Transport CommitteeWritten evidence from IAAG (AS 22)


1. What should be the objectives of government policy on aviation?

(a) Connectivity

This can be defined as providing an infrastructure of land sea and air routes from all parts of the UK to major overseas destinations, important for:

1. Maintaining and developing British commercial and trading interests with developed and developing world

2. Maintaining links with British and related communities in the commonwealth, other major countries i.e USA & Argentina

3. Encouraging the correction of trading deficits and tourism imbalances by providing connection and connectivity from these markets into the UK. Providing links from other domestic points for discretionary low cost travel is of less relative importance. Connectivity from and into UK is therefore not ideal when defined as non-stop direct services to these destinations

However due to the inability by BA to mount additional profitable capacity and the congested nature of LHR, connectivity is increasingly provided by non-British air carriers operating from all parts of the UK through their superior hubs to all important international points of origin and destination. This is becoming an irreversible trend and is outlined in more detail in other sections of our papers.

In overall terms connectivity is well provided to the UK especially in connecting services through European and Middle East and Far Eastern hubs (altogether 8 hubs and 8 high quality and aggressive and expanding hub carriers. This is at the expense of British aviation interests but not necessarily of British consumers nor overseas visitors. More later on this key subject.

(b) Benefits to the UK economy

A strong high quality aviation sector is important to the British economy in:

1. Preserving the notion of the UK’s centrality in world financial markets

2. Preserving the UK’s reputation for incoming tourist and VFR traffic.

3. Maintaining and enhancing the UK’s reputation worldwide as a place to do business and base executives, families & investors.

Unfortunately the UK has lost its leadership position in these aspects.

It has lost its centrality because of the low quality experience of Heathrow, difficulties of efficient connecting service networks and the apparent absence of purpose in developing a satisfactory air travel experience through major airports to/from ultimate destinations.

(c) APD

Has rendered air travel more expensive than UK’s major competitors. It is shrinking demand and encouraging passengers to connect through European points where there is much less or no APD equivalent.

Demand management is a dirty word and is seriously disadvantaging UK aviation and crippling demand.

Baby and bathwater come to mind whereby by attempting to reduce highly price sensitive traffic to holiday destinations by LCC (Low Cost Carriers) it is forcing business and VFR traffic to seek non-British carrier solutions via European points. Even, however a UK carriers are participating in this feeder services ie FlyBe and easyJet by special prorate agreements with foreign carriers.

(d) Improving the Passenger Experience

This is a key component and centres around two subjects:

1. Delays inbound and outbound at Heathrow, unacceptably high and persistent. This seriously impacting the desirability of using the Heathrow “hub”

2. Inefficient and eccentric quality levels of ground services.

IAAG has a detailed plan already published as to how to transform these manifest shortcomings.

Please see below how these problems can be resolved in the short term at no cost and with enormous benefits.

(e) Overall transport Strategy

Aviation has become the unwanted toxic chill of Government policy.

Little or no co-ordination of overall road, rail sea and air transport policy is being conducted. Policy making is hesitant & piecemeal. Ministries are not competent to deliver the required investments and resultant benefits.

This saps confidence in the government when considering the GWR debacle and procrastination and un-deliverability in HS2 and Aviation infrastructure development.

IAAG has always tried to establish a multiple transport mode dynamic which is the only approach that will bear fruit.

Please see our past and updated papers on this key subject.

Strategy must absolutely deliver an acceptable cost/benefit ratio; acceptable ROI’s and incentives for overseas investors which we maintain will be the only source of large scale funding. Government strategy must be to create partnerships with investors, leasing and taking golden shares without tax payers cash which in the aviation context is the only way forward.

This provides a much needed participation in a large strategically vital segment of the British economy over which the government has presently no control.

(2) The best use of existing Airport Capacity

The present government has characterised improvement at British airports as “better not bigger”. IAAG’s guidance is “Use what you’ve got” whilst considering expansion of the asset base. Govt’s measures are currently insignificant. They seem unable to address straightforward issues and find solutions.

(a) What can be done to improve the passenger experience?

The most serious shortcoming is the poor on-time record for both arrivals and departures. The most common excuse is that Heathrow is “full” which is incorrect. With the demise of several airlines and the reduction in frequency of several operators there are slots available, prominently those of BMI, inherited in part by BA, which are not being used to reinforce long-haul routes as expected. Liberia and Sri Lanka are not considered critical routes; Leeds and Strasbourg are hardly important routes. However “use it or loose it” is the abiding rule and BA’s Fortress Heathrow policy is designed to minimize competition even in spite of prevalent open-skies policies of most major destinations. Exploitation of open-skies and competitive excellence has created and grown large hubs with fast expanding carriers even though the local population base is tiny. For Example:

Hong Kong and Cathay Pacific pop eight million.

Singapore and Singapore Airlines pop 4.5 million

Dubai and Emirates pop two million.

Amsterdam KLM pop 1.5 million.

(b) Mixed Mode

A dramatic improvement in on-time achievement, major reduction in kerosene burn, reduction in pollution, elimination of stress and cutting crew time and passenger delays can be achieved by the following:

Use both runways when required to cater to diurnal peaking of activity. For example, this means that when there is pressure for long-haul arriving aircraft between 0630 and 0830 both runways can be used for landing.

Similarly from morning peak take-off timings both runways can be used for take-off. This of course does not prevent aircraft landing on one or both r/ways. This is exactly what happens at Gatwick which has only one runway & most other multi-runway airports around the world.

However, it is absolutely essential that the government assemble all local stake-holders, HACAN etc and provide a solid pledge that this heightened efficiency will not be used to gain extra frequency. Otherwise the process will be stopped in its tracks as in 2009 when BA suggested that this would release extra frequency.

Incomprehensibly BA & BAA are opposed to this process when BA in particular will be able to save millions by drastically reducing fuel burn & other related costs resulting from

(i) Queuing on take-offs on Heathrow congested runways.

(ii) Circling/Stacking on landings due congested final approaches to highly congested Heathrow runways which will result in enormous savings on improved Aircraft/Crew Utilisation and on reduced “Delayed Passenger Compensation” ....then progress can be made to regenerate confidence in the airport.

IAAG can help in devising a strategy in this respect in dealing with local groups who may be in opposition if inadequate presentation is made. It will help also to assemble exact numbers on what financial savings will be made.

(c) Operational management

As well as mixed mode IAAG proposes that operational management techniques are introduced to allocate targets for performance to all service providers at the airport including the Border Agency to be strictly enforced by the chief executive of the airport. As in Hong Kong, Essential Service Legislation should be introduced to prevent wildcat or unauthorised stoppages in this strategically critical area as is the case in many other airports.

(d) Improvements outside the South East

Several improvements are currently forthcoming, ie runway extensions at Birmingham & other UK Regional Airports largely for the benefit of foreign carriers, especially the long-haul carriers like Emirates, Qatar & Etihad operating very large aircraft (A380s and Boeing 777s) to the fast-emerging markets in the Middle East & the Far East get the benefit of these Runway Extensions NOT the British Carriers as they do not operate from the Midlands, The North & Scotland direct from these UK Regional Airports to these highly-lucrative markets.

(e) Surface Access

Surface access is poor at Heathrow and Stansted resulting in congestion & stress and in the Heathrow case, pollution since 80% of traffic arrives by petrol and diesel burning vehicles. HSR2 will not solve the major problems. Crossrail is eventually able to relieve some congestion and the branch of the GWR.

(3) Constraints on Increasing UK Aviation Capacity

(a) Impact on the environment

Presently the government does not have a viable policy to reduce noise impacts on local populations. In fact the opposite, the refusal to abandon the 3rd runway debate will only severely exacerbate the massive and persistent opposition to government laissez-faire in this respect. Even the European directives demand a reduction in noise and pollution in the Heathrow area.

Without mixed mode or draconian measures to reduce frequency and tighten night curfew controls will the Government even begin to demonstrate a sympathetic understanding and corrective measures for adverse environmental impact on local residents and more broadly as much as three million residents under or near the glide path and take off paths of aircraft departing and arriving at Heathrow.

The solution proposed by IAAG and also by the Mayor’s team is to design and build a new large hub airport in the Thames Estuary, in IAAG’s case near Cliffe. This is outlined in detail in the submissions which we will attach for your reference and will drastically reduce the impact of noise and chemical pollution on surrounding areas.

(b) Government’s proposals to reduce carbon emissions

Only if the Government adopts the mixed mode plan and cap frequency at Heathrow will any progress be made. Converting all service vehicles on the airside of the airport will any impact be made on the level of carbon emissions. Much more important CO2 emissions are toxic chemicals such as sulphur dioxide, nitrous oxide and carbon monoxide all of which can lead to premature death as recently proven in the MIT study published this month Oct 2012. We will examine this important finding later in our paper.

Aviation can be made more sustainable by lifting the burden of escalating APD and other taxes and the threat to include the European directives on carbon emissions to UK carriers. Competitive carriers in other countries are not subjectedto the same level of taxes and consequently UK carriers and UK aviation suffer from diversion of traffic through other points, particularly in continental Europe. Helsinki is now added to the list of Paris-CDG, Frankfurt & Schiphol.

(c) EU aviation policies

There appears to little productive dialogue with the EU in terms of facilitating and protecting UK aviation. Continental EU administration are quite happy to see the discomfort of UK carriers since it continues to enhance the competitive position of their own national carriers.

(4) Step-Changes in UK Capacity

Government policy presently does not include increases in Frequency at S.E. Airports ie Heathrow, Gatwick & Stansted. The 3rd runway will not be built at LHR which adds very little frequency, anyway, on a short runway.

(a) Should there be a new hub airport? Where?

IAAG ‘s proposal has always been that plans must be finalised for a large “hub” airport to be built in the Thames Estuary at Cliffe. Comprehensive supporting document are submitted to explain and emphasise the justifications in this respect.

(b.) Costs and benefits of increasing UK aviation capacity

There is no cost benefit available in the other proposals to consider a 3rd Runway at Heathrow or a large airport on the Isle of Grain or 11miles N.E. of Whitstable in the North Sea. Detailed analysis is contained in the following IAAG’s supporting documents sent to you earlier today (15 October 2012) namely:

16 October 2012


(a.) General Outline

The general outline of events is that the question of capacity at London’s airports has become a hot topic with all shades of professional and lay opinion being expressed. Out of the confusion the following three proposals have been exposed. These are the only proposals to have received serious attention.

1. Third Runway at Heathrow

2. Boris Island either in the North Sea or on the Isle of Grain (Lord Foster and group)

3. The-IAAG proposal, first drafted and publicised widely in the press in April 2009 for an airport at Cliffe.

This has been updated regularly and we have submitted these newer versions to you in hardcopy. The foundation for this work was SERAS 2001–2. This in detail recommended that in the absence of extra Runway capacity at Heathrow, Gatwick and Stansted, the Cliffe site on the Hoo peninsula was the favoured and recommended option. This comprehensive and authoritative work was well received by Government and formed the basis of the government White Paper. This is compulsory reading for any study group wishing to formulate conclusion and draft policy. The financial analysis for the Cliffe option is still largely true today and simply needs to be adjusted for inflation. There have been other eccentric contributions which do not deserve serious attention. IAAG’s views on these three proposals are as follows:

(1) The proposed 3rd Runway at Heathrow

This is confronted by serious opposition, political, financial and environmental. It is a short runway costing £7–8 Billion will take

Eight years to build and will not attract sufficient funding and does not have a viable ROI or any cost benefit ratios.

In our view no more time should be wasted on this consideration which is being propped up by a collection of vested interests which will not carry the day or provide a solution for the deficit in Government policy.

This has no accompanying short or medium term solutions and will result in the accelerating decline of aviation activity in the UK. The only beneficiaries in this void of seven–nine years will be filled the continuing expansion of foreign carriers draining UK originating and destination business from domestic points in the UK which BA has abandoned to boost European hubs even further.

FLY BE is the main feeder and short haul carrier in the UK and western Europe but has no connecting services into LHR at all. It therEfore progressively feeds Continental hubs such as Frankfurt-FRA, Amsterdam-SPL and Paris-CDG

Other large Low Cost Carriers (LCCs) such as easyJet and Ryanair have signed commercial agreements (special prorate agreements) with Continental competitor carriers. This further contributes to the decline of Heathrow-LHR and reduction in the number of destinations served. The only solution for a declining LHR is to adopt IAAG’s 3 stage plan and eventually combine BA & FlyBe and even Ryanair and easyJet, (supported by commercial agreements) in one major hub in the Thames Estuary ie IAAG’s project at Cliffe-LGA the “London Gateway Airport”. IAAG has fully explained all other reasons why this project will never succeed, in hardcopy papers submitted separately.

(2) “Boris Island”

There seems to be a reluctance, deliberate or otherwise to identify the most important feature of a new airport, which is its exact location. The initial selection by Douglas Oakervee of the North Sea location on Shimmering Sands is clearly totally unacceptable, too far from population centers 10.5 miles N.E. of Whitstable with no ROI and impossible to finance. We have submitted a hardcopy paper rebutting this absurd initial choice. The Foster proposal which followed for a location at the Isle of Grain involves the following.

1. Demolishing a new power station, a gasification plant, large gas storage containers and an ocean terminal for very large LNG carriers off loading nearby.

2. A town of 7,000 people in Grain who work on these strategically important and sensitive installations is clearly poorly researched and impossible. This would involve the evacuation of the entire town protected by a Health & Safety perimeter. It also does not fit the ICAO and IATA criteria for Airport design. No airport with 4 runways can be built on this site. Minimum runway width and separations are not complied with and will not be allowed.

3. The SS Montgomery is in the final glide path and must be avoided since there are 4.000 tons of unexploded ordinance.

4. The London array of wind turbines lies in the approach and will be identified as a hazard.

5. Thamesport lies close to Grain and hosts large container ships arriving at the confluence of the Medway & Thames estuary.

6. Grain is at a dead end served by one of the most dangerous roads leading from Thamesport. Pipelines carrying gas products the length of the South part of the Hoo Peninsula are a hazard for any development of communications.

7. Economic geography dictates that any important hub will only grow at the intersection of connecting routes. Grain is the antipathy of this concept, Cliffe fits it exactly.

8. There are wildlife issues and the approach will be over the island of Sheppey which has a substantial residential population.

9. It is too far from both supporting markets and destinations from labour supply.

10. The cost of building supporting transportation infrastructure will be prohibitive & will never attract public or private investment.

All of the above 10 reasons are killer-blows in their own right. It is strongly suggested that this project is relegated to the undo-able bin before even more amounts of public or private money is spent needlessly.

(b) IAAG Proposal

This has been extensively described in the four papers mailed to you on 15 October 2012 and is built on the following criteria:

1. Airports must be treated in a similar way to other major infrastructural undertakings.

A realistic pay-back period (ROI) and acceptable financial ratios must be justifiable, agreed and sufficient to attract overseas investments, since UK sovereign finance is most unlikely to be forth coming.

2. Connecting surface infrastructure must synchronise easily with the airport location. Larger projects such as the Lower Thames Crossing can be tolled and therefore funded, again from overseas sources.

3. We have described in detail how existing communications by road, rail and sea can be utilised focused on the land hub of Gravesend with onward transmission to the airport services complexes both north and south of the Thames, can be enhanced by relatively inexpensive additions. This is in strong contrast with the Grain project which will cost in excess of £30 billion and will not attract overseas investors nor produce any ROI whatsoever.

4. Please refer to the colour brochure to observe how rail connections from five main rail terminals in London can connect with Gravesend for short onward transmission to the LGA airport seven miles away by local shuttle on the Hong Kong format.

Likewise rail connections can be extended through Tilbury and Crossrail extended (which is the intention) though the Lower Thames crossing thus connecting Medway with Essex and Dubai World Container Port. The lower Thames crossing will create great synergies for local regional and airport related travel. This can be funded from overseas since it can be tolled and produce revenue. It will also have a very beneficial effect on relieving congestion at Dartford on the M25 and enable direct connections from the A13 to the A2 and A20.

3. This growing infrastructure must be multi-use directly benefiting local populations and a Logical Hub for distribution by road and rail traffic as well as air routes.” “Use what you’ve got “and extend and enhance accordingly.

4. Create a dynamic for growth and regeneration on the Dutch Mainport Model ie the “multiplier” effect (i).

5. Investment must create a value-added activity. Simply building housing gives rise to more debt. Job creation must come first.

6. It is essential to create a complete 3-stage plan, short, medium and long-term all of which must fit logically in place and be supported by government and the private sector and public opinion.

7. This has the enormous advantage to government for the following reasons:

(a) It refocuses on the absolute requirement for long-term planning to deliver LONG term benefits breaking the mould of patch, mend and muddle through.

(b) It delivers achievable results in the very SHORT term to improve greatly the performance of LHR which has to be used for the next 10–12 years anyway. It will thereby boost confidence in the government, the industry and public opinion. It will in short restore self-respect and demonstrate there is a quick answer to Heathrow’s biggest problems—Delays.

(c) It brings breathing space where additional capacity can be introduced in the medium term at LGW. This will need to be tackled promptly and with diligence.

The land is available, the location secure and the finance presumably available through partners and shareholders. Standing in the way is a local agreement not to build before 2019.

In the national and local interest it would be sensible to override this undertaking. Having only 1 Runway with in excess of 360,000 movements a year is not “resilient” in the event of any even minor mishap on the main runway which would mean closure of the airport with severe consequences.

Thus Gatwick can expand more freely and retake some of the traffic it lost to LHR. LGW could then as it is now re-establish hub status. There is no reason why there should not be more than one hub airport in the South of England as long as viable connecting services grow as a result of sound and profitable commercial airline planning.


Short Term

(a) Introduce Mixed-Mode at Heathrow WITHOUT placing additional frequencies.

Binding government guarantees must be given to all stakeholders to this effect. The result will be a dramatic improvement in on-time performance for all users with millions of £s savings in fuel, aircraft and crew utilisation and the removal of the most bitter point of contention at Heathrow, ie poor time-keeping.

(b) Introduce essential service legislation

(c) Introduce a system of Operational Management with targets enforceable on all service providers including Border Agency and Security. The above can be explained in detail in the question and answer sessions.

Medium Term

(1) Within five years open a 2nd runway at Gatwick which is fast improving and attracting long-haul and connecting-hub-traffic.

Delays will be reduced and runway congestion reduced. Land has been allocated and private funds should be forthcoming.

Overdue enhancements to rail and road access can be introduced.

(2) Open Manston for all-cargo services. This has already been done on a limited and temporary basis in the past. Improved surface communications must be established with the main road hubs ie A13, M20 and M25 and with London Gateway Airport, when it is built, Cliffe location will act as a clearance facility for cargoes. Also Dubai World through its logistics centre will be able to distribute and collect cargo and mail and package traffic from all parts of the UK.

(3) Open Northolt for general aviation traffic on a very limited basis thus relieving LHR of congestion of slots.

Long Term

Commence immediately detailed costing and research into the Cliffe IAAG Proposal. This is the only realistic, fundable proposition left standing.

Before having finally to commit the government to long-term project, we will have seen real improvements made to LHR and will be progressing in the reshaping and expansion of LGW at no cost to the taxpayer.

There is therefore no risk to the national best interest and sensible, informed careful but timely large infrastructural planning can take place.

London Gateway Airport-LGA near Cliffe.

The government owns large tracts of the Hoo Peninsula through MOD and PLA. The Church Commissioners are also landowners. This can be consolidated and then offered for lease to sources of investment on long leases thus creating an income stream and an element of control by government which they presently do not enjoy. A “golden-share” in the aggregated investment can encourage both investors and government to work closely together to move the project forward efficiently.

Healthy interest has been expressed from Middle East sources in what will be an iconic and attractive investment. When the project is completed, it can be opened in stages: London City Airport can be absorbed into LGA, a new 24 hour airport with excellent connections to the City and Canary Wharf through road, rail and Crossrail links. (see the colour brochure). When the new London Gateway Airport (LGA) is completely opened Heathrow will be closed and Heathrow operators invited to relocate to LGA or possibly to Gatwick with a second runway to meet Govt & Industry objective of creating healthy competitions between airports in SE. The site at Heathrow will be opened for development as an ECO City and should realise in excess of £5 billion and provide a large number of jobs for developers at the new site. T5 can be used as a new Earls Court. T4 can be used as a permanent exhibition centre for British Industry with subsidised stands for exhibitors and run by the CBI. Power will be supplied by solar panels and geothermal energy. Blocks will be highrise residential and commercial. Training colleges will be established and educational research and entertainment centers encouraged. Useful transport links can be maintained and hotel accommodation utilised. Extensive water features can easily be designed with the aggregate removed for building requirements. Local transport within the security boundary will be all electric cars, buses and taxis.

The model for this bold ECO investment has already been established in several Chinese cities with help from Singapore interests who are respected masters of urban planning. Land values are suggesting that the LHR area would be valued at circa £5 to £6 billion more than any value of the area as an airport. Several potentially interested parties are expressing interest.The main point to be made here is that there would be continuing interest and development available for Heathrow after its substitution as an airport. It would be a wealth generating entity creating many new jobs of all categories and serve as an icon in Europe as a truly ecological and sustainable environment and world leader.

Thus, wholesale redevelopment in the Thames Estuary would be matched by an existing project to the west at Heathrow, both equidistant from the new London landmark the “Shard” which itself is close to London Bridge Station which would serve as a collection and dispersal point for all traffic.

Both areas should be awarded “Enterprise Zone” status.

(c) Principals at stake

(1) Without question there is a need for extra runway capacity in the SE of England—now.

(2) Aviation needs however better facilities, better managed and serving the best interests of consumers and providers (airlines).

(3) This requires a mix of short term, medium term and long term commitments to be infused now in principal and in practice. The political risks of embracing this strategy are very small and the national interest will be well served with Government taking most of the credit.

(4) IAAG will fully cooperate and assist in advancing the process for everyone’s benefit.

(5) The main events are:

(a)Modernise and improve airports and aviation both in shape size and function.

(b)Create a sustaining dynamic infrastructure based on a new airport in the Thames estuary and a new eco city in the west of London at a newly revitalised Heathrow site.

(c)This will resolve the failed Thames Gateway Project.

(d)This will resolve the problem of toxic chemical and noise pollution affecting several million Londoners. This will decongest west and east London two of the most un-resolvable black spots of the UK.

(e)It will re-awaken interest in sea and estuary access to the airport both for staff and travelers (see brochure for details).

(f)Decongest Britain’s stumbling and outdated transport system and revitalise commercial and economic interest in building and maintaining the world class facilities it deserves.

(d) Conclusions

These papers and written material have been assembled over a period of 4 years. IAAG has not changed its views over this time having presented to government, public bodies and private institutions. Inflation over this period and also since the publication of the SERAS report has been modest. We expect therefore by making generous allowances for mitigation and inflation the delivered cost to overseas investors will be circa £12–13 billion.

This can be built in 10 years from approval, creating income for the government in partnership with the principal investors. Government’s role is to take early action to embrace the package of measures which only IAAG has been able to assemble. It will be the task of the private sector to deliver and execute to end decades of indecision and procrastination. IAAG remains at the disposal of Parliament to progress these vital issues for the sake of the future of aviation and the national interest.

Prepared 31st May 2013