Parish Council Heathrow Consultation Response

Published: 04 March 2019

 

4.    We expect that existing and newly overflown residents within the Parish could experience significant increases in overflights and noise disturbance and we would expect them to be offered adequate compensation dependent on full assessment of the impact. The proposed compensation offer must be detailed fully in the next consultation, including details on eligibility and terms and conditions and Heathrow should commit to clear timescales for the roll out of the proposed compensation package.

 

Question 1 – Managing noise at an expanded Heathrow

1a Do you support our proposals for a noise objective?

Having considered the draft noise objective, Windlesham Parish Council is supportive of its aim to limit and reduce the effects of noise for communities. In addition to the general aims stated in the objective, we would like to see a specific commitment that emphasises minimising noise arising from night flights in particular. It is also considered important that the objective should seek to limit the number of residential communities and people that are impacted by noise. This would help ensure that ambitions go beyond the limitation of noise, also seeking to minimise the number of people who are impacted by noise.

 

1b Please provide any comments you have on our proposals for a noise objective.

Heathrow needs to define what it means by ‘limit’ and ‘where possible’, otherwise the objective is too vague and open to wide interpretation. A clear objective that aims to reduce the effects of noise to protect the health and quality of life of impacted communities and makes reference to a scheduled night flight ban and predictable and regular respite from aircraft noise during the day is likely to be more meaningful to the public.

 

We consider that Heathrow should also set out a separate objective on night noise given the health costs associated with sleep disturbance.

 

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 support Heathrow’s commitment to a noise envelope and package of measures to manage noise that would be legally secured through the DCO process in line with the provisions of the Airports NPS.

 

The definition and design of the noise envelope and mitigation measures should be done in consultation with the Parish and take into account noise effects down to at least 51dBLAeq16h (the Government’s assessment threshold) and frequency of overflight.

 

Question 2 – Future operations for an expanded Heathrow          

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?

It is considered, due to the Parish’s position in relation to London Heathrow, that airspace alteration is likely to have a greater impact in our area than runway alteration, as the latter will mostly impact communities directly adjoining the Airport. However, we recognise the directional preference of arriving and departing flights will impact the Parish area and have therefore submitted comments in relation to this in the Directional Preference section of our response. In principle, airspace alteration and respite zones should offer less overflight to communities surrounding Heathrow than the current airspace pattern for both arrivals and departures. However, having reviewed the existing defined departure flight paths and the arrival patterns, compared with the proposed Design Envelopes, our interpretation of the information presented is that the proposed new arrangements would introduce an increased number of flight paths and more flight paths in areas that are currently not overflown.

 

We are concerned that whilst the proposed flight path alteration measures would provide respite from the flight path options indicated by the Design Envelopes, their implementation would still result in increased overflight and noise related disruption for Parish communities.

 

If, following London Heathrow’s consideration of the concerns outlined above, the potential new flight path routes demonstrated through the Design Envelopes are still to be implemented, Windlesham Parish Council would support the offer of respite to communities, through airspace alteration. In response to whether it would be preferential to have longer periods of respite less frequently or a shorter period of respite every day, it is considered that this is a subjective question, as different communities will have preferences that are specific to their own unique circumstances. However, we would expect airspace alteration to be operated fairly, ensuring all impacted communities are afforded equal levels of respite, as far as possible.

 

 

2c Please provide any other comments or suggestions you have on runway and airspace alternation.

No further comment.

 

Question 3 – Directional preference

3a. Should we continue to prefer westerly operations during the day and easterly operations at night to reduce the total number of people affected by noise?

 

It is acknowledged that currently, London Heathrow operates a westerly directional preference, meaning that the majority (70%) of night time aircraft arrive from the east, over London and take-off to the west, over Berkshire and Surrey. It is also understood from the consultation material that arriving aircraft are quieter than departing aircraft. The options for future directional preference presented are:

Westerly preference,

Easterly preference,and

No preference.

 

Having reviewed the options, Windlesham Parish Council considers that the operation of an easterly directional preference for aircraft arrival and departure would provide a fairer balance, which, in practice, would mean operating approximately a 50/50 split in easterly and westerly operations at London Heathrow due to the prevailing wind direction being from the southwest. However, from the information provided, we understand that an easterly directional preference could result in all night flights arriving from the west, once departure operations have ceased. This is not considered to be a reasonable approach for communities to the west and southwest of London Heathrow. Therefore, Windlesham Parish Council would suggest that intervention should take place to change the direction of aircraft arrival operations during the night period, to provide relief for communities to the west and southwest of Heathrow and to strike a fair balance for those impacted by noise. A ‘no preference’ scenario is considered undesirable for both London Heathrow and surrounding communities, as this would result in increased uncertainty and unpredictability of noise arising from aircraft operations, as a result of frequent changes in the direction of flight.

 

3b. Please tell us the reasons for your answer

No comment

 

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?

A system of managed preference to help deliver periods of relief for local communities if there has been a prolonged period of operating on easterlies or westerlies would help share noise impacts.

 

3d. Please tell us the reasons for your answer

There could be potential health and quality of life benefits from providing respite from prolonged periods of aircraft noise.

 

3e. Please provide any other comments or suggestions you have on directional preference

No comment

 

Question 4 – Early morning arrivals

4a. To help inform our consideration of the options, we want to know whether you would prefer for us to:

- Use one runway for scheduled arrivals from 5.30am (runway time 5.15am)

- Use two runways for scheduled arrivals from 5.45am (runway time 5.30am)

Without a comparison of number and location of people experiencing significant adverse effects in terms of noise, it is difficult to provide comment on the different options. Needless to say different communities will have preferences specific to their own unique circumstances.  

 

4c. Please provide any other comments or suggestions you might have on early morning arrivals.

It is disappointing that Heathrow Airport did not make it clear in the consultation last year when they asked for feedback on the timing of the proposed 6.5 hour scheduled night flight ban in the night period that the timing of the end of the ban in the morning is the time a plane reaches the airport stand rather than the time a plane touches down on the runway. Many of the public have been surprised, and may even feel they have been misled, that a scheduled ban finishing at 6am means that communities could experience noisy overflights from as early as 5.30am onwards.

 

 

Question 5 – Night flight 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).

Windlesham expects that only the quietest aircraft will operate for the full night period (11pm to 7am) and there should be financial incentives so that airlines are encouraged to do this as new, less noisy planes become available.

 

Furthermore, Heathrow should progressively reduce the amount of quota available for the period outside the proposed scheduled night flight ban. There should be regular review of the quota and this process should be included within the design parameters of the noise envelope in order to share the benefit of less noisy planes. There should be appropriate compliance mechanisms put in place.

 

5b. Please provide any other comments you have on night flights and restrictions

The fact that the runway time is approximately 15 minutes earlier than the scheduled time on arrivals and 15 minutes later on departures so that a 6.5 hour scheduled night flight ban means local communities could actually experience noisy overflights for a shorter period is likely to have come as a surprise to many of the public, who may now feel they have been misled. It is disappointing that Heathrow Airport did not make this clear in the consultation last year when they asked for feedback on the timing of the proposed 6.5 hour scheduled night flight ban in the night period.

 

There should be no earlier start time for scheduled departures (including freight flights) than the current 6.00am.

 

We consider that Heathrow should set out a separate objective on night noise.

 

Question 6 – Design envelopes for an expanded Heathrow

6. 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.

In terms of designing flight paths, they should be routed over less sensitive land uses such as commercial and industrial areas and reservoirs to reduce impact on residents.

 

The presentation of the design envelopes in the consultation documents takes no account of topography. Although this is recognised in the text in the consultation document, it is still potentially misleading as higher areas within a band are likely to experience more noise than lower lying areas.

 

Question 7 – Making better use of our existing runways (Independent Parallel Approaches)

7. 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.

Within the framework for noise management in Heathrow Airport’s draft Noise Action Plan 2019 – 2023 under the general commitment to quieter procedures, Heathrow Airport states, ‘We are committed to take full advantage of opportunities to manage airspace differently, working with local communities to identify changes that could benefit them. This will include trialling new airspace management and operating procedures.

 

Windlesham Parish does not support IPA. We cannot see how the proposals for IPA are in line with this commitment as they would represent a significant worsening of the current situation for many local communities across north Surrey, particularly in the early morning period between 6am and 7am. Many residents that previously would have had respite when the wind changed direction will no longer benefit and will be subject to adverse noise impacts from departing and arriving aircraft flying over them.

 

Furthermore, as the design envelopes for the IPA flight paths have to fit in to existing airspace and because of the complexity, the ability to give communities respite through flight path alternation is likely to be reduced as dedicated, concentrated flight paths are required. This would likely increase the adverse effects on health and quality of life for those beneath them.

 

The consultation document states that IPA flight paths will not be used by aircraft landing at Heathrow before 6am (which presumably means a runway time of 5.45am, but it would be helpful if this were clarified so there is no ambiguity as to whether this is runway time or scheduled time) and it is intended to be a temporary measure for the period 2022 – 2026, before the third runway opens. However, Heathrow Airport indicates that it intends to introduce IPA irrespective of whether the third runway is built to increase resilience and improve how current operations are managed during busy periods, such as the early morning arrivals peak, and the consultation document indicates that the IPA proposals will only be subject to the CAA’s Airspace Change Process. We are very concerned, therefore, that if the third runway does not go ahead there will be no legal obligation on Heathrow to not use IPA flight paths before 6am and they would be permanent.

 

In terms of designing arrival flight paths, they should be routed over less sensitive land uses such as commercial and industrial areas and reservoirs to reduce impact on residents.

 

The presentation of the design envelopes in the consultation documents takes no account of topography. Although this is recognised in the text in the consultation document, it is still potentially misleading as higher areas within a band are likely to experience more noise than lower lying areas.

 

Question 8 – Other comments

8. Please provide any other comments you have relating to the airspace elements of the consultation.

No further comments.

 

Windlesham Parish Council wish to be notified of the outcome of this consultation and to be kept informed of future consultations released by London Heathrow in respect of its expansion, changes to airspace and future operations.

 

Yours faithfully,

 

Sarah Walker

Clerk to the Council