APPENDIX 4
Memorandum submitted by Dr Esmond Birnie
MLA
INTRODUCTION
Northern Ireland needs to create a sustainable
air strategy with a specific regional identity and market focus.
This should create maximum economic benefits and address the peripheral
nature of the Province whilst allowing for the social costs generated
by airport activity.
The number of passengers using domestic services
has grown substantially in recent years and this sector continues
to dominate despite growth in the volume of international traffic.
We need to improve direct services avoiding London in order to
increase tourism while maintaining regular daily flights to London
and other key commercial European cites for the busy business
traveller. We are only capturing some of the benefits, others
are leaking away to the Republic of Ireland or not being created
at all.
A sustainable long-term strategy for Northern
Ireland means finding the right balance between benefits and impacts,
and determining how impacts on people living close to airports,
the built and natural environment and surface access infrastructure
and services might be mitigated and managed.
This submission should be considered as complementary
to one by the Ulster Unionist Party as a whole. I attempt to deal
with the four main items listed in your letter of 29 July though
my concentration is on the subject of most particular concern
to the Belfast constituencies; the growth in traffic at the City
Airport relative to the International. My conclusion is not necessarily
that the International be the sole airport serving the entire
Province but certainly most growth in passenger numbers should
be concentrated there. There are three main reasons for this:
— The avoidance of risk and disamenity
in terms of over-flights in the most densely populated part of
Northern Ireland.
— Achieving the necessary critical
mass at the International Airport allowing it to better compete
with Dublin.
— Reduction in strain on the already
heavily congested roads network through central Belfast.
THE DEVELOPMENT
OF CAPACITY
AT EXISTING
AIRPORTS
Lately there has been a concerted effort to
push forward the case for expanding Belfast City Airport. It has
been argued that there is consumer demand and that such a development
would benefit the Northern Ireland economy as a whole—a
case yet unproved.
Local residents in parts of South and East Belfast
and North Down are concerned by the prospect of further development
at Belfast City Airport. Belfast City Airport is already a source
of noise pollution; is responsible for increased road congestion
in the Belfast conurbation and has placed significant numbers
of people at some level of risk under its flight path.
For local residents on the flight paths at Belfast
City Airport, aircraft noise is a problem. Both the total number
of flights and the number of late flights have recently increased
sharply.
It is a stronger economic and social argument
to foster and develop Belfast International Airport which is fortunate
to be in open country, easily accessible to all and capable of
development without environmental problems.
In detail:
1. Belfast City Airport has been allowed
to develop as a competitor to Belfast International Airport but
has now reached a scale that if it wishes to develop any further
changes will have to be made to current planning controls. In
almost no circumstances should the present planning controls and
restrictions be relaxed.
2. Belfast City Airport operates under a
Planning Agreement that imposes a series of limitations on the
way the airport operates—airport operating hours (operative
services between 6.30 am and 9.30 pm), air traffic movements and
air flight paths (the maintenance of the present bias in favour
of the main flight path over Belfast Lough).
3. The Department for the Environment in
Northern Ireland has always recognized that growth at the Belfast
City Airport creates problems for its environment and a Public
Inquiry was set up to consider objections to the Belfast Harbour
Local Plan 1990-2005 which included objections to the growth of
Belfast City Airport. After a lengthy Public Enquiry which opened
on 23 October 1990 and closed on 14 January 1991, a Report was
published setting out the findings of the Commissioner who presided
over the Enquiry and his Report was endorsed by the Planning Appeals
Commission in Northern Ireland. Subsequently, the Department for
the Environment in Northern Ireland accepted the recommendations
of the Planning Appeals Commission in their Adoption Statement
1991.
Both the Report and the Adoption Statement 1991
clearly recognized that because of its situation in a city setting
only 2½ miles from the City centre there had to be operational
and environmental constraints on the future growth of Belfast
City Airport.
4. Belfast City Airport has been classified
as a "City Airport" by European Directive 2002/30(EC).
It is recognized by that Directive that any increase in noise
at a "City Airport" will give rise to particular high
annoyance.
5. Belfast City Airport has now reached
a scale where it is in breach of the prescribed and acceptable
noise levels. Recently commissioned acoustic research by Kinnegar
and Cultra residents shows that:
— The average noise level at Kinnegar
is 3DB outside that allowed by the 1991 Planning Enquiry. It is
therefore highly likely that the average noise in parts of South
Belfast also requires to be measured.
— The maximum noise in at least one
East Belfast School, Mersey Street Primary exceeds World Health
Authority guidelines and BB98. This has serious implications for
local educational authorities, in terms of statutory responsibility
and likely claims.
— The maximum noise in bedrooms in
Kinnegar exceeds PPG 24 levels.
— There is concern about the effect
of noise on the quality of life of many people living under the
approach and or departure flight paths of Belfast City Airport.
6. Belfast City Airport's curfew on flights
from 9.30 pm to 06.30 am has to be retained and protected. Local
residents have consistently complained about aircraft noise after
9.30 pm. It is estimated by local residents that approximately
50 flights every month breach the night time flying curfew. In
no circumstances should this curfew be relaxed.
7. Belfast City Airport is located on the
main arterial road into Belfast from the south and east. The road
is already congested and as house building and commercial development
is continuing in North Down, can only become more congested. Increased
usage of the airport would be a major issue for commuters using
the Sydenham bypass, as it will come on top of additional traffic
generated by the D5 development. Any increase in activity at Belfast
City Airport is likely to force significant public expenditure
on road improvements at the expense of other public spending priorities.
8. It is understood that the West Link Public
Enquiry was told that any new capacity created in terms of widening
that urban motorway would be filled up again by growth in traffic
within a fairly short space of years and that dedicated freight
lanes are needed to avoid strangling the Ports of Belfast and
Larne. To allow Belfast City Airport to take up additional capacity
would render pointless substantial public expenditure.
9. Belfast City Airport might seem more
convenient for some living and working in East and South Belfast
for the other two-thirds of the Northern Ireland population, who
can get to the City Airport, (particularly those wishing to connect
to the London, Heathrow hub) only by using the West Link, M2 or
other congested commuter routes it is often not the case—a
point acknowledged by a number of Northern Irelands biggest employers.
10. There is dense residential property,
commercial property and approximately 39 schools right on the
edges of Belfast City Airport and which are being over flown at
very low heights.
11. Among local residents there is concern
about the economic effects of any increased aircraft noise on
house values.
12. Belfast International Airport should
be our focus for regional development because it has virtually
no surrounding population, two runways, plenty of land and accessed
by roads which are not essential parts of Belfast conurbation
roads system.
13. Belfast International Airport was carefully
and deliberately located in open countryside convenient to Belfast
after a selection process about forty years ago which considered
and then eliminated the Shorts factory site which is now know
as Belfast City Airport. Belfast International Airport has received
around £50 million of public money.
14. There is no further need for competition
between Belfast City Airport and Belfast International Airport.
Dublin is already providing all the competition that is needed
at airport level and competition between airlines is well developed.
SPECIFIC CHALLENGES
FACING NORTHERN
IRELAND ON
A PERIPHERAL
REGION OF
THE UK
Considerations should be:
1. The population of Northern Ireland is
around 1.7 million, of whom around 4,000 are employed directly
in the aviation industry.
2. Northern Ireland's has a small catchments
population and limited tourist inflow. Furthermore, the situation
is made more difficult given that both airports are only 16 miles
apart and compete to attract carriers to the same destinations.
3. Northern Ireland has a small domestic
market and relies on exports to create economic activity and employment.
4. Northern Ireland urgently requires more
direct scheduled services to European Business destinations. Having
frequent air services would assist local business in trading outside
Northern Ireland and help attract foreign direct investment.
5. A priority for Northern Ireland's airports
should be to continue to develop and encouraging sub/core air
transport hubs with the UK mainland, the rest of Europe and North
America. In particular, Belfast International Airport should be
urged to seek new services particularly to Germany, Geneva and
US. Direct scheduled flight to Brussels should, ideally, be re-introduced.
EFFECTIVENESS OF
THE ROUTE
DEVELOPMENT FUND
Considerations should be:
1. The fund seems to have been a success
on the surface—recently attaching a number of new routes
to Europe from Belfast International Airport—which is welcomed.
2. The dangers of over reliance on "low
cost" airlines given their tendency to move when financial
incentives end.
3. The Government should be encouraged to
release future funding when required.
4. The difficulty of attracting passengers
arriving at Belfast City Airport from Heathrow to transfer to
Belfast International for any new transatlantic service.
POTENTIAL IMPACT
FOR NORTHERN
IRELAND OF
WIDER AIR
TRANSPORT ISSUES
ON THE
ISLAND OF
IRELAND
Considerations should be:
1. It is estimated that between 5% and 15%
of air passengers originating in Northern Ireland choose to travel
from airports in the Republic of Ireland.
2. Northern Ireland's airports are at a
disadvantage compared to the Republic of Ireland because of RoI's
low Corporation Tax rate, individual member state in the EU and
a reduced VAT rate on tourist services.
3. Dublin Airport has pre-emptily developed
an extensive range of air services to direct European and North
American destinations.
4. The completion of the Dundalk by-pass
has reduced the time from Belfast to Dublin to around one hour
and 15 minutes. Improved coach services have also increased the
number of Northern Ireland passengers using Dublin Airport.
5. Perceived congestion and security risk
associated with transiting through Heathrow and other London airports
have encouraged passengers from Northern Ireland traveling from
Dublin.
6. Dublin Airport and the Republic of Ireland
Government encouraged and maximized the economic benefit of concentrating
nearly all air transport activity at one airport. This is a pattern
recently adopted by Germany in the development of Berlin's main
airport.
7. Given the small geographical catchment
area and population size of Northern Ireland there is certainly
an economic argument for concentration on just one airport.
8. Northern Ireland is likely to share in
the very rapid growth in overall UK air passenger numbers envisaged
for the 2000-30 period. Consideration should be given as to how
this might be reconciled with certain national and regional environmental
objectives (notably in terms of carbon emissions).
CONCLUSIONS
Aviation is very important to economic development
and helps reduce the peripherality of Northern Ireland. Northern
Ireland is fortunate in that it may not have to make as stark
a choice between economic activity and the environmental problems
caused by airport expansion as that faced in other UK regions.
This is because it has a major airport, Belfast
International, with virtually no surrounding population, two runways,
plenty of land and accessed by roads which are not essential parts
of Belfast conurbation roads system. Therefore, there is no little
justification for intensification of use at Belfast City Airport
which is located only 16 miles away and in a densely populated
residential area.
Local residents on the edges of Belfast City
Airport including those living in my constituency, South Belfast,
feel that Belfast City Airport is a major source of noise pollution,
is responsible for road congestion in the Belfast conurbation
and has placed significant numbers of people at some level of
risk under its flight path. Therefore, here is no need to change
the current planning restrictions at Belfast City Airport.
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