Evidence given to the Airport and Communities All Party Parliamentary Group

This is the text of the evidence given to the Airport and Communities All Party Parliamentary Group (APPG) meeting on 5 Sept 2023.

Introduction.

1. I’m Stephen Clarke, one of the co-ordinators of Bristol Airport Action Network and the No Airport Expansion national campaign. I’m a retired lawyer and former Bristol City Councillor. I am here to talk about Bristol Airport’s expansion plans but also about the problems in the planning process itself that have been exposed by what has happened in Bristol. This is very important in the context of the many other regional airports which have plans to expand ⁹ .

2. Bristol Airport Action Network (BAAN) is a network of individuals and groups who came together in 2019 to resist the expansion plans of Bristol Airport Ltd. The expansion plans, which were submitted in Dec 2018, included an increase in annual passenger numbers from 10m to 12m passengers per year and also other works, including a multi-storey car park on Greenbelt land. It is also worth noting that the airport have longer term plans (on their website) to double in size to 20mppy.

3. The starting point for understanding the context in the region is that there has been an overwhelming majority of local people against them, but they have still been approved.

4. The opposition to the expansion planswas wide ranging and came from all sides of the political spectrum.

a. The local MP (Liam Fox-Conservative) and the regional WECA Mayor (Labour) were strongly against the proposals.

b. The local councils including Bristol, rural town councils and parish councils of all political stripes submitted objections.

c. More than three quarters of the 11,000 plus residents who submitted comments on the planning website were against the plans.

5. As a result of this opposition, the plans were rejected by a large majority of the local Planning Committee. The main issues which led to this decision were:

a. Many local residents and others from around the UK were deeply concerned about the carbon impact of these extra flights during the current climate chaos. This was the main point on which my organisation led in the inquiry.

b. There are huge concerns concerning local road congestion. Access to the airport is by way of very narrow local roads and one main road with one carriageway in each direction. Notably, it is the biggest airport in the UK not to have a rail link and only a very small percentage of users (3-4%) travel by bus. Congestion on surrounding roads is already very severe.

c. Noise is a huge issue, with many residents saying that the present level of noise is already intolerable without any expansion. The new permission allows there to be 4,000 night flights (nearly as many as Heathrow which has 5,300) and these were seen by medical experts as very negative to the health of surrounding residents.

6. The airport appealed to the Planning Inspectorate against the local rejection and there was a ten-week Planning Inquiry. We were a ‘Rule 6 Party’ and submitted considerable evidence from scientific experts. Despite this, and the verbal evidence from dozens of local residents, the airport’s appeal was granted and the expansion was approved.

7. We submitted a Statutory Appeal against the Planning Inspector’s decision which was rejected by the High Court. The Court of Appeal have now refused us permission to appeal the High Court decision.

8. At no stage (despite requests from a number of the parties-including the airport) did Michael Gove or anyone else from the government become involved in any way in the decision making. The relevance of this will be seen shortly.

9. The net result is that the airport can now continue with their planned expansion; albeit completely against the will of the local people. We think this is anti- democratic and wrong but, looking at the wider context, we consider that there are a number of specific points where this decision demonstrates that the planning system as currently being used to decide regional airports expansion plans, is outdated, ambiguous and not fit-for-purpose.

The ‘Planning Gap’.

10. The first of these is what we have called the planning gap. As you will know, the main policy document in regional airport planning decisions is called Making Best Use (MBU). Unfortunately MBU is out of date and ambiguous. Even within the document itself there are contradictory statements about the treatment of GHG emissions. ¹⁰

11. The interpretation of MBU adopted by the Planning Inspectors in the Bristol case was that GHG emissions from aircraft could not be considered as a material considerations at a local level but should only be considered nationally. ¹¹

12. The problem that has arisen is that, because Michael Gove chose not to call-in the decision, the extra carbon from the planes has not been considered at all; not by any government agency.

13. This means that, at a time of a declared climate emergency, where the UK government has a legally defined carbon target of net-zero by 2050, an extra million tonnes of carbon ¹² resulting from this airport’s expansion is simply not 10 MBU at 1.29 says ‘This policy statement does not prejudge the decision of those authorities who will be required to give proper consideration to such applications. It instead leaves it up to local, rather than national government, to consider each case on its merits.” (original emphasis). However at 1.11, it says ‘There are, however, some important environmental elements which should be considered at a national level.’

11 The High Court in Bristol Airport Action Network v Secretary of State for Transport [2023] EWHC 171 (Admin) at [118] agreed with the Planning Inspectors interpretation of MBU and said that ‘that one “important environmental element” which “should be considered at a national level” is the issue of “aviation carbon”.

12 Calculated by an independent expert at the Planning Inquiry as being over a million tonnes of carbon a year from the expansion alone. To give a sense of scale; the annual carbon emissions from all road transport in Bristol is estimated by Bristol City Council to be only half of this figure. considered as being important enough to be even considered in the planning decision. This cannot be right.

The ‘drop in the ocean’ fallacy.

14. The next item that emerged in the evidence to the inquiry was the ‘drop in the ocean’ idea widely used by the aviation industry in many such inquiries. The argument is basically that Bristol Airport’s emissions are too small to make any difference but only if you compare them to a big enough comparator.

15. The test that was used by the planning inspectors when considering the increased carbon emissions at Bristol was whether they would be ‘so significant as to have a material impact on the government’s ability to meet its climate change target and budgets’. In other words, whether these extra emissions alone would make it difficult for the UK government to reach net-zero.

16. This must be the wrong test. It cannot be right to weigh the emissions from a single project like Bristol Airport’s expansion against the total UK aviation emissions in order to measure whether they are significant or not.

17. It will always be the case that the emissions from any one expansion project (perhaps with the exception of a new runway at Heathrow) would appear small when compared with the entire aviation budget for the UK. This concept, if it is allowed to stand, will inevitably lead to all regional airport expansion plans being approved.

18. What is needed is a cumulative impact assessment by the government; where the impact of all current expansion plans are considered. If this approach was adopted it would quickly be clear that there was a problem with the emissions from aviation (especially with the UK increase of 70 million passengers a year planned and allowed for by the government and the industry). Even taking into account increased engine efficiency and techno-fixes such as SAF, the available carbon budget will be massively exceeded.

19. Plans for expansion have recently been approved in Stansted and Bristol and there has been approval for a new airport at Manston. There are applications from Luton, Gatwick and others. As many as 20 other airport also have expansion plans. None of these applications should be considered (and approved) in isolation but should be counted cumulatively. The impact of non-CO2 gases.

20. The third issue is that planners chose to simply ignore much of the impact of airport expansion on global warming; in particular the toxic brew of gases other than carbon that aircraft emit into the high atmosphere.

21. The government’s own team at what used to be BEIS, considered the leading research papers and concluded that these ‘non-CO₂ emissions’ as they are called, do increase the warming potential of the emitted carbon. A further scientific overview of this issue is contained here 13 .

22. Having considered the evidence, BEIS decided to adopt a multiplier approach to estimate the impact of these other gases. The multiplier they chose to express this was 1.9x the carbon. Others have said that the multiplier could be as high as three. This means that the true impact of the gases are effectively twice or three times that of carbon alone. What no-one seems to be arguing is that there is no impact at all.

23. However, the Planning Inspectors at Bristol took the view that, because they did not know exactly what the amount of the impact was (in other words what the multiplier should be), they could completely ignore the issue and totally ignore the impact of these gases.

24. In our view, the inspectors have therefore not carried out their duty of considering the total warming impact of the gases emitted by the extra planes. In order to make a reasoned decision on the environmental impact of airport expansions the impact of these additional gases released at high altitude must be considered.

Conclusion

25. The decision making process concerning regional airport expansion planning applications is flawed. MBU is clearly out of date; it is ambiguous and open to many different interpretations. It was published in June 2018 when we were in an entirely different world; the extent of the climate emergency was only just becoming clear to decision makers and crucially, the UK had not yet committed to net-zero under the Climate Change Act.

26. Each project cannot be considered on its own against an artificially enormous comparator to measure its significance. Instead, there must be a cumulative impact assessment of all current and planned airport expansions.

27. All of the ecological impact of each planned expansion needs to be considered including the impact of all gases emitted by aircraft at altitude; not just carbon but hugely impactful non-CO2 gases as well.

28. Local democracy must be empowered. The planning laws pretend to listen to local opinion but Bristol shows this is not happening. Local objections massively outweighed support and yet were completely ignored in the Bristol decision- making process by Bristol Airport, the Planning Inspectorate and central Government.

Stephen Clarke Bristol Airport Action Network (BAAN)

Notes

9 Leeds/Bradford, Bristol, Southampton, Stansted, Gatwick, London City, Luton,
Manston.