Aviation Strategy

Written evidence from the UK Airport Consultative Committees Liaison Group (AS 85)

The Liaison Group for UK Airport Consultative Committees (UKACCs) welcomes the opportunity to respond to the Transport Select Committee’s current inquiry which seeks to examine the Government's aviation strategy and in particular airport capacity in the UK.

UKACCs brings together 23 airport consultative committees (ACCs), ranging from major international gateways to smaller regional airports across the UK (member committees listed at the bottom of this letter), fulfilling the statutory role required by government that airports should provide consultative facilities. The 2010 CAA airport statistics record that these 23 airports had a total annual throughput of over 203 million passengers accounting for about 96% of total UK passenger movements of 211 million. UKACCs provides a valuable forum as its membership covers a wide range of airports each with different local operational circumstances. As such UKACCs can play an important role in helping inform government in policy development.

As the Committee will be aware, there are a number of key aviation related Government consultations either under way or planned. These include the Government’s consultation on its draft aviation policy framework, the Independent Commission chaired by Sir Howard Davies and proposals for a new night noise consultation at Heathrow, Gatwick and Stansted. UKACCs, as well as individual consultative committees, will be responding to these consultations reflecting particular local circumstances and issues.

UKACCs supports the Government’s stated objective that UK aviation should 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 Group also endorses the three proposed key themes that should underpin a future high-level framework - Aviation and the Economy; Aviation and Climate Change and Aviation and the Local Environment.

UKACCs fully recognises the importance of connectivity and its key role in helping the UK economy grow on a sustainable basis. Airports outside the South East have a vital role in providing international and domestic connections across the UK, and contributing to local economies. The Group has welcomed the Government’s stated wish to explore how to create the right conditions for such airports to flourish.

UKACCs has long lobbied the Government to address the issue of protecting domestic services from the far regions of the UK into the London airports. The Group has regularly highlighted that there is an urgent need to review the worsening situation. In addition to this, there has been growing concern about the increase in landing charges at Heathrow and Gatwick airports which has resulted in some regional carriers withdrawing services between the regions and the London airports because a viable operation can no longer be sustained.

UKACCs - particularly its regional airport member committees - continues to have real concerns about the negative impact of capacity constraints. In particular the major London airports have seen a steady reduction in point to point regional services. The crowding out of regional services from the capacity constrained London airports is continuing to have an adverse impact on the economic performance of the far regions of the UK and so affect their contribution to the national economy.

Faced with capacity constraints, the major airports appear to be prioritising long haul international services over regional services. Whilst it is clearly open to airports to use their commercial judgement in the best interests of the airport company and its shareholders, such action clearly has wider national and regional implications. Passengers using regional airports faced with limited services to Heathrow will look to interline over European hubs such as Schiphol, Frankfurt and Paris etc. This leads to dilution and loss of revenue to the UK economy.

UKACCs has been keeping a watching brief on the CAA’s consultation investigating the complaint made by Flybe against Gatwick Airport (GAL) about the change in the structure of landing charges. Flybe have maintained the new structure of charges discriminates against operators of small aircraft. It also believes that the new charges will have a detrimental impact on point-to-point regional services to London because airlines using small aircraft are less able to absorb higher costs. The CAA has reached a provisional decision that GAL has not unreasonably discriminated against any particular user of the airport or class of users (whether airline or passenger). This case has raised important issues and UKACCs therefore suggests that the Committee might wish to consider the implications for capacity constraints at the London airports on services to the far regions of the UK.

The Group notes that the Government has suggested that demand for domestic aviation and much of that for near-European short-haul aviation could be met by high-speed rail although it also acknowledges that air transport will continue to provide essential links to more remote parts of the UK and areas not served by high speed rail. UKACCs welcome the development of high-speed rail initiatives and the important contribution that these can make to the future UK transport network. However it must be accepted that high speed rail connectivity will not be delivered for many years and that domestic air travel is a reality. The Government therefore needs to preserve domestic air travel as an essential part of the UK’s strategic transport infrastructure for many years to come.

It needs to be recognised that whilst new high-speed rail connections will provide an opportunity to replace existing domestic air services for some regions especially the Midlands and the North, it will not provide a total solution across the UK. There will be a time threshold where rail does not provide a viable option especially for the Scottish airports, and never can to Northern Ireland, the Channel Islands or the Isle of Man. There will still be a requirement for domestic services from these areas if the Government’s wish that there should continue to be essential air links to the more remote parts of the UK is met. It must also be recognised that neither Gatwick nor Stansted airports will have a direct connection to the high speed rail network and a connection at Heathrow will only be realised in around 20 years time.

UKACCs will continue to urge Government to review its policy towards domestic air services to ensure the future viability of an effective network. UKACCs accept that the preservation of an effective domestic network is subject to a number of considerations including commercial interests and EU obligations. UKACCs has been encouraged to note that the current airport slots regulations are now being reviewed in the EU. The Group hopes that this will lead to a mechanism that might protect domestic access to the London airports. UKACCs will also be asking the Government to consider the appropriateness of the current PSO legislation and decide whether it remains fit for purpose. If the UK is to have a sustainable domestic network of air services, it would seem essential that slot allocation must be looked at in a different way.

22 October 2012

Prepared 12th November 2012