Transport CommitteeWritten evidence from NATS (AS 51)
1. Introduction
1.1 NATS is the UK’s leading provider of air traffic management (ATM) services. NATS is licensed by the Civil Aviation Authority (CAA) as the monopoly provider of en-route air traffic services in the UK and the eastern North Atlantic. NATS also provides air traffic services at 15 UK airports through commercial contracts.
1.2 Airspace is a pillar of the UK’s transport infrastructure—airports don’t work without it. NATS seeks the most efficient use of airspace to maximise its use (capacity), minimise delay, minimise environmental impact (noise and CO2 emissions) and maximise flight efficiency (less fuel burn) while maintaining a high standard of safety. More efficient use of airspace and more efficient flights can help reduce the environmental impact to enable sustainable growth.
1.3 In 2011–12 NATS handled more than 2.2 million flights in UK airspace. This equates to around 6,000 flights per day, some 4,000 of them to and from the five main London airports, making the airspace in the south-east the most complex in the world.
1.4 NATS is also responsible for designing and implementing airspace changes, subject to CAA approval.
1.5 Airports have historically expanded without strategic oversight or consideration of the airspace network. NATS has had to design and manage airspace on a reactive and incremental basis. This has had particular impact on the crowded airspace over the London airports.
1.6 The Civil Aviation Authority (CAA), together with the DfT, MOD and NATS has developed the Future Airspace Strategy (FAS) to provide the safest and most efficient airspace possible, aligned with European developments and technological changes, reducing the impact of aviation on the environment and balancing the needs of all airspace users. NATS fully espouses these aims.
1.7 Airspace should, therefore, be at the heart of the Government’s Aviation Policy Framework (APF), currently out in draft form for consultation. Fundamental changes to the UK airspace structure are a cornerstone of the FAS and while we note the Government’s support for the strategy in the draft APF, we would like to see more emphasis to underline its importance in achieving Government aims for the sustainable development of the aviation sector.
1.8 NATS is currently in the early stages of developing the airspace design which will deliver our part of the FAS through two major design programmes in the north and the south of England; clear environmental parameters within the APF are crucial to that work.
1.9 Getting the environmental parameters for the APF right is, in our view, critical to future development through the FAS. Clarity, stability and predictability in the policy framework are clearly vital in underpinning the integrity of any future airspace change proposals.
1.10 With this kind of assurance, NATS can deliver benefits in line with Government ambitions, wherever the Government decides further airport capacity should be provided. Such assurance, though, is necessary because of the level of investment required in a period of uncertain economic strength and within the context of a new regulatory framework for ATM in Europe which has the potential to limit NATS’ ability to deliver tangible benefits in the future.
1.11 NATS has unrivalled environmental credentials in establishing and managing innovative solutions to the environmental impacts of ATM; NATS was the first ATM provider to set targets for reducing CO2 emissions for aircraft under our control. We were also the first ATM provider in the world to devise a metric for measuring our environmental performance; this was introduced as part of our regulatory mechanism at the start of 2012 and we hope will provide a model for the rest of Europe and, potentially, further afield.
1.12 Government consultation on draft Aviation Policy Framework: NATS’ response to this consultation focuses on the importance of clear guidance from Government, particularly with respect to environmental parameters, to enable best practice airspace management and design, and ATM procedures.
1.13 The document specifically acknowledges (Para 1.23) the importance of airspace and the FAS to enable sustainable growth and we very much welcome that.
1.14 The Davies Commission: NATS welcomes the establishment of the independent Davies Commission to investigate options for ensuring appropriate hub capacity to support economic growth and to assure the UK’s position as a leading global trading centre; and the intention that its interim report in 2013 will address interim measures to address the south east airspace capacity pending development of future hub strategy.
1.15 The DfT has made it clear that the Commission will need to wait until the APF is published in its final form before it is able to make its own recommendations on hub capacity. NATS is also keen that while the APF must establish a clear framework and guidelines, it should be sufficiently flexible to accommodate various options for future change that may be recommended by the Davies Commission.
In response to the Committee’s specific questions, NATS offers the following answers:
2. What should be the objectives of Government policy on aviation?
(a) How important is international aviation connectivity to the UK aviation industry?
(b) What are the benefits of aviation to the UK economy?
(c) What is the impact of Air Passenger Duty on the aviation industry?
(d) How should improving the passenger experience be reflected in the Government’s aviation strategy?
(e) Where does aviation fit in the overall transport strategy?
2.1 NATS answers: As an island nation and global trade hub, aviation is critical to the economic wellbeing of the UK. It is key to enabling UK economic growth. Acknowledging these benefits also means addressing its negative environmental impacts. NATS therefore supports the Government’s objective of a sustainable framework to enable aviation to grow by reducing its environmental impact.
2.2 Airspace is too often the forgotten factor in considering how aviation can develop; yet it is as important as the ground infrastructure. Airports don’t work without it.
3. How should we make the best use of existing aviation capacity?
(a) How do we make the best use of existing London airport capacity? Are the Government’s current measures sufficient? What more could be done to improve passenger experience and airport resilience?
(b) Does the Government’s current strategy make the best use of existing capacity at airports outside the south east? How could this be improved?
(c) How can surface access to airports be improved?
3.1 NATS answers: NATS fully supports the principle of making better use of existing airport capacity. It is cheaper, quicker and more efficient than seeking brand new solutions and is a basic requirement for an interim solution before any long term solution arising from the Davies Commission can be delivered.
3.2 Airspace changes in the medium term (to 2020) are a cornerstone of the FAS that will both improve performance and enable sustainable growth. NATS has developed a world-leading capability in making maximum use of constrained runway capacity in south-east England, but the full benefits of what could be delivered will only be realised through the infrastructure developments that will be considered by the Davies Commission.
3.3 NATS has fully supported, and committed considerable resource to, the trial of operational freedoms at Heathrow with the view to improving resilience in the short term and to supporting sustainable development in line with the FAS objectives.
4. What constraints are there on increasing UK aviation capacity?
(a) Are the Government’s proposals to manage the impact of aviation on the local environment sufficient, particularly in terms of reducing the impact of noise on local residents?
(b) Will the Government’s proposals help reduce carbon emissions and manage the impact of aviation on climate change? How can aviation be made more sustainable?
(c) What is the relationship between the Government’s strategy and EU aviation policies?
4.1 NATS answers: An accepted balance of benefits is key to delivering successful airspace development, and achieving this balance means gauging their relative importance to a range of stakeholders.
4.2 For example, avoiding noise over a populated area will often involve lengthening a route to go around it, resulting in higher fuel burn and increased CO2 emissions (much like a ring road around a town will always be longer than a straight road through it).
4.3 Consultation is an important means of assessing the relative importance of different impacts among a variety of stakeholders. It is also expensive and, in order to assure value for money and certainty for those people in the consultation areas, we need to know that our changes can be for the long term. Consultation only happens once there is a design on which to consult, so it is important to have clarity around relative priorities; the Government is currently reviewing its 2002 Environmental Guidance which we hope will provide this.
4.4 NATS supports the overriding principle of promoting emissions reduction internationally through EU ETS and technological developments in aircraft and airspace performance. It is only through international cooperation that we will achieve a global reduction in emissions.
4.5 The draft APF states that the Government will decide later this year whether or not it accepts the Climate Change Committee’s advice that all the UK’s aviation emissions (ie including emissions from international aviation) should be included in the UK’s national carbon budgets. While not expressing a view on this issue, NATS considers that the Government’s decision could impact on the relative importance of the different environmental objectives (ie noise and emissions) for the UK’s airspace. For example, if the Government accepts the CCC’s advice to include international aviation (which accounts for some 90% of the UK’s total aviation emissions) this would mean a significant increase in the relative contribution of aviation compared to other industries in the UK’s national carbon budget. This might therefore increase the emphasis the Government wishes to put on mechanisms to reduce emissions/climate change effects presented in the APF.
4.6 NATS strongly believes that at a national level the Government should set very clear direction in supporting the development of national airspace infrastructure, which has a major role in delivering CO2 reduction (as well as offering potential benefits in terms of safety, capacity and noise).
4.7 The FAS Deployment Plan will realise climate change benefits through major redevelopment of parts of the route network (in particular the South East and Manchester areas). An enabler for this redevelopment is the upgrade of all existing airspace structures to utilise modern RNAV navigation standards.
4.8 Sustainable Aviation (SA) Noise Roadmap: National initiatives still, however, have a place in the drive for CO2 efficiency and they need to be encouraged, incentivised (eg through sponsorship for research) and acknowledged. NATS is a founder member of Sustainable Aviation (SA), a unique cross-sector initiative to identify how ATM, aerospace, airports and airlines can work together to achieve efficiencies.
4.9 SA’s CO2 Roadmap, setting out the long term strategy of the aviation industry to drive down carbon emissions out to 2050, has been well received by stakeholders including Government, recognizing that this is a robust cross-industry approach to producing workable and deliverable solutions. SA has subsequently decided to develop a similar Noise Roadmap to define the industry’s view of the future noise environment around airports out to 2050.
4.10 This project began in Spring 2012 led by NATS with support from airports, airlines and aerospace manufacturers, addressing potential improvements in noise across five workstreams—technology, operational improvements, operating restrictions, communication and community engagement and land use planning. The Roadmap is still in development and expected to be published early in 2013 in time to inform the Government’s final APF document.
4.11 With the appropriate enabling measures provided through the APF, the FAS can deliver sustainable improvements in the ATM system that are consistent with both the objectives of the APF, and the need to modernise ATM in line with developments in Europe under the Single European Sky programme, and specifically the technology R&D programme (SESAR) and its subsequent deployment.
5. 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?
(b) What are the costs and benefits of these different ways to increase UK aviation capacity?
5.1 NATS answers: We welcome the Government’s decision to appoint an Independent Commission, with cross-party support, to consider how to ensure the UK retains international hub status and connectivity. Airports don’t work without the airspace to support them, so it is crucial that the Davies Commission keeps airspace at the core of its work. We will play a full part in supporting it.
5.2 Runway capacity in the south east is currently insufficient to support demand. Additional runway capacity is required to promote hub connectivity, allow room for growth and improve operational resilience.
5.3 Doing this is feasible, albeit challenging, given the complex airspace interactions between a large number of airports within a small geographical area; and the very dense population in the region.
5.4 Adding another 4-runway airport would have various implications, including impact on other airports in the area; it would also require entirely new flight paths, some of them at low level—not only affecting people in the vicinity of the new airport, but also those living under flight paths to/from other London airports, which would also be likely to have to change. This would obviously require significant consultation with local communities.
5.5 NATS has unrivalled expertise in safe and efficient airspace design and management and wherever the Davies Commission recommends providing additional new runway capacity, NATS can build the supporting airspace infrastructure.
19 October 2012