1. INTRODUCTION

  1.1 British Airways welcomes the publication of the Government's White Paper on Integrated Transport and believes it provides a useful framework for the sustainable development of an integrated transport infrastructure.

  1.2 It has introduced some innovative and welcome thinking whilst acknowledging the enterprise already demonstrated by both private and public sectors. This is already making a great difference to local transport infrastructure in localities such as airport communities where such partnership is vital in maximising their potential as major public transport interchanges.

2. INTEGRATED TRANSPORT

  2.1 The White Paper has concentrated primarily on road and rail, with limited coverage of the role of aviation but British Airways welcomes as a useful starting point the section promoting airports as interchanges. This requires further development, not least in the forthcoming Airports Policy White Paper and we look forward to participating in the consultation on that.

  2.2 British Airways expects that the Airports Policy White Paper will pay particular attention to the role of airports as major public transport interchanges, generating sufficient passenger flows to support a wide choice of public transport links. Many of these links could not be justified without the boost generated by the airport.

  2.3 There are many other initiatives that should be considered. These include:

—  the potential for dedicated bus and coach lanes to airports, particularly where widening schemes are planned (such as the M25 near Heathrow). This would enable public transport links to operate reliably to and from airports, linking both to flights and other forms of public transport.

—  Park and Ride schemes to airports, where economically reasonable, with remote car-parking in order to relieve pressure on the immediate airport area.

  Clearly schemes like this require significant investment and would need to be incorporated into wider strategic thinking on airport capacity development. In British Airways' view, it would be timely for the Government to give these matters serious thought and incorporate a framework for such proposals in its Airports Policy White Paper, which we understand will take account of the Inspector's report on the T5 Inquiry.

  2.4 The civil aviation industry is a growth industry with potential to be a catalyst for further progress in integrated surface transport. The prerequisites that enable this are firstly the concentration of demand as outlined above and secondly, location of airport capacity near the market (which minimises journey times and distances, and maximises the potential to use the airport as a convenient interchange). Proper consideration of these factors will also lead to improvements in the environmental efficiency of transportation.

  2.5 Despite growth in public transport, there will still be a requirement for some growth in car travel to airports. The proportion of air passengers (and airport/airline staff) using public transport will increase over time but industry growth, combined with the recognition that many UK airports (notably Heathrow) already have a high proportion of passenger access by public transport, makes planning for expanded future road usage essential.

3. AIR TRANSPORT FORUM

  3.1 We welcome the White Paper's endorsement of the success of the Airport Transport Forum initiative, and its comment that all airports with scheduled passenger services should lead such a Forum (paragraph 3.204). Our experience is that at the major airports where such Forums have been introduced they are working well and are the best means of ensuring that interested parties work together to generate the greatest overall benefit. We do not consider that additional structures are required where these Forums are in place.

  3.2 Significant funding will be required to enable vital new rail links and support for bus services. British Airways sees the airline industry contributing by channelling any congestion parking surcharges imposed in the airport area, directly into public transport improvements. The Airport Transport Forums would agree priorities. Any attempt to divert airport related user charges, such as car parking levies or congestion charges,have been opposed by airlines as contrary to the single till principle.

  3.3 British Airways is already contributing through development of a Free Transport Zone aimed primarily at reducing staff dependence on cars. We see this as a model which could be developed in other areas. We are also working with our airport partners on further measures to reduce car dependence. We believe that whatever the size of the levy charged for providing car parks, it will have little or no impact on the volume of private car usage, unless there is adequate and reasonably priced public transport between places of work and large catchment areas before the levy is charged.

  3.4 We will also continue to press for revenues raised by the Air Passenger Duty to be reinvested in infrastructure projects to the benefit of transport users.

4. AIRPORTS POLICY

  4.1 British Airways welcomes the Government's foresight in announcing its intention to prepare a UK Airports Policy looking some 30 years ahead (paragraph 3.189) since it is critically important for the airline industry to be able to plan for the future with some certainty.

  4.2 Aviation is still a comparatively young industry, with great potential for growth, wealth and employment generation, and for under-pinning the international trade on which the UK increasingly relies for prosperity. Planning, to provide the infrastructure that encourages UK aviation and meet the needs of UK passengers and freight forwarders, will require a robust approach that allows for balanced growth in passenger, runway and airspace capacity.

  4.3 However, we would caution against attempting to plan so far ahead that many of the key assumptions are uncertain.

  4.4 For example, it is difficult to assess more than 20 years ahead the likely development of aircraft design, or whether further significant steps forward will be possible, for instance in terms of environmental impact. Similarly, the impact of technology (video-conferencing, virtual reality and so on), changing patterns of tourism and the potential long term impacts of low cost carriers may change demand volume and patterns. The full impact of global alliances and changes in the world regulatory scene are likely to impact significantly any strategy which, whilst addressing UK infrastructure, should take account of the global reach and international competitiveness of the UK's aviation industry.

  4.5 We would recommend a staged approach to policy, looking at 10 year periods in the 30-year strategy, as follows:

0-10 years (to around 2010): Policy for the immediate short term requires consolidated thinking on known or planned developments such as Heathrow Terminal 5, and the proposed terminal developments at Gatwick and Stansted; and concentration on the improvements necessary to improve the efficiency of the industry such as investments in Communications, Navigation and Surveillance (CNS) and Air Traffic Management (ATM). Given planning timescales, other significant developments will not impact this period.

10-20 years: It is important to start work now on the requirements for this period, which will be critical in setting the framework for future airport and runway capacity, beyond those identified in the 10 year period. Decisions will be needed early in the next century to enable major developments to come into effect within the 20 year time-frame. This is the timescale over which certainty is of particular value for the airline industry because of the lifetime of aircraft, etc.

20-30 years: The Government should set out its long-term strategic ambition for the industry, but decisions for the period beyond around 2020 do not need to be taken imminently. Indeed, given the uncertainties identified, in our view it would be prudent to concentrate on enabling the conditions which will permit the industry to achieve its potential in the long term.

5. ENVIRONMENT

  5.1 British Airways is working, through IATA, with ICAO to consider how best to control emissions of noise, engine exhaust gases and waste. We have supported the tightening of the requirements for NO_x emissions from aircraft engines, which has been recommended to the ICAO assembly (paragraph 4.154). We have also supported the return of engine noise certification standards to the ICAO agenda.

  5.2 Environmental levies and fuel taxes (paragraph 4.155) are not the only options for encouraging fuel efficiency: others include tradable permits, regulatory action, and voluntary action. Indeed, airlines already have commercial incentives to be as fuel efficient as possible; in any case, fuel taxes are an inefficient means of incentive since fuel accounts for a relatively small part of overall costs. To date, regulatory action has been very successful in tackling environmental issues in the aviation industry.

  5.3 We believe an independent study of the various options would be the best means of balancing the desired economic, competitive and environmental effects; this was something we recommended in our response to the Green Paper and we still hope the Government will take this course of action.

  5.4 British Airways recognises the global significance of aviation (paragraph 2.24). Nevertheless, air transport only accounts for some 2-2.5 per cent of CO₂ emitted worldwide as a result of the burning of fossil fuels. Figures used for the fuel efficiency of aviation are often incorrect, misleading or outdated and we would be happy to work with the DETR on the most relevant means of assessing the true impact of the industry. We would urge the Government to request early completion of an authoritative comparative study, already proposed by the European Commission but not yet under way, of the overall environmental impacts of different transport modes.

  5.5 It should not be forgotten that considerable investment has gone into the environmental performance of aviation, in particular in terms of noise and engine exhaust gases, over the past 20 years and that considerable progress has been made. There may be a need for further measures but these must be introduced multi-laterally to avoid competitive disbenefits to the UK industry.

6. DEMAND MANAGEMENT

  6.1 For most air passengers there is no alternative to flying. The potential for substituting air travel exists only for some limited sectors of the market, for instance rail for short UK domestic and European routes. The aviation industry is increasingly looking at ways of combining these alternative transport modes so that passengers gain the benefits of an integrated system.

  6.2 There is, however, considerable resistance from passengers, businesses and authorities in the UK regions even to substituting a different airport for access to London and onward connections, so the scope for demand management is limited.

  6.3 Any form of demand management in the air transport industry, whether planned or by default, would impact the number of people travelling and would disproportionally affect certain groups of passengers, in particular those who are most price sensitive. In the most recent CAA data (CAP 677) the numbers and proportion of passengers from socio-economic group C1 using Heathrow and Gatwick have increased dramatically since the previous survey in 1991, while the numbers of passengers in the A/B group have remained broadly static. Numbers of C2 and D/E have also increased but remain quite small. BA would therefore expect that the C1 group would be most affected by any mechanism that attempted to dampen demand.

7. PLANNING AND REGULATION

  7.1 British Airways welcomes the Government's commitment to promote the interests of the UK aviation industry through negotiation of international air service agreements (Paragraph 4.42) and to further liberalisation of the industry. We fully support the Government position as set out in the White Paper in relation to bilateral negotiations.

  7.2 We note the observations in paragraph 4.40 about the system of economic regulation of airports. We are, however, concerned that the current system, while keeping passenger charges down, discourages operators from timely investment in airport capacity and customer service facility improvements. The regulatory system, therefore, meets only some of the interests of passengers and airlines. This will be an important issue for the timely delivery of new investment that flows from the airport policy review.

  7.3 We note with interest the clarity with which the Government sets out its proposals for streamlining and co-ordinating planning guidance in relation to land use and transport. We still have concern about the existing planning approvals process which we believe requires a complete overhaul to simplify and speed up the mechanisms for dealing with large infrastructure projects.

8. AIR SAFETY

  8.1 British Airways notes the proposal in the White Paper for a review of the arrangements for transport safety (Paragraph 3.259). The present criteria imposed by the CAA Safety Regulation Group are prescriptive and we would welcome a review of its role with a view to the creation of a safety organisation including a revised SRG, NATS (in whatever form is decided) and the Airspace Users Group that would work collectively and proactively on matters of safety and operational efficiency.

  8.2 A review of the Accident Investigation Branch should not place any restrictions on its independence or role.

  8.3 We look forward to participating in the consultation.