Memorandum by London Luton Airport (IT
A NEW DEAL FOR TRANSPORT:
BETTER FOR EVERYONE
1.1 The Government's commitment to an integrated
transport system provides a welcome opportunity to develop a strategic
and efficient inter-modal system of transport providing greater
mobility for all.
1.2 A very comprehensive statement of intent,
much will depend upon the policy papers for each topic which will
determine the practicability of attaining the White Paper's objectives.
1.3 A UK Airports Policy warrants early preparation
rather than await the outcome of the Heathrow Terminal 5 Public
Inquiry given the current growth of traffic. LLA will respond
comprehensively to the proposals when submitted.
2. LONDON LUTON
2.1 LLA is currently one of the fastest growing
airports in the United Kingdom. 4.3 million passengers are expected
to be handled this year with five mppa likely in 1999-2000.
2.2 In January, LLA embarked upon a £80
million expansion of the airport and is currently preparing proposals
to increase capacity further in accordance with Local Plan Policy.
The proposals will take account of the White Paper's objectives
for integrated transport and sustainable development.
3. ENDORSEMENT TO
3.1 LLA supports the following key objectives,
in principle, subject to a review of the more detailed policy
3.1.1 A predominantly advisory as opposed to
regulatory role for Government supporting LLA's view that Government's
role is one of stewardship as opposed to regulation.
3.1.2 The reduction of pollution and improvements
to air quality.
3.1.3 The publication of targets.
3.1.4 The views of the customer as a priority
in determining transport needs. It is important that it is the
transport users themselves who determine the "public interest".
3.1.5 The need for strategic vision throughout
transport policy, and within those other areas of Government policy
that either impact upon or are affected by transport, most notably
in the fields of environment and economic regeneration.
3.1.6 Modernisation of the planning system and
welcome emphasis on economic development issues, particularly
in those areas in urgent need of regeneration policies.
3.17 the provision of safe, secure, clean, efficient
and value for money public transport and improved customer service
training, reliability of journeys, provision and integration of
information, fares, and interchange of transport systems;
3.1.8 the production of Local Transport and
Green Transport Plans;
3.1.9 the development of Quality Partnerships
and Quality Contracts;
3.1.10 support for TENS, particularly where
4.1 LLA regrets that the proposed Airports Policy
will not be available for consultation until after the Terminal
5 planning process is complete. Both RUCATSE and the White Paper
identify LLA as being able to provide relief to the other London
airports, especially in the area of low fare scheduled services.
Currently there is a lack of policy to support this role. LLA
therefore urges Government to prepare a consultative document
on Airports Policy as a matter of urgency on a "with and
without" T5 basis.
4.2 Airports are partners in improving access
but should not be required to contribute a disproportionate cost
of access improvements. The development of integrated local transport
initiatives in which airports are key participants can provide
the catalyst to public transport improvements and LLA will pursue
this objective as it brings forward further proposals for expansion,
in partnership with local authorities and the local community.
Noteworthy is the recent TENS award of funding support to our
feasibility study which will examine a potential transport link
from the Luton Airport Parkway Station to the airport passenger
terminal. It is intended that the link will integrate with other
planned local transport improvements to the benefit of the community
as a whole.
4.3 In terms of rail access, the short term
remit of the Franchise Director and his unwillingness to offer
a Section 54 undertaking which would have secured private sector
investment in the new Luton Airport Parkway Station, has resulted
in a substantial delay to construction. Modal integration should
have been a consideration as without doubt the Director's decision
has limited LLA's capability to increase public transport modal
4.4 Should it be determined that airports meet
their external costs this should only be considered where the
evaluation of all transport modes is undertaken on a fair and
equitable basis and includes an assessment of the economic benefits
derived from each mode.
4.5 The redistribution of traffic through regulation
has failed in the past, conflicts with consumer interest and has
international implications likely to result in regulation and
redirection of traffic within other countries to the disadvantage
of UK airlines and industry generally. Better to encourage the
development of additional services and/or increased route frequency
from airports other than the main hubs, although relief to the
south eastern airports should only be to satisfy local demand
where this is economically justifiable. The role of low fare airlines
at the less congested airports will be important as is the case
at LLA now.
4.6 Borrowing outside the PSBR should be available
to all Local Authority airports or not at all. To do otherwise
distorts competition. There needs to be consistency to ensure
4.7 Slots at airports are created by airport
operators, in conjunction with the air traffic management organisation
and other agencies at the airport, through their investment and
the adoption of efficient operating practices. Airports thus have
a legitimate interest in the allocation of slots at an airport,
including the ownership of slots in the first instance.
4.8 LLA supports the principle of transparent
and non-discriminatory criteria for the allocation of slots administered
by a neutral co-ordinator in accordance with EU procedures. Airports
play an important role in serving regional communities, however,
and slot allocation procedures should recognise that airports
need to serve the full range of passenger demands to and from
their catchment area, consistent with the economics of airline
operation. This may require safeguarding of slots for particular
categories of traffic. The needs of each airport will be different
and should be recognised by continuing to allow local rules, provided
that these are transparent and non-discriminatory and provide
for the needs of the airport operator, its airline customers and
passengers. This is particularly relevant in the case of UK regional
air services requiring access to major UK and European hub airports
to give consumers access to the full range of international air
4.9 Whereas, in some circumstances, priority
in the allocation of pool slots to new entrant airlines might
be appropriate to encourage airline competition, LLA believes
that it may be preferable to give priority to new route development
or the introduction of competition onto existing routes, whether
in the EU or otherwise, in order to increase the range of services
available to passengers. This will depend on local circumstances.
The ultimate test should be consumer benefit
4.10 Responsibility for the negotiation of air
services agreements by the EU should only be delegated when they
can demonstrate that they can do it better.
4.11 The separation of ATC safety, economic
regulation and operational issues is welcome.
4.12 All major UK airports have their own air
noise policies, many of which are voluntary. Government needs
to ensure that any noise standards are consistent to ensure that
neither airports nor airlines can claim a competitive advantage,
both within the UK and the EU. Further, airports must ensure that
any planning conditions to which they are prepared to agree do
not undermine the capability of other airports to meet similar
conditions without disproportionately affecting their business.
4.13 In respect of taxes, any proposals, if
agreed, must be non-discriminatory. The Air Passenger Departure
Tax for example, fails to distinguish between the low fare carriers
and other scheduled operators producing a disproportionate affect
upon ticket cost.
4.14 United Kingdom regions have disparate needs
and the devolving of transport decisions, amongst others, to the
regions is sensible. National policies must not, however, be undermined
by regional priorities. The objective should be to ensure the
optimum use of airports as national, as well as a regional, assets.
4.15 Any assessment of the cost of environmental
impact must be evaluated on a fair and equitable basis between
all transport modes and should include the economic and social
benefits that transport can bring, particularly with regard to
4.16 LLA is alarmed at the prospective EU Charges
Directive that seems to suggest that airports will be permitted
to cross subsidise others within their group (e.g., BAA) through
commercially generated income. LLA has suffered adversely as a
result of the competition from Stansted and offered evidence to
support its claim that charges at Stansted were priced below cost
as a consequence of which business was lost from LLA. Cross subsidy
within BAA enabled this anti-competitive situation to arise. LLA
urges Government to use its influence to ensure that the EU Directive
preserves fair competition.
5. THE RELEVANCE
5.1 The current Phase 1 development works will
provide a capacity increase to 5 mppa. LLA is currently developing
proposals to increase capacity beyond 5 mppa.
5.2 Locally the two most important environmental
issues will be air noise and road traffic. It is to both that
mitigatory measures will be focused.
5.3 Simultaneously LLA is implementing an Environmental
Management System (EMS) with a view to achieving accreditation
to ISO 14001 in 1999. Not only will this address the need for
continuing environmental best practice in the day to day operations
of the airport, it will also be used to underpin the preparation
of future Environmental Statements that will accompany Planning
5.4 Further, LLA is but one business in a geographical
corridor of Luton that includes other potential major development
sites. All of these developments will bring pressure to bear not
only on the access roads but also on the public transport system
generally. There is, therefore, a major challenge, and opportunity,
for the developers to contribute to the improvement to and integration
of public transport within the town. LLA intends to be a leader
in bringing about such development. This opportunity is further
enhanced by the proactive transport policies of Luton Borough
Council whose schemes include the Luton Dunstable Translink project
which aims to upgrade and integrate public transport provision
within the local conurbation.
5.5 LLA will, therefore, specifically focus
upon opportunities for improvements to the local transport network
and public transport generally. This will be enhanced by the project
to provide a new railway station closer to the airport in respect
of which construction has already started and is scheduled for
completion next year.
5.6 In conclusion, LLA looks forward to the
receipt of practical support as it pursues its role in delivering
its contribution to the development of integrated transport within
the United Kingdom.
24 September 1998