SBAEx representation to the Public Inquiry …

…. looking into the Bristol Airport appeal against North Somerset Council’s rejection of a planning application to expand.

SEE ALSO OUR GUIDELINES on making a personal response to the Inquiry (live link)

Application No. 18/P/5118/OUT & 20/P/2896/APPCON

WHO WE ARE
The Stop Bristol Airport Expansion (SBAEx) campaign was founded in 2004 and regenerated in 2018 when over 100 people met together in Redhill to decide how best to combat the new Airport expansion application. SBAEx draws support from across the West region and beyond, providing resources for community information and action and holding to the importance of effective community participation in planning decisions. It opposes and acts against the many damaging regional effects of Airport expansion and connects with initiatives in the UK and beyond to counter the global climate emergency.
For further information see our website: https://www.stopbristolairportexpansion.org/

OBJECTIONS TO EXPANSION
1     Expansion is unnecessary. This tourist airport (85% leisure traffic) meets the leisure needs of the region perfectly well and serves the business community effectively at is present size. Business travel is unlikely to increase significantly and the Airport still has 15% headroom to grow under current planning permissions. The case for expansion by 25% from 9 mppa (2018) to 12mppa is motivated by the commercial drive to become a hub airport rather than serve as part of a regional network for the West, South West and South Wales.

2     Expansion is evasive The UK government is belatedly acting to meet the challenge of the climate emergency and this appeal is a desperate attempt by the Airport to outflank a possible cap on passenger numbers and other constraints in the upcoming environmental and aviation legislation, notably the Environment Bill (last debated on 26 January 2021), ‘Aviation 2050: the future of UK aviation’, and the 6^th CCC Budget (Dec 2020).

3     Expansion is unacceptable, increasing GHGs and particulate emissions from aviation that pose such a fundamental challenge to the health and wellbeing of regional communities. The Airport claims that increased emissions are ‘not significant’, yet credible projections show that the increased GHG emissions from the Airport operation would negate the substantial efforts under way by city, town and village communities across the region to reach net zero emissions by 2030.

Reducing carbon emissions from ground transport is a plank of government and regional policy. Yet Bristol Airport is encouraging passengers to ‘fly local’ thereby ‘reducing road journeys to London and reducing pollution’. However, traffic emissions cause far less pollution than flights and that London airports are just as accessible from the East of the region; the argument hopes to distract from the fact that expansion is designed to funnel passengers from and beyond the region into North Somerset, creating up to 9,500 additional passenger and service vehicle movements daily, to feed the car park and retail operations.

In compensation the Airport proposes to offset carbon emissions from passenger and service traffic to and from the Airport. This is a course pure greenwash since no amount of offsetting reduces by one gramme the emissions pumped out across the region.

4     Expansion is unacceptable given the damaging impact of aviation noise on mental health and well-being of interrupted sleep is well established as the Airport itself recognises. Pre-pandemic level of aviation noise by day were already unacceptable and night flights caused widespread sleep disturbance and anxiety.
Lifting seasonal restrictions on night flights goes beyond nuisance – it is an inhuman addition to the debilitating impact on many communities beneath and adjacent to flight paths already affected by issues of mental health and well-being caused by aviation noise.

Airport expansion will also exacerbate the problems of noise arising from 24-hours access to the Airport from the A38 and the network of country lanes adjacent to the Airport as passengers search out the remote unauthorised and illegal parking sites. The Airport has no control over this collateral damage.

5     Expansion is unacceptable, creating yet further traffic congestion on and around the A38. The lack of public transport to the Airport is compounded by the inadequate road access. From both North and South the A38 is the sole means of getting to the Airport. For most of its length, this road is single lane each way with sections for overtaking (often badly designated and frequently abused). The only other option is to navigate to the A38 near the Airport through narrow country lanes.

There is no possibility of serious road widening for the A38 through the South Bristol suburbs nor beyond, where is squeezes between the Barrow tanks (the reservoirs that cover around 120 acres to provide mains water to the city). Little wonder that Bristol airport has the highest modal share for driving to the airport of any UK airport of its size or larger.

The ‘road improvements’ proposed by the Airport, which we understand the CPO request will now form part of this Inquiry, amount to some minimal tinkering with land bordering the A38 at the Downend Road junction. This should be seen in the context of the frequent road works and traffic incidents that characterise the A38, creating gridlock in the narrow country lanes that offer the only possibility for diversions resulting in complete disruption for agricultural traffic and local residents who, given the dearth of public transport, have no option other than the car for social, domestic and professional life.

6. Expansion is unacceptable given the inevitable growth of authorised, unauthorised and illegal car parking.
Airport parking sites

As with many airports, the commercial viability of Bristol Airport rests on the need to maximise income from secondary activities: retail activities and car parks. Expansion will create provision for 6,350 cars, including 2,700 vehicles sprawling across good quality agricultural land within the Green Belt without the ‘exceptional reasons’ required by the NPPF. In fact a key aim of expansion is to exploit the appalling public transport access to the Lulsgate site, used by just 12.5% of passengers (with no rail or metro links in the foreseeable future), to maximise profit from its near-monopoly on authorised parking (warned against by the CAA).

Unlicensed and illegal car parking using a range of green and brownfield sites beyond the Airport boundaries causes many issues for local communities including increased and often hazardous traffic with drivers unused to rural lanes, 24-hour noise from traffic seeking these parking sites, much nuisance in country lanes (from litter to improvised toilets), and parking blight across the landscape. Dump parking is a serious problem in nearby villages with cars scattered through residential streets by those seeking to avoid any parking payment and can provoke retaliation.

The Airport claim that more ‘on-site’ parking is the solution to the problems of uncontrolled development of unauthorised car parks around the Airport and antisocial parking in local neighbourhoods. The fact is that Airport expansion will simply increase the number of passengers using these ‘off-site’ facilities to the further detriment of the local communities. North Somerset Council has long since acknowledged that it doesn’t have the resources to enforce regulation, and fleet-of-foot pirate operators are preparing for a bonanza should Airport planning approval be granted.

7.         Expansion is insensitive  to the damage to natural habitat and landscape. The proposed parking site is less than 2km from a Special Area of Conservation. In particular, two endangered species of bat (Greater and Lesser Horseshoe) will lose habitat at a time critical to their survival. Spillage from car park lights affects wildlife by, for example, drawing insects away from the surrounding countryside and disorientating wildlife in a number of ways. We recognise the complexity of quantifying impact, but expansion comes at a high cost to the natural habitat and the many aesthetic and historical qualities of natural environment and landscape, as well as visual and aural impact on impact on the adjacent Mendip Hills, AONB with SSSI. The pylon-mounted lights in the Silver Zone park already diminishes the pleasures of contemplating the night sky, an important part of rural life for many people.

8.    Expansion is indefensible, prioritising economic gain over the health and wellbeing of regional communities. The Airport has always asserted expansion would massively strengthen the regional economy. However, a strong body of evidence shows claims of economic benefit are hyper-inflated, based on partial statistics and misleading statements. For example, they take no account of the tourist pounds funnelled from the region with consequent loss to the regional tourist, hospitality and retail sectors. The vaunted automation is likely to reduce employment opportunities, as it has done in other airports across the world.

As we are learning from the global response to the Covid pandemic, there is no economic argument that trumps health and well-being, and no economic benefit from Airport operations, such as might exist, can compensate for the negative impacts of aviation on health, quality of life and productivity.

9.         Expansion is unsustainable for future generations. The Airport has made no attempt to show that expansion is based on sustainable principles such as meeting our own needs without compromising the ability of future generations to meet their own needs.



The Airport could have chosen alternative development paths bearing in mind the advice of the Local Enterprise Partnership that  ‘taking action on climate change should also have substantial economic benefits for the region. Growth in carbon efficiency amongst businesses and within the green economy can help to increase productivity and help to create good jobs as well as protecting the climate and environment.’

The Airport owners, the OTPP, should now heed current developments. The French government, for example, is scrapping plans to expand the Roissy-Charles de Gaulle airport on the grounds that it does not fit with current environmental goals and has asked the airport operator ADP to present a scheme consistent with national strategies to combat climate change and protect the environment.

The Airport should withdraw from the appeal process, go back to the drawing board and develop a business plan fit for the 21st Century, based on a sustainable vision and strategy in line with the recent route map set out by the UK Government’s Climate Change Committee (Dec 2020) to reduce carbon emissions by 80% by 2035. Longer-term growth must be in lock step with developments in aviation, surface transport and fuels technologies to deliver the necessary reduction in GHG emissions. The Airport cannot continue with the illogical claim to be ‘net zero’ by simply excluding all reference to its core operation: servicing airlines and aircraft.

10.  Expansion is undemocratic. The Airport has long since looked on North Somerset as a private fiefdom, acting with a strong sense of impunity. One example is the consistent abuse of permitted development, such as the recent erection of a new office building on the skyline of the sub-Mendips that was immediately put on the rental market.


In line with the sense that it is accountable only to itself, the Airport appeal wilfully ignores the massive opposition voiced by North Somerset and other regional electorates. City councils (including Bristol and Bath), regional town councils, an overwhelming majority of parish councils, and a wide range of community groups have all taken a democratic decision to oppose Airport expansion. They are supported by the regional Members of Parliament who have also voiced opposition to expansion. Over 8,000 people also voted against expansion in the public consultation organised by the LA (an extraordinary response for this kind of consultation). 

Conclusion
North Somerset Council’s decision to reject the Airport planning application is entirely in line with LPA policies, public concern, the National Planning Policy Framework and UK Government legislation. Our objections support the reasons for rejection set out by North Somerset and we believe that the LPA was fully justified in refusing the Airport’s application for expansion, and that this obdurate appeal should be dismissed.

End note
We welcome this Public Inquiry as an opportunity to scrutinise the Airport arguments although we condemn the Airport’s choice to pursue the appeal, which places a huge financial burden on North Somerset Council and its communities – money desperately needed to support social services, education and other public resources during the Covid pandemic.

Planning should prioritise the impact of proposals on people so we ask the Inquiry to place substantial weight on the views of the regional communities. We are greatly dependent on the PI directive that ‘local people are encouraged to take part in the inquiry process. Local knowledge and opinion can often be a valuable addition to the evidence given by the appellant and the local planning authority.’ Local knowledge and opinion are now very well informed, despite a degree of exhaustion in the face of the Airport’s well-funded information haze.

Finally, many people have experienced problems with planning processes, including decisions about who participates and when, the purpose of participation, how information is provided to participants, and how the process is organised. To reverse the North Somerset Council decision would further harm public perceptions and confidence in the planning system as an effective instrument to combat the climate emergency and enact the democratically expressed wishes of our communities.

References
For the sake of brevity we have included only a few exemplary references from the substantial literature that inform this submission, omitting local and national policy documents, reports, debates and so on.

Section 1
‘Business travel’: see, for example, https://www.reuters.com/article/us-travel-flying-climate-idUSKBN1WH23G
Section 2
‘Cap on numbers’: see for example: https://www.thetimes.co.uk/article/airport-growth-plans-fly-in-face-of-climate-targets-xrwnmlbck
‘CCC budget’: The 6th Climate Change Committee Budget (Dec 2020) See table, Aviation supplement,8.1. https://www.theccc.org.uk/wp-content/uploads/2020/12/Sector-summary-Aviation.pdf
Section 3
‘not significant’: (https://www.bristolairport.co.uk/about-us/who-we-are/our-future/planning-application) promises that ‘net carbon emissions from flights will be stabilised at 2020 levels through the implementation of the Carbon Offsetting and Reduction Scheme for International Aviation.’
‘credible projections’: https://www.isonomia.co.uk/just-plane-wrong-bristol-airports-expansion-application/
‘fly local’: See for example, Professor Steve Melia, University of the West of England. Stevemelia.home.blog/2019/08/01/bristol-airport-why-the-expansion-case-doesnt-add-up.
Section 4
‘Airport … recognises’: Bristol Airport website (ref tba)
Section 5
‘modal share’ Melia
Section 6
NPPF: National Planning Policy Framework
‘CAA’: Consumer & Markets Group (CAA)18 Sept 2018 ‘Open letter to airport operators following CMA airport car parking investigations’
Section 8
‘benefit hyper-inflated ’: New Economic Foundation (NEF Consulting) / CPRE, ‘Evaluating the Case for expansion of Bristol Airport’ (2019); ‘Response to York Aviation rebuttal’ (2019)
‘automation’: see, for example, http://www.airport-business.com/2019/06/airports-investing-automation/
Section 9
‘LEP’: LEP Update Report (presented to the WECA for debate on  31 January 2020)
‘RCdG Airport’: https://www.politico.eu/article/french-minister-roissy-charles-de-gaulle-airport-expansion-scrapped/
End Note
‘PI directive’: Para.9.1, https://www.gov.uk/government/publications/planning-appeals-dealt-with-by-an-inquiry-taking-part
‘information haze’: SBAEx press files and website