Farnborough Airport: ERM 'independent' report on TAG risk contours

RBC [Rushmoor Borough Council] has given an undertaking in respect of a consent order in the High Court [Parkins v Rushmoor] to discontinue legal proceedings that independent advice would be taken on the details submitted by TAG for the purposes of Conditions 16 and 17. -- Richard Short, Rushmoor planning official

The risk modelling is only intended to calculate the average individual risk at an airport and its environs for a given mix of traffic. It takes no account of the population on the ground. -- NATS

... it is important to be clear that our recent work for the DETR does not aim to provide a detailed risk assessment of operations at the aerodrome [it] is intended simply to provide advice to the DETR to assist in determining whether Farnborough should have a PSZ. -- Penny Foot, NATS

... the size and shape of Public Safety Zones are determined by individual risk contour modelling work undertaken by the Department's consultants, NATS. The NATS model seeks to take account of the annual probability of a crash occurring at a given airport, the distribution of such crashes, and their consequences. The specific factors for each airport which are used in the calculations are ... the landing thresholds and forecast of the number and type of aircraft expected to use the airport in the year 2015. No account is taken in calculating the size and shape of the Zones of other local factors such as the distribution of the population around an airport and the local topography. -- Phil Cotterell, Aviation Policy Division, DETR

Public Safety Zone Policy is intended to control developments close to existing airports, and not specifically to address the circumstances which arise when a new airport, or significant development at an existing airport, is proposed. -- Phil Cotterell, Aviation Policy Division, DETR

The Department does not dissent from the figure of a 25% risk of a crash outside the airport boundaries during a 10 year period, assuming 28,000 business jet movements per year. -- Paul Cox, Aviation Policy Division, DETR

... the Secretary of State regards the 1 in 10,000 risk contour as being an intolerable level of risk ... This figure is consistent with the Health and Safety Executive's upper limit to the tolerable risk to third parties from hazardous industry. -- Paul Cox, Aviation Policy Division, DETR

The upper limit to tolerable risk to people living, working or congregating near airports is set at an individual risk of death of 1 in 10,000 per year. This is the same as the widely accepted upper limit to the tolerable risk to third parties from hazardous industry adopted by the Health and Safety Executive. -- Phil Cotterell, Aviation Policy Division, DETR

If you ask the wrong questions you get the wrong answers. Garbage in gives garbage out.

Two years ago, against strong local opposition, TAG Aviation were granted outline planning permission for a business airport at Farnborough. Recently TAG have applied to discharge two conditions of the outline planning consent (conditions 16 & 17 relate to 1:10,000 & 1:100,000 annual individual risk contours).

As the result of a successful court case (Parkins v Rushmoor), Rushmoor have been obliged to seek 'independent' advice on TAG's submission on conditions 16 & 17. ERM have been engaged to scrutinise the TAG application.

ERM were asked to look at two different models, and compare and contrast. This has not been done. The NLR model, developed for use in the Netherlands, is dismissed out of hand. The only justification for this is the false assumption that aircraft at Farnborough keep to the centre line of the runway. They do not.

ERM do not include helicopter movements, take no account of the topography, take no account of the steep approach angle. ERM assume 300 MoD movements. Farnborough Airshow alone accounts for 3,000 movements. Were Northolt to close (likely), all MoD movements would relocate to Farnborough.

All ERM have done is attempt to replicate the annual individual risk contours produced by TAG, using their version of one model (NATS), alternative models are not used.

No account is taken of fuel on board, no account is taken of injuries. Whilst ERM are correct in ignoring these in an attempt to replicate the work of TAG, these are real factors that pose real risks to those who live near the airport. Thus should have been looked into by a Council that was concerned with the well being of the local community.

It is not clear what crash rates ERM have used, other than supplied by NATS. Are these based on published crashes (only recorded where there is a fatality or write-off of the aircraft) or do they include all crashes?

ERM use crash rates for executive aircraft. Does this mean a class of aircraft used as executive aircraft (which also could be used for other purposes) or does it mean a subset of a class of aircraft when only used for business purposes?. There is a big difference between the two. ERM have done nothing to check the validity of these figures. ERM have simply taken what has been given to them by NATS (who in turn were provided with the data by TAG).

ERM make the bold statement that the use of business aviation crash rates may overestimate the crash rate for Farnborough. On what basis do they make this claim in the absence of sufficient statistical data? Did they visit Farnborough? Are they aware of the cavalier operation? Wednesday 29 October 2002, aircraft were using Farnborough during very poor visibility. It was not possible to see the aircraft from the ground. Was the malfunctioning ILS in operation on that day, or were the pilots on visual? Were ERM aware of during the short period of operation by TAG, one crash at Farnborough, an aircraft on takeoff had to make an immediate emergency landing due to fumes in the cockpit, a flight from Farnborough crashed in France, the number of aborted landings etc? Not a good track record upon which to base the claim by ERM.

No examination is made of the assumptions behind the predictions of the mix of aircraft by TAG. What is the sensitivity of this mix?

ERM accept the TAG assertion (TAG provide no evidence) that the TAG risk contours may overestimate the risk on the dubious grounds that 'there is no evidence to dispute this'. Did ERM look? ERM have failed to take account of factors which would increase the size of the risk contours, appear to have taken no account of the current operation.

ERM were asked to examine the validity of the models used by TAG. All they have done is take the equations used by NATS, inputted the data supplied by TAG, and not surprisingly come up with similar results. The surprise would be if it came out otherwise.

Or to quote ERM: 'As expected (because both methods [ie TAG and ERM] are based on the NATS model), the risk zones are of similar size.'

This is not an exercise in checking the validity of either the NATS model or the validity of the data. It is an exercise in bullshitting, wrapped up in integral equations and probability density functions. If nothing else an exercise in futility as we have learnt nothing of the validity of the data or the model.

If I were to process flawed data with a flawed model, then repeat the exercise, I would be very surprised if I got a dissimilar result the second time around.

ERM have relied on Richard Short as the source of data. Well known as a leading authority in the field (for those slow on the uptake that was an exercise in sarcasm as a point of light relief).

What ERM should have done, is independently check the validity of the model (ie construct their own models, or run an alternative model) and independently check the validity of the input data (eg are TAG's assumption on aircraft mix reasonable).

ERM put forward a perverse argument that the model used by TAG must be okay because it was developed by NATS, ie the NATS model is okay because NATS developed it. And furthermore 'Based on this [argument], it would be difficult to justify a case for using an alternative method'.

All ERM have effectively done is check that the given data has been correctly fed into the model. No checks have been carried out on the validity of the input data (eg is the crash rate appropriate) and no checks on the validity of the model.

ERM have looked at the 1:10,000 risk contour extending into the boundary of the Swan Hotel, but no account is taken of the contour extending westwards over the canal towpath, Basingstoke Canal, Fleet to Aldershot Road and into the heathland.

The ends of the risk contours are fuzzy. Thus the question as it relates to the Swan Hotel cannot be answered with any degree of certainty. The obvious fact that in extending into the grounds of the Swan Hotel the 1:10,000 risk contour passes over Slough Estates has been conveniently ignored.

The recommendation from HSE is that third parties, who derive no benefit from a hazardous operation, should not be subjected to a 1:10,000 risk, ie the risk should not extend outside the boundary of the hazardous operation, ie the 1:10,000 risk should be retained within the airfield boundary.

I have not attempted to examine the mathematical models used by ERM. This I have left to others who are as capable of if not more capable of doing so than myself.

As part of the tendering process ERM were required to demonstrate their expertise in this area. No mention in their report. They were also required to demonstrate their 'independence'. No connection with TAG is a necessary but not sufficient condition. The same applies to NATS and the UK government. To the list could be added SBAC and BAE Systems as both have been major backers of TAG and will be beneficiaries of a successful application.

To say the NATS model is okay because other people say it is, is not good enough. If ERM have expertise in this field they should have been capable of a critical appraisal of the NATS model.

A minimum of three consultants were asked to tender. Who were the other two, on what criteria were ERM chosen?

In his brief to the consultants as part of the tendering process Richard Short prejudices both the independence of the consultants advice and the planning process itself with the statement: 'Flying pursuant to the permission is expected to commence in January 2003'. Does Short know something we don't? Has Short given similar assurances (guarantees) to TAG Aviation? In the same brief, Short states: 'Planning permission was granted'. TAG have not been granted full planning permission, they have been granted outline permission only. [Richard Short 02 September 2002 consultants-brief-cond16-17]

It is easy to see why the local community has no confidence in the competence or impartiality of the planning department and is calling for an independent inquiry.

Attempts have been made to clarify some of these points with ERM. This has not proved possible as ERM have been gagged by Rushmoor officials and instructed not to talk to third parties (pers comms with Dan Quinn and ERM technical director Paul Davies). This is clearly not satisfactory in an open and informed debate. Planning officials need reminding that they work on behalf of the local community, not developers.

Whilst some criticisms are levelled at ERM (and they may not be at fault if misled by Rushmoor) the main criticism has to be levelled at Rushmoor planning department, in particular planning official Richard Short who commissioned the ERM report.

Reports last year by ex-CAA inspectors, who were asked to look at CAA safety (ie safety of the planes in the air), were misused. Councillors were misled into believing they were being presented with a study of ground safety, furthermore they were told the TAG operation met strict CAA safety requirements. The inspectors said, strict CAA requirements were not met (councillors saw a cleansed report, draft reports highlighted there were more problems), the inspectors stressed they had not been asked to look at ground safety, and furthermore were not qualified to do so had they been asked.

To prevent the ERM report being misused, the authors should be invited to give a presentation to councillors and public and be open to expert cross examination (ie by the public). The draft report submitted by ERM should be placed in the public domain, together with all communications (incl e-mails and notes of telephone calls and meetings). The gag on ERM should be removed.

Why were ERM asked to submit a draft report one week before their final report? How 'independent' is a report if the officials have had the opportunity to comment upon and request revisions? Were ERM given sufficient time for their study?

Various assumptions, flaws etc to one side, all the ERM study attempts to do is replicate the TAG risk contours, nothing more. No account is taken of ground safety. ERM were not asked to address ground safety, ERM were not even asked whether or not the 1:100,000 contour, by enclosing more people than at any other UK airport, posed an unacceptable risk to the people of Farnborough.

The inputs to the derivation of the contours are: number of movements, aircraft weight, crash rate, crash consequence area and the physical location of the runway. No input of the number of people on the ground.

The only purpose of the risk contours is to draw a Public Safety Zone (loosely based on the 1:100,000 annual individual risk contour). A PSZ is a future planning tool, to restrict development in a zone deemed unsafe. The development that already lies within any future PSZ is non-permitted development, ie if it did not exist it could not be built as the area is not safe.

Determination of a PSZ does not address the planning application from TAG.

Were Farnborough open desert or lower Manhattan, the risk contours would be the same! That is NO ACCOUNT IS TAKEN OF THE POPULATION ON THE GROUND.

NATS and DfT (Department for Transport) have both advised Rushmoor officials that risk contours do not take account of the population on the ground, do not address ground safety, that their only use is for the derivation of a PSZ. Why therefore are Rushmoor officials deliberately misleading councillors that a study of ground safety is taking place? Why have they repeatedly deceived councillors that all previous studies of risk contours (most of which were flawed hence the need for several studies) were studies of ground safety? NATS became so concerned at the misuse of their work that they issued a statement that risk contours were for the purposes of deriving a PSZ and took no account of the population on the ground.

DfT have advised Rushmoor officials that a study of ground safety is necessary as part of the process of discharging the TAG planning application. A study that, contrary to misleading statements by planning officials, has so far not taken place.

Such a study has to take in expert opinion (why is local expert opinion, incl this author, being ignored?), has to be given significant weight, has to be sufficiently robust to withstand scrutiny.

Why, have Rushmoor officials failed to take the opportunity to engage ERM to conduct such a study? Why is the ERM study (flaws and assumptions to one side) being passed off as a study of ground safety, when it clearly is not?

ERM were told that the independent study was the requisite of a court case (true). Why therefore was I told by planning official Daryl Phillips that it was nothing to do with a court case and Rushmoor were free to do as they liked? A statement that has probably placed Rushmoor in contempt of court. Or why did Richard Short (the same Richard Short who in the tendering process stated was a requisite of a court case) tell the Environment Panel (15 October 2002) that 'There have also been representations on submissions on planning conditions including an unsuccessful High Court challenge'? (emphasis mine)

I am still waiting for the instructions to ERM to enable an assessment to be made as to whether the Consent Order has in fact been complied with. Numerous requests have been made, but I am still waiting. Not a single request should have been necessary. This is information that should have been automatically supplied, together with a copy of the ERM report (which I have yet to be formally supplied with a copy).

The level of deception by Rushmoor officials includes: misleading letter sent to only a handful of people, a letter that does not correctly specify the risk (and a failure to correct when this error has been highlighted), failure to state conditions 16 & 17, failure to include a map of the risk contours.

Bogus claims to myself (by various planning officials up to and including Keith Holland head of planning): we do not have to notify anyone (we do so out of the goodness of our hearts), TAG do not have to make a formal application to discharge conditions 16 & 17, we have notified everyone within the risk contours and a widespread area outside. I was not formally notified because it was claimed I lived a long way away! I have found people within the risk contours not notified, I have yet to find anyone outside (even those whose property borders the contours) who have been notified.

Curiously, ERM do not state conditions 16 & 17 (which is what their report is supposed to be addressing) nor do they state the definition of the risk (so we can see they have a modicum of understanding of what they are addressing). For completeness I include these below (using the correct definition of risk, not the misleading definition used by Rushmoor).

Condx 16: No flying pursuant to this permission shall commence until it has first been demonstrated and agreed in writing with the Council that the 1 in 10,000 per annum risk contour at either end of Runway 07/25 does not extend to areas where people live, work or congregate or beyond the area at the eastern end of the runway where Policy FA1 of the Rushmoor Local Plan (1996-2011) Review applies. Thereafter, no flying pursuant to this permission which results in the 1 in 10,000 per annum risk contour at either end of Runway 07/25 extending to areas where people live, work or congregate or beyond the area at the eastern end of the runway where Policy FA1 of the Rushmoor Local Plan (1996-2011) Review applies shall take place.

Condx 17: No flying pursuant to this permission shall commence until the extent of the 1:100,000 per annum risk contour has been first agreed in writing with the Council. Thereafter all flying pursuant to this permission shall conform to the agreed 1:100,000 per annum risk contour and the maximum extent of the 1:100,000 risk contour shall not be changed without the prior approval of the Council in writing.

A 1:100,000 per annum individual risk means that at the point of exposure 24 hours a day, 365 days a year there would be for any one individual a probability of 1:100,000 that they would be killed in any one year.

The risk contours are drawn by joining together points of equal risk. Moving inside the risk contour increases the risk of being killed, moving outside decreases the risk of being killed.

Several important points can be drawn from these two conditions and the correct definition of annual individual risk.

No flying should take place until such times as the two conditions have been agreed. Flying is currently taking place, such flying is unlawful (Rushmoor has received legal opinion to that effect), enforcement action should be taken.

The conditions refer to annual risk not annual individual risk. Although for consistency with the TAG/ERM reports I have assumed they are the same, they are not. Annual individual risk refers to the risk of any one individual being killed, annual risk is to anyone being killed (or for that matter any group of people being killed). I explore this important distinction in my comments on TAG's submission. It follows that neither ERM nor TAG have addressed either condition 16 or condition 17 as TAG and ERM rather crudely attempt to address annual individual risk, whereas conditions 16 & 17 refer to annual risk, unspecified.

The statement by planning official Daryl Phillips 'Conditions 16 and 17 are quite specific and deal solely with the issue of annual individual risk' (emphasis mine) is simply not true.

Apart from any legal and moral obligation to the local community, apart from the strong and clear advice given by DfT, the Council, in their evidence to the High Court in London (Parkins v Rushmoor), stated that although no ground safety study had yet been carried out (which will be news to most councillors who have been repeatedly assured that several such studies have already been carried out), a ground safety study would be carried out when TAG submitted their proposals for discharge of conditions 16 and 17 of the outline planning consent for a business airport at Farnborough.

Failure to conduct a ground safety study, failure to give significant weight to the risk to those living within the environs of the airport, will be treated as a serious breach of the Human Rights Act. No doubt the High Court in London will treat equally seriously the deliberate deception that was perpetrated in the evidence presented to the Court to contest the case.

In conclusion, Rushmoor has still to carry out an independent assessment of ground safety that takes account of the safety of those living on the ground. A requirement that has been spelled out by DfT. But even on the basis of the ERM/TAG submissions, conditions 16 & 17 have to be REJECTED as more people are enclosed by the 1:100,000 risk contour (ie more people at risk of being killed) than at any other UK airport.

A more generalised conclusion that can be drawn is that the planning department has to be subjected to an independent investigation by the Audit Commission. What is highlighted here is not an isolated example or an anomaly. It is the norm. Which is why 520 people on one planning application alone (Manor Park, Aldershot) signed a petition that they had no confidence in the planning department and are now, like myself, calling for an independent investigation by the Audit Commission, and may, following the successful example set by myself, be seeking legal redress.

Planning documents

This document



Phil Cotterell, Public Safety Zone Policy and Farnborough Aerodrome, 1 February 2002 {letter from DETR (now DfT) to local resident}

Phil Cotterell, Public Safety Zone Policy and Farnborough Aerodrome, 28 May 2002 {letter from DETR (now DfT) to local resident}

Paul Cox, Business Aviation at Farnborough Aerodrome, 11 April 2001 {letter from DETR (now DfT) to local resident}

Paul Davies and Dan Quinn, Farnborough Aerodrome: Provision of Independent Advice Regarding Agreement of 1 in 10,000 and 1 in 100,000 per Annum Risk Contours, ERM, October 2002

Penny Foot, Farnborough Aerodrome, 16 July 1998 {letter from NATS to local resident}

Keith Parkins, TAG Aviation outline planning conditions 16 and 17, October 2002

Keith Parkins, various e-mails to Rushmoor chief executive Andrew Lloyd re airfield and related matters, September and October 2002

Daryl Phillips, Farnborough Aerodrome - Conditions 16 & 17, 27 September 2002 {letter from Rushmoor planning department to Keith Parkins}

Dan Quinn and Paul Davies, pers comms, afternoon Friday 1 November 2002

Richard Short, Farnborough Aerodrome: Provision of Independent Advice Regarding Agreement of 1 in 10,000 and 1 in 100,000 per Annum Risk Contours, 2 September 2002

This report is to be placed in full before the planning committee. Failure to do so will be treated as a serious breach of the Human Rights Act.
Surrey-Hants ~ Farnborough ~ Farnborough Airfield ~ Inspector's report ~ Rushmoor modifications to Local Plan ~ TAG planning application ~ TAG risk contours ~ ERM supplementary report
(c) Keith Parkins 2002 -- December 2002 rev 3