Regional Response - Generic · Web viewOur response specifically identifies the three largest potential developments at Birmingham, Manchester and in the Scottish Lowlands. However,

THE FUTURE DEVELOPMENT OF AIR TRANSPORT

IN THE UNITED KINGDOM

BA RESPONSE TO THE RASCO CONSULTATIONS

JUNE 2003

CONTENTS PAGE

Context and Structure of British Airways’ Response 4Summary 5

Answers to the questionsA : National Policy Scenarios 7B : Location of Airport Capacity 9C : Competition v Complementary Development 11D : Economic Benefits 12E : Social Inclusion 15F : Environmental Impacts 16G : Surface Access 17H : Access to London 19

Regional Specific Responses 22Midlands 23Northern Ireland 25North of England 26Scotland 27South West 29Wales 31

THE FUTURE DEVELOPMENT OF AIR TRANSPORT IN THE UKBA response to RASCO consultations Page 2June 2003

CONTEXT AND STRUCTURE OF BRITISH AIRWAYS’ RESPONSE

British Airways’ (BA) interest in the RASCO (Regional Air Service Co-ordination) studies is twofold.

Firstly BA, together with its subsidiaries, is a major operator from UK regional airports to other points in the UK and overseas. BA’s comments on development in UK regions incorporate both regional services to/from London Airports and its subsidiary British Airways CitiExpress (BACX).

BACX is one of Europe’s largest regional airlines and operates from over 20 airports in the UK regions. BACX operates over 90 routes, has a current fleet of 71 aircraft and carries around 4.5 million passengers a year. BACX supports the development at regional airports to meet local demand.

Secondly, and equally importantly, BA has an interest in the overall aviation policy in the UK. Policy scenarios in the South East impact the regions and vice versa. In addition, for most of the UK’s key regional airports, the most important route is to the main National hub for onward connections (as well as direct services) and therefore capacity in the South East, and particularly at the main hub, Heathrow, is of particular relevance.

At the policy level, BA’s interests are largely common to all UK regions. As such BA has prepared a single response to most of the questions.

Questions asked only in relation to individual regions and/or on the detail of individual airports/regions are included, by region, at the end of the document. These comments concentrate particularly on BACX’s main bases and on the major airport development proposals such as additional runways.

Responses to a few questions have been intentionally omitted.

BA’s response to RASCO should be read in conjunction with its response to the SERAS (South East and East of England Regional Air Services Study) consultation.


Summary

The Government has put forward a number of possible growth scenarios. The ‘RASCO reference case’ assumes a continuation of current environmental, fiscal and aero-political frameworks; this provides an acceptable starting point and recognises the balance of issues that need to be considered. Nevertheless, there are elements of the ‘Facilitating Growth’ scenario that could and BA feel should be adopted, such as streamlining of the planning process, a clear framework of support for developments in the White Paper and encouragement of surface access links. BA does not support either of the constrained growth scenarios.

We believe the most critical location for additional capacity in the South East is at Heathrow, for the UK, for the South East market and for the UK regions. At a UK level, it will enable the UK to have the competitive global hub it needs in the coming decades : the risks of any other decision are too high for the UK economy and a hitherto successful aviation industry. A Heathrow regional runway will have three main benefits for the regions :

i) It will provide additional slots at Heathrow allowing the regions to maintain and strengthen their links to Heathrow. It may be possible for Government to design guarantees that a proportion of flights on the new runway would be reserved for new regional destinations (5-10% of slots would, for example, produce 30-60 flights per day enabling the introduction of new services and the restoration of those lost due to capacity constraints). We would support such a Government initiative.

ii) It is the only South East airport which provides the regions with access to a global hub and the onward connections that delivers. An additional runway will enable Heathrow to offer a competitive number and range of services.

iii) It will enable delay standards to be reduced (currently set at an average 10 minutes at Heathrow because of the pressure on slots) cutting taxiing and holding times at Heathrow, improving overall flight times, and critically the reliability of those times. This would provide a better service for regional passengers to Heathrow and improved efficiency for regional carriers.

We support the principle that regional airports should develop to meet their own demand - where that demand can be profitably served by the region. We believe there will be a case for such development, brought forward in a sustainable way, at many regional airports. Our response specifically identifies the three largest potential developments at Birmingham, Manchester and in the Scottish Lowlands. However, regional airlines require a passenger catchment area (of sufficient volume and profitability) to sustain routes, especially in the case of longhaul destinations. This is reflected by the relatively slow growth in range of longhaul airlines at Manchester, even given the development of the second runway.

Many economic benefits are gained in the regions by virtue of access to global markets. The inward investment decisions and businesses that rely on those global links are critically dependent not just on the regional airport, but access to a major hub. These benefits can best be captured and preserved for the future by ensuring Heathrow’s long-term competitiveness by adding the regional runway proposed in the SERAS consultation. Other benefits to the regions of a thriving UK industry include aviation support functions which can be located in the UK away from BA’s main base e.g. BA’s aircraft maintenance bases in South Wales and Glasgow, BA’s Information Management centres in Newcastle and its Glasgow, Newcastle and Manchester call centres. These would be at risk if the UK industry, whose underlying strength comes from a successful Heathrow hub, declined within Europe.

At a regional level, attracting inward investment to regional areas of the UK is often critically dependent on good air-links to London, ideally Heathrow.

BA consider that the Government should support an additional runway in the Midlands in the period to 2030 and believe that Birmingham is the best location for this because :-

i) there is a need to concentrate demand to get competitive levels of frequencyii) Birmingham is the best located airport in the Midlands, near to the city centreiii) Birmingham has the best road and rail linksiv) Birmingham provides an option for some passengers in the Northern fringe of the South East region.

We do not support the option of a new airport in the Midlands.


BA is in general agreement with the proposals for growth in apron and terminal infrastructure at Manchester airport outlined in the consultation document and recognise that substantial development will be necessary for Manchester to reach its full potential. Runway capacity at Manchester is not a critical need given the recent opening of Runway 2. We agree with the issues identified in the consultation report concerning the possibility of a 3rd runway. While such demand may exist at the very end of the 30 year consultation period, this is by no means guaranteed: as such it is not appropriate, and critically not necessary given the timescale for runway development, to make a firm decision on 3rd Manchester runway at this stage.

We recognise that there is likely to be a need for an additional runway in the Scottish Lowlands towards the end of the consultation period. We do not think that a new airport in the Scottish lowlands should still be considered. Replacing one of the existing airports is a hugely costly option and adding an additional airport would tend to duplicate services. We do not, at this stage, have a view as to which of Edinburgh and Glasgow is the best location for an additional runway.


A: National Policy Scenarios

While our UK wide National Policy Scenarios are not intended to be viewed as definitive statements of potential Government policy, they do provide a means of examining broad-brush alternative policy approaches.

A.1 Which, if any, of the National Policy Scenarios do you think should form the basis of the UK Government’s national airports strategy to 2030 and why? Considerations might include:-

• enhancing consumer choice and accessibility to air services;• fostering a strong and competitive airline industry;• facilitating existing businesses to compete effectively in global markets;• attracting inward investment and inbound tourism;• ensuring aviation develops sustainably and minimises environmental impacts of growth;• minimising distance people have to travel;• reducing congestion; and• encouraging the use of public transport.

A1.1 BA considers that all of the above points identified are valid. The first four points are prime considerations, essential to the future of the aviation industry, tourism and business as well as meeting social needs. These must then be balanced by - but cannot be driven by - environmental sustainability issues.

A1.2 RASCO has identified 4 possible growth scenarios. BA does not support either of the constrained scenarios (SE constrained or UK wide constrained). The RASCO reference case gives a continuation of current environmental, fiscal and aero-political frameworks, which provides an acceptable starting point for debate and recognises the balance of issues that need to be considered. Nevertheless, there are elements of the Facilitating Growth scenario that could and BA feel should be adopted, such as streamlining of the planning process, a clear framework of support for developments in the White Paper and encouragement of surface access links. There are however elements of the Facilitating Growth, such as financial support for projects that are not financially viable, where we would have some reservations.

A1.3 BA note that demand is forecast to grow faster in the regions than in the South East, some four times current demand by the end of the 30 year consultation period. Regions will therefore need to have substantive development plans in place to meet their own demand. Under the SE constrained scenario, the regions - particularly those bordering the South East will be put under pressure to accommodate ‘overspill’ demand from the South East. BA do not consider that this additional level of development would be welcomed by the Regions and would certainly not be welcomed by South East passengers.

A1.4 RASCO has also identified two spatial scenarios: ‘fly local’ and ‘concentrated growth’ both of which postulate public sector intervention. There are elements of the two scenarios that have merits, in particular the increased range of services that can be achieved if growth is concentrated. We do not feel that, in general, any such benefits are likely to outweigh the potential undesirable effects of intervention, and in particular have concerns under concentrated growth that the airport identified for concentration would not reflect the needs of the market.

A1.5 There may be other, non-interventionist, ways of realising the potential benefits of the ‘concentrated growth’ scenario, by supporting the roles of some airports as core bases. This can best be done with the support of the relevant airport and critically with airlines rather than by attempting to interfere in the market.

A.2 If you think additional capacity should be provided in the South East to meet the needs of regional air passengers interlining or accessing services from London airports via surface modes:

• how much capacity do you think should be provided; and• where in the South East should it be located?

A2.1 We believe the most critical location for additional capacity in the South East is at Heathrow, for the UK, for the South East market and for the UK regions. At a UK level, it will enable the UK to have the competitive global hub it needs in the coming decades : the risks of any other decision are too high for the UK economy and a hitherto successful aviation industry. A Heathrow regional runway will have three main benefits for the regions.i) It will provide additional slots at Heathrow allowing the regions to maintain and strengthen their links to

Heathrow. It may be possible for Government to go further and design guarantees that a proportion of flights on the new runway would be reserved for new regional destinations (5-10% of slots would, for example, produce 30-60 flights per day enabling the introduction of new services and the restoration of those lost due to capacity constraints). BA would support such a step by Government.


ii) It is the only South East airport which provides the regions with access to a global hub and the onward connections that delivers. An additional runway will enable Heathrow to offer a competitive number and range of services.

iii) It will enable delay standards to be reduced (currently set at an average 10 minutes at Heathrow because of the pressure on slots), reduce scheduled flight times, and critically the reliability of those times, providing a better service for regional passengers to Heathrow and improved efficiency for regional carriers.

A2.2 It is not the only runway that will be needed in the South East but it is essential and the top priority for action. The Heathrow regional runway will enable other airports in the South East also to develop organically and sustainably.

A.3 Which of the scenarios will most enhance consumer choice and accessibility to services in:

• the UK as a whole• This Region

A3.1 Overall the Facilitating Growth scenario would provide the widest customer choice and accessibility to services, with the RASCO Reference case giving similar benefits.

A3.2 The South East constrained case has winners and losers, with the South East and UK as a whole having reduced choice but with some pockets of the UK where local consumer choice would be enhanced. For example Birmingham would grow faster under this scenario, giving a wider range of services to the Birmingham community, but relying on ‘overspill’ frustrated passengers from the South East to generate the volume of passengers necessary to support the enhanced services. Nevertheless, it is unclear that Birmingham would support additional development for the purpose of accommodating passengers from the South East. Many more distant regional markets - notably Scotland, the South West and North East England - suffer under this scenario, as routes to the South East form a major part of their operations, and these are constrained - or even squeezed out of the South East - under this scenario. Overall therefore, there are more losers than winners.

A3.3 The UK constrained scenario clearly gives reduced consumer choice and accessibility to services.

A.4 Are there any other policy scenarios, including any combination of those set out in the document, which would better meet your aspirations for the development of regional air services and airports in This Region ?

A4.1 We believe there are merits in combining elements of Facilitating Growth with the RASCO base case (see answer to A.1).

A.5 The Government is committed to bringing forward policies for civil aviation and airports that are sustainable. Please explain why you think your preferred scenario best supports the Government’s sustainable objective?

A5.1 Sustainable development options need to balance economic, environmental and social aspects. Constraining airport growth (UK Constrained or SE Constrained), particularly in the South East would have huge economic and social downsides, not just on the aviation industry but also on industries that rely on it including global businesses, financial services, and tourism. A weaker South East weakens the UK economy generally.

A.6 Which of the policy mechanisms set out in Chapter 3 do you think are essential to delivering your preferred scenario? Are there any that you consider might assist in doing so but you do not consider essential? Are there any policy mechanisms not covered in Chapter 3 that you think should be considered?

A6.1 See response to A.1 .


B: Location of Airport Capacity

B.1 This document has described how airports in the region might develop, if policy is to meet demand. Do you have any comments on these suggestions for new infrastructure?

B 1.1 See answer to B2. See also end of document for Regional specific answers

B.2 If your preferred strategy for This Region involves accommodating growth in air services, where would the projected levels of growth best be accommodated and what form of airport development should be supported in order to achieve this?

B2.1 BA’s comments on developments in the UK regions reflect both its operation to the regions from London as well as those operations based in the regions, namely BA CitiExpress (BACX). BACX’s strategic plans reflect its intention to have 6 core bases as its main UK airports : Manchester, Birmingham, Bristol International, Southampton, Glasgow and Edinburgh.

B2.2 As such, while BA supports general development at regional airports to meet local demand, it has a particular interest in those regional airports indicated above. For these bases to be successful, airport charges need to recognise the cost imperatives of regional operations.

B2.3 See end of document for Regional specific answers

B.3 If it does not, does This Region need all of its current complement of airports, and are there particular airports whose development should be constrained and why?

B3.1 We do not support artificial constraint at airports where economic demand exists and where demand can be accommodated in a sustainable way.

B.4 If you are of the view that This Region should seek to accommodate its own demand (and attract demand from Adjacent Regions) how might this best be achieved? Can the existing airports be developed to provide sufficient capacity?

B4.1 We support the principle that regions should develop to meet their own demand - where that demand can be profitably served by the region. We also recognise that catchment areas may overlap - as differing airports offer a different range of services and choice.

B4.2 However it is worth recognising that regional airlines require a catchment area - with both volume and yield - to sustain profitable routes, especially in the case of longhaul destinations. This is reflected by the relatively slow growth in range of longhaul airlines at Manchester - even given the development of second runway.

B4.3 There is sometimes speculation that a multi-runway regional airport (such as an expanded Birmingham or Manchester) may have the potential to develop into regional hub over time, with airlines expanding their networks by feeding routes with transfer passengers. This would need to attract traffic from outside its immediate region (that might otherwise travel to London, Amsterdam or another European hub). This would be slot intensive, requiring frequent services on relatively small aircraft from regional points to feed the hub. In BA’s view any prospect of success for such a strategy would be undermined indefinitely if attempts were made to develop a second hub in the South East.

B.5 Is it important that demand should be met direct from This Region , or can the needs of the region be met by passengers interlining at hubs elsewhere in the UK or in continental Europe

B5.1 It is important that demand should be met from the regions where it is economically viable to do so. Nevertheless, interlining is also important to allow passengers access to greater choice and there are important advantages to passengers, UK airlines and the UK economy of passengers interlining at UK Airports rather than European Airports.

B5.2 There is a need to be realistic about what can be achieved by direct services. In many cases local demand may only justify low frequencies (one service a day on shorthaul or one service a week on longhaul) which may not meet the needs or offer the level of flexibility required by some passengers. It is therefore often not possible to meet all local demand without interlining.


B5.3 Where demand cannot be met directly, passengers are required either to interline or to use surface travel to another airport. There are some risks in relying on airports in continental Europe to provide interlining services to the UK. This is because, particularly in the case of smaller UK airports, these services are generally short distance and operated by small aircraft and are therefore the most likely services to get squeezed out if the European airports become slot constrained. Other drawbacks of relying on inter-continental hubs for interlining are outlined in question H.8 . BA therefore believe that it is in the UK’s interest for Government policy to encourage the provision of capacity for such services to operate into the UK’s major airport(s).


C: Competition v Complementary Development

C.1 Are there opportunities for greater partnerships between airports, airlines and the public sector stakeholders to foster the wider economic interests of This Region ?

C1.1 Opportunities should be considered to co-ordinate development for aviation in the regions - airlines, airports and other stakeholders. This should provide co-ordinated strategy both within the region and also pan UK. Priorities should be given to facilitate route development and reduce infrastructure and operating costs.

C1.2 It is critical for regional airline operations that the costs of development are integrated into and supported by national and regional funding e.g. surface access and such partnerships can help achieve this.

C.2 Is competition always preferable to complementary development? Do you think there are any circumstances in which the latter approach would bring wider economic or other benefits?

C2.1 BA considers that competition best stimulates price and service quality. The increasingly competitive market in the UK, both on domestic and European routes, means that airlines are reducing costs and offering competitive fares. Airports, too, must become less monopolistic and more competitive to ensure their costs also reflect the competitive nature of UK aviation business. Airport costs are rising whilst other suppliers are responding to the competitive market.

C2.2 Market forces in the regions have led to a natural development of airlines focusing at main airports.

C2.3 Where there are catchment overlaps then complementary developments have taken place e.g. Manchester and Liverpool. There are some benefits to complementary development. Some airport facilities are specialised and expensive and it makes economic sense not to provide all facilities in all locations. This needs to be weighed against the competition benefits of keeping price and service standards competitive.


D: Economic Benefits

D.1 How important is the contribution of aviation to This Region’s economy? How and where can the benefits be captured?

D1.1 The OEF report (The Contribution of the aviation industry to the UK Economy, 1999) highlighted the major contribution of aviation to the UK, although did not seek to break it down to a regional level.

D1.2 Regional airports are significant generators of employment (some 4000 direct, indirect and induced jobs per million passengers) and economic benefit in their own right.

D1.3 However, many other benefits are gained in the regions by virtue of access to global markets. The inward investment decisions and businesses that rely on those global links are critically dependent not just on the regional airport, but access to a major hub. These benefits can best be captured and preserved for the future by ensuring Heathrow’s competitive future by adding the regional runway proposed in the SERAS consultation.

D1.4 Other benefits to the regions of a thriving UK industry generally include the major aviation support functions which can be located elsewhere in the UK e.g. BA’s aircraft maintenance bases in South Wales and Glasgow, BA’s Information Management centres in Newcastle and its Glasgow, Newcastle and Manchester call centres. These would be at risk if the UK industry declined within Europe.

D.2 What barriers need to be addressed if the jobless on benefit, in particularly low employment areas, are to take advantage of the employment opportunities that arise from growth in aviation and airport services? Are there any solutions?

D2.1 A successful aviation industry not only generates opportunities itself but also has a multiplier effect, generating jobs indirectly as well as indirectly and inducing others. It can therefore support employment in a wider area than the immediate vicinity.

D2.2 At a local level, the best solution to enable these groups to take advantage of the growth opportunities at airports is to provide inexpensive, and ideally relatively rapid, public transport access from low employment areas to the airport employment areas. Use of planning law or incentives could also be given to airports/airlines and other key employers to locate functions that do not need to be on-airport in low employment areas.

D2.3 Aviation provides a huge range of employment opportunities spanning the full spectrum of education and qualifications. The location of airport development cannot be driven by the needs of low employment areas, as the traffic will not exist to drive the hoped for economic benefits.

D2.4 At a regional level, attracting inward investment to regional areas of the UK is often critically dependent on good air-links to London, ideally Heathrow.

D.5 Would improved air-links help to:

(a) increase inbound tourism to This Region ?(b) reduce reliance upon London as the primary point of interest for airborne inbound tourists?

D5.1 The quality of air-links is one of a number of aspects that influence potential tourists. Potentially in isolation and certainly in combination with other stimulating factors, improved air-links to the UK regions could contribute to increasing inbound tourism to those regions.

D5.2 Of more critical concern, however, is the potential impact on tourism if capacity in the UK was constrained. If capacity were constrained, it is most likely that this would translate into higher fares, with those passengers least prepared to pay higher fares squeezed out. These are likely to be leisure passengers rather than business passengers. However, more critically for the UK tourism industry, these are more likely to be inbound tourists rather than outbound tourists : this is because outbound tourists have limited choices of destination if they do not fly, while inbound tourists have many other choices and will increasingly limit trips to the UK if it does not offer value for money.

D5.3 It is not clear that increased air-links to other parts of the country would reduce the attractiveness of London to inbound tourists. Most tourists to the UK choose to include London as a main part of their itinerary, even if they also travel elsewhere in the UK. In many cases, also, London - not the UK - is the destination of choice and if services to London were not available many passengers would choose other destinations (such as


Paris, Amsterdam, Rome or Vienna) ahead of other UK destinations.

D5.4 For many passengers, where for reasons outlined in B.5 above, services can only be economically justified to London, the best way to stimulate travel to the UK regions may well be to provide improved air-links from the regions to London and better transfer facilities at the London hub to facilitate access to the UK regions.

D.8 How important are air cargo services for the economic objectives of This Region ?What measures are needed to give air freight and mail operators confidence to plan their long-term investment in airport facilities? Should night-time slots be guaranteed for air freight and mail? Should such guarantees be contingent upon noise/emissions standards of theaircraft being operated?

D8.1 As with other sectors of the aviation industry it is important for operators to be able to plan ahead with confidence. This is particularly important where investment is being made in dedicated facilities, but also applies to aircraft purchase where decisions may vary depending on the characteristics of the airports used.

D8.2 In the case of major freight operators, East Midlands is generally the preferred choice. They have little support for a new airport at Alconbury. BA believes that pressure is best taken off the South East airports by supporting the development of those freight facilities supported by cargo operators.

D.9 Is there scope for capturing more of the UK and global aircraft maintenance market at This Region’s airports and how might this best be achieved? What would be the advantages and disadvantages of encouraging growth of this sector?

D9.1 Operational maintenance must be carried out where aircraft are normally based and for this reason it is preferable that BA Engineering retains a presence at each of its main operating hubs. The success of operational maintenance is directly linked to the infrastructure provided at the airports in which the maintenance is carried out. Fleet and operational changes drive a requirement for flexibility and changes to the use of facilities. BA are considering the use of “Nose-in” and “wing-in” facilities which will allow efficiencies in the use of space at the airport. Security concerns are also an issue and this may impact the use of and accessibility of maintenance facilities. Other considerations for maintenance activity are towing delays leading to delayed maintenance inputs and poor infrastructure leading to poor utilisation of space.

D9.2 For other categories of maintenance, attracting global aircraft maintenance contracts relies on being competitive both in price and quality of service but there are also logistical requirements. Key amongst these is the ability to access the maintenance facility while minimising the time the aircraft is out of operation. This requires available slots at appropriate times at both the airport from which the aircraft is coming (usually its home base) and the airport at which the maintenance facility is located. This will therefore have implications for the runway capacity at the relevant airports.

D9.3 The increasing technical complexity of new generation aircraft will dictate a change in the methods and process used to maintain aircraft. Increasingly to maintain competitive advantage airlines are demanding higher utilisation from their aircraft assets. This in turn necessitates supplementary night maintenance activity requiring well-lit and modern facilities, which enable effective maintenance to be completed in line with manufacturers and regulatory requirements. In addition future fleet acquisitions may include the Airbus A380. Heavy maintenance and support for any fleet of BA A380s would almost certainly be devolved to a regional base in line with current strategy. This may involve a new dedicated facility in the regions or an extension of existing capacity in either Wales or Scotland. At present no hangars at Heathrow, or indeed the UK, can accommodate this aircraft. Meeting regulatory requirements stipulated by the CAA will necessitate the provision of facilities prior to entry into service.

D9.4 The provision and use of modern facilities could lead to direct benefits to the local community, as environmental benefits could be included in the design of new hangars. We would welcome the opportunity to engage in discussions with local communities regarding potential benefits.

D9.5 BA currently performs the majority of its major maintenance work in the regions. BA employs in the region of 1000 staff at Cardiff and approximately 200 in Glasgow. The scope for the devolved work depends directly on the success of BA’s mainline operation at Heathrow. The volume of maintenance activity varies directly with the number of aircraft in the fleet and the fleet age profile. Maintenance activity can be outsourced to MRO (Maintenance, Repair and Overhaul) providers either overseas or in the UK ; however BA aims to contain as much activity as possible in-house. In this way BA contributes to the economic well-being of the local communities through the direct generation of employment opportunities.


D9.6 The viability of regional maintenance centers is directly dependent on the availability of sufficient slots from BA’s Heathrow hub. In order to be efficient and effective it is necessary that slot availability and timings for maintenance purposes can be guaranteed. Increasing runway capacity at Heathrow, leading to an increase in the size of the BA operation is therefore the only viable way to support and/or generate maintenance development in the regions.

D9.7 BA recognises that as airports in the South East continue to grow there will be significant space constraints on MRO activity at main UK hubs. As outlined earlier BA has recognised this trend and is actively engaged in displacing MRO activity to regional sites. In order to support this strategy BA Engineering welcomes the positive efforts by the UK government to establish Centres of Vocational Excellence. To ensure CoVEs are effective BA Engineering would encourage the establishment of dedicated aerospace vocational centres around already established MRO clusters (Wales and Scotland).

D9.8 The growth of MRO activity in the UK is directly dependent on the availability of a relatively low cost, highly skilled workforce. Initiatives already started within regional centres must be expanded upon and grown if the UK is to maintain competitive advantage in the MRO global market.

D9.9 As with other categories of demand, it is important for maintenance activity to have certainty about the future. As well as the slot issue already identified, a clear long-term masterplan for the airport, including hangar and maintenance development sites, is important when identifying the potential locations for expansion/ redevelopment.

D.11 How important is it for your business/organisation that the UK remains the aviation Gateway to Europe.

D11.1 Critical. The UK is based in a prime position to be an effective gateway to Europe, and this is particularly important to BA. For passengers travelling between the US and Europe, Africa or the Middle East, the UK is in a prime position for a stop-off point or a transfer hub. BA can gain large economic benefits by attracting this market on its services. The valuable transfer market also enables thinner routes to become more viable, benefiting point to point passengers from the UK, and further boosting BA’s performance.

D11.2 See BA’s response to the SERAS consultation for full details.

D.12 Would the relaxation of the UK’s current policy in relation to international air service agreements to allow unlimited 5th Freedoms from regional airports, materially affect the ability of This Region’s airports to capture new services?

D12.1 The UK would need to exercise caution in ‘giving away’ 5 th freedom rights, with their limited UK benefits, without gaining any benefits in exchange.

D12.2 It is not clear that such freedoms would materially affect the ability of regional airports to attract traffic as generally if profitable demand exists between the two points an existing carrier is likely to already operate or consider operating it. To the extent that new services were attracted, they would reduce the ability for national carriers from the UK and other end of the route to compete on those routes. Where an overseas carrier is thus affected it could have implications on Bilateral negotiations.

D12.3 5th freedom services typically include a high proportion of transit passengers - not to be confused with transfer passengers. Passengers transiting the UK on 5 th freedoms make minimal contribution to the UK or the region and nothing to UK airlines, with modest benefits to the airport only. The benefits are small compared to transfer or direct passengers.


E: Social Inclusion

E.1 Can the development of aviation within This Region help to address deprivation and social exclusion?

E1.1 A successful airline operation at an airport requires economic demand to make it viable. This demand is generated by businesses or leisure passengers who are sufficiently affluent to afford air services. Where this demand exists, aviation - as an employment generator - can greatly assist a region but it cannot be used to solve deprivation and social inclusion issues.

E1.2 It is important to recognise that aviation in the UK, other than in the South East, has not been subject to any constraints and markets have been free to develop. Where airports have got close to constraints, new facilities have been provided, such as the new runway at Manchester. Arguably therefore, outside the South East, aviation is already fulfilling its maximum potential to address deprivation and social exclusion.

E1.3 Development in the South East, however, has been constrained for many years, particularly runway capacity. The result of this has meant that some routes have been squeezed out of London airports and others that might otherwise have been served have not had the opportunity to develop (Schiphol serves more UK points than does Heathrow, and it seems reasonable to assume that they could equally profitably be served from Heathrow if the slot capacity were there). This is limiting the potential for many parts of the UK to access global markets and depressing the potential economic development of those regions.

E1.4 Constraining growth - either in the South East or UK wide - will serve to exacerbate issues of social exclusion as market forces will dictate that air travel is increasingly restricted to those that can afford it and widening social divides.

E.2 What measures are needed to ensure the benefits of growth in the air transport industry are transmitted to less economically successful areas of This Region ?

E2.1 It is possible for some of the benefits of the growth in air transport to accrue to less economically successful areas. Critical to maximising the benefits of this, however, is the need to ensure that the aviation industry can operate as successfully as possible across the UK : the more successful the industry, the more potential benefits can be distributed.

E2.2 There are however limits to the extent that policy should attempt to ensure these benefits go elsewhere in a privatised industry which has to remain internationally competitive and we would challenge any presumption that this is feasible.

E2.3 Nevertheless, there are actions that policy makers can take to facilitate spreading the benefits of aviation. For example, support should be given to schemes, particularly public transport schemes that provide access to the airport and its jobs from less economically successful areas. Consideration may need to be given to providing discounted fares for workers.

Questions (continued)


F: Environmental Impacts

F.1 Are there any environmental impacts from the National Policy Scenarios or infrastructure projects appraised in this document which you regard as unacceptable?

F1.1 BA does not consider that there are any impacts that are unacceptable in the options to which it is giving its support.

F1.2 Nevertheless some impacts, such as demolition of churches or graveyards are particularly sensitive. If such impacts can reasonably be avoided by modifications to the proposal, they should be, where this can be done without impacting the viability of the project.

F.2 Could these environmental dis-benefits be controlled or mitigated to reduce them to acceptable levels? Do you have particular views on this in respect of:

• noise (day-time and night-time);• air quality (air traffic and surface access impacts);•land and property take (residential, agricultural, green belt, landscape);•biodiversity;•climate change;•other environmental impacts.

either in general, or at particular airports in This Region .

F2.1 The whole essence of sustainable development requires keeping environmental impacts to acceptable levels, which BA wholeheartedly supports.

F2.2 Distinction needs to be made between local impacts and global impacts. Climate change is a global impact and any impacts on it are driven by the overall level of aviation, not by a particular location. If the UK chose not to develop its aviation industry further, it is likely to decline at the expense of other European countries, creating no overall benefit in global impact terms.

F.3 Would you support the scenarios to keep pace with consumer demand if they carried with them enforceable targets for environmental improvement (e.g. air quality, noise, public transport mode split, energy savings, and waste reduction)?

F3.1 BA support scenarios to keep pace with profitable demand, subject to sustainability criteria. BA accept that standards need to be set for environmental impacts and in many cases such standards already exist.

F3.2 BA strongly support improvements in public transport, particularly rail, to airports but would note that funding for such links needs to reflect all those benefiting from the links.

F3.3 In general BA support standards that address environmental measures directly (e.g. noise, air quality levels) but strongly oppose any proxy measures such as limiting ATMs or passenger numbers which limit operations but do not necessarily deliver the environmental standards intended and, crucially, do not provide incentives for on-going improvements.

F3.4 See also BA’s response to the SERAS consultation questions 14 and 16 for details of the potential for stakeholder groups and voluntary agreements to tackle environmental improvements.


G: Surface Access

G.1 Under all our National Policy scenarios, we forecast that a significant number of passengers originating in at least two of the regions on [the North of England] will still use airports outside the region, predominately in the South East. Should surface access schemes to facilitate journeys from the regions concerned to these airports be considered? For example

• Direct services from Manchester to Heathrow and Gatwick.• New air-rail interchanges at Kings Cross-Euston-St Pancras, Peterborough and Watford or Milton Keynes offering improved connections from the East and West Coast Main Lines to major South East airports.• Enhanced Trans-Pennine links to Manchester from the North East and Yorkshire and the Humber.• In the longer term a new North-South high speed line to London and the near continent via the Channel Tunnel rail link with links to Heathrow and possibly Manchester and Birmingham airports.

G1.1 See response to G2 below

G.2 Should the focus of any public expenditure which may be available to help improve surface access to This Region’s airports be on improving local or inter-regional access or both, and why?

G2.1 It is British Airways' view that the prime focus for the development of improved opportunities for surface access to airports should be the creation of new and enhanced facilities for local, sub regional and regional access, with long-distance inter-regional (or even international) schemes generally having a lower priority.

G2.2 In terms both of absolute numbers of users likely to be attracted, and the probability of generating mode shift away from the private car, such local and regional schemes appear to hold out greater prospects of being successful than national-scale schemes and therefore, overall, of contributing more positively to the general development of better integrated transport as a policy objective.

G2.3 We also believe that the scale of investment required and the timescales required for the creation of major transport developments - especially significant rail projects - means that such local and regional schemes have substantially greater likelihood of successfully being funded and brought to fruition than national-scale development. The West Coast Mainline upgrade and Channel Tunnel Rail Link development do not provide encouraging precedents for major rail scheme implementation.

G2.4 In addition, the environmental case for rail substitution of regional air services for long-distance and inter-regional access to major airports is, at best, unproven and British Airways believes that there is no evidence on the basis of which it would be proper to pursue such substitution as a matter of public policy.

G2.5 In terms of funding, BA recognises that it is Government policy for aviation to assist in the funding of the development of transport links to airports to the extent that aviation benefits. It seems most unlikely to British Airways that the benefits to aviation of some of the more ambitious schemes - e.g. for new North-South high speed rail links - would imply that any substantial funding for such schemes might reasonably be expected from aviation.

G2.6 However, where schemes which are likely to be brought to fruition for other, broader reasons - such as improved trans-Pennine links or Crossrail in London - can be utilised or adapted at reasonable cost to provide useful airport access facilities - e.g. "gateway" stations, significant interchange points, or even direct airport access, British Airways would certainly support, in principle, such opportunities being pursued.

G.3 Under many of our National Policy Scenarios there will be a large increase in the number of passengers using This Region’s airports over our forecasting period. Our analysis indicates this will place considerable strain on surface access provision, particularly key roadlinks in a number of places:• Should these surface access constraints be addressed?• Which schemes outlined in the document do you consider are the key ones for improving access to the regions airports and what priority should they be given relative to other projects. Which do you think should not be taken forward?• Are there any surface access schemes identified in the analysis that you support or oppose? Please give your reasons.• Are there any surface access improvements, which should be regarded as pre-conditions before new capacity can take place at airports within the study area?• How should these surface access improvements be funded?


G3.1 British Airways is not able to comment in detail on specific scheme proposals at all regional airports covered by the consultation. It believes, however, that a number of underlying principles should apply to the consideration of these issues. Some of these are outlined in the answers to other questions in this section. Some other considerations are outlined here:

i). Where it is reasonable and practical to provide viable alternatives to the car for airport access - particularly new or improved rail links - British Airways believes that these should be pursued as a priority. However, at many regional airports, particularly the smaller ones, such options will not be available and upgrading of road capacity will be the only practical means available of avoiding the substantial inconvenience and economic disadvantage of congestion for airport-related and all other users of the road network.

ii). British Airways does not consider that for longer inter-regional journeys - e.g. from the South West to Heathrow or Birmingham, it is likely that the level of demand or potential funding available would support the development of rail or road schemes specifically to meet the needs of air passengers over and above the general needs of other long-distance travellers over the same routes. As indicated above, where suitable access can be provided as part of a wider scheme - e.g. Heathrow access via the "Western Connection" to the GWR mainline, which could have substantial benefit for travellers from Wales, the West and South West as well as the Thames Valley, could form part of a wider package of much-needed capacity improvements to this line. British Airways notes, however, that in many cases, the surface journey could be avoided altogether if adequate capacity were provided at main airports, particularly Heathrow, to permit a range of direct air services to the regions to be maintained or resumed.

iii). With respect to funding, British Airways would expect contributions from aviation to be limited to the benefits which aviation will gain from particular developments. Many access schemes will contribute to the achievement of overall public policy objectives for the creation of an improved and more integrated transport network and, as such, should be a high priority for a full measure of support from the public purse.

G.4 How might the share of public transport access to airports be increased?

G4.1 British Airways believes that the public - both air passengers and staff - will use public transport for airport access where those public transport facilities provide a genuine and reasonable alternative to the private car when measured against the key determinants of cost, convenience and time.

G4.2 It therefore follows that the creation of alternatives which meet those criteria is most likely to lead to success in increasing the share of public transport access to airports. Following from the answer to questions G.2 and G.3 above, in general, the shorter the travel distances involved and the denser the concentration of prospective users, thus allowing greater frequency of services, the more probability British Airways believes there is of meeting those criteria and successfully generating mode shift.

G4.3 In principle, British Airways prefers the use of "carrots" to encourage the use of public transport rather than "sticks" to force users in to taking actions they would not otherwise choose. The provision of subsidy to support the provision of bus services which might not otherwise be provided at an adequate frequency, or during off-peak hours is an example of one such measure which has been successfully employed at some airports. Some measures intended to discourage car use can, of course, have an opposite effect. There is a balance to be struck, for example, between keeping airport long term parking charges sufficiently high to avoid encouraging car use, whilst ensuing that they are not so high that they result in a significant substitution by taxi or "kiss and fly", which actually doubles the number of vehicle journeys.

G4.4 British Airways does recognise that "carrots" alone may not always produce the desired result. It nevertheless does not support the use of draconian measures to force users on to inadequate and inconvenient public transport but does believe that there may be circumstances in which a degree of carefully targeted and proportionate discouragement or restriction on car use may be a useful adjunct to the provision of reasonable public transport alternatives.

G4.5 The provision of such reasonable public transport alternatives for airport access will, in many instances, need to be supported by external funding and whilst airport operators and airlines can (and already do) provide some measure of assistance, as a general principle, once again, aviation should not be expected to provide funding in excess of the value of the benefits that it derives from the provision of particular transport schemes. In many cases this will imply a requirement for funding from the public purse if the public policy objective of reducing car dependence is to be met.


H : Access to London

H.1 Would it be desirable to have a greater number of flights from the region’s airports to London?

H1.1 Yes, if capacity is available. However, if London capacity is constrained, the relative desirability of these services would need to be compared with the alternatives. If Heathrow were to get a new regional runway, the government would need to consider how to ensure a proportion of that new capacity is made available for regional services.

H.2 From which airports in the region to which London airports?

H2.1 See answer to H3 as to why Heathrow has particular benefits.

H2.2 There may appear to be benefits in serving as many points as possible in a region to as many London airports as possible to offer maximum choice. However there are trade-offs between frequency and number of airports served in a region (either number of London airports or number of regional airports) i.e. if demand is spread between a number of different airports, this will tend to reduce the frequency of services possible from any one airport. Frequency is particularly important for the business market.

H.3 Would these be beneficial mainly for:

• Access to London itself?

H3.1 Additional flights to London airports would all benefit access to London itself. In general, the higher the catchment area of the airport (both for originating and destination passengers), the greater the benefit (although if an airport is significantly under-served compared to its catchment the benefits may be higher).This means that for most regions, access to Heathrow is strongly preferred as it is the best located airport for the majority of the demand.

• Access to onward flights? H3.2 The benefits of access to London airports for onward flights are even more strongly stacked in favour of Heathrow. For access to onward flights, not only do passengers need the range of connections that a substantial hub serves (which increase exponentially with size) but they also require an acceptable transfer service. For most passengers this means being able to check-in for both sectors at the first airport, to check baggage through to the final destination, to have staff and transportation on hand to facilitate the journey through the transfer airport, for alternative arrangements to be made should the incoming flight be delayed causing a missed connection for passenger and/or baggage; this is facilitated by passengers travelling with a single airline or alliance. Passengers generally also prefer an airport with a large number of services so that, if there are problems, there are likely to be viable alternative flights.

H3.3 These requirements mean that while there are limited transfers at other airports, the main benefits to passengers from onward connections are achieved at Heathrow, the only airport with an internationally competitive network and the base for two alliances (oneworld and Star) which market transfers through the airport. Transfers at, or between other London airports, are small in comparison and benefits are far less.

H.4 Should additional capacity be provided at any of the London Airports (please specify) to assist such connections?

H4.1 Additional capacity should therefore be provided at Heathrow to assist such connections. The short runway proposed at Heathrow provides additional capacity for shorthaul services from the regions. Combined with Heathrow’s existing network and growth potential with a new runway, this proposal would provide a very competitive range of potential one-stop destinations for the regions.

H4.2 Adequate transfer infrastructure would need to be provided as part of the Heathrow development package to enable this potential to be maximised and to provide an attractive product to passengers.

H4.3 Capacity at Stansted is unlikely to offer similar benefits as there is no network carrier based there to offer the connection requirements (as outlined in H.3 above). The “no frills” carriers and charters that take up the vast majority of existing capacity do not provide transfer facilities or infrastructure and their business model looks unlikely to change to accommodate this level of complexity even if additional runway capacity were provided at Stansted. There is no evidence that a network carrier would choose to base itself at Stansted or


Cliffe, and therefore any assumptions of substantive transfer potential would be purely speculative.

H.5 If access to London area airports continued to be/was further restricted, to what extent would this be off-set if a wider range of services was available from or within the region to other major airports and particularly to Manchester, Birmingham and Edinburgh?

H5.1 None of Manchester , Birmingham and Edinburgh have the catchment areas, either in terms of volume or yield, to provide anything close to the range of services offered by London. The numbers of connection opportunities increase exponentially (with the number of services), so these are substantially less at these airports and the off-set effect would be relatively small.

H5.2 If access to London for onward connections was restricted, most passengers would look to other hubs providing good frequencies of onward connections, primarily Paris CDG, Amsterdam and Frankfurt.

H.6 Would high-speed rail access (to London) provide an adequate alternative to domestic air services to London and its airports, or should they be seen as complementary to them?

H6.1 High speed rail links between airports could provide an adequate alternative to air links, for journeys up to about 3 hours by rail. This would mean, for example, that there might be potential to substitute Heathrow-Manchester with a high speed rail link, but other potential is very limited. Information from Manchester airport suggests that most existing passengers on the Heathrow-Manchester route are either transferring to another flight (and therefore much less likely to accept a mode change) or travelling to and/or from locations in the vicinity of Heathrow airport or Manchester airport. Passengers from city centre to city centre generally already use rail links.

H6.2 The experience of the effect of the Channel tunnel rail link on Paris flights was that although some traffic was substituted (and significant traffic stimulated), air service frequencies remained broadly similar - reflecting the demand for frequency - but operated by smaller aircraft (to reflect the substituted demand). As such, while high speed rail may attract passengers, it may not generate any reduction in runway capacity requirements, unless the air service is dropped completely.

H6.3 For longer journeys, air and rail can only reasonably be complementary as it is at least as important to offer the ability for day trips between major UK cities as it is between UK cities and key European cities. In the absence of a national network of TGV-style very high speed lines, only air can meet this need.

H6.4 Even where this (limited) potential for high-speed rail may exist, BA is concerned that neither the economic nor environmental case for such substitution is proven. There is no conclusive evidence of which BA is aware which demonstrates that high speed rail is more environmentally sound than air. It also seems probable that the costs of the creation of high speed lines would significantly exceed any likely benefit to aviation, leaving a funding gap to be filled from other private investment sources or by public funding. We are not persuaded that such development should be a priority for public funding and would be concerned about subsidisation in a competitive market.

H.7 What are the best means of securing access to the South East’s airports in your region?

H7.1 The best means to secure access is to provide sufficient capacity to meet market demands. The closer to this that can be achieved, the lower the vulnerability of the regions to finding access is limited by capacity.

H7.2 The provision of a short Heathrow runway would provide some reassurance for the regions as that capacity would be limited in the range of aircraft types that could be accommodated therefore protecting capacity for shorthaul services in perpetuity.

If access could be guaranteed to some degree, which criteria should be used to determine priorities for access?

H7.3 The UK has only one viable option for an internationally competitive hub in the medium term, providing an additional runway at Heathrow. The Heathrow option’s capacity should be used largely or exclusively to contribute to expanding its hub potential. As such, it would make sense if priority were given to new destinations (both UK and international), increasing capacity on existing destinations (to a pre-defined optimal level for that destination or route type) and to those carriers who offer interlining capability, if this can be managed within appropriate legislation.

How would national and regional interests be balanced?


H7.4 The best means to balance national and regional interests would be to ensure that a proportion of new capacity was allocated to the regions. For example, with a new regional runway at Heathrow generating some 200,000 atms per annum, if 5-10% were allocated to the regions this would enable some 30-60 flights per day from Heathrow to the UK regions. The government would have to consider how such an allocation was best achieved.

H.8 Does it matter whether demand from This Region is served directly from the region, or by more passengers interlining by way of hubs elsewhere in the UK or in continental Europe?

H8.1 Where economic demand and adequate yield exists to serve a route directly it is clearly preferable for passengers.

H8.2 However, very often demand on a route is not sufficient to sustain a service or to sustain a sufficiently high frequency of service to meet the needs of travellers. There is therefore a very important role for interlining by way of hubs elsewhere which complements the contribution made by a regional airport and gives the passenger additional travel options.

H8.3 For some passengers, it may not matter whether the hub is elsewhere in the UK or in continental Europe. However, potential downsides of being forced to transfer in Europe rather than the UK because no service exists in the UK include: i) revenue for the onward connection (and usually for the connection, as most will be same-carrier

connections) will go to a foreign airline, ii) reluctance of some passengers to transfer at a ‘foreign’ airport in case of delays/disruption, iii) dependence on the availability of slots at the overseas hub airport (if the hub airport becomes constrained);

short sectors served by small aircraft being the most likely routes to be squeezed out, iv) exporting to Europe those aviation jobs which support transfer traffic,v) the services offered from a UK hub are more likely to meet the needs of the UK passenger, reflecting both

the UK’s historic trading links and those countries from which UK has large immigrant or emigrant populations where trips to visit friends/relations are an important sector of the market,

vi) transfer passengers add to the passenger volumes on flights which improve unit costs. This makes fares more competitive for direct passengers. A greater proportion of these benefits accrue to UK passengers if they transfer in the UK.

H.9 What level of importance should be ascribed to the development of a wide range of direct services from This Region as a whole and its individual component regions?

H9.1 Regions of the UK require good air-links to attract inward investment to their regions. It is also critical to support existing businesses. Nevertheless, this need can be fulfilled either by direct services or by good, frequent access to a major hub. In many cases, the frequency of service that can be provided from a hub may provide a service better suited to the demands of business than an infrequent direct service. Other routes may only justify being served from one or very few UK points by gathering all the passengers together; lack of support for the hub airport that provides this impacts all of the UK that would make use of them.

H9.2 Policy should support development of regional airports to their full economic potential but not at the expense of services elsewhere which also have a key role to play in supporting the needs of regional passengers.


The following pages cover questions which are only asked in the consultation documents for particular regions and/or relate to specific airport developments in that region.


MIDLANDS (MID)

This section on the Midlands covers only particular questions on new runway capacity in the Midlands. It should be read in conjunction with the main RASCO report for all other aspects of the RASCO response. Specific references to the Midlands or airports in the Midlands region also occur in the main report : Summary, A3.2 (National Policy scenarios), B2.1 (BACX bases), B4.3 (multi-runway airports), D8.2 (Freight), G3.1 (Inter-regional links), H5.1 (Range of services) .

Questions on Part 3 Options (Chapter 7)

1 Do you think that Government should, as part of its policies for airports in the period up to 2030, support in principle the construction of a new runway/runways/new airport site for the Midlands?

2 If you consider that a new runway for the Midlands should not be supported, on what grounds is this view based? What if any alternative options would you support for increasing capacity in the region? For example, development of secondary airports, notably Coventry, Wolverhampton Business Airport and potentially RAF Cosford, in order to serve commercial passenger flights.

3 On the basis of our appraisal of options for new runway capacity at Birmingham and East Midlands Airports as well as a new airport for the Midlands, which if any of these do you believe best serves the interests of the region in terms of the following:

· Providing accessibility to a wide range and frequency of air services for air passengers originating in the Midlands.

· Maximising economic benefits for the Midlands (in terms of the impacts of both passengers and freight).

· Providing additional capacity in the most sustainable manner.· Which of these options do you support overall?

4 Should the development of a new runway/or new airport site for the Midlands be made dependant upon imposition of planning conditions, for example measures to regulate and govern local air quality emissions, aircraft noise exposure, public transport mode split etc?

5 Do you agree the land required for an additional runway/or new airport site should be safeguarded in the forthcoming Air Transport White Paper?

6 Our appraisal of the financial viability of new runways at existing airports and the new site for the Midlands, indicates that some form of public funding might be required to fund their development. Would you support the use of public money for airport infrastructure development?

MID7.1 BA consider that the Government should support an additional runway in the Midlands in the period to 2030 and believe that Birmingham is the best location for this because :-i) there is a need to concentrate demand to get competitive levels of frequencyii) Birmingham is the best located airport in the Midlands, near to the city centreiii) Birmingham has the best road and rail linksiv) Birmingham provides an option for some passengers in the Northern fringe of the South East regionMID7.2 In particular, Birmingham needs capacity in the peak to develop new, competitive services.

MID7.3 BA welcome BIA’s recent proposal “The Birmingham Alternative”, where a shorter (2000m) runway option with reduced environmental impacts (specifically reducing the number of properties required, reducing the amount of Green Belt land required by half, preserving the sites of special scientific interest Bickenhill Conservation area and reducing numbers affected by severe noise) was put forward. The option also includes lengthening the existing runway. BA believes this option best meets the criteria set out in question 3 above. In particular, such a runway would help support the development of additional regional jet services.

MID7.4 BA does not support the option of a new airport in the Midlands. BA believes there are good reasons not to add to the number of existing airports serving broadly similar markets. These include :-i) the overall land take required is minimised if demand is concentrated at fewer airports,ii) duplication of services is reduced, iii) new people are not exposed to noise and other impacts in areas that were previously well away from airport

development.


iv) if the funding available for surface access infrastructure is spread across a number of airports this imposes limitations on what can be provided. Similarly spreading demand across a number of airports reduces the viability of some links. As a result, higher levels of public transport can be achieved with fewer airports serving a region.

In addition the new airport at Rugby is presented as a potential substitute for growth in the South East. BA believe this is a highly flawed approach.

MID7.5 BA does not support the use of public money to develop uneconomic facilities. However BA would encourage the use of public monies to support infrastructure links to airports where these benefit the wider community.


NORTHERN IRELAND (NI)

This section on Northern Ireland covers only the particular question relating to PSOs for Northern Ireland routes to the South East of England. It should be read in conjunction with the main RASCO report for all other aspects of the RASCO response for Northern Ireland.

H.2 In view of the evidence presented in the document is retention of the existing services to South East airports essential? Should this be subject to slot ring fencing and if necessary a PSO if loss of the service is threatened?

NI.H2.1 BA believe that regional air links to London are a major factor in attracting inward investment to the regions. They are also important for business trips and providing links to the networks of services provided from London. NI.H2.2 There are two specific needs that need to be met, firstly, a link to London and secondly a link to the network of services provided by a global hub. Arguably any of the London airports can provide an adequate link for point-to-point traffic although Heathrow, and to a lesser extent Gatwick, are better located for the majority of passengers. However, for onward connections, a service to Heathrow is far superior to any other London airport.

NI.H2.3 We believe that in general terms the provision of additional capacity at airports where there is demand is preferable to ring-fencing slots for particular services. As BA identify in paragraph A2.1(i) above, there may be potential to protect a proportion of new slots on the new runway for use by regional services not currently served at Heathrow.

NI.H2.4 In BA’s view, the best solution to protecting links from destinations such as Northern Ireland is to provide a regional runway at Heathrow, providing capacity that can only be used for Domestic and near European services.


NORTH OF ENGLAND (NOE)

This section on the North of England covers only particular questions on airport development in the region. It should be read in conjunction with the main RASCO report for all other aspects of the RASCO response. Specific references to the North of England or airports in the region also occur in the main report : Summary, A3.2 (National Policy scenarios), B2.1(BACX bases), B4.2 (Longhaul airlines at Manchester), B4.3 (multi-runway airports), C2.3 (catchment areas), D1.4 (BA Information management bases), E1.2 (addressing deprivation), G2.6 (trans-Pennine links), H5.1 (catchment areas), H6.1 (London-Manchester passengers).


See answers to B.2

B.2 If your preferred strategy for The North of England involves accommodating growth in air services, where would the projected levels of growth best be accommodated and what form of airport development should be supported in order to achieve this?

Manchester

NOE.B2.1 BA is in general agreement with the proposals for growth in apron and terminal infrastructure at Manchester airport outlined in the consultation document and recognise that substantial development will be necessary for Manchester to reach its full potential.

NOE.B2.2 Runway capacity at Manchester is not a critical need given the recent opening of Runway 2. We agree with the issues identified in the consultation report concerning the possibility of a 3 rd runway. While these may bring forward such demand into the very end of the 30 year consultation period, this is by no means guaranteed and as such it is not appropriate, and critically not necessary given the timescale for runway development, to make a firm decision on 3rd runway at this stage.

NOE.B2.3 Under current preferred options it is unlikely that Manchester will develop as a major hub but it is important for connectivity between UK airports and Europe. There are also opportunities for further route development and growth associated with alliance partners. We would note that any proposals which attempt to develop a second hub in the South East would undermine the prospects of developing Manchester as a regional hub (see BA’s response to SERAS paragraphs 122 and 128 and paragraph B4.3 above).

NOE.B2.4 In the short term we believe that apron infrastructure will become a capacity restraint and this will become a critical infrastructure issue.

NOE.B2.5 Consultations on terminal extensions and further development of options for the site of a 4 th Terminal should commence in the short term.

NOE.B2.6 Surface access also needs to be improved but it is critical that airport and regional benefits of development should be clearly identified and funded accordingly.

NOE.B2.8 We assume that Liverpool will act as complementary airport development in the north of England region.


SCOTLAND (SC)

This section on Scotland covers only particular questions on airport development and policy mechanisms in the region. It should be read in conjunction with the main RASCO report for all other aspects of the RASCO response. Specific references to Scotland or airports in the region also occur in the main report : Summary, A3.2 (National Policy scenarios), B2.1(BACX bases), D1.4 (BA Information management bases), D9.3/D9.5/D9.7 (Engineering facilities), H5.1 (catchment areas).


SC.B1.1See answers to B.2.

B.2 If your preferred strategy for Scotland involves accommodating growth in air services, where would the projected levels of growth best be accommodated and what form of airport development should be supported in order to achieve this?

B.4 Should the case for constructing a new airport in Central Scotland still be considered?What would be the basis for such a case? When should it be built and how might it be funded?• As an alternative to a new airport, should an additional runway be built and if so where? At Glasgow or Edinburgh?• Should runway extensions at Edinburgh and Aberdeen be supported?

SC.B2.1 BACX has substantial operations based at both Edinburgh and Glasgow and currently intend to continue and develop both.

SC.B2.2 BA recognises that there is likely to be a need for an additional runway in the Scottish Lowlands towards the end of the consultation period.

SC.B2.3 BA does not think that a new airport in the Scottish lowlands should still be considered. Replacing one of the existing airports is a hugely costly option and adding an additional airport would tend to duplicate services. The lack of concentration in any one location would make it difficult to achieve the stated policy objectives of wider route networks.

SC.B2.4 BA does not, at this stage, have a view as to which of Edinburgh and Glasgow is the best location for an additional runway. Again, a final decision is not required at this stage in order to deliver a runway near the end of the 30 year period. The future rates of development of the two airports and market demands over the coming years will help determine the relative economic potential for additional runways, along with the environmental, social and cost data.

SC.B2.5 However, it would be helpful if the preferred development at each airport, should a new runway go ahead, be identified. This would help with interim planning of other facilities by identifying the relevant areas of the airport that would be impacted by future runway plans.

SC.B2.6 BA supports the proposed improvements to existing infrastructure at Edinburgh, notably the parallel taxiway.

H.2 What policy mechanisms or approaches should the Government explore to ensure that access to London Airports from Scotland is maintained or improved.

SC.H2.1 BA believe that regional air links to London are a major factor in attracting inward investment to the regions. They are also important for business trips and providing links to the networks of services provided from London.

SC.H2.2. There are two specific needs that need to be met, firstly, a link to London and secondly a link to the network of services provided by a global hub. Arguably any of the London airports can provide an adequate link for point-to-point traffic although Heathrow, and to a lesser extent Gatwick, are better located for the majority of passengers. However, for onward connections, a service to Heathrow is far superior to any other London airport.


SC.H2.3 We believe that in general terms the provision of additional capacity at airports where there is demand is preferable to ring-fencing slots for particular services. As BA identify in paragraph A2.1(i) above, there may be potential to protect a proportion of new slots on the new runway for use by regional services not currently served at Heathrow.

SC.H2.4 In BA’s view, the best solution to protecting links from destinations in Scotland is to provide a regional runway at Heathrow, providing capacity that can only be used for Domestic and near European services.


SOUTH WEST (SW)

This section on the South West covers only particular questions on use of airports outside the region , PSOs for airports in this region, and accommodating growth in the region. It should be read in conjunction with the main RASCO report for all other aspects of the RASCO response. Specific references to the South West or airports in the region also occur in the main report : A3.2 (National Policy scenarios), B2.1(BACX bases), G3.1 (Inter-regional links).

G.3 Under all our UK National Policy Scenarios, we forecast that a significant number of passengers originating in the South West still use airports outside the region, such as Heathrow and Birmingham.

• Should surface access schemes to facilitate journeys from the South West to these airports be considered?• What priority should be given to the improvement of surface access to airports outside the region for passengers originating in the South West?• How should these surface access improvements be funded?

SW.G3.1 We agree with the assessment that a significant number of passengers originating in the South West will use airports outside the region, predominantly Heathrow and Birmingham. These airports are likely to remain the most convenient choices for many journeys, irrespective of any surface access improvements. BA would note that other South East airports, identified in SERAS as potential options for new runways, are substantially less easy to access from the South West and the importance of adequate Heathrow capacity for the people of the South West should not be underestimated.

SW.G3.2 British Airways is not able to comment in detail on specific scheme proposals at all regional airports covered by the consultation. It believes, however, that a number of underlying principles should apply to the consideration of these issues. Some of these are outlined in the answers to other questions in this section. Some other considerations are outlined here:

SW.G3.3 Where it is reasonable and practical to provide viable alternatives to the car for airport access - particularly new or improved rail links - British Airways believes that these should be pursued as a priority. However, at many regional airports, particularly the smaller ones, such options will not be available ; upgrading of road capacity will be the only practical means available of avoiding the substantial inconvenience and economic disadvantage of congestion for airport-related and all other users of the road network.

SW.G3.4 British Airways does not consider it likely that, for longer inter-regional journeys - e.g. from the South West to Heathrow or Birmingham, the level of demand or potential funding available would support the development of rail or road schemes specifically to meet the needs of air passengers over and above the general needs of other long-distance travellers over the same routes. As indicated above, where suitable access can be provided as part of a wider scheme e.g. Heathrow access via the "Western Connection" to the GWR mainline, which could form part of a wider package of improvements to this line, this could generate substantial benefit for travellers from the West and South West (as well as Wales and the Thames Valley). British Airways notes, however, that in many cases, the surface journey could be avoided altogether if adequate capacity were provided at main airports, particularly Heathrow, to permit a range of direct air services to the regions to be maintained or resumed.

SW.G3.5 With respect to funding, British Airways would expect contributions from aviation to be limited to the benefits which aviation will gain from particular developments. Many access schemes will contribute to the achievement of overall public policy objectives for the creation of an improved and more integrated transport network and, as such, should be a high priority for a full measure of support from the public purse.

Bristol (BRS) SW.G3.6 BA agree that the most critical development for Bristol is improved road access, particularly given its distance from the city centre. Without a significant upgrade this will impact Bristol’s role as major airport for the South West region.

H.2 In view of the evidence presented in the document is retention of the existing service from Gatwick to Plymouth and Newquay essential? Should this be subject to slot ring fencing at Gatwick and if


necessary a PSO if loss of the service is threatened?

SW.H2.1 BA believe that regional air links to London are a major factor in attracting inward investment to the regions. They are also important for business trips and providing links to the networks of services provided from London. SW.H2.2 In BA’s view, a service from Plymouth and Newquay to Heathrow would better serve the needs of the South West as it would provide the link to London but also provide a more attractive link to the far superior network of services available from Heathrow.

SW.H2.3 We believe that in general terms the provision of additional capacity at airports where there is demand is preferable to ring-fencing slots for particular services. As BA identify in paragraph A2.1(i) above, there may be potential to protect a proportion of new slots on the new runway for use by regional services not currently served at Heathrow.

SW.H2.4 In BA’s view, the best solution to protecting links from destinations such as Plymouth and Newquay to London is to provide a regional runway at Heathrow, providing capacity that can only be used for Domestic and near European services.

Bournemouth/Southampton


SW.B1.1 See answers to B.2.

B.2 If your preferred strategy for the South West involves accommodating growth in air services, where would the projected levels of growth best be accommodated and what form of airport development should be supported in order to achieve this?

SW.B2.1 BACX’s intention to develop operations at Southampton rather than at Bournemouth reflect the substantially greater catchment. BA support upgrading the runway at Southampton. Improvements to terminal infrastructure and access will also be required for Southampton to fulfil its potential.

SW.B2.2 BA also considers that Southampton could make a useful contribution to meeting sub-regional shorthaul demand although it is no substitute for London capacity.

SW.B2.3 See also BA’s response to the SERAS consultation as Southampton is treated as a South East airport by the Department for Transport.


WALES (WAL)

This section on Wales covers only the particular questions on access to airports outside the region and aircraft maintenance. It should be read in conjunction with the main RASCO report for all other aspects of the RASCO response. Specific references to Wales also occur in the main report : D1.4 (BA maintenance bases and Information management bases), D9.3/D9.5/D9.7 (Engineering facilities), G3.1 (Inter-regional links).

1 Access to London Under all our UK National Policy Scenarios, we forecast that a significant number of passengers originating in Wales will still use airports outside Wales, predominantly Heathrow for passengers from South Wales and Manchester for passengers in North Wales.

• Should surface access schemes to facilitate journeys from the Wales to these airports be considered?• What priority should be given to the improvement of surface access to airports outside the region for passengers originating in the Wales ?• How should these surface access improvements be funded?

WAL1.1 We agree with the assessment that a significant number of passengers originating in Wales will use airports outside Wales, predominantly Heathrow for passengers from South Wales and Manchester for passengers from North Wales. These airports are likely to remain the most convenient choices for many journeys, irrespective of any surface access improvements. In the case of South Wales passengers, BA would note that the other South East airports identified in SERAS as potential options for new runways, are substantially less easy to access from South Wales and the importance of adequate Heathrow capacity for the people of South Wales should not be underestimated.

WAL1.2 British Airways is not able to comment in detail on specific surface access scheme proposals at all regional airports covered by the consultation. We believe, however, that a number of underlying principles should apply to the consideration of these issues. Some of these are outlined in the answers to other questions in this section. Some other considerations are outlined here:

WAL1.3 Where it is reasonable and practical to provide viable alternatives to the car for airport access - particularly new or improved rail links - British Airways believes that these should be pursued as a priority. However, at many regional airports, particularly the smaller ones, such options will not be available; upgrading of road capacity will be the only practical means available of avoiding the substantial inconvenience and economic disadvantage of congestion for airport-related and all other users of the road network.

WAL1.4 British Airways does not consider it likely that, for longer inter-regional journeys - e.g. from Wales to Heathrow or Manchester, the level of demand or potential funding available would support the development of rail or road schemes specifically to meet the needs of air passengers over and above the general needs of other long-distance travellers over the same routes. As indicated above, where suitable access can be provided as part of a wider scheme e.g. Heathrow access via the "Western Connection" to the GWR mainline, which could form part of a wider package of improvements to this line, this could generate substantial benefit for travellers from Wales, (as well as from the West and South West and the Thames Valley). British Airways notes, however, that in many cases, the surface journey could be avoided altogether if adequate capacity were provided at main airports, particularly Heathrow, to permit a range of direct air services to the regions to be maintained or resumed.

WAL1.5 With respect to funding, British Airways would expect contributions from aviation to be limited to the benefits which aviation will gain from particular developments. Many access schemes will contribute to the achievement of overall public policy objectives for the creation of an improved and more integrated transport network and, as such, should be a high priority for a full measure of support from the public purse.

2 Aircraft Maintenance Cardiff already serves as an important focus for aircraft maintenance and related activities.: how can this sector’s potential be maximised throughout Wales?


WAL2.1 The main RASCO report, section D9 outlines the requirements for aircraft maintenance and the key issues that would drive further development of aircraft maintenance in Wales or elsewhere. We would note particularly that scope for such devolved maintenance relies on the success of BA’s Heathrow operation (see main report D9.5). We would note also the potential for new or expanded capacity in the regions should BA, in the future, choose to operate a fleet of Airbus A380s (see main report D9.3) .


Documents

Regional Response - Generic · Web viewOur response specifically identifies the three largest potential developments at Birmingham, Manchester and in the Scottish Lowlands. However,