LONDON AIRSPACE CHANGE – GATWICK LOCAL AREA CONSULTATION Issue 1, May 2014
Penshurst Parish Council (PPC) has viewed the consultation document online. It believes that its electorate’s interests will be best served by a written response dealing with appropriate paragraphs from the entire consultation document, including the Introduction and other supporting commentary to the questionnaire, to ensure that we can attempt to address all issues fairly. To avoid any doubt or confusion paragraphs will be shown under the same numeric headings as in the consultation document.
Our position on the specific points raised is dealt with below. However, we wish to highlight two general points in particular.
Firstly, we are extremely concerned at the proposal to narrow the current swathe within which arrivals for RWY 26 are channelled. Narrowing the swathe will intensify the frequency with which our community is subjected to the nuisance of over-flying. It is inequitable, unjust and unnecessary to concentrate flights over any community within the current broader swathe. We challenge the rationale for the changes, including the notion of CO2 emission savings. Whilst the impact on our community, being within an Area of Outstanding Natural Beauty, is already significant, we believe that all communities in the area should continue to share the burden of overflight in the same way as they do today.
Secondly, we have concerns as to the implementation of the “consultation” process to date. In our view, the stated purpose and formula for fair consultation have been ignored. Vital information was not provided to stakeholders at the time their views were sought. Responses from stakeholders have been substantially ignored, particularly in relation to the overwhelming desire of respondents to continue with the broad swathe approach to ensure that one community and environment is not unfairly blighted by aircraft noise.
Any process which does not clearly and openly provide relevant information, seek stakeholder’s input in a straightforward and easily comprehensible way, and then act upon the majority views of stakeholders cannot validly be considered a “consultation”.
Dianne Broad (Mrs), Vice Chairman, Penshurst Parish Council
7 July 2014
With the benefit of having viewed the responses, now published in the London Airspace Consultation – Final Report – April 2014, the Parish Council stands by its original claims of the negative impact that Point Merge could have due to the proposed concentrated flight path and its limited respite. Some of these points were highlighted in the report but we reprint the most fundamental, as follows:
….As there are no indications as to where these [concentrated flight paths] would be we cannot support this concept. It would be grossly unfair on those whose lives would be devastated with a continuous stream of overhead flights from a Point Merge when they previously had substantial relief from the tactically vectored flight paths across a broad swathe. The current system is a proven, safe and a fairer distribution of incoming flights…
… Penshurst Parish Council
We can now see when examining the sum of the responses from stakeholders and the public how percipient our comments were. Not even the airlines are in full agreement on the efficiency of a Point Merge system on fuel burn. The stated primary objective of the Point Merge proposals is to increase runway efficiency, so that another 5 flights can operate each hour. In our opinion, the resulting CO2 emissions from increased flights will be substantial adding tens of thousands of tons to the millions already produced by aircraft movements from GAL and negating any alleged CO2 emission benefits of the Point Merge system. On question 11A ‘Making best use of Gatwick Airport Runway 26,’ of the 492 online responses from the public 86% did not support the proposal.
When we examine what environmental objectives are being promoted in this consultation process it is difficult to find one that stands up to scrutiny, yet we and the vast majority of respondents find a multitude that adversely impact on the environment and just as important on the quality of people’s lives and their general health and well-being – and economic sustainability.
Penshurst Parish Council’s response to the LONDON AIRSPACE CHANGE – GATWICK LOCAL AREA CONSULTATION Issue 1, May 2014
Gatwick Airport Limited (GAL)
Question 1a: Which ONE of the SIX alternative proposed options, if any, do you believe provides the best balance of benefits for RWY26 departures?
Penshurst Parish Council’s Response (PPC)
For questions 1a, 1b, 1c & 1d we believe that as these proposals are not relevant to our area, they are best responded to by those affected.
Question 2a: Compared with today’s routes, do you believe the proposed realignment for RWY08 departures to the east/northeast of Gatwick Airport is better or worse?
We support the alignment that has been drawn up on the basis of feedback from Kent County Council and other stakeholders. This alignment is shown in Maps 26 and 27 and in the forecast route usage as shown in Table 7 and the Population Counts as shown in table 8. Our support is based on the 500m NPR indication that a negative population figure of – 3900 will be achieved against a 0 (zero) figure of those newly affected. This proposal is much better than the current system.
Question 2b: Which, if any, factors do you believe to be the most important for us to consider when determining whether to realign the RWY08 departures to the east/northeast?
We believe that many factors should be taken into account including:
Noise that affects health
Noise at night that disturbs people’s sleep
Noise in the day that impacts people’s quality of life
Noise in the daytime that affects our schools and community facilities
Noise over Areas of Outstanding Natural Beauty, National Parks and historic houses and gardens
Question 2c: If we were to implement the proposed route, what width NPR swathe do you think is most appropriate?
We support the most practical width that causes the least disturbance to those being overflown.
Question 2d: If you answered question 2c, what were the reasons for your choice?
Our support for this swathe is directly linked to the fact that there will be no increase in the population that are affected and no increased intensity of over-flying for any population. Conversely, there will in fact be a decrease in the nuisance caused. It is our submission that this fundamental principle (the need to ensure that there is no increase in the populations overflown or the intensity of over-flying on any population) should be central to all of the proposals
Question 3a: Should we seek changes to the current DfT noise abatement requirements, so that the proposed night-time arrival respite route for RWY26 could be implemented (as shown in Map 34 and Map 35)?
We do not consider that a single respite route is appropriate. Our position is that a multi respite should be given priority through a tactically vectored broad swathe approach, as is currently operational. The consultation process freely admits that an element of this will have to be maintained in the proposals. In the original consultation question ‘On Arrivals Based on Point Merge at Gatwick,’ of the online responses from the public only 8.5% strongly supported Point Merge, 17% tended to support but almost 75% did not support Point Merge.
Question 3b: Which, if any, factors do you believe to be the most important for us to consider when determining whether to seek changes to the current DfT noise abatement requirements, so that the proposed night-time arrival respite route for RWY26 could be implemented?
PPC: These changes should only be considered if they form part of a multi respite path option across a broad swathe, as is currently operational. This would give additional benefits to a number of areas. As it is stated that this proposal is purely for night-time respite, then clearly the reduction of noise is primarily for a reduction in disturbed sleep.
Question 3c: What, if any, comments or suggestions do you have about the proposals for us to seek changes to the current DfT noise abatement requirements, so that the proposed night-time arrival respite route for RWY26 could be implemented?
We stand by our previous answer that this should not be about a single respite path. However, if it was part of a multi respite swathe it could be supported if it was proven that there would be a reduction in people adversely affected by noise nuisance and/or no increase in those newly affected.
GAL Questions 4a, 4b,4c are not relevant to our area and are best dealt with by those affected.
Question 5a: Should Gatwick Airport Ltd re-centre and narrow the published NPRs to take account of aircraft performance on the modern PBN routes in place at Gatwick Airport?
We have a neutral position on this given that the information suggests that it is purely a cosmetic exercise. However, if the narrowing of NPRs could lead to a higher concentration of noise for a minority of residents, GAL should not go ahead.
Question 5b: Which, if any, factors do you believe to be the most important for us to consider with respect to re-centring and narrowing published NPRs to take account of aircraft performance on the modern PBN routes?
NPR swathes should indicate potential noise impact from over-flights of nearby areas.
Question 5c: What, if any, comments or suggestions do you have about the proposals for Gatwick Airport Ltd to consider re-centring and narrowing published NPRs to take account of aircraft performance on the modern PBN routes (please provide any views you have on what the optimal width for NPR swathes should be)?
The optimal width should reflect the effects on the population below. However, we have seen no environmental metrics used in this consultation process that would fill this objective and reliance is purely made on population count within the NPR 4000ft ceiling.
Question 6a: Should we implement shortened NPRs to take account of the observed climb performance of the flights at Gatwick Airport?
Question 6b: Which, if any, factors do you believe to be the most important for us to consider when determining whether to implement shortened NPRs to take account of the observed climb performance?
Although we are not in agreement with the proposal on balance NPR swathes should indicate potential noise impact from over-flights of nearby areas.
GAL Questions 7a, 7b and 7c are not relevant to our area and are best dealt with by those affected.
Question 8a: Should Gatwick Airport Ltd consider NPR swathes with variable widths, dependant on sharpness of turns on each route, as a more accurate portrayal of where aircraft actually overfly?
Yes – probably.
Question 8b: Which, if any, factors do you believe should be the most important for us when considering NPR swathes with variable widths, dependant on sharpness of turns on each route, as a more accurate portrayal of where aircraft actually overfly?
NPR swathes should indicate potential noise impact from over-flights of nearby areas.
Question 8c: What, if any, comments or suggestions do you have about whether we should consider NPR swathes with variable widths as a more accurate portrayal of where aircraft actually overfly?
Nothing further to add.
Question 9: What, if any, additional comments do you have that are relevant to this consultation and that you would like to make?
To reduce content we will comment on a sample of the information and observations supporting the questionnaire to London Airspace Change – Gatwick Local Area Consultation – Issues 1 – May 2014, which we believe is pertinent to QUESTION 9
LONDON AIRSPACE CONSULTATION Issue 1, May 2014
Gatwick Airport Limited (GAL)
1.2 This means that, from time to time, the organisations responsible for managing our airspace will make proposals for changes to the use of existing airspace structures in order to enhance safety and improve efficiency. These proposals are usually subject to consultation and when they change the flight paths for aircraft flying at low altitudes, that consultation is open to members of the public to provide feedback.
Penshurst Parish Council’s Comment (PPC)
We do not believe that the original feedback to the London Airspace Consultation has been properly considered. On the contrary, given that they do not reflect the majority of responses to the consultation, we believe that the concentrated flight paths and respite corridors now proposed in this document were possibly determined prior to stakeholders’ response. This calls into question the validity of the entire consultation process. The CAA’s Director of Airspace Policy has made it clear in the forward to the Airspace Charter that: ‘The Directorate is to ensure that UK airspace is utilised in a safe and efficient manner. This is to be achieved through the development, approval and enforcement of policies for the effective allocation and use of UK airspace and its supporting infrastructure, taking into account the needs of all stakeholders.’ If fundamental changes to airspace management are pre-determined outside of stakeholders influence, then the purpose of the consultation process is fundamentally flawed, and is being treated by GAL and NATS as essentially irrelevant.
1.3 This consultation follows on from the consultation that we (Gatwick Airport Ltd) ran with NATS1 between October 2013 and January 2014; this was referred to as the London Airspace Consultation. That consultation aimed to uncover local requirements to take into account in the on-going design process. It ran relatively early in the design process, before the detailed options for route alignments had been fully considered. The consultation therefore presented the corridors within which we are seeking to position the new routes, described the potential effect of a route overhead and asked for local views on what factors should be taken into consideration in the development of the design.
The specific Point Merge arrival corridors were not shown in the original consultation documentation, nor was there any room in the documentation for debate: only the existing broad swathes were shown in Appendix K. The original consultation process made it clear that GAL were not going to publish the nominated concentrated flight paths from Point Merge. The follow-up consultation dated 1 May 2014, to which we are now responding, also fails to give stakeholders the opportunity to address this issue, as there is no specific question on this point in the documentation. This calls further into question the fairness of the “consultation”, and whether it can on any analysis be considered a true consultation process.
1.4 This was an effective way of describing potential effects across a wide area and ensured that we captured local requirements across a range of options. However, it did not allow the consultation to cover all the measurable environmental analysis, known as ‘environmental metrics’.
1.6 This follow-on consultation presents these metrics; in particular noise contours and footprints3, and population counts for the Noise Preferential Routes (NPRs4) which are used to ensure that aircraft fly the routes they are supposed to.
We, and many others, believe the environmental metrics used for airspace consultations in the United Kingdom are seriously flawed. Once again the discredited ANCON Leq 57dBA sound energy contours and their equivalents have been used. These have not been subject to the scrutiny of modern-day scientific analysis. They find their distant origins in the 1980s and with some peripheral juggling over the years they still emerge as arcane and irrelevant. Noise contours and footprints do not take into account the vast majority of the stakeholders who are affected by aircraft movements at Gatwick Airport and elsewhere. In the Summary of Responses to the Draft Aviation Policy Framework Consultation, recently published by the Department for Transport, the consensus of public opinion was: “The 57 dB LAeq, 16h contour is the wrong means of measurement because it is outdated / represents an average / is ineffective. In summary, there is no confidence in this contour as the (sole) basis for taking decisions regarding aviation noise.”
In addition to the above, aircraft noise disturbance from airports in the UK is not adequately monitored. This has allowed a generation of Airbus A319/320/321 series of aircraft, which dominate aircraft movements at Gatwick Airport, to cause severe annoyance with a high pitched whine particularly noticeable along the low approach to touchdown from at least twenty-five miles away. The CAA advised on 16 October 2013 that the ‘Tone is emitted around 500-600Hz, close to peak sensitivity of the human ear, hence it is very perceptible.’’ The CAA also confirmed that the ANCON modelling system has failed to measure this type of noise within its confined boundaries. In Europe airports such as Frankfurt have a policy of working with airlines, aircraft manufactures and local authorities to reduce operational noise and have been successful in bringing about modifications to eradicate this airframe whine that is affecting tens of thousands of people in the UK and hundreds of thousands in Europe: much of this caused by aircraft operating out of Gatwick Airport. Due to the unacceptability of this persistent nuisance from May of this year all new deliveries of Airbus A319/320/321 will be fitted with this modification. Clearly, Gatwick Airport (and airlines such as easyJet, who use this series of aircraft) should work together in accordance with their social responsibility to ensure that all aircraft of this type operating out of Gatwick Airport have these modifications retro fitted.
The reduction in day and night time misery from aircraft noise that this will bring for thousands of people will help to alleviate the environmental harm brought about by aircraft movements from Gatwick Airport and elsewhere.
Both Air France and Lufthansa have agreed modifications to their fleets of Airbus A320 series stating that they have an obligation of social responsibility to do so.
Objectives and Justification for Proposed Changes
3.11 The London Airspace Consultation described our objectives for changing the routes to/from Gatwick Airport; it described what we are trying to achieve and the generic benefits/impacts that would result; it then sought the views of stakeholders on these objectives. We are not re-consulting on these objectives, or on the rationale for changes already covered in the initial London Airspace Consultation; however the key elements are described here again for reference only.
In the online response from the public and directly from many stakeholder organisations in regards to questions such as : 12Aa Respite Routes for Gatwick Airport below 4,000ft, there was a substantial criticism of the consultation process. Multi respite routes were proposed by respondents in line with tactically vectored approaches across a broad swathe as are currently operational and we see this same request repeated. For GAL and NATS to require responses on flight paths that were unknown at the time of consultation is not acceptable. In short, a process which does not provide fundamental information (which is required to make informed responses) to stakeholders cannot fairly be considered a “consultation”. Rather it simply discredits the process. Then to restrict further comments in the latest response once these concentrated flights paths were published is fundamentally unfair, unacceptable and beyond rationale. Further, it calls into question the validity of this “consultation” process. .
3.15 Environmentally we are also seeking to utilise PBN to improve noise management, as it provides the opportunity to refine the application of the following techniques:
Positioning routes away from populated areas and potentially other noise sensitive areas12
Creating respite routes
The proposed concentrated flight path approaching RWY26 from Point Merge has been positioned so that it overflies ‘noise sensitive areas,’ in particular it now entraps the village primary schools of Langton Green, Speldhurst, Fordcombe, Penshursts, Chiddingstone and Hever. These quiet local schools, so important to the early development of children in learning, personal and social development – much of it from playtime contact, will be bombarded with noise. However, much of this potentially disruptive disturbance can be avoided if a sensible and responsible approach is taken by Gatwick Airport. We have advocated retaining the tactically vectored broad swathe approach to RWY26 which is currently in operation as we believe this is the fairest way to spread the nuisance and environmental damage of noise from aircraft movements.
Under the “Kent” heading in the on-line response from the public, of the historic villages Penshurst received more support than other similar locations yet is now shown in the epicentre of the proposed concentrated flightpath for arrivals to RWY26, as are other listed villages, all of which the public tried to protect in their responses. Local economies relying on the major tourist attraction of internationally important buildings
12 There is no formal definition of a ‘noise sensitive area’; it is a deliberately open term as we believe a purpose of consultation is to identify if there are specific local areas for which there is a rationale for it being particularly noise sensitive, and therefore requiring special consideration in the design of low altitude routes.
and grounds such as Hever and Chiddingstone Castles and Penshurst Place could be irrevocably damaged.
With the proposal of one concentrated flight path and possibly one respite path these historically important sites could be irrevocably damaged. What can be seen here is that the air travel industry is in total denial of the collateral damage of their proposals. The ongoing financial viability of these properties is vital for their
maintenance and upkeep, as well as for the local economies. Even a relatively short period of reduced visitor numbers resulting from the concentration of flight paths overhead could lead to irrevocable damage to these otherwise extensively protected houses and gardens.
8 Night-time respite option for RWY26 arrivals
8.3 During the on-going design process, we have been developing a more detailed design that can accommodate this flexibility. In general, arrivals would still be seen across the same swathe as they are today, but the spread of flights within that swathe would differ. More flight paths would be concentrated towards the centre of the swathe, and fewer towards the periphery. This is in line with the response received from key council authorities during the London Airspace Consultation which highlighted reducing the number of flights that stray over Royal Tonbridge Wells and Tonbridge as a priority.
It is clear when we examine the responses of the two major towns mentioned above – Tunbridge Wells and Tonbridge (and the villages affected by RWY 26 arrivals) that their views on these issues have been misrepresented and/or totally ignored as is illustrated below. The overwhelming request has been for arrivals to be across a broad swathe approach and the excuse to concentrate RWY26 arrivals to avoid overflying these towns is at complete odds with both the towns’ published recommendations which we see below. In any event their towns centres have a minimum of aircraft movements over them in comparison to their neighbours and the ambient noise levels in their built-up areas is recognised to be at least 10dBa higher and people’s routines to be less affected by overflying aircraft than those in rural communities.
In their detailed response to the original London Airspace Consultation Tunbridge Wells Borough Council specified, amongst other matters, as follows:
….. We feel that it will be essential to re-consult on the respite route or routes and would like to see justification for both the original route and the proposed respite route. This should be accompanied by reasons why other routes were not chosen and why more respite routes were not considered feasible.
Thus Tunbridge Wells Borough Council is supporting a multi-route method so that the pain can be shared and increasing everybody’s stake in ensuring that aircraft noise is addressed so that it does not become marginalised as a problem for those overflown and therefore “ignorable”.
There appears to be unnecessary exclusion of certain options that could give rise to a fairer approach to sharing the burden of air traffic. For example respite routes are restricted to main route and one other option. There was no compelling evidence given by NATS on the justification for this restriction. Surely with the massive benefits of the PBN it should be possible to vary the routes very easily with little or no inconvenience to pilots as they would just input the new route instructions into their navigation systems. We would strongly advocate a policy of spreading the load over many routes so there are no “big losers” in the scheme and ensuring that other linked policies are progressed to get steeper descent angles and point merge over the sea.
Likewise, Tonbridge & Malling Borough Council (TMBC) are clearly not in favour of the concentrated flight path from Point Merge with only one respite route as can be seen from the Minutes of their PLANNING and TRANSPORTATION ADVISORY BOARD dated 20 January 2014, in response to the London Airspace Consultation. Please see below:
Minutes TMBC 20/01/2014
1.3 Consultation Issues
1.3.1 The consultation asks two specific questions that are relevant to the Borough and the summary above. Firstly, as a matter of general approach, whether alternative routes should be identified in order to provide ‘respite’ paths. Secondly, in what geographical locations should be considered for altering routes for ‘respite’ paths and what should the criteria be for these choices.
1.3.2 Members should be aware that the consultation itself has been met with considerable uncertainty by some and I share the concern that I have heard expressed. It is extremely difficult from the evidence available to make a fully informed judgement on the question of ‘respite’ paths until potential paths have been identified and can be assessed. It is also very difficult for the Borough Council to reach any definitive view as to which locations should be preferred pathways and which areas within the range of practical choice might be avoided. In this respect CAA guidance already exists to make such assessments based on environmental factors, such as noise impact
1.3.3 In this context I feel that the most useful representations that the Borough Council can make in respect of the two questions is to provide some support in principle to the approach to respite but reserve its position to see further detailed assessment of potential paths. In other words respite is agreeable so long as specific pathways are themselves acceptable.
1.3.4 On the second point, there is clearly a balance to be made between flight paths over areas of population versus more rural areas. However, that is a very simplistic view as the actual impact on some rural areas including villages might be more noticeable in terms of background. The current guidance provides a framework for such considerations and should form the basis for some more firm options in terms of flight paths that could then usefully be the subject of a further round of consultation.
1.3.5 As a matter of further comment I would also suggest that the Borough Council makes the very simple point that we would not expect any selected flight path to be placed and join the final approach path any further to the east as such a scenario would definitely increase noise impact on parts of Tonbridge.
What we determine from Tonbridge & Malling Borough Council’s minutes, in their response to the original consultation, is that they are not even advocating decreasing flights over their area, realising of course as the other borough, towns and villages have, that this would put unfair pressure elsewhere. There is an overwhelming response for a broad swathe approach for arrivals along multi respite paths as is currently operational. In every proposal we see from Gatwick Airport Limited in this apparently irrelevant process it is all about the airport and not the people they fly over. Their views have been gathered – but ignored – or misrepresented, in our opinion. It has been seen from the material we have presented that these ‘ key council authorities’ did not advocate the proposals as suggested in GAL’s statement in 8.3 above. Edenbridge Town Council, another key council authority, has responded to the London Airspace Consultation in similar vein to others including the lack of transparency in the consultation process as, we can see in the following:
EDENBRIDGE TOWN COUNCIL
Briefing and Response to the London Airspace Consultation
4 Other Relevant Considerations, Omissions and Challenges:
4.1 We have already drawn attention to some of the structural shortcomings of the process including the ‘one shot’ opportunity to discuss changes, which have the potential to affect communities fundamentally, without access to the information which will determine that outcome. This raises particular questions around trust and transparency of due process. It also offers no evidence that the process will establish that optimal balance between benefits and impacts.
In summary, Kent County Council’s views support the publics’ response to this consultation and that of the majority of organisation stakeholders – that a broad swathe approach should be maintained in order to spread the substantial burden of aircraft noise.
Response from Kent County Council
David Brazier, Cabinet Member for Transport and Environment, Kent County Council, 20 January 2014
‘‘… Although the introduction of an alternative respite route will provide a break from over-flight for an agreed period of time yet to be determined, it will still result in two groups of people (under the two routes) from experiencing all of the noise half of the time (assuming the use of alternate routes is split evenly). A more equitable approach would be to provide multiple routes so that respite is given more often and the burden of over-flight shared. Although Government policy favours concentration over dispersal this should not be interpreted to mean that one group of people (or two groups with respite routes) are subjected to all of the noise all of the time. Indeed, the Aviation Policy Framework also states that where there is intensive use of certain routes, and following engagement with local communities, it may be appropriate to explore options for respite which share noise between communities on an equitable basis, provided that is does not lead to significant numbers of people newly affected by noise.
Each route can still be precision based and therefore concentrate noise rather than spread it within a ‘swathe’; and as long as the different precision routes are within areas already impacted by noise, more people and new groups of people will not be affected by noise. Instead, with multiple precision routes different groups of people will be affected while others benefit, and vice versa depending on the alternating pattern of respite. KCC therefore urges that multiple precision routes are designed so that respite can be offered more often rather than just one route with one alternative respite route that all aircraft must take.
In general, KCC supports Point Merge Arc systems provided that they are positioned over the sea or Estuary and not land. KCC also urges that although precision navigation will reduce the number of people affected by noise, which is in line with Government policy, the focusing of that noise over a single group of people under a precision route is unacceptable. The provision of a respite route will provide some relief for potentially up half of the time, but it must be possible to provide multiple precision routes so that respite can be provided more often so that noise is shared out rather than focused on one or two groups of people. This is also in line with the Aviation Policy Framework which states that it may be appropriate to explore options for respite which share noise between communities on an equitable basis, provided that is does not lead to significant numbers of people newly affected by noise.
A further consultation is also required to establish the frequency and timing of the respite once the potential options for alternating between routes are known.’’
Cabinet Member for Transport and Environment
Kent County Council
20 January 2014
Penshurst Parish Council Meeting, Monday 7th July 2014