Written evidence submitted by Airlines UK



Written evidence for the Digital, Culture, Media and Sport Committee’s inquiry into Promoting Britain abroad


About Us: Airlines UK


Airlines UK is the trade association for UK airlines. Our members are 2Excel, AirTanker, British Airways, CargoLogicAir, Eastern Airways, easyJet, Jota Aviation, Jet2.com, Loganair, Ryanair, TUI Airways, Titan Airways, UPS, and Virgin Atlantic. The CEO of Airlines UK, Tim Alderslade, is a

member of the Government’s Tourism Industry Council.


We welcome this opportunity to provide evidence to the Digital, Culture, Media and Sport

Committee’s inquiry and would be glad to support with further written or oral evidence as needed.


Aviation directly employs more than 536,0001 people across the nations and regions of the UK. With most international tourists arriving to the UK by air, aviation is also a vital enabler of inbound tourism. Ultimately, those issues holding back the recovery of UK aviation will need to be addressed if UK inbound tourism is to be able to recover from the pandemic.


In this response, we will focus on:

-          Impact of Covid on UK aviation sector (now Omicron)

-          Impact of UK traveller testing regime

-          Experience at UK border


















1 https://airlinesuk.org/aviation-jobs-in-great-britain/


What needs to be done to re-establish the UK as a holiday destination for international travellers?


-  What should Government and the tourism boards be doing to support the inbound tourism industry in its recovery?

-  What will the impact on the UK’s hospitality, cultural and heritage sectors be if inbound tourism is slow to recover to pre-pandemic levels?


The pandemic has had a devastating and immediate impact on the whole of the UK travel and tourism industry, including UK airlines. This crisis is still not over, with the emergence of Omicron resulting in the recent reimposition of an onerous and costly multiple testing and isolation regime for the UK that has been, again, more restrictive than most of our competitor markets (i.e., the reimposition of the pre-departure test for all arrivals, and switch to PCR arrivals test with mandatory self-isolation until negative result).


However, even before the Omicron variant resulted in additional emergency restrictions on international travel to the UK, the progress made in simplifying the UK’s international travel system and reducing the testing regime was not yet complete.


Last summer UK airlines, unlike many of our international rivals, were still not able to trade on pre- pandemic terms, with even fully vaccinated travellers subject to testing (pre-and post-arrival) and the extra cost, inconvenience and uncertainty that entailed. This contrasted with Europe where for the fully vaccinated, there was no need to take any tests at all – which was the case over most of the summer travel season.


It was only in the Autumn when the requirement for fully vaccinated arrivals into the UK to take a pre-departure test was dropped, however the need to take a test on arrival (changed from PCR to lateral flow) remained. Following the announcement made by Government on 5 January, this is the situation to which travel will return shortly, i.e., with emergency measures dropped but the retention of the Day 2 arrivals lateral flow test, even for the fully vaccinated.


Clearly, for travellers looking to holiday in the UK or do business, the UK was and will remain a less appealing destination compared to countries that have dropped testing requirements – not least for the fully vaccinated, business, or short-stay travellers. Moving forward, a priority must be delivering a level playing field for the UK as a destination – including by removing the need for ANY tests for the fully vaccinated - if our inbound UK tourism sector is again going to be able to fully recover and compete internationally.


Bookings respond to restrictions


The following chart helps show how sensitive bookings have been to the rules and measures in place. You can see the increase in bookings, except for the UK, over the 2021 summer as restrictions were lifted across Europe. This highlights how far behind the UK was compared to its competitors over the summer when our rules were, relatively, the strictest (including pre- and post- arrivals tests, even for the fully vaccinated, compared to no tests across most of Europe).


We saw a sudden rise in UK bookings in September when UK restrictions were eased (i.e., the announcement that the fully vaccinated would only require a single lateral flow test on arrival),

A screenshot of a computer  Description automatically generated with medium confidence


Figure 1


which quickly saw the UK recover significant demand, comparable to levels seen in France and the Netherlands at the time.


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As can be seen in the Eurocontrol data below on airport passenger traffic and flight numbers from 2021, across the year as a whole Europe saw a much faster recovery in international travel volumes and passenger numbers compared to the UK:


Figure 2 2021 Traffic Loss. Source: EUROCONTROL



Figure 3 2021 Traffic Loss. Source: EUROCONTROL




In summary:

15% in Spain).


The UK pre-pandemic was home to one of the most dynamic and successful aviation sectors in the world and had the 3rd largest global aviation network behind only the United States and China. This supported directly over half a million aviation jobs, and many more across the wider economy, particularly in tourism.


The danger is that the UK is unable to recover this status, and sees both jobs and connectivity lost to rivals, particularly to rival hubs in the continent and in the Middle East. The pandemic saw London Heathrow lose its top spot among European airports last year, trailing both Istanbul’s new


hub, and Paris Charles de Gaulle. Today, many travellers are bypassing the UK, because travel to other parts of the world and particularly into Europe is easier, and cheaper.


To date, since the crisis began UK airlines alone have announced or consulted on over 30,000 job losses, and research suggests that across the industry some 5,0002 jobs have been lost across the sector each month since the crisis started. Many thousands more jobs remain under threat across the supply chain. Whilst we have seen few airline failures, many carriers are smaller, supporting fewer jobs, and offering reduced international and UK connectivity.


The overall impact of the past two years on inbound tourism is laid bare by VisitBritain data published in December 2021, which showed a loss of inbound tourism spending in the UK of

£48.6bn, with domestic tourism spending down £97.4bn.


Impact of Omicron


Omicron has had a major impact on the UK aviation recovery. Data from Visit Britain shows how inbound flight bookings to the UK made in the week 6-12 December were down 74% when compared to the same week in 2019, a fall from -48% three weeks before, due to both a fall in new

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bookings and an increase in cancellations since news of the Omicron variant broke.


Visit Britain calculated that the fall in bookings in the first three weeks of Omicron, equates to an estimated initial loss of £498 million in inbound tourism spending in the UK.


The most recent changes to restrictions, announced on 5 January, are a hugely welcome move at a critical time in the booking season for passengers. The relaxing of the testing requirements back to those in place before Omicron will provide a massive boost to those wanting to travel abroad or

2 ‘Almost 62,000 UK aviation jobs lost since start of pandemic’ | Travel Weekly


come to the UK this year. This is an important step towards learning to live alongside the virus, helping passengers and the travel sector look ahead to what will be an all-important spring and summer season for inbound tourism in the UK.

Testing and Isolation


Following welcome progress towards reopening international travel in recent months, the emergence of the Omicron variant prompted a reimposition of restrictions on UK air travel. UK airlines were deeply concerned about the proportionality of these measures, the haphazard way they were implemented and the impact they had and continue to have on our struggling sector.


Following the emergence of Omicron, the UK was the only major European market to apply a blanket pre-departure test and an arrivals PCR and isolation requirement irrespective of vaccination status. Neither the EU nor the US and Canada applied this level of restriction on a universal, rather than targeted basis (e.g., based on country specific circumstances or vaccination status, and excluding countries applying a closed border strategy, i.e., Australia). The UK was, until the announcement on 5 January, a clear outlier.3


Comparative Travel Rules in December 2021:


Figure 5 Comparative Travel Rules in December. Source: gov.uk, Randox


UK airlines fully recognise the need to take steps to address emerging variants of concern and continue to support the use of a Red list for that purpose. However, travel was again singled out for wholly disproportionate wider measures like testing that the Transport Secretary himself has acknowledged risk ‘killing off’ our sector:



3 Appendix 1: Summary of travel rules for comparable competitor markets, December 2021



Together with Manchester Airports Group, Airlines UK recently commissioned analysis from Oxera and Edge Health looking at the value of the Government’s current travel measures. This analysis concluded that continuing with travel restrictions through January would make no material contribution to reducing the spread of omicron in the UK.


Key conclusions from Oxera and Edge Health’s most recent study on 31 December 2021 were:


The ineffectiveness of the recent heightened travel measures provides a clear rationale for why we asked Government to remove these emergency measures as soon as possible, and we are grateful that this has happened. If the UK is to rebuild our aviation and tourism sectors Government must pursue a model with variants of concern that are managed by a Red list, rather than through knee- jerk testing changes impacting all travellers. This was the approach promised via the Department for Transport’s Global Travel Taskforce process.


We cannot stumble into a future situation whereby PCR testing is used to deal with future variants, and the planned review of international travel restrictions at the end of January must put in place a proportionate and robust system for dealing with variants that does not see the imposition of PCR testing every time a new variant is detected.


Experience at the UK Border


All arrivals into the UK are required to complete a Passenger Locator Form (PLF). The PLF remains a barrier to the UK again becoming an attractive destination for international travellers. The form is still much too long and complex, though progress has been made in removing unnecessary or repetitive data fields. It remains, however, only available in English, and requires a level of technical IT competency to complete.


An ongoing concern for airlines throughout this pandemic has been the complex layering of checks that carriers are required to administer, which have added significant time to the check-in/boarding


process. The process has improved over time, with greater levels of automation, an improved and less complex PLF form and the use of apps (e.g., for vaccine certification). Nonetheless, the system remains sub-optimal, and carriers today continue to face punitive fines for any passenger that arrives in the UK without the required credentials:


We understand that the PLF forms part of the track and trace system. However, the need for a PLF should not be ‘baked in’ for the longer term. Our concern is that even if the epidemiological situation improves, legacy measures remain that will make travel to and from the UK more burdensome that it need to be. For as long as the PLF is required the aim for it should be to provide a clear, automated, and single ‘go’ or ‘no go’ signal for carriers.


Simplifying the whole system and removing the punitive fine regime will serve to improve traveller confidence and stimulate inbound tourism.


Does the Tourism Recovery Plan go far enough to support the industry’s recovery from the Covid- 19 pandemic?

-  What are the biggest challenges to delivering the plan?


The emergence of the Omicron variant and re-imposed travel restrictions in the last few months has reversed progress made in re-opening the UK to international tourists. Therefore, the Tourism Recovery Plan’s target of a full return to pre-Covid levels by 2023 will now be even harder to achieve. As the Tourism Alliance has set out, achieving this goal will require the implementation of initiatives that generate £20bn of additional tourism revenue over the next two years, of which 70% must come from overseas visitors.


The Plan, however, does not include any demand driving programmes to increase inbound tourism. Without this, and without the immediate and comprehensive overhaul of the travel regime at the end of January review, including changes to restrictions detailed above, the industry’s recovery will be even slower than expected and the Government will miss its target of returning to previous levels within two years.


Many competing countries have invested significant funds to rebuild their inbound tourism, including:


A lack of investment in similar demand driving initiatives, such as funding for international marketing or the GREAT campaign, will leave the UK at a competitive disadvantage in the immediate short-term. In the longer-term the UK will have to work even harder to win back lost business and return to pre-pandemic levels of inbound tourism. Airlines UK supports calls for a new five-year visitor visa that will enhance the UK’s competitiveness versus the Schengen area, in addition to action on Air Passenger Duty (APD).