Objections to Inspector's Report on Rushmoor Local Plan (Farnborough Airfield)

Aircraft Pollution

The Inspector appears to believe that pollution is not a problem and can be dismissed as insignificant. He cites DETR as his frame of reference. DETR (and its predecessor Department of Transport) has a vested interest in the promotion of transport schemes, it also has a poor track record on pollution and environmental sustainability. It was DETR that promoted the Newbury bypass (which has been a failure even on the DETR narrowly defined criteria). For decades DETR peddled a flawed model on transport and traffic modelling.

There is a growing body of evidence on the problems caused by aircraft pollution. Aircraft are a significant and rapidly growing contributor to greenhouse gases due to the fact that the emissions are at high altitude where they have maximum effect.

Per passenger mile aircraft are the most polluting form of transport. The situation is even worse for air freight transport. Executive transport, with its low occupancy, will be at the extreme end of the pollution scale.

The EU has proposed tighter controls (currently non-existent) on aircraft emissions due to the growing recognition of the problem. The UN Intergovernmental Panel on Climate Change has also called for tighter controls on aircraft emissions. International Civil Aviation Organisation is working hard to block any controls on aircraft emissions or noise.

The UK is a signatory to the Kyoto protocol on greenhouse gas emissions. Any increase in flying at Farnborough would be contrary to the UK's Kyoto commitment on the reduction of greenhouse gas emissions.

The pollution impact of flights into and out of Farnborough should include the entire flight length.

Within the local area the pollution associated with each flight should include all the associated infrastructure - transport to service the plane, crews, staff transport, freight transport, associated warehousing facilities etc. In addition there are fuel spillages and run-offs (kerosene is regularly dumped over Farnborough), de-icing fluids (runways and planes).

Variable Landing Fees

One way to reduce aviation pollution into Farnborough, whatever the level of flying (and the ideal is zero), is by means of variable landing fees. The fees reflect the level of emissions.

This has been tried in Sweden, for both ships and aircraft, and has been found to be very effective in lowering the environmental impact.

Levying a kerosene fuel tax is another possibility, but this has to be done over a group of countries (eg EU), otherwise as the experience of Norway has shown, aircraft will take on board additional fuel outside the country, and the additional payload offsets any intended advantages with greater emissions.

Noise

The maximum noise boundary (averaged equivalent continuous noise contour) should be set no higher, and preferably lower, than the current level of flying, which is already unacceptable for those living on the approaches to Farnborough.

If TAG (airfield operator) are unable to accept these limits that is their problem, not the community's problem. Their claims that the current levels are not economically viable are bogus, partly by their own admission that they have not yet done the sums, and also because the airfield has operated at or below the current level for the last ten years.

People's lives are already being made hell by the current level of flying. The situation can only get worse with an increased number of air movements. Were the number to be increased, the current peak nuisance during late afternoon/early evening would extend throughout the day.

Aircraft noise was the second most common source of noise reported in the 1991 National Noise Survey. Complaints about aircraft noise to Environmental Health Officers rose sixfold over a ten year period (1984/5-1994/5). For those living on the flight approaches to Farnborough the present intolerable situation can only worsen with an increase in flying.

Young children at schools in the flight path of busy airports have a reading age 9 months behind those of their peers attending schools in a quieter environment.

Currently, there is no protection from aircraft noise. The Environmental Protection Act (1990), used to control noisy neighbours, specifically excludes aircraft noise. The Secretary of State for the Environment has powers under Section 78 of the Civil Aviation Act (1982) to issue orders to control aircraft noise, but these are rarely used, and to date have only been used to control Heathrow, Gatwick and Stansted (areas in which the local authorities have been prepared to fight on behalf of the local community).

There should be a peak level that individual planes may not exceed. Several planes currently using Farnborough are unacceptable on peak noise. There should also be a maximum frequency of these events that may not be exceeded.

Noise boundary should include helicopters as well as fixed wing, engine testing on the ground, military flights, the Airshow, DERA flying club.

The Inspector notes that at a little under 10% of air movements the DERA Club flying is insignificant. It may be small but it is not insignificant. He also make the erroneous comment that it would require additional infrastructure to monitor the noise. It would not.

The Inspector notes that any increase in weekend flying would result in a loss of amenity. The same flying causes the same loss of amenity to local residents during the week!

Flying should be restricted to 0900-2100. Bad weather, emergency landings would be the only permitted exceptions. Any flying that occurs outside these times (other than for permitted exceptions) should be heavily weighted to exact a high penalty when calculating total movements for the purpose of falling within the noise boundary.

The average noise figure should be averaged over the period of operation so as to reflect actual operation not some hypothetical period of operation (ie not 0700-2300). The average noise figure represents an extremely crude method of limiting total air movements, it has no other use, but it should be noted that it is extremely insensitive to total movements, eg a doubling of movements will only give a 3 dB change in average noise level. Peak noise and the frequency of such incidents is the only reliable measure that reflects the nuisance and stress caused, and thus the consequential impact on health.

The noise limits should be progressively reduced to reflect improvements in engine and aircraft design.

Control should also be extended to noise generated by associated ground activity (traffic, plant etc).

BAA, who operate Gatwick, provide a free telephone number, 0800 393070, to enable local residents to complain about noise. A similar system, provided at the operators expense, should operate in Farnborough.

Any noise monitoring equipment should feed into a sealed Black Box (tamper proof), with independent data links to TAG (airfield operator), Rushmoor and ideally an independent Third Party. The capital cost and running costs to be met by the airfield operators. The operation should not be by the airfield operators unless zero notice inspection procedures are in place.

Safety

The Inspector makes the ludicrous comment that size does not matter!!!!!

The damage caused on ground impact is by the dissipation of kinetic energy. Kinetic energy is a linear function of mass. Or as anyone but a fool realises, that if a light aircraft falls out of the sky it causes much less damage than if a jumbo jet falls out of the sky.

The Inspector sets a limit on flights based upon the probability of a crash on the approach to Farnborough. Unlike most airfield approaches the area is well developed, in addition aircraft are forced to fly in low over a residential area in order to drop down to the runway. A crash on the approach to Farnborough would have a high probability of causing damage to persons and property. Taking this into account would give a much lower limit than that permitted by the Inspector. A further factor that needs to be taken into account, is that business aviation has an order of magnitude greater accident rate than commercial schedule airlines.

The 1 in 100,000 risk contour should be contained within the airfield.

Societal risk, eg loss of hospital, school etc, has a much greater impact upon the local community. Such establishments, eg Farnborough College of Technology, should be outside of a 1 in 1,000,000 risk contour.

Public Safety Zone

A Public Safety Zone is an area of land that funnels into the runway of a busy airport. Within this designated area development is severely restricted to limit casualties in the eventuality of an aircraft crash. The type of development permitted within the Public Safety Zone is restricted to long-term parking, warehousing, open space.

Farnborough is unusual in that what would be designated as the Public Safety Zone already contains non-permitted development - medium density housing and an educational establishment (with high rise blocks). On this ground alone Farnborough should not be permitted to operate as a commercial airport.

A second unusual feature of Farnborough is that the approach is higher than the runway, forcing planes to fly low over a residential area, adding considerably to the safety risk.

A very busy major road (close by the end of the runway) passes through what would be designated as a Public Safety Zone. Traffic lights and a busy junction, virtually on the line of the main runway, adds considerably to the safety risk. As does three bus stops.

Farnborough is a major air disaster waiting to happen.

Freight

The airport is currently being used by freight planes and for the shipment of live animals.

TAG will do whatever is most profitable for TAG. With a direct link to the M3 out of the north of the airfield and a two-lane highway out of the south to the Blackwater Valley Relief Road (the costs carried by the local community), Farnborough would become one of the best placed airports in the UK for freight transport.

Unlawful Operations

Neither the Airshow nor TAG have planning consent for their operations, the current operations are thus unlawful. An enforcement notice should be served.

Ground Development

The designation of the old factory site for warehousing and industrial units is a waste of a prime site. The site should be earmarked for high-tech, with the emphasis on the establishment of a university for the next millennium.

No housing development should be permitted on the site. It would be difficult to envisage a more inappropriate site in terms of noise, air pollution and safety.

The Inspector's Report places inadequate emphasis on habit conservation, which in view of the prime nature of the site, should hold precedence over all other development.

Farnborough Common

Farnborough Common, of which the airfield is part, was seized by the military from the local community. Now the military has no further use it should be returned to the local community as public open space, with due safeguards for environmentally sensitive areas.

This has happened at Greenham Common, at the height of the Cold War a US airbase housing nuclear cruise missiles. There is no reason why it cannot happen at Farnborough, other than a local authority that has failed to act in the local community's interest.

Greenham Common has much in common with Farnborough Common, besides the fact that it was seized from local people by the military. It is seen as classic lowland heath, with the same fauna and flora, many of the same endangered species as the airfield and the surrounding heathland. The main difference is that at Greenham the local authority has imagination and can see the potential of restoring the site and returning it to the local community.

At Dunsfold Aerodrome, surplus to requirements by BAe (Beyond All ethics: Still arming repressive regimes!), the local authorities from Parish Council upwards are pushing for it to be returned to the local community. In contrast, Rushmoor failed to even register Farnborough Common as public open space when it had the opportunity to do so.

Consultation Committee

With well over a third representing Rushmoor Borough Council, over a third representing airfield operators and vested interests, and less than a third representing what can even remotely be described as the local community, the committee is not consultative of or representative of the local community, at best it exits to further the interests of vested interests and their supporters.

The committee should be restructured to represent the local community with a single representative each for the operators and the local authority. There should be an independent chairman and secretariat.

Transport

The likelihood of green transport to the airport is a pipe dream. Are we seriously expected to believe that fat cat executives will turn up on their bicycles or on public transport for a junket on their executive jets?

Farnborough International Airshow

The Inspector claimed he saw no disruption to the locality during FI 1998. He must have had his eyes closed and his ears stuffed.

Whilst it is unquestioned there may be benefits to the exhibitors and the organisers, there are no benefits to the locality. The Airshow causes major disruption to the area in terms of noise, air pollution and traffic congestion. Many residents go away during the Airshow, schools close for the afternoon, local people avoid Farnborough causing losses to local traders, the noise disrupts local business, the traffic congestion adds to costs and increases local air pollution.

Employment

When one looks beyond the hype the aviation sector is seen not to be the generator of employment it claims to be. Within the EU the sector accounts for only 1% of GDP, 0.2% of employment, but externalised costs amount to 4.6% of EU GDP (16.4 billion euros/year) with direct and indirect support and subsidies running at 45 billion euros/year.

Other than low paid, low skill work, all employees are likely to be drawn from outside of Rushmoor. Those commuting into the borough will add to the externalised costs (pollution and traffic congestion), those who move into the borough will increase the pressure on housing.

Flight movements increased at Frankfurt airport by 77.8%, employment rose by 0.6%.

Health Implications

A recent report by Health Council of the Netherlands (August 1999) has highlighted the health impact of airports. The report, prepared by an international group of experts, has added additional weight to what most people are already aware of, but what few airports want to acknowledge - that airports and their surrounding activities have a negative impact on public health.

The report found that segments of the population had a deterioration in their quality of life, with clinically observable health effects. Identified was the occurrence of premature death, aggravation of respiratory and cardiovascular disorders after an episode among susceptible individuals as a response to air pollution. Specific subgroups (a much larger group than 'susceptible individuals'), suffer from reduced lung function and increase in chronic respiratory conditions (bronchitis) due to chronic exposure by air pollution.

Regarding noise, the report found there to be sufficient evidence for the effect of hypertension among specific subgroups and ischaemic heart disease among susceptible individuals. The report confirms that aircraft noise has a negative impact on the cognitive abilities and performance at school of children.

The report acknowledges that these problems can also be associated with industrial developments and heavy traffic, but notes that such activities are subject to controls whereas airports are usually exempt. The report also notes that it is easier to control small airports than large.

The report ends with a stark warning:

If civil aviation is not a part of internationally accepted mobility policies, that take into account both short and long term, local and global environmental and health impacts, then the aviation endeavour that started with the Wright brothers might become an important contributor to permanent loss of health and life.

Spread of Disease

Not covered either by the Local Plan or the Inspector's Report is the spread of disease. Airports act as the focal point for new and novel diseases. Were a single traveller to arrive at Farnborough, infected with Ebola Zaire, to come into contact with a local person, it would wipe out Farnborough within days. The only countermeasures that could be taken would be to seal off the entire area and leave those within to die.

There is already a small but growing number of cases of the spread of malaria (via mosquitoes infected with Plasmodium falciparum) to airport localities. This has led to secondary cases of infection. A problem that can only worsen as global warming raises northern temperatures (for which aircraft emissions are a significant contributory factor).

A recent study in Norway showed that every year there are cases of the import of infectious diseases. These included malaria, shigellosis and typhoid fever.

Future Policy

The plans for the airport are supposed to reflect government policy, though in their statements Rushmoor are duplicitous - whether or not the airfield is being driven by government policy depend entirely upon the forum in which their views are presented.

It is difficult to claim that the plans reflect government policy as there is no government policy (the 1985 White Paper is long out of date). The Heathrow Terminal 5 Public Inquiry highlighted the lack of a government policy. There is expected to be a government White Paper on the subject but this is not expected until some time into the new millennium. The government is not expected to complete its research until at least the end of 1999.

The Royal Commission on Environmental Pollution in its 18th Report, Transport and the Environment (October 1994), recognised that unlimited growth in air transport was no longer acceptable, it also made a number of recommendations on reducing emissions and noise, and for the sector to pay its externalised costs. The government's White Paper on the Future of Transport (July 1998) recognised that the discredited policy of 'predict and provide' was no longer acceptable.

Internationally, having recognised the impact aircraft have on pollution in general, and global warming in particular, the target is to reduce air travel, especially short haul (within the EU 69% of all flights are less than 1,000 km). Short haul to be replaced by train, and an increasing emphasis on executive meetings to take place in cyberspace. With the rapid penetration of the Internet into all aspects of our lives the latter is already a practical possibility.

Globalisation

Executive travel and air freight are the engines of globalisation. On these grounds alone any increase in the capacity at Farnborough should be opposed.

Globalisation destroys local sustainability. Globalisation is contrary to Rushmoor's stated LA21 objectives on local sustainability and building and strengthening the local community. To date Rushmoor has paid lip service to LA21 and engaged in cosmetic window dressing.

Local Sustainability

Any activity involves risks and benefits. Going to the shops for example involves the risk of being run down as we cross the road. Imposing a major airport on Farnborough forces Farnborough to bear all the risks with zero benefits. There will not even be the advantage of cheap charter flights on the doorstep as such flights have been specifically excluded.

Any increase in flying at Farnborough exacts a high price on the local community, with no benefits to the community.