Memorandum by the Heathrow Airport Consultative
Committee (IT 104)
A NEW DEAL FOR TRANSPORT: BETTER FOR EVERYONE
1. THE COMMITTEE'S
1.1 The Heathrow Airport Consultative Committee
(HACC) welcomes the opportunity to submit its views regarding
the Government's proposals for integrated transport to the Inquiry.
1.2 The HACC is a committee established in compliance
with the provisions of Section 35 of the Civil Aviation Act 1982,
as amended by the Airports Act 1986.
1.3 The Committee contains representatives from
local governments, environmental groups, chambers of commerce
and other business interests, the travel trade, airlines, consumer
interests, air transport users, the tourism industry and trade
unions. It therefore speaks on behalf of a wide range of international,
national, regional and Greater London interests.
1.4 The HACC is the main forum for consultation
by the Department of the Environment, Transport and the Regions
and by the Civil Aviation Authority regarding matters affecting
users and airport impacted communities arising from the operation
of Heathrow Airport.
1.5 Heathrow Airport is a major contributor
to the economy of the United Kingdom but in achieving this eminence,
it exercises a substantial influence on land use, transport, environment,
regional development and also the economy of both Greater London
and its hinterland.
1.6 Whilst it might be thought that the main
interests of the HACC would be concerned primarily with air transport,
policies on integrated transport will impact upon many of the
matters which are the concern of the Committee given the multi-modal
nature of the transport services upon which Heathrow Airport depends
for its efficient operation and very existence.
2. THE WHITE
Our comments are written in the order in which
the various policies appear in the White Paper.
2.1 Sustainable air freightthe
growth in air freight, and Heathrow Airport is the premier handler
in the UK, gives rise to increased pressures on land use, both
on and off airport, traffic and highway congestion. Most air freight
is now carried in the belly holds of passenger aircraft and thus,
this growth does not result in increased aircraft movements nor
does it justify the creation of airports dedicated to carriage
of air freight.
2.1.1 There are no recent studies of the economic
importance of this trade to the United Kingdom and the Committee
welcomes Government's intention to commission new research into
this activity. We see a viable future for the introduction of
air/rail freight services and recommend that the research should
cover this dimension.
2.2 Integrated airportsthe white
paper is a disappointment insofar as its relevance to national
air transport matters is concerned; very little attention has
been paid to anything but peripheral matters. The last statement
of Government policy was published in 1985 (Cmnd 9542) and that
has been largely irrelevant for some years now given the considerable
changes which have taken place in the air transport industry since
that time. However, we are pleased to see that the policy will
concentrate, inter alia, or integration with surface transport
as it is absolutely vital that new major rail and road links with
airports should be developed.
2.2.1 Government has said that it will take
account of the conclusions of the Inspector's report of the Inquiry
into the proposed Terminal 5 at Heathrow Airport, which it does
not expect to receive before year 2000, in preparing an airports
policy. In view of this, it is probable that such a policy will
not be published until 2001 and, following from that, the probability
that any resultant legislation will have to compete for a place
in the next Parliament's timetable.
2.2.2 Although some members of the Consultative
Committee do not believe in the concept of "Predict and Provide",
it is recognised that successive Governments have failed to grasp
the nettle of providing timely and sufficient airport capacity
in acceptable locations to serve South East England or to recognise
that the consequences of not doing this may lead to a situation
where air travel has to be capped because of a lack of capacity.
2.2.3 The consequences of such a situation would
(a) increasing congestion occurring in the
air and on the ground;
(b) the consequent impact on the environment;
(c) the harm to the national interest if
this lack of timely planning loses the London airports their premier
position in Europe; and
(d) giving an advantage to airports whose
Governments are already implementing long term plans to take that
leadprincipally Paris, Amsterdam and Frankfurt.
2.2.4 The White Paper offers nothing to address
these concerns, promises little to alleviate the situation and,
when an air transport/airports policy does finally appear, it
is likely to be too late to remedy some of the important problems
currently facing the industry and those affected by its operations.
2.2.5 It should be recognised that for some
20 million people living in South East England, the London airports
have a role as their regional airports in addition to that of
being international gateways to the United Kingdom.
2.2.6 Whilst the policy of encouraging the growth
of international air services at regional airports is supported
as a contribution to easing pressure at the London airports, too
much must not be expected from this as the great majority of air
passengers at those airports have their origins/destinations in
South East England and the evidence of this is set out in the
statistics provided in the Appendix to this memorandum.
2.2.7 Recent experience has shown that some
of the long haul international routes instituted at regional airports
have not proved to be economically viable and that they have,
as a result, been withdrawn at least temporarily, by the airline
2.2.8 The recognition of the need for long term
planning for airports is welcomes but 30 years is a long time
in so volatile and dynamic industry which has a growth rate seldom
matched elsewhere; examples of this are provided in the Appendix
to this memorandum. Any policy will need to be extremely flexible
to accommodate changing circumstances.
2.2.9 We recommend that any national air transport/airports
policy should be subject to review at intervals of not more than
2.3 Trans-European Networkswe
welcome Government's intention to work with the European Commission
on the development of these networks but note that consideration
is, apparently, being limited to railways with no mention being
made of the Airport TENS. The Airport TENS includes a number of
continental airports which the Commission is giving financial
assistance to and some of which are competing with those of the
UK. This must not be lost sight of in Government's preparation
of an airports policy with pressure to ensure that UK airports
receive equal treatment.
2.3.1 The HACC welcomes the references to the
Channel Tunnel Rail Link (paragraph 3.214) which is expected to
deliver a new international and domestic multi-modal transport
interchange centred on Heathrow Airport, providing an international
gateway for rail services across the UK.
2.3.2 However, the development of Heathrow Airport
has put considerable pressure already upon land use, ground transportation,
labour resources and the environment in the airport's hinterland
and the Committee will be concerned to learn more of the proposal
and its implications for those people and organisations it represents
before endorsing the plan wholeheartedly.
2.4 Air Safetythe Committee has
recently considered the questions of air safety and public safety
zones involving aircraft using Heathrow Airport following recent
Press reports of the ATC system being overloaded and of a number
of claims of air misses. Its concern derives from the fact that
the majority of aircraft accidents occur during landing or take-off
at airport and this is exacerbated by the fact that 70 per cent
of landings at Heathrow take place over the heavily populated
areas of Greater London.
2.4.1 The Committee is pleased to note Government's
intention to separate air safety regulation from service provision
and, particularly, of the intention to review the arrangements
for public transport safety although we would wish to know more
of the details of the public-private partnership proposed for
NATS before endorsing such a scheme.
2.5 Aviation and Airport Regulationthe
proposals to regulate airports by bringing them into line with
other utilities, to extend to the Civil Aviation Authority a duty
to protect the interests of consumers and the creation of a duty
on regulators to have specific regard to Ministerial guidance
on environmental objectives could have implications for the consultative
committees which exist at many UK airports and airfields as a
result of their statutory designation by the Secretary of State
under the provisions of section 35 of the Civil Aviation Act 1982.
2.5.1 The Civil Aviation Authority has, of course,
already got its own consumer interest organisation in the Air
Transport Users Council (AUC).
2.5.2 Successive Secretaries of State, Ministers
of Aviation, airport operators, local governments, consumer and
environmental organisations have all endorsed the concept and
value to them of airport consultative committees as a means of
looking after the interests of the providers and consumers of
air transport as well as those affected by the operation of the
industry. The Heathrow Committee as the first such organisation
in the UK, is celebrating its 50th year of service to the community
2.5.3 The position of consultative committees
should not be overlooked in the reforms being proposed. We would
urge that any airport regulator should deal only with issues of
national importance with the local Airport Consultative Committee
overseeing all matters concerning the development or operation
of the airport which have an impact on its users and on the people
living and working in areas affected by the airport, i.e., on
the issues which are matters of local concern requiring local
2.6 Air Transport and the Environmentaircraft
engine emissions and, to a much greater extent, noise, continue
to be major problems affecting large numbers of people living
and working in a wide area around Heathrow Airport. The problem
of aircraft noise seems, from the increasingly wide area from
which complaints are being received, to be affecting areas previously
considered remote from this nuisance due to the larger numbers
of movements which are having to be accommodated. The Committee
welcomes Government's intention to give the issue of reducing
noise a high profile in discussion with the International Civil
Aviation Organisation and the European Union.
2.6.1 The proposal to take powers to enable
airports to enforce mitigation measures, for example against non-compliant
airlines, and to enable local authorities to enforce noise mitigation
agreements are potentially fraught with problems as false expectations
of what is technically feasible and justified may be raised. International
agreements may be involved where foreign airline operations are
concerned as well as the difficulty of considering whether an
aircraft is technically capable at all times of operating within
a specified noise level having regard to operational and meteorological
conditions. If local authorities are to be given powers to enforce
noise mitigation agreements, they may have the necessary acoustic
experts on staff but it is unlikely that they will have available
to them the necessary aviation expertise with which to do this
on an informed and fair basis.
2.6.2 Airport consultative committees probably
have a wider experience of the feasibility of undertaking such
measures, particularly where they have noise and track keeping
monitoring work undertaken in association with their airport operator,
as well as their general considerations of environmental matters.
They are in a strong position to be able to comment constructively
upon any such proposals and would wish to be consulted by Government
in their preparation and implementation.