We object to the proposals to concentrate the flight paths being introduced without planned respite.
- Concentration without respite is inequitable
The plans will result in the residents living under the concentrated flight paths getting nearly all, if not all, the aircraft flying over them.
London City Airport argues that, since the chosen corridors are more than a mile wide, the routes will vary a little but the strong suspicion is, as the technology improves further, the aim will be to direct all the planes down the centerline of the chosen route. Tens of thousands of people will be impacted. North East London already has problems with noise from City Airport but in South London it tends not to be a problem because the routes are so dispersed. The proposed plans to concentrate will create a problem.
Indeed, London City is clear in its consultation document of the impact:
As we are seeking to replicate rather than redesign our existing routes, we expect that flights will still be seen in the same areas as today. The main difference would be that aircraft will follow the routes more consistently than they do today. This is due to the improved track-keeping ability of RNAV. Improved track keeping means that there will be less dispersion of aircraft either side of each of the routes; this would mean a reduction in the overall area regularly overflown, but an increase in the concentration of over-flights in some areas.
It is disingenuous for the airport to claim that the changes will be minor.
- Concentration without respite is contrary to Government policy
London City claims that it is following Government policy in concentrating without offering respite. Our view is that it is mistaken. It is worth quoting at some length the Government’s advice to the CAA on concentration and respite:
While the CAA should follow a policy of concentration in most cases, the Government recognises that there may be local circumstances where the advantage lies in dispersing traffic, for instance when considering multiple routes, and NPRs where relevant, for the purposes of providing noise respite over areas which may be considered to be noise sensitive.
It is important that any decisions about whether to concentrate or disperse traffic take account of the local context alongside the operation and generic environmental objectives presented in this Guidance. This local context may become apparent through appropriate consultation with the local community (see Chapter 9 of this Guidance). The Aviation Policy Framework reaffirmed the Government’s view that it is important to consider exploring options for respite wherever feasible for those already affected by noise, especially where frequency of movements has increased over time.
- The Government therefore encourages airports and airlines to work with the CAA, NATS and their local communities to consider creative solutions to protect and enhance the use of respite as a means of mitigating the impact of aircraft noise.
7.10 One such example is with the shift to PBN which is expected to be introduced widely in the UK over the coming years. The Government would therefore like to encourage airports, along with NATS and the CAA, to consider how PBN could be used to introduce an element of alternation for respite purposes, providing that this brings a noise benefit and where this is appropriate given local circumstances.
7.11 Other opportunities for arrivals such as varying joining points and reducing the amount of airborne holding are also encouraged as are trials which seek to understand the benefits and impacts of respite measures on local communities.
7.12 When seeking opportunities to provide respite for those already affected by aircraft noise it is important that decisions about respite should always be made after considering the specific local circumstances and through engagement with the local community.
The full document is at:
We would argue that London City has not followed the guidance, in particular where it says: “One such example is with the shift to PBN which is expected to be introduced widely in the UK over the coming years. The Government would therefore like to encourage airports, along with NATS and the CAA, to consider how PBN could be used to introduce an element of alternation for respite purposes, providing that this brings a noise benefit and where this is appropriate given local circumstances”.
- The quality of the consultation has been poor
London City has only put its consultation documents – quite technical documents – on its website and told its Consultative Committee about its plans. It did not directly tell local authorities, MPs, Greater London Authority members or local residents. It refused to hold public meetings in, or leaflet, the affected areas.
London City argues that its consultation adhered to the guidelines laid down by the CAA –http://www.caa.co.uk/docs/33/20130819PBNSIDReplacementReviewProcessFinal.pdf
This is open to some doubt. It revolves around the airport’s interpretation of the extent of the changes which are being introduced.
The basic CAA guidance for consultation on route changes is laid out in paragraph 6.1 of the document:
6.1 The introduction of replicated SIDs to replace existing conventional SIDs requires an Airspace Change Proposal (ACP) as defined in CAP 725 (Introduction paragraph vii (c)). In this instance the use of Local Airport Consultative Committees (LACC), together with any additional stakeholders deemed appropriate (e.g. local environmental groups etc), may target consultation to those directly affected thus avoiding un-necessary consultation with stakeholders who will not be affected by the introduction of a PBN replication of a conventional SID.
If the proposed changes are minor, less extensive consultation is required. Paragraph 11.1:
“11.1 Depending on the degree to which RNAV 1 / RNP SIDs are able to replicate conventional SIDs, it is expected that, in most circumstances, consultation can typically be satisfied through established consultative committees / forums, with additional representation agreed at the Framework Briefing. Therefore, LACCs, regular airport operators groups (such as airport Flight Operations Sub Committees), and interested parties, without the need to include all the authorities and environmental groups as detailed in CAP 725 Stage 2 paragraph 9, may form the consultees stakeholder group”.
We argue that, because the proposed changes impact the quality of life of tens of thousands of people in a significant way, the consultation London City has carried out (as laid down in paragraph 11.1 of the CAA guidance) is not adequate and that the airport should have been required to carry out the wider consultation (as laid out in paragraph 6.1 of the guidance).
We shall be writing to the CAA about this.
- The emissions benefits are uncertain
It is correct that making more efficient use of airspace should reduce the emissions from each aircraft. However, if the Point Merge scheme has the effect of pushing stacks much higher up (in altitude), it could increase emissions as it is accepted that emissions at higher altitudes have a more serious affect on the atmosphere and climate in terms of heating, the principle of radiative forcing. Before any new scheme is given ahead, the overall impact on greenhouse gases needs to be fully assessed.
Chair HACAN East
Some other recent news stories about London City Airport:
Packed public meeting in Wanstead calls on London City airport to reconsult over flight path changes
There is growing anger in areas affected by London City Airport flight paths, because of the inadequate consultation they have launched – it ends on 27th November. On 3rd November, there was a packed meeting in Wanstead, which called on the airport to re-consult. Over 200 people crammed into Wanstead Library and gave London City Airport a very tough time over its failure to consult local people, and even their local councillors, over its plans. The airport wants to concentrate departing flights in a narrow band over Bow, Leyton, Leytonstone, Wanstead, Collier Row and Havering. Planes arriving over South London will also be concentrated. Most councillors knew nothing about the plans until contacted by HACAN East. The plans are on the airport website, but the airport has not put out leaflets or held any public information sessions. Roger Evans, the GLA member for Redbridge and Havering said, “The decent thing to do is to re-run this consultation.” The CAA has been criticised for allowing this poor consultation. People have been encouraged to write to the CAA and the Government calling for a fresh consultation, and sign a petition against concentrated flight paths.
People in Waltham Forest have criticised London City Airport for not informing residents on proposed flight path changes
London City Airport has a current consultation on the use of high-tech satellite navigations (RNAV) in planes, which would result in a narrower flightpath over Wansted, Leytonstone, Leyton and Barking. Under the plans, most planes travelling to and from the airport would use a ‘flight corridor’ over Waltham Forest and Redbridge, leading to concerns over noise disturbance. Campaign Group HACAN East called on the CAA to stop the process, which it says has not directly consulted people living in either area. Now the deputy leader of Waltham Forest council has written to the head of City Airport and urged him to contact residents. The airport is claiming there is hardly any change, as it is just that planes will follow routes more accurately. The reality is that they will be concentrated along a narrow line, at the centre of the previously wide path swathe. HACAN East is organising a public meeting on 3rd November in Wanstead, as the airport has neither leafleted affected areas, nor arranged a meeting.
Open letter to London City Airport asking that they consult properly on flight path changes, and treat people fairly
London City Airport is proposing to concentrate flight paths, in the same way that other airports have been doing recently. This is how air traffic controllers, NATS and the CAA want airspace to be used in future, in order to fit more aircraft into our already very crowded skies. However, London City Airport decided not go give any prior notice to anyone about the changes, except their Consultative Committee, or any warning about the substantial increase in aircraft noise for those unlucky enough to be under one of the new concentrated routes. It seems even local councils were not notified. Local community group, HACAN East, have now written an open letter to the airport, to complain. HACAN East says the flight path proposals will have a profound effect – for the worse – on the lives of tens of thousands of Londoners. This is deeply inequitable. While the airport makes out that the proposed changes are not significant as the planned flight paths are not noticeably different from the current routes. That is incorrect. There is now a concentrated line. Thousands living in Bow, Leytonstone, Wansted, Catford, Brixton and Vauxhall are very well aware there is a significant change. And that these are seen as unfair.
HACAN East suggested letter of objection to London City Airport re: its plans to concentrate flight paths
London City Airport are conducting a consultation on airspace changes, which started on 4th September. It ends on 27th November. It aims to concentrate flight paths, in line with the intentions of UK air traffic control service, NATS. Concentrating flights along narrow corridors is more efficient for air traffic control. Instead of a swathe of perhaps 2 miles wide along which planes are directed, they can now follow a 100 metre track. This means fewer people in total are overflown; but for those unlucky enough to live under the new concentrated route, the noise can be deeply unpleasant. London City airport chose not to give any warning about the changes to local councils or local residents. It is not leafleting any areas, nor holding public meetings to explain the proposals. The areas particularly affected are Bow, Leytonstone, Wanstead, Colliers Row, Dagenham, Hornchurch, Catford, Dulwich, Brixton, Stockwell and Vauxhall. It is deeply inequitable. Local campaign group, HACAN East, will be holding a public meeting. They also have a simple template letter people can send in, to express their views. The lengthy consultation document is hard for laypeople to clearly understand.