Land at Jelbert Way, : Proposed Heliport (PA16/09346) Response to Third Party Comments – 27 th June 2018

Introduction

This document responds in turn to comments on the above application made by a number of third parties relating to heliport operations and claims relating to the associated health effects.

Heliport Operations

It has been claimed by a number of parties that the heliport will result in a 40% increase in flights and a corresponding 40% net increase in noise nuisance, compared to the BIH operations.

We clarify the position as follows, which supersedes the information contained in WYG’s email of 13 th June 2018.

Former Heliport (BIH) – Operated 69 hours per week with 276 Aircraft Movements

We have reviewed the former BIH operating schedules, which are still available on its website and hardcopies dating from 1964 - 2011. The former heliport was not subject to planning controls on its operations or flight numbers. However, generally it operated as follows, subject to extended hours to cover disruption:

Monday to Saturday:

Operating Hours: 7.30 am – 7.00 pm

Flight numbers: At peak, 276 movements per 6-day week or 23 return flights per day

Sundays : Closed

Proposed Heliport – Proposed to operate 75 hours per week with 220 Aircraft Movements

Monday to Saturday

Operating Hours: 7.30 am – 7.00 pm (69 hours)

Flight numbers: Maximum of 34 movements or 17 return flights per day

Sundays

Operating Hours: 11.00 am – 4.00 pm (5 hours)

Flight numbers: Maximum of 16 movements or 8 return flights

Compared to the BIH operation, this represents a 7.25% increase in operating hours as a result of proposed Sunday flying and a 20.29% decrease in aircraft movements.

It is noteworthy that the proposed heliport is likely to be subject to a series of operating restrictions imposed by planning condition on any planning permission:

• Restriction on operating hours between Monday to Saturday of 7.30 am – 7.00 pm • A maximum of 34 aircraft movements each day Monday to Saturday • Restriction on operating hours between 11.00am and 4.00pm on Sundays • A maximum of 16 aircraft movements on Sundays • A maximum of 204 aircraft movements Monday to Saturday

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• There will be an allowance for additional movements to the above by the emergency services or public service helicopters or in the event of adverse weather or for safety reasons.

The proposed heliport will not operate at night.

On Sunday’s it will operate for 5 hours during times when the nearby Sainsbury’s supermarket, Heliport Retail Park and other nearby retail/quasi-retail facilities will be trading.

Furthermore, the maximum of 17 return flights per day Monday to Saturday is only envisaged to be achieved during peak summer season.

The scheme also includes built-in mitigation with a lowered landing pad, acoustic buffering due to building location and an improved Cornish hedgebank on the site’s north west boundary.

Health Effects

This section contains a review of academic research reports referred to by 3 rd parties and an analysis of the health benefits of the proposed heliport.

Reports referred to by 3 rd Parties

3rd parties have referred to the potential for adverse health effects arising from aircraft noise, as identified in the following reports:

1. Living with aircraft noise: Airport proximity, aviation noise and subjective wellbeing in (Ricky N. Lawton, Daniel Fujiwara, 2015)

2. Aircraft noise and health effects: Recent findings (CAP 1278, Civil Aviation Authority, 2016)

3. Quality of Life Assessment (Airport Commission July 2015 1)

4. Research into the Improvement of Management of Helicopter Noise (University of Salford Report NANR 235, 2008)

We comment on these assessments in general terms as non-medical professionals below:

In general terms, the research documents referred to above are principally relate to the development of major international and regional European airports - major expansion at London Gatwick and London Heathrow are referred to extensively. These airports operate much more intensively over much longer hours than the proposed heliport would (including at night) with different aircraft and as a result generate very different environmental effects. Studies associated with these locations cannot be used as an analogue for the proposed heliport and it is misleading to claim adverse health effects will arise from the proposed heliport.

They do not consider the effects of rotary-wing aircraft in detail (similar to the observations within the University of Salford study – see below).

The CAA review of studies undertaken since 2009 notes that the evidence is emerging and continues to mature. As a result, it is our view that there are no clear conclusions on which to base policy or planning decisions. The CAA review also notes a series of shortcomings with the methodology adopted by some research, following independent review, such as Hansell et al (2013) and HYENA. Despite this, the HYENA study concluded that there is no statistical association between day-time aircraft noise and indices of stroke/heart disease.

1 NB at the time of writing, the report was not available on the Council website and a report of this title dated 2014 could not be located

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Many of the studies refer to the effects of night time noise. In fact, Lawton and Fujiwara found no association between night time noise levels at or above 50dB and wellbeing. While other studies made different conclusions, these are not material in this case because Penzance Heliport would not operate at night.

Significantly, Lawton and Fujiwara “… find no association between living near an airport and SWB measures. This suggests that it is not the presence of an airport per se that affects wellbeing .” It then notes that one reason for this may be “… that the positive aspects of living near airports, such as improved transport infrastructure and access to jobs, are offset by the negative effects .”

Lawton and Fujiwara also concluded that: “ The negative effects of unemployment, poor health and smoking on SWB were at least twice as large as those from aviation noise. Policy decisions that use SWB data should consider the relative merits of interventions designed to improve the environmental and socioeconomic drivers of wellbeing (Layard, 2009) .”

Consistent with Lawton and Fujiwara, there are a number of factors that affect issues such as wellbeing and cognitive development. However, it should be noted that within the WYG assessment, Gulval School has been considered and predicted aircraft noise levels are at least 10 dB below 55 dB (the day-time level referred to by the World Health Organisation/WHO and the level at which the presence of aircraft noise is taken to begin by Lawton and Fujiwara), even when considered over a worst case one-hour period. If noise levels were to be assessed over a 16-hour daytime period (as is considered within the studies referred to above), the overall noise levels at properties would be lower than the worst-case one-hour period that has been considered within the submitted noise assessment because as noted above, the heliport will operate for a maximum period of 11.50 hours, Monday to Saturday, with maximum in peak summer months only.

The University of Salford report at 4 above, though a useful reference, should be read in the appropriate context. The assertion that helicopters are regarded as 15 dB(A) more annoying refers to two social studies conducted by the CAA in 1982 and 1992 which found that “helicopters in the London area were up to 15 dB(A) more annoying at the 10% and 20% Very Much Annoyed Level than fixed wing aircraft.” Furthermore, the Salford University report compares this with results from helicopters operating in Aberdeen that demonstrate similar levels of annoyance associated with fixed- wing and rotary-wing aircraft which “indicates a strong non-acoustic factor in the community annoyance rating” and is attributable to the wider community benefits, as well as factors such as fear of crashes, reactions to leisure uses, community/airfield relations.

Crucially, however, and as noted by Lawton and Fujiwara, the benefits of either living near an airport (or in this case, the benefits of the service itself) are material and must therefore be considered in the planning balance. These benefits are addressed below.

Health Benefits of the Proposed Penzance Heliport

The potential for health benefits to Island communities is significant. In this context, it is material that the application proposal is supported by:

• NHS Kernow • Medical Centre • Helston Medical Practice • SW Ambulance Trust • Cornwall Air Ambulance. • Council of the Isles of Scilly.

The basis for this support can be summarised below:

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Statistically the Isles of Scilly are aging faster than the England average. This makes access to health services increasingly important. As a population ages its health needs generally increase, while mobility often decreases.

The Council of the Isles of Scilly states that the Islands, as a ward, are in the bottom 2% of wards for access to services. This is largely due to access to secondary and tertiary health care and specialist services such as mental health and substance abuse clinics.

Islanders currently have a Medical Centre, a minor injuries small hospital and the ambulance service and associated personnel. These deal with as many cases as possible, but inevitably specialist consultants have to come to Scilly or Islanders need to attend medical appointments on the mainland.

The 2017 Isles of Scilly Healthwatch Community Survey stated that:

Issues that arise currently with off-Island medical appointments are:

• Appointments early or late necessitating over-night stays, especially on Monday’s, when Land’s End Airport is closed on Sunday’s and the Scillonian ferry service is not operating or in the event of bad weather • Lack of capacity, especially in the summer • Disruption to flights – an hours’ delay can mean a missed appointment • Consultants and specialists unable to attend clinics on St Mary’s and the associated cost to patients and the NHS • To ensure patients attend they will often book in advance and stay over in Cornwall at additional cost • Samples taken on Scilly such as blood often travel to the mainland for testing – this is often time sensitive.

The Penzance helicopter service will address a number of these issues. While the NHS currently subsidises fixed wing flights for its patients, the applicant’s intention is to tender for this opportunity, noting that the former BIH service operated subsidised routes for NHS patients and as such there would be an expectation that the subsidies would be extended to the proposed service.

Arriving in Penzance without the need to travel from Land’s End makes it easier to get to or from early and late appointments at West Cornwall, Hayle or Treliske, especially as few Islanders have access to a car and rely on the train or buses. This will relieve stress but more importantly allow patients to attend medical appointments in a single day, without the additional expense of extra night’s accommodation in Cornwall.

The Penzance helicopter service will provide extra capacity enabling flights to be booked at short notice, so vital appointments are not delayed.

An associated but well-rehearsed point is that a Heliport at sea level in Penzance will be far more weather resilient than Land’s End, both for patients and health care professionals.

As well as the economic cost, it is important to note the impact travel delays can have on patients at what is already a stressful time. Isles of Scilly Healthwatch, in evidence to the Transport Select Committee in Parliament, stated in 2014 that current provision for essential travel is not adequate, on the following grounds:

• Islanders often cannot undertake necessary medical travel without additional cost, both in time and monetary expense

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• These factors, together with the difficulties and stress of the journey, have led to some patients cancelling or delaying their treatment

• Travel related disruption to accessing mainland health provision has led to delays in diagnosis and treatment.

The Isles of Scilly Healthwatch reports spanning the years from 2013 to the present day confirm that:

• 20% of all respondents were unable to attend medical appointments due to flight delay or cancelation on the day

• 50% of all respondents experienced delay on the outward leg and 40% on the return leg.

In the Winter Transport Survey of 2016, 1 in 5 respondents had missed appointments due to disruption at Land’s End. On the Cornwall Council planning website there are numerous letters of support from Doctor’s, many of them mentioning health issues related to missed appointments and the costs to the NHS of missed appointments and consultants clearing diaries to come to Scilly and not being able to travel due to weather disruption.

A selection of (but by no means all ) health care professionals’ comments sourced from the Council’s website is reproduced in Annex 1 to this document.

Conclusion

Flight Operations

Third party claims that the heliport represents a 40% increase in operations and noise compared to the BIH operation are factually incorrect. The actual position compared to BIH is:

• 7.6% increase in operating hours, solely as a result of proposed Sunday operating hours

• 20.3% decrease in aircraft movements.

Academic Research Papers

The academic research papers referred to by 3 rd parties indicate an emerging understanding of health and wellbeing effects relating to major international airports. This body of evidence is at best inconclusive about these effects and one of the papers concludes that no association was found with health effects arising from day-time aircraft noise, even for a large international airport. From a lay analysis of the papers, it would appear that there is no scientific evidence on which to base a claim relating to adverse effects on health and well-being associated with the proposed heliport.

While it may be appropriate to have regard to these and potentially other papers, the Council as decision maker will determine whether they represent a material consideration in determining the planning application and if so, the weight to be attached to them. On this matter, the applicant considers the papers to be of peripheral materiality only and that as such only very limited weight should be attached to them in this case. This is particularly in view of the scale and nature of the application proposal and its operating regime, which would have materially different effects to say those of an expanded London Gatwick or Heathrow.

In any event, the effect on amenity arising from the proposed heliport in noise, vibration and air quality terms has been robustly assessed by the applicant.

Health Benefits of the Proposed Heliport

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Evidence is submitted of the potential health benefits arising from a more weather-resilient heliport at sea level close to Penzance. This evidence is corroborated by submissions from numerous medical professionals and Islanders, whose comments can be viewed on the planning portal. Some of these are reproduced at Annex1 to this statement.

A094051-4/SC/27.06.18

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ANNEX 1

Representations in respect of PA16/09346 by Health Care professionals

Alison Butterill, Managing Partner – Helston Medical Centre:

“As a practice there have been a number of occasions when weather conditions make it unsuitable to fly and this often results in clinicians being on the wrong side of the water or indeed delaying their return to the islands. This not only impacts on clinician’s availability on the islands but impacts on when people are prepared to work and cover the islands. Access to transport during difficult weather conditions will enhance who we can send over and how quickly they can return. The provision of supplies and/or transportation of samples to the hospital have also been an issue and a more sustainable system would be wholeheartedly welcomed.”

Paula Martin, Chief Executive, Cornwall Air Ambulance:

“Every litre of fuel carried affects mission range. We did in the past refuel the air ambulance using both Penzance heliport and RNAS Culdrose, and neither facility is available to us today. Having a refuelling facility in West Cornwall – and a potential pre-surveyed landing point for patient transfers – would be extremely valuable.

While the air ambulance has managed to meet the needs of all of our patients since the closure of the previous heliport in Penzance, it would be in the best interests of patients in the future that we maximise the opportunities to provide the very best service in West Cornwall.”

Dr Mary Lowth - Comment submitted on 16th January 2018

I strongly support the application for the Penzance heliport. The helicopter is needed on Scilly. Arguments for it include: - improved access for those with poor mobility. It is needed for people travelling to and fro for doctor's appointments and chemotherapy on the mainland (you will be aware of the limited medical facilities on Scilly, both diagnostic and therapeutic. Article 14 of the Human Rights Act (1998) upholds the principle of equality. Here there is an issue of equality of choose where we go, a freedom contained in Article 8. - there is also an obligation under the UN Convention on the Rights of Persons with Disabilities Article 9 Section 1a, which states: "1. To enable persons with disabilities to live independently and participate fully in all aspects of life, States Parties shall take appropriate measures to ensure to persons with disabilities access, on an equal basis with others, to the physical environment, to transportation, to information and communications, including information and communications technologies and systems, and to other facilities and services open or provided to the public, both in urban and in rural areas. These measures.... shall include the identification and elimination of obstacles and barriers to accessibility The heliport is also needed - for people who live on Scilly but have commitments on the mainland and need more reliable transport options, particularly in the winter. - for people with homes on Scilly who can't get maintenance people over to do safe electrical and plumbing work in the winter. - so that those visiting as tourists, supporting the islands' main industry, don't get stranded and are not therefore put off from visiting. The loss of the helicopter has been heavily felt. Some people with mobility problems can no longer visit because the small planes and the Scillonian are impossibly for them. The Scillies economy will benefit from the helicopter. Like any remote island economy, it needs a range of means of transport on and off to put it on a more equal basis with people living on the

7 mainland. The helicopter will be a more expensive but more reliable option for those people whose trip is important enough that they would rather pay the extra than travel much earlier than they wanted to - or not get back to Scilly at all between appointments. The helicopter was a huge asset to Scilly. There seems to be overwhelming support for it on the islands. The Steamship company have opposed it for commercial reasons, and people understand their wish to protect their investment but the reasons for having the heliport, and therefore the helicopter, are far more significant for the island community than narrow commercial interests. The helicopter offers an additional service which the planes and boat cannot offer, and one that is needed for human, not commercial reasons.

Dr R Hessing- comment submitted 2nd November 2016

I have been a G.P. On the Islands of Scilly for 20 years. The loss of the helicopter service for patients, path. samples, medical specialists, x-ray, Outpatients etc has had a very negative impact on our services on the islands due the erratic weather conditions and subsequent disruption to and fro Lands End. It has also had a negative impact on the economy and tourism vital to these Islands. A resumption of helicopter services would be highly supportive and welcomed on these Islands and would also contribute to the economy of Penzance and the surrounding areas of mainland Cornwall.

Mr Christopher H Mills: comment submitted 2nd November 2016

The reinstatement of a helicopter service is essential for the Islands. From a medical point of view the number of missed appointments due to adverse weather at mainland hospitals has a very significant effect on the health of islanders. It even quite often prevents consultant visits to St Mary's Hospital out patients. This has a significant effect on the NHS as it can be cost effective for a consultant outpatient clinic on St Mary's. On a personal basis I have twice this year had to spend an extra night when attending South West Ambulance Trust meetings adding to NHS costs, and once had to cancel my attendance. On the three pleasure trips not one has been completed as planned. The poor weather at Landsend is the main factor. A helicopter from sea level in Penzance is not so affected and the visibility limits are smaller with rotary aircraft, nor is wind a significant limiting factor. For all islanders another way of getting to the mainland is essential in spite of the Isles of Scilly Steamship Company trying their best .

Mr Peter McLelland QCBA - comment submitted 12 th February 2018

Between 2007 and 2013 I was the Chief Pilot for the "Cornwall air ambulance" and can speak with total conviction in supporting the arguments given in the application for a new Heliport to be located as proposed.

In my time flying the Cornwall air ambulance I have on numerous occasions flown to the Scilly Isles in poor weather; this weather has precluded any flying from Lands end airport, due to its geographical position and height above sea level the airport is under constant threat from our predominant South westerly weather systems. One only needs to look at how disruptive the operations from the airport have been during the past winter to realize that a more reliable service is desperately needed.

In brief, the majority of weather that we experience in the South West comes from the Tropics. This air mass is known as the 'Tropical Maritime' (this is fact), as the name suggests it brings with it warm temperatures and moist air which presents itself as low cloud, fog, drizzle and rain. In the winter we are subjected to more of these weather systems than in the summer, albeit in the summer we can have weeks of low cloud, drizzle and rain. In my experience this is usually the July/August months which coincides with thousands of tourists in the county.

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The geographical position of Lands end airport is unfortunate in that it will always suffer the full force of these weather systems, furthermore, the commercial regulation's specify that aircraft can only take off and land when a minimum cloud base exists

The difference in the height above sea level between the suggested Penzance Heliport and Lands end airport would on numerous poor weather days allow commercial flying operations from Penzance Heliport, but not from Lands end; thus providing a more reliable service for people trying to get to the islands with the added economic effect on the local area.

To ask for a Helicopter service from Lands end airport would be crazy when a more suitable site exists at Penzance. It would be utterly pointless and present no solution to the current problem.

We really need a Helicopter service to the islands, as previously mentioned July and August can be very poor weather months, this is really the time when people need options, to have one option in flying to the islands is ridiculous.

What better way of promoting not only the Islands but Cornwall as a whole; having a helicopter service will also prevent the current operator monopolizing the system and promoting healthy competition, which again benefits everyone.

If we are to move forward and be part of a successful 21st Century then anything that promotes Cornwall and Tourism should be given the highest priority and assistance in making it happen. Penzance Heliport should be given full support; to reject this application would serve no benefit whatsoever.

Ms Louise Gough - comment submitted 15th February 2018

I am emailing to reiterate my support for a helicopter service flying from Penzance to the Isles of Scilly. Having travelled to work on the islands since 1989 initially with BIH and subsequently using Skybus it is clear that they primary difference in reliability is due to geographical placement. A Penzance based service is still needed. In the last 12 months 12 out of 24 intended clinics had to be cancelled and rescheduled due to weather. High winds, cross winds and low visibilty occur far more frequently at Land's End than in Penzance. The links to onward travel is clearly far better from Penzance. The islanders often have additional costs involved in any trip to the mainland as they often have to pay for accommodation as they are "stuck" due to fog. I believe it was the hard work of the Jet boats that returned people to their families intake for Christmas last year as flights were cancelled. Please pass this planning application for the benefit of the people in the Islands and Penwith as well as supporting healthy business competition.

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