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 Transport and Environment Committee (TEC) is a statutory joint committee representing all 32
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
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,
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 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 Councils would be happy to discuss any issues raised in this response