Memorandum by British Airways plc (IT
THE GOVERNMENT'S WHITE PAPER ON THE FUTURE
(DEVELOPING AN INTEGRATED TRANSPORT POLICY)
1.1 British Airways welcomes the publication
of the Government's White Paper on Integrated Transport and believes
it provides a useful framework for the sustainable development
of an integrated transport infrastructure.
1.2 It has introduced some innovative and welcome
thinking whilst acknowledging the enterprise already demonstrated
by both private and public sectors. This is already making a great
difference to local transport infrastructure in localities such
as airport communities where such partnership is vital in maximising
their potential as major public transport interchanges.
2. INTEGRATED TRANSPORT
2.1 The White Paper has concentrated primarily
on road and rail, with limited coverage of the role of aviation
but British Airways welcomes as a useful starting point the section
promoting airports as interchanges. This requires further development,
not least in the forthcoming Airports Policy White Paper and we
look forward to participating in the consultation on that.
2.2 British Airways expects that the Airports
Policy White Paper will pay particular attention to the role of
airports as major public transport interchanges, generating sufficient
passenger flows to support a wide choice of public transport links.
Many of these links could not be justified without the boost generated
by the airport.
2.3 There are many other initiatives that should
be considered. These include:
the potential for dedicated bus and
coach lanes to airports, particularly where widening schemes are
planned (such as the M25 near Heathrow). This would enable public
transport links to operate reliably to and from airports, linking
both to flights and other forms of public transport.
Park and Ride schemes to airports,
where economically reasonable, with remote car-parking in order
to relieve pressure on the immediate airport area.
Clearly schemes like this require significant
investment and would need to be incorporated into wider strategic
thinking on airport capacity development. In British Airways'
view, it would be timely for the Government to give these matters
serious thought and incorporate a framework for such proposals
in its Airports Policy White Paper, which we understand will take
account of the Inspector's report on the T5 Inquiry.
2.4 The civil aviation industry is a growth
industry with potential to be a catalyst for further progress
in integrated surface transport. The prerequisites that enable
this are firstly the concentration of demand as outlined above
and secondly, location of airport capacity near the market (which
minimises journey times and distances, and maximises the potential
to use the airport as a convenient interchange). Proper consideration
of these factors will also lead to improvements in the environmental
efficiency of transportation.
2.5 Despite growth in public transport, there
will still be a requirement for some growth in car travel to airports.
The proportion of air passengers (and airport/airline staff) using
public transport will increase over time but industry growth,
combined with the recognition that many UK airports (notably Heathrow)
already have a high proportion of passenger access by public transport,
makes planning for expanded future road usage essential.
3. AIR TRANSPORT
3.1 We welcome the White Paper's endorsement
of the success of the Airport Transport Forum initiative, and
its comment that all airports with scheduled passenger services
should lead such a Forum (paragraph 3.204). Our experience is
that at the major airports where such Forums have been introduced
they are working well and are the best means of ensuring that
interested parties work together to generate the greatest overall
benefit. We do not consider that additional structures are required
where these Forums are in place.
3.2 Significant funding will be required to
enable vital new rail links and support for bus services. British
Airways sees the airline industry contributing by channelling
any congestion parking surcharges imposed in the airport area,
directly into public transport improvements. The Airport Transport
Forums would agree priorities. Any attempt to divert airport related
user charges, such as car parking levies or congestion charges,have
been opposed by airlines as contrary to the single till principle.
3.3 British Airways is already contributing
through development of a Free Transport Zone aimed primarily at
reducing staff dependence on cars. We see this as a model which
could be developed in other areas. We are also working with our
airport partners on further measures to reduce car dependence.
We believe that whatever the size of the levy charged for providing
car parks, it will have little or no impact on the volume of private
car usage, unless there is adequate and reasonably priced public
transport between places of work and large catchment areas before
the levy is charged.
3.4 We will also continue to press for revenues
raised by the Air Passenger Duty to be reinvested in infrastructure
projects to the benefit of transport users.
4. AIRPORTS POLICY
4.1 British Airways welcomes the Government's
foresight in announcing its intention to prepare a UK Airports
Policy looking some 30 years ahead (paragraph 3.189) since it
is critically important for the airline industry to be able to
plan for the future with some certainty.
4.2 Aviation is still a comparatively young
industry, with great potential for growth, wealth and employment
generation, and for under-pinning the international trade on which
the UK increasingly relies for prosperity. Planning, to provide
the infrastructure that encourages UK aviation and meet the needs
of UK passengers and freight forwarders, will require a robust
approach that allows for balanced growth in passenger, runway
and airspace capacity.
4.3 However, we would caution against attempting
to plan so far ahead that many of the key assumptions are uncertain.
4.4 For example, it is difficult to assess more
than 20 years ahead the likely development of aircraft design,
or whether further significant steps forward will be possible,
for instance in terms of environmental impact. Similarly, the
impact of technology (video-conferencing, virtual reality and
so on), changing patterns of tourism and the potential long term
impacts of low cost carriers may change demand volume and patterns.
The full impact of global alliances and changes in the world regulatory
scene are likely to impact significantly any strategy which, whilst
addressing UK infrastructure, should take account of the global
reach and international competitiveness of the UK's aviation industry.
4.5 We would recommend a staged approach to
policy, looking at 10 year periods in the 30-year strategy, as
0-10 years (to around 2010): Policy for
the immediate short term requires consolidated thinking on known
or planned developments such as Heathrow Terminal 5, and the proposed
terminal developments at Gatwick and Stansted; and concentration
on the improvements necessary to improve the efficiency of the
industry such as investments in Communications, Navigation and
Surveillance (CNS) and Air Traffic Management (ATM). Given planning
timescales, other significant developments will not impact this
10-20 years: It is important to start
work now on the requirements for this period, which will be critical
in setting the framework for future airport and runway capacity,
beyond those identified in the 10 year period. Decisions will
be needed early in the next century to enable major developments
to come into effect within the 20 year time-frame. This is the
timescale over which certainty is of particular value for the
airline industry because of the lifetime of aircraft, etc.
20-30 years: The Government should set
out its long-term strategic ambition for the industry, but decisions
for the period beyond around 2020 do not need to be taken imminently.
Indeed, given the uncertainties identified, in our view it would
be prudent to concentrate on enabling the conditions which will
permit the industry to achieve its potential in the long term.
5.1 British Airways is working, through IATA,
with ICAO to consider how best to control emissions of noise,
engine exhaust gases and waste. We have supported the tightening
of the requirements for NOx emissions from aircraft
engines, which has been recommended to the ICAO assembly (paragraph
4.154). We have also supported the return of engine noise certification
standards to the ICAO agenda.
5.2 Environmental levies and fuel taxes (paragraph
4.155) are not the only options for encouraging fuel efficiency:
others include tradable permits, regulatory action, and voluntary
action. Indeed, airlines already have commercial incentives to
be as fuel efficient as possible; in any case, fuel taxes are
an inefficient means of incentive since fuel accounts for a relatively
small part of overall costs. To date, regulatory action has been
very successful in tackling environmental issues in the aviation
5.3 We believe an independent study of the various
options would be the best means of balancing the desired economic,
competitive and environmental effects; this was something we recommended
in our response to the Green Paper and we still hope the Government
will take this course of action.
5.4 British Airways recognises the global significance
of aviation (paragraph 2.24). Nevertheless, air transport only
accounts for some 2-2.5 per cent of CO2 emitted worldwide
as a result of the burning of fossil fuels. Figures used for the
fuel efficiency of aviation are often incorrect, misleading or
outdated and we would be happy to work with the DETR on the most
relevant means of assessing the true impact of the industry. We
would urge the Government to request early completion of an authoritative
comparative study, already proposed by the European Commission
but not yet under way, of the overall environmental impacts of
different transport modes.
5.5 It should not be forgotten that considerable
investment has gone into the environmental performance of aviation,
in particular in terms of noise and engine exhaust gases, over
the past 20 years and that considerable progress has been made.
There may be a need for further measures but these must be introduced
multi-laterally to avoid competitive disbenefits to the UK industry.
6. DEMAND MANAGEMENT
6.1 For most air passengers there is no alternative
to flying. The potential for substituting air travel exists only
for some limited sectors of the market, for instance rail for
short UK domestic and European routes. The aviation industry is
increasingly looking at ways of combining these alternative transport
modes so that passengers gain the benefits of an integrated system.
6.2 There is, however, considerable resistance
from passengers, businesses and authorities in the UK regions
even to substituting a different airport for access to London
and onward connections, so the scope for demand management is
6.3 Any form of demand management in the air
transport industry, whether planned or by default, would impact
the number of people travelling and would disproportionally affect
certain groups of passengers, in particular those who are most
price sensitive. In the most recent CAA data (CAP 677) the numbers
and proportion of passengers from socio-economic group C1 using
Heathrow and Gatwick have increased dramatically since the previous
survey in 1991, while the numbers of passengers in the A/B group
have remained broadly static. Numbers of C2 and D/E have also
increased but remain quite small. BA would therefore expect that
the C1 group would be most affected by any mechanism that attempted
to dampen demand.
7. PLANNING AND
7.1 British Airways welcomes the Government's
commitment to promote the interests of the UK aviation industry
through negotiation of international air service agreements (Paragraph
4.42) and to further liberalisation of the industry. We fully
support the Government position as set out in the White Paper
in relation to bilateral negotiations.
7.2 We note the observations in paragraph 4.40
about the system of economic regulation of airports. We are, however,
concerned that the current system, while keeping passenger charges
down, discourages operators from timely investment in airport
capacity and customer service facility improvements. The regulatory
system, therefore, meets only some of the interests of passengers
and airlines. This will be an important issue for the timely delivery
of new investment that flows from the airport policy review.
7.3 We note with interest the clarity with which
the Government sets out its proposals for streamlining and co-ordinating
planning guidance in relation to land use and transport. We still
have concern about the existing planning approvals process which
we believe requires a complete overhaul to simplify and speed
up the mechanisms for dealing with large infrastructure projects.
8. AIR SAFETY
8.1 British Airways notes the proposal in the
White Paper for a review of the arrangements for transport safety
(Paragraph 3.259). The present criteria imposed by the CAA Safety
Regulation Group are prescriptive and we would welcome a review
of its role with a view to the creation of a safety organisation
including a revised SRG, NATS (in whatever form is decided) and
the Airspace Users Group that would work collectively and proactively
on matters of safety and operational efficiency.
8.2 A review of the Accident Investigation Branch
should not place any restrictions on its independence or role.
8.3 We look forward to participating in the