South Gloucestershire Review of the BAE Systems Aviation Options Report for Filton Airfield December 2011 South Gloucestershire Council Filton Airfield Purpose 1. To report the conclusions of work undertaken in response to the Full Council Question No.3 dated 19th October 2011, in respect of Filton Airfield. Background 2. In April 2011 BAE Systems Ltd announced its decision to close Filton Airfield at the end of 2012. That decision has significant implications for the District and wider area including the programme for the Council’s emerging Core Strategy. 3. The Council has in the period since April 2011 undertaken widespread engagement to listen to the wide ranging views being expressed in response to the closure announcement and to better understand the issues which arise from BAE Systems Ltd decision to close the airfield. 4. The Council is committed to having its Core Strategy ‘examined’ by an independent Inspector at the earliest reasonable opportunity with view to adoption of the Core Strategy in the summer of 2012 if possible. The consequences of not having an adopted core strategy are far reaching. It is therefore very important that both the position in respect of Filton Airfield and more generally are resolved as quickly as possible. 5. In order to better understand the reasons advanced by BAE Systems Ltd for closing the Airfield, and to explain that decision as part of the engagement process, the Council invited the Company to prepare and publish an Aviation Options Report. This summarises the key information and aviation options considered and which led BAE Systems Ltd to conclude that the Airfield is not thought to be viable or needed. 6. The Aviation Options Report was published by BAE Systems in October 2011 in parallel with the Council’s engagement process on airfield related issues. The overall engagement process and feedback received is summarised at Appendix 1. A number of issues were raised with aspects of the aviation and options report. At the Council meeting of 19th October the Leader of the Council was asked that, “given the huge importance of the airfield site, what action would be taken to ensure that the report is independently assessed so that the process can command the confidence of local people”. 7. The Leader confirmed that all reasonable steps would be taken to establish whether the report can be considered balanced and factually accurate. Specific checks identified were to: 1. Review planning, transportation, engineering and financial elements of the report. 2. Review the technical competencies track record and expertise in this field of Mott Macdonald the reports principal authors. 3. Seek confirmation from Airbus, Rolls Royce and GKN whether they consider that the statements made in the report are correct and accurately reflect the position of those companies. 4. Work closely with the Local Enterprise Partnership and wider business community to gauge their opinion and thoughts. 5. Review and consider the feedback and comments that local communities and key interested parties and stakeholders including Bristol City Council have made to the airfield consultation. 6. Use external expertise where necessary to assist and support in house staff with those reviews. 8. This report provides updates on the steps which have been taken to progress these reviews and the main conclusions reached. Detailed updates are given in subsequent sections of this report. In summary Officers have: 1. Identified technical areas of the Aviation Options Report which have been questioned and have sought to check whether the comments and assumptions made are sound. 2. Reviewed the technical competence and expertise of Mott MacDonald and other lead consultants. 3. Written to the principal companies at Filton and a range of other interests to seek confirmation that comments attributable to them are accurate. 4. Held a workshop with local companies on 26th October at Hollywood Mansion (appendix 2) and have had follow on correspondence with the LEP and other companies. 5. Reviewed the feedback from consultation and followed up issues and ideas. 6. Held a Member meeting with Bristol City Council to explore issues and concerns. 7. Commissioned consultants, York Aviation, to provide specialist input to these reviews. Specifically to advise on the aviation options considered by Mott MacDonald. The York Aviation report is reproduced at Appendix 3 to this report. 8. Held a planning workshop with all stakeholders including businesses, landowners, community representatives and Members, on 4th November, which looked at implications and opportunities for the area if the Airfield were to be redeveloped. This followed from a previous workshop held on March 3rd which had looked at a vision for the area with the airfield retained. 9. Written to Government and others inviting views on the future of the Airfield. 10. Reviewed the need for employment land in this part of the North Fringe. 11. Met with Airbus, at their request to better understand its view of the proposed airfield closure and the long-term direction of the local aerospace sector. 12. Met with the Concorde Trust and Great Western Air Ambulance service to consider the implications of the proposed airfield closure. 9. This paper aims to draw together the arguments and evidence presented by BAE Systems Ltd for closure of the Airfield and by those, including the Save the Filton Airfield Campaign Group (SFACG), who wish the Airfield to be retained and developed for aviation related activities. This is undertaken in specific response to the Council motion. Key positions expressed for and against closure of the airfield 10. In summary BAE Systems Ltd argues that: • The airfield is no longer viable • The airfield is no longer needed • The needs of existing users of the airfield can be met in other ways • Redevelopment would present new opportunities for business and residential development which would benefit the local economy. 11. In summary those opposed to the closure of the Airfield argue that: • Closure is motivated by short-term financial and commercial considerations; • The Council will view it as a relatively easy way of meeting housing targets. • Closure would be short sighted and a serious and genuine threat to local economic prosperity. • The Airfield is needed. • The Airfield is potentially viable. Consideration of Issues in response to the 19 October Council motion 1) Review of Planning and Legislative Issues 12. Relevant policies for the consideration of Airfield issues are: National Planning Policy 13. The Department of Transport Future of Air Transport White Paper (December 2003) provides a strategic framework for the development of air transport in the UK for the period to 2030. The White Paper lent general support to the development of Bristol International (Lulsgate) and refers to consideration of a new airport north of Bristol (although not necessarily the Filton site). 14. In its report for the Council York Aviation note that the White Paper notes that “a new airport north of Bristol would be neither economically beneficial nor commercially viable.” However, the White Paper notes that “Filton and Gloucester Airports play an important local role in respect of business aviation, and we fully support the continuation of these roles” (White Paper 2003, Paragraph 10.30). 15. Current national planning policy for transportation is set out in PPG13 (Transportation). Some aspects of the policy were updated by the Coalition Government in January 2011 but references to aviation were unchanged. 16. Paragraph B5 states that Local planning authorities will need to consider: 1. The growth of regional airports … Filton is not a regional airport in this context. 2. The role of small airports and airfields in serving business, recreational, training and emergency services needs. As demand for commercial air transport grows, this general Aviation, may find access to larger airports increasingly restricted. General Aviation operators will therefore have to look to smaller airfields to provide facilities. In formulating their plan policies and proposals, and in determining planning applications, local authorities should take account of the economic, environmental, and social impacts of general aviation on local and regional economies. 17. Paragraph B6 to PPG 13 goes further to state that local planning authorities should: “consult the Department for Environment, Transport and the Regions’ Airports Policy Division on draft development plan policies and proposals relating to airports and airfields. In consultation with the Airports Policy Division, local authorities should: 1. Identify and where appropriate protect sites and surface access routes, both existing and potential (including disused sites), which could help to enhance aviation infrastructure serving the regional and local area. 2. Avoid development at or close to an airport or airfield which is incompatible with any existing or potential aviation operations. 18. Paragraphs B7-B9 set out further guidance for the operational development and support of airports and airfields. 19. In line with the requirement at Annex B to PPG 13 the Council has notified the Airports Policy Division, the Department for Transport and the Department of Environment, Food & Rural Affairs at all stages of the Core Strategy’s production, including: 1. Issues & Options, 2008 2. Pre-Submission Publication Draft, March 2010 3. Proposed Changes, December 2010 4. Further Proposed Changes, February 2011 5. Filton Airfield Position Statement, June 2011 6. Filton Airfield further consultation, October 2011 20. No comments have been received in response. Draft National Planning Policy Framework (NPPF) 21. The draft National Planning Policy Framework was published for consultation in July 2011. The draft policy in respect of airports is given at Paragraph 87 which states: “When planning for ports, airports and airfields that are not subject to a separate national policy statement, planning policies should consider their growth and role in serving business, leisure, training and emergency services needs. In doing this policies should take account of the Framework as well as the principles set out in the relevant national policy statements and the Government Framework for UK Aviation.” 22. Since the announcement of proposed closure of the airfield and publication of the Aviation Options Review contact has been to Government through BIS. The view expressed has been that the closure of the Airfield is a commercial decision of BAE Systems and is most appropriately dealt with at local level. 23. It follows that if Government is not directly concerned with the closure of the airfield it remains for the Council to address the tests currently set out at Paragraph B5.2 of PPG13 in respect of General Aviation needs. This is a specialist area of analysis and Officers have sought consultant input to that review. 24. The Government Framework for UK Aviation – is due to be published in March 2012 and adopted in early 2013. Regional Policy 25. Economic and planning strategies generally seek to consolidate Bristol Airport at Lulsgate as the main airfield for the sub region and do not promote commercial aviation development at Filton. The South Gloucestershire Local Plan – Adopted January 2006 26. Policy E4 – Safeguarded Employment Areas. This policy seeks to safeguard strategic employment areas from alternatives forms of development. The whole area “comprising and adjoining the British Aerospace and Rolls Royce Establishments to the west and east of the A38 at Filton” is shown as safeguarded. This includes the eastern part of the Airfield. The effect of the policy is also to limit development where this would impact on employment activities. For example it seeks to resist development of housing where this might result in residents’ complaints about employment activities. 27. Policy E5 – Filton Airfield Safeguarding This policy seeks to safeguard the current technical operation of the airfield and carries a general presumption against further development which would prejudice this, such as those which would adversely affect the performance of navigational aids and landing systems. 28. The supporting text also notes that the Council supports the continuation of the authorised operations at the airfield and is concerned to safeguard jobs in the aerospace sector. The assumption at the time of drafting the policy was that the future success of the aerospace sector was dependent on the operation of the airfield. It would follow that if the airfield were no longer operational Policy E5 would effectively cease to apply. 29. Policy T14 – Filton Airfield This policy states criteria for the assessment of any proposals to develop Filton for passenger or air freight services. It would not apply if the airfield were to continue as existing or were to close but would apply if it were proposed to develop the airfield along commercial lines. In those circumstances the criteria require assessment of impact on residential amenity, the environment and transportation impacts. South Gloucestershire Core Strategy 30. The submission Core Strategy follows principles established in the South Gloucestershire Local Plan including the presumption from SGLP policy E5 that ‘the long-term operation of the airfield is crucial to the prosperity of the area and will be protected’. (Core Strategy Paragraph 4.13). : • Policy CS25.3 (Communities of the North Fringe of Bristol Urban Area) effectively reasserts SGLP Policy E5 in stating that “development proposals… will not prejudice the continuing authorised operations of the airfield”. • Core Strategy Policy CS12 continues the principles of safeguarding employment land and identifies sites including: 5. Employment land at Filton Northfield (part of Charlton Hayes) 6. Land East of A38 Filton Patchway (Principally Rolls Royce, former East Works and North Bristol Business Park) 7. Land west of A38 (inc Airbus South) (the main Aerospace cluster south of the Hallen Freight railway line but for practical reasons excluding areas within Bristol City Council’s administrative area (e.g Brabazon hangar). 8. Land west of the A38 (including runway and Royal Mail Depot). As with the SGLP the western end of the runway is not shown as safeguarded for employment purposes. To have included this area in calculations would have significantly distorted actual availability of employment land. 31. The assumption of an integral link between continued operation of the airfield and future success of the aerospace sector is challenged by BAE Systems Limited. Paragraph 1.33 of the Aviation Options Report states: “Filton Airfield is no longer an integral and strategic part of the success of the aerospace industry in the region. The closure of the airfield is unopposed by the aerospace industry and industry representatives have confirmed that the closure will neither impact on jobs nor prejudice the ability of the industry to attract new manufacturing , engineering research and design business to the cluster. “ 32. The potential implications of closing the airfield on the future of the aerospace sector are a central issue to be addressed in this report, and is considered further by York Aviation. 33. Officers have not identified any permission which would be required to close the Airfield. 1. Parliamentary approval is not required. 2. Planning permission is not required. 3. Civil Aviation Authority (CAA) approval is not required for closure. However York Aviation note that BAE Systems Ltd would need to liaise with the CAA given that Filton is a licensed aerodrome and that the CAA would need to issue a Notice to Airmen (NOTAM) advising pilots of closure. York Aviation also indicates that runway markings would need to be changed to indicate that the runway is not in use. 4. The Light Aircraft Association has suggested that the airfield is reserved for aviation use by a planning condition which may have been put in place because the village of Charlton was compulsorily purchased then demolished in the 1950s to extend the runway. The Officers have reviewed the planning history for the site but have found no such condition. 5. Some assertions have also been made that there is a covenant with the Ministry of Defence which requires its approval for closure. No evidence has been received from the Ministry of Defence to support this. 34. However, planning permission would be required for any material change in operation of the Airfield e.g. to function as a commercial Airport, or to redevelop the site. 35. The planning issues which would arise from any proposal to further develop the airfield for commercial use were assessed when the planning application for use as a commercial airport was made to Northavon District Council in September 1993 (P93/2321). The subsequent planning appeal was dismissed in March 1996 by the Joint Secretaries of State. 36. The Aviation Options Report (at Section 6) provides a summary of the issues raised at that time. It concludes (at paragraph 6.13 of the TOR Report) “that these decisions set a clear precedent for any future applications. Filton is not seen as a suitable location for a commercial airport and no circumstances have changed to suggest that a new application now would receive a different result”. 37. The York Aviation report considers the prospects for a commercial airfield within policy at Section 2 of the report and within practical considerations at Table 3.1. It notes the planning presumption against such development in the 2003 White Paper and concludes that the site “does not lend itself to such a scheme”. Bristol International Airport, at Lulsgate, has developed to become a significant regional airport and has further potential for growth. 38. Officers note that when last promoted in the mid 1990s there was clear opposition to the development of Filton as a commercial airport. While a number of respondents to consultation suggest ways and means of improving the viability of Filton Airfield few are suggesting development as a fully commercial airport, which is not being promoted by Save Filton Airfield Campaign Group (SFACG). However it is one of the options to be appraised as part of this review process. Transportation Issues 39. The main issue in respect of transportation is whether wings and other large components can reasonably be transported by road and sea, rather than by air, for final assembly. 40. To date it has primarily been wings that have been transported by air from Filton. Other components made, for example, by Rolls Royce and GKN, are already transported by road. This is not a unique situation. The existing Airbus operation at Broughton transports the A380 wings by road to the river Dee for onward transport by sea to France 41. Officers have worked with consultants for Airbus and with the Highways Agency to establish the scale of vehicle movements required to move wings to the Port at Avonmouth or Royal Portbury. 42. Officers are satisfied that they are able to be moved by road. 43. Both the route along the A38 to J16 of the M5 and the route along Hayes Way to J17 of the M5 are acceptable options. The preferred route would be via A38/ J16, However, if the A38/J16 route is unavailable then the Hayes Way /J17 route would be an acceptable alternative. 44. Airbus and the Council would confirm the wing transfer dates and times. The Highways Agency will be informed prior to each wing transfer to confirm that the route is clear of incidents. Engineering Issues 45. Questions have been raised about the physical space requirements and associated estimates for maintaining and improving the airfield for future operation. 46. The Aviation Options Report does not give specific estimates for future works but notes at paragraph 5.23 that “over the last decade BAE Systems has continued to invest in the airfield despite it remaining operationally unviable. The refurbishment programme to improve the airport facilities and ground equipment alone represents an investment of approximately £7million. The airfield has not been left to run down”. 47. The scale of costs required to maintain and develop the airfield would in large part depend on the model of airport to be provided. For example development for passenger services would have different requirements from a business or general aviation airport. Equally the scale of revenue generated would also be different.