The three District Councillors for Wharfedale have all submitted their objections to Leeds Bradford Airport's planning application over problems with the application as well as concerns over noise and air pollution, particularly in Burley and Menston.
Should you wish to comment the last date for submission is Friday 10th July using the below link:
Then enter 20/02559/FU in the search box, which will take you to the application summary page where you can read other people’s comments and make your own.
The full objections of Cllrs Gerry Barker, Dale Smith, Jackie Whiteley can be found below:
Cllr Gerry Barker's comments:
The present planning application made by Leeds Bradford Airport Authority (LBAA) actually comprises of two separate aspects:
- a new modern terminal building
- an extension to flying hours
and should be considered as two separate and distinct applications. The latter aspect also concerns the flight-path taken by the majority of aircraft to and from Leeds Bradford International Airport (LBIA).
In my view, the proposal to build a new modern Terminal building is welcome, as is also the intention to develop the airport to accommodate the growth in the public’s demand for better and wider services.
However, there are several highly concerning issues raised with the second part of this proposal, which I cannot support it in its present form, namely with regard to air and noise pollution.
These issues are also of major concern to the official liaison representatives, both those present and past, of the residents of Menston and Burley in Wharfedale, as well as other resident's bodies within both villages.
Further air pollutants and carbon emissions also run contrary to both Leeds MDC and Bradford MDC’s declared climate change commitments.
Additionally, these issues are also of great concern to the Independent Commission on Civil Aviation Noise (ICCAN), which is a non-statutory, advisory body created to provide independent, impartial advice to government, regulators and the UK aviation industry and sponsored by the Department of Transport.
I would also add that the last application made by LBAA to develop the airport was refused by the Civil Aviation Authority (CAA), the statutory corporation that oversees and regulates all aspects of civil aviation in the United Kingdom.
The public expects, indeed demands, the provision of air travel so they may go on holiday, visit relatives and friends, and attend to business. The question is how best to achieve this without adding greatly to the present levels of pollution?
LBAA are boasting that the new modern terminal building will be carbon-neutral. This may be so, but what about all of the extra passengers that will travel in private cars to the airport to park, or arrive via taxis? The LBAA also fails to mention the substantial increase in carbon emissions expected from a minimum 300 extra flights per week (If every seat on each aeroplane is filled? If not, there will be even more flights). Again, LBAA fail to reveal the bigger picture and identify their lack of transparency with the public.
With regard to air pollution, the newer aircraft issue fewer pollutants into the air than the older ones did and further research, which is being driven by the government, is ongoing to find new ways to reduce the carbon footprint still further towards zero. This won’t be easily and quickly achieved, but has to be our short-term goal for the immediate future.
As regards noise pollution, the anticipated increase in flights, or Air Traffic Movements (ATMs), from 4m to 7m people, will cause this to get worse, if the present plans are approved. LBAA speculate that these levels will fall as new aircraft are introduced, but this is a commercial decision made by airlines and outside the control of LBAA.
Aircraft noise emissions are measured by Leeds MDC via noise monitors. These are placed approximately 1km away on either side of the NPR / SID and, consequently, do not measure the actual noise experienced by the residents whose houses are located beneath the swathe. An additional monitor has recently been located near to the NPR / SID, but will have limited information, due to the pandemic lockdown.
It has also been suggested that the calculation to measure the noise being emitted is out-of-date and, therefore, inaccurate, providing lower readings than those actually being experienced by residents. The measurements used are either by the 1992 methodology or that of 2009, but, apparently, the LBAA is unable or unwilling to say which it is.
Aircraft have a designated flight-path to follow, when taking-off and landing, called the Noise Preferential Route (or NPR) or Standard Instrument Departure (SID). The NPR / SID has a margin of tolerance on either side, termed the ‘swathe’, to allow for flight fluctuations in exceptional circumstances.
The CAA has stated that “It is the responsibility of the aircraft captain to follow the departure clearance, and in this case the coincident SID/NPR, as accurately as possible taking into account aircraft performance and weather considerations. There may, of course, be legitimate deviations but if the nominal track is not consistently being achieved, it is reasonable to expect the airport to take action to determine why this is occurring and take remedial action where practicable. Aircraft should adhere to the SID centre-line wherever possible and not deliberately use the extremities of the swathe as a matter of course. Finally, the swathe is not a zone within which operators can plot their own tracks; the objective remains NPR/SID track, but it must be recognised that legitimate fluctuations may occur.”
The NPR / SID for the majority (75-80%) of ATMs from the airport are over the fields between the villages of Menston and Burley in Wharfedale. However, according to residents under the ‘swathe’ (including myself), most flights rarely follow the NPR and fly within the ‘swathe’, which means they fly over the top of residential housing. Actually following the NPR appears to be the exception. Yet, despite many complaints over several years, regarding aircraft failing to comply with the NPR / SID, LBAA has failed to take any action.
This NPR / SID was necessarily agreed upon, in years gone by, between the CAA and LBAA, due to the obvious flight-path down the Wharfe Valley, having previously been claimed by the RAF as military airspace and not being available for civilian flights. That changed many years ago, when the RAF withdrew from its use, and the airspace became part of LBAA Controlled Traffic Airspace (CTA) and available to be used, which, for no readily apparent reason, they are refusing to do!
This would mean that departures would climb in a straight line for 5 nautical miles. This would negate flight fluctuations, which are regularly experienced when using the existing NPR / SID between Menston and Burley in Wharfedale. I understand that flying in a straight line will reduce the power required for ascent, thereby reducing the level of noise emissions and also require less fuel to be burned. Commonly referred to as a "Twofer"!
It is my belief that this alternative route would provide an elegant solution to one of the main issues currently being experienced and the primary issue that is of the greatest concern to residents.
LBAA have announced that they have consulted with residents on these latest proposals and that residents of Leeds support them. What they fail to mention is that these consultations took place only in Leeds and were attended by fewer than 190 people! Also that flyers and poster were posted at 27 (actually 26, as Burley in Wharfedale is duplicated) public information sites. These sites were at the Post Office, the Cricket Club and the Library in both Menston and Burley in Wharfedale. Because of the pandemic, only the Post Offices have been open to the public and, I would suggest, their customers have not lingered around the premises reading notices, but exited as quickly as possible.
What LBAA have also failed to mention is the lack of consultation with the residents over whom the majority of flights occur. When they last consulted with the residents of the villages of Burley in Wharfedale and Menston, part of Bradford MDC, via open day presentations, they met with a resounding negative response. Maybe this is the reason why the residents have not been consulted on this occasion?
They following bodies should have been consulted:-
- The Airport Consultative Committee (ACC)
- Those Parish and District Councils whose communities would be most affected by the planning application
Additionally, the following consultative processes should have taken place:-
- Consultation events in each of those communities
- Wide distribution of publicity in those communities (not just some leaflets in a few shops)
I would also point out that the CAA criticised LBAA in having a poor reputation for public engagement, as was clearly noted in their Airspace Change Proposal (ACP) last year (2019). So, yet again, LBAA is showing itself to be consistent in its lack of consultation with the public as a whole.
In a questionnaire, issued by the Authority, question 6 states that LBA benefits from a 24hr operating consent, yet then goes on to ask if the public supports its expansion in flying hours between 6.00 and 7.00am and arrivals between 11.00 and 11.30pm. This question is misleading, as it fails to point out that these proposed additional flight times are included within a 'capped period' that is classed as 'night-time flying'.
I am a frequent traveller to Dublin, departing from and returning to LBA, and, since 2010, my morning flight has always departed before 7.00am. The earliest being at 6.20am and the latest at 6.45am, with the vast majority at 6.30 or 6.35am. LBAA are permitted a limited number of 'night-time' flights, but being regularly awoken at such an early hour, on a more regular basis, will not only create more noise pollution, but will definitely not be conducive to the health and welfare of the residents beneath the present flight-path.
By far, the vast majority of the publicity and information regarding this application has addressed the erecting of a new modern terminal building and barely mentioned the change in flying hours. The planned extension to daytime flying hours should have been included as a headline on the flyer and all advertising, including the website. Omission of this information again questions the transparency of LBAA with the public in making this application.
Duty of Care
As the Lead Planning Authority (LPA) overseeing this planning application, Leeds MDC has a duty of care to their residents and, I would say, to all others who will be affected by any decision they make. This, I would assert, includes the residents affected by flights to and from LBA, the vast majority of which reside outside of Leeds MDC and within Bradford MDC.
It is also worthy of note that Bradford MDC, within which area Menston and Burley in Wharfedale reside, has declared that it does not have a duty of care for the residents of these villages with regard to another Council's decisions. That being the case, it must be the responsibility of Leeds MDC, unless both Councils are giving an emblematical representation of that well-known act performed in the Holy Bible by the Governor of Judea, Pontius Pilate?
Finally, before the end of this year ICCAN will issue strict guidelines in relation to all airport planning activity, including noise monitoring. As this organisation is greatly concerned with air and noise pollution, it is highly likely that it will be critical of LBAA's proposals, especially with regard to increased flights and their affect on the health of nearby residents. It is also worth remembering that it reports direct to the Department of Transport.
I would, therefore, recommend that the LPA would be well-advised to be aware of these forthcoming guidelines and, perhaps, consult with ICCAN on what they are likely to recommend. Failure to consider impending rules can be grounds for a judicial review, as in the recent hearing at the Court of Justice with regard to the Leeds Site Allocation Plan in Aireborough, which, on such grounds, found against Leeds MDC.
I am, therefore, against this planning application being approved.
Cllr Gerry Barker
Cllr Dale Smith's comments:
20/02559/FU - LBIA planning application.
In my view it is deceitful to mix two issues together and combine them into one planning application.
The application appears to be in two sub-sections:-
1. Lengthy and comprehensive details with regard to the replacement of what are outdated terminal facilities with more modern and fit-for-purpose structures.
2. Concluding by throw away phrases seeking modification to flight time controls and the extension of the daytime flight period.
It is disingenuous to lump these two aspects together, trying to slip the second under the radar! The second part being the more important and contentious of the two as far as most local residents are concerned.
The application must be deferred and split into its two separate applications.
A. Lengthy and comprehensive details with regard to the replacement of what are outdated terminal facilities with more modern and fit for purpose structures.
Undoubtedly the replacement of what are outdated terminal facilities with more modern and fit for purpose structures are probably long overdue but whether they can be fully economically justified in what will be the post-Covid-19 new normal I would doubt. I would therefore suggest that this part of the planning application should be withdrawn by the applicant for further consideration.
B. Modification to flight time controls and the extension of the daytime flight period.
As you will be well aware:-
1. A key focus of the CAA's new guidelines when considering applications for airspace changes is the effect of noise on peoples' health and wellbeing.
2. LBIA must apply to the CCA for a new Airspace strategy and the outcome of this planning application will be dependent on their decision.
3. It is well documented that there is much dissatisfaction with the inability of the LBIA to keep current flight paths of aircraft using runway 32 for take-off to stick to the NPR which the CCA defines as the line midway in the centre of the swathe.
4. There is also evidence that the noise monitors are poorly placed to give accurate noise readings and comparisons.
5. With regard to operating hours I dispute that LBIA is disadvantaged as compared to other UK airports.
6. ICCAN (Independent Commission on Civil Aviation Noise) reporting to the Department of Transport will be expected to be involved in the debate and is expected to issue guidelines by the year end.
7. The opportunity to revise the outgoing flight path from runway 32 to the flight path down the Wharfe Valley, previously claimed and used by the RAF but now abandoned by them, should be seized with both hands so enabling aircraft to climb gradually for 5 nautical miles thereby saving fuel and reducing noise. A win-win!
In additions to the many representations already made these 7 reasons should be adequate and sufficient for rejecting the current application and recommending it be split for a more detailed and intensive application at a future date.
10, Craven Park
Bradford District Councillor for Wharfedale Ward
Menston Parish Councillor
Cllr Jackie Whiteley's comments
I am a District Councillor representing Burley in Wharfedale and Menston villages, undoubtedly the two communities most affected by the expansion of flying hours. I am a member of Leeds Bradford Airports Consultative Committee and was involved in documenting the villages’ concerns to the Civil Aviation Authority (CAA) regarding the lack of proper consultation with nearby residents in relation to Leeds Bradford Airports Air change Strategy. The CAA gave lack of consultation as one of their reasons for turning down LBA’s application.
I am also the Shadow Spokesperson for Planning and Highways on Bradford Council and as such I write on behalf of all residents of Bradford. I have raised concerns with Bradford Council’s Environmental Health Department about the effect of noise on people’s wellbeing. This is a key focus of the CAA’s new guidelines when considering applications for airspace changes.
I have served on Bradford Councils Regulatory and Appeals Committee in the past and that committee had an option to defer applications so that an applicant could change their application.
I am writing to ask you to consider asking for this option so that the two parts of this application can be considered separately.
I have no objection to the headline project of the construction of a new terminal building and associated works and believe this to be beneficial to the local and regional economy.
The problem with the application is the inclusion within the single application, almost as a postscript and as the last item on a list of 11 related projects, of the controversial increase of 1½ hours in defined daytime flying hours. Together with the proposed increases in passenger numbers of 75% by 2030 and 125% by 2050, and therefore not dissimilar increases in flights, this will exacerbate the disturbance to those already suffering.
In my communication with the Department of Environmental Health at Bradford Council I have asked them to consider this point in their submission because:
Expanding the buildings and improving the facilities at the airport is unlikely to be as contentious as expanding the flying hours. Leeds Bradford Airport must still apply for a new Airspace Strategy to the Civil Aviation Authority. This cannot be avoided, and the outcome of their decision will inform any application to extend the flying hours.
It is not only about timing but also about considering the vast amount of background information which is pertinent to expanding the flying hours.
Unfortunately, you must accept or refuse the application or none of it and the desirability of the former may detract from the latter. Please consider asking for a deferment to allow the separate parts of this application to be considered independently.
Cllr Jackie Whiteley
Wharfedale Ward Bradford District Council
Shadow spokesperson Planning and Highways.
Here are a few points which are relevant to this application.
The noise preferential route (NPR) or SID.
• As you are aware the departure NPR is a centre line which passes between the villages of Burley and Menston of Runway 32. The airport is continually criticised for its inability to keep aircraft inside the NPR. The NPR is not the entire swathe, as misrepresented by the airport, but is defined by the CAA as a line midway between Burley and Menston in the centre of the swathe. There is increasing noise disturbance due to poor track keeping that leads to overflying of Menston and Burley. Although track keeping has improved over the years, the issue remains, and many more aircraft are technically off track over Burley than Menston.
The quote from the Civil Aviation Association about the NPR(SID) is as follows:
“aircraft should adhere to the SID centreline wherever possible and not deliberately use the extremities of the swathe as a matter of course. … the swathe is not a zone within which operators can plot their own tracks; the objective remains NPR/SID track, but it must be recognised that legitimate fluctuations may occur.” (CAA Letter, 15.01.2009)
There are root causes of these issues on both the NPR and the Standard Terminal Arrival Route (STAR). I have added these in the explanation, as they are technical in nature.
• It’s also evident that noise levels have increase by between 1.5dB(A) and 2dB(A) over the period November 2015 to March 2020. That having been said, the positioning of noise monitors in and around Burley are completely inappropriate, and therefore I wonder about the accuracy of sound monitoring. I believe, that like Horsforth, noise monitoring equipment should be placed either:
o Either side of the centre line of the swathe, but closer to the swathe (similar to Horsforth)
o Directly on the centre line.
It’s further noted that there are more complaints from Burley regarding aircraft noise than from Menston. This reporting appears counter intuitive, but closer examination reveals why this is so:
o LEQ(16) is a measure averaged over a 16 hour day. Eg: 1 arrival at 10dB and a departure at 100dB, the average is 100+10/2dB = 55dB.
o Prevailing winds are from the west, so that aircraft noise is ‘blown’ towards Burley.
o The distance of noise monitoring from the centre line of the swathe, that is they’re nowhere near the swathe in Burley or Menston.
o Off track flight are more likely to overfly Burley.
o 80% of all flight arrivals and departures are mode over Burley/Menston. Of the 80% of arrivals, 100% are made over Burley.
• No one at the airport has addressed the 80%- 20% split in flight arrivals and flight departures that take place over Burley\Menston and Horsforth respectively. Common sense would suggest that the numerical split should be closer to 50%-50%.
• Has the community been consulted, and has any detailed sound analysis taken place? I think that we can answer no to both questions, indeed two requests for noise information have not been adequately addressed and that begs the question as to why?
Increasing daytime flying hours.
Of those supporting the combined application very few have considered or mentioned the increase in defined daytime hours, so it looks as if the airport's strategy of implying that this operational issue is incidental is proving successful. Most supporters do not live anywhere near the airport.
• Aircraft are currently allowed to depart from LBA during the night, but in limited numbers (2,800 flights over the summer period, May-October). Daytime hours are currently defined as 7.00am to 11.00pm, with night-time therefore being classed as 11.00pm to 7am.
The new proposed daytime flying hours are for unrestricted flying between 6.00am and 11.30pm. Some flights that are currently classed as night-time flights (those between 6am-7am, and 11.00-11.30pm), will become daytime flights. Therefore, there is a potential to have more flights during daytime hours, and the same number of night-time flights (2,800) during proposed reduced night-time hours. That is potentially an overall increase in daytime and night-time flights.
• It is true that LBA can schedule flights between 6.00am and 7.00am, but these are subject to numerical limits, and LBA considers itself disadvantaged relative to other UK civil airports, but this is not the case.
o Luton Airport has the same daytime hours as LBA, and a similar night-time flight allowance. Luton handled 18 million passengers in 2019.
o Stanstead has a 16-hour day 7.00am to 11.00pm.
o Liverpool has severe restriction in place between 6.00am and 7.00am and throughout the night-time 11.00pm to 7.00am, but still managed to carry 5 million passengers in 2019.
o Bristol Airport carried 8.9 million passengers in 2019, in the same daytime and night-time hours under which LBA currently operates.
• There are potential benefits to airlines and the airport, these are really obvious. What’s not been considered or factored into the equation, is the effect of increased flying hours, that is noise over 17 ½ hours during the day, plus the same number of flights in compressed hours during the night.
• LBA state that they flew 3.99 million (let’s say 4 million) people on 30,000 (the actual figure is 30,648, although total ATM’s are 35,641) flights annually. On that basis 7.1 million passengers would require 53,250 air traffic movements. Can LBA squeeze an extra 3.1 million passengers onto the additional 16,000 flights that they predict? Each flight would have to carry an average of 194 passengers in and out of season, that is simply unrealistic. If all new air traffic was on the new Boeing 737-800, which has a seating capacity of 189, then this simply is not possible.
Environmental & health impacts.
• Both Leeds and Bradford have declared climate emergencies, how does expansion sit with their climate change policies?
• What are the justifications for expansion, jobs, a growing knowledge-based economy, can these be quantified and accurately measured?
• Has a health impact assessment been carried out by the council or LBA?
The effect of both extended flying hours and increased air traffic movements will introduce continued noise throughout a 17 ½ hour day and through the night. This will affect the well-being of residents.
It should come as no surprise that airlines themselves, carry out noise studies that determine the effect of prolonged noise exposure (LEQ16) on all aircrew. They use these studies, to inform them about best working practice and to control working hour. This type of study (for residents who live on or near the flight paths) is noticeable by its absence from the planning application.
There is a wealth of evidence from the World Health Organisation, that relates to the health impacts of aircraft noise, and this can be found at: http://www.euro.who.int/en/health-topics/environment-and-health/noise/d…
Here is what happens at present:
In 2019, LBA saw 35,641 air traffic movements (flights). A small number of those flights were for services other than passenger travel, such as private charters, movement of aircraft between airports, military and private (club) flights. The CAA data indicates that passenger travel accounted for 30,648 (86%) of those flights (Air Traffic Movements or ATMs);
• 79% of all ATM’s involved travel within the EU
• 18% of all ATM’s were to UK destinations.
• Only 3% for international travel outside the EU.
How many of these ATM’s are related to European/International business?
What is needed.
The first thing is to have a proper public consultation, and that will need to have robust evidence to support any proposed changes to flying hours and noise. Let us not forget, LBA do not control airline commercial decisions, therefore cannot speculate about the type of aircraft which may or may not fly from the airport.