HACAN East’s official response to City Airport’s flight path consultation

London City Airport’s Flight Paths Consultation

Response from HACAN East

We support the principle of airspace being used more efficiently but we object to these proposals.

We object to the proposals to concentrate the flight paths being introduced without planned respite.

  1. 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.

  1. 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.

Respite

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.

  1. 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:

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/207856/air-navigation-guidance-draft.pdf

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”.

  1. 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.

  1. 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.

John Stewart

Chair HACAN East

 

 

HACAN East’s submission to the CAA why the City Airport flight paths consultation should be reconsulted on

London City Airport’s Flight Paths Consultation

 Reasons why the consultation should be done afresh

We believe that the consultation was neither carried out with regard to natural justice nor according to the official guidelines set down.  We also argue the consultation was not consistent with current Government policy.

The background

London City is looking to concentrate its flight paths.  The result is that residents living under the concentrated flight paths will get nearly all, if not all, the aircraft flying over them.  When the east wind is blowing (about 27% of the time in a typical year), planes landing over South London will be concentrated in a narrow corridor over Eltham, Catford, Dulwich, Brixton, Stockwell and Vauxhall.  There will also be concentration on easterly take-offs over East London.  During westerlies, the take-offs will be concentrated over Bow, Leyton, Leytonstone, Wanstead, Collier Row and Havering.

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.

  1. The consultation against the laws of natural justice

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.  Considering the potential impact the changes could have on the affected residents, this is against the laws of natural justice.

  1. The consultation did not adhere to the official guidelines

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).

  1. The proposals were contrary to current 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.

 Respite

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.

  1. 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:

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/207856/air-navigation-guidance-draft.pdf

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”.

We are asking the CAA to require the consultation to be done afresh.

John Stewart

Chair HACAN East

London Assembly calls on London City Airport to reconsult on its controversial flight path changes

Press Release

 20/11/14 for immediate use

 London Assembly calls on London City Airport to reconsult on its controversial flight path changes

Yesterday the London Assembly called on London City Airport to reconsult on its plans to concentrate its flight paths.  The letter which was sent to the airport, the Civil Aviation Authority and government ministers was signed by the chair of the Assembly Roger Evans and supported by all the political parties.  It intensifies the pressure on London City to take action.  Tonight a motion is being put to Redbridge Council asking it to back the calls for a fresh consultation.  On Monday Leytonstone residents will be holding a public meeting at 7pm on November 24 at St Andrew Church Community Hall, in Colworth Road, Leytonstone.  This follows a packed public meeting staged by HACAN East in Wanstead two weeks ago.

 London City is planning to concentrate the flights paths in and out of the airport but has refused to leaflet or hold public meetings in the areas affected.  It has simply put technical information on its website.  Amongst the areas worst affected would be Bow, Leyton, Leytonstone, Wanstead and parts of Havering and Dagenham. South of the river Eltham, Catford, Dulwich, Brixton, Stockwell and Vauxhall are in the line of fire.

HACAN East chair John Stewart said, “The pressure is mounting on City Airport to carry out a new consultation.  The current consultation is simply unacceptable.  If it refuses to reconsult, there is a fair chance it will face a legal challenge.”

ENDS

 

Another Public Meeting to be held as campaign hots up against City’s plans to concentrate flight paths

Following the packed public meeting organised by HACAN East in Wanstead on November 10th to protest at City Airport’s plans to concentrate flight paths, local residents’ associations will be holding a public meeting at 7pm on November 24 at St Andrew Church Community Hall, in Colworth Road, Leytonstone.  All welcome.

It is part of a growing campaign.

  • At the Mayor’s Peoples Question Time held in Walthamstow last week Boris Johnson agreed that the noise from City Airport in answer to a question from HACAN East chair John Stewart.
  • At the same meeting all the political parties on the Greater London Assembly agreed to sign a letter initiated by Assembly chair Roger Evans (GLA member for Havering and Redbridge) calling on the airport to reconsult.
  • And on Thursday 20th Redbridge Council will debate a motion put forward by Cllr Sheila Bain and Cllr Paul Merry to write to the Civil Aviation Authority (CAA) asking for the current consultation to be scrapped.  The debate will be held at the full council meeting at 7.15pm next Thursday at Redbridge town hall in Ilford.

Send email objecting to City Airport’s flight path consultation

At last night’s public meeting in Wanstead London City came under fire for the poor quality of its consultation.  So did the CAA (Civil Aviation Authority) which is overseeing the consultation (see press release on the meeting as the next post).

We are looking for a fresh consultation.

Here is a letter you can email to the airport and the the Civil Aviation Authority who have overseen the consultation – this one email address takes it to both organisations: lamp@londoncityairport.com.  Feel free to adapt it as you wish and to encourage others to also email in.

I strongly object to the way you intend to concentrate the flight paths in and out of London City Airport over particular areas.  It is creating noise ghettos and is deeply unfair.

 I also object to the fact that you are refusing to tell directly the communities that will be affected what is in store for them.  You are holding no public meeting and are doing no leafleting.  Most people don’t even know what is on your website.

London City Airport is planning to concentrate its flight paths over certain areas.  But it has not told anybody.  The areas particularly in the line of fire are Bow, Leytonstone, Wanstead, Colliers Row, Dagenham, Hornchurch,  Catford, Dulwich, Brixton, Stockwell and Vauxhall.  It is deeply inequitable.

If you want to read the full consultation, it is at http://www.londoncityairport.com/londonairspacemanagement.   It started on 4th September and runs until 27th November 2014.

For more detail, read HACAN’s open letter to the airport – http://www.hacaneast.org.uk/?p=493 – and our blog:  http://www.hacaneast.org.uk/?p=491

Packed public meeting calls on London City to reconsult over flight path changes

Press Release

 4/11/12 for immediate use

 Packed meeting calls on London City to reconsult over flight path changes

A packed meeting last night called on London City Airport to reconsult on its controversial flight path changes.  Over 200 people crammed into Wanstead Library gave London City Airport a very tough time over its failure to consult local people and their local councillors over its plans to concentrate flight paths in a narrow corridor.

Roger Evans, the Greater London Assembly member for Redbridge and Havering said, “The decent thing to do is to re-run this consultation.”

HACAN East Chair John Stewart echoed his words, “As far as common sense in concerned, this is not a consultation.”

London City Airport is planning to concentrate departing in a narrow band over Bow, Leyton, Leytonstone, Wansrtead, Collier Row and Havering.  Planes arriving over South London will also be concentrated.  Lambeth Councillor Jennifer Braithwaite who attended the meeting said that she and fellow councillors knew nothing about the plan until contacted by HACAN East.

London City have put their plans on their website and told their consultative committee but refused to hold their own public meetings or leaflet the areas most affected.  The Civil Aviation Authority (CAA) also came in for a lot of criticism for allowing such a consultation to go ahead.

People at the meeting were urged to respond to the consultation which closes on 27th November.  But the meeting also resolved to write to the CAA and the Government calling for a fresh consultation.  People were also encouraged to sign the petition urging the airport not to concentrate the flights (1).

One local resident got a sustained round of applause when she said “I’m not a nimby, equity would be a fair share of this burden.”

ENDS

 Notes for Editors:

(1). The petition is at:  http://www.change.org/p/city-airport-stop-the-current-proposal-to-concentrate-departures-from-city-airport-over-a-narrow-corridor-of-east-london-bow-hackney-wick-leyton-midland-road-leytonstone-wanstead-barkingside-colliers-row?recruiter=9107754&utm_campaign=twitter_link_action_box&utm_medium=twitter&utm_source=share_petition …

For further information:

John Stewart on 0207 737 6641

City Airport confirm they will attend flight paths Public Meeting

London City Airport have confirmed they will attend the Public Meeting on their plans to change flight paths being staged by HACAN East on Monday 3rd November at 7.30pm in Wanstead Library.  The meeting is being held because City has refused to hold their own public meetings or inform residents directly who will be living under the proposed concentrated flight paths.  Leading members of the Greater London Assembly Roger Evans and Murad Qureshi will also speak at the meeting alongside HACAN East chair John Stewart.  There will be a lot of time for questions and discussion.

Meanwhile today the story hit the front page of the South London Press under the banner headline Plane Wrong.  It outlined the impact of the proposed changes on Sooth London: SLP flight paths.  

Leading GLA members to speak at City Airport Flight Paths Meeting on 3rd November

Press Release

 27/10/14 for immediate use

 Leading GLA members to speak at City Airport Flight Paths Meeting on 3rd November

Greater London Assembly members Roger Evans and Murad Qureshi will be speaking at a public meeting on Monday 3rd November called by residents’ group HACAN East to protest at the new flight paths London City Airport propose to introduce (1).  Airport representatives will also be at the meeting to answer questions.

London City is planning to concentrate the flights paths in and out of the airport but has refused to leaflet or hold public meetings in the areas affected.  It has simply put technical information on its website.  Amongst the areas worst affected would be Bow, Leyton, Leytonstone, Wanstead and parts of Havering and Dagenham.  South of the river Eltham, Catford, Dulwich, Brixton, Stockwell and Vauxhall are in the line of fire.

HACAN East chair John Stewart said, “There has been a lot of interest in the meeting.  People are furious that they have not been told about the changes.  As well as local residents, a number of councillors, some from as far afield as Brixton, are coming to the meeting.”

Stewart added, “The airport is saying that the changes are not significant.  We disagree.  They will be very significant for people right under the flights paths who will get a plane overhead every 90 seconds at the busiest times of the day.  We asked London City if they would organize public meetings in the affected areas but they refused to do so.  That is why we are holding this meeting”.

The flight path changes are part of a wider programme of reorganizing airspace across Europe.  More efficient use of airspace will allow airlines to journey times and so reduce fuel bills and cut emissions.

ENDS

 For more information:

 (1). The meeting will take place on Monday 3rd November 7.30pm in  Wanstead Library Spratt Hall Road, Wanstead, London, E11 2RQ

 

 

Petition to stop concentration of flight paths; Public Meeting

Sign the petition calling on City Airport to stop plans to concentrate planes over a narrow corridor of East London

PUBLIC MEETING

 City Airport’s plans to change its flight paths

 Monday 3rd November

 7.30pm

 Wanstead Library

 Spratt Hall Road, Wanstead, London, E11 2RQ

 

Public Meeting on Flight Paths

PUBLIC MEETING

 City Airport’s plans to change its flight paths

 Monday 3rd November

 7.30pm

 Wanstead Library

 Spratt Hall Road, Wanstead, London, E11 2RQ

Buses: 66, 101, 145, 308, W13, W14 all within a short walking distance

 About 5 minutes walk from Wanstead Underground Station

 The plan to concentrate the flight paths will have a real impact on places like Bow, Leytonstone, Wanstead and beyond into Redbridge and parts of Havering.  Below is a map from the airport’s consultation document.

London City Airport are consulting on changes they propose to make to flight paths.  They intend to concentrate all the flights over particular areas.  This would have a profound impact on these communities.  Yet few people have been told about the planned changes.

We asked London City if they would organize public meetings in the affected areas but they refused to do so.  We, therefore, have organized a meeting on the issue to which we invite you.

City Airport flight paths map