UK airports and ‘hard Brexit’ – Stansted and Liverpool most exposed

Airports with lots of EU connections and heavy reliance on non-UK low cost carriers are most exposed by Brexit. The good news is that many UK airports should benefit from increased long-haul connectivity to an expanded Heathrow. Learn more at the free Heathrow Connectivity Conference at the British-Irish Airports EXPO.

Following our recent article following Ryanair’s application for a UK AOC, decided to take a look at which of the UK’s main airports could suffer the largest impact to their networks if the UK were to lose its access to the European Single Aviation Market. The airports currently at risk of losing the most traffic are those with a heavy reliance on non-UK owned LCCs such as Ryanair or Wizz Air. This would put airports like London Stansted, Liverpool, East Midlands and London Luton in the firing line, since they have the highest dependence on EU services as a proportion of their total capacity, with significant seat numbers operated by non-UK based LCCs. Stansted and Liverpool also have among the highest proportion of domestic seats served by non-UK airlines. The detail of where the UK currently is, and where it may end up, with regards to the Single Aviation Market is explained after the following graphs. For those of you that need some light revision, the ‘Freedoms of the Air’ are also explained in full at the end.

EU traffic more important to some UK airports than others

The graph below shows the top 20 largest airports in the UK based on weekly departing seats in S17. The airports are listed in descending order, according to their available capacity. Unsurprisingly, London Heathrow topped the list with 982,717 seats, while Cardiff was the smallest airport with 23,565 seats. There was considerable variation between airports in terms of the importance of EU services as a percentage of overall capacity, when domestic and other international destinations are also included. At seven airports, seats to EU destinations accounted for 80% or more of their total capacity. These were East Midlands (90%), Leeds Bradford (87%), London Stansted (86%), London Luton (83%), Liverpool (81%), Bristol (80%) and Cardiff (80%). 

Source: OAG Schedules Analyser. Data is for week commencing 1 August 2017.

Not all of the UK’s leading airports were as dependent on EU services during S17. At seven facilities, EU links accounted for less than half of departing weekly seats. These included Jersey, which saw only 4% of its available capacity depart to EU destinations, followed by Belfast City with 12%, Aberdeen (28%), Heathrow (35%), Belfast International (43%), Southampton (43%), and Glasgow (47%). At most of these seven airports, EU services play second fiddle to domestic links. The exception is Heathrow, where EU and domestic connections are both overshadowed by capacity to other international destinations. The UK’s primary long-haul gateway saw 59% of all seats departing on non-EU international links during the week under analysis. 

Stansted, Liverpool, East Midlands and Luton most exposed for EU flights

When each of the top 20 airports’ EU connections are considered by operator, it is possible to identify their potential exposure to a Brexit backlash by highlighting the percentage of seats that could be lost if seventh freedom rights were not maintained. Belfast City would be the most at risk, with 98% of its weekly departing seats to the EU in S17 operated under seventh freedoms. However, since these EU services only amount to a small portion of the airport’s total network, the overall impact of losing these flights might not be felt as keenly as elsewhere. The airports that may be most in the firing line are Stansted, Liverpool, East Midlands and Luton, since these four facilities also witnessed some of highest proportions of seats operated under seventh freedoms to EU destinations in S17. In addition, we have already identified that these four airports each depend on EU links for a high proportion of their overall capacity. Stansted saw 73% of departing weekly seats to EU destinations operated under seventh freedom rights in S17, followed by Liverpool (48%), East Midlands (47%), and Luton (40%). A common theme running through all four airports is that they see significant operations from non-UK LCCs or ULCCs. Stansted is Ryanair’s biggest network base, with the Irish carrier accounting for the vast majority of seventh freedom flights from the airport in S17. Ryanair also serves East Midlands, Liverpool and Luton, with the latter two also playing host to non-UK Wizz Air and Blue Air operations.

Source: OAG Schedules Analyser. Data is for week commencing 1 August 2017.

The other three airports at which EU destinations account for 80% or more of departing capacity are less reliant on seventh freedom services, with 26% of EU-bound seats from Bristol and Leeds Bradford and only 3% from Cardiff, operated under those rights. In total, five airports saw 11% or less of their EU-bound flights operated under seventh freedom rights, with both Heathrow and Southampton witnessing none at all during the week under analysis, making them the least exposed to potential post-Brexit scenarios. At Heathrow this was due to many flights to EU destinations being operated by full-service flag carriers, under more traditional third and fourth freedom rights. At Southampton, Flybe is by far the dominant carrier, accounting for 85% of all services to EU destinations in S17. Since the airline is UK-based, it will operate these flights under third and fourth freedoms.

Stansted would see biggest domestic decline

The table below shows the 20 largest airports in the UK, but this time in descending order according to their departing weekly domestic capacity in S17. Edinburgh offered the most domestic seats, with 65,627 available, compared to 4,230 at Cardiff. Ninth freedom rights are used less extensively than seventh freedoms, with only 8% of the domestic seats available from the top 20 airports being flown by non-UK airlines in S17. The airport that would be most exposed in the event of the removal of ninth freedom rights on domestic services would be Stansted, since 38% of its weekly departing domestic seats in S17 were operated by Ryanair, as the Irish carrier linked London’s third airport to Edinburgh and Glasgow. As a percentage of overall capacity the next most-exposed airport would be Liverpool, since its Flybe-branded links to the Isle of Man are operated by Irish-registered Stobart Air. Ten of the top 20 airports saw no domestic services operated under ninth freedom rights.

Source: OAG Schedules Analyser. Data is for week commencing 1 August 2017.

RABA on smaller regional airports impact

Other UK airports outside of the top 20 tend to be very reliant on one, or sometimes two operators. Their potential exposure to the worst-case Brexit scenario will therefore depend on whether those carriers rely on seventh and/or ninth freedom rights to provide their services. At Exeter for example, Flybe is the dominant carrier and this contributes to the airport seeing no seventh or ninth freedom services in the week under analysis. In contrast, the schedules at Glasgow Prestwick and Bournemouth are dominated by Ryanair, leaving those facilities far more exposed. All of Prestwick’s seats were flown on seventh freedom services operated by Ryanair, while the Irish carrier also accounted for 74% of Bournemouth’s departing seats to EU destinations.

The 40-strong UK Regional and Business Airports Group (RABA) consequently has a clear interest in the outcome of the eventual Brexit deal. “The UK was at the forefront when the EU’s Single Aviation Market was created, and we managed to convince some instinctively protectionist countries to follow this lead. Many UK regions have not looked back since,” says Neil Pakey, a former air transport negotiator for the European Commission, ex-boss of Liverpool and Shannon airports, and current Chairman of RABA. “When we hear the term ‘hard Brexit’, we know in the aviation context this could lead to one current agreement being replaced in effect by 44 agreements, including an estimated 17 we agreed with other nations as part of the EU. Countries like Ireland, Netherlands and Spain would happily subscribe to continued open skies, but others may see it as an opportunity to protect their national carriers from competition, reducing access to and from their own regional airports, resulting once again in higher air fares. Picking up old bilateral agreements and dusting them down may be a starting point, but most are much more restrictive.

“Many UK regional airports, depend on seventh freedom and ninth freedom traffic,” continues Pakey. “If we don’t manage to stay in the Single Aviation Market, we will be reliant on the bilateral negotiations between the UK and the other member states to deliver these. That is difficult enough at the best of times, without trying to deliver 44 agreements all at once. We encourage all airlines operating to UK regions to communicate with the UK Civil Aviation Authority [CAA] to consider obtaining a UK Air Operator Certificate [AOC] in case of a ‘hard Brexit’ and at least then they will be considered as a third and fourth freedom carrier, which will help. We also support the Department of Transport in its efforts to prepare the ground and hope that we somehow avoid the ‘hard Brexit – no EU agreement’ scenario for aviation.”

Neil Pakey, Chairman of the 40-strong UK Regional and Business Airports Group (RABA), is spreading the word about the potential impact of Brexit on the UK’s regional airports. Pakey points out that many UK regional airports depend on seventh and ninth freedom traffic, which would come under threat if access to the Single Aviation Market is not maintained.

Afraid to ask? 3rd, 4th, 5th, 7th, 9th freedoms explained

Although the UK is likely to remain a part of the EU’s Single Aviation Market through a transition agreement until end-2020, there are still many uncertainties about what will happen to its membership of the Single Aviation Market. Everything depends on whether the UK transitions to a membership of the European Common Aviation Area (ECAA), a regime designed to extend the Single Aviation Market to include non-EU countries like Iceland and Albania, or whether a far more complex series of bilateral air services agreements between the UK and the EU are implemented, with many confining disadvantages for leading airlines and many UK airports.

An integral part of any deal is an understanding of some of the old-fashioned ‘Freedoms of the Air’ which govern international traffic rights but which have not been used in most of Europe for almost 30 years and would have to be used again to construct a new, unique UK-ECAA agreement:

  • Third freedom rights – the right to fly from one’s home country to a foreign state;
  • Fourth freedom rights – the right to fly from a foreign state back to one’s home country;
  • Fifth freedom rights – the right to fly between points in two foreign countries outside of one’s home market, provided the full itinerary includes a link to one’s home country;
  • Seventh freedom rights – the right to fly between two foreign countries while not offering flights to one’s own country;
  • Ninth freedom rights – the right to fly within a foreign country without continuing to one’s own country.

The EU Single Aviation Market means that all EU airlines can utilise any of these freedoms. But while it seems conventional for the UK to maintain third and fourth freedoms between it and other ECAA states after the expected transition to end-2020, if seventh and ninth freedom rights are not maintained, non-UK operators will no longer automatically be able to operate UK domestic services, or links between the UK and ECAA destinations outside of their home countries after 2020.

This analysis above looked at which of the UK’s top 20 airports could be most exposed if seventh and ninth freedom capacity is lost. Fifth freedom rights were not considered. The review is not comprehensive, but gives a strong indicator of which airports could be most affected by a “hardish” Brexit in aviation. It is based on a number of assumptions. Firstly, the analysis of which airlines are operating under which freedom rights only looks at UK domestic services and services to the other 27 EU member states. Services to other qualifying states in the ECAA would also be affected. The schedule data used only covers one week from peak S17; the week commencing 1 August. The analysis is meant to provide a moment in time snapshot and does not account for the countless variables that could develop between now and the UK’s formal exit from the EU, including any subsequent or potential UK AOC applications made by non-UK operators.

Liverpool witnessed one of the highest proportions of seats on EU services departing under seventh freedom rights, along with London Stansted, East Midlands and London Luton. The airport plays host to a number of non-UK-based LCCs or ULCCs including Blue Air, Ryanair and Wizz Air. These carriers provided nearly half of all weekly seats from Liverpool to EU destinations in S17, operating under seventh freedom rights.

The specific freedom rights were identified according to the home country of the operating airline where possible. Flights performed by third-party carriers on behalf of leisure operators were allocated to the leisure airline rather than the wet- or dry-lease provider. However, flights performed by franchisees or ‘white-label’ operators were allocated to the specific operating entity, since these arrangements tend to be longer-term in nature and may need some adjustments if seventh or ninth freedom rights are removed.

Another assumption was to use both Denmark and Sweden as the home market for SAS. It should be noted that as its third home market of Norway is not in the EU it was not necessary to account for this when allocating freedom rights by operating airline in this analysis. Jersey is included because services between the island and the UK are considered domestic, despite the fact that Jersey is a self-governing crown dependency. The Channel Island currently operates an open skies policy with countries in Europe, but this is independent of arrangements between the UK and EU, and it remains to be seen whether it will be impacted in the aftermath of Brexit. It should be noted that routes to and from Gibraltar have not been considered.

Remember this…it might never happen

This analysis is an effective way to highlight the potential vulnerability of some UK airports, if the British government does not find a way to maintain Single Aviation Market access, but the reality is unlikely to be as bleak as the picture painted here. Both Ryanair and Wizz Air have already taken steps to gain UK AOCs which would allow them to operate British-registered aircraft under third of fourth freedom rights. It is also not beyond the realms of possibility that the respective officials in the UK and the other 27 member states of the EU could come to an understanding that allows the status quo to prevail.

London Stansted would currently top the list as the most at risk UK airport if access to Europe’s Single Aviation Market is lost. A large proportion of its destinations are in the EU and nearly three quarters of capacity on these services are operated under seventh freedom rights, which includes the London airport’s link to Oradea in Romania which launched with Ryanair last September.


  1. peter blanchard says:

    So does that mean airline fares would increase between, for example, U.K. Stansted and EU destinations?

    • Nick Preston says:

      Hi Peter, in the worst case scenario this is possible, since competition would be reduced, but as the article points out, carriers such as Ryanair are already taking steps to gain UK AOCs. It remains to be seen how far this would go in terms of offsetting the potential challenges of Brexit, since ownership regulations could also come into play.

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