Representation by Holiday Extras Ltd (Holiday Extras Ltd)
- Date submitted
- 21 June 2023
- Submitted by
- Members of the public/businesses
These comments are raised on behalf of Holiday Extras Ltd, a leading UK distributor of on- and off-airport car parking spaces. My clients sell a range of holiday related products in addition to airport related car parking, including airport hotels, airport lounges, travel insurance and car hire. These products are sold directly to customers on their database, which extends to approximately 6 million UK homes, as well as to a wide range of business partnerships and other travel related organisations. Introduction Holiday Extras Ltd support the DCO application which will deliver significant socio-economic benefits both regionally as well as nationally. They also appreciate that there is a need for a comprehensive package of measures to mitigate the environmental effects derived from the Airport’s expansion, seen in the context of the Government’s specific net zero strategy for aviation. My clients do however have a number of concerns surrounding the topic of airport surface access, with particular reference to on-airport passenger related airport car parking provision. The accompanying comments set out those most salient issues forming part of my clients’ concerns, to be elaborated upon at the Examination into the DCO application. Holiday Extras Ltd’s subsidiary company Airparks operate a traditional long term off-airport car parking business from Slip End based on the park and ride model, where cars are parked before the customer is transported by bus to and from London Luton Airport. The total number of car parking spaces available at Slip End varies between 3,500 and 5,300 spaces, being dependent on market conditions, which in turn dictates the extent to which customers’ vehicles are either self-parked or block-parked. In order to appreciate the scale of Airparks’ business, the maximum capacity in terms of car parking spaces at their Slip End site is greater than the provision of existing long stay passenger on-airport car parking at London Luton Airport in 2019, prior to the construction of the Luton DART; being equivalent to 81% of all anticipated long stay on-airport car parking in 2043 at which time the Luton DART will serve the two terminals, and when passenger throughput is expected to reach 32mppa. Previous Discussions Involving LLAL During the period from mid-November 2019 through to the end of February 2020 discussions took place between my clients and representatives of LLAL over the provision of a new satellite long term off-airport car parking facility, to be run by both parties to meet the needs of air passengers relying on the private car mode as part of a future DCO application. No reference was made in the subsequent consultation exercise carried out between February and April 2022 to the same proposal, and no reasonable assessment has been conducted of this option, especially given the comments made by LLAL at paragraph 2.6.23 of the Surface Access Emerging Transport Assessment (SAETS) entitled “Getting to and from the Airport – Emerging Transport Strategy”, where it formed part of the 2022 consultation exercise: “2.6.23 For those passengers that have no reasonable alternative choice to driving, we want to ensure that the overall number of vehicle movements at the airport is minimised, and their environmental impact is reduced where possible. We will do this by encouraging more efficient use of the road network that will lead to less vehicle mileage overall by ensuring passenger trips to the airport made by car and taxi are as clean as possible in terms of vehicle emissions.” Surface Access Strategy (SAS) The current DCO application incorporates a Surface Access Strategy (SAS) [TR020001/APP/7.12] which sets out the vision and objectives of the applicant, Luton Rising, for surface access, along with priority areas and interventions that form part of their approach to achieving their vision. The SAS’s vision comprises five objectives, three of which are particularly relevant to the business conducted by Airparks from Slip End, namely (i) supporting Luton Borough Council’s climate ambitions; (ii) striving to be the best possible neighbour to communities and authorities; and (iii) contributing towards the local economy through multi-modal transport links. To fail to engage with my clients, who have raised representations to previous consultation exercises leading up to the current DCO application is unhelpful, particularly at a time when a key principle throughout the SAS’s 20-year duration is the need for flexibility given the levels of uncertainty which exist, along with the requirement for the same document to remain effective in the long term. Since discussions surrounding a possible satellite long term off-airport car parking site were terminated at the end of February 2020, no attempts have been made by Luton Rising to contact my clients and hold open, meaningful and transparent discussions over the contribution which they can make to the SAS’s vision, objectives and the priority area relating to vehicle access, parking, private hire vehicles and taxis. This priority area is particularly pertinent to the business conducted by Airparks, who as a major existing long term off-airport car parking provider are in a position to make a positive contribution. The SAS incorporates Limits and Targets, with the Limits being set out in the Green Controlled Growth (GCG) [TR020001/APP/7.08] and Targets set out in the five-year Travel Plan (TP). The GCG is a binding framework for managing the growth of the airport through the coming decades within definitive environmental limits, which in terms of surface access is directly related to potential congestion on local and strategic road networks. The TPs set out the management Targets based on non-sustainable passenger travel mode share (% of passengers using non-sustainable travel modes of all passengers travelling to and from the airport) comprising one of two surface access limits whose purpose is designed to control changes in mode share. The definition of ”Passenger non-sustainable travel” as part of an “unsustainable mode” is defined in paragraph 3.5.17d. of the Green Controlled Growth Explanatory Note [TR020001/APP/7.07] as comprising “travel by car, taxi (Hackney carriage), private hire vehicle (minicab/Uber, etc) motor cycle and any other modes with the exception of minibus, bus, coach, rail and tube (also referenced as metro, subway, tram in the CAA survey), walking, wheeling, cycling and other active modes (e-bikes, e-scooters, etc)”. This definition relating to passengers does not sit comfortably with the view expressed by the applicant and operator that members of staff comprising part of a car share are to be classified as a sustainable trip. The document comprising Appendix F – Surface Access Monitoring Report relies on the “main mode” of a particular trip, despite the dataset being recognised as having fewer survey records, with its results being inconsistent. Relying on the “main mode” is at variance with CAA records which is determined according to the final mode of travel, being the last mode used to access the airport, whilst at the same time appearing inconsistent with the approach to monitoring passenger mode share, which as indicated in the FTP [TR020001/APP/7.13] is dependent on CAA passenger survey data, particularly the final data sets published at Easter time. The Least Sustainable Trips to the Airport What the SAS does not grapple with in any comprehensive way is the accepted least sustainable means of passenger access to London Luton Airport, being what has been termed “kiss and fly” along with taxis/minicabs and private hire vehicles. These modes involve a doubling of trips to the same airport. It is counter-intuitive to set up a charging mechanism at the airport’s car parks which on the one hand seeks to discourage the “kiss-and-fly” mode, whilst on the other, simultaneously proposes a steep increase in the number of drop-off and taxi spaces over the three phases of the DCO development, along with an additional pick/drop off area provided in car park 12 in Phase 2b. The management of vehicle demand through the use of access and parking charges, whilst a key component associated with incentivising sustainable modes, vehicle choice and protecting surrounding communities from potential negative impacts; has the ability to give rise to unintended consequences in terms of parking in surrounding residential streets, in order to avoid having to pay costly on-airport car parking charges. In this respect, the pricing strategy adopted by Luton Rising towards all passenger car parking products, including use of the Luton DART, is strongly correlated to the demand for on-airport passenger car parking products, including the extent to which passengers will then rely on the least sustainable access modes to the same airport. In the case of the current DCO application, a far more reaching impact is that all the proposed interventions and measures require funding to support both capital and operating costs. No framework forming part of the DCO application assesses the costs and benefits of surface access interventions to ensure investment decisions maximise the opportunity of reaching set Targets, seen in terms of the choice of modal access share generally. Any aim of incentivising the use of cleaner greener vehicles serving the airport as part of a move to zero emissions has an opportunity cost; with the passenger asking themselves the question of whether there are alternative more reliable cheaper options, an important consideration to those households who are confronting cost of living difficulties or other financial challenges. The 2019 passenger modal split survey at a throughput of 18mppa reveals that 45% of those accessing London Luton Airport relied on a taxi/minicab and private car (drop-off/pick-up), being a far higher percentage than passengers relying on either public transport modes, or those passengers dependent on combined long term on-and off-airport car parking provision . The number of passenger person trips in the AM and PM peak periods reflect reliance placed on these two least sustainable modes . These figures are required to be seen in the context of the toolbox of interventions relating to vehicle access, parking, private hire vehicles and taxis, which seek to introduce measures to encourage more efficient use of taxi and private hire trips, ensuring where possible vehicles are occupied in both directions, thus reducing the number of empty vehicle trips coming into and out of the airport. Both taxis and private hire vehicles along with the “kiss-and-fly” modes are required to be examined from a wider locational context, with surrounding residential streets revealing an absence of parking restrictions, and where in recent years there has been a rise in the number of technological platforms matching drivers with car parking spaces through their websites and apps, representing part of what has been referred to as the “sharing economy”. JustPark is one of a number of technological platforms whose mission is to transform the way drivers look for parking spaces, whilst delivering cash to home owners who rent out their driveway. The same platforms enable other businesses such as hotels to maximise their income from airport related car parking. Exploring More Sustainable Approaches to Surface Access These aspects of access mode to London Luton Airport do not seem to have been assessed as part of the DCO application despite their increasing popularity. When combined with the need to carry out improvements to the highway network throughout the duration of the proposed development to ensure its efficient use; the same factors collectively point to the requirement to explore a more sustainable approach to surface access. In the opinion of Holiday Extras Limited it requires further consideration to be given to satellite long term off-airport park and ride facilities which (i) have the added benefits of reducing trips and vehicle emissions on the highway network close to London Luton Airport, (ii) minimising the propensity for indiscriminate passenger car parking on surrounding residential streets, (iii) ensuring valuable space on-airport is utilised for alternative purposes, and (iv) avoiding on-airport passenger car parking encroaching onto Wigmore Park and the Green Horizons Park development, the latter required to meet its own parking needs. The fact that multiple interventions are associated with the applicants’ surface access toolbox supports the importance to be attached to a detailed assessment of available alternative access strategies. The Framework Travel Plan (FTP) The submitted Framework Travel Plan (FTP) [TR020001/APP/7.13] sets out a framework for the content of travel plans which should be produced every 5 years following the current DCO application, whose purpose is to set out the structure and approach for developing the 5 year TP. For vehicle access, a key priority is progressing measures which support the uptake of electric vehicles through supporting infrastructure and incentives. TPs will contain the results of on-going monitoring and consider comments and views from stakeholders including the Airport Transport Forum (ATF) and the London Luton Airport Consultative Committee (LLACC) on their content and level of ambition, although as previously indicated, no role has been set aside for the largest private long term off-airport car parking operator to effectively engage in this process. Airparks have been operating from Slip End for a continuous period approaching 25 years and at no time has an opportunity been extended to my clients to join the ATF, neither have their views been sought by the LLACC, or the associated dedicated Passenger Services Sub-Committee. With these facts in mind, they have been excluded from taking a pro-active role as part of these important airport access related organisations in the future development of the airport. This is a significant omission given that the primary purpose of ATFs as confirmed in paragraph 2.1.2 of the FTP [TR020001/APP/7.13] is to “encourage partnership between airport operators, local authorities, transport operators, local people and businesses, and other relevant parties, to improve public transport access to airports, and reduce reliance on private, road-based transport, congestion, and pollution on nearby roads”. The ATF is intended to summarise current surface access across six priority areas in any five year period, including consideration relating to “vehicle access, parking, private hire vehicles and taxis”, together with the specific matters relating to drop-off and pick-up locations, car parking locations and quanta. My clients as the only major private long term off-airport car parking operator have both a role to play in these important airport access related issues, at a time when the airport operator accepts its sustainability aspirations are reliant on third parties. In this respect, the toolbox of interventions and measures in the FTP where it concerns the same topic have implications, and are pertinent to the running of a long term off-airport car parking operation, particularly in those areas of i) promoting EV charging points for passengers and the uptake of electric vehicles; ii) improving forecourt operations especially limiting queueing and anti-social drop-off; iii) incentivising a change from diesel/petrol to electric/hybrid service vehicles; iv) contributing to a feasibility review associated with the opportunity to support luggage delivery from/to the airport to/from the passengers home destination, and v) improving an understanding of passenger travel behaviour as part of more comprehensive surveys to robustly monitor progress in achieving airport targets. Green Controlled Growth (GCG) My clients have carefully considered the GCG Framework where it is directed at surface access and the various limits and thresholds surrounding future growth at London Luton Airport, alongside the approach to the preparation of Monitoring Reports and the trigger mechanism for the submission of a Mitigation Plan. It is acknowledged that the approach is innovative and far reaching in seeking to enable the sustainable expansion of London Luton Airport, particularly in circumstances where mitigation is necessary with reliance placed on the slot co-ordination process, and capacity declarations. To what extent this mechanism ensures sustainable growth at London Luton Airport along with the extent to which it will impact on the ability and decision of passengers to switch airports remains an unknown factor. This aspect of passenger behaviour does not appear to have been considered. The situation depends, in part, on the extent to which passengers regard services at different airports as reasonably close substitutes, and the costs they face in switching demand to the next best alternative. The availability of suitable alternative flights to the same destination as well as the willingness of passengers to follow an airline to an alternative airport is likely to be important in deciding to switch. There are other associated implications surrounding this process based around reducing harmful pollutants from vehicle emissions and issues of air quality. Holiday Extras Limited have reservations concerning the governance of the Environmental Scrutiny Group (ESG) whose independent chair will initially be nominated by the airport operator, following consultation with the Applicant and Secretary of State, and where the majority of parties represented on the ESG comprise local authorities with a tendency to pursue common goals, without the added diversity of views from private organisations with surface access business interests. To the extent that representatives from local authorities should be suitably qualified senior planning professionals; so too should the requirement be the same for those private bodies with access business interests. Equally relevant is the remit of the Surface Access Technical Panel, where Holiday Extras Limited have a wealth of experience as a successful long term off-airport business, yet again no private organisations with surface access interests are expected to comprise this Panel, despite it being accepted that “not all of the organisations listed above have this in-house capacity”. Passenger Modal Share Although local development plan documents are not the starting point for consideration of a DCO application, they are, as previously acknowledged by the Applicant, an important and relevant consideration. Policy LP6C forming part of the adopted Luton Local Plan 2011-2031 indicates where airport related car parking is to be located within the Airport Strategic Allocation on the Proposals Map. In these areas the airport is required to demonstrate that the proposals meet an objectively assessed need; do not adversely affect the adjoining highway network, and will not lead to detriment to the amenity of the area and neighbouring occupiers. New Century Park, renamed Green Horizons Park, along with Wigmore Valley Park, although situated in the Airport Strategic Allocation, are excluded from providing airport related car parking in Policy LP6C. In effect this means that in development plan terms, the only real difference between sites lying within the Airport Strategic Allocation but excluded for airport related car parking purposes; and other sites situated outside the Airport Strategic Allocation, is that in the case of the latter they are required to accord with the sustainable principles defined in the Local Plan as a whole, as well as the current requirements of the current approved ASAS. The broad split between public transport and private modes of travel, relying on the modified version of the Central Bedfordshire Luton Travel Model, amended to take into account Hertfordshire County Council COMET transport model is provided at Table 18.7 of the Document TR020001/APP/5.01 Chapter 18 Traffic and Transportation Volume 5 Environmental Statement and Related Documents. Equivalent figures for total public transport modal share by passengers of 45% in 2043 at a throughput of 32mppa is provided in Table ES.2 reproduced in Document 7.02 Transport Assessment – Part 1 of 4 [TR02001/APP/7.02]. Table 18.7 shows that in 2043, at a 32mppa throughput, 39% of the modal share will be by car, which is the same as the drop-off figure in the same year derived from those various sources set out in Table 1. It is not clear whether the 39% in Table 18.7 includes both drop-off and passengers leaving their car at on-airport car parks. In the event that the 39% includes drop-off, there remains a need to calculate the proportion of passengers accessing London Luton Airport leaving their cars in an on-airport car park. Two important aspects should be taken into consideration when considering public transport modal share. Firstly, it is largely dependent on non-UK business and leisure passengers compared with UK based business and leisure passengers, which falls outside the direct control of the airport operator. Secondly, the information provided in Document TR020001/APP/5.01 reveals in terms of rail passengers that the greatest share in terms of the distribution of additional passenger loading over each phase of the DCO application is in locations situated to the south of the airport in the section extending from Luton Airport Parkway station to West Hampstead, occupying a relatively small part of the catchment population of the airport. Existing and Proposed Airport Related Passenger Car Parking Provision It should be noted that where staff car parking was previously located on-airport within the Operational Area Boundary, it has been decanted outside the Operational Area Boundary of London Luton Airport, onto two separate sites east and west of the Luton Airport Parkway railway station. Car Park P1 is to comprise a new multi-storey to accommodate 1,000 car parking spaces for airport staff only, with Car Park P2 being a surface level car park previously used as a trailer park site occupied by HGV parking and coaches, again for staff car parking purposes only. In this way, Car Parks P1 and P2 are reserved for staff parking to be provided in Phases 2a and 2b. These two proposed staff car parking sites lie in close proximity to Bartlett Square which was previously the subject of an application (Luton BC Ref. No. 18/00271/EIA) for “combined-long/short/staff/mid stay car parks, car hire and valet”, despite an earlier proposal preventing the use of the same land for airport related car parking. All future mid and long-stay on-airport car parks in Phases 1, 2a and 2b are required to have shuttle buses to transport passengers to the respective terminals, in the same way as is the case with the long term off-airport car parking site operated by Holiday Extras Ltd at Slip End. The locations of the various on-airport passenger car parking products over the three phases of the DCO application are based on information set out in Figure 8.8, Figure 8.9 and Figure 8.10 taken from Document [TR020001/APP/7.02] Transport Assessment – Part 2 of 4. Short stay on-airport car parking in Phases 1 and 2a is provided in the Operational Area Boundary of the existing airport at car parks P3 and P4, the latter comprising two multi-stories. Increased provision for this parking product is provided in Phase 2a at a throughput of 27mppa on a new decked car park on land at P5, which itself results in a reduction in car parking capacity on the same land of 1,250 spaces, having previously been used in Phase 1 for long term passenger block parking, where approximately 2,450 spaces were available. In Phase 2b commencing in the first quarter of 2037, additional short stay car parking is provided in a new multi storey car park P12 lying outside the Operational Area Boundary of the existing airport providing approximately 2,225 car parking spaces to meet the needs of Terminal 2, but where it is also intended to be used for pick-up/drop-off use including valet parking. Mid stay on-airport passenger car parking during Phases 1 and 2a is provided on existing car park P3 within the Operational Area Boundary of the airport along with the short stay product. Car park P7 constructed on land forming part of Wigmore Park, beyond the airport’s Operational Area Boundary, is also used for mid stay on-airport passenger provision in Phases 1 and 2a. Car park P7 fundamentally changes shape as a consequence of the construction of the second terminal, and the Green Horizons Park development, resulting in a reduction in the number of spaces from 3,090 to 1,230 over the two phases, having previously been used for long stay passenger parking in Phase 1. Two new car parks P10 and P11 meeting both mid and long stay car parking are constructed on land beyond the Operational Boundary of the airport during Phase 2a, catering for 1,150 and 2,700 spaces respectively. In Phase 2b, mid stay passenger car parking is concentrated on car park P3; at car park P10 where the capacity is increased to 3,165 spaces, and on existing decked car park P5 which accommodates 1,200 spaces. Long stay on-airport passenger car parking in Phase 1 is retained on car park P5 as well as on extended car parks P6 and P7 beyond the Operational Area Boundary of the airport. In the same way as car park P7, car park P6 changes shape primarily as a consequence of the construction of the second terminal, and the Green Horizons Park development, being used for long stay purposes in Phases 1 and 2a, but altering from a self-park to a block parking format in Phase 2a with a resultant increase in capacity from 1,250 to 1,620 available passenger spaces. In Phases 2a and 2b, all long term on-airport car parking is provided outside the Operational Area Boundary of the airport on car parks P6, P10 and P11. Car park P10 is devoted to both mid and short stay passenger car parking being subsequently extended in Phase 2b to 3,165 spaces but where 505 spaces are also used for staff car parking. The capacity of car park P11 used for long stay purposes increases from 2,700 to 5,530 spaces in Phase 2b. Important Conclusions Five conclusions arise from this exercise when analysed in conjunction with the contents of Table 2 along with Inset Maps 4.10, 5.36 and 6.6 where they comprise part of Document TR00001/APP/5.02 Appendix 4.1 Construction Method Statement and Programme Report 2 Assessment Phase 1, 2a and 2b Car Park Locations. A. There has been no material change in the number of short and long term on-airport passenger car parking spaces since the time Application No. 12/01400/FUL was submitted to Luton Borough Council in December 2012. The number of mid-stay on-airport passenger car parking spaces since the date of submission of same application has declined as a consequence of the subsequent construction of the Luton DART linking the Airport to Luton Parkway railway station. The number of long-term on-airport passenger car parking spaces has remained static over the last 11 years at around 4,500. Put into perspective, a passenger throughput of 19mppa equates to 52,000 passengers per day but there is less than 10,000 on-airport car spaces to service their needs. These conclusions are required to be assessed alongside the contents of paragraph 7.32 of the Statement of Case prepared on behalf of Luton Borough Council to Application No. 21/00031/VARCOM called in by the Secretary of State which sought variations to earlier conditions, as well as to accommodate a throughput of 19mppa: “7.32 The provision of available car parking at the airport is below that which was envisaged in the 2012 application and the rapid growth of the airport has resulted in a greater under provision of available spaces.” B. The DCO application reveals that from Phase 1 there is a requirement for the airport to use land outside its Operational Area Boundary to accommodate mid stay and long stay on-airport passenger car parking requirements, and this continues with further extensions westwards during Phases 2a and 2b. Short stay on-airport passenger parking also has to rely on land outside the existing Operational Area Boundary of the airport in Phase 2b. There is no indication of how the key modelling input in calculating the number of on-airport passenger car parking spaces required at London Luton Airport at a passenger throughput of 21.5mppa, 27mppa and 43mppa has been calculated, including whether it has considered the occupancy/demand ratio, being the number of cars wishing to park at London Luton Airport, and the volume of spaces required to service that demand on a monthly basis. Similarly, no study appears to have been undertaken of anticipated changes in customer behaviour where emphasis has been placed on customer profiling based on the popularity of certain destinations; flying frequency; trip duration and trip frequencies as part of a greater understanding of the cyclicality of passenger parking demand throughout the year. C. An examination of Table ES.1 Proposed Car Parking in Document [TR02001/APP/7.02] Transport Assessment – Part 1 of 4 and Table 8.2 Proposed Assessment Phased Car Parking Provision taken from Document [TR02001/APP/7.02] Transport Assessment – Part 2 of 4 set out in columns 4, 5 & 6 in Table 2, is required to be considered in the light of Inset Maps 4.10, 5.36 and 6.6 where they comprise part of Document TR00001/APP/5.02 Appendix 4.1 Construction Method Statement and Programme Report 2 Assessment Phase 1, 2a and 2b Car Park Locations. The relevance in carrying out this exercise lies in the fact that in Phase 1 at an anticipated passenger throughput of 21.5mppa, a total of 2,485 spaces comprise relocated mid and long stay car parking on car parks P6 and P7, whilst in Phase 2a as a consequence of the further reconfiguration of the shapes and capacities of car parks P5, P6 and P7, a total of 2,740 spaces are lost when compared with the same car parks present at the earlier Phase 1. D. It is therefore important when considering the intended use of on-airport car parks for short, mid and long-term passenger parking purposes, to have regard to the same Inset Maps, to the extent that they reveal that the entirety of certain car parks are not devoted to on-airport passenger car parking use. By way of example, car park P7 at a passenger throughput of 21.5mppa is not used solely for mid and long stay, whether in terms of either new or relocated provision. The same car park is to cater for relocated car hire and for new employee car parking. In a similar vein, car park P10 in Phase 2b at a throughput of 32mppa reveals a capacity of 3,165 spaces, of which 700 spaces are to be used for car hire purposes and 505 spaces for staff. In the case of staff car parking, this is in addition to additional staff car parking amounting to 1450 spaces provided on land to the east and west of Luton Parkway railway station in Phase 2a. E. It is contended that 16,000 car parking spaces which are to cater for short, mid and long-term passenger car parking purposes in 2043 at a throughput of 32mppa, is insufficient for the above reasons and particularly when considering alternative airports displaying similar modal share characteristics to those at London Luton Airport. In the case of London Stansted Airport, the total number of short, mid and long-term spaces in 2017 was 26,800 spaces, equivalent to a doubling of spaces per million terminating passengers at a throughput of 24.2 mppa. These considerations place increasing importance on companies such as my clients in meeting any future shortfall in supply at London Luton Airport, irrespective of the interventions that are to form part of the GCG and the provisions of the FTP. A further important attribute of long term off-airport car parking companies such as Airparks Services Ltd, operating form lawful uses in the vicinity of London Luton Airport, extends beyond issues of demand and supply. They provide a welcome choice for passengers where, if left to be dominated by the airport company, there would be an absence of competition in the market for airport related car parking, The importance of this issue becomes apparent from the document produced by the Civil Aviation Authority CAP 1473 entitled “Review of Market Conditions for Surface Access at UK Airports – Final Report” published in 2016, paragraph 4.9 of which is noteworthy. “4.9 Under such a market definition, it follows that airport operators generally are present in both the upstream (access to the airport) and downstream (services to get to the airport) levels of the surface access sector. As such the airport operator provides third parties access to facilities that are necessary for them to supply surface access services to passengers, whilst at the same time competing with those third parties in the downstream market. This may mean that airport operators have incentives to favour their own services in granting access to facilities needed by their rivals.”