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

This document should be read in conjunction with the subsidiary documents Objections to Inspector's Report on Rushmoor Local Plan (Farnborough Airfield) and Objections to TAG Planning Application (Farnborough Airfield).

In rejecting key recommendations in the Inspector's Report on Rushmoor Local Plan, Rushmoor claim to be following government policy. There is no current government policy dealing specifically with airports. Letters from low-ranking civil servants instructing Rushmoor to ignore the Inspector's planning recommendations are not government policy, neither are throw away remarks by past government ministers re Farnborough Airfield. The government is currently in the process of drawing up a national airports policy, it would be improper to attempt to second guess that policy. To go ahead with airport expansion at Farnborough would be contrary to declared government policy to reduce transport congestion, declared government policy to reduce air pollution, declared government policy to reduce greenhouse gas emissions (international treaty obligation to reduce CO2 emissions by 20% under Kyoto agreement). It would also be contrary to the reports of various Royal Commissions, and other committees. In a soon-to-be-published report on greenhouse gas emissions the Royal Commission on Environmental Pollution is expected to call for deep cuts of 60% (in line with the recommendations of the Intergovernmental Panel on Climate Change).

The DETR had the opportunity to air their views at the Public Inquiry, where they could have been scrutinised and cross-examined. They chose not to. Rushmoor should not be paying heed to views submitted by the back door.

[for more on government policy see above referenced documents]

To override or ignore a Planning Inspector's recommendations there has to be overwhelming grounds. Rushmoor has not demonstrated such grounds. To reject the recommendations of the Public Inquiry on a whim has made a mockery of planning process and turned the 2-3 months Public Inquiry at which all sides were able to present their case under detailed cross-examination before an impartial adjudicator into an expensive farce.

The extraordinary council meeting at which the Inspector's Recommendations were thrown out may not have been legitimate as notice of the meeting for the public was not placed in the local library until 2 days after the meeting. All decisions reached would thus be null and void.

Council officials appear to be acting as a lobby for TAG. Council officials are refusing to place before councillors documents critical of the TAG proposals thus presenting councillors (who are too reliant upon the advice of officials) with a one-sided view. It appears to be the interests of TAG, a foreign-based Arab-owned consortium, which are driving the entire planning process, not the interests of the local community.

A one way artificial distinction is being made between the TAG Planning Application and modifications to the Local Plan. On the one hand TAG are driving the alterations to the Local Plan so as to ease the passage of their planning application, whereas on the other hand objections to the TAG application are being ignored in the consultation process for the Local Plan. As many of the objections to TAG equally apply to the Local Plan changes, these objections should be taken into account when reviewing the Local Plan. The Local Plan appears to have been modified to accommodate the TAG application, therefore all objections to the TAG application must be considered as objections to the modified Local Plan. For many members of the public there is no distinction between the two and they have made no such distinction when lodging their objections.

There needs to be a further Public Inquiry. There are also more than sufficient grounds to refer the way this entire planning process has been handled to the Local Authority Ombudsman. The blind eye that is being turned to TAG's unlawful operation of the airfield (no planning consent for current operation) is in itself sufficient grounds for an inquiry by the Ombudsman. As is the crude attempt to prevent Councillor Patrick Kirby from speaking on behalf of the local residents who elected him.

The local community does not support an increase in flying. No great surprise as it is the local community that will suffer from any increase with no tangible benefits. Any benefits would accrue to a foreign-based company. The results of the recent Mori poll have been deliberately misused. The relevant question was: 'Do you support or oppose the continuation of business flights (not schedule or holiday), or do you "Have no views either way?"' No question was posed on (substantial) increased levels of flying, noise, environmental damage, air quality, public safety zone. Ben Marshall, Senior Research Executive at MORI, has been forced to complain at the way his organisation's poll results are being misused. The election of Patrick Kirby, on a platform opposed to increased flying (in the only poll that counts), indicates the strength of local opposition to expansion at the airfield.

Rushmoor are failing to act for the local community.

Public Safety Zone

A Public Safety Zone, the area lying inside the 1 in 100,000 risk contour, is designed to protect the public interest. Development is not permitted within this zone.

In their recommendations (by council officials) and subsequent discussion and endorsement (by councillors) there was displayed an appalling lack of understanding and ignorance of the significance of a public safety zone.

The zone cannot be traded off against the public interest as the zone in its very definition encompasses the public interest. In any case the trade off is not in the public interest but a trade off of the public interest versus private interest. Any relaxation of the PSZ puts the local community at risk, the only beneficiaries are TAG, a foreign-based company.

Whilst it may be true, that imposition of a PSZ makes the airfield economically non-viable that is no reason to relax the PSZ. On the same grounds we would allow a factory to continue releasing toxic waste or breaches of Health and Safety Regulations to occur.

The societal risk contour, 1 in 1,000,000 risk contour, extends over Farnborough College of Technology.

The Risk analysis by NATS on behalf of DETR underestimates the risk to the locality. A number of factors are ignored or buried away in assumptions. The NATS assessment assumes a flat topography, residential Farnborough is on a hill at the end of the runway. Helicopters are ignored, as is the Farnborough Airshow. Both factors not only add to the risk but also to the noise. The airshow adds a further 1500 air movements every two years. The additional risk from the airshow is difficult to assess as there is not the data for the aircraft (new planes), but as they are new there may be as yet unknown problems. The flying is designed to put the aircraft through their paces or as NATS note 'display flying and movements may be riskier than passenger and cargo movements.' NATS assume that the aircraft are from the First World not Third World where maintenance and crewing standards are far lower than UK. NATS assume a lower weight limit than TAG are proposing for the site. The impact area used by NATS is smaller than assumed in the US.

Rushmoor have seriously underestimated the number of people at risk. They have used out of date census information, have only considered the residential population, ignoring those studying and working within the PSZ.

One of the first casualties of a relaxation of the PSZ would be Farnborough College of Technology. No responsible parent would permit their offspring to study in a death trap. Noise and air pollution are further disadvantages of studying at FCoT. Plummeting student numbers would affect the economic viability of the college. The site would become worthless as no permitted development within a PSZ and no responsible employer would relocate to a death trap. Loss of the college would lose 1200 jobs and an estimated £15 million brought into the local economy. TAG in comparison would generate a couple of hundred jobs at most in the remote and distance future and repatriate all profits to hidden bank accounts in Luxembourg and Switzerland.

Executive aircraft using Farnborough are safe! Tuesday 2 May 2000, a Learjet en-route from Farnborough to Nice, experienced engine trouble and was forced into an emergency landing at Lyons. The jet came in at very low altitude and crashed short of the runway, killing pilot and co-pilot. Had the journey been reversed and the crash-landing happened on the approach to Farnborough it would have destroyed a part of residential Farnborough killing or seriously injuring more than two people.

Learjets have a reputation for being difficult to handle. This is to be expected as the faster the manoeuvrability of an airframe the more unstable.

Kieran Daly (Ed, Air Transport Intelligence), commenting on the Learjet:

It's a very sporty plane but is quite a handful to fly. It really is very demanding and has almost fighter-aircraft-style handling.

In 1994, a Learjet 23 crashed into two apartment buildings in Fresno, California, killing the flight crew and 21 people on the ground. Six more fatal accidents over the next two years killed 20 people. In 1996, a Learjet 35 overshot the runway at RAF Northolt and landed on the A40 hitting a van. October 1999, a Learjet crashed in South Dakota after flying out of control for several hours killing crew and passengers. The crew flew too high and blacked out. This may also have been the cause of the loss of a Learjet 23 in Ohio in 1996.

During the Nato war against Kosovo, a fully-fuelled tanker crashed on take-off in Albania. Nothing was left in the ensuing inferno. It was flying fuel to the airport in Kosovo. It's failure to arrive enabled the Russians to seize the airfield 12 hours later. It doesn't bear thinking about if such a crash occurred at Farnborough.

The Boeing Business Jet (converted 737) will have extra fuel capacity (adding an additional c 20 tonnes of fuel), placing it in the same league as a Boeing 747. The crash at Schipol shows what a Boeing 747 crash can do.

The two most important statements made by the Inquiry Inspector were:

Proposals which result in the 1:100,000 risk contour at the eastern end of the runway 07/25 extending beyond the operational boundary of the aerodrome will not be permitted.

Proposals for flying which result in the 1:100,000 risk contour at the eastern end of the runway 07/25 extending beyond the operational boundary of the aerodrome will not be permitted.

Public safety should be regarded as of paramount importance and cannot be traded off against anything else, certainly not against the private profit of a foreign based company. These two proposals by the Inspector should be regarded as carved in stone.

The DETR Draft Circular on Public Safety Zones states (15 June 1999):

The consequence of an aircraft crashing into certain types of development, such as a hospital, school or sports stadium, may be expected to have a very great societal impact because of the nature or number of third party casualties. Societal concerns are very difficult to assess on a numerical basis. Nevertheless, the local planning authority may wish to consider restricting such forms of developments within areas of greater extent than the Public Safety Zones, themselves, and in particular just beyond the boundaries of the Zones.

Farnborough College of Technology would be within the PSZ. The worst case scenario would be a fully-fuelled transatlantic jet crashing on the college during take-off. A blazing inferno of molten steel and glass with a couple of thousand students incinerated beyond recognition.

The proposed developments of the airfield and relaxation of the Local Plan would be contrary to government policy on PSZs.

No residential area should lie within the 1 in 100,000 risk contour, ie the PSZ should not extend over residential areas. No school, hospital, old folks home etc, should lie within the 1 in 1,000,000 societal risk contour, eg the societal risk contour should not extend over Farnborough College of Technology.

[for more on PSZ and local risk see above referenced documents]

Air Movements

Rushmoor are proposing increasing the ceiling on movements to 28,000, ie even more than the 25,000 applied for by TAG.

The level of 28,000 is for business aircraft only, ie all other movements would be in addition to this.

The present level of around 12,000 movements is already intolerable for those living on or near the flight path.

Movements should be restricted to present levels or ideally reduced.

Rushmoor has failed to demonstrate the rationale for an increase from 20,000 (current Local Plan) to 28,000 (modified Local Plan). The figure of 28,000 appears to have been plucked from thin air.

Noise

Rushmoor are proposing an increase in noise. No deterioration in noise levels compared with 20,000 movements is an increase in noise when current movements are around 12,000.

For those on or near the flight path there is already an intolerable level of noise (conversation impossible, stress levels rise).

At other airports (eg Manchester) there are ongoing programmes of annual noise reduction. Proposals for Farnborough would increase noise levels.

There is a growing body of international evidence of the detrimental effect of noise on cognitive ability. The UK government in PPG 24 'Planning and Noise' regards schools as noise sensitive. The upper limit for noise sensitive areas is 60 dB. TAG, on 20,0000 movements (their application is for 25,000), would place Farnborough College of Technology within the 63 dB noise contour. Higher levels of flying (Rushmoor are attempting to raise the ceiling to 28,000 and TAG have publicly stated they wish to see a much higher ceiling) would worsen the situation. The average noise contours underestimate the problem, cf peak noise. Students at FCoT would be at an educational disadvantage compared with those at a quieter location. Rushmoor are deliberately ignoring stated government policy on planning guidelines.

All Stage 3 aircraft should be banned from Farnborough, and as soon as the standards are agreed for Stage 4 (late 2001?), all Stage 4 aircraft should be banned from Farnborough. No aircraft using hush kits should be allowed to use Farnborough.

Any improvement in quieter aircraft should accrue to the local community in quieter skies, not to TAG in more movements to maintain the same noise levels. There should a be a progressive reduction in both average noise levels (ie noise contours) and peak noise compared with existing noise levels.

[for more detailed discussion of noise see above referenced documents]

Local Plan Stated Objectives

Any development at the airfield would fail to meet the following Local Plan stated objectives [FA2.2(C)]:

• cause no demonstrable harm to the natural environment, amenities and safety of the surrounding area
• maintain or enhance employment opportunities and economic prosperity in the locality
• can be served by local transport infrastructure
• do not adversely affect ambient air quality

Development of the airfield would fail on all four criteria. There will be demonstrable harm to the natural environment, the local community will be put at greater risk as the risk contours broaden and extend further from the airfield. The operation, as proposed by TAG would extract wealth from the area, no one would wish to be located near a busy airport and business will be driven out of the area, eg Farnborough College of Technology have stated they will be forced to close or relocate. The airport will be for the executive end of the market, thus will not be using public transport, and currently no public transport to the airport (nor is any envisioned). Rushmoor is already unable to meet its air quality targets, the airfield will be an added burden, plus it will be adding to greenhouse gases.

[for more detailed discussion of these adverse effects see above referenced documents]

Hampshire Structure Plan

Hampshire Structure Plan states [Policy EC5(ii)]:

Proposals to expand and enhance the facilities at Farnborough Aerodrome to accommodate the development of a business aviation facility will be supported except where there are overriding environmental, safety, or transport objections ....

The proposed development by TAG and the relaxation of the Local Plan would fail the above policy statement on environmental, safety, and transport grounds, thus would be contrary to the Hampshire Structure Plan.

[for more detailed discussion of environment, safety, and transport see above referenced documents]

Sustainability Metrics

The sustainability of an area can be measured by two metrics: the biodiversity and the maintenance of the ecosystem function. Ecosystem function is usually treated as a free function, it is only when we lose it that we count the cost, eg degradation of a water catchment area requiring expensive water treatment plant. Other benefits, eg social and economic benefits, flow from the maintenance of these two metrics.

Although Farnborough is primarily an urban environment it has the green pocket of the airfield and surrounding heathland.

No development should be permitted that has a detrimental effect on local biodiversity or has external biodiversity or eco-function costs.

Airfield development would have massive biodiversity costs: destruction of heathland, destruction of airfield grasslands, pollution of Cove Brook, siltation of Fleet Pond (through destabilisation of heathland) loss of trees. External costs: noise, traffic congestion, air pollution, increase in greenhouse gases and climate destabilisation.

By 2015, half of the annual destruction of the ozone layer and 15% of greenhouse gas emissions will be caused by air traffic. A single transatlantic return flight emits half the yearly carbon dioxide admissions of an average person, or put another way the same used by an average African in a lifetime.

Failure to meet sustainability metrics is a failure to meet LA 21 objectives, a failure to comply with government policy, a failure to meet international treaty obligations.

Alternatives

Rushmoor should be looking at alternatives for the airfield site that are environmentally sustainable. Housing or an industrial estate are not acceptable alternatives.

The area should be returned to the local community as public open space with due protection for sensitive areas (cf Greenham Common). An alternative use would be to establish a university on the site (the area currently earmarked for development by Slough Estates) together with large area of public open space.

A university on the site would meet what seems to be a common requirement of bringing prestige to Farnborough and maintaining the aviation heritage. There is no prestige in ferrying around pampered businessmen full of their own self-importance.

[see Keith Parkins, Rushmoor Local Plan, July 1996 for discussion of university option]

J R Sturgeon (residents rep Airfield Advisory Panel), written comments on airfield developments, 7 May 2000 {letter to Keith Holland, Head of Planning, Rushmoor}