5 Impacts of aviation policy The terms of reference require the Commission to report on ‘the impact of international and domestic aviation policy on the Victorian tourism industry and the broader economy, and any implications for policy positions that the Victorian Government might adopt in its own right or present to the Commonwealth Government’. A number of participants considered that aviation policy will have an important influence on the future growth of Victoria’s tourism industry. An important issue is the need to ensure Australia’s international air services agreements are not impeding airlines meeting the anticipated growth in international visitors from countries such as China, India, Indonesia and other growing markets in the Asia-Pacific region. This chapter considers how aviation policy affects the number of international visitors to Victoria and the extent to which the Victorian Government can pursue or advocate for changes that would benefit the Victorian tourism industry. Aviation policy covers international, domestic and regional aviation. International policy includes issues that are largely outside the Victorian Government’s control such as the arrangements that govern airlines’ access to international passenger markets. Domestic aviation policy covers issues such as Government investment in and regulation of airports as well as safety and security regulations applying to international and domestic airlines operating in Australia. In both of these areas, the Victorian Government’s role is largely limited to making representations to the Commonwealth Government. Recognising the broad scope of aviation policy and the Victorian Government’s limited direct role, the Commission has focused on areas of potential constraints raised by participants, including: the capacity of airlines to fly to Australia, and to Melbourne in particular, especially in markets that are forecast to experience rapid growth (section 5.3) the development of additional airport infrastructure capacity in Melbourne (section 5.4) other issues relating to regional airport pricing and policy (section 5.5). Before examining these issues in detail, the next two sections discuss the importance of aviation to the Victorian tourism industry and outline key aspects of the aviation policy framework. IMPACTS OF AVIATION POLICY 125 5.1 Importance of aviation to Victoria’s tourism industry The capacity to meet the expected growth in international visitors to Victoria is dependent on the availability of adequate airport infrastructure: 99 per cent of inbound tourists and 65 per cent of interstate tourists arrive by air (DITRDLG 2009) around 5.5 million international passengers travelled through Melbourne airport in 2009–10, representing one-fifth of all international passenger traffic through Australian airports (table 5.1) passenger movements through Melbourne airport have been growing more rapidly than Sydney and this trend is expected to continue, with movements forecast to rise to 15.6 million by 2029 (table 5.1) most of the forecast growth in passenger movements is predicted to come from China and other emerging Asian markets (TRA 2010a, p. 18). Table 5.1 International passenger traffic through Australian international airports Airport Year ended June 2010 (million) Share of total (%) Forecast annual average growth rate (per cent)a Sydney 11.1 43.4 4.7 Melbourne (excl. Avalon) 5.5 21.4 5.7 Brisbane 4.2 16.2 6.0 Perth 3.0 11.6 5.8 Gold Coast 0.73 2.8 - Adelaide 0.52 2.0 4.9 Cairns 0.43 1.7 - Darwin 0.21 0.8 4.6 a Annual average growth rate 2008-09 to 2029-30. Source: DITRDLG 2010, p. 11, BITRE 2010. Victoria is considered to be well served by airport capacity and has a number of advantages as a destination compared to other major gateways. Unlike Sydney airport, Melbourne airport does not have a curfew, has access to additional runway capacity and currently has relatively low airport fees and charges. A further advantage is that a substantial amount of general aviation traffic passes through Essendon airport which allows a greater proportion of Melbourne 126 UNLOCKING VICTORIAN TOURISM airport’s capacity to be directed towards scheduled domestic and international passenger flights. Victoria’s second airport is Avalon which provides domestic aviation services to around 1 million passengers each year; a figure that is expected to grow. Low cost carriers such as Jetstar and Tiger Airways operate domestic flights from Avalon, with international flights being a future priority for the airport (see below). Victoria has a number of regional airports catering mostly to business and local travellers. Essendon and Moorabbin airports together with regional airports such as Mildura, Portland and Hamilton provide domestic and regional airline services (table 5.2). Mildura airport is the busiest regional airport in Victoria with Qantas, Virgin Blue, Regional Express and Sharp Airlines providing scheduled passenger services (Mildura airport 2010). Table 5.2 Airport traffic at selected Victorian airports 200809 Airport Inbound passengers – major domestic airlines Inbound passengers – regional airlines Total passengers – inbound and outbound passengers Avalon Not publicly available Not publicly available Not publicly available Essendon 0 7 394 14 545 Mildura 16 041 78 071 187 720 Moorabbin 0 6 347 12 684 Portland 0 5 740 11 612 Source: BITRE 2009. 5.2 Importance of international aviation policy International aviation is regulated, amongst other things, by a series of government to government (bilateral) air service agreements that determine the levels of market access for countries’ respective airlines. The underlying regulatory framework was established by the 1944 Convention on International Civil Aviation (the Chicago Convention), and is given effect in Australia by the Air Navigation Act 1920 (Cth). Australia’s international aviation policy goal is: An open and competitive international aviation market that serves the national interest by benefiting tourism, trade and consumers, allows Australian and overseas airlines to expand, and maintains a vibrant Australian-based aviation industry. (DITRDLG 2009, p. 40) IMPACTS OF AVIATION POLICY 127 Australia currently has 68 bilateral air service agreements. These agreements are negotiated with other countries by the Australian Government and, in general, set out the number of seats that the airlines of the two countries may provide, the cities they may serve in each country and the rights to operate to third countries. These agreements typically also include provisions on matters such as airline ownership and control, competition law, safety and security (DITRDLG 2008, p. 99). Once an agreement is finalised, the capacity available to individual Australian carriers on these routes is allocated by the Australian Government’s International Air Services Commission. The issue for this inquiry is the current and future capacity within ASA’s and how the capacity for international flights by Australian and foreign airlines is allocated between Australian cities. While the Victorian Government does not have any direct role in the negotiation of these bilateral air service agreements, it has several avenues to influence the Commonwealth Government’s position, the most important of which is through Victoria’s membership of the Tourism Access Working Group (TAWG) (previously the National Tourism and Aviation Advisory Committee (NTAAC). 5.3 Restrictions on international aviation capacity Some participants considered that the system of negotiating international air services agreements has the potential to impede the future development of Victoria’s tourism industry. The specific concerns were that: (1) the international system of bilateral air service agreements harms Victoria’s interests by limiting capacity on some key routes (2) that even where sufficient capacity exists in Australia’s air services agreements, airlines prefer to operate flights through Sydney rather than flying direct to Melbourne (3) the process of negotiating these agreements is cumbersome, slow and non-transparent so that capacity may not be able to respond rapidly enough to increases in demand from particular countries. 5.3.1 Participants’ views The Victorian Tourism Industry Council (VTIC), for example, considered that the international system of negotiating bilateral air service agreements has the potential to harm Victoria’s interests: The existing international system of bilateral Air Service Agreements (ASA) is fundamentally anti-competitive and inefficient, and harmful to the competitiveness of air service users. (sub. 40, p. 52) 128 UNLOCKING VICTORIAN TOURISM Likewise, Tourism Victoria argued that: … growth in services [to Melbourne] is constrained by the global regulatory regime governing air access. Progress towards substantive liberalisation, particularly in multilateral fora, remains slow. Bilateral agreements provide some scope for progressive liberalisation, but with a focus on bartering commercial air services rights. (sub. 48, p. 7) According to the City of Melbourne, a lack of direct inbound flights to Melbourne can increase travel costs and travel time for international visitors to Victoria. It submitted that despite experiencing recent rapid growth in international passenger numbers: Passenger demand, however, continues to outstrip supply on key international routes, with more than 600 000 people each year still flying between Melbourne and Sydney solely to connect with international flights. (sub. 53, p. 12) The Tourism and Transport Forum (TTF) also suggested that there is a lack of capacity on international flights into Melbourne, but that this mainly reflects airlines’ decisions to operate direct flights to Sydney: Victoria and Melbourne have a lower share of international airline seat capacity to Australia than their share of origin/destination international airline traffic. This reflects the historic bias of international airlines to first establish services to Sydney, as well as the preference by Qantas for first servicing international destinations from their Sydney base (sub. 44, p. 50) The TTF provided data on capacity and visitation (table 5.3) suggesting that around 30 per cent of international visitors to Victoria enter Australia through an interstate gateway.1 This information is not definitive about whether this pattern is determined by demand or by constraints on the number of flights to Melbourne under air services agreements. TTF considered that Melbourne’s share of inbound flights to Australia will increase in future due to the growth in international services offered by Jetstar and as Qantas seeks to regain market share into and out of Victoria (sub. 44, p. 50). 1 IMPACTS OF AVIATION POLICY 129 Table 5.3 Capacity, arrivals and departures for Victoria, New South Wales and Queensland Victoria (per cent) New South Wales (per cent) Queensland a (per cent) Share of seats to Australia (inbound) 20 44 21 Share of international visitorsb 29 52 38 Share of outbound travellers 25 35 18 a Queensland includes Brisbane, Gold Coast and Cairns. b International visitors commonly visit more than one state/territory, with the average being 1.5 states/territories per trip. Sources: Adapted from TTF (sub. 44, p. 50), based on Tourism Research Australia, International Visitor Survey and National Visitor Survey; Airport Coordination Australia for international airline seats. 5.3.2 Is supply limited by air services agreements? To examine whether there are overall capacity constraints, the Commission has compared for major international tourism markets, current air service agreements and the capacity limits under these agreements and the extent to which this capacity is being used by foreign airlines flying to Australia. Airline capacity utilisation for several important tourism export markets is shown in figure 5.1. Figure 5.1 Capacity use by selected country airlines 100 Capacity use (%) 75 50 25 0 China Hong Indonesia Malaysia Vietnam Kong Korea Japan United Kingdom India United States New Singapore Zealand Note: New Zealand, Singapore, the United Kingdom, and the United States have open capacity entitlements. No capacity is currently being utilised under the Indian air service agreements. Source: Tourism Access Working Group, Mapping Tourism Access Priorities – Stage One. 130 UNLOCKING VICTORIAN TOURISM The capacity utilisation data presented above suggests that: There are no capacity limits under Australia’s air services agreements with several countries that are important sources of visitors to Victoria (the United Kingdom, the United States, New Zealand and Singapore). Capacity limits under current air service agreements are now evident for several inbound tourism markets including China, Hong Kong, Indonesia Malaysia and Vietnam. This suggests that while Australia has ‘extremely liberalised aviation regulations’ (sub. 42, p. 6) this does not appear to extend to all inbound tourism markets, especially those that are likely to play an important role in Australia’s future tourism export growth. In reviewing available capacity under Australia’s air services agreements and arrangements the Commission understands that airlines have the flexibility to use available capacity on inbound flights to Melbourne or other major gateways such as Sydney, Brisbane and Perth. This suggests that in the majority of cases commercial decisions rather than regulatory controls determine the likely entry point for tourists. The 10 Year Tourism and Events Industry Strategy (DIIRD 2006) identified actions to encourage airlines to increase the number of inbound flights to Melbourne from destinations such as China, the United Kingdom, the United States and India. These actions focused on influencing the commercial decisions of airlines, rather than the Australian Government negotiating position with other countries. The Strategy, for example, identified opportunities to attract more direct flights to Victoria by developing ‘Network Development Agreements’ with high value carriers, and the goal of working with Jetstar International to boost inbound passenger numbers from strategic destinations (DIIRD 2006, p. 23). A subsequent progress report indicated that new airlines, including AirAsia X, Etihad Airways, Qatar Airways, V Australia and Korean Air had established direct flights to Melbourne. It also reported that additional capacity had been added from carriers including Cathay Pacific, Emirates, Singapore Airlines, Air China and China Southern. The progress report also identified further actions aimed at influencing airlines commercial decisions such as developing a new strategy to attract direct air services from key inbound markets, building Melbourne as a connection hub between other popular short haul tourist destinations and population centres, and strengthening research, data collection and analysis capabilities to support the development of aviation strategy (Tourism Victoria nd, p. 16). IMPACTS OF AVIATION POLICY 131 5.3.3 Future regulatory constraints? The available evidence suggests that the current pattern of direct flights to Melbourne reflects the commercial decisions of individual airlines. It also suggests that future growth in demand, especially from markets such as China, Indonesia and Malaysia could be constrained by current air service agreements. For example Chinese and Indonesian airlines are utilising close to 100 per cent of their current seat capacity entitlements (figure 5.1), suggesting there may shortly be an excess demand for seats into Australia. A failure to expand the limits on capacity in air services agreements in line with growth in demand could have adverse consequences for the Victorian tourism industry. According to the Tourism and Transport Forum (TTF): Victoria has a strong interest in the Australian Government negotiating bilateral agreements with seat capacity set well ahead of current traffic levels. If the bilaterals offered limited unutilized seat capacity, Melbourne’s opportunities for growth in seat capacity will be severely affected. (sub. 44, p. 50) Several participants therefore supported further liberalisation of international aviation markets. VTIC submitted that: In order to enhance tourism industry competitiveness, there must be further liberalisation of international air access arrangements. Priority must be given to increasing direct inbound services to Melbourne, including low-cost carrier services. Priority should be given to key routes, high-yield inbound destinations, and growth areas including China and India. In addition, Victoria must support policies to increase direct flights into all Australian airports, and recognise the significant benefits of the tourism industry nationally. (sub. 40, p. 52) The Commission understands the Australian Government is likely to continue air services negotiations with China in 2011 aimed at concluding an ‘open skies’ agreement, removing most if not all of the existing limitations on Australian and Chinese airlines operating between the two countries. There are two additional ways of responding to potential capacity constraints: (4) The Australian Government could unilaterally open up its skies with those countries where there is excess demand for seats into Australia. (5) The Australian Government could designate Avalon airport as a regional international gateway, thereby effectively allowing international carriers to operate an unlimited number of flights to and from Avalon airport (section 5.4.1). The Australian Government’s position is that it will seek to enter into ‘open skies’ agreements on a bilateral basis, where possible, and otherwise ensure that capacity available to foreign and Australian airlines under the bilateral agreements 132 UNLOCKING VICTORIAN TOURISM grows ahead of demand. This position was set out in a recent White Paper on aviation policy in which the Australian Government stated that it: … will continue to pursue liberalisation of the international aviation market, including ‘open skies’ style agreements, where these are assessed to be in the national interest. In all cases the Australian Government will seek to ensure capacity available under our bilateral agreements remains ahead of demand so that airlines are free to make commercial decisions about the frequency and types of services they operate. Such an approach provides airlines with the regulatory certainty to enable them to commit to long-term growth plans in the Australian market. (DITRDLG 2009, p. 41) Some participants supported the current policy stance of the Australian Government. Qantas stated that: The Federal Government’s policy on air services liberalisation strikes an important balance in that it seeks to promote further liberalisation of air services whilst also recognising the need to support a strong local aviation industry. (sub. 42, p. 5) Qantas also suggested that any decision to move from the current policy stance of the Australian Government would require careful consideration of a number of matters including: Australia already has extremely liberalised aviation regulations foreign carriers currently enjoy a high level of access to the Australian market there is surplus capacity for foreign airlines in major [origin/destination] markets that is not being utilised Qantas and Jetstar are major contributors of inbound tourism into Australia and Victoria. (sub. 42, p. 5-6) The Commission’s view With forecast growth in the number of tourists wishing to travel to Australia over the coming years it is important that there is sufficient unutilised capacity in the air service agreements to ensure that demand is not unnecessarily constrained–which would negatively impact on the tourism industry. Capacity constraints may lead to higher airfares than would otherwise be the case, and can be viewed as a ‘tax’ on the export of Australian tourism products. Inbound tourism may be deterred as a result, leading to net costs to the Australian tourism sector, from reduced growth in international tourism. A simple analysis of forecast Victorian tourist numbers and total inbound economic value (TIEV) illustrates that a small reduction (for example 5 per cent) in tourist numbers from IMPACTS OF AVIATION POLICY 133 China and Indonesia over the next 5 years may lead to large reductions in income for the Victorian economy, in the order of $500 million2. Recent forecasts by the Tourism Forecasting Committee suggest that China, India and Indonesia will be significant sources of growth in inbound tourism to Australia in the coming decade, with more modest growth also coming from a number of other regions and countries (figure 5.2). Figure 5.2 Forecast growth rates of visitor arrivals to Australia- selected markets 10 Forecast Annual Growth Rate (%) 9 8 7 6 5 4 3 2 1 0 India China Indo nesia Thailand M alaysia So uth Singapo re United Ko rea States Ho ng Ko ng Taiwan Germany New United Zealand Kingdo m Japan Growth rate 2009-2020 Source: TRA 2010a, p. 19 The information available to the Commission suggests that there are capacity constraints within several existing agreements (China, Hong Kong, Indonesia and Malaysia). Given future forecast tourism growth, particularly with respect to China and Indonesia, it is important that additional capacity is provided for these markets to ensure that inbound tourism is not unnecessarily constrained. Current Australian Government policy is to attempt to negotiate extra capacity with China ahead of this demand. Clearly, an open skies agreement with China would remove any regulatory impediment to airlines adding the necessary capacity to meet future demand growth. For this to happen, however, the This estimate has been developed for illustrative purposes only and is based on (International visitor forecast (Vic.) x TIEV) for 2011 to 2015. For each year this amount has been reduced by 5 per cent to arrive at a total for China and Indonesia. Data source Tourism Forecasting Committee 2010a, pp. 26-29 and Tourism Victoria 2010b. 2 134 UNLOCKING VICTORIAN TOURISM Chinese Government must be willing to enter into such an agreement with Australia. The Victorian Government can play a constructive role in this process by arguing for an open skies agreement with China and other countries. Recognising that current Australian Government policy seeks to consider, among other things, the impact of such agreements on the domestic aviation industry, the Victorian Government should also argue for transparency in the way that the Australian Government evaluates the industry impacts of air service agreements (particularly on tourism) in arriving at an assessment of the national interest. Draft recommendation 5.1 The Victorian Government seek agreement from the Commonwealth Government that, in the lead-up to future air service negotiations, the Commonwealth would develop estimates of the potential costs and benefits of potential outcomes and test these in discussions with stakeholders (including state governments) through existing consultation mechanisms. This would ensure that negotiations for more liberalised air services are driven by a full understanding of the relative net benefits of preferred negotiated outcomes. 5.4 Other impediments to the development of additional airport capacity in Victoria Ensuring that the system of international air services agreements is flexible enough to accommodate current and future demand for travel to Victoria is clearly important for the future of Victoria’s tourism industry. But it is also important that the infrastructure to support interstate and international visitation is provided efficiently and competitively. As noted, Melbourne airport is the principal gateway to Victoria for interstate and international visitors. Avalon airport has emerged recently as the second domestic airport. While participants considered that Victoria is well placed to accommodate growth in international and domestic tourism there are some issues requiring attention. Charges for parking at Melbourne airport were identified as a negative factor by some participants. VTIC, for example, argued that measures are needed to encourage greater competition in the provision of car parking facilities at airports (sub. 40, p. 9). While this is clearly an important issue, the Commission notes that the Productivity Commission (Cwlth) has recently commenced an inquiry into the economic regulation of airport services which includes a review of current arrangements for monitoring airport car parking charges. IMPACTS OF AVIATION POLICY 135 Participants also considered that there is scope to build on Victoria’s strengths by investing in additional airport infrastructure. While there were a number of suggestions for public and private investment in areas such as transport and air traffic control systems (see chapter 6), the focus in this section is on two potential regulatory issues: (1) The process of obtaining approval for Avalon to become a second international airport in Victoria. (2) The need for efficient planning controls to address land-use conflicts in proximity to the airport. In addition the TTF also raised a number of Commonwealth and international policy issues that it considers impact on the sector, including: fast tracking implementation of Required Navigation Performance (RNP) at Melbourne Airport and other Australian airports endorsing the ICAO resolution calling for a global aviation industry solution to deliver emission reductions rather than inclusion of aviation in individual countries approaches to pricing carbon incentives for airlines to introduce more fuel efficient aircraft through changes to depreciation through the 2011 review of Australia’s taxation system providing a concessional excise tax treatment for second generation bio-fuel for airline use in aircraft on domestic routes, similar to the approach applied to the taxing of Ethanol for use in motor vehicles arguing against other governments introducing aviation specific carbon taxation, as this will particularly impact Australia as a commonly long haul destination establishing a research and development fund to develop second generation bio-fuels in partnership with the major Australian airlines and Boeing (sub. 44, p. 8). The issues raised by TTF are part of the much broader issue of ‘climate change’ and potential solutions that are specific to the aviation sector. Given this broader perspective, which raises a number of Commonwealth and international policy issues, the Commission considers that these issues are not in the scope of its current inquiry. 5.4.1 International airport status for Avalon airport Several participants supported measures that would allow Avalon airport to cater for the expected growth in international visitors. Victoria University, for example, stated that: 136 UNLOCKING VICTORIAN TOURISM With regard to aviation policy, we support the expansion of airport capacity to accommodate the growth in international tourism across business, leisure and [Visiting Friends and Relatives] markets. We also believe that the granting of ‘Regional Package’ status to Avalon airport is pivotal to increasing capacity for international airlines in accommodating this growth. This will provide improved access to regional areas increasingly sought by international visitors. Avalon airport is strategically located as a gateway to the Great Ocean Road and other regions that are linked through regional touring routes such as the Great Southern Touring Route. (sub. 51, p. 6) Tourism Victoria noted that in the past the Victorian Government has argued for: … the Commonwealth [Government] to support the development of Avalon as an international airport by identifying it as a ‘Regional Package’ airport. This outcome would place Avalon on equal footing with other gateways which have internationally capable regional airports which complement capital city airports. (sub. 48, p. 8) The TTF was, however, sceptical about the benefits of expanding capacity at Avalon as a means for overcoming any barriers arising from restrictive bilateral air service agreements: Victoria’s second airport at Avalon could gain international services if it is classed as a regional airport and also if there is a shortage of negotiated capacity in bilateral agreements. However, Victoria is better served as a State by having Australia negotiate seat capacity well ahead of demand rather than a third best alternative of hoping that tight capacity will encourage international carriers to use Avalon as a regional airport (if the Australian Government allows Avalon as a regional airport). In reality the regional package has not led to significant new international airline services to ‘regional’ airports as international carriers much prefer to go to the major airports like Melbourne which have existing large traffic flow. (sub. 44, p. 51) VTIC also supported Avalon airport becoming Victoria’s second international airport (sub. 40, p. 52). The Commission’s view Avalon is currently a domestic only airport, with Jetstar, Tiger Airways and Sharp Airlines operating services to destinations including Sydney, Brisbane, Gold Coast, Adelaide, Perth, Alice Springs, Mackay, and Portland. The Australian Government offers foreign airlines unlimited access to airports other than Brisbane, Sydney, Melbourne and Perth. This policy, often referred to as the ‘regional package’ is designed to spread the benefits of international tourism more broadly across Australia, and in particular to regional centres (DITRDLG 2008, p. 8). The designation of Avalon as a regional international IMPACTS OF AVIATION POLICY 137 airport would allow foreign airlines to access Victoria without being constrained by capacity agreements with Australia. The Commission acknowledges a number of benefits may flow from Avalon being granted ‘regional package’ status, including: Greater access to those markets where air service agreements are constraining tourism access to Australia (e.g. China) Increased tourism and airport related activity in the region Competitive pressure on Melbourne airport (landing, car parking fees etc) and greater choice for consumers Reduced risk of airport capacity in Victoria being constrained in the future. These benefits significantly rely on the extent to which international airlines seriously consider choosing Avalon airport over Melbourne airport. Some organisations, such as the TTF, are sceptical about the level of demand from international airlines to land at Avalon. The potential gains would also be affected if ‘open sky’ arrangements were negotiated with China and other countries where demand is constrained by current capacity restrictions. While there may be benefits to Avalon being granted ‘regional package’ status there are also potentially significant costs of upgrading Avalon to accommodate international traffic including: costs of planning and other approval processes private and public infrastructure upgrades (for example runways, refuelling facilities, terminals, roads, and transport facilities) provision of Commonwealth Government required security, customs and other services. There is a range of benefits and costs that may be incurred through the process of Avalon becoming an international airport and being granted ‘regional package’ status. These costs and benefits would need to be explored by the private sector to ensure that expansion activities to cater for international air services are commercially viable. Following the development of a business case and preparedness of a private sector operator to invest in required airport upgrades, the Victorian Government should again advocate for regional status for Avalon. 5.4.2 Planning controls Melbourne airport has a curfew-free status that ‘plays a vital role in boosting airline services in the state, including passenger and freight services’ (sub. 40 p. 52), and also provides Melbourne Airport with a competitive advantage relative to Sydney. 138 UNLOCKING VICTORIAN TOURISM Several submissions pointed to the importance of ensuring that Melbourne retains this advantage and has the ability to expand its capacity as demand for services increase. VTIC commented that: There should be coordination between the leased federal airports and privatised airports, to ensure the long-term requirements for infrastructure are met, including the provision of safe and reliable services. There must be consultation with state and local authorities and the community to ensure a coordinated and considerate approach to investment and development. (sub. 40, p. 52) Qantas also identified the importance of long-term and coordinated planning for the expansion of Melbourne airport and supported recent Australian Government measures to implement such an approach (sub. 42, p. 3). In relation to State Governments, Qantas noted: It is essential that State Governments adopt a similar collaborative approach to ensure that critical economic and tourism benefits provided by aviation and airports are not undermined by inappropriate developments in and around airports. This is an area where the Victorian Government could take a leading role in Australia in ensuring the benefits of Melbourne airport’s current curfew free status is not threatened by residential creep towards the airport or other inappropriate development. (sub. 42, p. 4) The Commission’s view In the past, recognition of the importance of Melbourne Airport’s competitive advantages and the interaction of planning regulation has been a feature of State planning policy. Melbourne Airport, as the State’s premier, curfew free airport and the country’s second international gateway, is protected under State planning legislation, through the Melbourne Airport Environs Strategy Plan and Melbourne Airport Environs Overlay planning scheme provisions. These provisions provide certainty to land use and development around the airport. (Victorian Government 2009, p. 4) The National Aviation White Paper also established a framework to support better-integrated planning outcomes, including through the establishment of: … planning coordination forums for each primary capital city airport to enable airports and governments to more effectively engage on strategic planning issues. (DITRDLG 2009, p. 170) The Commission acknowledges that the curfew-free status of Melbourne airport and its ability to invest in additional capacity is an important issue for the tourism and broader Victorian economy, and for the communities close to the airport. At this stage, in the absence of submissions indicating a significant issue, the Commission is of the view that airport planning related issues are sufficiently IMPACTS OF AVIATION POLICY 139 addressed by current and future initiatives outlined in the National Aviation White Paper, together with current State planning regulations. 5.5 Other issues raised Several other issues were raised by stakeholders relating to: regional airport pricing flights over national parks regional aviation policy. 5.5.1 Regional airport pricing The majority of regional airports are operated by or on behalf of local government and some are not obligated or required to provide transparency in pricing. Qantas suggested that: Mildura airport has recently increased its passenger charges without any reasonable and transparent explanation having been provided to justify the increase. The increase does not appear to be linked to investment in the airport or improvements in infrastructure that deliver benefits to the travelling public. (sub. 42, p. 4) The Commission acknowledges that airport pricing is an important issue, particularly for airline operators. Unjustified or excessive additional airport charges can increase the cost of travel and hamper the growth of both business and tourism markets. Unreasonable increases in charges imposed by regional airport operators can lead to fare increases and lower passenger volumes in price sensitive market segments. However, the Commission has not been presented with sufficient evidence to suggest that the issue between Qantas and Mildura airport is likely to significantly impact on the broader Victorian tourism market. Information request 5.1 Is the issue of airport pricing (fees and charges levied on airline operators) at Mildura airport likely to significantly impact on tourism? If so, what evidence is available to support this view? 5.5.2 Flights over national parks Current regulations, made under s. 48 of the National Parks Act 1975 prohibit the landing of a helicopter or other aircraft in a park except in an emergency or if a permit has been granted. Mansfield Council argued that permits are not provided and appropriately licensed helicopter landings should be permitted in the Alpine National Park. Helicopter operators cannot obtain Parks Victoria permission to land within the Alpine National Park unless it is an emergency, engaged in management 140 UNLOCKING VICTORIAN TOURISM operations (i.e. fire suppression, spraying weeds, feral animal control, etc) or a one-off special event e.g. media access. Permission for each and every request is handed down from the Secretary of National Parks. Council argues that appropriately licensed helicopter landings should be permitted to support high yield product development providing low impact ease and speed of access, transport logistics and supply transfer. (sub. 47, p. 10) Access to national parks by commercial operators, which would include helicopter operations, is considered more broadly in section 4.1 (restrictions on private development in national parks) of this draft report. Draft recommendation 4.1 proposes a response to these issues. 5.5.3 Regional aviation Victoria has around 200 airports and airstrips including regional airports such as Portland, Mildura, Hamilton, Swan Hill, Sale, Bairnsdale, Yarrawonga, Warrnambool, Geelong, Shepparton, Albury-Wodonga, Mt Hotham, Ballarat and Bendigo. As previously mentioned, regional airports are generally operated by or on behalf of local government. A Victorian infrastructure audit conducted in 2008 reported that: Many local councils are faced with high ongoing maintenance costs for their airport facilities and, with the exception of high revenue-generating airports such as Albury-Wodonga and Mildura, they face significant annual operating losses at these facilities. As Victoria is compact in comparison with other States, with a higher population density and well developed road and rail infrastructure, regional airports face difficulties competing for freight and passenger traffic. The Victorian Government is investing in upgrades to regional airports via the Regional Infrastructure Development Fund (RDIF, which has a $20 million subprogram for capital works projects delivered in partnership with regional councils. (Victorian Government 2008, p. 50) While some funding is available for capital works projects, East Gippsland Shire argued environmental regulations were impeding airport expansion: Vegetation management at Mallacoota Aerodrome, which is surrounded by State Forest and a National Park, has become an issue with large areas of trees growing into its Obstacle Limitation Surfaces…This has resulted in the shortening of one of the two runways. (sub. 11, p. 7) The lack of emphasis on direct air services was also raised by East Gippsland Shire: Current Victorian Government transport policy is geared towards improvement in surface travel with little emphasis on direct air services. In May 2007 the Shire IMPACTS OF AVIATION POLICY 141 engaged qualified consultants to undertake a report into the feasibility of an air service for the East Gippsland region. The report found a number of issues currently inhibiting the likelihood of an air service being viable, including the lack of a Victorian regional aviation policy. (sub. 11, p. 8) Central Goldfields Shire stated that: Small Regional airports and aerodromes offer some underdeveloped potential for tourism. Connectivity with other transport services is critical. (sub. 30, p. 3) The VTIC advocated for a more integrated approach to aviation policy in Victoria, based on a view that regional aviation is important to encourage dispersal and the further developments of Victoria’s tourism industry: In order to achieve industry growth, there needs to be a coordinated approach to aviation policy, which gives appropriate consideration to the long-term vision for tourism development. It is important that regulations affecting air transport encourage industry growth by providing more direct international flights to Melbourne, as well as support greater regional air access. [And] Any aviation policies must take into account broader tourism objectives. There is a need for greater alignment between aviation, transportation and tourism policies. (sub. 40, pp. 51-52) The Commission notes that the purpose of the Transport Integration Act 2010(Vic) is to create a new framework for the provision of an integrated and sustainable transport system3 in Victoria. The Act provides for integrated land use and transport planning decision making which is a key component of developing planned tourism, including access to tourism products. It is unclear to what extent a specific regional aviation policy would assist in the dispersal of tourists throughout regional areas, particularly given the geographic characteristics of Victoria, and the availability of alternative transport modes. Based on the information received, the Commission does not consider it likely that regulatory impediments are constraining airport development in regional areas. It may be that commercial considerations are the key obstacle to further developing regional airports and attracting scheduled flights. In considering future funding for further development of regional airports the Victorian Government should carefully evaluate the commercial costs and benefits and also any broader benefits and costs to the local community. The Transport Integration Act 2010 defines the transport system as all the components which make up the system for the movement of persons and goods, including airports. 3 142 UNLOCKING VICTORIAN TOURISM