Transport CommitteeSupplementary written evidence from Airport Operators Association (AS 91A)


General Points

1. Aviation is a hugely important sector for UK Plc, adding some £50 billion (around 3.6% of GDP) a year to the economy and supporting around one million jobs. Not only is it an important industry in its own right, facilitating jobs, business growth, travel connectivity, the goods and services that people need more widely, and tax revenues to the Exchequer, it can also enable the kind of high-value export-led recovery the Government is keen to promote. For example, some 40% (by value) of the UK’s exports go by air, whilst express freight creates about £1 billion of economic value and employs around 40,000 people directly.

2. The Airport Operators Association (AOA) has called on the Government to introduce a policy regime which promotes growth in the aviation sector, ensures the sector remains globally competitive and provides both world-class hub capacity and adequate point-to-point connectivity. One of the areas which we believe can impact further airport growth is Red Tape and Regulation.

3. The AOA has supported steps which the Government has taken since May 2010 to reduce the regulatory burden impacting UK businesses, including airports. We responded to the Aviation section of the Red Tape Challenge in 2012 and have expressed support for policies such as the New Planning Policy Framework. On the latter, we were encouraged that the document signals to Local Authorities (LAs) that their default position should be to approve development, unless there is a compelling reason not to, as well as the fact that in future LAs will be offered incentives to establish local plans. We believe this leaves little doubt that the Government wants developers to get on with the business of providing infrastructure, and we urge Ministers to press for these principles to be translated into practice by LAs and actively monitor delivery on the ground.

4. We support other measures aimed at streamlining the planning system, in particular Clause 4 of the Growth and Infrastructure Bill, which would introduce a new provision into section 62 of the Town and Country Planning Act 1990 to limit the Local Planning Authority’s power to require information with planning applications. Previously, we have expressed our belief that information requirements should be set largely at a national level with key tests for additional information requirements beyond that. This will ensure consistency and certainty for developers across geographical areas and reduce local regulatory burdens.

5. We also support Government efforts to reduce and simplify planning practice guidance through the Taylor Review, and we urge Ministers to make an early decision on implementing Lord Taylor’s recommendations as soon as possible following the consultation’s close.

6. However, we continue to have strong concerns about the Government’s actual record on reducing the impact of Red Tape and Regulation since May 2010.

7. In October 2012, we conducted a comprehensive analysis of the impact of individual regulations on our airport members since May 2010. This looked at every regulation listed on Government Statements of New Regulation (SONR) as they impacted UK airports. Their cost to airports was then assessed by using Government data provided on Impact Assessments. New legislation was also assessed, where possible in the form of the “Final” Impact Assessment, but where the legislation was still making its way through the legislative process, the “Consultation” IA’s were used.

8. The study concluded that, despite the Government’s public commitment to reducing the regulatory burden, the net impact of regulation on airports since May 2010 has actually been a COST. It found the following:

There is a net cost in the transitional stage (£-3.04 million) and a net COST annually (-£67.46 million);

The Department for Transport has done little to ease the regulatory burden on airports;

Aviation has been affected by other Government departments, at a net COST;

Planning regulation and policy has the single biggest impact on airports; it is a net COST.

9. Major costs which impact airports include the EU Workers Directive, due to the unique nature of airports in their need for large numbers of short-term staff; the introduction of a cap on Tier 1 and 2 migration numbers; the introduction of the Community Infrastructure Levy; the introduction of compulsory pre-application consultation by developers; and the decentralisation of planning application fees to LAs.

10. The AOA conducted a separate study in 2010 (updated in 2011) which analysed the economic impact of individual Government regulations at a single member airport, in this instance Luton Airport. It found that the cost of complying with these regulations was equal to 14.7% of annual controllable costs.

11. Bristol Airport, in evidence provided to the House of Commons Transport Select Committee last year, concluded that the cost of complying with individual regulations (including Civil Aviation Authority (CAA) costs and the costs of policing and security), has increased from £2,693,174 in 2008 to £4,399,688 in 2012. This is despite the fact that passenger numbers over the same period have decreased by 2.5%.

12. The AOA has very strong concerns about the ever rising costs of producing Environmental Impact Assessments (EIAs). We are opposed to the increasing tendency for EIAs to be asked for as a matter of course, even for very modest developments, within existing operational and well established airports. This adds a further burden of time, cost and delay. Last year we collated evidence from eight airports which range in size from major airports to small general aviation airfields which showed that for EIAs alone, the costs of compliance range from around £35,000 to £250,000. The developments range from car park development through to an application for a new terminal building, but none are unusual in their type, scale or impact. All are within the airport boundaries, and most will be in line with adopted policy and the agreed Masterplan for the airport.

13. We believe this represents clear evidence of the increasingly risk averse approach of LAs; the urgent need for clear advice from Government that EIAs should be the exception, and only required where there are likely to be “significant environmental effects in the proper context of the original EU Directive.

14. Our members also report an increasing tendency for screening requests, which can also add cost, time and delay. Our survey shows the average cost of these alone to be up to £20,000 and before any other application costs are incurred. Yet the Department for Communities and Local Government (DCLG) only quote a figure of £18–25,000 as the total cost of a major application. It has therefore seriously under-estimated the scale of benefit arising from reform measures. For information, we have also included indicative costs for the preparation of Transport Assessments for which costs are also often over £20,000.

15. These examples show that Ministers’ drive for simplification is still being frustrated by the culture and practices of LAs. Without action on these areas, procedural reform alone will not be enough to deliver the Government’s wider growth agenda.


16. The Government needs to take account of the cumulative impacts of regulation on sectors like aviation. Without a concerted attempt to work across Government Departments airports continue to be affected by many different types of regulation that impose large costs. This conclusion supports the AOA’s call for a Joint Taskforce to be set up to tackle Red Tape and Regulation as it impacts aviation.

14 February 2013

Prepared 31st May 2013