Sir George concerned at NATS proposals
10 Aug 2007
In May this year, the National Air Traffic System (NATS) published proposals to take effect from next April to "change the airspace structure" between Newbury and Andover. Consultation was scheduled to end on August 10th, with the changes being implemented on April 10th 2008.

"Tucked away in the document, on page 44, was a statement that Parish Councils were not on the list of consultees; but that District Councils - such as West Berkshire, Basingstoke and Deane and Test Valley should "cascade the proposal" to "additional groups."

"For whatever reason, this did not happen and some Parish Councils in my constituency have only recently learned about these proposals."

"I am concerned at the impact which the proposed flight paths will have on my constituents, particularly during the silent hours. Those living in Highclere, Penwood, Woolton Hill, East Woodhay, East End, Hollington, Ashmansworth and Crux Easton have been in touch with me; and I saw representatives from Ashmansworth and Crux Easton at my advice bureau in Andover last Saturday. Those two villages are some 550 feet above sea level and would therefore be particularly affected. Much of the area is an AONB, which should be protected from unnecessary intrusion."

"I have asked NATS to extend the consultation period to the end of September, as the proposals have caught many people on the hop. Ashmansworth are working on some modifications to the proposals, which they believe will meet NATS objectives, without the adverse consequences of the current proposals on the communities concerned."

"As the local MP, I want to do all I can to bring this to a satisfactory conclusion, and am prepared to raise the matter with Ministers if necessary. I am already in touch with the CAA, and have asked them not simply to rubber stamp any proposals that emerge from NATS, but to take independent advice. The proposals are not primarily about safety, but about the reduction of delays. This should not be an absolute imperative, which overrides the environmental consequences of changing flight paths."

My colleague Cllr Horace Mitchell is the Cabinet Member for Planning & Transport at Basingstoke & Deane, and also the ward member for many of the affected parishes. He said:

"It has certainly taken too long for the implications of this complex document to become clear to people on the ground in our local villages. We are asking NATS and the CAA to extend the period of consultation so that the Borough Council can make a properly considered response, having fully understood all the impacts. We very much welcome Sir George's support in this.

"I also represent Basingstoke & Deane on the AONB council of partners. We're very proud that such a large part of the borough is covered by the AONB and we take great care in protecting the AONB from inappropriate development. Access to the peace and beauty of the countryside is important to those who live in our towns as well as to our rural communities. In principle, I'm opposed to any intrusion of low level commercial traffic into the AONB, where tranquillity and dark night skies are just as important as the beauty of the countryside and an appropiate balance between the natural world and human activities.

"We recognise the need for continuing economic development and we respect the ambitious plans for further growth at Southampton airport. But shaving a few minutes off a one-hour or two-hour flight time has to be balanced against the destruction of tranquility in those very few areas of the South East where it can still be enjoyed - by visitors as well as by residents."

Another colleague is Cllr Clive Sanders who represents East Woodhay, a very large part of the affected area. He has also been pressing hard to obtain an extension of time.
"Unless the outcome has already been decided, the views of residents should be an integral part of the decision making process and not an afterthought. The reasons why the consultation process has not worked are irrelevant. The fact is it clearly hasn't and it has to be suspended until interested parties at all levels, particularly those most concerned locally, have the opportunity to consider and respond properly, and, because of summer holidays, that won't be for another ten weeks at the earliest. We also need to see from NATS what alternatives were considered and why they were rejected. The only way public confidence can be restored in this process is for NATS and the CAA to recognise the problems and publish a new timeplan, even if that means delaying any implementation. It is totally unacceptable for communities to be denied the opportunity to make their voice heard."

The County Councillor for the area is John Maxwell, and he has been in touch with me on behalf of his constituents. He has asked me to include the following draft response from Hampshire County Council on the website

Draft response to NATS consultation on expansion of controlled airspace.

Dear Mr Bentham,

NATS Consultation on extension to airspace from Bournemouth and Southampton Airports

I refer to your letter dated 4 May 2007 regarding the consultation relating to the proposed extension of controlled airspace on the approaches to Bournemouth and Southampton Airports.

It is acknowledged that the proposals are not designed to increase the number of flights and that this does not form part of the consultation. However by increasing the area of controlled airspace, additional capacity is being provided. The development plans for both Southampton and Bournemouth Airport include plans to increase traffic. Therefore I believe that the likelihood of additional flights resulting indirectly from and facilitated by these proposals, must be taken into consideration.

Policy EC5 in the County Structure Plan supports proposals to expand and enhance the facilities at Southampton Airport, except where there are overriding environmental, safety or transport objections As a strategic authority the County Council is supportive in principle of the expansion of Southampton Airport because of its significance in economic terms for the future prosperity of the South Hampshire Sub Region. Therefore in terms of the potential economic impact the Authority has no objection to the proposals in principle. However the County Council’s policy position clearly caveats this in principle support against tests of environmental, safety and transport impacts.

The environmental impact on Hampshire of these proposals is very important and the routeing of flights needs to be sensitive to environmental concerns. The principal concern is the impact of aircraft noise. Therefore the issues below also need to be considered carefully.

Environmental considerations.

I note that you indicate that the will be no impact because the planes will be flying at above 5,500 feet. However parts of the area of the new flight path are up to 1,000 feet above sea level and therefore likely to have a greater impact.

The proposal to extend airspace for flights into and out of Southampton and Bournemouth Airports will have very significant impacts on the New Forest National Park (NFNP) and the North Wessex Downs Area of Outstanding Natural Beauty (NWDAONB).

The purposes of the designation of the New Forest National Park as set out in the Environment Act 1995, are:
(a) to conserve and enhance the natural beauty, wildlife and cultural heritage of the New Forest; and
(b) to promote opportunities for the understanding and enjoyment of the special qualities of the area by the public.

The purposes of the designation of the North Wessex Downs AONB are:
(a) The primary purpose of designation is to conserve and enhance natural beauty.
(b) In pursuing the primary purpose of designation, account should be taken of the needs of agriculture, forestry, and other rural industries and of the economic and social needs of local communities. Particular regard should be paid to promoting sustainable forms of social and economic development that in themselves conserve and enhance the environment
(c) Recreation is not an objective of designation, but the demand for recreation should be met in so far as this is consistent with the conservation of natural beauty and the needs of agriculture, forestry and other uses.

New Forest National Park

A full and detailed response to the consultation has been prepared by the National Park Authority and it is not intended to repeat those comments. However, there are a number of key factors that we wish to reinforce through our response. The special qualities of the NFNP are set out in the New Forest Strategy 2003 and its corporate strategy. Of particular relevance is the profound sense of tranquillity and remoteness that can be found in many parts of the National Park, contributing to a sense of wildness and low levels of urbanisation.

These factors have a very significant bearing on the quality of life of residents and visitors. It is reported in the consultation document that noise levels could reach 70 decibels, against a World Health Organisation recommended threshold of 50 decibels. However, ambient noise levels in the National Park are relatively low, which will lead to a perception of greater noise levels. This will inevitably damage enjoyment of the special qualities of the National Park, a primary purpose of the designation.

North Wessex Downs AONB

The North Wessex Downs AONB has been limited in its ability to respond to the consultation. It is a small organisation without a Planning Advisor in post, and so the AONB Council of Partners has responded to the consultation by drawing attention to the key policies in the Management Plan. As a statutory document, the Management Plan is a material consideration in Development Planning matters. It has been referenced and quoted by the Planning Inspectorate in the consideration of appeals against development decisions, and was prepared with a high degree of stakeholder consultation. The relevant background and policy statements from the Management Plan are attached in an Appendix.

As with the NFNP the key impact is on tranquillity, and several policies in the Management Plan are aimed at conserving and enhancing tranquillity and remoteness. Again, there will be implications for the quality of life of residents and visitors, especially as one of the highest parts of the AONB, almost 1000 feet above sea level, lies under the proposed airspace extension. This will have the effect of reducing aircraft altitude to around 5,500 feet, with the associated increase in noise.

Evidence of Tranquillity

The Council for the Protection of Rural England (CPRE) has recently published its map of ‘Tranquillity in England’. This map has been developed from the assessment of over 40 factors that contribute to or detract from tranquillity in 500x500 metre squares across England. It is a key reference for the application of policies relating to tranquillity, together with the mapping of dark night skies also undertaken by CPRE. Whilst it has not been possible to undertake a precise analysis of the CPRE tranquillity data overlain by the NATS information, the areas that are affected by the extension to airspace appear to have a high level of comparative tranquillity. Similarly, these areas appear to have significant pockets of relatively dark night skies that may be affected by increased night time air traffic.

Visual intrusion is another factor that should be taken into account. This rates as a significant detractor of tranquillity, with seeing and hearing aircraft both featuring in the top eight responses in determining the 40 factors relevant to tranquillity

The Duty of Regard to the Purposes of Designation

I am sure you are aware that there is a statutory duty under the National Parks and Access to the Countryside Act 1949, the Environment Act 1995 and the Countryside and Rights of Way Act 2000 on ‘relevant authorities’ to have regard to the purposes of National Park and AONB designation in making decisions or carrying out activities. NATS and the CAA will need to satisfy themselves that their duties the Acts have been implemented. Not least of our concerns is the absence of any apparent consideration of alternative options for providing additional airspace capacity which would lessen or remove the impact on the local area arising from the current proposals, for example, approach over sea routes. In our view, the need for additional airspace has not been adequately proven since the benefits seem modest, and alternatives should be considered fully, including ‘do nothing’ and local stakeholders fully consulted on all the options.

In considering these factors, NATS and the CAA should be mindful of the probable uptake of the available airspace by increased numbers of aircraft movements. This will lead to a cumulative increase in the impacts set out above.

Transportation Considerations

Southampton Airport
Southampton Airport, is well located for road and rail access, being next to Junction 5 of the M27 motorway and close to the M3. It has a dedicated rail station (Southampton Airport Parkway) on the main line between London, Southampton and Bournemouth. These road and rail links ensure that the airport is a key transport interchange and is therefore well placed to be able to cater for additional traffic resulting from any increase in flights and passenger numbers.

Passenger numbers using the airport have increased from 485,000 in 1994/95 to 1.4 million in 2003/04 and the airport master plan, envisages air traffic growing to six million passengers by the year 2030, this will have a major impact on the local transport network. The Southampton Airport surface access strategy will need be updated in order to maximise the use of non-car modes for travel to and from the airport.

The County Council recognises the airport’s importance as a major transport interchange (Policy T10, Hampshire County Structure Plan 1996-2011 (Review) and Transport in Hampshire - a Framework for the Future). The airport’s location provides excellent opportunities to make improvements to interchange facilities for public transport. The County Council’s policy is to encourage local journeys to Southampton Airport where this is an alternative to longer journeys to Heathrow or Gatwick. The airport is increasingly adopting the essential role of an important hub on the local public transport network for non-flying passengers.

Bournemouth Airport
Bournemouth Airport is in the South East Dorset conurbation, but given its proximity to the county boundary and the transport links with Hampshire, developments have a direct impact upon the transport network within Hampshire. Approximately 0.5 million passengers travelled through the airport during 2004/05. The airport predicts significant growth over the coming years with passenger numbers expected to increase to 1.8 million by 2009/10.

The County Council recently objected to a planning application to expand the passenger facilities and car parking at Bournemouth Airport and the concerns expressed then are equally valid in relation to any increase in traffic resulting from the NATS proposals.

The major concerns being:
• The A31 through Ringwood and Avon Causeway are unsuitable in their present condition to take the type and amount of traffic likely to be generated by increased use of the airport.
• Developments need to make the best possible use of opportunities to reduce reliance on the private car. There are currently insufficient alternative means of transport to the private car to support potential increases in passenger numbers.

Community Engagement

Finally within the consultation document there is insufficient evidence to support the evaluation of impacts by stakeholder organisations, or indeed the local community. The County Council and its local government partners are not resourced to determine specialist technical impacts in areas such as aircraft noise impacts, and this is a deficiency in the consultation documents. Equally the local community has been provided with little notice of the consultation, and we believe that this is also a serious deficiency of the process. We would support local communities that are asking for an extension of the consultation process to enable them to engage and respond. However we would also recommend an improved consultation which sets out the alternatives and their implications for the matters of concern set out above. Until that time, the County Council is registering an objection to the proposed airspace extension.

Yours sincerely,

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