EGAG suggestions for response to Heathrow Airpace and Future Operations Consultation – summary
Heathrow Consultation Questionnaire DANGER for Englefield Green
Sample copy of points you may wish to include using your own words whatever your views.
Englefield Green Action Group (EGAG) supports a vibrant and better Heathrow but not an expanded one. The third runway is seeking to put the equivalent of the same number of flights as at Gatwick on top of their existing 480k flights. We continue to be opposed to a third runway at Heathrow. Nothing in our response should be taken as support for the new runway.
1.Managing noise for an expanded Heathrow.
Draft proposal for a noise objective: To limit and, where possible, reduce the effects on health and quality of life and deliver regular breaks from scheduled flights for our communities during the day and night. We need to do this whilst making sure the measures we put in place are proportionate and cost effective
1a.Do you support our proposals for a noise objective?
1b. The principle of limiting noise effects is positive. However the devil is always in the detail. Phrases such as “where possible” are much too vague and lack clarity. We would like to see much more ambitious statements such as “The objective will be that noise will be limited to no more than present in currently overflown areas and where there is no other alternative the principle of equitable sharing and dispersal across design envelopes will be practiced”
The number of dispersed routes within each Noise Preferential Route (NPR) should be at the maximum consistent with safety – Heathrow are suggesting three but our view is that this could be increased to six which would give a fairer distribution and avoid what the Civil Aviation Authority (CAA) have called “noise canyons” Locally we call them noise sewers!
The phrase commensurate and cost effective again begs the question of “whose judgment?” The balance of commerciality and community interests is critical. Communities believe that these interests are weighted too much towards the airline sector. Their gain from a third runway and Performance Based Navigation (PBN) far outweighs the trade off for less noise on the ground for those communities overflown.
This consultation does not give clear details on where the new flight paths will be and as such is inadequate.
We believe that there should be a noise target on a tapering scale to reach lower levels as proposed by the World Health Organisation (WHO). The improvements on operating procedures and improved technology should be focused on noise reduction on the ground rather than improved commercial benefits for the airline sector. The proposed noise envelopes require full revision so that planes are flying at the highest possible levels over communities surrounding Heathrow. The Department of Transport (DfT) should ensure that health impacts are minimised and trump commercial considerations of the airline sector. There needs to be a better study of the health impact of the consequences of the third runway, and flight concentration. We are surprised that we are unaware whether the Department of Health has published a report on these health impacts.
1c. Please provide any comments you have on our proposals for a noise objective.
No additional comments
2. Would you prefer to have longer periods of respite less frequently (all day on some days but no relief on other days) or a shorter period of respite ( e.g. for 4-5 hours) every day? Please tick one of the following options.
We regard this question similar to “which arm do you want removed/ do you want to die by knife or by gun?”
Our view is that we do not wish to have any less respite than is currently available for those who are overflown on a two-runway configuration. We believe that if a third runway is built then respite will be reduced from a half day to a quarter. We would ask Heathrow to clarify this. Again until the exact flight paths are known the full impact of alternation is not clear.
In principle we believe longer periods of respite every day are preferable.
2b. Please tell us the reasons for your preference.
Over the past 10 years aircraft have moved 400 metres closer and are flying lower over Englefield Green. The latest draft report by consultants hired by Heathrow show aircraft are now a further 200 metres closer and lower still. We oppose this gradual creep and demand that flight paths and heights go back to where they were 10 years ago.
2c. Please provide any other comments or suggestions you have on runway and airspace alternation.
|A longer period of respite but not every day|
|A shorter period of respite every day|
|I don’t know||X|
It is important that any new flight paths are far away from each other for respite to be meaningful. Our view is that within each noise envelope the maximum number of departure routes, consistent with safety, be introduced. We believe this should be at least six and not three as proposed by Heathrow.
A simple, understandable scheme is important.
Wherever possible, departures and arrivals should not fly over the same areas, i.e. areas that have departures flying over them on westerlies should not have arrivals landing over them when there are easterlies. Otherwise there would never be respite for these communities when the wind changed.
3a. Should we prefer westerly operations during the day and easterly operations at night to reduce the total number of people affected by noise?
3b. Please tell us the reasons for your answer.
Currently the broad split of 70/30% on westerly/easterlies is generally a matter of climate/wind strength. The suggestion that the change to a more balanced mix would be a good option for the majority in Englefield Green but would be opposed by other areas. However the principle of fair distribution is part of our overall supported policy.
3c. Should we sometimes intervene to change the direction of arriving and departing aircraft to provide relief from prolonged periods of operating in one direction – even if that means slightly increasing the number of people affected by noise?
There should be no increase in noise for those currently overflown.
3d. Please tell us the reasons for your answer.
The overriding principle must be, to ensure that there are no more concentrated routes overflying Englefield Green than is at present suffered by residents.
We understand that No Preference has a fairness ring about it and that managed preference could allow Heathrow, wind conditions permitting, to switch the direction of the aircraft, albeit for just a short period, to allow residents to get a break from a unusually long period of the easterly or westerly operations.
3e. Please provide any other comments or suggestions you have on directional preference.
Directional preference gives “carte blanche” to Heathrow to affect people’s lives, which is a major concern. If this is agreed by the CAA, we would insist on a quarterly report on the facts as it would be unfair for any one community to be adversely affected by changes, in say, the summer months when residents tend to spend time outdoors as opposed to winter months where noise may be minimised by insulation.
4. Night Flights
4.a.To help inform our consideration of the options, we want to know whether you would prefer for us to:
|Option 1 – Use one runway for scheduled arrivals from 5.30am (runway time 5.15am)|
|Option 2 – Use two runways for scheduled arrivals from 5.45am (runway time 5.30am)|
|X||I don’t know|
4b. Please tell us the reasons for your preference
Dealing with departures only, the World Health Organisation ( WHO ) have said that in order to protect good health, there is a requirement for 8 hours uninterrupted sleep. The Transport Select Committee (TSC) recommendation was for a minimum of 7.5 hours. The local view is that the night flight quota should not be increased from the current absolute number.
Earlier flights than those currently should be opposed as that has a direct impact on sleep patterns of those being overflown. The consultation says nothing about whether there is a plan to change the time of first departures, which we would oppose.
4c. Please provide any other comments or suggestions you might have on early morning arrivals.
We would oppose any earlier start time for departures.
5.Other night Restrictions.
5a. Please provide any comments or suggestions on how we should encourage the use of the quietest type of aircraft at night (outside of the proposed scheduled night flight ban).
Quieter planes should be encouraged but their heights should not be reduced for commercial advantage but kept at least to the same height or indeed at higher levels. Quieter planes should give quieter ground noise level. i.e. technology improvements should go to reducing noise on the ground.
Financial penalties for noisier and late flying planes should be at a level, which
becomes commercially prohibitive. At present the charges are relatively modest so as
not to be a real disincentive.
The operational reasons for delayed night flights should be restated and airlines, which constantly depart late because of poor baggage or admin systems, should be heavily penalised and prohibited.
5b. Please provide any other comments you have on night flights and restrictions:
Airspace – Local factors.
6. To answer this question, please look at the design envelopes for expansion online using the postcode checker or look at them in our document Heathrow’s airspace design principles for expansion.
What sites or local factors should we be aware of in your area (or other areas of interest to you), when designing flight paths for an expanded three- runway Heathrow?
Please give enough information ( e.g. postcode, address or place name) for us to identify site(s) or local factor(s) you are referring to and tell us why you think it is important.
Englefield Green is 5 miles away from Heathrow and on a hill (280 feet above sea level). This makes it more vulnerable to noise than some other local areas as planes pass over at lower levels from the ground.
The area is an internationally known tourist location of national interest with the Runnymede slopes being the site of the Magna Carta signing, the American Bar Association, the John F Kennedy memorial, the National Trust (Writ in water Roundel), and the Jurors chairs.
On the brow of the hill is the Airforces Memorial, (AFM) where families from all parts of the world particularly from the Commonwealth visit to pay their respects to the 25 thousand men and women who were lost, presumed dead from the allied Airforces during World War II. This is an area of quiet contemplation and further over flights would be totally inappropriate and should be avoided.
We await the final noise report from Anderson Acoustics from the monitor in the AFM, which based on the draft will show planes lower, noisier and moved closer to Englefield Green.
Royal Holloway university has over 10k students, many of whom live in the Englefield Green community during term times but few are on the electoral roll and therefore are not on the population count. We believe this needs taken into account, as there is significant evidence showing the poorer learning outcomes by those affected by aircraft noise including health and stress levels.
7. Independent Parallel Approaches (or “IPAs”)
IPA changes the existing status quo and it would be contrary to natural justice for areas west of the airport to be subjected to arrivals as well as the historic level of departures. Many residents moved from noise blighted areas to Englefield Green and made life decisions on where to live based on previous Government and Heathrow commitments that there would not be a third runway. It is a breach of good faith for this now to be reversed and for these communities to now have arrivals also inflicted upon them. We are therefore against IPA.
If the Government and Heathrow believe that noise levels are not unreasonable then there should be a wider compensation package of unblighted market price plus a premium of 25% for any properties where noise levels are increased by a level to be agreed. It is noted that a 3dBA increase is the equivalent of a doubling of noise. Such a scheme could be open for a period of say three years post a third runway being built and underwritten by government.
The introduction of PBN allowing aircraft to fly closer together will mean narrower, dedicated and concentrated flightpaths and the risk of creating “Noise Canyons” or ‘noise sewers.’ The effect of these changes again may mean that respite for some communities will be reduced which we oppose.
There is particular concern about the period between 6am and 7am when there will be 25 new flights on arrivals overhead Englefield Green.
8. Comments relating to the consultation.
The consultation cannot be said to be truly open as the options are predicated on a conclusion, which local communities do not support. The balance between the commercial interests of the airline sector and those overflown is unequal. The vested interests and the weight of the research and public relations machinery of Heathrow significantly overwhelm any input that residents are able to raise.
The current questionnaire implies that an expanded airport and PBN is good for those overflown and unless communities are aware of the hidden consequences, then it has to be said that, yet again, the airline sector is being disingenuous.
The simple facts should show current and future levels of noise and air pollution, the current level of road congestion and the net amount of public finance that will be required to back this flawed project are significant. The fact that clear flightpaths and the proposed breaking of the existing cap of 480k flights by a further 25k flights per annum from Heathrow were not clear when parliament was asked to vote on the scheme is yet another example of why people have a profound concern for balance within the establishment and our democratic system.
Is there a cap on the number of flights if a third runway goes ahead?
9. Any other comments.
Some parts of the airline industry have said that they cannot concede matters such as world-class ascent and descent levels and real night time bans (not merely scheduled night time bans). They say both will work against their commercial interests and therefore there is no incentive for them to expand. The counter to this is that if they truly support their growth then the trade off for a further 260k flights has to be a much bigger concern for the rights of those overflown. It is for the government to make the balance more even handed and hold the airline sector to account. Warm words will not be good enough there has to be statutory force.
10. Please give us your feedback on this consultation (such as the documents, website or events)
EGAG is disappointed that a consultation event was held in The Hythe Centre, Staines and no event was held in Englefield Green, an area that is much more likely to be affected than most, given its topography and proximity to the airport and the moving and lowering of the flight paths over time more towards Englefield Green.
With regard to the Audio Visual (AV) exhibit, we don’t believe this reflected adequately the indoors experience with the windows open or closed. In reality there was no discernable difference between the windows closed and with the sound installation included.
The most significant omission from the AV exhibit was the total lack of the portrayal of directly overhead PBN concentrated flight paths, that this whole Heathrow Consultation is predicated on, to reflect the flight path changes with aircraft flying over at 60 seconds intervals, above 65 dBs, as they will be with the 3rd runway and as was historically experienced with the 2014 concentrated PBN trial flights debacle.
A further significant omission with the AV exhibit was there was no attempt to demonstrate the AV experience when being outside, attempting to enjoy the amenity of your garden or recreational enjoyment of an outside open space, so important for health and wellbeing.
The presentations, as ever, were very professional and continue to explore the positives for the airline sector but conceal the consequences for local communities in terms of the environmental harm caused, giving instead warm words to the public without the balance of the reality that a minimum of 260,000 additional flights would cause, causing more air and noise pollution, 54,000 additional vehicle journeys per day to the airport compounding congestion for the southern half of the UK. If this project can be delivered both feasibly and more important politically then the distribution of this pollution must be equitable and shared out to everyone and it will be a travesty of natural justice if there is an unbalanced burden taken by any one community.
The website and the consultation documents are written in plain English but people have found the size and the complexity of the consultation daunting. There is still a strong sense of distrust with Heathrow arising from past broken promises.
25th February 2019