Click here to view the consultation – Deadline 26 Jan 2018
Parish Councils Airport Association draft response to ‘Your airport: Your views’ consultation
Bristol Airport has identified five ‘pillars’ for its proposed expansion:
| Views of Bristol Airport | Views of PCAA |
| A World Leading Airport Delivering easy and convenient access, excellent on time performance, friendly and efficient customer service, a great range of destinations, state of the art facilities and a distinctive sense of place that reflects the unique part of the world we serve. |
Why do not we want more expansion? Bristol airport is already a leading airport, it has 120 destinations including three European hubs which enable residents and business travellers to go anywhere in the world. If the airport expands the quality of life and well-being of residents in the Chew Valley and surrounding villages will deteriorate. There will be more noise night and day, light pollution, traffic on our roads and car parking on greenbelt land. Aviation’s carbon emissions will increase.
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Employment &supporting economic growth Creating employment and supporting economic growth by connecting the South West of England and South Wales to new markets, talents and tourists.
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It is a myth that the airport is a major driver of the South West economy – Bristol Airport is a leisure airport. Nationally, business travel accounts for only 19% of passengers and at Bristol it is a considerably smaller figure. – Due to technological advances such as automated check in, jobs at the airport are approximately 3,000. In the Master Plan of 2005–2030 it stated nearly 4,000 jobs at the airport at 10 mppa.
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At the heart of an integrated transport network Making Bristol Airport an integrated hub by bringing together different modes of transport, not just for our passengers and staff, but also for people travelling within, to and through the region.
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Why has an integrated transport network not been delivered as promised under the planning consent of 2011 to allow expansion to 10 mppa? Conditions to the planning consent stated that there would be an ‘ erection of 2 multi-storey car parks of four and five storeys north of the terminal building providing 3850 spaces and a transport interchange for buses and taxis with a pedestrian bridge link’. Where is it? This was to be delivered for 8 mppa to save green belt land from car parking. Instead North Somerset Council has rolled over and granted green belt land with the hope that one multi-storey of three storeys will be delivered with 984 spaces. Bristol Airport prefers greenbelt land to building a multi-storey as it’s cheaper. There is considerable financial uncertainty surrounding the airport, as shown in their accounts. The airport is currently unprofitable at the current level of operation after financing costs to construct the airport are taken into account. The consolidated accounts show a net loss for 2016 of £36M, and an accumulated loss of £262M. Of the total revenue of £90M in 2016, £34M was aeronautical income, £27M car park revenue and £26M concession revenue. This shows why they wish to have a near-monopoly on car parking and does not bode well for future contributions from the airport to new infrastructure projects.
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Sustainable approach Seeking to reduce and mitigate our effect on communities and the environment, locally and globally, as well as finding opportunities to deliver enhancements.
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Bristol Airport is the largest carbon polluter in North Somerset and continuing to grow its carbon footprint whilst all other industries need to reduce their emissions to fit within the UK’s legally agreed carbon budget. The airport cannot mitigate the impacts of noise day and night on residents as most residents would prefer to open their windows, sleep at night, enjoy their gardens and have less traffic. If expansion happens there will be noise all day. There will be a substantial increase in air transport movements. The night noise quota point system will be reviewed whilst we already need a reduction in flights at nights. Houses from the 54 dBl noise contour may be devalued. Bristol Airport should mitigate by offering to pay council tax on these properties. Light pollution affecting the dark skies surrounding the Mendips will again be reduced from a new terminal, increased car parking and new infrastructure. The public transport usage to and from the airport remains at approximately 13%. This means that around 87% of passengers to and from the airport still continue to travel by car. New roads and a rail link will further destroy the countryside and affect wildlife especially the bats, a protected species in this area.
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Deliverability Developing proposals which are flexible enough to be delivered in phases to meet demand, and which represent value for money for passengers, airlines and other stakeholders.
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So far Bristol Airport has not delivered on the integrated transport network under phased development to 10 mppa. Note that there is no mention of what is good for the community when delivering the phasing of the development. It is all about profit for a private company that is based in Canada and Australia. The phasing of this development allows Bristol Airport to grow at their convenience without delivering promised conditions, as has happened under the planning consent given in 2011. A rail link will not be delivered in the next decade, even it is affordable (think of Portishead Railway). New roads aren’t going to happen overnight. An option should be considered by Bristol Airport that it has already reached its natural growth limit and is spatially constrained. We demand that an option in the new Master Plan for no further growth is considered by Bristol Airport and North Somerset Council.
A full cost of all negative impacts should be given in the Draft Master Plan which is the next stage, including estimated costs of the infrastructure required.
Likewise the public would like to see all mitigations in the new Master Plan in case BA submits this development as a Nationally Significant Infrastructure Project to the Planning Inspectorate rather than a planning application to North Somerset Council.
The public and residents have a right to know how much public money is to be spent on the developing infrastructure, in order to make an informed decision on whether to support further development at Bristol Airport or perhaps spend public money on education, health and social care.
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Draft PCAA Response
Executive summary:
The PCAA have found it impossible to respond to the consultation due to the lack of information provided because, as you can imagine, parishes have the utmost concern for people and the natural environment. It is our belief that the scale of development proposed can not be mitigated. Our comments are as follows:
The airport consultation document states that more details will be given. The PCAA reserve the right to make an informed comment and comparison of the impacts of the scenarios when detailed information is given by the airport in order that our decision-making process is based on evidence.
The PCAA believe that due to the airport’s location, it is spatially constrained. An option in the Master Plan, that must be considered, is that Bristol Airport has reached its natural growth limits. Please note that the airport was capped at 10 mppa for this very reason: lack of surface access infrastructure. The airport will be aware that no infrastructure improvements are deliverable, even if desirable, until between 2025 and 2035 which will compete for deliverability with the housing developments proposed in the Joint Spatial Strategy.
This consultation completely ignores the local community and its right to know the impacts of the proposed development (in its various phases) compared to the present level of activity at 8 mppa. No negative impacts have been given. The obvious starting point should be that the proposed expansion of 150% carries the threat of a 150% expansion in noise, night and day, light pollution, road traffic, parking on greenbelt land and aviation greenhouse gas emissions. Of course it might not be quite as bad this, if more passengers come by public transport but nothing is certain. No doubt there will be some improvements to noisy aircraft but by referring to a 75 per cent reduction of noise over the last 50 years shows how weak the airport’s case is – any gains in quietness or carbon reductions are outpaced by an increase in aircraft movements. Many civil aircraft have a 25 year operating life so little room for improvement in ground and air noise is expected in the next two decades in fact we shall see a deterioration in well-being for residents. Our concerns range from surface access, ground and air noise, air pollution, loss of biodiversity, climate change, landscape and visual impact and uncertainty over whether the airport can really deliver the economic benefits to the region it is proposing without damaging the local and global environment. A detailed analysis of all our concerns is expected in the Master Plan.
This consultation makes no mention at all of night flights which are the subject of serious public concern. We look forward to a clear statement that there is no intention whatever of increasing night flights, indeed that their number will be progressively reduced
Bristol Airport is framing the discourse of expansion under five pillars with three scenarios on which to comment, but has failed to give any meaningful detail. The PCAA reserve the right to comment at the Master Plan stage on these scenarios once a detailed set of analysis on passenger forecasts, air transport movements, traffic flows, environmental concerns (including the greenbelt and loss of biodiversity) have been given and of course impacts on settlements close by. A full detailed economic report should also be included with a break down of economic benefits. For instance what type of employment is the airport hoping to attract as a strategic employment location?
As no announcement has been made on the mass transit proposals it is extremely difficult to give an informed comment on these development plans without knowing the impact of the mass transit on communities and the environment. The PCAA view this exercise as being premature and will comment when details are made available.
Planning Process:
The PCAA request that the Bristol Airport Master Plan confirms which planning route is to be taken – as a Nationally Significant Infrastructure Project (NSIP) or via a planning application to North Somerset Council.
It is our understanding that, to date, the UK government has not made a National Policy Statement (NPS) on aviation. The revised draft ‘Airport National Policy Statement: new runway capacity infrastructure at airports in the South East England’ is only subject for approval sometime in 2018. There is no NPS for regional airports. NPS have to have parliamentary approval.
The Town & Country Planning Act 2017 requires reasonable alternatives to be given for the proposed development and that these are assessed. The PCAA request that an assessment is made of the demand for flights from Bristol if Cardiff and Exeter airports serve more fully the demand from their own regions, given that they do not have the space constraints experienced at Bristol Airport. If these airports expand they will create growth in jobs and the economy, reducing the figures claimed by Bristol Airport (related to these other regions) and weakening the justification for expansion at Bristol (see page 21). This will give the whole of the South West and South Wales a more balanced economy.
Response to Questions:
Do you have any comments on our pillars?
It is important to remember that Bristol is essentially a leisure airport taking passengers from the UK to spend their holidays abroad. Currently business usage is under 17% (nationally it is only 19%). Heathrow is the main business airport for the UK and will remain so due to frequency and flexibility of long haul flights.
Pillar 1: A World leading Airport:
Bristol Airport is already a leading airport, it has 120 destinations including three European hubs which enable residents and business travellers to go anywhere in the world. It already has enormous capacity to increase business usage without any further expansion at all. If the airport expands, the quality of life and well-being of residents in the Chew Valley and surrounding villages will deteriorate. There will be more noise night and day, light pollution, traffic on our roads and car parking on greenbelt land. Aviation’s carbon emissions will increase. House prices will devalue. Can the airport state why they think residents would want more expansion when they receive all the negative impacts?
Pillar 2: Employment & supporting economic growth:
Bristol Airport is already a successful airport and plays a modest part in the regional economy but it is quite false to pretend that the airport is a major driver of the South West economy. Our main concern is deliverability of the economic benefits to the region as proposed by the airport. Until we view a full economic report we are unable to comment.
Pillar 3: At the heart of an integrated transport network:
Why has an integrated transport network not been delivered, as promised under the planning consent of 2011, to allow expansion to 10 mppa? Please answer this question in the Master Plan. Conditions to the planning consent stated that there would be an ‘ erection of 2 multi-storey car parks of four and five storeys north of the terminal building providing 3850 spaces and a transport interchange for buses and taxis with a pedestrian bridge link’. These conditions should be honoured before any further planning application is considered. A three storey multi-storey car park with just 1,000 car parking spaces is not the same as what was proposed above.
The PCAA believe there will be continued delay in the provision of the integrated transport network as there is considerable financial uncertainty surrounding the airport, as shown in their accounts. The airport is currently unprofitable at the current level of operation after financing costs to construct the airport are taken into account. The consolidated accounts show a net loss for 2016 of £36M, and an accumulated loss of £262M. Of the total revenue of £90M in 2016, £34M was aeronautical income, £27M car park revenue and £26M concession revenue.
The PCAA question the deliverability, even by 2035, of the integrated network system, mass transit proposal and dualling of the A38 as suggested by these proposals for 20 mppa.
No multi-storey car parks are included in the scenarios given. The PCAA requests that multi-storey car parks are constructed rather than more land acquisition for low cost parking on green belt land.
Pillar 4: A sustainable approach:
Where the airport says (p. 24) “We pride ourselves on being a considerate neighbour and limiting our effect on the environment. That’s why we are aiming to be a carbon neutral airport by 2030” and refers its Airport Carbon Accreditation award, it is important to realise that it is ONLY referring to carbon emissions within the airport boundary. The major objection to the expansion of aviation is the large impact on global warming of aircraft in flight. Aviation has a major and increasing impact on climate change as was acknowledged by the government’s Draft Aviation Policy Framework document. This serious problem is passed over in silence in the airport’s consultation document. Significant constraints on growth are essential for the U.K. to stand a realistic change of achieving its greenhouse gas reduction targets for 2050.
Bristol Airport is the largest carbon polluter in North Somerset and is continuing to grow its carbon footprint whilst all other industries need to reduce their emissions to fit within the UK’s legally agreed carbon budget.
Although an agreement has been reached on a global carbon offsetting and reduction scheme for international aviation, it is an offsetting scheme rather than a reduction scheme and subject to controversy. It doesn’t even start until 2020.
Can you explain how international and domestic emissions will fit the UK carbon budget for 2050 and the assumptions you have made?
It is exceedingly disappointing that this consultation has failed to mention any impacts on communities and the environment and how this development will minimise the adverse activities of airport operations. Our concerns range from surface access, ground and air noise, air pollution, loss of biodiversity, climate change, landscape and visual impact.
Question 2. What aspects of the airport experience would you like our future plans to focus on?
The PCAA would like residents to be able to:
- sleep at night without being disturbed by aircraft noise; WHO night noise limits should be formally incorporated into any agreement to allow expansion
- open their windows and enjoy periods of tranquillity in their gardens.
- walk on Felton Common and in woods such as Goblin Combe without being disturbed by aircraft noise.
- stop cars being parked outside their houses and on Felton Common waiting to pick up passengers.
- see dark skies rather than an illuminated landscape.
- cycle along the A38 and Brockley Combe in safety.
- stop their local roads turned into rat runs for airport usage.
Question 3. How important is a successful airport to the regional economy?
This question misses the point. The PCAA believe Bristol Airport is already a successful airport contributing modestly to the regional economy. It already has enormous capacity to increase business usage without any further expansion at all. The critical point is do we want a larger airport? The PCAA do not want more expansion due to the negative impacts on communities and the local and global environment.
Question 4. How could access to Bristol Airport be improved?
Before any road improvements are made Bristol Airport should construct an integrated transport network as promised under the planning consent of 2011 to allow expansion to 10 mppa to be completed.
Until detailed analysis is given on traffic flows on the suggested scenarios the PCAA is unable to give an informed comment.
Question 5. How might we use emerging technology to reduce our impact on the local communities and environment?
There may be benefits from ‘emerging technology’, but effects are notoriously difficult to anticipate. Any expansion proposal should be made on the basis of impacts presently known.
The PCAA do not see aircraft in the next decade becoming significantly quieter. All current aircraft are still noisy but just less noisy than they were decades ago. The PCAA believe that with the increased frequency of aircraft movements any benefits from quieter aircrafts are lost.
Question 6. Is there a case for increased public and private investment in and around the airport?
Private investment from Bristol Airport has failed to deliver an integrated transport network as promised under the planning consent of 2011. Bristol Airport should invest here first without aid from public funding. With public services so much in need of public investment, further subsidies for an already highly subsidised industry should be ruled out.
The PCAA would like to see all costs of new road infrastructure and the proposed mass transit scheme put into the Master Plan. Due to austerity measures communities may prefer to support public funding for the health, education, housing and social care sectors rather than a private company such as Bristol Airport.
The PCAA question whether the proposed mass transit will benefit the wider public other than those using Bristol Airport.
Question 7. Which Scenario best reflects our five pillars and why?
The current planning approval layout of 2011 shows a transport interchange. The PCAA expect this to be delivered before development consent for any new scenario is given.
The PCAA believe that in order to make an informed comment on the scenarios traffic, noise assessment and environmental assessments must be carried out and the results fully published. There are, for example, considerable differences in land acquisition (using greenbelt land on each occasion). If these assessments are to be objective and if their findings are to command respect, they should be at the airport’s expense, but commissioned and carried out independently of Bristol airport. This might be done by using a university department which could be shown to have no commitments to the aviation and similar industries. The for-profit environmental consultants employed by Bristol airport in connection with the previous master plan (2006) destroyed any credibility in their objectivity by uncritically supporting the airport in its public relations propaganda exercises, even to the extent of providing personnel to man stalls at public “consultations”.
Question 8. What information would you like to see presented at the next more detailed consultation stage?
It is essential, at the Master Plan stage, that Bristol Airport confirms the planning route it has chosen (via North Somerset Council or via the national route for infrastructure projects) in order that residents and communities have ample opportunity to comment fully. It is for this reason that the PCAA expect the Master Plan to have more detail and frank explanation of the widely acknowledged negative impacts of this development than did the Master Plan of 2005 – 2030. Our major concerns revolve round the social impacts on residents as well as environmental concerns from surface access, ground and air noise, air pollution, climate change, loss of biodiversity, landscape and visual impact. Bristol Airport is required to show how residents will be affected by this development.
As stated above, the PCAA will provide detailed comments on the scenarios once more information is available and therefore request that the information is provided in a format that includes a comparison of the scenarios. For instance:
- The amount of land use required for A, B and C.
- Forecasts
- Infrastructure proposals
- Safeguarding and land property requirements
- People and the natural environment
- Proposals to minimise and mitigate adverse effects
More specifically, the information provided should include the following which will, at the next stage, be examined in full; all three scenarios should be included alongside the scenario for no further growth:
- Assumptions made on forecasting and growth rates
- Assumptions taken with regard to Brexit post 2019
- Air transport movement capacity of the runway without any capped restrictions
- Air transport movement capacity of the runway capped at 20 mppa
- Air transport movement capacity of the runway capped at 20 mppa with current night time restrictions such as the night noise quota point system
- Air transport movement capacity of the runway capped at 20 mppa without night time restrictions such as the night noise quota point system
- Airspace changes required and any new flight paths
- Aircraft stands required for this development
- A commitment to a reduction in night time flying
- A comparison should be given of the ground and air noise impacts of the Scenarios.
- A commitment that the Airport is not going to become a depot for cargo flights
- Hours of respite from ground and air noise each day for residents
- Conditions to minimise impact on residents and the environment
- Detailed analysis of the employment to be provided
- Ground noise assessments for all scenarios should be made accessible, including aircraft taxiing, revving of engines before take off, engine and braking noise on landing (including the use of reverse thrust). Use of APU’s and GPU’s, vehicular movement
- Car parking and noise from the integrated transport network with the proposed mass transit for all scenarios will be significant and should be assessed.
- Local roads should be subject to detailed assessment of traffic roads in a ten mile radius.
Proposals to minimise and mitigate adverse effects:
The PCAA request that the Master Plan includes an up to date list of the existing conditions. It should show the ones that have been implemented and discharged as well as those not been fulfilled such as the integrated transport network system.
The PCAA wishes to see in the Master Plan a proposed set of new conditions which would be applied, if future planning consent is given to 20 mppa.