CHATR Statement On Heathrow Consultation
Advice for Chiswick residents on how to respond to current airport consultation
(Expanded Heathrow - 3 runways)
• Envelope Type: Arrival
• Height band: 2000ft to 3000ft
• Number of flights: 0-47 Flights per hour
• Number of these flights above 65 decibels: 0-47 Flights per hour
The Chiswick Against The Third Runway group (CHATR) has published its guidelines for residents who would like to respond to the current Heathrow Airport consultation. CHATR hopes that this may help with the complexities of the issues involved.
The Bedford Park Society has also issued consultation response guidelines which are more specific to its own location.
The deadline for response is March 4th 2019.
HEATHROW AIRSPACE AND FUTURE OPERATIONS CONSULTATION
1a. Do you support our proposals for a noise objective? Yes/ No/ I don’t
know
No.
1b. Please provide any comments you have on our proposals for a noise
objective:
We believe that Heathrow should be subject to regulatory constraints with
regard to the impact that its expansion plans may have on noise, air quality
and traffic but do not believe that Heathrow’s draft noise objective currently
goes far enough.
So, we believe it should state:
“To limit and reduce the effects of noise on health and quality
of life and deliver regular breaks from scheduled flights for our communities
during the day and night, in accordance with the Balanced Approach to
Aircraft Noise Management.”
This removes the words “where possible” and the references to
“proportionate and cost effective”.
The noise objective does not currently conform with nationally adopted
health and environmental protections. The proposed changes to airspace
should not go ahead unless Heathrow can commit to adhering to these environmental
protections. As the proposals stand there will be a massive increase in
the number of people affected which means that this protection assumes
even greater importance.
Independent Parallel Approach - 2 runways)
• Envelope Runway Info: I2 - Arrival route for southern runway for westerly
operations
• Height band: 5000ft - 6000ft
• Flights per hr 6am – 7am: 0-25 Flights per hour
• Number of these flights above 60 decibels: 0-2 Flights per hour
• Flights per hour after 7am: 0-6 Flights per hour
• Number of these flights above 65 decibels: 0 Flights per hour
• Up to 40 flights per day in total after 7am.
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:
We agree with measures such as incentivising the use of quieter
aircraft and requiring aircraft to use quieter operating measures. Restrictive
measures such as bans or quotas are likely also to be required to meet
the protections referenced in 1b.
We believe that Heathrow’s proposal that “the overall impact of aircraft
noise must be limited and, where possible, lower than 2013 noise levels”
has little credibility. Our view is that no matter how much the noise
footprint is manipulated this proposal will be impossible to achieve given
a 50% increase in flights.
We would also add that the measurement of these environmental impacts,
including noise, should be undertaken by an independent body so as to
provide reassurance to local communities of their objectivity and impartiality.
Respite through runway and airspace alternation
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? Please tick one of the following
options: A longer period of respite, but not every day/ A shorter period
of respite every day Yes / No/ I don’t know
No
2b. Please tell us the reasons for your preference:
Any reduction on overall respite is unacceptable and would have
harmful health effects. Both options offered result in an overall reduction
in respite.
A shorter period of respite every day would be the preferable option of
the two available. Aircraft noise is both repetitive and highly intrusive
and for these reasons respite is essential. There should be at least one
period each day when there is respite from the effects of this type of
noise.
2c. Please provide any other comments or suggestions you have on runway
and airspace alternation:
We would add there are currently no flight paths over the majority
of Chiswick (postcode areas W4 1, W4 4 and W4 5). This means that the
proposals to changes in airspace, which affect the area (design envelopes
IPA A1, IPA A2, A1 and D2) could not be implemented without contravening
design principles 6(b) and 6(f).
Directional preference
3a. Should we prefer westerly operations during the day and easterly operations
at night to reduce the total number of people affected by noise? Yes/
No/ I don’t know
No.
3b. Please tell us the reasons for your answer:
We strongly support an easterly preference during the night and
early morning. However, we also support an easterly preference during
the day.
The impact of night and early morning arrivals are particularly detrimental
to the communities overflown. Therefore every effort should be made to
minimise the number of people overflown by these arrivals in accordance
with design principle 6(f). This would be achieved by adopting an easterly
preference during the night and in the early morning when arrivals, which
would therefore be from the west, significantly outnumber departures.
Our experience of easterly departures is that they turn onto their course
relatively soon after departure and therefore would impact fewer people
on the more densely populated east side of the airport. This would minimise
the number of people overflown by these departures in accordance with
design principle 6(f).
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? Yes/ No/ I don’t know
No.
3d. Please tell us the reasons for your answer:
We have suggested above that an easterly preference should be
adopted both during the night and day. In practice, because of the prevailing
winds, this would in fact mean a 50:50 split between easterly and westerly
operations. This would reduce the likelihood of operations being continuously
in one direction and therefore reduce the need for intervention.
In very exceptional weather conditions we would be supportive of intervention
to change the direction of operations except where this lead to contravention
of design principles 6(b) or 6(f).
3e. Please provide any other comments or suggestions you have on directional
preference:
We would add there are currently no flight paths over the majority
of Chiswick (postcode areas W4 1, W4 4 and W4 5). This means that the
proposals to changes in airspace, which affect the area (design envelopes
IPA A1, IPA A2, A1 and D2) could not be implemented without contravening
design principles 6(b) and 6(f).
Night flights
Early morning arrivals
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) Option 2 – Use two runways for scheduled
arrivals from 5.45am (runway time 5.30am) Yes No/ I don’t know
Option 1.
4b. Please tell us the reasons for your preference:
Communities would benefit from a later start two out of every
three days increasing the overall amount of respite.
4c. Please provide any other comments or suggestions you might have on
early morning arrivals:
We believe that there are local factors mentioned in Sections
6 and 7 (both demographic and legal constraints limiting the ability of
residents to implement noise mitigation measures) which would make the
detrimental impact of night flights greater in Chiswick.
We would add there are currently no flight paths over the majority of
Chiswick (postcode areas W4 1, W4 4 and W4 5). This means that the proposals
to changes in airspace, which affect the area (design envelopes IPA A1,
IPA A2, A1 and D2) could not be implemented without contravening design
principles 6(b) and 6(f).
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 the proposed
scheduled night flight ban):
Landing fees should penalise all but the quietest aircraft landing
in the early morning. This should be used to manage the demand for slots
before 7.00am.
This would result in improved resilience over this early morning period.
It would also remove the need to introduce independent parallel approaches
(concentrated between 6.00am and 7.00am) thereby demonstrating Heathrow’s
commitment to the implementation of design principles 6(b) and 6(f).
Heathrow must continue to encourage the use of quieter aircraft. Our expectation
is that progress in this regard will be slow and should not be negated
by an increase in the number of arrivals at sensitive times of day such
as at night or in the early morning.
5b. Please provide any other comments you have on night flights and restrictions:
There is a large and growing body of evidence in relation to
the harmful health effects caused by night flights. The first step is
to recognise that the night should be defined as an eight hour period
as recommended by the World Health Organization.
The goal must be to progressively reduce the number of flights within
this period and the number of people affected. New navigation technology,
such as PBN, should be used in support of this goal rather than undermining
it as is the case with respect to the design envelopes proposed for independent
parallel approaches.
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 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:
We object in the strongest terms to any new flight paths directly
over Chiswick and therefore to the area being covered by any design envelopes,
and in particular two of the design envelopes for an expanded Heathrow
A1 and D2.
The proposed design envelopes contradict the design principles Heathrow
have agreed:
• 6(b) Minimise the number of people newly overflown
• 6(f) Minimise the total population overflown
There are currently no flight paths over North Chiswick, so new flight
paths over this area would, by definition, add to the number of people
newly overflown and would add to the total population overflown. Furthermore,
it does not promote principle 6 (g), Designing flight paths over commercial
and industrial areas.
Chiswick is a predominantly residential area with a large proportion of
families. Consequently the number of children in the area is high along
with related infrastructure including many nurseries and schools which
must be considered “noise-sensitive buildings”.
Chiswick also has a high proportion of listed buildings and therefore
the soundproofing options are severely limited due to the restrictive
listed building rules. For example, the replacement of traditional glazing
with double glazing is normally prohibited, leaving residents of such
properties with limited scope to mitigate the impact of aircraft noise.
These properties must also be considered “noise-sensitive buildings”.
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: Please tick the box if you would like your response to 6a
to be copied as a response to 6b.
For the same reasons as set out in the answers to 6 above we object
in the strongest terms to any new flight paths directly over Chiswick
and therefore to the area being covered by any design envelopes, and in
particular two of the design envelopes IPA A1 and IPA A2.
The above design envelopes could not have been created with greater disregard
for the design principles. They almost exclusively affect communities
not previously overflown contrary to principle 6(b). The ability to route
a flightpath over one community (not previously overflown) as opposed
to another community (also not previously overflown) within these design
envelopes does not resolve this contradiction.
These design envelopes also require aircraft to bank steeply thereby needing
more engine power and generating both more noise and pollution than would
be the case using the present glide paths. In this regard these design
envelopes are also inconsistent with design principle 6(a) Using more
noise efficient operational practices.
There appears to have been no attempt to evaluate the detrimental effects
of the independent parallel approaches nor has there been any parliamentary
scrutiny. This is particularly surprising given the concerns that exist
over the use of concentrated flight paths over densely populated areas.
8. Please provide any other comments you have relating to the airspace
elements of the consultation:
We wish to highlight and re-iterate that the airspace proposals
contravene the design principles Heathrow have agreed, in particular the
principle to minimise the number of newly overflown people.
We also wish to highlight that these proposals put economic and business
interests above the health of local communities, and this should not be
permitted.
We therefore object strongly to the airspace proposals.
General comments
9. Having considered everything within the consultation, do you have any
other comments?
We strongly object to the fact that Heathrow have failed to hold
a consultation event in Chiswick, an area of some 35,000 people who will
be very badly affected if the proposals were to be implemented, with so
many newly overflown homes (should Heathrow fail to comply with its design
principles). This leads us to question the validity of the consultation.
10. Please give us your feedback on this consultation (such as the documents,
website or events):
You state on your website that the questionnaire will take an
estimated 45 minutes to complete. This is a huge underestimation if people
are to read, digest and consider the material and respond thoughtfully.
This is an enormous burden on individuals affected by these proposals
and a serious impediment to participation. The consultation encompasses
extraordinarily complex issues which are not clearly enough explained
to enable readers to understand them within the timeframe allowed (a difficulty
shared by Heathrow representatives at consultation events), and include
questions that suggest binary answers are appropriate when they are not.
There is an assumption that residents can access the internet to review
the material, whereas in fact many residents are unable to do so. As such,
this is a deeply flawed process.
11. Please tell us how you found out about this consultation:
Leaflet through your door Newspaper advert Online advert Billboard/Outside
advertising Local radio/ Other (please specify)
National newspaper, then leaflet through letterboxes and local media website.
Signed:
Name:
Address:
Date:
February 13, 2019