RESPONSE
TO
THE EAST MIDLANDS AIRPORT
(RUNWAY EXTENSION)
ENVIRONMENTAL STATEMENT
(AUGUST 2000)
Planning Application No. 9604867
Campaign Headquarters & Press Office
11 Clements Gate
Diseworth,
Derby.
DE74 2QE
Tel & Fax: 01332-812044
CONTENTS
Page
1.
Executive Summary
3
2.
Introduction
8
3.
WINGS Response to Scott Wilson
Environment Statement
12
Chapter 1
Introduction
13
Chapter 2
Development Proposals
15
Chapter 3
Approach to Assessment
21
Chapter 4
Planning Policy
21
Chapter 5
Noise
23
4.
Chapter 12 Vortex Effects and Public
Safety Zones
30
Chapter 13 Summary and Conclusions
35
References
38
EXECUTIVE SUMMARY
1. The WINGS response to the Environmental Impact Assessment Study, carried out
by Scott Wilson on behalf of East Midland Airport, contains a detailed response to the
factors, environmental and otherwise, put forward by Scott Wilson in support of the
Planning Application to further extend the runway by 190 metres.
2. WINGS argues that the very premise of the Scott Wilson ES is fundamentally
flawed insofar as the requirements of both NWLDC and the Secretary of State have
been ignored throughout the document. EMA, at the time of the original application in
1996, were required to produce an ES that considered both the ‘permitted
development’ (the runway extension of 610 metres and completed in 2000) as well as
the ‘proposed development’ – that under consideration in this current ES. That they
have singularly - and deliberately – failed to meet this fundamental and basic
requirement renders their entire hypothesis invalid.
3. In choosing to use the year 2000 as a ‘baseline’ from which measurement of
environmental impact is measured this ES wilfully and cynically avoids the impact of
the permitted development (as this was already in existence in 2000). It also sidesteps
the requirement to measure the impact of the runway length as it was in 1994, when
the first extension was approved. In order to give a true measure of environmental
impact of this application, as originally required, the combined length of both
extensions (800 metres) should have been considered.
4. Not withstanding the above WINGS has prepared a detailed response to the
arguments proposed by Scott Wilson.
5. Scott Wilson argues that the runway extension is small and will have little impact
on total air traffic movements. They contend that the issue is one of ‘payload/range’
only and therefore will have little adverse environmental impact.
6. WINGS agrees, in part, with the former claim but strongly challenges the latter. We
agree insofar as we accept that air traffic movements will not increase very much as a
result of the extension. It follows therefore that the debate surrounding this application
is not about employment. The airport will achieve full capacity whether or not the
extension is granted. Full capacity means maximum jobs. A further extension will not
provide any more – even the airport accepts this. The issues are only and solely about
the environmental impact.
7. We disagree with the claim that the extension is ‘small’. It amounts to some 6.5%
increase in the present runway length but this increase is far more significant than just
190 metres. Not only will it make the airport that with the 3rd. longest runway in the
UK, behind only Heathrow and Gatwick, but it will also generate an aircraft mix that
has been given no consideration by Scott Wilson in this ES. Indeed their thinking is
amazingly muddled and contradictory on this issue, to the point of losing any
sustainable credibility. We contend, in line with the ES, that the issue is one of
payload/range. This will be fully exploited by airlines and the number of ‘maximum
weight’ take-offs that they make will be considerable. This factor is vastly
underestimated in the ES, as is their impact.
8. Maximum weight take-offs represents the noisiest possible. There will be many of
this type and they will generate both considerable noise and considerable pollution.
This issue is simply not addressed in the ES. Nor is it well understood – or even
mentioned by Scott Wilson - that even under the present (Chapter 3) ICAO noise
regulations, larger aircraft are permitted to make more noise than smaller ones. Thus a
Boeing 747-400 (the latest model ‘Jumbo’), whilst quieter than its’ predecessor
(Boeing 747 300 and 747 200), is still a noisy aircraft, albeit that it is Chapter 3
compliant. It is therefore simply not good enough to dismiss this issue, as Scott
Wilson do, by saying that noisier aircraft are being phased out.
9. WINGS disputes the figures given in the ES for air traffic movements and argues
that the ES underestimates the annual number by as much as at least 100,000
movements. This huge anomaly arises because the ES fails to take any account of
national and international trends in aviation over the next 15 years – up to 2016. Scott
Wilson’s forecasts are hopelessly inadequate because they have failed to understand
that air traffic is set to double in this timeframe. Airport capacity in the South East is
now almost full. Heathrow, Gatwick, Luton, Stansted, all have little room for
expansion. East Midlands is a well placed regional with good infrastructure. Indeed,
DETR at the present time, are in the process of producing a revised forecast for UK
growth that is driven by this fact.
10. The overflow from the South East will gravitate towards EMA. A longer runway
will not change this fact but it will accelerate growth and it will mean many more very
large aircraft operating at very heavy weights in to and out of EMA.
11.WINGS disputes Scott Wilson’s calculations on surface transport impacts for
much the same reasons. A failure to understand what will be happening in this
locality, even without the new extension, is grave folly indeed and NWLDC and it’s
Highways Dept. would do well to seek truly objective and independent advice in this
regard, particularly where aviation related surface transport is concerned. The present
road system will soon be hopelessly inadequate for present levels of traffic. The
underestimated impact of traffic with a further extended runway will be catastrophic.
Do not claim that you have not been warned!
12. WINGS disputes the Scott Wilson claim that training flights will remain static.
We contend that training flights will increase substantially. The runway is long and
presently under utilised. Airlines will take advantage of this and indeed are
encouraged to do so by the airport that offer reduced landing fees to this type of
traffic. This practice is not sustainable – particularly as airlines and aircraft which do
not operate from EMA, and therefore contribute nothing to the local economy, will be
imposing their noise on local communities.
13. WINGS challenges the Airports intent to implement any meaningful noise
constraints. The ES contains no substantive detail as to how the airport will
implement or control any noise measures. There are many extravagant claims and
promises but close examination reveals that there is no substance to any of the
proposals. Rather it seems that vague promises are on offer – provided the extension
approval is granted.
14. If the Airport is the good neighbour it claims to be then why has it not already
introduced noise mitigation measures? Why has it not sought to control night noise?
Why has it not seen fit to introduce an engine test noise attenuation system? Why has
it constantly shied away from local consultation? NWLDC must insist that the Airport
demonstrate its commitment to local communities and the environment by publishing
and implementing its noise policies prior to any application being approved. Such
policies must be transparent and open to public consultation and approval prior to
their being accepted. A good neighbour would have already done this anyway.
15. We believe that the fact that National Express – the present owners of the airport –
are currently endeavouring to sell EMA is material to the manner in which they have
approached this ES and in the manner with which they treat any effort to curtail noise,
particularly at night. A major benefit to any airline using EMA is the fact that there
are no night flying constraints. This has had a major bearing on freight movements at
the airport and is particularly attractive to a potential purchaser. It is not in the best
interests of National Express to encourage its airport company to enter into voluntary
agreements that adversely impact any potential sale price. An airport with the third
longest runway in the UK and with no night noise constraints is very attractive. The
airport will simply not move forward on these issues on a voluntary basis. When
forced, the airport will introduce policies that are the minimum that they believe that
they can get away with. It’s a commercial game to them. To the local communities the
prize is their environment and their quality of life. NWLDC should not lose sight of
this fact.
16. As with our response to the Stanger ES (Jan 1999), we remain greatly concerned
with the safety issues raised by wake vortex incidence and the treatment of the Public
Safety Zones. The Scott Wilson proposal to move the landing point of the runway 150
metres away from Kegworth will have no material effect on mitigating against wake
vortex damage. We contend that these incidents, which are already set to rise
significantly with the current runway length, will be made much worse with a further
extension. Not only will moving the runway threshold be ineffective but also the
extended runway will encourage even more of the larger ‘wide body’ type aircraft – it
is the size of aircraft that is relevant to this issue, not the type.
17. Scott Wilson themselves acknowledge in the ES that the Public Safety Zones are a
function of the number and size of aircraft taking off and landing. Given that the
runway extension will generate larger aircraft, at heavier weights than are presently
permissible, they go on to say that no study is required to review the PSZs. This is of
great concern and should not go unchallenged.
18. The Summary and Conclusions of the Scott Wilson ES merely serve to underline
the weakness of the document and the failure of the Airport to make any real effort to
recognise, explain, address and deal with the issues that are generated by this
application.
19. WINGS believes that the forecasts, the arguments and the proposals put forward
by Scott Wilson in this ES are wholly inadequate and significantly inaccurate. The
baseline, traffic forecasts and conclusions drawn by Scott Wilson greatly underplay
the adverse impact of the proposed extension.
20. NWLDC have no recourse other than to reject this document, and with it, the
planning application to extend the runway by a further 190 metres.
21. No further application to extend the runway should be considered until EMA and
its agents have produced an ES that properly addresses the issues raised in this
response, particularly the following :1. Accurate air traffic forecasts based on internationally accepted growth forecasts
should be the basis of calculations.
2. An accurate forecast of the traffic mix should be determined and applied.
3. An accurate forecast of ‘maximum weight’ take-offs should be determined and
applied.
4. The impact of National UK growth – and its’ effect on EMA – should be
determined and applied.
5. An independent and objective study of the wake vortex and PSZ issue should be
determined and a proper resolution achieved.
6. A detailed, transparent, effective and enforceable noise policy must be articulated
and included.
7. The requirements of the Secretary of State to include the permitted development
must be used as the baseline.
22. We contend that any objective Environmental Impact Study that utilises these
criteria will demonstrate that any further extension of the runway at EMA is
unwarranted. A further extension will have adverse environmental impacts that very
significantly outweigh any marginal trading benefit that the airport or the airlines
might derive.
23. If the airport operators believe that a further extension is imperative to their
business case then they must understand that they have an obligation to generate
mitigating policies that have material meaning and effect within the locality. The
airport, with the encouragement of NWLDC, irrespective of any planning application
that it wishes to submit, should at the very least, in any event introduce the following:1. Provision of night movement quotas that are derived from consultation and
agreement with local communities, with a provision for review.
2. Implementation of sanctions on operators who violate noise restrictions. The
proceeds of which are dispersed to local communities by a panel independent
from the airport, and constituted from local communities.
3. Adequate provision of ground running engine bays and regulations, acceptable to
local communities, governing engine running operations.
4. Adequate road traffic provision, including an internal road from J23A into all
areas of the airport.
5. The introduction of Noise Preferential Routings, as well as noise abatement
procedures on departures.
6. Curtailment of the unnecessary running of APUs and the provision of fixed
electrical ground power for aircraft.
7. Regulations to minimise the reversing of commercial vehicles at night.
8. Use of only reverse idle/pitch – commensurate with safety – to be used on landing.
9. A scheme to provide effective sound proofing for properties affected by noise,
including roof sound insulation.
10. A binding undertaking by the airport and NWLDC that the runway 09 threshold
will not be moved further west at a future date.
11. Reconstitution of the Airport Consultation Forum to give proper representation to
local communities.
12. An end to the scheme that offers rebated fees for training airline traffic and an
embargo on the provision of training facilities to military ‘fast jet’ aircraft.
13. A commitment by the airport to operate a ‘good neighbour’ policy to include full
transparency of all matters relating to, and affecting, local communities.
24. Only very recently (reference Lord McDonald, 2000) Minister of Transport,
determined that the significant issues that encompass airport environments should be
resolved by consultation between the airport operators, local councils and local
communities. Failure to heed this statement is likely to bring significant
consequences, in this case, to NWLDC and EMA. There can be no doubt that the
local communities are prepared to play their part. So too, should be the Airport and
NWLDC
INTRODUCTION
INTRODUCTION
25. It may seem ‘prima facie’ that the planning application to extend the runway at
East Midlands Airport by an extra 190metres is a straight forward matter. WINGS,
however, does not take this view, rather we set out our response to the planning
application and its accompanying Environmental Impact Statement (ES) to show that,
within the context of extant policy and the soon to be determined National Airport
Policy, there are significant reasons to refuse this application. It is also important to
place this application in the historical context of runway development at East
Midlands Airport, where we shall argue that there has been a cynical attempt to ignore
public opinion, avoid consultation with local groups and to manoeuvre around a
planning process which requires the developer to account for the impact of 800m - not
190m - of new runway build.
RECENT HISTORY
26. The current application to extend the runway at East Midlands Airport (EMA) by
a further 190m, to achieve a total length of 3080m, follows after a period of almost
two years since the previous application for this extension was put before North-West
Leicestershire District Council in December 1998.
27. During this time a major new freight development has been completed for DHL
and the runway extended by 610m under permission granted in 1994, to bring it to its
present length of 2890m.
28. The significance of this latter development is not that it has been allowed to take
place, which may have been seen by reasonable people as beneficial to the local
economy, but that it has been permitted without an environmental assessment and
without any conditions attached.
29. The 1998 application required the developers to account for the cumulative
environmental impact of both 610m (permitted) and 190m (proposed) extensions. The
application remains undecided after the developer asked for it to be ‘set aside’
because there was no resolution to important questions of environmental impact
arising from statements in the accompanying environmental impact assessment.
Permission, however, had been granted for the 610m extension without any conditions
being placed upon it that would ameliorate its environmental impact. That part of the
runway has now been constructed.
30. The opportunity, therefore, for conditions or restrictions to be placed upon the
Airport’s operations, particularly on night flights, which could have accompanied a
planning consent, has been denied those people who will now suffer from the
increased commercial activities of the airport. The environmental impact, it is
important to re-state, would have been calculated for a total of 800m of runway build.
31. The new application, according to NWLDC, does not require the developer to
provide an environmental impact assessment that would account, retrospectively, for
the 610m of runway already constructed.
Thus, we have the situation where 75% of 800m of new runway build has no
environmental impact assessment which, in theory, amounts to stating that it
contributes nothing adversely in impact upon the environment. This obviously is total
nonsense!
32. It is on this basis that the Scott Wilson Kirkpatrick & Co Environmental Impact
Assessment (EIA) has been undertaken.
33. Of overriding importance in the construction of this ES is the deliberate and
premeditated thwarting of the requirement of the Secretary of State’s determination
that the 1998 application for the additional 190m extension should be preceded by an
ES that considered both the permitted (610m) extension as well as the proposed
(190m) extension.
34. In reality the impact of this additional 190m of runway has more significance than
it would have had if the previous 610m of runway, new build, had been subject to an
environmental impact assessment. This point is vital to bear in mind when considering
the new planning application.
35. There are other important aspects of policy and current plans for airport
development that also need to be considered with this application.
THE COMMERCIAL VIABILITY OF EAST MIDLANDS AIRPORT.
36. The runway, at present, with its recent 610m extension brings the total to a length
of 2890m, the sixth longest runway in UK. This permits a wide range of aircraft,
including Boeing 747’s, amongst the largest wide-bodied aircraft in service
throughout the world, to use EMA.
37. Aircraft can now reach the United States and other destinations of equivalent
distance throughout Europe, Africa and Asia, directly from EMA. Refueling at these
destinations allows for onward flights to even further destinations with the advantage
of additional freight opportunities of loading and off-loading. What advantage does an
extra 190m of runway present to the operators?
38. It permits aircraft to fly further and carry heavier loads. There is, therefore, going
to be a very significant commercial advantage gained by an extra 190m of runway
compared to the extant runway, where the Airport is destined to be receiving and
dispatching significant numbers of wide bodied jet freight aircraft; not as that
understated in the ES.
39. The extra 190m would bring the total runway length to 3080m, allowing EMA to
claim the third largest runway in UK after those at Heathrow and Gatwick.
40. It appears that the planned development is targeted at creating a major freighthandling airport to give it top European freight league-table status. The threatened exit
of DHL from European airports, particularly Brussels, because of imposed sanctions
on night flights, makes the manoeuvres for an extra length of runway at EMA even
more critical in DHL’s development plans. In these terms the commercial advantage
then becomes significant and would be acceptable were no other factors to come into
play.
41. There is, however, a cost in environmental damage. A huge cost which Brussels
has already paid for in terms of noise, night flights, air and water pollution. This is the
same currency that EMA is currently allowed to extract from those communities who
live within its compass. Moreover, this cost is set to increase.
42. It should also be well understood that there is no benefit in this application for
additional employment. Even Scott Wilson have been wise enough to recognise this
fact in their ES. The debate on this application is confined to environmental issues
only. The developer’s arguments in favour of the further extension are restricted to
payload/range matters only. These benefits will have no effect on job creation but will
have very significant environmental disbenefits – all of which are greatly understated
by Scott Wilson in the ES.
WINGS RESPONSE
TO
SCOTT WILSON
ENVIRONMENT STATEMENT
Chapter 1
INTRODUCTION
Background
1.2 ‘…Additional runway length will allow slight increases in permitted
aircraft take- off weights..’
The use of the word ‘slight’ in this context is misleading. 190m represents an increase
in TODA (take-off distance available) of 6.5%. Whilst accepting that aircraft
performance capability is not strictly linear, this increase in runway length will allow,
even so, an increase in gross weight to a Boeing 747 of close on 25 tons. Even Scott
Wilson cannot claim that this is ‘slight’. The increase in noise and environmental
issues such payloads will generate are considerable.
Planning History
1.4 Scott Wilson fail to take note that the Secretary of State required that the ES
should take account of ‘…the cumulative effects of both the permitted and proposed
runway extension schemes..’ This duty has not been discharged, thus rendering the
entire document flawed.
1.5 ‘…The 1998 ES raised a number of issues, mainly related to noise and
air quality effects…’
This is incorrect. We submit that the 1998 ES was wholly flawed, inadequate,
inaccurate, misleading and fell short of properly addressing many more concerns than
just noise and air quality. The inability of East Midlands Airport and its agents to
properly respond to the many areas of concern raised, led to the application remaining
undetermined.
The EIA Regulations
1.7 ‘..Since the proposed runway extension at EMA will not change greatly the size of
the aircraft or the number of air or road traffic movements, it was considered that
significant environmental effects were unlikely to result..’
This statement is not only simply not true (and neatly side steps the Secretary of
State’s fundamental requirement for the ES to consider both the proposed runway
extension (190m) and the permitted extension (610m) that was completed earlier in
2000), but also demonstrates the best use of weasel words.
It is not true because it is a false assumption to claim that the proposed extension will
have little environmental impact. The fact is that the extension will make the runway
the third longest in the UK. Further, it is now stated Government policy to develop
regional airports. These factors alone, coupled with an annual growth rate in the
aviation industry of some 6%, mean that the future growth of the airport will be
expediential and that the environmental impact will be cataclysmic if uncontrolled.
And this takes no account of the disproportionate expansion of the airport as a freight
hub nor of the fact that the airports in the South East are all close to saturation and
that future airline growth will fall to regional airports, of which EMA is a premier
player.
It is weasel words because it ignores the requirements of the Secretary of State, it
ignores the impact of large aircraft operating at greater weights and it ignores the
impact of surface traffic required to feed these aircraft and their greater capacity.
The EIA Process
1.8 ‘Opportunity for public scrutiny’ is not a factor that East Midlands Airport is wise
to highlight. Their record on such matters is nothing short of woeful.
Scope of Assessment
1.12. If the Airport is to boast about ‘public scrutiny’ why is it that the forum
convened to construct the Scoping document did not include one single representative
from the local communities? Further, why did NWLDC also see fit to exclude
representation from the local communities in the consultation process, particularly
given the strong and informed representation that local community bodies had made
to the initial ES?
It is noted that Scott Wilson have been exceedingly economical in detailing the
participants involved in the construction of the Scoping document. This body, with
the stroke of a pen, eliminated the existing 610m extension from any consideration.
Such arrogance cannot go unchallenged.
The Scoping document underpins the entire ES and East Midlands Airport can surely
not have been ignorant of its’ make up. The decision to exclude the existing 610m
extension can only have been a deliberate, premeditated and cynical attempt to avoid
having to answer any real pertinent issues arising from the impact of the extensions –
as required by the Secretary of State.
Indeed, this decision leads one to ask if the proposed extension was ‘set aside’ simply
to allow the permitted extension to be completed before the proposed extension was
re-submitted, precisely to allow this approach to be adopted?
Further, the exclusion of the existing 610m extension from consideration in this ES
flies in the face of the requirements of The Town and Country Planning (Assessment
of Environmental Effects) Regulations1988/94, Town and Country Planning
(Environmental Impact Assessment) Regulations 1999, Directive 97/11/EC and the
requirements of The Secretary of State. Thus it renders the entire ES invalid.
1.13..land uses within and around…the airport ..will remain largely unaffected by the
proposed runway extension..’
We take grave exception to this statement. We have already seen very significant
development on and around the airport. Not only do we now have three additional
roundabouts and a veritable forest of traffic lights where none existed twelve months
ago but we also have a business park (Pegasus) on airport land that is housing
business that is not airport related. One can argue that the road schemes improve
traffic flow (which, in fact, they do not) but it is not defensible that development on
the airport, which is not airport related, should occur.
The airport is presently squandering its family silver. The fact is, even without the
proposed extension, the airport will grow very substantially over the coming years for
the reasons given in 1.7 above. There will be a pressing requirement for more terminal
space, car parking, aircraft apron parking, maintenance facilities, ground running
noise attenuation area, etc., in the foreseeable future. That capability is being lost to
non-related development at the present time. NWLDC would be derelict in its’ duty
were it not to guard against this trend. It will not be long before the Airport is pressing
for development outside its’ present boundaries because it is hemmed in from within.
What will happen to the local environment and the local communities then? And what
proposals will NWLDC support when this happens – as it surely will unless due
diligence is employed with immediate effect.
The Environmental Assessment Team
1.17..The ES draws considerably upon information presented in the 1998 ES prepared
by Stanger Science and Environment..’
Scant comfort should be drawn from this statement. The 1998 ES has already been
shown to have been flawed, was shown to be inadequate and was not accepted by
NWLDC.
Chapter 2
DEVELOPMENT PROPOSALS
Ownership
2.10 It should be noted that the Airport is now offered for sale by National Express.
In the seven years since its purchase National Express have invested heavily in airport
infrastructure; new terminal, new control tower and longer runway. They now plan
further investment in yet another runway extension. And yet what investment has
there been in local communities or the environment by either National Express or
their Airport Company? There is still no night flying policy. There is still no
enforceable noise policy. There is still no ground running noise attenuation system.
There is still no proper local consultation. In short there has been next to nil
consideration given to environmental issues and even less investment in this area.
There can be no doubt that any potential new owner will be equally aggressive in
protecting its trading position at the expense of local communities and the
environment.
Airport Growth.
2.11. ‘…1995, 1.9 million passengers used the airport….1999, increased to
2.22million...’This represents an increase of 12% over 5 years.
2.12 We doubt that there is any sinister intent here but it should be noted that the
Airport has never been a ‘pure cargo airport’. Much of its income is derived from
passenger traffic.
The Proposed Runway Extension
Landing Threshold
2.18 Scott Wilson do not specify how far West the threshold of Runway 27 will be
moved here but table 2.1 states that it will be 150 metres.
2.16 *(1) ‘..Aircraft are at greater heights over any population centre…including
Kegworth’
This statement is utterly meaningless. The approach will remain as a 3 degree glide
slope. A 150 metre displacement of the threshold represents an increase in height over
Kegworth, or any other point on the approach, of 24ft. This is so insignificant in the
context of any relevant parameter, be it noise or vortex, as to be of absolutely no
benefit whatsoever. To argue otherwise is to decry credibility.
*(2) ‘..Runway utilisation times are reduced as the aircraft land nearer to exit
taxiways..’
This statement is absolute nonsense. Runway occupancy is a function of many factors.
The repositioning of a threshold is categorically not one of them. The most significant
factor in runway occupancy in the context of airport design is the positioning of the
exit taxiway and it’s angle relative to the runway itself. At East Midland Airport the
exit taxiways are a sad accident of history and contribute nothing to runway
occupancy. In fact, as they stand, they positively hinder runway efficiency, create
greater noise and add to air pollution.
*(3) ‘..Aircraft land nearer the centre of the airport.’
This is true. They will also, for the same reason, apply reverse thrust further down the
runway thus carrying noise further toward Castle Donington and Diseworth. There is
no net improvement here. Kegworth might benefit (except they will have already been
woken up by the aircraft as it flew overhead) but Diseworth, Isley Walton and
Donington will suffer more. In any event 150 metres will have no discernible effect,
the argument is cosmetic only.
Air Traffic Forecasts
2.32 ‘…It is common practice for noise impact assessment at airports to consider the
92 day summer period..’
It may be common practice but it is irrelevant in the case of East Midlands as there are
no restrictions whatsoever on flying activities. All other UK airports of similar
runway length – Heathrow, Gatwick, Birmingham, Manchester, Stansted – have
enforceable noise restrictions and a formula for restrictions to night flying.
East Midlands has no such constraints. Further, no other UK airport has the
combination of both a significant freight hub and a significant Post Office hub. Both
are night operations and both are less prone to seasonal fluctuation than passenger
traffic. Common practice and convention cannot therefore be applied as the scenario
at East Midlands is unique. It is very clear that expansion at East Midlands Airport
will outstrip all forecasts contained within this ES. The ’92 day summer period’ is
therefore not relevant.
Implications of the Runway Extension
This section should be read bearing in mind Scott Wilson's statement in chapter 1
(1.7), which states ‘since the proposed runway extension will not change greatly the
size of aircraft or number of air movements….significant environmental effects [are]
unlikely to result.’
2.34 then goes on to list 5 ‘wide bodied’ aircraft which will find solace in the
additional extension. No significant environmental effect – can they be serious?
Not change greatly the size of the aircraft – This might be correct, but it will change
significantly the weight at which these aircraft operate.
2.35 lists 11 new destinations and acknowledges the potential of many more.
This will not change greatly the number of air movements – can they be serious?
2.36 argues that, as full payload will not always be carried, additional fuel will allow
further range. It then gives examples of destinations such as Bangkok and Hongkong.
Scott Wilson confirm then, that fuel will make up any shortfall in payload available to
achieve maximum take-off weight. Yet significant environmental effects are unlikely
to result – can they be serious?
Further, it follows that if more fuel can be loaded to reach further destinations with
the same aircraft, it is equally true that these same aircraft can carry more freight to
closer destinations, thus still achieving max. take-off weight which generates the
noisiest departures possible. Yet they claim significant environmental effects are
unlikely to result – can they be serious?
And this is only the freight element of the operation.
2.37 Here 7 ‘wide body’ aircraft are listed for passenger operations.
‘..All of these aircraft will need the longer runway to operate at maximum payload
range..’ we are told. But yet again in chapter 1 Scott Wilson claim that the new
extension ‘ will not change greatly the size of aircraft …[and] significant
environmental effects are unlikely to result’ – can they be serious?
Scott Wilson state ‘..All of these additional movements are assumed to occur over the
period 0700-2300 hours..’
They are again incorrect. It may be that most such movements occur during this time
band at other UK airports but this is only because night flying restrictions exist. No
such restrictions apply at EMA. Operators will take advantage of this fact to improve
utilisation and it will be a full 24 hour operation. Because of time zone changes with
East/West routes long haul aircraft from outside Europe routinely arrive in the UK in
the early hours of the morning. The bulk of these aircraft would arrive between 02000600 hours if left unchecked.
2.38 Scott Wilson argue here that 2 scheduled night freight operations will be
generated by 2016.Yet in 2.35 they list 11 new destinations! Presumably the rest will
be day time flights? In Chapter 5.5 they say that very few additional flights will be
generated. This is either muddled thinking, or naïve or both. In any event it
significantly underplays the reality of the development that will actually occur.
Passenger Forecasts
2.39 Appendix B details the methodology of traffic forecasts. Figures are based on
DETR projections from 1997. DETR has recognised that these forecasts are out of
date which is why their forecasts are currently being revised. Total UK traffic has
grown 15% in the intervening 3 years since 1997. The figures used by Scott Wilson
are therefore meaningless and take no account of the situation in which the Airline
industry finds itself in to-days environment. Further, the baseline used by Scott
Wilson takes no account of Government policy – as detailed in the present Transport
Bill – to encourage regional airport development on a sustainable basis.
The ‘with runway extension’ and ‘without runway extension’ scenarios are too
speculative as to have any meaning. Scott Wilson argue that the extension is a
payload/range issue only. In fact it is much more than that. What is at stake here is a
very significant aircraft mix issue and the noise and environmental problems that stem
from the maximum take-off weight departures that this extension will generate.
The issue that the ES fails to address is how many ‘wide body’ max. weight
departures will occur if the new extension is allowed? The answer is a considerable
number and this is compounded by the fact that many will be in the ‘unsociable hours’
band.
Air Freight Forecasts
2.41 The same comments apply here as above.
Aircraft Movement Forecasts.
2.45 The methodology here is again fundamentally flawed for the reasons given in
both 2.39 and 2.32 and hugely underestimates growth.
The fact is that on a national basis, by far the greatest demand for air transport is in
the South East. The airports in the S.E. are now all but full – Heathrow, Gatwick,
Luton and Stansted have little or no further potential to contain expansion, even over
the next 3 years. There is no chance of a new runway in the South East, it just won’t
happen – it’s politically too difficult.
Regional airports will therefore increasingly take the overflow from the S.E., as well
as growing to meet local demand.
Gatwick now schedules 48 movements per hour – and achieves this throughput.
East Midlands has the same potential, and there is no reason to assume that it too, will
do otherwise than reach this level of operation.
The only question is:- When? All projection forecasts, be they the European
Commission PRC (Performance Review Commission), Eurocontrol, ICAO
(International Civil Aviation Organisation), or the UK CAA (Civil Aviation
Authority) recognise that air traffic is set to double over the next 15 years. There is
nowhere for this traffic to go other than to regional airports.
East Midlands is a ‘premier’ regional and will gain as large a part of this traffic as it
can handle. East Midlands is therefore set to achieve maximum throughput within the
16 year timeframe projected by Scott Wilson in this ES. The projected annual growth
rates of 2.5% and 5% for passengers and freight forecast by the ES is woefully
inadequate.
Even if EMA can only manage 40 movements per hour because of ground
infrastructure constraints, this means that by 2016 the airport will handle some
233,000 movements per year (assuming that operations are confined, by then, to
0700-2300 hours. If not numbers will rise commensurate with night operations) and it
will need not one more inch of runway than it presently has to achieve this. This is
more than 100,000 movements per year greater than the forecasts by Scott Wilson!
2.46 ‘Other aircraft movements are therefore assumed to remain constant at 1999
levels up to 2016’.
This is another incorrect assumption. The runway is now already 2980 metres long
and is greatly under utilised. Both these factors are very attractive to airlines looking
for training capacity. When, as is true at EMA, large discounts are given to airlines on
charges for training flights – and there is no landing charge raised at all for goarounds – then it is obvious that EMA will be used frequently for airline training
flights. We already have examples of Cathay Pacific (Boeing 747), Airtours (Airbus
A330), Virgin (Airbus A340) and easyJet (Boeing 737) using the airport for this
purpose. None of these airlines operate these aircraft from EMA and yet local
communities have to suffer their endless ‘circuits and bumps’. The long runway
attracts this activity and a longer runway will attract even more. To argue that this
activity will remain constant is more nonsense.
2.47 shows annual aircraft movement tables and is invalid for the reasons already
stated above.
2.49 shows tables for average day and night movements. Again it has no validity
except to demonstrate that, by including night movements, it is clear that the Airport
has not the slightest intention to voluntarily introduce any meaningful night operation
constraints.
However, let us examine these tables and ‘correct’ the figures shown to reflect full
capacity at the airport – for the reasons given in 2.45. The table 2-6 shows daily
movement rates increasing from 282 to 290 by 2016 if the extension is built. This
represents a 3% increase. With full runway capacity utilised this figure grows to 19.
Scott Wilson themselves argue that the additional length is specifically designed to
allow max. weight departures – the noisiest take-off operation possible. And at the
same time they claim there is no significant environmental effect! Their muddled
thinking is further amplified when one takes account of the statement in 2.37 where
they say that all long haul passenger aircraft will need the longer runway whilst they
show, in these tables, that a total of only 12 will use it, including freight!
Table 2-7 shows night-time movements. The same reasoning as above changes the ES
figure of 4 (5%) to 16 movements. All at night and all the take-offs at max weight.
That is two movements per hour, every hour, all night long and in addition to another
potential 38 movements per hour – many of which will also be at max. take-off
weight! How much sleep will any local resident achieve?
Road Traffic
2.51..Since the runway extension will have fairly minimal impact on the level of air
traffic, it follows that the effect on road traffic will be limited..’
2.52 Again this is not correct, for the many reasons already given in the comments
above.
The ES then compounds the error by declining to include a Transport Impact
Assessment!
Table 2-8 shows Additional Airport Related Road Traffic and shows an increase of
2,900 daily movements by 2016 if the extension is built – presumably relating to the
additional 12 aircraft movements detailed in 2.49 where the ES claims that only 12
additional movements will be generated.
This works out at 242 road traffic movements for each additional aircraft. By the same
logic, when the airport reaches maximum capacity and the runway extension creates
the additional 19 day and 16 night aircraft movements calculated, additional road
traffic movements will rise to 8,470. (and this is only an extrapolation of the Scott
Wilson figures for ‘heavy’ aircraft operations and takes no account of ‘other’
movements!)
This is a very significant number in it’s own right (one vehicle every 10 seconds for
24 hours every day) and is not manageable with the present infrastructure. But the ES
says that ‘..the effect on road traffic will be limited’.
2.53 ‘…Table 2-8 shows….the increment would be far less than 10% ..’
Our calculations show that the increment will be closer to 30%.
Alternatives
2.57 ‘..In relative terms this alternative configuration offers a number of
improvements as described in paragraph 2.19..’
This statement cannot be sustained. Our response to para. 2.19 clearly demonstrates
that the claims made have no substance.
Chapter 3
APPROACH TO ASSESSMENT
EIA Scoping
3.9 Given that both EMA and NWLDC were both well aware of local communities
interest and concerns – vis. the responses received to the first ES – why were no local
community representatives included in either the Scoping construction process or the
consultation process?
Technical Scope
3.10 The content of this particular ES, in addition to Town and Country Planning
(Environmental Impact Assessment) Schedule 4, was also determined and directed by
the Secretary of State.
The omission of the requirement to include both the permitted development and the
proposed development from the scope of the ES is in direct breach of those
requirements and renders the ES invalid and misrepresentative.
Temporal and Spatial Scope
Assessment Scenarios
3.24 ‘..The baseline year is taken as 2000 and it is against this date that any changes
due to the proposed runway extension will be assessed..’
This baseline is challenged very strongly. It is nothing more than a concerted and
cynical attempt to abdicate from the requirement placed upon EMA to produce an ES
for the permitted development as well as the proposed development. As has already
been emphasised, it renders the entire ES open to ridicule and leaves it devoid of any
credibility.
3.25 This statement is open to the same comment as 3.24.
Chapter 4
PLANNING POLICY
It is notable that the ES makes reference to “The Emerging District-Wide Local Plan”
4.32. as a document to which considerable weight can be attached. By the same token
an even more significant document, which has reached the Inspector’s Report stage, is
that of the new Regional Planning Guidance. Changes following the Inspector’s
Report will be available for consultation post the Secretary of State’s reading in
January 2001. The final document will have a defining influence upon both Structure
and Local Plans and will bring revisions to both documents.
With respect to EMA in particular it is important to make reference to paragraph 9.70
page 84 of the Report (2000),
“…there is recognition of the important role played by EMA in the regional economy,
not least in employment terms, On the other hand there is widespread concern about
its environmental impact, especially the noise of uncontrolled night-time flying over
residential areas, and more explicit policy guidance about how the effects of any
future expansion should be assessed is sought. Another important issue raised is how
the strategy for surface access to the airport should be developed.”
Perhaps more importantly is the statement under paragraph 9.74
“As the draft Guidance affirms, EMA has expanded rapidly, with dramatic growth in
airfreight in recent years. For various reasons associated with the planning history,
this growth has taken place in a framework which does not impose any restriction on
the size of aircraft that can use the runway or on the number or timing of aircraft
movements to and from EMA. Voluntary agreements have addressed some of the
concerns that have arisen from the recent growth, but great care should be exercised
in the future. The sustainability appraisal of the draft Guidance identified that there is
potential for incompatibility between Policy AT1 and environmental objectives. We
have no doubt that the need to minimise the environmental impacts of any future
development should be explicitly considered in RPG.”
AND 9.76
“RPG should make explicit that the sustainability assessment of proposals for
operational expansion of EMA should consider the impacts on the local environment
in terms of noise, air quality, water quality, human health, landscape, biodiversity,
natural resources and cultural assets, together with the effects on social and
economic factors, as well as wider, global considerations. These impacts should be
tested against the sustainable development objectives of RPG, and the assessments
should be subject to public consultation.”
The failure of the Airport’s Independent Consultative Forum and other airport
consultative committees to address noise issues is well documented (See Minutes of
EMAICF and attempts by WINGS to raise noise agenda items). It is also generally
acknowledged by environmental groups, AEF in particular, that airport consultative
bodies, set up by airports and administered by airports, avoid consulting with airport
neighbouring communities who are most damaged by their pollution.
This greatly devalues the concept of ‘consultation’ and makes the notion of
‘independent’ meaningless.
There are other significant policy measures in the pipeline which will have a profound
affect upon regional airports and their development and should be borne in mind both
in terms of their national and local impact for EMA. It seems premature to address
such a major development as the runway extension before these important matters
come to light in the very near future.
The Consultation Paper for the National Aviation Policy is due on 12th December
2000. It would make good sense therefore, should there be a resolution to this
planning application, before the publication of the National Aviation Policy, to build
in safe-guards and codicils which can be the basis of conditions for granting planning
permission.
These would reflect the anticipated Policy along with those conditions which are
called for by local communities to safe-guard their quality of life.
Locally we await the onset and results of multi-modal studies to be carried out by
DETR wherein congestion and safety problems on the A453 (M1 to Nottingham) and
congestion problems on the A42/M42 will be addressed. Traffic to and from EMA
will have its impact upon these road systems. This point was acknowledged by
Inspector Moxon in his Report on Objections to the Deposit Draft NWL Local Plan
(1998) when he recommended the following:“East Midlands Airport is currently accessed by the single carriageway A453 road,
which joins the M1 motorway –via Finger Farm roundabout at junctions 23A and 24.
If all the development in the vicinity of the airport this Local Plan envisages proceeds,
the capacity of both this section of the A453 and these motorway junctions will be
exceeded.
The highway safety and traffic implications of developing additional passenger or
freight capacity at East Midlands Airport will therefore need particularly careful
consideration.”
These references generate a number of questions relating to the statement in para. 4.37
of the ES, page4/7, where the use of a dedicated bus service between a possible new
station and the Airport by means of existing and proposed high quality road links is
discussed. There’s already a dedicated bus service from Loughborough station and it
is grossly under-used – why have another from an as yet un-built station? Where are
the proposed high quality roads to be built and who is footing the bill? Would it not be
more in line with Government policy to move traffic off the roads altogether and to
have a direct rail link into the Airport?
Chapter 5
NOISE
Introduction
5.5 *(1) ‘ a small increase in runway length, less than 7%’
7% is not a ‘small increase in runway length’ - by anyones standards. It represents a
very significant financial investment and it will move the runway from being the 6th.
longest in the UK to being the 3rd. longest (with only Heathrow and Gatwick with
longer runways). If it is so small why are the Airport so keen to achieve it and why are
they so keen to spend so much money on its construction? It is a very significant
increase as we have already detailed earlier in this response.
*(2) ‘envisaged level of aircraft movements little greater ..than…when… planning
permission given to extend…in 1994..’
This is misleading for the many reasons already given earlier in this response. The
real issue here is the traffic mix that will be generated and the impact of significantly
more noise, pollution and road traffic from the much greater number of maximum
weight take-offs that will be generated.
*(3) ‘Operation by aircraft types which are…significantly quieter than some of
those used currently…due to the phasing out of noisier aircraft’
This is not correct. Noisier aircraft are being phased out by law, not by the Airport
and not by the airlines. In any event there is no such thing as a quiet aircraft, they are
all noisy. They are even more noisy when operating at maximum weight – and many
will if this extension is allowed, and many will be at night. To claim that operations
will be significantly quieter is arrant nonsense. This claim is further undermined by
the fact that ‘Chapter 3’ noise criteria which is forcing out aircraft such as the Boeing
727 has differing values for different sized aircraft. Large aircraft are permitted to
make more noise than smaller aircraft. An aircraft such as the Boeing 747-400
(Boeings most modern Jumbo) is still a noisy aircraft, even under the latest noise
criteria. They are most certainly not ‘significantly quieter’ as claimed.
*(4) ‘A very small increase in Air Traffic Movements arising from this small
extension, less than 5%’
Again, this is misleading and the same comments made at bullet (1) above apply. It is
the aircraft mix and the associated noise pollution that are relevant.
5.6 Again, the runway extension is not ‘small’, it is significant. Again, it will not
allow ‘slight increases in permitted aircraft take-off weights’ it will allow significant
increases and these will generate an equally significant increase in noise.
5.7 ‘The current scheme… has the benefit of allowing use of a displaced threshold for
landings..over Kegworth’
Misleading again. There is no benefit in this ploy (see our comments at Chapter 2.
2.19).
5.8 ‘..the impact appraisal assumes no off-site new road construction…which links the
Airport to the M1.’
Why not, the A453 will become unusable? (See comments at Chapter 2. 2.52).
5.9 ‘..The benefits of.. {the Airports Noise Amelioration}.. strategy…have not been
taken into account...{so}.. this chapter presents a worse case scenario.’
Why have benefits not been taken into account? It is all very well to say that ‘this
chapter presents a worse case scenario’ but this is just not good enough.
What is the strategy? How will it be enforced? Who will police it? How effective will
it be? What will happen at night? How will local communities be protected? How will
noise be monitored? How transparent will noise monitoring be? Will local
communities be involved?
The questions are endless and no judgement can be made by NWLDC on this
application until this strategy is tabled, the local communities have been consulted and
the questions have been satisfactorily answered.
As it presently stands, the only conclusion available is that the strategy is not included
in the document because the Airport know that to produce an enforceable and
effective strategy they will lose the significant advantages they have in attracting a
maximum bid for the sale of the Airport. They also know that they will loose the
considerable premium that they will be able to charge for night operations.
It is not in the Airports interest to publish such a strategy because the only strategy
that suits their business case will be ineffective in providing any real constraint on
noise.
Baseline Noise Conditions.
Introduction
5.10 ‘The main effect .. is the ..small change in aircraft take-off performance… and
the forecast small increase in Air Traffic Movements, less than 5%..{background
noise} … is determined from local roads, the…motor racing circuit and the airport…’
The ES again falls into the basic problem it set itself in the scoping process. There
will not be a small change in aircraft take-off performance, there will be a large
change.
It is not correct to exclude the permitted 610 metre extension, already built, from the
ES, all its assumptions are therefore incorrect.
With reference to background noise, to include the motor racing circuit as a primary
contributor demonstrates that the ES really is clutching at every available straw to stay
afloat! Certainly the circuit is very noisy when it is operating but it’s activity is very
spasmodic when compared with the Airport.
For example, it does not operate at night and this effect needs to be quantified. Its
activities are already restricted and policed. It operates over daytime hours and the
activity tends very much to be frantic but short lived.
The airport, by contrast, operates 24 hours per day, seven days a week. The circuit
will never mask this activity to any great effect at all, noisy though it may be.
Further, the use of ‘average’ noise values over a given timeframe totally masks the
effect of peak noise. A single very loud event in a 60 minute period will produce a
low average figure but only a few such events per night at 60 minute intervals, for
example, will destroy sleep for many people.
Airborne Aircraft Noise
Introduction
5.12 The use of the year 2000 as a baseline is incorrect as it excludes any effect of
the permitted extension, which is very considerable.
5.16 Again year 2000 is not the correct baseline.
Impact Assessment Criteria
5.19 to 5.30 introduces a long and convoluted argument to justify the principles and
values used in this chapter.
Buried within this text is the acknowledgement that the figures used are at variance
with advice from the World Health Organisation (5.30). Additionally, DETR are
currently reviewing criteria that should be used. In the meantime the ES has used
criteria ‘developed over many years in … UK, and used on an equitable basis at many
UK airports’
The ES admits then, that controversy surrounds their methodology and yet they persist
in applying it. Why did they not use the more environmentally friendly criteria
suggested by the WHO?
There is no case to suggest that because the criteria ‘has been developed over many
years’ that it is satisfactory. Indeed the contrary is true, there have been endless
arguments, disputes and demonstrations over airport noise, nationwide, and it is
abundantly clear that present conventions are neither satisfactory or credible.
The science of noise measurement is altogether highly unsatisfactory when it comes
to airport issues. To rely on criteria from a team of consultants who are paid by the
very agency that generates the noise is dangerous indeed.
NWLDC should use the utmost scrutiny in analysing the data contained in this section
of the ES.
5.33 ‘..once asleep, very few people living near airports are at risk of any sleep
disturbance due to aircraft noise’
This is seen by some as the most misguided statement in the whole ES.
WHO (1999) state that, “ The probability of being awakened increases with the
number of noise events per night….
For a good night’s sleep, the equivalent sound levels should not exceed 30 db(A), for
continuous background noise, and individual noise events exceeding 45 db(A) should
be avoided.”
It is interesting that PPG 24 criteria for air traffic over the 23.00 to 07.00 hours has
been employed for noise contours Fig. 5.2 at 48 dB LAeq, 8h and 55 dB Laeq, 8h.
Where are the noise references for this section of the ES? Without them what
credence can be given to statement such as “The extensive Department of Transport
research study on the effect of night noise (DoT, 1992) indicated that outdoor noise
levels below 90 dB(A) SEL due to aircraft noise events are most unlikely to cause any
measurable increase in the overall rates of sleep disturbance experienced during
normal sleep.”
5.34 1993 was a long time ago. Attitudes relating to environmental issues have
changed significantly since then and have much more impact as we move into the new
millennium. The attitudes of the early nineties are way out of date and therefore
irrelevant to this ES.
5.45 Table 5-3 Guidance with Regard to Airborne Aircraft Noise (Night –Time)
That stated as exposure at 48dB and 70 dB LAeq, 8h as compatible with WHO
internal level of 35 dB(A) in order to “preserve the restorative powers of sleep” is in
fact misquoted. According to WHO (1980) criteria section 1.1.3.3 it states, “..a level
less than 35dB(A) Leq is recommended to preserve the restorative process of sleep.” (
Reference NoiseNet.org/Noise_Enviro_WHO.htm)
This is restated by Berglund (1996), “If negative effects on sleep should be avoided
for continuous noise, the equivalent sound level should not exceed 30dB(A) indoors. If
the noise is not continuous, the maximum level is best correlated to sleep
disturbances; effects have been observed at individual exposures of 45dB(A) or even
less….it should be noted that it should be possible to sleep with a bedroom window
slightly open (corresponding to a reduction from outside to inside of 15dB).”
It is pertinent to this item to reflect upon WHO thinking with regard to the concept of
‘annoyance’ particularly as this is employed in the ES. In the Executive Summary of
Guidelines for Community Noise (Berglund et al 1999), it states, “During daytime,
few people are highly annoyed at LAeq levels below 55dB(A), and few are moderately
annoyed at levels below 50dB(A). Sound levels during the evening and night should
be 5-10 dB lower than during the day.”
5.120 ‘..the airport’s Environmental Management Strategy …has included the setting
up of a formal Airport Consultative Committee to ensure adequate dialogue between
the Airport, the airlines and the local community..’
What strategy, where is it, how does it work, who is involved, what is it’s remit, how
is it enforced etc., etc.? This statement is just woolly words with no substance.
Certainly the Airport Consultative Committee, correctly named East Midlands
Independent Consultative Forum is, as many airport consultative committees are
known to be, not an effective forum for local consultation and has consistently refused
to discuss material matters.
5.121 ‘The recent development of the departure routes has sought to minimise noise
impact.’
This is simply untrue. There are no departure routes in existence. We challenge the
Airport to show where they are published and to confirm which airlines are using
them.
In any event, if and when, they are introduced, they will have no positive noise
benefits for Castle Donington, Kegworth or Diseworth. Further, the lack of
navigational guidance required to accurately fly these routes is questionable as is the
ability of heavyweight aircraft to follow them. There will be large variations of scatter
that will impinge on many local communities and heavy aircraft at low altitude for
longer periods of time will have severe adverse impact. Additionally, greater track
mileage flown by aircraft will add to air pollution.
5.122 ‘…appropriate steps [will be taken] to reduce noise..’
How is it proposed to achieve this? It is not possible. You cannot ask pilots to reduce
power on take-off, for example, the aircraft will fall out of the sky! If you sanction
maximum weight take-offs by extending the runway then you are stuck with the
consequences which are maximum noise departures. No amount of soft soaping or
kind words will prevent the consequence of the decision.
5.123 *(1) ‘Noise Amelioration Policy … will ensure flight routes are operated using
the appropriate noise abatement techniques..’
Such techniques have little practical value, especially on heavy weight take-offs.
Aircraft manufacturers design aircraft to meet minimum climb gradients at maximum
thrust (it’s cheaper that way) at maximum weight. They will be slow to accelerate and
slow to climb to the point at which they can reduce power and accelerate (normally at
1500ft. above the ground) so there will be no benefit.
‘..circuits are optimised to minimise impact on local amenity..’
This is utterly meaningless. A circuit is a circuit, no more and no less, it’s either right
handed or left handed and that is all. You cannot ‘optimise’ it. Pure waffle!
*(2) ‘ ..Runway utilisation (where practicable) is optimised via the
encouragement of a preferred runway (landing on RW09 and departing on RW27)
particularly at night to minimise local impacts..’
More waffle! Runway 09 has a downhill gradient and pilots of large aircraft will not
accept landing downhill with a tailwind component.
Even if they did then the freight aircraft would subsequently create more ground
noise as they take a long ground run back to the freight apron which is at the Western
end of the airport. Easterly approaches might appease Kegworth but they impinge on
Ticknell and Isley Walton. In any event the predominant landing runway is 27 due to
wind direction.
*(3) ‘..Time restrictions on training flights by turbo-jet aircraft..’
What time restrictions? Where is the substance in this? Why should local residents
have to suffer training flight noise/pollution when the operator does not even fly from
the airport and worse still, enjoys the benefits of subsidised landing fees? No doubt
these time restrictions will exclude night flights and so local communities will suffer
an increasing number of these flights (that an extended runway would create) during
daylight hours and at week-ends whilst they endeavour to enjoy their gardens.
*(5) ‘..Night Flying Regulation to keep under control noise at night. This shall
be generally in line with the quota Count scheme developed and operated at the
London Area Airports and proposed for Teesside Airport….’
This policy should already be in place. If the Airport were serious about being a good
neighbour – which it constantly claims - then it would have introduced such a policy
a long time ago. The airport should introduce this policy prior to any further
application for any extension. The airport is openly and cynically using this measure
as a bargaining tool, nothing more and nothing less.
At what levels will the Quota Count be set? Where is the detail of this procedure?
Why is it not included in this ES? When will it be introduced? Why is it that the
airport will not discuss this issue in the Consultative Forum? No one should be
seduced by this statement. The levels will be set – by the airport, for the airport – so
that it can accommodate its noisiest customer airline.
*(6) ‘..The measures will be monitored …and reported regularly to the Airport
Consultative Committee by an appointed member of the airport staff..’
And just what will this bureaucracy achieve? There is no proposal to generate any
sanctions on those who violate. These are just empty words, again. The more so
because the Consultative Forum is denied any teeth by the airport.
Noise of Aircraft Ground Operations
Introduction
5.125 ‘..the noise from these future operations will differ from the situation without
the runway extension due to the very small increase in ..[air traffic movements]
arising from the development..’
We assume that Scott Wilson is trying to say here that there will be no real noise
difference. We refute this suggestion for the reasons outlined many times already in
this response. It is not the ATM s that are the issue. It is the mix of aircraft. Heavy
aircraft taxiing at maximum take-off weight will make substantially more noise than
their present counterparts. Further, surface transport serving these aircraft, with their
increased capacities, will substantially increase in number and also create more noise,
particularly with reverse klaxon warnings.
5.126 ‘..In the future, aircraft operations will be carried out by new turbo-fan and
turbo-prop aircraft. New turbo-fan aircraft are generally quieter when taxiing.. than
previous jet types ..Future turbo-prop aircraft are noisier than new turbo-fan
aircraft..’
This statement is so generalised as to be meaningless. In fact it is not even accurate.
There will be a large influx of Boeing 757 aircraft, for example. These are far from
new aircraft and are being purchased by DHL , second hand, from British Airways.
As we have pointed out many times in the past, there is no such thing as a ‘quiet’
aircraft, they are all noisy it is merely a question of relative values – presumably this
is why Scott Wilson are sufficiently vague as to say that modern aircraft are
‘generally’ quieter.
5.135 ‘..Engine maintenance has not been considered…[as] .. the runway extension
has no effect on such activity..’
This is not correct. Firstly this is incorrect because the entire ES ignores the existing
extension contrary to the requirements previously set.
Secondly it is naive to assume that a runway that is planned to become the third
longest in the UK will not develop as a maintenance base for operators – particularly
if there is a night flying restriction scheme. Does anyone believe that airlines would
not use the ‘down time’ whilst aircraft are idle, to carry out maintenance?
The airport already has three substantial hangers and a sophisticated maintenance
facility, is it the assumption that this will not be utilised?
With the inevitable growth of air traffic movements – with or without an extension –
that will occur at EMA, even unscheduled engine maintenance will increase
substantially. This will be further magnified by the additional proposed extension
which is designed to facilitate maximum power requirements for take-off. Engine
maintenance requirements will grow substantially with this further planned extension
for this reason alone. Pilots will simply not be prepared to operate with engines that
are not giving of their best when they face performance limited operations - which a
maximum weight take-off most certainly is.
5.155..the Environmental Management Strategy will * Include…duration of APU
operations and targets on ground running of engines .. * Restrict high power
maintenance runs..’
How will it achieve these goals? Again, there is no substance to the statement.
Unlike most airports EMA has not seen fit to introduce fixed electrical power
supplies for aircraft. The airlines therefore have no choice but to use APUs (auxilary
power units)or GPUs (ground power units). Both are noisy and pollutants.
What targets will there be on engine ground running and how will they be enforced?
What restrictions will there be on high power engine runs and how will they be
enforced?
Chapter 12
VORTEX EFFECTS AND PUBLIC SAFETY ZONES
INTRODUCTION
Vortex Effects
We do not disagree with this paragraph but wish to make the following clarification:Whilst vortex effect is certainly ‘partly dependent on air speed’ as the ES observes,
the more significant factors are those of aircraft configuration and weight. In order for
aircraft to achieve speeds that are low enough to allow them to land (and stop before
the end of the runway!), ‘high lift’ devices in the form of slats and flaps, which are
fitted to the wings, are employed. It is the deployment of these devices, and the
energies inherent in the airflows over them that exacerbates the vortex effect close to
the ground during the aircraft’s approach to land. The heavier the aircraft the more
the energy that will be required to allow it to sustain safe flight at a given speed - and
the greater the strength of the vortex wake that will be generated. It follows therefore,
that the heavier the aircraft the greater the vortex effect. A small single engined
aircraft will generate very little vortex indeed whilst a large commercial jet will
generate significant wake vortex. A Boeing 747 landing at heavy weight will generate
a great deal of vortex wake.
It is important to bear these factors in mind whilst studying this section of the
WINGS ES Response.
Baseline Conditions
Vortex Effects
We note that since 1994 there are known to have been 10 incidents of wake vortex
damage in Kegworth, all associated with Boeing 757 aircraft.
Public Safety Zones
The 5 paragraphs under this title explain the methodology employed in determining
the shape of the Public Safety Zones (PSZ) relevant to this application.
12.13 advises that ‘the PSZ is a function of runway configuration and the volume and
type of air traffic forecast for 2015’.
There can therefore be no validity to these PSZs. EMA forecasts were used to
determine volume [12.20 refers] and we have already demonstrated (2.45) that Scott
Wilson and EMA, in this ES, have underestimated air traffic volume by as much as
100,000 movements per year by 2016. If DETR figures were to have been used even
Scott Wilson point out (2.39) that DETR are re-evaluating their forecasts in the light
of current industry trends and those that they presently have are invalid. How then
can these PSZs have any credibility?
If traffic type is a criteria then the same arguments apply. Scott Wilson have seriously
misidentified the traffic mix that will grow at EMA and DETR are still evaluating
their prognosis!
12.14‘…the coordinates of the PSZ for the current runway configuration, length and
traffic have been established by DETR’s consultants and issued…to NWLDC’
We note that these coordinates are for the current runway, not the runway with the
proposed 190 metre extension under consideration in this application. We question
the basis of the traffic forecasts used in this evaluation as DETR have not yet
published their revised predictions. These again are EMAs own underestimated
forecasts.
‘..local planning authorities have been asked by DETR to take responsibility
for … [Public Safety Zone] .. policy from 1st. June 2000..’
NWLDC has a clear and onerous responsibility here. Safety is a key issue and is now
in the hands of the Council and its Planning Committee – fair and square. How will it
react should there be another major accident within the PSZ in the light of the
concern and criticism levelled here and how accountable will it’s officers be?
12.15 ‘PSZs based on these coordinates have therefore been taken as the baseline
for this EIA and are shown on Figure 12.1’
How can a PSZ that has been calculated (questionably) for an existing runway be the
same as that which will apply to a longer runway when ‘runway configuration’
[12.14] is a major criteria in its construction? This is nonsense and demonstrates
again the fact that these PSZs are invalid.
IMPACT ASSESSMENT
Vortex Effects
12.17 ‘ the proposed runway extension will lead to a slight increase in larger
bodied aircraft…consequently…vortex strikes occurring in Kegworth… [will]…
increase’
Here, at last, Scott Wilson is correct, of course they will increase! Albeit that this is
not what they are trying to say. But they will increase substantially. History has
shown that the Boeing 757 is the threshold of aircraft size at which vortex strikes
become an issue (10 strikes since 1994). DHL alone will influence the number of
these aircraft using the airport. The mix of wide-bodied aircraft that will use the
extended runway – and will land at high weights – will be significant and the
incidence of vortex strikes will rise proportionately.
‘…However by relocating the landing threshold on runway 27 by 150m…the
overall change is likely to be minimal’
Again, Scott Wilson’s use of English is to be admired! If we took them literally, then
we would agree with this statement. Sadly we have to assume that they mean the
opposite even though they contradict themselves.
As we make clear in 2.19 moving the threshold by 150 metres will make a difference
in height to an aircraft anywhere over Kegworth of only 24 ft. This will have not the
slightest effect in mitigating any vortex strike and is merely a hollow ploy.
The overall change will certainly be minimal. There is no alleviation from vortex
strikes, from noise, nor from the already existing – very real – issues involved with
any of these subjects.
It is interesting that no statistics have been provided in this area since the present
extension was completed at the beginning of 2000.
Public Safety Zones
Runway Configuration
12.19 This paragraph argues that the PSZs have not been changed despite the fact that
the threshold for runway 27 has been moved further West than at present so it is
safer. It also argues that there is no change to the runway 09 end so it remains
equally safe.
This is incorrect. Scott Wilson themselves say in 12.5 that the PSZ considers ‘..an
aircraft crash on take-off or landing..’ Let us examine the facts:
It is only the landing threshold that has been moved at the Kegworth end, the full
runway length will still be available for take-off. As the airport claim that this is only
to allow maximum weight take-offs it must change the criteria at the Donington end
of the runway as aircraft taking off on runway 27will be lower, slower and heavier as
they pass through the PSZ at the Western end of the runway. How can it then remain
equally safe?
Neither should it be forgotten that there have been at least three accidents resulting in
hull loss at the Donington end of the runway in recent years and the tragic loss of life
from the Kegworth accident.
The PSZ at the Kegworth end, as well as at the Donington end, in their present
configuration are both also compromised by the change in traffic mix and volume
that will occur over the coming years – with or without a further extension. Scott
Wilson’s argument just does not stack up.
12.20 ‘..air traffic forecasts for 2015 supplied by EMA …accommodate the growth in
traffic forecast for both the with and without …runway extension schemes’
We have already refuted this argument. EMAs traffic forecasts are hopelessly
inadequate and this undermines the case for maintaining the present PSZs.
MITIGATION
Vortex Effects
12.22 ‘…in order to reduce the risk of vortex strikes…aircraft will be re-routed,
where possible, to land on runway 09’.
This is not enforceable and will have no material positive effect. It is naïve to argue
otherwise. Further, the strategy has serious safety considerations. Runway 09 has a
downhill gradient. This, coupled with a request to pilots to land ‘downwind’ (i.e. with
a tailwind component) is not a set of circumstances that pilots will readily accept.
Indeed, some airlines and the CAAs in some States specifically prohibit the practice
of downwind landings. Certainly, pilots flying larger aircraft types – the very types
that are more likely to generate vortex incidents – are unlikely to accept such
requests.
‘In addition, EMA has contacted Boeing 757 operators to instruct them of
alternative runway allocation..’
This may well be the case but the fact remains that no airline will commit it’s pilots to
such a policy and no pilots Union will endorse it, certainly not BALPA (British
Airline Pilots Association) or IFALPA (International Federation of Airline Pilots
Association). This strategy is mere words. As we have already ascertained [at the
beginning of this chapter] aircraft size is critical to vortex issues, the Boeing 757 is
merely the smallest aircraft that has a material input to vortex damage. It has featured
heavily in the EMA statistics because it has historically been the largest regular user
of the airport. This will not be the case in the future where Boeing 767, 747 and 777
will all be regular players alongside this smaller cousin. As will also Airbus A300,
A330, A340 and MD 11, DC 10, and Tristar. All these types, and their derivatives, are
larger than the 757. All too, as a result of the proposed extension, will be landing at
higher weights than they presently do and all will adversely contribute to vortex
damage.
12.23 ‘…In order to monitor the situation a procedure has already been introduced in
the Air Traffic Controllers manual.. with..a report to be filed where vortex
damage ..has been reported..’
We are pleased that this is the case but this will not stop any damage. It is clear that
the airport has no desire to instigate preventative measures that are effective – because
it cannot – instead it resorts to a paper process to create an illusion. Remember that
the Boeing 757 is not the only aircraft that causes the problem, it is merely the
smallest aircraft that causes the problem. Larger aircraft will cause more damage. And
more often.
Public Safety Zones
12.24 ‘…the proposals…provide some mitigation of Public Safety aspects by
relocating the Runway 27 threshold 150 metres to the west, which reduces the impact
on Kegworth’
We have clearly argued that this is not correct. There has been no consideration given
to realistic traffic volume or traffic mix. Both are essential in determining the
boundaries of a PSZ. Do not forget either that the ‘S’ in PSZ stands for Safety.
Conclusions
12.25. Relocating the threshold of runway 27 150 metres to the west will have no
material benefit, safety or otherwise, to Kegworth. The additional 24 ft. in height
afforded to overflying aircraft will count for nothing. This Scott Wilson conclusion is
incorrect.
Public Safety Zones
12.26 Again, moving the landing threshold west will not have any benefit to
Kegworth because the proper traffic mix has not been considered. Further, there is a
marked disbenefit to the Donington end of the runway (09) because of the additional
weight of aircraft departing in that direction.
CHAPTER 13
SUMMARY AND CONCLUIONS
Introduction
13.5 and 13.6 discuss the Environmental Impact Statement ‘regulation’ and ‘process’.
As we have argued in our response in chapter 1, the process used by Scott Wilson is
flawed because it has ignored the requirements of the Secretary of State to include
both the permitted development (the recently constructed runway extension) as well
as the proposed extension. This was also required by NWLDC and was the basis on
which the Stanger ES was written. What has changed in the interim?
13.7 Summarises the Scoping process of the ES.
As we argue in chapter 1 of our response, Scott Wilson have been significantly wrong
in the construction of the scoping parameters of this ES. Firstly insofar as the
requirements of the Secretary of State have been deliberately ignored and secondly
because there has been no proper consultation with local communities. Even if this
latter point is not required in law it demonstrates the cavalier attitude held by the
airport about such matters.
13.8 claims that land use will remain largely unchanged by this extension. This we
refute. It is wrong to make such a claim and it is incumbent on both the airport and
NWLDC to ensure that airport land is utilised for airport related development only. If
the airport is allowed to continue to develop non related business (PowerGen etc.) it
will be soon pushing to expand outside its present boundaries.
The Development Proposals
13.13 The claim here that moving the runway threshold 150 metres to the west will
benefit Kegworth is unworthy of a company such as Scott Wilson. There will be
absolutely no measurable improvement in the noise characteristics of either landing,
or departing, aircraft. It is nothing short of shameful that Scott Wilson make this
claim.
Operational Effects
13.14 to 13.20 discuss operational effects and air traffic movement forecasts.
As we argue in our response (chapter 2) the Scott Wilson proposals are greatly
flawed.
They fail to understand and take account of the internationally forecast growth of
aviation over the next 15 years, during which time it is set to double. This factor has
not been taken into account in their forecasts. Indeed, instead they rely on DETR
figures which they acknowledge are under review at the present time.
They fail to understand that growth at EMA will be much greater than the national
average due to the congestion and pressures on the major airports in the south east.
They fail to understand that it is the change in the mix of aircraft that this proposed
extension will generate that is a key issue and they have not addressed this factor.
They fail to understand that their own argument of ‘payload/range’ will give rise to a
huge increase in maximum weight take-offs and have not addressed the impact of this
factor.
Our detailed comments on these issues are contained in our comments in chapter 2.
Road Traffic
13.21 This paragraph is again inaccurate and misleading. Scott Wilson significantly
underplay the impact that the proposal will have on road traffic flow and volumes.
(see chapter 2).
NOISE.
13.22 to 13.27 summarises the Scott Wilson perspective on noise. We strongly
challenge their prognosis. The claim that aircraft noise will be substantially
unchanged due to the proposed extension is preposterous. Our detailed response is
contained in chapter 5. For the ES to argue that daytime noise will remain ‘similar’
and that the increase in night noise will be ‘slight’ is misleading in the extreme. This
claim demonstrates that they have no clear understanding of the growth in
air traffic that will occur, they have no clear understanding of the impact that the
traffic mix will have and they have no clear understanding of the number, or the
effect, of maximum weight take-offs that will occur.
13.24 relates to the EMA environmental strategy. This strategy, as we argue in
chapter 5, is meaningless. There is no detail, there is no accountability and there is no
mechanism for enforcement. The strategy as it presently stands is only empty words.
Were the airport the good neighbours that they claim to be then this strategy would
already be detailed and in place. To offer an amelioration strategy as a bargaining tool
for a planning application is nothing more than cynical. To offer a strategy that has no
substance and no positive impact is to insult those who are responsible for
determining the application.
Road Traffic Noise.
13.27 As we have demonstrated in our detailed response to this issue, the ES is yet
again significantly inaccurate in its assumptions on the increase in road traffic that any
extension will generate – by a factor of some 30%.
VORTEX EFFECTS AND PUBLIC SAFETY ZONES.
Vortex Effects
13.48 The Scott Wilson proposal to move the landing threshold of runway 27, at the
Kegworth end, 150 metres to the west will have no significant effect on wake vortex
damage. Our own analysis of this proposal is contained in our response at chapter 12.
Suffice to say that the strategy will prove ineffective and the number of vortex
damage incidents will rise greatly as more large aircraft use the runway. In our
response to the Stanger ES (1997) we demonstrated that the strike rate would rise to
18 over a similar timeframe to the then recorded number of 6. Since then the forecast
growth in traffic will mean that this number is set to grow significantly larger.
Public Safety Zones.
13.50 and 13.51 Scott Wilson argue that there is no need to vary the PSZs presently
extant. We argue that this is not correct. The proposed extension will generate a
greater number of larger aircraft operating at higher weights and at the margins of
their available performance. To suggest that because the threshold at the Donington
end of the runway is not being moved and that the Kegworth end will derive benefit
from the proposal to move it 150 metres west falls significantly short of what is
required.
CONCLUSION
13.52 It is axiomatic that the planning documents mentioned in this paragraph are
fundamental in determining planning applications. Of great significance in the
application to extend the runway is the account that must be made of the evolving
RPG for the East Midlands the Inspectors’ Report of which, from the Public
Examination in June 2000, is now with the Secretary of State. It states that, “1.2 The
draft Guidance updates RPG8-Regional Planning Guidance for the East Midlands
published in 1994.” The document from the Secretary of State will be available for
consultation early in the new year. Of equal significance in this application is the
proposed National Aviation Policy. This will have a significant influence upon
operations at all regional airports. WINGS maintains that there must be built into any
conditions set for planning permission codicils and safe-guard clauses which protect
the environment, the health and the quality of life in general of airport adjacent
communities.
13.53 We do not dispute the importance of the airport to the local economy, indeed
we support and applaud it. We dispute the claim that the proposed extension has any
material bearing on this economy. The airport, with its’ present length of runway is
already able to provide international travel to the USA, to Africa and to Asia. No
more employment will be generated by extending the runway further.
The consequence of the proposed extension will be environmental disbenefits that will
be hugely significant to local communities and will exist in perpetuity. Neither the
airport nor the airlines will be able to mitigate against these adverse influences.
13.54 The claim here that the ES has demonstrated that the proposed runway
extension will not increase significantly the environmental effects of the airport is
quite wrong.
We have clearly shown in our response that such a claim is unfounded as the premise
upon which Scott Wilson have built their arguments are false. They claim that there
will be a minimal increase in air and road traffic, we have shown this to be incorrect.
They claim that there will be a minimal increase in aircraft and road noise, we have
shown this to be incorrect. They claim that only a few aircraft will operate at
maximum weight, we have shown this to be wrong. They claim that the wake vortex
and Public Safety Zone issues will be resolved, we have shown this to be incorrect.
They claim that the airport has an environmental strategy to mitigate the issues, we
have shown this to be ineffective and unenforceable.
WINGS CONCLUSIONS
The summary of our response, together with our conclusions and full
recommendations, is contained in the ‘Executive Summary’ at the front of this report.
REFERENCES
Berglund, B.
Berglund, B. Lindvall, T.
& Schwela, D.H. (Eds)
1996 Aircraft Noise and Health. The Second Airport
Regional Conference. Vantaa, Finland. November 1996.
1999 Sustainable Development and Healthy
Enironments:Protection of the Human Environment.
DETR
2000
National Aviation Policy: Consultation Paper.
Published 12.12.2000.
McDonald, Lord
Letter to Rt Hon Kenneth Clarke QC MP on East
Midlands Airport ref: P/GM/024875/00. 28.9.2000
Regional Planning
Guidance.
East Midlands. Public Examination: Report of Panel.
Government Office for the East Midlands. 18.10.2000.
EMAICF
Minutes of Meetings 1999-2000.