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.
- 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.
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