Airspace and future operations consultation

Section 1

The Five Areas of Objection:

1) Independent Parallel Approach
2) Night Flights
3) The Compton Route
4) Proposed Increase in ATMs
5) Penalty Fines

Independent

Parallel Approach SBC opposes the introduction of the Independent Parallel Approach (IPA) because it would:

• increase the number of early morning flights (from 6am);
• increase the frequency of disturbance, and
• require new flightpaths to be introduced with new communities being overflown

Furthermore, SBC has safety concerns and needs the necessary reassurance that the proposed, designated IPA safe zone (and inter alia danger zone) is deemed safe. There are operational conflicts between the proposed IPA and Compton route. It needs to be demonstrated that during blunder situations, emergency evasive manoeuvres are guaranteed to be safe within limits on the manoeuvre severity of both the blundering and evading aircraft.

Night Flights

The use of the term "Night Flight Ban" is a misnomer and causes confusion amongst communities. SBC's position is that it should be a complete ban, except emergency flights.

Night flight CAP (quota) - SBC is of the view that HAL's noise quota limits whilst having been reduced from 5100 to 2735 (summer) and from 4080 to 2415 (winter) are still too high.

SBC maintains that our communities experience far too many late running Air Traffic Movements (ATM), therefore, night time bans should be better enforced with greater penalties for infringements and for these to be passed to the communities affected.

Compton Route

It remains the Council's position that this route should no longer form part of Heathrow's airspace operations. It is both disappointing and disconcerting that this most problematic route both for Heathrow and SBC has not been included within this consultation.

SBC considers the Compton Route to be a poorly devised, low-flying, highly disruptive route, with its track holding and associated noise problems causing harm to the amenities of Spelthorne's residents.

It is anticipated that the technological advances advocated by HAL which form an intrinsic part of its Third Runway case will ensure that this route is completely removed and never repeated.

Proposed Increase in ATMs

SBC opposes the early release of 25,000 additional air traffic movements (ATM) per year across the existing two Heathrow runways prior to the build of a third runway.

The 'total impact' must not be lost because our communities are also overflown by aircraft operating at other London airports, and we experience a great number of helicopters movements, including military ones.

The recent World Health Organisation (WHO) sleep and wellbeing standards remain paramount in the consideration of any ATM increase.

The only circumstance where we may accept IPA, being one of the methods to facilitate the increase, is when the third runway is operational and subject to the following:

• the impacts on Spelthorne's residents living near the airport and those overflown have been fully assessed;
• the identified impacts are fully mitigated; and
• where necessary airspace has been redesigned to resolve problem routes such as the low altitude flightpath Compton Route, and without the introduction of new ones

Section 2

Airspace and Future Operations Consultation and Questions

Do you support our proposals for a noise objective?

Spelthorne Borough Council does not support HAL's proposed noise objective.

• HAL's proposal to 'limit and where possible, reduce the effects of noise on health and quality of life' is unacceptable, weak, and unquantified
• HAL's proposal to "deliver regular breaks from scheduled flights from our communities during the day and night" is without real meaning. HAL's proposed noise objective is too far in favour of providing benefits to the aviation industry and not enough benefit to communities in terms of protection from noise, especially for those living close to the airport

Any comments you have on our proposals for a noise objective

Research shows that exposure to excessive noise (such as that caused by aviation), causes significant health impacts, it also impacts on the ability to learn, and quality of life. HAL must ensure it rigorously strives to ensure that noise caused by its activities continues to be reduced.

The Aviation National Policy Statement has set a baseline for Heathrow as being the 2013 noise contour for the 57 dBA LAeq 16-hour metric, which encompassed an area of 108km2.  However, HAL has stated it will be a long time before Heathrow achieves its full ATM capacity if granted a 3rd runway. HAL must limit the growth of this contour from the start.

Since 2013, the 57 dBA Lea contour area has continually reduced. In 2014, HAL reported the contour area had reduced to 104.9 km2, in 2015 it had reduced to 102.5 km2, and more recently in 2017 the contour had reduced to 93.2 km2,  which was the smallest area for this contour since tracking started in 1988.

If HAL is serious about 'sharing the benefits of aviation' with local communities, and about protecting people's health and quality of life, HAL must put in place tough but achievable, quantified targets that are measurable against and protective of the 2013 baseline. HAL should therefore be looking to prevent re growth against the 2017 contour at the outset, and not setting its target at the 2013 baseline.

In light of the level of significant dos-benefits a 3rd runway will bring to the affected communities due to the negative environmental impacts, the proposal put forward by HAL for the provision of predictable respite from scheduled flights during the day and night is not a new benefit. This is because the proposed respite is a reduction from the 8-hours currently experienced by communities, and the scheduled night flight ban is just a formalisation of the voluntary ban currently existing at Heathrow.

HAL needs to demonstrate a greater sharing of the benefits that will be brought by the 3rd runway, as required by the 'balanced approach principle', which the aviation industry is legally required to share with its affected communities. To this end, HAL and the new Independent Commission on Civil Aviation Noise (IC CAN) must toughen up on the mitigation and the penalties for unscheduled night flights. One appropriate objective would be to limit the night flight quota and movement limits to those currently set, this would also support Heathrow incentives quieter aircraft at night.

Any other comments or suggestions you have on our proposed approach to developing a package of noise measures for an expanded Heathrow

Spelthorne Council fully supports the London Assembly's January 2019 statement that "the noise level thresholds used to map the area over which aircraft noise causes disturbance to residents should be reduced, taking into account the World Health Organisation (WHO) guidance. Spelthorne Council therefore believes that HAL should be providing a mitigation scheme that takes into account WHO guidance, especially for those communities affected by night time flights.

Spelthorne Council therefore agrees that IC CAN, should regulate noise disturbance more stringently, using lower thresholds for disturbance (taking into account WHO guidelines and the need for residents to keep windows open).

Compton Route

Spelthorne is concerned that the long promised removal of the Compton Route has not been included within this consultation. HAL will be carrying this out as a separate discreet consultation sometime this year. It is the Council's understanding that this will need to follow the same CAP1616 process route as this consultation, although HAL has not yet confirmed this.

Spelthorne Council is concerned that residents will have grown tired of the continual consultations they are being asked to consider, or simply miss that there is another important consultation which will look to address Heathrow's (and Spelthorne's) most problematic flightpath, the Compton Route.

HAL has assured Spelthorne Council that none of its new arrival or departure flightpaths will have the same track holding and noise causing problems that the Compton Route causes. In anticipation of the new flightpath that covers the Compton Route the Council is in full expectation that the new flightpath will be free of the existing Compton Route problems.

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?

Spelthorne Council would like to see its communities enjoy longer periods of respite, but not at the expense of having no respite for whole days at a time.

Any reasons you have for your preference

Communities currently experience 8-hours of respite, as such the proposed 4-5 hours of respite are not a gain but a loss.

With the implementation of a 3rd runway and higher operational efficiencies, it is not unreasonable to expect the respite periods to be at least equal to that currently experienced. While HAL has stated this is not possible due to the operational difficulties of managing three runways it has not presented a reasonable justification as to why regular respite of at least 8-hours is not achievable.

Any other comments or suggestions you have on runway and airspace alternation

HAL's proposals for runway and airspace alternation, the use of an easterly preference at night, and the intensification of aircraft taking off/landing/flying overhead will result in greater disturbances to communities.

The introduction of an 'easterly preference whenever possible' is for the direct purpose of reducing the total number of people exposed to disturbing noise. However, this proposal will greatly disadvantage the lives and health of residents to the west of Heathrow, especially the communities of Stanwell and Stanwell Moor who are close to the runway and will have their sleep routinely disturbed. The proposed airspace alternation does not offer respite for Stanwell or Stanwell Moor communities.

Currently, over 90% of all scheduled movements that operate during the night quota period are early morning arrivals. With the introduction of a 3rd runway (and the early release of 25,000 ATMs), as the number of ATMs increase the number of scheduled night time movements is also likely to increase unless the night quota is further limited. Spelthorne Council, therefore, proposes that as Heathrow amends its operations to reduce unscheduled night flights for recovery purposes, that the night quota and movement limit should be similarly reduced, rather than being increased by a third.

Spelthorne Council objects to the introduction of a directional preference that causes significant disturbance to the residents of Stanwell and Stanwell Moor. If this is to be taken forward HAL must take into account the significant impacts on the health and quality of life of residents. HAL must look to introduce mitigation measures designed to be protective of human health that takes into account WHO s recommendations of a night noise target LOA EL of 40 dB Knight, outside.

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?

Spelthorne Council objects to this proposal.

Reasons for your answer

Communities to the west of Heathrow would not only routinely have their sleep disturbed, they would then also be unfairly exposed to the greater noise of departures throughout the day.

Should we sometimes intervene to change direction of operations 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

Reasons for your answer

This would be more equitable and would provide relief to residents to the west.

To help inform our consideration of the options for early morning arrivals, 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);
• or don't know. Spelthorne Council's preference would be for the use of two or three runways for scheduled arrivals from 6.00am (runway time 5.45am).

The reasons for your preference

The implementation of more efficient procedures such as performance based navigation, along with a third runway, will enable Heathrow to land a higher number of aircraft in a short amount of time than current procedures allow. Given the significant health impacts caused by routine sleep disturbance HAL must give a more significant proportion of the benefits to residents who would be disturbed. Failing this, HAL must look to improve their noise insulation scheme as mentioned in 1c and 2c above.

The benefits as explained within the consultation documents seem to be weighted in the favour of the business benefits of the aviation industry rather than being fairly shared with the communities affected.

Any comments or any other suggestions on how we should encourage the use of the quietest type of aircraft at night (outside proposed scheduled night flight ban)?

Spelthorne puts forward the proposal for a reduced quota count and movement limit for the control of unscheduled night flights.

Spelthorne also supports rigorous auditing by IC CAN of all night flight movements, with the application of stronger penalties for infringements.

Any other comments you have on night flights and restrictions.

In its compliance reporting HAL should be reporting on the number of flights, the number of days over the year when night flights of all categories occur, and the number of days where residents are not disturbed by any category of night flight.

What local factors should we be aware of in your area when designing flight paths for an expanded three-runway Heathrow?

See attached maps and spreadsheet of locations we consider should be taken account of as particularly sensitive to noise in Spelthorne, comprising schools, nurseries, libraries, law courts, hospitals, care homes and places of worship. In addition, public open spaces and biodiversity sites within the Borough should be considered, which can be found on our Local Plan Proposals Map.

What local factors should we be aware of in your area when designing new arrival flight paths to make better use of the existing two-runways?

See attached maps and spreadsheet of locations we consider should be taken account of as particularly sensitive to noise in Spelthorne, comprising schools, nurseries, libraries, law courts, public open spaces hospitals, care homes and places of worship. In addition, public open spaces and biodiversity sites within the Borough should be considered, which can be found on our Local Plan Proposals Map.

Please provide any other you have relating to airspace elements of the consultation:

To minimise noise, flight paths must be designed to prevent overlapping flight paths, stacking, and low-level overlying, and flightpaths which have the same characteristic problems as the Compton Route.

Any other comments you have on the consultation

The Council fully supports the London Assembly's January 2019 statement that "the noise level thresholds used to map the area over which aircraft noise causes disturbance to residents should be reduced, taking into account the World Health Organisation (WHO) guidance (which looks for mitigation of aircraft noise above noise levels associated with adverse health effects).

Spelthorne Council therefore believes that HAL should be providing mitigation schemes that take into account WHO guidance, especially for those communities affected by night time flights. Spelthorne Council agree that the new Independent Commission on Civil Aviation Noise (IC CAN) should regulate noise disturbance more stringently, using lower thresholds for disturbance (taking into account WHO guidelines and the need for residents to keep windows open).

Feedback on the consultation process (e.g. documents, website, events)

Spelthorne Council is surprised by the volume of the consultation documents that HAL has been able to produce in the two months since the closure of the previous airspace change consultation, for which only limited documentation was available.

The consultation documents do not make sufficiently explicit that the use of performance based navigation systems will greatly increase the impacts of being directly overflown by aircraft using the new narrower flight paths, or that the frequency at which residents will be overflown will be greater and the intervals between them much shorter. This information should be clarified so that residents are able to understand this more clearly.

Spelthorne Council applauds HAL for the use of its radio commercials, however, the Council is concerned that these give the impression that the impacts of HAL's proposals for a 3rd runway and operational changes won't have a significant impact for many residents (unfortunately, instead they sound happy and sunny, almost like a TV commercial). They do not make clear to the listener the importance of 11 the proposals and the impacts they can bring to people who will be overflown or living near airports.

As with previous consultations, Spelthorne Council is again concerned that HAL is not providing detailed information about noise levels and the cumulative impacts on communities, especially those who will be affected by runway noise, which HAL should be in a position to readily produce. This again means that respondents to the consultation are being asked to make decisions without full-sight of the impacts. While HAL put forward that this is to prevent biasing the outcome of the consultation, it could be equally argued that HAL is biasing the outcome of the consultation by not providing information on impacts where it can.

Section 3

Further Areas of Concern/Clarification

What confidence can our communities have in HAL's promises and commitments in light of major Public Inquiries such as Terminal 5 wherein assurances were given that there would be inter alia no third runway. Moreover the more recent "enabling works to allow implementation of full runway alternation during easterly operations at Heathrow Airport" Public Inquiry paragraph 1147 of the Inspector's report (February 2017) acknowledges that "HAL argues that, even if 470,400 ATMs cannot be seen as a reasonable worst case, then 480,000 ATMs cannot be seen as a reasonable worst case either - in that for practical reasons 480,000 ATMs would never be scheduled."

Airspace Change - the consultation document states that typical savings are estimated to be up to 13 hours of arrival flight delay per day. Could HAL please explain what this means in terms of their operations, hours of use, number of flights per hours, length of respite?

Developing our approach to noise management - How long (in hours and minutes) does HAL believe residents should be able to sleep without being disturbed by aircraft noise? Could HAL advise how this document compares with the Heathrow Noise Action Plan? Turning to the issue of the 'Objective' this must be quantifiable in terms of noise. It is noted that HAL appear to present some 'health' based metrics, many relate to "reported" disturbance, whilst others relate to hospital admission information against specified illness. However, the use of these seem to be caveat ed against the impacts identified 12 in the EIA. In regard to regulation EU598, this requires that operating restrictions introduced to mitigate noise, taken in combination with other measures, are no greater than are required to achieve any noise abatement objective set by DfT; will this be quantitative? Could HAL please provide details of the Noise Expert Review Group?

Directional Preference - What is the current take-off and arrival situation at Stanwell/Stanwell Moor. Which directional operational option would have the biggest impact/change, taking into account arriving aircraft are quieter than departing aircraft and the frequency of ATMs in that area.

Making Better Use of our Existing Runways - HAL expects the average daily ATMs using the IPA flight paths and landing on the departure runway to rise back up to a similar number as those observed today, or slightly higher. Could HAL clarify what is actually meant here and when this is expected to happen?

Heathrow flightpath envelopes for IPA (2 runways) - The design envelopes seem to account up to the point of where the aircraft joins the final approach and therefore does not give noise information for below 1000ft. Could HAL advise on the numbers of houses and area affected for each option?

Heathrow flightpath envelopes for expansion - what are the noise levels for flights above 4,000ft and below the 60 dBA?

Compton Route

The Council would appreciate receiving further information and clarification of issues regarding the "Compton Route" including when it was introduced and if it was meant to be temporary? If it was meant to be temporary, what is HAL's definition of "temporary"? What are the earliest and latest scheduled departures over the borough using the Compton route? Following on, what is the latest time a scheduled departure is audible over the borough (including taxi, take-off, and flight over the borough)? What were the latest scheduled and unscheduled flights using the Compton route in 2018 (departure times and aircraft)? How is the Compton route impacted by IPA, are the IPA and Compton routes compatible? Could HAL please advise of the earliest and latest possible dates the Compton route could be abolished?

IPA

Would IPA increase the number of people overflown in the borough and how many more people could IPA newly overfly? What is the earliest time of day IPA would be used and the maximum period it would be in use? What type of 13 aircraft could use the IPA e.g. A380s, 747s etc? Finally what other UK and EU airports use IPA?

Unscheduled Flights

Theoretically what is the maximum number of night flights that could take place? Could HAL provide details of the latest unscheduled departure and arrival flights in 2018? Additionally, please provide details of how many unscheduled 'night' arrivals and departures took place in 2018 - (in total number of flights and days)? Further to this, on how many days were there no unscheduled flights in 2018 - ie no departures beyond 23:05 or landings earlier than 04:30?

How many 'bad weather' days required unscheduled landings earlier than 04:30 in 2018 and unscheduled departures later than 23:05 in 2018? Could HAL provide details of how many emergency situations required unscheduled departures and landings in 2018?

Could HAL provide details of how many emergency situations required unscheduled departures and landings in 2018? Furthermore please provide all details of the exceptional circumstances that interrupted normal schedule departures beyond 23:05 in 2018? How many exceptional circumstances days occurred in 2018, and what constitutes exceptional circumstances? Aside from emergencies, what are the 'acceptable' categories for unscheduled flights?

Finally, on how many days have technical problems with runway lights impacted on maintaining scheduled arrivals and departures?

Health/Noise

Excluding 'exceptional circumstances', period where residents won't be disturbed by night flights is between 1am and 04.30am, so 3.5 hours. How many people do HAL consider get overflown in the borough? What are the current health effects that HAL consider our residents are exposed to from aircraft? At what noise Lea contour does HAL believe residents' health is impacted? How many residents are impacted by aircraft noise - numbers by differing contours? What are the effects on health/quality of life from recent research? What are the expected health effect increases that HAL consider our residents will be exposed to a) up to the third runway opening b) beyond?

How many flights 'dumped fuel' to facilitate emergency landings in 2018? What's the lowest altitude non-RHS bound flights fly over the borough between 23:20 and 04:30?

What is the lowest noise level that HAL compensates for? What are the current compensation schemes, and when were they introduced? Have they been reviewed since then? If so, what changes were made to their eligibility criteria? How many residents have applied for noise insulation and been 14 refused? How many residents have applied for hardship property purchases and been refused? Could HAL please advise how many residential properties it owns in Spelthorne?