ERM have a reputation for 'greenwash'. ERM are the company large corporations go to when they desire a flaky report to make them look cleaner, greener with a better reputation than they actually posses or deserve. With the two so-called 'independent' reports for Rushmoor Borough Council on the TAG risk contours for Farnborough Airport - main report (October 2002), supplementary report (December 2002) - ERM demonstrate they have a well deserved reputation.
In summary: TAG have produced flawed risk contours (which underestimate the risk), ERM have produced two reports of little substance. Both have avoided the real issue.
Drawing the 1:100,000 annual individual risk contour (ie the probability of an individual being killed in any one year) however well or badly drawn, is not a mechanism for determining the TAG planning application.
The 1:100,000 risk contour is of use only for drawing the Public Safety Zone. A PSZ is a future planning tool. It is a sanitised zone in which no future development should take place, ie no one should live, work or congregate, ie no houses, playing fields, car parks, schools, colleges, office blocks etc. At Farnborough this non-permitted development is already extensive within the PSZ, ie if it did not actually exist, it could not be built as not safe.
The PSZ is loosely based on the 1:100,000 risk contour. It is drawn for the movements and mix of aircraft in 2015, ie not the current mix and number of movements.
Annual individual risk contours (ie the risk of an individual being killed in any one year) are determined by the number of movements, the weight and mix of the aircraft, the crash consequence area and the crash rate. No account is taken of the population on the ground. The risk contours for Farnborough would be the same whether Farnborough were open desert or lower Manhattan, because no account is taken of the population on the ground.
What we can say of the risk contours for Farnborough is that more people are enclosed than at any other airport, ie more people at risk of being killed. The 1:10,000 contour extends outside the airfield boundary. This is contrary to HSE advice that no third party should be exposed to such a risk.
To date a ground safety study has not been carried out.
NATS, DfT have both advised Rushmoor that drawing risk contours is not relevant for determining a specific planning application. That a ground safety study should take place, that the safety study should be robust and able to withstand scrutiny, that serious weight should be given to safety when weighing other considerations (benefits and disbenefits). To date no such assessment has taken place, Farnborough reaps all the disbenefits and receives no benefits.
No account has been taken of the Human Rights of those affected by these applications.
Before making detailed comments on the planning agenda including the subsidiary ERM report I would note that the subsidiary ERM report was not made available until a few days before the planning meeting (making comment difficult), that isolated paragraphs and statements have been taken and quoted out of context from my reports (councillors should have placed before them the complete reports), these comments should be read in conjunction with previous detailed comments on TAG and ERM reports.
All three reports should be placed before councillors. Failure to do so will be seen as a serious breach of the Human Rights Act. In the absence of these reports councillors are seeing information out of context, and being deliberately misled.
The agenda placed before councillors is flawed and extremely biased. It contain false and misleading comments by officials. It is extremely one-sided. Reports by and on behalf of TAG and two reports by ERM (incl one which takes highly selective out of context quotes from my reports) are included, whereas, the three reports by myself, and reports by others, are not included. I will expect these missing reports to be included. As this will be additional information that councillors need time to absorb and digest, and have the opportunity to ask questions, the discussion should be deferred.
The flawed and biased agenda is yet one more example why an independent investigation of the Rushmoor planning department is long overdue.
The overall impression given is that ERM still do not understand the subject. In a nutshell, ERM are simply taking the NATS model (or the ERM approximation to the NATS model) and feeding in the TAG data. This demonstrates nothing other than TAG and ERM are both capable of feeding in the same data into the same model. To claim otherwise is an exercise in dishonesty and deception.
Will ERM be invited to make a presentation, to be open to expert cross-examination? If not, why not? Are ERM not able to withstand expert scrutiny?
ERM mislead. They only take part of the college. Are we to assume that a crash on the college only affects the part of the college hit? Clearly a false premise, especially when account is taken of the structure of the college.
Using ERM's perverse logic, a crash on a building only effects that part of the building actually hit. If we transfer this perverse logic to the Twin Towers in New York, we should only count the floors hit, not the entire buildings.
Comparison is made with Manchester and Heathrow. More people at risk at Heathrow, less at Manchester. We are not comparing like with like. Both Heathrow and Manchester have two runways, thus four PSZs. Within the PSZ running over Farnborough, there is high density, including a kindergarten and the college, with no empty space. Thus within the crash zone, nothing to miss. Not true at the other two airports. ERM have to cite two major international airports to make a comparison with Farnborough, ie Farnborough with 28,000 movements and lighter aircraft, is in the same league for the number of people at risk compared with two major international airports, ie as many people at risk of being killed at Farnborough as at Heathrow or Manchester. Hardly an act of faith for Farnborough.
If we look in detail at the figures - 2,200 Heathrow, 1,400 Farnborough, 370 Manchester - we can see that if a more realistic assessment is made for the numbers at Farnborough College of Technology, the figure for Farnborough may well exceed Heathrow. Apart from the college, ERM have only counted dwellings, they have conveniently ignored the Kindergarten, the Phileas Fogg travel agency, the Barons BMW franchise, the Swan Pub, and other work/leisure places, the people held at the A325 junction (a situation that will worsen with the bus lane), those waiting at the bus stop. A PSZ also prohibits any major road junction. The figure for Manchester, a major international airport, is an order of magnitude less than Farnborough (even when using ERM's flawed figures).
Why no comparison with Gatwick, another major international airport? Could it be because nowhere near the number of people are at risk at Gatwick?
The comparisons are in any case flawed. Farnborough does not yet have a PSZ. The PSZ has to be drawn for the number and mix of aircraft in 2015, not the 28,000 planned for now. Thus the PSZ will be larger and encompass more people.
But even using the TAG/ERM/NATS 1:100,000 risk contour, it is widely acknowledged that it underestimates the risk thus should be bigger, thus more people at risk.
ERM are careful not to comment on the false definition used by Rushmoor. Residents were sent a letter with a false definition of risk. No attempt has been made to correct this, even though it has been highlighted by several people (and was highlighted and corrected at an airfield consultation panel some years ago). The letter was also misleading in other aspects (see my previous reports).
Statements by ERM highly misleading and false.
The college and kindergarten are close to the centre line of the runway, close to the end of the runway. Other properties similarly at risk are the Phileas Fogg travel agency, the Swan Pub and the Barons BMW franchise.
To introduce the 1:10,000 risk contour is irrelevant and deliberately misleading. The 1:10,000 risk contour should not extend beyond the airfield boundary.
The comparison is with other properties within or near the 1:100,000 contour. Of all possible 'targets' for a crash, those identified above are most likely.
To which we have to add, that of these most probable targets, the people within, as well as in the riskiest location, are also at maximum exposure, as they are there weekdays during working hours, the worst for this is the college before 9am until 9pm. In comparison most households within the PSZ, unless occupied by the house-bound, will be empty for some or part of the day.
In terms of the result of crash, because nothing to miss, would have a couple of houses, with half a dozen dead, through the kindergarten, with a dozen small children dead, to the college with several hundred dead. Of these possible scenarios, a crash on the college or kindergarten is most likely.
No one can live, work or congregate, ie no houses, flats, schools, car parks, playing fields etc. In the long term, all within the zone must be removed as an area not safe. The development already within the zone would not be permitted if it did not currently exist.
The only use of the 1;100,000 risk contour is to draw a PSZ. The PSZ is drawn for the movements and mix in 2015, ie not the current limit of 28,000 movements.
ERM note what happens in the event of a crash. This is not the same as what factors the NATS model accounts for.
NATS model is effectively the damage caused by the physical impact of a crash. Consider a crash on the college, the glass corridor fills with fuel, then ignites. A Boeing Business Jet could have on board 35 tonnes of fuel. Take due note of which councillor is prepared to see kids at the college or kindergarten incinerated.
No account is being taken of injuries.
ERM were asked to do an 'independent' study. To justify their ignoring relevant factors they are now citing previous studies. That is not an 'independent' assessment.
Helicopter movements, topography, and airshow movements are being ignored.
Rushmoor ignore topography because RMC say it is okay to do do so. The RMC study (to verify the NATS study) is okay because NATS have verified the RMC study and say it is okay. RMC are one of the organisations nominated by TAG to take up one of the TAG seats on the Farnborough Airfield Consultation Committee.
ERM were supposedly carrying out an independent review.
It is questionable that Rushmoor have yet met the High Court settlement for an independent review (Parkins v Rushmoor).
Airshow movements are real movements which impose real risk on those who live in the vicinity of the airfield. These movements cannot be ignored because it is convenient for ERM to do so.
Only 300 MoD movements? Does this take account of diplomatic immunity flights? Does it take account of the fact that when Northolt closes (likely if Farnborough ever gets a licence) the traffic will relocate to Farnborough? Is there a ceiling on the MoD flights, or is it whatever MoD at the time decides?
Still true. ERM were asked to give an independent assessment. They appear to be either incapable of of doing so or are refusing to do so.
To claim the NATS model is okay because NATS use it, or that the government has used it (same thing), is to go round in circles.
ERM have not validated the NATS model.
ERM have not validated the input data.
ERM claim there is no reason to dispute the crash rate used. If they have not attempted to validate the data, how do they know?
ERM are simply replicating the NATS model (with errors), feeding in the TAG data, then claiming similar results. This is an exercise in 'are we and TAG capable of feeding the same data into the same model and getting similar results'. It is difficult to see the purpose of the exercise other than to con gullible people.
ERM reject the NLR (ie Dutch) model for precisely the reasons I have stated (see my detailed comments on ERM's main report).
The onus is on ERM to feed the relevant data into the NLR model, and explain any discrepancies. It is only by using an alterative model to NATS that we can have any confidence in the NATS model.
Why has this not been done? ERM were asked to look at the NLR model, not dismiss it out of hand.
In attempting to replicate TAG's work, all ERM have done is drawn risk contours. As explained above, drawing risk contours is not a study of ground safety as no account is taken of the population on the ground.
ERM are correct that they were not asked to look at the issue of ground safety, that is a criticism of the tendering process, but also serves to emphasise the fact that a ground safety study has not yet been carried out. But this begs the question: why was one not requested?
To claim that ground safety is ill defined, is either deliberate deception on the part of ERM or incompetence, either way they were not fit to carry out the study.
A ground safety study is a study of the safety of those living and working on the ground. In the same way that the risk to a nominal hypothetical single individual is used to draw the annual individual risk contours, similar calculations can be carried out to determine the risk to any population grouping.
On the basis of their past work it is disingenuous of ERM to claim ground safety is ill defined. In their list of past achievements ERM claim to have looked at the probability of crashes on oil and gas installations. All that is required is a similar study for residential Farnborough, or did in these past studies, ERM say the problem of ground safety was ill defined?
If ERM are not capable of understanding or carrying out such a study, why were they granted the contract? Or are we back to 'greenwash', ERM are capable of greenwash, but not a competent risk assessment, that far from showing there is no problems, show the extent of the risk to the local population and why the TAG proposals cannot be allowed to proceed?
It is important to emphasise: ERM state they were not asked to carry out a ground safety study, ERM admit a ground safety study has not been carried out.
IN THE ABSENCE OF A PROPER AND COMPREHENSIVE AND INDEPENDENT ASSESSMENT OF GROUND SAFETY THE TAG PLANNING APPLICATION MUST BE REJECTED.
ERM may not have been asked explicitly to compare and contrast the two models (NATS and NLR), but without conducting such an exercise, which ERM admit they have not done, it is difficult to assess the various merits or otherwise of the two models.
ERM fail to understand the difference between a class of aircraft, and a subclass of that aircraft type used in a particular type of operation. ERM are classing executive jets as 'non-airline jets (excluding military)' this does not get us any further forward, and encompasses a huge range, eg freight, maritime patrol, customs, etc. What is important is not the crash rate for a specific type of aircraft eg Lear Jet, but that jet for the type of operation such as Farnborough, which historically for a number of reasons is known to attract a higher crash rate.
In their main report ERM admit that business aviation often has higher crash rates due to operational reasons, then claim such rates would not be applicable at Farnborough. They fail to address this in their response. See my comments on ERM's main report.
For those of us observing on the ground, we see nothing that merits a high degree of confidence in the TAG operation. Recently TAG have been flying in extremely murky conditions.
ERM have still not validated the NATS model, and still are maintaining it's okay because it's the NATS model.
All good con men come equipped with long and impressive lists. Without seeing their 'impressive' work, not possible to comment, but if it is of the same standard as demonstrated here, then it is not very impressive.
Seriously flawed work seems to be the name of the game for ERM. See for example their work on the proposed BP pipeline through Turkey. This work has strong links to the UK government. We are repeatedly told we have to approve TAG as 'government policy'. ERM independent?
ERM's client is a local authority supposedly working on behalf of the local community. This is supposedly part of an open and informed debate, 'consultation' as Rushmoor call it. I was told by Paul Davies (ERM technical director) that ERM had been gagged by planning official Richard Short. Short had explicitly told ERM not to talk to third parties, and furthermore that any such contacts were to be immediately reported to Short.
Is this what Rushmoor chief executive Andrew Lloyd meant when he said the process was to be 'open and democratic'?
See my previous comments and e-mails to Rushmoor chief executive Andrew Lloyd for the extent to which planning officials Richard Short and Daryl Phillips have misled councillors and the public.
As with many people across the borough, I too would like to see an independent inquiry into the activity of the planning department, especially these two officials.
I would also like to see a copy of all correspondence (incl e-mails, faxes, and notes of telephone calls and meetings) since TAG submitted to discharge conditions 16 and 17 of their outline planning consent.
I forwarded ERM a copy of my criticisms of their main report. As they extensively quoted from my report in their supplementary report, I would have expected them to reciprocate the courtesy. But it seems the normal professional courtesies don't apply to ERM.
ERM state this is not built into the NATS model. Correct, but account should be taken with the crash data used.
This contrasts with ERM's claim the operation at Farnborough will be 'safe'.
To unfamiliar conditions and questionable Middle East pilots, we should also add the malfunctioning ILS.
As others have commented on ERM's poor mathematical abilities, I see little to be gained by piling on the agony.
The claimed consultation is not true. I have carried out my own survey. I have found people within the 1:100,000 risk contour who have not been notified, I have yet to find any outside the risk contours, including those whose property adjoins the risk contours. I for example was not contacted on the dubious grounds that I was some way outside!
Why were properties in Mytchett and Church Crookham not contacted? Why were local fishing clubs not contacted? The western end, on the canal, is affected by the 1:10,000 risk contour, a favourite spot for fisherman to congregate. Not even so much as notices placed on the canal.
Why were Hart, Surrey Heath, Mytchett residents association, Church Crookham and Crondal Parish Councils, not notified?
See above detailed commentary on ERM supplementary report (Dec 2002) and previous commentary on ERM main report (Oct 2002).
It is claimed that careful consideration has been given as to the most appropriate model in the current context. Not true. ERM admit this to be not true, and even state they were not asked to validate the models.
Only two models have been considered. The source for the models, TAG. Not exactly an impartial recommendation.
It is claimed the NATS model overestimates the risk. No supporting evidence. ERM (in their main report) made the same assertion, again with no supporting evidence.
It is claimed that ERM have independently confirmed the NATS model as the appropriate model to use. As ERM (see above) explicitly state they have not validated the model (or for that matter compared and contrasted with any other model), this statement is clearly not true.
Reference is made to previous work on topography. Rushmoor were required by a High Court settlement (Parkins v Rushmoor) to seek independent advice. This is previous advice thus not part of that advice. Even worse, this work was carried out by RMC (allied to TAG and occupying a TAG seat on the airfield consultative committee) and subsequently verified by NATS (it is the NATS model ERM were supposed to be 'independently verifying, but have not done so). ERM, have not examined topography. The RMC report looked at safety clearance for the aircraft, it did not look at the issue of ground safety.
All ERM have done, is to feed the TAG data into an approximation of the NATS model. All this does is check the data has been fed into the NATS model, nothing more.
It is also worth noting that the so called TAG study, supposedly undertaken by a third party on behalf of TAG, was in actual fact undertaken by NATS! Presumably NATS also say the NATS model is the most appropriate model.
It is falsely claimed that people do not congregate at the western end. Not true. It is a favourite spot for fishing.
Apart from fishermen, people may only be within the contour for a small amount of time but this misses the point. No third party should be exposed to the 1:10,000 risk. This risk contour (HSE advice for a hazardous operation) should be retained within the airfield boundary.
TAG fail to meet condition 16.
It is not correct to conclude that TAG meet condition 16, as far from not extending into prohibited areas the contour does in fact so extend. But even if this was not prohibited by condition 16 it would be prohibited by HSE recommendations.
On this alone, the TAG application must be REJECTED.
To meet condition 16, TAG would have to reduce the number of movements and/or weight. This would cause the 1:10,000 risk contour to shrink back inside the airfield boundary.
ERM should have been asked to vary the mix and number of movements to discover what operational limits were necessary to ensure condition 16 was met. They were not asked to do so. Why?
It is noted that similar numbers of people are enclosed within the risk contours as Manchester and Heathrow. Or looked at another way, as many people are at risk at Farnborough as at two major international airports (one of which is the world's busiest airport). As noted above, proper account has not been taken of the number of people at risk on the ground at Farnborough, therefore more people may be at risk at Farnborough than at even Heathrow, the world's busiest airport.
The 1:100,000 annual individual risk contour serves no useful purpose other than drawing a PSZ. A PSZ has to be drawn for movements and mix of aircraft in 2015. This has not been done.
Drawing the 1:100,000 annual individual risk contour is not a study of ground safety, as no account is taken of the population on the ground.
No study of ground safety has yet taken place.
NATS and DfT have both told Rushmoor officials that drawing the 1:100,000 annual individual risk contour does not constitute a study of ground safety, that its only merit is for deriving a PSZ (a PSZ is loosely based on the 1:100,000 risk contour for movements and mix of aircraft for 2015). Why is this not being conveyed to councillors? Why are officials still maintaining the fiction that a ground safety study has taken place?
Rushmoor are required to carry out a ground safety study, one that is robust and will withstand scrutiny, to weigh this against other disbenefits and any possible economic benefits (none have yet been demonstrated).
It is worth noting that in the Heathrow night flying case before the European Court, the government were unable to demonstrate any economic benefits for Heathrow, it is therefore ludicrous to try and claim there are any for Farnborough.
The fact that more people are placed at risk of death than at any other UK airport, the fact that a ground safety study has yet to be carried out, this application must be REJECTED.
See also comments above and previous reports.
In the appendix, I am not happy at the summary of the points I have raised. It is claimed the points I have raised are addressed by ERM. As I have shown in some detail, they are not.
I require my reports to be placed in full before the committee, not isolated quotes taken out of context. Failure to do so will be treated as a serious breach of the Human Rights Act.
Control of Development in Airport Public Safety Zones, DfT Circular 1/2002,
Department for Transport, 10 July 2002
Eco-protesters target eco-consultants, UK Indymedia, 4 December 2002
Keith Parkins, Objections to Inspector's Report on Rushmoor Local Plan
(Farnborough Airfield), August 2000
Keith Parkins, Objections to TAG Planning Application (Farnborough Airfield),
Keith Parkins, Farnborough Airfield Judicial Review, UK Indymedia,
4 February 2002
Keith Parkins, Oil and Turkey, Indymedia, 31 August 2002
Keith Parkins, TAG Aviation outline planning conditions 16 and 17,
Keith Parkins, Farnborough Airport: ERM 'independent' report on
TAG risk contours, November 2002
Keith Parkins, Farnborough Airport - consultants 'gagged', UK Indymedia,
4 November 2002
Control of Development in Airport Public Safety Zones, DfT Circular 1/2002, Department for Transport, 10 July 2002
Eco-protesters target eco-consultants, UK Indymedia, 4 December 2002
Keith Parkins, Objections to Inspector's Report on Rushmoor Local Plan (Farnborough Airfield), August 2000
Keith Parkins, Objections to TAG Planning Application (Farnborough Airfield), September 2000
Keith Parkins, Farnborough Airfield Judicial Review, UK Indymedia, 4 February 2002
Keith Parkins, Oil and Turkey, Indymedia, 31 August 2002
Keith Parkins, TAG Aviation outline planning conditions 16 and 17, October 2002
Keith Parkins, Farnborough Airport: ERM 'independent' report on TAG risk contours, November 2002
Keith Parkins, Farnborough Airport - consultants 'gagged', UK Indymedia, 4 November 2002