Aviation Strategy

Written evidence from GATCOM (AS 49)

GATCOM (Gatwick Airport Consultative Committee) welcomes the opportunity to respond to the Transport Committee’s inquiry into airport capacity in the UK.

GATCOM is the statutory advisory body for Gatwick Airport and comprises representatives from local authorities, the aviation industry, passengers, business, environmental interests and other users of the airport. We provide a forum for informed discussion leading to the provision of advice to the Government, Gatwick Airport Ltd and other organisations on a range of matters concerning the operation and future development of Gatwick.

Given the broad range of interests represented on GATCOM, it is not possible for the Committee to comment on all the questions posed in your call for evidence because there is a diverse mix of views.

Government’s objectives on aviation policy

GATCOM supports the Government’s stated objective that UK aviation shoul d be able to grow, but to do so it must be able to play its part in delivering environmental goals and protecting the quality of life of local communities.

The real issue in considering a long term strategy for aviation is to strike a balance between the economic benefits of meeting demand and the needs of the industry with the impact this has on local communities and the environment. It is essential that airports work in harmony with the local communities around them.

Connectivity

As an island nation, UK airports have a critical role to play in the transport of people and goods . GATCOM recognises the importance of connectivity and its key role in helping the UK economy grow on a sustainable basis. Aviation is one of the UK’s success stories with world leading airlines and airports with the UK being seen as a key destination for existing and new airlines.

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The importance of the UK position in international aviation is recognised and there is a role for government working as a partner with the industry to safeguard national interests in the face of growing competition from Europe. The objective must be to maintain a prominent position in the international market, but not necessarily the dominant one that it has enjoyed in the past. It must be recognised that without good connectivity the UK will become removed from global markets and jobs will be lost. A core objective of the Government should be to make a positive choice for a global hub in the UK complemented by greater interlining between the regional hubs. This would help the UK to compete with other European airports and support economic growth in the UK. The current delay by the Government in agreeing a new policy creates uncertainty for all interests.

GATCOM agrees with the description of connectivity, and the value of connectivity, as presented in paragraph 2.14 of the Draft Aviation Policy Framework. The Government’s objective of making the UK, through its air links, one of the best-connected countries in the world is supported. GATCOM believes this can be achieved by encouraging better utilisation of existing runway capacity in the short to medium term supported by improved surface connections, particularly high speed rail links between regions and dedicated airport express services. In parallel there should be a more stringent night flights regime to encourage the use of the quietest aircraft during the night period.

Flexibility should be incorporated into any future approach to exploit the benefits of technological advances and changes to global resources/government priorities. The industry is committed to reducing aircraft and airport emissions and noise impacts and technological advances are being developed but it will take time for the benefits to be realised. Measures to further incentivise airlines to invest in new fuel efficient, "cleaner" aircraft could be achieved through the implementation of greater differentials in the structure of landing charges at airports but it is acknowledged that this would be controversial particularly in the current economic climate.

Surface Access

Gatwick has a strong performance in surface access provision but there are a number of barriers that need to be overcome. If best use is to be made of existing capacity at airports, co-coordinated action and investment by the Government is needed so as to encourage a greater number of passengers and airport workers to access the airport by public transport.

The rail network will help to meet domestic passengers’ requirements but it is important that rail links to airports are extended and improved through better rolling stock designed for the needs of the airline passenger. The importance of rolling stock design for rail services serving airports should be recognised in the Aviation Policy Framework building on the references made in the Government’s Rail Command Paper issued last year. Air passengers have unique requirements, which differ from commuters and other rail passengers, as they are often carrying baggage in a foreign country on part of a longer journey. GATCOM believes that in order to integrate airports more successfully into the wider transport network, rail services to airports should seek to meet the needs of air passengers by providing step-free access, wide doors, large luggage racks and information displays.

In addition to Local Enterprise Partnerships, airports should be encouraged to engage actively with new Local Transport Bodies to ensure that, where possible, transport investment supports airport growth plans and the integration of investment and services.

As an international gateway with around 33 million passengers annually, Gatwick is London’s best connected airport by rail. The airport rail station has around 900 trains arriving and departing each day and serves over 12 million rail users annually; making it one of the busiest rail stations in the UK. The scale of demand for surface access to and from the airport is growing. Over 10 million journeys are made by people who work on the airport campus every year. There are also a significant number of journeys made by suppliers and service providers. Gatwick is well connected to the motorway network via the M23 and M25 although there is growing concern about the capacity of the motorway network being able to accommodate further growth.

Improving surface access is an integral part of the sustainable growth of the airport. Effective, efficient and resilient surface access to the airport benefits not just passengers but also the local community and helps to manage the airport’s overall environmental impact. Rail is the largest single mode of passenger access to and from Gatwick and there is strong evidence that this demand will continue to grow in the future. However, there is limited capacity on the London to Brighton main line which prevents additional services being introduced to support demand on the part of air passengers. This is a major barrier to the effective provision of rail services to a major airport.

Due to limited capacity, the dedicated Gatwick Express service has effectively been removed in peak hours and turned into a commuter service to Brighton. This has obvious implications in terms of the quality of rail provision to and from the airport. Ticket gates have also been introduced at Gatwick this year by the train operating company as part of its franchise agreement with the DfT, which has also further diminished the premium Gatwick Express service as the purchase of tickets on board the train and the removal of train staff to assist air passengers have been lost and has exacerbated queuing for tickets on the station’s concourse.

In addition, the level of direct connectivity between Gatwick and both the local and national rail networks has declined substantially in recent years. Locally, rail access to the east and west of Gatwick is a challenge. The loss of a direct link to Kent is of particular concern both to passengers and the local community, as Gatwick Station is a regional rail hub.

The long-awaited upgrade to Gatwick Station, with an additional Platform 7, is underway. However, the station concourse will continue to have limited capacity for passenger growth even after the current enhancement project. If Gatwick’s status as a major international gateway is to be maintained, and the overall passenger experience is to continue to be enhanced, improvement work to the station should be on-going rather than subject to a near thirty-year interval, as was the case until mid-2010.

As regards the Strategic Road Network, Gatwick is located close to very congested parts of the motorway network; the south-west quadrant of the M25 motorway and the M23. Safe, reliable and resilient access to Gatwick, given its significant international gateway status, is economically and operationally critical. There is a need to expedite the introduction of active traffic management and selected hard shoulder running schemes on key sections of motorway to support reliable access to Gatwick.

In terms of encouraging a shift from air to rail, there are three key criteria to help decision making when balancing alternative modes of transport.

Pricing structures need to change due to the fact that environmentally it is not sustainable to continue to fly short distances therefore prices need to reflect this. Rising oil prices are also likely to be a contributing factor; however governmental ‘pressure’ in the form of general taxation and further investment in the rail network will also be required.

Noise and other local environmental impacts

GATCOM supports the establishment of effective noise management regimes and the majority of members believe that the current noise limits are in need of review.

In terms of addressing the issue of aircraft noise and disturbance, on balance GATCOM believes that it is probably preferable to minimise the total number of people affected by aircraft noise through the use of noise preferential routes, as additional design features could be used in these areas to minimise the direct impacts where possible, for example the use of treble glazing in existing and new housing. This approach is likely to make it easier to identify areas affected and adequately plan suitable land uses or incorporate mitigation measures to minimise disturbance.

There are however impacts flowing from the introduction of new technological advances such the use of direct routeing/PRNAV. As navigational accuracy has improved, what was a relatively wide swathe of aircraft trajectories has increasingly narrowed. This has resulted in fewer people being overflown but an increasing number of overflights for a specific number of people, causing disturbance and distress. The increased navigational accuracy through the implementation of PRNAV will exacerbate this situation. The majority of direct routeing flight paths are expected to be at high level for the foreseeable future with little impact on those on the ground. However, longer term developments indicate a possibility that these routes could be lower, and closer to airports, and so result in aircraft overflight of people who have not previously been overflown and who may have purchased their house following research into existing flight paths.

GATCOM would like to see further research into the potential of greater dispersal within existing noise preferential route swathes and arrival paths so as to share more evenly the burden amongst those already suffering disturbance.

Noise disturbance from aircraft arriving at Gatwick, particularly from areas further away from the airport, is an area of growing concern amongst local communities around Gatwick. The main noise abatement measure identified for arrivals is set out in the Code of Practice for Continuous Descent Approach (CDA). In addition to aiding noise reduction, CDA also reduces fuel burn thereby cutting emissions and producing an overall environmental benefit. GATCOM supports the use of CDA because of the overall environmental benefits achieved but in view of the disturbance still suffered by those local communities under the arrivals flight paths further away from the airport, we would like the Government to consider whether the use of steeper approaches could feature in the Code.

It is recognised that implementing steeper approaches at Gatwick could be problematic because it is an international airport and the ICAO international standard is for a 3º approach. Nonetheless GATCOM would welcome studies to determine whether there are possibilities available. Even a slight increase in the steepness of approach would result in aircraft being higher for longer and thus help reduce the noise impact.

Noise Action Plans also have a key role in predicting and demonstrating an actual reduction in noise levels. To give local communities confidence that action is being taken to reduce the noise impact around airports, there is a need to demonstrate hard results, not just be a list of ‘soft undertakings’.

Resilience

Gatwick is the busiest single runway commercial airport in the world. Air traffic control does a skilful job in scheduling take-offs and landings at the shortest possible intervals, allowing for the differing wake vortices created by different types of aircraft. But inevitably this system is not resilient, and the minor disruption as a result of adverse weather or other incidents can result in delays. When delays occur, aircraft are required to fly elongated approach paths or to stack, causing increased noise and climate change damage. One solution could be direct routing as described in the CAA’s Future Airspace Strategy. Another would be to place a limit on the number of flights scheduled to use the runway in any one hour. However this would be highly contentious and could reduce capacity further.

Regulation could have a role in minimising delays and ensuring the airfield and airspace is used as efficiently as possible. The CAA’s congestion delay term at Heathrow and Gatwick does focus the airports’ attention on making best use of the airfield infrastructure and resilience planning is key to ensure that disruption is handled efficiently and delays kept to a minimum.

The experience of resilience planning at Gatwick during the severe winter weather conditions in 2010/11 was that it worked well and lessons learned have been taken forward. Aviation is an integral part of the UK’s transport infrastructure and other transport modes also need to be as resilient.

Improved resilience at airports is also reliant on punctual and efficient surface transport and inter-modal connectivity. The severe winter weather conditions in 2010/11 saw surface access networks around Gatwick recover at a slower pace than the airport resulting in airport staff and passengers not being able to access the airport. This had implications for flight schedules outside the control of airports and airlines.

Improving the Passenger Experience

The Government’s proposals to extend the Fifth Freedoms policy is supported in principle provided there are conditions put in place so as to ensure that competition for UK based airlines is not hampered or distorted, as it will provide greater choice for passengers using the South East airports. Preserving and improving the passenger experience at airports should be one of the key themes of the new aviation policy to complement the new powers being given to the CAA in the Civil Aviation Bill which places the passenger at the heart of airports regulation. It needs to take into account the end to end journey experience for air passengers.

The passenger experience would also be enhanced by the Aviation Policy Framework looking in more depth at the spread of destinations for all the main London Airports to ensure less travelling time and congestion on the M25.  If this is not commercially viable, the new policy needs to ensure that public transport links between the main London airports are far more robust for the full range of passengers and not reliant on coaches (which add to the M25 congestion) and London Underground trains (which have had funding plans for wider accessibility withdrawn). 

Capacity planning should concentrate more on passengers end to end journeys and alternatives to car travel in spreading capacity loadings.  Contingency planning should be written into all plans to include disruptions of all types including weather, traffic and the changing spread of the passenger population between business, leisure, families and PRM’s.  More research should be done with passengers about their transport interchange needs with a ‘business case’ attitude on flight delays etc. perhaps involving mystery shopping as well as questionnaires which usually only show a snapshot of experience.

Working together

GATCOM welcomes the Government’s endorsement of the valuable role played by the airport consultative committees (ACCs) in the draft Policy Framework and agrees that there is a need to update the existing guidance for ACCs in view of the fact that the role of ACCs is now far wider than in 2002 when the guidelines were last updated. GATCOM has and will continue to work with the DfT and the CAA in reviewing best practice in the way we work and will fully participate in the review of the DfT’s guidelines for ACCs. GATCOM would however urge the Government to ensure that the guidelines continue to be non-prescriptive and flexible as what works well for one ACC might not be appropriate for another. It is therefore important that there should be sufficient flexibility in the reviewed guidance to reflect the variations between airports and smaller aerodromes.

19 October 2012