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Airport Capacity
The
Future Development of Air Transport in the United Kingdom
South
East Consultation Document (second edition)
Submission by
The
Charter Airline Group of the United Kingdom (CAGUK)
June 2003
Introduction
The
Charter Airline Group of the United Kingdom (CAGUK) is an independent
grouping formed to represent the interests of the major UK charter leisure
airlines and their passengers. The Group consists of
First Choice Airways,
Britannia Airways,
Monarch Airlines,
MyTravel Airways and
Thomas Cook Airlines.
Although CAGUK members all belong to the British Air Transport Association
and support the BATA submission in response to SERAS, we also appreciate the
opportunity to respond more specifically to the Department’s consultation.
In
this submission we address the options for new runways at Gatwick as
contained in the revised consultation document of February 2003.
We
recognise that decisions taken now will have major influences on aviation
for an extended period of time and wish to see that the Government’s
decisions are taken with regard for the totality of airline interests,
consumer interests and environmental balance.
We see
it as a priority that the Government should publish a clear statement of
intent in its White Paper indicating the options at specific airport sites
to be developed. This must be done before the end of 2003 in order to remove
the planning blight and uncertainty that adversely affects business and the
public alike. Beyond this, we believe the funding of new runway capacity
should be met from revenue at the particular airport site thus reflecting
demand. There should be no element of cross subsidy from other airport sites
that might be in the same ownership.
SECTION 2 – WHERE TO PROVIDE ANY NEW AIRPORT CAPACITY
Q7 Giving reasons for your answer, which
combinations do you prefer and which do you not favour? If the combinations
on which you comment include one new runway at Gatwick, please make clear if
you have any preference for or against the two options for one runway (close
parallel or wide-spaced) and why.
HEATHROW
The Charter Airline Group supports the construction of the new runway at
Heathrow as outlined in the consultation document. Although none of our
members operates services from Heathrow, we recognise the strategic
importance of Heathrow to the UK economy.
The provision of additional runway capacity at Heathrow as soon as possible
would also alleviate some of the existing pressure on capacity at Gatwick.
Given the likely difficulties involved in renegotiating the 2019 planning
agreement at Gatwick, it might well be possible to construct a new runway at
Heathrow earlier than at Gatwick.
In addition, to speed up this alleviation, we should like to see creative
solutions employed to maximise Heathrow’s capacity (eg mixed-mode
operations) at the earliest opportunity and in advance of the new runway.
GATWICK
Much of the southeast leisure demand is located in the area from Kent
through Sussex to South London and Surrey. With Heathrow effectively
reserved for scheduled airlines, only Gatwick is left to serve the charter
market. Gatwick is therefore the principal UK airport for our members who
base a total of forty-five aircraft there and account for the bulk of the 12
million charter passengers of all ages and social groups who travel through
the airport each year.
Although four of our members also each have one aircraft based at Stansted,
making just four in total, we believe the construction of a new runway at
Gatwick to be a far higher priority. We consistently experience far less
demand from our tour operator clients for services from Stansted, hence its
relative lack of importance to us in favour of Gatwick. Were Stansted to be
expanded in place of Gatwick, there would be significant surface access
problems as passengers from the large conurbations to the west and south of
London were forced to make long cross regional journeys. We therefore
support development of facilities best placed to serve local demand.
In
seeking to meet the demand for sustainable airport capacity, we believe the
Government should also seek to maximise the net economic benefit to UK plc
while taking account of environmental and social factors. According to SERAS,
the highest net economic benefits – over £18 billion - are derived through
the construction of one new runway at Heathrow (2011) and two at Gatwick
(2018 and 2024).
In
terms of noise impacts on the local population, one additional runway at
Heathrow would result in a total of some 332,000 people being exposed to a
noise impact of 57 LEQ(dBA) or greater by 2030. One new wide-spaced
southerly runway at Gatwick would result in a total of just 23,000 people
being exposed to the same level of noise by the same date. Two new runways
at Gatwick would similarly affect 31,000 people. This assumes that further
improvements in technology aimed at reducing noise at source are not
forthcoming. CAGUK members have already invested significantly in modern
quiet and efficient aircraft and shall continue to do so.
In
terms of land and property impacts, we note the further work carried out by
BAA that a better solution for the wide-spaced southerly runway than
building two new passenger terminals would be for the construction of just
one on the existing sewage works east of the railway line together with some
expansion to one or both of the existing terminals. This could reduce the
significant loss of housing in Hookwood and at Povey Cross accounting for
the bulk of the 300 residential properties and agricultural/green belt land
required for that option.
We
therefore firmly believe that the optimum solution would be for a new
wide-spaced southerly runway as soon as possible after Heathrow. This
option provides a greater likelihood of satisfying demand forecasts of 301
mppa in 2030 through the construction of just three runways in the southeast
than were the close Gatwick parallel to be constructed as per the table
below:
|
RUNWAY OPTIONS |
TRAFFIC SERVED |
SHORTFALL FROM DfT
FORECAST |
|
LHR
(2011), LGW (2018/2024) |
264 |
37 |
|
LHR (2011), LGW* (2018),
STN (2024) |
284 |
17 |
*
wide-spaced totalling 77mppa by 2030
It
will be noted that the second of the two options shown above minimises the
loss to the UK system of any option considered in SERAS at table 14.4. It
would also deliver the second highest net benefit of all options illustrated
in SERAS at approximately £18 billion (see SERAS table 14.6 after taking
account of the additional benefits derived from a wide-spaced option), only
exceeded by the net benefit of £18.3m derived from the first option shown
above ie LHR (2011) and LGW (2018/2024).
In
terms of air quality, we also note the further modelling carried out by BAA
and its assessment that the DfT figures significantly overstate the numbers
of people affected by NO2 exceedences. We further note the BAA’s belief that
given planned actions to improve local and national air quality, the numbers
of people affected could be reduced to zero in the time periods considered.
CAGUK recognises the validity of the 2019 planning agreement between West
Sussex County Council and the BAA. However, we do not believe this should be
seen as an overwhelming impediment to construction of a new runway if deemed
in the national interest. We would contend that the case for a new runway at
Gatwick is so great given its economic, social and environmental advantages
over new runway options at the other BAA London airports, that a new
wide-spaced southerly runway should be constructed as soon as practically
possible at Gatwick.
We
therefore conclude that in terms of the much-needed additional capacity
provided at minimal environmental cost but with high net economic benefit,
at least one new wide-spaced runway should be constructed at Gatwick as
soon as possible and preferably before 2019. This would be in the best
interests of the national economy and should therefore override the forty
year local planning agreement that we and others contend was in fact an
unreasonable “fettering of discretion” on successor bodies, entered into
without regard for the greater national interest.
It is also important to recognise that due to the very different operating
conditions at Heathrow and Gatwick, any mitigation options appropriate to
Heathrow’s traffic (eg a restriction on night flying tied to new runway
provision) might not be appropriate at Gatwick where charter airlines
operate around the clock and already make best use of the scarce capacity
resource. |