Exactly How Big a Problem are Seaplanes ?
Let us put seaplane operations in some kind of context. Seaplanes are an endangered species. In the whole of the UK there are no more than 10 airworthy seaplanes. This, out of a total of some 10,000 registered aircraft. In Scotland there are 5 resident seaplanes (3 professionally operated and 2 privately operated). Of the three professional seaplane operations in Scotland, one has operated on Loch Earn (within the National Park and prior to the National Parks creation) for the last 15 years, teaching seaplane pilots (including many airline pilots and RAF pilots) from all over the world - while another has operated on Loch Lomond on a charter basis since early 2004. Together, all the seaplanes in the UK generated less than 400 landings on Loch Lomond in 2004. That is an average of less than 2 per day over a year. Most of this activity only takes place in the summer months (April-Sept), when the loch is already busy. There are probably 6 months throughout the rest of the year when wind and weather prevents flying from taking place altogether, so a ‘busy’ day might only involve up to 6 landings. Each landing/takeoff runs about 200-400m and takes about 25-35 seconds. Landing/takeoff activity for the entire year is probably the equivalent of one motorboat on the water for about 4 hours.
By comparison, there were 5403 registered motorboats, jetskis and watercraft registered and operated on Loch Lomond in 2003. Remember too that all those with outboard motors and diesel boats are polluting the water with a diesel/water/exhaust mix.
The National Park is also crossed by several major trunk roads, including the western shore A82 and A83 (main roads from Glasgow to Oban and Fort William) and main access to Europe’s largest nuclear weapon store at Gareloch, (which is encircled by the National Park and lies less than 10 miles from the west shore of the loch!!). This certainly makes LLNP unique amongst NPs in the world and does rather put the whole issue into perspective ! The A811 (Balloch-Stirling) and the A85 Stirling-Glencoe road also lie within the Park. Taken together it is estimated that there are well in excess of 10 million vehicle movements within the National Park each year.
The National Park also lies close to several major airports, air routes and upper air routes carrying passengers to and from Edinburgh, Glasgow, Inverness, the Western Isles, Europe and North American destinations. During the course of a busy day there may be several hundred aircraft movements flying over the National Park area. In addition, there are many more flights for Mountain Rescue (approx 300 per year in Scotland to rescue walkers and climbers), helicopters on charter to the National Park, or transporting golfers to and from Cameron House. Other flights for forestry, filming, police, medical, recreational, training and military flights all pass through the Park on a daily basis. None of this is subject to Byelaw or restriction. There were over 1 million flights in Scotland’s airspace in 2003.
A National Park that is there for everyone to enjoy in a safe and responsible manner has been hijacked by a small number of very vocal objectors who have the ear of the press. It would appear they want to keep the Loch for themselves and will not be happy until they ban everything but their own pursuits.
In the meantime, seaplanes, as a minority interest, present a very visible and easy target for them.
So EXACTLY what are the National Park objecting to ?
Well as we said earlier no-one has clearly said what the problem is. We now examine the 5 issues that will apparently be taken into consideration for any application to operate a seaplane. They are restated below - with our counter-arguments highlighted. It is worth restating we only want to be treated fairly and treated to exactly the same standards as other National Park users.
1 – Noise Impact - will seaplane operations (landing, taxiing, taking off) result in an unacceptable increase in noise above the ambient noise, both in relation to the areas of the loch in the vicinity of the proposed landing/taxiing route and to the nearest land, including any islands?
What is ‘unacceptable’ and unacceptable to whom ? What IS the ambient noise level? Where is it measured ? Is traffic on the A82 monitored ? What about Heavy Goods Vehicles ? Motorbikes ? Other loch users ? Jetskis, motorboats? Diesel engines on yachts? Agricultural machinery ? Strimmers, lawnmowers and grasscutters ? Helicopters filming golf events or carrying out National Park work ? Commercial aircraft overflying to America ? Search and Rescue helicopters seeking mountaineers ? Military low-flying jets ? Why should seaplanes be singled out for sanction ?
Seaplanes already have their noise levels monitored by the CAA and must be in possession of a valid noise certificate. They are virtually silent on landing (as commented by the President of The Friends of Loch Lomond … one of our strongest opponents!). Any noise is transient and at maximum (on take-off) only lasts for 30-45 seconds. Seaplanes only ever operate during daylight hours, and seek to conduct a good neighbour policy – avoiding repeated flying over the same area – reducing takeoff power as soon as it is safe to do so
2 – Wildlife - the operations must demonstrate that wildlife is not disturbed through aspects such as noise, shadow, effect of landing and taking off.
Survey after survey has shown that seaplanes are the preferred transport by environmental agencies across the globe precisely because they have the most minimal impact on the environment and wildlife. Don’t take our word for it – read the reports in the Advocacy Section of the UK Seaplane Association website. Again the question must be posed, what is the yardstick being applied to other loch users ? How much wildlife is killed or maimed on the roads surrounding Loch Lomond? Are anglers or boaters being asked to demonstrate that they do not disturb wildlife ? How much birdlife is maimed each year by discarded fishing tackle? What damage and pollution is being caused by the use of petrol or diesel engines on the thousands of registered boats on the loch ? We have evidence of diesel spillages in the loch by commercial boat operators – what action has been taken against them ?
3 – Loch Users – the operation of a seaplane may increase the likelihood of unacceptable conflicts with other users of the loch (what is an unacceptable conflict?). Activities such as landing, taking off and taxiing to the proposed landfall is considered (by whom?) to increase the likelihood of unacceptable conflicts. The Park Authority will consider whether the operator has taken adequate safety measures in relation to other loch users in respect of the proposed seaplane operation and in relation to emergency rescue provisions.
What is an ‘unacceptable conflict’ ? Who considers that the likelihood will be increased ? We are responsible loch users too – in fact seaplanes were first recorded on the loch in the 1930s and probably operated there before WW1 ! The drafters of this Byelaw have completely ignored the legal position of seaplanes and pilots, and worldwide experience of seaplane operations.
Seaplane pilots have had an absolute minimum of 50 hours flight instruction, have passed rigorous exams in navigation, law, weather and human factors. Seaplane pilots sit annual flight-tests, are licensed by the CAA, subjected to annual medical checks, hold radio licences, must be sober and are the only loch users required (by the CAA) to pass a seamanship exam. Seaplane pilots already operate under one of the strictest and most regulated regimes. Aircraft must be maintained by licensed aircraft engineers to the highest CAA standards, must have a noise certificate, are fully insured (including 3rd party) and can be worth anything from £60000 to £300000. These are not toys, they cannot just be bought on a whim. It takes an incredible amount of dedication, skill and effort to achieve and operate a seaplane in the UK. By contrast – anyone, whether they be drunk or criminally insane, can go out, buy a boat or jetski (without any set maintenance standard) and take to the loch, with NO training, no insurance, no appreciation of other loch users, no demonstrated weather or navigation skills.
The National Park are missing the perfect opportunity of using these professional standards. Rather than seeking to discriminate against and marginalise seaplane pilots we should be held up as an example to all of ‘best practice’ on how to operate responsibly and safely with respect to other users. We can provide the perfect basis for a Code of Conduct for all loch users. Similar schemes work successfully at Lake Como in Italy and at Loch Earn (within the LLTNP).
Seaplane pilots (with a unique aerial perspective of the landing area) are required by marine law to give way to boats and are solely responsible for avoiding collisions with boats. It must be asked of the National Park - in the interests of fairness, what measures and training will other loch users then be required to take to avoid unacceptable conflicts with each other? Or what about the thousands of vehicles each day travelling along the A82 ? How do they manage to avoid hitting each other without advising the National Park of their every movement ?
Experience elsewhere in the world shows seaplanes and boats co-exist happily. At Victoria Harbour in Canada there are 100 seaplane movements and 1000 boat movements per day. This harbour is less than 1% of the size of Loch Lomond – there has never been a collision between a boat and a seaplane. Lake Union in Seattle has been a seaplane base for 58 years. The lake, which is 3% of the size of Loch Lomond has 30000 seaplane landings a year. Vancouver Harbour has more seaplane movements in day than Loch Lomond had in the entire year of 2004 !! – In the entire USA, National Transport Safety Board statistics show that in 10 million seaplane flying hours, over a 15 year period, there were 3 collisions between boats and – in the same period there were 12500 fatalities with boat collisions.
4 – Servicing of Aircraft - the Park Authority will consider whether those activities associated with the servicing of a seaplane, which do not require planning permission, are considered to raise unacceptable hazards. In particular, the appropriateness of any proposed refuelling points and refuelling and servicing practices. All maintenance of public category aircraft MUST be carried out by licensed aircraft engineers, and this is usually carried out at licensed airfields and not at Loch Lomond. What about the servicing and refuelling of boats – the refuelling of outboard motors, the spillages that occur on the water, the transporting of fuel in cars for use by boats? Supply and storage of aviation fuel is strictly controlled by the Civil Aviation Authority. Amphibious seaplanes will be generally be refuelled at airfields away from Loch Lomond.
5 – Commercial Passenger Service – where the proposed seaplane relates to a commercial passenger service the operator would supply details of the proposed licensed aerodrome area, including details of clearways and movement areas and any apparatus required for Civil Aviation Authority licensing purposes, including marker buoys.
In relation to ALL proposals the operator will be expected to supply –
· Details of the proposed landing and take-off area, required take-off and landing clearance area, taxiing route and landfall
· Details of intended protocol for dealing with the presence of other loch users in the proposed landing area, including proposals for alternative landing areas
· Details of aircraft including engine type
· Details of the proposed flying days per year, number of flights per day, frequency of flights and operating hours
· Details of any shore-based supporting operations, including details of refuelling activity and measures to deal with any emergency incidents.
· An assessment of noise impact on the proposed seaplane activity including a selection of nearby shore-based locations agreed by the Park Authority. Such assessments should highlight the likely changes in relation to normal ambient noise levels at such locations.
Imagine if you had to provide that level of detail, in advance, to obtain written permission to fly. How discouraging and impossible would that be ?
We hope you can see how proscriptive the intention is behind these measures. Again we suggest that seaplanes are a tiny fraction of the users of the loch and their impact is minimal compared to the other ‘accepted majorities’ of motorised transport – HGVs. Buses, motorboats, outboards and cars.
Nobody is asking these other users to justify their continued existence.
The National Park say that Seaplanes are a new loch user and must be controlled quickly
Once again the Park are very selective with their facts. Seaplanes have operated quite happily on Loch Lomond for many years. In fact since World War One there has been a strong link between seaplanes and the area. Hundreds of seaplanes were built on the Clyde up until the end of World War 2, and vital research and development work was also carried out, including freshwater trials and operations on Loch Lomond.
Seaplanes can be considered as an integral and unique part of the local heritage and cultural history. There were commercial operations in the 1970s with a Lake Buccaneer, and in the late 1980s and early 1990s with a Cessna 206. Caledonian Seaplanes have also used the loch regularly from their established base at Loch Earn (which incidentally also lies within the boundaries of the National Park and is a model of how seaplanes and other loch users can co-exist).
If they can co-exist happily on Loch Earn, (without a Byelaw) why not on Loch Lomond ?
Seaplanes have been using the loch since well before the introduction of millions of motor vehicles, well before the invention of jetskis and well before the inception of the National Park !!
There are, however, less seaplanes (5) operating in Scotland that at any time previously in history.
HOW DOES THE BYELAW CONFLICT WITH THE FOUR AIMS OF THE NATIONAL PARK ?
So there you have it. There are probably other arguments that we have missed – feel free to enlighten us if you have a pet statistic or fact that we can use to put our case.
Thank you for taking the time and trouble to read our arguments. We hope that you can now contribute to the Consultation and look forward to answering any questions you may have or receiving a copy of your correspondence…….
RETURN TO ADVOCACY