Select Committee on Transport Written Evidence


Memorandum submitted by Mr David Purdy

  I am submitting this document in response to the Committee's press release dated 13 October 2005, inviting submissions from interested parties by 14 November 2005.

  My interest arises as a resident affected by the airspace consultation undertaken by Nottingham East Midlands Airport (EMA), and the questionable conduct of the Civil Aviation Authority in initially approving the proposal. This was announced on the 3 August 2004, and in spite of the omission of a number of local authority stakeholders" from the consultation, as defined by CAP 725 (Airspace Change Process Guidance).

  Thus my concern relates to the omission of Derby City Council, but other councils were overlooked, too. This was raised in a letter to my MP (Margaret Beckett), in August 2004, and an extract has been appended, along with the Phase I" consultee matrix understood to have been used by the airport. The following month, EMA were attributed in the local press as saying that Derby City Council did not need to be consulted because it was not affected by the airspace proposal. However, this was disproved by route maps issued as part of the subsequent Phase II" consultation indicating that, for example, easterly arrivals would overfly residential parts of the city at relatively low altitudes.

  Secondly, another concern relates to the CAA's apparent failure to heed several important aspects of the departmental guidelines on related environmental objectives, for example, by taking account of likely future as well as current planned operations". I refer to the omission from the airspace proposals of the larger/heavier/noisier aircraft envisaged at night at EMA, to which the Airbus A380F may now be added. [9]This was noted in my submission to the Phase II of the airport's airspace consultation in January 2005, also appended.

  The committee may also wish to know that the Air Transport White Paper drew specific attention to the need for stringent noise controls" at EMA. [10]Circa March 2004, the Aviation Minister (Tony McNulty) indicated to local MPs (eg, to Sir Ken Clarke), that he would be issuing further guidance soon" on what constituted stringent control. But this guidance has yet to materialise. Accordingly, the above concerns raise doubts about the effectiveness and efficiency of the CAA in the discharge of its duties, and I hope that the committee will be able to investigate these concerns for the purpose of avoiding future repetitions. Further details would be readily available upon request.

18 October 2005

Extract from my letter dated 10 August 2004 to Rt Hon Margaret Beckett MP, (Derby South)

  [A]  second issue concerns the consultation process conducted by EMA concerning a proposed increase in controlled airspace. This proposal has recently received approval, but regrettably failed to include Derby City Council as a stakeholder consultee" with a legitimate interest, and is presumably in breach of the Civil Aviation Authority's consultation guidelines, CAP 725 Airspace Change Process Guidance, extract appended. This is not an isolated incident, as Oadby and Wigston Borough Council was also excluded, as reported in the attached Leicester Mercury story.

  I have been aware of this consultation for some while, but after a cursory glance at several items of consultation material that I had obtained in April, copies attached, it was not immediately clear whether or not it represented an issue of concern to Derby. However, further research last week, with reference to amalgamated aeronautical route charts, also superimposed on a map of the county, suggests that the city has two overflight" reasons to review the proposal's impact, namely: (a) the arrival route from the ROKUP holding area to the north-east of Derby, which crosses the city, and, (b) the southern outer limit of ROKUP, which appears to overlap the northern and central parts of the city (to accommodate say larger aircraft unable to follow the inner limit, and which may be also flying under problematic wind conditions), details attached. [eg annotated/amended map extracts below] [11]

  I have also attached a copy of the correspondence matrix", understood to have originated from EMA, recording a list of consultees, which includes Nottingham (and Leicester) City Council, and Nottinghamshire County Council, but I cannot locate Derby City Council (or Derbyshire County Council for that matter) in the list.

  Also, I am not certain that the consultation material that I have seen represents the full complement of documentation, but I am particularly struck by the problem of relating the proposed route information to the various towns and villages sitting below. If this is standard practice, then it could be argued that this not helpful for the local authorities having to assess such information—especially local councillors (as laypersons). There appears to be a strong argument for each aeronautical chart to be accompanied by complementary detailed map, illustrating the location [of] the local communities in relation to the routes/operational features. Indeed, if this principle had been in place during the EMA proposed airspace consultation, then one or more persons within EMA, the Civil Aviation Authority or the Department for Transport, might have spotted the omission of a city the size of Derby before the consultation was closed....

Nottingham East Midlands Airport: Controlled Airspace Proposals Phase I"

ConsulteeAshfield District Council AOC (Airport Operators'
Parish CouncilsAmber Valley Borough Council   Committee)
Barrow-upon-Soar Parish CouncilDerbyshire Dales District Council UPS
East Goscote Parish CouncilBlaby District Council Consumers Association
Rearsby Parish CouncilBroxtowe District Council Heart of England Tourist Board
Sileby Parish CouncilGedling District Council Leicestershire Chamber
Walton on the Wolds Parish CouncilNorth East Derbyshire District ABTA
Burton-on-the Wolds Parish Council  Council Burton on Trent Chamber
Quenilborough Parish CouncilNottingham City Council Consumers Association
Seagrave Parish CouncilBolsover District Council DHL
Thrussington Parish CouncilHinckley and Bosworth District Institute of Export
Ratcliffe on the Wreak  Council Nottinghamshire Chamber
  Parish CouncilLeicester City Council AARPC (Assoc of Airport Related
Trowell Parish CouncilNorth West Leicestershire   Parish Councils)
Cossall Parish Council  District Council South Derbyshire District Council
Kimberly Parish CouncilHarborough District Council East Staffordshire Borough Council
Stapleford Town CouncilRutland Council Association of Leicestershire Parish
Awsworth Parish CouncilMelton Borough Council   Councils
Breaston Parish CouncilICF Nottinghamshire Association of
Draycott Parish CouncilCPRE (Council for the Preservation   Local Councils
Risley Parish Council  of Rural England) South Derbyshire District Council
Stanley Common Parish CouncilKings Newton Resident's CPRE (Council for the Preservation
Dale Abbey Parish Council  Association   of Rural England)
Ockbrook Parish CouncilPAIN (People Against Intrusive Charnwood Borough Council
Sandiacre Parish Council  Noise Erewash Borough Council
Stanton by DaleLoughborough University North West Leicestershire District
District CouncilsWINGS We Insist No Granada   Council
Charnwood District Council  Services Rushcliffe District Council
Rushcliffe Borough CouncilBroxtowe Borough Council CPRE (Council for the Preservation
Erewash Borough CouncilDisabled Association   of Rural England)
Donington Park Racing Circuit Others
Melbourne Civic Society Nottinghamshire County Council
SAVE (Save Aston Village South Derbyshire District Council
  EnvironmentBeeston & District Society
Employment Services
Derbyshire Association for the Stapleford Forum
  BlindBramcote Conservation Society

The Airspace Consultation Co-ordinator,

East Midlands International Airport Ltd.,

Building 34,

Nottingham East Midlands Airport,

Castle Donington,

Derby DE74 2SA

6 January 2005

Dear Sir/Madam,


EMA Correspondence Ref. GN628, 23 November 2004

  I am writing in response to the above consultation and wish to register my opposition to the proposal outlined in the above documentation.

  My opposition is based on the proposal's lack of compliance with the government's guidance to the CAA on airspace design (concerning the omission of large freight aircraft forecasted to be operating at night within the foreseeable future) and also a general lack of stringency towards night-time noise controls as required by the government in the Future of Air Transport" White Paper. The main concerns relate to disturbances arising from the use of aircraft at night, and the key points are:

  1.  A failing regarding the forward looking"—and therefore the comprehensive" and rigorous"—requirements of changes to airspace arrangements (DTLGR, 2002, p7). Derby residents are entitled to question the need for any overflying of residential areas at night by the largest/heaviest aircraft, but the strength of the case depends on the types under consideration. Accordingly, the supporting Environmental Impact Assessment And Statement (EMA, 2003, p8) refers to the MD11 as the largest aircraft type to operate at EMA during the night time period". Whilst this may be correct, larger/heavier/potentially noisier Boeing 747-400/200Fs were not considered, but were previously cited as specific operational examples in the planning application for a further runway extension (Scott Wilson, 2000, Ch5 pp15-16). The environmental assessment was updated last year and cites the use of B747-400F and An124-100 models (Scott Wilson/EMA, 2004, p2). I understand that EMA was pressing for a determination of the planning application last year—North West Leicestershire District Council being the relevant planning authority—and thus the expected use of these omitted aircraft types clearly falls within the foreseeable future and should therefore have been considered by the airspace proposals.

  2.  The proposals include a departure route variation to reduce the overflying of the east side of Derby, but no route changes are proposed to reduce the noise impact from departures on the west side. The west side is subjected to approximately three times the volume of air traffic than that on the east (due to the prevailing wind), and being closer in flying distance, it is also subjected to aircraft flying at typically lower altitudes. It is understood that residents living towards the west edge of Derby, namely Mickleover/ Littleover, are still being disturbed by certain night-time operations (the MD11 aircraft being a specific example). It has therefore been suggested to Derby City Council that representations should be made for the adoption of more stringent limits to reduce overflying, such as a blanket" 5,000 ft. release altitude similar to that in place at Manchester Airport (see also the attached extracts from a presentation given to the city council's corresponding area panel meeting in November 2004).

  NB  EMA's departure route proposal, moving the easterly" route away from Derby, is very similar to an amendment suggested by Derby City Council to EMA in March 2000, which was noted at the time. Should this come to pass—perhaps sometime later this year—then this particular improvement will have taken over five years to materialise, whilst the air traffic at the airport has increased by more than 50%.

  3.  The use of a 55 dB LAeq contour to assess night noise impact (EMIA, 2004, 6.10 p9) is markedly less stringent than comparable maximum levels recommended by either the World Health Organisation or the government's PPG24 planning guidelines. They say: outside sound levels about 1 metre from facades of living spaces should not exceed 45 dB LAeq, so that people may sleep with bedroom windows open" (WHO, 1999, xiii), and, that a sound level of less than 48 dB LAeq is required for new residential developments located within noise exposure category A (ODPM, 2001, Annex 2). Thus the use of a markedly smaller area 55 dBA LAeq contour fails the government's stringency" criterion...we consider that the projected expansion of air freight operations at East Midlands should be permitted. However, this would need to be accompanied by stringent controls on night noise in particular and increasingly generous noise insulation and other mitigation measures. These measures should build on those applying currently." (DfT, 2003, p98)

  4.  A consultation departure route map, also published in the local press, shows a significant gap between a nearby route and the western edge of Derby—but a map of actual flight tracks issued by the airport to its consultative committee in 2004 indicate that the locality is exposed to an appreciable level of overflying. Prospective purchasers of residential property in the locality, and who are also sensitive to noise disturbances, may be misled by the route as depicted. Indeed, it is felt that the use of such material in a promotional context would warrant a complaint to the Advertising Standards Authority. It is therefore suggested that the map, extracts appended, and any others of a similar nature, should be amended to show an overlapping of flights over the western residential edge of Derby until EMA can prove to the contrary.

9   Ms Buck:...Nottingham East Midlands airport will also accept the A380 from 2006 but for cargo purposes only....", House of Commons Hansard Written Answers for 11 July 2005 (pt 11). Back

10   At the same time, given the particular importance of air freight to the future national and regional economy, and of East Midlands Airport as a centre of these operations, we consider that the projected expansion of air freight operations at East Midlands should be permitted. However, this would need to be accompanied by stringent controls on night noise in particular and increasingly generous noise insulation and other mitigation measures. These measures should build on those applying currently." The Future of Air Transport (White Paper), Department for Transport, December 2003, 9.28 p 98. Back

11   Not printed. Back

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