MSP Angela Constance responds to ‘fundamentally flawed’ Edinburgh Airport Consultation


angela
Angela Constance MSP has published her consultation response to Edinburgh Airport for all areas affected across West Lothian – here is her respomse on Flight Path A
Edinburgh Airport 2nd Stage Consultation Response from Angela Constance MSP
Flight path A – Runway 24 departures left turn
We investigated seven flight path options however flight path A7 was ruled out on
safety grounds. All flight path options for flight path A are examined in full on page 40 of the consultation book.
Our preferred option is flight path A6. To what extent do you agree with our preferred flight path A6?
Strongly Disagree
Please explain your answers and provide us with any other comments in the space
below:
You have indicated in your guidance that all EA proposed routes for the purpose of this consultation are routes of 0-7000ft; that EA has two runways 24/06 and 30/12, the latter used when 24/06 is undergoing maintenance or wind direction prevents landing. In addition, on “new population impact” you stated that you used the 2011 census population figures but that EA also identified known areas of housing development. However, under “community impacts” you state that the population information was taken from the most recent census only i.e. 2011.
 
In the interests of all my constituents, I want to ensure that those who have already experienced aircraft noise for many years do not bear any additional burden and that those who are in the preferred flight path options have their views fully represented. In addition, the advantages and disadvantages of EA’s expansion should be dispersed proportionally and equitably. Whilst I accept that there are advantages that would accrue to the general population of Scotland, I am of the opinion that the greater level of advantage would be to the benefit of Edinburgh as the capital city, its businesses and tourist industry.
As such, identifying routes over my constituency is an unfair distribution of disruption as opposed to the level of benefit it would secure. West Lothian has no direct transport link to Edinburgh Airport and no representation on the Edinburgh Airport Community Board despite the considerable disruption/noise pollution experienced by my constituents from existing flight paths for many years. The proposals put forward should also take account of cumulative impact on some householders e.g. those adjacent to busy roads or railway lines.
Many of my constituents have asked that EA extend the consultation or withdraw it in its
entirety. Either of these options would allow EA to address what my constituents feel are
serious deficiencies in the process and content of the 2nd Stage Consultation e.g. to afford EA the opportunity to correct the out-of-data population figures and revisit the conclusions it has drawn based on those figures and which underpin the statements made in the 2nd Stage Consultation as well as addressing the change of focus on the flight paths.
I believe that this is essential because the consultation at this stage is fundamentally flawed.
EA have stated “You spoke, We Listened”. This statement is erroneous as the First
Stage of the consultation was directed at a different audience. Individuals who were
unaffected by the 1st Stage consultation did not respond because they felt that there was
no need to as their areas would not be affected. To come back in the 2nd Stage and say
that Preferred Route/s are now routes outside the original design envelopes and would
affect communities that were hitherto unaffected, is unacceptable.
  •  the population figures are inaccurate – six years out of date – and grossly underestimated
  •  the use of inaccurate and incomplete population figures undermines the conclusions drawn in the 2nd Stage Consultation
  • EA has indicated that it seeks to modernise the airspace to accommodate growth. I am informed that although passenger numbers have increased as a result of larger aircraft, the actual number of aircraft movements has decreased e.g. in 2016 EA website states that these numbered 121,800 which in turn is less than any year between 2004-2008. Moreover, there is no information on the envisaged potential increase in movements.
  • EA has not offered an option of “no change” to existing flight paths using the M8 corridor – an area less densely populated because it has been under a flight path for many years and where industrial estates are common.
  • EA has successfully lost all credibility in this consultation as a result of the initial faulty community engagement over the Tutor flight trials and how the 1st Stage Consultation was presented leading on to a completely different scenario for the 2nd Stage.
 The Department for Trade Guidance to the Civil Aviation Authority states that in
considering airspace change, the CAA should bear in mind the Government’s policy to
minimise noise impact of aircraft and those affected by it as well as considering the
value of maintaining legacy arrangements i.e. where route design options below
4,000(amsl) are similar in terms of impact on densely populated areas. The EA’s
proposal would lead to a significant number of people in West Lothian closest to EA
being directly impacted for the first time.
EA has not undertaken or produced safety and noise assessments on how these
proposed routes would affect local communities in terms of health, environment and
natural habitat.
In addition, I find that the consultation form questions are devised in such a way that they could be interpreted as leading to a desired EA outcome by default; that they promote division between local communities and without the extensive guidance do not have sufficient information on the form to allow an informed response. In addition, EA’s website has two versions of the consultation guidance – one a PDF version of 156 pages and one an easy read version of only 11 pages. The latter has no information relevant to completing the feedback form.
EA’s on-line information on route A indicates:
The Route A design envelope covered areas in West Lothian including Livingston, Kirknewton, Polbeth, Addiewell, Blackburn, East Calder, Mid Calder and West Calder.
Yet the A6 route falls outside the original design envelope and impacts on communities that were informed at earlier stages of the consultation that they would not be affected by new routes. In addition, no trial has taken place to establish the impact of this change on the communities it will fly over. In effect, it can be considered a new, untested and unmonitored route. Your returns do not list what the impact would be for Wilkieston, Calderwood, East Edinburgh
Calder and Mid Calder as these communities are omitted from your tables. Only Kirknewton is mentioned.
In terms of preferred option A6, you have noted in Table 3 page 43 that
Noise – population overflown is less (positive impact)
Noise – new population impacted is slightly more (no change/neutral)
In terms of Kirknewton you have indicated a negative impact as it is closer.
However, you have quoted the 2011 census population figure and there is no mention of theimpact on Wilkieston, Calderwood, East Calder or Mid Calder as separate entities despite EA’s on-line information stating that the route design covered East Calder
You also state that this route would be for non-jet aircraft.
I am concerned that the preferred route A6 does not appear to take into account
the current and future housing developments in East Calder extending through to
Wilkieston and as a result does not accurately reflect the growth in population or
the anticipated growth in population. In brief, the consultation findings appear to
be based on out-of-date 2011 census data about population in the area, which in
turn has influenced and determined EA’s choice of the A6 route alongside C02
emissions. The core development at Calderwood alone involves 2,800 new homes
with a potential population of circa 7000. East Calder has a population of 5,600.
I am informed that East Calder and Kirknewton residents were informed following
the first part of the consultation that they would not be affected by any proposed
changes. To claim that the routes will be operating over 25,000 less people when
the population data used appears to be incomplete undermines the case for any
preferred option.
This route falls outside the original design envelope under Stage 1 of the
consultation and its introduction at this late state is detrimental to the interests of
those living within its range and undermines the consultation process.
There is concern at the height at which Kirknewton and the Calderwood development will be overflown. If it is 500-1500ft and not 3000-4500ft, the altitude difference could increase noise pollution to unacceptable levels. Kirknewton is nearer the airport and is 500ft above sea level, so the route over Kirknewton will have flights operating at full power at a much lower level than the other options. As a consequence, the noise disturbance will be greater.
The Ministry of Defence has located all cadet glider training for Scotland and
Northern Ireland at Kirknewton. I am informed that the Letter of Agreement with
the MOD means that during glider operation the A6 route would not be available.
EA has indicated that it is in discussions with the MOD but clarification on how
this would impact on the A6 route would be appreciated.
I am in receipt of complaints from East Calder, Kirknewton, Mid Calder, West Calder, Harburn and Deer Park in Livingston indicating an increase in aircraft noise. As EA has indicated that as there has been no change in the routes at present, it follows that there should be no change in the level of noise experienced by my constituents. Since my constituents are reporting increased noise disturbance and in some instances experiencing it for the first time, this would suggest that even if aircraft are flying on unchanged routes, current practices are  changing e.g. they are flying at different ranges within the route and possibly flying at lower levels.
There is concern that there has been no health impact assessment for the A6 route or impact assessments as this route falls outside the original design envelope with respect to Kirknewton, East Calder etc.
EA has indicated that it needs to expand provision and capacity. There is no information on the numbers of increased flights, whether they are short or long haul, internal or external, passenger or cargo and how these are allotted to aircraft type.
I believe that EA has no flight restriction times and is classified as a 24-hour airport. What guarantees can the airport give to ensure that night time disruption is kept to an absolute minimum especially in areas that would now be open to noise disruption especially from low flying aircraft. In brief, I would seek assurances that there would be no night time flights across my constituency on any flight routes.
The A6 route has not been properly trialled to assess impact on the Kirknewton, Wilkieston and East Calder communities. Such a trial should be undertaken to allow a proper assessment of the impact especially in terms of noise from low flying aircraft. Following a meeting with Edinburgh Airport officials and at the request of the Calderwood Residents Association, I have written to EA formally requesting a flight trial and/or test flights with decibel monitoring. Other constituents object to the A6 in principle and believe that the route option should be withdrawn completely.
The proximity of communities is not well represented. Illustrations imply that they are further apart than they are in actuality and that the impact of the flight paths is more localised and direct.
Constituents have queried the carbon footprint information and the impact on home and natural environments.
The proposed route exposes my constituents to an increase in noise and air pollution. This is aggravated by the fact that the vectoring allows a significant divergence from the route. This proposed route will fly over the planned sites for the new Calderwood Primary School and East Calder High School.
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