HACAN East Response to Newham Consultation on London City Airport Expansion

Posted on February 15, 2014

Dear Sir/Madam,

HACAN East (www.hacaneast.org.uk) represents residents living east of central London and with regard to this consultation, under the London City Airport flight paths. We also represent residents who live under Heathrow flight paths in the area.  In due course, the combined impact on residents Heathrow and City Airport flights needs to be assessed.  We live in East London and South Essex.   It is densely populated and has suffered a substantial increase in air traffic over recent years, particularly due to the massive expansion at London City and the recalibration of their departure routes, which has affected the people in our area more widely in terms of noise and annoyance.


Below is our response to the consultation: 

  • ·         Very often a re-organisation of airspace requires the flight paths to be changed.  It is flight paths which are all-important to residents.  We understand that, at present, it is not NATS' intention to consult again once it decides where to put the new flight paths.  This is a big mistake and inadequate.  Residents under London City Airport flight paths can only express a view when they know the proposed flight paths or any alterations. They can also only express an informed view when any changes to Heathrow are seen in conjunction.
  • ·         There needs to be a further consultation on the flight path implications of these airspace changes for all London City flights.
  • ·         For those under 4000ft, it cannot be assumed that, given their track record on "consulting", London City Airport will carry out an adequate consultation.  It needs to be carried out by NATS.
  • ·         The previous NATS consultation (NATS Terminal Control North: Proposed Changes to Airspace-East London and South East Essex Area) was extended after it was pointed out that it had been concluded without consideration to the expansion of London City airport by 120,000 flights which had been applied for around that time.  The same situation is again occurring now with the consultation closing before London City airport’s current expansion application has been heard by the London Borough of Newham.
  • ·         We understand the requirement under the European Union’s SESAR programme to reassess airspace so that more efficient use is made of it by allowing for more aircraft to use the airspace, but also to ensure that the CO2 emissions from each individual aircraft are reduced.  However, we have not found an adequate or understandable explanation of the amounts of CO2 that would be "saved" by using the "Point Merge" process. 
  • ·         The plethora of separate documents and annexes, coupled with the vast amount of "technical" data, particularly concerning Gatwick, renders the consultation inaccessible to even the reasonably knowledgeable "stakeholder" and incomprehensible to the layperson.
  • ·         The Airports Commission is currently reviewing aviation capacity in the South East. While the main thrust of its report does not focus on smaller airports, as London City Airport is in the South East it raises a number of issues. A Thames Estuary Airport would mean the closure of London City Airport (Source, NATS) and an enlarged Heathrow would mean increased aircraft movements of East London.  Clearly this needs to be factored into any changes. 
  • ·         We would support respite routes for London City, but it appears this option is not available.  Point 8.5 states that the consultation is “not considering respite options for London City routes in intermediate airspace”, because of “a complex interaction with Heathrow arrivals”.  Since the consultation on Heathrow airspace changes is not due for another two years, there is no information in this consultation about Heathrow arrivals or the possibility of changes to Heathrow routes.  It is therefore difficult to comment on alternative respite routes for London City, but we would nonetheless support further investigation into this matter.
  • ·         It is difficult, if not impossible, to comment on the impact of London City flights when the consultation does not consider the impact of all flights on an area, but only those from one or two specific airports, not including Heathrow, which has the largest percentage of air traffic in our area.
  • ·         The concept of respite would only work if it considers the removal of ALL air traffic from an area for a specific period of time and we would ask for this to be given further consideration.        
  • ·         We realise that the London Borough of Newham (LBN) is the Responsible Authority in terms of London City Airport, but NATS, the CAA and the Department of Transport should take a closer interest in the operations of London City, as LBN have failed to police the airport or ensure that agreements are adhered to, or enforced.  Since 2009 London City Airport have operated over 60,510 flights, breaching legally binding noise limits agreed with Newham Council – a shocking 21.44% of all flights over the period.
  • ·         Research compiled from the Airport’s own Performance reports between 2009 – 2012 show a mean averaged 60,510 of the total 282,151 flights have operated abovethe very
  • maximum noise level of 94.5 PNdB allowed at the airport.  This is unacceptable.  No penalties have been inflicted on the airport.  It continues unabated with Newham Council in the full knowledge that it is happening.   Because of this, submitted noise contours cannot be trusted.  Air Traffic Movement contours are wrong due to these breaches.  One aircraft, the RJ100, has operated 43,264 flights breaching the noise factors every year since 2009, yet remains operating at the airport.  Newham Council have taken no action against the Airport.
  • ·         London City airport were given permission in 2009 to increase flights by 120,000 per annum.  Currently this is at the early stages of implementation, so the impact of this upon our area in the future will be greater.  A further planning application is under consideration which will increase the number of flights at peak times from 36 to 45 per hour.  The number of stands under this application would increase from 18 to 25 to enable larger jets to be operated.  No information was provided in this application on the potential impact of bigger jets on flight paths.  We consider that such larger jets will need a wider turning circle on departure, which would in turn impact upon this consultation.
  • ·         It is bizarre that London City Airport is not participating in this consultation for activity under 4,000 feet when London City and Gatwick Airports are owned by the same company, GIP.  The two airports also, strangely, use different models when assessing noise.  GIP Gatwick have submitted strong evidence to the Davies Airports Commission suggesting that Heathrow’s use of the FAA INM model can produce a very different size and shape of noise contours from the CAA required model.  London City Airport uses the Heathrow INM Model to assess noise.  London City Airport has not used the model required by the CAA if an airport is to make an airspace change in the UK and as is also required in the current DfT Air Navigation Guidance document, which is the ANCON 2.3 model.  The models can produce very different results on an absolute basis, and potentially on a relative basis as well.  This is because, whilst they use the same base algorithm, the assumptions built into the CAA model are based on ACTUAL data of flight profiles and noise impacts for an airport, whilst the FAA use THEORETICAL assumptions.  GIP, Gatwick’s owners (and also London City Airport’s owners), claims to have followed the usual CAA practice employing ANCON 2.3, whereas Heathrow used the American FAA INM model as does London City Airport.  Gatwick notes that the American approach uses theoretical assumptions for flight profiles and noise impacts whereas the CAA model deals with actual flight and noise data.
  • ·         Given London City's track record and London Borough of Newham's failure to "police" it, we are distressed that this consultation excludes London City routes below 4,000 feet. Regarding this, Part "A" Paragraph 1.6's tiny footnote 2 says "….. London City Airport is in the process of determining how to best modernise its existing routes below 4,000ft in line with FAS and the forthcoming European requirement for ‘PBN’ routes (these are described in Paragraph 3.5); their intention is to match the position of today's flight paths as closely as possible. NATS and London City Airport is working together to ensure that the changes above 4,000ft and the route modernisation below 4,000ft are coordinated, however, for the time being London City Airport are progressing this work independently, and hence they are not co-sponsors of this exercise; the intention is to draw the two strands of work together in a joint submission for London City Airport routes in the latter part of 2014.".
  • ·         There is no information on whether this "joint submission" will be put out to consultation or whether those unfortunate enough to be blighted by the noise and annoyance from their routes under 4,000 feet will have the opportunity to comment or object. Without that information we are tempted to view this as a fait accompli. Can we have an explanation?
  • ·         If the current London City Airport expansion planning application is approved, it is likely that bigger jets will need variations on, or a larger turning circle on take-off, which would affect different and/or more people. No mention of changes in flight paths or their projected trajectory are included in that application but the bigger jets will need a wider arc to turn upon departure. Airspace under 4,000 feet being excluded from this consultation also, only further frustrates and annoys people living in our area as it appears we can only know those new routes once the consultation has reported and decided, with opportunity to comment remaining presently unknown!