EGAG suggestions for response to Heathrow Airpace and Future Operations Consultation – fuller version
Heathrow Consultation Questionnaire Danger for Englefield Green
Fuller version response
EGAG (Englefield Green Action Group) as an organisation continues to be opposed to a third runway at Heathrow. Although we are responding to a consultation which is planning for a third runway, nothing in our response should be taken as support for the new runway or the breaking of the legal planning limit of 480k flights per annum.
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
Question 1a. Do you support our proposals for a noise objective?
Question 1b. Please provide any comments you have on our proposals for a noise objective.
EGAG supports a reduction in noise to reduce health impacts but not Heathrow’s objective without qualification.
Heathrow’s proposed noise objective. The wording is ambiguous – Heathrow suggests the 2013 noise level be a limit but how this is defined and if and when noise will be reduced is pure speculation. “Regular breaks” is open to wide interpretation and in the case of the Englefield Green area, the current half a days respite each day will be reduced to quarter. “Proportionate and cost effective” could give preference to growth and aviation profits over environmental cost and ignores the “polluter should pay”. Heathrow’s local noise objective is similar to the national aviation noise objective but this is no reason to give unqualified support to either.
EGAG’s proposed additional noise objective. There is no national or local noise objective that allocates noise across Heathrow’s communities, which EGAG believes is essential if there is to be a fair and equitable distribution of the additional noise from Heathrow’s expansion. The EGAG proposed additional noise objective is:
Where there is a reduction in overall noise the benefits be distributed proportionately to those already most affected and where there is an increase in overall noise the dis-benefit be distributed proportionately to those already least affected.
The EGAG objective results in dispersion of noise and minimisation of the average noise per individual. In the absence of such an objective Heathrow has convinced the Civil Aviation Authority (CAA) that additional noise from expansion should be focused on those already experiencing noise while minimising the noise over those not already effected. EGAG regards this as unfair and inequitable and we continue to challenge Heathrow, the CAA and Government on the issue of concentration versus dispersion of flight paths and noise. In our view those already exposed to noise should not be additionally exposed by Heathrow’s expansion.
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”
Management of noise
1c. Please provide any other comments or suggestions you have on our proposed approach to developing a package of noise measures for an expanded Heathrow?
Balanced Approach. Heathrow supports an international approach to management of aviation noise called the Balanced Approach. This requires priority be given to reducing noise at source (i.e. the aircraft), land use planning whereby local authorities avoid noise sensitive developments being exposed to flights paths near airports and operational mitigation (e.g. steeper descents and ascents). Less noisy aircraft trends are gradual and insufficient to give urgent support for noise reduction towards World Health Organisation Guidance levels. Available operational improvements are relatively small. Therefore, restrictions such as a night flight ban and a cap on the number of flights and passengers are essential.
Noise Envelopes. These are not airspace design envelopes being consulted on. In due course Heathrow will develop noise envelopes that have a suite of noise constraints. They should include constraints imposed by the Airports National Policy Statement (APNS) approved by parliament in June 2018 in support of Heathrow’s expansion. They are mentioned in the consultation but without more detail there is not much that can be said, other than that effectively managed noise controls are essential. Managing Growth within Environmental Limits. The consultation refers to commitments Heathrow has proposed but there is insufficient detail for meaningful response.
The way noise measurement is averaged out is meaningless and is simply a way for
the industry to obfuscate the true harm to health that is being caused by aviation noise
– The World Health Organisation strongly recommends reducing average aviation
noise levels to below 45 decibels, as aircraft noise above this level is associated with
raised blood pressure, cardiovascular disease, stress etc. Protecting communities from
the harm caused by aviation noise should always take priority over commercial
interests of the airline industry.
Communities believe that the weight is biased too much towards the airline sector whose gain from a third runway and airspace changes far outweighs the trade off for less noise on the ground for those communities overflown. There will be more noise with a third runway.
We would recommend a reducing noise target from current levels fixed for an agreed time period which aircraft would need to comply with or face heavy financial penalties.
The proposed noise envelopes require full revision so that planes are flying at the highest possible levels over communities surrounding Heathrow. The 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 impacts of a third runway, and concentration. We are surprised that we are unaware whether the department of Health have published a report on these Health impacts.
Questions 2a, 2b and 2c (Section 3.1) – Respite through Runway and Airspace Alternation
With three runways we plan to revise our approach to runway alternation to make sure that all communities get respite from noise. We are also proposing to provide respite for communities further away from the airport by using airspace alternation. Respite = predictable relief from aircraft noise for a period of time.
Question 2a. 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?
Respite definition: A short period of rest or relief from something difficult or unpleasant.
EGAG suggests there should be respite every day but not shorter respite than at present as a consequence, i.e. there should be 8 hours of uninterrupted respite for residents in the Englefield Green area as at present and not reduced to 4 hours as proposed for the southern runway. With the limited information provided it is impossible to assess the noise impact of airspace alternation.
2b. Please tell us the reasons for your preference?
Existing exposure in Englefield Green area to aircraft noise. On westerly operations three out of the six existing flight paths (known as Noise Preferential Routes (NPR)), directly overfly the area, from both northern and southern runway.
Respite. Runway alternation was conceived to alleviate noise for those living under arrivals flight paths, by switching the arrival runway at 6:00am and 3:00pm each day so that aircraft would land on one runway between 6:00am and departures on the other runway, at 3:00pm operations switch runways. On the busiest one of those three flight paths, affecting our area, many people hear noise from both runways all day. Runway alternation, however, on the other two flight paths, affecting our area, does provide respite for 8 hours a day, for some.
Alternation can provide respite but often this is only partial due to multiple flight paths. Respite is a form of noise dispersion and respite for one community means noise for another; sometimes the effect is not equal and opposite for different communities. The consultation provides incomplete evidence on the health impact of respite and its variations in timing and length and integration within the patterns of noise.
Runway alternation with a 3rd runway. The consultation explains four feasible operating modes using runway alternation. A three runway airport logically has to always operate one runway in mixed mode (i.e. arrivals and departures at the same time) but for safety reasons the middle runway (current northern runway) cannot be operated in mixed mode.
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.
Also, as pointed out in HEATHROW’S AIRSPACE DESIGN ENVELOPES FOR
EXPANSION January 2019 document, it may be possible to hear overflight from
adjacent Design Envelopes, in Englefield Green.
Heathrow Community Noise Forum (HCNF) published “Englefield Green traffic analysis results December 2015” which showed that in the 10 year period up to the publication, aircraft had moved 400 metres closer and were flying lower over Englefield Green. The 2019 draft version for Englefield Green shows that aircraft are now a further 200 metres closer and lower still in this period; where will it end? People made life choices and paid a premium to live in Englefield Green, on the assumption that the area would not be blighted by additional aircraft noise and pollution.
The use of Performance Based Navigation (PBN), using satellite navigation as trialled in 2014, creating concentrated noise and flight paths of just 10’s of metres wide, with all aircraft travelling down those narrow corridors, instead of a 3 km swathe as currently, raised a public outcry.
Question 2c. Please provide any other comments or suggestions you have on runway and airspace alternation.
At the HCNF, the Community Noise Group’s (CNG) – EGAG is a founding member – challenge to Heathrow, the CAA and DfT, has been consistent over the past year or more where we have asked them to show us any examples, anywhere in the world, where the introduction of PBN has resulted in acceptable living conditions for those overflown.
As far as we are aware there are none; the industry has not been able to identify any. There are however vast numbers of lawsuits challenging these inhuman changes to PBN and concentrated flight paths.
Heathrow’s comment to the European Aviation Safety Agency on PBN implementation in the European air traffic management network, was (our italics and bold):
“Whilst Heathrow Airport Limited fully supports airspace modernisation, ….we have the following concerns: The Social Impact of PBN trials in the UK has been enormous, therefore this should be considered and not dismissed in one sentence. There does not appear to be an environmental assessment of this proposed change in terms of noise. ”
As has been acknowledged by Heathrow, there have been no community acceptable implementations of PBN worldwide, we hope that Heathrow does not also fall in this category.
● The new flight paths and therefore the respite should extend to at least 7,000ft.
● Departures and arrivals should not fly over the same areas.
A critical and as yet unanswered question by the DfT is the height at which aircraft pollutants cease to affect the local area. The United Nations’ International Civil Aviation Organisation (ICAO) state that it is 1000 metres, but the DfT foundation document (Airspace Navigation Guidance 2017) states it to be 1000 ft. This looks like a simple translation error i.e. the DfT using feet instead of metres. A Freedom of Information (FOI) to the DfT has resulted in no clarification and that further research is needed to determine what the true figure to be. This potentially has significant consequences for the effects of concentrated flight path changes over Englefield Green.
The topography of Englefield Green is ~ 200 ft (285 ft AMSL (Above Mean Sea Level)) higher than Heathrow .
The average height over the years of aircraft transiting Englefield Green has been
reducing and in 2018 stood at 3,310 ft above airfield height (3,500 ft in 2015; 3800 ft
in 2005), or 3,110 ft above Englefield Green.
3% of departures over Englefield Green are between 1500 – 2000 ft above airfield height or 1300 -1800 ft above Englefield Green;
10% of departures over Englefield Green are between 2000-2500 ft above airfield height or 1800 – 2300 ft above Englefield green; 20% of departures over Englefield Green are between 2500 – 3000 ft above airfield height, or 2300 – 2800 ft height over Englefield Green and 27% are between 3000 – 3500 ft above airfield height or, 2800 – 3300 ft height over Englefield Green.
Heathrow’s 3rd runway operations are stated to be quieter than 2013 by the year 2050, which means that it will be noisier up to that time if predictions are realised.
Currently there appears to be no cap placed on the number of flights, only that a minimum of an additional 260,000 flight must be achieved. Official documents estimate that 900,000 flights a year is achievable, i.e. an 87% increase with far greater potential for harmful noise impact.
To protect local communities and the harmful effects that this would cause to climate change, a cap must be placed for capacity commensurate with noise and climate obligations.
Question 3a, 3b, 3c,3d, 3e Directional preference.
With expansion, we want to use directional preference to manage noise. We have been testing whether this means we should change the ‘westerly preference’ that is in place at Heathrow during the day today. Our current thinking is that we should adopt a managed preference which can adapt to circumstances over time.
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?
3d. Please tell us the reasons for your answer.
The overriding principle must be to ensure that there are no more concentrated routes overflying than existingly suffered by residents.
3e. Please provide any other comments or suggestions you have on directional preference?
Directional preference gives a carte blanche to Heathrow to affect people’s lives which we do not support. 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 the noise may be minimised by insulation.
Questions 4a, 4b, 4c, 5a and 5b (Section 3.3) – Night Flights
With today’s two runway operation, Heathrow’s early morning arrivals land on one runway between 0430–0600. For an expanded Heathrow with three runways, we are looking at opportunities to schedule these early morning arrivals later, to provide a longer time without flights at night. We still need to maintain the same number of pre-6am arrivals as we currently have, but our aim is to start our operation later than today. This will mean we need to narrow the window within which these flights land.
4a. 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)|
|X||Option 2 – Use two runways for scheduled arrivals from 5.45am (runway time 5.30am)|
|I don’t know|
We have a preference for reduced night flights.
4b. Please tell us the reasons for your preference?
Dealing with departures only, WHO (World Health Organisation) have said that in order to protect good health, there is a requirement for 8 hours uninterrupted sleep. The Transport Select Committee recommendation was for a minimum of 7.5 hours. The Government and the industry have said that there will be only 6.5 hours of unscheduled flights. 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. We would oppose any earlier start time for departures.
EGAG is opposed to up to an extra 25,000 flights using the existing 2 runways, as it exceeds the legal planning permission limit of 480,000 flights per annum and was not part of the ANPS.
4c. Please provide any other comments or suggestions you might have on early morning arrivals
We would oppose any earlier start time for departures.
5a. Please provide any comments or suggestions on how we should encourage the use of the quietest type of aircraft at night (outside the proposed scheduled night flight ban)?
Quieter planes should be encouraged but their heights should not be reduced for commercial advantage as has been the case in the past, 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?
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 area 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 the 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 (285 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 Air Force 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 air forces 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
Royal Holloway University has over 10,000 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 taking into account as there is significant evidence showing the poor learning outcomes of those affected by aircraft noise including health and stress levels.
7. To answer this question, please look at the design envelopes for Independent Parallel Approaches (IPA) online using the postcode checker or look at them in our document Making better use of our existing runways. What sites or local factors should we be aware of in your area (or other area of interest to you), when designing new arrival flight paths to make better use of our existing two runways? Please give enough information (e.g. postcode, address or place name) for us to identify the site(s) or local factor(s) you are referring to and tell us why you think this local factor is important?
IPAs are new dedicated, concentrated noise and flight paths which would take place on the existing runways, without a third runway. These were not included in the ANPS voted for in Parliament. Heathrow argues they would enhance the resilience of the airport. There would be a number of these new flight paths from the holding stacks. They would join the final approach to Heathrow closer to the airport than aircraft currently do. They will impact on new areas, and for the first time arrivals would occur over Englefield Green specifically Arrivals I3 in the Consultation documents.. They will be lower than the current flight paths as they join the final
approach at between 4 – 8 miles from touchdown. They will be in place from about 2022 until 2026, if a new runway opens then, or they will remain in place if not. It may well be the case using PBN that Heathrow could increase the number of aircraft operating on the 2 runways significantly, if the 3rd runway does not go ahead.
Between 6am and 7am there would be a suggested maximum of 25 flights on these new approach paths. Between 7am and 11pm, there could be a total of up to 6 planes an hour on the new runway but Heathrow expects that, typically, there will be around 15 per day.
IPA was not part of the ANPS and 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 may mean narrower, dedicated and concentrated flight paths 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 more flights on arrivals overhead Englefield Green.
EGAG members oppose Independent Parallel Approaches. There is particular concern about the period between 6am and 7am.
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 flight paths and
the proposed breaking of the existing cap of 480k flights by a further 25k flights per annum, for its 2 runway operation, 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?
Q9 Having considered everything within the consultation, do you have any other comments?
EGAG welcomes Heathrow’s commitment to propose legally binding obligations in the event of a third runway to ensure that the proposed growth takes place within agreed environmental limits, however we do not know what those limits are and could as far as we are aware provide no constraints or safeguards to local communities.
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 protect communities from environmental harm, 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 the closest 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
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 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 for 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.
(on behalf of the EGAG)