The Consultation Response Form from the Department for Transport (DfT) has some ‘technical’ questions, to which we suggest you simply provide a minimal response, then focus on the evidence of your own experience where relevant. Do take our response below as a touchstone but use your own wording where possible.
CONSULTATION RESPONSE FORM
The Department for Transport would welcome your views on:
1. whether or not Bristol Airport should be designated as fully “Coordinated” for the purposes of the EEC Regulation No 95/93 on airport slot allocation, from the Winter 20/21 scheduling season onwards; and if so, 2. whether to approve Airport Coordination Ltd (ACL) as the coordinator for the airport.
A series of questions are set out below. Wherever possible please give reasons or provide evidence to support your answers. The boxes will expand as you type. You would also be welcome to include further views if you wish.
|Your name Job title|
|Organisation|| Stop Bristol Airport Expansion|
|Question 1 Do you believe that the capacity analysis produced for Bristol Airport by Mott Macdonald meets the criteria in the Slot Regulation as referred to in paragraph 8 of the consultation document? If you disagree please provide evidence (where possible) to support your reasoning.|
|Response : See below|
|Question 2 Do you agree with the capacity analysis conclusions on the aspects of capacity considered, and its overall conclusions on the capacity position at Bristol Airport? If you disagree, please provide evidence (where possible) to support your reasoning.|
|Response : No. Firstly, SBAEx does not believe that it is appropriate for this consultation to take place during a time of national emergency, particularly given its potential impact on the future financial framework underpinning the entire aviation industry. Secondly, the consultation is based on the assumption that the current capacity level of Bristol Airport has been changed by a planning application 18/P/5118/OUT submitted to North Somerset Council and determined on 10 February. This application was refused and the Council’s decision has now been ratified. Bristol Airport now have a six month window during which to lodge an appeal against the decision of North Somerset Council. Thus, current capacity remains under application 09/P/1020/OT2 growth to 10 mppa, not 12 mppa as proposed. The consultation therefore is based on a false assumption. Thirdly, SBAEx does not believe that the Secretary of State for Transport can consider designation of Bristol Airport as a coordinated airport during all hours of both summer and winter seasons with effect from the Winter 2020/21 season, as concluded by the Mott MacDonald Report. The report titled ‘Demand and Capacity Assessment 2019’ is based on current capacity levels. The current capacity level is set under the planning consent of application 09/P/1020/OT2 in which there are ‘Night Restrictions’. One of these is planning condition 38 which states that the number of take-offs and landings between the hours of 23:30 and 06:00 is limited to 3000 in the summer season and 1000 in the winter season within any one year. The airport is already partially coordinated in the summer months to maximise night time flying. Therefore the only way to become fully coordinated is to remove the condition set under the previous planning consent of 2011. We also question why the consultation states that the designation as a ‘coordinated airport’ should take effect from the Winter 2020/21 season, when capacity of the airport is not predicted until mid 2021 at the earliest. There are now coherent reasons why growth may not reach capacity levels even in 2021 with Brexit, impacts from the Coronavirus and the knowledge that there is a climate emergency resulting in changing travel behaviour in both business and leisure sectors. The Bristol Airport Noise Action Plan (BANAP) 2019 – 2024 consultation was held in July 2018. It was approved by Defra and adopted by the airport in February 2019. The consultation document failed to mention that planning condition 38 – the number of take-offs and landings between the hours of 23:30 and 06:00 limited to 3000 in the summer season and 1000 in the winter season – would change within this period to that of an annual limit. Yet the Noise Action Plan did state ‘In association with a successful planning application the quota count system will be reviewed’. It is important for the consultation to maintain transparency on the issue of noise which is so important to communities. The consultation for the Noise Action Plan was held in July 2018 as the airport planning application was submitted to North Somerset Council in December 2018. The Noise Action Plan adopted by Bristol Airport contains many of the new noise reduction measures within application 18/P/5118/OUT. Communities will benefit from these regardless of the outcome of the planning application and the public inquiry. The planning application gave nothing additional to communities and instead offered more day time aircraft movements removing the remains of any tranquillity left to communities and an increase in night flights during the summer months. We therefore object to any change in the Night Restrictions proposed in the consultation. We believe that any change in Night Restrictions will need to be discussed at a public inquiry.|
|Question 3 On the basis of the capacity analysis, do you believe that Bristol Airport should be designated as fully Coordinated on a permanent year-round basis for the purposes of slot allocation from Winter 2020/21? What are the key factors supporting your response?|
|Response : No See above|
|Question 4 If you do not think that Bristol Airport should be designated as fully Coordinated, do you think that it should: a) remain designated as coordinated for the summer scheduling period and schedules facilitated in the winter scheduling period? b) be undesignated? What are the key factors supporting your response?|
|Response : (a) Remain unchanged SBAEx does not support any alteration to the status of Bristol Airport that changes the current night flying regime.We note that the Mott Macdonald consultation Report states ‘Changes to Night Restrictions. Unlike the London airports’ night restrictions, which are subject to a regular 5-yearly review process, the Bristol Airport night restrictions are fixed in the planning condition. Therefore, there is no mechanism to change or remove the restrictions except by a new planning permission.’ On 18 March, North Somerset Council ratified the decision to reject planning application 18/P/5118/OUT. We now fully expect that, if Bristol Airport appeals, there will be a public inquiry. The night noise regime will then be discussed. It is not acceptable to increase flights within the summer months or any other period within the year. Conditions are set for many reasons including, importantly, to protect communities from the adverse impacts of airport activities such as noise from night flying and associated traffic and parking disturbance. It seems perverse that as a limit is reached on an activity with major impacts, it is then lifted.|
|Question 5 Do you believe that designating Bristol Airport as fully Coordinated would give rise to the benefits mentioned in the capacity analysis? What are the key factors supporting your response?|
|Response : No, see above|
|Question 6 Are there further positive impacts that should be considered? If so, what do you think is the magnitude of those impacts and who is likely to benefit?|
|Response : No|
|Question 7 Are there disadvantages, including hidden cost increases or other potentially adverse effects on your business, or the interests you represent, that also need to be taken into account? If so, what do you think is the magnitude of those impacts and who is likely to be affected?|
|Response : Yes. The Stop Bristol Airport Expansion (SBAEx) alliance was formed to oppose the unsustainable expansion of Bristol Airport. It now includes strong links with regional organisations including many North Somerset Parish Councils, Extinction Rebellion Bristol, the Somerset Campaign for the Protection of Rural England, the North Somerset and Bristol Green Parties, Bristol Friends of the Earth, Bristol Clean Air Alliance, My World, My Home students, and the Bristol Airport Parking Community Association (BAPCoG). There are numerous problems from both aircraft noise and the consequent increase in vehicle traffic to and from car parks at night which cause sleep disturbance and heart disease. These will be increased by the roll-out of fully Coordinated status. The World Health Organisation (WHO) recognise noise as an ‘underestimated threat’ that has significant Public Health effects. They advise decibel (dB) levels of less than 30db(A) in a bedroom for good quality sleep. It is not possible to verify the airport’s fleet mix projections, and the claim that quieter aircraft will arrive as suggested in the airport application 18/P/5118/OUT or the Mott MacDonald Report. The report states ‘Aircraft operating at Bristol Airport are expected to get quieter in coming years with the introduction of new types such as the A320neo and B737Max.’ This is not a guarantee. Neither the Local Authority nor an airport has control over the delivery of these quieter aircraft, only the airlines. Quieter aircraft should be used to mitigate the night noise now and not as an excuse to increase night flights. Even quieter aircraft will still generate noisy night time vehicle traffic to & from parking areas servicing passengers.|
|Question 8 If Bristol Airport is designated as fully Coordinated, do you agree that the Secretary of State for Transport should approve the appointment by the airport operator of Airport Coordination Ltd (ACL) as the coordinator for the purposes of the EEC and UK regulations? What are the key factors supporting your response?|
|Response : No|
SUBMITTING YOUR CONSULTATION RESPONSE (UPDATE)
We have considered the timing of this consultation, and in light of the COVID-19 pandemic, we will be extending this for a further 12 weeks.
The previous deadline (Friday 3rd April 2020) has now been extended to Friday 26th June 2020.
If you would like to submit your views as part of the consultation, please return your completed response form by email by this date – titled “Bristol Airport slot coordination consultation” to:
This email account will be monitored throughout the consultation period.
The documents relating to the consultation can be found on the Department’s gov.uk web page at the following address – https://www.gov.uk/government/consultations/bristol-airport-designation-as-a-coordinated-airport
Please note that we will not be able to consider consultation responses received after the closing date. If you have already submitted a response to this consultation, this will still be considered. Should you feel that you wish to now submit a revised response, you are welcome to do so but please do highlight this to us when you submit it so we can disregard your previous response.
Alternatively, you can send your completed response by post to:
Josie Fieulleteau, Airports and Infrastructure Directorate, Department for Transport, Great Minster House, 33 Horseferry Road, London SW1P 4DR
Please note that we will not be able to consider consultation responses received after 26 June.
NOTE: Should this ‘co-ordinated designation’ be approved, the change would now be implemented in the Summer 2021/22 scheduling season (originally this was planned for Winter 2020/21).
This consultation is being conducted in line with the Government’s key consultation principles. Further information is available at: https://www.gov.uk/government/publications/consultation-principles-guidance
Consultation reference DfT-2020-02