The Aerodrome lies in an area of considerable nature conservation sensitivity, with significant expanses of wetland, grassland and heathland habitats in and around the site. -- TAG
This paper deals specifically with the details of TAG's Planning Application for a Business Airport at Farnborough and should be read in conjunction with the paper Objections to Inspector's Report on Rushmoor Local Plan (Farnborough Airfield) which raises more general objections to expansion of flying at Farnborough which are implicit in TAG's Planning Application.
TAG Farnborough Airport Ltd (current operators of commercial flying at Farnborough) are a wholly owned subsidiary of the Luxembourg-based TAG Group SA.
TAG Planning Application to Rushmoor Borough Council Reference Number 99/00658/OUT (Farnborough Aerodrome).
The TAG proposal is to be objected to on the following grounds
TAG demand 25,000 movements (ie 2 1/2 times 1997 level), with the automatic right to subsequent revision when the movements reach 20,000.
TAG are effectively saying they wish to get a foot in the door at more than twice the present level of flying, with effectively no limits on future operations. This tallies with their submission to the Local Plan Inquiry where they stated they wished to see no limits on weight, movements or noise, and their statements to the local press where they said they had no intention of complying with restrictions placed by the Planning Inquiry.
TAG's summary statement makes no mention of noise (other than an oblique reference to noise contours), pollution or safety, which indicates their priorities.
The noise contours should be no worse than at present. There should be limits on peak noise, and limits on the frequency of such events. All noise limits should be progressively reduced to reflect advances in airframe and engine design. The safety risk for Farnborough should not deteriorate. The total number of flights should not exceed the present annual rate.
Flights should be restricted to 0900-2100 local time.
TAG use the 1985 White Paper to justify their plans. This is long out of date (TAG agree it is dated), and a new White Paper is in preparation (not expected until 2000 at the earliest). The absence of government policy on aviation was noted at the Heathrow Terminal 5 Inquiry.
TAG use the Hampshire Structure Plan to justify their plans, but this only allows for a continuation of flying at Farnborough, not its increase, and there is no reason why flying cannot decrease or even terminate.
The 1998 White Paper on the Future of Transport, which TAG use to support their plans, explicitly criticises 'predict and provide', on which essentially TAG's whole case is built.
Para 1.4:
'Predict and provide' didn't work ...
The 1998 White Paper goes on to say (para 2.1):
We need a transport system which supports our policies for more jobs and a strong economy, which helps increase prosperity and tackles social exclusion. We also need a transport system which doesn't damage our health and provides a better quality of life now - for everyone - without passing onto future generations a poorer world.
The TAG application does not meet the above criteria, nor does it meet the aims outlined by John Reid (then Minister of Transport) when he announced a study of transport needs in the South East (South East Study, March 1999):
I must emphasise, however, that the study will not be an exercise in meeting demand and then just mitigating the environmental effects.
The TAG application is 'an exercise in meeting demand', only in their case they fail to even 'mitigate the environmental effects'.
The draft Planning Policy Guidance on Transport acknowledges that government policy on airports is in a state of flux and that a new policy looking ahead for the next 30 years is awaited. The general thrust of the policy document, PPG 13, is that transport systems must be sustainable, meet the needs of all sectors of society (including disadvantaged and excluded groups) and be part of an overall sustainable planning policy. In particular promote more sustainable transport systems and reduce the need to travel. In achieving these desirable ends, and in particular in assessing planning applications, the local authority has to ensure that any proposal complements and supports existing policies on sustainability and puts people before traffic.
SERPLAN has identified 'hot spots' where further growth should be restrained in order to fend off increased congestion and to protect environmental assets. Farnborough is one of these 'hot spots'.
Hampshire Provisional Local Transport Plan calls for a reduction in traffic growth in Farnborough by one third.
TAG use the discredited 'predict and provide' to justify expansion at Farnborough, a policy that drove much of the road building programme until it was scaled down when it was recognised that such a programme was not sustainable.
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.
TAG attempt to justify their application on a very weak economic argument. That it will save businesses money 'within the region' on reduced time travel to airport.
There are many flaws in this argument:
Those travelling to Farnborough are a traffic problem for Farnborough, a delay that has a cost. Each flight generates excessive noise which interrupts local businesses whether this be a conversation or a thought processes. These negative costs are not mentioned by TAG, let alone costed.
Nor do TAG mention the extensive subsidies the sector receives.
Nor do TAG mention the cost to be borne by the local community of stress, related health care problems.
Had TAG done a proper costing, rather than an extremely one-sided costing, it would be seen that the supposed economic benefits put forward by TAG are greatly exaggerated, and for the local community there are net economic costs.
The proposed job creation, from 150 to an anticipated 350 (by 2011) is negligible, especially within the context of the capital invested (£60 million) and the externalised costs.
Flight movements increased at Frankfurt airport by 77.8%, employment rose by 0.6%.
TAG try to argue that a high critical mass of high-tech companies needs a business airport and vice a versa. This is simply not true. There are areas of the country which have an airport without a high-tech hinterland and high-tech islands that lack their own airport.
High-tech companies arose around Cambridge University because of the strong links with the university, and because of the quality of life in the area. To follow TAG's argument, without reaching their flawed conclusion, if we want to maintain a thriving high-tech local base, we would invest in a University for the New Millennium on the vacated factory site (currently downgraded for warehousing and low-tech light industry). [see Keith Parkins, Rushmoor Local Plan, July 1996]
Many high-tech companies, and low-tech for that matter, are moving into e-commerce, where bricks and mortar is seen as a millstone, where geographical location is an irrelevance. In such a scenario, which is seen as the future, TAG's business airport has no place.
Were there a genuine intention to put Farnborough on the map, were TAG's £60 million put into high-tech Internet companies based in Farnborough, we would see a real return on the capital invested without the high associated costs. Of considerable more importance than an executive airport are high speed, wide bandwidth digital communication links, and ease of access (including low cost) to the local population to maintain a high-skill pool of labour.
Almost anything, whether high-tech or low-tech, would be a greater employment generator than TAG's proposed development.
One of the first casualties of any increase in flying by TAG would be Farnborough College of Technology. The college would become a death trap. No responsible parent would permit their offspring to study at the college. Additional problems are noise and air pollution affecting the learning and health of those at the college. Plummeting student numbers would affect the economic viability of the college. Were the college forced to relocate, the abandoned site would be worthless as no planning permission would be obtainable for redevelopment as within a Public Safety Zone nor would any responsible employer wish to relocate to a death trap. Loss of the college would lead to a loss of 1200 jobs and a loss of £15 million injected into the local economy.
Contrary to the claims made by TAG, aviation is a negative economic generator due to the level of direct and indirect subsidies and the level of externalised costs.
Within the EU:
Businesses, and more importantly their key personnel, will move out of the area due to the deteriorating quality of life that TAG will bring in their wake.
In any case TAG's argument of secondary economic benefit is meaningless as any economic activity has secondary economic effects. What is more to the point is what is that economic activity, is it of benefit to the local community, is it sustainable? A nuclear meltdown would generate secondary economic activity, but few would argue it is desirable. In the light of aviation's privileged and subsidised status almost any economic activity would have greater initial and secondary economic effect than an airport.
Contrary to the claims made by the sector, aviation is not the great economic powerhouse. Worldwide, aviation accounts for 2% of GDP, air transport employing 1% of the world's workforce. Within the EU, aviation contributes 1% of GDP, air transport employs 0.2% of the workforce (6% of transport workforce).
Within the UK we have 'hot spots' of economic activity and 'black spots', making the UK look more like a Third World economy than an integrated First World economy. Income disparities show the same trend. The TAG proposals were they to have a positive economic benefit, as claimed by TAG on crude indices of GNP and GDP, would only serve to exacerbate such trends.
The New Economics Foundation should be invited to carry out an audit of the TAG proposals.
TAG try to claim that their development is sustainable!
TAG claim that their proposal 'is in line with policies aiming to reduce the adverse effects of road traffic and measures will be taken to encourage the use of alternative modes of transport such as cycling.'
This statement by TAG is so ludicrous it is difficult to take it seriously. The development of an airport at Farnborough will generate additional road traffic, there will also be ground movements within the perimeter of the site. Who or what are TAG suggesting will use cycles - fuel transport cycles with tanker trailers, executives arriving on their chauffeur driven tandems, or are they suggesting that bicycles be used instead of executive jets?
It is correct that alternative methods of transport should be used, but those alternatives should be rail to replace short-haul flights. There should also be better planning - is the trip necessary, longer stays to reduce the number of trips etc.
Rushmoor are unlikely to meet their targets for air quality. The main Farnborough Road is one of the worst polluted roads in the South East outside of London. The TAG proposal can only add to the deteriorating air quality.
Pollution from road traffic kills more people than road accidents.
TAG would be expected to introduce a car pool policy to reduce the percentage of single occupancy journeys to less than the national average (currently 70%). This would apply to business travellers not just the workforce. But note this would be about as effective as pissing in the wind as it would be entirely swamped by the passenger to fuel to pollution ratio of the business flights.
In terms of fuel usage and pollution emission either per passenger-mile or tonne-km air transport is the worst form of transport. Business air travel is an order of magnitude worse than commercial aviation.
If we are to have air travel, then we should at least aim to fill to capacity. Executive jets are bad enough, but the type of large business jets TAG are contemplating with a few passengers and full on-suite office facilities to massage some self-important personage's over-inflated ego are nothing short of obscene.
UK is committed under the Kyoto agreement to a reduction in greenhouse gas emissions. The TAG proposal will cause an increase in greenhouse gas emissions.
TAG admit that aircraft emit greenhouse gases (they could hardly argue otherwise), but TAG put forward a novel argument in a vain attempt to persuade that their development would lead to a decrease in emissions. TAG argue that as aircraft are held in a stack over Heathrow and will be able to land immediately at Farnborough, they spend less time in the sky, thus lower greenhouse gas emissions. This is flawed on two counts. First, there is stack over the South, over London, and over the airports. Farnborough would be held over the South, possibly in the London stack. There is no guarantee a Farnborough-bound plane would get down any quicker, and is unlikely to have priority airspace over a plane destined for Heathrow or Gatwick. Second, TAG ignore the fact that the vacated Heathrow slot would be taken by another plane, thus the flight to Farnborough would be an additional flight, with additional emissions, and, apart from very short-haul, would make stack holding emissions insignificant.
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.
If the development is restricted to executive travel only, it is correct, as TAG state, that it will only lead to a marginal increase in traffic, only they are conveniently forgetting the development of the old factory site. The impact of one cannot be considered in isolation from the other. The TAG development will stimulate the factory site and vice a versa, the main thrust of TAG's economic case is based on this argument. Development of the vacated factory site, with proposed light industry and warehousing (Local Plan) or offices, shops, leisure facilities (Slough Estates) will lead to a massive increase in traffic.
TAG are claiming (Church Crookham, Thursday 28 October 1999) that their development will bring large numbers of companies into the area, even though there is no evidence to support their claim. But, were there claim to be correct, that in itself would lead to a substantial increase in local traffic and further pressure on housing and would thus in itself be grounds to reject the TAG application. The local area cannot accommodate either more traffic or more housing (and the latter would in itself be a further traffic generator).
Ively Road, along which TAG wish to bring their traffic, has 1,000 vehicles per hour. TAG are ironically relying on the traffic noise to mask their engine testing, which will take place at the northern end of the site close to the perimeter fence. A residential estate is the other side of Ively Road.
A sustainable transport system is an affordable system providing basic mobility to all citizens without damaging the environment. The TAG proposals fail on several grounds. It is an exclusive transport system, its very exclusivity is for the purpose of globalisation which is of itself an unsustainable activity, the current growth in aviation is damaging the environment (globally greenhouse gas emissions, ozone depletion; locally noise, air quality, safety, habitat destruction etc).
A development that is heavily subsidised, does not cover its externalised costs, generates noise, air pollution, is a major contributor to global warming, has widespread negative health impacts, huge safety risks, is not a sustainable development.
The TAG development 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. Executive travel and air freight are the engines of globalisation, the antithesis of local sustainability.
Major developers are required to submit a Transport Impact Assessment, in particular indicating modal split of transport use.
Apart from some nonsensical comments on cycle use TAG appear not to have submitted a transport assessment.
TAG talk of destroying part of the local habitat under the guise of environmental improvement. A classic case of Orwellian Newspeak. TAG wish to create reed beds as a filtering system, then to cover the area to prevent its use by wildlife!
TAG propose extending the main runway 150 metres westwards towards the canal. This will extend almost into and potentially damage a SSSI (Eelmoor Marsh). The reason for this extension (of one of Europe's longest runways) is to enable planes taking off over Farnborough to start their take-off marginally further away from the town. The downside is that anyone on the canal at the time will have their ear drums blasted.
TAG wish to lop and uproot a number of mature trees at both ends of the main runway. These trees are outside the perimeter of the airfield. Once destroyed a mature tree can never be replaced. The area outside the airfield within which TAG wish to destroy trees extends eastwards as far as Canterbury Road, and westwards across the Basingstoke Canal for some distance into the Long Valley training ground (a SSSI). TAG justify this destruction on the grounds that it will open up the view (part of their landscape enhancements). The need to remove or lop trees in the residential part of Farnborough (and it may be necessary to extend this area beyond Canterbury Road for CAA compliance) indicates how low aircraft will be flying over residential housing.
Four SSSIs will be damaged or potentially damaged by the TAG proposals:
Bourley and Long Valley SSSI is a nationally important site for the richness and diversity of its bird population, especially noteworthy are the large populations of vulnerable and protected species (eg woodlark, Dartford warbler & nightjar). It contains at least 11 scarce species of insects and three Red Data Book species, including the crab spider and jumping spider.
A 1999 survey of Bourley and Long Valley SSSI found 15 rare and notable species of insects. Two Red Data Book species were found in a recent survey. Bourley and Long Valley host three species of birds listed in the EC Directive on Conservation of Wild Birds - Dartford warbler, nightjar, woodlark.
The Basingstoke Canal is the most important wetland habitat in Southern England. Part of its uniqueness lies in its sharp chemical gradient, rising from chalk springs by the Greywell Tunnel, and fed by acid springs running off the heathland as it runs through the Farnborough Aldershot area. The Basingstoke Canal hosts half of the listed wetland and aquatic plants in Britain (including five rare species), and supports 24 species of dragonfly (including two very rare Red Data Book species). In recent years the canal has suffered at the hands of the zealots in the boating lobby.
Eelmoor Marsh is an extensive area of wet acidic peat, having similarities to raised bog and valley bogs. It has an exceptionally rich variety of bog flora. More than 250 species of flowering plants and grasses have been found, including insectivorous plants and 12 species of orchid. There is a large patch of pale dog violet. Eelmoor Marsh provides a feeding ground for many of the dragonflies found on nearby Eelmoor Flash, the boggy ditches provide a breeding ground. Devil's-bit scabious supports a colony of marsh fritillary butterflies (Britain's most rapidly declining species). Eelmoor Marsh is also important for its population of silver-studied blue butterfly.
Fleet Pond is a large shallow lake, fringed by reed beds and wet woodland. It supports a rich aquatic flora including many rare species. Large shallow lakes are rare in the south of England.
Within Long Valley, two hills (Miles Hill and Eelmoor Hill) are to be lowered - extensive ground works leading to extensive habitat and species damage, with reverberations further from the site of the ground works. Both sites support protected reptiles (adder, grass snake, common lizard). Eelmoor Hill supports a substantial reptile population. Long Valley supports a nationally important adder population.
John Eyre, a self-styled expert engaged on behalf of TAG, based upon a very brief survey, was able to note of Miles Hill:
Despite its small size, the Miles Hill site supports an impressive range and number of breeding birds.
Two of the bird species, little ringed plover and woodlark are protected species under Schedule I of the Wildlife and Countryside Act. Nightjar and nightingale are suffering long-term decline and are highly vulnerable to habitat loss and disturbance. Redstart is locally scarce in the Thames Valley, wood warbler locally scarce. Nightjar and woodlark are ground nesting birds.
Miles Hill has several rare species of insects, including two Red Data Book species.
Gareth Matthes, a self-styled expert engaged on behalf of TAG, commenting on the effects of the earthworks:
... the [reptile] population may not be used to such an extreme level of disturbance ...
[For a detailed list of species affected and the areas covered see TAG submission Environmental Statement and supporting Technical Appendix III: Natural Heritage.]
Heathland (the southern equivalent of upland moorland) is an endangered habitat. The main threats are encroachment by developers and fragmentation.
Semi-natural heathland is a mosaic of bog, lichen covered sand, grassland, scrub (heather and gorse) and open self-seeded Scots Pine woodland (with oak, birch etc). To therefore argue (as TAG do to justify destroying pine woodland) that it is to revert it back to heathland (thus habitat enhancement) is false. Were TAG instead to offer to cut down some of the dank conifer plantations that despoil surrounding heathland they would be performing a public service.
TAG propose destroying woodland with the false claim that it would revert to open scrub. If it reverts to anything it is likely to be the same or similar woodland, not open scrub. It also pre-supposes some form of ongoing habitat management. TAG have produced no evidence that what they propose would work (ie long term studies where similar work has been undertaken elsewhere), nor do they put forward any management plans.
On heathland to the east of Mytchett, where thinned conifer woodland has been destroyed the area has not reverted to open heather scrub. The increase in light has resulted in explosive growth of annual weeds, heathers and conifer saplings. After a year the conifer saplings rapidly overtake the heathers. After a few years, dark impenetrable conifer thickets. In another part of the country at old gravel workings where the top level has been skimmed off exposing underlying very acid sands and gravels (thus analogous to what is planned for Long Valley), the area has primarily remained bare or covered in lichens. In parts where some vegetation has started to appear the area is so fragile and sensitive it has had to be fenced off to minimise disturbance.
Lopping off the top of Miles Hill and Eelmoor Hill will disturb fragile and unstable soils. During construction this poses a threat to Fleet Pond. There is also a long-term threat to Fleet Pond if this introduces additional instabilities. Gelvert Stream drains from the area into Fleet Pond.
Proposals by TAG to resolve the problem of Fleet Pond siltation by (hopefully) flushing the water over a large area to be attenuated by the ground vegetation could simply replace one problem with another by redirecting the silt away from Fleet Pond into the Basingstoke Canal.
Where is the gravel and other sand and soils removed off the top of the hills to go?
TAG claim (pers comms) they have had the approval of English Nature to carry out this work, but have not been able to substantiate this claim (ie no documentary evidence included as part of their environmental impact assessment).
Surface water flows through the TAG site. This will carry away surface pollutants. TAG propose the installation of reed beds to attenuate the flow of water. Once the beds become saturated (when they are most needed) they will fail to work. The recent tropical rains (September 1999) are likely to saturate the reed beds. Global warming (to which the TAG operation is a contributory factor) will increase the frequency and intensity of such events.
Run-off from the site could lead to contamination of Cove Brook (an important green corridor that the local community has devoted a large amount of volunteer resources to restoring); countermeasures proposed by TAG may negate the damage (but they produce no evidence to substantiate their claim).
Work within the TAG aerodrome site will destroy a large area of valuable species-rich heath grassland. There is no evidence that plans to relocate the grassland to an alternative part of the airfield would work, and it also begs the question as to where as all parts of the airfield site are environmentally sensitive.
Destruction of a large area of species rich grassland will be taking place in an area designated as a Site of Importance for Nature Conservation, and recognised nationally as an important biodiversity habitat. Slough Estates in their planning application for the old Factory Site, justify their own proposed destruction of grassland on the grounds that a similar habitat exists on the airfield.
Reptiles within the Bourley and Long Valley SSSI are already being relocated. As no one appears to be aware of this situation, it is doubtful that there is any independent monitoring of what is happening. This work started before TAG even submitted their planning application and would seem to indicate that TAG regard the result as a foregone conclusion.
TAG claim (Bowenhurst Hall, Church Crookham, Thursday 28 October 1999) that no harm has been done to the reptiles. Lacking the expertise, it is not for TAG to say. Was permission given, if so by who, what follow-up has there been on the relocated reptiles?
The major earthworks TAG plan for Long Valley and the lopping and destruction of trees in residential Farnborough (many of which are protected by TPOs) would require submission of separate planning applications. The major earthworks in Long Valley involve gravel extraction, for which TAG should seek a mineral extraction licence. For the works in Long Valley TAG should not hide behind MoD and try to claim Crown Immunity as neither military nor national interest is involved and to invoke Crown Immunity would be to abuse the planning process.
TAG show two 20th century artefacts by Eelmoor Bridge. There was a WWII pillbox, this was destroyed a few years ago.
This single error highlights the danger of taking TAG's submissions at face value. Clearly they carried out no survey on foot, on the ground. TAG appear to have only surveyed the airfield, not the surrounding land that will be affected by their work.
There is evidence of an Iron Age chieftain's homestead in the area of Long Valley TAG wish to destroy. This should be checked out as a matter of some urgency, especially as TAG are threatening to go ahead with their earthworks irrespective of planning consent being obtained. It should be noted that they have already removed reptiles (protected species) to enable this work to go ahead.
TAG use meaningless terms to label their noise contours - 'high annoyance', 'medium annoyance', 'low annoyance'. These are meaningless within the context of Farnborough where people on or close to the flight path are already subject to an intolerable level of noise and any increase would not be acceptable.
Church Road East is outside of the 1997 57 dB contour 'low annoyance' and yet residents are subjected to an extreme degree of annoyance every time a noisy plane flies low overhead (the extent of the annoyance is radio is blanked out, conversation becomes impossible, stress levels rise). This would indicate that any noise contours extending over Farnborough would have to be less than 57 dB. TAG's 57 dB contour for 20,000 movements (ie not the requested 25,000) covers a large area of Farnborough and extends right out to Mytchett and just touches Church Crookham.
TAG's projected contours for 20,000 movements can either be interpreted as a worsening situation for people under present day contours (1997 projection) or more people being covered by the same level of nuisance (as contours widen out to cover a larger area).
TAG's projections are flawed on a number of grounds:
TAG have requested 25,000 movements but show projections for 20,000; average over 16 hours when their hours of operation are 15 hours (weekdays 0700-2200) or 12 hours (weekends 0800-2000); the mix of aircraft is based on 1997 whereas TAG are wanting no weight limit, 80 tonne aircraft and at least 12.5% over 50 tonnes (Inspector recommended 50 tonne max, current limit 35 tonne max).
Taking all these factors into account would give far worse noise contours than shown by TAG. The contours should be redrawn to reflect the Planning Application submitted by TAG. The contours should be redrawn using the UK CAA model (TAG use a US FAA model).
Within a 70 dB contour would expect to find hypertension among specific subgroups and ischaemic heart disease among susceptible individuals. Learning ability and business efficiency is affected by worsening noise levels. To put the TAG figures in context, Slough Estates, as part of their planning application for the DERA Factory Site, consider an increase in noise levels of 1 dB to be 'significant' and show that their proposals will only increase background noise levels by a fraction of a dB.
In addition to average noise levels as a crude limit on the maximum number of air movements would also require limits on peak noise levels and limits on frequency of peaks. It is the peaks and frequency of those peaks to which people are most sensitive.
There is a growing awareness of and sensitivity to aircraft noise. Various case studies have shown that at Heathrow although the population affected has gradually reduced the number of complaints has grown, similarly at Munich although the noise level is decreasing the number of complaints is not. There is a trend worldwide to reduce aviation noise on the surrounding population. At Manchester the area covered by the noise contours is being progressively reduced. US Airways is replacing its ageing Boeing 727 Boston to New York shuttle service with Airbus A320 aircraft. The Airbus A320 will have a 75-decibel noise footprint that affects 10 times less area at Boston and 17 times less area at LaGuardia (New York).
B Ben Baldanza, US Airways senior vice president of marketing:
These modern, environmentally friendly aircraft [Airbus A320] significantly reduce overall noise and pollutant levels, while establishing unprecedented levels of customer comfort and convenience.
Moving against international trends, TAG wish to increase the noise exposure for the local community.
The area under the 57 dB contour (what TAG call 'low annoyance') should not extend beyond the 1997 values at the start of TAG's operation. The area should then be progressively reduced over the next ten years. After ten years the rate of decrease would be subject to revision but TAG would not be permitted to apply for an increase. No Chapter 2 aircraft to use Farnborough (the use of hush-kits would not be acceptable as the reduction in noise is marginally and leads to an increase in emissions).
TAG will be engine testing close to the northern perimeter fence affecting nearby housing. TAG claim that the background noise from road traffic will mask the noise. Even close by the road where the road noise dominates this is unlikely to be true as the engine noise is of a different spectral density and the human ear is good at isolating such noise from a noisy background. Further away from the road the road traffic would have no masking effect. Church Road East is some distance from the airfield (in comparison with the housing close to the northern perimeter fence) and is separated from the site by two very busy roads, nevertheless the running of engines at full thrust on the airfield can at times be both loud and extremely annoying.
The current weight limit is 35 tonnes, the Local Plan Inquiry recommended 50 tonnes. TAG are seeking no limit on weight to enable them to bring in aircraft of at least 80 tonnes. This is to accommodate a trend towards heavier and larger business aircraft. TAG require at least 12.5% of their movements to be in excess of 50 tonnes, they claim a restriction of 50 tonnes is not economically viable: 'This is essential for commercial viability.'
Boeing Business Jet 77,000 kg, A319 Airbus 68,000 kg.
The current weight limit of 35 tonnes is regularly flouted giving little confidence that TAG would comply with any regulatory limit on weight.
TAG make the false claim that weight is not a safety issue. Whilst it may be true that the probability of a plane falling out of the sky is not correlated with weight, the damage caused should it do so is a linear function of weight (strictly speaking, mass).
The wing-tip vortex created by large low flying aircraft could cause structural damage.
No weight limit will open the way for future use for freight. Farnborough is ideally situated to be a major freight hub. TNT are already pushing at the door to use Farnborough for freight.
What do TAG mean by 'business aviation and related activities' (emphasis added)?
The maximum take-off weight should not exceed 50 tonnes, as determined by the Local Plan Inquiry.
TAG do not regard safety as an issue. A risk assessment was not submitted with their planning application.
Air travel, in comparison with other modes of transport, is relatively safe, nevertheless there are 1500 airline passengers killed every year, one fatal crash every week. Had the Boeing 737 which crashed on the M1 on the approach to East Midlands Airport a few hundred yards from the runway (8 January 1989), been in a similar position on the approach to Farnborough, it would have taken out a large chunk of the residential area of Farnborough.
A study of air accidents by the Flight Safety Foundation found that the vast majority occurred during taxiing, take-off, initial climb, or on the landing approach. A more detailed recent study by the Foundation analysing data from 1959 to 1994 found half of all worldwide commercial jet accidents occurred during the final approach and landing.
The authors of the DETR risk assessment for Farnborough reiterated the same points:
Air travel is a safe method of transport. Unfortunately, aircraft crashes do occur, and it is clear from historical accident data that the majority of commercial aircraft crashes have occurred during the take-off and landing phases of flight, with only a relatively small proportion occurring en-route. This implies that people living and working in areas close to busy airports will be subject to more risk from aircraft crashes than people living and working elsewhere.
Due to prevailing westerly winds, 80% of the approach flights into Farnborough are over the residential part of Farnborough.
The crash that occurred at Stansted Airport less than a minute from take-off narrowly missed outlying farm buildings, there was no loss of life on the ground (December 1999). Were such a crash to have occurred at Farnborough it would have destroyed a sizeable chunk of Farnborough. The aircraft was carrying highly toxic, highly radioactive depleted uranium as a tail fin counterweight. Most of the depleted uranium has not been recovered. El Al Flight LY 1862 crashed into a block of flats on the outskirts of Amsterdam (October 1992). Apart from the immediate consequences of the crash (at least 43 people killed on the ground, the exact number not known due to illegal immigrants living in the area), 850 people have since fallen ill as a consequence of a giant fireball that erupted from the plane and choking white smoke. The plane was known to be carrying 1,500 kg of depleted uranium (only 163 kg recovered), plus the possibility of nerve gas agents or biological weapons agents. The plane was destined for the Israel Institute for Biological Research (a top secret establishment for biological and chemical warfare, where according to an ex-employee 'There is hardly a single known or unknown form of chemical or biological weapon ... which is not manufactured at the institute' [Sunday Times, 4 October 1998]). In a paper published in Nature physicist Robert L Parker estimated a worst case scenario of 250,000 people exposed to DU in a 747 crash. Farnborough will be specialising in non-scheduled flights, the controls on the carrying of hazardous materials are far less stringent and less rigorously enforced than for regular passenger flights.
The excellent display on safety prepared for the extraordinary council meeting (14 March 2000), very clearly demonstrates the problems. Past crashes at other sites when translated to Farnborough, would impact upon residential areas. No other operational airport in the UK exposes the local population to the same risk as would Farnborough should the airfield become operational at the capacity demanded by TAG.
Modern on-board computer control does not necessarily help to alleviate risk as it can misinterpret the pilot's action and deny him control during a critical period (a probable cause of the Airbus crash at the Paris Airshow).
In the eight years following its launch in 1988, the A320 Airbus was involved in at least five accidents and numerous other 'incidents' due to a conflict between pilot and software. When Microsoft operating systems regularly crash we can reboot the system, we don't have that luxury with computer controlled aircraft.
TAG are wanting a relaxation of weight limits to enable them to bring in the A319 Business Airbus.
[The author of this paper studied risk assessment under one of the leading experts in the country. One of the problems we found was the impossibility of accurately assessing the risks of modern computer/software controlled planes as too many variables, compounded by feedback loops.]
Business aviation has a crash rate an order of magnitude greater than commercial scheduled airlines. The reported crash rate for executive jets is 15 times that of commercial airlines, the real rate may be higher.
A Public Safety Zone is a delineated area at the end of a runway in which development is highly restricted to limit casualties in the eventuality of an air crash. At Farnborough the likely delineated area already contains non-permitted development (housing, schools, busy major road, traffic lights, bus stops).
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.
The 1 in 100,000 risk contour should not extend outside of the perimeter of the TAG site.
DETR have plotted risk contours for 1997 movements (10,167), 20,000, 30,000 and 40,000 movements, using a mix of aircraft provided by TAG Aviation.
For the 1997 movements the 1 in 100,000 edges into residential Farnborough, the 1 in 1,000,000 extends over the technical college. For 20,000 movements the 1 in 100,000 risk contour extends way past Brookwood, the 1 in 1,000,000 extends as far as Mytchett and Tweseldown, covers a fair part of residential Farnborough and entirely encompasses the technical college. For 30,000 movements the 1 in 1,000,000 risk contour includes a play school in Reading Road and a primary school in Mytchett.
At no other airport do the risk contours encompass such a large sensitive area as at Farnborough. At other airports the risk contours extend over open countryside, not medium density housing and areas of high societal risk.
What these contours show is that the TAG proposal is unacceptable on safety and has to be rejected. And even the present unlawful flying (now believed to be approaching 13,000 movements) has to be reduced on safety. TAG are looking for movements in excess of 30,000.
DETR have assumed that the inspector's recommendation of no planes in excess of 50 tonnes will be heeded. The mix of aircraft supplied by TAG Aviation does not include any aircraft over 50 tonnes. Were risk contours to be plotted for what TAG have requested (no weight limit, 12.5% over 50 tonnes, aircraft up to 80 tonnes - Boeing Business Jet, Airbus 319) the risk contours would be worse than the DETR study. DETR have assumed a flat topography, the hilly topography of Farnborough would worsen the risk.
The 1997 movements would have to be reduced to a lower level than simple pro rata figures would suggest. The 1997 contours are for a mix of aircraft that is only 65% executive jets. TAG propose 100% executive jets (which have a 15 times greater crash rate) and heavier aircraft (which kill more people on ground impact).
The DETR study does not include the airshow. A second set of contours should be drawn to indicate the extra risk imposed by the airshow (ie contours with and without airshow).
TAG should be required to submit a risk assessment showing the risk of the weight regime they have requested and to include the airshow. Additional plots for 30,000 and 40,000 movements should be drawn at the same detail as lower movements to enable it to be seen in detail the effect on residential Farnborough.
TAG are vague on how the Airshow will be integrated into their activities, other than '[business] flights will cease while the flying displays take place'.
The Airshow has a major impact upon the local community. This should be accounted for within TAG's permitted flight movements and noise budgets.
Peak noise and frequency of peaks would exceed TAG's limit. TAG would have special exemption for the two weeks, but would still attract penalties.
TAG would be required to implement measures to reduce traffic flows. As a minimum these would include discounted combined airshow/rail tickets (at least 1/3, with no restrictions), free coach service from Farnborough Station, North Camp Station and Aldershot Station during the day and evening. These measures should be in place for FI 2000.
The SBAC activity for the airshow has no planning consent and as such is an unlawful activity. An enforcement notice should be served.
TAG claim their proposal will bring international prestige to Farnborough. This clam is so ludicrous it is hardly worth addressing.
What international fame has accrued to Farnborough and put Farnborough on the map is the aviation research carried out by the RAE (and those days are long gone), Samuel Cody (who few people outside of Farnborough have ever heard of) and to a lesser extent the Farnborough Airshow (and this will decrease in the future with the rise of major airshows in the Far East). It is absolute nonsense to claim Farnborough will gain international prestige for an airport ferrying around business executives and a few 'famous' people.
Farnborough may gain a name for fame, but the sort of fame Farnborough could do without, when a major crash occurs over residential Farnborough or destroys the technical college. The fame that has guaranteed Tenerife Norte (airport in the mountains outside of the capital Santa Cruz) a place in the history books when two jumbo jets collided in aviation's worst ever accident.
Whilst it is noted that housing does not form part of the planning application, it should be noted that due to false rumours deliberately spread by TAG and their supporters, many people have been led to believe that rejection of the TAG application will lead to 10,000 houses or something equally ghastly on the airfield site, and as such have expressed their support for the TAG option as the lesser of two evils.
There are no plans for housing, no alternative planning applications for housing, housing is not part of the Local Plan (which is quite explicit on the need for the maintenance of a strategic gap between Fleet and Farnborough).
The Crow Report has also added to the confusion. Stephen Crow has been widely discredited by all informed observers, and even SERPLAN who commissioned the report have dissociated themselves from his extremist conclusions (a meeting of SERPLAN on 18 November 1999 unanimously rejected the Crow Report). It is also worth noting that with the high water table and the increased winter rainfall expected under global warming the airfield would be a very unsuitable site for housing.
The locality will suffer disruption during the construction phase due to noise, dust, and heavy traffic. Apart from the construction traffic there will also be heavy logging traffic.
The buildings proposed by TAG pose a high fire risk. Whilst TAG and its insurers may find the risk acceptable, and TAG is prepared to risk its own employees, it is not an acceptable risk to the local community. It is the local community that suffers from the combustion of toxic material, it is local fire-fighters who are obliged to risk their lives fighting the blaze.
TAG have claimed they will be 'good neighbours' and that their activities can be tightly controlled outside of the planning process by a legal agreement.
What value such agreements? The people of Dunsfold (south of Godalming) thought they had such an agreement with BAe (Beyond All Ethics: Still Arming Repressive Regimes!). That on BAe relinquishing control of the Dunsfold Airfield it would revert back to the community as common land. Showing their true colours and living up to their well earned reputation, BAe have torn up the agreement, thrown it back in the face of the local community and told them where they can stuff it. As Waverley has discovered to its cost, what they thought was a binding legal agreement wasn't worth the paper it was written on.
BAe are working closely with TAG to promote the TAG planning application.
TAG Group SA is registered in Luxembourg. Can there be any confidence in a company that hides behind a veil of secrecy? A business model that places TAG on a par with Robert Maxwell, drug dealers, money launderers and arms dealers?
TAG Aviation SA is registered in Switzerland.
A project of this size is usually accompanied by a glowing account of the company involved. The TAG planning application is remarkably silent in this respect. It has proved impossible to penetrate Luxembourg and Swiss secrecy. TAG employees seem to know very little of the company structure and ownership or are not authorised to say. What little is known is that the company is believed to be Arab owned.
At the Noise Workshop held at the Borough offices (Committee Room 1, 1630-1830 Thursday 7 October 1999) TAG said they had strong links with Farnborough College of Technology. What are these links, what is their financial value, is the college being bought off? At the same meeting Councillor Mathews (chairman of the planning and transportation committee) said he wished to see any spare cash sloshing around at TAG come his way. These comments may have been made in jest, though in the light of various other comments he made at the same meeting that any problems TAG may have with their application, meetings would be held and ways and means found to accommodate, it would appear not to be so. Such comments (whether said in jest or not, and no one was smiling) give little confidence in the propriety or manner in which the TAG application will be handled. Nor can the community have any confidence when the public was barred from an advisory committee meeting considering the TAG application.
One of the major backers of TAG is BAe (Beyond All ethics: Still arming repressive regimes!). At the Church Crookham Public Meeting (Bowenhurst Hall, Thursday 28 October 1999) TAG admitted that BAe would be major beneficiaries of a business airport at Farnborough. A company nominated by the Telegraph as the least ethical in the UK. A company that is not only happy, but eager, to arm the world's pariah states (Hawk ground attack aircraft to Indonesia, assault rifles to Turkey, in the past the murderous Pinochet and Suharto have been valued customers). A company that is believed to be producing depleted uranium munitions and explosives for illegal anti-personnel landmines. A company that reportedly paid a £4 million sweetener to ease an arms deal in South Africa.
Rushmoor accepts a large amount of sponsorship from BAe. The level of dependency is that of a junky looking for the next fix. A clear conflict of interest.
A clear and unequivocal statement is needed from Rushmoor that no sponsorship or benefits in kind will be accepted from TAG, BAe or associated companies. The same applies to paid and elected officials.
TAG currently do not have planning consent for the existing commercial flying activities. An enforcement notice should be served.
Rushmoor served an enforcement notice on a tree-house that was causing no problems to anyone, whereas a convenient blind eye is being turned to commercial flying that is having a major environmental impact on the area.
Executive jets are one of the main drug routes into the US (especially when coordinated by the CIA and DEA). Drug trafficking could become a growth industry, with Farnborough becoming the Miami of Europe.
Pop stars and other assorted riff-raff prefer to fly into Farnborough as it has a reputation for being soft on drugs.
By one of those strange quirks of fate TAG submitted their application on the day of the Paddington rail crash. One of the factors that is believed to have contributed to the crash was a problematical signal and a bidirectional line. Commercial considerations overrode safety. At Farnborough the desire by a foreign company to exploit Farnborough for its own commercial gain is being allowed to override all other considerations.
The Planning Application submitted by TAG will lead to a marked deterioration in the quality of life for the local community. The application submitted by TAG does not even meet the minimum requirements of the Inspector's Report following the Local Plan Inquiry.
Local authorities outside of Rushmoor are pushing hard for no expansion of flying at Farnborough. Rushmoor should take heed. Rushmoor should also take heed of its own local community in Farnborough, a community that will be destroyed by a business airport on its doorstep, a local community who Rushmoor are elected and paid to serve, a local community who are saying loud and clear no, No, NO to TAG.
The Planning Application by TAG for the development of Farnborough as the major business airport for Europe should be rejected.
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