Many thanks to my fellow Green councillors (especially Martin Love and Andy Cooper) and other activists on whom I have based my comments!
I hope as many people as possible support this critical campaign!
I am writing to object in my capacity as an elected member of Bradford Council, representing the Shipley ward.
1) The Climate Emergency.
LBIA wants to increase passenger numbers from 4 million per year now to 7.1 million by 2030 – a near doubling of passengers if we take into account the increase in passenger numbers in recent years.
This will generate a huge increase in greenhouse gas emissions at a time when we should be drastically reducing them. The UK is legally bound by the Paris agreement, which mandates limiting the global temperature rise to well below 2C. The UK’s Climate Change Act mandates net zero emissions by 2050. Doubling emissions at LBA is clearly a breach of these legal requirements.
Leeds City Council declared a Climate Emergency in March 2019 and committed to achieving a carbon neutral city around 2030. The Leeds Climate Commission (a partnership of LCC, University of Leeds, local businesses, the local public sector and the third sector) has forecast that airport expansion would mean emissions from the airport become higher than emissions from the whole of the rest of Leeds by 2026. Expansion would render the target of 2030 impossible to meet, and LCC have admitted that 'continued growth in aviation nationally is incompatible with the climate emergency'. There is little point in committing to a carbon neutral target and then allowing an airport expansion that makes target impossible to meet.
Planning applications are guided by the National Planning Policy Framework (NPPF). Paragraph 7 of the NPPF states that 'the purpose of the planning system is to contribute to the achievement of sustainable development. At a very high level, the objective of sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs'. Clearly this expansion does not meet the objectives set by the NPPF. Councils at Stansted and Bristol have been guided by this and turned down similar expansions.
The proposed expansion flies in the face of recommendations from the committee that advises the government on climate change. In September 2019, the UK Committee on Climate Change stated that we must limit aviation passenger growth to a maximum of 25% from 2018 to 2050. It said: "In the absence of a true zero-carbon plane, demand cannot continue to grow unfettered over the long-term. Our scenario reflects a 25% growth in demand by 2050 compared to 2018 levels." LBIA wants an increase of 72% in just 10 years, way beyond the recommended level.
The airport's owners talk a lot about how 'green' the proposed new terminal will be. They don't mention that the old building will still be used. And they don't mention that emissions would more or less DOUBLE from all the extra flights. The chair of Leeds Climate Commission has said the reduced emissions from the new terminal are like 'grains of sand' compared to the increased emissions from extra flights.
Claims of mitigating the climate impact are false. LBA likes to rely on claims relating to improved performance of aircraft and reductions in fuel consumption. These are marginal technological improvements that only apply to new aircraft. LBIA have no control over the age, maintenance regime or replacement schedule of the aircraft that use its facilities, whether based there or not.
2) Noise pollution
Aircraft noise is a serious problem. The World Health Organisation is recommending far lower thresholds for the avoidance of adverse health impacts from aircraft noise. Safeguarding the health of the community must be a priority consideration – more flights mean more noise. This increase will impact residents of areas other than Leeds, including those of the ward I represent in Bradford which is under the flight path of many flights.
LBIA can fly 24/7 but there are restrictions between the hours of 2300 - 0700. An important part of the application is a shrinking of this restricted time to 2330 - 0600. This means that peak activity at the airport will start at 6am (that is 'officially' - in reality flights are likely to ramp earlier, as happens now).
At night, the area surrounding the airport where people will experience LOAEL (the lowest noise dose at which there is an observed adverse effect) will increase after development by 8.6km2, to 56.2km2. This means that 123,000 people will fall into this category, and due to the increased incidence of noise the number of people being Highly Sleep Disturbed will be 42,000 and the number of people being Highly Annoyed will be 93,500. Many of these are people whom I represent on Bradford Council.
The airport's own application Noise and Vibration section admits that "... This confirms that that whilst the changes are forecast to be 'negligible' or 'low', the Development will result in an adverse effect on health due to increased noise."
3) Air pollution
Ultrafine particles (known as PM2.5) come from jet engines and are now one of the major health concerns relating to airport expansion. New research shows that they can have serious adverse health impacts even at levels well below current World Health Organisation guideline limits. They are produced not only at aircraft take-off and landing but have also been found up to 14 miles from an airport. The new research confirms previously known associations between PM2.5 and respiratory and cardiovascular disease. Safeguarding the health of the community must be a priority - double the flights means double the air pollution.
4) Traffic impacts
Doubling passenger numbers will greatly increase road congestion on routes to and from the airport. Moreover, the traffic will start to build up even earlier than at present thanks to the unrestricted flights starting at 0600 and more flights at night.
5) The adverse economic impacts
The economic benefits of airport expansion are routinely overstated. Generally, airports like LBIA, which are based on low-cost airlines, do not make a sustainable contribution to the local economy. They are geared towards outbound leisure travel and therefore take money out of the country. Worldwide, airports are shedding jobs to give way to automation leaving low skilled, typically zero-hour, retail and catering work. Profits from LBIA go to AMP, the Australian investment company that owns the airport. The health of the people in this region and the wellbeing of the planet are far more important than the claimed economic benefits and the profits of AMP.
Once we get over the Covid crisis, how do we rebuild the economy and deal with the climate emergency? We currently have a historic opportunity to address these questions together – investing in low carbon transport and infrastructure would reinvigorate the economy and address the climate emergency. We cannot afford to invest in dirty, polluting industries such as this.
LBIA makes big claims about how expansion would help the local economy and create jobs, but their case is out of date. LBIA's economic impact report is based on assumptions that pre-date the COVID crisis (see paragraph 1.5). Everyone knows that the pandemic has changed all previous economic forecasts. In particular, aviation industry experts forecast that demand for air travel will remain low for some years (a welcome development from an environmental perspective). Any assessment of the application based on out of date assumptions would clearly be invalid. LBIA should be required to produce a new economic assessment before the planning application is even considered.
Most passengers don't benefit the local economy - 93% of LBIA's passengers use the airport for leisure. LBIA's own report says "these passengers do not generate significant wider economic impact (and are in fact sometimes viewed as a negative in terms of economic impact)". 71.5% of all passengers take holidays abroad. How does spending money abroad help the economy in Leeds? LBIA itself says that only 7% of passengers create a significant, positive, local economic impact. Even using LBIA's out of date, pre-COVID figures, they only expect 340 full time jobs to be created in the whole region (well beyond Leeds) by 2024 and only 2,310 by 2030 (these forecasts are now, of course, invalid).
Do these paltry economic returns compensate for worsening the climate emergency and undermining the health of local communities? I think not.
Cllr Kevin Warnes (Green, Shipley)