Response to Edinburgh Airport Ltd. Initial Consultation: June – September 2016
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.
Many of the towns and villages within my constituency have already been adversely affected by both the TUTUR trial and other apparent changes to current airspace use, with a number of constituents reporting changes in frequency, volume and flight movement particularly within the GOSAM and GRICE routes. It is established that there has been change to the preferred flightpath for jet aircraft from TALLA to GOSAM and an increase in numbers of flights of those jet aircraft.
On 25 July 2015, Edinburgh Airport Ltd (EAL) commenced the trial of a new flight path route, TUTUR. Following numerous complaints from members of the public I took the decision to conduct a survey of constituents living within the areas most affected by the flight path trial. A copy of the results can be found here: http://www.fionahyslop.com/wp-content/uploads/2016/01/Fiona-Hyslop-MSP-Survey-Results-for-CAA-final-3.pdf.
The survey was personally addressed and hand delivered to all those on the electoral register living in the towns and villages of Broxburn, Uphall, Dechmont, Bridgend, Ecclesmachan and the Springfield area of Linlithgow. It received an overwhelming response from more than 2000 people, particularly significant when considering that there was no freepost return and constituents had to pay for their own postage.
It is clear from the results of that survey that the majority of those who responded opposed the TUTUR route, with many severely affected by the noise impact from aircraft at low altitudes and turning of aircraft over heavily populated towns. I strongly believe that this route should not be considered as being part of any proposed airspace changes.
As requested, I have set out below the factors that I believe should be taken into consideration when proposing changes to current airspace use:
The question being asked at this stage is so general and vague that constituents currently unaffected by aircraft may not have thought it could have an impact on them in the future and this may affect the level and more importantly the geography of responses. In a recent consultation process the CAA required a count of ‘newly over flown’ population to be included. It is not clear how such information would be taken into account in a decision making process. However, it represents the common sense and anecdotal evidence that suggests previously unaffected communities are likely to be particularly sensitive when it comes to changes in airspace use. The consultation should take this into account.
1.1 The biggest issue that has been brought to my attention is the route changes which occurred just before the start of the TUTUR route and since it began. Any redesign with new routes should not go over built up areas at low altitude and must revert to using routes south of the A89 and the M8 as previously. Serious consideration should be given to a left hand turn after take-off over green fields with the route heading over the Harburn area as was proposed by representatives of Dechmont Community Council.
2. Timing of Consultation
2.1 I would like to stress that the timing of this consultation is of concern to my constituents as I understand that The Civil Aviation Authority is seeking to review and strengthen its community consultation guidance for designing airspace EAL should wait until the CAA’s new guidance has been published before proceeding with the next stage of its consultation. The CAA process itself needs to be subject to more public accountability and transparency.
2.2 Furthermore, the initial consultation, which commenced on 6 June 2016 and concludes on 12 September 2016 and now extended to 19 September 2016, falls during the period in which many Community Councils and elected representatives are in recess, affecting their ability to respond to this consultation.
3.1 Many of my constituents remain unconvinced that there is a requirement for change at this point in time. The need for any proposed changes to the current use of airspace must be justified beyond any reasonable doubt. I understand that Edinburgh Airport is not currently operating at capacity and whilst I recognise the need to consider future increased demand it must be established if this can be met by more efficient timetabling and ground management in the first instance. This in itself can address fuel efficiency and customer satisfaction. It also underlines the reasonable argument to defer the next stage of the consultation process until after the CAA’s revised guidance as the demand for increased capacity is not immediate.
4.1 I believe that it is essential to set up a ‘Local Noise Forum’ as has been proposed by Edinburgh Airport and I would suggest that this is established sooner rather than later.
4.2 The control and reduction of noise from aircraft over heavily populated areas must be a priority consideration. It is not acceptable for the level of noise intrusion experienced by my constituents, particularly during the TUTUR trial, to continue. Many of my constituents have expressed their concerns over the potential negative effect of aircraft noise on their quality of life, health and wellbeing, sleeping patterns, children’s education and property values. These are all factors which should be taken into account when considering airspace.
4.3 Prior to 2015 I had received no complaints of aircraft noise from constituents yet despite the TUTUR trial ending prematurely noise intrusion continued to be experienced by residents. We know that in the months preceding the trial that changes had been made to the way in which flights operated within the existing flight path corridors. This would explain why a large number of noise complaints received by the EAL during the trial did not relate to the TUTUR route, calling into question the validity of any of the trial findings to community response/complaints.
4.4 The majority of complaints that I have received from constituents do not relate to the individual noise of specific aircraft but more the constant noise all day, every day, and overnight. This must be addressed without exception. The noise monitoring location, capability, provision and information must be made more transparent going forward.
5. Flight Times
5.1 As I have previously mentioned, it should be established if a more efficient timetabling of flights would offer the EAL the capacity increase that they seek, at least in the short to medium term. My constituents who hear aircraft noise in the early morning should not be subjected to it at night. Currently Edinburgh Airport has no restriction on the times at which aircraft can arrive and depart this should be changed to preclude night time flights apart from essential services or for emergencies.
6. Pollution/Air Quality
6.1 Any changes in airspace should seek to reduce the environmental impact of pollution from aircraft and there needs to be robust monitoring systems in place.
7. Community Benefit and Trust
7.1 Edinburgh Airport is an important economic asset and its continued success, which is desirable, should have a direct benefit for the communities which it neighbours. To date the Airport has not had such a relationship with West Lothian as it has been more Edinburgh focused. EAL should identify ways to help support the skills training, transport routes to the Airport, tourism needs and other community benefits for West Lothian.
7.2 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.
I would strongly urge that all the views expressed in this consultation, including those relating to the consultation process itself, be given full respect and consideration.
Fiona Hyslop MSP