UK airlines Aviation Strategy Green Paper response

June 20, 2019

Responding to the deadline for submitting responses to the Government’s Aviation Strategy Green Paper, Tim Alderslade, Chief Executive of Airlines UK, the industry association that represents 13 UK-registered carriers, said:

“Airlines believe we need a strategy that meets the Government’s stated ambition of promoting sustainable growth for our sector, which makes such a vital contribution to the UK’s social and economic life. We understand aviation has to earn the right to expand and that’s why we’re committed to halving our emissions by 2050, and working with national governments to agree an ambitious plan that can deliver a zero carbon future.

“We want to continue connecting families and businesses across the regions and to the world, delivering excellent value for money, and doing more to make air travel accessible for passengers.

“Provided it can be delivered sustainably, we also support additional capacity where it is needed, as long as operational resilience is prioritised and it does not lead to higher charges for passengers and cargo operators.”

The Aviation 2050 strategy should:

Build UK connectivity

• Promote the further liberalisation of international air transport, the modernisation of obsolete restrictions on airline ownership and seek to establish an ambitious new relationship with the European Union that protects all current market access.
• Support the delivery of Heathrow on time and with no additional costs to airlines, and ensure any domestic slots that are not used are available for general use.
• Support airport expansion where it is needed, provided it is privately funded – with Government not picking winners – and that airport charges do not increase and operational resilience is built in. This support must be contingent upon the UK being able to meet its commitments on carbon reduction.
• Commit to an Airports Connectivity Study to improve understanding of where bottlenecks occur with respect to surface access, and which airport connectivity projects should be included in national rail and road infrastructure investment programmes.

Strengthen competitiveness

• Set out a clear roadmap to cutting and eventually abolishing the negative impact of APD on economic growth and route connectivity.

Support sustainable growth

• Support and strengthen the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA), working with member states at ICAO to agree a meaningful work stream aimed at signing off on new long-term targets on emissions reduction at the 2022 General Assembly, rather than pursue unilateral measures.
• Make the UK a world-leader in the use of sustainable aviation fuels and boost support for research and investment in new technology.
• Support an approach to noise that fully implements the Balanced Approach and is far more proactive in ensuring local planning decisions – in particular on housing – are consistent with the needs of a growing airport.
• Direct the Department for Transport to play a vital leadership role in making the case for airspace modernisation through a concerted Government-led communications and education campaign, ensuring proper independence within the governance structure, with airspace fully modernised by a target date of 2025.

Deliver for UK air freight

• Recognise explicitly within the Aviation Strategy White Paper the national, strategic importance of UK air freight capacity through its own, dedicated chapter.
• Set out a clear plan for making full use of the UK’s existing freight capability across the country in the short term.
• Seek to implement no further restrictions to Night Flight operations, with no additional airports brought into the night noise regime, and supported by a policy statement on night operations which provides guidance for local authorities on the application of the Balanced Approach to local planning decisions on night controls.
• Appropriate consideration of, and support for, cargo operators should be given in any forward looking strategy to deliver sustainable growth, in particular within Government noise policy.
• The National Infrastructure Commission should be tasked with examining how the UK’s existing air freight infrastructure acts as both a barrier to and enabler of UK air freight – alongside what infrastructure will be required to enable the UK to capitalise on global trends in air freight up to 2050.

Enhance the passenger experience

• Ensure any Passenger Charter is developed collaboratively with the sector and prioritises best practice, voluntary commitments, ensuring there is no confusion with existing legal airline obligations.
• Introduce alcohol licensing airside at international airports to help prevent incidents of disruptive behaviour by introducing robust legal mechanisms to ensure the responsible sale and supply of alcohol in airports.
• Legislate for the removal of miniature bottles of alcohol from all duty free shops airside at airports, and make the use of sealed bags for alcohol purchases mandatory.
• Support a long-term strategy for the UK Border, developed in close coordination with industry, with an accompanying budget to deliver the resources that will be required to accommodate passenger growth without recourse to a passenger charge.
• Commit to a review of the implementation, and economic impact, of EC261 on UK carriers.
• Review the behaviour and business practices of Claims Management Companies with respect to passenger compensation.
• Ensure any consideration of new measures to address issues related to airline insolvency are proportionate to the actual risk to customers of being affected, and avoid introducing unnecessary market distortions or otherwise undermining the competitiveness of our sector, for example via a levy.