RE: Formal response to the CAA consultation on Future Airspace Strategy (FAS) 2011 – 2030
Introduction:
Fight the Flights (FTF) is a residents group which was initially formed in 2007 to campaign against the expansion of London City Airport whilst considering the environmental and public health effects of the operations of the airport in this most densely populated area of the country. FTF now also performs a watchdog role upon the operations of London City Airport and the management of planning conditions by Newham Council aswell as political lobbying. FTF provides information, advice and support to residents in any area affected by London City Airport flights and has formed an alliance with HACAN due to the accumulative effect of both Heathrow and London City Airport flights over a vast area of south and east London.
We welcome the invitation to positively contribute to this consultation and look forward to continuing positive dialogue with the CAA in the future. We are particularly pleased to see that the environment has been highlighted as one of three drivers of new policy and a willingness of the CAA to look at things 'radically'. We also welcome a focus on reducing noise. These are all points that could have a positive impact in improving the quality of life and health of residents in east and south London and across the UK as a whole with associated gains beyond in regard to reducing emissions and the impact of aviation's contribution to global climate change.
We would like to raise our concern that at this first stage the consultation appears to be solely aimed at the aviation industry. We feel that it is imperative that communities and NGOs are included and have accessibility to contributing to such a consultation in the very first stages. This essentially promotes a balanced starting point, with all interests being dealt with equally at the same time. We appreciate that the consultation material is technical, but it should not be assumed that such data cannot be grasped by those outside of the aviation industry. However we do feel that it would be best practice to always present the data and text in a way that is generally felt would be accessible to the widest audience possible. This should also take into account equal opportunities on a wide scale and be shaped accordingly. We appreciate this offers challenges in itself but we feel a consultation that is inclusive and accessible adds value in the long term and enables positive dialogue to be built whilst acknowledging equal opportunities.
Further Research Required
FTF welcomes the new strategy offering a chance to review flight paths and the acknowledgment and commitment that ‘.... careful analysis is required to understand the issues .... [such as] concentration versus dispersion of aircraft routes across the ground.’
Research is needed to assess the disturbance caused to people by dispersing flights over what are currently lightly/not flown over areas against the disturbance caused by the concentration of flights. The impact of both methods needs to be fully understood if the best case scenario is to be secured. We would not advocate a move that removes the problem of noise from one locality only to drop it upon another area which would simply move the problem to another set of people. We do however support an approach in which the impacts of the options on communities are fully researched and decisions made upon independent and objective analysis, providing a basis for fairness and transparency.
Research is needed into the way aircraft noise is measured. Leq is outdated and simply does not reflect the noise levels that communities experience: we would like to see this replaced by Lden and in doing so, see the measurement fall in line with the EU. The ANASE report reflected much more accurately the noise that residents and communities actually experience and we feel strongly that the previous government made an error of judgment in they way that it de-valued and discarded the findings. Since the introduction of the Embraers: E170 and E190 at London City Airport it appears that low frequency noise is a particular problem and appears to be prevalent in these newer aircraft. Since a sizable proportion of noise of landing aircraft is caused by the airframe, low pitch noise may be a significant, but under-recorded, element in noise complaints
London City Airport Flight Paths
In the past year we have seen considerable disruption and annoyance from residents who have found themselves newly affected or beneath a more intensified flight path as a result of the SIDS changes at London City Airport. The impact and changes have been discussed with the CAA over the past year in written exchanges and meetings. The impact of these changes have been further compounded by the constant heavy volume of Heathrow flights crossing east and south London in readiness to join the CDA to Heathrow.
The height of aircraft on take off from London City Airport is held down in order to pass beneath Heathrow flight routes. Keeping LCY flights at this lower level, whilst also making a sharp turn upon taking off into the West has the effect of compounding aircraft noise over a concentrated path, but wide area of east London. We welcome the suggestion in the draft strategy that in a redesign of air space an endeavor will be made to remove such restrictions.
Although there are claims in the wider realm outside of this consultation regarding aircraft noise having reduced over the last decade this is not what the communities, both those local and some considerable distance away reflect. At London City Airport this has been due to massive increases in flight numbers, and also in the size of aircraft, and most particularly in noisier profile jets replacing quieter profile propeller planes. It is worth us pointing out that it has been the ever increasing amount of jets at London City Airport that forced the SIDs change in 2009 and which have also had an all round effect of causing more disruptive noise events throughout the day. This is of course in addition to the constant stream of Heathrow traffic above the layer of London City Airport aircraft. It is the ceiling of Heathrow planes and the forced lower level flight of LCYs that further concentrates aviation noise levels over south and east London.
In recent years the problem of disturbance to people living under the Heathrow and London City Airport approach path has been getting worse, partly because of the increase in the number of aircraft movements from both London City Airport and Heathrow. Aircraft are larger and Air Traffic Control is instructing aircraft to join the straight ILS path further out (for Heathrow), and improvements in navigational equipment mean that for the final approach all aircraft now follow a narrow track. People living directly under the flight path up to 30 miles east of Heathrow airport suffer a continuous stream of aircraft overhead and above the stream of London City Airport aircraft that operate at a lower level.
The decision to instruct most Heathrow aircraft to join the ILS glideslope further out has brought disturbance to new areas further east. Other areas previously overflown have benefited, but for those people adversely affected the situation has become intolerable. They feel it is totally unfair that they should be made to suffer the whole burden. Residents find that the more noise events (i.e. individual aircraft flyover) there are, the more disruptive they find it. Frequent lower levels of noise are considered worse than the occasional higher noise: constant noise brings the feeling that there is no escape from it, and for some this leads to desperation. This is indicated in the complaints that residents make to our group and other bodies. Many have found themselves becoming actively involved in lobbying and campaigning for the first time in their lives as a result of the increase in aircraft noise and disruption to their lives.
Concentration or dispersal?
There is strong support from residents in some areas for a curved final approach on Heathrow ILS paths, this should be introduced in order to enable aircraft to join the glide slope nearer the airport and thus reduce the problem of concentration in those areas.
The draft Strategy recognises that any new flight paths would need consultation. There is a case to be made that it would be fair to share the misery of noise from curved flight paths joining the ILS, however the impact on residents should be fully considered and any decision should be based on the assumption of fairness. Any area faced with increased aircraft overhead will wish to be fully consulted and feel that the impact upon them has been fully considered and compared with alternatives. We cannot highlight enough the need for inclusiveness and transparency in the consultation and decision making process.
Continuous Descent Approach
A considerable amount of noise is generated from Heathrow aircraft banking over east and south London to join the ILS. We were advised by the CAA that pilots are told (in regard of best practice) to glide the aircraft when joining the ILS, however it is clear that this is rarely carried out. We have been informed that there is considerable variation between the airlines training of pilots to minimize noise. However there is no regulation, nor recording of the noise of aircraft joining the ILS and therefore the issue fails to be addressed. Without identifying which aircraft and pilots are not using noise reduction methods when possible, the situation cannot be improved. However with the use of noise monitoring of aircraft from beneath the flightpaths a positive improvement in noise levels could be achieved with best practice.
Climate Change
We would welcome a focus on reducing emissions and hence the impact on climate change. This would of course be in line with the Governments Aviation Policy target of returning aviation emissions to 1996 levels. The direct routing of aircraft would contribute in some way towards this and minimize disruption for some areas.
We feel that the section dealing with strategy on climate change is somewhat misleading: The statement ‘Aviation CO2 emissions currently account for [..]1.6 % of global GHG emissions’ is indeed the global figure but it is relevant to acknowledge that UK airport departures account for about 6% of UK total emissions. In addition this figure is set to increase considerably in future years if aviation expansion is to continue. By presenting only the global figure it does not give a clear picture of aviation emissions in the UK at all. The majority of aircraft seats in the UK are filled by UK citizens, therefore the climate change attributable is even higher. Any strategy should therefore be based on a realistic assessment of the damage caused by air travel.
In addition it is stated: The [IPCC] review estimated in 2050 under ‘business as usual’ projections that CO2 emissions from aviation … would account for around 5% of the total warming effect in 2050. Airlines often quote this in order to minimize their responsibility to reducing emissions, but again this is misleading. The 'business as usual’ term makes the unrealistic assumption that neither Britain nor any other country will take any action to reduce C02 emissions during the next forty years. The CAA should not build an Air Space Strategy on an uncritical acceptance of airline propaganda and to do so would be irresponsible and short sighted.
The draft Strategy refers to the Committee on Climate Change (CCC) advice that the UK aviation demand growth should be restrained to around 60% by 2050 if it is to be compatible with the target of keeping CO2 emissions no higher than 2005. The Strategy is at fault in not mentioning that the CCC considered this equivalent to a 55% increase in the number of flights. It therefore appears wasteful and irresponsible for the CAA to base the draft Strategy on an 80% growth in flights. Indeed an 80% growth, not by 2050 but by 2030.
We would like to see the Air Space Strategy revised to take into account the recommendations of the Climate Change Committee.
Other comment
We would like to reiterate the value that any decisions which will have an impact on communities should be fully researched and are based on objective analysis and fairness. We do not support a moving of a problem from one area only for it to be given to a new area. We very much value looking at positive and fair solutions to mitigate and improve the quality of residents lives and environment in a fair and transparent manner.
