Aviation Strategy

Written evidence from Southend on Sea Borough Council (AS 119)

I ntroduction

Southend on Sea Borough Council`s interest in the development of the Aviation Strategy focuses on the proposals to build a new airport in the Thames Estuary.

This response is intended to assist and support the Committee`s examination of the Government policy proposals and the need to expedite the development of an aviation strategy.

We are aware that runway capacity in the South East and the UK’s largest and only International hub airport, Heathrow, is severely constrained. This causes delays and impacts upon the UK’s global connectivity, our ability to attract new long haul services to emerging economies and, more importantly, the economic competitiveness of UK business.

At present South East England is the ultimate destination of 75% of customers exiting Heathrow by surface transport. This fact and the economic importance of London to the UK economy suggest that future hub capacity must directly service the capital.

The Institution of Civil Engineers and Chartered Institution of Highways and Transp ortation have recently published a statement documenting their thoughts on the UK Aviation Strategy and concluded that, If political support could be secured, new capacity in the form of a third runway at Heathrow is likely to be deliverable earlier than a new facility.

As we know, a range of proposals including wholly new facilities in the Thames Estuary and expansions of existing London airports, most recently a four runway facility at Stansted are at various stages of development.

Many of the points that are made in this document have already been stated by other sources, but we feel that it is important for us to put on record the position of this Council in opposing the Estuary Airport proposals. Where appropriate we have contributed to the questions posed by the Committee and then added further comments to arrive at a sensible and realistic assessment of the many ideas and proposals for aviation development more recently suggested and put forward.

For example we have significant concerns over the viability of building an airport on a man-made island, particularly as the plans are very vague. We also believe that it could take over 20 years to deliver the project. The transport links for "Boris Island" show a new connection to the east of Southend, which is neither practical or feasible. Southend already suffers from a railway line (Liverpool Street to Southend Victoria ) in need of extensive modernisation and investment, which together with the problems encountered daily on the A127 and A13 rules out any form of road based access.

Bird-strike would pose a significant risk, together with the threat posed by the SS Richard Montgomery, an American wartime ship containing unexploded ammunition. Furthermore, there is strong and growing opposition from environmental groups worried about sensitive areas for EU protected winter breeding birds.

However, w e do believe that well planned airport infrastructure , in the appropriate location , attract s inward investment, enables access to an international labour force and provides direct business and leisure links to growing economic and cultural centres. We have strong evidence of this in the development plans associated with the expansion of London Southend Airport.

What should be the objectives of Government policy on aviation?

Future aviation policies must ensure that the UK remains competitive within the global economy whilst ensuring that air travel remains accessible for general consumers. In addition, the role of regional airports are vital in this respect and must be afforded greater scrutiny in examining how this can be clearly identified. Ultimately the Government’s strategy must be based on practicality, affordability and common sense.

The Government should not plan to ‘solve’ the UK`s capacity shortfall by building an airport in the Thames Estuary, which can only at this stage to be seen to be a high risk strategy in respect of funding, long term support and very significant connectivity and environmental problems

As background, the South East LEP recently appointed Parsons Brinckerhoff to carry out a significant research study to identify how the airports of the Greater South East can be used more effectively and efficiently and, where possible, grown to accommodate the anticipated increasing demands of air travel. The study has concluded that airports in the south east of England make a significant contribution to the economy of the region and UK Plc. Without a doubt global companies have located in London and the greater SE, attracted by the connectivity afforded by the London Airport System.

Therefore in submitting evidence to this Committee, it is essential that it is clearly identified that the regional airports are not ignored by the Davies Commission, owing to the more detailed discussions over hub capacity.

Our regional airports have an enormous role to play in providing point to point services and a key objective of the Government’s policy going forward must be to look at ways of supporting regional airports, potentially looking at measures to incentivise a broader spread of air travel, where practical throughout the UK. These measures could be as simple as improving rail and road connectivity and as challenging as reviewing air passenger duty (APD), to potentially introduce differing levels of APD.

It is also worth noting at this stage that the research study has put forward some short term enhancements that could be introduced to increase capacity over the next decade including;

· Mixed Mode Operations at Heathrow;

· Reviewing artificial planning caps at Heathrow, Gatwick and London City;

· Incentivising airlines to move point to point services away from Heathrow to free up slots for an enlarged long haul network;

· Improved management of slot allocation at Heathrow and to a lesser extent Gatwick; and

· Developing a "two airport hub" between Heathrow and Gatwick, or Heathrow and Stansted.

More locally, the short term role of London Southend Airport is to provide an alternative for point-to-point travel for passengers with origins and destinations in London and the East of England. The availability of the runway enables a range of demands to be met including scheduled and charter passenger flights, Business and General Aviation. London Southend Airport has also been a long term home for a thriving Maintenance Repair and Overhaul (MRO) sector which has consistently provided jobs and export earning over many years.

The development of the Joint Area Action Plan (JAAP) for the airport environs includes significant employment opportunities at the new airport Business Park. The value of connectivity must reflect the economic benefit that is derived from the proximity of high value engineering and research to airports

How should we make the best use of existing aviation capacity?

It is fact that Heathrow, as the UK’s sole hub airport is currently approaching capacity and that this is already having a major impact on the UK`s ability to accommodate flights to new destinations, particularly China. It is also the case that there is capacity at the other London Airports and scope to increase this. New flights to emerging markets are being accommodated at Gatwick which demonstrates that airlines are flying to other airports outside Heathrow. For example, for the first time it is possible to fly to the USA from London Southend Airport (via Dublin).

In the recent consultation on the Draft Aviation Policy Framework, it is pleasing to see the Government’s recognition that regional airports can and must play a greater role in improving UK connectivity. It is vitally important to consider how airport development can benefit local business and local economic growth taking into account the nature of routes operated from each airport and the specific local circumstances. This is a role that the Local Enterprise Partnerships can develop further by bringing local and business expertise together.

Local regional airports, such as Southend and Manston, providing direct links to European Hubs could increase GVA to the SELEP Region. The development of Southend Airport, for example, who now offer direct links to Schiphol and Dublin (and their onward long haul networks), has opened up a range of new opportunities for South Essex which previously did not exist. Residents who previously travelled to Stansted or across London to either Heathrow or Gatwick now have the option of using Southend Airport and connecting elsewhere.

What constraints are there on increasing UK aviation capacity?

The environmental impact of aviation must be a key consideration in the Government’s aviation strategy and should be a strong factor when considering the feasibility of proposals to build a new hub airport in the Thames estuary. We are of the view that these proposals are incompatible with the UK’s environmental commitments on both national and international levels.

The mouth of the Thames Estuary is a site listed international and national designations and special protection areas (Globally - The Ramsar Convention, at a European level - The Habitats Directive (Special Areas of Conservation) and Birds Directive) that the Government has committed to.

Altogether, the airport land and surrounding areas and waters include five separate Special Protection Areas for passing or over-wintering avocet, hen harriers, ringed and golden plovers, marsh harriers, little tern, dunlin and pintail, as well as hosting one of a new breed of marine sites, this one designated for its population of 6,000-8,000 red-throated divers. There is a Special Area of Conservation preserved for its species-rich estuaries, mudlflats and salt meadows. Much of the area is also covered by the Ramsar international convention on wetlands, recognising how crucial the estuary is for birds travelling as far afield as Siberia, Canada and north Africa.

Each of the designations would have to be significantly changed for an airport in the Thames estuary to go ahead, whilst destroying the habitat for over 300,000 migrant birds that rely on the area for feeding and roosting during the winter.

A recent quote from the RSBP states that:-

"We are vehemently opposed to the construction of an airport in the Thames Estuary, including the latest proposals for a four runway airport. This world-class coastal wetland has been saved from a series of ill-thought out airport proposals over the past few decades by our campaigning alongside local communities and many others. The most recent proposal, launched in autumn 2011 by Norman Foster on the Isle of Grain in North Kent has been catapulted to prominence by the Mayor of London, Boris Johnson, who is favouring the idea in the context of forthcoming Government consultations on the UK's airport strategy. We will actively campaign to reject the plans on the grounds that they are unsustainable; because of the direct and indirect impacts on internationally recognised and protected coastal wetlands and wider concerns about the impact of increased aviation on climate change".

Further to this, the estuary airport has been assessed to have the highest risk of bird strike in the UK (twelve times higher), even with extensive management measures.

Echoing the words from the Medway Council submission, we would reiterate the issues around the World War II liberty ship, SS Richard Montgomery:-

"In 1944 the ship sank 1km off the coast of Sheerness, and poses a significant hazard in the mouth of the Thames estuary. The ship which is packed with approximately 1,500 tonnes of unexploded ammunitions would require, what was labelled in a report by New Scientist magazine in 2004 "one of the biggest non-nuclear blasts ever and would devastate the port of Sheerness " .

Engineers who have examined the ship suggest that if the wreck exploded it would likely create a metre high tidal wave. Furthermore, Government tests on the site as far back as 1970 suggested a blast would hurl a 1,000ft wide column of water, mud, metal and munitions almost 10,000ft into the air – risking the lives of wildlife and many people."

A new hub airport in the Thames Estuary would be three times more likely to be affected by fog than Heathrow Airport, according to the Met Office. Research commissioned by Medway Council was carried out over a five-year period. Data was analysed from two weather stations - one at Heathrow and another in Shoeburyness, Essex, which is on the Thames Estuary. Between January 2007 and December 2011 there were 762 hours of fog in the estuary compared to 247 at Heathrow.

There are also significant risk issues associated with locating the airport in the Thames estuary. Richard Deakin (Chief Executive Officer of National Air Traffic Services) has stated that the proposed airport in the Thames estuary would be in the 'very worst spot' for the south-east's crowded airspace, directly conflicting with Heathrow, Gatwick, Stansted, Luton and London City flight paths (in addition to Schiphol).

This is all to be taken into account within an area that has substantial shipping lanes, fisheries, a power station, the Isle of Grain gas storage facility and existing and new port terminals.

The Climate Change Act 2008 committed the Government to a legally binding, long-term framework to tackle carbon emissions. Any new airport at the suggested size and scale as the Thames estuary proposals will have a significant effect on the UK’s carbon emissions output.

With global sea levels anticipated to rise and areas becoming susceptible to frequent flooding it is with great concern that we do not see significant research into the effects an estuary airport may have on low lying areas on the east coast.

For example, in respect of the "Thames Hub" proposal, produced by Foster and Partners and consultants Halcrow, the bringing together of rail freight connections between the UK’s main sea ports, 150 million passengers, a tidal energy barrage and a new flood protection barrier will have enormous consequences to the tidal flows and estuarial sea levels. Although the project states that a new barrier upstream of the London Gateway port would provide effective flood protection for the capital to 2100 and beyond, the consequences further east into the wider estuary and North Sea are unknown.

Any changes to the estuary by building artificial islands will have major consequences to the land lying on both sides and impose significant and unacceptable mitigation measures to the Southend seafront, which is primarily protected by sand/shingle beaches and low lying sea defences. These are key assets to the Borough and support the tourism offer attracting over 6m day visitors every year.

Aircraft noise disturbance remains the most obvious local environmental impact associated with airports and one that has given rise to capacity constraints, limiting the ability of some airports to respond to demand when and where it arises.

As an example, noise disturbance was cited as the single greatest concern of respondents to the Department for Transport’s 2011 scoping document on aviation policy. DfT’s subsequent July 2012 consultation on a Draft Aviation Policy Framework restated government’s policy objective as "to aim to limit and where possible reduce the number of people in the UK significantly affected by aircraft noise".

Experience suggests that airports not only need to minimise exposure to noise and visual intrusion, but should do so in consultation with local residents to secure buy-in to the process and ensure that any remedial action or commitments actually addresses local concerns.

An informed Airport management should however, already understand the noise challenge and the necessary responses to ensure sustainable growth and this should be reflected in the Noise Action Plans prepared by individual airports and should be one of the first considerations in insisting that Estuary Airport promoters develop comprehensive noise maps and are clear about the scale and magnitude of disturbance so that the public are able to understand and have a clear say in the process of formulating the Aviation Strategy.

Do we need a step-change in UK aviation capacity? Why?

a) What should this step-change be? Should there be a new hub airport? Where?

We understand that an airport in the Thames Estuary will be discussed as an option, however we believe that this solution put forward, from whatever source, is not viable, is unaffordable and does not correspond with a more wider generally held view by either the industry or local authorities.

There are suggestions that an Estuary Airport could be built within twenty years. In that time there is no doubt that other countries will have continued their rapid expansion and moved ahead of Heathrow as the leading European hub, together with the loss of Heathrow and the many of thousands of jobs that it supports.

The effect on regional airports will also be significant with uncertainty over the future affecting investment decisions (predominantly from the private sector) and planning policies and strategies.

Affordability

Figures of an estimated £20bn for the proposed Foster & Partners’ multi-runway Thames Hub airport on the Isle of Grain and an additional £30bn for the required infrastructure have been put forward. These figures have been questioned, particularly in light of the projected £9bn cost for only one new runway at Heathrow Airport.

The recent research study by Parsons Brinckerhoff summarises:-

· costs ranging between £40bn and £70bn for a Thames estuary airport, associated infrastructure and the building of a "multitude of new railways lines" connecting the airport to London, but warns that "even the £70bn being discuss ed is a conservative estimate;

· "that large UK infrastructure projects, much less technically complex than this, have suffered considerable cost overruns" - the Channel Tunnel, originally planned at £4.7bn, ultimately costing £9.5bn is only one example of that;

In addition, it is estimated that the planning for a Thames estuary airport would span a period of at least ten years. From a base figure of the estimated £20bn cost, adding 3 per cent construction cost inflation for that period would result in £600m annually increasing the cost of the airport to £26bn even before construction has started.

In March 2010, a survey carried out on behalf of Medway Council stated that 90 per cent of the international airlines using Heathrow were against the idea of building an airport in the estuary. Willie Walsh, chief executive of the International Airlines Group (including British Airways) has also rejected the idea and has claimed a new hub airport would only work if Heathrow were closed.

Analysts have further warned that current cost estimates fail to factor in the current amount of BAA’s £12.5bn debt levels which are a result of the expansion at Heathrow Airport, should it close, together with the loss of over 100,000 jobs.

This is supported by the fact that, in 2008/9, nearly 77,000 people were employed in jobs related to the airport with 45.5% of Heathrow staff (33,483) living in the five boroughs of Hounslow, Hillingdon, Ealing and Slough and Spelthorne that form the priority area for BAA’s local labour strategy. Within the five boroughs, 1 in 14 of all people in employment works at Heathrow (ranging from 1 in 26 in Ealing to 1 in 10 in Hounslow). Air cabin crew represent the largest occupational group, followed by passenger services, sales and clerical staff. Together, those categories represent 46.9% of Heathrow staff.

Economic Development Aspects of an Estuary Airport

In January 2011, a scoping report into Estuary airport development from the London Mayor was published, which pointed out some of the economic difficulties. It stated that airlines and airports are commercial businesses operating in a competitive free market environment, not serving just London but the global travel community. These are significant issues that need to be understood.

All the major airports are owned and operated by non UK based private companies and the majority of movements into Heathrow are foreign-owned airlines. Therefore, encouraging airlines to leave Heathrow will be very challenging unless there is an overwhelming economic advantage which could be demonstrated.

State subsidy towards the development of any London airport is not an option due to UK and EU competition rules. Therefore the development of new capacity has to be affordable to the user. Given that BAA, comprising Heathrow, Gatwick and Stansted, was purchased by Ferrovial for around £10bn the difficulty of funding a new airport in the range of £20-£40bn cannot be understated. The issue of affordability is a critical issue to address.

More directly relevant to Southend is the investment that the Stobart Group has made in London Southend Airport.

Since they took on the lease of Southend Airport in 2008 they have invested over £120m in the site and its surroundings. This has been multiplied many times over in the local economy through local spend and recruitment. The airport now employs nearly 2,000 jobs directly and also indirectly through the Maintenance, Repair and Overhaul cluster located at the airport and through the supply chains and associated spend. A new Hotel on the site is also developing a conference and dining offer to compliment the growing appeal of Southend’s destination credentials throughout the year.

The expansion of Southend Airport has also boosted non-aviation industry with commercial agents reporting significant demand for premises in close proximity to the airport with occupiers seeking to maximise the prestige and reputation of co-location. The land to the west of the airport is planned to become a hi-tech business park and it is anticipated that the demand currently being experienced will extend to this site and see thousands of jobs created. Part of this site is earmarked for the Anglia Ruskin MedTech Campus launched in the House of Commons in May 2012 by Earl Howe.

If the Estuary Airport were to be constructed and result in the closure of London Southend Airport these benefits would be lost, with devastating effect. Southend has an unemployment rate above the national average and below average skills attainment levels so the loss of current and future employment opportunities would not only affect the workforce of today but also the aspirations of the workforce of tomorrow. The closure of London Southend Airport would also negatively impact on the wider aviation industry with many aviation businesses around the airport being reliant on the airport operation for their business and could trigger the relocation of these businesses to other sites – and potentially overseas losing the benefit to UK Plc. It would also risk stymieing the development at the proposed airport business park through the removal of a major economic driver and attractor in south east Essex.

Southend recognises six key sectors in its economy, the largest of which is tourism. Since the introduction of Aer Lingus and easyJet flights to London Southend Airport from an ever-increasing list of European destinations, and the USA via Dublin, tourism in Southend has grown. Not only that, but the airport has supported tourism in other locations in Essex and further afield – including air passengers for the Olympics given the airport’s proximity to London and ease of travel to the city by train. The boost stimulated by the growth of the airport continues to be felt within the leisure-tourism industry but also for business tourists with businesses using LSA as a port of entry for overseas colleagues, customers, specialists and sales teams.

Ford now fly from LSA to Germany and Romania from Southend Airport enabling their business to operate more effectively and thus supporting jobs along Thames Gateway South Essex. The on-site hotel provides further opportunities to secure business tourism objectives and assist the strategic development of increase average spend in the Borough.

The economic benefits lost through a closure of LSA would not be recouped by the introduction of a Thames Estuary airport. The disruption caused by the changes would risk some airport-dependent businesses relocating overseas rather than within the south east, particularly given the limited space available adjacent to the proposed Estuary Airport. Similarly, due to the dense urban population and limited land availability along Thames Gateway South Essex, the area would not be accrue the benefits of a hub airport as seen along the M4 corridor when Heathrow was built and ample space was available.

Conclusion

If the UK is to remain competitive, then realistic options need to be considered. There is no doubt that hard, challenging, decisions will need to be made, but it would be advisable not to waste scarce resources and create decades of uncertainty by signaling that there is continued merit in developing the estuary airport proposals.

Future planning of airport and other related development should be based upon as much certainty as possible given the long lead in times and scale of investment involved. Building confidence in the business community and attracting investment is a key role for local authorities who are responsible for delivering the Local Development Documents and have significant experience in bringing forward well planned and achievable airport developments and managing the environmental consequences as far as possible within existing legislation.

For example, consistency between Airport Surface Access Strategies (ASAS) and Airport Masterplans is vital, particularly where new passenger transport services require financial backing both to start and for promotion. The ASAS can provide the strategy for investment where the airport operator is willing to make the necessary contribution.

In preparing Local Plans, Local Authorities are required to have regard to the emerging Aviation Policy Framework and aviation capacity policies and strategies. It is therefore imperative that there is consistency between the long-term policy framework for aviation and the National Planning Policy Framework (NPPF). It is also imperative that NPPF is adequate for the purpose of implementing high quality planning determinations.

For example, airport developers must be required to meet the costs of transport improvements in a proportionate manner related to the numbers of airport-related trips compared with other trips and also consistent with other developers, and note that airports are transport operators within their own right, and not simply a commercial development. In the case of Southend Airport, an investment of £16 million in a rail station, as well as support for other transport facilities and service, should be recognised.

In summary, the following points are key to understanding the case for not considering an estuary airport proposal:

· Loss of Heathrow, which would most likely be required to close with the loss of over 100,000 jobs;

· Loss of employment in Southend either directly or indirectly related to London Southend Airport, with no evidence to suggest that this would be replaced with other opportunities

· the proposals put forward within the SELEP Parson Brinkerhoff for both short, medium and long term solutions must be considered, including expansion at Heathrow, a system of allocating slots based upon an economic case and utilising spare capacity;

· Lifting of artificial planning restrictions and government intervention could increase capacity for a period of between five and ten years.

As the debate intensifies, the number of options appears to be increasing. In September 2012, a proposal for "London Britannia Airport", designed by architects Gensler, includes four floating runways tethered to the sea bed. The architect said the design allowed for future expansion to accommodate six runways when required.

Recently, consultant Beckett Rankine has announced a vision for a high capacity hub airport on the Goodwin Sands, 3km off the east Kent coast at Deal. This together with the London mayor announcing Stansted Airport plus a fourth unamed site would be included alongside the existing Thames Hub and "Boris Island" proposals into his £3m study into the feasibility of a new estuary airport.

The Parsons Brinckerhof report concluded that:-

A new hub airport – we believe that this could only be located in the greater SE, probably within the Thames Estuary; whilst this is a grand and ambitious scheme we do not believe that it is a viable solution to the capacity issues facing the SE.

In any event, it is clear that, despite the growing number of ideas being presented, the proposals to build an airport in the Thames Estuary are not practical, well thought through or in any sense deliverable.

4 January 2013

Prepared 16th January 2013