Draft Aviation Policy Framework – The benefits of aviation

Date added: 1 October, 2012

Draft Aviation Policy Framework

The section on “The benefits of aviation”  is Pages 13 – 35

The questions on this section are:

1.  Do you agree with our analysis of the meaning and value of connectivity, set out in Chapter 2?

2.   Do you support the proposal to extend the UK’s fifth freedom policy to Gatwick, Stansted and Luton? Please provide reasons if possible.

3.  Are there any other conditions that ought to be applied to any extension of the UK’s fifth freedom policy to Gatwick, Stansted and Luton?

4.  Do you agree that the Government should offer bilateral partners unilateral open access to UK airports outside the South East on a case-by-case basis?

5.  Do you have any other comments on the approach and evidence set out in Chapter 2?

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Further comments made by AirportWatch members:

Connectivity:

1.  Do you agree with our analysis of the meaning and value of connectivity, set out in Chapter 2?

In the absence of supporting evidence, it is either over-stating the case or simply rhetoric to claim that ‘the future of the UK will undoubtedly continue to be shaped by the effectiveness of its international transport networks’ (para 2.13). What is the evidence for this statement and in which way will the effectiveness of the UK international transport networks shape the UK’s future?

It is far more likely in the foreseeable future that electronic communications technology will advance further and faster than aircraft technology and will increasingly replace air travel as a means of doing business.

It is surprising that there is no mention of videoconferencing in the discussion on connectivity in this chapter (but we note that it is discussed in a later chapter in the context of seeking to address climate change impacts).

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No argument with the definition: as to assessing its value in objective, financial terms this is missing entirely.

1.  Do you agree with our analysis of the meaning and value of connectivity, set out in Chapter 2?

We agree with paragraphs 2.17 and 2.18 that the UK is one of the best connected countries in the world.

In our response to the Scoping Document we explained why a new runway at Gatwick is not practicable, and also why past attempts by airlines to use Gatwick as a subsidiary hub have all ended in failure.  We will not repeat these points here but will be submitting evidence to the Connectivity Commission.

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[We] consider that this can be achieved by encouraging better utilisation of existing runway capacity in the short term supported by improved surface connections, particularly high speed rail links and dedicated airport express services and a more stringent night flights’ regime to encourage the use of the quietest aircraft during the night period. The Government’s short term approach of making best use of existing runway capacity is supported in principle. The Government should acknowledge that growth in the use of runways should be subject to agreements and commitments which manage local environmental impacts.

The establishment of an independent commission to address the provision of longer term capacity is also supported. When published, the Aviation Policy Framework should make it clear that all options for the long term are to be given due consideration to include the balance between hub capacity and point-to-point, and that there is no presumption in favour of either.  The scale and location of future capacity should rightly be determined following a full examination of all the options.

Development of connectivity by air should not, however, be seen in isolation. It should be looked at in the context of other modes of surface transport and, more specifically, against the background of the rising use of the internet for long distance communication. Whilst it is not always a replacement for face-to-face communication, the internet performs an increasingly valuable economic and social role.  The UK should establish and maintain its role at the forefront of electronic communication and avoid becoming overly focused on a mode of transport which may be seen by future generations as only a small part of a much more complex network of communication.

Fifth freedoms:

2.   Do you support the proposal to extend the UK’s fifth freedom policy to Gatwick, Stansted and Luton? Please provide reasons if possible.

Filling more seats per aircraft could be a positive step in terms of reducing the aviation industry’s carbon footprint but it could also have the opposite effect if, for example, an aircraft on a flight from the Continent to the US stopped off at Gatwick, Stansted or Luton to pick up only a small number of passengers.

In addition, local residents could be subjected to all of the noise and local air pollution impacts of a large long haul jet aircraft for the sake of a accommodating a small additional number of air passengers.

Finally, whilst there may currently be some spare capacity at Gatwick, Stansted and Luton, the DfT forecasts indicate that this will not be the case in the longer term, and when capacity becomes tighter it would be highly inefficient to use these airports as ‘bus stops’.

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Yes.  Luton has, at present, none of the controls over night movements which exist at Heathrow, Gatwick and Stansted, whose objective is to control and limit the noise pollution and disturbance caused.  Indeed, Luton has no limit whatsoever on night movements and, if “fifth freedom” rights encourage heavier, noisier, aircraft from far-distant destinations it is essential that an externally-mandated night noise control scheme is implemented at that airport.  A complete night curfew would be even better.  There is authoritative evidence [1] (CE Delft, January 2011)] that a ban on night flights, even at Heathrow, would produce an overall benefit if the societal  costs of such flights were considered.

Do you support the proposal to extend the UK’s fifth freedom policy to Gatwick, Stansted and Luton? Please provide reasons if possible.

In principle we approve of filling more seats per aircraft.   But in practice this would mean more large, and probably noisier, aircraft using Gatwick for the purpose of putting down or taking on-board comparatively few passengers.  When airport capacity is scarce, and there is no scope for building new runways, it would seem unwise to use up slots for comparatively few passengers.

3.  Are there any other conditions that ought to be applied to any extension of the UK’s fifth freedom policy to Gatwick, Stansted and Luton?

No Comment.

Are there any other conditions that ought to be applied to any extension of the UK’s fifth freedom policy to Gatwick, Stansted and Luton?

Fifth freedom flights during the night quota period must count against night quotas, both as an arrival and as a departure.  Where the quota is nearly fully used, problems may arise in allocating quota points.

Airports outside the South East:

4.  Do you agree that the Government should offer bilateral partners unilateral open access to UK airports outside the South East on a case-by-case basis?

No Comment.

Any other comments:

5.  Do you have any other comments on the approach and evidence set out in Chapter 2?

The UK accounts for less than 1% of the world’s population but some 12% of global air transport movements (‘ATMs’) and these are heavily concentrated at airports in the south east of the country.

This disproportionately large number of ATMs brings concomitant adverse environmental impacts to the country, particularly the south east. It is therefore important to provide clear evidence about aviation’s role in the economy since the adverse environmental consequences are not trivial.

The DAPF fails to provide any such clear evidence. Moreover, the DAPF lightly dismisses evidence of negative economic impacts by concluding (in para 2.9) that ‘… the evidence available to us does not show that a decrease in the number of UK residents flying abroad for their holidays would benefit overall the UK economy.’

This is very odd conclusion because at least some of the disposable income which would have been spent by UK residents on overseas holidays would be diverted to consumer spending in the UK – benefitting the domestic economy and delivering higher VAT receipts.

What assessment did the DfT make of this substitutional effect and what other evidence did the DfT review before reaching this conclusion?

In August 2011 we submitted a paper to the DfT on aviation, jobs and the UK economy, as part of our response to the Scoping Consultation. This contained a considerable body of evidence to indicate that a decrease in the aggregate expenditure by UK residents on overseas leisure visits benefitted the domestic UK economy.

The paper was fully referenced, drawing upon other studies carried out in recent years and we find it disappointing that the DfT, which should be making transparent evidence- based judgments, has not explained what evidence it has accepted, what it has rejected, and why.

It is disappointing that, once again, the DfT uses tendentious terminology in that it always refers to ‘the economic benefits of aviation’ rather than its ‘economic effects’.

If it did the same with regard to the environment it would refer to ‘environmental damage, whereas it commonly refers to ‘environmental effects’.

Do you have any other comments on the approach and evidence set out in Chapter 2?

Having pointed out in our response to the Scoping Document that the figure of £9 billion economic output is misleading because it does not include depreciation (ie the need to buy new aircraft, to renovate airport buildings or re-surface runways), we are shocked to see it repeated.

We are glad, however, to see that the figure for the number employed in air transport has been revised down from 150,000 to 120,000 at the instigation of our colleagues from Stansted.  A far cry from the figure of 200,000 in the Air Transport White Paper.

Posted: Monday, October 1st, 2012. Filed in Recent News.