Fiona Hyslop MSP – Submission to Edinburgh Airport Ltd Airspace Change Programme departure and arrival procedures

Fiona Hyslop MSP for the Linlithgow Constituency

Submission to Edinburgh Airport Ltd Airspace Change Programme departure and arrival procedures

I am responding to this consultation as the Member of the Scottish Parliament for the Linlithgow Constituency. My constituency includes the towns and villages of Armadale, Avonbridge, Bathgate, Blackburn, Blackridge, Boghall, Bridgend, Broxburn, Dechmont, Ecclesmachan, East Whitburn, Greenrigg, Linlithgow, Linlithgow Bridge, Newton, Philpstoun, Torphichen, Uphall, Westfield, Whitburn and Winchburgh.

I will be responding to the proposed flight paths which directly affect my constituents.  This response is based upon the feedback and valid concerns raised by my constituents. Any constituent who has contacted me either directly or communicated with members of my staff has been encouraged to respond to this consultation directly and individually.

I have set out below some of my recent activities relating to Edinburgh Airport Ltd’s (EAL) Airspace Change Programme:

  • 17 October 2016 – met with UK Transport Minister Lord Ahmed along with my colleague Hannah Bardell MP to lobby for the establishment of an Independent Aviation Noise Authority (IANA).
  • 6 March 2017 – met with representatives of EAL at my constituency office in Whitburn to discuss the second consultation and the concerns raised by my constituents about their proposals.
  • 4 March 2017 – attended EAL drop in session in Winchburgh.
  • 8 March 2017 – welcomed Scottish Government’s Minister for Transport and Islands, Humza Yousaf MSP to West Lothian to show the Minister West Lothian’s many transport links.  I drove the Minister from the new railway station in Armadale, through the A801 Avon Gorge Road and passed through Winchburgh Development. During this visit I took the opportunity to speak with the Minister about the scale of this development and concerns regarding the proposed new flight path routes.
  • 19 April 2017 – attended Winchburgh Community Council’s public meeting addressed by EAL and Edinburgh Airport Watch.
  • 27 April 2017- attended Scottish Parliament debate.

I have also included a link to my original response to the first stage of consultation as these points are just as important and relevant now as they were then. A copy of this can be found at

In my submission to the initial consultation I highlighted the importance of considering 7 key areas:

  1. Use of existing routes
  2. Timing of Consultation
  3. Need for change
  4. Noise
  5. Flight times
  6. Pollution/environmental impact
  7. Community benefit and trust

I would like to reiterate in, particular, points 3, 5 and 7 of my submission about the need for change, flight times and community benefit and trust. 

Any change to the use of airspace should be made on the basis of need, with clear guidelines as to when change should be triggered. In the case of the need for additional capacity, I understand that the number of passengers using Edinburgh Airport has increased recently however the number of aircraft movements at the airport in 2016 are less than in each single year from 2004 to 2008. The issue that EAL wants to address is movement capacity at peak times but it is unclear and no evidence has been provided on the actual numbers that they are trying to address. I recognise that EAL should of course make preparations to meet future service demands, including the review of airspace use, however change must only be implemented when clearly defined triggering points are satisfied. These trigger points themselves should be consulted on and subject to governance and independently approved guidelines.

Research conducted over the past two years by one of my constituents found that the busiest early morning hour in summer 2016 was Saturday 6 August between 06:40 – 07:40 with a total of 31 scheduled aircraft movements (26 scheduled departures and 5 scheduled arrivals) – which is well short of the “one departure per minute” sought by EAL.

The same constituent passed on that the Airport describe Easter weekend as one of their busiest weekends, yet on Easter Saturday, 15th April 2017, scheduled departures in each of the first 4 hours from 05:40 amounted to 13; 18; 10 and 10 respectively. Scheduled arrivals for the same 4 hour-long periods were 0; 7; 6 and 8 giving combined aircraft movements of 13; 25; 16 and 18 per hour respectively. So according to this, even at its busiest times, Edinburgh Airport has sufficient capacity.

In relation to flight times, I understand that there are not enforceable restrictions on night time flying at the airport. It is essential that EAL provide reassurance that they will not allow flights to operate from late at night to early morning. I will be contacting the new council administrations for West Lothian and Edinburgh to request that they use any powers that they have to restrict night flights to clearly defined essential services such as those used by Royal Mail and emergency situations.

I am also concerned about the potential effects of flight divergence. Some of the routes being consulted on appear to be in close proximity to each other above 4000ft which with vectoring leaves a larger area open to being overflown, such as could be in the case of EAL’s preferred B2 and B5 routes.

With regard to community benefit and trust and as previously stated, Edinburgh Airport is an important economic asset and its continued success, which is desirable, should have a direct benefit for the communities to which it neighbours. Whilst it is recognised that Edinburgh Airport provides an essential service in connecting Scotland to the rest of the world, contributing to the economy, and provides local employment opportunities, it must recognise the effect its decision making can have to the detriment of communities and quality of life of residents.

The feedback that I have received from constituents continues to demonstrate a lack of trust in the airport’s motives and consultation methods.  This is particularly evident from the response of my constituents living in Winchburgh. Many Winchburgh residents contacted me to express their feelings of having been misled by the first consultation during which members of the public were asked to respond based on the information provided to them and were told their responses would inform the next stage of the consultation. The design envelopes for future flight paths in the first consultation, showed that Winchburgh was outside the affected area. An online postcode search returned results of “unaffected” for Winchburgh postcodes. Having not been shown to be within the design envelope many constituents feel that they were misled during the first consultation leading to a lower number of response from Winchburgh and the surrounding areas.

Furthermore, having attended Winchburgh Community Council’s Public meeting on 19 April 2017 I was concerned to hear that the Airport had not approached Winchburgh Developments Ltd before the consultation started or more recently after I and others had alerted them to the fact that Winchburgh is due to grow to as big as Linlithgow in the future. I now understand that a meeting between both parties has been arranged.

I am aware that EAL is solely responsible for conducting the consultation and once this has been completed it will also be up to the airport to submit their formal airspace change proposals to the Civil Aviation Authority (CAA), who will undertake a consultation assessment as part of the airspace change process. It is the responsibility of the CAA to ensure that any proposed changes to airspace meet regulatory requirements in respect of safety, consultation, environmental and operational factors, compliance with airspace design criteria, and that it is operationally justified.

In my submission to the first consultation I called upon the airport to delay proceeding with this stage of the consultation as the CAA are currently in the process of reviewing and strengthening their community consultation guidance for designing airspace. I understand that EAL have progressed with this stage of consultation as they believe that the current EAL consultation will satisfy these changes. I am not convinced it will meet the standards that the new CAA guidance should rightly be expected to demand.

I am again calling upon EAL to postpone progressing with their airspace change programme at this time and to fully engage with communities to consider and address the many concerns raised about the consultation process itself before making any determination of its worth. Should EAL progress with submission to the CAA they can be assured that any and all failings of this consultation will be robustly challenged. In particular, the lack of baseline information relating to current and potential noise levels, environmental impact, accurate population data, altitudes of aircraft on ‘other viable routes’, and no option for choosing the status quo means the current consultation does not meet the current CAA guidelines for consultation materials which should be ‘clear, consistent and readily accessible’, let alone any improved standards of consultation the CAA should or would be expected to adopt. On the issue of accessibility, I would at this time also like to highlight that despite my staff requesting, on three occasions, 20 copies of the consultation material for constituents visiting my office and being given reassurances that these would be delivered, to date these have not been received.

I am also supportive of the extensive work of my colleague Hannah Bardell who as a Member of Parliament has pursued the need for improved governance of airspace and aviation noise as although there has been extensive privatisation in this sector, there has been little improvement in independent governance in the public interest in over 40 years.

In relation to the individual routes proposed by EAL I will only be responding to the routes which will directly affect my constituency and would respond as follows:

 B2 – Strongly Disagree

I strongly disagree with the implementation of this route and any of its possible variants.  This route will negatively impact on Uphall, Dechmont, Ecclesmachan and Torphichen, leading to these towns/villages being frequently and directly overflown. In the cases of Uphall and Dechmont this would happen at low altitudes between 3-5000ft.  This is not acceptable.

Furthermore, this leaves a large area open to being overflown by possible flight vectoring, particular when considering the close proximity to the airport’s other preferred route option B5.

As evidenced during the TUTUR trials, which also involved aircraft turning and flying over these towns, the noise disruption is unwanted and significant.

As you are aware I conducted a survey of my constituents living in the areas most affected during the TUTUR trial including Uphall, Dechmont and Ecclesmachan.  The response to my survey was an overwhelming rejection by residents to being overflown due in part to the unacceptable levels of noise disruption experienced.

A copy of the results from this survey can be found here:

B5– Partly Agree

I could only be supportive of the continuation of the use of this route on the condition that aircraft revert back to flying south of the M8 motorway.

As stated in my response to the initial consultation a large volume of noise complaints during and after the TUTUR flight path trial related to the apparent change in use of GOSAM, with a number of my constituents reporting changes in frequency, volume and flight movement.

I am to this day still regularly contacted by constituents from Broxburn, Uphall and Dechmont regarding noise complaints about aircraft flying this route.  Prior to the TUTUR trial I had received no complaints from constituents regarding this.


C5 – Strongly Disagree & D0 Strongly Disagree

It is important to recognise that Winchburgh is one of West Lothian’s core housing development areas. Both C5 and D0 propose a new flight path directly over the east side of Broxburn and Winchburgh, including Winchburgh Primary School.

The consultation document states Winchburgh having a population of 2000 people.   This information has been taken from the 2011 Census.  This information is out of date and does not reflect the current level of development in the town nor does it consider the future large scale development which is expected to lead to the increase in population in excess of 9000 people, which is near to the size of neighbouring Linlithgow which EAL recognises should not be overflown.

Whilst I recognise the need to use a baseline which would provide a meaningful comparison of settlements across the whole consultation area, there must be a recognition and thorough consideration of ongoing developments and the potential impact of airspace change on them.

Furthermore, the consultation document states that “In low altitude airspace (below 4,000ft AGL) the priority should be to minimise aviation noise impact and the number of people on the ground significantly affected by it” (Section 10.2).  However, Route C5 and D0 will make frequent flights at a height of only 2-3000ft over the east of Broxburn and 3-4000ft over an expanded Winchburgh with 9,000 residents.

I cannot see how the implementation of both these routes which include low altitude, turning manoeuvres whilst aircraft are climbing, would not cause significant disruption and distress to current and future residents of Winchburgh, Broxburn and surrounding areas.

Other viable departure routes

B1 – Strongly Disagree

This route would lead to a large population in Broxburn and Ecclesmachan being directly overflown at low altitude causing significant noise disruption.

B6 – Strongly Disagree

I am not sure why this route is being consulted on as the consultation material itself clearly states that this route does not comply with safety and ICAO design criteria.

C1 –Disagree

I disagree with this proposal due to the lack of information in the consultation document relating to the expected altitude of aircraft as they progress along this route and therefore does not allow for an informed decision to be made.  Whilst I recognise that this route would lead to Torphichen being overflown and aircraft movement closer to Dechmont and Bathgate I understand the design proposed could allow for aircraft to potentially gain greater altitude before commencing a north bound turn however, I cannot support that without knowing the full effects on my constituents.

C2 – Disagree

This route would directly fly over Dechmont. There also appears to be no consideration again given to future development in this area as this route would also directly fly over a planned large scale housing development at the Bangour Hospital site.

C3 and C3A – Strongly Disagree

These two routes would subject a large population of residents from Uphall and Linlithgow to being directly overflown at low altitudes whilst aircraft are turning.

C4 – Strongly disagree

This route would lead to Uphall and Ecclesmachan being directly overflown at low altitude whilst aircraft are turning and the noise disruption from this would be unacceptable.

D1 – Strongly Disagree

For the same reasons cited in response to D0.

D3 – Strongly Disagree

This route is very similar to that used during the TUTUR trial, which was overwhelmingly rejected by my constituents.

D4 – Disagree

I am disagreeing with this proposal due to the lack of information in the consultation document relating to the expected altitude of aircraft as they progress along this route, which does not allow for an informed decision to be made.  Whilst I recognise that this route would lead to Dechmont being overflown and aircraft movement closer to Linlithgow I understand the design proposed could allow for aircraft to potentially gain greater altitude before commencing a north bound turn however, I cannot support that without knowing the full effects on my constituents.

D5 – Strongly Disagree

This route would lead to an unacceptable number of people being directly overflown including my constituents in Dechmont and Linlithgow.

Runway 06 arrivals – Strongly Agree

No change from the status quo.