Information for planning an aerodrome

1.1 Noise arising from the use of land as an airstrip or aerodrome is not necessarily an issue in itself.  What is of greater significance is the impact that noise has upon the occupants of properties within the vicinity of a GA operation.  A study made of GA related planning applications and appeals determined over a five year period to March 1994 (Section B refers) demonstrated the importance of the noise impact issue.  In some of the 84% of applications studied, and 88% of appeals examined, noise was a key issue given great weight by officers, Members and Planning Inspectors.  Hence the need for a separate paper to examine this issue more fully.

2.1 Outdated Circular 10/73 Planning and Noise has been replaced by PPG24 Planning and Noise which was issued in September 1994, some 33 months after publication of the draft PPGXX.  Whilst attention must now focus on PPG 24 it is important that reference is also made to the historical background advice embodied in Circular 10/73 and the draft PPGXX.  Both documents were used in the context of most recent GA related appeals.  Important lessons can be learnt from these decisions.  These should not be lost, simply due to the introduction of PPG 24.

2.2 It is not the purpose of this paper to provide an in depth summary and analysis of PPG24.  Its importance in decision making in respect of noise issues is such that it should be read in its entirely.  However, for ease of reference, officers and Members are reminded that one of the key features introduced in PPG 24 is the concept of four noise exposure categories (NECs) - A, B, C, and D.  These relate to new dwellings near existing noise sources.  Category A (where noise need not be a determining factor in granting planning permission) defines a maximum daytime level 57dB (A) Leq (previously 35 NNI) in respect of air traffic.  Category D (where planning permission should normally be refused) is appropriate where day time air traffic noise is in excess of 72 dB (A) Leq 16h (previously 60NNI). This is based upon the value embodied in the well established Circular 10/73 and includes a 2dB allowance for ground reflection.

2.3 PPG 24 advises that NECs cannot be used in the reverse context for proposals which would introduce new noise sources into areas of existing residential development.  However, it clearly endorses the use of  the Leq as the means of assessing aircraft noise. In line with national and international standards.

2.4 It is important that existing operations are also protected by means of thoughtful decision making which should prevent the siting of new residential, or other noise sensitive, development in close proximity to an aerodrome boundary.  Whilst this may seem obvious, it is apparent that a number of recent decisions, which allowed in appropriate development adjacent to aerodromes, have resulted in operational constraints being imposed upon operators due to complaints from incoming residents.  Paragraphs 5 and 24 of PPG 24 make a specific reference to this issue which is also examined in Section B, Paragraph 4.2.

2.5 More generally, advice embodied in PPG1 - General Policy and Principles - sets out the presumption in favour of development unless proposals cause "demonstrable harm to interests of acknowledged importance"  (Paragraph 5). This is a critical point when assessing the impact of noise.  A presumption is often made against a proposal on noise grounds, even when sound objective evidence is produced to indicate that noise can and will be constrained to a reasonable level and there is no "demonstrable harm".

2.6 Other means of dealing with aircraft noise can be found in the Civil Aviation Act 1982, which provides for noise mitigation measures at designated aerodromes.

2.7 The manner in which aircraft may be flown is specified in S76 of the Civil Aviation Act aircraft are exempt from action in respect to trespass or nuisance, including noise nuisance as long as they comply with the provisions of any Air Navigation Order.  Rule 5 of the Rules of the Air Regulations states that with certain exemptions an aircraft should fly at below 1500 feet over heavily populated areas or closer than 500 feet to an object elsewhere, except when taking off or landing.  Should these limits be broken the pilot may be reported to the Civil Aviation Authority.

2.8 The Secretary of State has approved a Code of Practice on Noise from Model Aircraft HMSO 1982 which may prove helpful on occasion.  The Sports Council has also produced a report "providing for Air Sports" (Study 35, August 1989). Whilst not a statutory document this may prove helpful to officers in the exercise of their powers and functions under the Control of Pollution Act 1974 and the Environmental Protection Act 1990.

3.1 Whilst acknowledging that PPG 24 is now the key document in assisting officers and Members to determine planning applications where noise is an issue, other sources of information remain useful and relevant in respect of GA.  Of particular value is a study issued in 1988 by the Department of Transport entitled "A study of community disturbance caused by general and business aviation operations".

3.2 The objectives of the study were threefold:

i to improve understanding of peoples reactions to General Aviation noise, and Business Aviation noise in particular. 

ii to advise on any 'critical' ANLs, (Aircraft Noise Levels) indicating the extent to which there can be uniform application of such criteria;

iii to use the information so devised to provide the basis for development assessment, e.g. for the assistance of Inspectors at Public Inquiries.

3.3 One of the principal findings of the study was stated as follows:

"General and business aviation lies at the low end of the aircraft noise level range in the region where the correlation between noise exposure and annoyance is very low.  People who are significantly annoyed by GA noise tend to be those who also feel aversion to other aspects of local flying.  It seems probable that this small proportion of the population will resent noise from GA operations as long as they are aware of the operations."

3.4 It was found that below ANLs of about 50 dB(A)Leq, GA  noise disturbance does not vary noticeably with ANL. About 3% of the population around GA airfields claim to be highly annoyed by the aircraft operations irrespective of the level of the noise. The study concluded:

"At these lower ANLs it seems that non-acoustical factors contribute markedly to public reactions.  Thus to reduce perceived noise nuisance it is at least as important for aerodrome operators to keep the public informed about their flying and noise abatement activities as it is to pursue the latter; indeed it could be argued that it is more important."

Thus, while noise is frequently raised as an issue in planning applications relating to GA airfields, impartial social surveys are likely to show that the noise problem is overstated.

4.1 Paragraph 12 of PPG 24 sets out the requirements for and Environmental Assessment as follows;-

"If the construction or development of an aerodrome with a basic runway length of 2,100 metres or more is proposed, it will fall into Schedule 1 of the Town & Country Planning (Assessment of Environmental Effects) Regulations 1988…and Environmental Assessment (EA) will be mandatory.  If the construction of an aerodrome is proposed which does not fall within Schedule 1 of the Regulations, EA will be required if the development is likely to have significant environmental effects.  Where a major aerodrome is the subject of a proposal which will affect its capacity, there will be a need to prepare or revise forecast noise contours to estimate the resulting noise climate".

Paragraph 22 of PPG 24 is also relevant to this issue.

5.1 INTRODUCTION

5.1.1 Currently, it is too early to assess the effect that PPG 24 has on planning decisions, although some conclusion can be drawn from recent cases where the Consultation Draft of the PPG (issued early in 1992 and identified as PPG XX) has been well used.  One such case is examined below, Circular 10/73 comprised the official guidance to the planning authorities.

5.1.2 In respect of aircraft noise, Circular 10/73 was concerned primarily with the problems of noise-sensitive development in the vicinity of an aerodrome.  The noise exposure levels around the aerodrome were determined in terms of NNI (the Noise and Number Index, now replaced by Leq), and the level of aircraft noise to which the development site was, or was expected to be, exposed was compared with criteria.  In the context of the present study, the most notable criterion was hat permission for a development must not be refused on noise grounds alone where the aircraft noise exposure is between 35 and 39 NNI (approximately 55 to 57 dB(A)Leq). This criterion has remained substantially unchanged in the new PPG 24.

5.1.3 However, Circular 10/73 restricted the use of such a criterion to noise from "major and expanding airports where the pattern of air movements is, or is expected to become, predominantly regular." It continued:

"For lightly used local airports and airfields at which movements are likely to vary unpredictably (e.g. military airfields), NNI is not a suitable tool for the prediction of noise exposure on the ground.  In these circumstances the local planning authority, in consultation with the airport owner, will necessarily have to make the best commonsense judgments they can in the light of all the available evidence."

5.1.4 Since 1988 "all the available evidence" has included the 1988 DoT study (section 3.) This Study analysed the results from social surveys around five general aviation airfields in the UK and provides a valuable insight into the reaction of people to noise from their local airfield.

5.1.5 As stated in section 3, one of the declared aims of the 1988 study was to use the information gained "to provide the basis for guidelines for development assessment, e.g. for the assistance of Inspectors at Public Inquiries. "There is little evidence, however, that either Inspectors or local authority planners take proper account of the important findings of this study.  Commonly, their approach has focused on the "best common-sense judgments" phrase of Circular 10/73, spawning any one of an astonishing variety of criteria which purport to define an acceptable level of noise from a lightly used airfield.

5.1.6 There is no means of predicting the noise criterion that a planning authority or planning inspector will see fit to impose on an airfield development.  As far as the developer is concerned it is the luck of the draw, a lottery.

Some of the criteria which have been proposed in recent planning applications and appeals are examined in the following sections.

5.2 COMPARISON OF PEAK AIRCRAFT NOISE WITH BACKGROUND NOISE

5.2.1 This approach has been used in the context of several applications and appeals relating to GA.  As an example, in an appeal by the Tiger Club at Wilmington, East Sussex, the Inspector commented;-

"..I would consider that the effect of aircraft noise should be assessed on what Circular 10/73 describes as 'the best common sense judgments'. In this case I consider that such a judgment should be based on the difference between existing background levels and noise generated by the passage of individual aircraft movements." (DoE Ref: P/C1435/A/88/089120)

Evidence was given at this inquiry that at many points "the level of aircraft noise in the circuit would be more than 5 dB (A) above the background level", and that at some points "the noise of aircraft taking off would be 20dB (A) greater than the background noise level at the same place".  The inspector concluded that "the flying activities would be very audible and noticeable, especially in those areas away from the A27 where background noise levels are low".

5.2.2 It is unfortunate that the inspector did not fully define the criterion by which he reached his conclusion.  It is not clear whether his judgment centers on an excess-over-background of 5dB(A), 20dB(A), or some other figure in between. Let us assume that it is 5dB(A).

5.2.3 Consider the case of an airfield where the number of movements is such that the noise environment can be safely assessed in terms of NNI, in accordance with Circular 10/73.  If in subsequent years the number of movements should fall, there can be little doubt that, other factors being equal, this would be perceived as beneficial to the noise environment.  At some point the number of movements might fall to a level where the airfield was deemed "lightly used". This may well constitute a very considerable improvement to the local noise environment, but according to Circular 10/73 that environment can no longer be assessed in terms of NNI. Instead, "best common sense judgments" must now be applied.  If these judgments take the form that the difference between background noise levels and the noise of individual aircraft movements must not exceed 5dB(A) the airfield will be deemed unacceptable.

5.2.4 Yet this excess over background is the very factor which has not changed throughout the life of the airfield.  It was acceptable when the airfield handled a large number of movements, but it is unacceptable when the airfield handled a large number of movements, but it is acceptable when the airfield handles few movements.  The airfield is being penalised for being lightly used.  Is this common sense?

5.2.5 This is an arbitary criterion.  There is no evidence to support the assertion that annoyance is related to the level of background noise.  Indeed, the report of the 1988 study (section 3) states:

"A European study designed specifically to examine the background noise question revealed no consistent effect, even when the average levels of background noise differed by 15dB between survey areas with equal aircraft noise levels."

Thus, in spite of its appealing simplicity, an acceptance criterion based on the difference between peak noise levels and background noise fails to find support either from the extensive research into aircraft noise annoyance, or from common sense. It cannot be justified.

5.3 BRITISH STANDARD BS4142: 1990

5.3.1 The defined scope of BS4142 is given as:-

"This British Standard Describes methods for determining, at the outside of a building:

a) noise levels from factories, industrial premises or fixed installations and sources of an industrial nature in commercial premises; and

b) background noise level

This standard also describes a method for assessing whether the noise referred to in (a) is likely to give rise to complaints from people residing in the building."

5.3.2 Despite its evident inapplicably to noise produced by aircraft, this standard has been used on several occasions by authorities in the context of applications and appeals.  Its validity was challenged in an appeal by the Essex and Suffolk Gliding Club and drew the following response from the Inspector in his report:

"Also referred to in evidence were The Code of Practice for Model Aircraft which clearly had little relevance on the operation of a gliding club, and BS4142 - A Method for Rating Industrial Noise. The latter deals with noise levels from factories and industrial premises or sources of an industrial nature in commercial premises. It contains nothing to suggest that it covers noise from aircraft and you submitted evidence that its authors did not regard it as an appropriate tool for assessing the noise of aircraft in flight.  I have attached little weight to either document except as background." (DoE Ref: T/APP/C/90/A1530/6 + 7/P6 et al)

5.3.3 He was not alone in condemning the use of BS4142 to assess aircraft noise. In 1992 the Secretary of State for the Environment recommended planning permission for a new airfield for light aircraft at Egginton, Derbyshire in agreement with the findings of the Inspector.  In his report the Inspector states:

" I do not consider that the use of a 5dB(A) difference between individual aircraft  movements and known background L90 levels, the BS4142 approach, is appropriate for moving noise source and also has the effect of overestimating potential annoyance." (Do Ref:- EMP 1040/220/1Pt3)

It is clear that BS4142 is not appropriate for assessing the noise of aircraft in flight.

5.4 DORA REPORT 8203:REACTION TO AIRCRAFT NOISE NEAR GENERAL AVIATION AIRFIELDS

5.4.1 This report was issued by the Civil Aviation Authority in 1982, and presented an analysis of the results of social surveys around five GA aerodromes. Whilst recognised as a valuable piece of research the report drew criticism from a number of quarters, leading ultimately to the commission of the 1988 DoT Study (Section 3 refers).

5.4.2 One particular aspect of the report had been used by authorities out of context and needs clarification.  The DORA Report suggested that exposure to 28 aircraft events per 12 hour day, each experienced at 67dB(A) maximum, represented a realistic annoyance threshold in communities overflown on a regular basis.

5.4.3 Faced with the prospect of this 28 movements per day criterion being used in the context of a proposed development relating to Wormingford, Essex, the Essex and Suffolk Gliding Club sought guidance from the CAA who observed:-

"Detailed statistical analyses such as that given in this particular section were certainly not intended to be extracted and used as criteria for acceptable levels of noise exposure from light aircraft.  This report needs to be considered in its entirety in order to be able to devise realistic operating criteria for aerodromes, which in general we would recommend should be based on 16-hour Leq."

This advice has now been embodied in PPG 24.

5.4.4 The statistical analysis from which the 28 flights per day annoyance threshold was derived made use of the Guttman Annoyance Scale (GAS), a seven-point scale in which social survey scores were grouped in the DORA report as follows:-

GAS = 0                'No annoyance

GAS = 1 or 2          'Some annoyance'

GAS = 1 to 6          'Considerable annoyance'

The analysis showed statistically that when the daily number of aircraft events producing at least 67 dB(A) does not exceed 28, then GAS = 0 and there is no likelihood of any annoyance.  This is the annoyance threshold referred to above.

What the DORA report did not reveal however, was that the same statistical analysis also showed the lowest rating 'some annoyance', ie GAS = 1, would be achieved at about 260 flights/day.

It is of course, arguable that obtaining zero annoyance is an unrealistic target, and that the very lowest rating of 'some annoyance' should be deemed the limit of acceptability.  On the basis virtually all the small aerodromes in the UK would comply.

5.5 SURREY COUNTY COUNCIL GUIDELINES

5.5.1 These guidelines were issues in May 1991 under the title “Control of Noise Sensitive Development In Areas Affected by Overflights From General Aviation And Business Aviation”.  They were introduced in response to complaints around two specific aerodromes, Redhill and Fairoaks.  Both aerodromes handle a large number of powered aircraft movements with a heavy emphasis on pilot training in fixed-wing aircraft and helicopters.  Due to the proximity of the airfields to Heathrow and Gatwick all flights are restricted to a maximum altitude of 1000 feet.

5.5.2 The problems in Surrey were primarily associated with circuit flying.  However, the guidelines also raise the extremely significant point that at low exposure levels annoyance is not associated with the level of noise but with the actual presence of aircraft in the environment.  This important finding of DORA Report 8203 was confirmed in the subsequent 1988 Study. (Section 3 refers)

5.5.3 The preamble of the Surrey guidelines goes on to discuss the 28 flights per day annoyance threshold (which has been examined in Section 5.4), and concludes:

“Such a ‘threshold’ noise exposure equated to an Leq (12hour) = 47 dB (A); it would require doubling of similar activity ….in order to reach the 50 dB(A) Leq exposure level quoted in the table overleaf [discussed below] as the lowest air noise exposure requiring comment from a noise stand-point.  At least 1 in 30 people would report themselves ‘very much annoyed’ at an air noise expose = 47 dB Laq (A) (12 hour).  By 50 dB Leq (A) (12 hour) at least 1 in 14 people would consider themselves ‘very much annoyed’.  This rises to approximately 1 in 7 by the time exposure reaches 53 dB (A).”

5.5.4 These figures are derived from the 1988 study report and are substantially correct except that the phrase ‘at least’ (1 in 30 people, 1 in 14 people, etc) should be replaced by ‘on average’, there being a scatter in the results of around ±2 to 3%.  A notable omission from these figures, however, is that at 38 dB Leq (A) (12 Hour) the number of people reporting themselves as ‘very much annoyed’ is still on average 1 in 30.  In other words, there is no benefit in reducing aircraft noise level from 47 dB(A) to 38 dB(A) leq.  This important finding was one of the principle conclusions of the 1988 DoT Study (paragraph 3.4 refers).

5.5.5 The Surrey guidelines report that an exposure level of 50 – 52 dB(A) Leq (12 hour) “problems can occur in the vicinity of an airfield where public gardens, open spaces and recreational areas are affected by repeated overflights at around 1000 feet altitude or lower (especially in periods of good weather).”  This is in line with the results of the 1988 Study which suggests that at this level around 1 person in 12 would report themselves ‘very much annoyed’.

5.5.6 However, the Surrey guidelines fall out of line with the 1988 Study with a suggestion of stricter limits at weekends:

“Consideration might for example be given to ‘loading’ non-weekday noise exposures with positive weightings (for example +3dB (A) on Saturday after 1300, +5 dB (A) on Sundays and 5dB (A) on Bank holidays).”

Whilst the 1988 Study found that GA noise is more of a problem at weekends than on weekdays, it found little difference between the levels of aircraft noise annoyance ‘in general’ and those at weekends, suggesting that weekends determine overall reaction.  In other words, the annoyance results reported by the study already include the weekend effect.  They do not support the concept of an additional weekend weighting.

It should also be noted that Surrey’s suggested weekend weighting would lower their outdoor guideline from 50 – 52 dB (A) to as little as 45 – 47 dB (A).  Not only is this below the ‘threshold of annoyance’ defined in the preamble to the guidelines, but it is also in the region where annoyance does not vary noticeably with noise.  Thus, while having a devastating effect on the activities of a flying club, the suggested weekend weighting would not in practice reduce the level of annoyance.

5.5.7 As far as we are aware, Surrey County Council stand alone in producing detailed guidelines relating to the noise generated by GA operations from small aerodromes.  So what use are they if the application/appeal site falls outside the County of Surrey?  In one known example where the guidelines were used, that of Essex and Suffolk Gliding Club, Wormingford, the Inspector did not accept the arguments advanced on the grounds that the guidelines had no formal standing in the County of Essex.

5.5.8 Nevertheless these guidelines comprise an important element of the available noise evidence which needs to be considered in cases where PPG 24 is not wholly applicable.  They should not be dismissed out of hand.

5.6 DRAFT PPG ON PLANNING AND NOISE (PPG XX 1992)

5.6.1 The Consultation of PPG 24 was used in June 1992 in a planning application by Clacton Aero Club to increase from 4 to 12 the number of aircraft allowed to operate from the aerodrome.  In his report to the Planning Committee the District Planning Officer stated:

“In order to assess the noise impact, the results of the test measurements have been examined against criterion which establish acceptable noise limits for this type of operation.  The latest guidance is given by the Department of the Environment in the 1992 Planning and Policy Guidance document ‘Planning and Noise’.  This outlines the relevant consideration to be taken into account by the local planning authority in determining acceptable noise exposure levels.

In this respect the draft PPG identifies four noise exposure categories; A, B, C and D.  The Lowest levels of noise are in category A and for proposals in this category ‘noise need not be a determining factor in granting planning permission’.  Noise in categories B and C requires increasing levels of restriction by the planning authorities, whilst [for] noise in category D planning permission should normally be refused.  The draft PPG defined category A for air traffic as being less than 57 dB(A) L (16-hour) measured over the period of 0700 to 2300 hours.”

Noise from the airfield was shown to be below 57 dB(A) L (16-hour) at all nearby residences, and planning permission was granted.

6.1 Objections to airfield developments tend to be similar in most cases.  They include such factors as visual intrusion, loss of privacy, increased road traffic and concern over safety (Section B refers).  The most powerful weapon in the objectors’ armoury is recognised to be noise, and it is not surprising, therefore, that noise issues are promoted so strongly by the opposition.  Thus, the noise is always claimed to be “excessive”, “intrusive”, “unacceptable”, “out of keeping with the quiet environment”, etc.  Yet such claims are rarely substantiated.  Can it be that if enough people say the noise will be unacceptable, then it must be true?

In the context of an appeal by Essex and Suffolk Gliding Club, Wormingford, the Inspector commented:-

“….I recognise that those who feel strongly about an issue might exaggerate or minimise problems, and that sometimes objectors are more likely to express their views than supporters….  Even so, it is unlikely that such a degree of commitment in opposition would have arisen unless noise was a real and substantial source of concern”. (DOE Ref: T/APP/C/90/A1530/6 + 7/P6 et al)

6.2 It is easy to assume that the views of the objectors are the views of the majority.  In the above instance the residents’ association formed to fight the proposal mounted a determined campaign in the parishes around the airfield, recruiting some 200 to 300 people to their cause.  Although apparently a sizeable number, this in fact represented only about 2% of the adult population, a figure which agrees remarkably closely with the findings of the 1988 DoT Study in terms of the population of people reporting themselves ‘very much annoyed’.

6.3 Nothing is known about the views of the remaining 98% of the population.  Judging by the results of the 1988 study, however, we may infer that some 64% of them consider that on balance the airfield is good for the community.

6.4 This issue was examined in the context of an appeal by Glyndwr Soaring Club.  Here, the Inspector adopted a different approach in respect of the noise issue and local residents’ concerns:-

“Whilst I must give due weight to the impact of noise on those living close to the airfield, I must also consider the advice in Planning Policy Guidance Note No 1 that the purpose of the planning system is to regulate the development of land in the public interest and not protect the private interests of one person against the activities of another.  Although the residential amenity of individual households can be a matter of public concern, I would draw a distinction between amenities, such as freedom from excessive noise or disturbance, which may affect the reasonable enjoyment of property rights, as such, and which ought, in the public interest, to be protected and the natural wish of neighbours for ambient background noise levels to remain unchanged which I consider to be an unreasonable expectation.” (Welsh Office Ref: P14/397)

6.5 In the majority of cases, an articulate minority will make their views widely known.  Whilst recognising that some residents will have reasonable cause for concern it is helpful to recall that studies have found only some 3% of the population around small aerodromes claim to be highly annoyed by aircraft operations, and as such annoyance is unlikely to be related to the level of noise.

7.1 In planning law there is a presumption in favour of a proposed development unless it can be shown that the proposals would cause demonstrable harm in the interests of acknowledged importance (PPG 1).  Yet this principle is not always applied to developments involving small aerodromes.  Here there is frequently a presumption against the proposals on the grounds of noise, even where sound objective evidence exists that the noise will be constrained to a reasonable level.

7.2 The evidence of many planning application and appeal decisions to date suggests that officers, Members and Planning Inspectors frequently lack a clear understanding of aircraft noise.  Methods used to assess aircraft noise are often inappropriate and sometimes seriously flawed.  This paper has drawn attention to some of the methods which have been used.

7.3 Social surveys conducted by the Department of Transport in the vicinity of GA airfields indicated that a small proportion (about 3%) of the local population claim to be highly annoyed by the aircraft operations irrespective of the level of noise.  The DoT concluded that these people would probably resent noise from GA operations as long as they were aware of the operations.  In practice this tiny sector of the community is seen to exert a disproportionate influence on planning authorities.

7.4 Noise from GA operations can, and should, be controlled by operational procedures in order to avoid the need for expensive noise monitoring.  These procedures might include restrictions on the number of movements, times of movements, types of aircraft etc.  However, it is stressed that such operational procedures need to be deduced in the first instance from a proper objective noise assessment.  The guiding principle is that controls should not be imposed arbitrarily but only as far as is necessary to achieve a reasonable level of noise.

The General Aviation Awareness Council has produced a leaflet ‘Fly Considerably’, which gives advice on operating procedures for aircraft owners and pilots.

7.5 PPG 24 has set clear guidelines for the assessment of noise in respect of new developments near to existing airfields.  It has established the use of the L as the means of measuring and assign noise form aircraft in these circumstances and while the PPG does not specifically address the case of a new airfield near existing dwellings it is reasonable to deduce that the use of the L is equally applicable in these cases, in line with national and international standards.

7.6 Armed with an appropriate range of tools, coupled with a solid foundation of relevant case law, officers and Members will be better equipped to handle the noise issues surrounding GA related proposals.  The time spent producing soundly based evidence will be amply rewarded with the longer term savings not only in time but also in costs.  This must surely be beneficial to all parties.

PLEASE NOTE

Report Section B: Planning