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Airports Commission Submission

Long Term Options: Capacity for Growth

Our submission on long term options focuses primarily on Stansted, since the South East of England is where demand for additional capacity is most acute, but we believe that all M.A.G airports have an important role to play in delivering capacity for growth.

Manchester has a strategically significant role, both as the major gateway to Northern Britain and the only UK airport other than Heathrow with two runways. East Midlands and Bournemouth airports have a smaller but nevertheless important role, as set out in our response to the Commission on making best use of existing capacity. Our response urges the Commission to keep a national perspective in the capacity debate. 

At Stansted, M.A.G is recommending that a number of options be put forward by the Commission for further consideration, including: 

  • Options for an additional runway, either to the north west of the existing runway (with capacity of between 70 – 80 million passengers a year) or to the east of the existing runway (with capacity up to around 90 million passengers a year). 
  • An airport with four runways (with capacity of between 140 to 160 million passengers a year) that would be designed and operated as an effective hub airport with good resilience and easy connections for passengers between flights. 

M.A.G believes Stansted offers the credibility and flexibility to meet the UK’s aviation capacity needs in the short, medium and long-term.

Best Use

Our submission on making best use of existing capacity argues that, in the absence of new runway capacity, it is imperative that we take steps now, to better utilise the runway capacity already available. We believe that intelligent, well timed policy interventions could be introduce to stimulate the take up of excess capacity, especially at regional airports. These could include: 

  • Reforming the structure of Air Passenger Duty to incentivise the take up of spare capacity by airlines; 
  • Improving surface access to airports with unused capacity, especially rail connections to Stansted, to increase their attractiveness; 
  • Exploring reforms which would make better use of the scarce capacity at Heathrow and other London airports, particularly economic regulation and slot reform; 
  • Promoting competition between airports wherever possible by removing economic regulation and championing consumer interests; and 
  • Further liberalising the UK’s bilaterals policy to open up capacity to overseas airlines. 

M.A.G is strongly committed to investing in the growth of its airports to ensure they make the fullest possible contribution to meeting demand in the short to medium term. However, with the right mix of Government policy support, we believe M.A.G airports could make an even greater contribution to meeting demand and supporting the growth of the UK economy. 

M.A.G’s airports have much to offer in terms of their current capacity:Stansted is the only London airport with significant capacity available at peak times. The airport currently handles around 17.5 mppa, but already has planning consent to handle around 35 mppa, and most of the infrastructure necessary to handle this volume of traffic is in place. We believe that with further development of infrastructure, Stansted’s single runway could handle around 40 to 45 mppa. 

Manchester is the only airport in the UK (other than Heathrow) with two full length parallel runways. It plays a national role serving a population of around 22 million people living within a two hour drive time. It has the potential to support long term growth, building on the existing short d long haul network, including clawing back around 4 million passengers per annum that currently travel by surface transport from its catchment to fly from airports in the South East.

Sift Criteria

Our response to the call for evidence on sift criteria suggests that there should be an over-riding criteria relating to whether a proposal is capable, by itself or in combination with other options, of delivering the objective of maintaining the UK’s position as Europe’s most important aviation hub. We recommend that particular consideration be given to how the term ‘hub’ is defined. 

M.A.G supports the six sift categories suggested by the Airports Commission (economic factors; social factors; climate change impacts; local environmental factors; accessibility; and feasibility considerations). We would add that other factors (contribution to the policy objective of maintaining and enhancing connectivity [particularly to emerging markets]; impact on consumers and competition; promoting regional growth and development; and sub national planning implications) should also be considered.


In our response to Discussion Paper 01: Aviation Demand Forecasting, M.A.G argues that a positive outlook is required to ensure that we develop recommendations that are capable of supporting sustained economic growth. The need for additional capacity has been reduced in the short term by the recession, but we are confident that growth will return. Whilst delivery of infrastructure can be deferred in response to a slowdown in demand, it cannot easily be accelerated. 

As well as reflecting the broader UK economy, the forecasts should also consider: the fact that traffic flows from the UK to emerging markets such as China and India will grow at a significant multiple to underlying GDP growth; the potential for demand to be driven by future improvements in cost efficiencies and technology; commercial trends in the air transport sector; the emergence of Gulf other hubs; the need to make best use of existing airport infrastructure; and the new competitive environment in which airports operate. 

Our response encourages the Commission to adopt an approach which avoids placing undue weight on the predictions of forecasting models when considering how demand is likely to be allocated in the future; to do so could well harm the development of competition to the detriment of consumers.


Our response to Discussion Paper 02: Aviation Connectivity and the Economy, recognises the significance of enhancing UK aviation connectivity to global markets. Our submission argues that UK connectivity is a national, not just a South East issue, and that regional airports can both support regional economic growth and ease the pressure on the South East, by ‘clawing back’ some of the leaked traffic. 

Our submission makes the point that hubs are not the only way to maintain connectivity and that a broader definition of connectivity is need. While direct links are important, indirect routes offer important alternatives, often with lower fares and greater consumer choice. Similarly, the importance of frequency varies according to whether the purpose of travel is business or leisure, and whether the journey is short-haul or long-haul. A ‘one-size-fits-all’ approach to connectivity is inappropriate.

Climate Change

Our submission to Discussion Paper 03: Aviation and Climate Change points to the Sustainable Aviation Carbon Roadmap as evidence that aviation will continue to become increasingly carbon efficient, accommodating all forecast growth to 2050 with little change in absolute emissions. 

M.A.G supports the use of appropriate market based measures to complement the industry’s efforts to increase environmental efficiency and reduce total emissions. The inclusion of aviation emissions within an appropriate policy framework will ensure that absolute emissions from aviation are capped and that net emissions are consistent with the trajectory established by the Government in its future carbon budgets. We therefore believe that climate change should not present a barrier to the provision of additional capacity.

Operating Model

Our response to Discussion Paper 04: Airport Operational Models states that the assessment of operating models should not lead the Commission to make a binary choice between ‘hub’ and ‘dispersed’ options. Rather, it should be used to develop an understanding of the airport strategies that are likely to yield the greatest benefits, to be taken into account as one part of the Commission’s assessment. M.A.G believes that while both models have the potential to offer significant benefits in theory, the dispersed model is best placed to translate those benefits into practice. 

If a new hub could be built, we could certainly see many theoretical advantages for the UK. However, we believe that a ‘true’ hub model may prove difficult to achieve in practice. Heathrow is not a ‘true’ or effective hub and it is doubtful as to whether it ever can be without substantive redevelopment and expansion, at high environmental cost. The development of a brand new hub would offer the opportunity for a fresh start, and could be designed and operated in a way that met the minimum requirements of an effective hub, but could not coexist with Heathrow. Without a commitment from Government to closing Heathrow, it would be difficult to finance investment in any new infrastructure. 

While M.A.G agrees that the hub model may be the most advantageous in theory, translating this into practice is likely to prove very difficult. We believe that a dispersed model offers the most realistic prospect of delivering runway capacity to accommodate the UK’s needs, in a way which is affordable, deliverable, future proof and with lower environmental impact. This approach retains the economic benefits the UK economy needs, without committing the UK to an inflexible future.

Aviation Noise

M.A.G recognises that aircraft noise can be intrusive and that the effects of noise are felt most acutely by those communities living and working in close proximity to airports, where aircraft operate at lower altitudes and noise levels are typically higher. M.A.G agrees that noise impact is one of the central considerations for the Commission and therefore it is imperative that the Commission’s deliberations are informed by objective evidence based criteria that are founded on sound science.