16th January 2014
RE: Appeal Case Ref: APP/M3645/A/2202134 REDHILL AERODROME
KRAG – The acronym stands for KEEP REDHILL AIRFIELD GREEN were formed in 1993.
The name of the organisation also sums up its sole objective.
KRAG is not an anti aviation organisation and is not opposed to existing operations at the aerodrome.
Our evidence at this Inquiry has not been given on the basis of an expert witness but as a layman, using knowledge of the aerodrome accrued over 25 years. It represents an entirely local perspective of how the development will create a negative impact on the local community.
KRAG currently numbers about 940 supporting households.
We consider it a fairer reflection of our level of support to count households rather than individuals. This is particularly relevant as sometimes supporters register as families, with no indication of the actual numbers. However every supporting household is registered in the name of at least one individual.
KRAG has a committee consisting of 7 individuals (Chairman, Secretary, Treasurer, IT and general organisers). This group should be considered to be the Steering Group.
The KRAG evidence presented to The Inquiry was researched by various members of the committee and also took account of information supplied by a number of supporters.
To ensure consistency and continuity the evidential documents were drafted by two members of the committee and the final proofs produced by the secretary, Paul Murray.
This process is probably similar to that used by the Consultants employed by the appellant as it is both logical and efficient.
There is no dispute that the aerodrome is within the green belt. Our supporters wish to keep the green areas within Redhill Aerodrome as they currently exist, as green fields, blending into the surrounding undulating and pleasant countryside. You don’t need to be an expert in planning to realise that the Aerodrome, from a visual perspective, has a minimal negative impact on the overall ambience of the area. The Inquiry has received evidence demonstrating the overwhelming level of objection raised by the local communities. Many individuals signing petitions, registering an objection by vote at public meetings, writing to the LPA’s and The Inspector are KRAG supporters.
Public attendance at this Inquiry has been substantial. The vast majority of people who have attended are clearly against the proposal.
THE ENVIRONMENTAL ASSESSMENT
We believe that the EA was produced on a basis that resulted in significant information being absent from the original version provided. Some of the missing information has only been established on receipt of rebuttal evidence and through cross examination.
The following are examples of information that did not appear in the EA.
The EA fails to identify that the proposed system consists, in the main, of High Intensity lighting.
The EA lacked detail concerning the instructions in CAP 168 that govern the periods for which the lighting must be operated. The phrases used in the EA give the impression that the lighting would be on for much shorter periods than will actually be the case.
Research by Rule 6 parties established that the proposed lighting system will consist of in excess of 180 lights, which in the main are high intensity.
It is accepted the existing lighting system creates very little light pollution and has not been subject of adverse comment from residents.
To enable an assessment to be made of effects of the new lighting NPC requested details of the present lighting system and of the current number of fixed wing movements during the hours of darkness.
Ms. Bartaby replied saying she was unable to supply the information requested. However some details were finally disclosed having been included the Ms Bartaby’s rebuttal.
The rebuttal did contain confirmation of the statutory time periods for operation of the lights. This essential detail was omitted from the EA. This information confirmed the analysis made by NPC was correct. The timing issue was misrepresented by omission within the EA, the actually rules governing this activity contained within CAP 168 have not changed therefore this information should have been available within the EA.
During cross examination Ms Bartaby confirmed that there are currently 42 lights of low intensity and they will be replaced with over 180 mainly high intensity lights if the appeal is allowed.
Ms. Bartaby also confirmed that the proposed lighting system includes the provision of approach lights which are not currently present. The introduction of the approach lighting will mark a substantial intensification of lighting.
The EA stated that it was estimated that some of the new lighting will be elevated above 2 metres however in Ms Bartaby’s rebuttal this has increased to 4 metres.
It is not disputed that the landing lights/poles are inappropriate development. It may be considered that the increase of height exacerbates the level of inappropriate development.
In her evidence Ms Bartaby contended that the present runway lighting will have to be replaced with or without the hard runway. Clearly if the appeal is dismissed such an upgrade for the existing grass runway will not be on the scale required for the hard runway.
Ms Bartaby’s evidence suggested that the replacement lighting would not always operate on full power. However it is clear that the increase to in excess of 180 lights, including elevated approach lights at 4 metres, coupled with a planned increase in aircraft movements during the hours of darkness will generate a degree of light pollution that does not currently exist.
The appellant’s consistent reluctance to provide information on the subject may be indicative of concerns of the overall level of light pollution that would occur.
Ms Bartaby’s Proof was provided in mid December. It contained the assertion that CAA Permitted Development Rights had been granted on the 10th October 2013. No prior mention had been made that the appellant had made an application to the CAA concerning this matter. We believe this to be unreasonable as this information should have been provided at a much earlier date.
The Appellant was able to model the maximum noise impact of individual aircraft flyovers on the residential properties situated at Copsleigh Avenue, Honeycrock Lane and Salfords Primary School. However, this was not provided within the EA and was only produced as the Inquiry commenced following a request by Cole Jarman.
This approach effectively restricted the time available to consider the significant impact on the area in question. It is possible that if this information had been made available within the EA the LPA’s may have taken a more robust approach to the Noise case.
OTHER EA MATTERS:
The table of air movement numbers in Ms Bartaby’s Proof substantially misrepresents the average figure of air movements since 1997. A correction was made within the Krag Proof but this was not accepted by the appellant until they were challenged at the Inquiry.
The figure used within the table in Ms Bartaby’s Proof is completely unrepresentative of the current 10 year operational history of the Aerodrome. It has the effect of substantially narrowing the gap between the projected figure of 85,000 and the actual current figure of circa 44,000. This results in the planned intensification of air movements being disguised. The figure of 60,000 existing air movements was used in a voiceover report in a BBC Television item about the Inquiry that was broadcast on Wednesday 8th January.
The EA makes no mention of the subject of Air Traffic Control, which has long been a source of concern for local residents.
The issues quoted are only the ones that we have already identified. They represent important matters of which it is reasonable to expect that full disclosure would be provided within the original EA.
The Business Plan examined by the University of Portsmouth was never provided to the Rule 6 parties and was only given to Reigate & Banstead Council upon the signing of a confidentiality agreement. Tandridge Council declined to enter into a similar agreement. We believe that any reliance on such a document should not be permitted in the course of a Public Inquiry.
In general terms we believe that the overall approach by the appellant is unreasonable. Relevant information should be made available at the earliest possible time to enable the details to be properly and fairly considered. This has not happened during this process.
Within the last 12 months (since the EA was produced) the Aerodrome has gained at least 2 new major contracts with the introduction of the air ambulance and the Police helicopter to the site. These operations are for rotary aircraft and hence not affected by the weather or the lack of a hard runway. They provide a regular and new income stream.
Evidence was produced, and Ms Bartaby confirmed in examination, that the unlicensed runway permits a significant number of fixed wing movements during times of poor ground conditions.
It is accepted that limitations apply in the use of the taxiway as a runway. The fact remains that some operational capability exists and is used during times that the prevailing weather is poor. Again this situation was not clearly accounted for within the EA.
During cross examination Ms Bartaby agreed that that in 2013 the Aerodrome enjoyed its best year in terms of air movements since 2007, achieving a total of 44,333. This is an increase of 4,425, an improvement of just over 11 percent, and achieved without a hard runway.
GREEN BELT ISSUES
The introduction of the NPPF has undoubtedly changed Government Policy. However the Government have made it clear that Green Belt protection remains firmly in place. Evidence given by Reigate MP Crispin Blunt confirmed that the Prime Minister himself had clarified the formal stance on Green Belt development.
Redhill Aerodrome has undergone very few changes in the last 40-50 years and has an open grass field aspect that blends into the surrounding rural area. The very nature of the current operational arrangements with the existing grass runways means that the Aerodrome enjoys a seamless visual relationship with the surrounding countryside.
This fact has been accepted by previous Planning Inspectors.
The longest existing grass runway is 897 metre long. The construction of a concrete runway of 1,349 metres is an increase in length of 452 metres (50.4 percent) will cause a material change in the appearance of the land.
The earthworks required to construct the new runway will require the topography of the land to be re-contoured at both ends with the Crab Hill Lane end requiring a minimum of fill of 2 metres in height and at least 50 metres in width.
Ms Bartaby confirmed in cross examination that material to construct the runway surface will be imported to the site. She further confirmed that the construction requires 300 mm of foundation material plus 150 mm of top surfacing.
That amounts to a minimum of 15,176 m3 of imported material to be brought to site. The only vehicular access is via the network of narrow country lanes.
The resulting new runway will be completely uncharacteristic within the existing landscape. The area in which the proposed runway will be built currently consists of open grassland with minimal urbanisation.
The expansion in size and change in character from grass to concrete will mean the new runway will have a seriously detrimental impact on the existing rural landscape.
The proposed engineered landscape and the extent of the man-made surface will have a huge adverse impact on the openness of the existing Aerodrome, representing an unacceptable proportional change to the existing minimal urban influences at the site.
Previous Planning Inspectors have concluded that this is in a vulnerable part of the Green Belt where it contributes to the separation between Redhill and Horley, This area has a vitally important role in maintaining the vulnerable gap between the two. It forms part of the wider rural landscape which remains relatively unspoilt and continues, as Planning Inspector Rosser (Redhill Aerodrome 1994 Public Inquiry) said two decades ago, to merit protection.
In Para 10.2 of her Proof of Evidence, Jane Davies confirms that the aerodrome forms part of the green belt separator. She says:
that the Aerodrome is an important component in ensuring the separation of the urban areas, however I believe that it ensures the continued separation of Salfords/Whitebushes and Nutfield rather than Redhill and Horley.
The role played by the Aerodrome as a separator is a vital distinction which places the value of the site in to its local context.
We contend that the proposed development will result in an unacceptable increase in noise and light within a rural area, causing harm to residential amenity. The proposed development will have an unacceptable visual impact on the existing rural environment both during the day, by way of its built form and at night by way of light pollution and as a result of the extended hours of operation.
It is our opinion the appellants believe that if they can get permission to build a hard runway then they begin the process of changing the nature of the site from what is currently accepted to be Green Belt to one that has significantly increased urbanised elements.
A hard runway will intensify the use of the site both in terms of air traffic movements and road movements. Ms Bartaby admitted that the increase in length of the longest grass runway by 452 metres to the proposed paved strip of 1349 metres will "have a bearing" on the intensification of use of the site.
This change would almost certainly lead to increased pressure from them to develop the site further. This must be resisted.
We contend the appellant's "very special circumstances" are insufficient to clearly outweigh the potential harm that would be caused to this Green Belt site.
The provision of a new full length runway by the year 2030 will have a major impact on overall capacity in London and the South East. The overall capacity constraints identified by the appellant in paragraph 4.39 of Ms Congdon’s Proof of Evidence will either no longer exist or be potentially insignificant.
The fundamental and essential element to the appellants Economic Case is to achieve the projected number of 85,000 Air Movements. This is the driving force behind any potential job increases and GVA.
However, absolutely no information has been presented to indicate how this would be achieved.
Under cross examination there was much confusion regarding the claims made that without the appeal being allowed the Aerodrome would close with the loss of all existing jobs.
Mr Whale established this "doomsday scenario" did not really seem to be a fully agreed position between Ms Congdon and Ms Bartaby, with both taking different views on the reliability of the original claim and/or the timescale involved. The University of Portsmouth report also did not concur with the closure scenario.
Ms Bartaby was also unable to confirm when or what the trigger point would be for the creation of any new jobs. Her position mirrored that taken by former CEO Jon Horne at a public meeting in Salfords Village Hall in August 2012, who also was unable to identify any timetables. Ms Congdon did claim that the aerodrome could close within a time frame of 12-18 months, if permission was not granted, but this assertion was as usual unsupported.
Ms Congdon admitted when questioned that the 2011 Eurocontrol forecast she relied on regarding Business Aviation was not the most recent and that she had extrapolated the forecast until 2030 when in fact it was only valid until 2018.
Within her calculations she had used a "conservative figure of 4 percent," but had extrapolated this figure for 12 years beyond the actual date the Eurocontrol forecast was valid until (2018). This approach is surely incorrect.
If she had taken the same conservative approach with the more recent 2012 Eurocontrol forecast she would have used a figure of 3 percent to represent the forecasted figure. It would have still only have been valid until 2018.
This small mathematical calculation error makes a substantial difference if projected until 2030 as Ms Congdon did. It results in a substantially inflated figure at 2030 that is completely unsupported by evidence.
Evidence in the Krag Proof that is confirmed by both Eurocontrol forecasts shows the trend in Business Aviation is now for larger aircraft. Potentially these could not be accommodated at a developed Redhill. This trend in increased size was confirmed by the evidence given by Paul LeBlond representing Biggin Hill.
The market for VLJ’s that Ms Congdon could "clearly see" in her paragraph 4.52 is not supported by any evidence she presented. The 2011 Eurocontrol forecast relied on by Ms Congdon indicated that this sector was diminishing and continues to diminish as confirmed by the 2012 version. In fact the evidence offered by Krag in their Proof indicates the "niche market" identified by Ms Congdon is clearly shrinking, if it ever existed at all.
Ms Congdon claimed in her cross examination that her knowledge of the VLJ market expansion was derived from manufacturing projections for this category of aircraft. However no such evidence has been offered.
Ms Congdon’s displacement theory also failed close scrutiny. It became apparent that no evidence existed that any suitably smaller sized Business Aviation aircraft, displaced in the future from using Luton and Stansted, would actually select Redhill as a suitable alternative destination. This would be due to Redhill being in a location that may not prove convenient for businessmen who find the use of Luton and/or Stansted fulfils their purposes regarding their ongoing destination.
Ms Congdon also accepted that the visiting dignitaries that might be displaced from Heathrow and Gatwick would be very unlikely to select Redhill as a replacement destination, preferring Farnborough.
Ms Congdon further accepted in cross examination that the potential 8,400 figure of Business Aviation ATM’s that could be accommodated by Lydd by the year 2030. This had been not included within the figures shown in her Redhill Proof. She had previously given evidence at the Lydd Inquiry in 2011 that this would be the case.
In 2012 Luton Airport had 19,113 Business Aviation movements. According to Ms Congdon’s displacement theory 50% of these, (some 9,500), would be seeking a new home by 2030. However, no account has been taken of the planned expansion of Luton to handle 36,000 Business Aviation movements. This is apparently achievable without the planning permission Luton will soon seek.
Finally in cross examination Ms Congdon agreed that in line with the York Aviation 2011 Filton Report that Business Aviation users are significantly less price sensitive than users of General Aviation.
Clearly the Filton statement undermines the attempt by the applicants to dismiss the potential competition from Biggin Hill and Farnborough on the basis of higher costs at those sites. Ms Congdon’s attempts to dismiss the relevance in relation to Redhill Aerodrome should be viewed in that light.
In relation to the winter closures affecting Redhill Aerodrome Mr Le Blond representing Biggin Hill Airport stated in his evidence that even with 2 hard runways there was a large element of seasonality at Biggin Hill.
He confirmed that movement numbers reduce significantly during the winter months. He further stated that General Aviation movements showed a diminishing trend which was common within the industry.
All parties agree that failure to achieve the projected 85,000 Air Movement numbers will result in the projected increase in jobs and GVA not being realised.
The applicant’s have failed to produce evidence that a market exists for the facility proposed. There is no evidence that can support the speculative projections made in the EA that 85,000 movements can be achieved.
The development is entirely speculative and the associated jobs remain total conjecture.
The damage to the Green Belt would be permanent should this appeal be allowed. It would be additionally disastrous if permission is granted on the basis of the perceived existence of Very Special Circumstances that are based on flawed economic and job creation forecasts that fail to be realised.
EXISTING INFRASTRUCTURE CASE
This is a policy that Redhill Aerodrome consultants, York Aviation, claim has relevance for the proposed development, but only if they already had a concrete runway. Redhill does not have the existing infrastructure that National Policy refers to.
Redhill made no submission to the Airports Commission to make a case for better use of their infrastructure.
Other airports are already capable of "being used to assist in meeting demand" as their infrastructure is in place.
TRAFFIC & HIGHWAY CONSIDERATIONS
The local community feel badly let down by Surrey County Council Highways regarding this matter.
Due to the vagaries of the Police recording of accidents and the fact that they do not attend every incident, the accident statistics relied on by Campbell Reith do not represent the actual volume of road accidents that occur. More incidents occur than are recorded.
This situation was confirmed by the evidence of Mrs Cook. Mrs Cook also stated that the recent imposition of additional signage has not achieved an improvement in driver behaviour.
The words limit and mitigation used by SCC are merely containment measures and will not resolve the serious traffic issues.
The additional volume of traffic generated by the proposal will bring a huge increase in vehicles to roads that are already dangerous and overcrowded.
We do not feel this matter has been adequately addressed by SCC.
REGARDING THE UNSUSTAINABLE LOCATION
If the proposal is approved and the applicant’s business projections realised the overall level of use of the airfield would intensify and road journeys would substantially increase.
It is an accepted fact that the site is not connected to any form of public transport network. The site is only accessible via a network of narrow country lanes which are dangerous and over crowded.
The distances to the neighbouring settlements, the lack of infrastructure available for pedestrians and cyclists, the absence of public transport and the nature of the proposed use will result in the inevitability that the site will be only be accessed by use of the private car or taxi.
Richard Berliand, a supporter of the proposed development confirmed when giving evidence that he would not consider using the bus offered in the appellants travel plan. This view, we believe, is probably representative of the demographic group that use business aviation.
Ms Congdon admitted in cross examination that reducing dependence on car travel compiles with Government policy. Development at Redhill would achieve the opposite to this.
Accordingly, we submit that the proposed development does not meet the national, regional and local planning policy imperative to minimise the need to travel, and thereby conform to meet the demands of climate change.
In any planning application for an aerodrome expansion and new runway an obvious aspect will be the implications for ATC matters.
On every (aviation) related planning application made by the appellant one of the first concerns raised by the public are ATC implications. The matter is routinely raised at public meetings involving aerodrome operations. The Local communities are sensitive regarding ATC issues, and they are a matter of significant concern to residents.
Yet this matter is completely absent from the EA.
The appellants have consistently verbally reported that ATC issues are resolved but no written confirmation of this has been supplied.
The appellants continue to rely on the response from NATS and Gatwick Safeguarding, both of which have been in the public domain for some time. They are the statutory consultees but they do not deal with ATC matters.
A direct unambiguous request to obtain documentation to confirm there are no issues was made to the appellants.
The reply was to again supply the NATS safeguarding response and to allude to the existence of other correspondence between the appellant and NATS.
The documentation supplied does not alleviate our concerns.
NATS have confirmed in writing to us that they have not been requested to undertake any detailed modelling for Redhill Aerodrome.
The appellants are aware of the communities ATC and Airspace concerns it would have been a very simple matter to address it in the EA without ambiguity.
Similarly if indeed the matter is straightforward it is baffling why the appellants have failed to produce the documentation and continue to rely on the NATS & Gatwick Airport Safeguarding letters that have no relevance to the issue.
In the circumstances we consider the matter of ATC remains unresolved.
THE APPELLANTS CASE
For the appellant to win this appeal they must prove that their very special circumstances clearly out weigh the accepted harm to the Green Belt.
We would contend that they in fact have clearly failed to achieve this.
The economic case presented by the appellant has not survived close scrutiny. The existence of the niche market for VLJ’s has not been identified, General Aviation numbers appear to show a diminishing trend at both Redhill and Biggin Hill, regardless of the hard runway at the latter.
The proposed concrete runway will be far more visually intrusive than the existing grass runways, especially as one end requires elevation by 2 metres and by about 50 metres in width. This will result in an inappropriate development causing harm within the Green Belt.
Our evidence confirmed that the site of the aerodrome should be considered as an unsustainable location to accommodate the proposed development. The site is not connected to the public transport network. Access is only available via narrow country lanes that are completely unable to safely accommodate the proposed increase in road traffic.
Pollution and disturbance in terms of increased noise and light will result if this appeal is allowed. There will be a significant intensification of use of the site which will diminish the standard of life for many in the local community.
KRAG do not accept that the evidence provided within the Environmental Assessment and other supporting documentation is complete and indeed in some aspects it is inaccurate.
The current owners bought the site as a grass field Aerodrome that was and remains wholly within the Green Belt. The Aerodrome had already been refused permission to develop a concrete runway before RAV purchased it. They had full knowledge of the potential limitations that existed to develop the site.
The Redhill Aerodrome group of companies unreasonably persist in making numerous and yet broadly similar planning applications to build a hard runway. On this occasion they threaten to close the Aerodrome if the appeal is dismissed.
We contend the appellant’s "very special circumstances" both individually and collectively are insufficient to clearly outweigh the harm that would be caused to this Green Belt site.
On that basis we submit that this appeal be dismissed.
We urge those affected to lodge a formal objection to the application using the information that is provided on this site at this link