Weston – Changes Sought in Development Plan

I have sought a number of changes in relation to Weston Aerodrome in the Kildare County Development Plan. A summary of these can be seen below, followed by my submssion. Once adopted the County Development Plan forms the basis for deciding on future planning applications, changes to the draft plan were invited up to 28th June.

 

The draft plan on display, as it relates to Weston and Aviation generally, seems to be written from an Aviation perspective, however, those living in close proximity to an Airport or Aerodrome also require careful consideration. The purpose of my submission is to address this aspect

 

 




The Changes Sought Include

 

Weston Aerodrome – Draft Kildare Development Plan

 

• The length of runway; Weston currently has permission for an 800m runway, this should be stated in the plan. Currently Weston advertises a runway length of 924m.
• A definition for the use of the Stopway/Clearway, which is located in Kildare and runs to more than 400m, should be provided for in the plan. Currently it is used as an extension of the runway but has no permission to do so.
• A baseline for the number of aircraft movements should be stated in the plan, any intensification including the use of larger aircraft must require planning permission.
• The protection of residential amenity and the issue of noise pollution should be addressed as part of the County Development Plan.
• Safeguarding maps should be provided as part of the County Plan, these maps define the area surrounding the Aerodrome where other developments are not permitted.
• In line with changes to the South Dublin Plan, CODE 1A should be specified as the CODE in the Kildare plan, this means the runway length should not exceed 800m and the wingspan of the aircraft allowed should not exceed 15m.

 




Chapter 6.11

 

The size and capacity of the Aerodrome is determined by the Reference Codes as such any future planning applications will be determined against this.

 




Reference Codes – Annex 14

For Obstacle Limitation purposes Code1, Code 2, Code 3 or Code 4 refer broadly to the length(s) of runway(s) at an airport or aerodrome.
(“Aerodrome” and “airport” have the same meaning in the above context).

 

In line with the recent decision by South Dublin Council to define Weston as Code 1A in its development plan. Kildare County Council should reflect this in the Co Kildare Development Plan.

 

 

From Annex 14 this is defined as meaning:

• Aerodrome reference field length: less than 800m
• Wing span of aircraft to use the aerodrome: Up to but not including 15m
• Outer main gear wheel span: Up to but not including 4.5m

 




South Dublin Council Motion 243 May 4, 2010

Schedule 5 – Weston Aerodrome, Lucan: It is the policy of this Council to revert the runway classification of Weston aerodrome to Code 1A. Reason: Condition 2 of the Third Schedule of An Bord Pleanala Decision of December 2003 (PL 131149) states that any material change in the type or capacity of the existing aircraft using the aerodrome shall be subject to a separate planning application.




 

Safety

 

Most Weston planning applications, to both South Dublin and Kildare County Council, have stressed that the changes sought are for safety reasons. Ironically, the flight paths and indeed the flying heights are often not adhered to. Planning applications were made, for example, for runway shoulders and a stopway/clearway, both were granted despite the fact that they were not safety requirements.

 

Annex 14

 

Runway shoulders are not required for the types of aerodromes of CODE 1A, 2A or 2B
Runway end safety areas (RESA) not required for the types of aerodromes of CODE 1A, 2A or 2B.

 

Weston advertises on their website that they have a runway of 924m, which they fully use; there is no evidence that they have permission of anything beyond 800m. One of the primary concerns of many local residents is that instead of a proper evaluation of the overall operation, we are seeing a piecemeal approach with the Aerodrome developing into an Airport by stealth.




 

An Observation Received By An Bord Pleanala Submitted By Buchanan’s on Behalf of Combined Action on Weston (08/2018) Stated:

 

The Bord Pleanala decision of 8th December 2003 PL O6S 131149 states that Weston would require to apply for planning permission should there be an intensification of use within the Aerodrome or in respect of the use of larger aircraft….

 

The length of the runway should be stated in the Development Plan in order that that decision is respected and there is no doubt what they have permission for.

 

4.1.31 Genuine anxiety is observable locally regarding the safety of the local community
with the growing use of the Aerodrome and the increase in business and corporate flying. On 27th January 2005, the Irish Examiner reported a total of 13 accidents involving aircraft at Weston Aerodrome that had been notified to the safely authorities since 2000. Including five separate accidents in 2004……….

 




Draft Development Plan 6.6.4.1

 

It is the policy of the Council:
WA1: to prevent encroachment of development around Weston Aerodrome which may interfere with its safe operation

 

(what exactly does that mean and does it work in reverse in relation to those who live and do business in close proximity. For example there is a bloodstock industry at the end of the stopway which is not compatible with low flying aircraft. Homes bordering the stopway clearway are subject to noise associated with a runway despite the fact that they are located beside a clearway, yet there seems to be no way of properly enforcing the intended use of the clearway.




 

Stopway Clearway

 

The Kildare County Development Plan should specify the role of the stopway and clearway. There should be no doubt about its intended use particularly given that there is no runway located in Kildare.

 

Annex 14 states
….A Clearway in this case would be considered as commencing at the end of the runway and which will provide an area over which an aircraft can transit in safely from Lift-off to a prescribed height……

 

An Bord Pleanala Ref PL 09.218796 which was granted with 4 conditions. (1) The stopway/clearway shall not be used for the take-off of aircraft. Reason: In the interest of clarity and the protection of the amenities of the area. (2) Within one month of the date of this order, the applicant shall submit plans for the written agreement of the planning authority indicating the extent of the clearway and hard shoulder, with the hard shoulder clearly delineated with white line markings of appropriate width in accordance with the standard requirements of the Irish Aviation Authority Reason: In the interest of clarity.

 

While the stopway clearway was granted permission by Kildare County Council on safety grounds, the permission was for just that and not a runway extension. The second condition to the best of my knowledge has not been complied with, a UD file was opened on it earlier this year.

 

 

The following has been taken from the observation made by Arthur Cox & Company on behalf of Tony Doyle in response to 08/2018 (PL09.235146)

 

6.1 We note that the Applicant has never been granted permission for the construction of a runway by Kildare County Council. The applicant did receive planning permission (98/876) (457m long by 23m wide) paved stopway/clearway and a small infill paved area 50.9m long by 23m wide to the existing runway with associated drainage and fencing. This permission was made subject to a number of conditions…..

 

On the 5th August 1998, the Irish Aviation Authority wrote to the County Secretary, they stated “With regard to the “notes” submitted by the applicant, I wish to advise that the Irish Aviation Authority has never stated that the “safety measure of most immediate concern” is the provision of a maneuvering area known as a stopway/clearway. Also, the Authority will not be “imposing” safety regulation which require the provision of a stopway or clearway.” Just as interestingly they also state in the same letter “It should be noted that the ICAO publication entitled “Aerodrome Design Manual Part 1 – Runways” (Doc. 9157) notes that stopways may frequently be an economical first stage in the extension of an existing runway. The manual also notes that the establishment of a stopway is operationally equivalent for the aeroplane to a lengthening of the runway.”

 

 

The following has been taken from the observation made by Arthur Cox & Company on behalf of Tony Doyle in response to 08/2018 (PL09.235146)

 

4.11C (i) failure to observe the existing planning permission (we note applicant was issued with warning letter by KCC (UD2823) on 16 May 2005 for the unauthorised use of the stopway/clearway for the takeoff and landing of planes, contrary to condition No2. of Permission 98/876 which provides that.

 

“This permission is solely for the provision of a paved stopway/clearway and paved area, to the existing runway with associated works and shall not be construed as giving assent to the extension of the runway as such, nor to increase the size or capacity of such aircraft over that already using existing aerodrome, as indicated in submitted documentation.”




Safeguarding Maps

It is essential that the safeguarding maps are made available in the context of the County Development Plan.

 

The following has been taken from the observation made by Arthur Cox & Company on behalf of Tony Doyle in response to 08/2018 (PL09.235146)

 

8.3 a letter addressed to Mr. T Skehan of KCC of 22 October 2004 contained in Appendix 3 to the Appeal was stated to enclose a safeguarding map for Code 3 airport and to supersede a letter of 25/8/03

8.4 We note the aerodrome has never been a Code 3 facility and does not have planning permission to operate as such.

 

 

In a letter to Kildare County Council 29th April 2005 the Department of Defense dealt with the issue of code 2 safeguarding and referred to the runway/stopway as follows:

 

“aeroplane reference field lengths” are made up of the Take-off run Available (TORA) which is the paved runway, the Take-off Distance Available (TODA) which may include a clearway, the Accelerate Stop Distance Available (ASDA). The implication of this on Weston is that the field length of an 850m long runway plus 450m stopway plus any clearway they may declare, makes the runway “code 3” allowing operations of larger aircraft. However, safeguarding is only for “code 2 runway. Later in the same letter the Department states “It is the contention of this Department that from a safety and operational perspective any development at Weston would require a reorientation of the runway to take traffic away from Baldonnell rather than the current extension to the existing runway which would have the effect of bringing large high powered executive jets into Baldonnell airspace and directly across its flight paths.”

 

Given that the owners of Weston advertise a runway length beyond what they have planning permission for, every effort should be made to make it abundantly clear what CODE they operate to. The Safeguarding Maps assist this process.




 

Aircraft Movements – Baseline

 

It is very important that the baseline is set at the time the development plan is adopted. The following statement in the plan needs to be amended to reflect this.

 

GA 5 To seek information (including aircraft movement logs) detailing (a) the number of aircraft movements and (b) the type and capacity of aircraft using an aerodrome, in order to allow a full assessment of any significant impact that may arise in relation to a new aerodrome or to an increase or change of use of an existing aerodrome in the interests of public safety.

 

The following has been taken from the observation made by Arthur Cox & Company on behalf of Tony Doyle in response to 08/2018 (PL09.235146)

 

Regrettably, no meaningful detail has been provided on the lawful baseline, existing activity and the proposed activity contemplated should permission be granted.

 

 

The Board refused permission in respect of the SDCC Application on 23rd September 2009 (Reference Number: PL06S 232683) for the following reasons:

 

…..that the full nature and extent of the changes in the noise environment, or the extent of the areas and populations which would be impacted on by any such changes, including implication for public safety, have been satisfactorily identified and quantified….

 

….(EIS) has identified the baseline air traffic types and volumes permitted or those types and volumes using the aerodrome in recent years, nor identified any changes that would be facilitated by the proposed development. In addition, it is considered that the EIS has significantly failed to identify the impacts of the proposed development resulting from the changes proposed to Runway 25…..

 

7.2 the aerodrome is reportedly licensed by the IAA for 147,000 movements per annum, with no distinction by reference to aircraft type. The applicant has indicated to our client that they currently hold a licence for four jet movements per hour.

 

 

The following has been taken from the observation made by Arthur Cox & Company on behalf of Tony Doyle in response to 08/2018 (PL09.235146)

 

6.7 We note that the confusion surrounding the length of the runway is mirrored in the information provided by the Applicant concerning other regulatory requirements. …

 

An observation received by An Bord Pleanala submitted by Buchanan’s on behalf of Combined Action on Weston (08/2018) stated:

 

4.1.32 The future safety of the local population, especially those living within the vicinity of the aerodrome must be considered as a priority. The lack of controls over use and number of movements is causing significant concern to the local residents who fear that their residential amenity is being jeopardised.




 

Airport in County Kildare

 

 

It is an objective of the Council

 

AO 1: To investigate the feasibility of providing an airport in the County, having regard to Government policy relating to the development of an additional airport in the Region. This needs to be balanced by specifying what would be needed to support such a development.

 

The above statement should be accompanied with some assurances such as the adequacy of public transport services, an adequate road system leading to such a facility, the CODE to which such a facility will operate to, the extent of the flight movements, assurances in relation to noise pollution, protection of residential amenity etc etc.

 

 

Residential Amenity

The plan is silent on residential amenity, this requires amendment.

 

 

An observation received by An Bord Pleanala submitted by Buchanan’s on behalf of Combined Action on Weston (08/2018) stated:

 

Protection of amenities including not only protecting the safe operation of the Aerodrome in terms of Training and General Navigation, but also includes protection of the environment and residential amenity. It is not in the interests of residential amenity that intensification of use in Weston Aerodrome occur as this is likely to have grave results for the residents nearby. Balance must be maintained between the permitted existing established uses in the interests of proper planning and sustainable development and indeed in the interests of safety within the wider area.




 

Noise

The issue of noise is not confined to the immediate vicinity of the Aerodrome, standards need to be set as to acceptable noise limits. There is for example no requirement to fit noise controls on many small aircraft these often fly low over housing estates on the flight path particularly when approaching for landing.

 

 

An observation received by An Bord Pleanala submitted by Buchanan’s on behalf of Combined Action on Weston (08/2018) stated:

4.1.11 Noise is a major and growing form of pollution and can interfere with communication, increase stress and annoyance, contribute to ill health, cause anger at the intrusion of privacy, and disturb sleep, leading to lack of concentration, irritability, and reduced efficiency. It is therefore clear that noise impacts are detrimental to achieving residential amenity. The potential increase in noise is of foremost concern to the local residents…..

 

4.1.12 it is further submitted that in order to seek to safeguard both the aerodrome use
and the community, environmental limits should be defined and enforced for the aerodrome in respect of noise, air quality, land take and safety. These limits should not be exceeded and would help to offer longer-term safeguards to local communities who currently fear that the growth in aviation is exempt from many controls despite the fact that it can cause major social and environmental concerns.




 

General Amendments

 

GA 6: To restrict the development of buildings, overhead lines or structures in the inner approach areas of aerodromes.

 

This needs to be mapped otherwise it is meaningless to the vast majority of people.

 

GA 7; To consider, in conjunction with relevant agencies and bodies the introduction of Public Safety Zones in the vicinity of aerodromes within or affecting Kildare.

 

What are Public Safety Zones what are their implications?

 

6.6.4Location and Description
Weston Aerodrome is located partly in County Kildare and partly in South Dublin County, to the south of Leixlip and between Celbridge and Lucan near the border with Fingal. I presume that should read South Dublin and not Fingal.

 




Language

The words “have regard to” really have very little meaning and should be strengthened to read comply with in the following two paragraphs.

 

WA2

To have regard to the advice of the statutory bodies responsible for he control and safety of operations at Weston Aerodrome, in the context of the proper planning and sustainable development of the area and the protection of amenities.

 

WA2 and WA 4 are duplicates.

 

GA4 to have regard to the International Standards and Recommended Practices as contained in Annex 14 to the Convention of International Civil Aviation published by the International Civil Aviation Organisation