, already operate differential landing fees, designed to encourage airlines to use quieter aircraft. However, it is unlikely that an airport such as George Best Belfast City Airport would take such a step voluntarily, as it is in strong competition with both its neighbouring and longer-established Belfast International Airport and with Dublin Airport. Low landing fees are one means of attracting the airlines required for commercial survival. Doubtless, there are a number of UK airports which, due to being in close proximity with a neighbouring airport offering similar routes, compete on landing fees. 5.8.2 However, the current system of air passenger duty (APD) could be refined so that a higher rate is levied on early morning and night-time flights from airports which have a serious adverse noise impact on a significant number of people. In addition, flights from these airports which use quieter planes could be subject to a lower level of APD. 5.8.3 Alternatively, we note in para 4.76 of the Draft Aviation Policy Framework that the Government does have the power to require airports to use differential landing fees to reflect environmental impacts and we therefore believe that, if APD is not used as an instrument in this regard, the Government should use its power to require airports to employ differential landing fees. 5.8.4 Where differential landing fees or APD is use to control noise from night-time flights, the term “night- time” must include the early morning period during which it can be assumed that most people would still be asleep ie “night-time” should include 11pm to 7am, and 11pm to 9am at weekends. Evening flights which disrupt children’s sleep should also be subject to differential APD or a differential landing fee.

5.9 Airport compensation schemes 5.9.1 The consultation questionnaire accompanying the Draft Aviation Policy Framework asked whether respondents felt that airport compensation schemes were reasonable and proportionate. The more pertinent question is not what we think of the compensation schemes offered by those few airports which go beyond what they are required to do by Government, but what we think of the Government’s requirements with regard to compensation. Like many airports, George Best Belfast City Airport takes the position that it will only offer to pay for noise insulation to homes affected at 63 LAeq 16h or above, in line with the Government’s requirement on insulation. There is ample evidence, as outlined in Appendix 2, that people suffer tangible health, quality of life and, in the case of children, educational impacts at levels well below 63 LAeq 16h. 5.9.2 Insulation does not solve the problem of aircraft noise, because people still need to open their windows. However, it can help to mitigate the adverse impacts of noise, and it is ridiculous that houseowners and landlords are currently forced to foot the bill where insulation is required primarily because of aircraft noise. As with other forms of pollution, the “polluter should pay” principle should be followed—and required by Government. Where airports are required to fund insulation programmes, these should include a comprehensive package of noise insulation measures, and not just double or triple glazing. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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5.10 The integration of noise regulation into a broader regulatory framework 5.10.1 We would like to see the integration of noise regulation into a broader regulatory framework which tackles the local environmental impacts from airports. We would also like to see robust regulation of localised air pollution from aircraft, and of fuel dumping.

5.11 The role of Airport Consultative Committees 5.11.1 As stated previously, we are very disappointed at the emphasis which the Draft Aviation Policy Framework puts on the role of Airport Consultative Committees in regulating noise at airports. It is quite inappropriate for airports to effectively regulate themselves via Airport Consultative Committees which are run by airports. Airports are commercial entities and the noise pollution they cause needs to be regulated externally in the same way that any other form of pollution is regulated. 5.11.2 We would like all commercial airports to have consultative committees, but it is vital that noise pollution at all commercial airports is effectively monitored and regulated by the Government. Aircraft noise pollution must be subject to a robust and consistent system of external monitoring, reporting and regulation, operated by the Government and paid for by the industry.

5.12 The role of the Civil Aviation Authority 5.12.1 The Draft Aviation Policy Framework (paras 5.19—5.24) sets out a proposal for the Civil Aviation Authority to have a role in providing independent oversight of airports’ noise management. However, while this proposal would certainly be an improvement on the current situation, it does not go far enough. What is required is a body which acts like the Environment Agency, and which has tough powers to monitor and enforce a consistent system of noise regulation properly. Given the body of expertise within the CAA, it may well make more sense for the CAA to take on this role. It should be responsible for noise monitoring and reporting, as well as enforcement. This cost should be borne by airports and airlines—and it may well make sense for these costs to be met through a system of differential aircraft noise levies and/or tailored APC as described previously.

5.13 Noise action plans 5.13.1 The Draft Aviation Policy Framework refers to airport noise action plans and seems to regard these as part of the solution. However, airport noise action plans are no more than token documents. For example, the current Noise Action Plan for George Best Belfast City Airport merely restates the existing steps taken by the airport at the time of writing or already planned, and the existing regulations to which it is subject. It further stated that it did not expect the number of people affected by aircraft noise to reduce over the period covered by the Plan (2008—2013).3 In fact, that number increased signiﬁcantly to 2010. 5.13.2 Noise Action Plans do have the potential to form part of a robust system of noise regulation—but not unless relevant airports are required to have targets for reducing noise, and to commit themselves to the necessary steps needed to meet those targets.

6. Proposed recommendations 6.1 We would like the Committee to make the following recommendations: 6.1.1 That the Government implement robust and ongoing mapping, monitoring and regulation of noise pollution caused by the all the UK’s commercial airports—carried out by the Department for Transport (DfT) (and devolved administrations, where applicable), or by the Civil Aviation Authority (CAA), rather than by the airports themselves. 6.1.2 That both the monitoring and the noise regulations must properly reflect the true impact of aircraft noise on health, education and quality of life, as evidenced in the substantive relevant research, and must reflect best practice as set out by the World Health Organisation in its relevant guidance. 6.1.3 That the Government should commit itself to a specific reduction in the number of people in the UK significantly affected by aircraft noise over the next 10 years—we suggest a 10% reduction. 6.1.4 That airports should be required to reduce the level and frequency of aircraft noise within the areas which are significantly affected by noise—priority should be attached to achieving this objective at the airports affecting the largest populations, and at those which affect large populations, and also duplicate the services of an airport nearby. 6.1.5 That no further growth should be permitted at airports which affect large populations in terms of noise, and which duplicate the services of an airport nearby, unless the airport operator in question can prove that any planned growth will not result in an increase in noise pollution. 6.1.6 That all airports whose noise pollution affects significant populations (and/or any schools) should be required to meet specified targets for reducing those levels of noise over a cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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five year period—there should be serious penalties for airport operators which do not meet these targets. 6.1.7 That the Government should make it clear in its Aviation Policy Framework that it is abandoning its outdated guidance stating that the 57 dB LAeq,16h contour marks the approximate onset of significant annoyance, and should introduce more sophisticated guidance which better reflects the considerable body of recent international research in this regard, and which properly reflects international research on health and education impacts of aircraft noise. 6.1.8 That the Government should either refine the current system of air passenger duty so that a higher rate is levied on those flights having the most serious adverse noise impact, or it should use its existing powers to enforce airports to use differential landing fees to reflect the noise impacts of flights . 6.1.9 That, at airports where aircraft noise affects a significant number of people (and/or affects schools significantly), any noise envelope should only be used as a device to ensure that the level and frequency of aircraft noise pollution does not get worse and/or is reduced over time—it should not be used as a device to permit any increase in the amount or frequency of noise at such airports. 6.1.10 That the Government should give serious consideration to the results of the EU-sponsored MIME study, which developed a model of tradeable noise permits for airports, with a view to its possible introduction in the UK. 6.1.11 That the Government should require airports to provide comprehensive and robust effective insulation (not just double or triple glazing) to all homes seriously impacted by aircraft noise, and not only those at 63 LAeq 16h. 6.1.12 That the Government should introduce an enhanced noise regulation role for the CAA— but it must have a consistent, proactive and tough regulatory and enforcement role, similar to the Environment Agency. 6.1.13 That the Government should introduce a requirement that all commercial airports affecting a significant population through noise pollution should provide periods of respite from aircraft noise for residents, similar to those which exist at Heathrow and at London City Airport.

APPENDIX 1

ORGANISATIONS AFFILIATED TO BCAW

1. The Bridge Community Association 2. Carew II Family and Training Centre 3. Connswater Community Centre/Connswater Community Group 4. Cultra Residents’ Association 5. Dee Street Community Centre/The Klub 6. Dee Street Computer Group 7. Dee Street Mums and Tots Group 8. East Belfast Healthy Living Project 9. East Belfast Toddler Group 10. GMB Trade Union Branch 252 11. Hampton Park Residents’ Association 12. Holywood Airport Action Group 13. Lagan Valley Group Residents’ Association 14. Lower Woodstock Community Association 15. Marlborough Park Residents’ Association 16. Newtownards Road Women’s Group Ltd. 17. Old Stranmillis Residents’ Association 18. Park Road and District Residents’ Association 19. Ravenlink Residents’ Group 20. Ulidia Residents’ Group 21. Wise Men of the East Network (network of nine afﬁliated east Belfast mens’ groups)

APPENDIX 2

RELEVANT RESEARCH AND GUIDANCE 1) The World Health Organisation (WHO) recommends that community noise (which includes aircraft noise) should remain below 50 LAeq, averaged over 16 hours (50 LAeq 16h) in outdoor living areas, if moderate annoyance is to be avoided. It further recommends that noise should not exceed 55 LAeq 16h if serious annoyance is to be avoided.4 cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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2) WHO makes further specific recommendations with regard to the following: a) The level of community noise in indoor environments should be less than 35 LAeq 16h to preserve speech intelligibility and prevent moderate annoyance b) To avoid sleep disturbance at night: c) The level of community noise in indoor bedrooms where windows are closed should be less than 30 LAeq 8h and 45 LAmax Fast5 (The latter is a more effective measure with regard to individual noise events) d) The level of community noise in bedrooms where a window is open should be less than 45 LAeq 8h and 60 LAmax Fast e) The level of community noise in school classrooms and pre-school indoor environments should be less than 35 LAeq during class to preserve speech intelligibility and message communication, and to prevent disturbance of “information extraction” f) The level of community noise in school playgrounds should be less than 55 LAeq during playtime to prevent annoyance 3) WHO sets out the purpose of these guidelines as follows: a) For each environment and situation, the guideline values take into consideration the identified health effects and are set, based on the lowest levels of noise that affect health (critical health effect). Guideline values typically correspond to the lowest effect level for general populations, such as those for indoor speech intelligibility. By contrast, guideline values for annoyance have been set at 50 or 55 dBA, representing daytime levels below which a majority of the adult population will be protected from becoming moderately or seriously annoyed, respectively.6 b) In other words, the WHO guidance recommendations are designed to ensure that adults and children are protected against critical adverse health impacts, the disruption of children’s learning and of social interaction, and moderate or serious levels of annoyance. c) In 2009, WHO issued guidance related specifically to night-time noise for member states of the European Union which stated: … an Lnight,outside of 40 dB should be the target of the night noise guideline (NNG) to protect the public, including the most vulnerable groups such as children, the chronically ill and the elderly. Lnight,outside value of 55 dB is recommended as an interim target for the countries where the NNG cannot be achieved in the short term for various reasons,and where policymakers choose to adopt a stepwise approach.7 d) Although WHO did not specify the hours within which this guidance should apply, it stated that a period of 8 hours was required for “minimal protection” (protecting 50% of the population) and that, on Sundays, people tend to sleep for an hour longer, probably to catch up on sleep missed during the week.8 This implies, therefore, that the period of protection on Saturday night/Sunday morning should be 9 hours. e) The Government’s guideline that “significant community annoyance” is likely to be caused at 57 LAeq for daytime (16h) is clearly out of date. As the Government is well aware, it commissioned an expert report into the impact of aircraft noise which was published in 2007, and is known as the ANASE report.9 This found evidence that intolerance of aircraft noise has increased and that the proportion of people who are very annoyed by aircraft noise generally starts rising once a level of 43 LAeq 16h is reached.10 f) The study further found that a level of just above 50 LAeq 16h can trigger a significant level of community annoyance (ie the average level of annoyance within the community at this point is “moderate”) and that, from 56 LAeq 16h, most communities will register an average level of annoyance which is either “moderate” or higher.11 g) However, the study also found that the LAeq measurement was insufficient as a measurement of likely annoyance levels, and that a measure needed to be devised which more accurately captured the actual impact of aircraft noise. h) In addition, an international team of researchers—the HYENA study—investigated attitudes to aircraft noise in six European countries. This found that annoyance ratings were higher than predicted by the European Union standard curve used to predict the number of people highly annoyed by aircraft noise. It concluded that attitudes towards aircraft noise had changed over the years, and that the EU standard curve for aircraft noise should be modified.12 i) For these reasons, we believe that the Government’s guidance with regard to the 57 LAeq 16h noise level is outdated and fails to reflect the actual community impact of aircraft noise. j) Moreover, there is plentiful research which shows that, regardless of annoyance levels, aircraft noise has serious impacts on health and education which must be fully taken into account in determining the noise impact which an airport is permitted to make. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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4) Health impacts of aircraft noise a) There is an extensive body of international and local research evidence which demonstrates the considerable adverse health impacts of aircraft noise. It must be borne in mind, when considering this evidence, that a considerable proportion of the population which falls within the areas worst affected by aircraft noise relating to George Best Belfast City Airport also suffers from considerable economic and social disadvantage which is known to increase the likelihood of ill health. Thus, any adverse health impacts are likely to further exacerbate the already relative high level of ill health experienced by those in this category. We understand this is also true with regard to the communities worst affected by noise at a number of other UK airports. b) These include: i) lack of sleep— (1) in a survey carried out by Belfast City Airport Watch in 2009, more than three-quarters (78%) said that aircraft noise affected their sleep, with almost 1 in 5 (19%) stating that they weren’t getting enough sleep13 (2) of those respondents with children, nearly half (46%) said their children weren’t getting enough sleep because of aircraft noise. ii) adverse effect on blood pressure—in 2003–5, a major EU-funded international study investigated the impact of aircraft noise on blood pressure. The Hypertension and Exposure to Noise near Airports (HYENA) study examined the impact of aircraft noise on 5,000 individuals, aged 45–70 years, living close to six major European airports. Its findings, reported in 2008, concluded that night-time aircraft noise, including that occurring in the late evening or early morning, caused a significant increase in blood pressure among participants.14 iii) heart problems and abnormally high blood pressure—in 2007, a German study found night- time aircraft noise increased the prevalence of prescriptions for antihypertensive and cardiovascular drugs, irrespective of social class15 iv) an increase in the level of anti-anxiety and blood pressure medication prescribed—the HYENA study found an association between the use of anti-anxiety medication and aircraft noise, both day-time and night-time) in all six countries in which its study was carried out, an association between the use of medication used to treat high blood pressure and night-time aircraft noise in both the UK and the Netherlands, and an association with regard to the latter medication and day-time aircraft noise in the UK16 v) an increase in stress and anxiety—the BCAW residents’ survey found that: (1) three-quarters of respondents (75%) said they often had to stop talking when a plane flew over because they couldn’t be heard (2) 71% said aircraft noise made their gardens less pleasant to be in (3) more than two-thirds (68%) said they often couldn’t hear the TV and/or radio when a plane flew over (4) 66% said aircraft noise made their homes less pleasant places to be (5) nearly half (49%) said aircraft noise made their lives more stressful c) In addition, the WHO working group which drew up its guidance on night time noise concluded that: there is sufficient evidence that night noise is related to self-reported sleep disturbance, use of pharmaceuticals, self-reported health problems and insomnia-like symptoms. These effects can lead to a considerable burden of disease in the population.17 d) It carried out a comprehensive review of the relevant research and produced a table which summarises the health impacts of night-time noise:18 The working group found that adverse health effects are observed at levels of 40 LAeq night,outside and above. At above 55 LAeq night,outside, WHO finds that “..the situation is considered increasingly dangerous for public health”, there are frequent adverse health effects, a sizeable proportion of the population is highly annoyed and sleep- disturbed, and there is evidence that the risk of cardiovascular disease increases.

5) Educational impacts of aircraft noise a) There is a considerable body of research which demonstrates the considerable adverse educational impacts of aircraft noise. The relevant studies include the following: i) a survey of schools, under or close to the Belfast City Airport ﬂight path over the city, undertaken by Belfast City Airport Watch in 2008, which found: (1) 12 schools said pupils’ concentration was adversely affected by aircraft noise (2) 9 schools said aircraft noise disrupted teaching and/or classes (3) 11 said aircraft noise made outdoor activities in school grounds less pleasant (4) 8 said aircraft noise made their school a less pleasant place to work in19 cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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ii) a comprehensive review of research on the impact of aircraft noise on children’s learning, carried out by the Civil Aviation Authority in 2010, concluded: ..there is evidence to suggest that chronic aircraft noise has a deleterious effect on memory, sustained attention, reading comprehension and reading ability. Early studies highlighted that aircraft noise was also implicated in children from noisy areas having a higher degree of helplessness ie were more likely to give up on difficult tasks than those children in quieter areas…. Reports often indicated that children exposed to chronic aircraft noise showed a higher degree of annoyance than those children from quieter areas. Evidence has been presented to suggest that children do not habituate to aircraft noise over time, and that an increase in noise can be correlated with a delay in reading comprehension compared to those children not exposed to high levels of aircraft noise.20 iii) a major international study, carried out in 2002, found that exposure to aircraft noise is related to impaired performance in reading comprehension in primary schoolchildren. The RANCH Project— which examined the academic performance of 2,010 children aged 9–10 years in three countries, including the UK—found that exposure to aircraft noise was correlated negatively with children’s reading comprehension and recognition memory, even when other factors were taken into account. No similar effect was found with regard to road traffic noise. The results of this research were published in 2005 and 2006.21 iv) a smaller follow-up study, carried out six years later in the UK with a sample of 461 of the original participants, now aged 15–16 years, found that, although no significant long-term effect of aircraft noise exposure at primary school or secondary school on reading comprehension was found, there was a trend for both types of exposure to be associated with poorer reading comprehension. The authors concluded that the findings indicated that exposure to aircraft noise at school may have long- term implications for children’s cognitive development.22 b) While we accept that the conclusions of the smaller, longitudinal study are more tentative as regards the long-term impact of aircraft noise on reading comprehension, the adverse effect on both the reading comprehension and recognition memory among the 9–10 years olds examined in the original RANCH study was very marked. The findings of the original study have particular relevance for primary schools in areas of Northern Ireland affected by noise, as the children in question will be at a disadvantage compared to their peers in schools unaffected by noise if they sit the unofficial transfer tests still used by most grammar schools in Northern Ireland. (These tests are normally undertaken at age 10.). 12 October 2012

References 1. AEF (2010) Approach Noise at Heathrow: Concentrating the Problem (London: AEF for HACAN) 2. Gühnemann, A., Nellthorp, J. and Connors, R. “Designing a market model to analyse tradable noise permit schemes for airports”. Institute for Transport Studies, University of Leeds. 2010 conference paper. Available at: http://intranet.imet.gr/Portals/0/UsefulDocuments/documents/02815.pdf 3. George Best Belfast City Airport Environmental Noise Directive Noise Action Plan September 2009. Available at: http://www.doeni.gov.uk/george_best_belfast_city_airport_action_plan_-_ﬁnal_agreed_plan_for_ adoption-2.pdf 4. The speciﬁc World Health Organisation guidance on noise levels is available at: http://www.who.int/docstore/ peh/noise/Comnoise-4.pdf (section 4.3.1). The full report WHO Guidelines for Community Noise, 1999, is available at: http://www.who.int/docstore/peh/noise/guidelines2.html 5. LAmax Fast measures the sound pressure level averaged over 0.125 seconds. 6. WHO, op. cit., pp. 55–56. 7. WHO, Night time noise guidelines for Europe, p. vi. 8. WHO, op. cit., p. 7. 9. MVA Consultancy et al. Attitudes to noise from aviation sources in England, 2007. 10. op. cit., para. 11.3.9, Figs 7.2 and 7.3, and para. 7.3.4. 11. op. cit., para. 7.3.6 and Fig 7.4. 12. Babisch, W. et al. “Annoyance due to aircraft noise has increased over the years—Results of the HYENA study” in Environment International, November 2009, Vol. 35, Issue 8, pp. 1169—1176. 13. The survey was carried out by BCAW between March and June 2009. 412 respondents were questioned in a door-to-door survey. Each respondent was from a different household. Of the 412 respondents, 281 lived in cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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east Belfast, 99 respondents were from south Belfast, while 32 were from Holywood. All respondents lived in areas which are either under or close to flight paths in and out of George Best Belfast City Airport. 14. EC News Alert Issue 103. Available at: http://ec.europa.eu/environment/integration/research/newsalert/pdf/ 103na1.pdf. See also Haralabidis, Alexandros S. et al. (2008) “Acute effect of night-time exposure to aircraft noise on blood pressure in populations living close to airports” in European Heart Journal. Available online at: http://eurheartj.oxfordjournals.org/cgi/content/full/ehn013v1 15. Greiser, E., Geiser, C. and Janhsen, K. “Night-time aircraft noise increases prevalence of prescriptions of antihypertensive and cardiovascular drugs irrespective of social class—the Cologne-Bonn Airport study” in Journal of Public Health, Vol. 15, pp. 327—337. 16. Floud S. et al. Medication use in relation to noise from aircraft and road traffic in six European countries: results of the HYENA study, Occupational and environmental medicine, Vol. 68, pp. 518—524. Abstract published online at: http://oem.bmj.com/content/68/7/518.abstract 17. Op. cit., p. xi. 18. Op. cit., Table 3, p. xvii. 19. 35 nursery, primary, post-primary and special schools responded to the survey. All are situated under or close to City Airport flight paths. The survey was carried out in June 2008. 45 schools were sent postal survey forms. Non-respondents were followed up by telephone. 20. Jones, K., (2010) Aircraft noise and children’s learning, CAA, p. 18. 21. Clark C. et al. “Exposure Effect Relations between Aircraft and Road Traffic Noise Exposure at School and Reading Comprehension, The RANCH Project.” In American Journal of Epidemiology, 2006, vol. 163, no. 1, pp. 27—37, and Clark C. et al. “Aircraft and road traffic noise and children’s cognition and health: a cross-national study” in The Lancet, Vol. 365, 1942—49.. Latter available at: http://aje.oxfordjournals.org/cgi/ reprint/163/1/27 22. Clark, C., Head J., and Stansfeld, S. “The long-term effects of aircraft noise exposure on children’s cognition: findings from the UK RANCH follow-up study” in The Journal of the Acoustical Society of America, April 2012, Vol. 131, No. 4.

Written evidence from Mr Basil Hutton (AS 17) I am a retired headmaster. I was a school head for 20 years, served on the Board of Studies of the Education Departments of Queens University Belfast and Stranmillis and St Mary’s Colleges of Education. I taught part- time on their undergraduate and post-graduate courses. I was awarded the M.B.E. for services to education in 2000. I am a member of Stranmillis Residents Association. 1. My main concern with the Policy Document lies in the question posed by your Committee in paragraph 3A:” 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 the local residents” 2. I was very disappointed with the direction and thrust of the Draft Aviation Policy framework. I was astonished to find that only the 3 main London Airports have been designated for noise management purposes. In the case of our own local noise polluter, George Best Belfast City Airport, it is even more astonishing. The document talks about the impact of noise at 57db at Gatwick and Stansted where together, only 4,200 people are affected, compared to the 11,500 similarly affected at GBBCA. Noise management is to be left to “better engagement” between airports and local communities, laissez-faire waffle at its woolliest. Governments should look after the overall welfare of its voters, but our Government has a completely cavalier attitude to its electors when it comes to aviation. Aviation seems to be cocooned in a world of its own and seems to operate in an unrestricted environment which is granted to no other industry. 3. Almost proudly the document admits that Heathrow’s environmental impact exceeds the combined impact of all the other hub airports in Western Europe! It is also worth noting that it has been voted the third worst airport in the world on CNNGo’s website. This should tell anyone that there is something seriously wrong with our current airport strategy. 4. Government must come to terms with the environmental impact of aviation and ensure that, as in Australia, the pain is fairly shared amongst as many people as possible, particularly those who preach about the evils of NIMBYism. The Government seems to have no will to take on the aviation industry and its political cowardice is cloaked in the weasel phrase “consistent with the Governments location policy” There is no policy, apart from a policy to do nothing. All other potential polluters, water, sewage, waste disposal, the oil and gas industries, sea and bathing water quality and so on, are all subject to strict regulation and centralised planning. Where is the control here? I don’t think that this document in its present form and scope will supply it. I have now appended some comments and suggestions on the framework document. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Do you think that the government should map noise exposure around the designated airports to a lower level than 57dbs?

5. Noise levels should be mapped by government at all commercial airports and not just the 3 designated ones. They should be mapped according to the World Health Organisation’s recommendations at 40db, 50db and 55dd. The 2009 WHO survey in particular gives excellent guidance on what constitutes tolerable levels of noise at different times of the day and in different situations.

Health impacts of aircraft noise 6. The impact of aircraft noise has been well documented most notably in the HYENA study which showed a signiﬁcant link between aircraft noise and hypertension. No government worthy of the name and with an ounce of empathy for their citizens who live under a ﬂight path should ignore this. There are very many other studies showing the malign effects of aircraft noise and these cannot be ignored or wished away.

Educational impact of aircraft noise 7. All research in this area consistently shows a strong link between aircraft noise and underachievement. The most recent study that I have seen, the 2010 CAA report concludes that it affects memory, concentration, comprehension and reading ability, four good reasons for people to be NIMBYS.

Noise envelopes and the Government 8. These should be set up, monitored and regulated centrally by government. I don’t believe that airports can or should do this themselves. Their business is making money for their owners and they are not greatly concerned either with their environmental impact or the welfare of the people who live under a ﬂight path. If all other sources of pollution are centrally controlled why should airports be allowed to be basically self-regulating.

Government, noise impact and penalties 9. Government should design and implement a robust system of noise regulation which would address this problem properly and which had appropriate penalties, especially for breaches of the night time curfew.

Airport compensation schemes 10. Airport should be required to offer compensation for proper sound insulation of homes where the noise level is greater than the WHO recommended maximum of 50db. Compensation should also be paid for loss of value to houses that are under a ﬂight path. The principal that the polluter must pay is paramount.

Conclusion 11. Naturally enough my main interest in the Policy Document lies in how it could affect our own situation in Northern Ireland. The lack of an overall aviation is most starkly illustrated in how the two Belfast airports compete to the detriment of both and to the detriment of Northern Ireland business. We have two half airports, neither with decent road or rail links to the east or west of the country. GBBCA in particular is already one of the noisiest in the UK and why it has been allowed to expand to the detriment of the only airport with the potential to fulﬁl all of the country’s aviation needs, Belfast International, is a disgrace and an indictment of our local politicians. Compared to the shiny new airports I have seen, especially in South East Asia, ours are antiquated and shabby, with little or no IT connectivity. Our problems are compounded as Dublin Airport is less than 2 hours away for most of Northern Ireland and where APD is minimal. Governments must address not only noise but the unnecessary duplication of routes such as we have in Northern Ireland. This results in avoidable greenhouse gas emissions and the ﬂying of half -full aircraft into the same airports.

12. My wife and I recently returned from an extended holiday in South-East Asia. We flew into Kuala Lumpur (pop 7 million, one airport) on to Hanoi (pop 6 million one airport) on to Hue (pop 2 million one airport) next to Saigon (pop 12 million one airport) and finally to Bangkok (pop 7 million one airport). We then flew home to Belfast (pop 500,000 two airports) Malaysia Vietnam and Thailand have one common pressing need and that is to secure a large and growing tourist business. They are doing this by concentrating their resources on building large modern airports with excellent road and rail links. Comfortable seating and cheap or free Wi-Fi and internet facilities are the norm. We in Northern Ireland need one International airport operating 24 hours a day with sufficient capacity to cater for any potential increase in traffic for the foreseeable future. It needs good road and rail links both to the east and west of Northern Ireland. The only airport that can satisfy these criteria is Belfast International and all future development should be based there. 14 October 2012 cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Written evidence from Peter Tomlinson, Iosis Associates, Bristol (AS 18) The Author Peter Tomlinson MA(Oxon)1 Dip Theol (Bristol) is an independent consultant currently specialising in ticketing and journey management technology for public transport. He is a Member of ITSO Ltd, the government controlled smart ticketing technology company, has been so from its launch, and in its early days was a Director of the company. He is currently involved in editing documents for the SEFT (South East Flexible Ticketing) project. Some aspects of the link between aviation and ground transport.

Summary In the current concern to plan and deliver appropriate additional airport capacity in England, primarily driven by London Heathrow traffic having reached capacity, there is an obvious desire that the further capacity be delivered quickly. Indeed, in an email from the Office of the Mayor of London [1], I read: The Mayor regards the need for a solution as urgent. Also, on 29 September the BBC’s Stephanie Flanders reported the government’s desire for ideas about infrastructure projects that can deliver in short order [2], partly because of the benefit that appropriate construction will bring, and partly, during the development phases of such projects, as a contribution to the immediate need to stimulate the UK economy. This submission to the Transport Committee is intended to urge planners to stop thinking about a brand new hub airport, or about enlarging Heathrow, but instead to start by looking closely at the linkage between ground transport and air transport, at UK spatial geography, and at emerging improvements to UK surface rail capacity. The author’s small scale study leads to a suggestion that planners should examine the idea that the redundant Lyneham airfield be rapidly developed as a commercially close-coupled satellite of Heathrow (ie operated by the operator of Heathrow). The author has been in contact with the Geography Dept at the University of Manchester (Prof Cecilia Wong), which has done relevant work and is prepared to take that work further.

Background Recent material in the media about future developments in civil aviation in the UK indicates that suggestions and studies have taken a new turn. There will, we now read and hear, be a new study about alleviating the problem of congestion at Heathrow, but no decision until after the expected 2015 General Election. The study will be in two parts: a quick review, then another two years of in-depth study. Discussion read and heard tends to revolve around three topics: 1. expanding Heathrow, 2. expanding other existing civil airports in England, and 3. developing a brand new UK national “hub” airport. One missing topic in the material is a sufficient treatment of the problem of surface transport to and from airports, and that is the area that I try to explore here. But it isn’t just a matter of trying to get heard by the team developing the main post 2015 report, for: — that team is said to be providing an interim report in short order; — the Parliamentary Transport Committee (chaired by Louise Ellman MP) is starting a study for which they want written submissions by 19 October this year—only a month away as these notes started to be written Hence this submission to the Committee. My mind went back to a 2009 GMPTE2 hosted conference at which Manchester University Geographers presented data about ground transport in and around major conurbations and also to and from major airports. The presentation was made by Prof Cecilia Wong, Professor of Spatial Planning. My particular interest over the last 14 years has been electronic methods associated with surface public transport: ticketing, journey management and journey reporting. That leads me to look at patterns of public transport and the reasons why and how people do (or do not) use it—not just in the UK but to some extent across mainland Europe. Also I travel two or three times a month between Bristol and London, and thus I am well aware that we have a redundant airfield at Lyneham, in Wiltshire just south of both the M4 and the Brunel Great Western Railway corridor. The dominant problem in UK surface public transport is usually seen as the Monday to Friday daily commuting peaks, requiring investment in infrastructure and equipment that is intensively used only during those peaks, and causing staffing problems because split shift and 12 hour working are no longer acceptable or, in some cases for drivers, no longer legal. For rail services in the South East and on some longer routes radiating out of London, there is a current DfT funded project to encourage more flexible travel patterns, thus contributing, along with more flexible working patterns implemented by the employers of a growing proportion 1 BNC (1962), Natural Sciences (Physics) 2 Greater Manchester Passenger Transport Executive, now an Integrated Transport Authority: Transport for Greater Manchester cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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of those travellers, to spreading the weekday peaks over longer periods3. The methods developed there will feed into the forthcoming new rail franchise contracts, and will help with the operation of rail services that feed airports.

But the dominant problem with the recent discussions is the combination of ﬁrst a statement that our only major hub airport, Heathrow, is full to capacity for all of its operating period (early morning to late evening), and then a conclusion that we must somehow ensure that we develop an ever bigger single national passenger aviation hub. Suggestions that we expand other existing civil airports near London (Stansted and Gatwick in particular) are consistently rejected on the grounds that having in effect a distributed hub network, comprised of independently operated airﬁelds scattered around the extended London area, connected by rail to different terminal stations in London, just doesn’t give the required travel experience. Examples of cities in other countries that have developed new hubs or extended existing ones are regularly cited, but also I have heard it said that none of those hubs are as busy as Heathrow. It does seem that being sited on the Greenwich Meridian makes this country unique as far as the demand for air passenger travel is concerned.

Analysis

In thinking about the airport problem I remembered that some while ago I had taken a quick look at some material about travel by road and rail (partly as a result of that 2009 GMPTE conference). Certainly the pattern of commuting into cities is growing all around the world, but there is a big difference between England and many other countries. I express that difference by stating that England is like a squeezed up version of France: similar population but one third the land area, and characterised by metropolitan areas (plus smaller conurbations) in and out of which workers commute. The “squeezed up” difference is that the hinterlands of major conurbations in France are quite widely separated, while those of our conurbations now signiﬁcantly overlap, and the policy (illustrated at the GMPTE conference by Janice Morphet) of putting more money where the wealth is (ie in the metropolitan conurbations) is making both the commuting problem and the hinterland overlap worse. In 2009, material from Prof Cecilia Wong of Manchester University showed that the volume of commuting into the metropolitan areas is growing and the average commute distance is also growing—but quite a lot of that material is several years old, some as old as 2001, so we could do with an update.

But the signiﬁcance of more recent Manchester University studies is the importance of travel time rather than distance, although the cost of that travel is obviously another factor affecting the decisions of commuters4. Prof Wong pointed me to a study that they have recently completed for the Royal Town Planning Institute: a Map for England [6]. The aim of that study is to help encourage progress on joined-up spatial planning.

With improvement in surface transport comes reduced journey time—until congestion because of corridor overload kicks in, of course. The rail infrastructure updates and new build, and the new trains currently funded for the Great Western Main Line and Crossrail, will bring both greater capacity and reduced journey times on that historic corridor and its extension through London. Bristol is already only 90 minutes from London Paddington (using the route from Bristol Parkway station), but Paddington is not ideally situated for many people. After the improvements, and after also adding a new spur into Lyneham, the journey time from Lyneham to several central London destinations (including other mainline termini) is estimated to be 60 minutes, and not much longer to the eastern side of Greater London.

Then there are interchange air travellers, landing at Heathrow and ﬂying out of Lyneham, or vice versa. Their rail journey is expected to be 40 mins—and the intention in suggesting that Lyneham be a commercially close coupled satellite of Heathrow is that their interchange journey should be seamless, with luggage transfer on the same train arranged for them. For reference, for other suggested but longer term solutions: — a new Thames Estuary Hub will be in the wrong place for those whose surface starting point or destination is anywhere other than Greater London or the nearby east coast and north Kent counties; — an Oxfordshire/Berkshire hub will be in the wrong place for large numbers of people (something that we could alleviate with a massive development of new very high speed railway services— we will not do that); and — expansion of Heathrow by simply extending its surface area in order to build more runways appears (particularly to those many people living nearby) to be an unacceptably disruptive solution, so we must search for a viable alternative;

I submit therefore that a viable alternative, providing both air and ground transport capacity, ought to be one that is capable of being developed in a short period of time, and that, if we can identify it, we should immediately start detail planning of the development. 3 The project is South East Flexible Ticketing (SEFT), about which the ﬁrst public presentation was at the Travel2020 conference on 11–10–12 4 For example the usage of local services on the HS1 line is reported to be not as high as predicted, despite the half hour reduction in journey time for some of the journeys cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Synthesis Now I have been told (but have not searched for the evidence) that an early study into possibilities for expansion of airport capacity looked at not only expanding Stansted and Gatwick but also at bringing into use some new capacity at other airfields not too far from London. My correspondent said that one of the sites considered was RAF Lyneham, due to be vacated (indeed now almost entirely vacated) by the RAF, but it was declared to be a non-starter. That was then; now we have major surface rail network enhancements (including electrification and new trains) under way along and close to a very long corridor (Brunel’s Great Western Main Line) from South Wales and South West England in the west, passing close to Lyneham, along the Thames Valley, continuing as Crossrail through (actually underneath) central London (with interchanges with London Underground, major radial surface rail termini, and through rail routes) and out as far as the eastern fringes of the London metropolitan area. The line from the junction with the Great Western at Didcot Parkway through Oxford and up to the West Midlands is also to be electrified. Lyneham is also close to the M4. And, for air travel, Lyneham is outside the western boundary of the congested South East airspace. Further, much of the land around Lyneham is sparsely populated (although I do respect the fact that developing Lyneham will cause very great disturbance to those whose land will be required, and therefore trust that they will be given full support if they have to relocate, and that others living nearby who decide to relocate should also be supported). So I thought: let us throw away those comparisons with air transport hubs in other countries, and consider a new configuration: Lyneham as a commercially close coupled satellite of Heathrow. Before considering further the possibilities it is necessary to look for government plans for the RAF Lyneham site. An 18th July news article [3] shows that the MoD is considering moving several existing army and support units to the Lyneham site, but the material in Hansard [4] indicates that the plans are not yet finalised. The 18th July statement reported in Hansard (made by Dr Liam Fox MP, then Secretary of State for Defence) did however include the information that a further statement is expected before the end of the year—so there is no time to waste if we are to have placed in the ground a stake that says “Look at Lyneham for civil air travel”. As a further aside, recently yet another study into the UK air travel capacity problem has been published [5]. Its authors Policy Exchange claim that their paper “examines all of the options for increasing airport capacity in the UK”—but it does not mention Lyneham.

So what does “commercially close coupled” mean? It means that, for the air traveller, their experience is that they are using one airport, whichever airfield they are physically travelling from and/or to, and that transfers between the airfields are managed by the common airport operator. As well as the obvious journey using ground transport to/from the airport from/to which you fly, for example you could: Drive to Heathrow, fly out of Lyneham. Drive to Lyneham, fly out of Heathrow. Seamlessly fly into one airport and out of the other. Land at either airport and take the train to the final destination. And, if one airfield is partially or completely closed when you arrive by air, the airline lands at the other airfield, with the train taking you onward.

What next? Who could do the modelling associated with Lyneham as satellite of Heathrow? Why not ask Manchester University or my alma mater Oxford? Since I read Physics, I don’t know any Oxford Geographers, but in 2009 at the GMPTE conference I did experience a little of the Manchester work. So this paper is also being sent to Prof Cecilia Wong, Professor of Spatial Planning at Manchester University. 15 October 2012

Annex SUPPORTING MATERIAL Parliamentary Transport Committee http://www.parliament.uk/business/committees/committees-a-z/commons-select/transport-committee/news/ aviation—tor/ There may be found the Parliamentary Transport Committee’s “terms of reference for a new inquiry that will examine the Government’s aviation strategy and will focus on aviation capacity in the UK”, plus a short video in which Louise Ellman MP, Chair of the Committee, explains their inquiry and invites input. Closing date for submissions is 19 October. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Relevant rail services The Brunel Great Western Main Line passes close to Lyneham. Major capacity and service quality enhancement for the GW Main Line is in progress. There will be a new spur to Heathrow to/from the west. Electrification will extend all the way to Bristol (possibly further into the South West)) and to Swansea, including branches to Oxford and other towns, and onwards to the Midlands. Reading Station capacity enhancement is not far off completion. New trains have been ordered. Smart Media ticketing is specified in the new Great Western franchise. The Cardiff Valley Lines will be electrified. Crossrail construction work has started. It will deliver journeys from the Thames Valley section of the GW Main Line, through Central London, and on to the eastern outskirts of Greater London. It will provide interchanges with other London rail termini and with the Thameslink north-south through London service.

Relevant air routes Lyneham is outside the congested airspace of the south east, facilitating routing of aircraft in a westerly direction (including Atlantic crossings) and also both north and south.

Relevant road routes Capacity improvements to the M4/M5 junction in the Bristol area are being constructed. The Second Severn Crossing was completed in 1996. [1] Email exchange with the Office of the Mayor of London Dear Mr Johnson, Another way: develop the redundant RAF Lyneham as a commercially close-coupled satellite of Heathrow. Quick to develop, leverages use of the results of investment already under way and committed to the railway network (Great Western Main Line and Crossrail and the route via Oxford to the Midlands), is situated at the western edge of the congested South East airspace so that delays to flights will be reduced. I’m sure that they will make space for your bikes on the high speed shuttle trains that will run to and from the airport.I’m working on a paper for submission to Louise Ellman MP’s Commons Transport Committee enquiry. Dear Mr Tomlinson, Thank you for writing to the Mayor. The UK’s sole hub airport, Heathrow, is operating at nearly 100% of its capacity and, in the Mayor’s view, cannot be expanded further without unacceptable consequences for the hundreds of thousands of people who live nearby. But the Mayor acknowledges that Britain does need a well-functioning hub airport if it is to continue to attract investment and tourism and so generate jobs and continuing economic growth. The country needs a new hub airport, located to minimise impacts on built-up areas. The Mayor is keen to explore a range of alternative solutions that meet the necessary requirements and to have a broad and open-minded debate about them. At this stage, the Mayor is not wedded to any single location; rather he is keen to ensure that decisions are made by those responsible on a proper basis, following a rigorous assessment not only of the economic costs and benefits, but also the social and environmental impacts of the various options. The Mayor regards the need for a solution as urgent. He is therefore disappointed that the Davies Commission, appointed by the Government to look into these questions, has been asked to report in mid-2015. But he does intend to submit detailed evidence to the Davies Commission and he is currently undertaking work that includes consideration of options for the location of a new hub airport. The Mayor and his staff greatly appreciate the time people take when they contact him with ideas for improving important aspects of life in London. As you can imagine, the Mayor receives hundreds of ideas and offers of advice from members of the public every year. They are gratefully received, and all suggestions are noted, recorded and given due consideration. We cannot respond to all in detail, but we will contact you again if we need help in taking any specific ideas forward. I would like to thank you again for getting in touch with the Mayor of London on this important matter. Yours sincerely Nick Waterman Transport Team, Greater London Authority [2] Stephanie Flanders on BBC Radio 4 Today on 29–9–12: Stephanie Flanders asked for ideas for public sector investment, particularly in infrastructure, that could get started quickly—but not to send them to her. So I sent her an email about Lyneham and smart rail ticketing topics… cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Stephanie, Investment that can start quickly? First: develop the now redundant RAF Lyneham (just off the M4 and the Great Western railway line) as a commercially close-coupled satellite of Heathrow Airport (and forget the ideas for a new hub airport). With help from material prepared by Manchester University’s Geographers (Prof Cecilia Wong’s team) for other purposes, I’m preparing a paper for Louise Ellman MP’s Transport Committee (deadline 19 Oct). The design work could start immediately. Such a development will take advantage of investment already committed for the railways, some of it already being spent, and would hopefully trigger a speeding up and expansion of the rail projects. Second (a smaller amount): we are already developing new electronic ticketing methods for rail services in an area stretching from Peterborough across to Reading, down to the South Coast and east of there to encompass all the rail services south and east of London (the SEFT project—South East Flexible Ticketing—for which £45 million was allocated in the last Autumn Statement by the Chancellor, but DfT has not publicised it, although Norman Baker was talking about it at the LD Conference this week). But the core technology (for which the government owns the ITSO specifications) needs further investment in order to ensure that it fully supports emerging technology developments and, crucially, in order to ensure that the emerging national network of data processing and security management nodes is of adequate capacity, is highly reliable and resilient, operates securely, and continues to address the growing IT security threats. The govt controls the core company ITSO Ltd, but is starving it of development and management money. And, alongside the SEFT project, there is a commitment in the new rail franchising programme for the operators to fully implement the ITSO methodology—but, on past performance, they will be very unwilling. New ticketing and journey management methods in public transport benefit the passenger more than the operating company—ie the business cases for the operators are always weak—so there has to be a fund created to assist in paying for the rollout and operation of the technology across the rail network (including providing training programmes—for the civil servants as well as for the service operators).Declaration of interest: I am a founder Member of ITSO Ltd (a company limited by guarantee without shares but with Members), and have recently been retained by another company to do technical writing work for the SEFT project. Further updates: — On 11–10–12 DfT made a presentation about SEFT to the Travel2020 Conference (a Landor event) — a recent report by PwC to DfT is known to have recommended that DfT consider further interventions along the lines of the SEFT development. [3] : http://www.lynehamvillage.com/news/lynehamraf/defencetech180711.html RAF Lyneham to be Defence Technical Training Centre 18 July 2011 THE former RAF Lyneham base is to remain under military occupation it has been announced. The move is part of a £1.5 billion investment in UK reserve forces over the next 10 years as part of a wide-ranging shake-up of the UK’s military. Defence Secretary Liam Fox told parliament this afternoon that defence technical training programme will move to the former RAF base “guaranteeing its future”. Dr Fox told MPs that the Territorial Army would form around 30% of a 120,000-strong Army by 2020. In a statement to MPs Dr Fox announced major changes in the basing of forces, with RAF installations set to be taken over by Army units returning from Germany. Speaking after the announcement, North Wiltshire MP James Gray said: “We fought long and hard to keep the RAF at Lyneham, but sadly failed, so I was delighted by the Secretary of State’s announcement today that the base will instead be used by the defence technical training establishment. “This will mean that at least 1,500 Service personnel will be moving into Lyneham in the near future to replace the departing RAF which is good news for everyone in the area”. Dr Fox told MPs £400 million would be spent this Parliament on boosting the reserve forces, with the possibility of new legislation to “ensure that the reserves are more readily usable on operations”. He said the growth in the Territorial Army’s strength would allow a “progressive adjustment” in the balance with regular troops. “The overall package I have announced today is good news for our armed forces and means they can look forward to the future with renewed confidence because the defence programme I have announced is underpinned with real resources,” he said Military lecturer Peter Caddick-Adams, at the Defence Academy in Shrivenham, described the announcement as “excellent news”. He said: “There was a great fear that the Lyneham estate would be sold off, which made cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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no sense. It’s a very intelligent use of the estate, which has had a lot of money put into it over the years and it would be a shame to see it sold off quite cheaply. Defefence Secretary Liam Fox was saying about Lyneham—RAF Lyneham is the preferred location for future Defence Technical Training. This confirms that the Department will withdraw from Arborfield, in Berkshire and Bordon, in Hampshire, releasing the sites for sale by 2014–15 at the latest. This announcement in no way threatens the existing Defence presence at St Athan. There are no plans to move or reduce the 300 technical training posts as part of the rationalisation to Lyneham. Indeed plans to relocate additional Defence units to St Athan are being developed, and if those plans come to fruition, they will bring a major uplift in employment at that base. We intend to make an announcement before the end of the year. Arborfield—Arborfield is currently the location of the Regimental Headquarters of the Corps of Royal Electrical and Mechanical Engineers of the British Army. Within the Garrison is a significant area of housing, containing a mixture of military and civilian properties. The garrison contains Hazebrouck Barracks, which is a training base for the Royal Electrical and Mechanical Engineers (REME) School of Electronic and Aeronautical Engineering (SEAE). The potential craftsmen within SEAE, study in the school to learn a trade as aircraft technicians, avionics technicians, and electronics technicians, (which encompasses all maintenanence operatives for all land based electronic equipment). The Defence College of Aeronautical Engineering (DCAE), established on 1 April 2004 as a result of the Defence Training Review (DTR), is responsible for training of aircraft and avionic technicians. This college from its conception has been integrated as part of SEAE. Bordon—The School of Electrical and Mechanical Engineering (SEME) is a training school, providing trade (Phase 2) training for soldiers of the Royal Electrical and Mechanical Engineers (REME). SEME is the UKs largest electro-mechanical engineering teaching establishment. At any time there are approximately 1500 soldiers at SEME undertaking career and equipment courses and gaining transferable qualifications ranging from NVQ level 2 to HND. SEME is committed to delivering relevant training in support of current operations, consequently the number and diversity of our technical courses is greater than ever. Their mantra is “Soldier First, Tradesman Always’ and so maintaining and developing soldiers’ military skills, in parallel with their trade, is at the heart of what they do. Currently, SEME also offers soldiers the opportunity to participate in a wide range of sporting and adventurous pursuits. The Bordon gymnasium, swimming pool and sports pitches are second to none. Also available are first class medical, dental and physiotherapy facilities. SEME is constantly updating and modernising its technical training courses and teaching techniques. They have recently invested in new computer based learning for soldiers undertaking the Common Foundation Module and further investment this year will see Armourers’ training being transformed. Prior to today’s annoucment SEME were under the apprehension that a move was on the cards. In around 2015, the Defence Training Review will relocate SEME and other Service schools to a brand new Defence Technical College at St Athan in South Wales. SEME offers real opportunity to those seeking a challenging and rewarding career within the Army. Our courses will test soldiers’ determination and commitment and in doing so prepare them for their first and future assignments. The Secretary of State for Defence Dr Liam Fox said “This commitment to increase Defence equipment funding after 2015 will ensure our Armed Forces remain a formidable fighting force on the world stage. I am determined to maintain Britain’s position in the international premier league and to ensure that our Royal Navy, Army and RAF are given the tools they need to do their vital work. [4] The substantive part of the actual statement on 18–7–12 by the then Secretary of State, as recorded in Hansard, is: http://www.publications.parliament.uk/pa/cm201011/cmhansrd/cm110718/wmstext/ 110718m0001.htm#1107182000375

Defence DEFENCE TRANSFORMATION The Secretary of State for Defence (Dr Liam Fox): The strategic defence and security review (SDSR), announced last October, marked the start of the process of transforming defence to meet the challenges of the future. It set out a path to a coherent and affordable defence capability in 2020 and beyond; and some of the key building blocks—such as the return of the Army from Germany, and a Royal Air Force (RAF) structured around fewer, more capable fast jets. This statement provides detail of our intent on future armed forces basing and rationalisation of the defence estate. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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RAF Lyneham is the preferred location for future defence technical training. This conﬁrms that the Department will withdraw from Arborﬁeld in Berkshire and Bordon in Hampshire, releasing the sites for sale by 2014–15 at the latest. This announcement in no way threatens the existing defence presence at St Athan. There are no plans to move or reduce the 300 technical training posts as part of the rationalisation to Lyneham. Indeed plans to relocate additional defence units to St Athan are being developed, and if those plans come to fruition, they will bring a major uplift in employment at that base. We intend to make an announcement before the end of the year. [5] Bigger and Quieter: The right answer for aviation, Policy Exchange, 5 October 2012 http://www.policyexchange.org.uk/publications/category/item/bigger-and-quieter-the-right-answer-for-aviation

Bigger and Quieter: The right answer for aviation examines all of the options for increasing airport capacity in the UK. It supports placing four runways immediately west of the current Heathrow site. This would double the existing capacity to 130million passengers, cementing it as Europe’s premier hub. If this was politically unfeasible, then a four runway airport at Luton would be the next best option.

The report says that the UK needs a new hub airport located in the South East which has spare capacity to accommodate the likely increase in demand, especially to cope with the rise in middle class travellers from emerging markets.

It doesn’t rule out the current proposal to build a third runway to the north of Heathrow, but claims that less people would be affected by aircraft noise if the four runways were instead located 3km to the west of Heathrow.

To reduce the effect of noise the report proposes: — A complete ban on the noisiest aircraft at all times, rather than just at night. Airlines would have to ensure their ﬂeet complied with new decibel measures by the time the new runways were ready for use. — Imposing a complete ban on night ﬂights. The increase in the number of slots available would mean no planes would arrive or depart between 11pm and 6:15am. — Landing narrow bodied planes at a steeper angle as they already do at London City airport. This again means they are higher over any part of West London on their descent. For example, a plane would be 925m rather than 260m above Hounslow. — In addition, moving the airport west means planes will be higher over London than at present

Because the proposal reuses existing terminals and infrastructure, the price is likely to be around half that of Foster’s proposal for an estuary airport. Approximately 700 properties would need to be demolished compared to the 1,400 that would need to go to make way for the estuary airport. The cost and ease of travel to Heathrow as well as the fact many businesses are already located near the current airport makes it the most suitable site.

The report says that other than Heathrow, Luton is the best located London airport. It is close to a high quality, four track rail line that goes to London St Pancras in 21 minutes as well as to key cities in the Midlands. It is also close to the M1, arguably Britain’s most important road. If expanding Heathrow is politically unfeasible, Leunig proposes a four runway Luton Hub with two terminals, the ﬁrst adjoining the M1, the second the Midland Main Line rail route. The disadvantage of Luton over Heathrow is that the terrain is much more challenging, and the location is not as strong.

The paper rules out: — Foster + Partners estuary airport (aka “Boris Island”) as it is too hard to get to for too many people. The environmental and construction challenges are also much harder to overcome than at Heathrow. — Connecting Heathrow and Gatwick to become a single hub. The two airports are 25 miles apart meaning that a direct high speed rail link would cost approximately £15 billion. — A four runway airport at Gatwick. The costs are higher than for Heathrow, and the location is not as good. Instead Gatwick should consolidate its position as a good quality base for point to point trafﬁc geared towards leisure travel and short haul ﬂights. — A four runway airport at Stansted. Like the estuary airport proposal, Stansted suffers from a poor location, with a weak hinterland and slow connections to London and the rest of the country.

No mention there of Lyneham…

[6] Royal Town Planning Institute

http://www.rtpi.org.uk/knowledge/core-issues/map-for-england/ cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Map for England Why do we need a Map for England? Despite the generally recognised and accepted need to ensure a joined up approach to planning infrastructure and services, there is remarkably still no single place or data source within government that makes all of these maps available to view. Good progress has been made in various areas but with an overarching framework—a Map for England— policy makers could make better judgments about how individual policy proposals interact with and affect development of the country as a whole. It would also increase consistency in appraisal, improve security and resilience, and provide a better understanding of sectoral issues that might complement or conflict with each other. Listen to our podcast on why we need a map for England. Additional benefits of a Map for England include: Helping to boost growth. Housing, industry and business would be able to make quicker and better informed investment decisions which are more closely aligned to public sector infrastructure funding plans. Being much more transparent. Local communities would be able to find out about how government plans affect their areas and to influence them. Saving time and money. When writing new strategies, government departments could see the existing plans for different parts of the country and relate their new strategies to them. Datasets drive innovation. Helping to coordinate infrastructure across borders with Scotland and Wales. Research findings We commissioned a study from the University of Manchester examining a broad range of existing government policies and how they relate to each other. See the study (pdf, 17.7 MB) and a compendium of policies in map form (pdf, 9.7 MB). To reach their conclusions, the researchers examined government web sites, individual policy documents and large numbers of reports to find policies and programmes that have strong spatial aspect to them: policies which potentially have a different impact in different parts of the country. It was a major task in itself to pull together almost 100 policy maps. In about one third of these documents the implications for different places are made explicit but in fully two thirds they are not. By overlaying a number of these maps and diagrams together, the researchers demonstrated that some policies and programmes, when considered against each other in relation to different parts of the country, may have unintended consequences. For example, the study revealed that there is considerable overlap between broad areas where housing growth is projected in the future and where there are the greatest environmental and policy constraints to growth. These constraints include the risk of flooding and expected future household water shortages.

Written evidence from Mr Francis Joseph McGlade (AS 19) I am responding, as a private individual, to the Select Committee’s invitation to comment on the Government’s draft Aviation Framework Document. I reside under the ﬂight path of Belfast City Airport, a regional airport where the number of residents affected by aircraft noise exceeds by a considerable margin the numbers affected at Gatwick and Stansted combined. I would preface my comments by saying that the Framework Document leaves one with the impression that it was written with the south-east of England primarily in mind. This is disappointing. My comments refer mainly to Chapter 4, or the Select Committee’s point (3a). 1. Noise is a form of pollution and should be recognised as such. All other common forms of pollution are properly legislated for and independently monitored. To leave it to the airports to self-monitor noise levels is wholly unsatisfactory and clearly isn’t working.Penalties should be set at a level that provides a realistic deterrent to polluters.

2. The proposal to allow the noise contour to remain at 57 dB LAeq,16h is too simplistic and out dated. It doesn’t adequately identify peak occurrences, and additionally, people’s noise tolerance threshold has reduced considerably since it was ﬁrst introduced. It doesn’t recognise the now well-researched impact that exposure to excessive noise has on health, particularly stress and blood pressure levels, and heart disease. Neither does it recognise the detrimental effect the level of noise it permits has on children’s education as a result of sleep deprivation and the reduced ability to concentrate. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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I believe therefore that the 57 dB LAeq,16h contour is much too favourable to the airports and airlines. The 2009 World Health Organisation guidelines would, if adopted, go a considerable way towards correcting this imbalance.

3. The document as written contains no incentive to airlines to adopt quieter aircraft. Measures such as variable landing charges or APD could be used as a tool to provide such an incentive. This would help correct the present situation where landing charges are used by competing airports as a means of winning business from rivals, thus obliging the airlines to use older, noisier aircraft.

4. Noise reduction and a reduction in CO2 emissions need not be mutually exclusive. 5. My personal experience of Airport Consultation Committees is that they are wholly ineffective as a means of improving environmental conditions for those whose lives are blighted by airports. They are merely puppets of the airport, which uses them to claim that they have “consulted” the local community. If local collaboration is to be effective airports must not be permitted to control the selection of the Consultative Committee, and it should have an independent Chair and minute taker.

Finally, but not directly related to noise issues, regional airports tend to make inﬂated claims about the economic beneﬁts they bring to the local community—claims that do not bear close scrutiny. Of particular note is that airports that service the “bucket and spade” destinations make a negative contribution to the economic well-being of the community in which they are based. 15 October 2012

Written evidence from the Board of Airline Representatives in the UK (BAR UK) (AS 20)

BAR UK is the airline association for scheduled airlines with an UK operation or presence.

Comprising over 80 airlines, our membership includes two major UK airlines (British Airways and Virgin Atlantic) and a wide range of non-UK airlines from all around the globe. Full details of BAR UK can be found on our website www.bar-uk.org .

The Committee’s Inquiry into UK aviation strategy is of immense interest to them all.

The core issue is that of the country’s hub airport that has been fully utilised for years. Until any clear policy direction emerges, and allowing for due planning processes to be completed, the UK is effectively advising airlines, especially those from outside of the UK, that no additional hub airport capacity will be available for at least 10–15 years. That’s a terrible indictment for a country that intends to trade its way out of recession.

In fact, capacity is so full that, even with slot trading permitted, the costs are so high, or the timings of the slots so unattractive, that existing airlines are hampered in their efforts to improve, and many new entrants simply cannot bear the costs, especially when normal start-up costs are so high in any event.

The result? Those airlines outside of the UK, who take strategic decisions years in advance, are simply beginning to ignore London in their expansion plans.

Should no slots be available at ‘LHR’, their planners/schedulers generally don’t then look at ‘LGW’ or ‘STN’, they simply look at the opportunities presented in ﬂying from their home base to other countries and operate additional ﬂights to them instead of to the UK.

Those countries then become the beneﬁciaries of the vacuum in the UK’s aviation policy that denies any additional hub airport capacity; it’s as simple as that.

As even a 3rd runway at Heathrow, if approved this year, would possibly not be operational until at least the mid 2020s, the UK is effectively telling the world that no additional trading opportunities will exist at our hub airport for at least 12 years. That, in UK economic recovery terms, seems completely unacceptable.

In respect of the questions posed, we have endeavoured to provide high-level responses, remain readily available to provide any further information that may be required, and are ready to appear as witnesses at the public hearings that the Committee may hold.

BAR UK Responses

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

A: The overarching objective should be to permit the operation of a market-driven industry that meets the needs of its customers (freight clients as well as passengers) whilst adhering to all relevant environmental standards and policies. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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(a.) How important is international aviation connectivity to the UK aviation industry? International connectivity is paramount. Any country that is not well-connected to its trading partners, future as well as present, will not be in a position to grow, and risks stagnation and decline as competing States take precedence. Connectivity means a world-class hub airport, if the UK is to compete on a global basis. The UK’s hub airport is Heathrow and has been operating to capacity for many years. A direct consequence is reduced capacity and a propensity for arrival and departure delays; in turn, these create additional emissions. Additional capacity at Heathrow has been required for several years, and the Committee is asked to note that it is the aviation industry that would ﬁnance the additional capacity, not the public purse. There are many facets to what constitutes a hub airport, so the Committee’s attention is drawn to the points of reference below: — “Connecting for growth: the role of Britain’s hub airport in economic recovery” by Frontier Economics for Heathrow. (hub.heathrowairport.com/index.php/download_ﬁle/view/15/1/) — London’s Connectivity Commission—Britain and the World, Transport links for economic growth (http://bit.ly/QULCCF) — Response of BAR UK to the DfT’s consultation “Developing a sustainable framework for UK aviation: Scoping Document” (http://bar-uk.org/consultations/response2011.htm)

(b.) What are the benefits of aviation to the UK economy? The UK economy benefits enormously from its aviation industry, and government needs to ensure its advancement if it is not to decline. There are 186,000 jobs directly created as a result of airport and airline activities within the UK, and a total of 520,000 directly and indirectly. Collectively, the UK benefits from direct economic activity to the value of £11.2 billion. Separately, the inbound travel market arising from aviation generates another £12 billion in economic activity, generating an additional 170,000 jobs in the process. By value, 55% of exports to non-EU countries are carried by air. Source: The Economic Contribution of the Aviation Industry in the UK, Oxford Economic Forecasting, 2006 (http://bit.ly/O2mXPk) There is a good range of studies that confirm the huge value of aviation to the UK economy. They include: 1. “Flying in the face of jobs and growth: How aviation policy needs to change to support UK business” by British Chambers of Commerce (http://www.britishchambers.org.uk/policy- maker/policy-reports-and-publications/?page=4) 2. What is the contribution of aviation to the UK economy? Report for AOA by Oxera (via http://www.aoa.org.uk/reports-and-publications.htm)

(c.) What is the impact of Air Passenger Duty on the aviation industry? Originally quite a small tax, Air Passenger Duty is harmful to the UK economy, not just to the aviation industry. APD rates have become so high, that they are the cause of objections, from overseas (including diplomatic protests) as well as within the UK, and are causing a resistance to visiting the UK. Originally devised as an environmental tax, the Treasury now openly admits that APD is simply a revenue- raising device. By its name, it is targeted solely at air passengers, with rates having increased since 2007 by over four-fold on long-distance routes eg: Jan 2007 April 2012 Basic Economy Class £20 £92 Premium Economy/Other classes £40 £184

Such high rates of taxation act discriminately against the airline industry as other forms of transport have no such tax levied against them. It can be seen that, for a family of four, the tax take on many long-haul routes is so high that it can be the equivalent of paying for ﬁve tickets but only getting four. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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The Committee is asked to remember that potential visitors from overseas have a choice of whether or not to visit the UK, or to go elsewhere. Evidence exists that they are beginning to go elsewhere, eg continental Europe, rather than pay APD. The “A Fair Tax on Flying” alliance (www.afairtaxonﬂying.org) has seen its activities result in over 200,000 people lobbying either their MP or, if from overseas, the Chancellor. As an immediate priority, the ﬁrst aim must to be to freeze the future increases to APD that the Chancellor has publicly planned.

(d.) How should improving the passenger experience be reflected in the Government’s aviation strategy? The “passenger experience” can be complex, with a natural focus on the departure experience; however, recent events have shown that the arrival experience can be totally disruptive, and extremely distressing, if resources are not in place. The well-known, and unacceptable, queues of two+ hours at the UK Border during this summer provide the main case in point, and are a direct consequence of government policy on one hand, linked to outdated processes and concepts on the other. The amount of passenger data provided by airlines, in advance of travel, through the e-Borders programme should provide the stepping stone to move from a manually-intensive set of border checks to a knowledge- based (not risk-based) border control system. A more specific strategy should be to continue the campaign for speedier implementation of the Single European Sky (SES). The benefits of this programme, if comprehensively implemented, would spread far and wide. More direct flight routeings would be available, emissions would be reduced and so would delays to passengers. It is recognised that the UK government is a leading proponent of SES and its efforts to date are valued. In broader terms, the government’s role in respect of the passenger experience should be to ensure that relevant passenger legislation is complied with by airports and airlines, and to undertake any major review where major lapses seem to occur. However, it should not be the role of government to interfere with the market-place competition that is the backbone of airline and airport services.

(e.) Where does aviation ﬁt in the overall transport strategy? Aviation should be regarded as an absolutely essential component within the UK’s transport infrastructure; by deﬁnition, it should also be an essential part of the country’s overall transport strategy. Aviation is a multi-layered spectrum. Within are included scheduled airlines, charter airlines, all-freight airlines, and business/general aviation. Within that spectrum, scheduled airlines play a vital role through the provision of passenger and belly-hold freight capacity, linking the UK to the rest of the world, including its import and export markets. Integration with surface transport/access is just as vital. BAR UK subscribes to the DfT’s Low Carbon Surface Access strategy, which aims to increase the use of public transport to and from UK airports.

2. How should we make the best use of existing aviation capacity? (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? The use of London airport capacity is largely determined by market needs. Most signiﬁcantly, this includes which London airport is considered for the marketplace. Prime amongst market needs is a global hub, an aspect that is considered essential by BAR UK airlines. For the sake of clarity, that hub airport is Heathrow. That spare runway capacity may exist at other London airports is, largely, of little consequence or comfort. Should it be the only available option, and it’s not the preferred one for airlines, then Mixed Mode operations should be considered as an extreme option. Whilst additional capacity could be generated on the current two- runway system, by gaining maximum use of them both, the resilience of the airport, already very fragile, would be reduced considerably further. The concept of a “virtual hub” eg Heathrow linked to another London airport, is theoretical at best and highly impractical for a variety of reasons. Should the airlines deem the concept practical, then they would readily advocate it. In respect of passenger experience, various research, including the CAA’s, shows that overall satisfaction levels are high, although there is always room for improvement. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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However, resilience is another matter. Any airport operating to maximum capacity and pace has little room for manoeuvre when circumstances change. Heathrow is in that position, and has been for several years. It is why airlines there, with BAR UK’s full support, have been lobbying for a third runway.

(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? The government’s strategy allows for market forces to operate at all airports, so those outside of the South East already have the tools at their disposal to obtain better utilisation of their capacity. BAR UK airlines have reasonable degrees of operations at airports such as Manchester, Birmingham, Glasgow and Edinburgh, but London and the South East dominates their market needs. Ultimately, the issue is whether or not routes which they operate to/from regional airports are actually viable in their own right. Whilst there may be a proportion of the ex-UK market for which travel from a regional airport may be practical, are there enough inward travellers who also wish to use that airport—or is London, as the UK’s capital, still the prime destination?

(c.) How can surface access to airports be improved? BAR UK fully supports the concept of improved surface access to airports, especially if there is a reduction in overall emissions as a direct result. Any improvement programme would be speciﬁc to each airport, and the business case rationales for transport providers.

3. What constraints are there on increasing UK aviation capacity? (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? The environmental questions asked here are broadly contained within the DfT’s consultation ‘Aviation Policy Framework’. The Transport Committee’s attention is drawn to the fact that the aviation industry at large, not just the airlines, has a consistent track record of significantly reducing the impact of aviation noise. Evidence of this can be seen by the fact that the noise contours for Heathrow have shrunk so significantly. 1988–2011: whilst flights increased from 352000 per annum to 480,000, the area affected by noise, using the DfT’s own metric of 57dBA summer day Leq, plummeted from 331 sq. km to 110 sq. km. (Source: ERCD, CAA—Annual Noise Contour Reports)

(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? Carbon emissions from aviation are, essentially, a global issue. They are being managed through a mix of regulation on one hand, and industry cooperation on the other. The UK strategy of working in conjunction with global efforts, and the industry’s own collaboration on noise, emissions and efﬁciencies continues to make aviation even more sustainable.

(c.) What is the relationship between the Government’s strategy and EU aviation policies? The government’s strategy is one of support for EU policies.

4. 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? There is a step change required, and now. It needs to be one based on recognising that the UK is losing out on air connectivity to competing countries. Airlines make their strategic plans, for new routes and for new aircraft types, a number of years in advance; they are not made on a whim. The lack of a clear airport capacity policy, allied to slot constraints at Heathrow, is already providing feedback that the UK is losing out to new routes and airlines. Consequently, this policy vacuum is making it easy to take decisions in overseas boardrooms to give the UK a miss, and no publicity will attach itself to such decisions. Competing states will continue to be the beneﬁciaries until the time that the UK takes a ﬁrm grip on aviation policy and states what its intentions are. Additional airport capacity needs to be provided as soon as possible. The quickest way is still the provision of a third runway at Heathrow. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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When and where a new hub airport may be required cannot be answered at this stage. There are far too many unknowns, not least the funding provisions for it, and what the situation may be in respect of the unamortised investments, paid for by airlines, at Heathrow. BAR UK looks forward to contributing to the work of the Independent Commission, to be led by Sir Howard Davies. At that time, BAR UK will urge that all options will be considered.

(b.) What are the costs and beneﬁts of these different ways to increase UK aviation capacity? Reference is made to Question 4 a. regarding the funding of current airports, as well as any new one. There are no known answers at this stage, merely many questions. 15 October 2012

Written evidence from Dr. Peter W. Skelton (AS 21) Executive Summary Construction of a new airport in the Thames Estuary would pose three unacceptable risks: (1) major impact on an internationally important area for wildlife conservation, particularly for birds; (2) increasing likelihood of surge tide ﬂooding due to geological subsidence of the area combined with global sea-level rise; and (3) necessity for expensive and widely disruptive transport infrastructure development to facilitate access for the majority of potential UK users. Any proposal for such an airport should thus be rejected on both environmental and economic grounds.

Details of submitter Retired academic geologist (currently Visiting Reader) from The Open University, Faculty of Science (Department of Earth, Environment and Ecosystems), with forty years experience of geological research and teaching, including Earth System Science and the geological record of climate change.

Arguments against proposals for a new Thames estuary Airport The Committee’s Issue 4(a) asks if there is a case for a new hub airport and where it might be sited. One proposal widely discussed in the media is for the construction of a completely new airport in the Thames Estuary (the so-called “Boris Island”). This proposal should be rejected on the grounds of posing at least three unacceptable risks: 1. Wildlife conservation. According to the RSPB, the area is “a vital migration hub for hundreds of thousands of wildfowl and wading birds”, its global significance being “recognised by its status as a Special Protection Area (SPA)”. Construction of an airport there would pose a major threat to this internationally important area for wildlife conservation, which would be further exacerbated by the ongoing need to prevent the risk of bird-strikes over a wide area. The proposal thus flies in the face of the National Ecosystem Assessment recommendation that “Sustainable management of Coastal Margin habitats must be holistic, taking into account physical, chemical and biological processes, spatial and temporal scales, drivers of change, and cultural elements. Most large Coastal Margin sites are designated as Special Areas of Conservation (SACs) under the Habitats Directive, or are Sites of Special Scientific Interest (SSSIs); therefore, the protection and maintenance of the biodiversity, natural processes and geomorphological interest remain primary objectives” (UK National Ecosystem Assessment (2011) The UK National Ecosystem Assessment: Synthesis of the Key Findings. UNEP-WCMC, Cambridge, p. 76). Moreover, as the NEA synthesis notes (p. 25) in relation to wetland and coastal hydrology “The breakdown of waste and detoxification of freshwater runoff … is locally problematic in estuaries and coastal waters”. The widespread environmental disruption caused by development of such an airport and the extensive drainage of approach areas would thus be likely to have a profound impact upon the hydrological and ecological “services” provided by this major estuary, eventually requiring costly remediation. 2. Flooding. Geologically, the estuary area is subsiding (Shennan, I. & Horton, B., 2002, Journal of Quaternary Science, 17, 511–526), in places currently at a rate of up to 2.1 mm/year, based on satellite measurements over the period 1997–2005 conducted for a DEFRA/Environment Agency-funded case study investigation of flood risks (Land vs sea level rise case study: London, “Terrafirma”, ESA Global Monitoring for Environment and Security (GMES) Initiative). With the current global rise in sea-level estimated by the Intergovernmental Panel on Climate Change (IPCC) at 3.1 mm/year, the relative rise in sea level in the Thames Estuary area should thus reach over 5 mm/year. Over several decades, a significantly increased risk of damaging surge tides could therefore be expected in the area, against which costly defensive systems would be required. 3. Access. The majority of UK travellers using the proposed airport would have to pass through or around London to reach it, necessitating considerable additional expenditure on transport infrastructure for access, not to mention the associated widespread disruption that it would cause. In the event of sharply increased air travel costs resulting from a combination of rising fuel costs and “the proper incorporation of environmental costs in the market pricing of air transportation” (Seely, A., 2012, ‘Taxing Aviation Fuel’. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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House of Commons Library, Business and Transport Section, Standard Note SN00523), many travellers might opt instead for alternative, more convenient and “greener” modes of travel to the continent, such as high-speed rail, such that the proposed airport would ending up becoming a massively expensive white elephant.

In short, the Thames Estuary is both environmentally and economically a most unsuitable place for a new airport—if, indeed, any such expansion of aviation capacity can be considered desirable given the increasingly pressing need to curb carbon emissions, particularly by aircraft. 15 October 2012

Written evidence from IAAG (AS 22)

GOVERNMENT’S UK AVIATION STRATEGY WITH FOCUS ON AVIATION CAPACITY

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

(a.) Connectivity

This can be defined as providing an infrastructure of land sea and air routes from all parts of the UK to major overseas destinations, important for: 1. Maintaining and developing British commercial and trading interests with developed and developing world 2. Maintaining links with British and related communities in the commonwealth, other major countries i.e USA & Argentina 3. Encouraging the correction of trading deficits and tourism imbalances by providing connection and connectivity from these markets into the UK. Providing links from other domestic points for discretionary low cost travel is of less relative importance. Connectivity from and into UK is therefore not ideal when defined as non-stop direct services to these destinations

However due to the inability by BA to mount additional proﬁtable capacity and the congested nature of LHR, connectivity is increasingly provided by non-British air carriers operating from all parts of the UK through their superior hubs to all important international points of origin and destination. This is becoming an irreversible trend and is outlined in more detail in other sections of our papers.

In overall terms connectivity is well provided to the UK especially in connecting services through European and Middle East and Far Eastern hubs (altogether 8 hubs and 8 high quality and aggressive and expanding hub carriers. This is at the expense of British aviation interests but not necessarily of British consumers nor overseas visitors. More later on this key subject.

(b.) Beneﬁts to the UK economy

A strong high quality aviation sector is important to the British economy in: 1. Preserving the notion of the UK’s centrality in world ﬁnancial markets 2. Preserving the UK’s reputation for incoming tourist and VFR trafﬁc. 3. Maintaining and enhancing the UK’s reputation worldwide as a place to do business and base executives, families & investors.

Unfortunately the UK has lost its leadership position in these aspects.

It has lost its centrality because of the low quality experience of Heathrow, difﬁculties of efﬁcient connecting service networks and the apparent absence of purpose in developing a satisfactory air travel experience through major airports to/from ultimate destinations.

(c.) APD

Has rendered air travel more expensive than UK’s major competitors. It is shrinking demand and encouraging passengers to connect through European points where there is much less or no APD equivalent.

Demand management is a dirty word and is seriously disadvantaging UK aviation and crippling demand.

Baby and bathwater come to mind whereby by attempting to reduce highly price sensitive trafﬁc to holiday destinations by LCC (Low Cost Carriers) it is forcing business and VFR trafﬁc to seek non-British carrier solutions via European points. Even, however a UK carriers are participating in this feeder services ie FlyBe and easyJet by special prorate agreements with foreign carriers. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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(d.) Improving the Passenger Experience This is a key component and centres around two subjects: 1.Delays inbound and outbound at Heathrow, unacceptably high and persistent. This seriously impacting the desirability of using the Heathrow “hub” 2.Inefﬁcient and eccentric quality levels of ground services. IAAG has a detailed plan already published as to how to transform these manifest shortcomings. Please see below how these problems can be resolved in the short term at no cost and with enormous beneﬁts.

(e.) Overall transport Strategy Aviation has become the unwanted toxic chill of Government policy. Little or no co-ordination of overall road, rail sea and air transport policy is being conducted. Policy making is hesitant & piecemeal. Ministries are not competent to deliver the required investments and resultant benefits. This saps confidence in the government when considering the GWR debacle and procrastination and un- deliverability in HS2 and Aviation infrastructure development. IAAG has always tried to establish a multiple transport mode dynamic which is the only approach that will bear fruit. Please see our past and updated papers on this key subject. Strategy must absolutely deliver an acceptable cost/benefit ratio; acceptable ROI’s and incentives for overseas investors which we maintain will be the only source of large scale funding. Government strategy must be to create partnerships with investors, leasing and taking golden shares without tax payers cash which in the aviation context is the only way forward. This provides a much needed participation in a large strategically vital segment of the British economy over which the government has presently no control.

(2.) The best use of existing Airport Capacity The present government has characterised improvement at British airports as “better not bigger”. IAAG’s guidance is “Use what you’ve got” whilst considering expansion of the asset base. Govt’s measures are currently insigniﬁcant. They seem unable to address straightforward issues and ﬁnd solutions.

(a.) What can be done to improve the passenger experience? The most serious shortcoming is the poor on-time record for both arrivals and departures. The most common excuse is that Heathrow is “full” which is incorrect. With the demise of several airlines and the reduction in frequency of several operators there are slots available, prominently those of BMI, inherited in part by BA, which are not being used to reinforce long-haul routes as expected. Liberia and Sri Lanka are not considered critical routes; Leeds and Strasbourg are hardly important routes.However “use it or loose it” is the abiding rule and BA’s Fortress Heathrow policy is designed to minimize competition even in spite of prevalent open- skies policies of most major destinations.Exploitation of open-skies and competitive excellence has created and grown large hubs with fast expanding carriers even though the local population base is tiny. For Example: — Hong Kong and Cathay Paciﬁc pop eight million. — Singapore and Singapore Airlines pop 4.5 million — Dubai and Emirates pop two million. — Amsterdam KLM pop 1.5 million.

(b.) Mixed Mode A dramatic improvement in on-time achievement, major reduction in kerosene burn, reduction in pollution, elimination of stress and cutting crew time and passenger delays can be achieved by the following: — Use both runways when required to cater to diurnal peaking of activity. For example, this means that when there is pressure for long-haul arriving aircraft between 0630 and 0830 both runways can be used for landing. — Similarly from morning peak take-off timings both runways can be used for take-off. This of course does not prevent aircraft landing on one or both r/ways. This is exactly what happens at Gatwick which has only one runway & most other multi-runway airports around the world. However, it is absolutely essential that the government assemble all local stake-holders, HACAN etc and provide a solid pledge that this heightened efﬁciency will not be used to gain extra frequency. Otherwise the process will be stopped in its tracks as in 2009 when BA suggested that this would release extra frequency. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Incomprehensibly BA & BAA are opposed to this process when BA in particular will be able to save millions by drastically reducing fuel burn & other related costs resulting from (i.) Queuing on take-offs on Heathrow congested runways. (ii) Circling/Stacking on landings due congested final approaches to highly congested Heathrow runways which will result in enormous savings on improved Aircraft/Crew Utilisation and on reduced “Delayed Passenger Compensation” ....then progress can be made to regenerate confidence in the airport. IAAG can help in devising a strategy in this respect in dealing with local groups who may be in opposition if inadequate presentation is made. It will help also to assemble exact numbers on what financial savings will be made.

(c.) Operational management As well as mixed mode IAAG proposes that operational management techniques are introduced to allocate targets for performance to all service providers at the airport including the Border Agency to be strictly enforced by the chief executive of the airport. As in Hong Kong, Essential Service Legislation should be introduced to prevent wildcat or unauthorised stoppages in this strategically critical area as is the case in many other airports.

(d.) Improvements outside the South East Several improvements are currently forthcoming, ie runway extensions at Birmingham & other UK Regional Airports largely for the beneﬁt of foreign carriers, especially the long-haul carriers like Emirates, Qatar & Etihad operating very large aircraft (A380s and Boeing 777s) to the fast-emerging markets in the Middle East & the Far East get the beneﬁt of these Runway Extensions NOT the British Carriers as they do not operate from the Midlands, The North & Scotland direct from these UK Regional Airports to these highly- lucrative markets.

(e.) Surface Access Surface access is poor at Heathrow and Stansted resulting in congestion & stress and in the Heathrow case, pollution since 80% of trafﬁc arrives by petrol and diesel burning vehicles. HSR2 will not solve the major problems. Crossrail is eventually able to relieve some congestion and the branch of the GWR.

(3.) Constraints on Increasing UK Aviation Capacity (a.) Impact on the environment Presently the government does not have a viable policy to reduce noise impacts on local populations. In fact the opposite, the refusal to abandon the 3rd runway debate will only severely exacerbate the massive and persistent opposition to government laissez-faire in this respect. Even the European directives demand a reduction in noise and pollution in the Heathrow area. Without mixed mode or draconian measures to reduce frequency and tighten night curfew controls will the Government even begin to demonstrate a sympathetic understanding and corrective measures for adverse environmental impact on local residents and more broadly as much as three million residents under or near the glide path and take off paths of aircraft departing and arriving at Heathrow. The solution proposed by IAAG and also by the Mayor’s team is to design and build a new large hub airport in the Thames Estuary, in IAAG’s case near Cliffe. This is outlined in detail in the submissions which we will attach for your reference and will drastically reduce the impact of noise and chemical pollution on surrounding areas. (b.) Government’s proposals to reduce carbon emissions Only if the Government adopts the mixed mode plan and cap frequency at Heathrow will any progress be made. Converting all service vehicles on the airside of the airport will any impact be made on the level of carbon emissions. Much more important CO2 emissions are toxic chemicals such as sulphur dioxide, nitrous oxide and carbon monoxide all of which can lead to premature death as recently proven in the MIT study published this month Oct 2012. We will examine this important ﬁnding later in our paper. Aviation can be made more sustainable by lifting the burden of escalating APD and other taxes and the threat to include the European directives on carbon emissions to UK carriers. Competitive carriers in other countries are not subjectedto the same level of taxes and consequently UK carriers and UK aviation suffer from diversion of trafﬁc through other points, particularly in continental Europe. Helsinki is now added to the list of Paris-CDG, Frankfurt & Schiphol.

(c.) EU aviation policies There appears to little productive dialogue with the EU in terms of facilitating and protecting UK aviation. Continental EU administration are quite happy to see the discomfort of UK carriers since it continues to enhance the competitive position of their own national carriers. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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(4) Step-Changes in UK Capacity Government policy presently does not include increases in Frequency at S.E. Airports ie Heathrow, Gatwick & Stansted. The 3rd runway will not be built at LHR which adds very little frequency, anyway, on a short runway.

(a) Should there be a new hub airport? Where? IAAG ‘s proposal has always been that plans must be ﬁnalised for a large “hub” airport to be built in the Thames Estuary at Cliffe. Comprehensive supporting document are submitted to explain and emphasise the justiﬁcations in this respect.

(b.) Costs and beneﬁts of increasing UK aviation capacity There is no cost beneﬁt available in the other proposals to consider a 3rd Runway at Heathrow or a large airport on the Isle of Grain or 11miles N.E. of Whitstable in the North Sea. Detailed analysis is contained in the following IAAG’s supporting documents sent to you earlier today (15 October 2012) namely: 16 October 2012

EXECUTIVE SUMMARY OF IAAG SUBMISSIONS—OCTOBER 2012 (a.) General Outline The general outline of events is that the question of capacity at London’s airports has become a hot topic with all shades of professional and lay opinion being expressed. Out of the confusion the following three proposals have been exposed. These are the only proposals to have received serious attention. 1. Third Runway at Heathrow 2. Boris Island either in the North Sea or on the Isle of Grain (Lord Foster and group) 3. The-IAAG proposal, first drafted and publicised widely in the press in April 2009 for an airport at Cliffe. This has been updated regularly and we have submitted these newer versions to you in hardcopy. The foundation for this work was SERAS 2001–2. This in detail recommended that in the absence of extra Runway capacity at Heathrow, Gatwick and Stansted, the Cliffe site on the Hoo peninsula was the favoured and recommended option. This comprehensive and authoritative work was well received by Government and formed the basis of the government White Paper. This is compulsory reading for any study group wishing to formulate conclusion and draft policy. The financial analysis for the Cliffe option is still largely true today and simply needs to be adjusted for inflation. There have been other eccentric contributions which do not deserve serious attention. IAAG’s views on these three proposals are as follows:

(1.) The proposed 3rd Runway at Heathrow This is confronted by serious opposition, political, financial and environmental. It is a short runway costing £7–8 Billion will take Eight years to build and will not attract sufficient funding and does not have a viable ROI or any cost benefit ratios. In our view no more time should be wasted on this consideration which is being propped up by a collection of vested interests which will not carry the day or provide a solution for the deficit in Government policy. This has no accompanying short or medium term solutions and will result in the accelerating decline of aviation activity in the UK. The only beneficiaries in this void of seven–nine years will be filled the continuing expansion of foreign carriers draining UK originating and destination business from domestic points in the UK which BA has abandoned to boost European hubs even further. FLY BE is the main feeder and short haul carrier in the UK and western Europe but has no connecting services into LHR at all. It therfore progressively feeds Continental hubs such as Frankfurt-FRA, Amsterdam- SPL and Paris-CDG Other large Low Cost Carriers (LCCs) such as easyJet and Ryanair have signed commercial agreements (special prorate agreements) with Continental competitor carriers. This further contributes to the decline of Heathrow-LHR and reduction in the number of destinations served. The only solution for a declining LHR is to adopt IAAG’s 3 stage plan and eventually combine BA & FlyBe and even Ryanair and easyJet, (supported by commercial agreements) in one major hub in the Thames Estuary i.e IAAG’s project at Cliffe-LGA the “London Gateway Airport”. IAAG has fully explained all other reasons why this project will never succeed, in hardcopy papers submitted separately.

(2.) “Boris Island” There seems to be a reluctance, deliberate or otherwise to identify the most important feature of a new airport, which is its exact location. The initial selection by Douglas Oakervee of the North Sea location on cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Shimmering Sands is clearly totally unacceptable, too far from population centers 10.5 miles N.E. of Whitstable with no ROI and impossible to finance. We have submitted a hardcopy paper rebutting this absurd initial choice. The Foster proposal which followed for a location at the Isle of Grain involves the following. 1. Demolishing a new power station, a gasification plant, large gas storage containers and an ocean terminal for very large LNG carriers off loading nearby. 2. A town of 7,000 people in Grain who work on these strategically important and sensitive installations is clearly poorly researched and impossible. This would involve the evacuation of the entire town protected by a Health & Safety perimeter. It also does not fit the ICAO and IATA criteria for Airport design. No airport with 4 runways can be built on this site. Minimum runway width and separations are not complied with and will not be allowed 3. The SS Montgomery is in the final glide path and must be avoided since there are 4.000 tons of unexploded ordinance. 4. The London array of wind turbines lies in the approach and will be identified as a hazard. 5. Thamesport lies close to Grain and hosts large container ships arriving at the confluence of the Medway & Thames estuary. 6. Grain is at a dead end served by one of the most dangerous roads leading from Thamesport. Pipelines carrying gas products the length of the South part of the Hoo Peninsula are a hazard for any development of communications 7. Economic geography dictates that any important hub will only grow at the intersection of connecting routes. Grain is the antipathy of this concept, Cliffe fits it exactly 8. There are wildlife issues and the approach will be over the island of Sheppey which has a substantial residential population 9. It is too far from both supporting markets and destinations from labour supply. 10.The cost of building supporting transportation infrastructure will be prohibitive & will never attract public or private investment All of the above 10 reasons are killer-blows in their own right. It is strongly suggested that this project is relegated to the undo-able bin before even more amounts of public or private money is spent needlessly.

(b.) IAAG Proposal This has been extensively described in the four papers mailed to you on 15 October 2012 and is built on the following criteria: 1. Airports must be treated in a similar way to other major infrastructural undertakings. A realistic pay-back period (ROI) and acceptable financial ratios must be justifiable, agreed and sufficient to attract overseas investments, since UK sovereign finance is most unlikely to be forth coming. 2. Connecting surface infrastructure must synchronise easily with the airport location. Larger projects such as the Lower Thames Crossing can be tolled and therefore funded, again from overseas sources. 3. We have described in detail how existing communications by road, rail and sea can be utilised focused on the land hub of Gravesend with onward transmission to the airport services complexes both north and south of the Thames, can be enhanced by relatively inexpensive additions. This is in strong contrast with the Grain project which will cost in excess of £30 billion and will not attract overseas investors nor produce any ROI whatsoever. 4. Please refer to the colour brochure to observe how rail connections from five main rail terminals in London can connect with Gravesend for short onward transmission to the LGA airport seven miles away by local shuttle on the Hong Kong format. Likewise rail connections can be extended through Tilbury and Crossrail extended (which is the intention) though the Lower Thames crossing thus connecting Medway with Essex and Dubai World Container Port. The lower Thames crossing will create great synergies for local regional and airport related travel. This can be funded from overseas since it can be tolled and produce revenue. It will also have a very beneficial effect on relieving congestion at Dartford on the M25 and enable direct connections from the A13 to the A2 and A20. 3. This growing infrastructure must be multi-use directly benefiting local populations and a Logical Hub for distribution by road and rail traffic as well as air routes.” “Use what you’ve got” “and extend and enhance accordingly. 4. Create a dynamic for growth and regeneration on the Dutch Mainport Model ie the “multiplier” effect (i) 5. Investment must create a value-added activity. Simply building housing gives rise to more debt. Job creation must come first. 6. It is essential to create a complete 3-stage plan, short, medium and long-term all of which must fit logically in place and be supported by government and the private sector and public opinion. 7. This has the enormous advantage to government for the following reasons: (a.) It refocuses on the absolute requirement for long-term planning to deliver LONG term benefits breaking the mould of patch, mend and muddle through. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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(b.) It delivers achievable results in the very SHORT term to improve greatly the performance of LHR which has to be used for the next 10—12 years anyway. It will thereby boost confidence in the government, the industry and public opinion. It will in short restore self-respect and demonstrate there is a quick answer to Heathrow’s biggest problems—Delays. (c.) It brings breathing space where additional capacity can be introduced in the medium term at LGW. This will need to be tackled promptly and with diligence. The land is available, the location secure and the finance presumably available through partners and shareholders. Standing in the way is a local agreement not to build before 2019. In the national and local interest it would be sensible to override this undertaking. Having only 1 Runway with in excess of 360,000 movements a year is not “resilient” in the event of any even minor mishap on the main runway which would mean closure of the airport with severe consequences. Thus Gatwick can expand more freely and retake some of the traffic it lost to LHR. LGW could then as it is now re-establish hub status. There is no reason why there should not be more than one hub airport in the South of England as long as viable connecting services grow as a result of sound and profitable commercial airline planning. (i.) http://www.ejtir.tbm.tudelft.nl/issues/2001_02/pdf/2001_02_02.pdf

Short Term (a.) Introduce Mixed-Mode at Heathrow WITHOUT placing additional frequencies. Binding government guarantees must be given to all stakeholders to this effect. The result will be a dramatic improvement in on-time performance for all users with millions of £s savings in fuel, aircraft and crew utilisation and the removal of the most bitter point of contention at Heathrow, ie poor time-keeping. (b.) Introduce essential service legislation (c.) Introduce a system of Operational Management with targets enforceable on all service providers including Border Agency and Security. The above can be explained in detail in the question and answer sessions.

Medium Term (1.) Within five years open a 2nd runway at Gatwick which is fast improving and attracting long-haul and connecting-hub-traffic. Delays will be reduced and runway congestion reduced. Land has been allocated and private funds should be forthcoming. Overdue enhancements to rail and road access can be introduced. (2.) Open Manston for all-cargo services. This has already been done on a limited and temporary basis in the past. Improved surface communications must be established with the main road hubs ie A13, M20 and M25 and with London Gateway Airport, when it is built, Cliffe location will act as a clearance facility for cargoes. Also Dubai World through its logistics centre will be able to distribute and collect cargo and mail and package traffic from all parts of the UK. (3.) Open Northolt for general aviation traffic on a very limited basis thus relieving LHR of congestion of slots.

Long Term Commence immediately detailed costing and research into the Cliffe IAAG Proposal. This is the only realistic, fundable proposition left standing. Before having ﬁnally to commit the government to long-term project, we will have seen real improvements made to LHR and will be progressing in the reshaping and expansion of LGW at no cost to the taxpayer. There is therefore no risk to the national best interest and sensible, informed careful but timely large infrastructural planning can take place.

London Gateway Airport-LGA near Cliffe. The government owns large tracts of the Hoo Peninsula through MOD and PLA. The Church Commissioners are also landowners. This can be consolidated and then offered for lease to sources of investment on long leases thus creating an income stream and an element of control by government which they presently do not enjoy. A “golden-share” in the aggregated investment can encourage both investors and government to work closely together to move the project forward efﬁciently. Healthy interest has been expressed from Middle East sources in what will be an iconic and attractive investment. When the project is completed, it can be opened in stages: London City Airport can be absorbed into LGA, a new 24 hour airport with excellent connections to the City and Canary Wharf through road, rail cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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and Crossrail links. (see the colour brochure). When the new London Gateway Airport (LGA) is completely opened Heathrow will be closed and Heathrow operators invited to relocate to LGA or possibly to Gatwick with a second runway to meet Govt & Industry objective of creating healthy competitions between airports in SE. The site at Heathrow will be opened for development as an ECO City and should realise in excess of £5 billion and provide a large number of jobs for developers at the new site. T5 can be used as a new Earls Court. T4 can be used as a permanent exhibition centre for British Industry with subsidised stands for exhibitors and run by the CBI. Power will be supplied by solar panels and geothermal energy. Blocks will be highrise residential and commercial. Training colleges will be established and educational research and entertainment centers encouraged. Useful transport links can be maintained and hotel accommodation utilised. Extensive water features can easily be designed with the aggregate removed for building requirements. Local transport within the security boundary will be all electric cars, buses and taxis. The model for this bold ECO investment has already been established in several Chinese cities with help from Singapore interests who are respected masters of urban planning. Land values are suggesting that the LHR area would be valued at circa £5 to £6 billion more than any value of the area as an airport. Several potentially interested parties are expressing interest.The main point to be made here is that there would be continuing interest and development available for Heathrow after its substitution as an airport. It would be a wealth generating entity creating many new jobs of all categories and serve as an icon in Europe as a truly ecological and sustainable environment and world leader. Thus, wholesale redevelopment in the Thames Estuary would be matched by an existing project to the west at Heathrow, both equidistant from the new London landmark the “Shard” which itself is close to London Bridge Station which would serve as a collection and dispersal point for all trafﬁc. Both areas should be awarded “Enterprise Zone” status.

(c.) Principals at stake (1.) Without question there is a need for extra runway capacity in the SE of England—now. (2.) Aviation needs however better facilities, better managed and serving the best interests of consumers and providers (airlines). (3) This requires a mix of short term, medium term and long term commitments to be infused now in principal and in practice. The political risks of embracing this strategy are very small and the national interest will be well served with Government taking most of the credit. (4.) IAAG will fully cooperate and assist in advancing the process for everyone’s beneﬁt. (5.) The main events are: (a.) Modernise and improve airports and aviation both in shape size and function. (b.) Create a sustaining dynamic infrastructure based on a new airport in the Thames estuary and a new eco city in the west of London at a newly revitalised Heathrow site. (c.) This will resolve the failed Thames Gateway Project (d.) This will resolve the problem of toxic chemical and noise pollution affecting several million Londoners. This will decongest west and east London two of the most un-resolvable black spots of the UK (e.) It will re- awaken interest in sea and estuary access to the airport both for staff and travelers (see brochure for details) (f.) Decongest Britain’s stumbling and outdated transport system and revitalise commercial and economic interest in building and maintaining the world class facilities it deserves.

(d.) Conclusions These papers and written material have been assembled over a period of 4 years. IAAG has not changed its views over this time having presented to government, public bodies and private institutions. Inﬂation over this period and also since the publication of the SERAS report has been modest. We expect therefore by making generous allowances for mitigation and inﬂation the delivered cost to overseas investors will be circa £12–13 billion. This can be built in 10 years from approval, creating income for the government in partnership with the principal investors. Government’s role is to take early action to embrace the package of measures which only IAAG has been able to assemble. It will be the task of the private sector to deliver and execute to end decades of indecision and procrastination. IAAG remains at the disposal of Parliament to progress these vital issues for the sake of the future of aviation and the national interest. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Written evidence from the Chartered Institute of Logistics and Transport in the UK (AS 23) Summary — International connectivity is the most important benefit of aviation to the UK economy. — Air Passenger Duty is damaging the UK economy and should be reviewed now that the EU ETS includes aviation. — In the longer term, the passenger experience will only be satisfactory if the aviation system operates well within its practical capacity. — Aviation can be aligned with current policies for other modes, in particular for rail. — Best use of existing capacity can be achieved by the removal of barriers which prevent a level playing field and by the application of common standards. This means the removal of price regulation, except at Heathrow, leaving normal competition law to apply, and the recognition that all major airports other than Heathrow can be promoted as ‘National’ airports. — Government policy should always try to seek a balance between the economic benefits and the environmental impacts, both global and local. Growth is the key without which benefits and reduced impacts will not be achieved. — EU aviation policy is generally helpful, with some exceptions. — Rather than a step change, the UK needs a continual growth of aviation capacity to meet its short, medium and long term needs in line with its climate change targets.

Introduction The Chartered Institute of Logistics and Transport in the UK—CILT(UK)—is the professional body for individuals and organisations involved in all aspects of transport and logistics. It has over 19,000 members in numerous disciplines, including the aviation industry and transport planning. As it is not a lobbying organisation it is able to provide a considered and objective response on matters of transport policy. Through its structure of forums and regional groups it provides a network for professionals in the transport industries to debate issues and disseminate good practice. This response has been prepared by the CILT(UK)’s Aviation Forum, the Chairman of which has previously appeared to give evidence to the Select Committee.

Question 1. What should be the objectives of Government policy on Aviation? (a.) How important is International aviation connectivity to the UK aviation industry? (b.) What are the benefits of aviation to the UK economy? International connectivity is one part of the benefits from the airline industry and, for the UK economy, it is the most important one. Connectivity has been crucial to UK business since the Industrial Revolution because of the UK’s geographic position and the need to export in order to achieve continued growth. After the Second World War technological advances in aircraft design progressively raised the profile of air travel as an essential generator of economic growth. It is now crucial both to growth of the economy and to the prosperity of key industries such as financial services, the high tech sector and inbound leisure. The most obvious example of this is at Heathrow where nearly two thirds of passengers are business or inbound leisure and there is ample evidence from numerous studies of the economic benefit from international routes at airports throughout the country. Equally the outbound leisure sector has, over the last 15 years, been radically changed by the “no frills carriers” whose business model is substantially different from both the “legacy carriers” and also the inclusive tour charter airlines (who were the originators of low cost air travel within Europe). The ability of the no frills airlines to set up operating bases at local airports throughout Europe has revolutionised the network of scheduled services to the detriment of both charter and legacy airlines. These networks offer substantially more options for business and leisure travellers to use direct air services from local airports and generate significant employment around many of those UK airports. In addition to being a local employment generator, leisure air services meet the aspirations and expectations of the UK population for worldwide travel, to holiday overseas, visit friends and relatives and attend international sporting events etc. In the earlier days of the low cost carriers there was concern that promotional fares during low season periods (eg 1million tickets at £1) created “unnecessary” and environmentally unfriendly travel. The hike in both fuel prices and APD has largely removed that issue. It should also be emphasised that for legacy carriers the frequency and range of international destinations that is so important to the business sector is normally only possible due to the significant contribution to load factors and revenue from leisure travel. Transfer traffic benefits the UK by making routes viable that would not be so if they relied on point-to- point traffic alone. Transfers have grown steadily as sophisticated yield management systems have enabled airlines to attract non UK passengers, which then benefits the UK economy by ensuring that routes are cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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operated more frequently or to a wider range of destinations. Detailed evidence is given in the Frontier Economics report of September 2011.5

(c.) What is the impact of Air Passenger Duty on the aviation industry? The Institute’s response to the All Party Parliamentary Group on Aviation Competitiveness6 made the following points: — The level of APD is now damaging to the UK economy and the UK airline industry and an unreasonable cost to UK business. — The structure of APD works against establishing business and exports in new markets and emerging economies. — The structure of APD is anomalous and arbitrary. The class bands are economically damaging to UK airlines and the inbound leisure sector, whilst the distance “banding” is quite simply discriminatory. — APD discriminates against travel (particularly business travel) in those areas further away from London and the SE—the more so for the north and Scotland. — APD should be radically reviewed if the EU’s ETS is successful.

(d.) How should improving the passenger experience be reflected in the Government’s aviation strategy? The Government’s South East Airports Taskforce, in examining how the passenger experience at airports could be improved, highlighted some problems under Government control which could benefit of both passengers and airlines—in particular the Border Agency’s staffing of immigration checks and a more holistic approach to security. At Heathrow, the operational freedoms should enable a reduction in delays, although at this time there is little evidence to show how effective NATS has been in making use of this. For many years, passengers have compared their experience at Heathrow unfavourably with modern facilities in the Middle and Far East and, more recently, with new airports are being developed throughout the BRIC nations. Primarily this is due to delays caused by the planning system before Terminal five could be completed, and the knock on delays to passenger terminal redevelopment in the Central Area. The current hiatus affecting any further development strategy for airport development in the South East will inevitably have a similar knock-on impact in years ahead. A longer term strategy is essential to safeguarding the passenger experience in future years.

(e.) Where does aviation fit in with the overall transport strategy? It is questionable whether an overall transport strategy exists, but the objective is clearly to deal with congestion which is inhibiting economic growth. The combination of current policies for various modes could, however, be considered as an overall strategy. Aviation strategy should be aligned with these other modal strategies under an overall objective of transport to support sustainable economic growth and contribute to social welfare. The relationship of aviation to the road strategy is relatively straightforward. There is now only limited new road building, and the emphasis is on better use of existing roads through management, the continuing drive to improve safety and environmental improvements. This means that airport development should be located in places where the existing roads can be adapted to accommodate growth, which in some cases this will mean road capacity increases. In the longer term, the method of payment for roads will have to change with the reduction in fuel duty revenue, and new payment methods will better reflect the benefit obtained. It is likely that airport road access will be valued more than many other road trips, which will enable airport road access achieve an appropriate priority. Complementary rail strategies are critical to the development of aviation. The UK led the way in establishing rail access to airports, but some current trends are resulting in a deterioration in the relationship. Gatwick and Stansted Airports once had, and Heathrow still has, successful dedicated express rail services which segmented the market, provided excellent service and brought in premium revenue. Although such services are highly efficient in terms of all day usage, at peak hours they are seen to have spare capacity when commuter services are full. This capacity has then been reallocated to commuter services and the effect has been, and will increasingly be, to make the services less attractive to air passengers. This will reduce overall rail mode share at airports, re-introduce the conflict between air passengers and commuters, reduce rail revenue (because passengers will not pay a premium fare for a non premium service) and inhibit the growth of these airports. Non dedicated rail services operate satisfactorily as a complement to the dedicated services at the large airports (eg. the Piccadilly Line to Heathrow). At smaller airports, or outside the London area where rail commuting is not so significant, non dedicated services can provide a satisfactory airport link. 5 Connecting for growth: the role of Britain's hub airport in economic recovery, Frontier Economics, September 2011 6 Submission by the Chartered Institute of Logistics and Transport in the UK to the All Party Parliamentary Group on Aviation Inquiry into Maintaining the Competitiveness of UK Global Aviation, 15 May 2012 cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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The strategy for HS2 should also be consistent with aviation policy. Ideally, airports should be served by High Speed Lines but the benefits to air passengers are limited, and may not sufficient to overcome the costs and time disbenefits to non air passengers. Thus the Birmingham International Station on HS2 is appropriate because it does not require a significant time penalty and also serves other markets in the West Midlands, but it will be difficult to justify a spur to Heathrow. CILT’s study of the Transport Use of Carbon7 shows that rail generally uses less carbon than air travel, but this is critically dependent on the decarbonisation of electricity and there are plenty of examples of sustainable short haul air travel. Passengers will also benefit if air services are not prevented from competing with rail. It is also clear that high speed rail will not substitute for air travel to an extent that would significantly reduce the need for additional airport capacity. Local transport strategies are generally well aligned with aviation strategies. Airports were among the first organisations to develop travel plans for their employees and there are numerous examples of local bus marketing support, car sharing, cycle initiatives and other sustainable transport activities, involving many local stakeholders and organised through Airport Transport Forums. It is legitimate for policy to require the aviation industry to contribute to the cost of a surface access improvement to the extent that it benefits, although an airport is a part of the transport network and not the same as a commercial developer. Neither should this be an excuse for Government to abrogate responsibility for the provision of transport improvements where these benefit the wider population, but happen to also serve an airport.

Question 2. How should we make the best use of existing aviation capacity? (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? Essentially, we should let the market operate, with competition where possible and a level playing field and impose restrictions only where necessary to ensure that community impacts and benefits are balanced. After the sale of Stansted by BAA, all the London airports will be in separate ownership (with the exception of Gatwick and London City having a degree of common ownership). It is difficult for airlines to obtain new slots at Heathrow, but there are slots available elsewhere, and different types of airport facilities are available in different locations in the South East. This means that passengers also will have a choice of airlines and types of service which leads to better passenger experience and competitive price. With separate ownership, there is no theoretical reason for price regulation at any of the airports. However, Heathrow holds a unique position in the UK in terms of the long term shortage of capacity, its unique role as an international transfer hub (where it competes with other major European hubs) and its proximity to the high yield passenger market in London for which there is limited competition with London City). Years of price regulation with a shortage or runway capacity has distorted demand and led to a grey market in slots. Equally there is no evidence that airlines have chosen not to operate from other London airports because of the lack of price differentials. On balance, we are in favour of ending specific price regulation at Gatwick and Stansted, noting that all airports are subject to normal competition law. In the case of Heathrow it is difficult to see how the removal of price regulation would be generally acceptable. However it is evident that the single till approach is now counterproductive (and there is also little to commend a dual till approach). The CAA needs to develop a more constructive approach which puts customer experience in a more central position. In terms of other regulations, we would support the extension of fifth freedom policy to all London airports other than Heathrow, on the grounds that it would enable all these airports to compete for new services. But we would not expect it to generate much in the way of additional flights. To ensure the balance of benefits with impacts, we support the application of common standards in terms of noise and other local impacts. It is quite clear that Heathrow’s noise impact is very much greater than that of other London airports, but it is possible to relate this to the benefits to give a benefit/impact ratio. This will then provide guidance towards how much mitigation is appropriate and, more significantly, will enable an evidence based comparison of alternatives for expanding capacity.

(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? There are few restrictions on the use of airports outside the South East but, if any restrictions do arise which are stopping the introduction of new routes, such as the necessity of achieving bilateral agreement, they could be removed on a case by case basis. We would agree that the distinction made in the past between the South East and the rest of the UK has not been helpful. We would instead suggest that, for the short and medium term, all of the UK’s airports which can accommodate long haul international ﬂights should be designated as ‘National Airports’ which would then 7 Transport Use of Carbon, CILT, November 2011 cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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enable them to be promoted around the world (eg. at airline scheduling events, or as part of trade missions) as gateways to the UK. This would mean that the situation is actively managed rather than simply waiting for the commercial decisions of airlines. Heathrow would, in practical terms, be the exception to this designation because it is effectively full and therefore is only be available for new services if slots can be acquired at excessive cost.

(c.) How can surface access to airports be improved? As noted in our answer to Question 1e, aviation is a transport mode and should not be treated as simply a commercial developer required to fund transport improvements. While it is legitimate to seek contributions to transport improvements associated with airport expansion, such contributions should be related to the beneﬁts received. We would also wish to repeat the point made in answer to Question 1e that degrading dedicated airport rail services will reduce the attractiveness of rail as an airport access mode, re-create the conﬂicts between airport and non airport passengers that were the reason for introducing dedicated services, reduce revenue to Government and constrain the growth of airports. Where airports are growing, it then becomes possible to justify surface access improvements. For example, if Heathrow grows, a western rail link at Heathrow would provide a welcome addition to the airport’s rail catchment area provided it can be cost effective. Similarly, a HS2 link, initially via Old Oak Common and ultimately by a direct route, will provide a choice for journeys currently made by road. A HS2 station linked to a growing Birmingham Airport and, possibly in Phase 2, to Manchester Airport, would provide passengers with a greater choice through better accessibility.

Question 3. What constraints are there on increasing UK aviation capacity? (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? Government should always seek a balance of impacts and beneﬁts, so the reference in the Draft Aviation Policy Framework to the balanced approach is absolutely correct.

There are several ways of measuring aviation noise, but the 57 dB LAeq16h contour has the merit of being consistently measured across many airports over a long time, and should be retained. When considering expansion, alternatives should be compared in terms of the absolute numbers of people affected, the change over time, the change resulting from the expansion and the addition or reduction of noise impact over particular communities.

(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? CILT supports the policy objective as set out in the Draft Aviation Policy Framework (paragraph 3.4). The Committee on Climate Change indicated that UK aviation can both grow and reduce carbon emissions signiﬁcantly to achieve the UK carbon targets. CILT supports the inclusion of aviation in the EU Emissions Trading Scheme as an interim measure pending a world wide scheme implemented through ICAO. We also support the other measures outlined in Chapter 3 of the Draft Aviation Policy Framework, noting that they are all fully supported by the aviation industry through the Sustainable Aviation Group. Evidence from the US shows that, unless the industry is ﬁnancially sound and growing, there will not be investment in new, more technologically advanced, aircraft.

(c.) What is the relationship between the Government’s strategy and EU aviation policies? The relevant EU policies include those relating to airspace, emissions trading, noise mapping, slot regulation, competition, bilateral agreements and passenger rights. In most cases, UK Government policy is aligned with these although there are examples where other EU countries do not appear to have the same enthusiasm for full implementation as the UK (eg. noise mapping). There are also examples where the EU seeks to resolve issues in some countries which are not a problem in the UK where competition is generally stronger (eg ground handling). In general terms EU aviation policy does not act as a constraint on increasing UK aviation capacity. It could be argued that EU policy encourages more growth than does the UK, as is evidenced by the faster growth rates achieved at many EU non UK airports. EU airspace policies such as the Single European Sky are particularly helpful in seeking to enable the sustainable growth of aviation, albeit they are very slow in being implemented.

Question 4. 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? (b.) What are the costs and beneﬁts of these different ways to increase UK aviation capacity? Since the 1960’s aviation policy has developed and been liberalised . Progressively from the early 1980’s the tight noose on the airports outside the London area—rigid Treasury controls on investment; the “Gateway” designation for long haul routes; rigid bilateral air service agreements, and Fifth Freedom restrictions on both cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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cargo and then passenger services—have been removed. The London area Trafﬁc Distribution Rules were removed more than 20 years ago.

However, expansion of airport runway capacity in the South East has fallen foul of successive governments— the reversal of projects to develop incrementally a four runway airport at Stansted, Cublington (which came out of the Roskill Commission), Foulness (advocated by one member of the Roskill Commission), the decision to shelve RUCATSE conclusions and ﬁnally the current administration’s reversal of the 2003 Aviation White Paper strategy.

Recent debate has been about a “hub airport for London”—this is an international transfer hub and is different to the “hub and spoke” model for domestic trafﬁc so popular in the US. Over the last 20 years there has been a growing impetus in the number and size of international transfer hubs throughout the world. With the exception of those in the Emirates, this has been stimulated by the strength of the three main airline alliances.

Heathrow is now the only transfer hub airport in the country but its traffic mix is complex. Around 36% of Heathrow’s passengers were transfer journeys with a third not on British Airways. The closure of BMI will reduce non British Airways transfer journeys and has raised serious questions about the Star Alliance’s ambitions to build a competing transfer hub using the new Terminal two. Virgin Atlantic is trying to establish some domestic flights to replace feed lost from BMI. On the other hand British Airways now has sufficient new slots to handle its medium term ambitions—in any case over the last two years BA’s commercial priority has been to start additional European routes (ie Paris Orly, Gothenburg and Bologna) rather than new destinations in the BRIC countries.

The group of airlines which have least opportunity to expand ﬂights or start services into Heathrow are long haul carriers who either are not in alliances or are not leading members. These airlines cannot afford the inﬂated price for such slots that become available at Heathrow. One or two have begun to use Gatwick but it is the failure to provide capacity for these airlines which is also reducing connectivity out of London.

Although there are examples around the world of cities with several airports (New York, Moscow), none of these are multiple transfer hubs. Like the airports serving London, each airport serves a particular market segment.

Turning to the “No Frills Airlines”, recession and the combination of escalating fuel prices and APD has signiﬁcantly reduced short break travel volumes and this looks likely to result in an adjustment to medium term demand for airport capacity in the South East.

All this raises the question of whether there is a real case for a “step change”. Since RUCATSE CILT has consistently supported the development of a third runway at Heathrow, but it has to be recognised that the political will to deliver that is now uncertain to say the least.

The need for additional airport capacity exists in the short term and will continue in the long term. Rather than a step change, we need a continual growth in capacity, to match the demand that the Committee on Climate Change says is compatible with the UK’s carbon targets. Any airport should be permitted to grow, within this overall limit and within local limits determined by whether the balance of benefits and local impacts. This implies that Heathrow should be maintained as the UK’s hub with additional capacity permitted only if the significant local environmental impacts, in particular noise, can be addressed. Additional runway capacity at Gatwick and Stansted may also be justified in due course. At the other ‘national’ airports, additional capacity should be permitted, again within the overall CCC limit and in accordance with the local benefit/impact balance.

Allowing existing airports to expand will mean that the private sector will meet the entire costs of the expansion programme. Airports are all commercially operated and their income is from airlines and the passengers they serve, with no public subsidy.

The alternative proposed for a hub airport in the Thames Estuary has the potential to deliver a “World Class” facility when compared with capital cities with super-airports elsewhere. However, it raises many unanswered issues although there can be no doubt that it is technically achievable. These issues include the routes and costs of fast road and rail links to Central London; a rail terminus that has connections to distribute passengers around Central London; similar links to main catchment areas in the Home Counties; air traffic control conflicts internationally and with other London airports; the availability of sufficient public finance; risks from migrating wild fowl, and the massive scale of support infrastructure.

Perhaps the most unquantiﬁable risk concerns the inevitable closure of Heathrow which will be necessary to give any hope of a ﬁnancial case for an estuarial airport. With so many businesses located to the west of London and the Thames Valley because of global connectivity there has to be uncertainty over how many will relocate premises and staff to the east of London or will they simply move to other centres in Europe. 16 October 2012 cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Written evidence from Dr William D Lowe (AS24) 1. The following is a personal and individual submission dealing primarily with making better use of existing aviation capacity at Heathrow and the reduction of some of the constraints on expansion of capacity, in particular noise and oxides of nitrogen. 2. The author has a Degree in Engineering, PhD in Applied Science and Honorary Doctorates from the University of Birmingham and London City for services to aviation. He was Director of Flight Operations for British Airways for five years and Chairman of the UK Flight Operations Director Group. He has served as President of the Royal Aeronautical Society and Master of the Guild of Air Pilots. He is a non-executive Director of Regional Airports Ltd and a Trustee of CHIRP. In addition to being a Concorde Pilot for 25 years, he was also Commercial Manager responsible for Concorde profitability within British Airways. 3. The submission suggests: (a.) Doubling the capacity of Heathrow without building a new runway. (b.) A means of reducing dramatically the noise footprint of aircraft arriving and departing from Heathrow. (c.) A method to reduce the concentration of the oxides of nitrogen in the north-eastern corner of the Heathrow runway and road complex. 4. The suggestions on capacity and noise can all be adopted separately but clearly provide the maximum benefit in terms of aircraft movements and noise reduction if applied together.

5. Doubling Heathrow Runway Capacity without a New Runway The two existing runways at Heathrow are longer than and twice as wide as required. By extending both existing runways to the west, towards but not as far as the M25, the length of both runways can be 20,000ft or more. This would allow the simultaneous use of each runway, the first part being used for landing whilst, at the same time, the second part is used for take-offs. 6. The four segments of the runways can be of different lengths to accommodate varying aircraft requirements and a large section in the middle will be the “safe zone”, to accommodate over-runs etc. Further amelioration of safety concerns can be introduced such as using the left side of the runway for landing and the right side for take-offs, high speed turn-offs and operational procedures. 7. The significant increase in landing and take-off slots will provide expansion for decades to come and, for some considerable time, will provide operational flexibility to allow non-mixed mode for periods of the day which will provide some noise relief. 8. One further advantage would be available for the early morning arrival bulge. As there are no departures, the second part of the runway could be used for landings. This would serve to further reduce the arrival noise footprint at a troublesome time by moving it westwards for the majority of arrivals. 9. There do not appear to be any regulations which would preclude the adoption of this suggestion.

10. Reduction of Noise Footprint This suggestion is not new but does not appear to have been adequately assessed. It involves a number of elements. 11. Firstly, the intermediate approach height of aircraft into Heathrow currently has a base of 4,000ft. This can be raised to approximately 7,000ft. This alone will reduce the noise levels for a large part of London. 12. The approach slope to Heathrow can then be divided into two segments. The first, steeper segment, will start at 7,000ft and be at approximately five or six degrees as opposed to the current three degrees. 13. The steeper slope will translate into a normal three degree slope at approximately 1,500ft. This gradual transition will ensure that the stabilised approach gate required by many airlines at 1,000ft will be achieved. 14. In this respect, this procedure is fundamentally different from that adopted at London City Airport where approaches of five and a half degrees are flown down to ground level. 15. This will mean that the aircraft engines will be close to idle power and by changing the operating procedures, the drag features of the aircraft can be spoilers/speed brakes which are located on the top side of the wing which reflects the noise upwards, rather than large flap settings and undercarriages which send noise downwards. 16. This should preferably be an autopilot flown procedure although this is not essential. 17. Additional electronic guidance will need to be provided, using microwave landing systems (already installed at Heathrow) and/or GPS. 18. For a number of reasons, overall safety levels will be improved by the adoption of this procedure, in addition to the reduction in noise. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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19. Modern guidance systems, such as MLS or GPS allow curved approaches to be flown although they are more difficult to integrate into the long established air traffic control procedures. By adopting the use of curved lateral approaches with the two segment vertical approaches, further noise mitigation can be achieved. 20. Once the intermediate approach height is raised for approaches, steeper initial climb-outs are also possible. This, too, would also significantly reduce noise, except for those under the immediate take-off path (1–2 miles from the airport).

21 Reduction of Oxides of Nitrogen in the North-East Corner of Heathrow One significant constraint on the increase in movement rate of aircraft at Heathrow is the recorded level of the various oxides of nitrogen, particularly in the north-eastern corner of the airport. 22. This build up is caused by the road use and emissions of aircraft on take-off. The problem is primarily in existence in the presence of the prevailing south-westerly wind. 23. The road traffic emissions can be reduced by the use of electric airport vehicles and the exclusion of some high emission diesel vehicles from the road system. 24. The bulk of the aircraft emissions could be channelled by the prevailing wind through ducts located at a safe distance from the side of the runway but within the airport boundary. The normal venturi effect should be adequate but, if not, fans such as those present in road tunnels could be used to augment the wind flow. 25. Most of the oxides are heavier than air and so lend themselves to this solution. 26. Once channelled through the ducts, extraction of the oxides of nitrogen is a relatively cheap and easy process using water scrubbing or ammonia extraction. 16 October 2012

Written evidence from Mr John G Miller (AS 27) PROPOSED CLOSURE OF FILTON AIRFIELD 1. Possible relief to S.E. England airports runway congestion. 2. Resulting loss of existing Facility. (1.a) The runway at Filton Airfield is one of the largest in the country. And is one of only three that can handle the A380 aircraft. Which would be a valuable asset in an emergency. (b.) Although regular scheduled passenger flights are not allowable on the airfield. It is fully capable of handling any of todays aircraft. (c.) Has CAA Licence and still has flight handling capability in place. Eg. Flight Control. (d.) Is adjacent to motorways and rail. Giving good access to all parts of UK. (e.) Would provide good capability for most ‘freight only’, that is currently handled by S.E. Airports. (f.) Fleet maintenance and any other aircraft maintenance could be handled. (g.) The Airbus company scheduled flights (to other company sites) can continue. (h.) Airbus components can be flown to other sights, as at present. (i.) Current emergency helicopter services can continue. (Police and Air Ambulance) (2.a) The Airfield is an integral part of the only remaining facility in the U.K. with the capability to Design, Develop, Manufacture, Maintain, Flight Test and Development, of Civil Aircraft. This would no longer be the case if the airfield closed. And although not currently utilised in this manner, the potential should remain, otherwise it is the case that this country will never again engage in full aircraft assembly of civil aircraft.

Recommendations. This airﬁeld must remain operational. AndBAESystems must be directed to not carry out their intentions at the end of the year. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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A negotiated purchase should be made by use of a 10 year Public Works type Loan with first two year interest roll-up. A Management Group of suitably experienced persons set up, with a mandate to operate and develop the airfield business. With a view to selling the business on in five years. 17 October 2012

Written evidence from the West Windsor Residents Association (AS 28) 1. Aviation Strategy (a.) West Windsor Residents Association represents more than 1000 households in the Royal Borough of Windsor & Maidenhead. Our members include many people who are currently employed, or have worked in the airline industry over the past six decades. They also have experience of living under a ﬂight path into Heathrow, where there is often no respite from aircraft noise between 4am and 11pm. Thus, we not only understand the adverse impact that the aviation industry has on our environment but also the service it offers and its positive impact on the economy. (b.) Many of our members have a good working knowledge of the functioning of airline operations, including ﬂight operations, aircraft and crew scheduling, maintenance and ground operations, passenger service, security and catering. We also have two chartered civil engineers on our committee. (c.) We do not have access to current data that is available to larger organisations, particularly airport authorities and airlines. However, we can bring to any discussion related to expansion of airport capacity, not only non-politicised common sense, but a wealth of experience. (d.) Capacity, connectivity and competition are three key issues that have to be addressed when considering the strategic needs of the aviation industry and the U.K economy. Within this context, the provision of good levels of service, security and safety have to be addressed and the potential environmental impact has to be considered. All too often opinions are expressed without adequate consideration of this range of issues.

2. Capacity (a.) The capacity limitations of airports are generally expressed in terms of the number of air transport movements (atms) per annum. However the key consideration is the capacity to handle the number of movements scheduled during peak periods. These often last for two hour periods or more and may be caused by the terminal and ground service limitations, runway capacity or the surface access to airport facilities. A key factor is often the scale of a hub operation. (b.) At Heathrow, for example, there appears to be ample terminal capacity planned but both runway capacity, surface access and support services are lacking. During periods of major disruptions, all the local hotels have often been full and passengers left to fend for themselves. Trafﬁc bottlenecks on the M25 around Heathrow also have a signiﬁcant impact.

The Hub Operation (c.) It is easy to understand the attraction of the hub operation to the airlines. It facilitates the concentration of resources, aircraft and crew scheduling and permits greater control of fare structures for an airline whose operation dominates at a given hub. However it contributes significantly to the creation of peak periods, and, when taken to excess, imposes considerable stress on air traffic control, security and the ability to handle off schedule operations (d.) Passengers normally want to travel directly from one point to another. If not, they want as rapid a connection as possible. Taken together with the fact that there have always been certain hours that are the most popular and convenient on given routes, the demand to operate during those times can readily exceed capacity. Passengers that transit on the same aircraft are not a problem but if they need to transfer from one aircraft to another or between airlines they add to the general congestion. (e.) Hubs are said to enable the operation of routes at a frequency that would not be feasible without accommodating transfer passengers. That is true but when this becomes excessive at an airport that is already operating at or near peak capacity, they inhibit optimum use of that airport to provide proper connectivity. An example that should be considered is the 9000 flights per annum from Heathrow to New York. (f.) In 2009 nearly 38% of the passengers using Heathrow were transfer passengers. They appear to contribute little or nothing to the U.K economy. (g.) We suggest that the Committee would be helped by an update to the 2003 Mott MacDonald report on Key European Hubs.

3. Connectivity (a.) The important consideration here is the degree of connectivity between cities rather than the connectivity to given airports. London, for example, is served by three major airports Heathrow, Gatwick and Stansted as cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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well as two other very significant airports, London City and Luton, all of which are suitable for regular scheduled service. Others, such as Manston are completely underutilised in large part because of the lack of good surface access. (b.) There is considerable debate about the provision of High Speed Rail and, properly planned, it will relieve some of the domestic demand for air travel, albeit only 7% to 8% of the passengers arriving at Heathrow are using domestic flights. Consideration should be given to the probability that the considerable pressure for these rail services to concentrate on Heathrow will only cause the airlines to seek to use Heathrow for even more international services. Thus, no relief to the congestion at Heathrow is likely to be achieved and the potential adverse impact of this on airports serving Birmingham, Manchester and Edinburgh needs to be considered, given their vital roles in developing the regional economies. (c.) Consideration should be given to connecting Heathrow, Stansted and Gatwick by using existing rail networks or new ones to connect to CrossRail rather than expensive tunnels between Gatwick and Heathrow. Equally, Gatwick could possibly provide a good connection to Eurostar through Ebbsfleet. (d.) In this manner, the airports serving London would become the hub for the U.K and would seem to provide the possibility of better connectivity that that provided to Paris through Orly and Charles de Gaulle or to New York through Kennedy Newark and La Guardia. (e.) Stansted, apart from serving London appears to offer excellent access to the Midlands. This must surely be an important consideration in any attempt to seek balance to the development of the U.K economy.

4. Competition (a.) If we are to expect airlines to cooperate in reallocating the use of the available airport capacity, more must be done to allow key airports to operate in an even manner. Airlines will not willingly move away from Heathrow, unless the alternative airport offers the possibility of an equal or better operation than that afforded at Heathrow. Their cooperation is needed because, apart from other considerations, the outdated slot allocation system together with the “grandfather” rights gives them the right to remain. (b.) One of the key attractions of Heathrow has been the extent to which Fifth Freedom rights have been granted to routes through Heathrow which permits foreign carriers to compete on more even terms with U.K. Based carriers. To date those rights have not been available on routes operated through Gatwick and Stansted. Equally, if other airports are to be used to relieve the pressure on Heathrow by attracting airlines to use them they must be accorded equal consideration in terms of surface access and all other facilities.

Available Alternative Airports (c.) Heathrow is clearly the airport of choice for airlines serving the U.K but it is at full capacity. There is a considerable possibility that it could be used more efficiently, particularly in view of the fact that, to make the routes served viable, it needs more than 37% of transfer passengers to support the frequency of those routes and as previously noted those transfer passengers are of little or no benefit to the economy and exacerbate the problems of the “peak” periods. It is possible that the available capacity of Heathrow is excessively committed to leisure travel, which currently has a negative impact on the U.K. Balance of payments. (d.) There has been renewed lobbying for a third runway at Heathrow. Apart from the numerous environmental problems this would cause, it would seem ridiculous to consider a developing an airport with an operation such as that at Heathrow with a very busy trunk road running through the middle as well as numerous hotels situated between two busy runways. Also a commitment to the further expansion of Heathrow would generate the need for a fourth runway, which would result in a second trunk road between two runways. This and the increased need for further hotel as well as the impact on other services, schools, housing, transport etc. should exclude such an idea from serious consideration. (e.) The United Kingdom is unique in the developed world in the number of its major or significant airports are limited to a single runway. Gatwick is prevented from building a second runway until 2019 but surely it is time to start planning for one now. The same applies to Stansted. Both airports can accommodate a second runway with considerably less adverse impact on the environment than other options. Improved access can readily be provided, to permit them to offer a considerably better service to London than is currently available. (f.) The runway at Luton needs to be extended together with additional taxiways in order to extend flexibility to its utilisation. Manston is another airport that should be considered for development. It has one of the longest runways in the country and much of the approach to Manston is over the sea. Its final approach is over Ramsgate but there is space to extend the runway to the west, which would allow that approach to clear Ramsgate at a higher altitude. Its other major problem is poor surface access which would need to be addressed. Lyneham, also, is deserving of consideration in view of the improved rail service serving London from the west. (g.) Before leaving this subject it is necessary to address the proposals to build a new airport east of London. Fifty years ago this seemed feasible and might have prevented many of the present day problems. Now it appears too costly both in terms of building the airport itself, providing the necessary infrastructure to support it and addressing the problems and costs in making such a move. The risk of adverse impact on Heathrow and the Thames Valley economy would be a major consideration. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Utilisation of the available airports (h.) Although there is considerable conjecture on the rate that aviation needs will increase there is less information as to the form that increase might take. The rate at which “full service, low cost/no frills” and “charter” flights might increase relative to each other would have a significant impact on how the various airports should be used to accommodate flying in the future. (i.) One might reasonably assume there will be more demand from the full service passenger for more convenient point to point routes particularly with new aircraft such as the 787 to fly further. Leisure travel from China and other developing countries will undoubtedly increase and do something to balance the leisure travel economy (j.) Equally an important consideration will be the extent that routes at a given airport are operated by an airline based at that airport vs. airlines operating into or out of that airport from a base situation elsewhere. (k.) At first sight it would appear logical to consider Heathrow and Gatwick to predominate in the long haul intercontinental market and Stansted to be the main hub for low cost operations. (l.) The roles of Manchester, Birmingham and Edinburgh will largely depend upon how the economies in those areas develop for which we have little information.

Air Traffic Control (m.) Regardless of how it is considered desirable to distribute the increase in anticipated aviation activity, it will be necessary to insure proper coordination with the various air traffic control functions in order to avoid conflict with existing procedures,

5. Environment Air Pollution (a.) It appears obvious that the aviation industry will not be able to meet WHO guidelines in the foreseeable future and the short fall must, therefore be taken from other industries. We have no expertise to comment further.

Disturbance Related to Aircraft Noise (b.) The problem in addressing this concern is that the attempts are being made with no commitment to properly understand it. It has been clear for at least twenty years that averaging noise energy levels, which is based on research conducted more than thirty years ago, no longer properly reflects the level of disturbance. Abandoning the ANASE report, for all its shortcomings, reflected the lack of commitment to do achieve full understanding. (c.) With that in mind, the only reliable noise abatement measure that can be consistently relied upon is runway alternation as currently practised for easterly landing at Heathrow. Consideration of runway alternation should be a standard at all two runway airports and capacity limited accordingly. This provides scheduled periods of relief. Also the alternation of runway use for night flying as practised at Heathrow should be adopted as standard. (d.) The lack of awareness of the importance of scheduled relief is demonstrated by the failure to inject any urgency into doing the necessary work on Heathrow taxiways and hard standing which would permit runway alternation on easterly landings. It is now nearly four years since the Cranford Agreement was abolished and little or no progress appears to have been made. (e.) There is no valid reason for continuing to ignore actual noise measurements for landing aircraft and noise limits should be introduced similar to those applied to take offs with appropriate penalties. The noise disturbance caused by landing aircraft has become of increasing concern.

Night Flying (f.) Considering that we believe that more long haul point to point routes are both necessary and desirable and considering the varying time clocks around the world, there will no doubt be demand for some night landings. However, it the current frequency of night flights appears excessive and we believe that such flights should be allowed only after stringent reviews of the necessity of each flight. There should also be restrictions requiring the use of the quietest aircraft. (g.) Finally serious consideration should be given to adopting European Time as standard in order to avoid the excessive problem of early morning arrivals currently experienced between 0600/0700. 17 October 2012 cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Written evidence from Bluespace Thinking Ltd (AS 29) Bluespace Thinking Ltd have no commercial interest in aviation and are not located near or impacted by any airport. Our objective in submitting evidence is solely to provoke objective thought and hopefully help improve Government and parliamentary decisions.

1. Summary 1.1 Currently there is spare capacity at Stansted and Gatwick also Heathrow is 5–6% below its previous peak demand level. It is possible to get a flight the next day to and from London to virtually anywhere in the world, if booked further in advance air fares are competitive, cheaper than rail and road and many are less than the cost of a taxi to the airport or car park fees. 1.2 Public transport to and from the principle areas of passenger usage (London and the South East) is not particularly good. For many people the duration of travel to the airport, security checks, check in or bag drop off times and immigration checks take longer than the flight. 1.3 The majority of passengers at the airports are travelling for leisure, any major increase in demand will therefore lag not lead an economic recovery. 1.4 The key question being asked by politicians and the public is whether a third runway at Heathrow, a new Thames airport or expansion at Stansted, Gatwick and the smaller airports are the most appropriate solution to the need for increased airport capacity over the next 20 years. 1.5 Our analysis shows that extension of Stansted, Gatwick and the smaller airports is a viable solution. The DfT Draft Aviation Policy Framework July 2012 [1] along with a short visit to the relevant locations provides compelling evidence that the social impact of noise at Heathrow should preclude its further expansion. The analysis of DfT and CAA data shows that there is no economic benefit in trying to extend Heathrow hub services 1.6 A new major hub airport in the Thames or elsewhere at a cost of about £50 billion is unnecessary and would be uneconomic however additional capacity equivalent to Heathrow will probably be required in 20–25 years time so if a major new airport is not built significant expansion at Gatwick, Stansted and the smaller airports along with larger aircraft and more direct flights (less hub services) will be required.

2. Bluespace Thinking Analysis 2.1 The key to deciding how to provide additional airport capacity in London and the South East is to analyze and understand the passenger markets. DfT segment the markets into Domestic/International, Leisure/ Business, UK/Foreign residence, regional destination and market maturity. 2.2 DfT reports [2] have been aimed primarily at predicting overall future growth however the key to deciding if a major new hub airport or the expansion of Heathrow is required is to segment and analyze the markets based on whether passengers have a London/SE origin or destination or whether they are “domestic” or “international to international” hub transfer passengers.

3. Understanding the markets 3.1 The graph shows the growth of these markets over the last 40 years. The data comes from the CAA airport surveys [3], which along with CAA reports and commentary and DfT forecasts and studies provide a good evidence base for understanding the market. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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3.2 Based on what has “actually happened”, as opposed to a narrative interpretation, the graph shows that while the origin/destination market is growing the hub/transfer market is not.

4. Key Past Events 4.1 Between 1972 and 1990 there is limited publically available data, it has been necessary to interpolate between the available data points. The increase in growth starting in 1992 is as a result of EU deregulation of the air industry enabling the emergence of lower cost direct routes. The dip in 2001 is as a result of the events of 11 Sept 2001. The decline from 2007 is in part due to the economic situation but appears to start a year or more before the recognized economic slump. The ﬁgures for 2010 are depressed due to the Icelandic volcano, without this a recovery from 2009 would be more evident. Preliminary part year 2012 data suggests a further 1% increase in total numbers.

5. London & SE Airports Origin and Destination Passengers 5.1 Due to the “events” since 2001 it is not possible to predict deterministically the rate of growth that will occur as GDP eventually starts to improve. It is however logical that it will increase at between 2–4%/year due to a combination of population increase and more disposable income for holidays and trips. 5.2 The majority of these journeys through the airports are for leisure by those in the 20–55 age band living in Greater London. At some point the amount of time this working age group has available for leisure purposes will restrict the growth however if it were to continue for 20 years it could add about 60 million passengers. Business travel may re start to grow or may be curtailed by the further use of information and communication technologies however this will not make a signiﬁcant impact to the level of overall growth.

6. Hub Transfer Passengers 6.1 This market shows a very different trend, although passenger numbers grew between 1992 and 1997 as a result of deregulation, from 1998 there is a picture of classic market maturity, saturation and decline. As European, world and UK regional economies grow it is logical that there are more direct flights between locations and in a relatively mature market, as in the UK and Europe, London Hub transfer passenger numbers would stay flat or decline irrespective of the capacity available. 6.2 DfT analysis carried out in 2009 shows this clearly; the detailed work shows that domestic transfer passengers at airports in the UK are predicted to decline by about 60% by 2030. Although one could carry out more detailed analysis it is unlikely an accurate deterministic prediction could be established. Given the past trend it is probable that the total hub transfer market will decline in the range of zero to -2%/year. Probabilistically over the next 20 years this could decrease the London Hub market by about eight million passengers/year. 6.3 London has been the major hub location for European flights to North America as it lies on the shortest great circle route to many European destinations. However for Far and Middle East routes German hubs are much better located. For passengers from Scandinavia and mainland Europe their journey would be significantly longer if they were to route through London. Geographic location will work against London capturing a larger share of a declining hub market but this is not the same as London capturing further business opportunities by cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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having an airport infrastructure plan that substantially improves journey times, passenger experience and available capacity, from journey origin to destination.

7. Economic Value of Additional Airport Capacity

7.1 Establishing the value of the London & SE origin and destination market is complex. With available capacity at Gatwick and Stansted it is unlikely that leisure ﬂights or business opportunities are currently not occurring because of airport capacity restrictions however within 20 years the value of the lost opportunity, if capacity is not increased, will be measured in £billions.

7.2 The value of the hub transfer market decline is easier to estimate. The value to the UK is the airport fees charged and any retail expenditure at the airport. This is probably about £20 for each arriving and departing passenger, valuing the potential eight million passenger decrease at about £160 million/year.

There is a debate about whether the hub/tranfer market is being curtailed by capacity restraints; certainly operators would like to fly more flights out of Heathrow. However It is difficult to see that there is an economic case for providing more hub/transfer capacity when what is needed is more capacity for origin/destination passengers with ease of access to and from their London and SE home and business locations.

8. The Question(s) to be Answered

8.1 The Independent Commission [4] set up by Government has a remit that presupposes that maintaining the UK’s position, as “Europe’s most important aviation hub” is synonymous with providing the best possible airport infrastructure to enable and support UK economic growth. Is Government’s objective to have “Europe’s biggest airport” or to grow the economy with jobs and a good quality of life for all?

8.2 Questions that seek to understand and allow for the evolving nature of air travel particularly the increase in direct ﬂights from regional airports in the UK, Scandinavia and Northern Europe and the emergence of hubs in the Far and Middle East maybe more helpful. Below is our response to the main questions; clearly there are also many more detailed issues that need to be addressed.

8.3 Do London and the SE need additional airport capacity?—Yes but not urgently, a good plan however is required to provide conﬁdence. It would be preferable if the plan encompassed all relevant major rail and road strategic decisions and improvements to local transport networks to work towards a strategic integrated plan.

8.4 Does London need a new hub airport or a signiﬁcant extension (third runway) at Heathrow?—Probably not, the value and economic role of hubs could well become less signiﬁcant to the UK as the market further matures. Development at Stansted, Gatwick and the smaller South East airports could provide a better alternative for the next 20 years than a new Thames airport

8.5 Should, as the DfT have proposed in their Draft Aviation Policy Framework, the management and control of noise be a key objective in evaluating options for increasing air port capacity? Yes the brief evidence included in the policy framework is compelling in the need for noise to be considered, page 49 of the framework document provides the key data. A short visit to communities near to the runway takeoff routes painfully enforces the point. 17 October 2012

References and Data sources

[1] DfT Draft Aviation Policy Framework July 2012 http://assets.dft.gov.uk/consultations/dft-2012–35/draft-aviation-policy-framework.pdf

[2] DfT UK Aviation Forecasts August 2011 http://www.dft.gov.uk/publications/uk-aviation-forecasts-2011

[3] CAA Airport Surveys 1990—2011 http://www.caa.co.uk/default.aspx?catid=81&pagetype=90&pageid=7640

[4] Secretary of State for transport announcement Sept 2012 http://www.dft.gov.uk/news/statements/mcloughlin-20120907a/ cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Written evidence from Rothwell Aviation Ltd (AS 30) 1. What should be the Objectives of Government Policy on Aviation? To implement policies which sustain the UK’s aviation industrial and technological base and provide air transport facilities to access global markets such that the national economy can be developed and the City of London protected. The UKs industrial aviation base must be protected by government through support for civil and defence projects, export activities and joint international projects where these are in the national interest. Access to global markets requires that the UK maintain connectivity directly with international markets and regions which encourage tourism. This involves facilitating the expansion of air transportation infrastructure.

(1a) How important is International Aviation Connectivity to the UK Economy? International Connectivity is vital. (1) UK business trades 20 times more with new markets which have direct daily flights to UK (Frontier Economics). (2) Improvement of 10% in connectivity would improve economic growth by £890 million per year (Oxford Economics). (3) 67% of business leaders in BRIC countries prefer business in Europe rather than UK because of better connectivity of European hub airports.(British Chamber of Commerce BCC). (4) 92% say direct flights are critical for inward investment (BCC). (5) 62% say they will only invest in UK if air connectivity is improved. (BCC). (6 ) Frankfurt Paris and Amsterdam with 14 runways operate to 760 destinations; Heathrow with 2 runways operates to 162 destinations. (7) Strong correlation between UKs Trading Success and visits from UK businessmen (CAA). (8) Foreign Direct Investment in the UK increased from £294 to £654 billion between2000 and 2009. (Office of Nat Statistics). (9) Emerging & developing economies will grow to 5% per year and account for 72% of global growth between 2011 & 2030 (Boeing Market Outlook). Registered in England Company Number 04738117. (10) Air travel and economic growth are directly related. (ICAO, GDP growth-IMF)

(1b) What are the Beneﬁts to the UK Economy? Aviation is not a government subsidised industry but it supports directly 921,000 jobs across the country and provides the very best of cutting edge design and technological innovation. It is an economic catalyst that underpins the whole of the UK economy representing 3.6% of UK GDP or a contribution of £49.6 billion.

(1c) What is the Impact of Air Passenger Duty(APD) on the Aviation Industry? (1) APD is costing the UK working economy some 91,000 jobs per year.

(2) Government advised that APD was an environmental tax to reduce CO2 emissions. In reality it is a tax on travel by air. (3) When the EU Emission Trading Scheme (EU-ETS) was introduced the UK retained both APD and ETS taxes. Germany is to reduce & cancel APD . (4) Jeff Smisek, CEO of the merged United & Continental Airlines operating 1,252 aircraft said “There will always be services to the UK; but there will be fewer services and fewer jobs. If you choose a tax to destroy an industry APD is doing a pretty good job” (5) APD for a family of four travelling to Florida has risen from £40 in 1994 to £260 in 2012. (6) APD in UK is 8.5 times greater than in any other EU country; this is totally irrational and is driving passengers to EU airports. (J Smisek CEO United/Continental Airlines) cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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(1d) How should improving the passenger experience be reﬂected in the governments aviation policy? (1) Reduction of Air Passenger Duty. (2) Provide dedicated air passenger, road and rail links to airports with systems designed to manage easy baggage handling. (3) Permit modern IT system for check in procedures. (4) Greatly improve passport and immigration systems which ensure rapid management of passengers. (5) Increase runway capacity to enable airports to overcome incidents and the unforeseen which cause landing and take off delays.

(1e) Where does Aviation fit in the overall transport strategy? (1) Given that the UKs economy relies almost completely on trading globally in remote markets, aviation is fundamental and critical to the nation’s economic future and quality of life. (2) Aviation provides the swiftest, and often, the only access to global destinations (3) Aviation is a key facility in the development of the economy in that it serves several commercial and industrial sectors and is a source of scientific and technological development which is used across a multiplicity of industries. (4) Air transportation is used by business persons, the leisure and tourist sectors and increasingly for freight. Freight fleets will also double in size over the next 25 years. (5) The location and purpose of airfields must be determined before road or rail links are established. There is a need for an overarching national infrastructure plan supported formally by all main political parties.

2. How should we make the best use of existing Aviation Capacity? (2a) How do we make best use of existing London aviation capacity and are the governments current measures sufficient? (1) It is difficult to see how the ad hoc development of privately owned airfields located around London can now be altered radically to achieve greater capacity and coherence. These airfields have tended to specialise in certain types of air transport operation. (2) Luton is structured to manage low cost (Easy Jet) operations. Stansted is similarly built for low cost operations and is essentially a base for Ryanair. Both of these airports have relatively small terminal buildings and limited first class facilities. Gatwick is a holiday and tourist traffic airfield. London City is structured for the business passenger. Southend is now focussed on freight operations. Farnborough is exclusively a business and VIP passenger airfield. Heathrow is the Nations HUB for global business, tourist travellers and freight and is by far the most comprehensively equipped. (3) Airfields are therefore not all equipped to be used in the HUB, freight or budget airline roles and they are not all directly connected except via London. Only Heathrow has two operational runways which are operating at 98%, but other London airfields could accept some more traffic if airlines care to operate from such airfields.

(2b) What could be done to improve airport resilience and the passenger experience? (1) Airport resilience is a function of airport capacity. Runways provide the operator with the facilities to adapt daily routine to cope with the unforeseen. Single runway airports have little or no real resilience or self contained capability to manage such scenarios without delays. (2) The “passenger experience” is universally measured as the length of time it takes a passenger to get from getting on transport to the airport to getting airborne or vice versa. The shortest time gains the highest points score. (3)It is directly a function of the organisation of vehicles to deliver passengers and the speed with which passengers can be relieved of cumbersome baggage. Check in, customs and immigration processes need to be extremely swift and responsive. There are plenty of examples around the world of excellent terminal facilities but like hotels, customer facilities have to be regularly updated and refurbished. (4) For transatlantic passengers there is much praise for the BA ﬂight from City Airport via Shannon to the USA. The high scoring beneﬁt is being able to clear US customs and immigration at Shannon whilst the aircraft is refuelled. This idea should be examined in more detail for wider application.

(2c) Does the government’s strategy make best use of airports outside the South East? (1) There is no identiﬁable government strategy and no infrastructure plan to exploit airports outside the South East except to use them. Airports are businesses structured and equipped to operate in their primary role cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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effectively and profitably. They are staffed appropriately for these operations; immigration and customs staff are provided to meet the primary business of the airfield. (2) Birmingham and Manchester could accept increases in passenger throughput but additional flights will generate more noise and that that will precipitate the same protests which occur around Heathrow, Gatwick and Stansted. Government policy is to prevent aviation noise becoming a nuisance; not to spread it.

(2d) How can Surface Access to Airports Be Improved? The immediate answer would be link airports to key cities by rail. That perceived wisdom needs to be tempered by the fact that the percentage of air passengers actually using air/rail terminals on airfields at Seoul, Narita (Japan) and Frankfurt are respectively 4%. 39% and 13% and these facilities are modern, integrated and tailored to the task. The reasons given for this low level of usage were baggage handling on to and off trains, matching rail and flight schedules and the availability of rail stations on the HS line (s) serving the airport. For example if HS2 ,were routed via Heathrow, this would not reduce conventional high speed travel times because passengers wanting to use it would have to drive to Birmingham first as there are no stations on the HS line between London and Birmingham. The journey time between departure address and London would be longer and the matching of air and rail schedules would become even more difficult. It would be possible to return to a concept used by BOAC/BEA where check in for flights took place at a terminus located in central London. There would have to be arrangements for operating this scheme for inbound passengers as well. In effect a central London location would become the airport terminal. In any event before more roads or rail lines are built it is absolutely essential to determine where the new national hub airfield is to be sited.

3. What Cnstraints are there on increasing UK Aviation Capacity? Constraints will include noise, runway capacity, airspace management, terminal infrastructure and political courage. (1) Airspace management will be greatly improved by new technologies both on the ground and in the air with the greater use of modern satellite navigation systems. These will only be used when there are sufficient runways to accommodate the flow rates which will follow a doubling in the passenger carrying strength of the global air transport fleet (2) Increased connectivity is a function of increased runway capacity which inter alia creates an increase in aviation noise. Rationing use of our airfields adversely affects connectivity and prompts UK business to relocate to countries where business development is assisted through direct trade contacts. Aviation noise will be reduced by engineers and scientists not politicians. It will not be eliminated and will increase temporarily with more movements. (3) Rationality, courage, logic and business acumen are factors in very short supply in the Whitehall village. There is however a surfeit of hearing impaired egos who see admission of error as a heinous character defect.

(3.1) Are the Governments Proposals to Manage the Adverse Effects of Aviation Noise Sufficient? (1a) No. The only proposal government is to spread the noise across the country to city and provincial airports irrespective of whether airlines consider that city and provincial airports provide sufficient business to make it worth while holding dispersed and expensive ground handling or engineering equipments at remote locations. (2b) There are other techniques which can be used to lower the impact of noise but some are counter productive and others require procedure developments and adapted aircraft control systems. Each will have an impact but non will be absolute. (3c) The future rests with the separation of aircraft noise from human beings who will continue to use their franchise to make sure political parties prevent noise expansion or intensity. However 21st century airfields will have to be able to operate on a 24/7 basis to achieve best return for the high cost of infrastructure and to optimise use of expensive aircraft fleets. (4d) There are only two solutions; (a) conclude an all party agreement to a site for a new hub airfield and recompense those who need to be relocated or, build an airfield where noise does not affect people. One of these options must be approved within the next 18 months. If decisions cannot be made until after the next election (2016) then by 2024, when some relief facility could be constructed, Heathrow’s connectivity will have fallen to the point where hub activities have been transferred to Europe and London will no longer be part of the global aviation network. (4c) By delaying decisions on the nations connectivity, to accommodate party political agreements, government has announced that its sectional interests are more important than saving the national economy and a final phase in the diminution of UK PlC’s influence in international affairs will have been reached . That cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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will prove to be as cataclysmic as the decision to abandon manufacturing to concentrate on investment banking and the City of London as the UKs route to economic success

3b Will the governments proposals help to reduce carbon emissions and manage the impact of aviation on climate change? No The cancellation of R3 at Heathrow in 2010 was justified on the basis that it would substantially increase pollution and noise around Heathrow and that the UK was obligated to reduce UK Aviation Emissions and join the EU Emission Trading Scheme. Notwithstanding public statements on emission pollution, the government knew that;— 1. The UK had no sovereign control over UK Aviation Emissions because they could not be quantified. (DfT Forecasts 2011) and they did not therefore exist. 2. That the EU Emissions Trading scheme was not only ineffective and costly to administer but it was strongly opposed by the USA, Russia, China and India because it was not a globally agreed scheme to reduce pollution but a tax on flying. The USA has by law made it impossible for US operators to make ETS payments. 3. That a lack of adequate runway capacity in the London area was, annually ,t wasting fuel and creating emissions in holding patterns over London which equated to that used and produced by 2500 transatlantic crossings per year. 4. That holding thwarted the introduction of the European Single Skies plan which was designed to reduce flight times, fuel burn and emissions by using direct airport to airport routes. There has been little said about emission pollution which has been taking place for decades because of a lack of runway capacity but those who live around London’s airports have been vociferous about noise and that is the issue which exercises the general public

3c How can Aviation be made more sustainable? (1) Current international aviation emissions are estimated to be 2% of all global emissions.

(2) Reductions in aviation CO2 emissions have been agreed internationally to achieve carbon neutral growth by 2020 and reduce CO2 emissions by 50% between 2005 and 2050. (3) To achieve these targets government must support development of more efficient aircraft and engines, large scale deployment of sustainable fuels, cooperate in efficient air traffic management and globally agreed carbon reduction systems and provide adequate and modern airport facilities. (4) Science and technology will provide fuel efficiencies of 10% by managing aircraft in the air and on the ground more efficiently. Technology will increase engine and airframe efficiency by 17% in 18 yrs and a further 26% over the period 2025 to 2050. (5) If governments meet their obligations, scientist engineers and industry will be able to meet their targets and greatly improve sustainability. Aircraft manufacturers are competing to secure orders for the enhanced global fleet of passenger and freight transport aircraft. They are already highly incentivised and progress is good.

3d What is the relationship between Governments Strategy and EU Aviation Policies? See 3b above.

4. Do we need a step change in UK Aviation Air Transport Capacity and Why? Yes; if the UK is to overcome recession and grow the national economy. Aviation makes a sizeable economic contribution in supporting 921,000 jobs across the country directly. It represents the very best of cutting edge design and UK innovation and is much more than just one sector. It is an economic catalyst which underpins the whole of the UK economy representing 3.6% of UK GDP or a contribution of £49.6 billion. (Oxford Economics)

(4a) What should the step change be? (1) The increase in disposable incomes in BRIC country economies is forecast to increase the number of passengers using UK airports from 211 million in 2011 to 335 million in 2030 to 474 million in 2050. (DfT Forecasts 2011). (2) Globally 630 airports are being developed to meet this challenge. The UK government is actively delaying the decision over whether it should build one airport but the nation is advised that there are plans to develop the economy! cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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(3) The step change needs to acknowledge the debilitating affect on the economy of not addressing with determination and purpose the building of aviation infrastructure to accommodate these huge increases in the size of the current global air transport ﬂeets and the passengers.

(4b) Should there be a new hub airfield? (1) Most certainly Yes; because there is no other way now to scale the mountain before us. The UK lags woefully behind European competition in the number of runways that need to be provided, as each day passes airlines are planning to base their expansion on established modern hubs in Europe and in the Middle East. (2) British global travellers speak of Heathrow as a third nation airport. It is also a blighted aviation facility because it is located in an urban area where aircraft noise is a nuisance to local residents. In order to make sure that Heathrow noise does not increase, locals use their franchise and the associated gerrymandering prevents growth and development. (3) If R3 at Heathrow is ever built it will be regarded as the start point for the creation of a new hub on the Heathrow site. However under current policy no decision on aviation infrastructure can be made before 2015–16. Runway 3 cannot therefore be built until 2023. At that stage Heathrow will have passed the point at which it is necessary to expand air transport infrastructure. UK will have already become the branch line station to the global aviation network and that status will be reflected in the UK economy. (4) The only realistic solution will involve the creation of a major multi runway hub which can be operated on a 24 hr basis. The global community recognised that reality a decade ago. (5) The second reality is that Airlines decide where they want to fly to and from not government ministers. The most favoured airport in the UK is Heathrow because it is an Air Transport hub where airlines will find the greatest concentration of passengers and where passengers can access the greatest number of destination options and airlines to transport them. If government restricts the development of airfields then airport businesses will fail and airlines will go elsewhere and there are plenty of international airports to welcome them. (6) Airlines cannot be likened to franchise operators for railways. A 3500 yd runway provides direct access to the worlds runways not just a departure point and a destination joined by miles of railway line which will require government maintenance, protection and subsidy throughout its life.

(4c )What are the costs and benefits of increasing UK Aviation capacity? (1) Such is the state of the economy that at some stage in the near future the government will be forced to admit that the nation cannot afford concurrently two major infrastructure projects and that does not take into account the need to import labour on a huge scale. A choice will have to be made between HS2 the high speed rail line from London to Manchester and Leeds via Birmingham and a new hub airport for the nation. (2) The final costs of HS2 are not yet finalised because the extensions to Manchester and Leeds have not been planned but a figure of £40 billion from existing estimates has been tabled. Figures for the development of the Foster project in the Thames suggests a figure of £55 to £60 billion which has not been validated. (3) If the government is serious about managing transport costs responsibly, after the fiasco of the West Coast Line Franchise, it must subject both projects to an independent review to determine which delivers the best benefit/cost ratio for the tax payers money The sooner this takes place the less tax payers money will be wasted because in national economy terms there can be no doubt that a new hub airport will yield the better benefit/cost ratio by some very considerable margin.

5. Managing the Step Change. (1) The UK’s global economic competitiveness is being seriously undermined because Heathrow is unable to match the capacity and connectivity of European airports and domestic flights are already operating directly into these locations for international connections. As a consequence Heathrow becomes steadily marginalized and a permanent pattern of business behaviour is being established. It is therefore imperative that Heathrow’s current levels of connectivity are sustained until a new hub is operational. (2) Over the last three years Rothwell Aviation has developed a solution to this immediate problem which in no way affects the solution which the Davies Review must recommend. (3) It involves the immediate development of the nearby airfield at RAF Northolt to meet CAA airport safety standards for the operation of short haul commercial aircraft thereby releasing capacity at Heathrow for long haul flights to new market destinations. (4) To achieve Civil Aviation Authority certification, the feasibility of which has been confirmed, the Northolt runway must be re-orientated to parallel those at Heathrow and lengthened to produce a paved surface of circa 2,400 metres. This would provide 80,000 plus movements per year (18%—20% of Heathrow ATMs), would harmonise Heathrow and Northolt air traffic movements, diffuse noise pollution and provide an additional 30 million passengers per year over 20 years. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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(5) Heathrow and Northolt would be connected by a dedicated surface rail link for the transfer of passengers and baggage, within 15 minutes, between the two sites. This is a modest inter runway link compared with many airport sites around the world. An associated “Air-Rail Terminus” built at RAF Northolt could, also provide a fast surface rail link directly to Paddington.

The Benefits of Rothwell Aviation’s Interim Solution: — The adaptation of RAF Northolt would preserve the connectivity of London quickly. — It does not compromise or predetermine the location of the essential replacement hub airport. — The airfield would be developed for military and civil use, and would not affect the strategic military nature of the air base. A realigned and resurfaced runway would benefit the RAF and Government in the short, medium and long term. — Revenue would be generated for Government from the joint use of this operational facility for the purpose of the Interim Solution, whilst retaining the base’s long term role and value. — Rothwell Aviation has confirmed that the infrastructure build would be funded from private venture investment. — Northolt would be adapted in four years by a consortia of Companies. There would be no disruption to Heathrow operations. — Military/government air operations can be accommodated during the runway reorientation programme. — Extending the runway length would provide 80,000 ATMs per year. (18 to 20% of Heathrow’s current ATMs) or an extra 30 million passengers per year over 20 years. — The facilities produced at RAF Northolt would be operationally comparable to those planned for R3. — Heathrow’s international Hub status would be preserved and it would retain its position in the expanding Global Aviation Network pending the building of the new hub. — Reorientation of the runway would harmonise Northolt and Heathrow Air Traffic Control and being six miles north of Heathrow this would diffuse noise. — However if R3 were built it is probable that RAF Northolt with its current runway orientation would have to close. — The project offers cost effective use of an under-utilised airfield which would otherwise require public investment to make it suitable for strategic military flying operations in the 21st century. — The project would create jobs during construction, during the period that the Heathrow replacement Hub is being built and for those who currently work at Heathrow. — RAF Northolt is the only airfield which can be easily linked to Heathrow by rail to create the vital London Hub facility. — The Royal Air Force would, on completion of the new hub airport, receive a legacy in the form of a modern and useful runway within the M25, a modern air traffic control system and terminal facilities. — At no cost to the treasury, government will be seen to be proactive and innovative in using one of its own underutilised facilities to help resolve an economic crisis which is fast becoming a national embarrassment. — The adaptation could be authorised immediately and independently as a response to the Heathrow runway capacity crisis because it has no effect on any decisions about the future of a main transport aviation hub. — It is a stand alone political and economic lifeline.

Observations — Increased air activity at Northolt will cause objections but three points need to be made. — Firstly the economic imperative to support Londons global position secondly he need to make the right decisions about a new hubs location. — Thirdly the temporary nature of the Northolt interim solution because Heathrow plus Northolt can only hold the line for a maximum of 20 years during which time a new hub must be built. — The building of R3 will raise suspicions that clearance has been tacitly agreed for the full multi—runway development of Heathrow — Detractors, or those just “change averse” will claim that closure of Heathrow will mean job losses and require the building of a new town to support the new hub. — Jobs will not be lost, they will be relocated and building more houses in a new town to service a new hub airport is just what the nation needs. Heathrow is an ideal site for both business and domestic development but not for a major airﬁeld for the 21st century. It could become the Canary Warf of West London. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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— There should be a reasonable expectation that this logical and necessary approach could gain all party support in the interests of the nation. — For 40 years prevarication and political gerrymandering have prevented this issue from being resolved. — This is the last opportunity to prevent Heathrow’s relegation to a second tier feeder airport or to salvage any inﬂuence it might have on the recovery of the UK’s economy or the City`s key ﬁnancial role.

Reflections — UK business trades 20 times more with new markets which have daily direct flights to UK. — 92% of BRIC business leaders say that direct flights are critical for inward investment and 62% say they will only invest in the UK if connectivity is improved. (CofC). — New economies will account for 72% of global growth between 2011 and 2030. — Air travel and economic growth are directly related (ICAO,GDP growth- IMF). — Aviation supports one million jobs across the country and provides the nation with cutting edge design and technological innovation. It is an economic catalyst which underpins the whole of the UK economy representing 3.6% of UK GDP or a contribution of £49.6 billion. (Oxford Economics). 17 October 2012

Written evidence from the Save Filton Airfield Campaign Group (AS 31) Introduction The “Save Filton Airfield” campaign group was set up in 2011 in response to an announcement by BAE Systems that they intended to close and redevelop Filton Airfield in north Bristol. The group is made up of local engineers, politicians and employees of the aerospace industry who feel that this decision represents a threat to the future of local aerospace design, manufacturing and supporting businesses, and to the ability of Bristol to provide a complete aviation solution to the wider UK economy. The decision to close the airfield has been dismissed in many quarters as a purely commercial decision for BAE Systems and outside the control of local or national government, despite local and national policy having asserted protection for the continuing operation of its runway and facilities. Public consultation revealed that local opinion favoured retention of the airfield as a keystone of aerospace and aviation activities.8 We would like to explain to the Committee how Filton Airfield and similar airfields under threat should be employed in addressing the overall picture for future aviation capacity needs. Whilst it is clear that there will be a requirement for large-scale capital investment in the South East of England to address long term demand in commercial passenger aviation, well equipped secondary airfields such as Filton can help to alleviate the situation in the short to medium term, at lower cost. We consider it vital that this Inquiry addresses aviation policy which covers ALL UK airfields and not just commercial airports in the South East of England.

Current Capacity Issues In addressing the issue of aviation capacity in the South of England, it will be important to identify where and how bottle-necks will occur in the future and over what time frame. It is clear that the imminent issue is that of commercial passenger services where demand is currently greatest—that is to say, in the South East of England. In evaluating demand, we need to examine the current model of both international and domestic flight operations. In recent years, there has been much debate concerning the “hub” based model of passenger aviation versus the “point-to-point” model. In attempting to address this, industry players seem to have reached their own, varying conclusions. Clearly, there are merits in both models, with a trade-off between cost of operations and flexibility for customers, but the reality is that there is likely to be a balance between the two. This choice will be influenced by national policies and availability of routes, airspace and airport facilities. In the UK there has been a trend since the early 1990s for long-haul operations to be centred on two major cities—London to serve the population in the south, and Manchester for the population in the north. British Airways has opted to concentrate all of its international operations on Heathrow and Gatwick, providing domestic feeder flights from regional airports. This has undoubtedly exacerbated the number of movements in the London area, contributing to aviation congestion there, and particularly to the pressures on Heathrow. 8 South Gloucestershire Council Core Strategy Post-submission Engagement Statement. November 2011 cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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A city such as London requires world-class airport facilities with easy access to the city, and in the longer term a radical solution is required, be this by building a new hub airport at a new location, or by extending the physical boundaries of Heathrow. However, neither solution is the complete answer to aviation capacity needs; a single major airport will always suffer issues as a result of heavily concentrating activity in one area: localised pollution and noise, surface access congestion, congested airspace and a lack of redundancy for emergencies. On a wider note, there is a risk that economic activity could become over centralised in the South East and leave inadequate provisions for transport, especially aviation, in the regions. A more geographically distributed solution to aviation capacity would yield many socio-economic advantages, but policies must be drafted carefully to ensure that the needs of the whole aviation community and the public are satisﬁed. This will ensure that investments from both Government and the private sector will return the greatest beneﬁt.

Providing Relief for London’s Airports Any solutions to long-term capacity requirements of London’s airports will inevitably require significant capital investment and will not happen overnight. History warns us that large infrastructure projects are mired in drawn-out public inquiries, political and public opposition, legal issues, lengthy tendering and building programmes and issues with commissioning. It is therefore imperative that the Government considers interim solutions that can be delivered in the short to medium term. It should examine integrated solutions involving re-organisation of commercial and ancillary aviation services. This must account for economic development policies and the changing landscape regarding surface access. The first and most obvious solution is to identify any types of movement that occupy airspace capacity, landing/take-off slots and ground operation requirements at the most congested South East airports, and to move them to suitable secondary or regional airports. Such movements should include: — Short-haul commercial passenger flights. — Maintenance operations. — General Aviation (GA). — Freight. Commercial passenger flights may seem a difficult issue to address; airlines have chosen to base operations around London due to a lack of viable alternatives, this serves only to perpetuate further demand in London. In light of current policies concerning economic displacement from London towards the regions, Government must evaluate how much demand for these services is likely to come from other areas of the country and whether this could be satisfied instead by services from regional airports. With the advent of a high-speed rail link to Birmingham, and with fast and improving links via Heathrow and all the way through to the West of England and South Wales, it is important to examine whether demand from north and west of London could be better served by point-to-point services from airports such as Birmingham and Bristol. However, we must be careful to ensure that increased usage at these regional airports does not jeopardise other economically important aviation activities.

Filton Airfield Filton Airfield lies just within Bristol’s urban area, five minutes from the M4 and M5 motorways and the local A38 trunk road, providing it with excellent road transport links to London, the Midlands, South Wales and the South West. Also within five minutes is Bristol Parkway railway station which is served by high speed rail services on Great Western and Cross Country mainlines. The freight line from Avonmouth Docks passes through the airfield site and provides connections to these mainlines in all directions. The site comprises just over 140 hectares of land and possesses a CAA Ordinary Aerodrome Licence allowing for the public transport of passengers, general aviation, commercial operations and for flying instruction and has full customs facilities. The concrete runway is significant in length at 2,467m, and is one of the widest in the UK at 91m (one of the few able to accommodate the Airbus A380). It is equipped with full runway lighting and an Instrument Landing System (ILS), a control tower, providing full radio telephony services to users, including a Lower Airspace Radar Service (LARS) for the north Bristol area using the on- site RADAR, and Category 6 fire cover. 910 The airfield is owned and operated by BAE Systems (Aviation Services) Ltd. having been transferred to their predecessor, British Aerospace PLC, in 1977 and then to the current legal entity of the same company under privatisation. 9 http://www.bristolfilton.co.uk/pilot_information/runway.php 10 Pooleys Guide cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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In recent years it has hosted a variety of aviation businesses, including freight, aircraft maintenance, aircraft livery services, business aviation operations, medical and police helicopter operations and flying schools. Whilst BAE Systems themselves do not make significant use of the airfield, the main economic user is Airbus Operations (UK) Ltd., whose activities employ approximately 4,500 people on the site in Research & Development and manufacturing, much of which is subcontracted to GKN Aerospace.11 The situation is similar at Airbus’ other UK manufacturing site at Broughton, which is also owned by BAE Systems. Airbus uses the airfield in two main roles. The first is to transport large wing assemblies from the manufacturing facilities to final assembly, such as the A400M military transporter aircraft wings which are shipped direct to Seville, Spain. The second is to provide the employees with shuttle flights to other Airbus sites within the UK and Europe, allowing staff to travel to technical meetings and back again, often on the same day. Commercial passenger services for the West of England are currently only provided by Bristol Airport at Lulsgate in rural North Somerset, some seven miles south west of the city.

The Economic Case Decentralisation from London The UK Government has in recent years made overtures about decentralising economic activity and power- making from London in an attempt to prevent uncontrolled growth in the South East and avoid economic stagnation in the regions.12 As well as public bodies, institutions such as the BBC have already started to move some functions to regional centres, including Bristol. The ﬁnancial services sector in the Bristol is also growing and will be spurred on by the Temple Quarter Enterprise Zone which will generate local business rates income as part of the City Deal. The scope for such new activity will represent an added pressure on both domestic and international transport links for the region. Domestically, it is hoped that this will be assisted by the planned upgrades to the Great Western mainline. Internationally, this will be served by local airports.

Locally displaced aviation These high-value growth industries will require access to both scheduled flights and business aviation services. The latter are typically provided by secondary airfields where civil airport security and immigration processes do not obstruct the required fast, hassle-free transfers. Locally, commercial flights will be operated from Bristol Airport. In 2011, Bristol Airport serviced 5.7 million passengers with aircraft movements over 66,000. The airport projects growth of passenger figures to between 8 million and 9 million by 2015 and up to 12 million by 2030.13 As part of this anticipated demand, the airport is currently investing in further enhancements to its passenger facilities by expanding the terminal building and adding new air bridges, multi-storey car parking and new aprons. In the longer term, it is considering an extension to the 2,011m runway and a possible second terminal building to the south of the runway, though absolute runway capacity is anticipated to be limited beyond the 2030 projections (approx. 140,000 movements). Although much expansion is planned, no improvements to the transport infrastructure between the airport and Bristol or the M5 motorway have been included in the plans, leaving it accessible only by country roads. General Aviation (GA) is an important sector. Nationally, it is currently valued at £1.4bn to the economy, 8% of the total Commercial Air Transport sector. 11,600 people are employed in GA, operating a fleet of some 15,500 active aircraft, and accounting for 4.6 million movements annually. This doesn’t include the value added to other businesses which rely on GA.14 Mixing GA with larger aircraft affects overall capacity for an airport because under CAA regulations, movements of lighter aircraft require increased separation from large commercial aircraft due to wake vortices and also light aircraft tend to operate at lower airspeeds.15 Therefore, to facilitate greater overall capacity for passenger flights, aviation policies must emphasise provision for separate GA airfields. If regional civil airports such as Bristol are to take up demand for commercial services, we need to be very careful that there is no jeopardy to either the business aviation or GA sectors. As these are increasingly likely to be displaced from primary civil airports to make way for passenger travel, there needs to be clear policy in protecting secondary airfields in every region to provide the necessary facilities. It should also be noted that if such airfields are allowed to close, these movements must be accommodated at other suitable airfields, exacerbating the problem. Filton, for example, averages approximately 28,000 movements per annum, which would be displaced to either other secondary airfields, or Bristol Airport.16 11 http://www.airbus.com/company/worldwide-presence/airbus-in-uk 12 HM Government: “Decentralisation and the Localism Bill: an essential guide” 13 http://www.airport-technology.com/projects/bristol-international-airport 14 General Aviation Awareness Council: Fact Sheet 14—GA value to the UK economy 15 CAA: CAP 493—Manual of Air Traffic Services Part 1, section 9.5.1 16 BAE Systems/Terrence O’Rourke: Filton Airfield Aviation Options Report 2011 cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Examples of regional airports where provision should be made for local secondary airﬁelds to alleviate potential movement separation issues include: — Bristol — Bournemouth — Cardiff — Edinburgh — Exeter — Glasgow — Liverpool — Leeds-Bradford — Teeside

Manufacturing The government has repeated a desire to embrace high-value manufacturing exports as way to grow the economy out of the current recession. A prime example of this desire is the UK aerospace industry, the second largest in the world and one of the most successful sectors of UK manufacturing.17 This industry is largely centred around the Bristol region for historic reasons. Nationally, the sector has a turnover of £24.2 billion and directly contributes £11.4 billion to the UK GDP. Civil aerospace in particular remains in a strong growth phase, with revenues increasing by 5.1% in real terms in 2011. Traditionally this sector has been supported by localised aviation capacity. No Airbus manufacturing site is currently without an operating airfield for this reason. In the UK, the main company involved in civil aerospace is Airbus. In 2011, the company took orders for 1,608 aircraft, as airlines seek ever more efficient fleets. This leaves the order backlog at over 4,300 aircraft.18 Finding manufacturing capacity to meet this demand is both a commercial and political issue as governments around the world seek a slice of the work. The main UK sites for manufacturing are at Broughton in north Wales and the site at Filton Airfield, both centres of excellence for wing design and manufacturing, working closely with sites in Bremen, Germany, and Toulouse in France. Currently this work directly and indirectly supports 140,000 jobs. 19 At Filton, over 2,000 engineers are employed in developing wing parts, with a further 2,500 at subcontractors GKN Aerospace. This workforce also supports EADS latest foray into defence aircraft by supplying wing assemblies for the A400M military transporter, which is assembled in Seville. The current threat to this site from the potential loss of airfield capacity stems from a complex history with BAE Systems and its forerunners. BAE previously held a 20% stake in Airbus’ parent company, EADS, but sold this in 2006 to concentrate on what it perceived would be its core business in defence contracts. The Filton site was a result of this earlier collaboration as an offshoot of BAE’s former manufacturing operations there. BAE continue to own the airfield and underlying land and Airbus pay rent to BAE for its office and manufacturing facilities. As the global recession has taken hold and BAE have relied heavily on defence contracts, primarily in the US, it has seen its own revenues fall, and has become increasingly indebted (to the tune of over £16 billion net). As it has reduced its exposure to UK markets, it has sought to sell off real estate assets acquired during privatisation. Such real estate includes ex munitions works, manufacturing sites and airfields. It would appear that in order to maximise value from the real estate at Filton, BAE has sought a change of land use through the local planning authority (who had been given an increased house-building target of 26,400 homes—up from 21,500—as a result of BAE’s announcement of their intention to close the airfield20). In order to facilitate this, Airbus were offered for sale 50 hectares of land so they could relocate their aerospace activities from BAE-owned land. In response, Airbus have claimed that they can “mitigate” the impact to future manufacturing sites by transporting wing assemblies by road to Avonmouth docks, then by sea to northern France and then by air for the last leg to final assembly (eg Seville). Employees attending meetings at other sites would have to use services from commercial airports such as Bristol or Heathrow. Travel between the two UK sites would have to be by road. Perhaps, as less-than-willing tenants to BAE, Airbus felt they could continue with office operations at lower overall cost by agreeing to this deal, albeit adding to the risks and costs associated with manufacturing and transportation. However, there is genuine concern (including by employees of Airbus) that the mitigating operations being proposed could cause a threat to the viability of current manufacturing, and stifle any new large-scale projects that Filton could otherwise accommodate. 17 House of Commons Trade and Industry Committee: The UK Aerospace Industry, Fifteenth Report of Session 2004–05 18 EADS Annual Review 2011. Progressing, Innovating, Transforming 19 http://www.airbus.com/company/worldwide-presence/airbus-in-uk 20 South Gloucestershire Council: Supplementary Housing Paper. December 2011 (section 7.1) cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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We contend that this scenario is not as might be outwardly presented by Airbus, and it will manifest itself as a major threat to the local economy. It is vital that local capacity is protected to support these operations.

Supplementary Operations As well as secondary airfields being used to support important economic activities such as manufacturing and for relieving regional airports of conflicting aviation, there are supplementary operations that they can support which would fit in with both the desire to decentralise economic activity and relieve some capacity at congested airports.

Freight Whilst most air freight is carried in the hold of passenger flights, there remain a substantial number of dedicated cargo services operating out of London airports carrying approximately 1.8m tonnes per annum. The two main airports handling cargo-only flights are Stansted (10,200 movements pa.) and Heathrow (2,500 movements pa.)21. With improved surface links between London and the regions, secondary airfields with sufficient facilities can be used to relieve these operations from London, freeing up capacity for more passenger flights. They are also an ideal alternative to congested passenger airports where time-sensitive logistics operations are concerned.

Maintenance Passenger (and freight) aircraft maintenance is a necessary operation for all airlines. Much maintenance occurs during layovers at commercial airports but heavy maintenance can, and often is, provided offsite at secondary airﬁelds. Airﬁelds such as Filton, which have excellent links for the timely sourcing of parts and engineers, must be considered as part of aviation policy as a means to support the commercial aviation sector, and to mitigate unnecessary movements at congested airports. In particular, as the need arises to maintain very large aircraft such as the A380, there must be an adequate provision of sites with runways wide enough to handle these. In the UK, there are very few such runways. It is notable that the exceptionally large hangars at Filton can accommodate large aircraft such as Boeing 747s.

Social and Environmental Factors As well as the arguments made here about directly and indirectly relieving capacity at the most congested airports, there are other considerations to be made concerning regional airports and secondary airﬁelds.

Convenience Encouraging local provision for air services has numerous beneﬁts for the public. It minimises the need for passengers to spend time and money travelling to London airports. It can also help airlines keep their costs down by having access to a greater pool of employees.

Pilot Training In order to achieve a sustainable supply of pilots for all aviation sectors, secondary airﬁelds are paramount for training. The RAF also requires airﬁelds with full commercial instrument and radio services in order to train their pilots (Filton, for example, is used by the RAF for instrument approach training, which may now have to be displaced to commercial airports.

Emergency runway capacity Throughout the UK, adequate provision must be in place for emergency situations, both for in-flight aircraft problems and airport diversions as a result of accidents, fire, terror incidents or poor weather. In particular, as aircraft sizes increase for hub operations, there needs to be specific provision of emergency airfields with sufficiently large runways.

Support for emergency services Most regions now rely on police air operations units and medivac and air ambulance operations. These typically require an airfield which can provide fuel and maintenance support at a location as close as possible to major regional population centres. The fast-response nature of these services are not well suited to mixing with the traffic at commercial airports, meaning suitable secondary airfields must be protected for their use.

Pollution Over-concentration of aviation contributes to localised and global pollution. By reducing as far as possible movements in London airspace and moving as much as possible to regional airports and airfields, the stacking of aircraft on approach can be kept to a minimum, improving the fuel efficiency of flights. 21 BAA: Patterns of Traffic at BAA Airports 2010 cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Minimising surface journeys to airports also offsets car journeys, reducing road congestion and pollution along major routes. Finally, encouraging ancillary operations such as freight, business aviation and maintenance to locations with a good local urban density (again, as is the case with airﬁelds like Filton) reduces the need for the associated workforce and patrons to make longer surface journeys by car.

Recommendations In light of the arguments made in this submission, the Government must take steps to reverse the trend for important airfields to be redeveloped. This requires addressing the motives for owners who take these decisions. In the case of airfields like Plymouth and Filton, the closure decisions have arisen from the landowners’ desire to maximise real estate values in order to turn short-term profits and as a result of pressures placed on local authorities to identify housing land supply to meet government targets. Therefore it requires all Government departments to work together to avoid conflicting and potentially damaging policy as a result of a failure to understand the bigger picture. In addition, the Government needs to be very cautious of claims made by private airfield owners, whose motives are often purely financial. With this in mind, we make the following general recommendations: — Reverse the automatic “brownfield” status of closed airfields until their potential can be evaluated by the DfT for aviation needs. — Ensure there is a sufficient supply of suitable secondary airfields to support functions that are in the national interest (such as supplementary aviation capacity, pilot training or potential military requirements). — Analyse and consider reducing central Government housing targets where they are likely to add pressure on local planning authorities to make detrimental decisions concerning airfield redevelopment. — Aviation policy is rigidly accounted for in local planning policy. With regards to the specific concerns of this group, we also recommend that the Government use their influence over BAE Systems to ensure that their significant holding of UK airfields is evaluated and, where necessary, ring-fenced and protected, in the national interest. We recommend that the Government liaises with BAE management to come an agreement to keep Filton Airfield open until the issues raised in this submission can be fully assessed. 17 October 2012

Written evidence from Mr Joe Watson (AS 32) Response to Governments Draft Aviation Document. I am extremely disappointed with the Draft Aviation Policy Framework. It is quite wrong that the Government should propose that the only real mechanism for the regulation of the noise pollution caused by non-designated airports in the UK—which form the vast majority of the UK’s airports—should be better engagement between airports and local communities. It is inconceivable that the Government would permit the sole mechanism for the regulation of air or water pollution, or pollution from waste, to be left to a laissez faire system of “better engagement” between the polluting company or organisation in question and the local community. These forms of pollution are all subject to strict controls which are monitored and policed closely by the statutory environmental agencies in each of the UK territories. Moreover nearly all other forms of noise pollution are subject to stricter controls through the statutory powers exercised by local authorities. I believe that the proposals set out in the Draft Aviation Policy Framework fall far short of what is required to ensure that all airports in the UK minimise the noise pollution which they produce. The adverse impacts of aircraft noise on health, education and quality of life are well established. The DfT needs to take decisive action to produce the better balance which it claims it seeks between the commercial interests of the aviation sector and its adverse impacts on local communities. In particular, I would like to see the following measures: — Robust and ongoing mapping, monitoring and regulation of noise pollution caused by the all the UK’s commercial airports—carried out by the Department for Transport (DfT) (and devolved administrations, where applicable), or by the Civil Aviation Authority (CAA), rather than by the airports themselves. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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— Both the monitoring and the noise regulations must properly reﬂect the true impact of aircraft noise on health, education and quality of life, as evidenced in the substantive relevant research, and must reﬂect best practice as set out by the World Health Organisation in its relevant guidance.

— The Government should commit itself to a speciﬁc reduction in the number of people in the UK signiﬁcantly affected by aircraft noise over the next 10 years—I suggest a 10% reduction.

— Airports should be required to reduce the level and frequency of aircraft noise within the areas which are significantly affected by noise—priority should be attached to achieving this objective at the airports affecting the largest populations, and at those which affect large populations, and also duplicate the services of an airport nearby. The noise levels that emanate from George Best City Airport affects my sleep, I don’t get enough which leads to sleep deprivation. I can’t open my windows during the summer as the noise levels throughout the morning, afternoon and evenings is extremely noisy and impacts on the quality of life for me, my family and local residents. I am also frightened in relation to the adverse impact it may have on the future health of my family and local residents in general. It affects my television reception and I have to stop talking when using the phone when a plane is overhead. It disrupts conversations with my neighbours and affects any social activities that I organise in my garden. I used to take my young grandchildren to my local Victoria Park a gem of an oasis in the heart of east Belfast. However, I had to cease this social and family outing as my grandchildren where petrified from the noise emanating from the aircraft. Local residents do not have to be subjected to this intrusion and daily disruption of their family lives. There is an International Airport less than 30 minutes’ drive away which is better placed and equipped to handle European/International flights.

— No further growth should be permitted at airports which affect large populations in terms of noise, and which duplicate the services of an airport nearby, unless the airport operator in question can prove that any planned growth will not result in an increase in noise pollution.

— All airports whose noise pollution affects significant populations (and/or any schools) should be required to meet specified targets for reducing those levels of noise over a five year period— there should be serious penalties for airport operators which do not meet these targets.

— The Government should make it clear in its Aviation Framework that it is abandoning its outdated guidance stating that the 57 dB LAeq,16h contour marks the approximate onset of significant annoyance, and should introduce more sophisticated guidance which better reflects the considerable body of recent international research in this regard, and which properly reflects international research on health and education impacts of aircraft noise.

— The Government should either refine the current system of air passenger duty so that a higher rate is levied on those flights having the most serious adverse noise impact, or it should use its existing powers to enforce airports to use differential landing fees to reflect the noise impacts of flights.

— At airports where aircraft noise affects a signiﬁcant number of people (and/or affects schools signiﬁcantly), any noise envelope should only be used as a device to ensure that the level and frequency of aircraft noise pollution does not get worse and/or is reduced over time—it should not be used as a device to permit any increase in the amount or frequency of noise at such airports.

— The Government should give serious consideration to the results of the EU-sponsored MIME study, which developed a model of tradeable noise permits for airports, with a view to its possible introduction in the UK.

— The Government should require airports to provide comprehensive and robust effective insulation (not just double or triple glazing) to all homes seriously impacted by aircraft noise and not only those at 63 LAeq 16h.

— I support an enhanced noise regulation role for the CAA—but it must have a consistent, proactive and tough regulatory and enforcement role, similar to the Environment Agency.

— Belfast International Airport should be earmarked as the regional gateway airport for Northern Ireland at which any further expansion, particularly of international routes, should be focused, if such expansion is deemed desirable. 17 October 2012 cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Written evidence from the Aviation Foundation (AS 33) A successful aviation industry means a successful Britain — Introduction. — Why aviation is a popular and essential industry. — How aviation beneﬁts local communities where you live. — Four key tests to secure a credible and lasting aviation policy.

Introduction 1. The Aviation Foundation is a non-profit organisation, established by British Airways, Virgin Atlantic, BAA and Manchester Airports Group. It is supported by the British Air Transport Association, the Airport Operators Association, ADS Group, BAR-UK and the Baltic Air Charter Association, between them representing the entire sector. The main purpose of the Aviation Foundation is to promote the economic and social benefits of aviation to the UK. 2. Set up last year, the Aviation Foundation has so far received the backing of more than 150 organisations and businesses, including trade organisations, FTSE 100 companies, universities, car manufacturers and football clubs. These supporters represent hundreds of thousands of businesses and millions of employees across the UK. All have signed the Aviation Foundation pledge to demonstrate how a successful aviation industry is vital to their work at home and abroad in light of the government review. (See Annex A for the pledge and current list of signatories). 3. This Aviation Foundation paper focuses on the terms of reference which cover international connectivity and the benefits of aviation. Sustainable Aviation will submit a detailed response focusing on the excellent progress made by the industry’s campaign to tackle environmental issues head-on. The Aviation Foundation is submitting this summary to make three key points. We think it is important to: (a.) Highlight the strength and depth of support for aviation in Britain. (b.) Demonstrate aviation’s positive impact on everyday life in local communities. (c.) Set out four tests that Government must adopt to deliver a policy that works.

Why aviation is a popular and essential industry 4. Aviation collectively creates over £50 billion of wealth for the UK each year and protects almost one million British jobs.22 In addition, the 150 supporters of the Aviation Foundation offer a powerful insight into how many more jobs and businesses rely on air travel. Despite this, the aviation industry and its supporters are often taken for granted. 5. Aviation is not an abstract concept and nor should it be treated as such in the national debate—it has real meaning in the lives of the vast majority of the UK population. Being able to travel is essential to doing business, enjoying a holiday and keeping up with family and friends, making the world smaller, more open and accessible. More than 210 million passengers pass through UK airports each year.23 6. UK residents make over 43 million visits abroad by air each year.24 These include more than five million visits by people on business. Also, nearly nine million trips are made by low to middle income families, shattering the myth that air travel is the preserve of the rich.25 22 million international tourists visit the UK by air each year, generating around £14 billion annually across the economy.26 7. Aviation keeps friends and family in touch. In 2010, UK nationals made around 10 million visits to see friends or relatives abroad. Heading in the opposite direction, 8.4 million people visited friends or relatives in the UK, the vast majority travelling by air. Of these, two million were UK nationals who live overseas.27 8. We agree with the government that the priority should be to ensure that the UK’s air links continue to make it one of the best connected countries in the world. Yet the meaning and value of UK connectivity will decline dramatically if we continue to ignore what is happening elsewhere in the world. The Institute of Directors is one of our 150 pledge signatories. The IoD’s director-general Simon Walker said: “Aviation is vital to UK trade and investment, but we are already falling behind our competitors in Europe. We urge the Government to be bold when drawing up its final framework”. 9. While leading trading nations across the globe have quickly recognised that a thriving aviation industry is vital to future economic growth, British politicians have debated this point for almost fifty years without effective action (for an example using a timeline, see Annex B). As a result Britain is falling behind as an economic powerhouse at the worst possible time. 22 Oxford Economics, Economic Benefits from Air Transport in UK, 2011 23 UK Civil Aviation Airport Statistics, 2011 24 Travel Trends, International Passenger Survey, ONS 2010 25 CAA Passenger Surveys 1996–2009 26 HM Treasury consultation paper on Air Passenger Duty, 2011 27 Visit Britain, VFR facts and figures, 2011 cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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10. We know that UK businesses trade 20 times as much with emerging market countries that have a direct daily ﬂight to the UK as they do with those countries that do not.28 Whether addressing capacity needs, a prohibitive visa regime or uncompetitive taxes, now is the time to make sure our island nation really is ‘open for business’ in the coming years. This is particularly important if the government wants to capitalise on trade and tourism opportunities presented in the post-Olympic glow.

How aviation beneﬁts local communities where you live

11. There is considerable scope for understanding better the sheer scope of aviation’s impact on the everyday lives of us all. Despite being integrated into so many aspects of our lives, by and large the beneﬁts of aviation are taken wholly for granted. While this demonstrates the penetration, strength and fundamental importance of aviation to our society, it runs the risk that aviation becomes insufﬁciently nurtured because the roles it plays, for example in many supply chains and in providing or supporting jobs, are largely invisible. This contrasts sharply with, say, a small but visible protest outside an airport.

12. Aviation brings goods to our shops, performers to our festivals, sports stars to our stadiums, art to our galleries, tourists to our attractions and most importantly friends and family together. The electrical components which make our computers and IT gadgets work, the car parts that keep us on the road, the life-saving medicines, international aid and letters to our armed forces are all delivered by plane. The computer you may well be reading this on and the smartphone in your pocket, like so many everyday necessities, were almost certainly brought to you by plane.

13. We have argued that the benefits of the aviation industry are widespread, impacting on so many lives across the country at a very local level. To demonstrate this, we have analysed three important sectors which are crucial contributors to our economy and are dependent on aviation for their continuing success. These are tourism, inward investment and exports. We have concentrated on England, Scotland and Wales, where all sets of figures were readily available at local authority or regional level (see Annex C for region and country figures). (i.) Employment in the tourism industry — Aviation plays an essential part in the continuing success of the tourism industry, punching above its weight since those arriving by plane spend more than those arriving by other means. 75% of the 30 million visits to the UK by overseas residents in 2010 were by air but they spent 83% of the £17 billion earned from all such visits.29 This is a significant contribution to the tourist infrastructure which helps to establish its viability for all tourists both foreign and domestic. — What this means for vital jobs at the local level becomes evident by analysing the impact on each local authority. Using England as an example where there are around 2.5 million tourist industry jobs, in broad terms around one fifth of local authorities rely on tourism for more than 10,000 jobs (many of them well over 10,000). Of the remaining local authorities in England, around half have 5,000–10,000 tourism jobs and the other half 1,500–5,000. — The Aviation Foundation is currently researching local populations at considerable distance from a major international airport to demonstrate that in every corner of Britain there is an irrefutable reliance on air links. Sue and Warren Holt run the Crossroads House B&B in Carlisle. Whilst many of their guests are from Britain, they are typical of thousands of B&B owners who depend on international visitors to run a viable business. Mr Holt said: “If foreign visitors who travel by air found it difficult to do so, it would have a big impact on us. It’s the difference between being comfortable and getting by.” (ii.) Employment in foreign-owned companies — Inward investment has always played an essential role in the economy of the UK where 3.7 million jobs can be directly attributed to foreign-owned companies.30 Last year more than 112,000 jobs were created and protected in the UK by foreign direct investment.31 Transport links and easy access to markets are absolutely essential for more than half of global companies deciding where to locate their businesses.32 — Aviation is a crucial factor in providing the right kind of environment which encourages foreign companies to invest in the UK. As the Secretary of State for Transport said in his written statement to Parliament on 7 September 2012, the aviation industry “provides this country with the global connections which our businesses need to sell their products abroad and which inward investors to the UK demand.” 28 Frontier Economics, Connecting for Growth, September 2011 29 Travel Trends, International Passenger Survey, ONS 2010 30 Oxford Economics, The Value of Aviation Connectivity to the UK, 2011 31 Department for Business, Innovation and Skills press release, July 2012 32 European Cities Monitor 2010, Cushman and Wakefield cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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— Over a quarter of local authorities in England each relies on inward investment for more than 10,000 jobs. For more than half of these, the total rises to over 20,000 jobs. Foreign owned companies provide 5,000–10,000 jobs in half the remaining local authorities, with the other half falling in the 500–5,000 jobs range. — The tourism industry and foreign owned companies taken together account for employment in the tens of thousands in nearly two-thirds of local authorities in England. That is the case for nearly half of local authorities in Scotland, rising to nearly 60% of local authorities in Wales. (iii.) Exports by air — The aviation industry plays a crucial role in boosting UK exports. In 2010, goods worth £60.3 billion were exported by air, 28% of all goods exported.33 Dr Neil Bentley, Deputy Director-General of the CBI, another Aviation Foundation supporter, said: “Aviation is important, particularly for an export-led recovery.” — The table in Annex C shows the importance of exports by air for Scotland, Wales and each English region. Just over one-third (£20 billion) of total exports by air from England (£54 billion) were from London and the South East. The remaining two-thirds came from the other seven English regions ranging from £3.3 billion in Yorkshire and the Humber to £7.3 billion in the North West. — Air freight is essential for high value or time critical goods. Many sectors in the Government’s Plan for Growth cannot function without this crucial link in the supply chain. During a keynote speech in September 2012, the Secretary of State for Business, Innovation and Skills said: “We must get behind successful British-based ﬁrms in vehicles, aerospace, life sciences and creative industries and our world-class scientists and universities.” These sectors almost all depend on air freight. The majority also rely on air links to export knowledge and conduct effective business through their global networks. — The aerospace industry is a key part of the advance manufacturing sector, which relies on good air links and air freight. According to Paul Lindsay MBE of Aerospace Wales Forum, there are approximately 160 companies in aerospace and defence in Wales. This £5bn industry that directly employs 23,500 people in Wales provides yet another example of aviation keeping Britain moving.

Four key tests to secure a credible and lasting aviation policy

14. Unlike the majority of the transport network, the aviation industry is funded through private investment at limited cost to the taxpayer. However, it still requires the long-term certainty that can only come through a credible and lasting aviation policy from Government. If this is in place, the aviation industry can play a full and proper part in boosting economic growth.

15. This was at the heart of a call made by aviation, business and trades union leaders in the lead up to the announcements of the consultation and the independent Commission. Chief Executives of the companies which established the Aviation Foundation—BAA, British Airways, Manchester Airports Group and Virgin Atlantic—along with heads of the British Chambers of Commerce and the TUC, called on the Government to adopt four key tests: (i.) Deliver a clear policy conclusion that can be progressed without further delay. With years of government inactivity on aviation policy, the draft framework and the Commission’s work must result in a plan of action and the commitment to see it through—“not another fudge”, as Willie Walsh, CEO, International Airlines Group, put it. (ii.) Aim for cross-party consensus and a commitment that lasts beyond the term of one Parliament and ensures the policy will be implemented. Whatever decisions emerge from the latest policy process, history shows they will not be implemented without real leadership by all political parties. It is time for narrow political interest to be put to one side and for our political leaders to grasp the nettle and work together for the good of the UK as a whole. (iii.) Achieve cross-departmental consensus and support Britain’s economic growth, consistent with our trade, tourism, transport, environmental and climate change strategies. In the past decade, there have been eight Transport Secretaries, six Business Secretaries, six Home Secretaries and nine Tourism Ministers, but not a single strategic aviation policy that has met the country’s needs. Different Government departments promote policies on air passenger duty, visas and planning that actively work against boosting trade and tourism. If aviation is to play its full part in getting this economy moving, Treasury, BIS, DCMS, DCLG, Home Ofﬁce and DECC should be working together on a long-term aviation policy to help growth. 33 Oxford Economics, The Value of Aviation Connectivity to the UK, 2011 cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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(iv.) Be based on a policy process that has considered all options rationally and objectively on their merits. UK aviation is a hugely significant creator of wealth and employment in its own right. However, its importance goes much further than that, which is why this country should have an aviation policy that truly addresses the needs of all, whether it is business or leisure, passengers or freight, hub or point to point. In areas of the UK where recession has hit particularly hard, economic growth driven by aviation is needed more than ever. 16. There is wide support for these tests with both the British Chambers of Commerce and the TUC solidly behind the Aviation Foundation’s drive for a successful aviation policy. Brendan Barber, TUC General Secretary, said: “Trade unions have pushed the Government for a meaningful growth strategy and the aviation sector clearly has a central role to play. Aviation provides hundreds of thousands of skilled, well-paid jobs for our members. In these difficult times, such jobs are at a premium. Of course, it is vital that our environmental and climate change commitments are taken into account as we develop the sector, but I am confident that that can be done.” 17. John Longworth, Director-General, British Chambers of Commerce said: “British businesses are busting a gut to increase their exports to new and growing markets across the globe. If we want them to succeed, we urgently require an aviation strategy that delivers capacity and connectivity for today, for tomorrow, and for the long term. The government must stop tip-toeing around on aviation because of short-term political considerations. Unless politicians grasp the nettle and make some tough decisions, both our export and inward investment potential will suffer. My message to Westminster is clear: don’t condemn Britain to second-class status as a trading nation. Deliver an aviation strategy that’s actually worth the paper it’s written on.” 18. The four key tests are the benchmark against which the aviation industry, businesses and unions will judge the outcome of this policy process. The Secretary of State has already acknowledged that “the aviation industry in the UK is extremely successful”. This is no historical accident but a result of world- beating innovation during the past 100 years. Now is not the time to stagnate whilst our competitors race ahead. It is essential that Government delivers a successful aviation policy in the national interest for the benefit of the UK in the decades ahead. 18 October 2012

Annex A The following 154 organisations have signed the Aviation Foundation pledge:

“We support a successful UK aviation industry because it is vital to our work at home and abroad” 5plus Architects Aberdeen & Grampian Chamber of Commerce Aberdeen Business School, Robert Gordon University ABTA ADS Group Ltd ADT Workplace AEGIS ALG-Europraxis Consulting Ltd. Ashley Riley Communications Asian Business Association Assembly Studios Association of Event Organisers Association of Event Venues Association of International Accountants Association of International Courier and Express Services Association of Leading Visitor Attractions Atlas Infrastructure Management Limited AviaSolutions Ball Packaging Europe UK Baltic Air Charter Association cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Board of Airline Representatives in the UK Beamish Associates Bentley Motors Best of the Best Bird & Bird Boeing UK Brazilian Chamber of Commerce Bridge the World British Chambers of Commerce British Hospitality Association British International Freight Association British Vehicle Rental and Leasing Association BritishAmerican Business Brodericks Love Coffee Bruntwood BT Burges Salmon Business to Business Business Visits and Events Partnership Cambridgeshire Chambers of Commerce CBI CBRE Ltd Chelsea FC China-Britain Business Council CMS Cameron McKenna Confederation of Passenger Transport UK Creative Solutions Critical Divide Daisy Group Demys Limited Event Supplier and Services Association Eversheds EYE Flower Import Trade Association Flower Wholesale Trade Association Free The Children Freight Transport Association G4S GE GMB GTMC Harbottle & Lewis Harrods Aviation cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Herbert Smith Hounslow Chamber of Commerce ICAP Institute of Directors Institute of Travel & Meetings International Export Supplies Ltd JAB Business Services Jaguar Land Rover James Aviation JP Morgan Cazenove Kia Motors UK Kier Infrastructure & Overseas Ltd KKR L.E.K Consulting Leeds, York & North Yorkshire Chamber of Commerce LeighFisher Liverpool FC Lloyds Bank London Chambers of Commerce London First London Stock Exchange Group M2 Macfarlanes Management Consultancies Association Manchester Central Convention Complex Manchester City Council Manchester Science Parks Manchester Vending Services MAPP IT & Business Management Recruitment Specialists Marketing Kinetics Marsh Middle East Association MWH Nathaniel Lichﬁeld & Partners National Private Hire Association National Taxi Association Newport Business Association Norfolk Chamber of Commerce NSG Group Nuance p3 property consultants Pannone LLP PAPR cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Pascall+Watson Architects Petroplastics and Chemicals Ltd Planit-ie Ltd Polymorph RDC Aviation Renault UK Rexam Road Haulage Association Robertson Group Rolls-Royce Russo-British Chamber of Commerce Salans Scottish Chambers of Commerce Scottish Council for Development and Industry Simpson Thacher & Bartlett SNR Denton UK STA Travel Stansted Airport Chamber of Commerce Stork & May Suffolk Chamber of Commerce Swordpoint Advisors Ltd T2 Impact T2 Impact Ltd The Caribbean Council The Licensed Private Hire Car Association The Meetings Industry Association The Monarch Travel Group The Original Factory Shop TheCityUK Tie Rack TIGA Timeshare Association (TATOC) Tourism Alliance Tower Hill Merchants Transport for Greater Manchester TUI Education TUI Travel UK Inbound United Utilities University of Glamorgan University of Salford Urban Futures Virgin Money cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Warren Partners Whitbread WHR Property Consultants World Duty Free WPP Group

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Annex C Region/Country Exports by Region34 Tourist Tourist 2010 industries35 Inward investment industries & Foreign Owned inward Total By Air Local Units36 investment £m £m % Employment Units Employment Employment East Midlands 15,210 4,759 31 195,600 5,625 249,565 445,165 East of England 22,732 6,299 28 241,300 8,215 301,305 542,605 London 28,446 7,287 26 518,800 19,140 737,077 1,255,877 North East 11,924 3,559 30 105,300 3,190 143,179 248,479 North West 24,659 7,262 29 323,900 9,910 375,866 699,766 South East 41,956 12,198 29 408,300 15,260 583,502 991,802 South West 11,100 3,530 32 287,100 7,535 256,507 543,607 West Midlands 17,450 5,410 31 226,400 7,695 314,345 540,745 Yorkshire and 14,039 3,294 23 229,400 6,960 255,706 485,106 The Humber Total England 187,516 53,598 29 2,536,100 83,530 3,217,052 5,753,152

Scotland 14,658 2,932 20 273,100 7,770 270,509 543,609 Wales 11,800 2,775 24 128,900 3,250 139,438 268,338

TOTAL 213,974 59,305 28 2,938,100 94,550 3,626,999 6,565,099

Written evidence from Vanderlande Industries UK Ltd (AS 34) Introduction This submission is made on behalf of Vanderlande Industries UK Ltd, part of Vanderlande Industries, the Dutch automated material handling systems provider that ranks among the top ﬁve worldwide in the materials handing ﬁeld and is the largest supplier and operator of baggage handling systems in the world.

1. Vanderlande Industries UK The main activity for Vanderlande Industries UK is the development, design, installation and maintenance of innovative baggage handling solutions for airports of all sizes. As a result, the company helps to create and sustain a secure baggage handling process with the highest passenger satisfaction and the lowest total cost of ownership. Vanderlande Industries UK contends that: — environmentally friendly, cost effective and state-of-the-art baggage handling systems are a major cornerstone in developing an integrated and sustainable UK aviation policy; — any sustainable UK aviation policy must entail capital investment in the infrastructure around regional UK airports; — rigorous R&D around baggage handling systems plays a crucial role in developing existing and new handing techniques that are energy efficient, cost effective and environmentally friendly; and are capable of reducing the energy consumption of the baggage handling system by up to 50%, or up to 10% of an airport’s overall energy consumption.1 — State–of-the-art baggage systems can make a significant contribution to balancing resilience and capacity within current areas of terminal real estate, and can help airports deal more efficiently with increasing volume of passengers while also reducing check-in queuing, improving the passenger experience and energy consumption.

2. Does the Government’s current strategy make the best use of existing capacity at airports outside the south east? How can this be improved? 2.1 Vanderlande’s views By careful terminal design an up-to-date check-in and baggage handling system can be used to increase capacity in the UK’s existing infrastructure in an environmentally friendly way, and to improve an airport’s overall profitability. Regional airports can and do absorb the pressure not only on the constrained major airports, but also on intercity rail and road links by being part of an integrated air transport system. Efficient regional airports with efficient check-in and baggage handling systems encourage people to fly from their nearest 34 Oxford Economics, 2010 35 Business Register and Employment Survey, ONS, 2009 36 ONS, Count and Employment of VAT and/or PAYE based Foreign Owned Local Units by Region and Country of the UK by employment size band for 2010 cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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regional airport rather than travel to major airports. This has positive environmental and energy reduction implications.

2.2 Supporting background information (a.) Vanderlande Industries UK aims to help airports minimise waiting times at check-in and reduce cost by using innovative baggage handling technology, thus avoiding the need for additional space to cope with growth. It provides airports with a consultative sales approach that includes advice on how they can do more with less, with an eye for increasing airport revenue. (b.) Vanderlande Industries helps airports increase profitability by helping to provide the means to handle additional passenger numbers, while maintaining energy efficiency. Vanderlande Industries systems are fast and efficient, allowing passengers to move to airside facilities quicker, giving them more time to use air-side retail outlets. Self-tagging automated check-in kiosks and automated early bag storage facilities provide this efficiency. (c.) Vanderlande Industries UK is making a significant contribution to balancing resilience and capacity within current areas of real estate. Vanderlande Industries UK’s state of the art technology such as BAGLOAD, integrated robotic baggage loading helps airports deal with an increasing volume of traffic and minimises delays for flight make-up. This not only improves the passenger experience, but also reduces handling costs for airlines as well as adapting the process and environment to a higher degree of automation. The BAGLOAD system together with Vanderlande Industries UK systems integration, work together to provide airports, airlines and ground handlers with the optimum level of automation. It saves costs through efficient employee assignment, integrated baggage reconciliation, less health related costs and efficient use of space. It also improves employee working conditions; improves process quality by reduction of errors and improves bag security. (d.) Vanderlande Industries UK’s work with regional airports is aimed at making these airports as efficient as possible without having to expand. Increased efficiency encourages local passengers to use their regional airports, thereby making the airports more profitable. Vanderlande is developing and improving a number of baggage handling systems that can be tailored to the size and capacity of the airport. (e.) Vanderlande’s BAXPACE concept is especially interesting for regional or smaller airports that are looking to automate their baggage handling process. BAXPACE is a compact and cost-efficient solution integrating all baggage handling tasks including check-in, early bag store, screening, manual coding and flight make-up within existing terminal baggage halls. Baxpace can help an airport realise a reduction of up to 30% in labour costs and up to 40% savings on energy consumption. (f.) BAXORTER from Vanderlande is a cost effective mid-range baggage sorting system that meets a wide range of airport demands. The BAXORTER has a capacity of 2,500 bags per hour and high flexibility in number of outputs to flights or destinations. This makes it ideal for many smaller to medium-size airports, where it meets demands for cost effective solutions for a wide range of environments; flexibility in system layout and configuration; and scalability for future needs.

3. How do we make the best use of existing London airport capacity? What more could be done to improve passenger experience and airport resilience? 3.1 Vanderlande’s views Efficient air transport connections—both international and domestic—are important for the fast movement of goods and people and, therefore, make an important contribution to the competitiveness of the UK economy. An integrated air transport system reduces carbon footprints (less reliance on cars), saves energy (more efficient means of transportation) and is cost effective. However an integrated air transport system will only begin to meet its environmental, energy reduction and cost effective targets if its airports have an efficient and up to date automated baggage handling and check-in system. The two most important aspects of the passenger experience are speedy movement through border control and deposit/collection of baggage.

4. Do we need a step-change in UK aviation capacity? Why? What are the costs and benefits of these different ways to increase UK aviation capacity? How should improving the passenger experience be reflected in the Government’s aviation strategy? 4.1 Vanderlande’s views To date UK aviation policy has largely ignored the contribution state of the art baggage handling systems can make to the passenger experience, environmental, energy efficient and profitability of UK airports. Vanderlande believes that this is a mistake and any sustainable UK aviation policy should take into account the central role that modern baggage handling systems play in fulfilling such a policy’s aims. In particular, up to date baggage handling systems improve the passenger experience as a result of less queuing at check-in, a swifter move airside, the speedier movement of bags to a secure area, less disruption of flight schedules and a reduction of congestion in terminals. Furthermore, any sustainable UK aviation policy must entail capital investment in the infrastructure around regional UK airports. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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4.2 Supporting background information (a.) Vanderlande Industries UK makes an important contribution to the local economy at the airports where it has installations, by enabling airports to operate more profitably, efficiently and in an environmentally friendly manner. In particular, it has made a substantial contribution to the creation of permanent jobs by helping airports increase capacity and providing a better passenger experience. (b.) At its UK offices in Harlington, Hayes, Vanderlande Industries UK employs 64 staff and at Heathrow Airport, employs 185 staff. (c.) A ComRes Omnibus Poll commissioned in April showed that 76% of respondents thought that state of the art baggage handling systems free up terminal space and lead to improved passenger experience in airports while only 7% disagreed.2 (d.) In the same ComRes Omnibus poll 80% of respondents thought that any sustainable aviation policy must include investment in UK airport buildings in order to provide better facilities such as more terminal space and better baggage handling systems while only 6% disagreed.2 18 October 2012

References 1. From a power consumption study carried out by Vanderlande Industries at a UK Regional Airport in 2011 2. ComRes Omnibus Poll—Baggage Handling Systems and a Sustainable Framework for UK Aviation, April 2012

Written evidence from Zac Goldsmith MP (AS 35) Summary — A third runway at Heathrow would be a noise and air quality disaster and would lead to a serious reduction in the quality of life for hundreds of thousands of London residents. — If there is a need for a four-runway “hub”, as most airport expansion advocates maintain, that is unlikely to be delivered at Heathrow. Indeed even the proposed third runway would be less than full length. The third runway therefore represents a dead-end investment. — The UK is currently one of the best-connected countries in the world and London remains the top city in Europe to do business. — We should focus on making better use of London’s existing airport capacity through more efﬁcient airport slot allocation and improving the transport links to London’s other airports (such as a Crossrail extension to Stansted) so that Heathrow could shed some of its short-haul and “point-to- point” trafﬁc to concentrate on long haul services to the emerging markets. — There is something approaching consensus that the independent commission on aviation chaired by Sir Howard Davies should bring forward its timetable so that the Government can make clear its position on Heathrow for the next Parliament ahead of the 2014 London local elections.

Maintaining the UK’s international aviation connectivity 1. It is a myth that the UK is falling behind in its international aviation connectivity. According to the Department for Transport: “The UK is currently one of the best connected countries in the world. We are directly connected to over 360 international destinations”.i In 2011 there were more scheduled flights from Heathrow to both India (over 5,500 scheduled flights) and China (over 4,500 scheduled flights when Hong Kong is included) than any of its continental rivals. There were also over 1,000 scheduled flights from Heathrow to Brazil. New direct routes are opening up from London to the emerging economies including Heathrow to Guangzhou (China Southern Airways, June 2012) and Gatwick to Beijing (Air China, May 2012). 2. A recent report published by AirportWatch finds that Heathrow is in a class of its own as far as connectivity with more flights to business destinations than any other airport in Europe, in fact more than the combined total of Charles de Gaulle and Frankfurt. The Heathrow pro-expansion lobby try to argue that Paris and Frankfurt enjoy 1,000 more flights per year to the three largest cities in China than Heathrow does, but if you look at Heathrow’s connectivity to China’s cities ranked by GDP rather than population alone, Heathrow is well placed. For instance, Heathrow has 1,938 more annual flights to Shanghai, Hong Kong and Beijing than Frankfurt and 1,426 more than Paris Charles de Gaulle. Furthermore, whilst Heathrow offers non-stop service to 82 long haul destinations, compared with 77 from Paris and 75 from Frankfurt, its lead in the numbers of seats is extremely large: 25 million, compared with 14 and 13 million for Paris and Frankfurtii. Heathrow remains the EU’s busiest passenger airport with 66 million passengers handled a yeariii. 3. According to the World Economic Forum Global Competitiveness Report 2011–2012, using available airline seat kilometres as a connectivity metric, only China’s and the USA’s aviation networks are more extensive than the UK. Germany and France are in fifth and eighth place respectively.iv According to an cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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assessment of the current aviation connectivity of London by the Civil Aviation Authority (CAA), the five main London airports serve more routes than any other European city.v 4. In addition, London remains the top city in Europe to do business and for business as a whole, other factors such as the strength of the business environment are of greater importance than the size of Heathrow. The World Bank ranks the UK as the market leader for ease of doing business amongst the major European economies. The Financial Times, through its fDi Intelligence Report 2012, ranks the UK as the primary FDI location in Europe. UNCTAD reported 7% growth in the UK’s FDI inflows to reach US$53.9 billion in 2011. It also confirmed the UK as the largest recipient of FDI stock in Europe, and second in the world behind the US, ahead of Hong Kong and France. The level of FDI stock in the UK rose 3% to reach US$1,198 billion.vi 5. According to UKTI, Foreign Direct Investment in the UK manufacturing sector increased in 2011–2012 by 22% from 2010–11 with existing investors showing their confidence in UK manufacturing with substantial investments from Tata, Nissan, Toyota, Honda, Sahaviriya Steel Industries and Nestlé in 2011–12. China was the third-largest investor in the UK, up from seventh the year before, with investment increasing by over 55%. Examples include the establishment of Agricultural Bank of China’s UK subsidiary, the first step in its global programme, and Huawei.vii 6. It is important to note that all these foreign companies invested after the Government had cancelled the BAA application for a third runway and a sixth terminal at Heathrow and made clear its opposition to further expansion. These recent investments reinforce the underlying message that the strength of the business environment is of greater importance than the size of Heathrow, and that London remains the “best city in terms of external transport links”. These were the words of the annual and influential survey carried out by global property consultants Cushman & Wakefield, The European Cities Monitor. London topped the league table “by some distance from its closest competitors—as the leading city in which to do business” for the 22nd year out of 22.viii

How should we make the best use of existing aviation capacity? 7. I recognise that Heathrow is the UK’s busiest and most capacity constrained airport, and the importance of securing both Heathrow’s hub status and increasing its links to the emerging markets in Asia and South America, but new runways or a new airport are not the answer. We should focus on making better use of London’s existing airport capacity and existing runways. After all, if the logic of the pro-expansion argument is followed to its natural conclusion not only should a third runway be added but also a fourth. The solution is a better not bigger Heathrow. This could involve a number of steps: 8. Planes aren’t full. In 2011, the average seat occupancy rate on flights at Heathrow was estimated to be 73% on both departing and arriving flights.ix More occupied planes mean more people can fly without any rise in the number of flights. Given concerns over the legality and feasibility of introducing a per-plane Air Passenger Duty (APD), I would urge the Committee to consider the alternative proposal for introducing a tax on slots for arriving and departing aircraft. 9. In addition, Heathrow could shift some of its short-haul traffic to concentrate on long-haul services. A large number of runway slots at Heathrow could be usefully allocated to longer-haul business flights—the category deemed most beneficial to the UK economy. According to Department of Transport’s figures, of the estimated 35 million passengers arriving at Heathrow in 2011, almost a third (11 million) were terminating passengers coming off short-haul flights:

Heathrow Airportx THE ESTIMATED NUMBER OF TERMINATING AND TRANSFER PASSENGERS ARRIVING FROM SHORT AND LONG HAUL ROUTES AT HEATHROW IN 2011 IS GIVEN IN THE FOLLOWING TABLE. Estimated number of arriving passengers million Terminating Transfer Short-haul (including domestic) 11 5 Long-haul 12 6 Total 23 12

10. While many short haul flights are important to Heathrow’s hub status, and would be less suited to shifting elsewhere, many are simply clogging up the slots that could be better used by intercontinental flights from the emerging markets. The recent Policy Exchange report on aviation stated that “there are many airlines with very few connecting passengers who continue to use Heathrow. The CAA state that the Skyteam airline alliance has just 400,000 connecting passengers a year. With around 300 departures per week from Heathrow this implies about a dozen connecting passengers per flight. Given that some will have more connecting passengers, and some fewer, it must be the case that some have very few connecting passengers at all.”xi Furthermore, given that 66% of passengers arriving at Heathrow are terminating passengers, nearly double the number of transfer passengers, it suggests that they could easily use another London airport. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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11. To relieve pressure on Heathrow, and boost its hub status, a priority must be to shift point-to-point tourist flights to non-business places (like Cyprus and Greece which between them take up nearly 2% of slots).These less economically important routes could be shifted to another airport to free up slots for new, predominantly long-haul routes to more economically important countries. 12. London is served by six airports and seven runways; compared to Paris by three airports and eight runways, Amsterdam by one airport and five runways; Frankfurt by two airports and five runways; and Madrid by one airport and four runways. Collectively there is spare capacity. Stansted is only operating at 50% capacity and actively seeking to add more airlines flying to more destinations. Stansted has spare capacity now—enough to handle double the number of passengers it does today and any aircraft from anywhere in the world. 13. Airlines could relocate their operations from Heathrow to Stansted without the need for runway expansion. It has the space, infrastructure and planning permissions in place to serve 35 million passengers a year on the existing single runway—passenger numbers are currently just under 18 million. It is worth noting that the conditions that were agreed as part of the planning process provide a robust and comprehensive package of noise and environmental controls for the benefit of the local community. 14. To enable full use of Stansted, the Government should press ahead with major rail improvement schemes to Stansted. It should also consider improvements to links from central London to Luton and Gatwick, and regional airports near London such Birmingham, London Southend airport and London Oxford Airport. 15. The Government says that the UK Government and Civil Aviation Authority have no role in airport slot allocation processes as EU regulation governs the allocation, transfer and exchange of slots at Heathrow, Gatwick, Stansted and London City airports; and Airport Co-ordination Ltd, as the UK’s independent slot co- ordinator, manages slot allocation at these airports. However, Section 31 of the Airports Act 1986 provides the Secretary of State for Transport with powers to introduce air traffic distribution rules (TDRs) relating to airports on the UK, provided that they comply with EU law.xii If we are to see better coordination between airports, and better use of existing capacity, the Government will need to adopt a proactive role in slot allocation. 16. The European Commission published its “Better Airports Package” on 30 November 2011, which includes a range of legislative proposals, including proposals to amend the EU Slot Regulation, which are intended to help boost capacity, reduce delays and promote quality at Europe’s airports. The Department for Transport has already stated that it is “working with the EU, in the context of the Commission’s proposals on reform of the rules on landing slots to secure measures to support UK regional connectivity, such as protecting the provision of air services between Northern Ireland and Heathrow”. I believe that the Government should similarly take steps to explore options, within the EU legislative framework, to regulate the distribution of air traffic and allocation of slots between the airports to secure measures that both increase Heathrow’s international aviation connectivity and ensure that slots at Heathrow are used in the way most economically beneficial to the UK. Airlines that are likely to be attracted by the freed capacity would include the various Asian airlines that would be able to acquire a relevant number of slots for the first time and thereby increasing the range of destinations served from Heathrow. I urge the Committee to explore this policy avenue.

How can surface access to airports be improved? 17. The Government says that it recognises the importance of good surface access transport links to airports and the crucial role the public sector must play in their delivery. Customers prefer Heathrow to either Gatwick or Stansted because it is easy and cheap to get to. If surface access transport links to airports were improved, that will allow airlines currently operating at Heathrow to consider moving to another airport. As stated above, Stansted is massively underused, currently by about 50%, and with proper rail links to the City, it would be the natural place for point-to-point flights that do not require transfer passengers to be viable. 18. Steve Norris has argued for a Crossrail extension to Stansted: The Crossrail links east and west London via a tunnel under the heart of London. It joins the City and Canary Wharf to Heathrow and transforms Farringdon and Smithfield. From east of Stratford a 10-kilomietre rail tunnel spur emerging at Fairlop Water and following the line of the M11 could link Stansted directly to Central London. There is the capacity for six trains an hour, more than the Heathrow or Gatwick expresses. Journey times to Tottenham Court Road or Bond Street would be around 40 minutes Steve Norris in The Times. Expanding Stansted is the least worst option. 13 September 2012. .xiii A Crossrail extension to Stansted now has the support of the Mayor of London Boris of Johnson: “You could be [up there] just as fast, if not faster, than at Heathrow.xiv 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? 19. The current 480,000 air transport movement cap was set as a condition of the Terminal 5 planning consent in 2001. A third runway would require an increase in the number of air transport movements allowed at Heathrow. To change or remove the cap would require a planning application.xv The Labour government constrained capacity at Heathrow with a third runway until at least 2020 to 605,000 ATMs—and full capacity would have been 702,000 ATMs. 605,000 ATMs equates to 125,000 additional movements compared to the current cap of 480,000 ATMs at Heathrow; 702,000 ATMs equates to 222,000 additional movements. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Noise 20. The Government consultation on its draft aviation strategy stated that “The Government’s opposition to the building of a third runway at Heathrow was, and continues to be, determined in large part by a concern about the scale of the noise impacts at the airport”.xvi More than a quarter of all people in Europe who are affected by aircraft noise pollution are under the Heathrow flight path. Estimates for the number of people affected vary from 700,000 to as high as 2 million, depending on the study and the level of noise taken as sufficient to cause a nuisance. A third runway at Heathrow would only increase the scale of the noise impact. 21. Furthermore, as the Environment Committee of the London Assembly highlighted in its report “Plane Speaking: Air and noise pollution around a growing Heathrow Airport, March 2012”, of particular concern is the significant contribution to poor air quality made by people using private cars and taxis to get to and from the airport. At the moment almost two-thirds of the 66 million passengers using Heathrow every year travel by car. Once the current redevelopment and construction projects at the five terminals are completed, from around 2014 onwards Heathrow will have the capacity to handle up to 95 million passengers a year. This will clearly have implications for local residents and communities, facing the probable prospect of increased road traffic, even poorer air quality and more noise.xvii 22. A third runway with the accompaniment increase in the number of air transport movements would only serve to compound this impending impact further with the ensuing increased road traffic, poorer air quality and more noise—and a serious reduction in the quality of life for hundreds of thousands of people. The aviation industry has not explained how London is supposed to deal with the estimated 25 million extra road passenger journeys each year to and from Heathrow. It seems likely that such an increase would cause gridlock, with dire consequences for London’s economy.

Air Quality 23. Aviation contributes to nitrogen dioxide pollution near airports through aircraft engine emissions, airport operations and road transport to and from airports.xviii EU air quality limits for nitrogen dioxide (NO2) are not met at Heathrow and the surrounding area. A third runway would lead to 702,000 ﬂights using Heathrow a year, a 46% increase on today, and, as the Government has said, would result in an unacceptable level of environmental damage to the quality of life of local communities. It’s self-evident that the lives of two million Londoners would be signiﬁcantly affected by aircraft noise if Heathrow expansion goes ahead.

24. London already has the worst air quality of any European capital. There were a near-identical number of deaths reportedly from air pollution in London in 2008 as the 4,000 people who died as a result of the Great Smog of London in 1952. Heathrow expansion would undoubtedly make the situation much worse. Given that legal air quality limits are already breached at Heathrow and the surrounding area, the event of a third runway would make compliance impossible.

25. Paragraph 22 of the Environmental Audit Committee’s report on Air Quality stated:xix

Defra’s consultation for an extension to meet EU NO2 limit values states that Greater London compliance is not expected to be achieved before 2025.xx EU air quality limits for NO2 are not met at Heathrow and the surrounding area. DfT recognises that aircraft engine emissions, airport operations and road transport to and from airports contributes to NO2 pollution near airports.xxi In the event of a third runway being developed at Heathrow, compliance with NO2 limits would be impossible. The Government has made clear their opposition to a third runway at Heathrow and BAA announced in May 2010 that it had stopped work on a planning application for such a proposal. However, for the Government to make the case that compliance with EU air quality limits throughout Greater London will be maintained beyond 2015, their application for an extension to meet EU limit values, the forthcoming Sustainable Framework for UK Aviation and the forthcoming Aviation National Policy Statement must contain an explicit prohibition of a third runway at Heathrow.

26. The Government’s response to the EAC’s report cited the commitment made in the National Infrastructure Plan (NIP), published on 29 November 2011, that the draft aviation policy framework would “explore all the options for maintaining the UK’s aviation hub status, with the exception of a third runway at Heathrow: “The Government has therefore made absolutely clear its opposition to a third runway at Heathrow”. However, the fact that the Government has asked the independent commission on aviation chaired by Sir Howard Davies to conclude just a few weeks after the election shows that the Government has no opposition to a third runway at Heathrow proceeding in the next Parliament. Transport Secretary Patrick McLoughlin conﬁrmed this when he said that “all options are on the table” in his ﬁrst major interview in post.xxii

27. The UK has already requested a ﬁve year extension to the 2010 compliance deadline for 24 of out of the UK’s 43 air quality zones last year. However, the commission has rejected the request for 12 of the zones on the grounds that the UK had not demonstrated that compliance with limit values could be achieved by 1 January 2015 or earlier (EC Commission decision 25 June 2012). The Government has to demonstrate compliance with the limit values in London by accepting the EAC recommendation and set out an explicit prohibition of a third runway at Heathrow. I urge the Committee to reject the “all options are on the table” approach and recommend that the Government accepts the recommendation of the EAC. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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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? 28. The Government has not made a decision on accepting the recommendations of the Committee on Climate Change in its report, Meeting the UK aviation target-options for reducing emissions to 2050, December 2009. And, the Government has made no assessment of the compatibility of a third runway at Heathrow with the Committee’s recommendations.xxiii 29. I urge the Committee to press the Government to make a decision and accept the recommendations of the Committee on Climate Change and undertake an assessment of the compatibility of a third runway at Heathrow with the Committee’s recommendations.

Do we need a step-change in UK aviation capacity? Why? 30. Relying on capacity at different locations will cater for point-to-point demand and relieve pressure on Heathrow, allowing it to maintain and improve its hub status. This, coupled with improved transport links to Stansted, will create a dual hub, with high value eastern-facing business journeys making use of Stansted, and western facing ﬂights making use of Heathrow. Other suggestions for improving connectivity include proposals for a 15-minute airside high-speed rail link between Gatwick and Heathrow to create in effect one London hub airport over two sites with three runways, with one airport as a terminal of the other, but given its position, extra capacity and the potential to link it to the City by extending Crossrail, Stansted seems to offer the best solution. More point-to-point routes meanwhile could be handled from Gatwick and other airports. 18 October 2012

References i Department for Transport. Draft Aviation Policy Framework. July 2012. http://assets.dft.gov.uk/ consultations/dft-2012–35/draft-aviation-policy-framework.pdf ii Frontier Economics. Connecting for growth. September 2011. http://www.frontier-economics.com/_library/publications/Connecting%20for%20growth.pdf Table 5. iii Eurostat. Air passenger transport in the EU27 in 2010. 14 May 2012. http://europa.eu/rapid/ pressReleasesAction.do?reference=STAT/12/72&format=HTML&aged=0&language=EN&guiLanguage=fr iv Department For Transport. Draft Aviation Policy Framework. July 2012. http://assets.dft.gov.uk/consultations/dft-2012–35/draft-aviation-policy-framework.pdf v CAA. Aviation policy for the consumer. vii UKTI. Inward Investment Report 2011/2012. 26 July 2012. viii Cushman & Wakefield. The European Cities Monitor. 2011. ix Hansard. Heathrow Airport. 2 July 2012: Column 441W http://www.publications.parliament.uk/pa/cm201213/cmhansrd/cm120702/text/ 120702w0002.htm#12070247001246 x Hansard. High Speed 2. 3 October 2011: Column 1387W http://www.publications.parliament.uk/pa/ cm201011/cmhansrd/cm111003/text/111003w0001.htm#1110033001277http://www.publications.parliament.uk/ pa/cm201213/cmhansrd/cm120903/text/120903w0007.htm#12090412001445 xi Policy Exchange. Bigger and Quieter—The right answer for aviation. 5 October 2012. http://www.policyexchange.org.uk/images/publications/bigger%20and%20quieter.pdf xii Hansard. Air Traffic. 9 July 2012: Column 67W http://www.publications.parliament.uk/pa/cm201213/ cmhansrd/cm120709/text/120709w0003.htm#1207104000650 xiii Steve Norris in The Times. Expanding Stansted is the least worst option. 13 September 2012. xiv Daily Telegraph. Boris Johnson backs new runway at Stansted. 18 June 2012. http://www.telegraph.co.uk/news/aviation/9339749/Boris-Johnson-backs-new-runway-at-Stansted.html xv Hansard. Heathrow Airport. 3 October 2011: Column 1387W http://www.publications.parliament.uk/pa/ cm201011/cmhansrd/cm111003/text/111003w0001.htm#1110033001277 xvi Department For Transport. Draft Aviation Policy Framework. July 2012. http://assets.dft.gov.uk/consultations/dft-2012–35/draft-aviation-policy-framework.pdf xvii London Assembly. Plane Speaking. March 2012 http://www.london.gov.uk/sites/default/files/Heathrow%20airport%20-%20Final%20version_0.pdf xviii Hansard, Heathrow Airport Pollution, 23 May 2011: Column 373W http://www.publications.parliament.uk/ pa/cm201011/cmhansrd/cm110523/text/110523w0001.htm#11052329000177 cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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xix Environmental Audit Committee Air quality: A follow up report. Ninth Report of Session 2010–12. 14 November 2011. xx Defra, Air Quality Plans for the achievement of EU air quality limit values for nitrogen dioxide (NO2) in the UK, 2011 xxi DfT, Developing a sustainable framework for UK aviation, 2011 xxii Evening Standard. “I wasn’t made Transport Secretary to push through third runway at Heathrow...all options are on the table” 27 September 2012. http://www.standard.co.uk/news/politics/i-wasnt-made-transport-secretary-to-push- through-third-runway-at-heathrowall-options-are-on-the-table-8181588.html xxiii Hansard. London Airports. 16 April 2012: Column 55W http://www.publications.parliament.uk/pa/ cm201212/cmhansrd/cm120416/text/120416w0003.htm#12041626000294

Written evidence from Assurity Consulting (AS 36) 1. Assurity Consulting is an independent workplace compliance consultancy specialising in health, safety and environmental solutions. We provide services to large corporate companies, property management companies, charities, independent schools, universities and colleges, both nationally and internationally. We employ 70 people at our offices in Horsham, West Sussex, which is within the Gatwick Diamond business area. 2. As a company that uses all forms of transport to travel to our customer’s sites we need sufficient aviation capacity along with a fair tax regime to ensure we remain competitive both nationally and internationally. Many of our corporate customers are moving to single suppliers to support them across Europe, Middle East and Africa. To ensure we are able to compete for this work we need to be able to demonstrate an efficient and cost effective service. With the uncertainty over UK aviation strategy and the cost of Air Passenger Duty, this is becoming increasingly difficult to achieve. 3. As an example of the additional cost we have to recover when quoting for work, which involves air travel, our company paid £3,300 in Air Passenger Duties on 214 flights during the last year (October 2011—September 2012). This equates to 11% of the total cost of the flights. This means we have to add 11% of the flight cost to all our quotes to recover the cost of this Duty. This makes us less competitive when quoting for work, which involves air travel. Alternatively, we can absorb this cost, which means we have less profit to re-invest in our company. Therefore, we would like to see Air Passenger Duty reduced or better still scrapped. 4. As we are based in West Sussex our local airport is London Gatwick. We prefer to use this airport for air travel as it allows us to reduce our travel time, cost and carbon emissions. At the current time, it only has one runway, which reduces the number of flights that can take off and land at times convenient for business travelers, ie early morning and early evening. Therefore we would like serious consideration to be given to installing a second runway at London Gatwick Airport, so it can better service the needs of companies based in the Gatwick Diamond business area. 5. Finally, the surface access to London Gatwick Airport relies on a “free-flowing” M23. When this road is blocked or restricted by road works, severe congestion quickly occurs, which can result in our employees missing their flights. An alternative route to London Gatwick Airport should be considered, which is of an equal standard or better to the existing motorway. This will help ease congestion and will also allow for the growth in traffic that will occur if a second runway is installed. I hope these items will be included in the Transport Committee’s inquiry into aviation capacity in the UK and the Governments aviation strategy. 18 October 2012

Written evidence from Marilyn Fletcher B.Sc.Ph.D. (AS 37) 2c. HS2’s Access to Britain’s Hub Airport 1. The Secretary of State appears to have concerns over how HS2 is connected to Heathrow. On 29 September 2012 the Telegraph newspaper reported Mr McLoughlin saying that HS2 may have to be “adapted” depending on what Sir Howard Davies, the economist leading the Government’s airport commission, recommends about Heathrow. 2. Sir Howard’s full report is due in 2015.37 According to the newspaper, aides acting for the Secretary of State made it clear that the route could be redirected towards Heathrow if Sir Howard recommends expanding the airport.38 37 “Aviation” delivered by the Secretary of State 7 September 2012 http://www.dft.gov.uk/news/statements/mcloughlin-20120907a/ 38 Sunday Telegraph 29 September http://www.telegraph.co.uk/news/uknews/9576183/HS2-rail-line-could-be-re-routed-to- Heathrow.html cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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3. How has HS2 been allowed to get so far without any decision on Britain’s hub airport? How has the Government allowed itself to commit £750 million of public money in this Parliament on laying down a route for HS2 before it decides on the location for the hub airport? 19 October 2012

Written evidence from IATA (AS 40) The UK plays a key role in international air transport. After the US, it is the largest market for international passenger services. If our forecasts are correct, in 2015 we expect 205 million people to travel to or from the UK—accounting for about one in every seven international air travelers. The UK will also rank seventh for international freight by handling about 2.2 million tonnes of cargo. Today, the contribution of aviation to the UK economy is substantial. The Aviation sector contributes 49.6 billion pounds (or 3.6%) to UK GDP. It supports 921,000 jobs in the UK, and pays 7.9 billion pounds in tax.

1. What should be the objectives of Government policy on aviation? Recognizing the critical role of aviation in the British economy and society, the overarching objective of UK government aviation policy should be to promote the growth of aviation connectivity in a safe, cost- effective and environmentally sustainable manner. a. How important is international aviation connectivity to the UK aviation industry? International aviation connectivity is critical to the UK aviation industry, to UK businesses and to the UK economy as a whole. According to the UK Civil Aviation Authority, 80% of passenger trips are international. As an island nation, international air connectivity is essential for the UK aviation industry to compete and grow in a global market. Such connectivity is maximized via a world-class hub airport. A hub adds economic value by facilitating connectivity that could not be supported independently. The UK’s international aviation hub is Heathrow, and has been for decades. But Heathrow is falling behind in connectivity. London has less frequent links to 27 emerging market destinations than the daily connections offered from continental European hubs. There are no direct services, for example, to major cities such as Jakarta, Manila, Santiago or the major Chinese cities of Guangzhou, Chengdu or Shenyang. If the UK wants to do business with these developing markets, air connectivity is the enabler. But with Heathrow operating at 99% capacity, new services can only be introduced at the expense of downgrading existing connections. Recently Frontier Economics calculated the cost of declining connectivity at GBP 14 billion in lost trade over the next 10 years. As a consequence of constraints at Heathrow, airlines are unable to expand their route networks to serve growing international demand. The Frontier Economics study estimated that Heathrow could serve far more destinations than it currently does. The connectivity gap includes 45 long haul destinations that could be viably added to airlines’ route networks, including 15 in emerging markets, while the frequency of service on existing routes could be enhanced. b. What are the benefits of aviation to the UK economy? Aviation in the UK is at the center of over GBP 90 billion of economic activity and supports the livelihoods of nearly 1.8 million people. But aviation’s influence extends much further. Could London function as a global financial center without air transport linking the City to its global customer base? Would the UK be a leading force in global culture without access to global influences? How would exporters get time sensitive shipments to markets around the world, or just-in-time manufacturers receive component parts? And would it be possible for the UK to derive the economic, social and national branding benefits of hosting 17,000 athletes, 60,000 support staff and hundreds of thousands of spectators for the Olympics? The UK punches above its weight globally because of air connectivity. And its economic prospects grow in tandem with air service improvements. Oxford Economics tells us that for every 10% improvement in connectivity, GBP 890 million is added to the UK’s long-run annual GDP. c. What is the impact of Air Passenger Duty on the aviation industry? The ever increasing Air Passenger Duty (APD) is a GBP 2.9 billion annual burden on UK businesses reliant on connectivity. Passenger demand is growing more slowly than at other European hubs because the APD is pricing air travel out of the range that consumers can bear. In Northern Ireland, APD meant that international services could no longer be competitive. APD there was reduced to retain the economic benefits of air connectivity. Unfortunately the wisdom of that decision did not extend to the rest of the UK. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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To put some numbers to the economic burden of APD, we estimate that the planned increase in the APD alone will result in GDP losses of about GBP 300 million per year and 7,000 job losses. To ensure that the UK is “open for business,” the national aviation policy must include bringing the cost of connectivity down to make the cost of doing business here competitive. Furthermore research commissioned by the World Travel and Tourism Council and carried out by Oxford Economics shows that abolishing the APD would result in an increase of up to 4.2 billion pounds in UK GDP and create up to 91,000 jobs. IATA notes that there have, in recent months, been increased calls from some regional airports for introducing regionally variable APD, or devolving APD to the devolved administrations. Such calls are made on the basis that this policy would support regional economic development, or increase the fiscal independence of devolved administrations. IATA believes that such proposals are short-sighted and risk fundamentally undermining the competitiveness of the UK aviation sector. APD is a uniquely distortive tax, and the best way to address its distortive effects is to reduce or abolish the tax, rather than introduce additional distortions. Devolving or varying APD by region would introduce unforeseen, perverse anomalies and incentives, which would not serve regional economies’ long-term interests, and could have significant, negative externalities. d. How should improving the passenger experience be reflected in the Government’s aviation strategy? It is the market that should enforce airline delivery of the passenger experience. Aviation, compared to other national and international forms of transport, is burdened with regulation. The market forces of choice and competition empower passengers and are the best way to drive up service levels so long as governments also do their part by addressing passenger inconvenience in the area of security and customs, often the most painful point in a passenger’s journey. Recently there have been long security queues at Heathrow’s security due to enhanced screening requirements. We have been made aware by an airline operating from Heathrow that, over this period, a number of its passengers missed their connecting flights due to being delayed at security. IATA has been promoting an airport Checkpoint of the Future that will make passenger security more effective, efficient and convenient by: — Differentiating screening based on risk using passenger data that is already collected for immigration checks at the end of the journey, and — Developing technology that will allow our customers to walk through checkpoints without stopping, undressing or unpacking. — Trials on differentiated screening are delivering positive results in the US and the technology has a 7–10 year development horizon. We are making good progress in cooperation with the EC and our other important partners including the US Transportation Security Administration, the International Civil Aviation Organization (ICAO), Interpol and many governments. The UK is also supportive of the effort which is well aligned with the Department for Transport’s Outcome Focused Risk Based Security initiative. This should feature prominently in UK government policy. The UK Border Agency has a central role to play in delivering improved passenger experience. While intense competition between airlines, (combined with economic regulation of dominant airports and robust powers for the Civil Aviation Authority to collect and disseminate information on the passenger experience contained in the Civil Aviation Bill) mean that airlines and airports have clear incentives to maintain high standards of passenger service, the UK Border Force has no such clear incentive, relying instead on effective oversight by ministers and parliament. It is essential that, in the formation of a new aviation strategy, the Department for Transport works with the Home Office and the UK Border Force to establish clear and robust lines of accountability, and puts in place an effective performance management regime to ensure that the Border is not allowed to undermine the efforts to which airlines and airport operators go to facilitate smooth passenger journeys. e. Where does aviation fit in the overall transport strategy? An integrated strategy that allows for efficient use of different transport modes to get people and goods from one place to another is critical to ensure the UK’s competitiveness. Aviation must sit at the heart of that effort. While 300 km of rail completes a journey from London to Manchester, three kilometers of runway facilitates journeys worldwide. As the only rapid worldwide transportation network, aviation enables world trade. It allows countries to participate in the global economy by increasing access to international markets and allowing globalization of production. The total value of goods transported by air represents US$5.3 trillion, or 35% of all international trade. It is also critical to bringing in the approximately 30 million tourist arrivals the UK sees every year. Some good examples of country governments where the positive impact of a low tax regime has a knock-on effect on jobs and the broader economy are Hong Kong and Singapore. These governments are building their economies around connectivity. The result is a virtuous circle. They are great markets for airlines. Businesses prosper from connectivity. And governments reap the benefits of increased employment and a stronger tax base. In Singapore, aviation accounts for 5.4% of GDP and supports 119,000 jobs. Governments will actually increase their tax revenue if they stop viewing aviation as a cash cow and start using it—as they do in Singapore and Hong Kong—as a stimulant for economic growth, job creation, international trade and cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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inward investment. Imagine the opportunity for growth if government policy was better aligned to support the industry.

2. How should we make the best use of existing aviation capacity? As noted above, a critical constraint in UK relates to capacity availability at Heathrow. 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? Building in resilience at the UK’s major airports, especially those that are already slot constrained, ie LHR & LGW, is essential if the Government’s aim to improve passenger satisfaction and service quality is to be realized. There is some scope to improve efficiency in airport operations for example, the Operational Freedom Trials at Heathrow which are running until Mar 2013 will result in enhanced resilience but the impact of these improvements is likely to be very limited at slot constrained airports . There are only a few ways to build in significant or meaningful levels of resilience at these major airports. The most sensible option is to increase capacity through construction of additional runways at airports that are already slot constrained. While this option may raise concerns related to the local impacts from the potential increased traffic flows, there would be significant economic benefits at local, regional & national level. In addition to improved passenger satisfaction and service quality, there would be benefits within the vicinity of the airport as enhancing capacity can support agglomeration at airports, which as noted earlier would lead to accelerated productivity and growth over and above the gains from better connectivity. At the economy level, this can help improve connectivity and support growth and development. Another option is to revisit the issue of mixed mode as a short-term fix, although it would not adequately address the chronic shortage of slots and hourly movements available, which if introduced on a permanent basis, for example at LHR, has the potential to lift the number of slots and hourly movements available. However, it is important to note that, while mixed mode operations could deliver an increase in the number of air traffic movements, if such additional capacity were fully utilized, it would bring no additional resilience to operational shocks or adverse weather conditions, and the airport would remain, to all intents and purposes, full. As noted above, the best way to increase capacity at these major airports is through construction of additional runways. 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? Evidence would suggest that there is limited or no scope for some of the demand from the constrained airports to be transferred to regional airports as this opportunity currently exists and is not being utilized in a market where airlines address the mobility needs of their passengers. This solution is adding additional capacity at the hub airport to match the forecast demand. c. How can surface access to airports be improved? In many continental countries the public sector has adopted an integrated transport approach together with substantial investment in High Speed Rail (HSR) at airports such as Frankfurt, Paris, and Amsterdam etc. Several HSR proposals are being considered in the UK but are unlikely to be operational before 2025. Classic rail projects such as Crossrail will increase Heathrow’s catchment area, enhance local connectivity for passengers, and reduce road congestion and emissions. Any improvement program would be specific to each airport and the business case rationales for transport providers.

3. What constraints are there on increasing UK aviation capacity? 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? The environmental questions asked here are broadly contained within the DfT’s consultation “Aviation Policy Framework”. The Transport Committee’s attention is drawn to the fact that the aviation industry at large, not just the airlines, has a consistent track record of significantly reducing the impact of aviation noise. Evidence of this can be seen by the fact that the noise contours for Heathrow have shrunk so significantly. 1988–2011: whilst flights increased from 352000 per annum to 480,000, the area affected by noise, using the DfT’s own metric of 57dBA summer day Leq, plummeted from 331 sq. km to 110 sq. km. (Source: ERCD, CAA—Annual Noise Contour Reports) As stated previously, the UK is falling behind in connectivity. That has dire consequences for British business and for the potential of aviation to play in the UK economy and society. Capacity constraints at the key hub airport, Heathrow, are already reducing Britain’s economic potential. Airlines are unable to expand their route networks to serve growing international demand. Heathrow could serve far more destinations than it currently cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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does. The connectivity gap includes 45 long haul destinations that could be viably added to airlines’ route networks, including 15 in Emerging Markets, while the frequency of service on existing routes could be enhanced, according to research by Frontier Economics. A key constraint on the development of a coherent and enduring strategy for aviation in the UK has been the remarkable lack of political consensus which has characterized the debate on airport capacity in recent years. As a matter of vital national interest, IATA believes that, while there is scope to debate the merits of individual policy options and interventions, it is imperative that a space is created in which long-term policy can be made on which there is a genuine willingness to reach political consensus among the main political stakeholders. Such a consensus will be necessary to ensure that, following any decision, progress can be made to deliver key infrastructure projects without the uncertainty which has blighted aviation policy to date. 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? Carbon emissions from aviation are, essentially, a global issue. They are being managed through a mix of regulation on one hand, and industry cooperation on the other. The UK strategy of working in conjunction with global efforts, and the industry’s own collaboration on noise, emissions and efficiencies continue to make aviation even more sustainable. Aviation’s license to grow depends upon managing its environmental impacts. We have a long history of doing precisely that. Over the last three decades Heathrow’s noise contour was reduced by 60%. And we have managed to contain aviation’s emissions at 2% of global manmade CO2 with a 70% improvement in fuel efficiency over the last four decades. While continuing to reduce noise we are stepping-up efforts on carbon emissions. Airlines, airports, air navigation service providers and manufacturers have made three sequential commitments with which I am sure that you are all very familiar: — Improving aircraft fuel efficiency by 1.5% annually to 2020. — Capping net CO2 emissions from 2020 with carbon-neutral growth. — Cutting net carbon emissions from air transport in half by 2050 compared to 2005. c. What is the relationship between the Government’s strategy and EU aviation policies? The government’s strategy is one of support for EU policies and to strive to align itself in full.

4. Do we need a step-change in UK aviation capacity? Why? Yes, absolutely. As stated above, global connectivity provided by a hub airport is essential for the UK to maintain its economic competitiveness and provide greater social benefits to the British population. Heathrow is the UK’s only hub airport. Its global role in connecting people and business generates some 220,000 jobs and GBP 11 billion in economic activity. But it is operating at 99% capacity, so new vital services can only be introduced by adding capacity. And about GBP 5.0 billion is being invested over the period 2008–2013 to expand its terminal capacity. But terminal capacity without runway capacity can only take growth so far. And failure to grow in an expanding market puts one on the road to irrelevance by shifting the demand to alternative European hubs. In this scenario Heathrow could decline from a world class to a local airport. a. What should this step-change be? Should there be a new hub airport? Where? b. What are the costs and benefits of these different ways to increase UK aviation capacity? With such high stakes for the UK, a number of proposals have emerged on how to provide a step change in capacity in the country. There is, for example, the proposal for “Heathwick” with a high speed train link between the two airports (Heathrow and Gatwick). But no matter how efficient the connection, it will never rival single airport connections at competing hubs the likes of Munich, Madrid, Frankfurt, Paris, Amsterdam, Zurich, Dubai, or Abu Dhabi. And absent more runway capacity the train wouldn’t solve the problem. Lord Foster’s Thames Estuary Hub is a further interesting and very expensive proposal. But we could get all the additional capacity needed to ensure that Heathrow continues as a great aviation hub for only a fraction of the cost and without the economic dislocation of moving 220,000 jobs. We must learn from mistakes that have already been made in the area of airport capacity management. For example, in Osaka and in Montréal, new airports were built while old ones remained open, with wasted costs and capacity as a result. If a major hub is built, the main competing airport—in this case Heathrow—needs to close. More importantly, Heathrow has the potential to expand. For that reason, the UK government should make Heathrow expansion a priority in a competitive new UK aviation policy. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Aviation plays a vital role in this great country. The national aviation policy discussion is a great opportunity to replace the tax, regulate and restrict policy trajectory of today with one that supports connectivity, jobs and economic prosperity with sustainable growth.

By refocusing the policy agenda towards competitive, cost-efﬁcient and sustainable growth, aviation can do so much more than the already impressive support for GBP 90 billion of economic activity and 1.8 million jobs. A strong aviation industry is a foundation stone of an economically strong and competitive Great Britain. 18 October 2012

Written evidence from Tim Gresty, Cognitio (AS 41)

A. Prologue

A.1 The oil and gas rich sovereign Arab state of Qatar has massive investments in UK plc, including Barclays, Sainsburys, the London Stock Exchange, Canary Wharf and Harrods.

A.2 At an Aviation Club Lunch on Wednesday 17 October 2012, Qatar Airways CEO Akbar Al Baker spoke with the authority of Qatar and its sovereign government. He was vocal in support for a third runway at the world’s busiest international airport to remain competitive with rival European airport hubs. In his speech, Al Baker said the third runway debate “was not an option, but a necessity” to overcome the capacity crunch Britain’s premier airport was currently facing.

A.4 “Heathrow is bursting at the seams and has already reached a critical point,” he said. “Already heading towards a double dip recession, the UK cannot afford to lose out on the huge beneﬁts a third runway would bring to the economy in south east England and the country as a whole through the creation of more jobs and more business opportunities. No capacity increase will inevitably lead to further economic hardship with job losses and businesses closing down.

A.6 “Heathrow is already losing out to European neighbouring hubs that have the resource to expand capacity. Measures to expand need to be taken soon to avoid a catastrophic situation in the future. The UK government cannot afford to immerse itself in long winded debate and public enquiries. Action needs to be taken.”

A.7 “The government needs to understand the importance of allowing airlines to expand and keep them at Heathrow otherwise there is a risk carriers will move away.”

A.8 UK Government, and the Transport Select Committee, would do well to heed his powerful words, spoken with the authority of the world’s second-richest per capita country, and heed the risk that “carriers will move away”. From recent strategy and policy framework consultations, it is clear they do not.

B. Overview

B:1 In the Foreword to the Department for Transport’s Draft Aviation Policy Framework published July 2012, the then Secretary of State for Transport Justine Greening MP made no mention of the word “airline”.

B:2 In the following Executive Summary, there was only a single mention of “airline” (1.22 : “provide passengers and other airport users with more information about airline and airport performance”). Similarly, there was no mention in either of these parts of the Report, or anywhere else in its 98 pages, of the key word “proﬁt”, the element that makes possible the operation of air routes by airlines into, from and within the UK.

B:3 By focusing its Draft Policy Framework on passengers, airports, local residents and other stakeholders, and ignoring the vital role of airlines which are based increasingly away from the UK, the Government shows a woeful lack of understanding of the mechanisms of today’s global air travel business. Strategies based on such misunderstanding are unlikely to be successful, a mirror of the situation that has marred air travel planning in the UK since 1946

B:4 In its introduction to the Aviation Strategy consultation, the Transport Select Committee makes an identical error—and evidences a similarly woeful lack of understanding of air transport serving the UK.

B:5 If the UK is to retain sustainable air services, to the benefit of its commercial, political and social interests, that sustainability must be based on the ability of airlines to provide route groupings and individual routes which serve passengers and freight customers at a consistent and reasonable profit. Without profit, those globally-focused airlines will turn their backs on the UK, and focus their swiftly-transferable aircraft assets on those emerging and established markets which deliver them the potential for traffic and profit which they need to reward their employees, and their investors. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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B.6 In recent years, airlines have learned the importance of profit, based on rigorous cost control and acerbic evaluation of route sustainability. They have also moved on from narrow national interests: — The focus of our once-British national airline has moved to Spain as a British Airways sub- brand of International Consolidated Airlines Group (IAG), whose its shares are traded on four Spanish stock exchanges alongside London. BA has abandoned its UK regional operations, for financial reasons — Loss-making BMI, once the UK’s second airline, has been eradicated by new owners IAG. — International minnow (but accomplished flag-waver) Virgin Atlantic is owned by Singapore Airlines (49%) and Virgin Group (51%), whose financial operations are managed from Geneva. — Ryanair, the UK’s largest low-cost airline operator, is Dublin-based, with substantial ownership by USA investment funds. — EasyJet’s second-largest base is Milan-Malpensa : the airline’s focus is increasingly Europe. — Europe’s leading lo-co Air Berlin has largely withdrawn from serving the UK, attracted elsewhere by routes offering better profit potential. A OneWorld alliance member, Air Berlin is 29% owned by Etihad. Each of these airlines is focused on building profit through carrying passengers (and freight) on routes which deliver financial sustainability. B.7 Any Policy Framework or Aviation Strategy Consultation that ignores airlines and profit, the key drivers of international and domestic air travel, is ill-conceived, and misguided. Airlines are no longer beholden to Governments, or to individual countries, as Michael O’Leary’s curt rebuttal of the Transport Select Committee demonstrated. Without the ability to attract and retain the operation of air routes serving the UK by internationally-focused airlines such as Ryanair, BA, Air Berlin and EasyJet, the UK’s vital network of air links will wither, and our trade-based commercial lifeblood will thin : the implications for employment, inward investment, community support and infrastructure affordability are dire. B.8 Such international airlines must be regarded as potential friends, to be nurtured and encouraged. They are not enemies, to be discouraged by capacity constraints, unnecessary fiscal and legal controls, and the imposition of Government revenue-driven disincentives such as APD, and thus driven to focus their investment and route networks elsewhere, to the benefit of our competitors. B.9 Government should recognise that its Air Transport Strategy must prioritise the attraction and retention of routes operated profitably by major international airlines if it is to serve its people, its workforces, and its businesses. B.10 If the airlines are to be attracted to and retained by the UK, investment must focus on building the UK’s primary international airport currently serving the capital and regions of the UK. London Heathrow must be developed, with priority for the following key aspects : — Capacity enhancement, via Runway 3 and potentially Runway 4. — Integrated public transport access : local and regional. For employees, travellers and freight. — Fast-rail links to key regional transport hubs including Manchester, Leeds, Birmingham and Bristol via HS2, HS3 and more. — Enhanced transfer speed and convenience between incoming and outgoing routes, and between terminals. Including UK regional airline feeds. — Establishing greener credentials in airport and airline operation, through utilization of “tight site” Heathrow, and the restriction of access to new routes and Runways (R3, possible R4) to “latest generation” cleaner aircraft, operated at maximum loads for minimized environmental pollution per passenger.

C. Questions Specified by Transport Select Committee C.1 As an initial observation, I would suggest that the questions listed demonstrate a limited comprehension of the aviation business serving the UK in its global environment, and a shallow understanding of what drives the provision of air routes by airline serving airports which provide air transport opportunities to their local and more distant markets for passenger travel and freight transportation. C.2 That limited comprehension and understanding undermines the credibility of this Aviation Strategy Consultation, and its potential effectiveness as a check and balance to the parallel (and even more heavily flawed) Aviation Policy Framework consultation carried out by the Department for Transport. A disappointment, with long-term and wide implications. C.3 Sadness is added to that disappointment by the lack of appreciation by DfT and the TSC that the failure of successive Governments to provide a proper Strategy and Policy Framework for the growth of aviation serving the UK has already gravely damaged the international prospects of our country, and imposed irrecoverable disadvantages versus our key international competition. I am not by nature a negative person, seeking clouds to accompany silver linings. However, it is difficult to be anything but negative in the context of Government inaction, and ill-advised misdirection in aviation strategies, tactics, objectives and policy. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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D: Question 1 What should be the objectives of Government policy on aviation? D.1 Primary Objective is to define and serve the economic, social and environmental interests of the peoples of the UK, in its capital city, and in all its regions. D.2 In achieving this objective, Government should adopt the tactic of prioritizing the retention and attraction of international airlines (including those based in the UK), and their investment in the routes which serve the capital city and regions of the UK. D.3 As airlines are increasingly focused on profit, to enable the retention and reward of their investors and stakeholders, Government must ensure that airlines attracted to serve the UK are enabled to achieve revenue and profit returns which compare with those available to them in countries and on routes which are their alternatives to the UK. D.4 That implies that Government must pull back strategically from opposition to airlines, obstacles to investment and reward, and the artificial erection of fiscal and legal constraints which could turn these most mobile of businesses away from the UK, and into the hands of eager and better-advised competitor markets.

E. Question 2 How important is international aviation connectivity to the UK aviation industry? E.1 Vital. In the global 21st century, and in centuries to come, international connections for trade and friendship are the vital lifeblood of a country and its sustainability. Our colleagues and competitors, in the developed world and in emergent economies from Scandinavia to Shanghai, recognise that fact, and are investing accordingly in ﬁnancially-sustainable travel links. For decades, the UK has not matched their endeavours. Today, there is a danger that economic and environmental constraints will lead our Government to kick the challenge of infrastructure development even further into the long grass. Our descendents, lacking the jobs and income that development could deliver, will not thank us for our lack of foresight.

F: Question 3 What are the benefits of aviation to the UK economy? F.1 This question can only be addressed by exploring the four sectors of air travel. Each is of differing importance to the UK’s social and financial economy, and its benefits of each should be rated by importance. To add complexity, those benefits vary according to whether the air travel is inward, or outward. The brief response preferred by the Transport Select Committee permits only an initial flavour of that exploration. — Business Travel — Holiday & Educational Leisure — VFR (Visiting Friends + Relations) — PfP (Purely for Pleasure)

F.2 Beneﬁts of Business Travel F.2.1 The UK is a trading nation, depending on international relationships for a large part of its wealth, status and employment. While e-communications have reinforced and speeded written links, nothing has yet replaced personal contact in establishing the relationships on which business and trade are built—as our competitors in Europe, in the Middle East, in North America and Asia recognise. Business travel, serving routes to our current and potential partners, suppliers and customers, is a vital ingredient of our manufacturing, service and support economies, both in taking us abroad, and in encouraging others to visit. It is also vital to secure the inward investment which funds an increasing proportion of our businesses, our infrastructure and our institutions. F.2.2 Inward business travel also delivers beneﬁts in the conference, exhibitions and incentives sector, supporting modern facilities in our capital city and in the regions. Freight aviation is vital to support our businesses and industries, both in exporting goods and services, and in importing ingredients, parts, spares and equipment as well as expertise. F.2.3 Of all aspects of aviation, business travel is the most important—yet, curiously, it is in this sector that APD is most damaging in discouraging “front cabin” business travellers, whose high value and expenditure make them particularly valuable to our investment, trade and business relationships. As London is clearly the epicentre of our business and trade world, it is London’s airports led by predominant Heathrow and their network of routes serving business and trade capitals that are the most important to this top-priority sector.

F.3 Beneﬁts of Holiday & Educational Leisure Travel F.3.1 This is the traditional “two weeks holiday” sector, including longer-stay visits abroad by UK citizens— and similar trips into the UK from overseas. It also includes “educational” tourism, from short visits to and from the UK to longer-term residence such as university and college courses provided in the UK, or taken overseas. F.3.2 While it may be damaging to our economy and employment for overseas travel by UK citizens to be encouraged, that damage can be minimized where the airlines and airports serving this market are British, or at least provide employment in the UK. On the other hand, the encouragement of overseas tourism into the cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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UK remains a key part of our national economic ambitions—and our need to boost younger-person lower- skills employment in the tourism and travel sectors. F.3.3 While Holiday & Educational Leisure Travel may be less directly beneﬁcial to the UK economy than Business Travel , the inward tourism element of this sector is vital—and particularly where emergent countries and sub-continents including India and China grow in wealth, and ambition in travel and education. F.3.4 I therefore rate the beneﬁts of Holiday & Educational Leisure Aviation second to Business Travel.

F.4 Benefits of VFR F.4.1 In our increasingly global world, where inter-country migration for business and social reasons increases annually, the market for Visiting Friends and Relations grows accordingly. UK citizens moving abroad for business or retirement provide airline demand (eg Monarch and other airlines serving the Iberian peninsula and Balearic Islands), and immigrant communities’ links with their “home countries” accelerate as their earnings and accomplishments grow (eg growth of Pakistan International UK route network serving Manchester, Leeds/Bradford and Glasgow as well as London Heathrow). F.4 2 While the social benefits of this sector of inbound and outbound travel may be significant in building relationships and understanding, the economic benefits are more limited—particularly where the “inward travel” benefits of additional expenditure within the UK are minimized by accommodation and subsistence provided by hosting families and friends, and less is therefore spent with hotels and catering in the UK. F.4.3 The loco airlines led by Ryanair have significantly grown this sector for short-haul travel, but this growth has been largely in increased frequency of travel, in the form of frequent repeat visits facilitated by “cheap as chips” ticket prices. This has replaced the traditional “once-in-a-while” VFR visits, for special occasions and celebrations, which was the norm for UK>

F.6 Benefits of PfP F.6.1 Purely for Pleasure flying is an extension of the short “pleasure flights” of a previous age—a decision to fly which is based on minimal pricing and increased leisure time, rather than planned Holiday or Educational travel, celebration-driven VFR, or travel for business. F.6.2 Where return travel can be purchased for less than £100, and where holiday entitlements in work and training are extensive, PfP flying becomes an alternative to a night out at the cinema with meal, or a shopping trip to Westfield or the Trafford Centre. A weekend on Prague or Paris, or a short break to Nice or the Nile, becomes an easy-to-access indulgence, rather than a justified journey or a well-earned reward. F.6.3 Where airlines operate routes that depend for a significant proportion of their revenue delivery on PfP, those routes contribute to environmental emissions while delivering little benefit to the UK economy. That applies to incoming PfP tourism by overseas visitors as much as outbound PfP tourism by UK citizens. As the least beneficial, it should be encouraged significantly less than air travel for Business, Holiday & Educational, and VFR. At some stage, we may wish to explore constraints on this category of flying.

G : Question 4 What is the impact of Air Passenger Duty on the aviation industry? G.1 We should not deceive ourselves that the impact is devastating. At worst, it is significant. At best, and in some of the four sectors, it could be beneficial to the UK. The vociferous lobbying of airline characters and their lobbyists must not convince that APD deeply damages the economics of airline operation. G.2 It is, however, iniquitous that APD distorts competition, and provides a very uneven playing field in an internationally-competitive marketplace. The retreat from APD by competitor countries such as Netherlands and Ireland delivers them with advantages that hurt our airlines, airports and air transport employees—and their ability to contribute taxes and expenditure to our economy. G.3 Business travel is essential to the profitable functioning of UK business. APD acts as an additional discouragement to airlines, signaling that the UK does not welcome them or their routes, and emphasising that, in a free worldwide market, there may be more attractive countries to serve. The example of VLM Airlines, and its withdrawal of its key routes linking Manchester and Liverpool to London’s City business airport, is cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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evidence here: CEO Johan Vanneste is on record as attributing their decision in part to the discouragement of a country which sought to encourage investment from Belgium-based and Dutch-owned VLM in its domestic routes, but then imposed direct APD disincentives that were not equally applied to competition from medium- speed rail. G.4 Where the travel is for VFR, for PfP or even Holiday & Educational Leisure, the impact of APD may be beneficial by discouraging unnecessary outbound travel, or minimizing travel which has a negative effect on the UK economy. For example, a significant percentage of flying with Ryanair, EasyJet and other loco operators is at minimal prices, facilitating increased outbound frequency of travel for VFR, an increase in overseas holidays and longer cultural and educational stays—to the cost of UK-based alternatives, resorts, tourism attractions and destinations. On the other hand, higher APD may act as a disincentive to inbound travel, which is a growing form of export, with benefits to UK trade, income, tax and employment. G.5 Impact? Variable, and uncertain. On balance, negative—but not unacceptable, particularly if it were restructured to encourage more environmentally-efficient aircraft operations.

H : Question 5 How should improving the passenger experience be reflected in the Government’s aviation strategy? H.1 A confused question. The absence of clarification or definition of “passenger experience” inhibits comment. H.2 I have assumed the relation between passenger experience and the Government’s aviation strategy is limited to those areas where Government activity and responsibilities affect passengers. H.3 Assuming “passenger experience” means those aspects of the passenger’s experience during travel, then the Government’s aviation strategy should concentrate on those aspects of the passenger’s travel directly affected by Government-sponsored activity. This is primarily Government-specified security checks (particularly prior to departure) and arrivals checks by HM Customs on passports and contraband. H.4 The aspects of “passenger experience” that requires inclusion in the Government’s aviation strategy are : — the waiting line times that mar the passenger experience; — the attitude and treatment provided by those from HM Customs and others who implement those checks; and — the lack of welcome and appreciation implied by the impersonal and at times inhuman attitudes of the Government-sponsored personnel applying the checks. Where a traveller is a visitor to our shores, and therefore a potential source of income to our country, they should be welcomed as a potential friend—and not treated automatically as a potential enemy. Long waiting lists, threatening treatment and impersonal attitudes do not friends make. Where the traveller is a UK citizen returning to his or her homeland, the need for a welcome expressed in minimal queuing and appreciative treatment is equally justified. H.5 Having experienced the “passenger treatment” from government agencies on arrival in many less democratic countries in the old Eastern bloc, and in passenger-ferocious airports in the USA, I am sad to note that the UK has begun to overtake them all as an unfriendly “passenger experience” where airport security, passport and other arrivals checks are concerned. Government aviation strategy should explore that, and the negative knock-on effects such passenger treatment has on the decisions of airlines on whether to invest in routes serving UK airports. To remind ourselves, the Government’s primary tactic should be to maximise the retention and attraction of international airlines, and their investment in the routes which serve the capital city and regions of the UK. Providing a welcome to an airline’s passengers, a vital component of their appeal to customers, is an essential element of that tactic.

I : Question 6 Where does aviation fit in the overall transport strategy? I.1 Airports represent the most immobile and concentrated elements of the overall transport strategy. Air routes are a vital part of our nation’s interconnectivity, and our ability to earn and profit in our global world. Airlines are the unequalled arbiters of our nation’s air transport facilities, as it is they who decide whether a route exists or closes. Their decisions are increasingly based on the actual or perceived profitability of each individual route. I.2 Therefore, aviation should be at the centre of the Government’s overall transport strategy. Airports must be integrated within the transport infrastructure. Local, regional and national transport must integrate airports, both in terms of location and timing, to ensure transport infrastructure serving airports does so at times which support the through-the-day-and-night ebb-and-flow of airport operations, airline arrivals and departures, and the transportation needs of the employees who keep the airports and airlines efficiently operational. I.3 The absence of effective integrated transport planning incorporating airports has long been a concern of those who would maximise usage of public transport, and minimize the environmental and traffic impacts of airport operation. Far too high a percentage of passengers and freight (particularly at regional airports) arrives and departs by private road vehicles—a situation where airports parking receipts can discourage airports from cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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motivating public transport usage. We need better integration of all aspects of public transport across the UK, and particularly in the provision of access to airports by passengers, freight and employees.

J : Question 7 How should we make the best use of existing aviation capacity? J.1 By maximizing the usage of existing airports, starting with London Heathrow. J.2 There are lessons to be learned from the failure of London Stansted to build traffic, encourage international airlines to maintain routes serving Business Travel and Holiday & Educational Leisure, and its resulting over-dependence on PfP and VFR travel, much of which is socially unwarranted and encouraged by loco airlines’ “cheap as a pair of cinema tickets’ pricing. You cannot force passengers to use airports that do not suit their needs, and you cannot force airlines to use UK airports that do not appeal to them, their passenger projections or their financial requirements. J.3 Routes are initiated and promoted by airlines at airports which they want to use, and which they perceive their potential customers want to use. That is why London Heathrow has over-demand, where its siblings at Stansted, Luton and even Gatwick suffer from too much capacity chasing too little airline demand. And that is why leading regional airports such as Manchester, Birmingham, Newcastle and Glasgow have suffered from shrinking route networks, and fluctuating passenger numbers J.4 This implies very simply that, for aviation and air travel to best serve UK plc, the Government must prioritise the development of London Heathrow. That covers access transport enhancement and integration (including fastrail such as HS2), the improvement of inter-terminal connectivity to build transfer traffic from within the UK and internationally—and the unpalatable but unavoidable expansion of airline operational capacity by the agreement to and swift construction of Runway 3, followed by exploration of opportunities for Runway 4. The salient words of Qatar Airways’ CEO Akbar Al Baker should ring in our ears.

K: Question 8 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? K.1 The UK needs to augment existing London airport capacity by providing additional slots at the airports where airline demand for additional routes and frequencies exists today, and in the future. As the succinct summary by Qatar Airways’ CEO firmly records, if UK plc is to benefit from aviation policy, there must be a third runway at the UK’s primary hub of London Heathrow—and quickly. K.2 Recent encouragements to airlines to add routes and frequencies at the other London airports of Stansted and Luton have failed: many airlines do not want to fly from those airports, because their passengers do not want to use them. Those airports are the preserves of the point-to-point loco airlines largely serving the VFR and PfP markets, with the low levels of service and minimal prices those markets need if they are to flourish. K.3 Similarly, airlines are loathe to take up the limited available capacity at London Gatwick, as it is a less attractive option to airlines and their passengers than Heathrow. This undermines the 17 October 2012 proposal of a second runway at London Gatwick announced by the airport’s owners US-based investment fund Global Infrastructure Partners (GIP), which is on record as planning to sell off its investment to a range of parties by 2018: that, of course, could be the reason for their announcement of expansion plans post-2020. K.4 London City, also owned by capital-gains-driven GIP, is full—and there is little opportunity for additional slots at times to suit its largely-business target markets. K.5 Therefore, Government’s measures to “make the best use of existing London airport capacity” have failed. K.6 To improve passenger experience and airport resilience (ie the ability of airports to react and change in the face of changing market conditions and demands), the Government must add capacity where the passengers, the markets and the airlines demand them. That means more capacity at London Heathrow, delivered by at least one additional runway, and before more “resilient” competitor hub airports in near-Europe, Middle East and beyond corner markets for international travel, take our trade, and endanger our economy and employment.

L: Question 9 Does the Government’s current strategy make the best use of existing capacity at airports outside the south east? How could this be improved? L.1 The best use of existing capacity at airports outside the south east is decided by the airlines that choose to serve them. I understand London Heathrow and London City are the only two airports in the UK where there is insufficient capacity to meet airlines’ demands for new routes and added frequencies—although major regional airports such as Manchester and Birmingham have limited capacity during morning and (to a lesser extent) evening peak times to meet all demand for new timeslots. L.2 Where Government aviation strategy encourages airlines to maintain and add new routes serving airports outside the south east, and helps convince them they will be able to operate those routes with acceptable profitability, demand may grow. Those encouragements include financial incentives rather than penalties such as APD, enhanced ATC for access over the rest of the UK, improvements in integrated transport serving the cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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airports, and other aspects which demonstrate the UK welcomes the airlines and their routes, and does not regard them primarily as tax-gatherers, pollution-creators, noise-deliverers and problem-bringers. L.3 Where Government’s Aviation Strategies and Policies discourage those airlines by ﬁscal charges such as APD, and by other constraints and limitations, those airlines will turn their backs on UK regional airports, and on the UK as a market.

M: Question 10 How can surface access to airports be improved? M.1 By the better integration of local and regional feeder services by rail and bus, particularly to regional airports but also to London’s further airports at Stansted and Luton. That applies to routes, to frequencies and to service timings that cater for early flight departures and late arrivals—and for the local staff who man those flights and provide airport support. UK airports have a poor track record of proper integration of surface transport, way behind competitor airports such as Zurich, Frankfurt and Amsterdam—although improvements have been noted over recent years. A great deal of the problem is the chicken-and-egg situation of not enough demand for public transport links, and therefore lack of provision under shorter-term financially-driven franchise structures. M.2 Swift access to London Heathrow by rail from anywhere other than Central London is poor : the dedicated if expensive non-stop Heathrow Express runs from relatively isolated Paddington Rail Station, as does the lower-price Heathrow Connect alternative. The Gatwick Express from Victoria is effective if expensive, with marginally-slower stopping services at lower prices. These options are good, but inadequate for airports serving the whole of the UK.

N : Question 11 What constraints are there on increasing UK aviation capacity? N.1 There is more than adequate airport capacity in the UK to serve the country’s cumulated inward and outbound needs. The trouble is, it’s not been built in the right places—yet Government seems to believe that travellers can be persuaded to use airports which are less than convenient for their needs. N.2 Failure to build adequate capacity in south east England, and particularly at the country’s primary hub at Heathrow, has put damaging constraints on the economic contribution of aviation to UK plc.

O: Question 12 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? O.1 Yes. Airlines share Government ambitions and green activists’ aims to reduce the environmental impact of flying, particularly as lower noise and lower emissions are delivered by more modern aircraft design, greater engine efficiency and lower fuel consumption. O.2 Airport operation in the UK has become significantly quieter over recent decades, and emissions per passenger kilometre reduced, as aircraft manufacturers have reacted to airline pressure to deliver aircraft with lower fuel consumption. Latest generation jet and turboprop aircraft have engines which are less noisy and more powerful, and which are increasingly fuel-frugal. In addition, weight of aircraft per passenger have been reduced, as demonstrated most effectively by Boeing’s new 787 Dreamliner, and also by Airbus’ large-capacity A380 Series. Additionally, and partly driven by the “pared to a minimum” attitudes of the new breed of loco airlines such as Ryanair, operational wastage of fuel has been minimized, and fuel frugality put high up the airlines’ priority list. That is the best way of minimizing the environmental and noise impact of aviation.

P: Question 13 Will the Government’s proposals help reduce carbon emissions and manage the impact of aviation on climate change? P.1 No. Air travel is a global business. In China alone, there are agreed plans for the construction of nearly 100 new airports and 150 commercial runways—including the monster Beijing Daxing Airport, opening in 2017 with 4 operational runways, plans for 4 more runways, and a capacity of up to 200 million passengers per year in addition to the existing Beijing Capital International’s 3 runways and 85 million passengers. The impact of UK aviation on climate change would be marginal even if the number of flights serving the UK doubled overnight. P.2 It is right that the UK should encourage its air transport business to minimize environmental impact by encouraging the usage of the most enviro-efficient aircraft available—a decision to upgrade airline fleets that is heavily influenced by airline’s route profitability. However, it would be unfortunate if UK Government policies aimed to help reduce carbon emissions put us further behind in our fight for international trade and exports, and thus reduced the ability of airlines serving our airports to generate the profitability and healthy balance sheets that facilitate investment in replacement higher-efficiency aircraft, and the disposal of the many old gas-guzzling airliners which remain on UK airlines’ fleet lists, such as British Airways’ aged 737, 767 and 747 Boeings. P.3 One key way of using Government strategy to reduce carbon emissions, reduce the impact of our aviation on climate change, and provide leadership by example to the rest of the world would be commission Runway cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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3 at London Heathrow as the world’s first “green runway”, by insisting (through fiscal and planning incentives) that only the most fuel-efficient aircraft, carrying the maximum Loads and resulting passenger numbers, are permitted to use that runway. P.4 Other than that, whatever the Government’s proposals, they will make minimal impact on climate change. As a tiny country, we are simply too small an act to have any material effect on world-spanning climate change.

R: Question 14 How can aviation be made more sustainable? R.1 If this means “more environmentally sustainable’ rather than “financially sustainable”, by encouraging: — the purchase of latest-generation fuel-frugal aircraft; — the selection of larger-capacity aircraft, to minimize energy usage per passenger kilometre; — the maximization of Loads on all routes (ie % available seats occupied per flight); and — the provision of new runway capacity whose usage is restricted to the most fuel-efficient aircraft, with maximized Loads and passenger occupancy.

S: Question 15 What is the relationship between the Government’s strategy and EU aviation policies? S.1 Disjointed and distant—and set to deteriorate, as the anti-EU stance of the Coalition Government, the media and other vocal opinion-leaders grows in breadth and momentum. Sad, because—having lost our leadership in aviation development—there is a great deal we can learn from the EU, and its progressive aviation policies and strategy development.

T: Question 16 Do we need a step-change in UK aviation capacity? Why? T.1 This is an appropriate and important question. Unfortunately, the Transport Select Committee (and our Westminster Governments) ask the question at least 20 years too late. Aviation capacity is not a national question. It is international. And the UK’s near-Europe competitors have taken steps to build capacity while UK Governments have kept control of airport capacity planning, but have dithered in their thinking and decision-making.

U: Question 17 What should this step-change be? U.1 A good question, but again too late. U.2 The UK’s competitor hubs in near-Europe led by Amsterdam, Frankfurt, Paris Charles de Gaulle, Madrid Barajas and Rome Leonardo da Vinci have all worked in association with their “local” airlines to increase capacity by huge investment in new runways, terminals and transport access : — Amsterdam Schiphol 6th Runway (12,350ft) opened 2003 — Frankfurt 4th Runway (9,240ft) opened 2011 — Paris CdG 3rd Runway (8,850ft) opened 1998, 4th (13,780ft) 2000 — Madrid Barajas 3rd +4th Runways (11,482ft) added 2006 — Rome LdaV (FCO) Current 4 Runways : additional two 10,000ft-plus Runways planned The airlines serving these UK-competitive hubs led by Air France/KLM and Lufthansa have capitalized on their host countries’ vision in investing in airport capacity by providing networks of routes serving UK regional airports, and linking to international and intercontinental routes to deliver UK-sourced revenue to these overseas companies, and jobs to their national communities U.3 Further afield, the recently-emergent Middle East superhubs have stolen our thunder : — Abu Dhabi two 10,000ft-plus runways in recent years to serve Etihad and others — Qatar new airport adds two 13,000ft-plus runways to one at existing airport 5km away. — Dubai five 10,000ft-plus runways at new Al Maktoum International airport : additional to three 10,000ft-plus runways at Emirates’ existing base In a few decades, the new super-airlines emerging from the UAE have imaginatively spread their wings to become the UK’s regional airlines of choice for inter-continental travel to the East. For Manchester, Birmingham, Glasgow and Newcastle, Emirates via Dubai is first choice—a situation which Etihad seeks to emulate, first from Manchester, and Qatar Airways plans to follow.

V: Question 18 Should there be a new hub airport? V.1 No. The UK has an adequate number of airports, and those which developed to serve the UK’s international travel are well-located. For example, London Heathrow (the replacement for London Croydon) is close to central London, well-served by public transport links from central and suburban London, and has good car access from the majority of the UK’s regional population, which is located to the North, West and South cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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of Heathrow. The addition of a long-awaited fast rail link to the UK’s regions would transform London Heathrow as the UK’s air travel hub, while maintaining the current business models of regional airports. V.2 Development of new airports is a fraught business, particularly in high-democracy states such as the UK. Development of existing airports is facilitated by existing infrastructure and intrusion, and by existing travel plans. Additionally, where individual airports are supported by a concentration of lower-income inconvenient-hours jobs ﬁlled by local populations with close family and social links, such as the Asian-heritage families supporting Heathrow and the family-home-dependent younger check-in and cabin crew staff supporting resident airlines, transfers of thousands of jobs to a replacement airport situated some distance away causes immense social and employment problems which airlines and local populations are loath to accept. It is wise to listen further than the local Nimby clamour of those who are not dependent on their local airport for their employment, business or social focus, and whose family and friendship lives are not enhanced by the proximity of such employers and related facilities.

W: Question 19 Where? W.1 The concept of a move of the UK’s prime hub to a Greenfield site, or a “Boris Island” airport in the Thames Gateway, is deeply flawed from the standpoints of staffing (see V.2, above), and the challenges of multi-airport operation faced by key airlines whose smooth-running in demanding times is essential if they are to maintain yields, loads and revenues in fierce competition with alternatives in near-Europe, the Middle East and beyond. W.2 The ideal location for a UK national hub serving its priority markets of Greater London, the south-east of England and the other regions of England, Wales and Scotland is to the west of central London, within reach of existing transport infrastructure and an appropriate workforce. Heathrow may not be perfect, but it is the best option the UK has to offer. W.3 In Victorian and Edwardian times, the ingenuity and imagination of UK business capitalized on the great opportunities for international trade and profitable exports by expanding the country’s leading ports in London’s Docklands, at Southampton and Bristol, at Liverpool and inland at Manchester. The benefits to national income, regional employments, educational development and civil progress were massive, and are evident to this day. W.4 Where decisions were made to withhold investment, and leave the way open for more nimble competitors, the results were catastrophic in employment and social costs. While Rotterdam’s Europort and Belgium’s Antwerp led the way, the UK’s leading port cities of Liverpool, its neighbour Manchester and London’s Docklands were starved of investment, and led the social and economic suffering. W.5 Where Government neglects to maintain and enhance the appeal to airlines of the UK’s primary international transport hub at London Heathrow, and leaves its competitors in near-Europe, the Middle East and beyond to lead the way in capacity and route development, that decline may well be mirrored in our economy, our employment, our international reputation, and our ability to maintain the profitability of UK plc in a world of merciless competition. W.6 The enhancement of the UK’s transport infrastructure by the reduction of constraints on development at London Heathrow, and the swift approval and construction of Runway 3, would help UK plc face that competition, and protect our country’s jobs, business development and status. The words of Qatar Airways’ CEO ring true.

X: Question 17 What are costs and benefits of these different ways to increase UK aviation capacity? X.1 This is too large and detailed a subject for adequate analysis within this initial Consultation, which has in my opinion been inadequately defined, particularly in its recognition of the key influencers and influences of the air travel business. X.2 The influence of airlines in this subject, and particularly their increasing overseas financial and operational focus, are elements of complexity that make a simplistic analysis of the costs and benefits of increasing UK aviation capacity inappropriate. X.3 Additionally, there are influencers and influences which lie well outside the orbit and influence of Government, its Department for Transport, and its Transport Select Committee. We live in a global world, and the UK has increasingly failed to maintain its leadership and authority in the world of aviation that links its global constituents. X.4 For decades, I have worked on many aspects of airline route evaluation and airport route grouping marketing, and for a wide span of airlines based in the UK and abroad. I recognise the complexity of the sector’s decision-making, and the need for forward thinking and long-term vision. I watched in dismay as successive Governments avoided properly-planned development of the airport and runway capacity that serves airlines and their customers’ airports—and allowed the UK’s leadership in airline route and operations development to wane, to the considerable economic, investment and employment cost of our country. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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X.5 As noted at the start of this response, the DfT’s Draft Aviation Policy Framework is flawed in the way it plans to evaluate future strategies and policy for aviation serving the UK. Its over-concentration on environmental matters, and its complete ignorance of the importance of building partnerships with airlines to encourage route development alongside environmental cleanliness and quietness, indicates a lack of understanding. It also fails to appreciate the massive costs to our country if we continue the policy of failing to provide aviation capacity where it is needed. X.6 Suffice to say that: — The costs of failing to build aviation capacity in the south east of England, and in particular at London Heathrow, are enormous, in jobs, business and trade, authority and international competitiveness. — The benefits of building that capacity within a swift timescale, before we are edged out by competitor nations with more progressive policies, are huge, and essential if UK plc is to recover and prosper. — That capacity hike cannot be replaced by building capacity elsewhere, or by trying to increase usage of that capacity where it exists at other airports, such as the under-performing medium- capacity airports of Manchester, Birmingham and Glasgow. — Proposals for a new high-capacity airport serving London from a new site away from congested urban areas are a time-wasting and deeply-damaging distraction. Within the 20 years’ planning and construction envisaged for “Boris Island” or its elsewhere equivalent, the predictions of Qatar Airways’ knowledgeable CEO will have come to pass. Carriers will have moved away, and taken the UK’s international trade and related employment prospects with them. We will all suffer from such myopia. 19 October 2012

Written Evidence from Crawley Borough Council (AS 43) Executive Summary 1. Crawley Borough Council is the Local Planning Authority for Gatwick Airport and therefore has a signiﬁcant interest in the development of the Government’s Aviation Strategy. 2. The Borough Council puts forward the following comments for consideration by the Committee: — The relationship between the Aviation Policy Framework and the work of the independent Aviation Commission needs to be clear to ensure that all options regarding airport capacity are given full consideration and assessment. — In making best use of existing capacity at airports in the short term, the environmental impact associated with increased passenger throughput needs to be managed. — Proposals relating to capacity at one airport could have a knock on effect on the role of other airports and it is important that this relationship is fully understood and assessed as part of the development of national aviation policy. — There needs to be clear guidance to local planning authorities on the role of safeguarding and protecting areas from “incompatible development” where there are potential options for future runway development. — Greater consideration needs to be given to assessing the surface access implications associated with airports and increases in capacity. — Guidance relating to the onset of community annoyance from aircraft noise needs to be based on more detailed evidence.

Written Evidence The Beneﬁts of Aviation 3. The importance of aviation to the economy is recognised both at a national, regional and local level. The proximity of Crawley to Gatwick Airport means that around one in seven of Crawley’s residents work at the airport, or in its associated services and industries. 4. The principle of making best use of existing capacity to meet demand in the short term is supported as it is efﬁcient in terms of maximising the use of the existing facilities. However, it should also be recognised that there is an environmental impact associated with increasing passenger throughput using existing capacity and it is still important to ensure that the environmental impact of this growth is mitigated. The existing S106 agreement between the local authorities and Gatwick Airport Limited is based on these principles and sets out various ways in which the environmental impact of the airport will be managed as it grows towards 40 million passengers per annum (the maximum capacity of Gatwick with a single runway). cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Airport Capacity 5. This is an issue of fundamental importance to the local area as the implications of any additional runway capacity wherever it is located in the South East will have a significant impact on Crawley Borough. Additional capacity at Gatwick could increase jobs and benefit the economy, but there would be considerable environmental impacts. Alternatively, if another location is identified for growth in hub capacity, there will be long term impacts for all the other airports including Gatwick as airlines potentially re-organise their operations. This could have a detrimental effect on the local economy. The Borough Council and other partners are preparing to undertake an assessment of the impacts of various scenarios of providing additional airport capacity on local and sub-regional employment in the Crawley area and Gatwick sub region. It is hoped this evidence will be useful in formulating the Borough Council’s contribution to the work of the independent commission dealing with maintaining the hub capability of the UK. 6. There has been uncertainty about future runway development at Gatwick for a number of years, with land currently safeguarded and therefore prevented from being used positively to meet local development needs. It is, therefore, important that the Government keeps to its latest timescales for assessing the issue of long term airport capacity in the UK. This will help give confidence to local and national economies and local communities to plan for the future. The draft Aviation Policy Framework, which is due to be published well in advance of the findings of the independent commission, should make it clear that all options for the long term are to be considered, including the balance between hub capacity and point to point to ensure that all decisions are made in light of all the available evidence. 7. The overall importance of surface access links to airports that is highlighted in the APF is welcomed. There is a particular focus on High Speed Rail 2 being an alternative to domestic and short haul flights but the importance of the role of rail not on High Speed Routes in enabling airports such as Gatwick to achieve their point to point function effectively, is not sufficiently highlighted. There is some reference to working with partners to identify further opportunities to improve rail services but it is important that this ultimately delivers improvements to services and overcomes capacity constraints on the rail network.

Climate Change Impacts 8. Addressing climate change issues at a global level is important to ensure that the whole of the aviation industry addresses the issue irrespective of where they operate from.

Noise and other local environmental impacts 9. The draft Aviation Policy Framework sets out a range of initiatives to manage the impact of airports on noise and other environmental issues. The following paragraphs represent the Borough Councils views on the proposals set out in the Framework. 10. The overall objective “to limit and where possible reduce the number of people in the UK significantly affected by aircraft noise” is reasonable as the principle of this objective is appropriate. The relationship of the “to reduce” part of this objective needs consideration in light of the assessment of the need for additional hub capacity in the UK including the contribution which could be made through increased size of aircraft, noise can be reduced with quieter engines. 11. In the APF the Government recognises that the 57dB LAeq 16hr contour no longer truly reflects the onset of community annoyance. It is therefore not appropriate to continue to use this contour. The Government should examine other indices to measure community annoyance as frequency of flights plays a major part in community annoyance. There is no conclusive evidence as the government has commissioned very little research into the subject. Community annoyance could also vary from urban to rural areas and this needs to be examined in more detail by the government. The daytime 57dB contour also fails to include the impact of night flights. 12. Consideration should be allowed for both a lowering of the finite 57 dB(A) band in tandem with alternative or complimentary ratings such as C weighting due to the noise type and intensity to allow better modelling of the likely community response where noise sensitive premises are exposed to high levels of aircraft movements. 13. There should be a move to the Lden as this reflects the relative impact of evening and night noise. There should also be further examination of LAmax contours, especially at night where regular sleep arousal can adversely affect health. Contours showing the number of events over 60dB LAmax for night noise would capture this. 14. The use of noise envelopes can be an effective method of controlling noise and can encourage the use of quieter aircraft to increase overall capacity. However as discussed above the frequency of flights can contribute as much to “annoyance” as the actual overall average noise levels, so all envelopes will depend on local conditions. Any envelope agreement must be clearly defined and come with an effective method of control. 15. It is difficult to put one environmental issue above another as all environmental factors need to be considered and given the relevant weight depending on their relative impact on health. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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16. The Government should continue to designate the three airports for noise management purposes. There are many conﬂicting interests surrounding airports and it would be difﬁcult for one authority to independently exercise adequate controls, unless these controls are clearly set out in legislation.

17. Any noise designated airport which has residents adversely affected by noise should be forced to establish and maintain a penalty scheme.

18. The current night quota at Gatwick is under utilised. With Gatwick aiming for 45 mppa this additional headroom is likely to be used as the daytime slots fill up resulting in a substantial increase in night flights. This will presumably be made up of additional holiday/leisure flights. Therefore charging more for night flights may only result in larger profits for the airport and no benefit to residents. To protect residents from the worst aspect of aviation, namely night flights, the Government should aim to reduce night flights incrementally over a period of time.

19. During the day differential landing fees should be introduced as it follows the principle of the “polluter pays” and will encourage quieter aircraft.

20. The present compensation schemes are the minimum that should be offered. The offer to cover the costs of moving only results in one household replacing another and doesn’t recognise that noise at that level could have a signiﬁcant adverse effect on health. Research is clearly demonstrating that high levels of noise can cause long term health problems and compensation schemes should ensure that those properties suffering high levels of noise are purchased and are no longer used for residential purposes in the future or until noise levels reduce again. The level at which this should happen should be around the 69dB LAeq16hr or 60dB LAeq8hr for night time noise.

21. The offer to cover the cost of moving should also be available to those who have experienced a signiﬁcant increase in noise due to changes in airport operation or expansion and are exposed to higher noise levels, for example a property exposed to levels above 63dB by changes in airport operation (ie new runway/changes in NPRs). Sound insulation only improves the internal noise environment of a home (with windows closed) and not private gardens or the surrounding neighbourhood. The impact of the loss of residential properties on the supply of housing in an area where demand already outstrips supply also needs to be taken into consideration.

Air Quality

22. The APF highlights the impact that airports can have on air quality and that the policy is to seek improved international standards to reduce emissions from aircraft and to work with airports and local authorities as appropriate to improve air quality.

23. The S106 agreement between Gatwick Airport Limited, Crawley Borough Council and West Sussex County Council signed in 2008 contains a number of obligations concerned with mitigating the environmental impact of the growth of the airport. It has been a useful mechanism for working with the airport on a range of environmental matters and whilst it recognises the role of meeting national regulations and targets (eg air quality standards) in managing the operation and growth of the airport, it does also give greater reassurance to the local authorities and others of the actions and activities which are being undertaken in order to help meet these targets.

Planning

24. The draft Aviation Policy Framework only touched on planning issues concerning the development of the airport. However, this issue is particularly important to Crawley Borough Council as the local planning authority for Gatwick Airport. As part of its response to the Scoping Document which preceded the publication of the draft policy framework, the Council sought clarity on the issue of safeguarding land for a second runway at Gatwick. Although the airport operator indicates that amount of land that is required to be safeguarded, this does not have any statutory basis unless it is included in the Local Plan.

25. It is felt that this section of the draft policy framework provides a clear steer that land for a second runway should continue to be safeguarded through the Local Plan until conclusions have been reached regarding the potential for future provision of a hub airport in the south east. It is presumed that this will now be provided by the ﬁndings of the independent commission which has recently been set up to examine the issue of a hub airport rather than through the Call for Evidence which is referred to in the document. Where airport expansion is a possibility then safeguarding should remain in place until a ﬁnal decision is made.

26. Given that it has been indicated that the aviation policy framework will be published in advance of the report on hub airports, it is important that the framework continues to provide clear guidance on the issue of safeguarding and that possible options for any required hub capacity are not precluded until there has been a comprehensive examination of the issues through the Independent Commission. The Borough Council is currently preparing its new local plan to cover the period to 2029 and will need to reﬂect the latest guidance on safeguarding land. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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27. It is also felt that further details on the meaning of “incompatible development” would be useful in formulating planning policies for the safeguarded area in order to give an indication of what sort of development is appropriate in the safeguarded area. 19 October 2012

Written evidence from Lagan Valley Group Residents’ Association (AS 45)

With respect to this inquiry, we would like to comment on paragraph 3 (a), (b) & (c)

We live in a residential area of detached family homes within the city limit of Belfast and about 4.5 miles from the George Best Belfast City Airport. We are under the flight path and many of our residents are seriously annoyed by aircraft noise. Even though we are not in the immediate vicinity of the airport we wish to make it clear that there are serious adverse affects from aircraft noise at a greater distance than is perhaps being monitored. — Sleep is disturbed by early morning flights. — Listening to TV or radio when the windows are open is difficult. — Conversation the garden has to stop when the aeroplane is overhead. — Aircraft noise spoils the enjoyment of our gardens. — Noise from daily flights is both an irritant and an annoyance.

We are fortunate to live in close proximity to areas where we can walk and enjoy nature; The Lagan Valley Regional Park with walks along the towpath beside the river Lagan: Barnett Demesne, The Botanic Gardens and Belvoir Forest Park. The pleasure of enjoying walks in these beautiful and popular surroundings is spoiled by the constant passage of low ﬂying aircraft as they come in to land—the noise is sometimes really deafening and it is frightening for children.

Our residents also have concerns about pollution from aircraft which must be more concentrated since the aeroplanes are lower as they take off or land. One resident had a large lump of ice fall on to her roof as an aircraft was de-icing the wings. Very fortunately this did no damage to the roof (or indeed to anyone passing by) but her garden was covered with shards of ice where it had shattered.

It is well known that many health problems occur with aircraft pollution, both emission and noise. We feel that all airports throughout the UK should be properly and robustly monitored and regulated with tough enforcement when breaches of regulations occur. We need to have conﬁdence that the government takes the impact of airport noise and pollution seriously. We feel that regulation by the airports themselves is unsatisfactory and may not necessarily address the problem properly when their commercial interests are at stake. This should be the responsibility of an independent body.

With regard specifically to Northern Ireland, there is great emphasis to expand the George Best Belfast City Airport, in view of its close proximity to the city and therefore its presumed benefits to the business community. However, the Belfast International Airport at Aldergrove is only about 18 miles from the city and this airport does not cause the serious problems of noise and pollution for thousands of people as is the case with GBBCA. BIA is easily accessible, especially to those living in the north and west of the province. The economic benefits are equally relevant to BIA and this airport should be further developed (not GBBCA) especially in terms of the availability of long haul flights. At present, BIA has only one regularly scheduled long haul flight and we are therefore forced to travel to either Heathrow or Dublin to access most long haul international flights. This increases the amount of air traffic, noise and pollution, much of which could be avoided if BIA at Aldergrove were further developed.

We are very concerned about the EU directive to increase the number of ﬂying hours for pilots to a level which is greater than prescribed by UK rules. Taking account of the fact that pilots need to travel to the airport and complete the check-in routine, both on the ground and in the ﬂight deck, before they take off, the proposed EU rules could result in a very long working day with serious implications for safety. 19 October 2012

Written evidence from the London Chamber of Commerce and Industry (AS 46)

1. London Chamber of Commerce and Industry (LCCI) is a not-for-proﬁt organisation, representing over 2,500 companies in Greater London. We are the capital’s largest and most representative business organisation with a membership ranging from small and medium enterprises to multi-national companies. Our members operate in a variety of sectors reﬂecting the true make-up of the London business spectrum.

2. We promote and defend the interest of London’s business community, representing our members to the Mayor and the GLA, national government, the opposition, international audiences and the media. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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3. LCCI believes infrastructure is central to guarantee sustainable and long-term economic growth. The lack of capacity on our roads, trains and airports is affecting our ability to expand and compete globally, whilst damaging our international reputation and limiting the UK’s capacity to attract and retain investment. 4. LCCI has canvassed its members extensively and according to the LCCI survey in August 2009, 85% of businesses in London see transport as “very important” or “somewhat important” in encouraging a business to locate in the capital. 5. This consultation’s questions ask on several occasions about the Government’s aviation strategy. When surveyed this year, only 16% of LCCI members stated the Government has a coherent national aviation strategy. This reﬂects the problem that the business community currently face. LCCI believes we are reaching a crucial juncture. If the UK wants to be part of a global, interconnected economy driven by domestic exports then it needs to have the capacity to allow the connectivity to exist to optimise trade with the emerging high growth markets. 6. LCCI believes that if the Davies Commission is to be successful and worthwhile it must create a cross- party consensus around a strategy that resolves our capacity and connectivity concerns. LCCI looks forward to working with the Commission to achieve this. It notes with great disappointment that this process will not report for another three years which is not a satisfactory time period given the need to act.

What should be the objectives of Government policy on aviation? 7. LCCI’s transport and infrastructure policy proposals are focused on making London the most competitive city in the world to do business. Aviation provides the international connectivity that makes London and the UK competitive. It needs to be viewed as one mode in an integrated network to maximise the connectivity and value of different transport modal networks. 8. LCCI primarily views aviation as a means to enable businesses to create economic growth. There are a number of important sectors that rely on having connections with clients and customers in emerging markets. For instance the service industry with consultants and engineers need direct flights to the right parts of the world or they may find it more sensible to switch their European HQ to Frankfurt, Paris or Amsterdam. 9. Another important element to consider is the importance of air freight. These services are a vital ingredient in the UK economy allowing it to function as an international centre of business and high value manufacturing. 10. London has seven airport’s, including its hub airport, Heathrow, four significant sized airport’s City, Luton, Gatwick and Stansted, and two specialist airports, Southend and Biggin Hill. 11. It is worth noting that aviation is a major UK industry in itself, carrying over 235 million passengers a year and over 2.3 million tonnes of freight.39 Furthermore, the UK aviation industry employs 234,000 staff, contributes £18.4 billion to the UK Gross National Product and £7.8 billion in taxation to the Exchequer.40 12. LCCI is a chief supporter of the need to maintain the UK’s position as a regional and international leader in the aviation sector. Therefore, it needs the connectivity to create the through traffic viable to make many destinations feasible for a hub airport. In a recent survey of LCCI members 80% stated the UK needs a hub airport to have the connectivity to trade successfully in international markets. 13. If we do not create the capacity to allow the connectivity to thrive we are at risk of losing out on superior trading relationships in major emerging market centres with high growth rates, as well as key destinations London already has direct flights too. The CAA has listed major routes that would be most likely to disappear without transfer passengers. They are, in order of vulnerability: Mexico City, Lusaka, Beirut, Halifax, Dar-Es- Salaam, Seattle, Phoenix, Chennai, Bangalore, Tripoli, Riyadh, Accra, Ottawa and Dhaka.41 Predictions for increased urbanisation and growing populations across emerging market cities by 2050 will mean that if we do not have the direct links we will not be able to compete with European rivals who have the capacity to create the connectivity to be competitive. 14. LCCI welcomed the Government’s announcement to consult on a new hub airport as recognition of the need for both additional long-term aviation capacity and a national hub airport. The Davies Commission has now been formed and if it can provide political consensus on a long term strategy it will be a worthwhile exercise. 15. However, any decisions on a long-term solution to capacity constraints do not address the urgent issue of London’s short-term aviation capacity constraints. After exhaustive study the only viable solution to these immediate capacity constraints is a third runway at Heathrow Airport. 16. Capacity constraints at Heathrow have led to a reduction in the overall number of destinations served, from 227 in 1990 to 180 today. For example, Chengdu and Chongqing are just two Chinese cities that are experiencing dramatic growth rates, but are not served by a UK airport, severely reducing the ability of the UK’s businesses to expand into those markets. It is worth noting that Heathrow’s rival European hubs have 39 Department for Transport http://www.dft.gov.uk/aviation (last visited 04–05–12) 40 British Air Transport Association http://www.bata.uk.com/ (last visited 04–05–12) 41 http://www.caa.co.uk/docs/5/Connecting_Passengers_at_UK_Airports.pdf table 7–1, p. 25 cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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more runways, for instance Amsterdam has ﬁve, Paris (Charles De Gaulle) has four, Madrid has four and Frankfurt has three with a fourth runway planned42. 17. Moreover, the lack of capacity also leaves Heathrow with no room for any contingency which has a direct negative effect on the airport’s reliability, passengers’ travel experience and, consequently, Heathrow’s and the UK’s competitiveness. It is also important to emphasise the negative effect of capacity constraint including costs and delays at major airports on the UK’s ability to attract signiﬁcant foreign investment.

Air Passenger Duty (APD) 18. APD was introduced in November 1994 at a £5 rate within the UK and EU, and £10 elsewhere. A senior international business executive, an SME looking to make international export contacts, or a foreign investor considering locating in the UK now has to pay up to £184 per outbound journey to a destination outside of Europe, depending on destination and class of travel. The high cost of APD includes travelling to emerging markets such as Brazil, China, India, Indonesia, Colombia, Venezuela and South Africa. 19. This increase continues to place the UK at a disadvantage to its international competitors. Only five of the 27 European Union countries levy some form of air passenger tax, with Denmark, Norway, and Holland scrapping similar taxes after analysis showed the revenue raised was outweighed by the economic damage. 20. The four other countries which levy air travel taxes are Austria, Germany, Ireland and France. They are significantly lower than the UK taxes with France and Ireland only levying nominal rates. For instance, the German revenues are roughly a third of the UK level and the German Government has made a commitment not to increase them since the EU’s Emissions Trading Scheme (ETS) has been introduced. LCCI believes the UK Treasury should consider offsetting the income from the EU ETS against APD. 21. It is worth noting that between 2006 and 2012, APD rates have risen 160% on short-haul flights and up to 360% on long-haul flights. In the same time period inflation has risen 18%. 22. The Treasury forecasts that it will raise £2.2billion from APD in 2011–2012, which will rise to £3.9billion by 2016–2017. This is a substantial revenue income in 2011–12, which is set to almost double by 2016–17. LCCI would like to see an acceptance that APD is too high in the UK and should not increase further. The business community wants to fulfil the Government’s aim to have an export-led recovery. Additional tax burdens on exporting will hinder their prospects. 23. Furthermore, a 2009 report by Oxford Economics for the Airport Operators’ Association found that the APD increases in 2009 and 2010 could, by 2020, result in job losses to the wider economy of 1,400 in terms of connectivity, 7,700 in terms of trade, and 22,300 in terms of investment. The same report warned that by 2030, growth in APD of 5% a year could reduce the aviation sector’s annual GVA by £450 million, with wealth created in the wider economy reduced by £500 million in terms of connectivity, £2.6 billion in terms of trade, and £8.3 billion in terms of investment43. Furthermore, it is worth noting the importance to London’s retail and hospitality businesses of inbound tourism and the disincentive to visit the UK that APD presents. APD is part of a triple whammy that afflicts both the tourism and business sector. The other two issues that need resolving are aviation capacity constraints and the UK visa system. 24. In a survey this year of London’s businesses 57% stated that increasing Air Passenger Duty is a barrier to their future business exporting activities. Therefore, LCCI believes the Treasury should commission its own independent research to analyse the impact of APD on the UK economy and to consider the wider economic and employment effects of reducing or eliminating APD. It is imperative that the UK’s competitiveness is not lost in the short term desire to maximise revenue for the Exchequer.

How should we make the best use of existing aviation capacity? 25. There are a number of airports in the South East and regional airports across the country that could increase capacity. LCCI has the following views: 26. Heathrow: LCCI’s position supporting an additional runway at Heathrow is ﬁxed at present in the light of no new evidence to propose a preferred solution. Our stance on Heathrow is clear. A third runway is the only way to retain the UK’s leading role as an international hub which can be completed in the short- medium term. 27. Gatwick Airport: Gatwick can grow by around 10mppa with its existing runway, although this would increase utilisation to 95% and reduce resilience. Safeguarding for a second runway to the south of the airport remains in place, and could be implemented in the early 2020s. The main constraint to expansion at Gatwick, and in particular to its ability to serve London, is the limits imposed by rail access. A second runway and an associated third terminal would require major expansion of the rail station and signiﬁcant upgrading of the rail services. 28. The Heathwick, high speed Heathrow-Gatwick rail link, would not work because the transfer times would be too high. Any expansion at Gatwick must be coupled with major improvements to rail access to 42 Future Heathrow http://www.priorityheathrow.com/page.php?id=8 (last visited 04–05–12) 43 “What is the contribution of aviation to the UK economy?” Oxford Economics (November 2009) cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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London and an acceptance that it cannot become a dual hub with Heathrow but remain a strong point-to-point airport serving international business markets. 29. Stansted Airport: A second runway at Stansted is no longer safeguarded, but the previous plans were well developed following a 2006 Government White Paper and showed potential for 70–80 mppa, with expanded road and rail links. A second runway should remain an option for the longer term, so safeguarding should be reinstated and the road and rail upgrades put into the respective long term strategies. 30. Luton: Current ambitions for Luton are limited to 15 or 17mppa compared with 10 at present, and such growth would not enable a transfer hub to be established. It would take significant changes as explained in the Policy Exchange 2012 report for Luton to be significantly expanded. 31. Smaller Airports: The other airports serving London; City, Southend, Biggin Hill, Farnborough, and Manston all have some capacity or potential to serve particular markets. 32. London City is a vital airport for the London business community serving direct links from the near City of London and Canary Wharf to important European trading partners as well as New York. Biggin Hill and Farnborough are niche Business Aviation airports which serve a very important market separate from commercial air transport and LCCI strongly supports these airports and plans to expand. It is worth noting the important role of Biggin Hill and Farnborough on relieving pressure from London Heathrow during the Olympics. LCCI’s support extends to other airports where they can meet a demand that is commercially viable. 33. Airports outside the South East: Some regional airports are making the case for diverting demand from the South East. LCCI supports strong regional airports and supports capacity increases where there is commercial demand. If that demand does not exist LCCI does not believe the Government should seek to implement a centrally planned system where sufficient capacity already exists.

Surface Access 34. LCCI is an advocate of ensuring that the transport modes seamlessly interchange to allow businesspeople to move with ease between regional, national and international networks. Encouraging better rail links has a number of benefits including moving more traffic of the roads network. Surface access is also one of the key considerations an international business will review when deciding where to locate or a city to do regular business with. 35. LCCI was pleased to see the Government recognise the importance of rail-air links in the Department’s Rail Command Paper which outlined this with the point that “international passenger journeys (…) and providing surface access to major airports” are one of six key market segments for rail. LCCI supports a number of surface access improvements across London airports. We support a number of improvements where there is a positive business case. 36. Gatwick Airport is a vital gateway for London’s businesses and international businesspeople accessing the Capital’s market. LCCI would like the Thameslink franchise to mandate the reinstating of the dedicated Gatwick Express, an upgrading of rolling stock to suit the needs of air passengers and the removal of ticket barriers to allow a seamless travel experience for passengers who are currently forced to wait and queue to exit the airport and join the rail network. These changes are all necessary taking into account the nature of passengers using air-rail links. 37. Luton Airport is also covered to the north of London in the Thameslink franchise. LCCI would like the future operator working in partnership with the Airport to utilise the opportunities from the Thameslink project to amend the timetable to improve links to the Airport and maximise its potential as a growth contributor to London and the UK. 38. The rail link between Stansted Airport and Liverpool Street station desperately needs to be upgraded. LCCI supports implementing improved infrastructure on the Lea Valley Line to enable faster, dedicated Stansted Express services as well as improved commuter trains. 39. LCCI supports the proposal from Wandsworth Council, based on BAA’s Airtrack scheme, which would provide four trains an hour from Waterloo to Terminal 5 with stops at Clapham Junction and Putney. It routes two trains an hour from Waterloo via the Hounslow loop and two existing services on the Waterloo-Windsor line that would split at Staines to provide a further direct link to Terminal Five. 40. The new scheme would require a new station at Staines and a new stretch of track from there to Terminal 5. The rest of the route would run along existing lines. The plans avoid routeing extra trains through level crossings in Mortlake and Egham, a key problem with the original Airtrack scheme. 41. HSR has the potential to decrease the number of domestic flights which would help capacity constraints in the aviation industry. Demand for air travel has been growing, with a five-fold increase over the last 30 years, and is expected to continue to grow to between four and six hundred million passenger journeys by 203044. HS2 could help reduce the number of short-haul domestic and European flights, allowing Heathrow 44 DfT (2003), The Future of Air Transport, aviation white Paper cm 6406; cited in Greengauge 21 (2006): The Impact of High Speed Rail on Heathrow Airport, p. 2 cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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to meet the significant demand to emerging markets. This would be done most successfully if the shift from air to rail is optimised by serving airports directly with high speed trains. 42. Therefore, to maximise connectivity and value HS2 needs to be fully integrated into Heathrow airport to allow passengers to use rail whilst transferring through the UK’s international hub gateway to emerging and developed markets. It is important to note that a reduction in short-haul domestic and European flights would not reduce air travel as demand for more flights and new destinations far outstrip supply of landing slots at Heathrow.

Environmental impact of aviation 43. LCCI believes the two most significant environmental issues are noise and carbon emissions. 44. A 2009 report from the Committee on Climate Change showed that growth in aviation is consistent with the UK meeting its climate change targets. The industry continues to place strenuous efforts on improving fuel efficiency and operational improvements that will lead to significant reductions in carbon emissions per seat km flown. 45. The industry has taken a proactive approach in recent years to tackling environmental issues. The Sustainable Aviation group was set-up to create a long term strategy which sets out the collective approach of UK aviation to tackling the challenge of ensuring a sustainable future for the industry. A world-first, Sustainable Aviation was launched in 2005 and brings together the main players from UK airlines, airports, manufacturers and air navigation service providers. This is an important vehicle for tackling noise concerns as well as emissions.45 46. LCCI believes that the UK must tack a proactive approach to reaching international agreements on tackling carbon emissions. A unilateral policy would damage the UK as a place to do business and have no material impact on global emissions reductions, creating a lose-lose scenario. 47. LCCI believes that investing in technology is the best way to reduce the impact of noise and meet our environmental obligations. This would ensure we do not export jobs and growth to countries that value the importance of a thriving aviation sector.

Conclusion Do we need a step-change in UK aviation capacity? 48. LCCI believes it’s vital that the Government develop a coherent strategy that details how the UK will create the capacity and connectivity to make London and the UK the most competitive place to do business. This needs a short and long term solution to our current problems. 49. LCCI has consistently argued that we need a hub airport and strong point-to-point airports that can serve high growth emerging market as well as the UK’s traditional trading partners. In the short term we have expounded our solutions above. In the long term it is plausible that a new hub airport will need to be built. LCCI will continue to assess the options put forward and welcomes new proposals. 50. Most importantly, we need to move beyond the politics to create a consensus around solutions that deliver on capacity, connectivity and the environment. 51. LCCI is keen to engage with the Committee during this inquiry at every opportunity. Please contact David Hodges, Public Affairs Manager, at [email protected] or call 020 7203 1918 to discuss this further. 19 October 2012

Written evidence from Merseytravel (AS 47) Merseytravel is a public body comprising the Merseyside Integrated Transport Authority (ITA) and the Merseyside Passenger Transport Executive (PTE), acting together with the overall aim of providing an integrated transport network for Merseyside which is accessible to all. Integrated Transport Authorities including Merseytravel have a statutory requirement to produce Local Transport Plans as a result of the Local Transport Act 2008. Via the Local Transport Plan (LTP), the ITA is responsible for multimodal transport policy including freight. However the Passenger Transport Executive (PTE) remains responsible only for delivery of passenger transport, concessionary travel, ticketing, etc and as a result we continue to work in partnership with the local authorities and other partners to deliver the LTP. The new Local Transport Plan 3 and its associated documents came into force on the 1 April 2011 and now form the transport policy framework for Merseyside. We are also represented on the Airport Transport Forum and Airport Consultative Committee for Liverpool John Lennon Airport. Our comments on the questions asked by the Committee are as follows. 45 http://www.sustainableaviation.co.uk/ cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Questions: 1. What should be the objectives of Government policy on aviation? We feel it is important that the objectives of the aviation strategy focus on reducing the environmental impacts of aviation as an integral part of the strategy, in order to (a) meet CO2 reduction objectives and (b) reduce the impact on communities through poor air quality, noise and disturbance and (c) reduce reliance on imported, finite fossil fuels. Encouraging sustainable surface access to airports by public transport, walking and cycling and seeing aviation as just one mode within the context of an integrated transport system should be another major focus for the objectives of the aviation strategy. These areas are of particular concern for us as an Integrated Transport Authority and Passenger Transport Executive. More generally the aviation strategy should ensure good international connectivity for all parts of the UK to key destinations and markets globally. It should enable sustainable growth in aviation as part of an integrated transport system within the constraints of noise, emissions and other impacts. The strategy should also move away from the present focus on a single hub approach to connectivity centred on Heathrow and instead go towards a multi-hub approach that makes best use of the capabilities and potential of all airports in the UK and not just those in the Greater South East. It needs to recognise that aviation is global, market led and rapidly changing so foreign airports now play a role in providing international connectivity for the UK not just airports within the UK. In recent years, due to severe congestion and capacity constraints at Greater South East airports, airports outside London are increasingly turning to major airports elsewhere outside the UK such as Madrid, Amsterdam, Paris or Frankfurt or even airports in the Middle East and further afield to improve their international connectivity. This should be reflected in the multi-hub approach. The fundamental factor which is critically important is good connectivity for all parts of the UK to key markets and destinations globally regardless of how it is achieved. This improved connectivity will create opportunities across the UK for investment and growth and help enable a more diverse and balanced UK economy. This is especially important in terms of links with the new growth economies such as China, India, Brazil, Middle East, Russia, etc.

(a.) How important is international aviation connectivity to the UK aviation industry? See answer to b) below.

(b.) What are the benefits of aviation to the UK economy? According to research by the Airport Operators Association (AOA), the aviation sector in the UK is worth over £18 billion and plays a significant role in the economy and job creation. The aviation sector generates £8.8 billion of economic output (measured as Gross Value Added). This increases to £18.4 billion, 1.5% of the total economy, when the activity needed to supply the sector is taken into account. The sector accounts for 141,000 jobs in the UK, which rises to 234,000 (0.85% of UK employment) when supply chain employment is also taken into account. Aviation and its airports also help sustain other sectors and industries such as £115 billion tourism sector. The tourism sector overall employs 2.5 million people and supports more than 200,000 businesses and accounts for almost 10% of the UK economy. The majority of international tourists visit the UK by air. Airports are a major employer and gateway for inward investment, trade and tourism. Airports have a key role to play in spreading prosperity around the UK. For example, good air transport links are crucial to attracting inward investment from around the globe. The majority of Europe’s top companies regularly say they consider transport links a key factor. In other regions, airports provide vital connectivity allowing business passengers and exports to reach new markets. In recent years UK airports have seen success in securing an increasing number of direct long haul routes connecting our cities to a range of key foreign destinations. In the longer term, the main influence of the aviation sector on the economy is likely to be the way in which it facilitates improvements in productivity outside the sector. Aviation enhances the ability to conduct international trade by increasing connectivity between the UK and international destinations (and can increase connectivity within the UK as well) which can lead to increased investment and two-way trade. The role of aviation will play an important role in underpinning and assisting the economic recovery by supporting businesses through international connectivity, the movement of goods and people, and attracting inward investment. With the rise of new growth economies such as China, India, Brazil, Middle East, etc, these will increasingly become important destinations to be linked with and with new aircraft designs; there may be an opportunity to enable these linkages to be direct from regional airports. New aircraft designs such as the Boeing 787 Dreamliner with its improved capabilities opens up the possibility of long haul fights direct from regional airports such as Liverpool to destinations such as North America (West Coast), South America, Australia, etc, which previously were only possible with aircraft such as 747s which could not be accommodated on many regional airport runways, etc. So this could open up the possibility for regional airports to have direct flights to many destinations that previously were only possible via a major hub. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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We feel that there is a signiﬁcant risk that if development and infrastructure investment continues to be primarily focussed on the Greater South East then this reduces options for the future of the UK economy and is likely to only create a service economy based around London. As the Greater South East becomes increasingly congested and full, this congestion will risk becoming a disincentive to business and they will move to the Continent. But if development and infrastructure investment is well spread across the UK and regions are equally well connected to international markets and destinations, then this will create new opportunities for business to remain in the UK, attract business to the regions and will lead to a more diverse and balanced UK economy. This rebalancing in turn will help take the pressure off the congested Greater South East and airports located there and spread prosperity and opportunity across the whole UK to the beneﬁt of everyone.

(c.) What is the impact of Air Passenger Duty on the aviation industry? The incentive regime around aviation policy is just as important as the policy itself and these aspects such as tax, emissions trading, visas and security need to be set at a level that does not make aviation in the UK uncompetitive internationally but still mitigates issues such as noise, emissions, security controls, etc. Therefore a joined up approach to these issues is required within Government to tackle this. It is known that APD is a particular issue of concern to the aviation industry currently, but airports and airlines will be better placed than us to give details on how Air Passenger Duty and the wider incentives framework affect them. In our opinion, Air Passenger Duty needs to be reformed so that it is much more targeted and flexible and more clearly linked to offsetting the disbenefits of air travel (noise, emissions etc) and not simply be a blanket tax that goes to the Treasury. APD should also be based on factors such as the length of the journey—a domestic flight could have higher rate of APD than a long haul, to encourage travel decisions between air or rail on financial grounds where rail can be an appropriate alternative. But this would need to be flexible and take into account the fact that clearly some domestic routes are essential by air and rail cannot provide an alternative in some cases. There may also be scope for APD to be ringfenced and localised (a bit like Bus Service Operators Grant), so that it can be used to support surface access improvements, provide environmental mitigation, help to offset carbon etc. Also differential APD charging based on age and environmental efficiency of aircraft should be considered so that flights on the newer fleets of planes could perhaps be subject to a slightly lower rate of APD as they have better environmental credentials compared with older aircraft. Although we understand that there may be constraints on this due to the Chicago Convention which was agreed in 1944 and ratified by the UK in 1947, which is the treaty which still governs the conduct of international civil aviation, so this may need reforming as well. If these reforms to the APD etc could be achieved then this would create a more flexible incentive structure to support the aviation strategy.

(d.) How should improving the passenger experience be reﬂected in the Government’s aviation strategy? The passenger experience should be not seen as just aviation (airports and airlines) but also include the entire seamless journey experience across all modes as part of an integrated transport system. See also answer to e) below.

(e.) Where does aviation ﬁt in the overall transport strategy? Aviation is only one mode in an integrated transport system, therefore the aviation strategy needs to be set within the context of a clear transport strategy at the national level and take into account integration with other modes. Travel is just a way of getting from A to B and journeys are often undertaken via several modes. So transport should be seamless across all modes and individual modes should not be seen in isolation. The Government’s strategy can appear fragmented so needs to be much clearer how it sees aviation being part of a single integrated transport system.

(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? We feel that in its current form the Government’s policy remains too focused on the Greater South East and could do more to maximise the potential of regional airports. International connectivity for the regions is important to support economic growth and investment in these areas and the local airport has a role to play in this. Airports are a major employer and gateway for inward investment, trade and tourism. Airports have a key role to play in spreading prosperity around the UK. For example, good air transport links are crucial to attracting inward investment from around the world. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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It is important that the role of all airports in the UK in enabling international connectivity is recognised and used to take pressure off the airports in the Greater South East. We believe regional airports have ample capacity to accommodate future growth and absorb some of the future demand from the congested Greater South East. Access from regional airports to key international destinations direct, without the need to go via London would improve the competitiveness and attractiveness of regional cities for investors and thus help provide a counter balance to London. We feel that the aviation strategy needs to consider all options regarding the future of international connectivity in the UK including moving away from the current single hub approach and instead considering a multi-hub approach using a London Airport as well as other major airports in the regions such as Manchester, Birmingham, Bristol, Glasgow etc. In this strategic context for infrastructure planning arguably the regions within England could be seen as Northern England, the Midlands, West Country and, of course, the Greater South East. The multi-hub approach needs to also recognise the increasing role played by foreign airports such as Amsterdam, Paris, Frankfurt, Madrid and even Middle East airports and elsewhere in providing connectivity for all parts of the UK. London Heathrow is not the only way to provide connectivity and airports in the Greater South East are just part of the UK’s network of airports and all airports (whether in London or elsewhere) should play a role in providing connectivity for all parts of the UK. The increasing competitiveness of high speed rail will also be a factor to consider. Between certain cities where high speed rail offers a competitive advantage there may be an increasing reliance on high speed rail rather than domestic flights. This in turn can help relieve capacity constraints at airports. High speed rail may also be able to replace some domestic shuttle flights into major airports that serve a hub role, so linkages from regions into hub airports may not necessarily have to be by air. This could then free up capacity at major airports to offer more long haul flights while maintaining domestic/short haul connectivity into the airport for connections. To achieve this, linking airports into the rail and high speed rail network will be essential. Like France’s TGV and Germany’s ICE high speed trains, give UK high speed trains airline codes so that they can act as “flights” into airports such as Heathrow just like KLM flight from Liverpool to Amsterdam used to feed into their worldwide network. Why do you need a flight when a high speed train can perform a similar role? High speed rail also needs to have stations to serve airports as well as city centre destinations. This way it can link to aviation as well as traditional intercity journeys. High speed rail can take a greater share of the market currently taken by domestic and short haul air travel but air travel will still have a role to play as well. We are supportive of high speed rail and the role of rail in regard to its ability to provide a better environmental solution for short/medium-term length journeys than air. We suggest that the Government should advocate a hierarchical approach to transport planning (with sustainable modes being the most preferential). We feel that there also needs to be greater synergy between the government’s aviation and high speed rail plans so there is much more joined up approach to transport. All modes of transport should play important roles together as part of an integrated transport system and use and development of one shouldn’t be at the expense of development in another, although the shares of each mode will clearly differ. Another important area to consider is reducing the need to travel in the first place. With new technology such as video-conferencing, etc, there are more options that mean travel may not even be necessary in some instances. High-speed internet access is a prerequisite for many alternatives to travel and in some areas of the UK, such access is sorely lacking. Government should invest in the installation of fibre optic cables for the transmission of data as this will ensure a much more robust and secure network for all and allow more people to use these services at the same time, with less disruption to the service.

(c.) How can surface access to airports be improved? We feel that surface access to airports is an important issue and encouraging access by sustainable modes such as public transport, walking and cycling in particular. As a result airport surface access strategies need to be aligned closely with the Airport Master Plan as well as with Local Plans and the Local Transport Plan. Where airports undertake new development they should be encouraged to contribute to any surface access improvements that may be required to support the development or their Airport Master Plan proposals via planning obligations. Merseytravel has, in recent years, been working closely with Liverpool John Lennon Airport to support its Airport Master Plan and Airport Surface Access Strategy. We also are represented on the Airport Transport Forum and Airport Consultative Committee. As a result we have been working in partnership with the airport to improve surface access to the airport particularly by public transport including via Liverpool South Parkway rail station. This rail station is served by several train companies including Merseyrail Electrics, Northern Rail, London Midland, East Midlands Trains and Transpennine Express. We continue to work with the airport to open up the region and enable convenient access for people to the airport. Merseytravel is represented on the Airport Transport Forum and Airport Consultative Committee. Based on our experience on these groups we believe that the current role of the Airport Consultative Committee (at least in the case of Liverpool’s) strikes the right balance between challenging the airport management over issues that may be of concern to communities close to the airport and recognising the important role this airport has in the current and future needs of the local economy it serves. If Airport Consultative Committees were to cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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increase their remit to look in more detail at certain topics, levels of workload could then be an issue and impede getting a good cross-section of representation from key organisations and interested parties. Liverpool John Lennon Airport is a major economic driver for Merseyside and indeed the North West Region. Therefore its continued prosperity, development and growth is of paramount importance to the economy. Airports are a major employer and gateway for inward investment, trade and tourism. Airports have a key role to play in spreading prosperity around the UK. Additionally Liverpool Airport is an important contributor and asset as part of the Liverpool SuperPort initiative which aims to develop synergies between the airport and the port and logistics sectors.

3. What constraints are there on increasing UK aviation capacity? (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? Noise is an important issue to consider in regard to aviation strategy and this is partly caused by older, noisier and less efficient aircraft. But just tackling this with replacement of old aircraft with newer, more efficient ones will not solve all of the issue. Frequency of flights can also contribute to noise for local communities due to the cumulative effect. But this understandably is quite hard to tackle.

(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? Climate change will be one of the major challenges especially in a sector that is growing. There are a number of issues that can be addressed such as direct emissions from the airport through efficient asset management and operation efficiencies. Emissions from the flights themselves will need to be reduced in order to contribute to carbon reduction targets. Alternative fuels will have a major role to play in this as more and more studies and trials are carried out to determine the most effective. It is important that sustainability is considered for the biofuel and where possible is locally sourced from the area airports are located. This will become more apparent with the advance of second generation fuels such as syn gas derived from lignocellulose. We feel it is important that reducing the environmental impacts of aviation is an integral part of the government’s strategy, in order to (a) meet CO2 reduction objectives and (b) reduce the impact on communities through poor air quality, noise and disturbance and (c) reduce reliance on imported, finite fossil fuels. We understand that the aviation industry is already doing much to safeguard the environment but there is always scope for further improvements while balancing these against sustainable growth in aviation.

(c.) What is the relationship between the Government’s strategy and EU aviation policies? The incentive regime around aviation policy is just as important as the policy itself and these aspects such as tax, emissions trading, visas and security need to be set at a level that does not make aviation in the UK uncompetitive internationally but still mitigates issues such as noise, emissions, security controls, etc. Therefore a joined up approach to these issues is required within Government to tackle this. Linkages with EU policies are not often clear and the cumulative effect of both EU and UK policies in terms of aviation and its surrounding incentive regime needs to be considered carefully to ensure that it does not make the UK uncompetitive.

4. Do we need a step-change in UK aviation capacity? Why? International connectivity for all parts of the UK is fundamentally important, and the way to deliver this outcome and achieve better international connectivity for the regions and all parts of the UK is really down to all partners in the aviation industry and the Government working together to properly debate and resolve the issue.

(a.) What should this step-change be? Should there be a new hub airport? Where? It is important that the role of all airports in the UK in enabling international connectivity is recognised and used to take pressure off the airports in the Greater South East. We believe regional airports have ample capacity to accommodate future growth and absorb some of the future demand from the congested Greater South East. We need to move away from a single hub approach and to a multi-hub approach which will bring beneﬁts across the UK.

(b.) What are the costs and beneﬁts of these different ways to increase UK aviation capacity? The fundamental factor which is critically important is good connectivity for all parts of the UK to key markets and destinations globally regardless of how it is achieved. It is clear that airports outside the Greater South East have ample capacity to accommodate future growth and absorb some of the future demand from the congested Greater South East. It is really a matter for the Government and aviation industry to debate and come to a decision on how best to achieve this connectivity and what capacity implications this may have in the short, medium and long term. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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It is a strategic decision of national importance and will shape the future direction of the UK economy and arguably presents a major opportunity to rebalance the UK economy to beneﬁt all parts of the UK and take pressure off the South East. 19 October 2012

Written evidence from GATCOM (AS 49)

GATCOM (Gatwick Airport Consultative Committee) welcomes the opportunity to respond to the Transport Committee’s inquiry into airport capacity in the UK.

GATCOM is the statutory advisory body for Gatwick Airport and comprises representatives from local authorities, the aviation industry, passengers, business, environmental interests and other users of the airport. We provide a forum for informed discussion leading to the provision of advice to the Government, Gatwick Airport Ltd and other organisations on a range of matters concerning the operation and future development of Gatwick.

Given the broad range of interests represented on GATCOM, it is not possible for the Committee to comment on all the questions posed in your call for evidence because there is a diverse mix of views.

Government’s Objectives on Aviation Policy

GATCOM supports the Government’s stated objective that UK aviation should be able to grow, but to do so it must be able to play its part in delivering environmental goals and protecting the quality of life of local communities.

The real issue in considering a long term strategy for aviation is to strike a balance between the economic beneﬁts of meeting demand and the needs of the industry with the impact this has on local communities and the environment. It is essential that airports work in harmony with the local communities around them.

Connectivity

As an island nation, UK airports have a critical role to play in the transport of people and goods. GATCOM recognises the importance of connectivity and its key role in helping the UK economy grow on a sustainable basis. Aviation is one of the UK’s success stories with world leading airlines and airports with the UK being seen as a key destination for existing and new airlines.

The importance of the UK position in international aviation is recognised and there is a role for government working as a partner with the industry to safeguard national interests in the face of growing competition from Europe. The objective must be to maintain a prominent position in the international market, but not necessarily the dominant one that it has enjoyed in the past. It must be recognised that without good connectivity the UK will become removed from global markets and jobs will be lost. A core objective of the Government should be to make a positive choice for a global hub in the UK complemented by greater interlining between the regional hubs. This would help the UK to compete with other European airports and support economic growth in the UK. The current delay by the Government in agreeing a new policy creates uncertainty for all interests.

GATCOM agrees with the description of connectivity, and the value of connectivity, as presented in paragraph 2.14 of the Draft Aviation Policy Framework. The Government’s objective of making the UK, through its air links, one of the best-connected countries in the world is supported. GATCOM believes this can be achieved by encouraging better utilisation of existing runway capacity in the short to medium term supported by improved surface connections, particularly high speed rail links between regions and dedicated airport express services. In parallel there should be a more stringent night ﬂights regime to encourage the use of the quietest aircraft during the night period.

Flexibility should be incorporated into any future approach to exploit the benefits of technological advances and changes to global resources/government priorities. The industry is committed to reducing aircraft and airport emissions and noise impacts and technological advances are being developed but it will take time for the benefits to be realised. Measures to further incentivise airlines to invest in new fuel efficient, “cleaner” aircraft could be achieved through the implementation of greater differentials in the structure of landing charges at airports but it is acknowledged that this would be controversial particularly in the current economic climate.

Surface Access

Gatwick has a strong performance in surface access provision but there are a number of barriers that need to be overcome. If best use is to be made of existing capacity at airports, co-coordinated action and investment by the Government is needed so as to encourage a greater number of passengers and airport workers to access the airport by public transport. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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The rail network will help to meet domestic passengers’ requirements but it is important that rail links to airports are extended and improved through better rolling stock designed for the needs of the airline passenger. The importance of rolling stock design for rail services serving airports should be recognised in the Aviation Policy Framework building on the references made in the Government’s Rail Command Paper issued last year. Air passengers have unique requirements, which differ from commuters and other rail passengers, as they are often carrying baggage in a foreign country on part of a longer journey. GATCOM believes that in order to integrate airports more successfully into the wider transport network, rail services to airports should seek to meet the needs of air passengers by providing step-free access, wide doors, large luggage racks and information displays.

In addition to Local Enterprise Partnerships, airports should be encouraged to engage actively with new Local Transport Bodies to ensure that, where possible, transport investment supports airport growth plans and the integration of investment and services.

As an international gateway with around 33 million passengers annually, Gatwick is London’s best connected airport by rail. The airport rail station has around 900 trains arriving and departing each day and serves over 12 million rail users annually; making it one of the busiest rail stations in the UK. The scale of demand for surface access to and from the airport is growing. Over 10 million journeys are made by people who work on the airport campus every year. There are also a signiﬁcant number of journeys made by suppliers and service providers. Gatwick is well connected to the motorway network via the M23 and M25 although there is growing concern about the capacity of the motorway network being able to accommodate further growth.

Improving surface access is an integral part of the sustainable growth of the airport. Effective, efﬁcient and resilient surface access to the airport beneﬁts not just passengers but also the local community and helps to manage the airport’s overall environmental impact. Rail is the largest single mode of passenger access to and from Gatwick and there is strong evidence that this demand will continue to grow in the future. However, there is limited capacity on the London to Brighton main line which prevents additional services being introduced to support demand on the part of air passengers. This is a major barrier to the effective provision of rail services to a major airport.

Due to limited capacity, the dedicated Gatwick Express service has effectively been removed in peak hours and turned into a commuter service to Brighton. This has obvious implications in terms of the quality of rail provision to and from the airport. Ticket gates have also been introduced at Gatwick this year by the train operating company as part of its franchise agreement with the DfT, which has also further diminished the premium Gatwick Express service as the purchase of tickets on board the train and the removal of train staff to assist air passengers have been lost and has exacerbated queuing for tickets on the station’s concourse.

In addition, the level of direct connectivity between Gatwick and both the local and national rail networks has declined substantially in recent years. Locally, rail access to the east and west of Gatwick is a challenge. The loss of a direct link to Kent is of particular concern both to passengers and the local community, as Gatwick Station is a regional rail hub.

The long-awaited upgrade to Gatwick Station, with an additional Platform seven, is underway. However, the station concourse will continue to have limited capacity for passenger growth even after the current enhancement project. If Gatwick’s status as a major international gateway is to be maintained, and the overall passenger experience is to continue to be enhanced, improvement work to the station should be on-going rather than subject to a near thirty-year interval, as was the case until mid-2010.

As regards the Strategic Road Network, Gatwick is located close to very congested parts of the motorway network; the south-west quadrant of the M25 motorway and the M23. Safe, reliable and resilient access to Gatwick, given its signiﬁcant international gateway status, is economically and operationally critical. There is a need to expedite the introduction of active trafﬁc management and selected hard shoulder running schemes on key sections of motorway to support reliable access to Gatwick.

In terms of encouraging a shift from air to rail, there are three key criteria to help decision making when balancing alternative modes of transport.

Pricing structures need to change due to the fact that environmentally it is not sustainable to continue to ﬂy short distances therefore prices need to reﬂect this. Rising oil prices are also likely to be a contributing factor; however governmental “pressure” in the form of general taxation and further investment in the rail network will also be required.

Noise and other Local Environmental Impacts

GATCOM supports the establishment of effective noise management regimes and the majority of members believe that the current noise limits are in need of review. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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In terms of addressing the issue of aircraft noise and disturbance, on balance GATCOM believes that it is probably preferable to minimise the total number of people affected by aircraft noise through the use of noise preferential routes, as additional design features could be used in these areas to minimise the direct impacts where possible, for example the use of treble glazing in existing and new housing. This approach is likely to make it easier to identify areas affected and adequately plan suitable land uses or incorporate mitigation measures to minimise disturbance. There are however impacts flowing from the introduction of new technological advances such the use of direct routeing/PRNAV. As navigational accuracy has improved, what was a relatively wide swathe of aircraft trajectories has increasingly narrowed. This has resulted in fewer people being overflown but an increasing number of overflights for a specific number of people, causing disturbance and distress. The increased navigational accuracy through the implementation of PRNAV will exacerbate this situation. The majority of direct routeing flight paths are expected to be at high level for the foreseeable future with little impact on those on the ground. However, longer term developments indicate a possibility that these routes could be lower, and closer to airports, and so result in aircraft overflight of people who have not previously been overflown and who may have purchased their house following research into existing flight paths. GATCOM would like to see further research into the potential of greater dispersal within existing noise preferential route swathes and arrival paths so as to share more evenly the burden amongst those already suffering disturbance. Noise disturbance from aircraft arriving at Gatwick, particularly from areas further away from the airport, is an area of growing concern amongst local communities around Gatwick. The main noise abatement measure identified for arrivals is set out in the Code of Practice for Continuous Descent Approach (CDA). In addition to aiding noise reduction, CDA also reduces fuel burn thereby cutting emissions and producing an overall environmental benefit. GATCOM supports the use of CDA because of the overall environmental benefits achieved but in view of the disturbance still suffered by those local communities under the arrivals flight paths further away from the airport, we would like the Government to consider whether the use of steeper approaches could feature in the Code. It is recognised that implementing steeper approaches at Gatwick could be problematic because it is an international airport and the ICAO international standard is for a 3º approach. Nonetheless GATCOM would welcome studies to determine whether there are possibilities available. Even a slight increase in the steepness of approach would result in aircraft being higher for longer and thus help reduce the noise impact. Noise Action Plans also have a key role in predicting and demonstrating an actual reduction in noise levels. To give local communities confidence that action is being taken to reduce the noise impact around airports, there is a need to demonstrate hard results, not just be a list of “soft undertakings”.

Resilience Gatwick is the busiest single runway commercial airport in the world. Air traffic control does a skilful job in scheduling take-offs and landings at the shortest possible intervals, allowing for the differing wake vortices created by different types of aircraft. But inevitably this system is not resilient, and the minor disruption as a result of adverse weather or other incidents can result in delays. When delays occur, aircraft are required to fly elongated approach paths or to stack, causing increased noise and climate change damage. One solution could be direct routing as described in the CAA’s Future Airspace Strategy. Another would be to place a limit on the number of flights scheduled to use the runway in any one hour. However this would be highly contentious and could reduce capacity further. Regulation could have a role in minimising delays and ensuring the airfield and airspace is used as efficiently as possible. The CAA’s congestion delay term at Heathrow and Gatwick does focus the airports’ attention on making best use of the airfield infrastructure and resilience planning is key to ensure that disruption is handled efficiently and delays kept to a minimum. The experience of resilience planning at Gatwick during the severe winter weather conditions in 2010–11 was that it worked well and lessons learned have been taken forward. Aviation is an integral part of the UK’s transport infrastructure and other transport modes also need to be as resilient. Improved resilience at airports is also reliant on punctual and efficient surface transport and inter-modal connectivity. The severe winter weather conditions in 2010–11 saw surface access networks around Gatwick recover at a slower pace than the airport resulting in airport staff and passengers not being able to access the airport. This had implications for flight schedules outside the control of airports and airlines.

Improving the Passenger Experience The Government’s proposals to extend the Fifth Freedoms policy is supported in principle provided there are conditions put in place so as to ensure that competition for UK based airlines is not hampered or distorted, as it will provide greater choice for passengers using the South East airports. Preserving and improving the passenger experience at airports should be one of the key themes of the new aviation policy to complement cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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the new powers being given to the CAA in the Civil Aviation Bill which places the passenger at the heart of airports regulation. It needs to take into account the end to end journey experience for air passengers. The passenger experience would also be enhanced by the Aviation Policy Framework looking in more depth at the spread of destinations for all the main London Airports to ensure less travelling time and congestion on the M25. If this is not commercially viable, the new policy needs to ensure that public transport links between the main London airports are far more robust for the full range of passengers and not reliant on coaches (which add to the M25 congestion) and London Underground trains (which have had funding plans for wider accessibility withdrawn). Capacity planning should concentrate more on passengers end to end journeys and alternatives to car travel in spreading capacity loadings. Contingency planning should be written into all plans to include disruptions of all types including weather, trafﬁc and the changing spread of the passenger population between business, leisure, families and PRM’s. More research should be done with passengers about their transport interchange needs with a “business case” attitude on ﬂight delays etc perhaps involving mystery shopping as well as questionnaires which usually only show a snapshot of experience.

Working Together GATCOM welcomes the Government’s endorsement of the valuable role played by the airport consultative committees (ACCs) in the draft Policy Framework and agrees that there is a need to update the existing guidance for ACCs in view of the fact that the role of ACCs is now far wider than in 2002 when the guidelines were last updated. GATCOM has and will continue to work with the DfT and the CAA in reviewing best practice in the way we work and will fully participate in the review of the DfT’s guidelines for ACCs. GATCOM would however urge the Government to ensure that the guidelines continue to be non-prescriptive and flexible as what works well for one ACC might not be appropriate for another. It is therefore important that there should be sufficient flexibility in the reviewed guidance to reflect the variations between airports and smaller aerodromes. 19 October 2012

Written evidence from A Fair Tax on Flying Campaign (AS 50) What is the impact of Air Passenger Duty on the aviation industry? Although an independent or HM Treasury-funded study into the impact of Air Passenger Duty (APD) on either the aviation industry or the wider economy has yet to be undertaken, many airlines and airports, who have submitted evidence to a recent inquiry by the APPG on Aviation, have cited areas in which APD tax has impacted negatively on their commercial operations and thereby placed the UK at an international competitive disadvantage. Most of the piecemeal evidence we are aware of centres on three aspects of lost business: — International Airlines cancelling their routes to UK destinations: Two such examples have been given by Manchester Airports Group and Continental Airlines. The former highlighted the claim made by Air Asia X that the over-riding reason for abandoning their flights to UK airports was the increasing levels of APD. The latter publicly announced that they would have abandoned their flights from Belfast to the US if the level of APD hadn’t been reduced in October 2011. — Passengers avoiding long-haul services from/to UK airports: With the UK’s European neighbours either imposing considerably reduced levels of air passenger tax, or no tax at all, separate analyses have shown that passengers have started to switch from UK long-haul flights to two, or possibly three, connecting flights through other European Airports, in order to avoid the tax. Information from research carried out by our Adviser and the CAA has shown that more than two million UK-originating passengers transferred onto connecting flights in Amsterdam in 2011. It appears that non-UK originating travellers are also starting to avoid UK airports, as evidence from an Airlines of America report shows that the total US-UK passenger market declined by 9.7% between 2006 and 2009, while the US-EU market rose by 3.4% across the same period. Both of these sets of data can be corroborated by anecdotal evidence from other European nations who impose or have imposed some form of air passenger tax. Despite being considerably lower than that of the UK, a recent German Government-funded study already shows that German residents are flying via Amsterdam to avoid the long-haul German version of APD. — Impact on Point-to-Point UK Airports: regional airports with competitive point-to-point links are vital for a healthy aviation industry. These regional airports themselves thrive on staying internationally connected. Although airport capacity is an important part of this argument, it needs to be recognised that as it is effectively a tax on international connectivity, APD is harming Point-to-Point travel. Using just one example, in the 2011 York Aviation report for BAA Scotland, it was calculated that “over the next three years……..Scottish airports will lose around 1.2 million passengers or around 1.8% of total demand”. APD will be a contributing factor to this. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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All of these are individual examples of the damage that APD is doing to an aviation sector which supports 921,000 UK jobs and contributes £49 billion to GDP. Our concern, nevertheless, extends beyond the 100,000s of jobs and billions of pounds that aviation supports and contributes, to the wider effect that aviation has on the UK economy. As an island, flying is crucial for all UK business sectors, as a means of attracting and carrying out business in a global market. Any barrier to international connectivity affects business growth opportunities. Below, we set out some of the ways in which we believe APD is damaging the wider UK economy: — Acts as a deterrent to inbound tourism: Tourism is currently the UK’s sixth largest export earner, bringing in £20.6 billion in overseas revenue. As the Government looks to build on the Olympic legacy and, in particular, concentrate on attracting visitors from emerging market economies such as the BRIC nations, we believe APD is and will continue to act as a hindrance in these objectives. In a recent survey carried out by the World Economic Forum, the UK was ranked 134th out of 138th for travel and tourism competitiveness, in terms of “ticket taxes and airport charges”. This can only harm our chances of attracting visitors from the BRIC countries, amongst others, pushing them towards our European rivals. If we look at a family of four flying from China, APD adds another £324 to the total fare. It could be argued that this a fundamental reason for the UK’s share of the Chinese market shrinking by half over the last 10 years. — Discouraging inward investment and general export-led growth: International connectivity is crucial for any UK company looking to expand its consumer market. We estimate that in 2010 alone, the Treasury took at least £600 million from businesses in flight taxes, half of this from foreign business travellers. These are costs that many companies simply are not willing to take on. Last year the Glasgow City Marketing Bureau said that the city has lost £22 million alone in conference business because of the high levels of Air Passenger Duty (APD), claiming that organisers were opting for cities where flights were cheaper. If we look at the bigger picture, a study by Oxford Economics has shown that a 10% improvement in international connectivity relative to GDP would see a £2.3 billion per annum increase in long-run GDP for the UK economy. At current levels of APD, foreign multinationals are more likely to look to our neighbours as a location for their European bases, and along with UK export-led growth being disincentivised, economic growth will be stymied.

With the negative impact current levels of APD are having on the aviation industry, inbound tourism and inward investment, evidence seems to suggest that the highest aviation tax in the world is damaging to the wider UK economy. The World Travel and Tourism Council estimates that the UK’s APD will cost the economy 91,000 jobs and £4.2 billion in additional revenue in 2012 alone, a much greater cost than the £2.9 billion predicted for 2012 APD receipts.

However, notwithstanding the piecemeal evidence outlined above, in order to fully access the impact APD is having, and will continue to have, on the UK economy, we would like HM Treasury to commission a full and comprehensive review into the wider impact of the tax. No such review has taken place since its introduction in 1994, and having brought in over £20 billion across this 18-year period, we believe some hard-proof evidence of its effects is needed. 19 October 2012

Written evidence from Liverpool City Region Local Enterprise Partnership (AS 52)

Liverpool City Region Local Enterprise Partnership (LEP) welcomes the opportunity to respond to the Transport Select Committee Inquiry into Aviation Policy Strategy.

We advocate an aviation strategy which addresses the barriers to regional competitiveness and supports the realisation of the recommendation for increased international connectivity in the 2011 report46 by the RT Hon the Lord Heseltine CH and Sir Terry Leahy.

We have set out our response to the issues the Transport Committee aim to address below.

1. The importance of international aviation connectivity to the UK

1.1. We recognise the importance of international aviation connectivity to the UK. Speciﬁcally as a regional airport, Liverpool John Lennon Airport is of vital importance to the connectivity of Liverpool City Region and to the international perception of Liverpool City Region as an attractive area in which to invest.

1.2. The Government’s Draft Aviation Policy Framework recognises the “important role in UK connectivity” offered by regional airports in England; yet the consultation paper centres the debate on Heathrow and the south east. Connectivity to the UK’s City Regions is integral to rebalancing the economy which is a consistent theme from the Government. 46 Rebalancing Britain: Policy or Slogan? cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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1.3. Liverpool City Region has the Government’s backing to host an International Festival of Business in 2014 which is an ambitious 61 day programme of national consequence yet we have no hub link from which visitors would easily be able to access such a high profile event. This issue could limit the impact of the effort and investment which will be undertaken to deliver a successful programme of events. 1.4. There is growing demand for regional connectivity. Liverpool is the fifth most visited city in the UK by international visitors. Globalisation is resulting in international visitors who expect to connect to cities such as Liverpool upon arrival at a hub airport. Over the last five years its growth in overseas visits has outstripped every UK city but for Glasgow. 1.5. HS2 should not be regarded as an alternative to regional aviation connectivity but rather as a complement to a modern transport network which offers the consumer choice and encourages market competition.

2. The impact of Air Passenger Duty (APD) 2.1. The August 2012 Inquiry into Aviation Policy and Air Passenger Duty from the House of Commons All Party Parliamentary Group for Aviation calls for the Government to implement a study “to quantify the full impact of APD on UK competitiveness” which is a view with which we concur. 2.2. APD requires a joint strategy across industry, the Treasury and Department for Transport to ensure it is not adversely affecting economic growth and employment. The current arrangement has a greater impact on regional airports which is inconsistent with the Government’s policy to rebalance the economy. Regional airports require the opportunity to compete on a national level.

3. Making the best use of Existing Aviation Capacity 3.1. Regional airports can help alleviate capacity constraints in the south east especially as airports within the south east will be more or less full by 2030. 3.2. We suggest London hub slots are ring fenced to promote regional connectivity which will beneﬁt the UK as a whole in terms of distributing foreign investment, regional economic development and easing capacity issues. The current economic model is not viable for enabling regional airports to use Heathrow slots. 3.3. We support the availability of route development funds and suggest that this mechanism is considered to support regional airports in realising their ambition to successfully maximise the potential for new routes.

4. Sustainable Aviation Strategy 4.1. We support the development of a sustainable aviation strategy but this must be weighed against the imperative for regional growth. In fact there is an argument for the efﬁcient use of regional airports which minimises journey times to and from airports and minimises the carbon impact of surface access. In summary Liverpool City Region LEP ask that consideration is given to the parity of UK aviation policy to ensure both short term and long term economic growth both nationally and regionally. 19 October 2012

Written evidence from Stop HS2 (AS 54) 1. Stop HS2 is the national campaign group against the proposed £33 billion High Speed 2 railway. As such general aviation strategy is outside our remit: however there are obvious cross over points between aviation strategy and high speed rail policies. 2. Stop HS2 believes the assumptions behind the HS2 proposal are ﬂawed and it should be cancelled entirely. 3. Our answers below are most relevant to the following inquiry questions: 1 e. Where does aviation ﬁt in the overall transport strategy? 2 c. How can surface access to airports be improved? 3 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?

HS2 is not part of an overall transport strategy 4. One of Stop HS2’s concerns is that HS2 has not been developed as part of a wider transport strategy. The proposed spur to Heathrow was not included in the original plans but has been retroﬁtted, which means the service pattern direct to Heathrow will be very low, due to capacity constraints. The spur will not open until Phase 2 of HS2, due to be completed in the mid 2030s. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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5. It is high risk to plan a £33 billion high speed rail line separately to aviation policy, especially as that aviation policy may include plans for a new airport.

6. High speed rail policy should not be considered separately to aviation policy. As one witness told the Transport Select Committee last year, during the High Speed Rail inquiry Q378 Steven Costello: The argument is that each node should be one of these pearls on a necklace. Therefore, as in Germany and France, an airport is an interchange directly located on the through line, but with high speed through lines so that not every train needs to stop. As soon as you start getting into branch lines or spurs, you start to lose that seamlessness and the ability to generate modal shift.47

HS2 is not an alternative to Heathrow third runway

7. The pressure on the previous Secretary of State for Transport to reopen the discussion of a third runway at Heathrow restarted earlier this year, shortly after she had given the go-ahead for HS2 in January 2012. This shows that many people do not consider HS2 to be an alternative to Heathrow expansion.

Timing of HS2 planning and the Davis Commission review

8. The Davis Commission on future aviation capacity is not due to report until summer 2015. Meanwhile the Government want to deposit the HS2 hybrid bill in October 2013, with the intention of getting it through Parliament by spring 2015.

9. If the Davis Commission recommends building a new airport, then the HS2 hybrid bill will have legislated for a route without links to this new airport. In these circumstances, it is highly likely that the Government of the day will scrap the HS2 legislation. It would have been a huge waste of Parliamentary time.

Modal Shift

10. In the three economic cases for HS2 (2010, 2011 and 2012), the expected modal shift from air to high speed rail has fallen signiﬁcantly.

11. The table below shows that HS2 Ltd now expect a signiﬁcantly smaller modal shift from air: the 2010 case which had 8% modal shift from air in 2033, compared to the most recent 2012 case which has 3% modal shift from air in 2037. Classic Rail New Trips Air Car 2033—(2010 economic case) 57% 27% 8% 8% 2043—(2011 economic case) 65% 22% 6% 7% 2037—(2012 economic case) 65% 24% 3% 8%

HS2 Ltd data: modal shift when rail usage has doubled.

12. There is in any case, limited potential of HS2 to reduce internal flights. There are currently no scheduled flights between London and Birmingham. Rail’s share of the London Manchester market is increasing by about 5% a year. In 2009, 74% of passengers on domestic flights between Heathrow and Manchester were transferring onto a connecting flight.48

Carbon emissions: HS2 is carbon neutral:

13. The limited modal shift explains in part why HS2 Ltd and the Department for Transport say HS2 is expected to be carbon neutral.49

Videoconferencing

14. With the growth of digital telecommunications and videoconferencing, people will be increasing using web-based alternatives to face-to-face meetings. This will affect the demand for air travel as well as rail travel. 47 1185-ii Volume II—Oral and written evidence http://www.publications.parliament.uk/pa/cm201012/cmselect/cmtran/1185/ 118502.htm#evidence 48 Air and High Speed Rail Briefing Paper—The Realities of Rail. March 2010 http://www.bata.uk.com/Web/Documents/data/policybriefingnotes/ BATA%20Air%20and%20High%20Speed%20Rail%20Briefing%20Paper%20March%202010.pdf 49 High speed trains use significantly more energy then conventional fast trains: a recently published report by high speed rail proponents Greenguage 21 showed that the HS2 trains would have to be significantly slower then currently proposed if they were to reduce CO2. This would however cause the business case to worsen. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Aviation Representation on HS2 Challenge Panels 15. When HS2 was originally being developed there were no aviation representatives on the scrutiny panels.50 This may explain why one witness to last year’s TSC inquiry on High speed Rail described the HS2 route as “in aviation terms, a thin route”. 51 19 October 2012

Written evidence from Mr Paul Pitcher (AS 56) 1.0. This response expounds on the following recommendations to the Transport Select Committee from the Energy, Environment & Sustainability Group (EESG) of The Institution of Mechanical Engineers (IMechE): A. A full-picture approach should be adopted, seeing Air Transport as a subset of a greater challenge of Sustainable Development. No transport system operates as an isolated unit, but is integrated to almost all other travel modes. See paragraph A. B. The strategy should be developed with the Air Transport Hierarchy as its framework, in keeping with the principles of Sustainable Development. See paragraph B. C. Funding for Research and Development, Thus a platform is provided on which to drive for greater efficiency through advances in technology and understanding of product lifecycle impact. See paragraph C. D. Expansion of UK airport capacity, building the UK aviation industry by providing economic stability. See paragraph D. E. A noise reduction policy which supports new technology development, recognising that an "every aircraft is the same" approach cannot achieve a satisfactory or scientifically sound result. See paragraph E. F. Continual engagement in the Emissions Trading System (ETS), pushing for a global system solution. It must also be implemented at all levels of the aircraft technology supply chain, encouraging greater efficiency and applying fair and equal economic pressure below the first tier of supply. See paragraph F. G. Alteration of Air Passenger Duty to encourage destination-centric passenger routing, moving away from a system which is overly simplistic. Development of the Air Freight Duty framework to reduce so-called food miles and minimise wasteful and unnecessary behaviours. See paragraph G. H. Clear and stable commitment to the roll-out of biofuels in aviation, developing an alternative fuel source in the long term for an industry that is dependent on a portable liquid fuel as an energy source.

50 Since then the Director of the Campaign for High Speed Rail has become a director of BAA.) 51 q 377 Steven Costello: .... Certainly, from aviation’s point of view, it is the worst of all possible worlds at the moment, simply because a line from Birmingham, bypassing Heathrow, through central London to HS1 and Europe would be, in aviation terms, a thin route. There would not be enough trafﬁc from point to point to sustain services at a frequency that is going to generate modal shift. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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A A.1. First we set the scene: the industry is suffering from massive fuel costs, leading to signiﬁcant end-of- year losses and the folding of multiple airlines. Aircraft are currently wholly reliant on fossil fuel as an energy source, with a very slow emergence of biofuel aka "biojet" as an alternative. Other energy-hungry methods of transport (such as road vehicles) are on the increase globally, especially in the BRICS countries, and world population is set to increase to 12Bn by 2050. The cold fact is that we will soon see an "energy crunch" like that already experienced South Africa.52 All strategies must be seen in the context of the wider subject of sustainability, and tackled using established methodical tools. The Energy, Environment and Sustainability Group (EESG) of the Institution of Mechanical Engineers (IMechE) has developed such a tool—The Air Transport Hierarchy: SUSTAINABLE Priority 1: Minimise Demand. Changing wasteful behaviour to reduce demand Priority 2: Energy Efficiency Using technology to reduce demand and eliminate waste Priority 3: Exploitation of renewable, sustainable resources

Priority 4: Mitigation of Impact of aviation transport UNSUSTAINABLE

1- Adapted from "The Transport Hierarchy", Source: IMechE53,54

B B.1. This tool essentially provides a framework upon which any transport strategy can be built and assessed: 1. Minimise Demand: If the demand for air transport is not there in the first place, then the problem is solved. Solutions such as web conferencing are a good example of this concept. Included in this is the enabling of a modal shift to other transport types with less damaging environmental effects. 2. Energy Efficiency: If air travel cannot be avoided, then we must maximise the efficiency of the vehicle and the system in which the vehicle operates. Technology updates to existing aircraft are one way to work at this level. Note that both the vehicle (aircraft) and the air transport system (the air traffic control etc.) must be considered. 3. Renewable Energy: Having taken all reasonable steps to minimise energy demand and improve efficiency, this next priority is to supply that demand from clean energy sources that are effectively infinite. As examples we have the use of biofuels in flight or hydrogen cell technology for aircraft- on-ground energy supply. 4. Mitigation of Impact: Once all other possibilities have been explored, the last step is to try to minimise the consequences of flight. Despite this being the lowest priority, it is often as far as government strategies extend, by for example, imposing "no-fly" restrictions during the early morning to prevent disruption to flight path households. A more effective action at this level would be to divert traffic away from super-hubs to avoid runway taxi times of up to 45mins (Schiphol).

52 “S.Africa battles to keep blackouts at bay”, Reuters (2012), accessed 13 October 2012 online at http://af.reuters.com/article/ energyOilNews/idAFL5E8G8EJZ20120514 53 “Transport Transitions” IMechE, Energy, Environment & Sustainability Group accessed 13 October 2012 online at http://www.imeche.org/knowledge/industries/energy-environment-and-sustainability/news/Transport-Transitions Reproduced with permission 54 “The Energy Hierarchy”, The IMechE (2009), available from www.imeche.org/policy cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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C C.1. On the 11 September this year, Vince Cable MP spoke of the governments' vision for UK industry55: "Support for sectors; clear choices and backing for core emerging technologies; continued efforts to boost skills... …It will be backed by…a cast-iron commitment… to identifying and dismantling the barriers to growth…Aerospace demands very long time horizons and there are literally trillions of pounds worth of orders for civil aircraft alone over the next 20 years or so. Britain will not get a decent share of these orders…without sustained investments in R&D." We must continue to invest in Research and Development, keeping the UK at the forefront of aviation technology worldwide. This brings future security in terms of equipment supplied, but also in intellectual property and know-how as BRICS countries seek consultancy from UK specialists. This strategy is effectual at the "Priority 2" level of the Air Transport Hierarchy, as R & D work helps us to drive for more efficient platforms and products. C.2. Product Lifecycle Assessment (PLA) should be prioritised as a field of research. As an engineer in the industry, I can testify that there is no good, reliable information on how to determine the resource footprint of my designs. Lord Kelvin said iconically that "you know nothing of a subject until you can measure it". PLA is a tool that allows me to determine how much my product will "cost" from start to finish. Cost meaning how much energy, CO2 and other general resource goes into harvesting and melting the steel I use in my design, then machining of the steel into components, then assembly, test and finally decommissioning. Considering the new Boeing 787 which contains roughly 32 tonnes of carbon fibre—what can be done with all this carbon fibre in 40 year's time with no satisfactory recycle or de-commissioning strategy? As a designer I need this information, but it is simply un-available.

D D.1. R & D cannot be adequately supported by the Public sector, and must be driven by commercially- targeted short and long term business investment. To secure such investment, UK aerospace companies must have a positive economic outlook and a full order sheet. This brings us on to UK airport capacity as a way to invest in the future of UK Plc. D.2. Once we have satisfied ourselves that we are doing everything we can to minimise unsustainable passenger behaviours and reduce demand for air transport, we can think about capacity issues. With this caviat that we have tried to reduce air traffic volume, this response recommends that implementation of additional capacity for flights to and from the UK must be made a priority in the short-to-medium term. As a nation, we lag behind other EU states such as Germany and France in enabling continued growth of air capacity. We need to seek out the correct, well-thought-through strategies for this objective. The South East is already heavily loaded and Heathrow is bulging at the seams. Currently, every year, a significant volume of fuel is wasted in aircraft holding patterns as the airports struggle to sequence incoming traffic volumes. D.3. Opportunity for air capacity increase should be sought outside of the South East, away from built-up areas and preferably in an area which would benefit from infrastructure improvements and additional employment prospects. The interfaces with any new capacity project must be considered at the concept level to implement aims and objectives of the industry. The European Commissions' objectives are worthy of note56: "90% of travelers within Europe are able to complete their journey, door-to-door within 4 hours" The aviation freight industry is currently stable and supports key industries throughout the UK, enabling economic growth and connectivity. New and existing facilities should aim for seamless connectivity and take advantage of contemporary information technology developments such as route planning phone apps.

E E.1. As regards government action to reduce noise to local residents close to busy flight paths, this subject must be approached from a balaced viewpoint. I am an enthusiast of outdoor mountain sport, so perhaps more than some, I value very highly the peace of the mountains and countryside, escaping the noise of urban life. This said, whilst I believe aerodrome noise reduction is a worthy objective, I feel it should be evenly and fairly applied across all transport sectors. There is much media noise about aviation noise, when automobiles and motorways generating more noise disruption, much more widespread. Overall, the subject of noise reduction should be discussed in close consultancy with the aircraft manufacturers, operators and air traffic management bodies. 55 “Industrial Strategy—Cable outlines vision for future of British Industry”, Vince Cable, Secretary of State, 11 Sep 2012, Imperial College, London. Accessed 12 Oct 2012 online at http://www.bis.gov.uk/news/speeches/vince-cable-industrial-strategy- september-2012 56 “Flightpath 2050—Europe’s Vision for Aviation” European Commission (2011) Report of the High Level Group on Aviation Research. Accessed 12 October 2012 online at http://ec.europa.eu/transport/modes/air/doc/flightpath2050.pdf cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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E.2. Additionally, there are new technologies on the horizon. The Open Rotor technology developed by Rolls Royce can yield up to a 30% increase in efficiency against an industry standard reference aircraft of the 1990s, but will be significantly more noisy than contemporary designs. Thus a choice must be made between emissions, economy and noise. It must also be remembered that aircraft noise changes throughout the flight cycle and is dependent on the engine type. There are two main types of engine on commercial transport aircraft: turboprop (propeller-type) and turbofan (most common "nacelle" type). In the immediate vicinity of an airport, residents will hear most noise from the touchdown phase of a turbofan engine when the thrust reverser is deployed (turboprops do not use thrust reversers). Turboprop engines (Open Rotor technology can be considered in this group) generate most noise during take-off. Thus if noise restrictions are to be made, they must be technology specific and not just dumb blanket requirements. Personally, I grew up in the Glasgow Airport flight path, and this is partly why I find myself following a career in aviation.

F F.1. Airlines would welcome the ETS as an economic mechanism to supply investment into greener technologies. Airlines are desperate for more efﬁcient aircraft—you just have to look at the unprecedented initial sales roster for the Airbus A320 NEO (New Engine Option), which offers around a 20% fuel burn improvement. However, it is worth noting that ETS does not consider harmful Nitrous Oxide (NOx) gases, which are a major driver in Aerospace Propulsion design. One can either design for ideal NOx or ideal CO2. F.2. In the implementation of ETS, implementation is necessary at the level of the Original Equipment Suppliers (OEMs), who design and manufacture the technology for modern aircraft. As the supply chain becomes further distant from the Airline, the motivation to spend extra money on low-Carbon, super-efﬁcient technology just isn't there. The supply chain has responded well to the recent REACh restrictions, preventing the use of harmful substances such as Cadmium on new designs. Can a similar set of requirements be set on high-CO2 materials or technologies?

G G.1. As regards Air Passenger Duty, the system is flawed and does not achieve its desired result. For example, if my destination is Dubai from London, compared to a single flight, I will pay less duty if I fly via Charles de Gaulle. This is despite the fact that the emissions and overall fuel used will be significantly higher. It is an established truth that aircraft take-off and climb to altitude is the most fuel-hungry stage of a flight. Air Passenger Duty shoul be revised to drive the desired sustainable passenger behaviours. G.2. It was very interesting to observe the impact of 2010's Eyjafjallajökull volcanic eruption. From The Guardian57 the 2nd day after the eruption: "Waitrose has said that the supply of "a handful" of products had been hit, including fresh pineapple chunks from Ghana and baby sweetcorn from Thailand. At Tesco, Thai orchids are likely to be the first item to vanish from stores if the disruption continues" G.3. My heartfelt reaction to the disruption, although an aviation enthusiast, was one of welcome. I really feel that we can live without Thai orchids and pineapple chunks! I believe an encouragement should be felt to buy locally and only import goods that are absolutely necessary. This will involve changes in UK residents' lifestyle and habits, but is not insufferable. I think of the reaction of Britain to the WW2 "Dig for Victory" messages. The "World War" of today is that our planet is running out of resources and we are ever the more hungry to consume more and more. I call upon the government to establish what imported goods are not "necessary" and are luxury items, and thereon impose an additional duty.

H H.1. The aviation industry is dependent on some kind of liquid fuel and cannot exploit the avenues available to the motor industry such as with electric cars. It is therefore critical to air transport to develop alternative, sustainable and safe fuels to fossil kerosene. This must be implemented in part by levelling the playing field with biodiesel, which currently enjoys EU benefits through its RTFC eligibility. Biojet should be treated in the same manner as biodiesel to unlock critical investment. H.3. The government must set forth a strategy for biofuel usage across the transport community. It is critical to define how biofuels will be allocated in the short, medium and long term. Will the feedstock be diverted away from aviation to energy-intensive industrial processes? More broadly, a stable policy on biofuels allowing investment and decision-making to be de-risked as demand is secured with more certainty. H.3. Finally, government incentives must be implemented to drive initial development of struggling demonstrator refineries. Bank investment is faltering owing to lack of secure business cases, lack of supply chain integration and lack of assured access to feedstock. In essence, the product and the market are too immature to attract suitable investors to drive to required industry-quantity production levels through injection of capital. This leaves an "everyone is waiting for everyone" scenario which is losing potential investment opportunities. Both incremental and prize-based incentives could be explored. Incremental in terms of short 57 “Flight ban could leave UK short of fruit and veg” The Guardian, Friday 16th April 2010. Accessed 12 October 2012 online at http://www.guardian.co.uk/business/2010/apr/16/flight-ban-shortages-uk-supermarkets cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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term milestone payments, or prize-based in terms of "ﬁrst company to produce X tonnes of Y will receive £10 million", in a way similar to the Virgin Galactic prize from space travel/tourism. 19 October 2012

Written evidence from the British Airline Pilots' Association (AS 58) Executive Summary 1. The British Airline Pilots' Association (BALPA) believes a strong, vibrant and successful aviation industry is vital to the UK economy, but that it must be underpinned by strong safety standards and robust regulation. 2. British pilots are proud of their industry and their profession. They want to see it compete globally without having one hand tied behind its back. 3. We are primarily concerned that much of the debate around aviation policy and strategy revolves around infrastructure alone without considering the issue in the round. In particular we would like aviation safety to be placed at the forefront of the Government's aviation framework and of aviation policy now and into the future. 4. Our comments in response to the Committee's questions will centre around the importance of ﬂight safety as well as the importance of aviation in terms of jobs and economic growth.

About BALPA 5. Over 80% of the UK's commercial pilots are members of BALPA and we are recognised as the main partner in 26 airlines covering all major UK operations. In addition over 1,000 commercial pilots have joined us even though their airline has no partnership agreement with BALPA. 6. BALPA was formed in 1937 when an airline was forcing professional pilots to operate when it was not, in the professional judgement of those pilots, safe to do so. This led to the Cadman report. Those origins remain a key feature of our DNA today and which is why, 75 years later, our vision as an association is still "to make every ﬂight a safe ﬂight". It is also perhaps why a recent public poll by YouGov found that airline pilots belonged to one of the most trusted professions. It is a responsibility we take seriously.

What are the beneﬁts of aviation to the UK economy? 7. The importance of aviation to the UK economy is not in question. According to Oxford Economics the sector supports 921,000 jobs and contributes 3.6% to GDP or a total of £49.6bn. 58 8. Beyond these raw economic data, aviation is a social good which enables people to contact with friends and family across the UK and globally. It is also a driver of our economic connectivity to new emerging markets across the world. 9. The beneﬁts of aviation are not seen just by business. The Trades Union Congress this year passed a motion proposed by BALPA to support the "great Great British aviation industry".

What is the impact of Air Passenger Duty on the aviation industry? 10. Sadly, the Government's policy on Air Passenger Duty is harming the UK economy as well as British aviation businesses. 11. APD is a regressive and counterproductive tax, especially at the levels at which it is now set. The UK aviation industry is taxed at a much higher level than anywhere else in Europe. French aviation taxation is around a tenth of that of the UK; in Ireland it is just €3 per ticket; and in the Netherlands the government completely abolished the tax after trialling it. This disparity clearly shows that the UK is at a competitive disadvantage to the rest of Europe. 12. There are impacts on UK airlines and UK jobs as a result. It is increasingly easy, for instance, to buy a cheap, low-cost ticket from the UK to Amsterdam in order to connect to a flight to Australia. In a poll for BALPA, 76% of people said that they would prefer to transfer via Amsterdam if it meant saving £85.59 The saving, however, could be as much as £171 for passengers flying to Singapore or Australia in premium economy or higher, which would be an increased incentive to make this transfer despite the additional effort involved. This means that UK airlines that fly those routes, and British workers who are employed by those carriers, are put at a disadvantage. 13. As well as a counterproductive tax, APD is an unfair one. It is increasingly the case that moderately paid families are finding it harder to afford a traditional family holiday. Note, for instance, that there is no reduction in APD payable for children's air tickets and that the short-haul economy rate of APD has increased by 260% since 2007. 58 Oxford Economics 2011, "Economic Benefits from Air Transport in the UK" 59 Ipsos-Mori Online Omnibus poll, conducted 15–19 May 2009 cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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14. This is a matter of concern to British airline pilots. We do not wish to see UK aviation at a disadvantage not only because of the impact on our own jobs, but because of the overall contribution a strong aviation sector makes to the UK economy.

Do we need a step change in UK aviation capacity? Should there be a new hub airport? Where? 15. BALPA has polled its members about views on where additional airport capacity should be. Our members are split on that issue, but there is overwhelming agreement that we need additional capacity somewhere. 16. The UK's international hub at Heathrow is over 99% full. The result is that UK businesses are losing out to their competition elsewhere in the world, especially in Europe. Amsterdam, Paris Charles de Gaulle and Frankfurt are major European hubs which have had the ability to expand in terms of the number of destinations served. Amsterdam Schiphol has five runways and serves 264 destinations. Paris Charles de Gaulle has four runways and serves 259 destinations. In contrast London Heathrow has just two runways and has seen the number of destinations served reduced to 183. 17. Aviation should be an industry that supports the growth of the UK economy. As the Chancellor said in his budget statement in March 2012, we need strong links to the emerging economies of Brazil, Russia, India and China. In this respect we are already lagging behind many of our European competitors. 18. As well as a strong, competitive, international hub we recognise the importance of high quality regional and point-to-point airports. The vast majority of airlines our members fly for do not operate into Heathrow at all. We must not forget the contribution, both on a regional and national level, that regional connectivity provides. 19. Decisions about future airport capacity have been delayed for far too long. The industry needs a definite future, not years —creeping into decades —of uncertainty. An agreed political settlement would enable long- term planning and give the industry the confidence to invest in the future. 20. BALPA supports the Government's decision to appoint an independent commission to make recommendations on future airport capacity to be chaired by Sir Howard Davies.60 But we do note that such commissions, committees and studies have come and gone many times. We've been here before. 21. We hope the Commission is sensibly constituted with a voice for those who rely on a strong aviation sector for their livelihoods. 22. BALPA was disappointed by the Government's decision to ask the Commission to report only after the planned 2015 UK General Election. We believe the Commission could and should report before then so as to bring forward the urgently needed final decision about this industry's future. 23. One potential side-effect of a step-change in aviation capacity could be the increased ability of some of the UK's competitors to take advantage of that capacity ahead of UK businesses. We would like assurances that there would be defence against other countries' airlines having a distinct advantage over UK business by using their government subsidies or countries' petrodollars to undercut British business.

Flight Safety 24. BALPA noted with concern the fact that the Department for Transport's Aviation Framework Scoping consultation made only fleeting mention of the importance of flight safety. We made a recommendation in our consultation response that safety should be woven far more deeply into the framework. We were disappointed that the Government did not take up that suggestion in the subsequent framework document (currently out to consultation). 25. Aviation debates over the past few years (with the notable exception of the important debate around European flight time limitation proposals) have centred entirely around infrastructure and capacity. 26. The UK has a good flight safety record. But with predictions of considerable increases in the number of flights, and with safety having reached a plateau, unless safety continues to increase, we could see the number of incidents rise. This is apposite to discussion around increasing capacity. 27. We believe that an increase in capacity may lead to a disproportionate increase in the number of incidents. We are in a fast-changing industry and past performance is, as the financial small print goes, no indicator of future performance. British pilots fly in some of the most congested skies in the world; skies which are due to become more congested still. We must never allow our attitude towards flight safety to become complacent.

Inadequate Regulation 28. BALPA has identiﬁed inadequate regulation as a key threat to aviation safety. Like in so many other policy areas, deregulation is the order of the day. However, in safety critical industries, and ones in which there is so much commercial pressure, we do not believe this is the appropriate paradigm in which to be operating. 60 http://www.dft.gov.uk/news/statements/mcloughlin-20120907a/ cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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On the contrary, strong regulation enforced by an independent and scientifically-driven regulator, is key to ensuring safe operation. Given an organisation's first duty is to survive, if the choice is between staying in business for one more day or spending money on safety, without regulation, we are not confident the right decision would be made. 29. We are aware that this shift towards "operator responsibility" has already begun. The European Aviation Safety Agency (EASA) has advocated for this approach in its latest version of pilot fatigue proposals and the UK Civil Aviation Authority (CAA) endorsed this approach. We remain sceptical.

Security 30. Pilots find the security screening situation they have to face bizarre and extremely frustrating. Passengers often get frustrated at the long queues and invasive searches they have to endure, but pilots often have to go through the same processes every time they go to work. This is not conducive to flight safety, nor does it recognise the important link in the security chain which pilots form. 31. Pilots' frustrations are compounded when they have items such as water bottles, glasses cases and nail clippers confiscated by security when they are about to board an aircraft and take responsibility for the safety of hundreds of passengers. Not to put too fine a point on it, but if a pilot ever wished to cause an incident, water and nail clippers would not be required. We background check and then trust pilots to operate safely, yet we do not trust them to walk into a departures lounge to get some lunch in the middle of their duty day. 32. The cost implications of needlessly security checking pilots is worth noting too. The Guardian reported that security costs £4.6bn a year61. A significant saving could be made by following the example set by the Known Crewmember programme in the United States which allows much freer access to trusted professionals following a thorough background and identity check.62

People 33. Again, the "people" side of the aviation industry has been largely ignored by policymakers over recent years. Air transport needs properly qualified, professional flight crew. Currently we see a situation emerging whereby pilots are either in feast or famine. Life for a newly qualified pilot, on a temporary, agency contract is insecure, financially unrewarding and fatiguing. 34. BALPA has grave concerns over the growing use of contract pilots in certain UK airlines. These pilots are not employees of the airlines they fly for. Rather, they are newly qualified pilots, desperate for experience, deep in debt from paying for their own training, and vulnerable to being furloughed or transferred at the whim of either their contract employer or the airline. This situation occurred very recently as easyJet announced that 46 of their "Flexicrew" pilots would be laid off for the winter period. 35. Allied with this and such recent developments as the sad closure of Bmi Baby we are seeing a gradual drift of pilots abroad. A recent event sponsored by BALPA to inform members of the reality of working abroad was heavily over-subscribed. Our question is will the UK have the supply of trained pilots needed to operate in any expanded capacity industry. We would encourage the Committee to consider, if not in this inquiry then in another, issues around training and apprenticeships of pilots. 19 October 2012

Further written evidence from the British Airline Pilots’ Association (BALPA) (AS 58A) 1. The British Airline Pilots’ Association believes that the following supplementary evidence may be of interest and use to the Committee in its current Aviation Strategy inquiry. In particular, this supplementary evidence is in response to the oral evidence given to the Committee by Mr Richard Deakin of NATS on 10 December 2012. 2. The standard angle for glideslopes is universally set at 3 degrees with variations typically between 2.5 and 3.25 degrees to accommodate local circumstances such as airspace restrictions and close in ground obstructions. A 5.5 degree glideslope, as proposed by the NATS Chief Executive, Mr Richard Deakin, is exclusively used at airports where a normally inclined approach path is precluded because of terrain as in mountainous areas or obstacles such as the high rise buildings that surround London City airport. Because of the stringent requirements on aircraft performance and certiﬁcation, and crew training in special procedures, 5.5 degree glideslopes are not generally considered appropriate as a means for alleviating local area noise disturbance. Where these steeper slope approaches have been adopted they have only been available for smaller aircraft types ranging up to Airbus A318 size and have never been used by bigger commercial air transport (CAT) types let alone the wide bodied long-haul aircraft types that predominantly operate in and out of London Heathrow. 61 http://www.guardian.co.uk/world/2011/sep/07/airports-wasting-billions-needless-security 62 http://www.knowncrewmember.org cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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3. For large aircraft the problems of approaching on a steep glidepath can be considered under the headings of operation and organisation:

Operational Issues 4. Speed stability. The inertia of heavy aircraft means that it is very difficult to accurately control approach speeds on a steep approach particularly when the airspeed has increased due to correcting to the glidepath from above. Use of airbrakes with landing flap is prohibited on most large types. Furthermore, the increased use of drag inducing configurations, possibly against thrust to allow higher engine power settings, would introduce issues of aircraft structural fatigue. 5. Engines at idle power. To achieve a steep glidepath heavy aircraft would need to have their engines set at or near approach idle power with the consequence that, in the event of having to go around (GA), with big, high bypass engines taking longer to spool up, the height lost between GA initiation and the aircraft beginning to climb away would be correspondingly greater. This is exacerbated by the fact that the aircraft is already descending faster therefore greater anticipation of having to GA would be needed. For the same reasons approach minimums would have to be set higher to ensure aircraft aborting their approach did not bust obstacle clearance limits with the knock on effect that, in poor weather, many more aircraft would require to GA. 6. “Sink Rate” EGPWS alerts. At a typical heavy aircraft approach speed of 160 IAS the rate of descent on a 5.5 degree glidepath would be around 1600 fpm which normally would be classified as an unstable approach and would be above the threshold for triggering an EGPWS “Sink Rate” aural alert. 7. All Weather Operations. A 5.5 degree glideslope is presently not compatible with an autoland profile and would require a significant certification effort to make it so if, indeed, it was possible to retrofit to current aircraft types. Such an operational restriction would be a major impediment to the all-weather capability of an airport. 8. Engine Out Approaches. All engine out approaches are predicated on a 3 degree or close to 3 degree glidepath. It would be impractical and add complication to introduce different contingency procedures for engine out approaches to accommodate the very few airports where steep approaches were in operation. Such airports could not be planned as alternates. 9. Flare/Roundout Manoeuvre. The transition from a 5.5 degree glidepath through to touchdown on the runway would be an abnormally challenging manoeuvre to fly which would require special training and would involve higher risk when compared to a landing off a normal 3 degree approach. The potential for “heavy” landings would necessitate the imposition of lower maximum landing weights and increased engineering maintenance of landing gears. Other risk mitigating measures might involve the setting of lower crosswind limits further limiting the availability of the airport to operators. Some aircraft types, particularly larger widebody types, would be more susceptible to tail scrapes. The complexity of the roundout manoeuvre combined with the normally acceptable variation in piloting skills would very likely result in a greater variation in touchdown positions and speeds with a contingent increased risk of “floating”, long landings and runway overruns as well as a potentially significant impact on runway occupancy rates and therefore runway capacity. 10. Tailwinds. Whereas on normal approach paths tailwinds of up to 10 to 15kts can be accommodated to allow a certain amount of operational flexibility in the choice of runway direction, with steep approaches no such flexibility could be tolerated.

Organisational Issues 11. Crew Training. Special crew steep approach training would be required for any approach steeper than that currently used. 12. Aircraft Modification/Certification. Significant aircraft modification (landing gear, flap/spoiler operation- fly by wire flight control law reprogramming , EGPWS reprogramming) would be required together with an extensive scheme of type certification for steep approaches. 13. Airport Availability. For several reasons (as stated above) an airport serviced by 5.5 degree glideslopes would be much more weather dependant in terms of cloud base, visibility, and wind and therefore would suffer a greater degree of weather closure events than would be the case with a normally inclined approach path. 14. In summary the introduction of 5.5 degree glideslopes would present substantial difficulties for both aircraft and airport operators. The former would be burdened with, initially, aircraft modification and certification costs and then recurring crew training and aircraft maintenance costs. The latter would not be able to boast a year round, 24 hour, all weather operational capability necessary to support scheduled CAT services. The likely upshot would be that aircraft operators would migrate to airports where the approaches were not so weather dependant and not so demanding of resources. 16 January 2013 cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Written evidence from Debbie Bryce (AS 62) I would like to respond to your avaition consultation, deadline today. My answers to your questions are included within the text below. I do want to focus on the importance of evidence to prove whatever claims are made. The current Government consultation on its draft aviation policy makes various unsubstantiated claims, especially on the issue of 70% fuel efﬁciency improvements. There is simply no evidence given or even available to my knowledge to support this claim. It can therefore be supposed that other Government claims are similarly unreliable unless evidenced. Similarly, there is no evidence that I know of to show that there is a crisis in capacity, especially if existing capacity were fully used. Government forecasts show that passenger demand could be almost entirely met with existing capacity, properly maximised. There is no evidence of need for new runways. More detail on the forecasts is given at http://www.aef.org.uk/?p=1423 Perceived need for more capacity at Heathrow ignores the fact that there is unused capacity at other South East airports. As Gatwick is currently applying for expansion to 70 mppa, surely this would supply any unmet need as well as give the opportunity to develop additional services.

1. What should be the objectives of Government policy on aviation? The only sensible answer to this, to meet all constraints, is demand management and the provision of alternatives such as the French and Germans have achieved with rail. a. How important is international aviation connectivity to the UK aviation industry? What evidence will you rely on to determine this? b. What are the benefits of aviation to the UK economy? Take into account the disbenefits. The Government consultation on draft aviation policy framework only shows gross benefits, not nett ones. c. What is the impact of Air Passenger Duty on the aviation industry? To manage demand, in the same way as happens in other areas of transport. The major question is why APD was not applied in the first place? Surely the impact is the same as applying duties and taxes to other forms of transport. d. How should improving the passenger experience be reflected in the Government's aviation strategy? By having smaller airports providing more services, thus alleviating the need to travel long distances to airports and wait very long times in transit. e. Where does aviation fit in the overall transport strategy? How should we make the best use of existing aviation capacity? By linking London airports with rail, so that, in effect, "London Airport" could see you arriving at any airport which has capacity for that moment, followed by a rapid journey into central London or to other airports. 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? 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? I think not. There is too much emphasis on bringing people to the South East, whereas everyone likes a local airport. c. How can surface access to airports be improved? More rail.

What constraints are there on increasing UK aviation capacity? The European Air Quality Directive. I am concerned that this was ignored when considering Heathrow runway 3. Heathrow already breaches the Directive. It would be illegal to expand it. Why has no one noticed this? cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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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? In no one's experience is this true. If so, please provide evidence of satisfied local communities, and balance it against the complaints and problems experienced by many 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? Technological innovations need to be in place before expansion, as industry claims relying on them are unfounded. There is no evidence to show that technology demands can be quickly met, or that fleets would be quickly replaced.# c. What is the relationship between the Government's strategy and EU aviation policies? Usually, Govt strategy is environmentally inferior to EU policies. What can the Govt do to redress this?

Do we need a step-change in UK aviation capacity? Why? Yes, because aviation is the fastest growing transport sector and the fastest growing quality of life and climate change detractor. a. What should this step-change be? Should there be a new hub airport? Where? It's too expensive. It would be better to maximise existing capacity with better connections and rail. b. What are the costs and beneﬁts of these different ways to increase UK aviation capacity? Please provide fully peer-reviewed evidence to support any claims made here. This is absolutely essential because this is a key and critical issue, central to aviation. What are the NET beneﬁts, if any? 19 October 2012

Written evidence from Unite (AS 64) 1. Introduction 1.1 This response is submitted by Unite the Union, the UK's largest trade union with 1.5 million members across the private and public sectors. The union's members work in a range of industries including manufacturing, ﬁnancial services, print, media, construction, transport, local government, education, health and not for proﬁt sectors. The Civil Air Transport (CAT) membership of Unite comprises of over 62,000 members working across the aviation sector making it the largest single organisation in the aviation industry. 1.2 In this response Unite intends to stress the importance of aviation growth and the urgent need for a comprehensive transport policy encompassing all transport modes to cope with future demand.

2. Enquiry Questions 1. What should be the objectives of Government policy on aviation? a. How important is international aviation connectivity to the UK aviation industry? 2.1 A regional or point-to-point airport only serves the local community it resides in either providing low frequency direct flights or feeding connections to hubs. Point-to-point airports can only offer direct flights to destinations if they can be sustained by local demand. Consequently, the frequency of these flights will be low, limiting access to that destination. A point to point like Manchester is large enough for more frequent services which has attracted a limited demand for transferring passengers, making some additional flights possible on popular routes. A hub, on the other hand, survives by offering multiple daily flights to a variety of destinations, as the customer base is derived not just from the locality but also the global aviation industry63. 2.2 In terms of what benefits international aviation brings to the UK industry it is simply access to this wider customer base. The same would be true regardless of nation. One has also got to remember that the UK aviation industry is becoming increasingly multinational with bases in several countries. b. What are the benefits of aviation to the UK economy? 2.3 It has been estimated by Frontier Economics that direct aviation connectivity produces twenty times more business than a connection that requires a stop over at a hub64. Oxford Economics highlighted in their 63 At Heathrow around a third of the passengers catching flights, arrived at the airport by air. These numbers should not be confused with the very limited number transiting through Heathrow, who arrive and depart on the same aircraft. 64 http://www.frontier-economics.com/_library/publications/Connecting%20for%20growth.pdf cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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report which came out in March65 that, by volume, 65% of international air freight going through UK airports in 2010 went via Heathrow. This freight is primarily carried in the hold of passenger aircraft, making the cost of a ticket that much more affordable. Oxford Economics also estimated that the manufacture of goods for export by air contributed £28 billion to UK GDP. They suggest that rather than just supporting the 100,000 or so staff employed at Heathrow, the airport was responsible for supporting 1.3 million jobs in throughout the UK.

2.4 The aviation industry opens up markets to the global economies, especially those in the BRIC66 developing nations, for UK goods and services. This in turn creates the potential for investment into the UK. Having good onward transport connectivity also attracts multinational businesses, keen to base their regional head ofﬁces in the area around hubs. If this connectivity becomes unreliable or cannot provide the range of services needed, then these businesses will relocate to somewhere that can cope, taking their inward investment with them. c. What is the impact of Air Passenger Duty on the aviation industry?

2.5 The principal effect of Air Passenger Duty has been the evaluation of the viability of services to the UK. This combined with the additional cost of carbon credits needed to ﬂy to any European nation under the European Emissions Trading Scheme (ETS) has already resulted in the break up of the deal between Qantas and BA. Qantas has now entered an agreement with Emirates and moved operations from Heathrow to Dubai. Another example of this is the threat by Continental to stop calling at Belfast due to the £3.2 million in additional costs per annum between calling at Belfast compared to Dublin.

2.6 Passengers are catching ferries out of the country so that they can ﬂy from Amsterdam to India67, and who can blame them when it costs £286 for a car and eight passengers return via Harwich and the Hook of Holland when the APD alone would be a minimum of £664. For those in the west of the country it costs £578 for the same part to go from Holyhead to Dublin from where air passengers would only have to ﬁnd €3 ahead.

2.7 Unite believes that by increasing APD, the ability to fly out of the UK is becoming the preserve of the rich. It also moves the holiday in the sun out of reach for hard pressed workers who have been suffering from below inflation increases or wage freezes. Whilst Unite believes this will result in more holidays taken at home, it reduces the number of tourists entering the country. A study by Malaysia Airlines into price sensitivity of airline tickets highlighted that a difference of just $2.50 was enough for a customer to choose one flight over another. Such price sensitivity means that by adding APD, the UK is actively discouraging passengers to visit the UK and trade with us. d. How should improving the passenger experience be reflected in the Government's aviation strategy?

2.8 Unite agrees that a lick of paint can make an airport far more welcoming than allowing facilities to fall into a state of disrepair. Real improvements in passengers experience can only be effective, however, if the airport can provide a safe reliable ﬂight which departs and arrives on time. This cannot be guaranteed currently at Heathrow, due to the lack of spare capacity in the system. Unite believes 'Heathrow hassle' as it has become known, has lost the UK untold amounts of business. Consequently, if the policy is one of improving capacity and reliability, the passenger experience will follow. Unite also believes a hassle free journey to and from the airport is also critical to ensuring that the best passenger experiences. e. Where does aviation ﬁt in the overall transport strategy?

2.9 Aviation fits into an overall transport strategy by providing rapid long distance travel opportunities to places out of reach of surface transport options. Over medium haul distances aviation can provide connectivity to destinations within hours which would take days to reach by rail or road. In relation to short haul the role may be in competition with high speed rail, but can on occasion provide a solution which produces fewer emissions68. Where terrain dictates a longer journey like between Manchester and Copenhagen, it may be the case that the journey by high-speed rail would take far longer69 and produce far more emissions than flying. On domestic trips, aviation has a critical role to play connecting communities which would have difficulty via any other option, especially in Scotland where it provides the lifeline to the island communities. Consequently, aviation should be viewed as an integral part of the public transport network. 65 http://mediacentre.heathrowairport.com/imagelibrary/downloadmedia.ashx?MediaDetailsID=887&SizeId=-1 66 Brazil. Russia, India and China 67 http://www.stenaline.co.uk/ferry/media/news/increase-in-indian-tourists/ amounts stated are based on a return journey over Christmas 2012. 68 A turboprop airline can reduce the total emissions from a flight by 40% over that of a jet aircraft. When comparisons are made between high speed rail and aviation the rail industry claims that high speed rail creates zero emissions. What they fail to consider is the footprint of the carbon produced at the power stations which generates the electricity and the losses in transmission. If you therefore compare a 400kmh high speed train with a turbo prop aircraft flight on routes between London and Glasgow (or any comparable journey) the flight would produce less emissions. http://www.euravia.aero/about-euravia/environmental-case-study/ 69 a passenger to travel through France, to Brussels change for a train to Cologne and change again to Copenhagen. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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2. How should we make the best use of existing aviation capacity? 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? 2.10 Given the nature of hub activities in needing to provide a seamless transition of passengers from one flight to the next, it is difficult to see how this can be improved by connecting London airports together by high speed rail connections. The delays caused by passengers transiting from Terminal 3 to Terminal 5 at Heathrow already affect scheduling and this is no more than 15 minutes. Equally, assigning an airport to a particular sector in terms of the industry would not work either given the need for passengers from domestic flights to connect with others flying short, medium or long distances; short haul passengers also desiring a connection to domestic, medium and long haul etc. 2.11 Dictating that short haul and domestic flights should not call at the hub will cause serious problems for regional communities. Lack of connectivity to a hub, or other major London airport, limits demand for onward connectivity. Key examples are the closure of Plymouth following the loss of the Gatwick service and the threatened closure of Durham Tees which followed the decline in passenger numbers from 940,000 in the year to July 2006 to 167,000 in the twelve months to July this year70 due to the loss of a connection to Heathrow. This has caused the airport to loose £2 million in their last reported financial year putting its future at risk. 2.12 Non connecting point-to-point services flying out of Heathrow only benefit from being able to capture market share on routes for domestic customers and those who decide to self connect. These point-to-point flights could be accommodated at an alternative London airport. Such a move would require governmental control of slot allocation given the value of these slots on the open market71. 2.13 Providing internal flights to a domestic hub is controversial as there are much less polluting ways to travel domestically. If these regions were offered a low carbon alternative to aviation, which allowed near flight level travel times, comfort and connectivity, then there would not be the need to provide the connection by air. This can clearly be illustrated by looking at the successful replacement of flights between Madrid to Barcelona72. The same could occur between Manchester73 or Leeds and Heathrow once the HS2 line is completed, if the line connects to the hub in the first stage. 2.14 Where the distance or terrain dictates and a flight is necessary, why does this connection have to be provided by a jet powered aircraft? A turboprop engine is more fuel-efficient than a jet. For flights of less than 500 nautical miles the use of turboprop powered aircraft becomes the most cost-effective and environmental way to fly as they use less fuel. In fact, some turboprops can use up to 40% less fuel with an equal reduction in emissions74. 2.15 In the short term the use of Mixed Mode could provide some growth if the infrastructure was developed to allow departures towards the East from the northern runway at Heathrow. Whilst this would provide some additional capacity and resilience in the very short term it would cause the removal of respite from over flights and noise for local residents. 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? 2.16 Unite would argue that there is currently no workable Government aviation strategy other than one which suggests you can fit a pint into a quart pot. Current capacity outside the south east is sufficient to cope with current demands and those placed upon it in the short term. In the longer term there will be the need to expand Manchester, Birmingham, and either Glasgow or Edinburgh to cope with regional demand. c. How can surface access to airports be improved? 2.17 Diversion of the HS2 route via Heathrow in the initial phase could provide some additional connectivity as highlighted earlier by offering an alternative to aviation. By doing so some of the connecting flights to Manchester could be replaced as could flights to Brussels, Paris and Lyon. This can clearly be illustrated by looking at the successful replacement of flights between Madrid to Barcelona75. The same could occur between Manchester76 or Leeds and Heathrow once the HS2 line is completed, if the line connects to the hub in the first stage. Moving the route to the west would also have the added benefit of going through a far narrower part of the Chilton's. 70 CAA statistics 71 Value of Heathrow slots—the value of £25–30 million is based on analysis of slot purchases in the last six months, such as Continental Airline who paid US$209m for four pairs of take-off and landing slots to GB Airways, Air France and Alitalia. 72 Until 2009, the Madrid to Barcelona route was one of the busiest air travel corridors on Earth. When the AVE high speed rail line between the two cities opened, air passenger rates declined by 46 percent within months causing several airlines to pull the service from their schedules. 73 Over 75% of passengers on the Manchester to Heathrow services did so in order to catch a connecting flight. 74 http://web.mit.edu/aeroastro/people/waitz/publications/Babikian.pdf 75 Until 2009, the Madrid to Barcelona route was one of the busiest air travel corridors on Earth. When the AVE high speed rail line between the two cities opened, air passenger rates declined by 46 percent within months causing several airlines to pull the service from their schedules. 76 Over 75% of passengers on the Manchester to Heathrow services did so in order to catch a connecting flight. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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2.18 Unite supports the Airtrack Lite77 proposals to build a link between Heathrow Terminal 5 and Staines which would enable passengers to better access the hub from the South avoiding the need to pass through central London. Such a connection would also enable passengers from Wales and the West Country to access Gatwick if the connection is built from the Great Western line.

3. What constraints are there on increasing UK aviation capacity? 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? 2.19 On point to point services the main constraint is the ability of an airline to attract customers for the service in the locality of the two airports between which the service will operate. In terms of hub operations the constraint should be environmental in terms of limiting the growth of emissions to what is sustainable. 2.20 Unite believes that noise management is a double edged sword in that by combating noise it will often result in more greenhouse gas emissions. There are measures such as the use of continuous descent that can reduce both but in the main the decision has to be made whether the industry concentrates on reducing fuel burn and emissions or noise. 2.21 Current proposals to maximise the use of existing facilities removes the respite currently enjoyed by residents from over flights by using runway alternation and require flights to arrive over a longer period during the day should there be an incident which disrupts normal operations. If the capacity provided by a third runway or a new hub was constructed, such respite provision could return and as long as this capacity is not fully utilised disruptions could be resolved far sooner. Consequently, Unite believes that whilst a larger area would be affected by noise pollution the effect on the individual would be a reduction in noise. 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? 2.22 Unite believes that the reverse is true. Providing additional capacity reduces unnecessary fuel burn while queuing both on the ground and in the air if it is not fully utilised. Figures from Boeing on fuel burn per minute highlights that for every minute a jet aircraft is on the ground it is burning the same amount of fuel as it does during up to ten minutes at cruise altitude. Attempting to squeeze even more flights out of the existing infrastructure will only result in more emissions. There are a number of measures that can make aviation more sustainable but the simplest in terms of government policy is to provide enough capacity to allow aircraft to land immediately on arrival at an airport and depart directly after leaving the gate. Electrically powered tugs to stop jet engines being used during taxiing would also reduce emissions and pollutants, making the working environment for employees better. Limits on flight numbers based on total emissions would limit increasing the carbon footprint and drive the industry toward being even more sustainable. c. What is the relationship between the Government's strategy and EU aviation policies? 2.23 The EU promotes a 40% replacement of Jet A1 aviation fuels with sustainable alternatives. The Committee on Climate Change based their findings on a 10% figure. Europe also appears to support its aviation industry, recognising the benefits it brings, whilst successive government policies suggest we do all we can to prevent the industry being successful.

4. 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? 2.24 As outlined previously the idea that you can get a better aviation industry without expansion is farcical. As commercial enterprises the industry is already trying to work within government limitations to maximise passenger load factors and increase profit. Unite believes that the government needs to get behind airport expansion now and needs to fast track the planning process for these facilities to make up for the years of debate over this subject if we want UK plc to be competitive. 2.25 Fears that having spare capacity would encourage the industry to fill this capacity to the limit again can be overcome by limiting air traffic movements by imposing limits. Legislation which ties together flight numbers with emissions would promote the use of more fuel efficient aircraft, which in turn would reduce global aviation emissions on flights destined to travel via Heathrow and other UK airports. 2.26 Given the limitations of the Heathrow area in the longer term a new centralised hub is needed to cope with demand from 2050 on with the space to expand further. NATS has identified that the problem with the airspace over London and the South East is the complexity due to the number of existing airports and aerodromes. If a new hub is created it will need to consolidate the flows through at least two airports as well as provide additional capacity. Unite believes the ideal location would lie to the West of London along the M4 corridor no more than 48km from Central London to minimise the disruption to the workforce demands needed to staff such a facility and service the business communities of the region. Unite would, however, support any workable proposal at this stage given the plight of the industry. 77 http://www.wandsworth.gov.uk/news/article/11195/support_builds_for_new_heathrow_rail_route cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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b. What are the costs and beneﬁts of these different ways to increase UK aviation capacity?

2.27 Unite does not have the resources to provide such an analysis but believes that a three stage approach beginning with the adoption of full mixed mode operations, while a third runway is constructed culminating in the opening of replacement new hub. Both of these initial stages would not cost the tax payer one penny as the costs have been already allocated by the private sector. The major expense will come with the construction of a new hub airport which would need a minimum of four parallel runways to be viable but Unite believes it should ideally have six.

2.28 Whilst it may be possible to utilise the land around RAF Northolt as an alternative, this would need to be combined with a high speed connection to the existing terminals at Heathrow from airside to airside. This may be possible if the proposal by Heathrow Hub Ltd is extended to forge a link between it and Northolt. Such a proposal would require the creation of a new runway on land adjacent to the current footprint of the airport to align it with those of Heathrow. Such a proposal would require extensive tunnelling to make this work which would be far more expensive than the third runway idea. Additionally, such a solution would increase connection time between terminals which in turn would heavily effect scheduling.

2.29 It is clear that the long term future of Heathrow post 2030 is in doubt unless government intervention ﬁnds a legal way of preventing aircraft using the airport as a hub post the creation of its replacement.

3. Conclusion

3.1 Unite hopes that whatever proposal is ﬁnally decided upon, that such a proposal is constructed as soon as possible and not delayed by government and legal red tape. Unite believes that if it takes a further 20 years to get a new hub open and running, it will probably be too late to save the future of the UK aviation hub.

3.2 Istanbul is now building a five runway hub airport which will exploit its geographic location to maximise flows from Russia, China, the Middle East, India and Europe which will be open in just four years. As Turkey is outside the European Union, flights to Turkey do not face the burden of having to pay for carbon credits for every tonne of carbon produced and is close enough to the East Coast of America to enable direct narrow body high frequency flights. In short, if the UK does not invest in new capacity it runs the risk of being left on the sidelines by Turkey and others inside Europe.

3.3 The lessons learnt from the construction of Montreal Mirabel airport should not be ignored and whatever is built needs to have enough supporting seamless intermodal surface connection options to make the journey from home to destination as stress and hassle free as possible. 19 October 2012

Written evidence from NECTAR (AS 65)

NECTAR—the North-East Combined Transport Activists’ Round Table—is pleased to send the following response to the Inquiry on Aviation Strategy.

NECTAR is an open, voluntary, umbrella body, established to provide a forum in which the many organisations with an interest in sustainable transport in all its forms can develop a co-ordinated view on contemporary transport issues.

NECTAR is one of a national network of Transport Activists’ Roundtables, each of which provides opportunity for the exchange of news, studies, and information.

The main points in our response to this Inquiry are:

(a) that global warming and carbon emissions are essential factors that must always be taken into account in forming any transport policy:

(b) that aviation fuel exhaust is among the world’s most polluting items, and is in any case a ﬁnite (and hence declining) resource: and

(c) that the need to travel by air has been grossly exaggerated, with future predictions of “demand” becoming increasingly impossible to make, especially as official figures for air travel in the UK have either remained at the same level, or declined, during the past four or five years.

We recognise that the committee has set up its Inquiry largely to elicit views about airport provision in London and the South East, but, with respect, we remind the committee that no attempt to work out an aviation strategy for any nation can be successful if it conﬁnes its attention to one rather busy region, at (by implication, at least) the expense of just about everywhere else.

Our detailed response answers, as far as possible, each of the Transport Committee’s questions in turn. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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1. What should be the objectives of Government policy on aviation? (i) Basically, to reduce, as far as is possible, the need for flying at all. This is in the interests of a cleaner environment, now especially threatened by the forecasts of the 50 months left in which to avoid a global 2 degrees Centigrade increase in world temperatures, if these forecasts are reliable. Other factors are, first, the continuing depletion of world resources in general, and of fuel oil in particular, and, second, the poorer air quality around airports, resulting from, among other things, the considerable volume of surface traffic attracted by every airport, as well as from the air fuel exhausts themselves, (ii) We recognise that air traffic levels cannot be reduced overnight: so our three specific objectives would be: (a) to concentrate on provision of long-distance air services, mainly transcontinental and transatlantic: (b) to develop high-quality rail links within the UK to larger regional airports, rather than short-haul internal flights: (c) to reduce the number of short-haul flights to and from Europe, on a basis of their redundancy for journeys that a rail link can cover in 4 hours or fewer. Increasingly-lengthy check-in and security times, plus the sheer vastness of so many airport terminal buildings, can easily triple or even quadruple the nominal flight time, seriously reducing any time advantage over a parallel rail journey.

(a) How important is international aviation connectivity to the UK aviation industry? (iii) This is really a question for the industry, not for us: we comment on “connectivity”, brieﬂy, below, at 1e and 2c in particular.

(b) What are the benefits of aviation to the UK economy? (iv) Not very noticeable, frankly—figures that we have seen show that much more money is taken out of the country as a result of British holidaymakers using low-cost flights than is brought into it by non-UK citizens visiting the country and spending time and money here. Business travellers are numerically only a small proportion of those who go by air, even if their per capita air fares are above the airline average.

(c) What is the impact of Air Passenger Duty on the aviation industry? (v) Probably far less than some n the industry claim. As long as this duty is charged fairly, on all who travel by air—including those on charter flights—the impact will affect all carriers in the same way, neutralising any legitimate feeling of unfair competition between or among airlines. (vi) Insofar as the charges levied by alternative modes of transport become lower than those by air, this probably reflects more truly the indirect cost to the world as a whole of air travel with its concomitant (and still untaxed) fuel consumption, and its production of chemically-undesirable exhaust fumes. Brendon Sewill’s “Fly Now, Grieve Later” shows in great detail how much CO2 pollution per passenger results from air travel. His figures, given in 2005, of 300 kg per head may now have been reduced thanks to improved technology, but they are more than double the figure for a single-occupancy car driven along a motorway over the same distance. (vii) We would add that these polluting agents remain with the planet, regardless of how ingeniously some countries devise, and then put into effect, carbon offset trading and other “credit” systems.

(d) How should improving the passenger experience be reﬂected in the Government’s aviation strategy? (viii) Directly, not at all, unless the Government runs the airline. Indirectly, this may be an invitation to comment on the different modes of payment that a passenger faces when using some “budget” airlines—is it acceptable to quote a basic fare for a ﬂight from A to (nearly) B, when nobody can actually travel for that fare because of compulsory supplements? We would say not. And we would add that (if international law allows it) there should be a clearly- stated and enforced limit to the distance between an airport and the centre of the town or city after which it is named—say 15 km. If this did arise, of course, neither Heathrow nor Gatwick could advertise itself as “London”, leaving far more scope, for good or ill, at London City Airport about which we hear far less than it perhaps deserves.

(e) Where does aviation fit in the overall transport strategy? (ix) Ideally, we might say, not at all, but first, may we ask exactly what the “overall transport strategy” is at the moment? From some viewpoints, it looks to be “cars first, second and last, with pedestrians, cyclists and bus users nowhere”. There is a continuing and welcome increase in the importance given to rail. But even so, the remote position of many UK airports demands far greater car use to reach them, for passengers, crew, and airport workers alike, than it need do. (x) Gatwick, Stansted, Birmingham International, Manchester and Southampton airports are better than average, with rail stations on their premises, sometimes astride main railway lines. Newcastle’s case is not far cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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short, serve as it is by the Tyneside Metro. In contrast, Luton Airport Parkway’s name is dangerously misleading, given the need for a lengthy bus journey between station and airport. (xi) If comparisons between transport modes are taken a bit further, we note again that aviation fuel is not taxed at all, whereas that for every land mode—apart, that is from pedestrians and cyclists (!)—is. See also our answers to 2b and 2c below.

2. How should we make the best use of existing aviation capacity? (xii) We question at the outset the implication that all existing capacity must be used at all. Environmental consequences far greater than those even from diesel-powered surface transport come from flights of every type, even when filters and other refinements have been added to every example of every kind of aircraft. [Cf. Sewill, op.cit., especially pp. 6–11.]

(a) How do we make the best use of existing London airport capacity? (xiii) It depends on who “we” are. Nobody in NECTAR is qualified to run an airline. If you are asking for suggestions on what kind of flight should be replaced by another means of transport—rail, for instance, at whatever speed—we would strongly advocate much greater effort to add North of London cross-channel rail services (mainly, but not exclusively, run by Eurostar) to those already running from London. We add that, on the face of it, the scope for reducing air traffic originating in the London area is much greater than it is anywhere else in these islands, as so many high-quality rail lines link London to much of the UK and to continental Europe.

Are the Government’s current measures sufficient? (xiv) Again, it depends on what “measures” are meant here. For the moment, we exclude the intermittent sabre-rattling about a third runway for Heathrow, because it has still not been made an official feature of policy—and we hope that it never will. (xv) On the other hand, the threat of more night flights across the London area (or, indeed, anywhere else) seems to us sufficiently real and damaging, to all under their flight paths world-wide, to prompt once again more effective steps to encourage current and future air travellers on to alternative, more carbon-friendly modes. In practice, this most often will imply high-speed rail to and from Europe, and medium-speed rail within the UK (for now). We know that, without any government effort, rail’s share of the market has increased very noticeably, at the expense of that by air, on some busy internal routes such as London—Manchester and London—Newcastle.

What more could be done to improve passenger experience and airport resilience? (xvi) What on earth (or elsewhere) is the resilience of an airport? And why is it so closely linked here with “passenger experience”? If it is a covert synonym for check-in and security procedures, waiting times, and distances between departure lounge and boarding gates, any or all of which test the nervous energy of most passengers, we would reply “quite a lot”. (xvii) Specifying the form this would take is probably not within our powers, though we do ﬁnd the UK’s exclusion from the Schengen area a vexing handicap, which at present weighs more heavily on Eurostar rail passengers, with their compulsory customs examination, security vettings and check-in processes, than we think they deserve.

(b) Does the Government’s current strategy make the best use of existing capacity at airports outside the South-East? (xviii) Once again, it depents on what is deﬁned as “current strategy”, and exactly how any Government can help or hinder airports in using capacity otherwise than they do. As we understand it, the allocation of ﬂight paths to airlines at any airport is carried out, in the last analysis, by those in charge of each airport. We know of no Government directives that could affect this, though we are of course aware of Government pressure on some airport authorities not to bid for ownership of more than a certain total number of airports, and/or to sell off one or other of those that they do own. How far this connects with use of capacity as such eludes us, so we say no more.

How could this be improved? (xix) Not knowing what “this” is in this context, we can offer no suggestions.

(c) How can surface access to airports be improved? (xx) By retaining and/or expanding rail links, and improving the quality and frequency of services along them. Failing a rail link—eg to Leeds/Bradford airport—by somehow ensuring that a bus-link, with vehicles speciﬁcally designed to take heavy luggage, (un)loaded easily and quickly, runs during the full length of the cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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airport’s operating day between the airport terminal and a central and well-connected town or city centre terminus. This would normally be a main rail station and/or a large bus station, both with adequate passenger facilities in them. The present régime at Luton Airport (cf. 1e above), though far from ideal as a genuine rail link, illustrates what we mean here. (xxi) Bus and coach access should also be improved as and where possible: in short, the aim should be to reduce significantly the number of journeys to and from every airport that are made by car, no matter how fully-occupied each car is. Newcastle Airport, for instance, has good access by public transport, particularly its Metro line: but we would advocate a far greater effort by local and national government to publicise this access more widely. At present, the only airports whose rail access is nationally known are Gatwick and Manchester, since each has main-line rail services: but even in these cases it could be argued that the publicity is for most people confined to the pages of the local and national rail timetables. (xxii) A Heathrow Airport spokesperson is reported in the Guardian (October 13 2012, p.18) as saying that the airport subsidises local public transport so that people can travel free of charge, avoiding the need for a car. If so, it is the first that we have heard about it, and in the absence of better publicity nation-wide, and more specific details, it is of little practical use to most air travellers, praiseworthy though the airport’s initiative may be. The common perception of non-car access to Heathrow is the premium-fare “Heathrow Express” rail service to and from Paddington, with a slow and crowded Piccadilly tube line as a cheaper substitute. (xxiii) If, in fact, provision of free public transport access to an airport (for, presumably, air ticket holders, as part of the overall price) is something that Heathrow is now pioneering, we encourage it warmly and hope that other airports around the country follow Heathrow’s example as soon as possible.

3. What constraints are there on increasing UK aviation capacity? (xxiv) In our view, the repeated reports of melt-down at one or both poles, plus the unusual weather-patterns and changes that result, are sufficient to conclude that expansion of air travel of any sort at any level is unacceptably risky. (The problem is by no means unique to aviation: motoring and other activities using fossil fuel—buses and trains—also cause pollution and climate change, of course.) There is also the associated problem of excessive “growth”; the earth’s resources are finite, and this alone poses many problems about population growth and average consumption levels. Just because there is room for more aeroplanes to roam the skies without bumping into each other, this does not mean that such roaming is of benefit to world well-being, now or in the future. (xxv) So, if anything, the planet’s inherent limitations impose a need to reduce, not to increase, anything that uses fossil fuels. Difficult though many will find it to perceive the dangers now, they are there, and will increase as long as human unsustainable activity continues.

(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? (xxvi) Again, it depends on what form these proposals take. Much as we would applaud all help, financial and material, to double or triple glaze more and more homes across the country, such measures do not reduce the impact of aviation, or any other noise, on those not in such houses, never mind those working or exercising outdoors, or simply travelling from place to place. (xxvii) A forthcoming report, mentioned in the Guardian article of October 13 (cf.§xxii above), is expected to show that a clear increase in the number of deaths from air pollution occurs in areas nearest to all airports, most notably around Heathrow. Possible reasons for this are the exhausts from so many cars and other road vehicles going to and from the airport, which have an even greater adverse impact on air quality than do the planes themselves! We repeat, in the light of these findings (by the Massachusetts Institute of Technology laboratory), the urgent need to reduce the amount of traffic around all airports as part of any policy to reduce the impact of aviation.

(b) Will the Government’s proposals help to reduce carbon emissions and manage the impact of aviation on climate change? (xxviii) A proposal, as such, can neither reduce nor increase anything: presumably the question means to say “implementation of its proposals”, or similar. Even so, we do not think that a Government wish-list can do much about either carbon emissions or climate change, neither of which are limited by national boundaries, nor do they seem to be as predictable in their extent as even the specialist scientists have hoped they would be. Compelling arguments that aviation can never be climate-friendly may be found at .]

How can aviation be made more sustainable? (xxix) In three words, it cannot be. “More sustainable” is almost a contradiction in terms—the essence of sustainability is that no additional resources of any sort are used. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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(c) What is the relationship between the Government’s strategy and EU aviation policies? (xxx) We are not qualiﬁed to answer this question.

4. Do we need a step-change in UK aviation capacity? (xxxi) Yes—but downwards, not upwards.

Why? (xxxii) We have already explained this in earlier answers.

(a) What should this step change be? (xxxiii) As already stated, downwards.

Should there be a new hub airport? (xxxiv) Dogged again by an ambiguous wording, we say that there should be no new airports of any kind, hub or otherwise. If, however, the intention is to ask about an upgrading to “hub” status of an airport already existing, our answer is different. We know, for instance, that Heathrow is regarded as a hub, and also that some in aviation deplore the fact that many air users prefer to go to Amsterdam, for instance, for connecting long- distance services. (xxxv) We respectfully remind such people that, if they check with their atlases, they will find that large areas of northern England (and all of Scotland) are about as near to Amsterdam as they are to Heathrow, and anyway the combined cost of flights to, and connections via, Amsterdam (and, indeed, elsewhere in western Europe) is often significantly lower than it would be via Heathrow. Depending on the ultimate destination, of course, it is arguable that going to Amsterdam from the north-east and from Scotland reduces the overall air mileage quite significantly, regardless of whether one route is more stress-free than the other.

Where? (xxxvi) If at all, preferably in the north of England, at Newcastle, with several provisos: (a) that it would totally replace several others in the region, so would need (or already have) first-class surface communications, including high-speed rail, with the areas they had served: (b) that its aim would be to reduce overall the number of flights available, mainly by providing high- capacity and high-occupancy services: and (c) that it would reflect current aviation practice, in that—despite appearances—Newcastle’s position is as near to that of Canada and the border areas of the United States as anywhere in southern England, or indeed in Scotland. Many current international flight-paths, eg from Frankfurt or Amsterdam to north American destinations, reflect this by flying along the east coast of England before veering westwards from south Tyneside towards Glasgow, and then crossing the Atlantic ocean.

(b) What are the costs and benefits of these different ways to increase UK aviation capacity? (xxxvii) As we deny that aviation levels should be increased at all, we have logically to answer that there are none of either. (xxxviii) It is not irrelevant to mention here that quoted statistics* for current airport usage, as hinted at above, show that passenger levels are either the same as in previous years or, here and there, tapering off. Few examples of increased usage exist. So why seek to increase a “capacity”, when even the official figures do not show a need for it? *2011 passenger numbers for London airports show a 4% drop from their 2007 level. Those for all airports were 8% down over that same period. During it, rail passengers numbers increased by no less than 25%. 19 October 2012

Written evidence from the Royal Town Planning Institute (AS 70) Introduction The Royal Town Planning Institute (RTPI) is pleased to respond to the call for written evidence to the Transport Committee to examine the Government’s aviation strategy, focusing on aviation capacity in the UK. The RTPI is the largest professional institute for planners in Europe, representing some 23,000 spatial planners. The Institute seeks to advance the science and art of spatial planning for the beneﬁt of the public. As well as promoting spatial planning, the RTPI develops and shapes policy affecting the built environment, works to raise professional standards and supports members through continuous education, training and development. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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The views in this submission follow consultation with the members of the RTPI, and speciﬁcally the members of the joint RTPI and Transport Planning Society (TPS) Transport Planning Network. This Network has a wide and varied membership with experts in the full range of transport modes represented.

Submission 1. What should be the objectives of Government policy on aviation? (a) How important is international aviation connectivity to the UK aviation industry? (b) What are the beneﬁts of aviation to the UK economy? 1.1 International connectivity is clearly of great importance to the UK aviation industry, but to turn the question around, international connectivity for the UK economy and UK Plc is the most important beneﬁt from the UK airline industry. Connectivity has been crucial to UK business for centuries because of the UK’s geographic position and the need as an island nation to export, in order to achieve continued growth. 1.2 The location of airports needs to be considered as part of a much wider set of considerations so that their links to housing and jobs and their considerable impact on surface transport and the shape of a whole region can be properly assessed. Airports are hugely important to the areas in which they are located, for example Heathrow Airport is a major employment generator in outer west London and is integral to the local economy. Similarly smaller regional airports can also be vital to local economies.

(d) How should improving the passenger experience be reﬂected in the Government’s aviation strategy? 1.4 Passengers are likely to be concerned with door-to-door travel, so the location of airports and the quality of the surface links to them from a variety of departure points within a region are critical questions. For far too long (until the early 1990s) Government was content to allow airports to expand with little interest in the impact on surface transport. Only recently for example has the issue of the connectivity of Heathrow Airport to anywhere other than central London received serious interest. 1.5 Airport location can also be an opportunity to invest in surface transport as a means of not only meeting air passengers’ needs but also in solving regional transport challenges. The same investment may achieve a variety of functions, but only if wider considerations are taken into account.

(e) Where does aviation fit in the overall transport strategy? 1.6 It is questionable whether an overall transport strategy exists, and this is a deficiency which should be addressed by Government. In the absence of an overall policy however, the combination of current strategies for various modes might be considered as a proxy for an overall transport strategy. An aviation strategy should be aligned with these other modal strategies. It is for example difficult to gauge the overall business case for high speed rail or the question of runway capacity in South East England in a situation where the Government’s intentions regarding modal split for short haul journeys are not clear. 1.7 It should be stressed however that even with a “transport strategy” embracing all modes; great care should be taken to ensure that transport investment performs a variety of purposes. It is not enough simply to plan to meet air and other capacity deficiencies; it is also necessary to use transport investment in order to achieve wider goals such as the provision of additional homes and jobs in the right places. Aviation investment and the necessary surface transport improvements it requires are an excellent way of doing this.

2. How should we make the best use of existing aviation capacity? (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? 2.1 No comment: as a professional Institute it would be inappropriate for us to make comments on speciﬁc projects and cities.

(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? 2.2 No comment.

(c) How can surface access to airports be improved? 2.3 See response to earlier question (para 1.4&1.5). The impact of airports on regional connectivity is far too important an issue for surface access to be regarded in solely aviation terms. Improvement to surface access should form part of a transport plan which has a number of other aims, such as increasing the amount of housing land which has good transport access, and meeting the needs for sustainable freight transport especially by rail. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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2.4 In terms of housing, the difﬁculties faced by housing developers in meeting the costs of transport infrastructure, the absence of much public funding of access to housing land and the seriousness of the housing crisis nationally mean that transport infrastructure for airports is a key potential element in meeting the country’s needs for homes and jobs.

3. What constraints are there on increasing UK aviation capacity? (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? 3.1 No comment.

(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? 3.2 Emissions data relating to international aviation could be made more transparent and be included as part the UK Emissions Statistics published by the Department of Energy and Climate Change.

(c) What is the relationship between the Government’s strategy and EU aviation policies? 3.3 The relevant EU policies include those relating to airspace, emissions trading, noise mapping, slot regulation, competition, bilateral agreements and passenger rights. In most cases, UK Government policy is aligned with these although there are examples where other EU countries do not appear to have the same enthusiasm for full implementation as the UK (eg noise mapping). There are also examples where the EU seeks to resolve issues in some countries, which are not a problem in the UK where competition is generally stronger (eg ground handling).

4. 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? (b) What are the costs and beneﬁts of these different ways to increase UK aviation capacity? 4.1 Given the importance of airports to their local regions, it is felt that wider social and economic factors need to be considered when making decision relating to aviation capacity. An integrated approach to aviation growth is supported, including coordinating aviation with infrastructure and new housing. 4.2 Decisions on airport capacity need to be taken in connection with the following considerations: — Policy on modal split for short haul journeys to neighbouring countries in the UK, Ireland and Europe. — The contribution airports can make to regional economies. — The contribution investment in surface access can make to unlocking land for homes and jobs and to solving other transport challenges. 19 October 2012

Written evidence from ADS (AS 74) About ADS ADS is the trade organisation advancing the UK Aerospace, Defence, and Security industries with Farnborough International Limited as a wholly-owned subsidiary. ADS encompasses the British Aviation Group (BAG) and jointly sponsors, with Intellect, UKspace. ADS is also a member of the Sustainable Aviation coalition of airports, airlines and aerospace manufacturers. ADS was formed on 1 October 2009 from the merger of the Society of British Aerospace Companies (SBAC), the Defence Manufacturers Association (DMA) and the Association of Police and Public Security Suppliers (APPSS). ADS comprises around 900 member companies within the industries it represents. Together with its regional partners, ADS represents over 2,600 companies across the UK supply chain. ADS welcomes the opportunity to respond to the consultation by the House of Commons Transport Select Committee. Representing the aerospace supply chain, the ADS submission focuses on the many technological improvements that manufacturers have made, thus reducing the environmental footprint of aviation.

4.1 The Aviation sector is vital to the UK economy bringing financial benefits to the UK and providing high skilled employment and connections to growing markets 1.1 Aerospace, including both fixed wing and rotary wing aircraft, is one of the UK’s big success stories and a significant contributor to the UK economy. The UK aerospace manufacturing sector is the second largest in the world (17% market share), and one of the UK’s few world-class manufacturing industries, worth over £24 billion to the UK, of which 75% is exported world-wide. The sector is high value and highly skilled, cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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employing nearly 100,000 directly and supporting a workforce of around 360,000, plus another 46,000 overseas. 1.2 An important contribution from the industry is in the regionalisation of commercial aviation, generating employment in many regional areas—a good example is Bombardier in Belfast, who provide employment to around 5,000 employees, generating almost 10% of Northern Ireland’s manufacturing exports. 1.3 Connectivity to emerging markets and those with growth levels greater than the UK, such as Brazil, the Russian Federation, India and China (the BRIC countries) are vital for the future prosperity and welfare of UK plc. UK Aerospace has a crucial role and is, as the Prime Minister has noted “a powerhouse in the UK economy”. In this respect, the UK is already losing out to its European neighbours who have latched on to the vital role that aviation plays. A recent report by Frontier Economics prepared for Heathrow,78 noted that companies do 20 times the amount of business with countries connected by air, than those that are not.

4.2 The Aviation sector takes its environmental responsibilities seriously, and has consistently demonstrated this in the past and present, projecting that continuous improvement is the norm for this industry in for the future 2.1 Technology improvements and advances in operations have improved the fuel efficiency of aircraft significantly—the Airbus A380 burns about 17% less fuel per seat and the new Bombardier CSeries aircraft will travel 100 passenger km on 2.3 litres of fuel. A Toyota Prius travels the same distance on 4.3 litres. Operationally, the “Perfect Flight” operating from Heathrow to Edinburgh, as part of the Sustainable Aviation initiative, demonstrated that around 12% of fuel burn/CO2 emissions could be saved if inefficiencies in airspace design and management could be improved. 2.2 Passenger numbers are expected to more than double by 2050 and air freight activity, vital to the UK’s trade with emerging markets, is expected to increase more than seven fold. However, the industry, under the Sustainable Aviation banner, has produced a “CO2 Roadmap” showing how UK aviation could accommodate significant growth to 2050 without a substantial increase in absolute CO2 emissions and support the reduction 79 of net CO2 emissions to 50% of 2005 levels through internationally agreed carbon trading. 2.3 Local air quality impact at airports is mainly caused by surface traffic, as the Government’s Project for the Sustainable Development of Heathrow (PSDH) study demonstrated and where advances in aircraft engine technology are reducing aero-engine NOx emissions even further. It should be noted that although EU nitrogen dioxide limits are breached at a few areas around this major hub airport, they must not be allowed to deflect the Government away from the real issues that exist in major conurbations, such as central London where the levels are substantially higher and still rising. 2.4 Noise contours around major UK airports have reduced substantially and aircraft today are significantly quieter than they were in the past. For example, the noise performance of aircraft such as the new 550 seat Airbus A380 are setting new paradigms for noise performance—it’s Quota Count (QC) 0.5 classification on arrival being equal to that of the 150 seat Boeing 737, and a quarter of that of the Boeing 747–400 it replaces. 2.5 Despite the huge technological innovations that have already been made, the industry is not resting on its laurels and is investing heavily in the future. R&D expenditure by the UK aerospace manufacturing sector was maintained at £1.77bn per year in 2010, and new concepts such as those highlighted in “The future by Airbus” demonstrates that the industry is not frightened of forward thinking.80 Government support through the Aerospace Growth Partnership (AGP) is crucial for the industry to retain world leadership in this area. ADS looks for cross-party support for the AGP so that UK Aerospace is able to continue to deliver for the UK economy.

4.3 Aviation does need Government to step up to its responsibilities regarding this sector, providing the right political framework to allow the Aviation sector to grow in a sustainable way, integrated with other transport modes and industries 3.1 It must be understood that more than any other industry, Aviation operates in a global market and, as such, needs global solutions to avoid market distortions that would prejudice against the UK industry.

3.2 ADS supports emissions trading on a global basis where the most cost-effective CO2 mitigation opportunities may be identiﬁed and pursued, irrespective of sector or geography. In this respect, the integrity of the international aviation system is based on the establishment of limits on the ability of any one country to impact the ﬂying rights of another country. Regrettably the EU Emissions Trading Scheme (ETS) does not currently appear to meet these requirements and the challenge now is for the European Commission to implement ETS in a way that does not distort competition. In the form ETS currently stands, UK Industry is being put at a serious disadvantage by other state’s retaliatory trade measures. This is already impacting the 78 Frontier Economics “Connecting for growth: the role of Britain’s hub airport in economic recovery”, http://www.frontier-economics.com/_library/pdfs/Connecting%20for%20growth.pdf, Frontier Economics, September 2011, last accessed 16/10/12 79 Sustainable Aviation “CO2 Roadmap”, http://www.sustainableaviation.co.uk/wp-content/uploads/SA-CO2-Road-Map-full- report-280212.pdf, Sustainable Aviation, March 2012, last accessed 16/10/12 80 Future by Airbus, http://www.airbus.com/innovation/future-by-airbus/, last access 16/10/12 cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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UK’s ability to deliver billions of pounds of its products to certain countries and putting future work and jobs in serious jeopardy. Airbus currently has 45 long range aircraft on hold, equating to a value of $15 billion— their order suspended by the Chinese authorities. We strongly urge the Government to press EU authorities on this issue to further prevent the indirect negative effects of ETS on UK exports continuing. 3.3 Local actions have had much less impact on aircraft and aero-engine design. In this respect, design standards set at international level have been significantly more effective in ensuring that the pace of improvement, in environmental and other performance (eg safety) areas, has been maintained. The UK Government’s role in the negotiation and development of these at the International Civil Aviation Organisation (ICAO) is fundamental in ensuring that this pace is maintained and that UK industry is not disadvantaged by other nation’s interests. 3.4 An important part to maintaining the UK’s position as a centre of excellence in this high technology sector is the continuing support for technology research and development. This is vital to keeping this important area within the UK, and to avoid it leaking out to other competing countries, where it could then be exploited to the detriment of the UK. It should be recognised that spin-offs from the aerospace industry have been essential in the design, development and manufacture of emerging “green” technologies that hold some of the solutions to the future decarbonisation of human activities. An obvious example is in wind turbine design. 3.5 At a time where there is increasing investment by AgustaWestland in UK Civil Helicopter engineering, matched by a strategic focus from Government, it is important that the Government consider sponsoring an inter-modal transport study to outline the economic and structural benefits of integrating rotary wing aviation into the UK transport system, and determining how these aircraft can play their part in the sustainable growth of aviation. 3.6 SESAR (the Single European Sky Air Traffic Management Research Programme) is an important part of the future of the air traffic management system and a study by McKinsey & Co has shown that delays will hurt European, and in particular UK economies dear. The study anticipates SESAR would benefit the European economy by €419 billion (the UK’s share would be €84 billion) from 2013 to 2030, creating 328,000 jobs and saving 50 million tonnes of CO2. A 5 year delay would cost Europe €117 billion, and a 10 year delay €268 billion and 189,000 jobs. UK Government support for this project is therefore vital in ensuring that these benefits are captured and not lost due to a lack of action.

4. Conclusion 4.4 The UK Aerospace sector is a successful, vibrant, high value, high technology engineering, manufacturing and service industry that generates signiﬁcant returns to all its stakeholders. UK Aerospace is investing in new technologies to reduce its environmental impact whilst working with Government to secure the future of the industry. ADS looks to Government to support industry lead Sustainable Aviation initiatives and press to ensure international emissions standards do not negatively affect UK trade. 19 October 2012

Written evidence from the Richmond Heathrow Campaign (AS 76) This submission is made in response to the call for evidence for the inquiry by the House of Commons Select Committee on Transport into the Government’s strategy for aviation. The Richmond Heathrow Campaign represents three amenity groups in the London Borough of Richmond upon Thames: The Richmond Society, The Friends of Richmond Green and The Kew Society, which together have over 2,000 members. Our members are affected adversely by noise from Heathrow’s flight paths, particularly in the night period. We nevertheless recognise the importance of air transport and we seek to make a positive contribution to the inquiry. The main points in our response, following the order of the questions to which they respond, are that: (i) aviation appears to be under-taxed for general revenue purposes; (ii) carrying more passengers per aircraft movement (as envisaged at the Terminal Five Public Inquiry) would increase the number of passengers that can be handled at Heathrow (and at other airports) without additional runway capacity; (iii) carrying more passengers per aircraft would enable night flights to be phased out at Heathrow and noise mitigation measures to be maintained for daytime air traffic; (iv) surface access to and air quality around Heathrow will continue to be major problems, particularly with additional passenger numbers; (v) if the hub model is applied to Heathrow it would require not just a third runway but a fourth as well; (vi) the hub model should be abandoned in favour of more direct services from more airports, with a reduction in the number of passengers who have to transfer. We have confined our response to answering those of the questions that the Transport Committee is considering that are most pertinent to our areas of our general experience and specific research. We would be happy to provide additional information and would welcome the opportunity to give oral evidence. We are content for our response to be published. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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QUESTION 1: WHAT SHOULD BE THE OBJECTIVES OF GOVERNMENT POLICY ON AVIATION?

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

1.1 Air Passenger Duty (APD) was introduced as a specific tax on the aviation sector in order to broaden the general revenue base and in recognition of the fact that the sector was under-taxed due to zero rating for VAT and exemption from fuel tax.81 The Coalition Agreement includes a commitment that aviation should contribute additional tax in order to fund in part an increase to £10k in the income tax personal allowance. We regard the general revenue need as a sufficient reason for retaining an aviation-specific tax. Those who call for the repeal or reduction of APD should explain how the resulting shortfall in the tax yield would be financed.

1.2 Other forms of public transport are not charged the equivalent of APD, but there are sound policy reasons for not doing so: the majority of passengers by bus or train are travelling much shorter distances than the typical air journey, with competition from the car, not the air fleet. For longer journeys, wherever train is a viable alternative to air (ie short haul flights), tax discrimination to encourage the use of train can be justified on transport and environmental management grounds.

1.3 The previous Administration re-branded APD as a green tax on aviation but the revenue continues to be used for general expenditure and is not hypothecated for the mitigation and/or remediation of aviation’s environmental damage. We agree that aviation should meet its environmental costs, but through speciﬁcally designed mechanisms (eg emissions trading for climate change impacts and airport surcharges for more local impacts such as air quality, road congestion and air trafﬁc noise) rather than through APD.

1.4 APD raises approximately £2.5 billion per year, but there is no criteria against which to assess whether that amount is fair or unfair to the aviation sector. Since the original rationale for APD was in effect as a surrogate tax in view of aviation’s exemptions from fuel duty and VAT, an objective assessment of fairness could be based on a comparison between the amount collected in APD and the amount lost in fuel duty and VAT. Unfortunately the Treasury does not publish these data. But a report published in 2003 by the Aviation Environment Federation estimated that the exemptions were worth £9.7 billion.82 The wide gap between the amount paid in APD and the apparent value of the exemptions highlights the need for a validated annual estimate of the amount that aviation does not pay in fuel duty and VAT.

1.5 It is difﬁcult to square the apparently favourable tax treatment of aviation with the sector’s image as a dynamo of the UK economy. But two direct consequences follow: (a) the burden on other taxpayers is higher than it would be; and (b) and the prices for air passengers are lower than they would be. Given that price considerations are likely to inﬂuence leisure passengers 83 and that leisure passengers account for more than two thirds of all passengers at UK airports,84 aviation’s apparently favourable tax treatment may have contributed to increased passenger numbers and congestion at UK airports.

1.6 The main direct beneficiaries from the low level of APD are the airlines, with air passengers as the main indirect beneficiaries (ie air fares are lower than they would be with higher levels of APD). It is claimed that account must also be taken of the benefits from inward investment and UK-bound tourists that aviation facilitates. But the UK has exported more investment and tourist spending than it has imported over many years and these deficits may also have been facilitated by aviation.85

1.7 The main direct loser from the low level of APD is the Treasury, which must either increase the burden on other taxpayers or cut back on public expenditure. The main indirect losers are the general taxpayer or people and projects that depend on State funding (eg pensioners, a new hospital). Although many taxpayers are also air passengers, the evidence indicates that those on higher incomes account for significantly more leisure flying than those on lower incomes.86 That is to say, to the extent that the general taxpayer is subsidising leisure flying, it is disproportionately for the benefit of the better off.

1.8 It should be recalled finally that transfer passengers are exempt from APD, the original rationale being to protect airlines at UK hub airports.87 More recently, the Government has argued that it would be unfair to charge the airlines twice for transfer passengers (ie for the flight to the hub and for the connecting flight from 81 Next, I propose to broaden the tax base ... First, air travel is under-taxed compared to other sectors of the economy. It benefits not only from a zero rate of VAT; in addition, the fuel used in international air travel, and nearly all domestic flights, is entirely free of tax. Kenneth Clark MP, Chancellor of the Exchequer (Hansard, 30 November 1993, Column 934). 82 Brendon Sewill, The Hidden Cost of Flying (2003). The report included an additional £0.4 billion on duty free goods, less £0.9 billion for APD, giving a net balance of £9.2 billion. The amount collected in APD has increased since 2003 as have VAT and fuel duty. 83 Business passengers are less price sensitive because a business air journey is a small component of a much larger financial package. 84 Civil Aviation Authority, UK Airport Statistics 85 The tourist deficit also has adverse revenue implications in that tourist spending often attracts VAT. The most recent tourist deficit is £20 billion, implying a VAT deficit of £3.4 billion. 86 From data on the Civil Aviation Authority website. 87 To protect the position of the United Kingdom’s international hub airports, there will be an exemption for transfer and transit passengers Sir John Cope MP, Paymaster General, (Hansard, 1 December 1993, Column 1132–1133) cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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the hub). But, regardless of the rationale for the exemption, its effect is to discriminate in favour of airlines and airports that maximise trafﬁc at a particular hub and may inhibit the development of services direct to ultimate destinations (ie without transferring at a hub). It is likely to be the case that the majority of passengers would prefer to ﬂy direct rather than transferring (see our response to Questions 4 (a) and 4 (b) for more detailed comments on transfer passengers).

QUESTION 2: HOW SHOULD WE MAKE THE BEST USE OF EXISTING AVIATION CAPACITY? 2 (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? Heathrow Airport 2.1 We consider that better use could be made of Heathrow’s capacity to improve resilience in the short term and to increase passenger numbers in the medium term, while continuing to operate in unbroken segregated mode and within the existing limit of 480 000 air transport movements per year. We consider that the efficient use of this capacity would also enable movements to be phased out in the night period (2300–0700). 2.2 Airport capacity is determined by three related parameters: runway capacity for the number of aircraft movements; terminal capacity for the number of passengers; and (within the two preceding parameters) passenger capacity per movement.88 The Terminal Five Public Inquiry found that Heathrow—operating in unbroken segregated mode and with Terminal Five in full use—would have the capacity to handle 480 000 air transport movements (ATMs) per year carrying 90 million passengers, with a corresponding increase in the capacity and number of passengers per movement compared the situation at the time of the Inquiry.89 2.3 The number of ATMs at Heathrow in 2011 (476 000) virtually reached the forecast maximum number of ATMs per year (480 000) with unbroken segregated mode, while the number of passengers (69 million) was 21 million short of the forecast maximum number of passengers per year (90 million). 2.4 The lack of spare runway capacity at Heathrow with which to manage promptly periodic disruptions to flight schedules (particularly for arriving aircraft) is therefore due to over-scheduling the number of ATMs in particular hours of the day rather than to the number of ATMs exceeding the forecast ATM capacity over the day as a whole. 2.5 Similarly, the passenger capacity bottlenecks at Heathrow have arisen because of the shortfall between the forecast number of passengers per ATM and the actual number of passengers per ATM; not because the actual numbers of ATMs or passengers have exceeded their forecast capacity. 2.6 As regards spare capacity for managing disruption, we consider that the airlines should be given incentives to spread their slots more evenly across the day in order to avoid spikes in the number of slots in particular hours that are vulnerable to disruption. The simultaneous use of both runways for arrivals should be reserved only for the most extreme cases of disruption and not for routine disruption. 2.7 As regards passenger numbers, we estimate that Heathrow’s 90 million passenger capacity would not be fully utilised until 2027 if the airlines increase the number of passengers per ATM to the level envisaged at the Terminal Five Public Inquiry and assuming a similar rate of increase to the annual average since 1991.90 We set out our analysis in more detail in Annex 1 to this response. 2.8 Increased passenger numbers per ATM in the short term could be delivered if the airlines aimed at a higher ratio of passenger numbers to passenger capacity in their existing fleet. The number of seats per ATM at Heathrow averaged at about 200 over each of the last five years, with the number of passengers per ATM in 2011 averaging at 146, a seat capacity use of about 73%.91 There is therefore scope to increase the average number of passengers per ATM, particularly on the most popular routes that are served by many flights per day.92 2.9 Increased passenger numbers per ATM in the medium term could be delivered if the airlines replace much of their existing fleet at Heathrow with aircraft with larger passenger capacities. This would not mean switching every aircraft to Jumbo size; but it would mean more aircraft with seats for more than 200 passengers and fewer aircraft with seats for less than 200 passengers.93 This could be done incrementally in line with routine fleet replacement, with the option of code-sharing between airlines to further defray the costs of switching to larger capacity aircraft. 88 Surface access to and from the airport is also a consideration, which we address in response to Question 2 (c). 89 See report from the Terminal Five Public Inquiry to the Secretary of State for Transport. 90 Assuming also the continued disproportionate growth in transfer passengers at Heathrow and no loss of terminating passengers from Heathrow to other London airports or to airports in other UK regions. We consider transfer passengers in response to Question 4 (a). 91 Data from the Civil Aviation Authority and Airports Co-ordination Limited websites. 92 Our analysis—incomplete at the time of preparing this response—suggests that the ratio of passenger numbers to passenger capacity is lower on the most popular routes from Heathrow than the aggregated ratio on all routes from Heathrow. 93 At present about 65 per cent of ATMs at Heathrow have a passenger capacity of less than 200 seats (data from Airports Co- ordination Limited website). cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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2.10 More passengers per ATM would enable the same number of passengers to be carried in fewer daily movements, particularly on the most popular routes, which in turn would free up slots for new destinations. 2.11 It is not clear why market forces and the rules of supply and demand—congestion pressures at Heathrow and competition between the airlines—have not resulted in larger passenger numbers per ATM. But carrying more passengers per ATM would create unused slots that would have to be surrendered without compensation under the European Union “use it or lose it” rule. The airlines may wish to retain the slots that they currently hold in order to open new routes in the future; or in order to keep competing airlines out; or in order to sell slots at their most lucrative value.94

Other London Airports 2.12 We consider that better co-ordinated use could be made of London’s ﬁve main airports (Heathrow, Gatwick, Stansted, Luton and London City). In particular consideration should be given to the reintroduction of air trafﬁc distribution rules for the most popular destinations in order to reduce the number of ATMs to those destinations (by increasing the number of passengers per ATM). This rationalisation would free up slots for new destinations.

2 (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? 2.13 Congestion at Heathrow and at London’s other main airports is due in part to the continued dependence of the other regions of the United Kingdom on South East England for international aviation connections. We welcome any initiatives to increase the number of direct international services at airports in the other regions in order to reduce the number of domestic terminating and transferring passengers at Heathrow. For example, the development of improved surface access to airports within each region should not lag behind the development of improved surface access from other regions to airports in South East England. 2.14 It might be helpful to commission a comparative study of the UK regions: to what extent can regional economic differences be attributed to the abundance or scarcity of aviation in each region? How does the international connectivity of major airports outside the South East (eg Manchester and Glasgow/Edinburgh) compare with airports in some of the smaller EU countries with similar population sizes to the UK regions?

2 (c). How can surface access to airports be improved? 2.15 Heathrow has spare capacity to handle an additional 21 million passengers per year (see paragraph above). Assuming a continuation of the ratio of two terminating passengers to one transferring passenger (a ratio that has been roughly constant at Heathrow since the mid 1990s) then there would be an additional 14 million terminating passengers per year at Heathrow by the time that its passenger capacity is fully utilised. How would those additional 14 million passengers get surface access to Heathrow? 2.16 The table in Annex 2 to this response sets out the different modes of transport that have been used by terminating passengers for surface access to Heathrow between 1972 and 2010. In 2010 (the most recent year for which the detailed data was available at the time of drafting this response) 30.8 million passengers accessed by road (private car, hire car, taxi/minicab, bus/coach) and 10.8 million passengers accessed by rail (including underground), a ratio of three road accesses to one rail access that has been roughly constant at Heathrow since the opening of the Paddington connection in 2000 (prior to 2000 the ratio was 4:1). Assuming the future continuation of the 3:1 ratio, 10.5 million of the additional terminating passengers would use road access, an increase in the total number of road access to 41.3 million per year. Increased passenger numbers would in turn increase the quantity of consumer goods and other supplies that are delivered to Heathrow primarily by road. 2.17 The road network around Heathrow already experiences significant levels of road traffic congestion, in part because of the high volume of road traffic to and from Heathrow. In many of these areas the air quality is already poor, with road traffic emissions identified as the main pollutant source. Reducing these related adverse impacts is proving difficult even with the present level of Heathrow access road traffic. If increased terminating passenger numbers stimulate increased Heathrow access road traffic there will be a corresponding increase in the magnitude of the adverse impacts on local road traffic congestion and air quality.

QUESTION 3: WHAT CONSTRAINTS ARE THERE ON INCREASING UK AVIATION CAPACITY? 3 (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? Air Quality 3.1 The Terminal Five Public Inquiry found that the air quality in areas around Heathrow exceeded what were at the time voluntary World Health Organisation (WHO) limit values for exposure to nitrogen dioxide; and that the exceedences would continue in future with or without Terminal Five. By the time the Secretary of 94 The sale value would presumably by higher from a gradual release of spare slots rather than a sudden ﬂooding of the market with all the available spare slots. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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State authorised the development of Terminal Five the WHO limit values had been made mandatory within the European Community, with a deadline for compliance by the end of 2010. 3.2 In paragraphs 77 and 78 of the letter dated 21 November 2001 authorising the development of Terminal Five the Secretary of State took issue with what he regarded as an unduly relaxed attitude towards the prospect of continued nitrogen dioxide exceedences around Heathrow: He [ the Secretary of State ] considers that the Inspector placed too little weight on the European Community law aspects of the air quality issues and he recognises the obligations that Community law imposes on the UK Government … The Secretary of State reaffirms his recognition of the UK Government’s obligations under the EU Directive. It remains the Government’s intention to meet the requirements of the Directive . 3.3 But compliance was not achieved by the end of 2010 and the Government had to apply to the European Commission for an extension for compliance until the end of 2015. With the extended deadline due to expire in just over two years’ time, compliance has still not been achieved. 3.4 Although road traffic in the Heathrow area is considered to be the main source of nitrogen dioxide (and of particulates, another cause of local pollution for which limit values have been set), much of that road traffic is Heathrow bound; and aviation emissions (particularly take offs) make an additional contribution to the overall nitrogen dioxide and particulate levels. Any significant increase in passenger numbers using road access in future would make compliance with the limit values even more difficult. 3.5 Quite apart from the legal obligations on the Government to comply with the EU Directive, the nitrogen dioxide and particulate levels pose a health threat to adults living and working near Heathrow and to children living and attending schools near Heathrow. Recent research by the Massachusetts Institute of Technology has confirmed the health risks from air pollution in areas around Heathrow.

Air Traffic Noise 3.6 The high nitrogen dioxide levels are restricted to certain areas within the immediate vicinity of Heathrow. Noise from air traffic extends over a much wider area, several miles to the east and west of the airport to those communities over which Heathrow’s arrival and departure flight paths are routed. 3.7 The harmonised mapping of air traffic noise around major EU airports—undertaken in compliance with Directive 2002/49/EC on the assessment and management of environmental noise—demonstrates that noise from Heathrow air traffic affects more people in the day-evening and night periods than at any other major EU airport. 3.8 Although the noisiest classes of aircraft have been phased out at Heathrow the recent noise trends are not encouraging: — Day and evening period (0700–2300) The size of the air traffic noise contour shrank by 50% between 1991 and 2001 but the rate of shrinkage has been much slower since 2001. The number of aircraft movements (ie the number of individual noise events) increased by 26% in 2011 compared with 1991 (see Annex 3 to this response for fuller details). — Night noise quota period (2330–0600) The number of aircraft movements increased between winter 1993/4 and summer 2011 but by a much lower percentage than the day and evening period. The noise per movement has not reduced to the same extent as in the day and evening period, as judged by the total number of night noise quota points used and the number of quota points per movement (see Annex 4 to this response for fuller detail). — Night shoulder periods (2300–2330 and 0600–0700) The number of aircraft movements has increased compared with the situation in the early 1990s, with an average 40 arrivals and 17 departures per night in 2010 (figures for 2011 not yet available). 3.9 Turning to Heathrow’s noise climate in the future, the Department of Transport is proposing to introduce a “noise envelope” at any new hub airport or at any other airport development which is a nationally significant infrastructure project. It is not clear whether a noise envelope would apply at Heathrow if Heathrow was selected for hub expansion (ie not a new hub airport) or if hub expansion is to take place elsewhere. But in either event we are deeply suspicious of a noise envelope. 3.10 The basis of our suspicion is that the noise envelope would apparently be based on limiting the size of the 57 decibel air traffic noise contour over 16 hours (0700–2300). A similar restriction already applies at Heathrow as a planning condition for Terminal Five, but the size of the permitted contour is so large that it has not provided any incentive to introduce quieter aircraft. The Planning Inspector at the Terminal Five Public Inquiry had severe reservations about the Department’s preferred method of assessing the impact of noise levels, which would form the basis for assessing compliance with the contour limit. For those reasons he recommended the setting of a 480 000 limit on the number of air transport movements per year at Heathrow. The Secretary of State accepted the Inspector’s reservations about noise assessment and imposed the 480 000 limit as a planning condition for Terminal Five. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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3.11 We also have concerns about how the noise envelope would apply to the night period. Again, the precedents are not good. The original restrictions on night ﬂights at Heathrow excluded the noisiest classes of aircraft and imposed a limit on the number of movements by other aircraft. But the last Administration attempted to abolish the limit on the number of movements in favour of sole reliance on a noise quota allowance (in effect a sort of noise envelope) which would have enabled the number of movements in the night period to increase provided that their individual and collective noise levels did not exceed the quota allowance. Again, the noise quotas have been too lax to produce any signiﬁcant reduction in night noise at Heathrow.

3.12 In our view the only way to reduce the noise from air trafﬁc in the day and evening periods is to set ever-tightening noise standards with which aircraft must comply within a reasonable deadline. That is how the dramatic reductions in the noise contour in the 1990s at Heathrow were delivered. The ultimate objective must be to ensure that the noise levels at Heathrow and other airports do not exceed the guideline values recommended by the World Health Organisation. As regards air trafﬁc arriving or departing in the night period, we consider that the only solution is a blanket prohibition 2300–0700 which could be delivered by increasing the number of passengers per aircraft movement: see our response to Question 2 (a) above.

QUESTION 4: DO WE NEED A STEP-CHANGE IN UK AVIATION CAPACITY? WHY?

4 (a). What should this step-change be? Should there be a new hub airport? Where?

4.1 Air passenger numbers are forecast to increase by a factor of two or three over the next ﬁfty years. Many argue that in order to handle the passenger growth new runways need to be built in South East England, with at least one of the new runways dedicated to maintaining a hub capacity in the South East. But there are widely diverging views as to where the new runways should be built; or to what the best option is for maintaining a hub capacity.

4.2 We accept that passenger numbers are likely to increase significantly. But we consider that the additional capacity could be delivered through primarily through larger passenger numbers per aircraft movement and with better co-ordination of services at London’s five main airports (Heathrow, Gatwick, Stansted, Luton and London City) without the need for additional runways and the implied significant increase in the number of aircraft movements. We also consider that the sheer increase in passenger numbers in future should result in more demand for point to point services, with less demand for transfer services and a reduced role for hubs.

4.3 We commented in paragraph 2.2 above that airport passenger capacity is determined by three parameters: runway capacity, terminal capacity and aircraft capacity. We are surprised that the debate about future capacity needs in South East England has got bogged down in acrimony about the need for additional runways, to the exclusion of any debate about aircraft capacity. In our view enhancing and utilising aircraft capacity is inherently less divisive and less costly than building additional runways.

4.4 We argued in paragraphs 2.5 and 2.7 above that the apparent bottleneck in passenger capacity at Heathrow is due to the shortfall between the forecast and the actual number of passengers per aircraft movement; and that the capacity could be fully utilised within the existing limit on the number of aircraft movements and in unbroken segregated mode by increasing the number of passengers per movement. Delivering that increase at Heathrow would become easier if the same objective was adopted for London’s other main airports (Gatwick, Stansted, Luton and London City), with the additional beneﬁt that additional passenger capacity would become available at all the airports, not just at Heathrow.

4.5 Between 1977 and 1991 traffic distribution rules were in operation at Heathrow and Gatwick in order to ease congestion at Heathrow and to assist the development of Gatwick. None of London’s five main airports needs assistance in their development now, but the consequence of past development has been that many of the most popular destinations are now served by three or more of the airports. There may be a case for introducing new traffic distribution rules across the region in order to promote larger passenger numbers per movement but with an overall reduction in the number of movements to the most popular destinations, thereby freeing up capacity across London for additional routes. Again, this option is likely to be less contentious than building new runways.

4.6 Turning from capacity across London to hub capacity, the term “hub” was first applied to airports in the United States, where numerous hub airports are graded according to their share of overall air traffic at all US airports. A key feature of the US hub model is the use of four runways, two central long runways with a short runway either side. There is no UK definition of a hub airport, but the designation is reserved for Heathrow with its two runways. Those who argue for a short third runway at Heathrow to the north of the existing two long runways in order to maintain its hub status need to explain for how long a third runway would maintain hub status before a fourth runway would be needed (and where it would be located) bearing in mind not just the US four runway hub model but also the presence of four runways at Paris and Frankfurt and five runways at Amsterdam, with all of whom Heathrow is said to be in competition for transfer passengers. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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4.7 The value of transfer passengers is said to be that they enable hub airports to serve a wider range of destinations with a greater frequency of service than would be economically viable if the hub handled only terminating passengers. But that win-win argument has broken down at Heathrow. In the period since 1991 the number of transfers at Heathrow has increased in absolute numbers and at a faster rate than the number of terminating passengers but Heathrow served fewer destinations in 2011 than it did in 1991.95 Over the same period of time the number of aircraft movements at Heathrow increased from 362 000 in 1991 to 476 000 in 2011. It would seem that the only impact of the disproportionate growth in transfers at Heathrow over the last twenty years has been to increase the number of movements to destinations for which there was already a high demand from terminating passengers. As a result Heathrow is now more congested and serves fewer destinations than Gatwick96 even though Gatwick handles half the total number of passengers at Heathrow with far fewer transfers proportionately and in absolute numbers than Heathrow. 4.8 In the early days of civil aviation there were relatively few passengers and transferring at hubs would have been the only economically viable option between low demand destinations. But passengers are likely to prefer to fly direct to their ultimate destination if given the choice, because direct flights should be quicker and cheaper than transferring at a hub. It might therefore have been expected that the growth in passenger numbers over the last fifty years would have resulted in a decline in the number of transfers and a corresponding increase in the number of terminating passengers; and that the projected growth in passenger numbers in future should further increase the demand for direct flights and reduce the demand for transfers and the need for ever-larger hub airports.

4 (b). What are the costs and benefits of these different ways to increase UK aviation capacity? 4.9 New runways in South East England would be controversial and would take several years to build even assuming that political support could be guaranteed. The building costs would be significant and would be “up front” for the airport owners, with the return on investment deferred for many years. 4.10 Larger passenger numbers per aircraft would not be controversial and could begin immediately at little cost. The airlines would have to switch larger aircraft over the medium term. But this could be done incrementally and in line with the routine fleet replacement. Costs could be further defrayed by increased code- sharing between airlines. 4.11 Surface access to airports is likely to become a more significant problem than it already is, regardless of which capacity-enhancing option is adopted, due to the sheer number of passengers accessing major airports in future. 4.12 Larger passenger numbers per aircraft is likely to be significantly less damaging to the environment than new runways, which would involve a large increase in the number of aircraft movements. 4.13 Making better co-ordinated use of London’s main airports would reduce the risk that over-development at any one airport would worsen what are already adverse environmental hot spots. 19 October 2012

Annex 1 HEATHROW: NUMBER OF PASSENGERS PER MOVEMENT 1991–2011 Years Passengers Movements Average per movement (millions) % (thousands) % %

1991 40.3 100.0 362 100.0 111.3 100.0 1992 45.0 111.7 388 107.2 116.0 104.2 1993 47.6 118.1 396 109.4 120.2 108.0 1994 51.4 127.5 412 113.8 124.8 112.1 1995 54.1 134.2 421 116.3 128.5 115.5

1996 55.7 138.2 428 118.2 130.1 116.9 1997 57.9 143.7 431 119.1 134.3 120.7 1998 60.4 149.9 442 122.1 136.7 122.8 1999 62.0 153.8 451 124.6 137.5 123.5 2000 64.3 159.6 460 127.1 139.8 125.6

2001 60.5 150.1 458 126.5 132.1 118.7 2002 63.0 156.3 460 127.1 137.0 123.1 2003 63.2 156.8 457 126.2 138.3 124.3 2004 67.1 166.5 470 129.8 142.8 128.3 2005 67.7 168.0 472 130.4 143.4 128.8 95 See Annexes 5 and 6 to this response for fuller details of destinations and transfer passengers at Heathrow. 96 According to their respective websites. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Years Passengers Movements Average per movement (millions) % (thousands) % %

2006 67.3 167.0 471 130.1 142.9 128.4 2007 67.9 168.5 476 131.5 142.6 128.1 2008 66.9 166.0 473 130.7 141.4 127.0 2009 65.9 163.5 460 127.1 143.3 128.8 2010 65.8 163.3 449 124.0 146.6 131.5

2011 69.4 172.2 476 131.5 145.8 131.0 Source: Civil Aviation Authority, UK Airport Statistics Notes: The source gives the number of passengers and air transport movements, from which the number of passengers per movement have been calculated. The percentage columns are calculated from 1991 as the base year. There are minor discrepancies in the passenger numbers given in UK Airport Statistics compared with the Civil Aviation Authority’s Air Passenger Surveys. The Air Passenger Surveys are published later in the year than UK Airport Statistics and presumably contain the more accurate data. But the Air Passenger Surveys have been published annually for Heathrow only since 1996, so UK Airport Statistics have been used to compile this table. Comment: The report to the Secretary of State on the Heathrow Terminal Five Public Inquiry advised that Heathrow would have an annual runway capacity of 480 000 air transport movements operating in unbroken segregated mode and would be able to handle 90 million passengers per year with Terminal Five fully operational. 480 000 movements carrying 90 million passengers is equivalent to an annual average of 187.5 passengers per movement. The number of air transport movements (ATMs) per year increased from 362 000 in 1991 to 476 000 in 2011, an increase over twenty years of 114 000 ATMs (31.5%). At the end of 2011 there was spare capacity to handle a further 4 000 ATMs per year (ie 480 000 less 476 000). The rate of increase in the number of ATMs between 1991 and 2011 was equivalent to an average annual increase of approximately 5 700. If the same rate of increase continues, the 4 000 spare capacity would be fully utilised by late 2012. The number of passengers per year increased from 40.3 million in 1991 to 69.4 million in 2011, an increase over twenty years of 29.1 million (72.2%). At the end of 2011 there was spare capacity to handle a further 20.6 million passengers per year (ie 90 million less 69.4 million). The rate of increase in the number of passengers between 1991 and 2011 was equivalent to an average annual increase of approximately 1.45 million. If the same rate of increase continues, the 20.6 million spare capacity would be fully utilised by early 2027. The average number of passengers per movement increased from 111.3 in 1991 to 145.8 in 2011, an increase over twenty years of 34.5 passengers per movement (31.0%). At the end of 2011 there was spare capacity—as implied by the ﬁndings of the Terminal Five Public Inquiry—to handle a further 41.7 passengers per movement (ie 187.5 less 145.8). The rate of increase in the number of passengers per movement between 1991 and 2011 was equivalent to an average annual increase of approximately 1.7 passengers. If the same rate of increase continues, the 41.7 spare capacity would be fully utilised by early 2036. In view of the legal limit of 480 000 on the permitted number of ATMs per year and the impending arrival at that number of ATMs, the only way that Heathrow can make full use of its 90 million annual passenger- handling capacity is to increase signiﬁcantly the number of passengers per ATM.

Annex 2 HEATHROW: PASSENGER NUMBERS PER TRANSPORT MODE FOR SURFACE ACCESS 1972–2010 Year Car/taxi Bus/coach Tube/rail Other Total millions % millions % millions % millions % millions %

1972 - 59 - 32 - 0 - 2 14.3 93 1978 - 63 - 14 - 20 - 1 20.8 98

1984 14.9 66 3.3 14 4.5 20 0.2 1 22.6 101 1987 17.2 64 4.0 15 5.4 20 0.2 1 26.8 100

1991 19.7 66 3.9 13 6.0 20 0.2 1 29.8 100

1996 25.0 67 6.0 16 6.0 16 0.3 1 37.3 100 1997 25.3 66 6.2 16 6.6 17 0.4 1 38.5 1998 27.2 67 5.7 14 6.3 18 0.4 1 40.6 cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Year Car/taxi Bus/coach Tube/rail Other Total millions % millions % millions % millions % millions % 1999 2000 28.4 63.7 6.2 13.9 9.8 22.1 0.3 0.4 44.6

2001 26.6 64.7 5.4 13.1 8.9 21.5 0.3 0.7 41.2 100 2002 25.9 65.3 4.9 12.3 8.8 22.1 0.1 0.3 39.7 2003 25.9 64.3 5.1 12.6 9.2 22.9 0.2 0.3 40.2 2004 27.8 63.7 5.4 12.4 10.2 23.5 0.3 0.3 43.6 2005 27.3 62.7 5.7 13.0 10.4 23.9 0.2 0.4 43.6

2006 28.5 64.4 5.8 13.1 9.9 22.9 0.0 0.0 44.2 100 2007 27.2 61.5 5.8 13.2 11.0 24.9 0.1 0.3 44.1 2008 25.7 59.8 6.1 14.1 11.1 25.7 0.1 0.3 43.0 2009 24.5 59.6 5.7 14.0 10.6 26.0 0.2 0.5 40.9 2010 25.2 60.5 5.6 13.4 10.8 25.9 0.1 0.3 41.7 Source: Civil Aviation Authority Passenger Survey Reports. The surveys have been undertaken annually from 1996 at Heathrow; at less frequent intervals before 1996. The report for 1999 had not been consulted at the time of preparing the table. Notes: The reports indicate the use of each mode of transport shown in the table97 as a percentage98 of the total number of terminating passengers.99 The reports from 2007 onwards indicate the percentage use of private, public and other surface modes of transport. The number of passengers using each mode has been calculated by applying the individual percentages to the total number of terminating passengers in each year from 1984 onwards100 The column car/taxi includes private hire cars and minicabs.

Annex 3 HEATHROW: AIRCRAFT MOVEMENTS AND 16-HOUR (0700–2300) NOISE EXPOSURE CONTOURS: 1991–2011 Years Number of aircraft movements Size of 57 dBA contour calendar year 24-hours 16-hours km² % 000s %

1991 382 (362) 100.0 1 046.6 - 234.9 100.0 1992 406 (388) 106.3 1 109.2 - 204.0 86.8 1993 411 (396) 107.6 1 126.0 - 182.3 77.6 1994 425 (412) 111.3 1 164.4 - 175.5 74.7 1995 435 (421) 113.9 1 191.8 - 169.2 72.0

1996 440 (428) 115.2 1 202.2 1 178.4 164.7 70.1 1997 441 (431) 115.4 1 208.2 1 167.0 158.3 67.4 1998 451 (442) 118.1 1 235.6 1 206.1 163.7 69.7 1999 458 (451) 119.9 1 254.8 1 215.5 155.6 66.2 2000 467 (460) 122.3 1 276.0 1 236.3 135.6 57.7

2001 464 (458) 121.5 1 271.2 1 237.7 117.4 50.0 2002 467 (460) 122.3 1 279.4 1 243.2 126.9 54.0 2003 464 (457) 121.5 1 271.2 1 232.2 126.9 54.0 2004 476 (470) 124.6 1 300.5 1 263.0 117.4 50.0 2005 478 (472) 125.1 1 309.7 1 248.7 117.2 49.9

2006 477 (471) 124.9 1 306.8 1 248.0 117.4 50.0 2007 481 (476) 125.9 1 317.8 1 258.2 119.6 50.9 2008 479 (473) 125.4 1 308.7 1 264.8 123.1 52.4 2009 466 (460) 122.0 1 276.7 1 230.5 112.5 47.9 2010 455 (449) 119.1 1 246.6 1 263.8 108.3 46.1 97 The reports since 2007 indicate the percentage use of public, private and other surface modes of transport, but not the percentages for the individual modes of transport published in the reports prior to 2007. The percentages for the individual modes since 2007 have been supplied by BAA Heathrow to the local authorities. 98 Rounded percentages prior to 2000, percentages to one decimal point since 2000. The individual percentages for 1972, 1978 and 1984 sum to 93 per cent, 98 per cent and 101 per cent respectively. For the subsequent years, the individual percentages sum to 100 per cent (or to one decimal point for 2000, 2003 and 2004). 99 Transfer passengers are excluded because they do not arrive at or depart from Heathrow by surface transport. 100 1972 and 1978 are excluded because the data are evidently incomplete for those years—see footnote 2. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Years Number of aircraft movements Size of 57 dBA contour calendar year 24-hours 16-hours km² % 000s %

2011 481 (476) 125.9 1 317.8 1 268.6 108.8 46.3 Sources: Civil Aviation Authority: UK Airport—Movement, Passenger and Cargo Statistics for the number of aircraft movements per year. The number of aircraft movements per 24-hour day (Jan to Dec) have been calculated from the number of movements per year. Civil Aviation Authority: Noise Exposure Contours for Heathrow Airport for the size of the noise contour and the number of aircraft movements per 16-hour day (mid-June to mid-Sept). At the time of compiling the table the number of movements had not been identified for the years 1991–1995. Notes: The percentage columns for the number of aircraft movements per year and for the size of the air traffic noise exposure contour take 1991 as the base year for observing the extent of subsequent changes. The numbers marked in bold indicate the years in which there was a reversal in the prevailing trend compared with the preceding year (an increase in the number of aircraft movements and a decrease in the size of the air traffic noise exposure contour—see comments below). The numbers in brackets in the column for the number of aircraft movements per year are the numbers of air transport movements (ie engaged in the transport of passengers, cargo or mail). Comment: The general trends (0700–2300 hours) have been for an increase in the number of aircraft movements in parallel with a decrease in size in the air traffic noise exposure contour. These trends were most pronounced and were continuous in virtually every year 1991–2001. The trends have been flatter since 2001, with several years showing a reversal in the trend for the number of movements or for the contour size; or for both.

Annex 4 HEATHROW: AIRCRAFT MOVEMENTS AND NOISE QUOTA POINTS IN THE NIGHT QUOTA PERIOD (2330–0600) WINTER SEASONS 1993/4–2010/11 Number of aircraft Seasons movements Number of noise quota points used total points used points per movement %%%

1993–94 2 352 100.0 4 384 100.0 1.86 100.0 1994–95 2 668 113.4 5 020 114.5 1.88 101.1

1995–96 2 751 117.0 4 760 108.6 1.73 93.0 1996–97 2 525 107.4 3 901 89.0 1.54 82.8 1997–98 2 446 104.0 3 858 88.0 1.58 85.0 1998–99 2 688 114.3 4 423 100.9 1.65 88.7 1999–2000 2 529 107.5 3 972 90.6 1.57 84.4

2000–01 2 615 111.2 4 118 93.9 1.57 84.4 2001–02 2 684 114.1 4 257 97.1 1.59 85.5 2002–03 2 620 111.4 4 316 98.5 1.65 88.7 2003–04 2 683 114.1 4 425 100.9 1.65 88.7 2004–05 2 591 110.2 4 361 99.5 1.68 90.3

2005–06 2 669 113.5 4 355 99.3 1.63 87.6 2006–07 2 659 113.1 4 266 97.3 1.60 86.0 2007–08 2 710 115.2 4 100.25 93.5 1.52 81.7 2008–09 2 715 115.4 3 947.50 90.0 1.45 78.0 2009–10 2 686 114.2 3 863.25 88.1 1.44 77.4

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SUMMER SEASONS 1994–2011 Number of aircraft Seasons movements Number of noise quota points used total points used points per movement %%%

1994 2 905 100.0 5 109 100.0 1.76 100.0 1995 2 968 102.2 5 159 101.0 1.74 98.9

1996 2 566 88.3 4 340 85.0 1.69 96.0 1997 2 757 94.9 4 276 83.7 1.55 88.1 1998 2 828 97.4 4 668 91.4 1.65 93.8 1999 3 138 108.0 5 342 104.6 1.70 96.6 2000 3 028 104.2 4 967 97.2 1.64 93.2

2001 2 939 101.2 4 694 91.9 1.60 90.9 2002 2 937 101.1 5 051 98.9 1.72 97.7 2003 2 899 99.8 5 165 101.1 1.78 101.1 2004 2 993 103.0 5 218 102.1 1.74 98.9 2005 2 956 101.8 5 225 102.3 1.77 100.6

2006 3 059 105.3 5 232 102.4 1.71 97.2 2007 3 053 105.1 5 235 102.5 1.72 97.7 2008 2 922 100.6 4 634 90.7 1.59 90.3 2009 2 848 98.0 4 429.25 86.7 1.56 88.6 2010 3 033 104.4 4 504.75 86.2 1.49 84.7

2011 2 958 101.8 4 491 87.9 1.52 86.4 Sources: Department of Transport and BAA Heathrow for the number of aircraft movements and noise quota points used, from which the number of quota points per movement has been calculated. Notes: The percentage columns take winter 1993/4 and summer 1994 as the base seasons for observing the extent of subsequent changes. The numbers marked in bold indicate an increase compared with the previous season.

Annex 5 HEATHROW: NUMBER OF DESTINATIONS IN 1990, 2001 AND 2011 Region 1990 2001 2011

United Kingdom 24 (18) (6) 14 (10) (4) 11 (7) (4)

Western Europe 54 (40) (14) 33 (32) (1) 35 (29) (6)

Central Europe 53 (41) (12) 33 (31) (2) 35 (32) (3)

Eastern Europe 16 (13) (3) 26 (23) (3) 21 (21) (-)

Near East 20 (17) (3) 18 (17) (1) 15 (14) (1)

Africa 29 (24) (5) 24 (21) (3) 23 (23) (-)

Far East 25 (25) (-) 29 (28) (1) 30 (30) (-)

Americas 43 (33) (10) 35 (34) (1) 41 (36) (5)

Totals 264 (211) (53) 212 (196) (16) 211 (192) (19) Source: Civil Aviation Authority, Aviation Statistics, Table 12.1 (International Air Passenger Traffic to and from Reporting Airports) and Table 12.2 (Domestic Air Passenger Traffic to and from Reporting Airports) Notes: The table sets out the number of destinations per listed region served by air transport movements from Heathrow in the years 1990, 2001 and 2011. The first column of numbers is the total number of destinations. The second column of numbers is the number of destinations to which 2 000 or more passengers (arrivals and departures) were transported. The third column of numbers is the number of destinations to which less than 2 000 passengers (arrivals and departures) were transported. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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The number of passengers at Heathrow increased from 45.6 million in 1990 to 60.4 million in 2001 (an increase by 32% compared with 1990), and to 69.4 million in 2011 (an increase by 52% compared with 1990). The number of air transport movements (ATMs) increased from 368 000 in 1990 to 458 000 in 2001 and to 476 000 in 2011. Comment: The table shows that the total number of destinations served by Heathrow decreased by approximately 20% in 2001 compared with 1990, with a further decrease of less than one% in 2011 compared with 2001, despite the increase in the number of ATMs in 2001 and 2011. The number of destinations that carried less than 2 000 passengers in 1990 decreased by approximately 65%. The number of destinations that carried 2 000 or more passengers in 1990 decreased by approximately 5%. The table shows that changes in the number of services to destinations carrying more than 2 000 passengers in 1990 varied between regions, with ﬁve regions experiencing net decreases and three regions experiencing net increases. The largest decreases in destinations served affected the United Kingdom (down from eighteen destinations to seven), Western Europe (down from forty destinations to twenty nine) and Central Europe (down from forty one destinations to thirty two), with smaller decreases in the Near East (down from seventeen destinations to fourteen) and Africa (down from twenty four destinations to twenty three). There were increased services to Eastern Europe (up from thirteen destinations to twenty one), the Far East (up from twenty ﬁve destinations to thirty) and the Americas (up from thirty three destinations to thirty six). Analysis of the individual destinations within the regions served by Heathrow shows variation between regions and within countries, with some destinations closed and others newly opened. The data upon which the table is based indicate that the majority of destinations that are no longer served by Heathrow (eg Antwerp, Corfu, Las Palmas) are now served by one or more of London’s other major airports (Gatwick, Stansted, Luton, London City).

Annex 6 HEATHROW: TERMINATING AND TRANSFER PASSENGERS 1972–2011 Years Terminating passengers Transfer passengers Total passengers (millions) % (millions) % (millions) %

1972 14.3 76.4 4.4 23.6 18.7 100.0 1978 20.8 77.2 6.1 22.9 26.9 1984 22.6 76.6 6.9 23.4 29.5 1987 27.0 76.9 8.1 23.1 35.1 1991 29.8 73.8 10.6 26.2 40.4

1996 37.3 66.8 18.5 33.2 55.8 100.0 1997 38.6 66.6 19.1 33.0 57.9 1998 40.6 67.4 19.6 32.5 60.3 1999 ????? 2000 44.7 70.2 19.0 29.8 63.7

2001 41.1 68.6 18.8 31.4 59.9 100.0 2002 39.6 64.0 22.3 36.0 61.9 2003 40.1 63.7 22.8 36.3 62.9 2004 43.6 65.2 23.3 34.8 66.9 2005 43.6 65.3 23.2 34.7 66.8

2006 44.2 65.9 22.9 34.1 67.1 100.0 2007 44.0 65.8 22.9 34.2 66.9 2008 43.2 64.6 23.6 35.3 66.8 2009 40.9 62.1 24.9 37.9 65.8 2010 42.2 64.2 23.5 35.8 65.7

2011 45.9 66.4 23.3 33.6 69.2 100.0 Source: Civil Aviation Authority Passenger Surveys Reports.101 Where the totals do not sum this is due to rounding. At the time of preparing the table the Report for 1999 had not been consulted. The Reports for the years 1972 to 1998 give the number of terminating and transfer passengers only as percentages of the annual total number of passengers. The numbers in the table for the years to 1998 have therefore been calculated from the percentages and the total number. 101 The surveys have been undertaken annually at Heathrow since 1996, and at less frequent intervals prior to 1996. At the time this table was prepared the report for 2011 had not been published. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Comment: The table shows consistent growth in the total number of passengers at Heathrow between 1972 and 2004, with stabilisation between 2004 and 2010 and renewed growth in 2011. Within this overall growth there were increases in the absolute number of terminating and transferring passengers throughout the period. But since 1991 the rate of growth has been faster among transfers, who have accounted for one or more passengers in three since 2002 compared with less than one passenger in four prior to 1991. The number of air transport movements (ATMs) at Heathrow increased from 362 000 in 1991 to 476 000 in 2011. The large number of transfer passengers increase the present levels of congestion at Heathrow. It is argued that transfers enable the airlines at Heathrow to serve a wider range of destinations than would be economically viable with only terminating passengers. But the period of exponential growth in transfers since 1991 coincided with a fall—rather than an implied increase—in the number of destinations served by Heathrow (see separate table for details). The impact of the additional transfer passengers since 1991 may therefore have been limited to inﬂating the number of ATMs to destinations for which there was already a high demand from terminating passengers.

Written evidence from NetJets Europe (AS 77) 1. Summary 1.1 NetJets Europe was founded in 1996 and today is the leading business aviation company in Europe. 1.2 With over 130 aircraft, NetJets Europe operates four times as many aircraft as the next largest business aviation company and ﬂies to hundreds of airports around the world. 1.3 Business clients make up around 80% of our customer base, with NetJets Europe customers including CEOs of FTSE 100 companies. 1.4 NetJets Europe welcomes the Transport Select Committee’s inquiry into the Government’s aviation strategy. We are pleased to set out in this submission our responses to the topics where we believe we can offer the most helpful view to the Committee, rather than addressing each question one by one. We would be happy to provide further details. 1.5 Key points include: — Primary objective of aviation strategy is to achieve sustainable, long-term economic growth. — Maintaining and growing connectivity is essential for the UK to be able to access key markets. — Business aviation plays a vital role in complementing the scheduled network. — Destinations must be connected by air transport links in a way that is convenient for the user. — Any steps to limit access to smaller aircraft at the busiest airports must take account of the crucial economic role of business aviation in supporting connectivity.

2. Introduction 2.1 We welcome the Government’s commitment to the development of a long-term aviation strategy, which will help to underpin long-term, sustainable economic growth. 2.2 The Government’s aviation strategy should consider the unique role of business aviation, which is not widely understood by policymakers. Indeed, it is frequently grouped together with “general aviation”, which represents more than 90% of the civil aircraft registered in the country,102 including in the draft aviation framework.103 2.3 As the name implies, and as published by in a recent report by Oxford Economics,104 “business aviation is devoted to the needs of commerce” and is predominately used by business leaders who are helping to drive economic growth. We call on the Government to clearly delineate between business and general aviation. 2.4 Business aviation plays a unique and complementary role in servicing demand and connecting the UK to destinations that are not commercially viable for scheduled carriers. As such, its attributes and features must not be overlooked by policymakers.

3. What should be the objectives of Government policy on aviation (question one)? 3.1 NetJets Europe agrees with the Government’s draft aviation framework that “a primary objective is to achieve long term economic growth”.105 We support the Committee’s focus on connectivity; as the draft aviation framework notes: “the UK must be able to able to connect with the countries and locations that are of most beneﬁt to our economy”.106 102 According to the British Business and General Aviation Association (BBGA) 103 Section 2.6 of the draft aviation framework 104 Oxford Economics: The Role of Business Aviation in the European Economy (October 2012) 105 Section 1.1 of the draft aviation framework 106 Section 2.2 of the draft aviation framework cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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3.2 While we are pleased to see connectivity referenced in the inquiry’s terms of reference (1a), we urge the Committee to consider the vital link between connectivity and flexibility. Destinations must be connected by links that are convenient for the user. 3.3 For business aviation users, flexibility and responsiveness are vital, and in many instances a business necessity. As a 2012 report by Mergermarket found, approximately two-thirds of executives believe that face- to-face meetings are crucial in completing M&A deals.107 Business aviation plays a crucial role in maintaining and enhancing UK business connectivity, by complementing the scheduled network. As Oxford Economics noted, users are able to fly multi-legged journeys that are either not covered by the scheduled network or would require significant delays between trips.108 3.4 This degree of flexibility makes business aviation very different from the scheduled network. As Oxford Economics found,109 the scheduled network provides “thick connectivity”, based on economies of scale and concentrated at major cities, while business aviation offers “thin connectivity”, carrying a low volume of passengers between a much larger number of destinations. 3.5 The importance of this “thin connectivity” is highlighted by the fact that, in 2011, business aviation connected 88,800 European city pairs. Of these 88,800 city pairs, 96% do not have a daily scheduled connection.110 This contrasts with the 360 international destinations served from the UK by scheduled airlines as noted in the framework.111

Economic benefits of aviation 3.6 The economic impact of aviation is increasingly understood—as the draft aviation framework recognises, the sector contributes £17 billion of economic output and employs 220,000 people directly.112 However, the significant economic contribution of business aviation is often less understood by policymakers. A PricewaterhouseCoopers study113 into the direct contribution of business aviation to the European economy found that, in the UK, business aviation generates €4.2 billion of Gross Value Added (GVA), and supports almost 50,000 full-time jobs. 3.7 As the draft aviation framework has found, economic growth is increasingly dependent on links to emerging markets and business aviation does and can continue to help in achieving enhanced access to markets and new business opportunities across the globe. In 2011 there were almost 49,000 business aviation flights between Europe and emerging economies outside Europe.114

4. How should we make the best use of existing aviation capacity (question two)? 4.1 As the draft aviation framework acknowledges,115 we face a medium to long term capacity challenge, particularly in the South East. Consequently opportunities to introduce new direct routes to growing markets will be severely limited. While such destinations could be accessed indirectly through other hubs, this would involve time and flexibility penalties; as a result, the complementary service offered to the scheduled routes by business aviation is likely to be even more crucial if the UK is to maintain the business connectivity it needs. The recent growth in flights to emerging markets demonstrates the potential for business aviation to facilitate both inward and outward investment as well as the export opportunities that the rebalancing of the UK economy demands.116 4.2 NetJets Europe is concerned by proposals within the draft aviation framework that the Government will in principle support non-discriminatory steps that aircraft operators may wish to take to limit access to smaller aircraft at the busiest airports.117 4.3 Central to this should be a consideration of the unique role played by business aviation. Any consideration about limiting access to business aviation must recognise its crucial role in supporting connectivity, its ability to fill in the gaps of the scheduled network and its essential economic role. This is especially important given the shortage of capacity in the South East, which is not likely to be alleviated in the short to medium term. 4.4 Business aviation passengers travelling from the regions use companies like NetJets because of the ability to avoid congested airports, either locally or in the south east with flights times to serve their business needs. This is an excellent example of where business aviation differs significantly in its business model from commercial aviation, which serves a distinct market based on scheduled flights. Equally, business aviation clients need to access larger airports, including busy hubs, meaning continued access to such airports is vital. 107 Mergermarket: Doing the Deal (2012) 108 Oxford Economics: The Role of Business Aviation in the European Economy (October 2012) 109 Oxford Economics: The Role of Business Aviation in the European Economy (October 2012) 110 Oxford Economics: The Role of Business Aviation in the European Economy (October 2012) 111 Section 2.17 of the draft aviation framework 112 Section 1.8 of the draft aviation framework 113 PricewaterhouseCoopers: The Economic Impact of Business Aviation in Europe (2008) 114 Oxford Economics: The Role of Business Aviation in the European Economy (October 2012) 115 Section 1.12 of the draft aviation framework 116 Oxford Economics: The Role of Business Aviation in the European Economy (October 2012) 117 Section 2.36 of the draft aviation framework cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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4.5 Within the South East, NetJets Europe makes signiﬁcant use of smaller airports where possible. These include Farnborough and Biggin Hill. However, for business aviation users working in London, who are likely to be key decision-makers on high value-added trips, access to London City and Luton remain crucial (see 4.6 and 4.7 below). 4.6 As the draft aviation framework recognises,118 access to congested airports in the UK is regulated through the European Commission and a revision of the existing regulation is currently taking place. 4.7 Historically, business aviation has been the ﬁrst to be excluded from airports when capacity becomes tight. Given the importance of the UK as a leading market for business aviation within the EU, NetJets Europe believes that the Government must work with other Member States to ensure fair access for business aviation to congested airports. 4.8 Regarding RAF Northolt this is an important airport for business aviation access to London, currently accounting for some 10% of business aviation movements into and out of London. Furthermore prospects for business aviation growth at other London airports are likely to be limited as London City and Luton are coordinated airports and Farnborough is subject to a movements cap. We are therefore concerned about suggestions that RAF Northolt could be closed to business aviation and used as a satellite airport for Heathrow. As well as reducing already limited business aviation access to London, we believe this proposal faces insurmountable operational and logistical challenges.

5. What constraints are there on increasing UK aviation capacity (question three)? 5.1 Within this section, the committee has asked how aviation can be made more sustainable (3b). As a leader in the ﬁeld, NetJets Europe feels a profound responsibility to minimise the environmental impact of air travel and we are on course to be entirely carbon neutral by 2012 through a carbon offsetting scheme for our passengers. Additionally, NetJets Europe is developing in-house expertise and operational capabilities to be able to use lower carbon fuels as the market matures. 19 October 2012

Written evidence from SPAA (AS 78) Introduction Established in 1921. the Scottish Passenger Agents Association (SPAA) is the world’s oldest travel trade association. Today the SPAA is Scotland’s largest travel trade association and represents the interests of Scotland’s major corporate & leisure travel agents, working alongside our Associate Members, which include many of the world’s leading airlines, tour operators and cruise lines together with Edinburgh & Glasgow Airport. Each of these sectors within the industry has an interest in aviation issues which are relevant to their customers who in turn become customers of the airlines and airports, plus ground arrangers, within the UK.

1. What should be the objectives of Government policy on aviation? The SPAA feels that the single largest constraint inhibiting growth within the aviation sector is the absence of a coherent, cross party aviation policy framework. The Government needs to agree a cross party policy which facilitates the conditions for airlines and airports to meet aviation demands in a sustainable manner. This continued lack of a coherent policy is damaging the UK, and needs to be rectiﬁed in a timely manner, otherwise much needed inward investment may be delayed if not lost completely to the UK economy. The UK is lagging in comparison to the progress made in aviation development by our European competitors and the creation of a coherent cross party policy is absolutely essential for the creation of long term projects, route development, world connectivity, passenger choice, if the UK wants to maintain and improve its position on the world stage.

1.1 How important is international aviation connectivity to the UK aviation industry? The aviation sector is of a vital strategic importance for the future competitiveness & economic prosperity of this country combining opportunities for inward investment, employment, tourism and much more.

1.2 What are the benefits of aviation to the UK economy? The economic benefits that a healthy aviation sector brings are enormous, affecting a wide range of sectors generating growth of employment, growth of inbound tourism, bringing benefits for inward investment as well as creating opportunities to do business with the rest of the world and particularly with the emerging BRIC markets. In the budget in April, the Government recognised the need to expand air capacity in the South East but has now again ruled out further expansion at Heathrow and produced no real viable alternative. There is an 118 Section 2.49–2.52 of the draft aviation framework cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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extremely urgent need for immediate expansion to maintain London as a global hub as our neighbours in Amsterdam, Frankfurt and Paris continue to grow. Through investment in additional runway capacity and infrastructure they are able to attract more ﬂights and investment from emerging markets. It is vital to the future of UK trade links from both existing and emerging BRIC markets that the need for increased capacity must be addressed and quickly. We are already losing out in the UK with six Chinese cities who are connected to Frankfurt and ﬁve of these are also connected to Paris but none of them are connected to the UK. We can also see the growing hubs in the Middle East. The SPAA believes that the aviation and tourism markets could help the economy to be strengthened and stabilised but the current suppression on necessary airport expansion and ongoing tax increases will ultimately risk the future of international and regional airport routes and without this connectivity, the UK will become an unattractive destination for investment and for inbound tourism. The Government must address the capacity constraints without delay alongside investment in strategic infrastructure projects to allow future growth and long term economic recovery planning together with creating additional employment. After the great success of the Olympics in London, Scotland is already making plans for the Commonwealth Games in Glasgow in 2014 which is a fantastic opportunity to showcase Scotland. A strong range of connections via a London hub is imperative as well as the inward direct routes from Europe, USA and Dubai and there will be a great reliance on the availability of good Domestic Services.

1.3 What is the impact of Air Passenger Duty on the aviation industry? The level of APD in the UK is the highest level of any other country in Europe and as part of the “Fair Tax on Flying” campaign, we would endorse their message that the level of APD is far too high and say that the UK has been placed in a situation where although the Government are looking to expand our export business and attract inward investment (especially to the emerging markets), it has created a barrier to this growth preventing the UK being able to be competitive in the world arena. The benefits of inbound tourism are being seriously damaged by a combination of the high cost and time taken to obtain a UK visas vs. the Schengen visa where a tourist can travel through 25 countries in Europe on a single visa for less than the cost of a UK visa. We have also heard from our members of many instances when overseas visitors travelling from both the Far East and also USA both as individuals and in groups are now travelling round Europe but missing out the UK due to the high cost of taxes and visas. UK Customers and businesses cannot continue to pay these ongoing increasingly high levels of APD without the corresponding outcome relating to the affordability and competitiveness of British business and the UK economy. Tourism contributed over £110 billion to the UK economy in 2010 and is fundamental to the rebuilding of our economy but current and proposed increases in the levels of APD are threatening the ability for the projected sustainability and growth. In the York Aviation report commissioned by Edinburgh, Glasgow & Aberdeen Airport in 2011 it stated that Scottish Airports would lose up to £77 million in lost tourism spend and 1.2 million passengers over the next three years due to the increases in APD. It also went on to say that Domestic routes would be hit the hardest losing almost 500,000 passengers and threatening the viability of some routes. (Six weeks later bmi withdrew flights from Glasgow to Heathrow.) As Amanda MacMillan, MD of Glasgow Airport commented that Scotland needs a thriving airline industry if it is to compete in Europe, attract more jobs, increase tourism and also investment as well as attracting new routes and maintaining its lifeline services to the Scottish Islands. The current increasing levels of APD are already proving a significant barrier to attracting new routes. There is no question that the ability of Scots to travel for business or leisure will suffer unless there is a fundamental review of APD. APD is now having an impact on businesses in the UK’s major cities. For example, last year the Glasgow City Marketing Bureau said that the city has lost £22 million alone in conference business because of the high levels of Air Passenger Duty (APD), claiming that organisers were opting for cities where flights were cheaper. APD has been branded as a very unpopular stealth tax which also affects families who are now paying the highest levels of aviation tax anywhere in the world whether they are travelling on a well earned holiday within Europe with no reduction for children as there are with the air fares or at an even higher level if they are visiting friends and relatives in places such as Australia. The UK is struggling to compete in the European arena and is at a competitive disadvantage due to its disproportionate levels of taxation which in turn is strangling growth within the aviation sector, investment in the UK and tourism. Other countries in the EU have already realised and acted upon similar taxes after realising the competitive disadvantage this was bringing to their economy by either abolishing this tax as in the Netherlands, where it was recognised that although it raised the equivalent to £266 million in one year, the Dutch calculated the loss to the wider economy from the tax was over £950 million. In Belgium they decided not to implement this tax and In Germany, they reduced it to a much lower level whilst offsetting ETS revenues against it. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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It should also be noted that passengers travelling from Scotland are further penalised by a double APD hit on their ﬂights via London and we would therefore support the possibility of a reduction in regional APD.

1.4 How should improving the passenger experience be reﬂected in the Government’s aviation strategy? The SPAA believe that the Government should produce at the earliest possible time, their framework on sustainable aviation which should then be set up as a cross party aviation group which will be able to consider and implement planning on a short, mid and long term basis. It will only be at this point that projects can be truly planned and executed and delivered on time and consideration can be given to the co-ordination of infrastructure at airports relating to terminals, security , immigration, road & rail connections and car parking which if taken into account would hopefully greatly beneﬁt passengers.

1.5 Where does aviation ﬁt in the overall transport strategy? The SPAA feel that currently a great deal of investment and time has been spent on rail and road improvement and planning but that although there has been a great deal of discussion on aviation, there has been little agreement on the way forward. With changes in Government and subsequent changes in policies & delays in decisions, aviation has suffered and with so many changes in direction the many issues that it is facing have failed to be adequately addressed. It is therefore the opinion of the SPAA that it is essential that a Cross Party Aviation Group be established to create a long term strategy for this sector to allow sustainable planned growth in the short, medium and long term. Aviation is an important part of the UK’s transport strategy, with many parts of the UK are dependent upon aviation as a lifeline, not just for communication purposes but economically eg the Scottish Highlands and Islands, Northern Ireland. It is important to recognise the value of all parts of aviation on the UK economy. The Government’s tourism policy should value all parts of the sector: domestic, inbound and outbound, as should it recognise the mix of aviation models that contribute to the UK’s economy: scheduled, charter, no- frills, leisure, business and cargo. A strategy that promotes one type of ﬂying over another or seeks to downgrade the relative importance of leisure aviation, for instance, should not be considered by the Government as this would fail the UK as a whole.

2. How should we make the best use of existing aviation capacity? 2.1 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? There has been a great deal of recent discussion and argument relating to constraints on capacity in the South East and a number of recommendations and reviews being commissioned. The SPAA acknowledges that this is a positive move but are extremely concerned over the timescales as we feel that we cannot wait for the results of the commissions and that more immediate intermediary action is required and in particular at Heathrow. In the recent APPG Inquiry into Aviation Policy recommendation published in August there was a suggestion of increasing the use of mixed mode landing and taking off at Heathrow, which has been previously trialled and used this year. This would allow an immediate increase in capacity and alleviate further and increasing levels of passenger delays. The latest figures produced in September from both airlines and Heathrow Airport indicates that punctuality levels are slipping which is as a direct result of the lack of capacity. Whilst the SPAA also agrees with the APPG Report that the transference of the 7,000 annual business movement to Farnborough may be helpful, allowing the use of these slots to be used as an opportunity to open up services to BRIC and other emergent countries not currently served from Heathrow, it is far from ideal, and should only be considered as a short term solution. Passenger delays and their airport experience are very important and the SPAA believe that the current level of investment at Heathrow and also Gatwick have benefited the passenger experience, with improved security areas , improvement in loss of baggage, on line check in and a much better terminal experience. The two problem areas that need to be addressed relate to delays in departures/arrivals (often related to capacity problems) but also accessibility to the airport via the existing transport infrastructure. Gatwick is well served with its rail connection but Heathrow is lacking in a strong cohesive offering other than the Heathrow Express which is only for passengers travelling from Central London but does not address the wider catchment area. The potential transference of 7,000 annual business movements to Farnborough would also create connectivity issues for passengers.

2.3 Does the Government’s current strategy make the best use of existing capacity at airports outside the south east? How could this be improved? As an organisation based In Scotland, we have a limited number of international direct services connecting us beyond the UK and many of these are connections over Amsterdam, Paris, Frankfurt and Dubai and so we rely very heavily upon the essential connectivity over a London hub airport to a wide range of additional destinations. British Airways carried 2.6 million passengers to and from Scotland in 2011 with 430 ﬂights per week to and from Heathrow and Gatwick and two thirds of these passengers travelling onwards to other cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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destinations. The final third of these flights is generally for Domestic point to point travel but this is equally essential for corporate travellers. It is only with this enhanced connectivity that the Scottish economy will be able to welcome inward investment, opening up foreign markets to Scottish businesses, raising productivity in the Scottish economy through lower transport costs and by encouraging local businesses to specialise in areas that play to the economy’s strengths. We welcome the introduction of new direct services (such as the recent increase of a double daily service from Glasgow to Dubai in June of this year by Emirates), but we fully acknowledge that there is only a finite number of flights that are economically viable and can be maintained from the population throughout Scotland and that regional connectivity over a strong and consistent London hub will always be an essential part of travelling by air.

2.4 How can surface access to airports be improved? In an ideal world, the best way for surface access to airports to be improved would be with the creation of fully integrated rail connections to airports as we see at Gatwick. This has been achieved at many airports in Europe and makes the entire travelling experience so much better. In Scotland, we have already seen both Edinburgh & Glasgow abandon the option of this concept and in Edinburgh the council opted for the trams. (It could be good if they are ever completed) In reviewing Heathrow, there have already been proposals on an integrated rail network which we are in agreement with but would also highlight the need for further Connectivity from Scotland.

3. What constraints are there on increasing UK aviation capacity? 3.1 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? The SPAA believes that great progress has been made in reducing the impact of aviation around airports with the development and investment in new aircraft which are both more fuel efficient and also a great deal quieter. A great effort has been made to review and adjust operational procedures to improve a reduction in noise levels and it has been noted that some airports have even managed to achieve carbon neutrality. Although there is a great deal of comment from residents living close to airports, many of these people have bought/rented their properties in full knowledge of the fact that they are on a recognised flight path to an airport

3.2 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?

Whilst the SPAA fully supports the reduction of carbon emissions we would point out that currently, CO2 emissions from the UK aviation industry account for 5% of emissions which in turn reduces to 2% globally. The predictions are that this will only increase by 0.5% by 2050. Noise pollution has been an emotive subject for many years for residents affected by living close to an airport but the introduction of newer, quieter and more fuel efficient aircraft has helped to reduce noise levels combined with better air traffic control procedures. We agree with the government continuing to explore the option of creating noise envelopes. The SPAA feels that the European ETS scheme is not the final answer and could prove harmful to the aviation sector. We feel that more should be done to achieve a global cap. The UK should also be concentrating on working with airline manufacturers regarding research into more fuel efficient aircraft and airline fleet renewal and alternative fuel solutions.

3.3 What is the relationship between the Government’s strategy and EU aviation policies? The SPAA acknowledges that the UK Government works with EU aviation policies with regard to air trafﬁc control and the ETS carbon scheme.

4. Do we need a step-change in UK aviation capacity? Why? The SPAA believe that there should indeed be a step-change in UK aviation capacity, failure to do so would be severely damaging to the long term UK economy.

4.1 What should this step-change be? Should there be a new hub airport? Where? In the budget in April, the Government recognised the need to expand air capacity in the South East and has now commissioned reports to review this but they will not deliver their ﬁndings before 2014 and as the capacity squeeze on Heathrow continues there is currently no real viable interim alternative options under consideration to address the capacity issue. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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There is an extremely urgent need for immediate expansion to maintain London as a global hub as our neighbours in Amsterdam, Frankfurt and Paris continue to grow with the help and investment in additional runway capacity and infrastructure and are able to attract more flights and investment from emerging markets. It is vital to the future of UK trade links from both existing and emerging BRIC markets that the need for increased capacity must be addressed and quickly. We are already losing out in the UK with six Chinese cities who are connected to Frankfurt and five of these are also connected to Paris but none of them are connected to the UK. We can also see the growing hubs in the Middle East. The SPAA firmly believe in and would support a third runway at Heathrow on the basis of the connectivity of flights from the regions to enable passengers to connect to a full range of destinations. To offer full connectivity to Scottish passengers from Aberdeen, Edinburgh and Glasgow there is really no other current solution which would offer any viable alternative extensive onward connections. It would also be potentially feasible for a second runway at Gatwick to serve the Highland and Islands airports which currently are served via Gatwick. The SPAA believes that the aviation and tourism markets could help the economy to be strengthened and stabilised but the current suppression on necessary airport expansion and ongoing tax increases will ultimately risk the future of international and regional airport routes and without this connectivity, the UK will become an unattractive destination for investment and for inbound tourism. The Government must address the capacity constraints without delay alongside investment in strategic infrastructure projects to allow future growth and long term economic recovery planning together with creating additional employment.

4.2 What are the costs and beneﬁts of these different ways to increase UK aviation capacity? The SPAA view the third runway option as the most economical and viable solution to the capacity ceiling currently hovering over the UK. Heathrow is the established UK hub airport, and if allowed the third runway would provide the solution to the capacity constraints within the shortest timescale and one would expect at the lowest overall cost.

Conclusion The SPAA will be making full submission on the Sustainable Aviation document later this month where we will expand on our thoughts relating to aviation matters. We would however be very happy to discuss any items relating to the enclosed document and we would urge the Committee’s support for an economic review into the impact of APD. 19 October 2012

Written evidence from the Chiltern Countryside Group (AS 82) The Chiltern Countryside Group (CCG) welcomes this opportunity to contribute to the Transport Select Committee’s Inquiry into Government strategy for aviation and aviation capacity in the UK. Within this paper, we outline the Group’s considered views on these important issues and request that the Committee take these fully into account in preparing their report from this Inquiry. The Group believes that whilst aviation remains firmly part of people’s lives in the 21st century, the world’s population holds collective responsibility for reducing their need to travel and that when we do so, we should aim to choose the most environmentally-sustainable transport mode available. With this qualification, therefore, we respond to the questions posed by the Committee’s Inquiry. The CCG’s mission statement is “Preserving the peace of the Chilterns”. However, the operation, impact and benefits of aviation are not restricted to this area of SE England. Indeed the questions raised by the Committee consider the whole of the UK. We, therefore, respond to this Inquiry from a national perspective which has been informed by our experience of aviation in the Chilterns. Since its foundation in 2008, the CCG has made several submissions to Government, the Department of Transport, the Civil Aviation Authority and the National Air Traffic Service’s different aviation Inquiries and Consultations. The Group has also made submissions to the most recent Noise Action Plan Consultations conducted by Heathrow Airport and London Luton Airport. We find that much of the contents of these submissions remains relevant to present strategy and challenges; therefore, we have drawn upon these earlier papers in the preparation of this document. Where relevant, we have given original source references.

Acknowledgements The CCG Steering Group wish to give particular appreciation to their colleagues in the Steering Group, Capt. Gwyn Williams, Dr. Marilyn Fletcher and Prof. Colin Waters for their invaluable professional knowledge and expert contributions in the compilation of this paper and its Appendices. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Executive Summary 1. The need for a National Transport Strategy — Since CCG was founded in 2008, the Group has been calling on Government for a properly researched and designed overall national Transport Strategy, so that major proposals as outlined below are appropriately integrated within a wider strategy which aims to (a) meet the UK’s genuine needs and (b) give an optimum environmental balance. Only then can Government ensure that available funds are deployed in the wisest, most efficient and effective manner. We remain doubtful that any programme for any transport mode can achieve its optimum aims if planned and delivered in isolation. — The CCG share the Transport Select Committee’s concerns expressed in that Committee’s Report following their May 2011 Inquiry into High Speed Rail that, despite their earlier recommendations for a proper Transport Strategy on a national level, this has yet to be achieved by the Department for Transport (DfT). The CCG finds this unacceptable for public accountability and use of taxpayers’ money, as it fails to provide an adequate base or structure on which to base any decisions on policy or the future of major projects such as airport expansion or the current proposals for the High Speed 2 railway. — An appropriate balance must be achieved between the economic, social and environmental costs and benefits of aviation. Within this balance, unconstrained growth of aviation is not an option. Nor is it likely to be required in the future with increased take-up of electronic communications, pressure on disposable incomes, increased public awareness of environmental implications and operational costs, including fuel. The priority should be to make UK’s airports better, but not bigger, for all, not just for users.

2. Reducing Environmental Impact — Aviation plays a key role in helping deliver Government’s carbon reduction goals. However, Government should not abdicate its own responsibilities towards supporting and facilitating the contribution which the aviation industry is challenged to make. — Noise pollution reduction should be a key element of Government and aviation’s environmental targets. — Improved operational procedures and new technology can and should facilitate better use of existing capacity, reduce or eliminate stacking and make a positive contribution to minimising local environmental impacts, particularly noise over densely populated and sensitive areas. — The CCG welcomes the Government’s recognition that poor air quality has a negative effect upon individual health & is taking steps to reduce aviation’s impact. However, we remain concerned that achieving compliance with legally binding European standards on pollutants is yet to happen. — Should the Government’s proposed new high-speed railway line (HS2) go ahead and the predicted small modal shift does occur from domestic flights to high speed rail, the aviation industry must take an environmentally responsible position by not re-allocating any vacated short-haul flight slots. If it does re-allocate these slots, particularly to long-haul, then any environmental benefits from HS2 will be negated.

3. Valuing the Importance of Areas of Outstanding Natural Beauty and National Parks and Reducing Aviation’s Impact — Relatively tranquil landscapes such as Areas of Outstanding Natural Beauty (AONB) and National Parks, together with other locally sensitive “green spaces”, are scarce and important resources which should be protected now and in the future. Impact and intrusion of aviation noise can be signiﬁcant but is not adequately addressed by either Government or aviation policies. In its recent Scoping Document on Developing a Sustainable Framework for UK Aviation, the Department for Transport continued to ignore the important issue of aviation impact on AONBs and National Parks. Impact and intrusion of aviation noise can be signiﬁcant reducing the environmental and economic value of such land. — Government should be in on-going dialogue on national and regional transport planning infrastructure with relevant bodies, including those such as AONB Conservation Boards, so that “joined-up” measures are put in place to reduce adverse environmental impact on sensitive areas from all modes of transport.

4. Capacity and Connectivity — Proper analysis and impartial modelling based on scientiﬁcally proven methodology needs to be carried out to underpin any concept of lack of aviation capacity in not just the SE, but the whole of the UK. Only then can accurate assessment be made of where needs are and from that, what constraints apply and how these might be overcome. — International aviation capacity and connectivity needs to be considered in a more environmentally- sustainable way, not just simply from a UK perspective, but from a world view. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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— International aviation connectivity is important but it should be driven by need and demand, based upon accurate and scientifically substantiated modelling evidence. — Some elements of the business community comment on lack of international connectivity. The CCG suggests this more accurately refers to lack of regional international connectivity and frustration with the time-consuming and costly need to travel to the SE to travel overseas. — It is essential that “removing barriers in sectors where there are clear opportunities for growth and where the Government can make a difference” (ref. DfT) is not at the expense or disadvantage of the well-being of the UK’s residents, including existing communities, or of the natural and irreplaceable resources of our nation, such as protected or locally strategic landscapes. — Maximising capacity at any airport in the UK must be balanced against the environmental impact, particularly that of noise, of its operations upon the communities and landscapes under its flight paths. It should be recognised that in practice such impact can still be experienced over 20 miles distant. — Regional connectivity throughout the UK and internationally by air is a key issue for overall transport strategy. This does not necessarily need to be London or SE-centred. — The CCG believes that a different non-London or South East centred approach could make a significant contribution. This would not move the noise or emissions impact elsewhere, but provide opportunities to reduce individual carbon footprints, enabling travellers to fly to/from an airport closer to their journey’s destination/origin. Transporting people around the UK to London airports (or indeed other airports) for them then to fly overseas increases their carbon footprint, time and use of resources.

5. Aviation and Noise Pollution on Communities — The CCG does not accept that when technological advances, modern equipment, quieter aircraft and efficient operational procedures including airspace management are all brought together intelligently, they cannot, in the 21st century, simultaneously fulfil the twin aims of local and global environmental impact reduction. We do not accept that one has necessarily to be at the expense of the other. — Night noise is a significant issue which is not as yet addressed nationally or adequately by Government or the aviation industry. — Government does recognise night noise from aviation has major impact on overflown residents. However, this recognition is too narrow as controls are not national and vary from the strict regulations in place for Heathrow, Gatwick and Stansted with full 24/7 operations permitted at others. London Luton is the only London airport which is not regulated on night flights. This is an unacceptable anomaly. — The CCG believes the number of people affected by significant levels of aircraft noise has increased over the past 30 years. The aviation industry has grown during that time, as has the UK’s population, particularly around cities, near to or where most of the UK’s airports are sited. — The concept of an airport noise envelope may lead to airport growth if, due to improved technology or operational procedures, noise output of individual aircraft or the overall airport performance fell. This would not allow for a reduction in airport noise but rather provide for opportunity to expand.

6. Changes to Operational Procedures can make a Real and Positive Difference — Airspace management nationally and internationally should be a key component of Government aviation strategy. — Technological changes are not local, regional or even national considerations. Aviation is a global concern and technological changes need agreement and support at this level. — Changes to operational procedures on take-off and arrival, together with removal or repositioning of restrictive stacking holds, have signiﬁcant potential to improve the noise environment. — Improved operational procedures and new technology should contribute to better use of existing capacity, but equally of importance, should make a positive contribution to reduction of local environmental impacts, particularly over densely populated areas and those which are sensitive, such as Areas of Outstanding Natural Beauty and National Parks.

Question 1: What should be the objectives of Government policy on aviation? 1. The CCG is challenged to perceive a deﬁnitive objective in current Government thinking on aviation. The Group is unable to discern a clear policy which is based upon realistic and sustainable objectives which the nation can afford and which are truly in the whole nation’s best interests. 2. To achieve realistic and sustainable objectives, an appropriate balance must be set and implemented between the socio-economic and environmental costs and beneﬁts of aviation. Within this balance, unconstrained growth of aviation is not an option. Nor is it likely to be required in the future with increased take-up of electronic communications, pressure on disposable incomes, increased public awareness of cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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environmental implications and operational costs, including fuel. The priority should be to make UK’s airports better, but not bigger, for all, not just for users. 3. A key Government objective should be to facilitate ways of making the UK’s airports better for all: users; surrounding and overflown communities; more efficient use of airspace with integrated management and communication internationally; reduction in energy demand from aviation and thus environmental impact/cost; policies, schemes and targets for reducing air, visual and aural pollution on communities and sensitive areas. 4. Technological changes are not simply local, regional or even national considerations. Aviation is a global concern and technological changes need agreement and support at this level. 5. Aviation plays a key role in helping deliver Government’s carbon reduction goals. However, Government should not abdicate its own responsibilities towards supporting and facilitating the contribution which the aviation industry is challenged to make. 6. This responsibility should not be restricted to carbon pollution, but extended to reducing aural pollution from aviation. Society has become noisier and busier; rural landscapes are becoming more valuable places where people can experience essential peaceful respite and relaxation. Noise pollution reduction should be a key element of Government and aviation’s strategy and environmental targets. 7. Relatively tranquil landscapes such as Areas of Outstanding Natural Beauty (AONB) and National Parks, together with other locally sensitive “green spaces”, are scarce and important resources which should be protected now and in the future. Impact and intrusion of aviation noise can be significant but is not adequately addressed by either Government or aviation policies. The Government continues to ignore the important issue of aviation impact on AONBs and National Parks. Impact and intrusion of aviation noise can be significant with detrimental effect upon communities, visitors and in reducing the environmental and economic value of such land. Tranquillity is a finite resource in our small island. 8. The CCG’s considered view is that Government and the aviation industry should work in partnership to identify, address and facilitate reduction of impacts on local environments by aviation, without compromising safety. This is of prime importance in areas such as the Chilterns which are impacted by flights from more than 1 airport. 9. International and regional connectivity throughout the UK by air is a key issue for overall transport strategy. This does not need to be London or SE-centred.

(b) How important is international aviation connectivity to the UK aviation industry? (e) Where does aviation fit in with an overall transport strategy? 1. The focus of question (b) should not be on the importance of such international connectivity to the UK aviation industry but to the UK, its wider business community and residents. 2. Government needs to develop a rigorously researched and planned overall transport strategy of which aviation is part. International aviation connectivity can then be considered more effectively and in a more environmentally-sustainable way not just simply from a UK perspective but from a world view. 3. International aviation connectivity is important but it should be driven by need and demand, based upon accurate and scientifically substantiated modelling evidence. A key issue which CCG considers later in this paper is the weighting of connectivity towards the SE. 4. If the UK’s aviation industry becomes largely dependent upon international connectivity, then it becomes even more imperative that a national approach is taken. Government and airlines need to move away from a SE-based approach and think more widely about the passenger base. 5. Transferring passengers using a UK hub do not mind where this is in the UK, providing the flight and transfer time, cost and actual transfer experience is positive. It is the direct, easiest and most cost-effective connection which is the motivator for the passenger and the shortest distance flown which should be the motivator for the air operator. For eg, the USA has many airports where it is possible to transfer onto national or international on-going flights; the UK should be evaluating more broadly and not perceive only one congested airport in the SE as the only option. 6. Relatively tranquil landscapes such as the Chilterns Area of Outstanding Natural Beauty (AONB) are scarce and important resources which should be protected. Intrusion of aviation noise onto relatively tranquil areas can be significant but is not adequately addressed by Government or the Civil Aviation Authority (CAA). This issue is discussed further later. 7. It is a complete nonsense that as one form of transport works to reduce its noise impact upon a community, another different, but noise intrusive, mode is introduced. 8. We give an example of how this anomaly currently manifests: In a consultation (January 2012) on their Environmental Programme, “Improving Aviation’s Sustainability Now and for the Future”, the Civil Aviation Authority (CAA) sought to reduce aviation’s environmental impact, recognising the value of our AONBs and National Parks. As the TSC has identified, a notional monetary value should be placed on natural capital of this kind. Simultaneously, in another arm of the DfT, plans are under way for a new railway route (HS2) which cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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will adversely and irreversibly impact on the Chilterns AONB, thus increasing the environmental damage and long-term pollution. 9. Therefore, the Government should be in on-going dialogue on national and regional transport planning infrastructure with relevant bodies, including those such as AONB Conservation Boards, so that “joined- up” measures are put in place to reduce adverse environmental impact on sensitive areas from all modes of transport. 10. Airspace management nationally and internationally should be a key component of Government aviation strategy. This is discussed further in Q2.

Question 2: How to make best use of existing airport capacity? 2(a), (b) 1. It is essential that “removing barriers in sectors where there are clear opportunities for growth and where the Government can make a difference” (ref. DfT) is not at the expense or disadvantage of the well-being of the UK’s residents, including existing communities, or of the natural and irreplaceable resources of our nation, such as protected or locally strategic landscapes. 2. Improved operational procedures and new technology should contribute to better use of existing capacity, but equally of importance, should make a positive contribution to reduction of local environmental impacts, particularly over densely populated areas and those which are sensitive, such as Areas of Outstanding Natural Beauty and National Parks. 3. The aviation industry’s future strategic policy has a vital role in the nation’s infrastructure development. The Government’s National Planning Policy Framework (NPPF) appears to indicate a presumption in favour of sustainable development, based on the predicate that expansion equals better and greater progress nationally. The CCG questions whether economic growth and development are mutually exclusive; investing finite resources to improve what is already present may, in these uncertain times, be the wisest and more widely advantageous option, both for the short and longer-term. 4. If London and/or the South-East are not the ultimate destination of long-haul travellers into the three main SE airports (ie Heathrow, Gatwick, Stansted), why do we need to encourage/facilitate flights into this already congested airspace? A more creative—and potentially environmentally advantageous—approach could be investigation into a shift towards regional long-haul flights so that both leisure and business travellers travel the shortest distance between their destinations. 5. Heathrow and Gatwick Airports’ trans-Atlantic long-haul flights overfly a considerable portion of the UK’s landmass at the end/start of their journeys, using fuel & adding to the burden of pollution in the air and on overflown land. Many of their passengers may not have London or the SE as their ultimate destination but they have no option but to fly in/out of a SE airport. 6. The CCG believes that a different non-London or South East centred approach could make a significant contribution. This would not move the noise or emissions impact elsewhere, but provide opportunities to reduce individual carbon footprints, enabling travellers to fly from an airport closer to their journey’s origin. Transporting people around the UK to London airports (or indeed other airports) for them then to fly overseas increases their carbon footprint, time and use of resources. 7. Regional connectivity by air throughout the UK is a key issue for overall transport strategy. Government identifies that “UK’s connectivity needs will change...in response to global economic and social trends...wants to ensure ... those ... needs can be met in an environmentally responsible way”. (ref. DfT Consultation Developing a Sustainable Framework for UK Aviation: Scoping Document 2011). 8. The Sustainability Commission (2011) has recommended to Government on transport that: “policy-makers [should] prioritise reducing demand for transport; encouraging more sustainable modes of transport and improving the efficiency of existing modes of transport over increasing the capacity of the transport system”. (ref: ). The Commission further states: [what is needed is] “more distributed development and local jobs rather than encouraging people to travel longer and longer distances”. 9. The CCG endorses these recommendations. Maximising capacity at any airport in the UK must be balanced against the environmental impact, particularly that of noise, of its operations upon the communities and landscapes under its flight paths. It should be recognised that in practice such impact can still be experienced over 20 miles distant. 10. The question is posed: “How to improve the passenger experience?” Passenger experience and choice is in practice restricted by the aviation industry itself. Presently, there is a financial incentive for passengers to choose flights at anti-social & night time hours. We suggest that passengers would not choose to travel at these hours unless there was the compelling reason of a cheaper seat. Until this is regulated, airlines will continue marketing in this way, ignoring the greater aural and pollutive impact of flights outside conventional daytime hours (EC. 6.00am-23.00pm). cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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2(c) How to improve surface access? 1. Improvement of surface access to airports should be planned and delivered within the context of an overall national transport strategy as outlined above. A more creative approach is needed than currently demonstrated where surface routes, regardless of transport mode, frequently run North-South, or for public transport, use London as an interchange, when it is not the passenger’s ultimate destination.

Question 3: What are the constraints on increasing the UK’s aviation capacity? 1. Before the subject of constraints can be properly evaluated, Government requires scientiﬁcally proven and researched evidence that aviation capacity in the UK needs to increase. A diverse range of views exists currently with a premise of the need for increased capacity being driven by the aviation industry itself, hardly an unbiased assessment. 2. Some elements of the business community comment on lack of international connectivity. The CCG suggests this more accurately refers to lack of regional international connectivity and frustration with the time- consuming and costly need to travel to the SE to travel overseas. 3. Proper analysis and impartial modelling based on scientiﬁcally proven methodology needs to be carried out to underpin any concept of lack of aviation capacity in not just the SE, but the whole of the UK. Only then can accurate assessment be made of where needs are and from that, what constraints apply and how these might be overcome.

(a) Are proposals to manage the impact of aviation on the local environment sufficient particularly in reducing the impact of noise for local residents? 1. No, they are not. 2. Aural pollution is probably the most immediate source of adverse impact on local communities and individuals; airports’ Noise Action Plans (NAP) more often concentrate on monitoring rather than pro-active response and implementation of noise-reduction measures. 3. The House of Commons Transport Select Committee’s findings from its earlier Inquiry on the Use of Airspace (ref: Findings from House of Commons Transport Select Committee in the Inquiry into the Use of Airspace (July 2009) ) reported that: “tranquillity is a key factor in sensitive areas such as National Parks and Areas of Outstanding Natural Beauty. Current guidance appears to allow unchecked increases in aviation activity over these areas. Without some level of constraint, the noise environment in these areas might degrade progressively as traffic increases.” 4. And further that: “The DfT and the CAA should examine the case for adopting maximum limits on noise levels and the number of aircraft permitted per hour over sensitive areas such as National Parks and Areas of Outstanding Natural Beauty. The DfT should fund exploratory research on evidence-based limits.” The CCG is unaware of any such measures or actions being implemented. 5. Negative impacts on a community will be manifested in diminished health for some residents and their families. This will place a burden upon health and social agencies, funded by Government. It is therefore in the Government’s own interests to ensure such negative impact is minimal; their response should facilitate, support and may indeed, drive the aviation industry’s own efforts. 6. The CCG’s considered view is that Government and the aviation industry should work in partnership to identify, address and facilitate reduction of impacts on local environments by aviation, without compromising safety. This is of prime importance in areas such as the Chilterns which are impacted by flights from more than 1 airport. For example, Government can legislate against night flights; urgently put in place operational procedures which reduce/eliminate stacking; and additionally, those which reduce noise on landing approach or take-off; restrict or prevent low level flights over sensitive areas, including AONBs and National Parks; restrict number of overflown flights during a given time period; place restrictions or legislate against flights operating at anti-social hours at all airports. 7. So far as we are aware, only three UK airports (Heathrow, Gatwick, Stansted) have noise regulations controlled by the CAA; this is a matter of some concern. As other airports seek to expand and airspace is managed differently, the CCG would expect the CAA to be pro-active in establishing a regulatory noise role over all the UK’s airports. It is unrealistic to expect individual commercial airports to make the same independent value judgements of their environmental impact upon overflown communities. The CAA is, and should be, best placed to fulfil this obligation. 8. The CCG accepts that aircraft generally have become mostly quieter as assessed by manufacturers and operators, but this does not always translate into a quieter experience for those being overflown. More work is needed. 9. Without any other change, greater uptake of the quietest aircraft should reduce local noise on take-off/ landing including at approach. Operational procedures should reduce this further and fuel saved will not only improve air quality locally, but should contribute to overall global improvement. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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10. Intelligent planning of strategic air space around airports so that air traffic controllers (ATC) can, and do, implement the best environmental balance for both aircraft and overflown community should be a priority for both Government and the aviation industry. 11. Certainly the experience of residents in the Chilterns is that they are impacted more often and by more noise in recent years from Heathrow operations than in the past. In the 1970s we would estimate that very few residents in the Chilterns even saw a Heathrow aircraft, let alone heard one. Now it is a daily experience with frequent heavily laden, low-flying aircraft flying directly over the hilly terrain and peaceful market towns of the Chiltern Hills. Stacking presents an additional problem over the Chilterns and as flights have increased, so has the need for stacking. There is no cause here for complacency—quite simply, the expansion of Heathrow has had a truly negative impact on the Chilterns. 12. Additionally, this pollution has been increased hugely by the expansion of operations at LLA which compound the complexity and challenge of managing this already congested airspace safely. The CCG offers suggestions on operational changes which would help reduce pollution without compromising safety in Appendix B of this paper. 13. In particular, whilst Government identifies the impact of night noise on overflown communities as a significant issue, it is not as yet addressed nationally or adequately by Government or the aviation industry. Night is recognised by the EC as between 23.00pm and 6.00am. 14. When the World Health Organisation (WHO) has for years identified sleep disturbance caused by noise as a significant contributory negative element affecting the individual’s health, it is unacceptable that some airports, such as London Luton Airport (LLA), still have no night time flight restrictions. This is even more unacceptable for overflown communities when an airport is pro-actively seeking to expand, as LLA currently are. (ref. ) 15. Government recognises the major impact of night noise from aviation on overflown residents. However, this recognition is too narrow as controls are not national and vary from the strict regulations in place for Heathrow, Gatwick and Stansted with full 24/7 operations permitted at for eg London Luton. This is unacceptable. 16. Night operations at all UK’s airports should have similar restrictions and parameters. The CCG therefore recommends that in addition to consultation on night noise for the three major London airports, that an integrated or parallel public consultation also be conducted for all airports in the SE, and in particular for those which have no controls in place currently. 17. The DfT, the aviation industry and NATS should recognise the detrimental impact on silent communities of intermittently scheduled flights throughout the night time period and take pro-active and positive steps to reduce such pollution. 18. Averaging of noise intrusion events gives a monitoring reading which is quite different from that experienced by the overflown resident. 19. Quotas are a very poor means of regulating night noise as an airline operator which has performed well and not used its noise quota is able to pass the surplus to another operator, which may well be failing in achieving noise reduction. 20. Currently, for example, residents within a c20 mile radius of LLA suffer from the night time operations (EC hours) of budget and charter flights throughout the year but particularly during the main April-October holiday period. These flights are scheduled by operators throughout the night, together with regular freight aircraft. Such scheduling is not driven by customer demand who, we suggest, would not choose to travel in the middle of the night without a cost incentive to do so. 21. The CCG believes this to be an unfair social balance. A far greater burden is imposed 24/7 upon local residents whose sleep is disturbed intermittently, but significantly, throughout the night, which they cannot choose to avoid, whilst the individual traveller incurs short-term inconvenience at their own choice. As there are currently plans in progress to expand passenger numbers and operations at LLA, the anomaly that this London airport has no night flight restrictions unlike its London counterparts, including London City, should be urgently addressed. A ban over core night hours, or at minimum, a cap to bring LLA in line with other London airports, should be given highest priority by NATS and the CAA. 22. The CCG makes further and detailed comments on noise impact and how this might be reduced in Appendix A of this paper. 23. Light pollution from night time operations is ignored by the aviation industry, its regulators and Government. It is significant and should be included in targets to reduce environmental impact. 24. The CCG believes it is imperative that the CAA and NATS establish an on-going dialogue, not just with the aviation industry, but with environmental bodies and community groups, such as AONB Conservation Boards, to achieve the optimum balance between the UK’s aviation operations and their consequent pollution on communities and landscapes. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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25. For eg, it has been encouraging that over past months, in response to dialogue with communities in the Chilterns, trials to operational procedures for certain arrivals into LLA have been carried out by NATS, which are intended to reduce local noise impact. The CCG suggests that more opportunities which have potentially positive outcomes for both operator and community should be facilitated soonest. 26. The CCG makes further comments and suggestions relating to the impact of aviation over designated land (AONBs and National Parks) in Appendix C.

(b) How to reduce carbon emissions and manage impact of aviation on climate change? How can aviation be more sustainable? 1. The CCG’s responses to Q2 are also relevant. 2. Government has expectations that “in the longer term, demand for domestic aviation and ...near-European short-haul aviation could be met by high-speed rail”. 3. Should the Government’s proposed new high-speed railway line (HS2) go ahead and the predicted small modal shift does occur from domestic flights to high speed rail, the aviation industry must take an environmentally responsible position by not re-allocating any vacated short-haul flight slots to long-haul. If it does re-allocate these slots, then if there are any environmental benefits from HS2, these will be negated. 4. The CCG notes that Government recognises the significant effects on health of poor air quality and is taking some steps in working with relevant other parties to monitor and improve this. Achieving compliance with legally binding European standards for ambient levels of pollutants thought to be harmful to human health and the natural environment must be an absolute priority. 5. During the period in April 2010, when UK airspace closed due to volcanic ash from Iceland entering the atmosphere, researchers gathered data on pollutants around Heathrow. They reported that: “This period of unprecedented closure during unexceptional weather conditions has allowed us to demonstrate that the airports do have a clear measurable effect on NO2 concentrations and that this effect dropped almost to zero during the period of closure, leading to a temporary but significant fall in pollutant concentrations adjacent to the airport perimeters.” These findings should not be ignored in targeting emission reduction. (ref: Preliminary analysis of the impact of airport closures due to the 2010 Eyjafallajokull volcanic eruptions on local air quality: Barratt, B and Fuller, G W. 01/05/2010 London Air Quality Network.) 6. There is extensive scope to influence people and industry to make choices aimed at reducing climate change impact from aviation. The CCG suggests, as a start, wider consumer education on the increased environmental impact of night flights and the minimisation of price incentives to choose these over daytime flights—these are industry, not consumer led. 7. Research in 2006 (ref: ) showed that whilst only 1 in 4 flights over the UK were at night, they accounted for at least 60% of the climate warming associated with aircraft condensation trails (contrails). As not all UK airports are restricted on night flights, this figure could have risen in the 5 years since the data was originally published. Consequently, greater incentives for air operators to reduce or eliminate night flights could lead not only to less noise pollution for overflown communities, but a wider environmental benefit also. 8. It is encouraging that in 2010, British Airways, NATS and BAA collaborated successfully to operate the UK’s “first perfect flight between Heathrow and Edinburgh.” This was “the most fuel efficient through efficient ground taxiing, aircraft climb and descent and optimal flight profile ...saving 350kg of fuel and a tonne of CO2 [total of 10%] compared to a normal flight on the same route”. (ref: ) 9. Aviation professionals identify that better flight management as above which involve air traffic controllers has potential to reduce aviation emissions by 5–8%. Having demonstrated it can be done, these improvements can now be integrated targets in airports’ Master Action Plans for carbon emission reduction. Government could help to progress this more rapidly. 10. Stacking wastes fuel and increases carbon emissions. he location of stacking “holds” such as the Bovingdon Hold for Heathrow arrivals places restrictions, which would otherwise be unnecessary, upon operations of neighbouring airports, such as LLA. These cause greater noise/air pollution on communities which, without the Hold’s requirements, might not occur. The CCG discusses the question of stacking holds further in Appendix B.

Question 4: Do we need a step-change in UK aviation capacity? 1. The Group’s responses to earlier questions are relevant to Q4. 2. The CCG believes that taking a whole UK approach has potentially greater beneﬁts, than concentrating simply on the SE. 3. The CCG remains ﬁrmly opposed to any expansion of operations at Heathrow airport. We give some of our reasons earlier in this paper. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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4. Neither do we find that Heathrow currently makes an appropriate level of response to minimise its present operational impact, especially in tranquil areas as the Chilterns and other significant green spaces, such as Kew Gardens. (ref. CCG response to Heathrow Noise Action Plan Consultation 2009.) 5. Therefore we have no reason to be confident that any expansion will bring anything less than greater pollution and adverse environmental impact on overflown communities and landscapes. 19 October 2012

APPENDICES A, B AND C The CCG includes the following Appendices which formed part of the Group’s response to the CAA Consultation on “CAA and the Environment: Improving Aviation’s Sustainability now and for the future” April 2012 and the DfT’s Consultation on “Developing a Sustainable Framework for UK aviation Scoping Document” October 2011. We ﬁnd they are relevant to the aims and outcomes of this Inquiry and ask that they be considered fully in its analysis and eventual outcomes.

APPENDIX A NOISE Response to Specific Issues on Noise The Scoping Document concentrates its considerations to the areas around airports and directs the Government’s response to the problem to the requirements of the Environment Noise Directive. These are limited to the major airports (greater than 50K annual movements) and the requirement for the production of noise action plans. (1) Great emphasis is put throughout this section on the need for local participation on the setting up and agreement to these noise action plans. The concept of setting a “Noise Envelope” around the major airports is mooted with a view to defining an area within a limiting noise area. Aviation growth up to this limit would be permitted. This sounds very similar to the limit on Heathrow noise set by the various Public Inquiries that the area within the 57 dB(A) Leq,daytime not be increased. Further detailed questions need to be answered before such a concept can be properly considered. — What metric or methodology would be used to define the envelope. — Would the bounds of the envelope exceed the present noise limits (eg the 57 dB contour at Heathrow). — What constraints would be placed upon the airport to maintain the envelope. — What sanctions would be available to prevent breaking of the envelope. (2) One aspect of the airport envelope concept would be that as technology or operational procedure improved the noise output of the individual aircraft or the overall airport performance then airport growth would be permitted. Such a concept would not allow for a reduction in airport noise but would seem to be designed to consign an area to continued noise pollution without any intention to provide overall mitigation. (3) Night noise is accepted as being a major environmental issue and one that causes significant environmental problems. A respite period is suggested during the night but warning is given that this would probably mean an increase in movements either side of this period. This has no real difference from the current night flying restrictions that are currently in place. (4) The Government has issued air navigation guidance to NATS to seek to concentrate routes so as to avoid overflying populated areas as much as possible. This approach completely misses the point that such routes will thus fly over the quietest areas and thus have the most impact over the low ambient levels. Noise from down the route operations and from stacking procedures will continue to have significant impact and this problem is not addressed in the document. (5) The document places some weight upon improved technology reducing the problem of aircraft noise. However, noise reducing technology may be at odds with other environmental concerns. One example is the open rotor technology that offers significant fuel advantage will increase the down the line noise of overflying aircraft. Technological changes are not a local, regional or even national consideration. Aviation is a global concern and technological change needs agreement and support at this level. Changes are very slow in being implemented. The planned reduction in aircraft noise set out by ICAO by 2020 has shown that technological changes cannot reach the targets. It is operational change that must be implemented. Low energy approach, continuous descent, total route planning from “Gate to Gate” are some of the changes that must be made. (6) As environmental expectations increase the extent of “local impacts” increase. Noise is not confined to the areas immediately around and airport but is being considered as a regional issue. In this regard much more control must be taken over noise emissions with strong government representations at international level for the early implementation of lower noise aircraft and operational procedures. Local planning control over cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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development close to airports and a system of measurement and assessment of noise that includes night time noise levels should be activated. (7) Noise contour maps may give an inaccurate indication of the level of noise actually experienced on the ground. (8) Such airport master plans are useful in concentrating the minds of airport operators. They could be made more effective by giving local communities additional powers of control over the content of these plans. This would give scope for further discussion; certain actions should be vetoed if not considered to be effective or extensive enough. (9) This concept appears to be very similar to the current Heathrow restrictions. The removal of Concorde from the airport fleet allowed the increase of movements that arose through growth while still maintaining the area of the 57 dB contour. Some control on the extent of noise exposure at airports is obviously needed. However the establishment of a noise ghetto without an inbuilt plan to reduce its extent over time is not a good idea. (10) It is better to minimise the number of people affected by noise by reducing the level of noise exposure of the overflown population. This is a huge question and not one capable of a simple answer. Route planning for overall noise adverse effect reduction must include consideration of background level, stability of the route plan, etc. not merely a simple population count. (11) NPR place heavy burden of impact on overflown population and if/as routes change, this impacts on different communities who may previously have been unaffected. It is an unfair socio-economic balance to impose maximum noise impacts on the same few communities, whilst many from different communities use the facility causing the problem. (12) However, whilst spreading the noise may give welcome relief for some, the impact is simply transferred, not lessened or withdrawn. Government and the aviation industry should be seeking to reduce or eliminate total noise impact not simply move it around. (13) Over-flying relatively tranquil areas at low levels will cause greater impact than over already noisy areas, but that does not justify increasing those noise levels, which may then become intolerable. This would be particularly true for areas of high daytime noise, which then also became affected by noise from night flights. (14) No flying at night, arrival or departure, should be allowed for any aircraft not fitted with the latest noise control technology. There should be no movement of freight aircraft at night. Aircraft which fall into either or both of these categories should not fly between the hours of 23:00 to 07:00. Additionally no aircraft should be held in any stacking area between the hours of 22:30 and 06:30. These measures would ensure that only the quietest aircraft operated at unsocial hours and delays on arrival at the airport area are prevented by proper on- route planning.

APPENDIX B PROPOSALS FOR CHANGES IN AVIATION OPERATIONAL PROCEDURES TO REDUCE ENVIRONMENTAL IMPACT (1) For most people the greatest environmental impact of aviation is noise from aircraft departing and arriving at airports particularly within approximately 20 miles of an airport. Some alleviation can be achieved by the use of “optimum” routes in and out of airports called “noise preferential routes”; these can help but do not solve the problem because the noise is merely moved laterally elsewhere. (2) Significant improvements in the noise environment can however, be gained by adjusting the vertical profiles of departing and arriving aircraft. The perceived noise at ground level reduces markedly as aircraft altitude (height above mean sea level ) increases so that in most circumstances aircraft flying above about seven thousand feet are barely heard at ground level. The sooner departing aircraft can reach this altitude and the longer arriving aircraft can maintain at or above this altitude then the better is the noise environment at ground level. How can this be achieved? (3) It is common practice for commercial aircraft to use less than full engine power for take-off and to employ a technique called a “reduced power take-off” so that, depending on ambient conditions, only sufficient power is applied to achieve a required, safe climb gradient. This is a safe and perfectly legal procedure and there are commercial advantages for operators in the use of less than full power but it does mean that aircraft do not achieve the best rate of climb of which they are capable. (4) A compromise power setting, at say, somewhere between the “reduced power” setting and full power would enable aircraft to achieve a steeper initial climb gradient than at present. Reaching seven thousand feet sooner would significantly reduce the noise footprint. Such procedures, if adopted, would not be popular with the airlines because they would incur higher operating costs as a result, but they could be very beneficial in relation to noise footprints. They would almost certainly need to be mandated by the aviation regulatory authorities. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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(5) Steep and continuous aircraft climb profiles are sometimes currently impeded by the local air traffic control (ATC) environment when for instance, crossing tracks or holding patterns require departing aircraft to stop their climb early to achieve safe separation with other traffic. A review of the ATC procedures and airspace organisation at specific locations where such conflicts currently exist could greatly improve the noise footprint by allowing aircraft to climb quickly without hindrance. (6) A good example of this situation has been highlighted by CCG in a previous consultation (TCN 2008) in relation to aircraft departing westwards from Luton Airport and routing over the Chiltern Hills and below the Bovingdon (BNN) holding stack. (7) The minimum altitude in the BNN holding pattern is seven thousand feet. Northbound departures from Heathrow (LHR) and Northolt also route underneath the BNN hold but because ATC require a minimum vertical separation of one thousand feet between conflicting aircraft their climb is restricted to six thousand feet altitude. In practice heavy, trans-Atlantic departures from LHR, which may also have used reduced power for take-off, can often only climb to five thousand feet by the time they reach BNN. Westerly departures from Luton are thus required to stay even lower at four thousand feet until they are some twenty miles from the airport and have crossed the Chiltern Hills which rise to nearly one thousand feet altitude. (8) In this instance removal or repositioning of the BNN hold and slight re-routing of LHR/Northolt departures would facilitate unimpeded climbs by Luton westerly departures. (9) For arriving aircraft, the optimum type of final approach is a constant descent approach from about four to five thousand feet and approximately 10 to 15 miles out from the runway; this results in low engine power settings, reduced fuel consumption and reduced noise. Although it is the flight crew who actually fly such approaches they can only be achieved with the active involvement of ATC controllers who vector aircraft from the airway system towards the airport and decide on its vertical profile. (10) However, in the modern ATC organisation such “area” controllers are usually located at a remote central control centre rather than at or near a particular airport and thus may have little knowledge of local topography and noise sensitive areas. Moreover, when there is little ATC activity, controllers often give arriving aircraft early descent and direct routings to the final approach point because this can save time and fuel. (11) While this may suit airline operators the downside of these procedures is that populated areas can be subjected to higher than normal noise levels by overflying aircraft. Some visual indication on their radar scopes of the location of centres of population near particular airports would enable controllers to prevent this happening by vectoring aircraft away from them prior to final approach and descent. If implemented such procedures could significantly reduce the noise footprint in the vicinity of airports, particularly at night.

APPENDIX C IMPACT OF AVIATION ON DESIGNATED LAND (AREAS OF OUTSTANDING NATURAL BEAUTY AND NATIONAL PARKS Low Over-flight of Designated land (i) Sustainable aviation is one of the Department for Transport’s (DfT) Business Plan priorities, not only in terms of carbon but also in terms of local environmental impacts, particularly noise (ref. Sustainable Framework for Aviation Scoping Document Oct. 2011, 1.10). The Aviation Scoping document told us that the previous government gave insufficient weight to the local impact of aviation in The Future of Air Transport White Paper, 2003 (ref. Ibid 1.14). In contrast the Coalition government’s Scoping document stated that reducing global and local environmental impacts is “The key challenge for the aviation sector now” (ref. Ibid 2.1). (ii) The CCG welcomes the rightful concerns of the DfT for the impact of aircraft noise on the environment. This is necessary and commendable and reducing aviation impact should be a priority. However, the CCG remains concerned that the current plans by the DfT/HS2 Ltd to build a new high-speed railway line (HS2) through the heart of the Chilterns gives insufficient weight to the special and protected status of the Chilterns AONB. HS2 may well minimise any positive effect which air operators may try to achieve. (iii) It is not acceptable to take a position that if noise is present, a little more will not matter. In today’s society, we all have a responsibility to preserve environments which are national assets from which many may benefit.

Over-flight of Areas of Outstanding Natural Beauty and National Parks (i) The CCG was set up four years ago when low over-flight for many miles was planned over the Chilterns AONB—threatening the AONB’s tranquillity. (ii) The CCG recognises the importance of the aviation sector to the UK economy. However, it also welcomes the Coalition government’s stance on the need to place sufficient weight on local impacts. Conserving the tranquillity of AONBs and National Parks should be considered among those impacts. (iii) The CCG notes that nationally designated land does not appear to be mentioned in either the Consultation document: CAA and the Environment Improving Aviation’s Sustainability Now and For the cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Future, or in the CAA’s Insight Note 2: Aviation Policy for the Environment. This is surprising considering: AONBs and National Parks are nationally-important designated lands; the government’s stance on reducing the local impacts of aviation as a priority; the government’s indication of its renewed commitment to protecting AONBs and National Parks in included in the National Planning Policy Framework.

The Civil Aviation Authority’s Duty towards AONBs (i) The Countryside and Rights of Ways Act 2000 s85 is concerned with conserving and enhancing AONB landscape. Section 85 of the act states “in exercising or performing any functions in relation to, or so as to affect, land in an area of outstanding natural beauty, a relevant authority shall have regard to the purpose of conserving and enhancing the natural beauty of the area of outstanding natural beauty.” The Civil Aviation Authority (CAA)—and thus NATS—are amongst those speciﬁcally listed as relevant authorities (Schedule 1 Part II Section 14e).

Statutory Designation Criteria of AONBs and National Parks (i) In considering the local impact of aviation on designated land it is important to consider the method used for assessing land for designation as AONBs and National Parks: the land must meet the Statutory Designation Criteria set out in Appendix 1 of Natural England’s Guidance for Assessing Landscapes for Designation as National Park or AONB in England. (ref. ) This is embedded in the following laws: National Parks and Access to the Countryside Act (1949 s5) (for National Parks) and the Countryside and Rights (2000 s82) (for AONBs). (ii) Of the Statutory Designation Criteria, a sense of relative wildness is given as an important factor in assessing land for designation as AONBs and National Parks where a sense of remoteness and a sense of a relative lack of human influence are given as important sub-factors. (iii) Relative tranquillity is also given as an important factor in assessing land for designation as AONBs and National Parks where presence and/or perceptions of birdsong, peace and quiet, and natural sounds are given amongst the contributors to tranquillity, and low-flying aircraft is given amongst the detractors from tranquillity. Given this, low over-flight over an AONB or National Park diminishes the value of the relative wildness and relative tranquillity factors of affected land. Put simply, the reason for the affected land’s original designation is greatly reduced. (iv) Please note that National Park and AONB landscapes are of equal value but are designated as a result of differences in size, scale and aims (National Association of AONBs) (ref.

Purposes of an AONB and Tourism (i) AONB status protects the ﬁnest examples that remain of small-scale landscapes in England and Wales (National Association of AONBs) (ref. (ii) The purposes of AONBs are laid down in the Countryside and Rights of Way Act (2000 s87). The primary purpose of an AONB is to conserve and enhance the natural beauty of the landscape. The secondary purpose of an AONB is to meet the need for quiet enjoyment of the countryside. These purposes jointly foster tourism as a function of AONBs. (iii). A further secondary purpose is to have regard for those who live and work in the AONB.

Low Over-flight of Designated Land Impacts on Tourism (i) Low over-flight reduces the amenity value of designated land in terms of tourism. Tranquillity and wildness are reasons why tourists should seek out AONBs and National Parks for daytrips and holidays. Clearly, low over-flight strongly detracts from the attraction of designated lands. (ii) The Countryside and Rights of Way Act (2000 s87) charges Conservation Boards with promoting the understanding and enjoyment of AONBs. The Boards’ Management Plans are embedded in the Countryside and Rights of Way Act (2000 s89). The Chilterns Conservation Board Management Plan, for example, contains many references to providing land where quiet leisure pursuits can be enjoyed or peace and quiet can be sought as an interlude or temporary respite from urban life (ref. )

Designing Flight Paths over Designated Land (i) In preparing guidance to those who design ﬂight paths it is important to recognise that the economic and environmental value of designated land is gained through maintaining its tranquillity. (ii) Development is restricted in designated land: AONBs and National Parks are designated as such because of their landscape qualities—these would not exist if there were many houses on such lands; PPS 7 paragraphs 21 and 22 prevent major development in designated land other than in exceptional circumstances; Green Belt and AONBs are often contiguous around London and other major cities—development is restricted in Green Belt. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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(iii) Those designing flight paths should not interpret the sparse population of AONBs and National Parks to mean that such land is therefore a good place to put low flying aircraft. As noted, this would considerably reduce the ability of designated land to serve the purpose for which it has been set up—a nationally-important facility offering relative wildness and relative tranquillity. Such air-traffic design decisions affect the proper functioning of AONBs and National Parks.

Guidance to the Civil Aviation Authority on Environmental Objectives Relating to the Exercise of its Air Navigation Functions (i) The Guidance to the CAA on Environmental Objectives is embedded in s 70(2) (d) of the Transport Act 2000. The CCG values paragraphs 45 and 46 of the Guidance to the Civil Aviation Authority on Environmental Objectives Relating to the Exercise of its Air Navigation Functions—but see below. (ref: (ii) The CCG recognises that airspace can be very congested. However, it would like to see greater observance of the recommended altitude for over ﬂight of AONBs that is given in the Guidance on Environmental Objectives: minimising ﬂying below 7,000 feet where possible (paragraph 45).

Guidance on Low Over-flying of High Terrain (i) The Guidance to the Civil Aviation Authority on Environmental Objectives Relating to the Exercise of its Air Navigation Functions does not appear to give any guidance to those designing flight paths that the height of terrain should be taken into account. (ii) In 2008 a flight path was designed from London Luton Airport so that aircraft could fly SE at 2,300–2,400 feet agl for many miles over half the length of the Chilterns Hills. This experience shows that consideration should be given to amending the Guidance on Environmental Objectives to include the suggestion that the height of the terrain should be taken into account. In this context it is worth noting that nearly all AONBs and National Parks are formed from raised terrain—hills, plateaux and mountains. (iii) The CCG therefore suggest that serious consideration should be made to incorporating taking the height of terrain into account for environmental reasons when designing low-altitude flight-paths in the Guidance to the CAA on Environmental Objectives Relating to the Exercise of its Air Navigation Functions.

Clarification Required (i) Paragraph 45 of the Guidance to the Civil Aviation Authority on Environmental Objectives Relating to the Exercise of its Air Navigation Functions states “Government policy will continue to focus on minimising over-flight of more densely populated areas below 7,000 feet. However, where it is possible to avoid over-flight of National Parks and AONBs below this altitude without adding to the environmental burdens on more densely populated areas, it clearly makes sense to do so.” (ii) Experience has shown that this wording is not clear (ref: “More densely populated” can be interpreted to mean either: “congested”—the word used in the next paragraph (paragraph 46); or in the comparative sense of “more densely populated” to mean that flight paths should be sited so aircraft over-fly wherever fewer people live—as occurred when airspace over the Chilterns was being designed in 2008. (iii) The inevitable result of pursuing the policy of over-flying less densely populated areas interpreted in the comparative sense is that as airspace is increasingly utilised, flight paths would eventually become clustered over National Parks and AONBs. This is clearly not what the government intends. (iv) The CCG suggests that clarification of paragraph 45 of the Guidance to the CAA on Environmental Objectives Relating to the Exercise of its Air Navigation Functions is made by replacing the words “more densely populated” with “congested” (as is used in paragraph 46).

CAP 725—The CAA’s Guidance on the Application of the Airspace Change Process (i) The CCG does not believe that CAP 725 (Appendix B Section 8 page 27) (ref ) is an adequate reflection of paragraphs 45 and 46 of the Guidance to the Civil Aviation Authority on Environmental Objectives Relating to the Exercise of its Air Navigation Functions. (ii) CAP 725 does not state that Government policy includes minimising flight below 7,000 feet over AONBs and National Parks (without adding to the burdens on more densely populated areas). This is despite the DfT’s Guidance on Environmental Objectives clearly stating this is Government policy (paragraph 45). (iii) The only instance when CAP 725 discusses AONBs and National Parks—as far as we are aware—is to say that over-flight of such land is not precluded (CAP 725 Appendix B paragraph 120). This is by no means an adequate or full representation of the DfT’s Guidance on Environmental Objectives of over-flight over designated land. (iv) In the context of tranquillity CAP725 says it is difficult to measure, apparently complicated and insufficiently researched (Appendix B paragraph 120). It concludes that no formal guidance on tranquillity can be issued to those designing flight paths. Why? With regard to low flying aircraft the subject of tranquillity cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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would appear to be fairly simple: noise from aircraft can be measured; low-ﬂying aircraft are visual detractors from tranquillity in the statutory document: Guidance for Assessing Landscapes for Designation as National Park or AONB in England (Appendix 1).

References Guidance for Assessing Landscapes for Designation as National Park or AONB in England—Appendix 1 National Association of AONBs The Chilterns Conservation Board Management Plan—Understanding and Enjoyment Guidance to the Civil Aviation Authority on Environmental Objectives Relating to the Exercise of its Air Navigation Functions Transport Select Committee Inquiry—Use of Airspace July 2009 Memorandum from Marilyn Fletcher B.Sc. Ph.D. AIR 10 Part 3)

CAP 725 (Appendix B Section 8 page 27)

Professional Background Information Dr. Marilyn M. Fletcher B.Sc. Ph.D. Dr Fletcher is a Biology researcher and a graduate of the University of Shefﬁeld. After qualifying for her Ph.D. at the University of London, Dr Fletcher lectured to under-graduates at the university for 15 years. She also supervised post-graduate students for Ph.D. and has published papers in biology and histology. She is now an independent researcher specialising in the environment and sustainability.

Prof. Colin Waters B.Sc(Eng) MSc C Eng MRAeS FIOA Prof. Waters is Principal of Colin Waters Acoustics and has professional consulting experience in this field for over 40 years. He has been a Director of Ove Arup and Partners Ltd with responsibility for environmental acoustics of that firm. He has carried out and directed major infrastructure environmental acoustics projects in both the national and international field. Prof. Waters has advised the Chinese Civil Aviation Authority on associated airport noise problems and their assessment. He is Visiting Professor of Airport Environmental Acoustics at Manchester Metropolitan University.

Captain Gwyn Williams Capt. Gwyn Williams has 40 years experience in aviation both as a military and civil pilot. A graduate of the RAF College, Cranwell, he trained as a fast-jet pilot and saw active service in the Middle East and an operational exchange tour in North America in the air defence roll. He qualified as a flying instructor and subsequently commanded the Advanced Flying Squadron of the RAF Central Flying School training instructors. His final posting was to the MoD Inspectorate of Flight Safety. After gaining a civilian Airline Pilot Licence, Capt. Williams acted as a pilot instructor and examiner, flew business jets and then schedule and charter flights with several airlines operating B757, B777 aircraft and Concorde for its last 10 years in service. As a Flight Operations and Training Inspector for the Civil Aviation Authority he was responsible for the monitoring of a number of major UK airlines; for the testing and approval of flight simulators and for the training of the airlines’ own training captains.

Written evidence from The Authorities’ Aircraft Noise Council (LAANC) (AS 83) LAANC is an umbrella local authority organisation which represents the interests of two dozen Local Councils comprising Boroughs, Unitary Boroughs, London Boroughs, County and Parish Councils serving a wide area around Heathrow Airport. The Constitution of LAANC covers environmental issues as well as aircraft noise and represents a very large community many of whom have direct contacts with Heathrow. The main points that LAANC wishes to make to the committee are summarised below. Detailed responses to the committee’s questions are attached as appendices. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Main Points It should be acknowledged that the provision of capacity cannot (within the current UK aviation regulatory framework) be guaranteed to produce increased connectivity for UK plc. This is especially the case at Heathrow. In LAANC’s view the Government need to identify if further regulatory powers need to be taken (for example, reintroducing some form of Traffic Distribution Rules) to ensure that government can play a part in maintaining connectivity. The choice of where planes fly to currently is made by neither the airport owner nor the Government. It is made by the airlines who naturally prioritise the more profitable routes. LAANC believes that the key issues for the Government in developing future policy are the requirements for runway capacity and the case for connectivity. In respect of Heathrow it has suited the Heathrow owner to conflate the two issues. It suits Heathrow’s business model to claim that additional capacity is best located at their airport—as opposed to those of rival owners—for example Gatwick or Birmingham. It also suits the operator to claim that the UK economy requires additional hub capacity and that that too can be located at Heathrow. Yet as the Mayor of London has shown there are other potential sites for a hub airport in the South East which would not be constrained in the same way as Heathrow which is set in the most densely populated part of the country. The current DfT Aviation Framework consultation document confirms that London is already one of the best connected cities in the world and has adequate supply of airport and runway capacity for the short to medium term (up to 2030). The capital has five airports (Heathrow, Gatwick, Stansted, Luton and London City) which together serve more routes than any other European city. There are other “near London” airports, currently under used (e.g Ashford and Manston) which have adequate runway length to contribute to the London airport system. Overall the United Kingdom position is very strong the UK being directly connected to more than 360 international destinations. Using available airline seat kilometres as a connectivity metric, only the Chinese and US aviation networks are more extensive than the UK. LAANC urges the government to take action to ensure that aviation forms part of an overall UK strategic national integrated transport infrastructure framework that encompasses airports, roads and rail, including any potential high speed rail. It is difficult to see how the decision already taken for a preferred high speed rail route with a spur to Heathrow can be taken forward at this stage when the decision on where any future aviation hub might be will not be taken before 2015 at the earliest. Airports cannot be allowed to have increased capacity at any cost. There must be sufficient weight given to complying with relevant European environmental legislation on issues such as local air quality and ensuring the avoidance of significant adverse noise impacts in order to protect the health and well being of local communities. UK policy on aircraft noise is currently to “limit and, where possible, reduce the number of people in the UK significantly affected by aircraft noise”. Successive governments have used the 57LAeq decibel contour as a benchmark for identifying onset of significant community annoyance. This covers an area of 106 square kilometres and a population of 224,500 where people live. The Government now admits that community response to aircraft noise has changed over the last 30 years and that this 57LAeq contour is out of calibration. It also concedes that the failure to update social surveys and community response data since the 1985 ANIS and in particular the failure of the ANASE study has led to a breakdown of trust with communities affected by aircraft noise—particularly when the headline results of the ANASE study have been shown to be in line with other independent studies in Europe. UK aircraft noise policy needs to acknowledge the impact of aircraft noise on people’s health and wellbeing. The noise climate around Heathrow is simply too noisy already for too many people, the Aviation Framework Consultation document admits that Heathrow has a significantly greater noise impact per flight than any other major European airport. However even this admission does not adequately describe the disruption to sleep from being awakened by the first arrival of the day at 4.30am for example or the constant passage of flights overhead during the day at 90 second intervals. The current noise metrics also are unable to recognise the value of predictable periods of respite during the day. A more accurate measure of community exposure to aircraft noise must be adopted as soon as possible, including recognition that the frequency of flights is an important aspect rather than just the noise of an individual flight. LAANC supports the government’s s proposals to extend fifth freedoms, review the current runway slots mechanism and access to other UK airports. LAANC believes all of theses measures will be helpful in incentivising the best use of regional airports, which in turn provide the opportunity for relieving the pressure at congested south east airports. LAANC supports the Mayor of London’s proposal that runway utilisation at any of the London airports should be at no more than 75% in order to avoid congestion on the ground, congestion in the air and to improve the passenger experience in terms of the airport’s ability to recover from disruption. Currently it seems there is no overall agreement within the airlines about how much or where extra runway capacity is needed. Before any decisions are made on the provision of extra capacity or whether the hub model is the correct operating model for increasing capacity and maintaining connectivity, the impacts of various changes should be appropriately taken into account including new technologies such as video-conferencing; substitution of short haul for rail trips; increasing oil prices; constraints in terms of reducing climate change cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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emissions; and the impact of new generation aircraft, such as the Boeing 787 which will have the ability to fly longer distances. An international hub needs to be situated where there is sufficient land to facilitate its function as a hub. LAANC believes that on environmental grounds alone Heathrow should be excluded from the review of airport capacity which is to be undertaken by the Davies Commission. There are equally strong operational reasons why a new expanded hub airport could not be sited at Heathrow. The Mayor of London has estimated that based on forecast growth a third runway would be full by 2030. The hub airport model has an insatiable demand for additional runway and terminal capacity. The many connecting flights which feed the long haul routes all need to arrive within a narrow time frame if passengers are not to be left waiting for hours for their transfer flight. Successful hub airports make sure they have additional runway capacity to cope with these “waves” of arrivals. It is why three runways will never be enough at Heathrow. Comparisons with key competitors are always made to support Heathrow’s case for expansion—but the nearest, Charles de Gaulle, has four runways (and is located away from the capital), Frankfurt has four runways and Schiphol has six. There are simply no circumstances in which a four-runway Heathrow would ever be acceptable. It would give rise to a host of new flight paths over residential areas on all sides of the airport and in so doing unreasonably impact upon new communities not currently affected by aircraft noise.

Key Recommendation LAANC would ask the Committee to recognise that a third short runway at Heathrow is not likely to be sufﬁcient in the long term and there will inevitably be pressure for a 4th runway. There is insufﬁcient land for Heathrow Airport to expand to meet the long term requirements of a hub airport. To attempt to propose airport expansion in such an already congested location, with the devastating impacts arising from the demolition of homes and the loss of communities and the unacceptable levels of noise and air pollution that this would be bring to large areas of London, is not rational in any future aviation policy. 20 October 2012

APPENDIX 1 AIRCRAFT NOISE DOSE RESPONSE DATA Introduction This paper presents evidence that there is a useful correlation between the aircraft noise annoyance studies reported in a recent European Environment Agency (EEA) report and the UK Government’s ANASE study. Both sets of studies have found a significant shift in that aircraft noise now causes annoyance at lower levels than it did previously. The significance of this, in relation to the current framework scoping consultation, is that it provides some support for the use of the ANASE findings in the development of future aviation policy. This is important, as without this support, the ANASE findings have been set aside. However, until the ANASE issue can be resolved, the conclusion is that the EEA findings should be accepted for the development of future aviation policy, in relation to annoyance. There remains an important caveat to this, in that the EEA evidence itself needs to be improved by including the significance of flight numbers in any noise annoyance assessment. Only once this is resolved can the question of acceptable aviation capacity be addressed fully. So, in spite of the various study deficiencies, the message remains clear, that aircraft noise now causes annoyance at lower levels than it did previously, and this issue must be addressed in any future aviation policy.

EU and UK Models for Aircraft Annoyance The recent European Environment Agency report[1] is a good practice guide intended to assist policy makers and competent authorities in understanding and fulﬁlling the requirements of Directive 2002/49/EC,[2] commonly referred to as the Environmental Noise Directive, relating to the assessment and management of environmental noise. It summarises the latest European view on issues such as exposure-response relationships and thresholds for health endpoints (annoyance, sleep disturbance, cardiovascular effects and cognitive impairment). Individual annoyance relationships with the noise metric Lden are given for road, rail and aircraft noise. The EEA report gives a previously used European aircraft noise annoyance relationship based on studies carried out prior to 1990. This is the same relationship as given in the 2002 EU Position Paper.[3] The relationship gives an estimate of the percentage of persons highly annoyed at a given Lden noise exposure. The EEA report mentions studies showing a trend change in annoyance around 1990, and gives an updated European annoyance relationship based on aircraft noise studies carried out after 1990. These were all European studies (Switzerland, Germany, Netherlands) regarded as more appropriate for the EU than the pre-1990 studies, which were mainly carried out in the USA and Australia. Figure 1 gives the results for the pre-1990 and post-1990 studies in terms of percentage highly annoyed in relation to Lden. It can be seen that levels of annoyance at a given noise level are much higher for the post- 1990 studies than for the pre-1990 studies. The analysis given in Figure 1 is conﬁned to the range of noise levels in the ANASE study (40.9 to 64.2 dB LAeq,16h). cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Figure 1: Comparison of EU and UK aircraft noise annoyance models

40 %HA

0 43 48 53Lden (dB) 58 63 %HA EEA post-1990 %HA EEA pre-1990 %HA ANASE-derived trend points %HA ANASE-derived %HA CAP725

HA = “Highly annoyed” At 59 dB Lden, for example, the relationship adopted for the pre-1990 studies in Figure 1 gives 16% highly annoyed. In the case of the post-1990 studies, the relationship adopted gives the same percentage highly annoyed at around 49 dB Lden. Thus, the EEA report suggests that levels of annoyance (expressed as percentage highly annoyed) that occurred at 59 dB Lden in the pre-1990 studies occurred at around 49 dB Lden in the post-1990 studies, a reduction of around 10 dB Lden.

The Government’s aviation policy uses 57 dB LAeq,16h as the level of daytime noise marking the approximate onset of significant community annoyance. This level is based on the Aircraft Noise Index Study (ANIS)[4] carried out in the UK in the 1980s. The CAP725 document[5] produced by the Civil Aviation Authority in 2007 outlines methodologies for environmental assessment of an airspace change proposal. It gives an aircraft noise annoyance response relationship for calculating percentage of people highly annoyed using LAeq,16h noise levels. The relationship is based on the Schultz curve produced in 1978.[6] The document states that the ANIS results exhibit the same general trend as the aircraft studies in the Schultz analysis. The EU annoyance relationships use the Lden noise metric rather than the LAeq,16h noise metric used in the UK. Analysis of data[7,8] relating to Heathrow airport in 2006 shows that Lden is typically around 1.7 dB higher than LAeq,16h. This 1.7 dB adjustment has been used to convert LAeq,16h to Lden to give the CAP725 annoyance relationship shown in Figure 1. The Attitudes to Noise from Aviation Sources in England (ANASE) study[9] reported in 2007 that annoyance with a given level of aircraft noise is much higher than when the ANIS study was carried out. The ANASE study made a direct comparison with the ANIS study in terms of “mean annoyance” with aircraft noise. This showed that the level of mean annoyance found at 57 dB LAeq,16h in the ANIS study was found in the ANASE study at a level of just over 50 dB LAeq,16h, a reduction of just less than 7 dB LAeq,16h. The Government accepted that the ANASE study demonstrated that annoyance with a given level of aircraft noise is higher than found in the ANIS study. However, on advice contained in an independent peer review report,[10] the Government decided that the detailed findings of the ANASE study should not be relied on. Most of the analysis in the ANASE report related to “mean annoyance”, and trend lines were fitted to graphs of mean annoyance versus LAeq,16h. Figure 7.2 of the ANASE report gave a graph of percentage “at least very annoyed” versus LAeq,16h, but no trend line was fitted to the plotted data points. In the ANASE study, responses from respondents were recorded using an annoyance scale of (i) “Extremely annoyed”, (ii) “Very annoyed”, (iii) “Moderately annoyed”, (iv) “Slightly annoyed” and (iv) “Not at all annoyed”. The annoyance scale did not include a response of “Highly annoyed” as used in the EEA and CAP725 reports so comparison of the results of the different studies is not straightforward. However, section 6 of the ANASE peer review report[10] assumes that the ANASE term “at least very annoyed” is equivalent to the term “highly annoyed” used in other studies. This assumption allowed the peer reviewers to deduce (apparently by eye) two trend points for the plotted ANASE data points. The two ANASE trend points given in the peer review report are 8.5% highly annoyed at 47/48 dB LAeq,16h, and around 40% highly annoyed at 57 dB LAeq,16h. These trend points relate to the corrected version of ANASE report Figure cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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7.2 given in the Erratum dated 1 November 2007 contained in the ANASE ﬁnal report dated October 2007. This paper therefore tentatively plots the ANASE data, but makes plain that the ANASE values for “highly annoyed” have been derived.

The two ANASE derived trend points are plotted in Figure 1, after converting LAeq,16h to Lden by adding 1.7 dB, derived from Heathrow data for 2006. Using the same assumptions that (i) the ANASE term “at least very annoyed” is equivalent to “highly annoyed” in other studies, and (ii) Lden can be estimated from LAeq,16h by adding 1.7 dB, the results derived for all ANASE sites have been plotted in Figure 1. That figure also shows a third order polynomial trend line fitted to the ANASE derived results. The relatively poor agreement between the plotted data points and the fitted trend line (R2 = 0.667) reflects the spread of the data points, but this is not unusual in social surveys of this kind.

It is important to note that Figure 1 shows that the annoyance levels at a given noise level are much higher for the EEA post-1990 studies than for the EEA pre-1990 studies. For example, percentage highly annoyed at 57 LAeq,16h (approximately equivalent to 58.7 dB Lden) is more than doubled from around 15% for the pre- 1990 studies to around 37% for the post-1990 studies.

It can be seen from Figure 1 that the annoyance levels for the UK’s CAP725 relationship are generally lower than given by the EEA pre-1990 studies relationship, and much lower than given by the EEA post-1990 studies. This implies that continued use in the UK of the CAP725 annoyance relationship will seriously underestimate levels of aircraft annoyance. The ANASE trend line is generally similar to the EEA post-1990 studies relationship, and certainly in much better agreement with the EEA post-1990 studies relationship than is the CAP725 relationship.

The Government rejected the detailed findings of the ANASE study and continues to rely on the ANIS, Schultz and CAP725 aircraft noise annoyance relationships, even though these relationships are based on social surveys carried out more than 25 years ago. It seems doubtful that these relationships remain in calibration for current public attitudes, flight numbers, aircraft fleet mixes and aircraft noise characteristics. The EEA report supports this doubt on the continued validity of these relationships. This is because the EEA report suggests that levels of annoyance at a given noise level are much higher than suggested by previous European guidance. Furthermore, these EEA findings of much higher levels of annoyance seem to be replicated by the results of the recent ANASE study.

Objectives and Findings of the ANASE Study

The ANASE study was commissioned by the Government in 2001 in order to update the ANIS study of 1982 which led to LAeq,16h noise index being adopted by the Government for measuring aircraft noise.

The ANASE report recognises that the amount of air traffic has increased significantly since 1982 whilst the sound levels generated by individual aircraft events have been significantly reduced as older, noisier aircraft have been replaced by more modern aircraft types with quieter engines and much improved climb performance. It is also recognised that attitudes to aircraft noise may have been changed due for example to the general growth in personal income, higher expectations of a peaceful living environment and less tolerance of environmental intrusion.

The main ﬁndings of the ANASE study are reviewed below against the study objectives.

Objective 1

Re-assess attitudes to aircraft noise in England

The study found that the annoyance level of respondents increased as the noise indicator LAeq,16h increased, and that a large proportion of measured variation in annoyance can be accounted for by LAeq,16h.

However, for a given LAeq,16h, there is a range of reported annoyance indicating that annoyance is not determined solely by the amount of aircraft noise as measured by LAeq,16h. The main additional inﬂuences on the level of annoyance were found to be respondent’s household income and socio-economic group.

The study found that for the same amount of aircraft noise, measured by LAeq,16h, people were more annoyed in 2005 than they were in 1982.

The study showed that people are much more sensitive to aircraft noise at night (particularly around midnight and the early hours thereafter). In contrast, people are least sensitive to aircraft noise in the morning and early afternoon. Ideally, therefore, a noise indicator for aircraft noise should reﬂect these times of day sensitivities. In contrast, LAeq,16h does not reﬂect weighting for sensitivities by time of day. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Objective 2

Re-assess their correlation with the LAeq,16h noise index

The study considered whether LAeq,16h is the appropriate measure of aircraft noise for predicting annoyance.

The study found that while LAeq,16h continues to be a good proxy for measuring community annoyance at a given point in time, the relationship between LAeq,16h and annoyance is not stable over time.

Because of this, use of LAeq,16h to predict future levels of annoyance may be misleading. In particular, where numbers of aircraft are increasing signiﬁcantly, the ANASE results suggested that under-prediction of annoyance is likely.

The study recognised that the LAeq,16h noise index incorporates a mathematical trade-off of 10 between event noise level and number of noise events,119 which means that each doubling or halving of the numbers of aircraft noise events counts as equivalent to a 3 dB increase or decrease in average noise levels.120 The results from the study suggested that the LAeq,16h noise indicator gives insufﬁcient weight to aircraft numbers, and a relative weight of 20 appears more supportable from the evidence than the relative weight of 10 inherent in LAeq,16h.

Objective 3 Examine willingness to pay to remove aircraft noise The study was required to examine (hypothetical) willingness to pay in respect of nuisance from aircraft noise, and whether attitudes might be affected if cash transfers or, for example, noise insulation grants were made available. The study found that aircraft event noise level, aircraft type, time of day and personal characteristics (in particular household income) inﬂuence annoyance and willingness to pay.

Aircraft noise action plans The EEA report[1] provides the dose-effect relationships intended to be used to assess the effects of noise on populations as required by the Directive.[2] Section 6 of the EEA report suggests that the lower noise thresholds for mapping are intended to delimit the area where noise is “considered to be a problem”. These thresholds are noise levels above which health effects start to occur. The EEA report accepts that use of the current threshold levels for noise mapping of 55 dB Lden and 50 dB Lnight is understandable as a ﬁrst step because of the large scale noise mapping required. However, the report points out that Member States are free to choose their own noise thresholds from where to start action planning, and the Lden threshold for noise mapping of 55 dB Lden does not take into account differences that exist between different noise sources. These differences are illustrated in Table 6.1 of the EEA report giving respective percentages highly annoyed at 45, 50 and 55 dB Lden for road, rail and aircraft noise. Table 6.1 of the EEA report is reproduced here (in part) as Table 1.

Table 1 TRANSPORTATION NOISE ANNOYANCE (REPRODUCED FROM EEA REPORT) Percentages of highly annoyed Lden Road Rail Aircraft 55 dB 6% 4% 27% 50 dB 4% 2% 18% 45 dB 1% 0% 12%

The EEA report states that while 55 dB Lden is a “fair” threshold for rail noise, use of 55 dB Lden for other noise sources leads to an underestimate of the actual burden. Table 1 gives the percentage highly annoyed at 55 dB Lden for rail noise as 4%, while the percentage highly annoyed at 45 dB Lden for aircraft noise is given as 12%. This means that to achieve annoyance levels approaching that regarded as “fair” for rail noise, the threshold for aircraft noise may have to be lower than 45 dB Lden. In fact, Section 2 of the EEA report gives 42 dB Lden as a general noise threshold above which annoyance effects start to occur or rise above background. It would therefore appear that the EEA report implies that the threshold for noise mapping where aircraft noise is considered to be a problem should be signiﬁcantly lower than 55 dB Lden as currently used.

Conclusions The EEA report recognises that levels of annoyance with aircraft noise are much higher for post-1990 studies than for pre-1990 studies. 119 LAeq,T = SEL + 10LogN—10LogT, where SEL is event noise level (dB) for N events in T seconds. 120 10Log(2/1) = +3dB and 10Log(1/2) = -3dB. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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This paper compares the results for different annoyance models over the range of noise levels in the ANASE study (40.9 to 64.2 dB LAeq,16h). Analysis in this paper shows that annoyance levels redicted by the UK’s CAP725 relationship are generally lower than given by the EEA pre-1990 relationship, and much lower than given by the EEA post-1990 relationship. In contrast, the analysis shows that the much higher annoyance levels in the EEA post-1990 studies seem to be replicated by the ANASE study. Despite this, the Government continues to rely on the ANIS, Schultz and CAP725 aircraft noise relationships derived from social surveys carried out more than 25 years ago. Until the issues of the ANASE study are addressed, it is suggested that Government policy should be based on guidance in the EEA report, including the speciﬁed relationship between annoyance and aircraft noise level. Although the EEA report gives increased levels of aircraft noise annoyance, it does not address all the objectives of the ANASE study. These objectives include the suitability of LAeq,16h as an indicator of community annoyance, the importance of numbers of aircraft ﬂights, the relative importance of different times of day, and determining willingness to pay to reduce annoyance from aircraft noise. Further work is necessary to address these objectives. It is concluded that there is an urgent need for updated guidance from the Government on the annoyance relationship for aircraft noise, and the threshold level at which aircraft noise is considered to be a problem.

References [1] Good practice guide on noise exposure and potential health effects. EEA Technical Report No. 11/2010. European Environment Agency, 2010. [2] Directive 2002/49/EC. Directive of the European Parliament relating to the assessment and management of environmental noise, 2002. Ofﬁcial Journal of the European Communities, L 189, 12–25. [3] Position paper on dose response relationships between transportation noise and annoyance. European Commission Working Group, 2002. [4] United Kingdom Aircraft Noise Index Study. DR report 8402, Civil Aviation Authority, 1985. [5] CAP725, CAA Guidance on the application of the airspace change process. Civil Aviation Authority, 2007. [6] Synthesis of social surveys on noise annoyance. Schultz, Theodore J. Journal of the Acoustical Society of America, 64(2), 1978. [7] London Heathrow Airport Strategic Noise Maps 2006. ERCD Report 0706. Civil Aviation Authority, 2007. [8] Noise exposure contours for Heathrow Airport 2006. ERCD Report 0701. Civil Aviation Authority, 2007. [9] ANASE: Attitudes to Noise from Aviation Sources in England. Final Report prepared for Department for Transport by MVA Consultancy, October 2007. [10] Attitudes to Noise from Aviation Sources in England. Non SP Peer Review. Civil Aviation Authority and Bureau Veritas, draft July 2007, ﬁnal October 2007. File: Aircraft noise annoyance_3

Written evidence from Heathrow Airport (AS 84) Introduction 1. Heathrow Airport welcomes the Committee’s inquiry into the Government’s aviation strategy and we are pleased to submit our comments for the Committee’s consideration. We would welcome the opportunity to present oral evidence to the inquiry should the Committee wish to invite us to do so. 2. This submission is focussed on aviation capacity and the importance of a hub airport to international connectivity. We would of course be happy to provide additional information on any other issues if this would be helpful to the Committee’s inquiry.

Aviation’s Role in the UK Economy 3. Flying is of real value to the UK, for the economy, for society and for consumers. Aviation is Britain’s link into the global marketplace. It supports billions of pounds of British exports and thousands of jobs by giving British businesses direct access to markets, customers and expertise worldwide. The UK aviation industry is a British success story. For the last ﬁfty years, the UK has been at the heart of global aviation and today aerospace is the UK’s second largest export. 4. More than 326,000 people in Britain are directly employed in the aviation sector; 76,500 people work at Heathrow alone, with 22% of jobs in local boroughs based at the airport. A further 100,000 jobs are indirectly supported by the airport. The new Terminal 2 will create 32,000 construction jobs over the lifetime of the project. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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5. Furthermore, over 345,000 people across the UK rely on the supply chain from aviation for their jobs. The supply chain for Heathrow’s new Terminal 2 stretches across the UK, with multimillion pound contracts awarded in every region of Britain, including steel from Lancashire, a roof from Merseyside, electrics from Wolverhampton and concrete from Yorkshire. 6. Aviation plays a central role in international trade. There is a direct relationship between frequent air connections and improved volumes of trade and investment. UK businesses trade 20 times as much with emerging market countries that have a daily direct flight to the UK as they do with those countries that do not121. 7. According to HMRC, the value of goods shipped by air freight between the UK and non-EU countries is around £116 billion, or 35% of the UK’s extra-EU trade by value. In recent times the UK’s manufacturing sector has evolved to concentrate on high skill, high value-added goods which are increasingly transported by air. 62% (by value) of all UK air freight passes through Heathrow, equivalent to goods worth around £35 billion a year. 55% of the UK’s exports of manufactured goods to countries outside the EU are transported by air. 8. The UK has the sixth largest tourism industry in the world and the Government has made growing inbound tourism a priority for this parliament. In 2008, overseas visitors to the UK arriving by air contributed £14 billion (86%) of the total of £16.3 billion spent by all overseas visitors. Of these approximately 75% entered the country through one of the airports in the London area. VisitBritain’s recent consultation on Britain’s tourism strategy argues that “new airport capacity in the south east is essential to accommodate tourism growth and ensure that Britain remains a competitive destination for airlines and their passengers”122. 9. Heathrow welcomes over four million long-haul visitors a year who spend £4.4 billion per year in the UK. A further 2.5 million transfer passengers chose to stopover in London, spending on average more than £500 each per visit. 10. The aviation sector is also a significant contributor to the public purse, as well a significant source of private funding for national infrastructure. A report published last year by Oxford Economics found that the UK aviation industry pays over £8.6 billion in tax each year—£6.7 billion through aviation firms and employees, and a further £1.9 billion through Air Passenger Duty.

The Importance of International Connectivity and Hub Airports 11. It is encouraging to see that the Government recognises the importance of a hub airport and the unique role that Heathrow plays in terms of the UK’s international connectivity. As the UK’s only hub airport, Heathrow provides Britain with a global route network of direct, fast and frequent connections to cities around the world. It has 75% of the UK’s long-haul flights, including its only connections to key business centres like Shanghai, Tokyo and Mumbai, and emerging cities like Sao Paolo, Bangalore and Mexico City. Seven out of the top ten business routes in the world currently have Heathrow at one end. 12. This scale of international connectivity cannot be provided by point-to-point airports. Hub airports are not simply larger versions of an ordinary airport; they operate in a different way. There is not enough demand in a local market (even in London), nor is the demand sufficiently constant day by day and month by month, to sustain a daily flight to economically important destinations such as Bangalore or Chennai. Airlines overcome this by pooling demand from a number of local destinations at a hub airport. Edinburgh’s, Belfast’s and Newcastle’s businesses alone might not be able to sustain demand for a daily flight to Mexico City or Sao Paulo but by pooling that demand from around the UK and Europe at Heathrow, airlines can keep direct flights to these destinations viable throughout the year and on off-peak days. 13. As an example, outside of Heathrow, only one airport in the UK had a direct scheduled flight to India. Birmingham Airport used to operate one flight a day to Delhi (it was withdrawn by Air India in 2009). This was driven by a particular local demand and was a typical point-to-point service. In contrast, Heathrow operates 123 flights a week to six cities across India. 14. Heathrow offers at least one daily flight to 82 long-haul destinations. 60 of those routes have between 15% and 50%+ transfer passengers. If airlines lost the revenue from those passengers, frequent flights to those destinations would not be sustainable. Some of the destinations most at risk would be Hyderabad (80% transfer traffic), Chennai (73% transfer traffic) and Mexico City (61% transfer traffic). 15. As the Government’s Draft Framework notes, the future of the UK will continue to be shaped by the effectiveness of its international transport networks. 16. Britain’s connectivity needs are changing and links to the BRIC economies are becoming increasingly important. The eight largest Emerging Markets will account for more than half of worldwide GDP growth over the next ten years. We are faced with choices about how best to structure Britain’s economy for this future. 17. The UK is currently lagging behind European competitors in terms of BRIC connectivity. Paris and Frankfurt already boast 1,000 more annual flights to the three largest cities in China than Heathrow. Passengers 121 Frontier Economics, Connecting for Growth, September 2011 122 Delivering a Golden Legacy—A growth strategy for inbound tourism to Britain from 2012 to 2020 cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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wanting to fly between London and Chengdu, Nanjing, Hangzhou, Xiamen or Guangzhou, have to fly via a European hub airport. In total, there are 21 emerging market destinations with daily flights from other European hubs that are not served from Heathrow; including destinations such as Manila, Guangzhou, and Jakarta123. The lack of direct flights to Emerging Markets could be costing the UK £1.2 billion a year in missed trade opportunities. 18. We support the Government’s objective to protect and enhance the UK’s connectivity and welcome the principle of aviation growth within a sustainable framework. We support the proposal to encourage growth at point-to-point airports around the UK but it is important to recognise that expansion at these airports cannot substitute Heathrow’s role as the UK’s hub, nor the range of long-haul connectivity that the hub function provides. 19. In setting up its Independent Commission on Aviation Connectivity, chaired by Sir Howard Davies, the Government has recognised that maintaining Britain’s aviation hub status is critical to the UK’s future economic success. 20. There are no easy options when it comes to hub airport capacity but there are plenty of solutions being proposed. Rather than advocate a particular solution at this stage, we believe that diagnosis is more important. Does it matter to the UK if we have a hub airport? And if so, what do we require from a hub? Until the UK can agree what it needs from its hub, it is impossible to assess which option is best placed to meet those needs. It is more important to make a considered decision than to make a quick decision. 21. The qualities that make hub airports successful can be defined and assessed. Heathrow will shortly be publishing a document which sets out the criteria against which all the different options for UK hub capacity could be assessed.

Making Better use of Existing Capacity 22. We support the Government’s objective to make best use of existing runway capacity at all UK airports. 23. At Heathrow we have taken, and continue to take, a number of important steps to make best use of capacity at the airport, including working with our airlines to improve punctuality and trialling operational freedoms to improve performance and resilience. 24. However, it is important to realise that these are limited tactical measures that will not slow the decline of Heathrow’s hub status, and in turn the UK’s relative connectivity, in the long-term. 25. It has been suggested that the Government should encourage greater use of regional airports instead of Heathrow. As the operator of several airports around the UK, we fully recognise the important role that point- to-point airports play in their local economy and we support Government efforts to enhance connectivity from airports across the country. 26. However, point-to-point airports cannot replicate hub airport functions. There is already spare runway capacity at other London airports, as well as airports like Birmingham and Manchester, yet airlines choose not to use them unless there is sufficient local demand to sustain a route. This is because without the feed of transfer passengers to top up the peaks and troughs of local demand, airlines find it hard to keep a route profitable. 27. Existing capacity at point-to-point airports across the UK is complementary to, rather than a substitute for, hub airport capacity at Heathrow. 28. Experience has shown that if network airlines cannot fly from Heathrow, they tend not move to other London or regional airports, they move to Amsterdam, Paris, Frankfurt, Madrid or Dubai instead. Our European and Middle-Eastern competitors have already taken steps to capitalise on the changing locus of the world economy. We should not take the UK’s position as a successful hub for aviation for granted. 29. The role of airspace should not be forgotten in making best use of existing capacity. More efficient use of airspace, including full implementation of the CAA’s Future Airspace Strategy and the EU Single European Skies (SES) initiative, is an important step in making best use of existing runway capacity.

Environmental Impacts 30. The challenges of aviation growth are being tackled with determination by the industry and aircraft are getting quieter and cleaner. However, we recognise that people living around airports continue to be affected by noise and pollution and we are committed to further improving our performance. 31. We believe that aviation, like all sectors of industry, has a role to play in avoiding dangerous climate change and meeting the UK’s 2050 target of cutting greenhouse gas emissions by 80% below 1990 levels. Through Sustainable Aviation, the coalition of airlines, manufacturers, airports and NATS, the aviation industry has set out a robust long-term strategy to play its role. More information is available at www.sustainableaviation.co.uk. 123 Ibid cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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32. Aircraft are getting cleaner. Aircraft today are around 70% more fuel efficient than forty years ago. Emissions trading will deliver net reductions in carbon, while technology, improved operational procedures and alternative fuels develop to deliver absolute reductions. The Committee on Climate Change has said that aviation in this country can grow by up to 60% without risking UK climate change targets. Government should focus efforts on ensuring successful implementation of the EU Emissions Trading Scheme (ETS) and achieving a global sectoral deal. 33. We are committed to playing our role in reducing local air pollution and helping to meet EU limits in the vicinity of the airport. We recently published our 2011–20 strategy for air quality at Heathrow which sets out the actions we plan to take to achieve this. This focuses on continuing to incentivise the use of cleaner planes and operating practices, promoting cleaner airside vehicles, and changing travel behaviour for staff and passengers. 34. Activities outside the airport also contribute to air quality concerns. The contribution to pollution of activities within the airport boundary falls rapidly with distance from the airport. Traffic on the road network in the surrounding area plays a significant role. Heathrow is close to two major motorways and a major motorway junction. Some of the traffic on that network is airport-related but much is not—on the M4 near Heathrow, only one in five vehicles are “airport-related”. Improvements in vehicle technology will therefore play a critical role in meeting pollution limits around the airport, as indeed they will in other urban areas in the UK (particularly in central London). 35. Noise is the main local impact of Heathrow. The airport’s location close to London, combined with its status as the world’s busiest international airport, mean that we have been at the forefront of UK and global approaches to tackling noise. We have a strong record of performance improvement. Equally, Heathrow’s location means that the bar is set high and we are committed to exploring what more we can do. 36. The aviation industry has delivered quieter aircraft and we are confident that technology improvements will continue to reduce noise. In 1970s, around 2 million people living around Heathrow fell within the 57dBA contour; by 2011, that number had shrunk to 243,350. New technologies, improved operations, more effective community engagement and enhanced mitigation measures will all have a role to play in reducing noise impacts in coming years. 37. Our strategic approach to noise is based on the “Balanced Approach” agreed by the International Civil Aviation Organisation’s (ICAO). The “Balanced Approach” has four elements: — The development and use of quieter aircraft (“reduction at source”). — The development and use of quieter operating procedures. — Land-use planning around an airport and mitigation schemes to reduce exposure to noise. — Operating restrictions. We have actively sought to limit the impact of noise around Heathrow over many years, based on the approach above. 38. Noise is a complex issue. Traditionally, airport operators, including Heathrow, have not been successful in communicating effectively on noise issues to the local affected communities. Our challenge, working with community groups, is to find ways to improve our communications about noise so that they are understandable to non-experts and reflect local concerns. We are currently undertaking an extensive programme of research to further improve our understanding of community attitudes to noise. This is critical if we are to focus our efforts on the issues of most concern to residents. 39. We support the Government’s aims of improved transparency and more effective collaboration between industry and community groups to help address and mitigate the challenges of noise. At Heathrow we have made particular efforts in recent months to improve our engagement with the local community and look forward to sharing best practice and lessons learned in due course.

Conclusion 40. Aviation plays a vital role in the UK’s economy. We welcome the Government’s recognition of the economic beneﬁts of aviation, particularly the importance of a hub airport and the unique role that Heathrow plays in terms of the UK’s connectivity. 41. The future of the UK will continue to be shaped by the effectiveness of its international transport networks. Britain’s connectivity needs are changing and links to the BRIC economies are becoming increasingly important. We are faced with choices about how best to structure Britain’s economy for this future. 42. Until the UK can agree what it needs from its hub, it is impossible to assess which option is best placed to meet those needs. It is more important to make a considered decision than to make a quick decision. 43. The Davies Commission should ensure that all options for maintaining the UK’s position as an international hub for aviation are objectively assessed against the criteria that make a hub airport successful. 44. Making best use of existing runway capacity is important but the scale of international connectivity offered by Heathrow cannot be provided by point-to-point airports. Hub airports are not simply larger versions cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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of an ordinary airport; they operate in a different way. Existing capacity at point-to-point airports across the UK is complementary to, rather than a substitute for, hub airport capacity at Heathrow. 45. The challenges of aviation growth are being tackled with determination by the industry and aircraft are getting quieter and cleaner. However, we recognise that people living around airports continue to be affected by noise and pollution and we are committed to further improving our performance. 46. The Government is right to place renewed emphasis on transparency and collaboration between industry and local communities. At Heathrow, we have been working with community groups to build on the measures we have taken in the past and explore what more we can do. We look forward to sharing lessons learned in due course. 22 October 2012

Further written evidence from Heathrow Airport Ltd (AS 84A) Thank you for the opportunity to give oral evidence to the Transport Select Committee on Monday 3 December 2012. I am responding to an email received from Dr Farrah Bhatti, the second clerk on Monday 3 December, following the evidence session, requesting the following information: 1. Further statistics on the number of hub transfer passengers at Heathrow—in particular, data on whether these are passengers flying into Heathrow from the UK regions (outside the south east) or from other countries (eg short haul European flights); and, 2. Further details of our estimate of the additional aviation emissions generated due to congestion at Heathrow and also due to passengers taking an additional flight, for example, by transferring at a European hub, rather than flying direct to their chosen destination. Dealing with these in turn.

1. Transfer Passengers Domestic transfers are key to making the hub operation work. According to CAA data, 16% of all transfer passengers flying into Heathrow in 2011 were from domestic airports and they connected onto long haul routes. The make-up of passengers on domestic routes illustrates how these passengers contribute to hub activity. So, for example, in 2011, 26% of all passengers flying from Aberdeen to Heathrow transferred onto a long haul flight, with a further 19% transferring to a short haul destination; 62% of passengers flying from Manchester to Heathrow transferred onto a long haul flight, with a further 17% transferring to a short haul destination.

2. Impact of Capacity Lack of capacity at Heathrow means direct routes that would be economically viable are not being realised. Our view is that, in carbon terms this is inefﬁcient since Heathrow passengers are ﬂying further and need to make an additional take-off and landing. This can be illustrated by two simple examples, based on calculations using publically available online emissions calculator (http://calculator.carbonfootprint.com/calculator.aspx) that compare CO2/pax for journey's made directly and indirectly to long haul destinations to the west and east.

Example 1 Flight going west: Heathrow to Caracas via Frankfurt: Caracas is a fast growing city which is not currently directly linked to Heathrow. If a passenger flies to Caracas from Heathrow via Frankfurt then this would create 16% more emissions per passenger than a direct flight from Heathrow. This is because you need to fly further and take off and land twice.

Example 2 Flight going east: Heathrow to Wuhan via Paris: Wuhan is a major secondary city in China which is not currently linked to Heathrow. Flying to Wuhan indirect from Heathrow via Paris creates 5% more CO2 per passenger than a direct flight from Heathrow (the distance penalty is much smaller than a flight where the final destination is West, but the take-off and landing penalty remains). I hope that this information satisfactorily deals with the questions you have raised, but please do let me know should you require any further information. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Supplementary written evidence from Heathrow Airport (AS 84B) Thank you for giving Heathrow the opportunity to appear before your Committee's Aviation Strategy Inquiry last year. I have been following the subsequent sessions with interest and wanted to write to you regarding the session on February 11th 2013 with the Mayor and his aviation advisor. During this session both your Committee and the panel spoke about the importance of surface access to aviation policy. Colin Matthews also spoke of the importance of surface access during his oral evidence session on December 3: "I think you will find that the question of surface access becomes a huge economic driver. For an airport in a new location, or one that is poorly served by rail connections, the cost of putting in those connections will be absolutely huge, whereas the case of an existing airport is different." I wanted to write to you to clarify the discussion with the Mayor and his aviation adviser regarding access to Heathrow from the West and Wales. Whilst it is true that currently there is no direct rail line coming to Heathrow from the West (passengers have to change at Paddington station and then can take the Heathrow Express—a 15 minute service, four times an hour), there are well developed plans for Western Rail Access (WRA). The Government's High Level Output Specification (HLOS), published on 16 July 2012, sets out its future investment plans for the rail network for the period 2014–19. As part of the HLOS's commitment to improving railway links to major ports and airports, it specifically refers to the development of plans for a new western rail link into Heathrow, requiring that construction of the western rail link is commenced during Control Period 5 (2014–19) with delivery anticipated to extend into Control Period 6 (2020–25). It states that: "This will be subject to a satisfactory business case and the agreement of acceptable terms with the Heathrow aviation industry. It will provide a major boost to the airport's accessibility, substantially reducing Heathrow airport journey times from Wales and western England, supporting the extension of the vibrant Thames Valley economy westwards, and complementing the proposed high speed rail access". Both the DfT press release accompanying the HLOS publication and the Draft Aviation Policy Framework confirmed that the Government had set aside £500 million towards the Heathrow rail link. In a more recent parliamentary question and answer session on 5 December 2012 in respect of High Speed 2, Transport Minister Simon Burns reaffirmed the Government's commitment to progress the Heathrow western rail link: Geoffrey Clifton-Brown: To ask the Secretary of State for Transport what estimate he has made of the likely level of additional funding for the proposed Western Connection to Heathrow; and what proportion of that funding will be (a) provided by the Government and (b) sought from a third party. [131940] Mr Simon Burns: The July 2012 High Level Output Specification includes provision for £500 million of funding for a new western rail access to Heathrow airport, subject to business case and agreement of terms with the Heathrow aviation industry. The rail industry is currently developing plans for the delivery of the scheme within the allocated funding. The cost of the link and availability of private funding will be considered in detail as the rail industry develops the proposal. Heathrow Airport supports the principle of WRA, and recognises that it has the potential to deliver significant benefits to society including driving economic growth and employment opportunities, reducing CO2/local air quality, as well as reducing congestion on local roads and the strategic highway network. This letter has also been copied to Boris Johnson, Mayor of London and Daniel Moylan, Aviation Advisor. If you would like any more information about the plans for surface access to Heathrow, or our current surface access arrangements please let me know. February 2013

Written evidence from the UK Airport Consultative Committees Liaison Group (AS 85) The Liaison Group for UK Airport Consultative Committees (UKACCs) welcomes the opportunity to respond to the Transport Select Committee's current inquiry which seeks to examine the Government's aviation strategy and in particular airport capacity in the UK. UKACCs brings together 23 airport consultative committees (ACCs), ranging from major international gateways to smaller regional airports across the UK (member committees listed at the bottom of this letter), fulﬁlling the statutory role required by government that airports should provide consultative facilities. The 2010 CAA airport statistics record that these 23 airports had a total annual throughput of over 203 million passengers accounting for about 96% of total UK passenger movements of 211 million. UKACCs provides a valuable forum as its membership covers a wide range of airports each with different local operational cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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circumstances. As such UKACCs can play an important role in helping inform government in policy development. As the Committee will be aware, there are a number of key aviation related Government consultations either under way or planned. These include the Government's consultation on its draft aviation policy framework, the Independent Commission chaired by Sir Howard Davies and proposals for a new night noise consultation at Heathrow, Gatwick and Stansted. UKACCs, as well as individual consultative committees, will be responding to these consultations reﬂecting particular local circumstances and issues. UKACCs supports the Government's stated objective that UK aviation should be able to grow, but to do so it must be able to play its part in delivering environmental goals and protecting the quality of life of local communities. The Group also endorses the three proposed key themes that should underpin a future high-level framework—Aviation and the Economy; Aviation and Climate Change and Aviation and the Local Environment. UKACCs fully recognises the importance of connectivity and its key role in helping the UK economy grow on a sustainable basis. Airports outside the South East have a vital role in providing international and domestic connections across the UK, and contributing to local economies. The Group has welcomed the Government's stated wish to explore how to create the right conditions for such airports to ﬂourish. UKACCs has long lobbied the Government to address the issue of protecting domestic services from the far regions of the UK into the London airports. The Group has regularly highlighted that there is an urgent need to review the worsening situation. In addition to this, there has been growing concern about the increase in landing charges at Heathrow and Gatwick airports which has resulted in some regional carriers withdrawing services between the regions and the London airports because a viable operation can no longer be sustained. UKACCs—particularly its regional airport member committees—continues to have real concerns about the negative impact of capacity constraints. In particular the major London airports have seen a steady reduction in point to point regional services. The crowding out of regional services from the capacity constrained London airports is continuing to have an adverse impact on the economic performance of the far regions of the UK and so affect their contribution to the national economy. Faced with capacity constraints, the major airports appear to be prioritising long haul international services over regional services. Whilst it is clearly open to airports to use their commercial judgement in the best interests of the airport company and its shareholders, such action clearly has wider national and regional implications. Passengers using regional airports faced with limited services to Heathrow will look to interline over European hubs such as Schiphol, Frankfurt and Paris etc. This leads to dilution and loss of revenue to the UK economy. UKACCs has been keeping a watching brief on the CAA's consultation investigating the complaint made by Flybe against Gatwick Airport (GAL) about the change in the structure of landing charges. Flybe have maintained the new structure of charges discriminates against operators of small aircraft. It also believes that the new charges will have a detrimental impact on point-to-point regional services to London because airlines using small aircraft are less able to absorb higher costs. The CAA has reached a provisional decision that GAL has not unreasonably discriminated against any particular user of the airport or class of users (whether airline or passenger). This case has raised important issues and UKACCs therefore suggests that the Committee might wish to consider the implications for capacity constraints at the London airports on services to the far regions of the UK. The Group notes that the Government has suggested that demand for domestic aviation and much of that for near-European short-haul aviation could be met by high-speed rail although it also acknowledges that air transport will continue to provide essential links to more remote parts of the UK and areas not served by high speed rail. UKACCs welcome the development of high-speed rail initiatives and the important contribution that these can make to the future UK transport network. However it must be accepted that high speed rail connectivity will not be delivered for many years and that domestic air travel is a reality. The Government therefore needs to preserve domestic air travel as an essential part of the UK's strategic transport infrastructure for many years to come. It needs to be recognised that whilst new high-speed rail connections will provide an opportunity to replace existing domestic air services for some regions especially the Midlands and the North, it will not provide a total solution across the UK. There will be a time threshold where rail does not provide a viable option especially for the Scottish airports, and never can to Northern Ireland, the Channel Islands or the Isle of Man. There will still be a requirement for domestic services from these areas if the Government's wish that there should continue to be essential air links to the more remote parts of the UK is met. It must also be recognised that neither Gatwick nor Stansted airports will have a direct connection to the high speed rail network and a connection at Heathrow will only be realised in around 20 years time. UKACCs will continue to urge Government to review its policy towards domestic air services to ensure the future viability of an effective network. UKACCs accept that the preservation of an effective domestic network is subject to a number of considerations including commercial interests and EU obligations. UKACCs has been encouraged to note that the current airport slots regulations are now being reviewed in the EU. The Group hopes that this will lead to a mechanism that might protect domestic access to the London airports. UKACCs cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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will also be asking the Government to consider the appropriateness of the current PSO legislation and decide whether it remains ﬁt for purpose. If the UK is to have a sustainable domestic network of air services, it would seem essential that slot allocation must be looked at in a different way. 22 October 2012

Written evidence from Friends of the North Kent Marshes (AS 88) Friends of the North Kent Marshes is a voluntary group, formed in 2004 out of the No Airport at Cliffe Campaign Liaison Group, following the successful ﬁght against the proposals for an airport at Cliffe. Our aim is to promote the Marshes and the ways in which everyone can enjoy them. We work both with the local communities that live on and around the Marshes, and with groups such as the RSPB as they develop ﬂagship visitor sites here. The area faces many threats as pressure for land and development in the southeast continues. We welcome the opportunity to make our voices heard in this important debate by taking part in the Transport Committee inquiry examining the Government’s aviation strategy.

Summary We are wholly opposed to the construction of an airport anywhere in the Thames Estuary because of the immense damage it would cause to the area’s internationally important wildlife and the wider environment. The whole issue was exhaustively investigated in the run up to the publication of the previous Government’s Aviation White Paper (2003). All the key players, including the aviation industry, contributed, and the idea of an airport in the Thames Estuary was ruled out. In addition to the unprecedented environmental damage and the resulting legal implications, the investigation found that an estuary airport did not make economic sense, would not meet the requirements of the aviation industry and presented a signiﬁcantly higher (up to 12 times greater) risk of “bird strike” than at any other major airport in the UK. It would potentially be the single biggest piece of environmental vandalism ever perpetrated in the UK. The Government would have to recreate any lost or damaged habitat elsewhere BEFORE work on the airport could start and even then only if they could prove there is no alternative site for the expansion and it is in the overriding public interest. They would face a legal battle, which could last for years. Recent statements and proposals by London Mayor Boris Johnson, Norman Foster and others in favour of an estuary airport, do nothing to alter these ﬁndings. The threats and risks remain the same. An airport in the Thames Estuary is unrealistic due to the ecological, environmental and economic impacts it would cause. An estuary airport would destroy whole communities and adversely impact many others on both sides of the Thames estuary.

Detailed Comments 1. Aviation expansion 1.1 We do not support aviation expansion be it anywhere in the Thames Estuary, Lydd or elsewhere. We believe that the demand for flights should be managed and the current Government policy on airports should be revised away from the “predict and provide” expansionist approach of the last decade that threatens the climate and important wildlife sites. There must be a moratorium on air travel expansion until it can be demonstrated that significant increases in emissions from air-travel can be accommodated within a UK cut of 80% in emissions by 2050, as enshrined in law by the Climate Change Act (2008). Without this, the scale of the cuts required in the rest of the UK economy to offset a continuing rise in aviation emissions would be potentially crippling. Instead, demand for flights should be managed by encouraging the use of lower carbon modes of transport and the removal of the substantial subsidies that the industry currently enjoys including tax-free fuel, and the absence of VAT on all aspects of aviation. 1.2 We do not believe that the case for extra capacity/new runways has been made and even if the Government ever came to the conclusion that it had, a Thames estuary airport should not be included as a viable option in any new Government strategy. Economically, environmentally and ecologically it would be a complete disaster plus it would be the most dangerous major airport in the UK due to the risk of bird-strike.

2. Economic issues 2.1 An airport in the Thames Estuary would be massively expensive and the necessary additional transport infrastructure would further add to the cost. The overall cost (with current estimates around £95billion in total and taxpayers would have to fund around £65billion of that sum, more if the full £30 billion airport costs cannot be met by private investment) combined with its apparent unpopularity with the aviation industry would mean that the airport could struggle to survive economically.

Furthermore 2.2 There is no evidence of support from the City and thus nobody to pay for it. 2.3 The cost could negate the chance of any signiﬁcant return on investment. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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2.4 The volume of air trafﬁc could mean that other London airports might need to close or have travel from them severely restricted. Indeed if Heathrow were to close it could cause huge unemployment around Heathrow, which employs 72,000 direct staff, and the collapse of the economy of the Thames Valley, west London, the M4 corridor and beyond even damaging the welsh economy. Indeed if Heathrow closed would major airlines and global companies then relocate to the new airport or simply move to an existing hub abroad like Frankfurt or Dubai with no risks attached? This scenario could potentially mean 100,000’s total job losses in the UK.

3. Damage to wildlife sites 3.1 An airport sited in the Thames Estuary would, damage or destroy huge areas of legally protected habitat. 3.2 The Thames estuary has extensive areas of internationally protected wildlife habitats (called Special Protection Areas). These protected areas stretch along both sides of the estuary from Gravesend to Harwich and across to Margate and include the newly designated Outer Thames SPA which covers the entire wider Thames Estuary, east of Sheerness. 3.3 The Government would have to recreate any lost or damaged habitat elsewhere before work on the airport could start—and even then only if it could prove there is no alternative site for the expansion and it is in the overriding public interest. It could face a long and protracted legal battle. 3.4 Any damage must be compensated for and there is nowhere in the Estuary or arguably in Europe where such large-scale damage could be compensated for adequately 3.5 Every year, the wider estuarine complex is a hub for 300,000 migrant birds that rely on the area for feeding and roosting. 3.6 The full impacts on the important fish spawning and nursery grounds in the estuary and the subsequent effect on established fishing operations are as yet un-quantifiable.

4. Wider environmental impacts 4.1 Climate change remains the greatest threat to mankind and biodiversity and we believe that there should be no further airport expansion. The construction of a massive new airport in the Thames Estuary will have impacts that extend far outside the immediate area. Emissions from aircraft are one of the fastest increasing sources of greenhouse gases. Unchecked, climate change may see up to a third of land-based species committed to extinction by regional climate change effects by 2050. The impacts of climate change on wildlife in the UK and abroad are already being felt. A report by DARA Climate Vulnerability Monitor 2nd Edition ( http://daraint.org/climate-vulnerability-monitor/climate-vulnerability-monitor-2012/ ) estimates that climate change causes deaths on average each year today, of 400,000 people per annum and that together the carbon economy and climate change related losses cost the global economy $1.2 trillion every year. 4.2 Emissions need to be slashed across all sectors if the 80 percent target is to be achieved, but emissions from aviation are rising rapidly—doubling between 1990 and 2000. Further airport expansion should be prevented until it can be demonstrated that significant increases in emissions from air-travel can be accommodated within a UK cut of 80% in emissions by 2050. 4.3 The demand for flights should be managed by encouraging the use of lower carbon modes of transport and the removal of the substantial subsidies that the industry currently enjoys including tax-free fuel, and the absence of VAT on all aspects of aviation. 4.4 In a low-lying area like the Thames Estuary, the threat of climate change is particularly significant and it is foolhardy to consider building an airport that would only contribute to the underlying problem. 4.5 Successive governments have stressed the importance of sustainable development, particularly in the Thames Estuary. The recent announcement of the Greater Thames Marshes Nature Improvement Area suggests that the estuary is still seen as very important in environmental terms. Such importance would be disastrously undermined if the airport became a reality. 4.6 Development of the scale proposed would alter tidal flows, changing erosion patterns; with potential negative outcomes for the estuary’s busy shipping lanes.

5. Bird strike 5.1 An airport in the Thames Estuary would be unsafe. To land planes in a foggy, bird-rich estuary makes it one of the most unsafe locations in the world unless draconian clearance of the ﬂocks that make the Thames their home is undertaken, year after year. Even with an aggressive bird hazard management programme (ie shooting or scaring the birds away), the bird strike hazard could be up to 12 times higher than at any other major UK airport. A 2002 study (Study on safety risks from birds and safety measures around Cliffe Marshes by Central Science Laboratory/British Trust for Ornithology for the Department for Transport, 2002) commissioned by the Department for Transport on the bird strike issue found that “the environment around the Cliffe airport option contains substantial numbers of birds hazardous to aircraft. Without a comprehensive and aggressive bird management programme in place, incorporating careful and considered airport design, appropriate habitat management and active bird control, an airport could not operate safely in this location. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Even with such world class management and mitigation measures in place as identiﬁed in this report, it is not considered possible to reduce the risk to a level similar to that experienced at other UK airports.” We believe it would be irresponsible for any government to ignore such evidence.

6. Hazards 6.1 A hazardous shipwreck packed with explosives lies in the estuary. The SS RICHARD MONTGOMERY was a US Liberty Ship of 7146 gross tons. She was built in 1943 by the St John’s River Shipbuilding Company of Jacksonville, Florida and was one of over 2700 of these mass-produced vessels built to carry vital supplies for the war effort. In August 1944 the ship was loaded with a cargo of some 7000 tons of munitions and joined convoy HX-301 bound for the UK and then on to Cherbourg. On arrival in the Thames Estuary, the vessel was directed to anchor in the Great Nore anchorage off Sheerness. The ship was to await the formation of a convoy to continue the journey across the Channel. However, on the 20th August 1944, she dragged her anchor in the shallow water and grounded on a sandbank running east from the Isle of Grain approximately 250m north of the Medway Approach Channel. The vessel grounded amidships on the crest of the sandbank and intensive efforts began to unload her in order to lighten the vessel so that she could be refloated and also to save the cargo of munitions that were vital for the Allies post-D-Day advancement. Unfortunately, by the next day, a crack appeared in the hull and the forward end began to flood. The salvage effort continued until the 25th September, by which time approximately half the cargo had been successfully removed. The salvage effort had to be abandoned when the vessel finally flooded completely. The wreck of the SS RICHARD MONTGOMERY remains on the sandbank where she sank. The wreck lies across the tide close to the Medway Approach Channel and her masts are clearly visible above the water at all states of the tide. There are still approximately 1,400 tons of explosives contained within the forward holds. The Department for Transport is responsible for the safety of the wreck. 6.2 National Grid’s £1 billion gas import terminal on the Isle of Grain is the largest in Britain with suggestions to Mark Reckless MP that it would cost £3 billion to remove it to make way for an airport 6.3 Fog A report commissioned by Medway Council showed that the Thames estuary region was three times more susceptible to foggy conditions in comparison to Heathrow Airport.

9. Impacts on Communities 9.1 Last, but by no means least, we come to the destruction of whole communities either under the footprint of a new estuary airport or due to noise, danger zones, pollution and the colossal amount of infrastructure that would be needed to service such gargantuan airport ideas. It has been suggested by Foster Partners that people have no comprehension of the size and scale of a new 21st century hub airport. Well, as communities who were last threatened with annihilation by an estuary airport only a decade ago, we most certainly do. It is so much more than just an airport and runways! 9.2 Medway: The myth that this area of North Kent is an unoccupied wasteland awaiting development is most definitely not the reality. As of February 2012, Medway had 6,508 unemployed. A Thames Estuary airport—which would see twice as many passengers use it a year as Heathrow (150million against 70million)—would employ 70,000 directly and at least another 50,000 in related industries such as warehousing, hotels, depots etc. Medway does not need that many jobs—as there are not anywhere near that many jobless—and is already doing much to bring about investment without concreting the whole area. For instance, Peel Holdings has just had a plan approved to build Chatham Waters a huge £650 million development of flats, hotels and a media centre at Chatham Docks. This will provide 3,500 jobs. Elsewhere, 6,000 jobs are set to be provided at the National Grid Site in Grain while the largest single distribution centre in the south east (1.2million sq ft) has gained planning consent at Kingsnorth. There is now also a fast train to London making commuting easier and faster and four universities providing an education for more than 10,000 students. In fact, Medway has worked closely with councils and businesses to bring regeneration across North Kent and the whole area is on target to see an extra 52,000 homes and 58,000 jobs in the years between now and 2026. 9.3 In contrast, a new Thames Estuary airport would be tied up in legal and planning issues for decades (BAA have already indicated they will take legal action against as they say it means Heathrow would be forced to close) and would not be built for decades. Many of the jobs at an airport will be low paid. As an airport will provide 20 times more jobs than needed for the local area, there will undoubtedly be a large influx of people to take these. Estimates show that a new airport would need a new city the size of Manchester built to accommodate all these new people, or around 170,000 new homes in or within the immediate vicinity of Medway. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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In addition, at least 20,000 people—and probably more as we are talking about two decades away—would also need re-housing following compulsory moves from the Hoo Peninsula to make way for any new airport. 9.4 Over 22,000 people live on the Hoo Peninsula, many whose families have lived and worked here for generations and whose children have left home but stayed on the Hoo Peninsula to raise families of their own in this unique area. Nine villages, Grain, Allhallows, Lower Stoke, Middle Stoke, Upper Stoke, St Mary Hoo, High Halstow, Cooling, and Cliffe & Cliffe Woods would either be destroyed by the airport footprint, danger zones, the massive amount of new road, rail and infrastructure or become uninhabitable due to the sheer volume of huge jets flying low overhead 24 hours a day, 365 days a year with no respite. Where would we all go where our close-knit communities and extended families, of which there are many on the Hoo Peninsula, could remain together? Communities in Southeast London, Kent and Essex would be subjected to noise and pollution on a scale never experienced before. On both sides of the Thames estuary, for a radius of around 25 miles, vast swathes of countryside, more homes, businesses and the highest grade agricultural land, a national resource, would be lost due to the immense amount of infrastructure “strengthening” that would be needed to service a new hub airport. 9.5 We have a rich cultural heritage, the Magna Carta is believed to have been drafted here, there are distinctive Napoleonic military defences, 20th century pillboxes and the remains of the Hoo Stop Line which served as a defence to protect London in WW11. This is Dickens country; St James Church in Cooling was the setting for the opening scene of his novel “Great Expectations”. “Ours was the marsh country, down by the river, within, as the river wound, twenty miles of the sea. My first most vivid and broad impression of the identity of things, seems to me to have been gained on a memorable raw afternoon towards evening. At such a time I found out for certain, that this bleak place overgrown with nettles was the churchyard; and that Philip Pirrip, late of this parish, and also Georgiana wife of the above, were dead and buried; and that Alexander, Bartholomew, Abraham, Tobias, and Roger, infant children of the aforesaid, were also dead and buried; and that the dark flat wilderness beyond the churchyard, intersected with dykes and mounds and gates, with scattered cattle feeding on it, was the marshes; and that the low leaden line beyond, was the river; and that the distant savage lair from which the wind was rushing was the sea; and that the small bundle of shivers growing afraid of it all and beginning to cry, was Pip.” People come from all over the world come to visit this beautiful area, a hidden gem, with its ruined castles, Norman churches, ancient monuments and fine listed buildings, where Charles Dickens lived, wrote and walked for miles. Indeed he took his house-guests out for walks across the marshes from his home nearby at “Gads Hill” in Higham. 9.6 Communities in North Kent have been here before and stood shoulder to shoulder with RSPB and many others as it fought its largest ever campaign against a proposal to site a new airport on Cliffe Marshes. The successful “No Airport at Cliffe campaign” brought a greater awareness of the Thames Estuary & its marshes, why they are so special and why they are protected under local, national & international law. These proposals, which were part of a Government review of airport capacity in the South East, were eventually rejected. The review also considered the option of siting an airport in the Thames Estuary. These proposals were also rejected A new hub airport anywhere in or around the Thames Estuary would potentially be the single biggest piece of environmental vandalism ever perpetrated in the UK. 9.7 There is a strong sense of community among those that live alongside the marshes. We share the vision of the RSPB Greater Thames Futurescapes project and look forward to a sustainable future and a healthy environment where development happens to benefit wildlife and people. We strongly urge the Transport Committee to ask the government not to include a new Thames estuary airport as a viable option in any new Government strategy and to rule out building a new hub airport anywhere in or around the Thames Estuary at the earliest opportunity. 22 October 2012

Written evidence from the Adams Group (AS 93) A PROPOSAL FOR A SOLUTION TO THE SITING OF A NEW LONDON/UK HUB AIRPORT 1. Introduction In reflecting on the discussions about where the next UK Hub Airport should be located there are numerous aspects that must be considered but, in our view, there are three (at least) that should play a major part in shaping the progress towards a solution: 1. that Heathrow, even with an Interim solution to the present runway capacity shortage, will have only a limited effective life (2030?) as a Hub because it’s future potential will not be sufficient to meet the International Aviation traffic demands of the 21st century and further, environmentally it will always be seen as an unacceptable threat to the large (and growing) urban residential communities cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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of Central and West London. It must therefore be seen as an Airport that will not be fit for purpose and must be either substantially reduced in size or completely closed. 2. that to be an effective replacement to Heathrow, the necessary new Hub Airport at any another location must be sited within a 30/40 mile radius of London with rapid connections to the centre. This would require that the capital costs of the airport construction and the surface connections that must be put in place to make it a successful operation should be constructed and installed as economically as possible but also, that those surface connections, wherever possible using existing elements of the capital’s existing facilities, must provide uninterrupted high speed links to the centre. (within 20–30 minutes) 3. that the location, the facilities and the surface connections of the New Hub are of such a high standard that existing and new International Airline Operators will find the new Airport an attractive proposition for their operations. There are, of course, many other considerations and later in this paper we shall identify them but, in our view, these are three key factors and in approaching an “acceptable” solution it is vital that a) the new Hub should have sufficient capacity to meet the expected demand, b) that it be located where there will be the minimum of disruption from noise and pollution for those who live and work in the new Airport’s neighbourhood and c), that it meets the requirements of airlines and their passengers. In pursuing these thoughts, we do not want to gloss over the significance of our suggestion that Heathrow be either closed or reduced to a very much smaller business type airport serving West London. Nor have we overlooked the possible impact that developing a new major Hub serving London and the South East will have on the other existing “London” airports. Again we should like to return to this aspect later in this paper but, we believe that it must be accepted that the creation of new modern 21st. Century Hub Airport, well connected and capable of meeting the demands of the substantially increased International traffic potential that London can generate as a destination, will have a compelling attraction for the world’s airlines as opposed to the other existing airports on the London fringe. As we see it, the consequences of building the new Hub Airport will change the pattern of all airport activity, not only in the South East but also throughout the UK. With these remarks in mind, we should like to develop our opinions about the siting of the new London Hub Airport.

2. The Present Political Position The Government’s approach (and indeed that of all Political Parties so far) to finding a solution to this pressing problem has appeared to demonstrate that they are afraid to make any decisions other than the initial announcement that there will be no more new runways in the South East and, more recently, the Prime Minister’s declaration that he would be interested in a greater study of the detailed proposals for a new airport in the Thames Estuary. That apparent avoidance of positive steps to reach any decision has been further masked by a protracted series of “consultations” that have been described in many of the Department for Transport’s documents as “seeking high level guidance” in order to formulate an Aviation Policy for the UK. This utopian hope for apparent “divine” guidance has been mostly interpreted by those concerned with finding a more practical solution as 1) kow-towing to the Environmentalist Lobby, 2) paying lip service to EU rulings and their new proposals and, 3) desperately trying to make sure that they, the Government or other Parties, do not lose votes (parliamentary seats) at the next election. Perhaps it is a combination of all three. The disastrous economic consequences of this behaviour have already been eloquently and repeatedly defined by the UK Aviation Industry, by the UK Financial and Business Communities and also, comprehensively described and debated in the Media. We do not believe that this document needs to repeat those arguments and criticisms but, it is evident to us that, so far, the Political Establishment and their bureaucratic advisors have seemed to not only failed to understand the consequences of their “inactivity” but, it also seems in the end, that they will wait to have the Aviation Industry find the answers for them.

3.The Right Location In some of the pronouncements explaining the other motivations behind the Government’s intended Aviation Policy, there have been (perhaps accidentally) some sensible phrases used eg “we must make full use of existing resources” and “Aviation should continue to make every effort to minimise it’s impact on the environment and communities”. We completely agree with both of those objectives and have considered and incorporated them in our thinking and our proposals. However, in suggesting that the Heathrow Hub cannot continue effectively to serve the UK, any replacement must certainly have a greater runway capacity together with other improved design features and facilities for airlines and their passengers. If the New Hub is to be a success and attract carriers to develop route networks that will fulﬁl the UK’s aspirations to continue as a major part of the new expanding Global International Aviation Network, the most modern equipment and design techniques must apply. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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To conform to those sensible Government intentions already mentioned and, in our view, to achieve major commercial success, the new Hub Airport must have a profile as follows: 1. It must have the right location—in a an area of minimal residential occupation, within thirty minutes (or faster) direct travelling time of London and, be capable of being connected by fast road/rail links to the other parts of the UK that are able to generate greater potential wealth. 2. That location must also ensure that the Airport can operate effectively. There must be Air Traffic Control acceptability; maximum operating hours; it must have a good weather record; acceptable staff availability; good internal and local surface access etc.etc. 3. There must be a sensible design layout and robust construction with thought given to the need to conform not only to Regulatory requirements but also to the provision of easy and quick traffic flows for aircraft, for passengers and the other necessary facilities; the availability of energy sources; easy access to Utilities eg water fuel supplies, drainage. 4. It must be owned and/or managed by professionals who understand the Aviation Industry, the Airport’s catchment areas and, also be capable of applying intelligent approaches to the necessary Business, Marketing and Charging philosophies. 5. There must be a recognition that all Airports (and this must certainly be the UK’s “showpiece” airport ) have a responsibility to/with their employees, their customers and their neighbours to protect the local Environment and conduct their operations accordingly. 6. Management must have an understanding of the economics of the airport operation and operate it so efficiently that investors, customers and employees can share in the success. These factors ( and more ) can make a success of any Airport and, coupled with an acceptance of the agreed Government requirements of “using existing resources” and “minimising the Environmental Impact”, such an Airport can then rightly be seen as an asset rather than a threat However, whilst recognising the vital importance of Factors 2 to 6 above, the main purpose of this paper is to concentrate on considering item 1—the right location for the new Hub Airport. London’s status as a Global Financial, Commercial, Cultural and Tourist attraction, means that it is essential that the new Hub Airport must have fast and easy access to the Capital by rail and road. In our view, a location to the South or West of the Capital would be environmentally unacceptable and strategically wrong. Everything suggests that, as in recent years the Financial, Commercial and Industrial London has moved and is still moving Eastwards, the new Hub should be somewhere East of the Greenwich Meridian. The proposed options for doing that, as we see it, are either a new Estuary Airport or an expansion of Stansted Airport.

Estuary Airport The idea of an Estuary Airport has, for some, a challenging civil engineering appeal in the great Victorian tradition and for others, it has the merit of being positioned where noise will not be a disturbance and is not intrusive. However, in practical terms: — it would be extremely difficult and very expensive to construct and would probably fail to attract investors. — the surface links with London would be even more costly and they would have to be funded by the taxpayer. — it would also certainly need the protection of a new Thames Barrier against extreme tidal fluctuations not to mention unpredictable North Sea surges. — on these grounds alone it would be difficult to get it approved and, if it was, it might take 20/25 years to get approval, secure investment, build the airport and the necessary surface links with London and the mainland. — by that time the rapidly developing Global International Aviation Network traffic would probably have decided on better solutions offered at Continental Hubs but, if it was built, there would be the operational problems of achieving a safe operation:- — poor weather ( river fog) in the winter months (October—March) — the higher risk of bird-strikes. — a possible hazard to/from active shipping lanes. — the considerable damage to and the responsibility to restore the long established riparian environment—avian and marine. — and, a very important consideration, the inevitable consequence of building such an airport in this location would mean that London City, Stansted and possibly Gatwick would become redundant. For all of these reasons it does seem to us that making proposals for an Estuary Airport would result in the building of the most expensive white elephant in aviation history and it is not the direction to take. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Stansted The case for a re-development of Stansted as the new UK Hub Airport is much more compelling and attractive because: — it already exists as an airport. — it was originally intended to have two runways and could have three possibly four built to a very much faster time scale. — it would be acceptable as part of the new Air Traffic Control plans for the London TMA. — it could successfully fulfil everything offered by an Estuary airport and more at a very much lower cost. — it is in a “rural” location and there would be less of an environmental impact. — It’s development would release Central and West London from the very large number of “overflights” and the consequent environmental blight. — it already has a (poor) rail link to the City of London (Liverpool Street Station) that could be significantly improved and, there could also be provision for a fast connection to be made to the new Crossrail to link the Airport with Central London and/or HS1(Europe) at St.Pancras or Stratford. — there is already an experienced airport work force there and existing maintenance facilities that already form the nucleus of an existing Aviation Culture ready, almost immediately, for rapid expansion. We do believe that for these reasons, this suggestion deserves serious examination and, although the Environmental Lobby, the genuine and “the false”, will violently oppose such a proposal (they will oppose whatever solution is put forward) a sensible programme to alleviate noise and pollution can be effectively introduced.

Other Thoughts on the Possible Wider National Benefits Moving the existing Heathrow Hub Airport to a better located and fully developed new Hub Airport facility at Stansted will provide the UK and London itself with the all important required connection that the Country must have to the expanding and vital economic Global International Aviation Network. In our view, the fast surface connections by rail and road to the capital are not sufficient to make the new Stansted Hub location fully effective for the UK Economy. A major UK Hub Airport should have “connections” with other parts of the country. Those “connections” in this new situation of a Hub Airport with much greater capacity can, without doubt, provide an additional economic stimulus through new and existing domestic air routes to all of the Regions and further, the Airport would encourage all carriers to develop that traffic from all parts as a feature of its Marketing Strategy to attract Transfer Traffic. If we may introduce the much wider subject of a cohesive Transport Strategy for the UK. Our thinking on this is that a major UK Hub should have “support alternatives” or secondary hubs (perhaps call them “Gateways”) that are capable of accepting traffic as either “overflows” or alternatives in the event of poor weather or any other emergency circumstances that interrupt the Stansted operation or, additional destination preferences for carriers. These “Gateways”, “alternates” or “secondary hubs” we suggest should be at Manchester (an Airport with two existing runways and very close to Liverpool Airport) and further, Glasgow Airport (which has the benefit of being close to Prestwick). With this kind of wider UK spread of “Hub” Airports, already in existence and classified as part of the UK “Aviation Gateway” system, led by the new major Hub at Stansted, we believe that one could see the emergence of a National Transport Strategy that could involve air, rail, road and sea connections. This is long term thinking but, the advantages of a primary North—South multi modal Transport Axis with strategically planned East—West connections would do much to serve and benefit the UK Economy in very many ways. We would suggest that: — in bilateral aviation negotiations with other countries the UK could offer all three locations in exchange for similar concessions including “Fifth Freedom” rights. This would not only encourage new operations at Manchester and Glasgow it could also bring further economic advantages to the Regions that those airports serve. — we have spoken earlier in this paper of linking Stansted with HS1 through St. Pancras or Stratford. Taking the view that as yet, there is not a “National Transport Strategy” in existence for the UK and, recognising that the new Stansted Airport Hub must be a key component in any such future National Plan, it is not too ridiculous to consider an extension of HS1 via Stansted to Manchester and Glasgow Airports. That would certainly add meaning to what we believe is every Political Party’s wish that “the North” should play a more direct role in becoming additional “generators” of the wealth and prosperity that is seen as apparently exclusive to the London and South East Region. Such thinking would make HS2 unnecessary. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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— should the HS1 high speed rail links be included in such National Transport Strategies, we believe that adjacent road links (motorway standard) should also be considered from the Stansted Hub location to links with the new Deep water Port nearing completion on the Thames which must also be part of the new Strategic Transport infrastructure. The scale of the possible proposals involved in our suggestion that Stansted should be the new UK hub Airport does naturally lead on to such considerations about the future planning and the extra benefits that could follow for the whole of the UK if the forward thinking could take in a much wider canvas than simply London. Internationally, the UK is too often seen as “London”. This needs to be changed and those of us who live and work here know that there is much more to it economically, commercially, regionally etc. To achieve that objective of a new international perception the first obvious “direction” to drive this proposal is to create a strong North-South axis. The suggestions above about a London, Manchester, Glasgow connection could begin that process. The Northern Ireland sector of the United Kingdom connection is clearly best served by air and the Stansted Hub would encourage that to a high frequency. Road and Rail connections at Glasgow and Liverpool would serve freight . The South West surface connections with London (road and rail) do need to be improved but again, that Region of the UK, using Exeter Airport as it’s focus, could have much more frequent and reliable direct links with London and the benefits of the International Hub at Stansted. Wales, North and South, could also enjoy better connections through Manchester and Cardiff airports as well as taking advantage of the much greater capacity that the Stansted Hub could provide. We make these comments because we believe that Aviation, International and Domestic, is a vital part of the total Transport concept. Too often and for too long in the past “Aviation” has been seen as something separate and different from “Transport” in its widest sense. Happily, this is beginning to change but, it is still true that in order to attract Investment for the growth of trade and the generation of prosperity for everyone in the United Kingdom, we must have a highly efficient and up to date Transport System—road, rail, sea and air—that works. If we take this opportunity to effectively link the UK into the new Global International Aviation Network by creating a new Hub Airport at Stansted and, give thought, support and action to the domestic connections referred to above, we shall certainly secure and enjoy the Social benefits and prosperity of the Financial and Commercial and potential that is well within the capability of this Country and it’s Citizens. William T. Charnock. Director—The ADAM Group P.S. In view of the suggestions made in this Paper, we would strongly suggest that the present procedures for the “sale of Stansted” (a decision that seems is mainly based on a “technicality” by the Brussels “Government” and the Competition Commission) be put on hold until after the final decision is made about the location of the new UK Hub. If Stansted does become the Government’s choice as the location for the new main UK Hub Airport, a possible untimely change of ownership could create additional complexities. The present and/or possible new owners might not be prepared to invest in the necessary expansion. It may be that that should become one of the conditions of future Ownership. 22 October 2012

Written evidence from Flybe (AS 94)

1. About Flybe (a) Headquartered in Exeter, Flybe is Europe’s largest regional airline and the UK’s number one domestic airline. Employing more than 3,200 staff, we currently operate 83 aircraft on 181 routes from 35 UK and 49 European airports in 17 countries and carried more than eight million passengers in 2011. (b) Flybe has established a comprehensive regional route network and its spread of airports is intended to offer customers a convenient local point-to-point network, particularly in transport-isolated areas like Northern Ireland, the north of Scotland and the south west. Our domestic route network does not compete with surface transport where alternative road or rail options give journey times of three hours or less. We offer nearly three times more domestic routes than our nearest competitor and as such can legitimately claim to understand the needs of the UK’s regions better than any other airline

2. Questions What should be the objectives of Government policy on aviation? (a) How important is international aviation connectivity to the UK aviation industry? cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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(b) To properly understand the importance connectivity of aviation to the UK economy, one need look no further than the Department for Transport’s own consultation document on its Aviation Policy Framework where it points out, among other things that: (i) “With the increasing globalisation of our economy and society, the future of the UK will undoubtedly continue to be shaped by the effectiveness of its international transport networks” (para 2.13, page 16) and (ii) “The broader the range of destinations served and the higher the frequency of flights to and from those destinations, the better connected an airport, city or country is.” (para 2.14, page 17). (c) Flybe exists to provide transport connectivity solutions for our passengers, particularly those in the UK regions. We provide that connectivity not only within the UK with services like our Belfast City, Inverness, Newcastle and Newquay flights to London Gatwick, but also by means of our services to European hub airports like Paris CDG, Amsterdam and Frankfurt, where a huge range of global destinations are available. (d) We also have sought to support our regional passengers by means of the creation of our “Manchester hub”. Introduced in March 2012, the airline created a regional network hub by optimising scheduling options through Manchester airport, meaning that Flybe passengers instantly benefitted from an additional 86 regional point-to-point connections.

(e) By working with Manchester Airport to streamline connectivity and reduce minimum connecting times to as little as 35 minutes, Flybe significantly added to the choice of our domestic flights, giving passengers an affordable choice of multiple day returns throughout the UK. In addition, the hub has created a long-haul alternative to Heathrow for the UK’s regional communities, allowing them to access the many flight connections to the rest of the world offered from Manchester Airport.

3. What are the benefits of aviation to the UK economy? (a) Again, when considering the benefits of aviation to the UK economy, the APF document makes it crystal clear that aviation is absolutely crucial to the UK economy, pointing out, among other things that: (i) The whole UK aviation sector’s turnover in 2009 was around £49 billion and it generated around £17 bilion of economic output. The sector employs over 220,000 workers directly and supports many more indirectly.” (para 1.8, page 7) (b) Aviation is particularly important to the UK regional economies in terms of access to market, through connecting services, but also as outlined above, crucial in allowing passengers to complete a day return journey that would, by rail or road, be impossible. A combination of practical and political obstacles, compounded by a London-hub driven transport policy, will ensure, for decades to come, no adequate rail infrastructure will be developed in the UK regions. For anyone needing to get from, say, Exeter to Glasgow and back in a day the choice is under 2 hours on an aircraft versus 14 hours on a train. (c) To that end, Flybe wholeheartedly agrees with the statement in the APF document: (i) “The Government recognises the very important role airports across the UK play in providing domestic and international connections and the vital contribution they can make to the growth of regional economies. For more remote parts of the UK, aviation is not a luxury, but provides vital connectivity.” (d) While we would take issue with use of the word “remote”, the sentiment is correct for the 19 million plus passengers that took a domestic flight last in 2011.

4. What is the impact of Air Passenger Duty on the aviation industry? (a) Air Passenger Duty is a barrier to economic growth. It is well documented that the UK has the highest aviation tax in the world—a seriously short-sighted policy for an island nation. Indeed, the government themselves have explicitly acknowledged that APD constrains demand, evidenced by their decision to approve a reduction in Continental’s APD from Belfast International to Newark in order to retain the service. (b) As can be seen from the table below, the numbers of UK domestic air passengers has fallen by nearly 20% since 2007–08. While this drop has been in part the product of the recession and continuing economic challenges, the fact that APD for a domestic flight was £5 per passenger per flight in 2007–08 and is now £13 per passenger per flight has undoubtedly had an impact. Variation from 07–08 2007–08 2008–09 2009–10 2010–11 2011–12 and 11–12 Total 25,326,857 23,579,169 22,060,930 20,275,085 20,172,440 - 20.3% domestic passengers cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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(c) Flybe commissioned an economic analysis by Oxera examining the regional impact of APD in 2011. The study showed, amongst many other conclusions, that a reduction in APD for the regions, but not London, would have relatively little impact on London itself—mainly because the proportionate impact on regional airports of a small percentage of passengers switching from London is quite substantial. (d) We argued strongly in our response to the Treasury’s 2011 consultation that any reform of the banding structure of APD must remove the inherent unfairness that means UK domestic passengers pay the tax on both legs of their journey, while those flying abroad pay just once. The fact that, for example, a return passenger travelling between Glasgow and Belfast City (208 miles) pays double the tax that someone flying between Glasgow and Dalaman in Eastern Turkey does (4,086 miles) is inequitable. (e) Although the government decided against such an amendment, Flybe still believes that this “double hit” must be addressed in order to safeguard UK domestic aviation and UK regional economic competitiveness. The practical effect of APD on a predominantly domestic operator like Flybe was that, during 2011–12, the airline paid some £64 million in APD to the Treasury, some 11% of our UK revenue, in a year where the airline recorded a loss before tax of £6.2 million. (f) APD is, of course, not the only barrier to growth for the industry—excessively high airport landing charges, the recession and the stubbornly high cost of fuel all make for a challenging environment— but it is something that impacts more heavily on UK airlines than their European counterparts. This is a subject we would be happy to expand upon separately—in particular with regard to flying UK passengers to mainland Europe in order to access global flights with lower APD charges.

5. How should improving the passenger experience be reflected in the Government’s aviation strategy? (a) It is still too often the case that passengers travelling for a flight of an hour or less can expect to suffer queues and security delays amounting to the same length of time as the flight. Where gaps in the market exist in the case of airlines, or where there is a perception that passengers are not getting value for money, the ultra-competitive nature of the industry means that, those gaps are quickly filled by competition. Unfortunately, the same cannot be said of airports and profits made by the airports are often far in excess of anything made by the airlines that operate from them.

6. Where does aviation ﬁt in the overall transport strategy? (a) Transport policy development must be embedded into the government’s growth and productivity strategy. In practice, this means Whitehall and the Cabinet—in particular, the Chancellor, BIS and DfT—working more closely together and putting country before party and short term popularity in the polls. An example of where this could have happened is in the area of aviation taxation and the government’s policy of re-balancing the economy away from London. In their response to the 2011 APD consultation, HM Treasury stated the following: (i) “The Government is committed to rebalancing the UK economy across the regions. As made clear in the National Infrastructure Plan 2011, the Government is also committed to maintaining the status of the UK as an international hub for aviation, with excellent connectivity to both developed and emerging markets. The Government will continue to work with stakeholders to examine the role of the tax system in support of these objectives.” (para. 3.31 on page 11 of “Reform of Air Passenger Duty: Response to Consultation”, Dec. 2011). We have yet to see any evidence of tax reform in this area.

7. How should we make the best use of existing aviation capacity? (a) The Government must address the lack of aviation connectivity to the national hub as a matter of urgency and if necessary, empower the CAA to guarantee regional access to those airports, both now and in the period until new capacity comes on line. Bluntly, regional access to hub airports must be protected for the beneﬁt of regional economies and connectivity to markets. (b) Meanwhile, such connectivity can be satisﬁed to some extent through airports such as Manchester, Glasgow or Birmingham which can act in the short term as “relief valves” for London, and also through Schiphol or Paris CDG.

8. 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? (a) Heathrow is effectively full and has, because of that lack of capacity and the high cost of slots, seen a gradual erosion of regional access from around the UK. Looking at just one statistic starkly exempliﬁes that fact: in 1990, there were 18 direct domestic services to London Heathrow. Today just six are left, from Manchester, Newcastle, Belfast, Aberdeen, Edinburgh and Glasgow. Medium term solutions can be found as long as there is courage, imagination and drive from government. Nothing should be ruled out, including radical ideas such as using Northolt as an “extension” to London Heathrow. One thing is clear though—the nation needs a world-class hub airport. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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9. Does the Government’s current strategy make the best use of existing capacity at airports outside the south east? How could this be improved? (a) We refer you to the Manchester hub concept, briefly described above, which we would be happy to expand upon verbally. There are other options available to make better use of capacity, such as extending the hours of flying available to airlines at regional airports—something which Flybe has experience of that and can offer more flights without undue environmental or noise disbenefits.

10. How can surface access to airports be improved? (a) Surface access and public transport, both road and rail, needs to be improved to the overwhelming majority of the two dozen or so UK airports Flybe serves. For a best practice transport hub that connects rail, road and air, we would recommend the Committee examines Southampton airport. It has all the features that a 21st century integrated cross-modal facility should have, with a train station a matter of 100 metres from the check-in hall and rapid access to both the M27 and the M3. Of note, Flybe’s post-code analysis of where our passengers commence their journey shows that increasing numbers are from South and West London, and are opting to travel from Southampton airport rather than the busier, slower alternatives of London airports. (b) Flybe understands and accepts that major regional transport infrastructure improvements such as those in relation to road and rail need Government pump priming funds to enable delivery. Aviation on the other hand, pays all its own infrastructure costs and all its own security costs, thereby improving the nation’s infrastructure.

What constraints are there on increasing UK aviation capacity?

11. 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? (a) Flybe supports the government’s suggested use of differential landing fees to encourage the use of quieter and cleaner aircraft and such incentives could be used to bring about investment in low- noise, lower-emission aircraft. (b) In the same way that HM Treasury suggested it could work with stakeholders to use the tax system to re-balance the economy geographically, there are existing measurements available to promote such noise reduction programmes. One such gauge is the Ecolabel, introduced by Flybe some ﬁve years ago which rates the environmental impact (noise, CO2 and NOX) of each aircraft type on the local and journey environment.

12. 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? (a) Similar to noise reduction by means of ﬁnancial incentives, Flybe supports the concept of giving airlines an incentive to invest in new aircraft by introducing a ﬁnancial penalty on aircraft over 15 years old. Aviation total emissions do, of course, remain a small part of global emissions and domestic aviation even smaller, however, government can do more to incentivise airlines to invest in lower-emitting equipment.

13. Do we need a step-change in UK aviation capacity? Why? (a) Although Flybe do not operate from London Heathrow, we supported the concept of a third runway which, wholly or in part, would have served the UK regions. (b) The government’s decision to constrain growth in the south east has had one very important impact on domestic services; the increase in landing charges for smaller, mainly regional aircraft using London Gatwick. A rises of some 107% between 2007 and 2012 is designed purely and simply to drive out such aircraft in order to attract bigger, long-haul aircraft that are thought to be more proﬁtable. Flybe continues to seek to persuade the DfT that the CAA should be given a legal obligation to protect and enhance regional services, and in particular access to London and we will lobby on this issue on the back of the DfT’s Draft Aviation Policy Framework document. (c) Given the slim likelihood of any extra capacity in the south east over the next 20 years, airlines like Flybe will seek to provide services to Europe from the regions, as demonstrated with the introduction of our Manchester hub. We will also, in part as a reaction to charging regimes at London airports like that outlined above, continue to forge partnerships with European airlines to create what are, in effect, “virtual” hubs at Paris Charles de Gaulle in association with Air France and at Amsterdam Schiphol, connecting the UK’s regions with the rest of the world. 22 October 2012 cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Written evidence from the Wildlife Trusts (AS 95) [INCORPORATING BERKSHIRE, BUCKINGHAMSHIRE & OXFORDSHIRE, ESSEX, HERTFORDSHIRE AND MIDDLESEX, KENT, LONDON, SURREY AND SUSSEX WILDLIFE TRUSTS] Summary 1. The seven Wildlife Trusts whose interests are most directly affected by aviation and airport development in the South East124 are pleased to have this opportunity to provide evidence to the Transport Select Committee’s Aviation Inquiry. We are acutely aware of the relentless pressures—through a range of both public policy and private initiatives—to expand airport capacity in the South East. The options and measures vary from more efﬁcient use of and extensions to existing infrastructure,125 to a completely new London airport.126 Any one of the options could have damaging impacts on our wildlife. 2. The key question for us is simple:

Is airport development in the South East sustainable?127 3. We support development which has been properly tested for its sustainability, where environmental consequences have been fully considered and the impacts duly moderated through the application of the conventional planning hierarchy in order to minimise damaging effects on our natural heritage. We have examined the policy framework and the emerging development proposals for aviation and airport development. Our primary concern arising from this assessment is that none of the public policies, including the Government’s new aviation policy framework, nor the various airport development proposals which focus largely on the South East take a proper strategic approach to aviation and, critically, none have been adequately tested for their sustainability. 4. We are further concerned that in the current climate of “enhancing economic performance over all else”, the process to define aviation policy and airport development strategy risks marginalising environmental considerations. Two particular examples which demonstrate the nature of problems which could act as barriers to proper consideration of the natural environment as we prepare the way for future aviation are: — The recent Policy Exchange/CentreForum publication128 takes a refreshingly clear and honest approach to factual matters concerning aviation. It unequivocally states (in the context of air quality and climate change) that “Flying is bad for the environment, and although it will improve it will remain bad for the environment.”129 It also takes inadequate, simplistic approach to assessing the environmental impact of its “preferred solution” to maintaining an international hub by developing a 4-runway westerly extension to Heathrow; the importance of wildlife sites is assessed—and dismissed—in one paragraph.130 — The Marketing Director for an airport in Kent, during the process of public scrutiny of its proposed plans to expand is reported as saying “So what if a few rare species of plant get wiped out—we should have the right to cheap and easy air travel.”131 124 Berkshire, Buckinghamshire & Oxfordshire Wildlife Trust; Essex Wildlife Trust; Hertfordshire and Middlesex Wildlife Trust; Kent Wildlife Trust; London Wildlife Trust; Surrey Wildlife Trust; and Sussex Wildlife Trust. 125 For example the Aviation White Paper (Department for Transport 2003 The future of air transport; Cm 6046) argues for two additional runways in the South East but sets as a first priority making the best use of existing capacity at all airports and in particular Stansted and Luton; DfT’s Draft Aviation Policy Framework (2012) proposes measures to deliver enhanced use of existing capacity; the “third runway at Heathrow” debate has recently been extended to consider a major reconfiguration to accommodate 4 runways; there are also recent suggestions that Northolt could provide short term “relief” for Heathrow (North by Northolt: A new London airport at RAF Northolt; Aerospace International; June 2012, p. 16; http://media.aerosociety.com/ aerospace-insight/2012/06/01/north-by-northolt/6875/) and Gatwick’s 2012 revised master plan (http://www.gatwickairport.com/ Documents/business_and_community/Gatwick%20master%20plan/2012–07–18-GAL_Masterplan.pdf) anticipates “.. that, in the longer term, a second runway at Gatwick may be needed.” 126 The focus over more than five decades has been on a new London airport at a range of locations in and around the Thames Estuary. The history of these is set out well in House of Commons Library Standard Note Aviation: proposals for an airport in the Thames estuary, 1945–2012 (SN/BT/4920; updated July 2012); and Standard Note SN 6144 Aviation: Mayor of London’s proposals for a Thames estuary airport, 2008-. summarises the current scheme for a Thames estuary “island airport”. 127 Our reference point for “sustainable development” is the set of shared guiding principles referred to in the section titled “Achieving Sustainable Development” of the National Planning Policy Framework for England (page 2; http://www.communities.gov.uk/documents/planningandbuilding/pdf/2116950.pdf). This is based on “Securing the Future” (http://www.defra.gov.uk/publications/files/pb10589-securing-the-future-050307.pdf) which refines the fundamental principles that became known as the “three pillars of sustainable development” (see http://www.un.org/en/ga/president/65/issues/ sustdev.shtml) first set out by Gro Harlem Brundtland in “Our Common Future” a quarter of a century ago (http://www.un- documents.net/wced-ocf.htm), and comprises ensuring a strong, healthy and just society, living within environmental limits, achieved through a sustainable economy, good governance and responsible use of sound science (“Securing the Future” 2005 Chapter 1, section 4; p. 16). 128 Tim Leunig (2012) “Bigger and quieter: The right answer for aviation”. Policy Exchange/CentreForum, London. http://www.policyexchange.org.uk/images/publications/bigger%20and%20quieter.pdf 129 ibid. Chapter 14 “Airports, aviation and global warming”; see p. 66. 130 ibid. Chapter 9 “Heathrow”; subsection “Does this proposal work for the area west of London?” pp. 47–49. 131 See “Extinction is ok—according to Lydd manager!” Posted on Aviation Environment Federation (AEF) website, 6th June 2007; http://www.aef.org.uk/?p=154. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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5. If we fail to properly integrate the full suite of environmental considerations right at the start of aviation— and indeed wider transport and communications—policy formulation and strategic planning, then we risk that this sector will continue to erode our natural heritage and wildlife assets.

Introduction

Who are we and what do we do?

6. This joint submission of evidence is contributed by the seven Wildlife Trusts most directly affected by aviation and airport development in the South East. We have a combined membership in excess of 201,000 individuals; the total membership of the 47 Wildlife Trusts is ca 800,000.

7. We are partners in The Wildlife Trusts movement which has a collective vision of an environment rich in wildlife for everyone and a mission to create Living Landscapes and secure Living Seas. The 47 independent Wildlife Trust charities in the UK, Isle of Man and Alderney share the common primary objective: to safeguard nature. In parallel we promote access to and enjoyment of nature for the cultural, spiritual, aesthetic, educational and other beneﬁts this brings to maintain and enhance our quality of life. We operate principally at a local level, supported by and working for our local membership and the wider communities in our areas. We manage our own nature reserves, provide advice to land, water and marine resource users and managers, develop and collaborate with others on landscape-scale actions to protect and to rebuild our natural assets in towns and cities, the wider countryside and marine and coastal environments. We undertake and support surveys, data collection and research to underpin our understanding and knowledge of the natural world, we provide educational services to children and young people in our communities and we lobby for governance (legislation, policy frameworks and strategic planning) and decision making at all levels—from local to European—which support our objectives.

Why are we interested in aviation policy and airport development strategies?

8. We support development which has been properly tested for its sustainability. We accept that aviation is part of our way of live and is likely to remain so for the foreseeable future. Our interest is to see that any development meets the highest standards of sustainability. This will include taking due account of new technologies and behaviours that can help to reduce the need and demand for air travel.

9. Aviation and airport development have direct and indirect impacts on wildlife and on the wider environment. Aircraft emit greenhouse gases (GHGs) and noise affects the environment at airports and along ﬂight paths; surface transport used by passengers and staff and for freight and support services emits GHGs and other pollutants (such as NOx and PM10 particulates) into the air.

10. The expansion of airports damages important wildlife areas through direct land take of key habitats and fragmentation of the landscape. It increases local pressures on the environment, for both people and wildlife. Impacts on wildlife can range from loss of habitats to depletion of water resources,132 noise and other disturbance of species populations, and both incidental and deliberate killing of birds arising from bird/aircraft collisions and management measures taken to reduce the risks of bird strikes.133

General Observations

11. We have set out below our views and supporting evidence in response to the headline questions of the Inquiry.

12. However, we are concerned that, in common with the DfT’s new Aviation Policy Framework and the range of private sector proposals coming forward for new and/or expanded airport development in the South East,134 the Inquiry is too narrowly focused to address the critical question: is airport development in the South East sustainable? 132 For example, Heathrow’s official website section on sustainability states that “Airports use significant quantities of water, mainly for construction projects, sanitation and catering. Airport operations also generate considerable volumes of surface runoff and wastewater that, if they contain pollutants, have the potential to impact on the quality of water courses and the wildlife they support.” (http://www.heathrowairport.com/about-us/community-and-environment/sustainability/environment/water). Heathrow is deemed to be the biggest single water consumer in the area. The impact of further development on a region under water stress seems not to feature as a major consideration in proposals for airport expansion. 133 See, for example, section on “Bird hazard management” (page 6 in “Towards a sustainable Heathrow: A focus on health and safety. Briefing document published by Heathrow Airport Ltd 2012; http://www.heathrowairport.com/static/Heathrow/ Downloads/PDF/A_focus_on_safety-LHR.pdf) and the US Bird Strike Committee’s selected list of significant bird strikes in the webpages on “Understanding and Reducing Bird Hazards to Aircraft” at http://www.birdstrike.org/events/signif.htm. 134 The announcement by the Secretary of State for Transport on September 7th this year of the “Davies Commission” to assess the “.. options for maintaining this country’s status as an international hub for aviation” has prompted the high-profile publication of several “hub” proposals, each of which could quite justifiably be subtitled: “Why [insert name of selected airport or location] should be the UK’s main international hub airport”. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Detailed comments on the main questions of interest to the Aviation Inquiry What should be the objectives of Government policy on aviation? 13. The briefing for this Inquiry raises the question “Where does aviation fit in the overall transport strategy?” This presupposes that there is an “overall transport strategy” for the country. But there is not.135 We have an incomplete suite of public policies and strategies covering different elements of the transport sector, and of different ages. None of these appear to be integrated with each other, nor is there any apparent attempt to integrate these with the other key element of communications. 14. The new “Aviation Policy Framework” is described as “… the Government’s draft sustainable framework for aviation.”136 There is no evidence from the consultation document or accompanying Impact Assessment137 that the framework has been properly tested to determine its sustainability. The policy framework characterises “Aviation’s environmental impacts [as] both global (climate change) and local (primarily noise, as well as air pollution and congestion).”138 These are, of course, very important issues; but they amount to an extraordinary and indefensibly narrow consideration of the environmental consequences of any country’s aviation strategy. 15. While we do not underestimate the scale of the task to provide the country with a comprehensive, integrated and up to date transport and communications strategy, we do believe that this is a task that a responsible Government should set itself for the benefit of the population and communities they serve. A fully integrated, long-term transport and communications strategy fit for the 21st century could be properly consulted upon in the normal way and tested for sustainability through the process set out in the EU Strategic Environmental Assessment Directive.139

How should we make the best use of existing aviation capacity? 16. Our key concern is that any plans to adjust frameworks and rules of operation (extension of “ﬁfth freedoms” to Gatwick, Stansted or Luton, or changes to periods closed to normal aircraft movements, for example) which could have the effect of altering the scale and pattern of airport use, including surface transport infrastructure and its use, should be subject to early assessment of their likely environmental effects making full use of the established tools and procedures for such assessments. 17. Surface access to airports is of particular interest to us. Poorly planned infrastructure is damaging to wildlife.140 Proper consideration of the natural environment, using the conventional “planning hierarchy” has the potential to ensure that surface transport infrastructure is integrated with wider environmental objectives, such as landscape scale enhancements, including habitat defragmentation. Combining enhancement opportunities with avoidance strategies, effective mitigation measures and, where absolutely necessary, proper compensation for unavoidable damage, would help to meet the new policy objectives for the natural environment. The challenge of shifting gear from an expectation of “no net loss of biodiversity” to “net gain for nature”, as set out in the Natural Environment White Paper and reinforced in the National Planning Policy Framework. These policy considerations must be integrated with aviation policy and strategies for enhanced use of existing airport capacity.

What constraints are there on increasing UK aviation capacity? 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? 18. In our view the Government’s proposals are not sufficient. They are unreasonably constrained. Our concerns over the local environment extend significantly beyond the impacts of noise on local residents. 19. Paragraph 4.104 of the Draft Aviation Policy Framework states that looking for the least environmentally damaging solution is a policy imperative, and continues that the planned call for evidence (subsequently cancelled) “…will make it clear that environmental sustainability, including protection of habitats, species...is one of the factors which respondents should aim to address.”141 This aim of environmental sustainability should be the keystone of any future policy and supports our view that, rather than the environment being a constraint, sustainable development principles should guide strategic planning of aviation capacity development. 135 For evidence for this see, for example, House of Commons Research paper 11/22 Transport policy in 2011: A new direction? (March 2011) which refers to “…the 15 specific transport-related policies in the Coalition Agreement …” (p.7). The list is not settled policy, but it does reflect the piecemeal approach to transport policy. 136 Para 1.4 in the DfT Consultation document Draft Aviation Policy Framework (Department for Transport, July 2012; p. 6). 137 DfT Aviation Policy Framework Impact Assessment (27/06/2012) http://assets.dft.gov.uk/consultations/dft-2012–35/draft- aviation-policy-framework-impact-assessment.pdf 138 Para 1.14 in the DfT Consultation document Draft Aviation Policy Framework (Department for Transport, July 2012; p. 8). 139 Current guidance on implementing this Directive is set out in A Practical Guide to the Strategic Environmental Assessment Directive Practical guidance on applying European Directive 2001/42/EC “on the assessment of the effects of certain plans and programmes on the environment” (ODPM; 2005). http://www.communities.gov.uk/documents/planningandbuilding/pdf/ practicalguidesea.pdf). 140 Fragmentation of the landscape by linear transport routes is known to have a detrimental impact on wildlife. A recent publication by the European Environment Agency summarises the available evidence on the effects of fragmentation on wildlife in EEA Report 2/2011 Landscape Fragmentation in Europe (http://www.eea.europa.eu/publications/landscape-fragmentation-in-europe) 141 DfT Draft Aviation Policy Framework; July 2012 p. 71. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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20. However, we are concerned that the development of a national policy statement (NPS) on aviation as set out in paragraph 4.103 of the Policy Framework will follow the conventional practice of excluding costs of environmental damage when assessing the “net economic costs and beneﬁts” of a development. This would result in the costs in terms of loss and damage to natural capital—ecosystem functionality (and services) and biodiversity—being ignored. The National Ecosystems Assessment142 recognises that the beneﬁts that we derive from the natural world and its constituent ecosystems are critically important to human well-being and economic prosperity. Aviation strategy must ensure that aviation pays for the environmental damage it causes. Currently, the external costs associated with environmental impacts are not internalised in the planning system and decision making processes.

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? 21. Aviation is the fastest growing source of greenhouse gas (GHG) emissions. Aviation strategy must be consistent with the country’s legal obligations to address climate change.143 The Government’s own estimates put the total cost of aviation’s climate change impacts at £69.5 billion for the period 2000–60, £20 billion more than the cost without expansion. This cost is ignored when aviation’s net economic impact is assessed. 22. The draft Aviation Policy Framework does not extend to a consideration of the full range of GHG emissions associated with the proposed options to expand aviation. Consequently, we believe that no predictions can be made of the implications for changes to carbon emissions. 23. We are aware that there are a number of technological solutions being actively investigated that would have the effect of reducing carbon emissions from aircraft. Some of these appear to be well developed technologies that could be introduced in the relatively near future, including the use of more fuel efﬁcient propfan engines;144 others are innovative airframe design concepts that seem to be a considerable way from commercial production.145 There is a wide range of options available for sustainable forms of transport, investment in which would help to reduce carbon emissions by surface access transport. These sorts of measures would clearly help the aviation industry to be more sustainable. However, from the perspective of wildlife and habitats and ecosystem functionality we feel it is essential that a strategic assessment of the implications for the natural environment of a range of aviation scenarios should be undertaken. This must be done properly and as an integral part of the development of ideas, solutions and proposals from other sectoral perspectives.

Do we need a step-change in UK aviation capacity? Why? What should this step-change be? Should there be a new hub airport? Where? 24. Our focus here is on the proposals for a new London airport in the Thames Estuary. As a general observation, we are not aware of any evidence to demonstrate that aviation and airport development will not result in unsustainable impacts on the natural environment in the South East. In our experience the calls for increased capacity/expansion, including new airports, are not supported by rigorous evidence of their likely costs and impacts. 25. There have been several proposals for hub airports in or around the Thames Estuary in recent years, from both the private and public sector, with most of the recent proposals for coastal developments in North Kent146 as well as the relatively recent and well-known proposals by the Mayor of London, dating from 2008. The concept goes back several decades, and clearly none of the proposals has been implemented. 26. The environmental arguments against using the Thames Estuary as a location for an airport are stronger than they have ever been. The importance of the area for coastal and marine wildlife is recognised through international, European and national site designations and increasing evidence of the scale and diversity of wildlife the estuary supports. Some of the important assets are the internationally important populations of breeding, migrant and over-wintering birds, marine mammals including small cetaceans (harbour porpoise and bottle-nosed dolphins), grey and common seals and less conspicuous but equally important species like water voles. 27. There is a wider, more complex interaction between the Thames Estuary to the functionality of adjacent marine ecosystems in the English Channel and North Sea. The Environment Agency reports that the estuary plays a major role in maintaining North Sea ﬁsh stocks.147 142 UK National Ecosystem Assessment (2011) The UK National Ecosystem Assessment: Synthesis of the Key Findings. Cambridge: UNEP-WCMC (http://uknea.unep-wcmc.org/Resources/tabid/82/Default.aspx) 143 Climate Change Act 2008 144 See Chapter 5 (Transport and its infrastructure, section 5.3 Mitigation technologies and strategies—5.3.3 Aviation). In: B. Metz, O.R. Davidson, P.R. Bosch, R. Dave, L.A. Meyer (eds) 2007 Contribution of Working Group III to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change. Cambridge: University Press (pp 352–356). http://www.ipcc.ch/pdf/assessment-report/ar4/wg3/ar4-wg3-chapter5.pdf 145 See NASA’s report on research commissioned to examine the concepts for aircraft designs that may enter service in 20 to 25 years time. “Beauty of future airplanes is more than skin deep” (17 May 2010) http://www.nasa.gov/topics/aeronautics/features/ future_airplanes.html 146 See Section 2 “Onshore [coastal] airports” (House of Commons Library Standard Note SN/BT/4920; July 2012 pp 5–24). 147 Environment Agency (December 2009) River Basin Management Plan: Thames River Basin District (p. 79) http://cdn.environment-agency.gov.uk/geth0910bswa-e-e.pdf cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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28. Landward environmental impacts of a Thames Estuary airport have barely been given any thought by the proponents. At the very least, major new surface transport infrastructure in the area would add to the overall impacts on the environment. 24 October 2012

Written evidence from the Government of Guernsey (AS 96)

I am writing on behalf of the government of Guernsey in response to the Transport Select Committee’s call for evidence relating to its inquiry into UK aviation strategy.

The Committee’s advice on providing evidence is to keep submissions short and relevant; therefore this submission is deliberately concise. However, we would value the opportunity to elaborate on the issues below and further discuss aviation issues of relevance to Guernsey, and will be in touch to arrange a meeting in due course.

The government of Guernsey is simultaneously responding to the UK Department for Transport’s (“DfT”) consultation on a draft Aviation Framework. In responding to the Committee’s call to evidence, we would reiterate the main points we will be making to the DfT:

— The maintenance and development of air links between Guernsey and the UK is to the economic advantage of both jurisdictions. These links, particularly between Guernsey and Gatwick, enable significant business flow between Guernsey and the UK and in particular the City of London. The relationship between London and Guernsey as international finance centres is beneficial not only to the island but also to the City of London and wider UK economy. Evidence for this can be found in the 2009 HM Treasury-commissioned independent “Review of British offshore financial centres” undertaken by Michael Foot CBE (“the Foot Review”). The Foot Review explained that the Crown Dependencies of Guernsey, Jersey, and the Isle of Man make a “significant contribution to the liquidity of the UK market”. The Foot Review found that at the end of June 2009, UK banks had net financing of approximately $74.1 billion from Guernsey in addition to $218.3 billion from Jersey and $40.1 billion from the Isle of Man. The finance industries in the Crown Dependencies also generate significant professional fees for UK lawyers, accountants, fund managers, compliance and advisors, and the Crown Dependencies are an important factor in London’s pre-eminence as a global financial centre. However, Guernsey is also connected to the wider “UK plc” and there exist clear mutual economic benefits in areas such as renewable energy, creative industries, intellectual property and the digital economy.

— The central role of economically viable links to a London hub/gateway airport, particularly Gatwick, in the economic relationship between Guernsey and the UK cannot be underestimated. However, the ﬁnancial pressures placed by the operators of Gatwick Airport on short-haul regional carriers such as those serving Guernsey present a real challenge to the economic viability of these routes. The government of Guernsey acknowledges the ability of Gatwick Airport Limited to set charges under the Civil Aviation Authority’s price cap. However, the government of Guernsey would reiterate that current slot allocation arrangements at major UK airports, London Gatwick in particular, must take into account the economic and social interests of regions such as Guernsey by reserving slots for existing regional services and enabling a proportion of any slots released to be reserved for new entrants that wish to extend such services.

— As a small island community, Guernsey depends on commercially provided regional air services to the UK for a significant amount of its economic, cultural and social well-being, as well as for the support of public service delivery in areas such as health and education. Guernsey depends upon its connections with the UK mainland and specifically into London Gatwick. Last year, 177,533 passengers flew from Guernsey to Gatwick. Guernsey passengers use the Gatwick route not only to access the capital city but also for onward connections to other areas of the UK and around the world.

— In developing an aviation strategy, we would respectfully encourage the UK Government to balance economic, social, and environmental issues. The government of Guernsey would take this opportunity to reiterate that Guernsey’s year-round lifeline air links with the UK are provided by regional airlines, which operate smaller, quieter, and less polluting aircraft than those used by long- haul international carriers. 24 October 2012 cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Written evidence from Mr Terence Hughes (AS 97) I would like make the following points for consideration by the House of Commons Select Committee on Transport with regard to the expansion of Heathrow. I apologise for the length of my statement and assure you that I am not “anti-aviation” but wish to be constructive.

The Environmental Issue Noise I have lived in Putney for over 40 years and during that time the disturbance from aircraft noise has grown considerably for the simple reason that aircraft movements have increased, the planes are larger and the engines more powerful. Although the government claims that the average noise level has decreased since the 1960’s (by 20 decibels), it is hard for people who do not live under the flight path to understand the degree to which the residents of a large part of London suffer. I find it difficult to work when there is a constant low rumble in the background and almost impossible when the stream of planes fly overhead—sometimes more than a hundred- at intervals of just over a minute. It is impossible to have a conversation with any person next to you. Yet the expansion of Heathrow will lead to a massive increase in the number of flights and even bigger aircraft.

Impact on Health Hopefully the Transport Committee will be aware that excessive aircraft noise has a high social and health cost. The effect of noise on people is complex and insufﬁciently understood. It is more than a question of intensity but also of pitch, frequency and atmospheric conditions. WHO Europe states that: “excessive noise seriously harms human health and interferes with people’s daily activities at school, at work and at home and during leisure time. It can disturb sleep cause cardiovascular and pyschophysiological effects, reduce performance and provoke annoyance responses and changes social behaviour.” These judgements are supported by clinical studies in Munich which have shown that school children suffer a loss of attention and ability to learn as a result of aircraft noise.

Noise as Torture The US Department of Defense would certainly agree with the WHO’s conclusions since it has used unbearable levels of sound in Iraq and elsewhere to force its enemies and prisoners into submission. Surely our government will not permit what can be described as a form of torture to be inﬂicted on thousands of Londoners who live on the approaches to Heathrow.

New Engines? The expansion lobby maintains that there will be a decrease in noise levels as new engines and aircraft are brought into service. However, this assumes further technological advance by engine manufacturers and a massive investment in new power plants by the airlines. Where is the evidence for these developments? Modern aircraft such as the Boeing 777 and Airbus are still unacceptably noisy as they fly over our neighbourhood and how “quiet” is “quiet” for a jet engine? Furthermore, will the many different airlines flying into Heathrow be willing to find the cash to re-equip their fleets with new engines at a time of recession? If so, how long would it take for the older engines to be replaced? Surely it would be foolhardy for the government to invest billions in expanding Heathrow on the back of a mere promise of quieter engines when they do not exist at anything like acceptable levels and may never exist. Moreover, many residents of London are deeply sceptical of undertakings given by the aviation industry since it has a poor track record in respecting planning decisions. Many remember the judgment of the Planning Inspector into construction of the 5th Terminal that any additional runway would mean that the noise level would be intolerable.

Aircraft Movements The expansion lobby maintains that the environmental objections can be overcome as larger aircraft come into service allowing more people to be moved by fewer planes. Yet air traffic increases at an average of 5% a year and according to the previous government’s 2007 forecast set out in “Adding capacity to Heathrow” current aircraft movements of 480,000 will rise massively to 605,000 in 2020, and a staggering 720,000 by 2030 if a third short runway is built. Only a small proportion of these movements are likely to be by large aircraft and it defies all reason to think that this huge increase in flights across London will not have a serious effect on the environment. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Risk Noise is just one major environmental reason for abandoning any scheme to expand Heathrow, there is also the problem of safety. A massive increase in aircraft movements over London will surely increase the risk of an accident. Whilst Heathrow’s safety record is good with 11 accidents (7 fatal) since it started civil operations, there is always an inherent risk in ﬂight. Some of the most advanced aircraft in the world- the Concorde, the A380 and the Boeing 777 have had accidents. In 2008, disaster was only narrowly avoided through the skill of the pilot when a Boeing 777 crash-landed at the edge of Heathrow’s runway. We trust that the Committee will make every attempt to assess the likely risk of an aircraft accident over London and how the emergency services would cope in such an event. The Economic Case

Travelling to the BRICS The expansion lobby claims that Heathrow needs more runways so that the UK can boost its trade links with emerging markets. However it seems odd that British business should blame lack of a runway for its relatively poor performance in global markets compared to France and Germany. Do the Chinese buy more German goods because there are better airports at Frankfurt and Munich—or do they just like BMW’s? If the Chief Executive of British Airways is so concerned about his airline’s connections with the BRIC’s surely he could change the corporation’s route structure by reallocating the short haul slots that BA has recently acquired from BE.

The China case As a hub airport Heathrow has been of great economic benefit to London and the Southeast but why should the Midlands and North be denied the advantages of developing their major own airports because so much traffic is attracted to London? In berating the UK’s slow pace of runway construction, the pro-expansion lobby makes endless comparisons with China’s a large airport building programme to overcome is communications needs. Yet by comparison Britain is well served with three times more airports per capita than China. Many local airfields have been developed in the Uk and Europe by low cost carriers such as Easyjet and Ryanair making it easier to by-pass Heathrow. As these regional airports become more attractive and their international appeal grows the demand for point to point flights will surely increase offering business alternatives to the Heathrow hub.

On the ground For many travellers—business or otherwise—even getting to Heathrow is a daunting experience. Its ground links are already inadequate. The Committee should try travelling on the Piccadilly Line at peak or try driving into London on the M25 at rush hour. Yet the expansion lobby pays little attention about to the costs and disruption of providing ground infrastructure. What will be the scale of the additional road and rail links required by a third runway, perhaps followed by a fourth? How long will the ground links take to construct? What will be the economic and social disruption caused by major road building around the M25? Who will pay the infrastructure costs? Why the silence? It is well recognised that airports attract a great deal of property development to meet business and domestic demand, If Heathrow grows in size there is every possibility that there will be an urban sprawl surrounding the airport and extending along the M4 corridor towards Reading. Much of the construction will be on valuable green ﬁeld sites and the economic axis of London will take a further shift west, away from the eastern side of the city where there is a need for development.

An Expensive White Elephant? Much of the justiﬁcation for Heathrow seems to be based on our ﬁnancial services and IT based economy— the laptop travellers rather than the tourist trade. Is it wise to spend billions expanding Heathrow when the business community is beginning to use more cost effective electronic means of communication than expensive, time-consuming air travel?

The Political Case—a Running Sore Perhaps the greatest issue arising from the Heathrow debate is the risk to democratic values. All the main political parties made manifesto commitments to scrap a third runway following a successful grass roots campaign organised by local people backed by their elected councils. However, the well- funded Heathrow lobby has worked tirelessly to reverse the electorate’s decision. BA, BAA—both internationally owned—have exploited the current economic recession by assiduously courting Whitehall and the Westminster village. This serves to undermine the public’s conﬁdence in the parliamentary system which has been forced to weather the scandal of MP’s expenses and the cynical operations of the spin doctors. Whatever one thinks of the Mayor of London’s proposals for a new London airport one can only agree that we may be presented with a “fudgerama” when urgent action is necessary. Why do we have to wait three or four years before any decision is reached on Heathrow? Why are there no representatives of constituencies cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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affected by the airport’s operations and environmental disturbance on the Transport Committee? In fact the committee seems tilted towards accepting Heathrow expansion. For example, Londoners can only be dismayed by the strong public positions taken by some members. If the government allows further expansion of Heathrow and fails to reverse a planning failure we have lived with for so many years there will be intense opposition from many quarters. Sadly there will be a colossal waste of political energy when there are so many other serious social and economic issues to be tackled. People will once again campaign vigorously against expansion for the simple reason that they have no alternative,— they cannot tolerate the continuous noise and environmental deterioration that will not go away. They do not need the US Department of Defense to tell them that excessive noise undermines well-being.

Future opposition Many legitimate avenues of resistance to Heathrow expansion will be actively explored through the UK courts and with planning appeals together with action at the European level. Hopefully the Transport Committee will give due regard to the EU’s 2002 directive calling for member states to establish active plans to control and reduce harmful effects of noise exposure. There is ever reason to expect that the European Parliament could tighten up environmental requirements.

Why reinforce a Failure? In many ways I have a great respect for those who have to manage Heathrow. They do an impressive job in handling the huge amount of traffic that has contributed to the economic well being of the country. In no way am I anti-aviation but the growth of London’s airport has been a story of muddling through under pressure from the international aviation industry. Ironically, it is the aviation industry and British business that should have been calling for a new state-of-the-art hub airport in the right place years ago. Heathrow has had its day and now needs to find another environmentally acceptable role in serving the country’s air travel needs.. The time has come for radical and imaginative thinking. Britain has world-class architects and civil engineers who have built spectacular airports and projects around the globe. As the Olympics have shown we also have the management skills to build the biggest and most complex projects. The UK even has the capability of raising long term funding through the City of London, the world’s leading financial centre. Why should we have to put up with the second best? It is surely odd that the country which created the original communications revolution and owes so much to the imagination and enterprise of its forbears should continue in this way. 11 October 2012

Written evidence from the Campaign to Protect Rural England, Kent Branch (AS 99) 1. Recommendations 1.1 Our submission is based on the National Planning Policy Framework (NPPF), which requires that any development needs to respect the triple bottom line of social, environmental and economic effects (NPPF paragraph 8), that the benefits must be greater than the adverse impacts (paragraph 14), and that economic, social and environmental gains should be sought jointly and simultaneously (paragraph 8). It also requires that such gains should be clearly calculated. 1.2 Our view is that clearer objectives are needed for the industry to ensure that aspects of the NPPF are fully considered. 1.3 We consider that a more equitable fiscal framework is required for the industry, so that it contributes more fairly to the social good of the country. This would also promote greater efficiency. 1.4 The Government’s new Review of Planning Practice Guidance148 must ensure better integration of the planning system with air transport policy to protect our increasingly scarce tranquil areas as well as our landscapes. 1.5 The Carbon Budgets and Emissions Trading Scheme must recognise that the global warming impacts from aircraft emissions are some two-and-a-half times as large as those of the carbon dioxide alone. 1.6 Tourism should be contributing even more to the UK economy, especially to that of Kent & Medway. Regrettably, that is likely to remain just a vision while so many people fly abroad. This appears to be encouraged by the draft Policy Framework and needs to be reviewed. 1.7 Aviation should be taxed in the same manner as other transport modes. The carbon dioxide emissions of driving a car per person-mile may be similar to those of taking a flight, but the car journey involves paying Fuel Duty and VAT on the fuel and on services used. Air transport avoids all these. The taxation loss distorts competition and encourages people to fly, thereby reinforcing the tourism deficit. 148 www.communities.gov.uk/planningandbuilding/planningsystem/planningpolicy/reviewplanningguidance/ cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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1.8 We contend that no further expansion of airport capacity, especially in the south east, should be considered without evaluating the effects of the proposals above, the consequent likely growth in passenger numbers (if any), and a realistic appraisal of the current spare capacity.

2. Responses to Questions 2.1 Is there a need for expansion? 2.1.1 We believe that this is the most fundamental question, and it does not appear on the list published with the announcement of the inquiry. CPRE Protect Kent believes that a robust case for expansion has yet to be proven, and that more rational use of existing runway capacity (and airspace) would deliver economic, environmental and social benefits. London for example has six airports (Heathrow, Gatwick, Stansted, Luton, Southend and City), more than any other European city. Only Heathrow is near maximum runway capacity. Manston, for example, in north east Kent, has been quite unable to attract any traffic which should have arisen if there were an overall shortage of capacity in the south east. 2.1.2 The Government’s own forecasts for passenger flights per annum show a declining rate of increase, confirmed by the latest information from the Department for Transport. We believe that this will and should continue because of the following factors: 2.1.2.1 The effects of a slowing economy; 2.1.2.2 The continuing increases in oil price, particularly over the longer term; 2.1.2.3 The need to meet climate change requirements. Air transport is the most polluting mode of transport with impacts more than double others and, as such, needs to be managed to reduce that pollution. Since 1990 UK air transport emissions have steadily increased in contrast to other sectors; 2.1.2.4 At present over £12bn is lost to the UK economy because of the absence of taxation such as VAT and Fuel Duty. VAT should apply at least to domestic flights as well as to all air transport maintenance and other activities, and would yield £3bn; 2.1.2.5 The recognition that re-directing proposed investment in air transport to more useful and productive sectors would reap greater benefits for the UK. In the South East, for example, around 164,000 people were employed in low-carbon jobs and the environmental sector in 2010–11, with more than £11 billion of sales; and 2.1.2.6 The cost to the UK economy. The UK is losing money from air transport due to the current tourism deficit of £13bn, which is equivalent to the loss of some 600,000 UK jobs. The graph below reflects the deficit plotted against the number of air passengers. These data cover the period 1980 to 2011 from the ONS and CAA. There are far more UK residents flying abroad than overseas residents flying to Britain. Deficit vs mppa

Deficit vs mppa

80.00 70.00 60.00 50.00 40.00 30.00 20.00 10.00 Deficit £ per passenger 0.00 0 50 100 150 200 250 300 -10.00 -20.00 Million Passengers per Annum

Graph: Tourism Deﬁcit (£bn pa) vs passenger numbers 2.1.3 Tourism and tranquillity are vital parts of Kent’s economy in, employing 45,000 in 2010. Nationally, the CAA has recently conﬁrmed the importance of rural tourism supporting 380,000 jobs and £13.8bn value, of which tranquillity is worth 186,000 jobs and £6.8bn a year to the economy149. This must not be damaged by increased air transport activity. 149 ERCD, June 2012, report 1207 cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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2.2 What should be the objectives of Government policy on air transport? 2.2.1 We believe the Government’s principal objectives should be these: 2.2.1.1 To provide a clear Air Transport Policy Framework to reduce the conflict between the air transport industry and those potentially affected so that they can work together to provide the best results for everyone; 2.2.1.2 To minimise public subsidy to air transport in keeping with the current and longer term economic imperatives; 2.2.1.3 To meet the essential air transport needs for users which cannot appropriately be met by other transport modes, and to do so in a manner which respects environmental limits as required by the NPPF; 2.2.1.4 To ensure the prudent use of land and air travel activities to ensure economic efficiency and environmental responsibility; 2.2.1.5 To address the issues of taxation including fuel subsidies as well as irresponsible pricing and marketing of leisure travel. 2.2.2 The Government’s review of Planning Practice Guidance460 is an opportunity to ensure that previous guidance, such as PPG24 on noise, is updated and replaced so that better integration is achieved between air transport policy and the planning system. This is essential to protect unique areas such as Romney Marsh from inappropriate development. 2.2.3 We consider that expansion will only be needed if there is a clear lack of connection to important business customers, and that air transport from the UK is the most environmental and efficient mode for such connection. If a proven need for expansion or amended services was to develop in the future, the government must ensure that clear minimum standards for climate change emissions, noise, air quality and access to airports are achieved, and monitored in a transparent manner. Direct regulation should be reduced to the minimum (a key government objective), to give the freedom to operators to choose the best way to operate, with monitoring of compliance. 2.2.4 These standards should also be subject to a similar process to that used by quality and environmental management systems (such ISO 14001), which require continual improvement over time, another of the government’s objectives in its Draft Framework (4.61).

2.3 What are the benefits of air transport to the UK economy? 2.3.1 Although there are economic benefits from the relatively small direct employment of 120,000 jobs in the air transport industry (paragraph 2.2 in the Air Transport Policy framework), we consider that air transport does not provide net benefits to the UK because of the tourism deficit and the lack of taxation. 2.3.2 The claimed benefits from improved connectivity (2.10 of ATPF) assume that we get all the benefits, but connectivity is a two-way process. It provides similar access to our markets for overseas countries, such as China seeking to export more—as illustrated by the Chinese enthusiasm for the “China Gateway” at Manston Airport in Kent. 2.3.3 The benefits of “just in time” to business are overstated, because the air transport industry has minimal taxation and low external environmental costs, while the construction and operation of a warehouse in the UK incurs taxes including VAT. This unbalances the economic equation, and gives an apparent benefit from using air transport with a small stockholding in the UK. If air transport paid its full costs and taxes, it would be cheaper to do more in the UK, and we would gain tax income, an improved environment and greater employment—a triple benefit.

2.4 What is the impact of Air Passenger Duty (APD) on the air transport industry? 2.4.1 We believe currently very little. The CAA noted that the decline in growth of passengers pre-dated the introduction of APD, and considered that changes in consumer expenditure best explain the decline in international traffic demand from the UK resident leisure passenger segment. 2.4.2 APD (equivalent to less than a third of the industry depreciation of £9bn) is paid by passengers, so other costs are more important. Some airlines also add all sorts of charges to the basic ticket price, so actual cost can be far greater than first expected. They would hardly add all these extras if they thought it would reduce passenger numbers. 2.4.3 We would propose that the current APD (worth £2.7bn) should be replaced by an Air Transport Duty on each aircraft, payable by aircraft operators, based on its maximum take-off weight. This would provide a strong incentive for operators to ensure that the plane has maximum payload, instead of wasting runway slots and airspace. This could be used in conjunction with a Fuel Duty (worth £12bn, if charged at road fuel duty rates) to encourage the use of more efficient and less polluting aircraft. 2.4.4 APD is also relatively inflexible and does not reflect the value of a flight. For example a one passenger business jet could pay a single person APD, but that flight would use a slot and airspace which could be used cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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more efﬁciently by a larger aircraft. So an APD charged on the aircraft’s Maximum Take-Off Weight would be far better. It would be non-discriminatory in terms of airlines, so all planes that take off from UK airports would be subject to the tax.

2.4.5 We note that the USA, often considered a “low tax” country, levies a 7.5% charge on commercial air transport as well as a $16.70 head tax for arrival or departure plus other taxes on air transport both for passengers and freight. This shows that such taxation is legal and practicable150. Some EU states levy Fuel Duty and/or VAT on tickets for domestic ﬂights.

2.5 Where does air transport ﬁt in the overall transport strategy?

2.5.1 We believe that there is a need to establish some objectives for the nation’s entire transport system, and in this, agree with the New Economics Foundation who state that this requires moving from the: “isolated, uni-modal policy debates and scheme appraisals with a disconnected and disjointed transport system with competing priorities, built on false promises which do not give taxpayers good value for money”151.

2.5.2 Air transport should fit in with a national integrated transport strategy. High Speed Rail and air transport need to largely complement each other wherever possible. We cannot afford to have them compete significantly, either in terms of the cost to the environment of unnecessary additional capacity, or the loss on return from the considerable investment. There is a similar parallel to public transport on the continent where buses and trains provide an integrated service, whereas here they are more likely to compete. High Speed 1, for example, has significant surplus freight capacity through the tunnel to London, so could provide a service as fast as air to many European areas, and with far lower global warming emissions.

2.6 How should we make the best use of existing air transport capacity?

2.6.1 The government cannot tell the industry how to manage itself, so has to define minimum standards and provide incentives, such as Air Transport Duty, to achieve its objectives. The objective should include avoiding duplication of services, for increasing the load factors of aircraft and thus ensuring the appropriate size of aeroplane for the traffic. These objectives will also benefit airlines, so there is significant common ground.

2.7 How do we make the best use of existing London airport capacity? Are the government’s current measures sufﬁcient?

2.7.1 Economic regulation of London’s airports restrains charges, and de-regulation could improve utilisation of the airports, but that must be accompanied by the requisite minimum environmental standards in the ATPF for all airports.

2.7.2 Lack of universal minimum standards also means that some airports have disproportionate impacts. For example, East Midlands Airport has many night ﬂights, which affect a large area, because it does not have the protection of the standards embodied in the designation enjoyed by the three main London airports. We are very concerned that without national limits, the same could happen at Manston in Kent.

2.8 What more could be done to improve passenger experience and airport resilience?

2.8.1 Airport resilience depends critically on airspace availability. Although Kent & Medway has relatively little originating air traffic, the lack of airspace means that airports around London have an adverse effect locally. West Kent, for example, is particularly badly affected by continuous noise from flights to or from Gatwick. Airspace is a key scarce resource, which has a value, as the CAA has recognised. That value would be best realised by charging more for it, to ensure that those who use it are doing so in the most efficient way possible.

2.9 Does the government’s current strategy make the best use of existing capacity at airports outside the south east?

2.9.1 The plummeting fortunes of airports such as Manston (annual loss £4m)152, Durham Tees Valley Airport (annual Loss £3m)153 and Lydd (annual loss £1.9), all of which have alternative nearby airports, suggest that capacity constraints are not the principal issue in the south east or elsewhere. Better use could be made of airports outside the southeast such as Manchester and Birmingham, subject to minimum standards as described above (paragraphs 2.7.1 and 2.7.2). 150 www.nbaa.org/admin/taxes/federal/fet/ 151 www.neweconomics.org/blog/2012/08/31/men-mice-no-we-need-a-coherent-national-transport-strategy 152 www.shepway.gov.uk/UserFiles/File/pdf/lydd-airport/documents/rcoun20090924%20LAA%20A-09–05%20appendix%205.pdf 153 www.nebusiness.co.uk/business-news/interviews-with-business-people/2012/08/13/robert-hough-chairman-durham-tees-valley- airport-51140–31609346/) cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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2.10 How could this be improved? 2.10.1 By Ensuring that the Framework has sufﬁciently strong minimum standards, and applying APD to all aircraft take-offs; this would ensure much greater efﬁciency in the system.

2.11 How can surface access to airports be improved? 2.11.1 The NPPF (paragraph 17) requires that fullest use is made of public transport plus cycling and walking. It also requires Travel Plans (paragraphs 29 & 36). All airports should have travel plans which have increasing targets (we suggest a minimum of 40% for non-car use, increasing by 5% every 5 years) and for increasing use of public transport, cycling and walking. Airports should be required to support alternative travel modes. 2.11.2 DfT research has shown that parking restriction is the strongest incentive for use of alternative modes, so airports must set targets to reduce parking space and contribute to non-car transport improvements, including bus frequencies and cycle facilities. 2.11.3 Surface access is a signiﬁcant contributor to the “sprawl” aspects of airports. We would not wish to see large areas of car parking at Manston, nor Lydd should it be allowed to develop. The review of Planning Guidance needs to ensure that sprawl is considered as part of airport planning.

2.12 What constraints are there on increasing UK air transport capacity? 2.12.1 Apparent capacity constraints arise because of inefficient use of resources. Heathrow for example has spare terminal capacity, but its planes are 25% empty. Fewer flights per day to some destinations would increase load factors, and release runway and air space. Heathrow airport charges are capped and APD does not go to the airline, so the apparent scarcity of runway and air space is not reflected in costs to airlines. 2.12.2 Air transport must keep within environmental limits, as required by the UK Sustainable Development Strategy154, which is the fundamental basis of the NPPF. Any proposals for airport development or changes in operations must ensure that they do not increase environmental impacts. As the NPPF says: “economic, social and environmental gains should be sought jointly and simultaneously” (paragraph 8). It also means complying with the Natural Environment White Paper155 (paragraph 9). This also requires prevention of soil, air, water or noise pollution as well as reducing existing pollution and enhancing the natural environment. Environmental limits and constraints must not be breached or traded off. Where limits conflict then there may be a need to reduce Air Traffic Movements rather than breach environmental limits.

2.13 Are the government’s proposals to manage the impact of air transport on the local environment sufficient, particularly in terms of reducing the impact of noise on residents below flight paths? 2.13.1 No. For example, the residents of Herne Bay (population 35k) are affected by the noise of Manston flights. As they are outside Thanet District Council area which controls Manston, they have no influence over the airport. This illustrates the need for more than just “local” control and for minimum national standards as well. 2.13.2 The government’s own research, such as ANASE, has shown that people are now much more adversely affected by aircraft noise than previously considered. The NPPF (paragraph 123) requires that noise from new developments does not cause adverse impacts on health or quality of life. The government also committed to reducing noise levels towards the World Health Organisation noise standards156,157. Hence the Framework proposals on noise are far too weak. 2.13.3 In terms of planning, the former Planning Policy Guidance 24 needs to be replaced with updated guidance. As well as the forecast noise of the activity, British Standard BS 4142 requires background noise to be assessed, and this is vital to reflect the impact aircraft noise can have on country areas. Likewise all aircraft, especially including the large numbers of General Aviation planes, must be required to have transponders to provide effective monitoring, which has been lacking at problem aerodromes such as Wycombe Air Park.

2.14 Will the government’s proposals help reduce carbon emissions and manage the impact of air transport on climate change? 2.14.1 No. The government continues to ignore the non-carbon emissions, hence under-estimates the warming impacts of air transport, which are some two and a half times those of the carbon dioxide alone158. A multiplier of 1.9 was accepted by the DfT159 but more recent data on contrail induced clouds has increased that multiplier160. The EU Emissions Trading Scheme (ETS) only accounts for the carbon dioxide element of 154 www.defra.gov.uk/publications/2011/03/25/securing-the-future-pb10589/ 155 Defra, 2011 Natural Choice: Securing the Value of Nature 156 WHO 1999 Guidelines for community noise 157 WHO 2009 Night Noise Guidelines for Europe 158 www.sciencedirect.com/science/article/pii/S1352231009003574 159 DfT 2009 Aviation Carbon Dioxide Emissions Forecasts 160 www.nature.com/nclimate/journal/v1/n1/full/nclimate1068.html cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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the emissions, so air transport will effectively be paying less than half price. This means that when an airline buys allowances, from (say) an electricity generating company, should buy 2.5 tonnes of CO2 from the supplier to allow the airline to offset 1 tonne CO2 from its aircraft. Nevertheless the ETS itself has been shown to be ineffectual by Sandbag161 and others. This is reinforced by DECC’s latest carbon values162 now being half previous ones. 2.14.2 The DfT has also stated “In the 2009 forecasts, it was assumed that air traffic management and operational efficiency gains would meet the midpoint of the IPCC projection of a 6%-12% gain in fuel efficiency over the period 2006- 2019. However, on the basis of the advice of independent experts working on the MAC curve analysis it is unlikely that these gains will be realised. Our calculations show how the fuel used per passenger has fluctuated without a clear downward trend. So it is insufficient to expect that improving aircraft fuel efficiency will solve the problem. 2.14.3 We strongly support the evidence (11 October, 2012) from the Chief Executive of the Committee on Climate Change (CCC), to the Energy and Climate Change committee that excluding air transport and shipping from the UK’s carbon budgets, would make it very likely for the UK to miss our climate objective of limiting the risk of global warming exceeding 2 degrees, and they should now be included. 2.14.4 Although we feel very strongly about tranquility, we support the NPPF (paragraph 8) in requiring benefits to be sought jointly and simultaneously, so that emissions reductions must be required as well as noise reductions.

2.15 How can air transport be made more sustainable? 2.15.1 By having targets for total climate change emissions which relate to 1990, as all industries are required to do. 2.15.2 B the application of increasingly stringent noise levels over time. 2.15.3 By requiring airports to come within the Industrial Emissions Directive163 which would ensure that the impacts from an airport are properly managed. 2.15.4 With no spatial national airport policy and no regional planning there is a signiﬁcant strategic gap to assess the cumulative effects, whether on demand (ie viability), emissions or areas of tranquillity. Hence it is vital that the review of Planning Policy Guidance includes some mechanism to enable this gap to be ﬁlled. This is made more urgent because most local authority Planning departments do not have, and cannot be expected to have, air transport expertise. 2.15.5 It is important that revised Planning Policy Guidance ensures that impacts such as emissions, caused by the aircraft using an airport are included as part of the airport’s overall impacts,

2.16 What is the relationship between the Government’s strategy and EU air transport policies? 2.16.1 Our perception is that industry and the Government not only want to avoid “gold plating”, but also seek to weaken policies, for example with regard to air quality in the Environment Theme of its “Red Tape Challenge”164 which says (Page 7) “Working in partnership with other Member States, we will also use the European Commission review of Air Quality Legislation, expected in 2012, to seek…amendments to the Air Quality Directive which reduces the infraction risk faced by most Member States, especially in relation to nitrogen dioxide provisions.” We cannot understand how a Government can propose to allow dangerous air pollution to continue, just to avoid an “infraction risk”. 2.16.2 The EU Transport White Paper includes policy for the modal shift of medium distance flights165 to high speed rail, but it is unclear if such considerations influence the Policy Framework. 2.16.3 In this connection, it would be better for policy to focus on connectivity in terms of passengers/freight rather than Air Transport Movements as that would ease considerations of modal shift including evidence of climate change benefits such as in the Greengauge 21 report166. This report shows that using a multiplier of 2 (see 2.14.1 above) for air transport multiplies HS2 benefits by two and half times, which highlights the importance of integrating transport planning.

2.17 Do we need a step change in UK air transport capacity? What should this step-change be? Should there be a new hub airport? Where? 2.17.1 A new hub airport could only be built if (a) most existing airports were to be closed down, or (b) it charged less to attract traffic, both of which appear unlikely. Promoters of any new airport will need to show 161 Sandbag June 2012 Losing the lead? Europe’s flagging carbon market 162 DECC October 2012Updated short-term traded carbon values for policy appraisal 163 IED, www.environment-agency.gov.uk/business/regulation/137903.aspx 164 www.defra.gov.uk/publications/files/pb13728-red-tape-environment.pdf 165 Under 1,000 km, or 600 miles; by comparison Gatwick to Inverness is 470 miles 166 www.greengauge21.net/wp-content/uploads/The-carbon-impacts-of-HS2.pdf cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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how they will attract traffic from existing airports and still be viable, as their airport charges are likely to be higher than other airports to pay for their construction costs. 2.17.2 We have been very active against the devastating proposals for an airport in the Thames estuary, since the consultation on the 2003 White Paper, and still consider this to be an unacceptable area for such development. The planning system, such as the new review of Planning Practice Guidance, needs to be clear in showing how air transport policy can be integrated with protecting valuable areas such as the estuary so that both promoters and ourselves can work together for the benefit of the UK as a whole. 2.17.3 We consider that the UK would gain far more benefit by applying the resources claimed to be needed for a new airport to improving existing facilities such as rail connections instead. This is of particular relevance to Kent, whose railways do not provide easy or direct connection to any major airport.

2.18 What are the costs and benefits of these different ways to increase UK air transport capacity? 2.18.1 We believe that there would be significant benefits to the UK if capacity were constrained. Notwithstanding the increasing environmental impacts of expanded aviation capacity, expansion would damage our economy by encouraging disproportionately more people to fly abroad and spend money out of the UK than it would encourage inward tourism. 24 October 2012

Written evidence from the States of Jersey Economic Development Department (AS 100) We have given careful consideration to this scrutiny. Many of the questions raised by the Committee are for the United Kingdom alone and are not for us to comment on. However, parts of your ﬁrst question have particular relevance to the needs and problems of island communities more dependent on air travel than others who live in mainland Britain. It is in that context we comment as follows-

1. What should be the objectives of Government policy on aviation? a. How important is international aviation connectivity to the UK aviation industry? International connectivity is vital if the industry is to meet passenger needs. Poor connectivity deters business and leisure travel. The diversity and inter-connectivity of the aviation route network is of vital interest to our island community. It is imperative that Jersey, no doubt echoing the concerns of other similar communities, retains suitable landing slots at the main London hubs airports. The Government of Jersey has had discussions with UK ministers on this specific issue over the number of years, whenever we felt concerned. There is an apprehension that slots currently allocated to “regional” services will be replaced with “international” slots at the main London airports. This would have a severe impact upon our economy and given the close links between Jersey’s finance industries with the City of London in particular, any loss of service would undoubtedly have a detrimental impact upon the UK economy also. b. What are the benefits of aviation to the UK economy? Jersey is not in a position to comment on the wider impacts upon the UK economy in general. However, air travel between the Island and the United Kingdom provides our lifeline link to the UK. It is the main form of passenger travel to and from the UK, which benefits both our communities. The majority of Jersey residents have strong family links with the United Kingdom. There is a very strong link in terms of the Islands use of the UK’s health and education facilities for which the island is charged for the benefit of the UK economy. c. What is the impact of Air Passenger Duty on the aviation industry? Air Passenger Duty deters air travel. Jersey does not levy airport passenger duty as it sees this as a disincentive to travel and has the potential to make marginal routes uneconomic to the detriment of ourselves and the UK linked airport. It is our view that Air Passenger Duty should be as low as reasonably possible for travel between British offshore islands and mainland Britain rather than being based on distance alone. d. How should improving the passenger experience be reflected in the Government’s aviation strategy? The passenger experience is best enhanced by good road and rail access into the major regionally and international hub airports. There should also be a minimum of passenger transfer from one hub to another for onward connexions. Inter-hub transfers are inevitably time-consuming; they are not environment-friendly and are not cost-effective. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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e. Where does aviation ﬁt in the overall transport strategy?

This is for the UK to address as a whole but alternatives such as better rail and road transport are relevant for travel within mainland Britain. It is international connectivity and connectivity between hub airports and the remoter regions of the British Isles that should form a signiﬁcant part of this strategy. 24 October 2012

Written evidence from the Yorkshire and Northern Lincolnshire All Party Parliamentary Group (AS 102)

Introduction and Summary

The All Party Parliamentary Group (APPG) for Yorkshire and Northern Lincolnshire has been formed by MPs to bring together key industry, public sector and Parliamentary voices, to debate and reach some practical agreement and conclusions on the critical issues impacting on the future growth and prosperity of the region.

There are a number of airports in Yorkshire and Northern Lincolnshire, including — Leeds Bradford International Airport, — Robin Hood Doncaster Shefﬁeld Airport and — Humberside International Airport.

There are also good links to Manchester Airport and Teesside Airport, which impact on our region and support the economy.

At a meeting of the APPG on “Transport in Yorkshire” on 11th September it was emphasised that the Transport Select Committee inquiry into aviation should receive evidence from this group and reinforce the importance of regional airports—including those in Yorkshire and Northern Lincolnshire. Attendees of the meeting felt that it is too often assumed that people will travel south to London to ﬂy, when there is considerable untapped potential to expand the airports of the North and ease the vastly stretched capacity across London and the South East.

Local Government Yorkshire & Humber, on behalf of the APPG for Yorkshire and Humber, has gathered MP and partner views from the last meeting and also contacted the region’s airports to identify local concerns.

By supporting regional airports aviation strategy could provide a boost to regional economies, improve regional connectivity, support inward investment and help grow the tourism economy. The Select Committee’s Inquiry ﬁnal report must reﬂect the potential for an uplift in airport capacity outside the south-east to support economic growth and recommend other measures that would help our region’s airports to be competitive.

What should be the objectives of Government policy on aviation? — An aviation policy which places too large an emphasis on London Airports and just a few major UK airports and a lesser support to regional airports growth could have a negative knock on effect on the regions and economic growth outside London. We need to support regional connectivity; avoid decline in regional economic output, and raise the issue that a lack of inward investment and decline in the number of overseas visitors will impact on the region greatly. — The Inquiry should recognise that regional airports are important for the Northern economy due to their direct positive economic impact, bringing in inward investment and that they offer Yorkshire & North Lincolnshire businesses much needed access to global markets. They are important to our local economy as they bring direct and indirect beneﬁts from services and employment to logistics and tourism. — Improved international connectivity is underpinned by regional connectivity which in turn enables our economy to compete more successfully in the international market place. Supporting our regional airports will help increase inward investment and grow the tourism economy which is crucial in Yorkshire and North Lincolnshire. — Aviation tax has a greater impact on the northern airports than the south which needs to be appreciated in universal policy decisions. In particular Air Passenger Duty (APD) is felt to be having an impact on the regional growth of our airports, which could have a devastating impact on price competitiveness in the north. — We support the airports’ view to work with the government to develop alternative options which would help address the disproportionate impact on the north of both APD and the Emissions Trading Scheme. (Other European countries have abolished APD due to the negative effect it had on their economy. The British Chamber of Commerce cited that an increase APD by 5% annually could lose the economy as much as £3 billion by 2020 and £100 billion by 2030.) cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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— The APPG for Yorkshire and North Lincolnshire supports the High Speed Rail proposals, however feels the Government should also support other transport improvements—including aviation. High Speed Rail could be seen as a catalyst for other transport improvements which underpin and support aviation connectivity. — Integrating air, rail and bus transport modes for a holistic transport solution needs to be an essential part of this strategy and Government policy. Improving linkages between current and new transport hubs and our regional airports should be included in the strategy also. This should emphasise rail links to Leeds Bradford International Airport, Humberside International and Robin Hood Doncaster Sheffield Airport. — For example there are plans that will significantly enhance the surface connections to Robin Hood Airport Doncaster Sheffield. This will support economic growth by integrating road (the M18 and A1(M)), rail (the Inland Port Strategic Rail terminal), water (the Humber ports) and air to form a logistics hub for not only South Yorkshire but the wider region serving a population of 5 million. The Gateway project will create an estimated 20,000 new jobs and has already attracted support from a Regional Growth Fund award of £18m to Doncaster Borough Council.

How should we make the best use of existing aviation capacity? — The regional airports have both runway and terminal capacity to accommodate future growth in travel demand and develop regional connectivity which will stimulate economic growth. We feel that our regional airports have untapped potential to contribute to UK aviation capacity as well as a key element as part of economic recovery. — £11m has been invested in the terminal at Leeds Bradford which will support new routes and unlock further business connections across central Europe and the middle East. — Local Authorities and LEPs are working together with airports regarding future economic development of local areas. The Local Development Frameworks can be a catalyst for capturing positive developments which foster economic growth. — Regional connectivity can be the key to unlocking regional economies’ potential for growth, inward investment and the tourism economy. However since the economic downturn connectivity in the UK has fallen. Investment in regional connectivity would make best use of existing capacity, increase revenue and improve growth rates. — The improvements associated with the Northern Hub will provide the potential to improve rail access to Manchester Airport. Given that Manchester Airport is the only airport in the north with a business focused range of international services, these connections are very important to Yorkshire and Northern Lincolnshire.

What constraints are there on increasing uk aviation capacity? — Improved connectivity from the UK’s regions to key European and International markets could have a signiﬁcant impact on the UK’s economy. The lack of connectivity is seen to be impacting on regional growth. — Connectivity both to and from London Heathrow airport is also critical to the successful growth and development of the Yorkshire economy. — If a percentage of new hub capacity, both in and outside London was ring-fenced for regional services, this would further enable region’s access to international markets and grow local economies in the north. — The APPG is supportive of environmental protection measures, but also mindful of the impact overly stringent measures will have on the economy. Therefore it is important to strike a balance to enable sustainable economic growth whilst moving towards goals to reduce carbon emissions.

Do we need a step-change in UK aviation capacity? Why? — We are keen to stress, in conclusion, that the underuse of regional aviation capacity and the declining competitiveness of our regional airports are real concerns. — Regional airports have demonstrated over the last decade that they are essential for regional connectivity and regional growth. We support this being emphasised in the Inquiry’s ﬁnal report and further support for our regional airports needs to be highlighted. 26 October 2012 cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Written evidence from Marinair, the Thames Estuary Airport Company Limited (AS 103) 1. Preamble 1.1 In all that follows in this submission to the current Parliamentary Transport Committee, the inescapable and indeed overriding fact remains—as it has done for the past 40 years—that for Great Britain to successfully meet future demand for adequate runway capacity in the south-east of England, it is necessary for HM’s Government to both demonstrate leadership by confirming the need for an appropriate and long-term solution to the current inadequacies in the provision of hub-airport facilities to serve the region and also, to support in a timely manner, a clear and positive policy which defines the principles of the solution to such serious problem. 1.2 A continued approach of “patch-and-make-good” has in the past been and remains today, a wholly unacceptable response. This has been demonstrated not only to be not in the best interest of Great Britain but also, damaging to Great Britain’s economy. 1.3 For a period in excess of 20 years, TEACo has identified sources of finance to take forward the Marinair solution to the lack of runway capacity in the south-east of England and which have been reported to successive Parliamentary Transport Committees. However, no financial institution will move matters forward in the absence of support from HM’s Government for a new airport to be created within the Thames Estuary. 1.4 TEACo’s Marinair project is THE ONLY effective and environmentally acceptable long-term solution to the provision of a hub-airport to serve London and the south-east of England and it is THE ONLY genuine Thames Estuary island airport submitted to Government.

2. General background to Marinair 2.1 The Thames Estuary Airport Company Limited (TEACo) was founded in 1988 by a group of architects, engineers, economists, aviation consultants and other design, engineering and cost consultants, who were aware of predictions by credible authorities that suitable runway capacity in the south-east of England which was at that time provided principally by London Heathrow Airport (LHR) and London Gatwick Airport (LGW) would, at a time in the not too distant future, be insufficient to accommodate air traffic movements (ATM’s) to serve the capital city of Great Britain and to maintain London’s position as the pre-eminent first choice of entry to Europe for long-haul travellers. 2.2 TEACo was set up to be the special purpose vehicle (SPV) both to lobby HM’s Government to recognise that “piecemeal” development at LHR and LGW would serve only to delay the time when a new hub-airport would need to be constructed and also, to be the focal point for parties interested in providing funding for both a new hub-airport in the south east of England and the marine and land based infrastructures that would be required to properly serve such a facility. 2.3 The Directors of TEACo were aware that a potential problem of providing suitable runway capacity in the south east of England had been identified as early as 1973 when HM’s Government granted approval for a third London airport to be constructed on Maplin Sands albeit that the project was abandoned following the subsequent global oil crisis. In addition to the provision of a new hub-airport, the Maplin proposal also included a deep-water harbour, a high-speed rail link to London and a new town to accommodate the airport workforce. 2.4 Since the abandonment of Maplin, improvements have been made to both LHR and LGW to increase both the number of ATM’s and the passenger and cargo throughput and, civil aviation operations have commenced in 1987 at the newly constructed London City Airport (LCY) and in 1991 at the newly converted London Stansted Airport (STN). 2.5 Customers of airlines—be these passengers or cargo distributors—wishing to gain access to London have many different requirements. However, the two principal requirements are to gain access to London as the destination or, to gain access to London for onward travel to a destination elsewhere in Great Britain or outside of Great Britain. The latter of these is described as “hub-and-spoke” operations whereby long-haul and medium-haul services are supported principally, by other medium-haul or short-haul services to other destinations operating from the same airport. LHR and LGW are both hub-airports from which “spoke” operations operate. 2.6 Although STN has sufficient runway length, it has never gained a position as an airport favoured by long-haul operators. Airlines that have at times in the past attempted to operate long-haul services from STN include Air Asia X, American Airlines, Continental Airlines, Eos Airlines, MAXjet Airways and Sun Country Airlines. All of these long-haul operators have now ceased services from STN with some of them having transferred to LHR and/or LGW. 2.7 Whilst it might seem that it is a good idea to locate airports in different locations around London, the reality of the situation is that such dispersal of facilities fails to provide the airlines with what they really require which is, a multi-runway airport which can operate without restrictions and which can accommodate all long-haul, medium-haul and short-haul ATM’s within one facility so that “hub-and-spoke” operations can be efficiently and cost effectively carried out to the benefit of the airlines and their customers. Transfer between LHR, LGW, STN and LCY is today possible only by surface transport systems and then, only with changes between various modes of such surface transport. For this reason alone—and there are many other good and cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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practical reasons—any future expansion of LHR, LGW and STN so as to try to attract long-haul and medium- haul operators to serve these airports, will be no more than a short-term solution to a long-term problem. For the avoidance of doubt, LCY does not have a runway of sufficient length to accommodate long-haul flights without refuelling stops on the way. 2.8 To state what has become obvious to those involved in the air transport industry, there is no long-term solution to the proper provision of suitable runway capacity in the south-east of England other than the construction of a new hub-airport. If this statement is accepted as factual—and there has not yet been a credible argument offered against the statement—then the only question that needs to be answered is where, within the south-east of England, the new hub-airport should be located. 2.9 The technical parties associated with TEACo, reviewed all previously considered locations for a new hub-airport. These included sites around London and further to the north and west of London and included former and existing military airfields and “green field” sites. To a greater or lesser degree, all of these required the “disturbance” of centres of population and/or the loss of prime agricultural land. Given that a new 4-runway airport suitable for long-haul operations with its attendant on-airport and off-airport facilities must by its operational requirements cover a significant area of such land, TEACo concluded that there was no suitable land based site on which the new hub-airport could be located. 2.10 For the reason given above, TEACo concluded that the most suitable place to locate a new hub-airport would be off-shore. TEACo established that the location of a suitable site off-shore closest to London and capable of being linked to major surface infrastructures is in the relatively shallow water in the Thames Estuary to the north-east of Herne Bay and to the east of the sea forts. 2.11 During the period from 1979–1982, one of the advisors to TEACo had been involved in the selection of the site for and the physical master planning of the new Hong Kong International Airport, the airport island for which, has been created by reclaiming land from the sea within the Tung Chung Basin to the north of Lantau Island. The airport island was created by demolishing the 460m (1500ft) high island of Chek Lap Kok and using the spoil for reclamation. Hong Kong International Airport and the Kansai International Airport which is also constructed off-shore in Osaka bay, are two off-shore airports constructed on artificial islands. The principle of building and operating civil airports off-shore is therefore well established. 2.12 For reason that the site selected by TEACo for further study and promotion as being a suitable site for an airport was located in a marine environment, the project was given the name “Marinair”. 2.13 As stated above, the location proposed for Marinair is in the Thames Estuary to the north-east of Herne Bay. In principle, the project proposes: 2.13.1 The construction of an airport island by way of reclamation; 2.13.2 4No x 4,000m instrument runways and attendant taxiways; 2.13.3 Passenger and cargo terminals and attendant parking aprons; 2.13.4 Aircraft maintenance hangars and attendant parking aprons; 2.13.5 Landside airport surface infrastructure; 2.13.6 New road link from M25-J29 via A127 and M25-J30 via A13 to tunnel to Isle of Sheppey and to the airport island; 2.13.7 New road link link from M20-J7 and M2-J5 via extension of A249 across Isle of Sheppey and tunnel to the airport island; 2.13.8 New HS rail link from north of Maidstone alongside A249 and across Isle of Sheppey and tunnel to the airport island; 2.13.9 New rail link by way of extension to Crossrail from Abbey Wood and across Isle of Sheppey and tunnel to the airport island; 2.13.10 New industrial parks and housing estates in south Essex and north Kent; 2.13.11 Electricity generation by way of water driven turbines incorporated into the airport island. 2.14 During the time to date that TEACo has been trading, the company has made many submissions to promote Marinair reference to some of which, are listed below; — 1990: Submission No1 to RUCATSE; — 1992: Submission No2 to RUCATSE; — 1996: Presentation of evidence to Parliamentary Transport Committee; — 2002: Submission of First Edition response to First Stage Consultation; — 2003: Submission of Second Edition response to First Stage Consultation; — 2003: Presentation to All Party Group of MP’s with copies to The Secretary of State for Transport and the Department for Transport; — 2003: Presentation of evidence to Parliamentary Transport Committee. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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3. The Advantages of Marinair 3.1 The principal advantage of the proposed location for Marinair over all other locations that have been suggested for a new hub-airport in the south-east of England (RAF Upper Heyford; RAF Lyneham; Cliffe; other locations within the “Thames Gateway” and most recently, the expansion of STN to create a 4-runway airport) is that it is in the sea. 3.2 For this reason, the size of the airport island would not be restricted by limitations on land-take and, if and when the airport may at a time in the future require to be enlarged, then this could be easily achieved by reclamation of additional seabed. 3.3 Of equal importance is that the proposed alignment of Marinair is such that all aircraft approach and departure corridors in and out of the location would be along the line of the River Thames and therefore over water. In fact, the closest land to the west of the extended centrelines of the proposed runways on the airport island is at a distance from Marinair in excess of 30 statute miles. Missed approaches and other “go-around” procedures would also be made over water. 3.4 In addition to the safety advantages of approaches and departures being made over water—and unlike approaches from the east into LHR which are at relatively low level over the London conurbation—given that the approaches and departures would not be over built-up areas, there would be no reason for the proposed new airport to have its ATM’s restricted by operating curfews. Marinair could therefore operate 24-hours a day, 7-days a week and 52-weeks a year. 3.5 Other advantages are those of noise pollution and pollution from aircraft engines the latter of which, according to a study published by MIT during October 2012, causes some 50 pollution related deaths each year under the LHR ﬂight path. 3.6 Marinair is the only proposal which provides for all ATM approaches and departures to be over the sea.

4. Matters Raised by Objectors to a Thames Estuary Airport 4.1 Access 4.1.1 From the centre of London (traditionally Charing Cross) the “straight line” distances to the three principal international airports serving London are approximately: — LHR: 15 miles — LGW: 25 miles — STN: 30 miles 4.1.2 All three airports are served by “heavy” railway services—LHR is also served by the London metro service—and are within 3 miles of a motorway junction. 4.1.3 The proposed location for Marinair is approximately 55 miles from Charing Cross. 4.1.4 However, with modern modes of transport, it is time and not distance that is of primary interest. From London St Pancras to Ashford in Kent, the travel time on HS1 trains is 30 to 40 minutes depending upon the service. Given that from St Pancras the proposed location for Marinair is at the end of approximately the same length of railway line as is Ashford from St Pancras, it is not unreasonable to assume that a similar travel time could be expected. 4.1.5 In addition, an extension of Crossrail would provide rail access to Marinair from the west of London from as far west as Maidenhead. 4.1.6 However, it should be remembered that Marinair is intended to be a new hub-airport for the south-east of England and not just an airport to serve London so, the road links proposed from the M25 would provide for access to the airport from the A1(M) M1, M2, M11 and M20.

4.2 Bird Strike Risk 4.2.1 The Isle of Sheppey is surrounded by water in the forms of the River Thames to the north and east, the River Medway to the west and The Swale to the south. The easternmost part of The Swale where it joins the Thames Estuary is approximately 12 miles to the south-east of the site proposed for Marinair. Some 8 miles to the west of this, is the RSPB Elmley Nature Reserve. The nature reserve is approximately 20 miles to the south-west of the proposed location of Marinair. As has been stated above, the westerly ﬂight paths out of Marinair would be in a westerly direction and would pass some 7 miles to the north of the Elmley Nature Reserve. 4.2.2 As has been stated above, there are numerous examples around the world of civil airports located either within the sea or adjacent to the sea. 4.2.3 In fact, some 12 miles to the south-east of the site for Marinair, is Kent International Airport Manston which is some 24 miles to the east of the Elmley nature Reserve. The runway 28 threshold at Manston is less than 1 mile from the water’s edge at Pegwell Bay. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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4.2.4 LHR is surrounded by areas of water and bird reserves as follows: — London Wetlands: 8.5 miles directly east of the centreline of runway 09L/27R; — The Queen mother Reservoir: 2.5 miles directly west of the centreline of runway 09L/27R; — Wraysbury Reservoir: 1.5 miles directly west of the centreline of runway 09R/27L; — King George Vl Reservoir: 0.75 miles south-east of the threshold of runway 09R. 4.2.5 To put the matter of bird strike risk into perspective, it should be noted that Sacramento International Airport in the USA is located some 100 miles east of the California coast and between 1990 and 2007, there were 1,300 bird strikes recorded. That is an average of in excess of 72 per year. 4.2.6 Given the shape of Great Britain, there is nowhere within the Country further from the sea than 70 miles. At a cruising speed of 500 mph, 70 miles will be covered in 8½ minutes. Bird strikes do not always occur at low level and have been recorded at heights between 6,000 metres (19,685 feet) and 9,000 metres (25,528 feet) above mean sea level. 4.2.7 If on the 15th January 2009 after suffering total engine failure following ingestion of Canada geese, US Airways ﬂight 1549 had not had the Hudson River in which to “ditch”, the outcome of the forced landing would have been tragic. 4.2.8 It would be wrong of TEACo to disregard the issue of bird strike risk. Preliminary studies have been carried out into the risk relative to Marinair and, if and when Government support for the project is given, bird strike risk and other risk management and risk avoidance studies will be carried out.

4.3 Noise and Air Pollution 4.3.1 Studies have been carried out using noise generation advice for modern civil aeroplanes. Aircraft noise is principally directed along the line of the aeroplane with “side spill” noise being signiﬁcantly less. The greatest noise generation is produced when aeroplanes are under power during the take-off roll and when climbing and when using “reverse thrust” after touchdown. The studies have suggested that from the centre of the Marinair airport island, signiﬁcant noise will spread to a distance of some 2 miles laterally (a 4 mile “footprint”) north and south and some 6 miles longitudinally (a 12 mile “footprint”). By the time aeroplane generated noise reaches the coast, it will have moderated to an acceptable level of background noise. 4.3.2 As has been stated above, all approaches to and departures from Marinair would be over water which has the capacity to absorb carbon dioxide and other pollutants.

4.4 Shipping Channels and Fisheries 4.4.1 The principal shipping lanes into and out of the River Thames from the North Sea are located to the north shoreline of the Thames Estuary. Preliminary studies have demonstrated that the location proposed for Marinair will not interfere with the recognised shipping lanes. 4.4.2 Other preliminary studies have demonstrated that Marinair would not have an adverse effect upon tidal ﬂows or pose a risk to the ﬁshing industries that operate within the Thames Estuary and the waters to the east. Similarly, there is no evidence to suggest that the Whitstable oyster beds would be adversely affected by the airport or the aviation operations it would generate.

4.5 Airlines would not operate from Marinair. 4.5.1 When in the distant past the idea of a Thames Estuary airport was ﬁrst promoted by TEACo, it was claimed that “The Airlines” would not relocate to Marinair from LHR and LGW. As is always the case with proposals to change the status quo, various parties with vested interests in maintaining their positions put forward al, manner of reasons why the relocation of hub-airport facilities away from LHR and LGW would never be successful. As time has passed and the reality of the situation relative to ATM’s at LHR having become an issue, such former “cannot do” attitudes have been changing. Although the Director of Dubai International Airport has recently stated that a Thames Estuary airport could never be funded and would become a “white elephant”, Willy Walsh has recently stated that even if LHR was granted a third runway, it would only delay the need for a new purpose designed hub-airport to serve the south-east of England and he is only one of a number of people now stating this. 4.5.2 It is difﬁcult to understand why, if the airlines were not provided with a purpose designed four-runway hub-airport with good surface transport access and no curfews, they would not wish to operate their services from such an airport.

5. Government Support for a Thames Estuary Airport 5.1 The principal problem that TEACo has faced since the company’s formation is that, whilst a number of credible sources of funding for the construction of a new hub-airport in the Thames Estuary and the necessary infrastructure have been identiﬁed, the project can be realised only if HM’s Government is prepared to promote cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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the building of such a new hub-airport in preference to enabling short-term solutions to current problems affecting existing airports in and around London.

5.2 To date, since the abandonment of Maplin, there has been no Government support for a new hub-airport to be built in the south-east of England.

5.3 In addition, for Marinair to be realised, it would be necessary for The Crown to agree to the new airport island being constructed on seabed owned by The Crown as the site selected for Marinair, is to the east of the eastern extremity of the seabed under the control of The Port of London Authority.

5.4 However, Marinair does not require the obtaining by Compulsory Order, of seven villages in the north of the Isle of Grain as is the case with some of the proposals for sites in or adjacent to the Thames Estuary.

5.5 A new hub-airport located in the Thames Estuary is of national importance. The unavoidable fact is that before TEACO and/or any other party can take matters forward, the principle of such a development requires the unequivocal support of HM’s Government and The Crown. In the absence of such promotion, no investor will be prepared to make a public statement about funding elements of the development.

5.6 To state the obvious, the future of British aviation interests rests with HM’s Government.

6. Conclusion—The Advantages of Marinair Outweigh the Disadvantages

6.1 The inadequacy of the three existing principal airports that serve London and the south-east of England and the advantages that Marinair would bring to the region are as follows:

6.1.1 London is currently not served by a “world class” hub-airport;

6.1.2 Proposals for the upgrading of LHR, LGW and STN will not result in the region being served by a “world class” airport;

6.1.3 LHR, LGW and STN do not collectively provide for optimum “hub-and-spoke” ATM’s with an integrated multi-modal transport infrastructure within the region;

6.1.4 There is no technical impediment to the construction and operation of a “world class” hub-and- spoke’ airport in the Thames Estuary;

6.1.5 Airports located in the sea pose no greater risk to ATM’s than do airports located inland. In fact, in certain circumstances, they are advantageous;

6.1.6 The location and alignment of Marinair would allow for all low-level ATM’s to be over water;

6.1.7 Marinair would resolve the issue of heavy aeroplanes over-ﬂying London at relatively low levels;

6.1.8 ATM’s at Marinair would not need to be subject to operating curfews;

6.1.9 Existing surface infrastructure could be upgraded to offer greater capacity;

6.1.10 New high-speed rail links and motorway links could be created mostly along existing “corridors”;

6.1.11 Areas of under-developed land in south Essex and north Kent are available for the development of supporting facilities; Marinair could be integrated with proposals for a River Thames Outer Tidal Barrier and power generation.

6.2 Finally, the directors of TEACo respectfully direct the attention of the Parliamentary Transport Committee back to the Preamble at the beginning of this submission. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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26 October 2012

Written evidence from the Institution of Mechanical Engineers (AS 106) This is an Engineering the Future response to the Transport Select Committee inquiry on the government’s Aviation Strategy. Engineering the Future is a broad alliance of engineering institutions and bodies which represent the UK’s 450,000 professional engineers. We provide independent expert advice and promote understanding of the contribution that engineering makes to the economy, society and to the development and delivery of national Policy.

1. What should be the objectives of Government policy on aviation? i. The Government should review the role of aviation as part of a low carbon dioxide travel and transport strategy and low carbon dioxide economy for the future. ii. Any transport policy that is produced needs to demonstrate integration between the modes where a multi modal approach better accomplishes transport policy objectives. The Government’s aviation strategy should be balanced on the principle of accessibility for communities who rely on it for connectivity, and driving technological change to reduce aviation emissions, noise and other negative externalities. iii. Government should pursue a balanced aviation strategy that allows businesses and customers across the UK to connect to the most dynamic and fastest growing markets and economies. With a growing amount of international trade the need for companies to have its entire manufacturing, financing and operational headquarters in one place no longer exists. iv. UK domestic flights and international departures are one of the fastest growing sources of greenhouse gas emissions and policies to reduce air traffic movements, alongside fuel efficiency, will be needed to reduce GHG emissions to meet commitments in the Climate Change Act. a. How important is international aviation connectivity to the UK aviation industry? i. The UK’s aerospace industry is the second largest in the world with a 17% global share of the market. We must maintain good connectivity to the aviation industry around the globe so that we can demonstrate our achievements and skills within this industry, encouraging international investment in the UK. b. What are the benefits of aviation to the UK economy? i. The benefits of aviation to the UK economy include the creation of wealth and employment through our service industries and business communities. The use of Rolls-Royce engines and the involvement that UK cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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manufacturers have in partnerships with Airbus and Boeing benefits the UK economy. Currently the UK aviation industry employs 234,000 staff and contributes £18.4 billion to the UK GNP and £7.8 billion in taxation to the Exchequer. In 2011, 129 million passengers and 1.1 million tonnes of cargo was carried as UK airline output. ii. Hub airports draw in passengers from a range of places in order to reach a critical mass of passengers to make flights to other destinations economic. Having a European hub located in Britain gives cost and convenience advantage to the British people. It also makes the UK an attractive location for emerging markets to set up their European headquarters. c. What is the impact of Air Passenger Duty on the aviation industry? i. Increased taxes and duties can help aviation pay for its environmental costs and provide funds to reinvest in other transport infrastructure. Airlines currently pay no VAT on their fuel and changing this will provide extra revenue. ii. Notwithstanding the objectives behind Air Passenger Duty, the application of a unilateral tax of this nature distorts the long distance aviation market while doing little to incentive airlines to utilise greener aircraft or to increase passenger load numbers on flights, as the tax is effectively passed on to the passenger. iii. Suggestions include that air passenger duty ought to be raised on short haul flights to make them less attractive and to try to encourage other more sustainable types of transport for shorter journeys. Changing Air Passenger Duty to a “per plane” duty would also ensure that flights that are not full, still account for the environmental externalities. Alternatively a tax on fuel usage could be another approach as this would encourage airlines to use more fuel efficient aircraft across their fleet and to maximise overall load factors, thus incentivising emissions reductions, while also bringing aircraft used for freight into the scheme. iv. While taxation of aircraft fuel is favoured by the European Commission, an attempt to introduce this through ICAO (which would require a worldwide agreement to overturn provisions in the 1944 Chicago Convention) was rejected at the ICAO level. As a compromise, Directive 2003/96/EC allowed EU Member States to tax aviation fuel for domestic flights and through agreements on a case by case basis with other EU member states, which could be an option to explore alongside withdrawing APD for certain destinations. d. How should improving the passenger experience be reflected in the Government’s aviation strategy? i. Passenger experience can be improved by Government taking a balanced approach when deciding its policies. A holistic strategy is needed that includes reference and acknowledgement to the impacts of emissions, noise and cost. Developments with information communications technology (ICT) allow the use of “apps” on hand-held devices that can provided a complete door to door route option. These systems can provide options of re-routing as a result of travel disruption. e. Where does aviation fit in the overall transport strategy? i. The overall transport strategy should give an integrated plan on how journeys that are point to point can encourage the use of the different modes encouraging low carbon dioxide travel. This multi-modal transport strategy needs to take into account capacity and address peoples need to travel.

2. How should we make the best use of existing aviation capacity? i. Make better use of the information gathered by the CAA, NATS, Airlines and Airport Operators to manage the flow of passenger and freight traffic through all of our airports is required. ii. Aviation capacity should be carefully planned and managed to ensure that it is focused in those areas where there is greatest need, alternatives are impractical and the local environment is duly protected. 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? i. There needs to be more work done on integrating our transport links between our airports and cities. An example of this can be seen with Stansted airport which runs at less than full capacity. It is fairly remote with poor rail links into London and elsewhere across the country. 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? i. By mapping the flow of passenger and freight traffic across our South East network we could make better use of the capacity available. Commercial opportunities must be taken into account as airports are businesses. We can therefore not dictate to them which airlines and destinations they should serve. ii. Other regional airports tend to be more accessible to the majority of the UK population. Regional airports could also be better placed for UK businesses, including those in the engineering and manufacturing industries, than those airports to the south or east of London cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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c. How can surface access to airports be improved? i. Many of the adverse impacts of aviation disproportionately affect local populations with noise, light and air pollution. ii. Through a national integrated transport strategy the UK could make certain there were good point to point multi-modal links. Individuals need to think about how they travel. Questions such as “Should we use rail for our longer domestic journey rather than ﬂying?”, need to be asked as currently rail is a less attractive option as these journeys are not competitive on price. This should be improved once the high speed network is extended. The Government should also consider alternative forms of travel which link suburban, urban and medium distance/intercity connections such as tram-train, which could help to reduce surface access congestion, emissions and noise issues.

3. What constraints are there on increasing UK aviation capacity? i. There are constraints in terms of land use, planning time and applications, and the need for better surface transport links to and from our airports. 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? i. Government needs to ensure that it works alongside the regulatory bodies including the Climate Change Committee, the Civil Aviation Authority and the World Health Organisation to make sure it is proposing targets that will have the overall impact of improving the local environment, including reducing the impact of noise on local residents. The CAA (for noise) and the Environment Agency (for air quality) need to be given a legal duty and the necessary powers to require those in breach of limits to come back into compliance. ii. Careful consideration should be given to attempting to reduce noise without understanding the potential impact this may have on other aspects of the design of an aircraft. For example, it is possible to reduce the noise by design but this may lead to an increase the environmental impact however, manufacturers are aware of this trade off. iii. Other noise issues such as road vehicles used at an airport could be reduced through the use of electric or hybrid vehicles. The Government should link increased aviation capacity with stricter rules on the noise category of aircraft allowed to use that increased capacity, thus helping to incentivise environmental mitigation even more so if done during peak hour slots. iv. Air pollution is also of great concern to local populations. In the past this has been attributed to road traffic, which whilst still an issue, there has also been a real terms increase in nitrogen dioxide emissions from aircraft and auxiliary power units on the ground. Depending on the location this can severely impact 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? i. Improved technology, more efficient air traffic management, the use of biofuels and other measures will help to reduce the impact of aviation on climate change. However the Committee on Climate Change concluded that in order to reach the interim milestone of cutting carbon dioxide by 26% by 2020, “deliberate policies to limit demand below its unconstrained level are [...] essential”167. Any policies to increase air capacity are incompatible with this. ii. It is helpful that the Government have recognised that there are non-CO2 contributors to climate change. These too need to be included in the EU Emissions Trading System. iii. The Government could implement additional incentives in contracts with OEMs which design, build, test and/or manufacture aircraft. The Government could also introduce tax incentives which operate in a similar manner to the Patent Box or RD Tax Credit schemes. These could be targeted at improving the design and operation of aircraft; this could have a positive effect on those aircraft characteristics which may impact the climate. iv. The OEM takes the business risk when choosing to develop a new type. If Governments are to implement additional incentives, it would be by way of regulations and legislative changes, these changes would need to influence the design and operation of aircraft. v. Of particular mention is the development of biofuels. For a sector that is completely reliant on a portable liquid fuel as an energy source, the development of sustainable alternatives must be prioritised. At present, there are Renewable Transport Fuel Certificate (RTFC) incentives to drive biofuel feedstock and supply into the road transport sector, not into aviation. A government policy must be put in place to govern the allocation of feedstock and resource across all transport modes and other sectors that could exploit biofuels, such as 167 COMMITTEE ON CLIMATE CHANGE. 2009. Meeting the UK aviation target—Options for reducing emissions to 2050. Available from: http://www.theccc.org.uk/reports/aviation-report cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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energy-intensive industrial processes. This should be carried out in consideration of other government policies such as the implementation of the electric car. vi. On the subject of business risk, at present investment banks are hesitant to invest due to lack of overall business case, poor integration and assurance within the value chain and product maturity. This is stalling and stunting development of biofuel reﬁneries and jeopardizing the future of this technology. Some incentive programme from the government must step in to provide the economics to drive a sustainable and investable way forward. c. What is the relationship between the Government’s strategy and EU aviation policies? i. Government’s strategy needs to build on the work done by the Future Aviation Strategy developed by the CAA building in the work being done through programmes such as the Single European Sky Air trafﬁc Management Research (SESAR).

4. Do we need a step-change in UK aviation capacity? Why? i. Aviation has significantly increased over the last 30 years which is the time when the UK focussed its business on the financial services—and as stated in the document London is an exceptionally well served capital city. Do we need to have a long term vision understanding what our strategy is for the entire country, understanding what our business focuses will be over the next 50 years and ensuring that we have the right aviation policy for the entire UK and not just focus on the south east? The Committee on Climate Change have calculated that there is the potential to reduce business travel by up to 30% through teleconferencing. ii. Our transport system needs to maximise our resources for the long term. As an island with over 60 million people living on it we are always going to be space limited when it comes to expansion of our airports therefore we need to look at how we can improve the efficiency to maximise the throughput of passenger traffic to meet the future demands. iii. Policy should focus on encouraging connections from regional airports into all the major networks. a. What should this step-change be? Should there be a new hub airport? Where? i. No comment. b. What are the costs and benefits of these different ways to increase UK aviation capacity? i. No comment. 29 October 2012

Written evidence from the Aberdeen Airport Consultative Committee (AS 108) Preamble Aberdeen Airport Consultative Committee is established under UK civil aviation legislation. It is independent of the airport’s ownership and management, although the Managing Director attends and advises meetings as appropriate. The Committee has 20 members, drawn from the local authorities most closely affected by its operations, local community councils, professional and trade organisations, such as the local Chamber of Commerce and ABTA, organisations connected with aviation, including NATS and the local Airport Operators’ Committee and passenger representation. The airport is predominantly a business airport, with a throughput of more than 3 million passengers a year. In addition to scheduled services to London and most of the UK’s provincial airports, and international scheduled services to Europe’s main hubs, Aberdeen is also the world’s busiest civilian helicopter airport, servicing the off-shore energy sector. We are pleased to offer the following observations in respect of your Committee’s invitation to interested parties to submit evidence. All that we say has been said in one way or another to the DfT, your own Committee, to the All Party Group on Aviation and to other consultations over the past few years, but we feel that the points must continually be reiterated, in the hope that government pays attention to them. We shall attempt to keep our responses brief. However, we are also willing to forward to your Committee a copy of the response we have today sent to the Secretary of State in relation to the current consultation on Aviation Framework, if you so wish.

Objectives of Government policy on aviation International aviation connectivity is critical to the whole of UK plc, as we seek to regain some of our former competitive edge in relation to international commerce and trade. At the moment, it seems to us, our near European competitors (France and The Netherlands in respect of the Sky Team alliance and Lufthansa in relation to the Star Alliance) have stolen a march on the UK in terms of the number of destinations served, but not necessarily in terms of frequency of services to some key international destinations served by the One World alliance, led by BA. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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From our own perspective, as one of the more peripheral regions of the UK, aviation connectivity is vital, not just in relation to international services, but also in relation to domestic connectivity. Aberdeen is at least 7 hours by rail from London and other major UK provincial cities, and longer by road in many cases. Business and leisure travellers therefore rely substantially on good frequent point to point air links across the UK, whether to do a day’s business away from their office, or to connect to longer haul flights that are only available from major hubs. For us, aviation will always fit into the overall transport strategy: even when HS2 reaches the central belt of Scotland, we shall not be “near enough” to London to encourage a general modal switch for journeys which, by road or rail, take longer than 3.5 to 4 hours. We therefore reiterate our long-held view that Government must find some way within general competition policy and EU regulation to ensure that sufficient slots are retained at both Heathrow and Gatwick for services from the further UK regions, now and for as far as one can see into the future. This might also require the CAA to change its current opinion, to ensure that landing fees for the aircraft that operate such routes are not priced off the airfield. We base our case not least on the very substantial contributions that the energy, distilling and other sectors based in the north east of Scotland make to the UK exchequer, and the fear that, without connectivity, energy majors may be tempted to relocate, not elsewhere in the UK, but beyond our borders. As far as APD is concerned, we would be more amenable to the tax if it were seen as a source of income for environmental improvement, rather than as straight income to the general exchequer. One of our concerns is that every domestic passenger making a return journey within the UK pays APD in each direction, whereas a passenger flying directly from the UK to an international destination only pays for the outbound journey. In the Chancellor’s consultation on APD last year, we suggested that a return flight within the UK should only attract one APD levy, or that APD should not be charged at all for domestic flights where there is no alternative surface transport with a journey of 4 hours or less. Neither suggestion was accepted.

Existing capacity There is a potential conﬂict between “best use”, whereby airlines focus their efforts on the most proﬁtable long haul routes using wide bodied jets, depending primarily on a catchment area close to their hub, and “best use” that serves the interests of the whole of UK plc. All the time BA and Virgin, the UK’s two remaining long haul airlines, focus almost all their services on London’s two main airports, they will be sucking in demand from all round the UK (as well as from beyond). We believe a balance needs to be struck, as we have already indicated, between long haul point to point services and the needs of UK businesses and citizens from the further regions, who also require access to such services. One option might be to build on existing capacity at Birmingham and Manchester airports to offer an alternative hub network. But unless BA and Virgin are prepared to develop a network of services from these airports, the attraction for interlining passengers will still be Heathrow and, to a lesser extent, Gatwick. For effective interlining, members of a single alliance or code share arrangement need to offer feeder services from other UK airports, with through ticketing. At the moment such services are not available. Is it, then, little wonder that more and more UK passengers are turning their business to such airlines as Air France/KLM and Lufthansa, through European hubs, and Emirates, through Dubai?

The future We do not feel competent to express a view on whether there should be a new hub airport for the UK, or where it should be. We do understand the impact of aviation on residents of parts of London (although Heathrow and Gatwick airports have been operational for many more decades than many residents have lived near to them). As we hope we have emphasised, whatever the future, we urge Government to ensure the aviation needs of all the UK are taken into account, and not simply the interests of the south east of England. 29 October 2012

Written evidence from Greenpeace (AS 109) What should be the objectives of Government policy on aviation? 1. Greenpeace believes that if the Government is serious about tackling climate change, aviation policy must be shaped within the parameters set out by the legally binding climate targets established in the Climate Change Act. 2. To be clear, the government has a legally binding commitment to reduce greenhouse gas emissions (GHG) by 80% using 1990 as a base line. During the passage of the Climate Change Bill in 2008, the then Climate and Energy Secretary, Ed Miliband, made clear that he accepted all of the Committee on Climate Change’s (CCC) recommendations, including the inclusion of shipping and aviation emissions by the end of 2012, when a suitable methodology for accounting for these emissions had been agreed. 3. In addition to this, the former Government set a target that aviation emissions should be no higher in 2050 than they were in 2005. It should be noted that even reducing aviation emissions to 2005 levels affords cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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the aviation sector special treatment compared to every other sector of the UK economy which is required to reduce emissions by at least 80% on 1990 levels. Allowing aviation to remain at 2005 levels means that these sectors have to do even more—cuts of at least 85%—and pick up the costs of doing so. 4. The current government has said that they will make their position clear on both the inclusion of aviation and shipping and the 2005 levels target by the end of this year. 5. The CCC has said in no uncertain terms that the government should plan on the assumption that aviation emissions will be no higher in 2050 than they were in 2005, and in fact aviation and shipping emissions have already been accounted for in the ﬁrst four carbon budgets. Allowing aviation to grow beyond the tight constraints set out by the CCC means watering down the UK’s climate targets and reducing our chances of limiting global temperature rises to 2 degrees Celsius. 6. In light of this clear commitment in the Climate Change Act, which secured a cross-party consensus, aviation policy must operate within the carbon limits set out.

How important is international aviation connectivity to the UK aviation industry? 7. The aviation industry and indeed wider business community will undoubtedly argue that international connectivity is vital to the UK aviation industry, which in turn is necessary to secure economic growth in the medium to long term. 8. Greenpeace believe that the key point that is missing in this debate is that the UK and London are already exceptionally well-connected to the rest of the world, much more so than any other city in Europe. The default position of the aviation industry is that the UK is losing this status, and therefore expansion is necessary. This is simply not true. 9. As the former aviation minister, Theresa Villiers noted in a Commons debate earlier this year: “It is very clear that London is one of the best-connected cities in the world, with its five busy and successful airports—six, if newly expanded Southend is included. Together, those five airports provide direct links to around 360 international destinations, including virtually all the world’s great commercial centres. That compares with just 309 such links from Paris, and 250 from Frankfurt. Heathrow provides more flights to New York than Paris and Frankfurt put together, and has more flights to the crucial BRIC—Brazil, Russia, India and China—economies than other European hubs, including more services to China… it is simply not true to claim that London’s connectivity is falling off a cliff-edge.”1 10. Specifically with regard to Heathrow, the airport has long been Europe’s biggest hub airport and remains so today. In 2011 it carried 69 million passengers.2 This compares to a 2011 total for Paris Charles de Gualle of 61 million,3 Frankfurt’s 56 million4 and Schipol’s 49 million.5 Heathrow and Gatwick combined carried more than 103 million passengers in 2011,6 15 million more than the nearest metropolitan combination of Paris CDG and Orly.7 11. Heathrow delivers over 9,000 flights every year to New York and 2,500 to Singapore and New Delhi, more than any other airport in Europe. BAA and the Confederation of British Industry claim that the UK is “lagging behind” other airports because it only has 30 direct flights to China.8 However, this ignores the 3,000 flights every year to Hong Kong (an important hub airport); taking these into account, there are in fact 81 direct flights a week to China from Heathrow airport.9 12. According to an analysis by Prime, a policy research think tank on macroeconomics, Frankfurt, London Heathrow and Paris CDG all have a broadly similar level of links to the BRIC countries—Brazil, Russia, India, China—(with the exception of Frankfurt, where Germany’s historically close relationship with Russia explain the high number of flights to Russia.) The table below taken from their report sets out those links in 2011.10 Brazil Russia India China Total BRICs Schiphol 6 6 5 10 27 Frankfurt 3 10 4 6 23 London HR 227415 Paris CDG 234514

13. As the report notes—“Schipol in recent years is the only hub to have built up a broader range of BRIC destination and London remains far ahead in terms of connectivity to North America.”11 14. Looking beyond Heathrow, there is not anything to stop individual airlines from offering direct flights to emerging markets from the other major London airports. Gatwick Airport has the capacity to handle up to 40 million passengers a year, but in 2010 just 31.3 million people travelled through it.12 Stansted has permission for 25 million passengers; in 2010 it serviced just 18.6 million.13 If there was sufficient demand for flights to China, India or other emerging markets, then there is already enough capacity at London’s airports for airlines to offer them. It is also worth noting that 75% of London’s aviation demand is for leisure travel and only 25% for business.14 cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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15. It is clear then that the UK and its capital city, London, is exceptionally well-connected, and that despite bluster from the aviation industry, the country’s connectivity isn’t lagging behind that of its European counterparts.

What are the beneﬁts of aviation to the UK economy? 16. Greenpeace believes that an assessment of the beneﬁts of the aviation must be looked at alongside the economic, environmental and social costs of the sector.

Tax breaks: 17. The significant tax benefits that the industry enjoys must be balanced against the contribution the industry makes to the economy. The industry is exempt from paying fuel duty and VAT amounting to around a £9 billion a year subsidy. Whilst the fuel duty arrangement would need to be addressed internationally, the UK government should make moves to push for this. 18. Environmental costs must be included in any balanced and objective assessment. Aviation is without question responsible for a growing portion of UK emissions, which are driving climate change and this should be recognised in any calculation of costs and benefits. The Stern Report estimated that if we carry on with business as usual, climate change will cost between 5 and 20% of global GDP.15

Jobs: 19. As the aviation industry has grown, airlines and airports have become more efﬁcient, with fewer members of staff per thousand passengers. Three reports, each sponsored by the aviation industry, show that the number of direct jobs in aviation fell from 180,000 in 1998 to 141,000 in 2007.16 Over the same period, the number of passengers grew from 159 million to 218 million, meaning that the industry went from employing 1,132 people per million passengers to 646 people per million in nine years. 20. This increase in productivity is dramatic and is driven by the growth of the low-cost operators. Individual airlines have been employing fewer people in real terms: British Airways, for example, shed 42% of its workforce between 1998/99 and 2009/10.17 The difference between low-cost and premium airlines is stark: British Airways had 1,157 employees for every million passengers in the year ended 31 March 2010 whilst Ryanair had just 106 employees per million passengers.18

Tourism deficit: 21. Greenpeace believes that there is evidence that the rapid growth in the aviation sector over the last decade or so has caused a loss of income in domestic tourism. 22. As the Department for Culture, Media and Sport noted in its Government Tourism Strategy, people in the UK are far more likely to holiday abroad than at home. Less than 40% of our total holiday spending goes on domestic tourism; just 20% of us holiday at home, compared to a European average of 28%.19 Almost a third of people in the UK (29%) holiday abroad each year, compared to just 16% in the rest of Europe. This has a direct effect on UK tourism: budget hotel operator Travelodge says that budget airlines “are the single biggest cause of decline in traditional tourism resorts”.20 23. Although the UK continues to attract international tourists, our predilection for foreign holidays has had a dramatic effect on our balance of trade. The UK’s balance of trade correlates closely with the number of passengers using the UK’s airports. In 2007, when our airports where the busiest they had ever been, our tourism deficit was also running at a record level. Research by Stop Stansted Expansion, using data produced by the Office of National Statistics, shows that when overseas leisure trips by UK residents fell from 60 million to 49 million between 2008 and 2011, the UK’s tourism trade deficit also fell, from £20 billion to £13 billion.21 24. The level of inbound-outbound tourist deficit varies around the country. London and the South East are almost at parity, with a ratio of 1.3, where British tourists from that region spend £1.30 for every pound spent here by foreign tourists.22 The largest tourist deficits are in the least affluent regions of the UK. The North of England has a ratio of 4.7: ie people from that region spend £4.70 for every pound spent in their region by foreign tourists. As a result, these are the areas whose local economies and jobs’ markets would have most to gain if a better balance could be achieved between outward, inward and domestic tourism.

How should we make the best use of existing aviation capacity? 25. Greenpeace believes that the capacity in the UK and Europe already exists to ensure that this country and our European partners are well connected with the rest of the world, including the emerging economies. The question must be whether this existing capacity is being used in the best way possible rather than automatically assuming that extra capacity is needed. 25. As Zac Goldsmith, MP for Richmond, noted in a debate on aviation earlier this year—“Does the hon. Gentleman agree that some of the problems that he has just described result not from lack of capacity but from poor prioritisation? Hundreds of flights every day to and from Heathrow involve places that do not in any way contribute to Heathrow’s hub status. We have short-haul flights, flights cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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to Malaga and 15 flights a day to Cyprus. Such point-to-point flights could happen at any other airport. We have masses of spare capacity, but it is not all at Heathrow. If that is the problem, surely the priority is to make better use of existing capacity and to get rid of some of those pointless flights that could easily happen elsewhere.”23 26. The point about prioritising existing capacity, for example in London, is an important one—both in terms of transferring short-haul flights onto rail, and by better using capacity currently within the system. For example both Gatwick and Stansted have spare capacity which could be used to improve connectivity to emerging economies, rather than building new runways. The former Transport Secretary, Philip Hammond, recently raised the question as to whether you could solve the issue with closer cooperation between Gatwick and Heathrow.24 27. The same point applies to Europe. It is nonsense to argue that European hub airports can continue to grow indefinitely given that we are increasingly living in a carbon constrained world and that the aviation industry has to make real reductions in its carbon emissions. 28. The vast majority of flights in Europe are intra-European. Before rushing to expand European hubs we need to look at whether existing capacity is being used effectively. Short haul flights should be transferred to rail and European hubs must work how to complement one another rather than compete.

What constraints are there on increasing UK aviation capacity? 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? 29. Above, Greenpeace has set out its belief that the main constraint on UK aviation capacity must be the government’s legal obligation to meet its climate targets as set out by the Climate Change Act. 30. An assessment must be made of aviation’s share of the UK’s total carbon budget between now and 2050, and aviation policy must be made on that basis. 31. A decision on the inclusion of aviation and shipping in the carbon budgets is due to be taken and announced by the end of the year. The government must agree to its inclusion and then from this calculate the proportion of the overall carbon budget that aviation is allowed to absorb. Aviation must work within these constraints.

What is the relationship between the Government’s strategy and EU aviation policies? 32. Much has been made of the inclusion of aviation in the EU ETS, leading some politicians to claim that its inclusion gives the aviation industry a free pass in terms of expansion.25 33. This is far from the truth. The Emissions Trading Scheme is a good start, but it won’t be enough on its own. It is dependent on the price of carbon and the number of credits. When the ETS ﬁrst launched, the number of credits issued was greater than the amount of CO2 emitted, so the price of carbon crashed. Companies were given millions of free permits, which they traded with each other for less than the cost of actually reducing emissions. The ETS will cap emissions at 97% of their 2005 levels, falling to 95% of 2005 levels from 2013. 34. Although the EU subsequently reduced the amount of permits, the price of carbon remains extremely low. In 2011, the DECC valued one tonne of carbon at £13.50 (€15.70), but permits for one tonne were trading at just £5.40 (€6.45). As the aviation industry is allowed to buy credits from other sectors (which are polluting less because of the recession) there is no incentive for companies to clean up their act. 35. In addition, airlines will be given millions of credits for free. Just 15% of emissions have to be purchased on the open market. A study by US academics, funded by the American aviation industry, concluded that this was going to lead to a major windfall of around €2 billion a year, because the industry would pass on the cost of carbon to its passengers.26 36. The government knows that the ETS alone won’t be enough to keep emissions under control. That’s why it asked the CCC for the UK’s carbon budgets, include sectors which were covered by the ETS, and it is why the government must include aviation and shipping emissions in future carbon budgets. 37. The CCC argued that the key was to stop emissions before they started through a suite of measures relating to investment and planning decisions. In other words, we shouldn’t get locked into high carbon infrastructure like runways.

Efficiency: 38. Whilst planes have made efficiency gains of around 1.5% each year any positive impact on emissions has been wiped out by the massive explosion in flights. 39. The industry claims that new technology will come on stream that will outstrip the rise in demand. But the fact is that many of the new technologies they refer to like blended wing aircraft, will require significant changes to airports. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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40. In the first CCC report, the then Chair, Lord Turner issued a cautionary note on efficiency gains and the role that it could play: “whilst estimates and targets suggest significant potential to drive efficiency improvement, it is likely that many of these improvements are already factored into projections of aviation emissions. More radical changes….. to aviation technologies eg blended wing bodied aircraft, are likely to be more expensive, require changes to infrastructure and may not lead to significant additional emissions reductions.” He concluded that—“the limits to feasible fuel efficiency improvement… make it likely that aviation emissions will continue to grow significantly unless demand is constrained.”27

The role of biofuels: 41. The Committee on Climate Change notes that—“concerns about land availability and sustainability mean that it is not prudent to assume that biofuels in 2050 could account for more than 10% of global aviation fuel.”[i] 42. Several airlines have run high-profile biofuels trials, including flights powered by biofuels obtained from algae. But these flights are about generating some positive headlines for a beleaguered industry. In practice, there are serious problems with powering planes with biofuels. 43. Concerns about biofuels have been raised by a wide variety of stakeholders including the Royal Society, the United Nations Food and Agriculture Organisation and the Environmental Audit Committee. 44. The greenhouse emissions generated by growing some crops for first generation biofuels are significant— particularly ethanol derived from maize grown in North America as well as those derived from palm oil in Indonesia . For example, biofuels continue to put huge pressure on land. Rainforests and other “carbon stores”, such as grasslands and peatland, are being cleared to make way for biofuel crops.28 Even when biofuels crops are being grown on land that is already cultivated, they often displace food crops, which forces farmers onto new land, again driving deforestation.29 In Indonesia, for example, forests and peatlands are being drained, cleared and burnt to grow palm oil driven by biofuel demand, releasing colossal quantities of greenhouse gases in the process. 45. Although second generation biofuels, such as algae, are being developed, there is no evidence that they can be produced on a large enough scale to replace kerosene. For instance, British Airways is talking of a new plant in East London, which would convert domestic, agricultural, forestry and industrial waste into a biogas that will then be converted into synthetic kerosene. BA says that by 2014 the facility could be converting 500,000 tonnes of waste a year into 16 million gallons of biofuel. But this is less than 2% of the airline’s annual fuel needs.30 We would need more than 50 refineries of this scale before BA would be kerosene free— and that’s just to cover the needs of one airline. 46. Given the rapacious demand of the aviation industry for fuel, it’s unlikely that there is a sustainable biofuel which can meaningfully contribute to emissions reductions. Whichever biofuel the industry were to decide upon, it would have a huge environmental impact if used at scale. Biofuels are not a silver bullet—and we can’t afford to let aviation expand on the off chance that one day someone might invent a sustainable fuel.

Do we need a step-change in UK aviation capacity? Why? 47. As set out above, we believe that there is no need to build extra capacity but there is a need to better prioritise existing capacity. London and the UK are exceptionally well connected. By transferring short-haul ﬂights to rail and better coordinating the use of existing capacity we can ensure that it remains so. 48. The question then must be whether this existing capacity is being used in the best way possible rather than automatically assuming that extra capacity is needed.

Accurately projecting passenger demand: 49. Many of the assumptions underpinning calls for additional capacity are questionable, specifically the DfT’s passenger projections. Greenpeace believes that the DfT has a track record of producing misleading and incomplete assumptions about passenger demand, and that the latest projections published in 2011 are inadequate. 50. DfT suggests that by 2050, demand for aviation would, if not constrained by airport capacity or environmental limits, grow from 211 million passengers per annum (mppa) to between 400 and 700 mppa.31 51. However, the DfT has a history of massively over-stating the demand for aviation growth. In 2000, it predicted that by 2020 unconstrained demand would be 400 million passengers per annum (mppa). By 2009 it had dropped its 2020 forecast to 365 mppa but was confident that in 2030 demand would be 465 mppa.32 Just two years later it had concluded that by 2020 demand would be just 245 mppa and revised its 2030 figure downwards to 345 mppa.33 52. In 2000 DfT thought that in 2010 276 million passengers would use airports in the UK. In 2009, it predicted that it would be 260 million people.34 In reality, it was just 211 million. In just over a decade DfT had revised its 2020 forecasts downward by almost a third; in just two years, from 2009 to 2011 it had downgraded its calculations for 2015 by one quarter. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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UNCONSTRAINED PASSENGER DEMAND FOR AVIATION FORECASTS, 2000–2011, BASED ON DEPARTMENT FOR TRANSPORT FIGURES 2000 forecast 2009 forecast 2011 forecast 2010 276 million 260 million 211 million 2015 333 million 315 million 240 million 2020 400 million 365 million 275 million 2030 465 million 345 million

53. As DfT notes: “even when outturn data for all the key drivers of demand are input into the model” ie even when we know what GDP, exchange rates, oil prices, carbon prices and all the other things which affect the number of ﬂights taken, “the forecasts of UK air passenger numbers for 2009 and 2010 exceed observed passenger numbers.”35 In other words, the model overestimates passenger numbers but DfT then seeks to make policy on the basis of its own ﬂawed model. 54. One reason that the government’s assumptions are so inaccurate is that they are based on questionable assumptions. For example, the latest forecasts assume that the price of oil in 2030 will be $90 (2008 prices). However, the latest forecast by the Department for Energy and Climate Change suggests that a barrel of oil would actually cost $120.36 55. DfT has not provided unconstrained data on future demand for aviation in the South East in its 2011 forecasts. However, it says that in 2010, 125 million passengers used airports in the South East. As the table below shows, passenger numbers eventually peak in 2040, at 185 million passengers, due to capacity constraints. 56. In other words, there is hardly an impending capacity crunch. Even in the supposedly congested South East there is enough capacity in the system for the next 28 years—and that is assuming that DfT is able to accurately model future aviation demand.

Conclusion 57. Greenpeace believes that: demand constraint must be a central plank of the government’s new aviation policy. It is untenable that the UK can meet its legally binding climate change targets whilst allowing aviation to absorb an even bigger share of a steadily shrinking carbon budget. 58. If we are serious about moving to a low carbon economy and improving the quality of life for local communities around the UK, then we must cap airport capacity, support low-carbon transport and improve connectivity through technological means. 59. In the immediate term this means: — The inclusion of aviation and shipping emissions in the UK’s carbon reduction targets — An objective assessment of what proportion of this overall carbon budget can be allocated to aviation which then frames aviation policy. — Ruling out any aviation expansion until this assessment is made. 29 October 2012

References 1. http://www.publications.parliament.uk/pa/cm201213/cmhansrd/cm120704/halltext/ 120704h0001.htm#12070471000096, WH272 2. http://www.heathrowairport.com/about-us/facts-and-figures 3. http://www.aeroport.fr/les-aeroports-de-l-uaf/stats-paris-charles-de-gaulle.php 4. http://www.frankfurt-airport.com/content/frankfurt_airport/en/business_location/facts_figures.html 5. http://www.google.co.uk/url?sa=t&rct=j&q=&esrc=s&source=web&cd=1&ved=0CCMQFjAA&url= http%3A%2F%2Fwww.schiphol.nl%2Fweb%2Ffile%3Fuuid%3Dbb1c88b4–0885–4b7f-a1ae- 0ac4f97c1e31%26owner%3D7ccedf61-a8f4–4180-b5b0–849e8def7d3e&ei= H02BUNH8HsOp0QWPqYCIBA&usg=AFQjCNEePFojHlzfzueBvrmEsWA69Q0q7w 6. http://www.gatwickairport.com/business/about/facts-figures/ 7. http://www.aeroport.fr/les-aeroports-de-l-uaf/stats-paris-orly.php 8. Speech to the Transport Times Aviation Conference, 18 April 2012. http://www.cbi.org.uk/media-centre/ press-releases/2012/04/uk-will-be-a-branch-line-destination-without-a-clear-aviation-strategy-cbi/ 9. Data compiled from Heathrow Airport’s online timetable. http://www.heathrowairport.com/flight- information/flight-timetable cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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10. http://www.primeeconomics.org/wp-content/uploads/2012/09/Heathrow-3rd-runway-03092012.pdf 11. http://www.primeeconomics.org/wp-content/uploads/2012/09/Heathrow-3rd-runway-03092012.pdf, P5 12. Gatwick Airport Master Plan. http://www.gatwickairport.com/masterplan/ Data on passengers from Transport Statistics Great Britain, Department for Transport. http://www.dft.gov.uk/statistics/tables/avi0102/ 13. Stansted Airport Interim Master Plan, BAA, 2006. http://www.stanstedairport.com/static/Stansted/ Downloads/PDF/STN_interim_masterplan.pdf 14. http://www.primeeconomics.org/wp-content/uploads/2012/09/Heathrow-3rd-runway-03092012.pdf, P2 15. http://www.hm-treasury.gov.uk/media/4/3/Executive_Summary.pdf 16. The Contribution of the Aviation Industry to the UK Economy. Oxford Economic Forecasting, 1999. The Economic Contribution of the Aviation Industry in the UK, OEF, 2006. What is the contribution of aviation to the UK economy?, Oxford Economic Research Associates, 2009. 17. British Airways Annual Report. 18. British Airways Annual Report and Ryanair Annual Report 19. Government Tourism Strategy, Department for Culture, Media and Sport, 2011. http://www.culture.gov.uk/ images/publications/Government2_Tourism_Policy_2011.pdf 20. “End unfair subsidy of cheap air travel to regenerate British seaside resorts, Travelodge tells inquiry”, Travelodge, 29 January 2008. http://www.travelodge.co.uk/press_releases/press_release.php?id=288

21. “Slowdown in cheap ﬂights gives boost to British economy”, Stop Stansted Expansion, 30 April 2012. http://www.stopstanstedexpansion.com/press439.html

22. Aviation, jobs and the UK economy, Stop Stansted Expansion, August 2011. Ratios derived from passenger surveys by the Ofﬁce of National Statistics.

23. http://www.publications.parliament.uk/pa/cm201213/cmhansrd/cm120704/halltext/ 120704h0001.htm#12070471000096, 260 WH

24. http://www.telegraph.co.uk/news/politics/9623148/Philip-Hammond-ﬂies-into-airports-row-with- Heathwick-plan.html

25. http://www.guardian.co.uk/environment/2012/aug/28/david-cameron-taunted-tory-mp-heathrow

26. http://www.guardian.co.uk/environment/2012/jan/11/airlines-windfall-eu-carbon-trading

27. Building a low carbon economy—Climate Change Committee, 1st Dec 2008, P316–318

[i] P9, http://downloads.theccc.org.uk/Aviation%20Report%2009/ 21667B%20CCC%20Aviation%20AW%20COMP%20v8.pdf

28. http://news.nationalgeographic.com/news/2008/02/080207-biofuels-carbon_2.html

29. http://www.guardian.co.uk/environment/2011/may/31/biofuel-plantations-africa-british-ﬁrms

30. http://www.guardian.co.uk/environment/damian-carrington-blog/2012/mar/16/aviation-biofuel-british- airways-carbon

31. UK Aviation Forecasts, Department for Transport, 2011. http://assets.dft.gov.uk/publications/uk-aviation- forecasts-2011/uk-aviation-forecasts.pdf

32. http://webarchive.nationalarchives.gov.uk/+/http://www.dft.gov.uk/pgr/aviation/atf/co2forecasts09/ co2forecasts09.pdf, p5

33. http://assets.dft.gov.uk/publications/uk-aviation-forecasts-2011/uk-aviation-forecasts.pdf, p44

34. http://webarchive.nationalarchives.gov.uk/+/http://www.dft.gov.uk/pgr/aviation/atf/co2forecasts09/ co2forecasts09.pdf, p42

35. http://www.transportxtra.com/magazines/local_transport_today/news/?ID=27945

36. DECC oil price projections, Department of Energy and Climate Change, October 2011. http://www.decc.gov.uk/assets/decc/11/about-us/economics-social-research/2934-decc-oil-price-projections.pdf Figures given in 2010 prices and have been converted to 2008 prices for comparison. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Written evidence from the UK Travel Retail Forum (AS 112) 1. What should be the objectives of Government policy on aviation? — In the interest of UK air passengers, UK airports and the UK duty free industry, the UK Travel Retail Forum (UKTRF) calls on the British Government to safeguard passenger rights—in an evolving aviation market. — The UKTRF wants the British Government to recognise, based upon established practice and normal passenger expectations, that passengers have a right to carry specified items on board a flight in addition to their hand baggage allowance. — Legislation, at national or EU-level, must be put in place as soon as possible to enshrine in law a right which passengers have enjoyed for the past 60 years and which has enabled UK airports to fund themselves without recourse to state aid. 1. The UKTRF is a national trade association whose members represent most sectors of the travel retail business. Non-aviation revenues, including the duty-free and travel retail businesses, are a crucial generator of income for airports of all sizes across the UK. The overall aim of our organisation is to secure a sustainable future and the most favourable operating environment for these companies. 2. The UKTRF’s number one issue is the refusal by certain airlines to allow their passengers to bring on board airport shopping in addition to the airline’s prescribed baggage allowance. This issue continues to impact consumer choice and regional airport revenue. 3. The UKTRF, supported by the Airport Operators Association (AOA), has noted the substantial impact this practice is having on the passenger experience and on airport retail sales at UK airports that rely heavily on commercial revenue to fund infrastructure, keep airport charges low and attract airlines. 4. Passengers travelling on these airlines are now required to cram all their personal belongings into a single carry-on bag with absolutely no exceptions. Otherwise they are forced to pay an exorbitant “fine”, throw the goods away or worse still, be denied travel. This runs contrary to established practice, is inconsistently applied and has led to enormous passenger confusion. 5. The practice is being implemented in at least 11 UK airports, with one Low Cost Carrier (LCC) enforcing it in nine airports. 6. Airlines who practice this policy maintain that this is a necessary measure for safety and efficiency. We dispute this claim entirely. If this were the case, the airlines operating this policy would do so on a consistent basis. Moreover the airline then sells items on board from their own duty free and travel retail selection, which has to be stored by the passenger until they arrive at their destination. Indeed, UK passengers have been enjoying airport shopping for over 60 years now without any operational difficulties for airlines. 7. Instead it appears that the practice stems from a desire to create additional revenue streams, as passengers are then encouraged to shop onboard from a very narrow product offering compared to that at airports. One low cost carrier experienced a 64% growth in ancillary revenue between 2005 and 2010. 8. The dominant market position of some airlines has made it difficult to find a commercial solution to this problem at many airports in the UK. 9. In general such airports are very reluctant to challenge the airlines in question for fear of losing vital traffic and routes. For the same reason, it would be very difficult for airports to make a complaint to the Office of Fair Trading, as that would risk retaliatory measures—certain low cost airlines have proven themselves very adept at withdrawing services at short notice, when an airport takes a policy stance they are not in agreement with. b) What are the benefits of aviation to the UK economy? — Airport shopping in the UK is worth almost £1.5 billion per annum. These revenues are crucial to the continued development and well being of UK airports. — It is estimated that over 20,000 people in the UK are employed directly in airport retail serving 220 million passengers each year. — For most regional airports over 50% of their income comes from non-aeronautical activity, of which retail income is a hugely significant part. 10. Shopping is an important means of generating revenue for the development of a vibrant and attractive retail space, which is considered to be a critical element of new infrastructure development. Airports use this revenue to finance these upgrades and to reduce their aeronautical charges. Airlines pass-on these reductions to passengers through lower ticket prices. Indeed airport charges in the UK are among the most competitive in Europe due largely to income from airport retail. 11. The practice, of not allowing a bag of duty free and travel retail or food and beverage purchases—unless it is crammed into a passenger’s one piece of hand luggage, threatens in the long run the viability of using retail income to finance airport operations. It also calls into question the justification for some airports to reduce cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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aeronautical charges to below cost in exchange for a guarantee that a minimum number of passengers will pass through the airport in the hope that they can recoup their losses from retail sales. — UK airports are losing conservatively over £3 million in annual revenue as a result of this practice. — The clearest way to see the negative impact is in spend per head (SPH). Typically SPH by a passenger on an airline with a “one bag” policy is between 35% and 60% less than passenger SPH on an airline where this policy is not applied. 12. Further evidence of customer confusion is clear from recent airport research that shows that passengers travelling on airlines who do not apply this policy are no longer confident that they can take their airport shopping on-board. 13. Airport retailers are already impacted by the general economic downturn, increased security costs and procedures, which reduce airside dwell time. With online check-in now the norm, people are arriving at the airport later and have less time to shop—statistics show that one minute less dwell time is equal to a decrease of 1% in retail sales. 14. Until recently the possibility of a regional airport being forced to close was limited as they were mainly state-run facilities. Today most airports in the UK are privately owned, and in recent years both Coventry and Sheffield City airports have been forced to close. In short, the commercial impact of this rule could have serious ramifications well beyond airport retail. d) How should improving the passenger experience be reflected in the Government’s aviation strategy? — 39% of all passengers say that uncertainty about cabin baggage allowances prevents them from shopping at the airport. 15. The practice is inconsistently applied in the UK and in other EU countries, with the result that passengers never know whether they can take their shopping on board or not, even when travelling on the same airline. The confusion is so great that even on legacy carriers significant numbers of passengers think that they cannot take their airport shopping on board in addition to their cabin baggage. The UKTRF remains convinced that the only solution to this issue is EU-wide legislation, which will prevent this market abuse. 16. A recent study at a major regional airport revealed that 39% of all passengers, irrespective of airline, are now not shopping at the airport for fear of confiscation and conflict with airline staff during the boarding process. 17. The UKTRF and AOA believe this practice to be grossly unfair to both passengers and airports. On boarding, passengers find that the airline is offering similar goods for sale, albeit with a fraction of the choice available at the airport. 18. Unlike airport shops, airlines only carry a very limited range of goods on board for sale. By effectively preventing passengers from buying at the airport, airlines are denying consumer choice.

3. What constraints are there on increasing UK aviation capacity? c) What is the relationship between the Government’s strategy and EU aviation policies? — The UKTRF is supported by the AOA and more than 30 cross-party UK MPs. — There is growing momentum across Europe for new EU legislation. 19. The British Government has a strong record of taking leadership positions on international civil aviation matters, and it has an opportunity to continue this by taking action on this arguably restrictive practice, which is bad for passengers and bad for airports. 20. The UKTRF, AOA and Mike Crockart MP met with Theresa Villiers, in April this year—as a direct result of the strong political support pledged by more than 30 cross-party politicians including the Transport Select Committee Chair, Aviation APPG Chair and MPs with airports in or neighbouring their constituencies. Minister Villiers assured us that the government would take a fresh look at its position on this matter. 21. Mark Prisk, in his position as Better Regulation Minister, also agreed that action is required at an EU- level and designated one of his senior ofﬁcials to work with us on this issue. 22. The forthcoming review of the Air Passenger Rights Regulation will give us a unique opportunity to solve this problem once and for all. We understand that a proposal will be forthcoming from the European Commission as early as December this year. 23. Across the EU, our position has received the full support of many governments including France, with others such as Italy and Portugal looking at it further. The European Parliament has now voted three times for legislation to solve this problem. 24. In May 2012, the European Parliament adopted Philip Bradbourn MEP’s report (The future of regional airports and air services in the EU), with an overwhelming majority. The adoption of this report reafﬁrms the European Parliament position, which had already been established in an earlier report by Keith Taylor MEP, cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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which references the right of passengers to carry their airport purchases on board in addition to their baggage allowance. 25. We have now written to the new Aviation Minister asking him to outline the government’s position and to invite his team to play a crucial role in the evolution of this legislation.

Concluding remarks — The only solution to this issue would be to introduce legislation, at national or EU-level, which will alleviate passenger confusion and prevent this market abuse. — The forthcoming review of the Air Passenger Rights Regulation will give us a unique opportunity to solve this problem once and for all, and to give passengers the certainty they need to buy with conﬁdence. — Across the EU our position has received the full support of governments including France. — On behalf of the British public, the travel retail industry and our airport partners, we urge the British Government to follow suit. 30 October 2012

Written evidence from The London Assembly (AS 113) The London Assembly recognises the vital role aviation has to play in the UK’s economy and the need to strike a balance between the economic beneﬁts there are to be gained from a dynamic aviation sector, and effectively managing the negative environmental impacts that can result from airport operations. We therefore welcome the Government’s commitment to developing a long-term sustainable approach to managing aviation impacts and we are pleased to submit this response to the Government’s consultation on its draft Aviation Policy Framework.

The London Assembly’s position on expansion While this response provides comments and views on the national approach it will do so in the context of what it means for Londoners and how the policy approaches outlined in the consultation document might affect them. The Assembly has consistently opposed proposals for expansion at London Heathrow on the grounds that the negative environmental effects are disproportionate to the estimated beneﬁts an expanded Heathrow would bring to London.168 In 2003, we opposed the recommendations in the White Paper to expand Heathrow.169 We maintained our position in 2005, when the British Aviation Authority produced an interim master plan for how expansion may take shape, raising concerns over the plan’s ability to meet air quality targets, to secure greater public transport access to the airport and to limit the impact of the airport on the quality of life for local communities.170 In 2007 we disputed the arguments in support of expansion, outlined in the Department for Transport consultation, Adding Capacity at Heathrow, on the basis that we were unconvinced that expansion at Heathrow was essential to the well being of London and the wider UK economy, and that the conditions placed on expansion did not adequately address the local and international environmental costs and impacts it would have.171 The Assembly reafﬁrmed its position this year, unanimously opposing expansion at Heathrow.172

Our response to the consultation This response does not revisit the merits of the argument for increasing capacity in the South East, whether through expansion at Heathrow or at another location, but it sets out what the Assembly believes are valid concerns and considerations that would need to be taken into account in managing the environmental impacts of aviation both now and in the future. This response will focus on Chapters 3 (Climate change impacts), 4 (Noise and other local environmental impacts) and 5 (Working together) of the consultation document. 168 See http://www.london.gov.uk/assembly/reports/plansd/heathrow_expansion.pdf 169 The White Paper “The Future of Air Transport” proposed a "balanced strategy" between airport expansion and the environmental impacts, in line with its "commitment to sustainable development", and concluded that the capacity of UK airports, particularly in southeast England, was "an important constraint on future growth". The White Paper supported runway expansion plans at Heathrow and Stansted airports. The Assembly maintained the position that the aviation industry must meet its environmental and external costs. The response is at http://www.london.gov.uk/who-runs-london/the-london-assembly/publications/transport/ aviation-consultation-response 170 See http://www.london.gov.uk/who-runs-london/the-london-assembly/publications/transport/heathrow-expansion 171 http://www.london.gov.uk/who-runs-london/the-london-assembly/publications/transport/response-governments-consultation- adding-capacity-heathrow-airport 172 Motion passed at 11 July 2012 Assembly plenary meeting. See http://www.london.gov.uk/media/press_releases_london_ assembly/assembly-says-no-revival-third-runway-heathrow cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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We draw on a considerable body of work including previous consultation responses by the Assembly, investigations led by the Assembly’s Environment Committee (on the environmental impacts of operations at the London Heathrow and London City airports),173 the Health and Environment Committee’s recent discussion with an expert panel,174 written submissions,175 and published research and information.

SUMMARY OF THE RESPONSE Climate change The general approach Meeting the national target to reduce net GHG (greenhouse gas) emissions by at least 80% below the 1990 baseline by 2050, as set out in the Climate Change Act 2008 will be a considerable challenge, requiring a significant curb in the growth of the expected increase in passenger numbers.176 The Committee would caution against the emphasis placed on securing international agreement and on the European Emissions Trading System (EU ETS), as currently configured, to achieve the national target. Further improvements and greater uptake of the EU ETS may be needed before it can deliver the desired reduction levels. A phased approach to reducing aviation emissions is needed, setting out short, medium and long term milestones; we previously recommended that these should be legally binding. We welcome the Committee on Climate Change’s advice to Government earlier this year that aviation should also be included in the five- yearly carbon budget system and would urge the Government to take this advice on board.177 Incentivising to improve aircraft performance The Government should continue to support and encourage technological developments through industry led projects. There is also scope for the Government to incentivise research into and the use of renewable transport fuels, other than biofuels.

Noise and other local environmental impacts Noise The Assembly welcomes the Government’s policy approach and its commitment to establish a framework that incentivises noise reduction and mitigation more strongly, and encourages better engagement and greater transparency between airports and local communities. The Assembly is concerned with two key aspects of this approach: the measurement used and the threshold that is applied. The 57 dB LAeq contour, the level at which the Government deems individuals become annoyed at noise, does not fully reflect the numbers of people affected by aircraft noise and is inconsistent with EU requirements for drawing up noise action plans. Government should take the opportunity to review the approach to measuring noise levels, and bring it in line with EU requirements. The Assembly cannot condone the introduction of an operational change that would deny residents such respite from aircraft noise, and have a detrimental impact on their health. The Assembly would wish to see a strategic approach to noise mapping and consistency in the way in which mitigation and compensation schemes are applied across London. The noise contours for London City Airport and Heathrow Airport are drawn up separately. There is a need for joint contours, as people are increasingly affected by the combined impact of aircraft noise arriving and departing from both these airports. The absence of joint contours completely underestimates the actual noise that is being heard. There is scope for developing joint contours or other indicators, such as flight path density plots, or noise event-based measures, for such areas. Night noise The Assembly welcomes the Government’s planned consultation on the arrangements for managing night time flights at Heathrow, Stansted and Gatwick airports later this year, and the inclusion of a review of the costs and benefits of night flights and current literature on aviation night noise health impacts. Air quality In addition to measures to improve air quality, such as increasing use of greener, quieter aircraft, ensuring on-site vehicles meet the latest EU emissions standards, and reducing airport related road traffic, there are a range of issues that will need to be tackled to improve surface access to Heathrow Airport to encourage greater use of public transport for journeys to and from the airport.

Working together Airport Consultative Committees The Assembly welcomes the Government’s commitment to see ACCs play a more effective role; they provide a useful forum within which to seek input from a wide range of stakeholders. In London we are seeing a growing need for inter-relationship between the Heathrow and London City Airports’ 173 Flights of Fancy: can an expanded Heathrow meet its environmental targets? January 2010; Plane Speaking: air and noise pollution around a growing Heathrow Airport, March 2012 http://www.london.gov.uk/who-runs-london/the-london-assembly/ publications 174 Health and Environment Committee Meeting, 16 October 2012. A transcript of the discussion is available at http://www.london.gov.uk/moderngov/ieListDocuments.aspx?CId=256&MId=4617 175 Submissions were received from London First and the WWF. 176 The level of gross emissions from a particular sector is the actual quantity of emissions emitted by the sector. The net emissions for the sector take account of the emissions allowances or international project credits that it has traded with other sectors 177 Page 9, Health and Environment Committee transcript 16 October 2012. See also http://www.theccc.org.uk/carbon-budgets cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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consultative committees and consider that there would be merit in enhancing arrangements for inter-airport liaison. Role of the Civil Aviation Authority (CAA) The Assembly believes that there is scope for an independent body to monitor noise and administer airport mitigation and compensation schemes. The lack of independent scrutiny of the noise action plans drawn up in the UK, are also a concern. Elsewhere in Europe they are drawn up by an independent third party. Independent administration could help rebuild the trust that has been loss by local communities in how airport operators seek to manage, mitigate and compensate for the negative environmental impacts that can arise from airport operations. Further research into who might best be placed to carry out this role is needed.

CHAPTER 3—CLIMATE CHANGE IMPACTS The Government is seeking views on: a) the general approach it is taking and, b) further ideas on how the Government could incentivise the aviation and aerospace sectors to improve aircraft performance with the aim of reducing emissions.

The Government’s approach The Government’s policy objective is to ensure that the aviation sector makes a significant and cost effective contribution towards reducing global emissions.178 Its’ emphasis is on global action as the best means of securing the objective, with action at European level a potential step towards wider international agreement. Around 95% of UK aviation emissions come from flights departing from UK airports to international destinations.179 The Government maintains that measures to tackle emissions from UK aviation will need bilateral or multilateral agreement.180 It is committed to taking action at national level where appropriate and justified, in terms of the balance between benefits and costs.

The national target The Climate Change Act 2008 sets a legally binding target to reduce net GHG (greenhouse gas) emissions by at least 80% below the 1990 baseline by 2050.181 Stakeholders have previously expressed concerns to the Assembly that the national target, while ambitious, appears to have been set without a clear pathway for how it might be achieved.182 Findings by the Committee on Climate Change (CCC) would appear to support this hypothesis. The CCC report notes that the exclusion of the non-carbon dioxide emissions of aviation—an estimated magnitude equivalent to up to two times that 183 of the carbon dioxide emissions—could have implications for the UK’s overall emissions reduction targets. The report also advises that increases in airport passenger numbers across the UK would need to be limited to 60%, instead of the 200% growth forecasted on a “business as usual” path, if the target is to be met.184 On the basis of this scenario, aviation could account for 25% of total UK emissions in 2050.185 Even accounting for improvements in technology and more efﬁcient fuel use, huge efforts will need to be made by society in other areas, such as decarbonised power supply by 2030, electric vehicle use, fully insulated housing stock, to meet the 60% growth. There are clearly critical choices to be made in the run up to 2050. It is therefore imperative that Government take a considered view of all the latest academic research on climate change to enable these choices to be fully informed.186 A long-term target is essential, alongside a clear sense of the incremental achievements needed and timings for them, to allow for review and/or remedial action as required. The Assembly believes that a phased approach to reducing aviation emissions is needed, setting out short, medium and long term milestones; we previously 178 Paragraph 3.4 Draft Aviation Policy Framework (APF) 179 Paragraph 3.6 Draft APF 180 As per the consultation document—see paragraph 3.6 181 The level of gross emissions from a particular sector is the actual quantity of emissions emitted by the sector. The net emissions for the sector take account of the emissions allowances or international project credits that it has traded with other sectors 182 Flights of Fancy: can an expanded Heathrow meet its environmental targets? January 2010 http://www.london.gov.uk/who-runs- london/the-london-assembly/publications 183 This approach is consistent with the Kyoto Protocol and the Climate Change Act. Meeting the UK aviation target—options for reducing emissions to 2050, December 2009. http://www.theccc.org.uk/reports/aviation-report 184 http://downloads.theccc.org.uk/Aviation%20Report%2009/AviationReportPRESSRELEASE08.12.09.pdf 185 Page 6, Health and Environment Committee transcript 16 October 2012 186 Page 10, Health and Environment Committee transcript 16 October 2012. There is a school of thought which argues that a more urgent and radical approach will be needed, requiring a 90 per cent reduction in emissions by 2030 (with interim reductions of 40 per cent by 2015 and 70 per cent by 2020). The paper, Beyond Dangerous climate change: emissions scenarios for a new world, 2011, by the Royal Society http://rsta.royalsocietypublishing.org/content/369/1934/20.full.pdf+html reports that it is virtually impossible to stabilise the global mean surface temperature at or below 2C by 2050, and recommends taking much more radical short and medium term reductions in emissions, in order to achieve 90 per cent reductions by 2030, otherwise the science indicates temperature increases of 4C by 2050–70, a point beyond adaptation and collapse of most eco-systems. It should be stressed that this view goes beyond the current global consensus, is not necessarily endorsed by the Committee, and should therefore be carefully analysed alongside all the other available evidence. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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recommended that these should be legally binding.187 We welcome the CCC’s advice to Government earlier this year that aviation should also be included in the ﬁve-yearly carbon budget system. We would urge the Government to take this advice on board.188

Reliance on an international agreement Progress on securing international agreement is slower than first anticipated. The Climate Change Summit in Copenhagen presented an unrivalled opportunity to make significant strides forward in tackling aviation emissions on a global scale. It was particularly relevant for the UK given that the CCC aviation report assumes UK action in the context of an international agreement.189 The global agreement reached at the Summit—the “Copenhagen Accord”, fell far short of any legally binding commitments. Agreement has proved elusive in successive summits. The Assembly acknowledges the commitments by the CAEP (Committee on Aviation Environmental Protection) on behalf of the ICAO (International Civil Aviation Organisation) to agree an international CO2 standard for aircraft by 2013 which aims to reward and encourage improvements in technology to reduce emissions. Also the agreement between UN Member states and relevant organisations working through ICAO to achieve global aspirational goals of carbon neutral growth from 2020 and average fuel efficiency improvements of two% per year up to 2050. The ICAO has recognised that the latter goal “is unlikely to deliver the level of reduction necessary to stabilise and then reduce aviation’s absolute emissions contribution to climate change and that goals of more ambition will need to be considered to deliver a sustainable path for aviation.”190 The Assembly welcomes the commitment by the industry to improving CO2 efficiency 1.5% per year on average from 2009 to 2020 to deliver carbon neutral growth through a cap on net emissions from 2020 and to cut net emissions in half by 2050 compared with 2005 levels.191 Net emissions take account of emissions allowances or international project credits that can be traded with other industrial sectors. But it is currently unclear whether these actions will result in a reduction in gross emissions.

Effectiveness of the EU Emissions Trading System (EU ETS) Research indicates that the inclusion of aviation in the EU ETS will provide only part of the solution over the short-term.192 As of 1 January 2012, all flights arriving into and departing from the EU were included within the scope of the EU ETS. Under the EU ETS, these flights are subject to an emissions cap of 97% of average annual emissions between 2004 and 2006. This cap will reduce to 95% in 2013. The 2% reduction in emissions under the EU ETS is to be welcomed, but cautiously, given the current economic climate and the resulting surplus in permits to purchase additional emissions allowances.193 The limited impact raises the question of whether the cap on aviation emissions under the EU ETS will be sufficient and highlights the need for a reduction in gross emissions as well as net emissions from aviation. Expert opinion is that Europe should be moving to a 30% target as opposed to 20% and that the UK should be pressing for this to happen.194 The CCC says that emissions trading to limit aviation emissions is feasible as part of a range of measures and that it will be useful for an interim period. But that over time aviation emissions growth will have to be carefully managed.195 The Committee has differing views on this. The Conservative Group supports the position of the CCC on this issue, but the majority of the Committee (the Green, Labour and Liberal Democrat Groups) is not confident that the trading scheme can be made workable, or generate a reduction in gross emissions overall.

Reliance on technological advancement The Assembly acknowledges the considerable effort by the aviation industry over the last 40 years to make aircraft more efﬁcient. Despite this, trends in improvements in aircraft technology are relatively slow when compared to other industries.196 As expressed in the consultation document, the Government should continue to support and encourage technological developments through industry led projects. 187 Recommendation 5, Flights of Fancy: can an expanded Heathrow meet its environmental targets? January 2010 188 Page 9, Health and Environment Committee transcript 16 October 2012. See also http://www.theccc.org.uk/carbon-budgets 189 COP15 Copenhagen, Held 7—18 December 2009 http://en.cop15.dk/frontpage 190 Declaration by the high-level meeting on International Aviation and Climate Change (HLM-ENV/09) in October 2009 http://www.icao.int/environmental-protection/Pages/programme-of-action.aspx 191 Paragraph 3.10 of the consultation document notes that airlines represented by IATA—the International Air Transport Association—have committed to these targets. 192 According to the European Federation for Transport and the Environment, integrating aviation into the EU ETS will do little to reduce aviation emissions. The EU Commission’s assessment back in 2008 was that integration of aviation into the EU ETS policy will reduce emissions by just three per cent—Including aviation into the EU Emissions Trading Scheme, updated June 2008 193 http://www.guardian.co.uk/environment/2012/may/15/eu-airline-emissions-tax-success 194 Page 13, Health and Environment Committee transcript—comments from Sir Brian Hoskins 195 Lord Turner’s Letter to Ministers, dated 9 September 2009. Available at http://hmccc.s3.amazonaws.com/ CCCAviationLetterSoS%2009.09.09.pdf 196 Meeting of the Environment Committee, 5 November 2009 This view was expressed by Dr Sam Fankhauser of Grantham Institute for Climate Change and a member of the CCC cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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There is also scope for the Government to incentivise research into and the use of renewable transport fuels, other than biofuels. According to the CCC, biofuels—fuel whose energy is derived from biological carbon fixation—will account for no more than 10% of the total aviation fuel mix in 2050.197 The national target set is challenging, but necessarily so. What is open to question is whether the existing road map to achieving it, particularly in terms of the contribution the aviation industry will need to make, will be sufficient. Considerable reliance has been placed on reaching an international agreement, and with little outcome to date. It appears that a more rigorous approach to the EU ETS will be needed and progress in making aircraft more efficient will need to be stepped up. Crucially, even working on the assumption that all three elements—international agreement, the EU ETS and technology improvement—are progressing at the desired pace, significant life-style and industry changes will be required over the next 30 to 40 years.

CHAPTER 4—NOISE AND OTHER LOCAL ENVIRONMENTAL IMPACTS This section of the response presents the Assembly’s views on the Government’s overall objective on aviation noise, the appropriateness of the current method used to describe noise impact and determine noise contours, the case for reducing noise exposure levels, and the adequacy of approaches to mitigating and compensating noise impacts. This section also covers night noise and air quality impacts. From time to time reference will be made to Heathrow airport, given that: a) it is based in London and accounts for around 70% of people in the UK exposed to average noise from airports above 55 decibels (dB)—the level at which the World Health Organisation has said that people become seriously annoyed by noise,198 and b) More than one in four people exposed to this level of noise around European airports lives near Heathrow.199 There are limits to what further improvements can be made to the noise generated by individual aircraft, with existing design and conﬁguration.200 Therefore the main levers for managing noise levels on the ground are controls on how many aircraft can ﬂy overhead, where and when.

The Government’s overall objective on aviation noise The Government has adopted the high-level policy objective on aircraft noise set out in the previous administration’s 2003 white paper, The Future of Air Transport—to limit and, where possible, reduce the number of people in the UK signiﬁcantly affected by aircraft noise.201 The objective is consistent with the Noise Policy Statement for England (NPSE) published in March 2010.202 More and more London residents are being affected by noise from aircraft. Historically aircraft noise through Heathrow was previously considered to be a fairly contained problem, affecting residents to the west of London. But in just over a decade the problem has spread to the south east and east of London affecting residents living up to 20 kilometres away from the airport.203 Residents in these areas and also to the north of London are increasingly affected by noise from aircraft arriving and leaving London City Airport. In some cases residents have to bear the combined impact of aircraft noise from both airports. Stacking increases exposure to noise as capacity increases. The Assembly therefore welcomes the Government’s policy approach and its commitment to establish a framework that incentivises noise reduction and mitigation more strongly, and encourages better engagement and greater transparency between airports and local communities.

Noise contour measurement methods and thresholds The Government is minded to retain the previous administration’s policy to use the 57 dB LAeq,16h contour as the average level of daytime aircraft noise marking the approximate onset of significant community annoyance. The Assembly is concerned with two key aspects of this approach: the measurement used and the threshold that is applied. Simply put the measurement used for assessing noise pollution is based on averages, meaning that the actual number of flights is not fully reflected. In practical terms this results in an underestimation of the extent of the noise problem around an airport, and the number of people affected. 197 Carbon fixation is the conversion of carbon dioxide into organic compounds by plants 198 The World Health Organisation (WHO) is the directing and coordinating authority for health within the United Nations. It provides leadership on global health matters, shaping the health research agenda, setting norms and standards, articulating evidence-based policy options, providing technical support to countries and monitoring and assessing health trends. 199 Frankfurt, Paris Charles de Gaulle, Amsterdam Schiphol and Madrid, source page 49 draft APF 200 Page 15, Health and Environment Committee transcript 16 October 2012 201 The Future of Air Transport, DfT, December 2003, http://webarchive.nationalarchives.gov.uk/+/http://www.dft.gov.uk/about/strategy/whitepapers/air/ 202 http://www.defra.gov.uk/environment/quality/noise/npse 203 All Change, Aircraft noise is no longer just a West London problem, HACAN, March 2011 cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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UK daytime aircraft noise is measured using the method LAeq, more commonly abbreviated to Leq.204 While Leq is recognised as the most common international measure of aircraft noise, drawbacks to the measurement are also well documented.205 The Government commissioned study, Attitudes to Noise from Aviation Sources in England (ANASE) concluded that the method of calculating noise, adopted since the eighties, was too narrow and failed to take account of either the growth in the number of flights or increasing public intolerance to noise. It recommended using an index, which would better reflect the number of flight events. 206 The 57 dB LAeq contour, the level at which the Government deems individuals become annoyed at noise, does not fully reflect the numbers of people affected by aircraft noise and is inconsistent with EU requirements for drawing up noise action plans. The EU requires Member States to draw up noise action plans using a measure called Lden, and applying a threshold of 55dB207. The Lden approach takes the combined effect of noise levels during the day, evening and night and averages them over a 24-hour period. But crucially, it weights the evening and night noise levels by adding 5dB and 10dB respectively to reflect the greater nuisance of noise at those times. Results from aircraft noise mapping for Heathrow airport in 2006 show that an estimated 725,000 people were within the 55dB Lden noise contour (the EU threshold for noise action plans), compared to the 253,700 that are shown to be affected within the 57dBLAeq noise contour.208 The World Health Organisation (WHO) suggests that the 57dB LAeq measurement is outdated, and notes that the thresholds of 50dB (for moderate annoyance) and 55dB (for serious annoyance) better reflect individuals’ experiences.209 Research by the campaign group HACAN shows that over two and half million people would be affected if a 50dB threshold were applied. This means that the affected area around Heathrow airport would extend into parts of South East and North London, and beyond Maidenhead to the West.210 Anecdotal evidence shows that residents are already significantly affected by aircraft noise in areas such as Clapham, Vauxhall, Stockwell, Camberwell, Kennington Park and Blackheath.211 The relationship between daytime Leq and Lden will depend on the pattern of operations at an individual airport, however, the overall outcome is that a 55dB Lden threshold shows that more people are “affected” by noise than by the 57dB Leq threshold. The Government’s method for measuring noise impacts should be consistent with the EU requirements for noise action plans. In light of the growing recognition of the need to review the 57dB LAeq method for measuring noise, Government must take the opportunity to review its approach, and seek to bring it in line with EU requirements.

The need to retain respite for local people Runway alternation is a valuable way of providing relief from aircraft noise to residents in West London. The Assembly cannot condone the introduction of an operational change that would deny residents such relief, and have a detrimental impact on their health. Analysis of data from the ﬁrst phase of the ongoing operational freedoms trial at Heathrow shows that signiﬁcantly more residents’ quality of life is being affected, with them noticing an increase in the frequency and noise from aircraft.212

Mitigating and compensating noise impacts The Assembly recognises that qualifying thresholds for mitigation and compensation vary considerably and that there can be plausible reasons for this. A recently published comparative study of airport noise insulation grant schemes highlights the wide variance in the thresholds identified by airports world-wide.213 However we are concerned by the inconsistency that is evident within the Greater London boundary and believe that there is scope to redress this, and develop a strategic approach to recognising and mitigating the impacts of aircraft noise across London. 204 The Leq method records individual plane noise in decibels and averages them out over a 16-hour day, between 7am and 11pm. The resulting figure is then averaged out over the year. As the measurement is based on averages it includes quiet periods when there are no planes, and excludes night-time flights and the busiest period of the day (6 to 7am), when both runways at Heathrow are used for landing. Information sourced from HACAN briefing note on airport related noise pollution, available at http://www.hacan.org.uk/resources/briefings/hacan.briefing.noise.pdf 205 The BAA written submission to the London Assembly Environment Committee notes that Leq is the most common international measure of aircraft noise. 206 Published November 2007. Available at http://www.dft.gov.uk/pgr/aviation/environmentalissues/Anase/ 207 Directive 2002/49/EC requires EU Member States to produce noise maps in 2007 using the Lden noise metric. Lden takes the noise levels during the day, evening and night and averages them over a 24-hour period. But crucially the evening and night noise levels are weighted by adding 5dB and 10dB respectively to reflect the greater nuisance of noise at those times. 208 Page 22, Heathrow Airport Noise Action Plan 2010–2015 209 Guidelines for community noise, World Health Organisation 1999 http://www.who.int/docstore/peh/noise/guidelines2.html 210 Aircraft Noise and London Heathrow Flight Paths, February 2007, Bureau Veritas, Acoustics and Vibration Group. (commissioned by HACAN) Available at http://www.hacan.org.uk/resources/reports/st06145.text.final.pdf 211 All Change, Aircraft noise is no longer just a West London problem, HACAN, March 2011 212 http://www.heathrowairport.com/noise/noise-in-your-area/operational-freedoms-trial 213 Page 9, Comparison of Airport Noise Insulation Grant Schemes—An Update, by Bureau Veritas on behalf of London Borough of Hounslow, June 2011 cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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It is becoming increasingly apparent that there is a need for a strategic approach to noise mapping across London. Residents in areas in east London, such as the Docklands, have, in recent years, begun to experience combined increased levels of noise from aircraft serving London City Airport and Heathrow. The noise contours for both airports are drawn up separately. We understand that this situation may possibly apply to parts of south east London, such as Lewisham.

The absence of joint contours in those areas where there are a significant number of both Heathrow and City aircraft completely underestimates the actual noise that is being heard. We would urge the Department for Transport in conjunction with the Civil Aviation Authority to consider the scope for developing joint contours or other indicators, such as flight path density plots, or noise event-based measures, for those areas of London where residents and communities are affected by the joint impact of noise from aircraft flying to and from Heathrow and London City Airports.

There should be consistency in mitigating and compensating for aircraft noise impacts. The noise mitigation scheme at London City Airport is currently based on the 57dB LAeq contour, while at Heathrow it is 69dB LAeq. Both thresholds are considerably above the 55dB recognised trigger point for serious annoyance by noise. Heathrow is proposing to adopt the Lden metric thereby reducing the threshold to 63dB. This is a welcome step in the right direction, as the move will narrow the gap between the respective thresholds, but we believe more should be done. At Heathrow the 57 LAeq contour would equate to the 59dB Lden contour at any given point around the airport.214 We have previously urged Heathrow airport to apply a 59dB Lden threshold in its revised mitigation scheme. Over time we would wish to see a lower threshold adopted by both airports.

Night noise

The Assembly welcomes the Government’s planned consultation on the arrangements for managing night time flights at Heathrow, Stansted and Gatwick airports later this year. We welcome the inclusion of a review of the costs and benefits of night flights and current literature on aviation night noise health impacts. We intend to submit a full response to the consultation but think it worth reiterating here a number of points raised by the Assembly publication, Plane Speaking, earlier this year.215

Our report stressed the importance of a comprehensive review of the latest evidence on the adverse health impacts of night aircraft noise, including a cost beneﬁt analysis. It also called for the consultation to take full account of the publication of the WHO Night Noise Guidelines for Europe in 2009.216 For as long as any night ﬂights continue, for example, during a phase-out period, consideration should be given to modifying the current night rotation scheme to change runway use/direction nightly, rather than on a weekly cycle, so that, if people’s sleep is disturbed on one night, they may have a greater chance of catching up on the following night.

Air quality and other local environmental impacts

Poor air quality is a London-wide problem, but particularly so around Heathrow. There has been little improvement in concentration levels of two key pollutants—NO2 and particulate matter (PM10), since 2001/ 02. Areas around Heathrow are already in breach of European Union (EU) air quality limits.

The Assembly has recently published two reports that consider air quality impacts quite extensively.

The ﬁrst, Flights of Fancy, can an expanded Heathrow meet its environmental targets, in 2010 examined the environmental conditions attached to the previous Government’s expansion plans for Heathrow Airport. Among the key issues the report identiﬁed, are: the lack of a co-ordinated package of mitigation measures to reduce nitrogen dioxide (NO2) concentration levels around Heathrow; concerns over the perceived disproportionate reliance on aircraft technology, and inadequacy of existing and proposed transport measures to mitigate air pollution levels, plus the lack of clarity around enforcement of the air quality condition. See pages 22 to 28.

The second, Plane Speaking: air and noise pollution around a growing airport 2012, follows on from Flights of Fancy reviewing progress made by Heathrow Airport to address air and noise pollution around the airport. The report proposed addressing air pollution by: increasing use of greener, quieter aircraft, ensuring on-site vehicles meet the latest EU emissions standards, and reducing airport related road trafﬁc. The report also highlights a range of issues that will need to be tackled to improve surface access to the airport and to encourage passengers and employees to use public transport more for their journeys to and from the airport. See pages 17 to 30. 214 Local Authorities’ Aircraft Noise Council consultation response to Heathrow’s review of its noise mitigation schemes, August 2011 available at www.laanc.org.uk 215 Plane Speaking: Air and noise pollution around a growing Heathrow Airport, March 2012 http://www.london.gov.uk/who-runs- london/the-london-assembly/publications 216 A copy can be downloaded at http://www.euro.who.int/en/what-we-do/health-topics/environment-and-health/noise/publications/ 2009/night-noise-guidelines-for-europe cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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CHAPTER 5—WORKING TOGETHER

The Government is seeking views on how local collaboration might be and transparency might be improved. This section of the response presents the Assembly’s views on the role of Airport Consultative Committees and the role of the Civil Aviation Authority.

Airport Consultative Committees (ACC)

The Assembly welcomes the Government’s commitment to see ACCs play a more effective role; they provide a useful forum within which to seek input from a wide range of stakeholders. Our response on the noise impacts of aviation highlights the growing inter-relationships between Heathrow and London City Airports, such as the overlapping of ﬂight paths, and differences in approaches to mitigation and compensation.

We consider that there would be merit in enhancing arrangements for inter-airport liaison in recognition of this growing relationship. Both airports have Consultative Committees which provide opportunities for monitoring issues and exchanging views between interested parties, including local authorities, stakeholders and the airport operator. Government guidelines strongly encourage interaction between Airport Consultative Committees where appropriate. Periodic joint meetings of the Heathrow and London City Airport Consultative Committees could be trialled, on an annual or bi-annual basis.

The role of the Civil Aviation Authority (CAA)

The Environment Committee’s review of the environmental conditions attached to expansion at Heathrow highlighted the complexity of the governance structure for managing them. Accountability effectively spans three Government departments, (the Department for Transport, Department for Environment, Food and Rural Affairs and the Department of Energy and Climate Change), two regulatory bodies, (the Environment Agency and CAA), and the Committee on Climate Change.

The complex governance structure has not helped in facilitating transparency and improved communication with local communities. Our report, Flights of Fancy, called for a simpliﬁcation of the governance structure to allow for a single reference point.

We welcome the conclusion of the Pilling Review that the CAA should have a general statutory duty in relation to the environment and that this should be executed within a clear policy framework set by the Government.217 In our response to the Government consultation on its proposals to update the Regulatory Framework for aviation, we noted that the Government’s review could be an appropriate juncture at which to consider whether a more stringent environmental objective to prioritise environmental considerations in exercising the regulatory function is needed, and whether the CAA is best placed to deliver on the objective. We believe that the UK’s specialist aviation regulator should keep environmental considerations at the forefront of its agenda. We were pleased to hear that the CAA is interpreting its duty in this context.218

In our report, Flights of Fancy, we noted stakeholder concerns about the lack of independent scrutiny of the noise action plans that are drawn up in the UK.219 The airport operator, for example in Heathrow’s case BAA, is responsible for setting targets and actions for managing and abating noise nuisance, and for recording outcomes and monitoring progress. We understand that elsewhere in Europe the approach is to appoint an independent third party to draw up the plans. We would wish to see further research carried out on this point, and believe that the Government should examine and draw lessons from how noise action plans are drawn up by other Member States.

Earlier in our response we referred to the growing need for a strategic approach to noise mapping in London. In our view the CAA in conjunction with the Department for Transport would be best placed to deliver this.

There is also merit in the suggestion that an independent body administer the airport mitigation and compensation schemes. This could help rebuild the trust that has been lost by local communities in how airport operators seek to manage, mitigate and compensate for the negative environmental impacts that can arise from airport operations. We were pleased to hear that those within the aviation industry see a potential role for 217 Sir Joseph Pilling, Report of the Strategic Review of the CAA, 2008 218 Page 2, Health and Environment Committee transcript, dated 16 October 2012 219 Page 18, Flights of Fancy can an expanded Heathrow meet its environmental targets 220 Page 31, Health and Environment Committee transcript 16 October 2012 cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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enhanced independent regulation and are open to looking at it as part of tackling the “trust deﬁcit” that exists between airport operators and local communities.221 31 October 2012

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 London. 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, airport 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 airports 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 M1 motorway 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, eg to Leeds or Manchester, onto the railways. It would facilitate the displacement of lower yield flights to less busy airports like Luton, Stansted and Southampton, yet enable them to be connected to Gatwick and Heathrow. It would also facilitate greater use of the existing available runway 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 West Byfleet. — 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 London transport 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 221 Page 31, Health and Environment Committee transcript 16 October 2012 cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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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, Heathwick 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, eg 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 Crossrail 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 Luton airport. 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 Bristol and Cardiff at Iver; West Coast trains to Birmingham at Kings Langley; South West trains to Southampton and the south west at West Byfleet; Southern trains to the south coast at Merstham; and South Eastern trains to Kent 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 cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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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 four 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 Thames estuary 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 London Underground 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 London City airport, 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 (eg 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%. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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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 guideway 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 Surrey 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 cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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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-airport rail link, 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 £7.2 billion 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 cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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APPENDIX 1 LARTS RAPIDRAIL TRAINS ON THE DUAL TRACK GUIDEWAY ALONG THE M25 RAPIDRAIL—CONNECTIONS MADE AFTER FIRST STAGES

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APPENDIX 2 RAPIDRAIL—TOTAL JOURNEY TIME COMPARISONS

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APPENDIX 3 RAPIDRAIL—FIRST CONSTRUCTION PHASES

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APPENDIX 4 RAPIDRAIL—COMPLETED PLAN FOR M25 ORBITAL LIGHT TRANSIT

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APPENDIX 6 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

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 East of England, 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 cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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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 cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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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 Manston Airport 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 31 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 19 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 13 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. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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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 South East England 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 London Southend Airport.

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 cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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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. — 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 Essex 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 cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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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 Isle of Grain in North Kent has been catapulted to prominence by the Mayor of London, Boris Johnson, 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 bird strike 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 Foster and Partners 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 6 million 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 cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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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 £20 billion for the proposed Foster & Partners’ multi-runway Thames Hub airport on the Isle of Grain and an additional £30 billion for the required infrastructure have been put forward. These figures have been questioned, particularly in light of the projected £9 billon cost for only one new runway at Heathrow Airport. The recent research study by Parsons Brinckerhoff summarises:— — costs ranging between £40 billion and £70 billion for a Thames estuary airport, associated infrastructure and the building of a “multitude of new railways lines” connecting the airport to London, but warns that “even the £70 billion 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 £4.7 billion, ultimately costing £9.5 billion 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 £20 billion cost, adding 3% construction cost inflation for that period would result in £600 million annually increasing the cost of the airport to £26 billion even before construction has started. In March 2010, a survey carried out on behalf of Medway Council stated that 90% 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 £12.5 billion 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. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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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–£40 billion 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 £120 million 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 Thames Gateway 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 cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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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 “London Britannia Airport”, 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 £3 million 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 Lydd Airport 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 cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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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 made222 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 the existing external guidance is inadequate being a 1988 Hansard entry223. 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 222 http://www.hse.gov.uk/nuclear/fukushima/ﬁnal-report.pdf—page 145 & 146 223 Hansard, HC 11 March 1988 Vol 129, cc357–358 (Written Answers)—“I am advised by the HSEs 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.” cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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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. 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 2012224) 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): Nuclear Accident: As set out in ONR;s response to the NPPF consultation, one of the key weaknesses identified as a result of the Boundary Hall Public Inquiry, is that ONR;s lack of status as a statutory consultee had an aimpact on the weight of consideration given to its advice on the need to control populations around nuclear installations. As DECC is the co-ordinating Department for the Government’s response to Mike Weightman’s reports, and it is DECC’s policy that populations around nuclear installations need to be controlled, it is vital that they also attend the meeting referred to in the e-mail chain below. 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 224 http://www.hse.gov.uk/nuclear/fukushima/implementation-report-oct-2012.pdf cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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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 safeguarding.225 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”.226 19 January 2013

APPENDIX 1 The ONR’s submission to the draft NPPF consultation*.227

APPENDIX 2 Email dated 16 May 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, 21 May 2012 from DCLG outlining the relevant paragraphs in the NPPF*.228231

APPENDIX 3 Email dated 22 February 2012 from HSE outlining HSE/ONR concerns and DECC’s status in relation to demographic controls*.231

APPENDIX 4 Airport Capacity—Lydd and Manston airports—see below: Lydd Airport Manston Airport Percentage of Per centage % of White White Paper Existing Paper % of Current Pottential Terminal Potential Terminal Year Passengers Capacity of Capacity of Passengers Capacity of 6 Capacity of 1 (end Dec) (number) 125,000 ppa 300,000 ppa (number) mppa million ppa 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% 5,574 0.1% 0.6% 2010 485 0.4% 0.2% 25,813 0.4% 2.6% 2011 496 0.4% 0.2% 48,450 0.8% 4.8% 2012 (e) 400 0.3% 0.1% 8,304 0.1% 0.8%

225 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. 226 CAP 772, Birdstrike Risk Management for Aerodromes (September 1 2008), Chapter 4, page 15, paragraph 4.4 last sentence 227 *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/ 228 Oxford Economics: The Role of Business Aviation in the European Economy (October 2012) cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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2012 estimated on the basis of 10 months actual data. 2004 and 2005 volumes based on unsustainable fares pre EU jet’s/Plane Station’s bankruptcy. Source: CAA Statistics: terminal and transit passengers.

Written evidence from The Air League (AS 121) Introduction The Air League was founded in 1909 and is one of the principal UK aviation organisations. It was instrumental in the formation of the Air Cadet organisation and The Air League’s President, Ofﬁcers and Council members are elected by reason of their experience and proven contribution to the ﬁeld of aviation, as is their Director. The Air League has produced a number of papers and organised lectures and seminars on key issues facing UK Aviation over many years, most recently on “London Airport Capacity”.

The Aviation Industry The UK air transport industry contributes over £50 billion to GDP and £8 billion to the Exchequer. It facilitates vital international connectivity to encourage exports and attract investment into the UK. It carries two-thirds of the tourists who visit the UK. It handles some 220 million passengers a year, thereby supporting 1 million jobs directly. It operates without Government subsidy whilst paying its full Carbon Cost. The UK air transport industry meets all its own capital and debt service costs for the development of airports and the acquisition of aircraft, unlike the rail network which received a £3.9 billion subsidy in 2011–12.

The Key Challenges The Aviation Strategy faces ﬁve key challenges: 1. Lack of runway capacity in the South East, particularly at the Heathrow hub. 2. Level of Air Passenger Duty. 3. Lack of comprehensive air links from the UK regions to the Heathrow hub. 4. Lack of clarity and logical thinking on environmental emissions. 5. Lack of strategic understanding of the importance of aviation to young people and the community.

Lack of Runway Capacity London is served by six airports but Heathrow is by far and away the most important as the national hub. Heathrow is the UK’s No 1 port by value but it is already running at 99% of capacity. London Gatwick is running at some 95% of its single runway capacity, already the most heavily used single runway in the world. The capacity situation is such that Heathrow now offers some166 destinations compared with 244 at Paris Charles de Gaulle, 264 at Frankfurt and 252 at Amsterdam Schiphol. Paris Charles de Gaulle now has four runways, Frankfurt has three and Schiphol has five. Even Munich, Germany’s second hub, has announced the construction of a third runway. China is planning 70 new airports by 2015 and annual growth for Beijing airport is projected at 13%, together with 19% for Djakarta, 15% for Dubai and 11% for Hong Kong. We need those entrepreneurs and travellers to come to the UK but the Heathrow hub has a projected decline in annual growth. London drives the UK economy especially during the economic downturn—it is an hour closer to the US. The richer that emerging countries get, the more important this will become. Overstretch at the UK hub also impacts on UK regions. A Far Eastern entrepreneur doing business in Europe measures travel time from his home to the hotel door. Since the air link from Plymouth to London was removed, it now takes longer to get from London to Plymouth than Concorde took to fly from New York. Over 70% of British Airways flights are short haul and BA brings 2.5 million passengers down to London every year, half of whom transfer to a long haul flight. They do not want to land at one London airport, collect bags, catch a train and check in at another. Five years ago there were 124 flights a week from Edinburgh to Heathrow, 115 from Glasgow and 54 from Belfast—now there are 109, 60 and 42. Amsterdam Schiphol Airport has 22 links to UK regional airports and KLM advertises itself as Scotland’s favourite airline. Heathrow by comparison has six links to UK regional airports. The UK regions are increasingly disconnected from their capital through the lack of seamless, interconnecting flights. Rail investment alone does not provide a solution.

UK Air Passenger Duty (APD) APD was originally introduced in lieu of tax on aviation fuel to offset its environmental impact. It has also proved a useful source of revenue to the Exchequer. This indirect tax had risen by 225% on some routes in just seven years and UK APD is now the highest air passenger tax anywhere in the world. It is almost 4 times the rate of France for UK domestic and European services. For long haul travel, the comparisons are much worse with UK rates being almost £90 more than the cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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rate charged in Eire. It can be cheaper to travel from Belfast to embark at Dublin Airport rather than ﬂy out of Belfast’s airports. Consequently, not only does the rate of APD serve to reduce the rate of growth of air travel (plus associated income, economic activity and jobs) but also it encourages UK long-haul travellers to change their itinerary. For UK passengers ﬂying onwards from Amsterdam (where APD has been removed), they can save up to £80 on the long haul APD; for a family of four, that would be a saving of £320. The high level of APD is damaging the UK’s international competitiveness.

UK Regional Links Continued growth of traffic at Heathrow and Gatwick has only been achieved at the expense of links to the UK regions, with service to 17 points being lost to Heathrow in the last 20 years. The closure of Plymouth Airport can be directly attributed to the lack of slots at both Heathrow and Gatwick. The residents of Inverness, Liverpool, Humberside, Teesside, Newquay or the Isle of Man lack direct access to the UK’s only viable hub, London Heathrow. The Government has consistently refused the regions’ air services protection via Public Service Obligations (PSO), which are used very successfully to protect air services in France and other European countries. This has led to the sale of slots by some regional and short haul airlines to intercontinental operators with larger aircraft that benefit from the economy of scale. Yet these self-same intercontinental airlines need the feed from a wide range of domestic routes to fill their aircraft and maintain frequency and connectivity.

Aviation and the Environment Technological advances have drastically reduced aviation noise and pollution to levels hardly imaginable a few years ago. Aviation is responsible for less than 3% of world CO2 emissions, below that for shipping (for which no equivalent of APD is charged on cruise or ferry passengers) and significantly less than from commerce, roads or domestic sources. Furthermore, its noise impact has reduced by 70% over the last 30 years. The aviation industry has a programme in hand to ensure that by 2050 it will not be generating any more CO2 than it did in 2005. Changes in engine and aircraft technology, improved operating procedures, greater and better use of satellite navigation systems, improved Air Traffic Management, descent profiles and track-keeping will continue to improve and minimise the environmental impacts from aviation, yet Government avoids defining acceptable noise and CO2 levels that are necessary to sustain the future prosperity of the UK and the status of UK as a world aviation leader. Assumptions made as recently as 2010 concerning aircraft noise and associated environmental impact around Heathrow are already out of date. For instance, the Boeing 787 noise footprint is 60% smaller than the aircraft it will replace and the noise footprint now stays well within the airport boundary.

Importance of Aviation and Education to Young People and the Community Aviation is one of the UK’s greatest success stories. It provides more skilled jobs and contribution to the country’s GDP than any other apart from the pharmaceutical industry. The future of aviation in the UK depends on stimulating and encouraging the brightest of the next generation to get involved. The Government is to be congratulated on developing apprenticeships but the background mood music is still that aviation is a rich person’s pastime. This must be corrected. Some 205,000 people depend on Heathrow for their livelihood. Around 20,000 pilots belong to the General Aviation community while 44,000 youngsters join the Air Cadets to fly. Yet there is no national strategy as to which airfields should remain and which should be allowed to disappear. Plymouth and Filton have closed in the last two years with others threatened by housing development and excessive, sometimes inconsistent, regulation. Moreover, UK professional flight training is subject to VAT which, when coupled with the high costs of aviation generally and the heavy tax on fuel used by the majority of training aircraft, will only further drive delivery of the training off-shore, with the loss of opportunity, skills, employment and standards oversight that goes with it.

Conclusion Government policy and action should encourage all concerned to think in terms of “where does aviation fit in the overall transport strategy and its role in the national economy”. Given the piecemeal approach to national aviation issues ranging from APD through environment and education to runway provision, the Air League believes that the Government’s aviation strategy should be much more integrated and focused than it is at present. Aviation contributes significantly to the economic and social well being of the UK. With the right forward looking policy, that contribution could be significantly improved. The UK has led the world in air transport service, innovation, technical excellence and standards. But that is not the natural order of things. In 2001, Dubai was the 99th airport in the world while Heathrow was first: next year, Dubai will overtake Heathrow. Without Government recognition and pro-active policies to sustain the existence and development of UK aviation, this standing will be prejudiced further. Once the UK’s position as a global aviation leader is lost, it will be next to impossible to recover. 5 February 2013 cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Written evidence submitted by British Airways, easyJet, Ryanair and Virgin Atlantic (AS 122) Background Last year, British Airways, easyJet, Ryanair and Virgin Atlantic commissioned PricewaterhouseCoopers (PwC) to provide an evidence-based economic assessment of the role of Air Passenger Duty (APD) in the UK economy. Although the airlines commissioned and financed the work, the final report represents the independent analysis of PwC. The report was published on Monday 4 February 2013. Conscious that the Committee is examining the impact of APD on the aviation industry as part of its Aviation Strategy inquiry, and that this report is a significant new contribution to the evidence-base, we provide this additional short submission presenting the main findings of the research.229 PwC carried out their assessment within the framework laid out by the Treasury Select Committee in its 2010 review of the fundamental principles of tax policy making. Underpinning the research was a dynamic economic model known formally as a Computable General Equilibrium (CGE) model. The model simulates how changes in one part of the economy affect the rest of the economy. This approach to modelling the impact of tax changes is very similar to that used by HM Treasury and is also widely used by national governments and organisations such as the IMF and World Bank. The analysis is more sophisticated than previous APD studies that have used “static” approaches less able to account for these economic ripple effects. The Chancellor has suggested that consideration should be given to whether tax policy in the UK should be appraised using a dynamic method.230

Key Findings In considering the nature of APD and its context within the UK economy, the report finds: — APD is the highest tax of its type in the world by some considerable margin; — APD is a regressive tax and impacts disproportionately on poorer households; — APD is a highly distortive tax that is at least as damaging to the economy—and probably more so on a pound for pound basis—than corporation tax, and second only to fuel duty among major UK taxes; and — UK businesses in aggregate pay around £500 million in APD each year. The main analysis in the report relates to the impact on the economy and Government tax revenues if APD were to be abolished at the 2013 Budget. The modelling suggests that abolishing APD could: — boost UK GDP by 0.45% in the first year, with continuing benefits through to 2020; — increase investment by 6% and exports (including earnings from foreign tourism) by 5% between 2013–15; — lead to the creation of up to 60,000 jobs between now and 2020; and — pay for itself, with increased business growth leading to higher tax receipts from other sources, outweighing the lost APD revenue. February 2013

Written evidence from Testrad (AS 123) 1. Construction Costs and Investment The cost estimates provided within the Testrad Limited LJIA Concept Report (Appendix 1) were indicative and based on the measurement of the key items with contingencies of 50% included. In addition a further 10% was allowed for project management, engineering, planning and the like. With a project of this scale and nature it is not considered appropriate at this preliminary concept stage to provide detailed breakdown of the sums. Inevitably there will be design developments and associated cost changes, both positive and negative, as the project moves through various stages of refinement. The two indicative cost estimates included within the LJIA Concept Report are reproduced below. The difference between the two estimates is driven, primarily, through the cost of a bored tunnel from the Ebbsfleet Origin and Destination terminal to the airport platform as compared to the use of a surface rail system with only an immersed tube tunnel used for the final sub-sea part of the connecting route to the airport platform. The two indicative cost estimates in the version of the Concept Report in the Appendix have been reworked slightly to clarify this comparison. It is clear that any airport development, or expansion of an existing facility, will require additional investment in surface access, which will require funding in the same way as any other road or rail investments. Public sector involvement in such investments will be essential. 229 This summary is provided by the airlines, not PwC. The content represents the views of the airlines, not PwC. The full PwC report is available at http://corporate.easyjet.com/~/media/Files/E/Easyjet-Plc-V2/pdf/content/APD-study-full.pdf. An Abridged Report is available at http://corporate.easyjet.com/~/media/Files/E/Easyjet-Plc-V2/pdf/content/APD-study-Abridged.pdf. 230 http://www.ft.com/cms/s/0/2663afda-7827–11e1-b237–00144feab49a.html. cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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As far as the airport itself is concerned, this will depend on the charges to be levied and how the basic land infrastructure is ﬁnanced. We estimate that private investors would be able to get a return from much of the airport infrastructure, although some public risk capital might well be necessary at the outset Item Scope Cost £m Airport Platform Site formation, 8,000 Airport Platform Infrastructure (runways, concourse, cargo and services), transport 7,000 connections and marine facilities O/D Terminal Main terminal building and transport connections 5,000 Transport Linkages Main running tunnels. Service tunnels, emergency stations, rail and 22,000 services infrastructure and trains Existing infrastructure Upgrading of M25, Crossrail extension other minor rail works and local 3,000 improvements highway access Logistics Centre Creation of the logistic park infrastructure, services and utilities, 4,000 administration facilities, tunnel connection for rail and road transport to the airport platform, including trains and road connections to M20 Total 49,000

Item Scope Cost £m Airport Platform Site formation 8,000 Airport Platform Infrastructure (runways, concourse, cargo and services), transport 6,500 connections and marine facilities O/D Terminal Main terminal building and transport connections 4,500 Transport Linkages Surface running tracks with tunnel connection to the Airport Platform. Rail 9,500 and services infrastructure and trains. Existing infrastructure Upgrading of M25, Crossrail extension other minor rail works and local 3,000 improvements highway access Logistics Centre Creation of the logistic park infrastructure, services and utilities, 4,000 administration facilities, tunnel connection for rail and road transport to the airport platform, including trains and road connections to M20 Total 35,500

As can be seen from the above tables there is no difference at the site formation level, however there is some saving for the airport platform in the second option due to the fact that the immersed tube will be coming in at a significantly shallower depth than the deeper bored tunnel in the first option. Similarly the depth of the bored tunnel at the O/D Terminal results in a saving at this location in second option. By far the most significant cost difference between the two options, £12,500 million, comes through the replacement of the bored tunnels by surface running high speed rail tracks from the O/D Terminal at Ebbsfleet to the airport platform.

2. The Cost of Reclaiming Land The Scheme as presented within the LJIA Concept Report is based on adopting a poldering approach to minimise the volume of sand required for reclamation purposes and as such minimising the potential environmental impact. To enable the poldering to take place it is necessary to introduce a cut-off wall along the perimeter of the airport platform with at least one cut-off wall across the width of the airport platform to allow accelerated construction. The cost of these works is very similar to the saving in the cost of the sand required if poldering was not adopted, however it clearly allows the site to be formed with a reduced level of disruption with associated faster construction programme. As given in the tables above the cost of forming the edge structures with the cut-off walls, cross bunds, ﬁlling to a level of +7 metres for all operationally critical areas (runways, aprons etc), and land drainage is estimated, with contingencies, to be some £8 billion. The total surface area of the airport platform amounts to some 115km2, giving a unit cost per m2 of approximately £70 to form the airport platform.

3. General Engineering Challenges The challenges of constructing the airport platform are by no means unique and are similar to many port- related infrastructure developments. The emphasis has to be placed on creating an initial island through normal dredging techniques which will then allow the creation of a supply base with supporting logistics, initially through marine craft and ultimately through a permanent shore link. In the case of LJIA it is proposed that platform construction should commence at the western extremity with conventional reclamation techniques. In parallel marine accessed construction would be used to create a supply base for construction activities and which will ultimately be incorporated into the permanent works. The construction of the outer perimeter bund and its cut-off wall will be undertaken by marine-based ﬂoating craft. It is envisaged that rock from Scandinavia will be used for the protection of the outer bund in a similar manner to methods employed for many of the East Coast coastal protection schemes. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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4. Specific Engineering Challenges A specific challenge is how to make available areas of the final platform formation for the safe construction of airport infrastructure, including runways and ancillary works, without waiting for the whole proposed platform area of 115km2 to be complete. It is proposed that a cross-wall will be constructed across the full width of the platform releasing the western half of the completed reclamation area for infrastructure development. Reclamation of the eastern half of the platform will continue in parallel to the construction of infrastructure on the western half. As noted above, it is proposed to introduce a poldering approach with the edge structure backed by a perimeter road and the runways at a reclaim level of +7m. We estimate that the edge structure will require a top level some 2m higher than runway and operational levels to further safeguard the airport from risk of overtopping allowing for climate change effects. Similarly we anticipate a significant piled cut-off wall to a depth of around -30m to ensure piping, erosion of soil through passage of water, does not undermine the edge structure. These design features have been included in our costs estimates. In non-operationally critical areas the area of sea bed inside the bunded edge structure will be capped by a blanket layer and retained at approximately—2m. Equally it is envisaged that all buildings will be piled with their founding slab also set at—2m. As noted within the Concept Report the lower basement levels of the buildings will be used for non-critical operational activities. A key aspect within the design development will be to ensure that the perimeter bund cannot be breached by a planned or accidental aeroplane impact, or indeed by a ship ramming the structure. The proposed perimeter arrangement with the edge structure backed by roads and runways to give a minimum depth of the order of 400m will ensure the integrity of the structure from such incidents. Equally the relatively shallow depths surrounding the airport platform, even allowing for tidal variations, will effectively limit the size of vessel reaching the structure.

5. Flooding, Storm Surge Implications and Costs The outer Thames Estuary is subject to tidal flows driven by the interaction of tides from the North Sea and English Channel. Flows in the northern part of the Thames Estuary are broadly aligned north east—south west whilst those in the south are orientated east-west. Sand banks have, over time, formed and aligned themselves as a result of these tidal flows. Swell waves generated by storms in the North Sea are generally dissipated by interaction with the banks such that waves in the outer Thames Estuary, inshore of the banks, are mostly associated with local wind conditions. When high water levels are elevated by storm surge wave conditions can become more severe as depths of water over the banks allow propagation of waves over greater distances. On a mean spring tide high water levels of + 5.4m CD occur at the platform site. The Highest Astronomical tide at the site is +5.7m CD and extreme storm affected water levels for a 50 year return period is +6.9m CD. Tidal flows are orientated east-west across the site and peak currents of about 2.5 knots occur during spring tides. Under extreme conditions, when winds may affect the flows, peak currents of up to 3 knots may occur. The prevailing and strongest winds at the site are from westerly and south westerly directions. However, as the platform is sheltered from this direction, the largest waves approach from the north north east to north east sector with a significant height (Hs) of about 2.5m for the 50 year return period condition. Wave conditions around the platform may be influenced by changes in exposure to different directions and the bund design will take this into account as well as any influence from long term trends and climate change on extreme water levels, winds and waves. The platform is not expected to significantly influence tide or surge propagation upstream into the Thames Estuary because at this location in the estuary the change in estuary cross section caused by the platform will be small. A platform further upstream could have a greater impact. In developing the concept consideration has already been given to the need for planning and design of the edge structure to resist storm surges and the sea level rises described, and indeed tectonic changes. The current cost estimate is based on providinga1in1000 year level of protection. Further detailed joint probability analysis supported by in-situ wave and tide measurements will be undertaken as part of the design process. The cost of protecting against these events is already included within the estimate as they form an integral part of the structure itself. Equally further detailed design will build resilience into the structure to allow it to be extended to provide increased protection levels as and if considered necessary.

6. Implications of Coastal Erosion Any potential development on the estuary bed will have some impact. The areas to pay attention to are the sand banks and navigation channels to the north of the platform which could be influenced by changes to flows and sediment transport that occur during the construction and operational phases. On the positive side the platform will influence wave conditions providing shelter in its lee on the inshore. The platform edge structure could also induce reflection from the platform potentially increasing wave conditions at some locations in proximity to the platform. Changes to waves and currents and availability of mobile sediment may have an influence on sedimentation in navigation channels and the dynamic stability of cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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the sandbanks in this area, as well as the potential to change the coastal morphology with a resulting impact on associated habitat, fishery and recreational use of these waters. However, the airport platform and its orientation (as well as suiting the runway configuration) has been planned and designed to minimise the impacts on tidal flows within the area. In essence it utilises the existing sandbank configuration and its existing deep-water channel alignments. Our preliminary numerical modelling has shown that there will be localised adjustments to the sea bed immediately outside the boundary of the airport platform as the tidal flows around the structure diverge. Equally some areas of siltation can be expected as the flows around the airport platform converge and flow velocities diminish. It should be noted that part of the land platform area already dries at low tide and thus the airport development becomes an extension of the drying area. The potential for erosion and longshore sediment transport in the coastal area may be mitigated by increased tidal velocities between the airport platform and the North Kent shoreline due to the constriction of the water area, and the reduction in the wave climate. Further investigation of this will be undertaken as part of the scheme development. Temporary works during construction of the platform and transport links to the platform will be subject to sedimentation during the works and this will need to be managed. Likewise dredging and placement of material into the platform will give rise to the release of some fine material into the outer Thames Estuary, and these fines may give rise to changes in suspended sediment concentrations and sedimentation. Emphasis will be placed on a construction strategy for works activities to be carried out in such a way to minimise the release of fine material and thereby local impacts.

7. Impact on Shipping Channels The airport platform has also been planned to have little or no impact on the existing shipping channels. The preliminary modelling undertaken predicts minimal wave or sediment implications both during and after construction. This will need more detailed analysis as the design is progressed. In addition the platform has been positioned to ensure that there are no airdraft restrictions imposed at the edge of any existing shipping channel. For these purposes an airdraft requirement of 80m has been taken which corresponds to the largest possible cruise ship. The largest container ships using ports have a lesser airdraft of 75m.

8. Platform to Mainland Linkages The proposed airport platform will have a number of linkages with the shore. For passengers using the airport platform the main means of access will be either via trains running in the deep bored tunnel or through a shallow immersed tube tunnel for the surface running trains. It is also proposed that an immersed tube should be laid between the proposed logistics and cargo park on the Whitstable shoreline and the airport platform. This would be used for worker access to and from the airport, cargo transfer and maintenance operations. It is proposed that this will be a two-lane dual carriageway with a local train service running between the logistics park and the airport platform. In addition the former construction harbour will be used to allow marine access for waste transfer and the movement of loads which cannot be accommodated by the tunnel. Fuel supplies will be either piped in or barged in depending on the degree of ﬂexibility required for supply. At the eastern side of the airport platform a cruise terminal will also be provided.

9. Settlement Requirements The planning and design of the settlement criteria will be an important element in ﬁnalising the costs and programme for the works. Various techniques are available to accelerate the natural consolidation progress ranging from surcharging with wick drains to vibro-compaction techniques. The selected techniques will have to be considered in relation to the phased release of land for further development. The cost of ground improvements has been included in the cost estimates. February 2012

Written evidence from London Ashford Airport Ltd (lydd airport) (AS 124) Thank you for the opportunity to submit written evidence to the Committee on the proposed Aviation Strategy. This letter is submitted on behalf of our client, London Ashford Airport Limited (LAA).

Summary LAA plays a valuable role in meeting local demand for air travel. There are current plans to expand it to accommodate up to 500,000 passengers per annum, helping to meet the demand for capacity in the South East. The Airport’s expansion will create 200 new jobs, promote inward investment, bring beneﬁts to local companies and boost regional economic growth. In short, LAA supports the draft Framework’s approach of making better use of existing airports, including small airports such as LAA. cobber Pack: U PL: CWE1 [E] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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Background LAA is an existing operational airport located at Lydd, Kent. The Airport has been operating since the 1950s. It is an important source of employment. It currently handles approximately 22,000 aircraft movements a year and acts primarily as a base for general and business aviation, including air taxi and business aviation operations, aircraft maintenance and a flying school. LAA is currently awaiting the outcome of a call-in Inquiry into two planning applications. The first (PINs ref: APP/L2250/V/10/2131934) proposes to extend the existing runway. The second (PINs ref: APP/L2250/V/ 10/2131936) proposes the construction of a new terminal building capable of processing up to 500,000 passengers per annum. The applications where “called–in” by the Secretary of State (SoS) for determination following the Shepway Council resolving to grant planning permission for both applications in March 2010. Although LAA is located near to a number of environmentally sensitive sites, including a SPA, a Ramsar site and a SSSI, it has been shown that its expansion would not have any significant environmental impacts. In addition, the two Dungeness Power Stations are in close proximity, but, the ONR has not objected to the applications, and an exclusion zone will continue to operate around the power stations. Both Power Stations will be either fully defueled and/or decommissioned by the time that the expanded Airport would be fully operational. The applications will enable the Airport to make a contribution and help deliver the Government’s objectives of achieving long term economic growth through the efficient use of an existing operating airport by: — Allowing larger commercial passenger and private business type aircraft to fly with a full payload of passengers from the Airport. — Extending the range of aircraft can fly from the Airport. — Maximising the availability of routes and aircraft choice to operators. — Improving the efficiency of aircraft runway operations in adverse weather (the longer runway will give pilots more flexibility to optimise aircraft performance for certain conditions eg in a crosswind or on a wet runway). — Providing a useful diversion airport, thus contributing to operational efficiency gains in the South-East. The planned expansion at LAA, although relatively small in the context of the overall airport capacity debate, would accommodate up to 500,000 passengers per annum. Given increasing capacity constraints at the main London airports, particularly Gatwick and Heathrow, LAA will help relieve this pressure by catering for short-haul and UK domestic flights.

How should we make best use of existing aviation capacity? LAA supports the Government’s intention to make the best use of existing airport capacity, as a general principle. The Government should make the best use of existing capacity by supporting and recognising the role that small airports can play in meeting future needs. There are many small airports, such as LAA, that can be better utilised to help meet the demand to for general passenger travel as well as increased commercial travel. This will help relieve the pressure of other larger airports in the South East. The strategy must make explicit reference to the role that small airports can make in meeting demand.

What constraints are there on increasing UK aviation capacity? Securing the objective of long term economic growth through the aviation sector will require infrastructure development. The primary constraint on delivering the infrastructure is the planning system. The planning process can be abused by objectors and activists who manipulate it to cause delays and unnecessary costs. For example, the planning applications relating to LAA’s modest expansion plans were the subject of a nine month long public inquiry which closed in September 2011. The applications were submitted in 2006 and received a resolution to grant by Shepway Council in 2010. The delay in the decision making process from September to now is due largely to delays caused by the actions of two malicious objectors exploiting the decision making system to their own ends. The Strategy should confirm the in principle support for improving infrastructure at existing airports. The Strategy should also set out a presumption in favour of infrastructure improvements at existing airports unless there are other over-riding considerations (such as environmental constraints). This will give investors some reassurance that their proposals will be supported. It should speed up the planning process and the overall delivery of the necessary infrastructure. In addition, the Strategy should incorporate flexibility that will allow smaller airports, such as LAA, to agree locally negotiated operational restrictions, based on local circumstances and the operator requirements. For example, despite there being no requirement for noise mitigation, LAA is offering an extensive range of options to address the concerns of objectors, including using a noise preferential flight paths, banning night cobber Pack: U PL: CWE1 [O] Processed: [24-05-2013 13:10] Job: 028863 Unit: PG01

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ﬂights (which is currently unrestricted), and introducing a Noise Management Plan. The Airport has also gone further than other larger airports by agreeing to a bespoke noise insulation scheme. These measures have been agreed locally and will help to reassure the local community without compromising the viability of the Airport.

Conclusion LAA supports the draft Framework’s approach of making better use of existing UK airports. LAA is an existing airport which could help relieve the pressure on other airports in the South East without harming the environment. We trust that the above comments will be taken into consideration by the Committee. February 2013

Written evidence from Mr S H Ashurst (AS 125) RAF Northolt Opening up the RAF airport for short-haul civilian flights has been suggested as a short-term solution while a third runway at Heathrow is being built. Currently the RAF’s main base in London, it is already used for a small number of private business flights. It used to be the key London base for British European Airways (Pre BA merger), handling as many as 50,000 take-offs and landings in 1957. Pros: Located only a few miles north of Heathrow, so in a better position to serve people transferring flights than Gatwick. There is already a runway and lots of spare capacity. The RAF would have use of longer runways. Cons: The government says it needs a military airfield inside the M25, so it would be difficult to add thousands of annual civilian flights. It would add more traffic to already busy skies in the area. PROPOSAL—Inspection of the satellite picture shows that the area of undeveloped land to the south of the A40 is greater than the total area of Northolt airfield. Approx.3000yds x 1000yds. With the runway layout shown there would be no need for any housing to be demolished. The 8000ft southern runway and 6200ft northern runway could be positioned so as best to avoid housing on the approach and departure paths. The Terminal Building could be positioned differently. It is shown close to the A4180 as that is the end the light railway would enter. To keep the Terminal Building as simple as possible (No Customs or Passport Control) the airport could be restricted to Internal UK flights only. An elevated light railway connecting the terminals at Heathrow and the Northolt Satellite could follow the A312 Parkway between Cranford and the Ruislip Road roundabout, thence to any new Northolt Terminal. March 2013

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