Response from Belfast City Airport Watch (BCAW) to GBBCA Draft MasterPlan 2040

Representatives of BCAW attended all the “Consultations “as did a number of our individual members. There was a consensus among our members and attendees to whom they spoke that these events might better have been described as “presentations” or “exhibitions”. “Consultations” before attendees have had time to take professional advice, without a question-and-answer session and without the opportunity to cross examine your assertions are not proper consultations.

There was also a consensus that your Questionnaire was heavily loaded towards the responses you wanted. We gathered from your staff that this Questionnaire was not professionally checked to eliminate bias. Without the elimination of bias any conclusions following the bias must be suspect. We have advised our members accordingly and they are therefore unlikely to use your questionnaire to respond. This letter is to convey their preliminary views in a more straightforward way and without distortion.

Our interest in your expansion plans centres on the noise and disturbance caused or likely to be caused by an increase in aircraft movements and the introduction of scheduled flights after the 21.30 deadline. As you know the current controls on the operation of George Best Belfast City Airport (GBBCA) were set in 2019, only 6 years ago. These controls were the result of a Public Inquiry at which the Planning Inspector arrived at a carefully considered balance between the ambitions of the Airport and the need to protect the Residents in what is a heavily populated residential area.

One of the conditions of the revised Planning Agreement of 2019 is that air traffic movements (ATMs) are limited to 48,000 per year. You are putting forward the proposition that 61,000 ATMs will be required at GBBCA to provide the flights that Northern Ireland will require. We do not consider this proposition proven at all and consider that evidence for it needs to be put forward at a Public Inquiry where your assertions can be tested using expert advice. We note that you are currently operating with around 30,000 ATMs and thus have 18,000 ATMs unused now.

You also assert in your Preliminary Environmental Report (at 5.1.25 on page 30) that if GBBCA has to operate within the 2019 Planning Agreement it is likely that neither Belfast International Airport (BIA) nor Dublin Airport could handle Northern Ireland’s share of the postulated demand. We gathered from your staff that you have not asked BIA if this assertion about their inability to expand is correct. As you can imagine, if BIA, which is in open countryside with little or no residential noise problem, can handle any necessary expansion of demand, that is vastly preferable to expanding GBBCA which is in a heavily built-up residential area. An assertion by you of such importance should be checked with BIA without further delay and if a correction is required it should be given wide publicity.

A key provision in the revised Planning Agreement of 2019 is that no flights should be scheduled after 21.30 and that only in “exceptional circumstances “should delayed flights be allowed between 21.30 and 23.59. This provision is of the greatest importance on a daily basis, now, to residents and to their families who need respite from aircraft noise. It is for this reason that as an organisation we monitor flights after 21.30 (late flights) and continually remind the Department for Infrastructure of the need for proper enforcement of the Planning Agreement and the “exceptional circumstances” exemption.

With this provision in the Planning Agreement and a proper, stricter, application of the “exceptional circumstances” rule, up to 9 hours of sleep are possible between 21.30 and 06.30 the following morning when flights start for the following day. Sleep is very important for health and well-being and particularly is this the case for children. The NHS puts the sleep requirement for children of 3-5 at 10-13 hours, children of 6-13 at 9-11 hours and aged above 13 at 8-10 hours. Sleep deprivation in children is not only highly undesirable but also correlated with serious health problems in later life. As GBBCA already has operating hours for scheduled flights which prevent these requirements being fully delivered it would be perverse and irresponsible to apply for scheduled flights beyond the exiting limit of 21.30.

These health problems in later life would, of course, be in addition to the effects on reading comprehension and recognition memory in school children. The RANCH project found a linear decrease in both reading comprehension and recognition memory with increasing aircraft noise.

There is no history of GBBCA being other than a commuter / business airport and that was the “character” it was given when change of use was allowed from a military facility to a civilian airport. In that commuter/ business “character” was contained any justification there was for a trade-off between noise and helping the Northern Ireland economy. We note, however, when comparing the so called “constrained “scenario (compliant with the Planning Agreement) with what you want, the extra flights appear to be to Europe and the Mediterranean (fig 5.4 on page 29 Preliminary Environmental Report). These have the appearance of holiday flights. These are more likely to be fully loaded with fuel, heavier, make more noise and be more subject to delays. The holiday business is currently almost entirely centred at BIA, which is in open countryside, has very few residents nearby and can operate 24/7 without creating noise issues. It is not suited to GBBCA which is in a heavily populated area and where there can be no case for creating noise and disturbance to enable holiday traffic which is likely to take money out of Northern Ireland rather than bring it in.

We have no objection to GBBCA operating in a responsible manner as a commuter/ business airport within the parameters set by the Public Inquiry. It is also largely a matter for you what you spend on improvements to terminals, rail connections, hotels, or car parking. What we will not support is the creation of more noise and disturbance or more hours of noise and disturbance. We will also not support a change in the “character “of the airport or the unnecessary duplication of services that could be provided by BIA without the destruction of residential amenity in Belfast and North Down.

It is our view that the existing balance between airport operations and protection of residents which was settled as recently as 2019 cannot safely be disturbed. If you want to make a planning application which in any way challenges the 2019 revised Planning Agreement this would have to be the subject of a very detailed examination. This could only be carried out at a further Public Inquiry.

Our lawyers will be advising the Department for Infrastructure accordingly.