Tuesday, September 08, 2009

London Councils response to the NATS Consultation on Airspace Changes to the Terminal Control North Region

Yet more surprises:

It now becomes clear that the London Councils Transport Environment Committee was not at all satisfied with the proposed flight path changes that were enforced by London City Airport flying more jets and more flights. The committee has also commented that it did not feel that the consultation was adequate, they describe this as not giving a 'true picture of the impact of overflying aircraft on the Terminal Control North area'.

All those residents in the newly affected areas, would surely agree, however residents have been saying the very same for over a year, but of course NATS, London City Airport and the Government care not for residents, only big business. Read the whole letter beneath to read what you had hoped your local council had said for you, in your area, but which many such as the London Borough of Greenwich, Redbridge and Newham failed to do.

London Councils response to the NATS Consultation on Airspace Changes to the Terminal Control North Region
London Councils Transport and Environment Committee (TEC) is a statutory joint committee representing all 32 London boroughs and the City of London. It is the main voice of the London boroughs and of their electorates on a wide range of issues relating to transport and the environment in London and related matters of concern to Londoners. It also carries out a number of statutory functions and works closely with the Local Government Association and with many private, voluntary and public sector bodies. London Councils TEC has considered the provisions contained within the consultation document and would like to make the following comments:

Consultation Process
London Councils is concerned that the consultation document does not give a true picture of the impact of overflying aircraft on the Terminal Control North (TCN) region. The consultation documents and associated maps only consider routes that are subject to change and do not address existing routes where changes are not proposed. Therefore, anyone reviewing the documents will not obtain a full understanding of the numbers of aircraft flying across the region, or the cumulative impact that will result from the proposed changes.

The consultation document has set out the preferred options but does not provide any information regarding the basis on which these options have been chosen. In particular, it is unclear what weighting has been given to key factors such as environmental and community impacts, safety, efficiencies and cost savings for airline operators. Understanding how these options were selected is necessary to enable stakeholders to fully understand what they are being asked to consider. For example, if the individual options proposed offer the greatest benefits in terms of noise reduction, then affected communities may view them very differently to options that have been selected because they offer the greatest cost savings to airline operators.

In addition, London Councils believes that an exercise to ascertain whether additional airspace capacity is actually necessary should have taken place prior to this consultation. London Councils opposes the Government’s ‘predict and provide’ policy towards providing airport capacity, as simply accepting projections based on previous growth trends is contrary to other parts of transport policy, such as road policy, where the principle of ‘predict and provide’ was abandoned as unrealistic over a decade ago. Rather than seeking to restructure and release airspace capacity to accommodate additional demand for flights, an exercise to ascertain whether this additional capacity is even necessary, including a comprehensive review of current operational arrangements at airports, should have taken place before any redesign of airspace arrangements.

The consultation document states that it “is not seeking, and will not respond to, feedback concerning the effects of aviation growth, focusing instead on the effect of the airspace change proposed” and the proposal “is not associated with, and does not assume, further development of Heathrow, Stansted or any of the other airports in the region”. However, London Councils questions how the issue of aviation growth can be separated from the proposals contained within the consultation document. The proposals in the consultation document cover the period up until 2014, during which time, should the current planning limits be lifted, Stansted could see an increase in the number of passengers using the airport from 25-35mppa. In addition, the recent DfT consultation on Adding Capacity at Heathrow has stated that mixed mode operations could be introduced at Heathrow as early as 2010/11. It is unclear whether these changes have been factored in to these proposals.

Furthermore, the recent DfT consultation on Adding Capacity at Heathrow, states that studies carried out by NATS to assess the impact of a third runway have indicated that: “airspace in the London area would require a significant re-design to accommodate growth at Heathrow” and it is not clear if this work represents the first stage of work needed to accommodate additional growth at Heathrow, or is entirely separate. London Councils is concerned that the consultation document has failed to provide any information regarding how any proposed increase in flights will impact upon airspace, whether this restructuring is taking place to accommodate future growth in air transport, which still has yet to be agreed, or whether any increase in airport capacity will require further restructuring of airspace arrangements in London. Without this information it is difficult for communities and stakeholders to make an informed decision regarding how these proposals will impact on them.

Aircraft noise adversely affects an increasing number of residents in London, and this situation is likely to become worse as the number of flights in to London’s airports increases. While these proposals benefit some London authorities, others will experience a greater degree of disturbance. London Councils has noted that this document uses the 57dBA contour as the definition of the limit of the onset of significant community annoyance, which was established in the 1985 United Kingdom Aircraft Noise Index Study (ANIS). However, the findings of the more recent Attitudes to Noise from Aviation Sources in England (ANASE) survey, which the Government commissioned in 2001 following on from the Terminal 5 enquiry, found that the onset of significant community annoyance is actually a much lower level of 50 dBA. This correlates with research carried out by the Institute for Public Policy Research which has suggested that the Government’s classification of unacceptable levels of noise to 57dBA is too high.

The Government questioned the findings of the ANASE study in the recent consultation on Adding Capacity at Heathrow, but the reason behind the refusal to accept the findings of a six year Government commissioned study, carried out by international experts and the reason why it is felt that this is less reliable than a 23 year old study was not made clear. The World Health Organisation believes that exposure to noise at 55 dBA and above has a harmful impact on children’s learning. No consideration is made in this consultation document regarding the number of people that will be affected at the 50dBA level and it is disappointing that NATS has also chosen not to provide this information, despite the recommendations of the ANASE study. The consultation document indicates the population counts within the 57dBA contour at Stansted, Luton, London City (by 11%) and Northolt will all increase under these proposals. Although the numbers within the 57dBa contour at Heathrow will decrease slightly, the numbers affected in the 66, 69 and 72 dBA contours will all increase. It is, however, difficult to get a true picture of the overall impact of the proposed changes on noise levels. This is because the figures do not consider any increase in noise resulting from an increase in the number of flights, nor do they consider the noise generated by other routes that are not being considered as part of this consultation.

Furthermore, it is also important to note that the population of London, and indeed that of the South East, is growing at a considerable rate and the construction of large numbers of new homes is planned across the region. It is not clear whether the calculations have taken into account the population increases that have been forecast and the numbers of homes that are expected to be constructed by 2014. This is likely to significantly increase the numbers of people in the region that are affected by aircraft noise.

Finally, of particular concern for London residents is the problem of noise from night flights. It is disappointing that the consultation document does not contain information regarding the impact of the changes on noise contours at night and in the early morning. Considering the Government’s pledge set out in the 2003 Aviation White Paper to “bear down on aircraft noise at night”, it would be expected that a key consideration informing decisions on airspace changes would be to reduce the numbers of people affected by aircraft noise at night.

Air Quality
London Councils questions the basis on which the consultation document has claimed that the air quality impacts of the proposals will be ‘neutral’. It is not clear whether these proposals have considered the impact of any increase in the number of flights, or taken into account current emissions generated by other routes not being considered as part of this consultation.

London Councils believes that, in the interests of safety, as far as possible attempts must be made to route flights away from population centres. However, increasing the number of aircraft using airspace above London does bring a number of safety concerns. Setting aside the environmental, social and economic issues, events in New York and Washington and more recently the terrorist attacks in London in July 2006 must stimulate very careful thought about the risks of increased flying over the capital. The potential dangers were again illustrated by the incident in January where only the skill of the BA crew prevented an aircraft crash landing before it arrived at Heathrow airport. These issues bring into question any proposal to increase the number of aircraft using airspace over London and other densely populated areas.

London Councils would be happy to discuss any issues raised in this response