“Plane Wrong” critical of CAA’s PIR decision to permit new easterly take-off route to continue
The CAA published its long-awaited Post Implementation Review report in early November. Gatwick is required by the CAA to change one westerly departure route (Route 4) that affects people in many villages to the South of Dorking and across to Reigate and Redhill. This has to revert back to being within the NPR (noise preferential route) as before. Local group, Plane Wrong, set up in response to the noise problems caused, says it welcomes the decision and wants this to be implemented rapidly so that residents do not have to suffer the noise for another summer. Plane Wrong is, however, dismayed at the CAA decision in respect of Route 3, which is not to be changed despite the fact that many more people are significantly affected by the change. This appears to have been entirely ignored. Plane Wrong has considerable doubts about some of the methodologies employed by the CAA to reach both these decisions. On the change to Route 4, Plane Wrong says the changes should be completed quickly, though the CAA has to test the change in simulators for Boeing and Airbus. They do not yet know when this work will take place. There is also a 2 month period that has to elapse after that, and there is no indication yet of when this will end.
Response to the CAA’s report of November 2015 in respect of the introduction of PBN for Gatwick Departures
- We welcome the decision of the CAA to require Gatwick Airport Limited (GAL) to change the westerly departure route (Route 4) and call for this to be implemented rapidly so that residents do not have to suffer the noise for another summer.
- We are, however, dismayed at their decision in respect of Route 3. The fact that many more people are significantly affected by the change appears to have been entirely ignored
- We have considerable doubts as to some of the methodologies employed to reach both these decisions.
The methodologies used
1 At no stage of the PIR process has the CAA considered noise actually measured on the ground. All their findings about noise have been based on theoretical models. We believe that this methodology may (in part) account for the considerable difference between what people are actually suffering and the CAA’s apparent views as to what they are experiencing.
2 The above failure to measure noise is compounded by the CAA’s selective interpretation of the Government’s Aviation Policy Framework. (See paragraph 4.37.) This interpretation provides their reasoning for stating that the environmental effect of the changes they authorised in August 2013 has not been significant.
Their choice of the 57dB LAEq 16 hour test set out in paragraph 3.17 of the APF combined with the unrelated noise test set out in paragraph 3.39 sets a high bar which greatly reduces the chances of noise which actually is significant being treated as significant by the CAA.
1 Although we are pleased that the CAA accepts that, under plans they originally approved, a large quantity of aircraft have been flying outside a long established NPR swathe since May 2014, we cannot understand why – as appears to be the case – the CAA is so relaxed about long suffering residents having to put up with another summer season (i.e. when windows and doors are open and when flights are at their most frequent) in which the NPR is regularly flouted. We think that to allow another season of stress caused by excessive aircraft noise in a once tranquil environment would be both unacceptable and unnecessary.
2 The changes the CAA have asked for should therefore be completed in the shortest possible time and ideally before the 2016 summer season starts in April. We are aware that, following discussions with the CAA, GAL has produced a revised design that is expected to take the route back inside the established NPR and we understand that the CAA requires this to be tested in simulators for both Boeing and Airbus. However, we do not know when this work will take place.
Also, whilst we know that approval from the CAA will be required after the simulation work and that there is then a 2 month period that has to elapse before implementation, we do not know how long this is expected to take.
It would be logical and helpful if the CAA and Gatwick were to collaborate and let local community groups see a draft timetable which would progress from today’s currently unsatisfactory position, via consultation with the public, to a new route being in place.
3 Nonetheless, we understand that it is likely that the new route within the NPR will benefit from only a limited degree of lateral dispersal. We believe that on balance an element of dispersal (similar to that which existed prior to the changes) would benefit the communities who live under or close to the flight paths.
The main reason for the new route being concentrated seems to be that the CAA and Gatwick are agreed on an industry-friendly interpretation of government policy. We do not accept that interpretation.
Further, we support all efforts to change government policy, so that it is accepted that there should be a fair and equitable lateral dispersal of aircraft both arriving and departing.
1 As we say above, we are dismayed by the CAA’s conclusion that the easterly departure route does not need to be changed.
2 Their reasoning here seems to be that outlined above – that their modelling does not indicate that the flightpath changes have made any previously quiet locations noisier, and even if they have, these locations are not significantly noisier. This erroneous reasoning is compounded by the methodology used to analyse the sources of noise complaints; here, the CAA simply made the decision not to associate any complaints arising in the Reigate and Redhill area with Route 3 flights. Given the increased number of complaints from this area since May 2014, this is perverse.
3 That there should be an increased number of complaints from this area is only to be expected. The new route affects more people significantly than the old one did partly because it is more concentrated (as the CAA accept – see para 9.33) and partly because more flights are flying closer to Reigate and Redhill.
4 So we urge the CAA to revisit their conclusions.
The CAA’s disappointing PIR finally published, showing only one Gatwick route to be slightly changed
Since autumn 2013 there have been changes to flight paths for Gatwick airport, given provisional approval by the CAA. Routes have been altered, and flight paths have been more concentrated. This has been done without consultation of affected communities. The CAA has done a PIR (Post Implementation Review) that ended in January. It has finally, after delays, published its findings. These are regarded as very disappointing, as almost no concessions have been made and though hundreds of complaints were sent in, there are few changes to routes. GACC says: “In a 198 page report they devote only 2 pages to the possibility of dispersal – spreading the aircraft over a wider area – and to the possibility of respite – giving people a break from constant noise. And then reject both. We will now need to take the case to the Government and indeed will raise this when we meet the Minister for Aviation, Robert Goodwill MP …on 18 November.” The more concentrated noise has caused great distress for the people unlucky enough to live directly under the flight paths. The only change to a route is one which takes off to the west, and flies over Holmwood, Brockham and Reigate – Gatwick will be consulting on a revised route in the next few months. People are angry that the CAA, yet again, ignores input from the public.
Sally Pavey’s comment on the CAA’s Gatwick PIR – it ‘ignored’ human cost of changed flight paths
Responding to the publication of the PIR (Post Implementation Review of Gatwick flight path changes since 2013, Sally Pavey (Chair of CAGNE) commented that it was “extremely disappointing”. It concluded that only the departure route taking off to the west, and heading north, had to change. Local group, Plane Wrong, welcomed that admission, but are dismayed by the CAA’s conclusion that the easterly departure route does not need to be changed. The PIR said a route towards the south-coast and another heading east were acceptable but should be reviewed by Gatwick; the remaining six routes did not need to change. Sally said the PIR now needed to be reviewed by the Aviation Minister, Robert Goodwill: “For a Government, in this day and age, to implement and subject residents to such an airspace concentrated system without any research into the noise readings or emissions from concentrated routes is beyond belief.” She added: “The noise shadow is far grater from a concentrated route than a dispersed route. It’s like having a country lane next to your home, which might see a few cars throughout the day and night, and changing it to the M1 overnight. The noise is relentless. Until the aviation industry recognise that concentrated routes create noise shadows these reports are pointless as they serve only the aviation industry and not the taxpayers.” The report offers little for people affected in West Sussex.