Written evidence from the General Awareness Aviation Council (SMA0018)

 

 

Para 3: 21,000 GA Aircraft and 32,000 Pilots use smaller airports in addition to the 900 Commercial Air Transport aircraft.

 

Para 6: Gloucester Airport supports 570 Direct jobs and an estimated 4,500 are employed in the cluster of aviation related activities. This illustrates the need to consider the worth of all GA aerodromes.

 

Para 7: The DfT has commissioned York Aviation LLP to update the Lober GASAR Study of 2006. York is to report on the Economic Contribution of GA to the UK Economy. The Transport Select Committee should consider this independent report when it becomes available in January 2015.

 

Para 9: The Planning Process is expensive and protracted.

 

Para 12: It is recommended that ‘official safeguarding’ be extended to all economically regulated and other aerodromes where safeguarding maps have been deposited with an LPA.

 

Para 17: It is recommended that ODPM Circular 01/2003 should be amended to improve LPA/CAA /Airport Operator consultation, with particular reference to obstacle safety.

 

Para 19: Recent Airport closures such as Manston illustrate the continuing loss of Airport infrastructure over many years which must be halted if the essential network of airfields is to be maintained. The GAAC has today learned that Balfour Beatty are to close Blackpool (235,000 passengers last year) with the loss of 110 jobs and another important smaller airport  We would recommend that the practice in other countries where a Public Inquiry must be held before the closure of an airport should be adopted in the UK.

 

Para 21: The National Planning Policy Framework Clause 33 needs to be strengthened to ensure that Airports are better protected against Housing, Wind Turbine and other ‘sustainable’ development.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Dear Sirs,

 

  1. The GAAC is supported by the Airport Operators Association; British Business and General Aviation Association; Honourable Company of Air Pilots; British Helicopter Association; Aircraft Owners and Pilots Association; Light Aircraft Association; British Microlight Aircraft Association; British Gliding Association and some 60 other aviation related associations with a membership totalling over 40,000. It has the authority to speak on matters related to landing and take-off sites.

 

  1. General Aviation, together with aerial work, covers all civil aircraft activity other than that carried out by the commercial air transport (CAT) sector and Military. GA includes business flights, pipeline work, police and pollution patrols, traffic surveys, medical flights, newspaper and postal flights, aerial surveys, civil search and rescue operations and pilot training.

 

  1. Whilst the CAT sector operates about 900 aircraft and uses 25 airports, the GA fleet exceeds 21,000 aircraft, including helicopters, gliders, microlights and balloons. These aircraft are flown by more than 32,000 pilots.

 

  1. We welcome the Select Committee’s consideration of the role of smaller airports.

 

  1. The Government’s Response to the GA Red Tape Challenge (November 2013), paragraph 1.6 stated that:

 

“The 2006 Strategic Review of General Aviation, drafted by the CAA, estimated the GA industry to be worth approximately £1.4bn in 2005, and notes that this is similar to Virgin Atlantic’s 2005 turnover of £1.6bn. This is higher than investment in UK film production in 2010.”

 

  1. The data above refers to the Lober Report (http://www.gaac.org.uk/gasar/gasar.htm), research into GA jointly sponsored by Department for Transport and GAAC. This comprehensive research has not been formally updated. However, in the absence of updated research some airports have produced independent studies, such as a 2012 study “The Economic Value of Gloucestershire Airport” (PDF available on request): that study identifies that there are 50 firms based on the airport which together with the Airport’s staff support over 570 jobs; that an estimated 4,500 jobs are based on and around Gloucestershire Airport, and the airport “forms the centre of a cluster of aviation-related and other employment activity…This supports a wider supply chain of businesses in the area…”

 

  1. The importance of new research has also been identified in the General Aviation Challenge Panel Report of May 2014, which states:

 

“The UK aviation sector as a whole is of considerable economic importance. Civil aircraft parts are the UK’s third largest manufactured product, by sales value, with a value of £6.4 billion, and £3.1 billion of sales are in repair and maintenance of civil aircraft. GA is critical to ensuring awareness of and enthusiasm for all aspects of aviation and aerospace [and] is a valuable source of recruits…”

 

  1. The DfT has recently commissioned York Aviation LLP to carry out research into the economic impact of GA and update the Lober Report.

 

  1. Small airports have identified planning as a major issue affecting their long-term viability. Airports have struggled to get planning permission to replace and upgrade infrastructure. These difficulties include replacing existing infrastructure such as old hangars; improving existing infrastructure such as converting a grass runway to a hard runway; and developing new infrastructure such as new buildings.

 

  1. An example is Sywell Airport: the local plan had supported aviation improvements at Sywell, and the aerodrome submitted a planning application for an all-weather runway. After two years the council had failed to decide the application so the aerodrome appealed on grounds of non-determination and permission was granted. Then a pressure group sought judicial review of the decision, subsequent to which there was a further undecided planning application and appeal on grounds of non-determination. After many years the aerodrome finally gained permission for the hard runway, but enormous costs were run up by both the aerodrome and the council.

 

  1. The approaches of local authorities towards GA are significant. The Lober Report said that only 26% of local planning authorities saw GA as having a notably positive role in providing recreational, business and emergency needs, while 18% specifically thought GA had no role to play. Also, 41% of local planning authorities indicated they would offer no proactive protection to offer planning safeguards for flying sites. It was noted that 30% indicated that, if asked, they might or would seek to protect flying sites, but only 7% said they would.

 

  1. Smaller airports have also identified the protection of existing aerodrome infrastructure from the development of obstacles as a critical issue. This problem has been raised by, among others, the Airspace and Safety Initiative “Managing the Impact of Wind Turbines on Aviation”, 2010:

 

“The introduction of obstacles in the vicinity of an aerodrome, particularly one that is used for flying training purposes, can reduce the areas available for pilots to use in the event of a forced landing, such as an engine failure after take-off. Even if the safety impact of new obstacles can be mitigated there may be a resulting loss in amenity due to the mitigation, or the perceived effect of the obstacle, that makes the aerodrome less attractive for potential users, with corresponding financial impact.”

 

  1. The mechanism which should assess potential obstacles near aerodromes is safeguarding. CAP 738 Safeguarding of Aerodromes contains a list of ‘officially’ safeguarded aerodromes. However, since the transfer of safeguarding functions from CAA to LPAs several years ago, there appears to be no mechanism by which aerodromes can now become added to the list of officially safeguarded aerodromes. We recommend that at the least all economically regulated aerodromes should be given ‘officially safeguarded’ status - or indeed, all aerodromes where safeguarding maps have been deposited with an LPA.

 

  1. In addition to describing ‘official’ safeguarding, ODPM circular 1/2003 says:

 

“Operators of licensed aerodromes which are not officially safeguarded, and operators of unlicensed aerodromes and sites for other aviation activities … should take steps to protect their locations from the effects of possible adverse development by establishing an agreed consultation procedure between themselves and the local planning authority or authorities. One method, recommended by the Civil Aviation Authority to aerodrome licensees, is to lodge a non-official safeguarding map with the local planning authority or authorities. Local planning authorities are asked to respond sympathetically to requests for non-official safeguarding.”

 

  1. This request that local planning authorities respond sympathetically does not work well or consistently. Sometimes LPAs resist unofficial safeguarding, for example an application was made for a safeguarding zone around an aerodrome in the south-west but the council instead offered a “constraint maps” agreement, and other local authorities have also resisted becoming involved in the bureaucracy required. Sometimes local authorities lose safeguarding maps, for example Denham discovered in 2008 that its local council had lost the safeguarded maps that had been deposited. Even if a local authority accepts a safeguarding map they still don’t always remember to adhere to it and they do not notify the aerodrome operator of applications for development, for example failing to consult with an aerodrome operator when a county council shortlisted a site close to the end of a runway for a waste incineration plant with a tall chimney.

 

  1. The CAA only formally obliges LPAs to refer planning applications in the vicinity of an aerodrome for their assessment for 27 civil aerodromes. For the remainder, it advises that the LPA should give due consideration to the expertise of the aerodrome operator. The CAA’s stated view is that:

 

“An aerodrome operator is normally competent to assess the safety parameters which affect the amenity of the site, and qualified to provide expert advice to planning authorities. The comment of third parties has less value as it lacks the detailed knowledge that can only be gained by site-specific experience, and will also be without the element of future planning which only the aerodrome operator will know.”

 

  1. However, when it comes to balancing an aerodrome operator’s opinion and a developer’s application there are tensions with which local authorities struggle. ‘Unofficial safeguarding’ excludes authorities from obtaining CAA input, and the lack of CAA oversight and the variable attitude of planning authorities leads to patchy outcomes. A particular point of difficulty appears in relation to the cumulative impact of developments - while hazards associated with one development might have the potential to be mitigated by change to aerodrome procedures, the same cannot be said for subsequent developments. It would be greatly preferable if the aerodrome operator were consulted at the earliest possible stage, because all too often the aerodrome operator’s opinion is only considered at a stage where a developer has already spent a considerable amount of money and is determined to push it’s proposal ahead.

 

  1. Similar points have arisen in consideration of en route obstacles, recently in the AAIB report on the accident to G-CRST. Safety recommendation 2014-028 refers to ODPM circular 01/2003 which requires that local planning officers notify CAA whenever they grant planning permission for developments that include an obstacle. We recommend that ODPM Circular 01/2003 should be amended to request that the LPAs notify both the CAA and any aerodrome operator whenever a planning application is received which includes an obstacle within 4km of any flying site or known low flying route.

 

  1. It is significant that any adverse results of a planning application which is permitted in contravention of an aerodrome operator’s opinion could in future place an LPA in a position of liability, and it would benefit LPAs that the situation be clarified.

 

  1. The Committee has expressed interest in receiving evidence on housing and enterprise zones. These are possibly the single biggest threat to GA aerodromes in UK today, given developers’ interest in aerodromes as potential housing locations. There has been an acceleration in the already worrying trend of aerodromes closing or coming under threat. The most high-profile airport closure in recent months has been Manston in Kent, despite concerted opposition from local residents, employees and politicians. Planning permission has been granted to build housing on Hucknall Aerodrome. Bourne faces inclusion in South Cambridgeshire’s plan as a location for a garden village. Long Marston has been designated in the council’s draft strategy as a preferred location for housing. Wellesbourne faces a planning application for housing. Panshanger was threatened by proposals within the local council’s core strategy and the aerodrome closed a few weeks ago. And the list continues with Blackpool the latest target. Much of the problem arose following the deletion of the footnote in PPG3 noting that airfields and hospital grounds should not be considered ‘brownfield sites’. An assurance given to our President, Lord Rotherwick by Baroness Andrews and in the lower house by Yvette Cooper has been overtaken by events.

 

  1. NPPF paragraph 33 is intended to protect the sustainable transport system:

 

“When planning for ports, airports and airfields that are not subject to a separate national policy statement, plans should take account of their growth and role in serving business, leisure, training and emergency service needs. Plans should take account of this Framework as well as the principle set out in the relevant national policy statement and the Government Framework for UK Aviation”.

 

  1. However, despite the above, local planning authorities are prioritising housing and other development. The GA Challenge Panel Report states:

 

“… the majority of people, including local government and councils (for fiscal and housing delivery reasons) generally do not consider the potential economic value of aviation or unlicensed aerodromes. As a consequence, fewer individuals are willing to take the financial risk of set up and developing a site and this is a prohibition to encouraging growth in the sector.”

 

  1. The GA Challenge Panel further states that:

 

“… the allocation of these unlicensed sites as brown field, and their inclusion in the strategic housing land availability policy means that when applications for re-development are submitted to the local planning authority there is no planning policy to support their retention. These sites need to become a material consideration and safeguarded in order to carry weight at a planning committee…”

 

  1. Different aspects of GA appear at different aerodromes and airports. For example, at a regional airport a GA aircraft may be a bizjet, and regional airports generally don’t encourage flying training. So smaller aerodromes perform the function of a hub, and are important not only in terms of regional connectivity but also in terms of local amenity because they offer a great diversity of aviation activity including flying training and access to sport aviation.

 

  1. While the EU is supportive, providing an Agenda for Sustainable Future in General and Business Aviation, COM(2007) Final, there is no doubt that the initial position adopted by EASA was heavy-handed and added greatly to the cost and regulatory burdens faced by Sport and Recreational Aviation. UK GA is being reviewed by the CAA for a more proportionate regulatory approach to aerodromes. We support this development and hope that the momentum will be maintained so that aerodromes can continue to provide opportunities for regional connectivity and the wider economic benefits that flow from the aerodrome network, as well as better capitalise on the UK’s aviation and aerospace innovation and experience.

 

Yours faithfully,

 

Charles Henry FRAeS FCMI MCIM

Chairman GAAC

September 2014