Aviation and Air Safety
In the meantime, we continue with our “bite-size” Fact Sheets in which we share with you the main areas of our Objection. This newsletter focuses upon aviation and air safety.
This is an area of great concern, which we believe has been treated by the developer F9E and its energy company partner EDF with insufficient attention. Little progress that has been made by F9E/EDF on this subject in the last 12 months despite the valid concerns raised over a year ago by SDLT, Cranfield Aerodrome, British Gliding Association (BGA), Aircraft Owners and Pilots association (AOPA) and local residents with local knowledge/experience of flying in the locality.
In addition the Council has recently received a very strongly worded objection from the General Aviation Awareness Council (GAAC). GAAC are the most representative UK body in General Aviation and recognised by Government, the Civil Aviation Authority (CAA) and others to be the organisation that speaks for General Aviation on planning and environmental issues. This most recent objection is an encouraging development that adds further weight to our own aviation concerns.
We believe that the 4 turbines will create a serious hazard to aviation. It is important to understand this is not a generic objection to 4 large wind turbines but one based on the local geography and local air traffic management. This is a function of the adjacent controlled air space for Luton and Heathrow and the broad range of light aircraft, helicopters, micro lights, air balloons etc that are funnelled into a discrete and congested amount of uncontrolled airspace between Leighton Buzzard and Milton Keynes. We also consider there to be a specific air safety concern with respect to Cranfield aerodrome, relating to the fact the Dorcas Lane site is directly in line of sight of Cranfield’s threshold and under their newly approved non-precision instrument approach procedures. This in itself compounds the choke point problem for other air traffic in uncontrolled airspace which relies on visual flight, in an area which is also shared with a controlled instrument approach which does not.
Planning guidance clearly states that “It is the responsibility of developers to address any potential impacts, taking account of Civil Aviation Authority, Ministry of Defence and Department for Transport guidance in relation to radar and aviation, and the legislative requirements on separation distances, before planning applications are submitted.”. The evidence we have indicates this has not been done.
More recently F9E/EDF have gathered together from the AVDC website the letters from SDLT, BGA, AOPA and various local residents and then submitted a document entitled ‘Review of the Aviation Issues report No 11/466/F9/29 by Spaven Consulting’. Our very real concern with this report is that rather than a review of the issues, it is simply a documented rebuttal to the concerns raised but without any further consultation or any attempt to visit or understand the local issues. SDLT sent a further submission into the AVDC website - this appears to have been completely ignored by F9E/EDF and in their most recent submission in December 2012 they concluded that they had dealt with all outstanding air safety issues.
Our outstanding concerns
1. It would appear F9E/EDF has not entered into any consultation with relevant parties nationally or locally on the matter of air safety since 2009. This includes Cranfield even though they have officially objected to the Dorcas Lane application. The CAA on being consulted by AVDC on this application have on two occasions stressed that local aerodromes should be consulted. Holmbeck is the closest airfield to the proposal at less than 4 statute miles away and yet has not been consulted.
2. The issues that have been raised are local in nature but neither F9E/EDF or their consultant have visited to discuss the objections and yet they consider them resolved by reference to theoretical rather than practical / site specific solutions.
3. This is a matter of importance, not least, because unlike many of the other still valid reasons for objecting to the turbines, this is dealing literally with matters of life and death. There has already been one incident on the 22nd August 2012 where a glider landing was involved in a near miss with the met mast on the site. In addition military helicopters are often seen flying low in this area.
Unless F9E/EDF carry out their moral let alone their statutory responsibility to consult as per the CAA’s recommendation with local aerodromes then it is impossible for them to disprove or mitigate the objections that exist and therefore we believe that the application must be refused. Regrettably the current situation is no different to the situation 12 months ago and yet to date F9E/EDF have shown no desire to treat this topic with the seriousness it deserves.
SDLT has directly requested the AVDC Councillors who are responsible for deciding on the applications to familiarise themselves with the complex aviation and air safety issues arising at Dorcas Lane and insist F9E/EDF carry out broader consultation and the location specific consideration required to fully address all potential aviation impacts. We have also urged them to listen to the evidence and objections already submitted by many interested and knowledgeable parties including, but not limited to, Cranfield and Holmbeck Airports and to hear the genuine concerns of informed local people that turbines at this congested site will compromise air safety and lives on the ground. Last but not least, we have clearly highlighted the fact that they need to take advice and consult with organisations such as AOPA and GAAC to verify our concerns, these being the largest aviation organisations next to the CAA, who are currently struggling with the deluge of wind turbine applications.