Written evidence submitted by Flybe|
Flybe welcomes the opportunity to submit a response
to the Environmental Audit Committee's inquiry into the Budget
2011 and environmental taxes.
We have restricted our comments to the tax system's
ability to create a "modal shift" from high carbon transportation
to low carbon alternatives, including Air Passenger Duty, and
issues the Government should consider when developing strategies
for sustainable aviation.
supports the view that human activity, including air travel, is
contributing to global climate change.
welcome the Chancellor's move to freeze Air Passenger Duty and
to consult on the tax banding.
do not believe that Air Passenger Duty as currently structured,
represents the best mechanism to promote sustainable growth in
the aviation industry.
believes that aviation taxation should be directly related to
emissions, so that those who have invested in cleaner fleets are
rewarded and those who have not are incentivised to cut their
of taxation to promote sustainable transportation must not be
at the expense of the UK's regions that rely on aviation.
2.1 Headquartered in Exeter, Flybe is Europe's
largest regional airline and the UK's number one domestic airline.
Employing nearly 3,000 staff, we currently operate 69 aircraft
on 188 routes from 38 UK and 37 European airports in 13 countries
and carried more than seven million passengers in 2010. The airline
began life in 1979 as Jersey European Airways, later renamed British
European in 2000 and was then re-launched as Flybe in July 2002.
2.2 Flybe has established a regional route network
and its spread of airports is intended to offer customers a convenient
point-to-point network operating from regional airports which
we believe are a preferable alternative to having to travel to
more distant major hub airports. In addition, the domestic route
network is structured with the aim of minimising the competitive
threat from alternative forms of surface transport (alternative
road or rail options give journey time of four hours or less.)
Not only is the average flight time of a Flybe flight less than
one hour, our route network attracts passengers in locations which
are more dependent on air transport such as Northern Ireland and
other locations where surface transport may be a less attractive
option, such as Inverness, Newquay and Aberdeen.
2.3 Since October 2008 Flybe has also operated
a franchise arrangement with the Scottish airline Loganair, under
which 16 Loganair aircraft fly using the Flybe brand across 28
franchise routes between 18 airports throughout the UK.
3.1 Flybe supports the view that human activity,
including air travel, is contributing to global climate change.
Although aviation accounts for just 2% of global CO2 emissions
Flybe is committed to leading the industry and minimising its
environmental impact wherever possible while continuing to provide
vital services to our passengers. Such leadership is exemplified
not only by one of the youngest fleet of aircraft in the world
but also by the implementation of the Flybe Ecolabel in June 2007.
The label, modelled on those used in the sale of white goods like
fridges, microwaves and washing machines, shows a full range of
environmental indicators per aircraft and informs the passenger,
in a transparent way, of the environmental impact of their flight.
4.0 BUDGET 2011
4.1 We welcome the Chancellor's move to freeze
Air Passenger Duty and to consult on the tax banding. APD disproportionately
penalises the UK domestic passenger given that, unlike those flying
abroad, they have to pay the tax on both legs of their journey,
so the freeze is very much a step in the right direction.
4.2 We are also pleased that the Treasury has
chosen to widen the scope of the tax to include private jets.
We have been calling for this level playing field for some time
and would encourage the Treasury to go further and include freight
4.3 However, we do not believe that Air Passenger
Duty as currently structured represents the best mechanism to
promote sustainable growth in the aviation industry.
4.4 Climate Change will not be solved by increasing
taxation. Only by providing incentives for businesses to promote
low carbon alternatives to existing technologies and business
models will we begin to reduce emissions and tackle Climate Change.
It is far more efficient to reduce the emissions of aircraft than
to seek to put an end to low cost air travel, which provides jobs,
innovation and investment in the British economy.
4.5 If the Government is committed to reforming
Air Passenger Duty to promote low carbon alternatives, taxation
must be in proportion to emissions, so that those that have invested
in cleaner fleets are rewarded and those that have not are incentivised
to cut their CO2. Only when the polluter pays will the wider aviation
industry begin to invest in cleaner fuels, green aircraft, more
efficient air traffic control management and other similar initiatives.
5.1 We understand that for some shorter trips
road and rail can offer a more convenient and low carbon alternative
for many passengers, especially when the journey time is less
than two and a half hours. However, it is a London-centric view
to suggest that there are always realistic low carbon alternatives
to aviation for passengers.
5.2 The rail network remains based around the
terminals in the capital city, whereas regional air travel offers
the flexibility and convenience of non-London-centric journeys.
For example, a trip from Southampton to Newcastle by train takes
up to six hours, including a tube journey through London. By contrast
this would take 80 minutes on a Flybe flight.
5.3 Regional economies rely on fast, reliable
air links and any reform of taxation to promote sustainable transportation
that limits such services runs the risk of damaging local businesses
and communities and undermining the UK's economic recovery.
5.4 With this in mind we welcome the Chancellor's
focus on the importance of the UK's regional airports in the APD
consultation document, published alongside the Budget, and will
strongly be arguing that regional and domestic aviation should
be subject to a lower rate of Air Passenger Duty in our response.
26 April 2011