Below is the response of Hampshire County Council to the NATS Consultation Document, proposing new flight paths into Southampton and Bournemouth.
23 August 2007
Dear Sir George
NATS Consultation on Airspace Extensions
Thank you for your letter regarding the consultation being undertaken by NATS into extensions to airspace affecting Southampton and Bournemouth Airports.
I confirm that Hampshire County Council has responded to the consultation, and I have attached a copy for your information.
Director of Environment
Hampshire County Council
Corporate & Technical Centre
Hampshire PO15 7FL
23 August 2007
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.
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.
New Forest and Test Valley in western Hampshire are largely undeveloped areas of the County, free from the noise and activity of the more urban parts of Hampshire. They contain 2 nationally designated areas in the New Forest National Park and the North Wessex Downs Area of Outstanding Natural Beauty, where protection from the impact of activity can be expected.
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 NA TS 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.
The January 2002 Department for Transport' Guidance to the Civil Aviation authority on environmental objectives relating to the exercise of its air navigation functions' recommends that more than one option should be consulted upon and that if this is not the case clear reasons should be given as to why only one option is being considered.
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, NA TS 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.
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.
The County Council's Local Transport Plan sets out the road access issues associated with airport expansion. Journeys to Southampton Airport have a considerable impact on the local and strategic transport networks. Junction 5 of the M27 is one of the busiest sections of the strategic road network. Traffic levels at the junction in 2004 were recorded as 34% above the junction's design capacity and it is predicted that traffic levels at this junction could grow to 160% by 2026 at current levels of growth and up to 169% if land use scenarios included being considered as part of the South East Plan. Similar levels of overcrowding are predicted on rail connections. The station car park at Southampton Airport Parkway is at capacity and the operator has already submitted plans for a major expansion.
The area of the airport will need major investment to accommodate improved interchange and development. The County Council has recently commissioned a strategic transport study looking at access to the South Hampshire Sub-Region, this includes a thorough assessment of the access issues and infrastructure needs for Southampton 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:
(a) 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.
(b) Developments need to male the best possible use of opportunities to reduce
reliance on the private car. There are currendy insufficient alternative means of transport to the private car to support potential increases in passenger numbers.
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 lime notice of the consultation, and we believe that this is also a serious deficiency. of the process.
The 2002 Guidance referred to above recommended that in addition to local authorities consultation should be carried out with other organisations and individuals who may represent the interests of people living there, which should clearly have included parish and town councils.
We would therefore 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.
Director of Environment