Strategic Development Plan
Rawdon Parish Council appreciates the importance of Leeds Bradford Airport as a gateway to Yorkshire and as a major employer in the local community and Leeds City Region. As a representative body whose boundaries are closest to LBA, we have a vested interest in its development and the impact of its plans on the locale, both in terms of residents and on the environment. The Aviation Policy Framework states that aviation needs to grow ‘whilst respecting the environment and protecting quality of life’ and it is in this capacity that Rawdon Parish Council would seek to act as a critical friend.
The observations of Rawdon Parish Council on the SDP are:
1. The creation of the Airport Village, Air Innovation Park and Air Freight Park as a hub will have a considerable effect on the community. The decision to remove 36 hectares of land from greenbelt appears to contradict the ethos of the National Planning Policy Framework and we would seek to ensure that that decision is both justifiable and sustainable. Additional employment opportunities are welcomed, but there is some inconsistency in the perceived need; brownfield sites in North West Leeds have been granted permission for residential development on the grounds that there was insufficient employment requirement, yet the SDP will help address the identified shortfall in employment sites in North West Leeds. Rawdon Parish Council would prefer to see firmer evidence of the employment plan, the type of property provision and likely take-up of business opportunities identified for the hub. Research conducted by Rawdon Parish Council for the Neighbourhood Plan indicates that there is a shortage of availability of business units in the area but not necessarily for large-scale employers.
2. Even with the advent of low-cost airlines and many more destinations, passenger numbers have only risen from 2.4m to 3.4m from 2004 to 2015; statistics quote that 83% of that throughput is from Jet 2, Monarch and Ryanair, which are predominantly short haul leisure flights. Additional routes are unlikely to have as great an impact as the introduction of these three airlines and no indication is given as to the source and scale of the forecast for increased business travel and air freight. We would appreciate some detailed and specific information as to how passenger numbers will grow by a further 100% by 2030 as stated in the SDP.
3. Discussions with and feedback from local residents have highlighted inevitable concerns about environmental disturbance as a result of the expansion, the likelihood of increased night flying and the associated noise pollution. Direct liaison of LBA management with the community has been very limited, and this has enhanced concerns. Further information at the next consultation would be appreciated.
4. Rawdon Parish Council understands that previous plans have indicated that expansion of the airport is not reliant on improved surface access. It is not clear from the SDP what has brought about the change in requirements.
Surface Access Policy
You have identified that a multi-modal approach to surface access is required, and indeed have set out options over the short, medium and long term. This multi-modal approach is said ‘to align with the development of an integrated transport network for the City Region’. The Parish Council conducted considerable research as part of the airport link road consultation which ended in February 2016. A copy of our response to Leeds City Council is appended for your information, but one of the key statements in our response was that the Parish Council believes Leeds City Council has no coherent strategy for transport infrastructure in the City Region, and focuses on one high profile project at a time. The SAS consultation draft does refer to all forms of public and private transport access, but in both timing and degree of emphasis appears to be at odds with the airport link road consultation, which itself was flawed insofar as other modes of access were not considered. The Parish Council is aware that discussions and proposals for rail links are not as advanced as those for the road link with Leeds City Council, therefore the Parish Council are unable to see how an informed judgment of the options and priorities can be made at this stage.
The Parish Council would also wish to make the following comments:
1. The provision of enhanced public transport access has been highlighted as a priority in order to ‘reduce the private transport mode share in line with the principles of the previous SAS’ yet the usage of public transport has diminished as a result of the increase in off-site parking for which further planning permissions have been granted over and above the current capacity.
2. Paragraph 2.6 states that many of the routes that provide access to the airport are congested, particularly during peak periods. The results of the Parish Council’s surveys indicate that any congestion is not as a result of airport traffic, and none of the suggested road link options would ease those routes used by the majority of travellers to the airport (from Harrogate, North Yorkshire and the North East-almost a quarter according to the SAS, and also routes from Bradford).
3. The projections of the increase in passenger numbers to 2030 based on the DfT central case ‘demand forecasts’ indicates that passenger numbers could reach 7.1 mppa by 2030. This would not appear to take account of the individual limitations of any given airport in terms of how this growth may be achieved. Historically, Leeds Bradford Airport has had difficulty in attracting and keeping many routes which would otherwise be popular, as they have proven to be uneconomic for the airlines concerned. It is difficult to see how this may change to drive up passenger numbers. You have identified that recent increases in passenger numbers has been as a result of the advent of low-cost airlines and the growth in city breaks, but also acknowledge that this trend may not continue at the same pace over the next 5-10 years.
4. Paragraph 5.2 (Objectives) sets out a key requirement to minimise the impact on neighbouring communities. The Parish Council believes this is contradicted by the routes chosen for initial consultation on the link road, as two of the three routes are hugely invasive on local communities and green space/greenbelt and have been considered in isolation without alternative transport options. A third suggested route (Route C) is limited by existing buildings and would be detrimental to the character of one of the oldest parts of the village. Genuine consultation with local communities by the airport has been minimal in terms of contact and provision of information.
5. Paragraph 5.3 (Principles) states that any measures used to guide any investment in surface access must ‘offer good value for money and as wide and equitable distribution of benefits as possible’. No business case has been presented for any of the proposed road link options but initial indications are that they could cost up to £75m compared to the provision of a rail link at less than £20m. In the absence of business cases for both, it is impossible to form an opinion as to optimal value for money.
6. Paragraph 10.1.3 states that proposed new road and rail links are within the WY+TF approved programme for which up to £1 bn. is the responsibility of the Combined Authority. However, Andrew Hall, the transport representative from Leeds City Council, indicated at the last Airport Consultative Committee meeting that actually the rail link was outside that investment envelope and the rail link proposals are ‘less well developed’. This is relevant insofar as Government will only provide ‘an initial £180 million over six years to support the WY+TF’ (para 10.2.1) and this agreement ‘when combined with local commitments, could deliver a £1bn+ transport fund in the Leeds City Region’. The investment decisions of other stakeholders and investors will inevitably be driven by the return on that investment, and therefore will skew the decisions as to the type, scale and order in which surface access improvements are made in the absence of adequate up-front funding. Paragraph 10.2.5 confirms that private sector funding will be essential and that Leeds City Council would seek to use Community Infrastructure Levy, Section 106 agreements and section 278 agreements as appropriate. These would not be available for rail link improvements, and therefore it would appear that in order to fund any surface access improvements, a road link has to be provided which would open up development opportunities regardless of the suitability of the mode of access, value for money and the impact on greenspace and neighbouring communities. This is a serious conflict of interest which should be addressed.
7.Rawdon Parish Council welcomes the very recent addition of a Parkway Station in the SDP as the number one priority. This is something that the Parish Council has always believed to be the most effective method of improving access to the airport. The council’s preferred site for the station would be at the Bramhope tunnel.
In conclusion, Rawdon Parish Council considers that the objectives and principles set out in the initial SAS consultation draft are not being met by the current plans and transport proposals put forward by Leeds City Council. The evidence base for the scale of any improvements to surface access by the airport is inadequate, and is being driven by forecast passenger numbers which are not consistent with past trends and have no specific substance as to how they will be achieved through additional routes and airlines.