BAA/6/A
Case Reference No: 2032278
Stansted Airport Generation 1
Inquiry
PROOF OF EVIDENCE BY:
STAN MAIDEN
Traffic Forecasts
April 2007
Air Traffic Forecasts – Proof of Evidence by Stan Maiden
Contents
Chapter
Title
Page(s)
1
Introduction
2
2
Purpose and Scope of Evidence
3-4
3
Statement of Common Ground
5-6
Annual Forecast s
4
Historic Growth in Passengers at SE Airports
7-8
5
Forecasts Approach
9
6
Forecasts of Unconstrained Demand
10 - 11
7
Airport Capacity
12 - 14
8
Distribution of South East Demand
15 – 17
9
The 25 mppa Case
18 - 20
10
Aircraft Movement Forecasts
21 – 23
11
Air Cargo Forecasts
24
12
Summary of 25 and 35 mppa cases
25
Other Forecast Inputs to the SG1 Environmental Statement
13
Terminal & Apron Forecasts
26
14
Inputs to Noise, Air Quality & Risk Assessments
27
15
On – Airport Employment
28 – 31
16
Surface Access
32 – 34
17
Car Parking Forecasts
35
Latest Forecasts and Conclusion
18
Latest BAA Forecasts
36 - 37
19
Conclusion
38
1
1
Introduction
1.1
My name is Stan Maiden and my position in BAA Ltd is that of Group
Research Director, a post I have held for nearly 20 years. After spells in
Planning and Finance I joined the department I now head in 1970.
1.2
As Research Director my role, and that of my team, is to provide the
following services for the BAA Group:-
a)
air traffic analyses;
b)
forecasts of air traffic and related activities such as airport
employment and car parking;
c)
market research among air passengers and other airport users;
and
d)
1.3
operational research support.
I have spent 38 years of my career in the field of air traffic research and
forecasting and in the course of this time have worked extensively as a
consultant to airport and airport-related organisations in the UK and
overseas. I have chaired three international industry working groups
and currently chair the Forecasts and Statistics Panel of ACI (the trade
association of world airports, the airport equivalent of IATA). I was also
the founding chairman of the UK Transport Statistics Users Group.
1.4
I have contributed numerous articles to aviation and tourist industry
journals and regularly lecture on the subject of traffic forecasting and
market research to academic institutions and other bodies. I am on the
Editorial Board of the Journal of Airport Management and am an
external examiner for the Cranfield Institute of Technology’s MSc course
in Airport Planning and Management.
2
2
Purpose and Scope of Evidence
2.1
The aim of my evidence is to explain the basis of the forecast advice
upon which BAA relies to support its case for lifting the annual limits of
25 million passengers (Condition MPPA1) and 241,000 air transport
movements (Condition ATM1) at Stansted.
2.2
The evidence is grouped into chapters with the bulk falling under two
key headings: -
Annual Forecasts
2.3
(Passengers, Aircraft Movements, Cargo)
Ch. 4 – 12
Other forecast inputs to the SG1 Environmental Statement
Ch.13 – 17
Latest Forecasts and Conclusion
Ch.18 - 19
Chapters 4 to 17 of this Proof relate to the process of producing the
forecasts that were published in the G1 Environmental Statement
Volume 16 (CD/19). The bulk of this work was undertaken during 2004
and 2005.
2.4
BAA is presenting two main forecasts cases, along with 3 supporting
sensitivities: -
Case / Sensitivity
Description
25 mppa case
Described in the Environmental Statement
35 mppa case
Described in the Environmental Statement
Fleet Mix Sensitivity
Impact of heavier fleet at 264,000 ATMs per annum
40 mppa Sensitivity
Impact of 40 mppa
SH & E Sensitivity
Tests alternative passenger ground origins
2.5
BAA regularly reviews and, if necessary, updates its forecasts in the
light of changing circumstances. Indeed, it produces these forecasts as
part of its annual Capital Investment Programme circulated to the
airlines. As a result of current developments affecting the air transport
industry (most notably concerning oil prices and the outlook for
3
environmental taxes) BAA has recently prepared revised forecasts for
all its airports and now considers that growth in air passenger
throughput at Stansted will be marginally slower than was forecast at
the time it made its planning application.
2.6
A fuller description of the background and the reasons behind the latest
forecasts is given in Chapter 18 to this Proof.
4
3
3.1
Statement of Common Ground
BAA’s forecasts have been reviewed by Uttlesford DC’s advisors,
(SH&E), who also separately commented on air traffic forecasts
produced by the ACC. SH&E’s views on air traffic forecasts for Stansted
are given in their ‘Review of BAA Traffic Forecasts for Stansted Airport,
Feb 2006’ (CD/133) and ‘Further Advice on Stansted Generation 1
Traffic Forecasts, July 2006’ (CD/134). Additional insight into SH&E’s
thinking is given in their memoranda to Uttlesford DC (see CD/135).
3.2
The comments made by SH&E highlight a strong degree of agreement
between the two parties about the robustness of BAA’s traffic forecasts.
Their only material differences in view are outlined in para 3.5 below.
3.3
Uttlesford’s planning officers also comment “it is considered the
forecasts in the ES are robust” (CD/33: Report on UTT/0717/06/FUL to
UDC Development Control Committee, 29 Nov 2006).
3.4
In their ‘Review of BAA Traffic Forecasts for Stansted Airport’ (Feb
2006) SH&E concluded “that the passenger forecasts produced by BAA
for Stansted are reasonable” (page 37, para 5.6). SH&E also
commented that BAA’s aircraft fleet mix forecasts ‘represent a
reasonable view of aircraft movements by type when Stansted operates
at 35 mppa.’
3.5
In their analysis SH&E suggested that there were two areas of BAA’s
forecasts where they held a different view. These were: -
a) the proportion of Long Haul passengers in the 35 mppa case, and
b) the zonal distribution of passenger ground origins in the 35 mppa
case.
However SH&E stated that these differences “are not material in the
context of a long term traffic forecast” (‘Review of BAA Traffic Forecasts
for Stansted Airport’, Feb 2006, page 37, para 5.6).
5
3.6
BAA has examined these respective viewpoints through the use of
sensitivities. The ‘fleet mix sensitivity’ (BAA Environmental Statement,
Volume 16, paragraphs 11.1.1 – 11.2.4) examines the noise impact of a
heavier fleet at 264,000 ATMs per annum (including a higher Long Haul
share, as suggested by SH&E) than that assumed for the 35 mppa
case. The ‘SH&E sensitivity’ (presented in Table 16.1 of this proof of
evidence and reported on in the Addendum to the Transport
Assessment) addresses the point about the zonal distribution of
passengers.
3.7
In conclusion there is substantial agreement on forecasts between BAA
and Uttlesford DC’s specialist advisors. Where there are different
viewpoints (albeit that these have not been deemed to be significant)
the potential impact of alternative forecasts has been assessed through
the development of sensitivities.
3.8
The Statement of Common Ground between BAA and Uttlesford DC
provides initial commentary on air traffic forecasts at section 6.2. At
para 6.2.3, UDC agree that “the air traffic forecasts set out in Volume 16
of the G1 ES are a reasonable set of forecasts, save for:
• The mix of long haul passengers
• The zonal pattern of passenger origins / destinations”
At para 6.2.5, UDC accept that “the air traffic forecasts produced in the
sensitivity tests are a reasonable set of forecasts”.
6
4
Historic Growth in Passengers at South-East Airports
4.1
Table 4.1 overleaf lists the growth in terminal passengers at the five
major airports in the South-East of England over the period 1970 to
2006. For comparison purposes it also shows the equivalent figures for
the UK as a whole.
4.2
Within the South-East traffic has grown at a compound rate of 5.2% p.a
over the 20 year period to 2006 and over the whole period, 1970 –
2006, with bouts of growth interrupted by events such as the major oil
price hikes, wars in the Middle East and the aftermath of 9/11 and
SARS. In only 4 out of 36 years did traffic fall between one year and
another and only in one case (1973 – 75) did the subsequent year fail to
see traffic levels in excess of the preceding year.
4.3
It shows that while Heathrow has remained dominant among South East airports throughout the period, Stansted has substantially
increased its share of the total, particularly since the late 1990’s. At the
same time there has been a steady, but gradual, decline in the share of
UK air traffic accounted for by airports in the South - East.
4.4
In the 10 year period from 1996 to 2006 Stansted has increased its
share of traffic from 5% of the South-East total (3.5% of UK) to 17% of
the South-East (10.0% of UK).
7
Table 4.1
PASSENGER GROWTH at SOUTH EAST AIRPORTS 1970-2006
Heathrow
Gatwick
% of
000s
Stansted
% of
Luton
% of
London City
% of
South East
000s
South East
000s
South East
000s
Total South East
% of
TOTAL UK
% of
South East
000s
South East
000s
UK
000s
1970
15,415
71.5
3,684
17.1
496
2.3
1,964
9.1
0
0.0
21,559
68.7
31,397
1971
16,175
67.3
4,655
19.4
493
2.1
2,703
11.3
0
0.0
24,026
69.1
34,760
1972
18,294
67.7
5,309
19.7
309
1.1
3,096
11.5
0
0.0
27,008
69.4
38,943
1973
20,329
68.9
5,765
19.6
176
0.6
3,216
10.9
0
0.0
29,486
68.6
42,982
1974
20,076
72.9
5,230
19.0
199
0.7
2,023
7.3
0
0.0
27,528
68.8
40,011
1975
21,295
74.1
5,344
18.6
238
0.8
1,869
6.5
0
0.0
28,746
68.7
41,846
1976
23,242
74.9
5,715
18.4
268
0.9
1,807
5.8
0
0.0
31,032
69.5
44,666
1977
23,386
72.6
6,588
20.4
300
0.9
1,947
6.0
0
0.0
32,221
70.2
45,927
1978
26,488
72.3
7,761
21.2
317
0.9
2,058
5.6
0
0.0
36,624
69.3
52,829
1979
27,979
71.3
8,701
22.2
347
0.9
2,207
5.6
0
0.0
39,234
68.8
56,992
1980
27,472
69.5
9,707
24.5
275
0.7
2,088
5.3
0
0.0
39,542
68.3
57,882
1981
26,401
67.1
10,730
27.3
262
0.7
1,971
5.0
0
0.0
39,364
68.1
57,771
1982
26,406
66.6
11,154
28.1
300
0.8
1,800
4.5
0
0.0
39,660
67.5
58,771
1983
26,749
64.8
12,477
30.2
342
0.8
1,708
4.1
0
0.0
41,276
67.6
61,100
1984
29,147
64.2
13,954
30.7
527
1.2
1,795
4.0
0
0.0
45,423
67.2
67,572
1985
31,289
64.8
14,883
30.8
514
1.1
1,586
3.3
0
0.0
48,272
68.5
70,434
1986
31,315
62.5
16,309
32.5
545
1.1
1,962
3.9
0
0.0
50,131
66.7
75,161
1987
34,742
60.5
19,373
33.7
712
1.2
2,585
4.5
15
0.0
57,427
66.7
86,041
1988
37,525
60.3
20,761
33.3
1,045
1.7
2,797
4.5
133
0.2
62,261
66.8
93,162
1989
39,611
60.8
21,183
32.5
1,322
2.0
2,828
4.3
216
0.3
65,160
65.9
98,913
1990
42,647
62.9
21,047
31.1
1,154
1.7
2,679
4.0
230
0.3
67,757
66.2
102,418
1991
40,248
64.1
18,690
29.8
1,684
2.7
1,957
3.1
172
0.3
62,751
65.5
95,768
1992
44,964
64.9
19,842
28.6
2,332
3.4
1,943
2.8
186
0.3
69,267
65.3
106,123
1993
47,602
65.7
20,065
27.7
2,671
3.7
1,851
2.6
244
0.3
72,433
64.5
112,280
1994
51,362
65.9
21,051
27.0
3,258
4.2
1,804
2.3
478
0.6
77,953
63.7
122,364
1995
54,107
65.4
22,382
27.1
3,890
4.7
1,810
2.2
554
0.7
82,743
63.9
129,586
1996
55,723
63.5
24,106
27.5
4,811
5.5
2,406
2.7
724
0.8
87,770
64.6
135,792
1997
57,808
61.3
26,796
28.4
5,367
5.7
3,217
3.4
1,159
1.2
94,347
64.3
146,654
1998
60,337
59.3
29,034
28.6
6,831
6.7
4,110
4.0
1,358
1.3
101,670
64.0
158,808
1999
61,975
57.2
30,407
28.0
9,420
8.7
5,246
4.8
1,384
1.3
108,432
64.4
168,286
2000
64,266
55.5
31,936
27.6
11,854
10.2
6,164
5.3
1,581
1.4
115,801
64.4
179,824
2001
60,431
53.3
31,098
27.4
13,650
12.0
6,540
5.8
1,619
1.4
113,338
62.6
181,195
2002
63,012
54.0
29,519
25.3
16,044
13.8
6,474
5.5
1,602
1.4
116,651
61.8
188,748
2003
63,200
52.6
29,895
24.9
18,712
15.6
6,786
5.7
1,471
1.2
120,064
60.0
199,952
2004
67,111
52.2
31,389
24.4
20,905
16.3
7,520
5.8
1,675
1.3
128,600
59.6
215,681
2005
67,687
50.7
32,703
24.5
22,014
16.5
9,135
6.8
1,996
1.5
133,535
58.5
228,214
2006
67,343
49.2
34,092
24.9
23,682
17.3
9,415
6.9
2,358
1.7
136,890
58.2
235,139
Source BAA Ltd
8
5
The Forecast Approach
5.1
In its medium-long term forecasts of traffic for the South-East BAA uses
a ‘top down’ approach which begins by making forecasts of
unconstrained
1
demand for either the BAA airports or all airports in the
South-East. The reason for initially considering the collective demand
for airports in the South - East is to reflect their close physical proximity
with overlapping catchment areas. It also makes it easier to deal with
the issue of passengers being deflected away from their airport of first
choice.
5.2
As well as preparing forecasts of unconstrained demand BAA has also
established the annualised capacities of the various airports in the
system. This involves estimating the annual equivalent of the maximum
flow of traffic that can be handled in busy periods by critical elements of
airport infrastructure (e.g. runways, apron area and terminal).
5.3
Drawing on evidence about the way in which passengers originating
from, or destined for, different geographical zones make use of existing
airport capacity in the South-East (and monitoring how this has changed
over time and by passenger type) we have devised a series of ‘rules’
which apportion predicted demand to individual BAA airports. Where
this demand in any year exceeds our previously assessed capacity we
have applied other ‘rules’ which determine which elements of initially
allocated demand would overspill in such circumstances of excess
demand and what their expected subsequent option would be.
5.4
The forecast demand for Stansted is therefore a combination of
indigenous demand and a small element of ‘spillover’ traffic which might
otherwise have used Heathrow or Gatwick (approximately 2% of total
Stansted traffic by the date 35 mppa is reached). Both elements are
then adjusted to reflect future changes in the cost of operating from
Stansted.
1
(Demand for travel at a future date assuming physical and statutory constraints are no more restrictive than at
the point the forecast is made)
9
6
Forecasts of Unconstrained Demand
6.1
In common with UK bodies such as the DfT and CAA, as well as leading
airlines and aircraft manufacturers, BAA relies on an econometric
modelling approach to predict the future demand for air travel. In other
words BAA believes that consumer demand for air travel is driven by the
desire to travel, fuelled or tempered by the cost of that travel (and
associated expenses) and the rate of economic growth.
6.2
The key assumptions which drive the model are largely economic. The
rate of GDP or consumers’ expenditure growth are key factors
influencing the medium – long term demand for leisure travel, while
foreign trade growth is a prominent driver of international business
travel.
6.3
The changing cost of air travel is a particularly important factor
influencing leisure demand.
Everything else being equal, falling air
fares act as a stimulus to growth and rising fares as a depressant. The
movement of air fares is a function of the degree of competition between
airlines, (sometimes with competing modes), and the airlines’ own
operating costs which includes the cost of fuel, staff, distribution, airport
handling and landing charges.
6.4
The cost of oil and hence aviation gasoline, is of fundamental
importance because it both comprises a substantial proportion of airline
operating costs and, through its wider macro-economic effects, is pivotal
in determining the rate of GDP growth and the discretionary spending of
consumers.
6.5
Assumptions concerning future trends of both sets of influencing factors,
the ‘income’ drivers such as GDP and consumers’ expenditure and the
‘price’ driver (air fares) are moderated in the model via the use of
‘elasticity’ factors. In effect these represent the gearing between the
respective economic drivers and the output demand.
10
6.6
In the case of ‘income’ drivers the elasticity values represent the
sensitivity of demand to changes in levels of discretionary income. As
such they can be altered over time to represent growing maturity or
saturation of demand. They therefore potentially vary according to the
particular market segment they are associated with and over time. Price
elasticities also vary according to market segment, with business travel
less sensitive to air fare changes than leisure travel.
6.7
Other,
non-economic,
factors
included
in
BAA’s
model
were
adjustments to reflect the impact of greater competition from rail
services for non-connecting Domestic traffic, the impact of the
completed UK fast link to St Pancras from the Channel Tunnel on short
haul international routes and growing competition from UK regional
airports.
11
7
Airport Capacity
7.1
In the context of BAA’s passenger forecasting process airport capacities
are expressed in terms of millions of passengers per annum (MPPA).
The derivation of these capacity figures stems from analysis of hourly or
short term factors and entails the consideration of three main issues: a) Critical Capacities – an airport consists of various infrastructure
elements (runway, apron, terminal and ground access) each of
which will have a more or less finite capacity, and each of which may
act as a bottleneck (with the most limiting element dictating the
capacity of the airport as a whole).
b) Peaking Patterns – different airports will have different combinations
of traffic and therefore may exhibit a different pattern of operation
(over the course of a day, week, season, year). However there is an
observed tendency in mature large scale airports for airport peaking
to diminish gradually over time, with growth in demand increasingly
being accommodated at hitherto off – peak periods.
c) Service Standards – implicit in assessing the hourly capacity offered
by a piece of airport infrastructure is a measure of the service
standards that will be experienced at a given level of hourly flow (for
example the level of delay likely to be experienced by arriving and
departing aircraft).
The capacity of Stansted in 2014/15
7.2
In BAA’s opinion the single runway will represent the most limiting factor
dictating overall airport capacity in the chosen assessment year of
2014/15.
7.3
The capacity of the runway, expressed in terms of millions of
passengers per annum, is arrived at through the following stages: -
a)
Calculation of the daytime hourly capacity of the runway (in terms
of
the
average
number
of
slots
available)
given
safety
requirements and the application of acceptable queuing levels for
aircraft in the air and on the ground.
12
b)
Calculation of the volume of daytime slots available across the
year, plus the number of movements available in the night quota
period (which combine to generate a theoretical maximum number
of runway slots available per annum)
c)
Estimate of the proportion of this capacity likely to be taken up by
aircraft movements (ie slot utilisation)
d)
Assessment of the proportion of total aircraft movements likely to
be accounted for by Passenger Air Transport Movements (PATMs)
e)
Assumptions about the average number of passengers likely to be
carried on PATMs (ie Pax per PATM), multiplied by the volume of
PATMs
7.4
BAA’s assessment of the annual runway capacity at Stansted in
2014/15, compared to that in 2005/6, is illustrated below: -
Table 7.1
Year
Night
Theoretical
Slot
Total
Av
Quota
Slots pa
Utilisation
Flights
PATMs
CATMs
NATMs
Pax /
Hourly*
(000s)
(000s)
%
(000s)
(000s)
(000s)
(000s)
PATM
MPPA
Capacity
2005/6
42
12
280
70
196
169
11
16
132
22.2
2014/15
47
12
313
88
274
243
21
11
144
35.0
* Daytime hours ie 0500 – 2229 GMT
7.5
The main assumptions are: -
a)
No increase to peak runway movements (currently 50 slots per
hour), but increase in the number of hours at which this number of
slots is made available
b)
General increase in off – peak slots
c)
Increase in the annual utilisation of runway slots, to about 88% by
2014/15
d)
Majority of new slots taken up by Passenger ATMs
13
e)
Increase in passengers per PATM, based on BAA’s assumptions
about fleet mix and % load factor development
7.6
For the purposes of comparison the same calculation has been applied
to Gatwick in 2005/6, where the single runway handled just under 33
million passengers per annum: -
Table 7.2
Year
Av
Night
Theoretical
Slot
Total
Hourly*
Quota
Slots pa
Utilisation
Flights
PATMs
CATMs
NATMs
Pax /
Capacity
(000s)
(000s)
%
(000s)
(000s)
(000s)
(000s)
PATM
MPPA
46
14
307
86
263
252
2
9
131
32.8
2005/6
* Daytime hours ie 0500 – 2229 GMT
7.7
Airport capacity, when expressed in terms of millions of passengers per
annum, will change over time (typically increasing). The 35 mppa value
represents our best assessment of the runway – constrained capacity
that will exist in 2014/15. BAA has offered to accept a condition limiting
the annual passenger throughput of the single runway to this level.
Passenger Throughput at the other London airports in 2014/15
7.8
BAA assumed the following annual passenger throughput volumes for
the other London airports coincident with our forecast of a 35 mppa
throughput at Stansted in 2014/15. The figures for Heathrow and
Gatwick are estimates by BAA, and the figures for Luton and London
City reflect our understanding of the long term capacities at those
airports prior to the publication of their respective airport master plans
during 2006.
Table 7.3
Airport
Capacity, MPPA
Heathrow
87
Gatwick
42
Stansted
35
Luton
12
London City
3
14
8
Distribution of South-East Demand
8.1
Having established the level of passenger demand for airports in the
South - East and the anticipated annual capacity of the individual
airports in the region, the next step is to predict how that demand is
likely to distribute itself.
8.2
BAA uses the CAA’s Origin and Destination surveys to identify the
factors that cause passengers to choose one airport over another. The
major determining factors have been found to be location (or more
precisely accessibility) and airline service frequency although different
passenger segments are not equally sensitive to these factors and may
also be influenced by the availability of low airfares or frequent flyer
programmes etc.
8.3
The CAA data can also be used to define airport catchment areas. It
tells us how many passenger trips to specific airports are made to and
from zones within the South - East. These zones are at borough level
within the Greater London area and at county level beyond.
8.4
Having created a matrix of trips from zones to airports we define a zone
as belonging to a particular airports catchment when the proportion it
accounts for of that airport’s total traffic is greater than the share it
accounts for any of the other airports in the system.
8.5
With the catchments defined in this way it is then possible to measure
the extent to which different passenger segments originating in the
different catchments currently choose to use the airports in the system.
This reveals that different segments respond differently to the attractions
of individual airports. Table 8.1 below illustrates, using recent CAA
survey data, the difference in airport choice by UK leisure passengers
and overseas resident business travellers.
15
Table 8.1
Choice of Airport by Catchment Area
UK Leisure
%
Foreign Business
Airport Used
Airport
%
Airport Used
LHR
LGW
STN
TOTAL
LHR
LGW
STN
TOTAL
LHR
50
36
14
100
86
10
4
100
LGW
25
65
10
100
63
33
4
100
STN
27
31
42
100
65
10
25
100
TOTAL
36
42
22
100
74
14
12
100
Catchment
Source: BAA analysis of CAA survey data covering period Jan – Dec 2003
8.6
It shows that UK leisure travellers, who have the widest choice of the
kind of service they favour, are more likely to use the airport in whose
catchment they are originating or destined for. Given the greater
frequency of service offered from Heathrow, which is known to be of
particular importance to business passengers, it is not surprising that,
irrespective of their origin such passengers tend to choose Heathrow
more often than the other airports combined.
8.7
Informed by this sort of analysis and observing how the patterns change
over time, BAA then predicts how the matrix might look in 2015, in the
first instance assuming no change in the level of restraint asserted by
each airport on demand through physical or statutory constraints.
8.8
A comparison of the demand with capacity at a specified future date
then reveals whether that level of demand can be accommodated.
Having identified the amount of excess demand a process of reallocation then follows which works by specifying the relative propensity
of different passenger segments to switch to another airport. These
‘attrition factors’ are applied to any excess demand at any airport and
form the composition of the spillover demand.
16
8.9
As an illustration the rules of the model assume that international to
international transfer passengers are eight times more likely to switch to
another airport (UK or overseas) than UK resident business passengers
with origins inside the airport’s catchment area.
8.10
The spillover traffic is then re-allocated using another set of rules that
vary according to passenger type. Not all of this spillover traffic is
assumed to remain within the South-East system. Some of the ‘lost’
traffic may switch to other airports or simply not fly.
8.11
The process is repeated until excess demand is eliminated and airports
are either at or below their estimated capacity.
8.12
The theoretical approach to the concept of spillover described above is
based in part on BAA’s observation of the way in which changes in the
level of constraint at one airport in the London area have in the past
caused an upturn in the growth experienced elsewhere in the South
East. Figure 1 to Appendix A illustrates what happened to Heathrow’s
share of South East traffic during the period from 1978 to 1990 when the
constraint applied was a statutory ban on the ability of airlines not
already using Heathrow to develop new international services at the
airport.
8.13
The result was that over that period while Heathrow grew at an average
compound rate of 4.0% per annum, Gatwick increased at a rate of 8.7%
pa. Over the five year period following the lifting of the ban Heathrow’s
traffic rose by 27%, Gatwick’s by 6%.
8.14
The fact that at a time when Heathrow was statutorily constrained there
was sufficient capacity at Gatwick to attract and accommodate a
substantial part of the frustrated demand for Heathrow has clear
parallels with the role that Stansted will increasingly play in respect to
approaching capacity constraints at Heathrow and Gatwick. With 2530% of the surface trips to the three largest London airports being
generated in zones most accessible to Stansted, the lifting of the 25
million condition would make the London airport system more balanced
in terms of supply and demand since it would permit some 22% of
demand to use it, rather than the figure of 17% possible were the
condition not to be lifted. (Table 1 of ES Vol 16).
17
9
Developing the 25 mppa case
9.1
Air traffic forecasts for the 25 mppa case are presented in Volume 16 of
BAA’s Environmental Statement.
9.2
The 25 mppa case assumes the continuation of condition MPPA1 which
currently restricts the airport to a passenger throughput of 25 mppa. The
25 mppa case identifies the characteristics of such an airport operating
in 2014/15, having been constrained to 25 mppa for some 6 – 7 years.
The 25 mppa case requires consideration of how the airport would
develop over time with a 25 mppa restriction on passenger numbers.
9.3
We have approached the issue employing a logic which can be
summarised
as
considering
three
different
models
of
airport
development, as follows: -
a)
Airport operating without annual constraint (physical or statutory) on
either aircraft movements or passengers. In this case airlines can be
expected to respond to and/or encourage a growth in customer demand
by a combination of increases in destinations served, flight frequency,
and aircraft size.
b)
Airport operating with a physical or statutory constraint on aircraft
movements. In this instance airlines are not able, collectively, to
increase flight frequency but might be in a position to do so on specific
routes. The reduced scope for competition and rising potential for
demand to exceed supply will tend to enable airlines to increase
average ticket prices and there will be a greater incentive for them to
increase the size of aircraft used.
c)
Airport operating with a limit on annual passenger numbers. In this case,
the Stansted 25 mppa scenario, one lever that airlines can pull to
develop their businesses is to increase average ticket prices (through
added value services and/or as a result of a tightening demand / supply
position). Part of the added value, particularly to attract a greater share
of higher spending business passengers, would be by increasing flight
frequency faster than would be the case under normal operating
conditions.
18
9.4
It was against this background that the 25 mppa forecasts given in
Volume 16 of the Environmental Statement show, relative to the 35
mppa case: -
-
a higher share for the low cost sector (as a 25 mppa cap would
lessen BAA’s incentive to market Stansted to new types of carriers,
especially Long Haul, mainly through the less attractive network
possibilities of a constrained airport)
-
a lower aircraft movement volume to handle 25 mppa in 2014/15
than is assumed to be the case when 25 mppa is first attained in
2008
-
a smaller proportion of transfer passengers reflecting the relatively
lower opportunity to connect between flights at Stansted
-
a higher proportion of business travellers as a result of the increase
in scarcity value of seats from Stansted
-
a higher concentration of passenger origins and destinations to /
from zones relatively local to Stansted.
-
a higher volume of cargo and non – commercial flights (as it would
heighten BAA’s commercial interest to develop non – passenger
related income streams)
9.5
The unique aspects of the 25 mppa case were discussed with SH & E
(in their role as advisors to Uttlesford DC) during the development of the
forecasts, and comments made by SH & E were subsequently reflected
in the final 25 mppa case forecasts.
9.6
BAA is confident that the 25 mppa case represents a robust scenario.
To highlight this assertion Stansted handled 23.8 mppa in 2006/7, with
208,300 aircraft movements (total including cargo and non – commercial
flights). Our expectation is that a 25 mppa throughput is likely to be
reached late in 2008, supported by about 219,000 aircraft movements.
19
9.7
This compares favourably with BAA’s forecast of 216,000 annual aircraft
movements in the 25 mppa case. Furthermore this accentuates the gap
between the number of movements required to support 35 mppa and 25
mppa respectively (as the 25 mppa case assumes a lower number of
movements than we believe Stansted will be handling, with 25 mppa,
late in 2008).
20
10
Aircraft Movement Forecasts
10.1
BAA’s air transport movement forecasts are presented in Volume 16 of
BAA’s Environmental Statement, see section 3.
10.2
The forecast aircraft load characteristics are presented and explained in
Volume 16 of BAA’s Environmental Statement, see para 3.3.1 – 3.3.3
Fleet Mix
10.3
Forecasts of the aircraft fleet mix in the 25 mppa and 35 mppa cases
are given in Volume 16 of BAA’s Environmental Statement, see
Appendix A5.
10.4
Fleet mix forecasts have been generated separately for the Passenger
ATM, Cargo ATM and Non – Commercial ATM fleets, and then
combined as a means to assess the environmental impacts of the
proposed development.
10.5
The mix of aircraft types in the PATM fleet (which accounts for 83% and
89% of the 25 mppa and 35 mppa cases respectively) has been
projected in light of the expected market and airline mix composition at
2014/15 in both cases. The Domestic and European markets at
Stansted are currently dominated by Ryanair and Easyjet who have firm
commitments to the medium – sized Boeing 737 – 800 and Airbus A319
respectively. This is illustrated in Table 10.1 below, which demonstrates
the current prevalence of medium – sized aircraft at Stansted. The
forecasts for both cases in 2014/15 are driven to a substantial extent by
the assumption that these two carriers will retain that commitment to
these respective aircraft types.
21
Table 10.1
Stansted PATM Fleet Mix, by stand size type (000s)
Size Type
2006
%
A380
0.0
0.0
Jumbo
0.0
0.0
Large
1.0
0.6
Medium Wide
2.9
1.6
Medium
156.3
87.3
Small
18.6
10.4
TOTAL
178.9
100.0
10.6
The other key factor underpinning BAA’s fleet mix forecasts is the
assumed development of Long Haul services, utilising larger aircraft
types (on average) than those used in the Domestic and European
markets. Long Haul movements account for 3% and 6% of the 25 mppa
and 35 mppa Passenger ATM forecasts respectively.
10.7
From the PATM fleet mixes an assessment can be made of the
proportion of airline capacity forecast to be used by air passengers. This
measure, the % load factor, is derived by dividing the volume of seats
forecast to be offered by airlines by the passenger volume forecast. The
volume of seats on offer is the product of BAA’s movement forecasts for
individual aircraft types multiplied by an assumed number of seats per
aircraft type. This in turn has been derived with reference to the current
characteristics at Stansted (for example the Boeing 737 – 800 is
assumed to provide 189 seats per flight).
10.8
The % load factor forecasts are illustrated below: -
Table 10.2
% Load
Year / Case
Factor
2006
77
25 mppa case
80
35 mppa case
83
10.9
For comparison the equivalent values at Heathrow and Gatwick were as
follows in 2006: -
22
Table 10.3
% Load
Airport
Factor
Heathrow
73
Gatwick
77
10.10 In both cases the % load factor at Stansted is assumed to be greater in
2014/15 than at present. However load factors in the 35 mppa case are
forecast to be higher than those of the 25 mppa case.
10.11 This is principally a reflection of the different contexts in which the two
cases are assumed to operate. In the 25 mppa case we have assumed
that the continued imposition of condition MPPA1, limiting the
passenger numbers to 25 mppa, would disincentivise passenger volume
growth for airlines at Stansted. Instead, with volume growth unlikely as a
result of the 25 mppa condition, carriers would focus on other ways to
develop profitability. Thus volume, in the form of higher load factors,
could be forsaken in a desire to boost profits through either extracting a
higher revenue per passenger (yield), and / or by driving operating costs
down further. In the 35 mppa case volume growth would emerge as a
potential factor in the drive for profits, and, as a result, there would be
far greater scope for price competition between carriers. Higher load
factors would result through this process.
10.12 In addition to the fleet mix forecasts for the 25 mppa and 35 mppa cases
BAA has provided a fleet mix sensitivity, where the 264,000 ATMs
proposed under revised condition ATM1 are assumed to reflect a
heavier (more long haul) fleet mix in 2014/15.
Movement Profiles
10.13 Hourly aircraft movement profiles for the 25 mppa and 35 mppa cases
are presented and explained in Volume 16 of BAA’s Environmental
Statement, see paras 9.1.1 – 9.1.9.
23
11
Air Cargo Forecasts
11.1
BAA’s air cargo forecasts for the 25 and 35 mppa cases are presented
in Volume 16 of BAA’s Environmental Statement, see section 4.
11.2
The air cargo tonnage forecasts have been used as an input to the
forecasts of on – airport employment (see chapter 15 of this Proof of
Evidence).
11.3
In essence the forecasts were driven by an analysis of demand growth
for the South East which suggested increasing constraints on cargocarrying capacity at Heathrow and Gatwick, through excess demand for
runway slots at both airports. This could be expected to reduce the
scope for growth in both bellyhold capacity (i.e. cargo space on
passenger ATMs) and freighter aircraft capacity.
11.4
The addition of increasing amounts of ‘spillover’ cargo demand to
Stansted’s own organic growth produces the forecasts.
The overall
demand is believed to be similar in both 25 mppa and 35 mppa cases,
but the distribution of it between whole plane cargo movements and
bellyhold capacity is expected to vary, with greater use of the latter in
the 35 mppa case because of the expected introduction of more long
haul passenger services.
24
12
Summary of 25 and 35 mppa cases
12.1
The key annual forecasts which were the basis of the assessments, and
which are set out in Volume 16 of the ES, are summarised below:-
Table 12.1
Measure
25 mppa
35 mppa
Difference from 25 mppa
case
case
Case
No.
%
Passengers (m)
25
35
+10m
+40
Passenger ATMs (000s)
180
242.7
+62.7
+35
Cargo ATMs (000s)
22.5
20.5
-2.0
-9
Total ATMs (000s)
202.5
263.2
+60.7
+30
Other Movements (000s)
13.5
11.0
-2.5
-19
Total Movements (000s)
216.0
274.2
+58.2
+27
600
600
Nil
Nil
Cargo Tonnes (000s)
NB: The slight disparity between some of the detailed figures given above and those
contained in Table 4 at para 6.7.1 of the ES Vol 1 is due to the rounding of the
figures given in Table 4.
25
13
Forecast Inputs to assessment of Terminal & Apron infrastructure
requirements
13.1
Forecasts supporting BAA’s assessment of the terminal and apron
infrastructure required for 25 and 35 mppa are presented in Volume 16
of BAA’s Environmental Statement, see section 5. These forecasts have
been derived from our assessment of the likely market mix, fleet mix,
and movement profiles described previously.
13.2
In its determination of the need for terminal infrastructure BAA uses a
measure of busy period activity known as the 5% Busy Hour (BHR).
This 95% percentile rate of passenger flow is meant to represent
conditions of crowding or queuing which would be experienced by no
more than 5% of annual passengers.
13.3 In the ES Vol 16 Appendix A1, Table A1.2 it can be seen that the
projected growth in these BHRs is less than the growth in annual
passengers.
This is the commonly observed experience as airports
grow in scale and traffic patterns tend, or are forced, to spread more
evenly both seasonally and diurnally.
13.4 As far as apron demand forecasts are concerned the peak at Stansted
in 2004 was for 57 passenger aircraft just prior to the morning departure
peak.
Having forecast the annual number and mix of aircraft types
consistent with the need to carry the passengers in the 25 mppa and 35
mppa scenarios the next step was to project the expected peak build up
of these aircraft requiring operational parking positions.
13.5
In the 25 mppa case it was assumed that the airlines would wish and be
able to continue to operate with broadly the same degree of peaking
patterns as observed in 2004.
In the 35 mppa case the degree of
enforced peak spreading was assumed to be greater, and there was
seen to be greater scope to develop new services with different peaking
patterns. This case would entail a more efficient use of required apron
space.
26
14
Inputs to noise, air quality and third party risk assessments
14.1
Air traffic forecast data forms an important input to the assessments
undertaken for air noise, ground noise, third party risk and air quality.
The base data on aircraft fleets used to derive the specific data for each
assessment was set out in Volume 16 of BAA’s Environmental
Statement, see Appendix A3 for air noise, Appendix A4 for ground noise
and Appendix A5 for third party risk. The air quality assessment also
used data drawn from these appendices, taken together with inputs from
the surface access assessment.
27
15
Forecasts of On-Airport Employment
Definition of Scope
15.1
The employment forecasts covered by my evidence relate to what is
known as direct on-airport employment. These are people employed by
firms engaged in activities directly related to the functioning of the
airport and whose place of employment is located inside the boundaries
of Stansted Airport.
Data Sources
15.2
There are two sources of on-airport employment data at Stansted. The
first is an annual census of all airport employers conducted by BAA that
produces a list of staff numbers by type of employer (e.g. airline, retail
concessionaire etc).
The second is via a more detailed survey
conducted at roughly 5 year intervals which, among other issues, obtain
information about employee characteristics such as place of residence,
household size, mode of travel to work and entry/exit time.
15.3
As a preliminary to gathering information directly from employees BAA
also attempts to conduct surveys among on-airport employers, mainly to
provide a guide as to their total workforce classified by job type so as to
ensure that subsequent returns from individual employees can be
scaled to make them representative of the total workforce.
15.4
The classification process aims to categorise employees in terms of the
airport function with which they are most closely linked, as follows: -
- Passenger related staff eg cabin crew
- Air traffic movement related staff eg pilots, refuellers
- Air cargo related staff
28
- Traffic related support staff eg firefighters, aircraft loaders
- Non-traffic related support staff eg administrative staff.
Forecast Process
15.5
There are four
stages in BAA’s methodology for forecasting
employment, as follows: -
i)
Categorise the employment in the base year according to the airport
function they support and whose growth will influence the rate at
which their numbers will change.
ii) Application of the relevant traffic forecasts to the three groups of
traffic related staff (passenger, aircraft movement and cargo
tonnage).
iii) Linking this growth to the base levels of general traffic related
support staff and non-traffic related support staff.
iv) Adjusting the resulting projected staff levels to reflect BAA’s
assumptions concerning the expected level of productivity gain.
15.6
The breakdown of employees established in the 2003 Stansted
Employment Survey was as follows: -
Table 15.1
Stansted On – Airport Employment 2003
Category
Staff
%
Pax Related
2,450
23
ATM Related
3,300
31
Cargo Related
480
5
Traffic Support
1,140
11
Non-Traffic Support
3,230
30
Total
10,600
100
29
15.7
The assessment of on-airport employment totals uses the forecast annual
passenger, movement, and cargo tonnage volumes summarised in the
table below: -
Table 15.2
Category
2003
25 mppa case
35 mppa case
Passengers (m)
18.7
25.0
35.0
ATMs (000s)
171.3
202.5
263.2
Cargo Tonnes (000s)
200.1
600.0
600.0
15.8
The pace of growth at Stansted in recent years, allied to the absolute
levels of traffic now attained, has been a major contributor to rapid
increases in labour productivity. This has been further boosted by the
nature of the traffic growth that has originated from low cost airlines with
high rates of labour productivity.
15.9
As a result labour productivity grew by over 14% between 1997 (when the
previous on-airport employment survey was conducted) and 2003. Such a
rate of productivity growth, which is significantly faster than that achieved
at Heathrow and Gatwick, cannot be expected to be sustained in the long
term. Factors that are likely to combine to reduce the rate of productivity
growth include slowing in the rate of traffic growth and changes in the mix
of airlines using the airport (including the introduction of long haul
services). As a result productivity is assumed to increase at a rate of
1.5% per annum in the 35 mppa case. The 25 mppa case assumes no
increase in labour productivity over 2003 levels. This reflects the
particularly strong commercial need that would prevail to develop nontraffic related activities (which still require staff) at the airport.
30
15.10 The resulting on-airport employment totals are given below: -
Table 15.3
On-Airport Employment
Total
2003
10,600
25 mppa case
14,350
35 mppa case
16,800
15.11 The employment survey recorded the staff distribution by location in 2003.
For the future this distribution has been adjusted to reflect: -
-
Growth in the various related components
-
Changes in volume of staff by category e.g. passenger related staff
are largely employed in the passenger terminal and Enterprise House
areas
-
Planned additions by zone to the stock of staff accommodation
-
Development of new zones of activity
15.12 The resulting distribution is given in Volume 16 of BAA’s Environmental
Statement, section 6.
31
16
Forecast input to surface access studies
16.1
In the consideration of surface access issues, the key air traffic forecast
inputs concern passenger volume, passenger type (for example UK
resident or foreign resident), journey purpose (for example Business), and
ground origin. This is because different types of non – transfer passenger
segments typically exhibit different modal choices (for example London –
originating Foreign Leisure groups are much more likely to use public
transport options than other groups).
16.2
The air traffic forecasts used as input to BAA’s surface access studies are
described in Volume 16 of BAA’s Environmental Statement, see section 7.
Passenger Volume
16.3
In the 35 mppa case non – transfer passengers account for a 83% share
of all passengers, against 90% in the 25 mppa case. The difference
between the two cases is a reflection of the additional airport capacity
available in the 35 mppa case. This will provide air passengers with a
greater range of routes and frequency than that offered in the 25 mppa
case, thereby facilitating a relatively higher transfer passenger share.
Passenger Type & Journey Purpose
16.4
There is a similar proportion of UK resident passengers (70 – 71%) in both
cases.
16.5
Although the absolute numbers of business passengers increases in the
35 mppa case, there is forecast to be a higher proportion of business
passengers in the 25 mppa case (23%) than in the 35 mppa case (19%).
The difference between the two cases reflects the circumstances outlined
in para 16.3; additional airport capacity in the 35 mppa case will provide
greater opportunities for travel to a wider range of passengers. In the 25
mppa case the relative scarcity of capacity is likely to lead to an increase
in airfares (relative to the 35 mppa case), with the opportunity to fly from
Stansted being purchased by those who can most easily afford it (ie
especially price inelastic segments such as business travellers).
32
Ground Origins
16.6
The constraints of 25 mppa will produce a more locally – biased set of
passenger origins than that likely in the 35 mppa case. In the 25 mppa
case 13% of passengers are assumed to originate from outside the South
East and East Anglia. This figure rises to 16% in the 35 mppa case,
illustrating the drawing power of an expanded Stansted.
16.7
In their report to Uttlesford DC, ‘Review of BAA Traffic Forecasts for
Stansted Airport’ (Feb 2006) SH & E commented that they held a different
view to BAA on passenger ground origins in the 35 mppa case. SH & E
suggested that Stansted’s passengers would be drawn from a more local
area than that assumed by BAA, with no more than 13% of passengers
originating outside the South East and East Anglia. This alternative
viewpoint is examined in the ‘SH & E’ sensitivity test. The ground origin
forecasts for this sensitivity, which have been agreed with SH & E are
given in Table 16.1 below and have been modelled in the Addendum to
the Transport Assessment.
Table 16.1
SH & E Sensitivity
This sensitivity, which examines an alternative set of passenger ground origins for
the 35 mppa case, is based on the following forecasts: -
Zone
Inner London
London Outer NE
London Outer SE
London Outer SW
London Outer NW
Outer South East NE
Outer South East NW
Outer South East SW
Outer South East SE
South West & Wales
W Midlands
E Midlands
E Anglia
Rest of UK
TOTAL
UK
UK
Foreign
Foreign
Business
Leisure
Business
Leisure
TOTAL
0.51
0.93
0.45
1.71
3.59
0.36
2.28
0.08
0.99
3.71
0.10
0.72
0.03
0.30
1.16
0.18
0.87
0.13
0.57
1.74
0.10
0.92
0.03
0.62
1.67
0.85
3.18
0.24
0.71
4.99
0.25
0.91
0.06
0.29
1.51
0.11
0.54
0.03
0.27
0.95
0.18
0.75
0.02
0.29
1.24
0.12
0.59
0.04
0.24
0.99
0.11
0.42
0.01
0.10
0.64
0.23
0.95
0.06
0.13
1.36
0.85
2.83
0.23
0.76
4.67
0.07
0.69
0.03
0.16
0.94
4.02
16.58
1.45
7.12
29.17
33
Busy Day Passenger Demand
16.8
Forecasts of the volume and hourly profile of non – transfer passengers
on a busy day are given Volume 16 of BAA’s Environmental Statement,
paragraphs 7.4.1 – 7.5.2.
Employee Reporting Profiles
16.9
Forecasts of employee reporting profiles have been used in the modelling
of surface access flows. These are presented in Volume 16 of BAA’s
Environmental Statement, paragraph 6.1.13.
34
17
Car Parking Forecasts
17.1
BAA’s assumptions about the requirement for public and staff car parking
spaces in the 25 and 35 mppa cases are presented in Volume 16 of BAA’s
Environmental Statement, see section 8.
17.2
The forecast requirement for car parking spaces is as follows: -
Table 17.1
Car Park Type
25 mppa
35 mppa
Difference from 25
case
case
mppa Case
No.
%
Long Stay*
23,200
28,900
+5,700
+25
Mid Stay
5,750
6,950
+1,200
+21
Short Stay
2,400
2,950
+550
+23
TOTAL PUBLIC CPs
31,350
38,800
+7,450
+24
BAA Managed Staff CPs
2,650
3,000
+350
+13
* Includes parking at off airport sites
35
18
Latest BAA Forecasts
18.1
As was referred to in paragraph 2.3 above, the forecasts prepared by BAA
contained in Volume 16 of the Environment Statement were the product of
work undertaken during 2004 and 2005. As part of the normal process of
running its business, BAA routinely reviews projections for all its airports,
including Stansted.
18. 2
The most recent forecast review, undertaken in early 2007, has taken into
consideration a variety of issues, but the most significant have been,
a)
The continued rise in the price of oil and more pessimistic views
about its future trend; and
b)
The growing pressure to reduce the rate of growth in demand for air
travel by means of taxes and / or emissions trading schemes
Oil Prices
18.3
The oil price assumptions made by BAA at the time it was preparing the
Environment Statement forecasts were based on its view that , in real
terms, prices would stabilise at around $55 per barrel (from a figure of $69
in September 2005) and gradually fall to $50 by 2015 as new sources of
supply were tapped and the rate of demand growth moderated. Since then
the evidence of sustained higher prices, demand growth and persistent
political instability in key producing areas has caused BAA to revise
upwards the oil price assumptions. In late 2006 the prevailing price was in
the range of $60 – 65 per barrel. BAA’s latest forecasts now assume a
decline to $60 (in real terms) by 2010 and $55 by 2015.
Environmental Charges
18.4
During the autumn of 2006, following publication of the Stern Review, the
Chancellor’s announced intention to double the rate of Air Passenger Duty
and the publication of a draft EU Emissions Trading Scheme, it became
clear that BAA’s previous assumptions relating to environmental charges
needed to be revised to assume a more rigorous charging regime. 3
36
18.5
This entailed reflecting a continuation of the new higher rate of APD and
making the assumption that the aviation sector would join the EU
Emissions Trading Scheme (ETS) from 2011.
18.6
The combined effect of higher oil prices, a doubling of APD, and the
application of assumptions about EU ETS has the effect of slowing BAA’s
demand forecasts for the South East. In the short term most of the
difference is attributable to higher oil prices and the APD increase, while
over the longer term the impact of an EU ETS becomes more significant in
reducing the demand forecast.
18.7
BAA now expects that passenger throughput at Stansted in 2014/15 will
be some 2 mppa below that forecast at the time it made its application.
This is the result of the slightly slower growth in throughput outlined above
and represents about 12 – 18 months slippage; in other words BAA now
expects 35 mppa will be reached in 2015/16.
3.
At the time that the forecasts in the Environmental Statement were conceived BAA had taken a cautious
view of the likely downward trend in oil prices as a proxy for the addition of environmental taxes, on the
basis that they would be more likely to be imposed (and / or be higher) if the oil price was to collapse
again as in the 1980s.
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19
Conclusion
19.1
Although, for the reasons given in Chapter 18, BAA has recently reviewed
and slightly revised down its forecasts for Stansted it is confident that
figures presented in Volume 16 of the Environmental Statement remain its
best view of the traffic characteristics associated with a 35 mppa and 25
mppa at around 2015.
19.2
It is re – assured in this by the comments of Uttlesford’s traffic forecasting
consultants who, as reported in Chapter 2, concluded “that the passenger
forecasts produced by BAA for Stansted are reasonable” and that its
aircraft fleet mix forecasts “represent a reasonable view of aircraft
movements by type when Stansted operates at 35 mppa”.
19.3
In the two areas where the consultants differed from the BAA viewpoint,
namely the proportion of Long Haul passengers and the zonal distribution
of passenger ground origins (both in the 35 mppa case), sensitivity tests
have been conducted to test the materiality of any additional noise or
surface access impacts.
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