Memorandum submitted by General Consumer
Council
1. THE DEVELOPMENT
OF CAPACITY
AT EXISTING
AIRPORTS
The Government White Paper, The future of Air
Transport, published in December 2003
— Supported the development of Belfast
International Airport within its existing boundaries to serve
forecast demand.
— Recognised Belfast City Airport faces
significant constraints and it invited the Northern Ireland authorities
to review the form of the planning "cap", if and when
the operator asks them to.
— Advised the Northern Ireland authorities
to consider the future requirements of City of Derry Airport carefully,
together with the Government of the Republic of Ireland.
The General Consumer Council believes that the
Department for Regional Development should consult further to
promote informed debate and devise a strategy on how Northern
Ireland airports can facilitate the proposed growth over the next
25-30 years. This should review all airport facilities, infrastructure
and opportunities and consider what changes may be required at
Northern Ireland's three main airports, particularly Belfast City
and Belfast International, to best meet the need of Northern Ireland
passengers and the region as a whole in the future.
This consultation should take into account all
issues, interests and concerns including those of consumers, residents,
business and environmentalists. All have an important contribution
to make to help achieve the right balance needed for the future
benefit of Northern Ireland. Until decisions are made on the development
of Northern Ireland airports it is not possible to judge what
improvements are required.
Belfast City Airport has currently limited scope
to attract any new services given that it is very close to the
cap on the number of seats available for sale from the airport,
which has led to the recent request to review this aspect of their
planning agreement. City of Derry airport is currently limited
in the aircraft that it can attract while Belfast International
at present has both the capacity and runways to facilitate any
new route development.
Airport "competition" or "complementarity"
In recent years Belfast City Airport has become
the focal point for Northern Ireland's full service airlines.
In contrast Belfast International has emerged as a significant
airport in terms of "no frills" carriers.
As a result of direct competition between airports,
and improved facilities at all three, the two Belfast airports
have become complementary in many ways. However, Belfast City
can no longer compete to attract new business from "full"
or "semi" service airlines without breaching its current
planning constraints.
The General Consumer Council has long held the
view that both Belfast airports should remain in separate ownerships—a
view endorsed by the Monopolies and Mergers Commission in 1995.
As a result, any move towards cooperation or common ownership
should be considered further by the relevant competition and regulatory
authorities to determine if it would be in the passenger interest.
All these issues makes further internal Northern
Ireland consultation, led by the Department of Regional Development,
important to decide on the best way forward so we can plan to
meet the anticipated future aviation needs of the region.
2. SPECIFIC CHALLENGES
FACING NORTHERN
IRELAND AS
A PERIPHERAL
REGION OF
THE UK
Northern Ireland has a land border with just
one other country (Republic of Ireland) and is geographically
isolated from the rest of the United Kingdom and the European
mainland. The result is that consumers living here are exceptionally
dependent on adequate air transport.
The 1.7 million people living in Northern Ireland
have a multitude of business, educational, family, social and
sporting links with the 59 million[1]
people of Great Britain, and with people in Europe, North America
and beyond. To travel in pursuit of these links Northern Ireland
business people, students and others must cross the Irish Sea
either by ferry or by plane. Ferry travel adds greatly to travel
times and there is a risk of lengthy delays or cancellations especially
outside the summer months.
Air services offer the only sensible way for
the residents of Northern Ireland to access London. Rail plus
ferry and road plus ferry alternatives are not viable for a community
reliant on links to its capital city and onwards to the world.
Our special situation makes good air access
essential for travel to the other regions of the UK and to the
key connecting airports, especially London Heathrow. Access to
the wider world is important but should be achieved within a framework
that ensures good domestic links so that no part of the United
Kingdom is isolated or disenfranchised. This is particularly important
for Northern Ireland which does not have realistic alternatives
to air travel.
Importance of Heathrow to Northern Ireland
The main issue for Northern Ireland consumers
is access to the South East of England hub airports, and Heathrow
in particular. This is particularly important due to Northern
Ireland consumers not having realistic alternative forms of transport
eg road or rail.
— Main UK airport—In terms of
national integration Northern Ireland and other regions should
have access to the nation's main airport, respecting their role
as integral parts of the United Kingdom.
— Interlining opportunities—Heathrow
has unrivalled links to other international destinations. The
interlining options provided at Heathrow mean that it remains
the only realistic option for Northern Ireland consumers who have
very little by way of International point-to-point traffic.
— Northern Ireland Business Travellers—Northern
Ireland companies depend on international links to do business
given our high dependence on exporting the goods we produce. Because
of our peripherality in terms of both the UK and Europe, Northern
Ireland needs good access to do business throughout the world.
Northern Ireland manufacturers spend £33 million per year
of which 58% is on air travel, while 70% of business travel in
the financial and business sector and 93% in the construction
sector is by air.
— Northern Ireland Leisure Travellers—Leisure
travellers want to travel to destinations throughout the world.
At present Heathrow and to a lesser extent Gatwick are the main
hubs for doing this. People here need good interlining opportunities
because of a lack of point-to-point international options.
— Northern Ireland Economy—The
importance to Northern Ireland business has already been mentioned.
However, Northern Ireland depends on a lot of inward investment.
Lack of access to Northern Ireland via Heathrow could potentially
have a negative effect on inward investors deciding Northern Ireland
rather than another UK region with better links or the Republic
of Ireland.
— Tourism—Northern Ireland has
a low level of visiting tourists compared with the Republic of
Ireland. Lack of interlining opportunities via Heathrow would
constrain growth in this area or have a negative impact. Research
carried out for the Department of Regional Development show that
passengers coming into Northern Ireland are eight times more likely
to use London Heathrow than any other airport, with 450,000 UK
passengers using Heathrow to access Northern Ireland each year.
This highlights the necessity of a Heathrow
link for Northern Ireland and why the UK Government should seek
the necessary EU legislative changes to have Belfast-Heathrow
designated as a PSO route.
Slot capacity at Heathrow Airport
Northern Ireland's access to the key London
hub airport at Heathrow should be protected in the interests of
consumers and business and steps need to be taken to secure the
existing 16 slots.
The Government White paper, The Future of
Air Transport, supported further development at Heathrow provided
that strict environmental limits can be met, including the development
of a third runway. A further shorter runway at Heathrow would
provide additional capacity for flights from Northern Ireland
and all airlines operating scheduled services to and from here
at present use aircraft that could use a smaller runway at Heathrow.
A proportion of any new capacity created should
be reserved and used to protect regional services. Northern Ireland
and other regions should be given the right for reserved slots
to ensure the continuity of regional air services. However, any
new runway at Heathrow is likely to be at least 15 years away
allowing for planning applications, inquiries, legal objections
and construction. In the shorter term Northern Ireland needs guaranteed
access to Heathrow.
Public service obligations (PSOs) and EU legislation
The Council believes that Northern Ireland's
access to Heathrow in the short term can be protected through
amended Public Service Obligation (PSO) regulations, or reserving
slots for regional services. The continuing shortage of runway
capacity in the South East needs to be addressed and the Council
believes government should use the tools prescribed by the European
Commission to help the nation's peripheral regions compete in
the wider world.
The Council understand that existing Public
Service Obligation (PSO) Regulations allow designations of City-City
services (eg Belfast-London) rather than specific airport designations
(eg Belfast City-Heathrow). Government should seek to have this
changed for the benefit of Northern Ireland and all other UK regions
that need access to the nation's capital by air. None of the other
London airports compare with Heathrow (see Table 1).
The Council will be outlining these issues in
its response to the current Department for Transport consultation
on the protection of regional air services to London.
Table 1
NUMBER OF DESTINATIONS FROM LONDON AIRPORTS
AUGUST 2003
|
| Heathrow
| Gatwick | Stansted
| Luton | London City
|
|
| Total Destinations | 168
| 126 | 100
| 28 | 20
|
| Weekly Departures | 4,506
| 1,804 | 1,572
| 502 | 445
|
| Long Haul Departures | 91
| 39 | 0
| 0 | 0
|
|
Reduction in air services
The General Consumer Council for Northern Ireland and much
of Northern Ireland commercial and business life is concerned
that its air links to London are under threat. BA stopped its
high-frequency service between Belfast International and Heathrow
at very short notice in Autumn 2001. However, these slots were
not made available to alternative carriers for a Belfast-Heathrow
service.
The Council is pleased to note that the Department for Transport
(DfT) recognises these concerns, and has put out a consultation
paper to consider the very real fears of those peripheral regions
of the United Kingdom that are almost totally reliant on air services
for their economic livelihood. However, the DfT assumes no responsibility
for justifying the air services needed by the various peripheral
communities of the United Kingdom, stating that it is the responsibility
of the Devolved Administrations and the Regional Development Authorities
in England. This currently puts Northern Ireland interests at
a disadvantage, as there is currently no devolved administration
in Northern Ireland, and the day-to-day administration is provided
from London.
The Council has consistently led the debate and campaigned
for securing regional air service access to London for a number
of years. It made a presentation to a seminar on the topic held
at the House of Commons organised by Calum Macdonald MP in May
2004 and subsequently held its own seminar on the issue in Belfast
in June. This resulted in a high level of interest and concern
from business and community leaders to the real danger of loss
of London links over time, without a rapid resolution of the runway
capacity problem or securing slots through PSO designation.
The Council also held a seminar on 22 June 2004 on the importance
of securing Northern Ireland's continued access to Heathrow Airport.
The event was well attended by representatives from all five assembly
political parties, business leaders, tourism representatives,
airlines, airports, universities, government and other key stakeholders.
There was strong agreement that this was an important issue that
required action.
3. THE EFFECTIVENESS
OF THE
AIR ROUTE
DEVELOPMENT FUND
The Council welcomes the Air Route Development fund and the
routes that it has been able to support. This has helped bring
about a significant increase in European destinations available
to Northern Ireland consumers and also a recent agreement in principle
for a north Atlantic route beginning in early 2005 from Belfast
International.
In welcoming the new routes the Council recognises that there
is a limit to the number of routes that can be supported by such
a scheme. Northern Ireland does not have the critical mass of
people to secure access to all of the destinations required. Therefore,
while we want to see more direct links developed there is a necessity
for us to retain our links to Heathrow and Gatwick to provide
access to wide variety of worldwide destinations available from
these two hub airports.
4. POTENTIAL IMPACT
FOR NORTHERN
IRELAND OF
WIDER AIR
TRANSPORT ISSUES
ON THE
ISLAND OF
IRELAND
The Council believes that the Department for Regional Development
needs to consider any other issues on the island of Ireland that
could potentially impact on Northern Ireland air services as part
of its consultation to devise a strategy on the future of aviation
in Northern Ireland over the next 25-30 years.
5. CONCLUSION
Expansion of air services is essential if Northern Ireland
is to catch up to the levels of economic activity achieved elsewhere.
It is also essential for Northern Ireland people to promote social
inclusion and their ability to interact with the European Union
and the wider global society. At the core of this is access to
the UK's major hub airport at Heathrow.
The United Kingdom Government needs to take immediate action
to secure access for Northern Ireland at Heathrow. Further investigation
should take place on existing provisions to determine if slots
can be reserved for Northern Ireland in this way. If not then
the UK Government must seek changes to the PSO regulations that
provide route and airport specific services to be given PSO status
and slot reservations.
Overall, increased air transport capacity in south-east England
would help to accommodate the growth of our region. Northern Ireland's
limited choice of transport options highlights the importance
of air services with good frequency and reasonable fares. However
the comparatively small size of the population means that competition
will not always provide the answer and thus regulatory protection
in the absence of competition is very important.
Given the potential growth forecast for Northern Ireland
the Department for Regional Development, which has responsibility
for airports policy, should take the lead on the further consultation
needed to promote informed debate on how Northern Ireland airports
can best facilitate and support forecasted passenger growth over
the next 25-30 years.
27 September 2004
1
Office for National Statistics UK Population Estimates June 2003
show 59.6 million people living in England, Scotland and Wales.
http://www.statistics.gov.uk/pdfdir/pop0904.pdf Back
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