Heathrow Expansion Consultation Response
We are a network of local people across South East London with one thing in common: our wellbeing is threatened by arrivals coming into Heathrow Airport (LHR). These low flying planes have a hugely detrimental impact on our quality of life in a way that did not exist before we moved in to our areas.
We live in areas like Brockley, Camberwell, Dulwich, Eltham, Greenwich, Lambeth, Lewisham and Peckham. We want changes to flight paths that are fair for everyone across London and we oppose a third runway at Heathrow.
Plane Hell Action responds to the Airspace Principles in part 2 of the consultation as follows:
We take issue with the statement on page 3 of the consultation document, that the number of people within Heathrow’s noise footprint has fallen by 90%. This is due to the use of inadequate measurement principles which completely fail to capture the experience of people in South East London. Noise from arrivals to Heathrow is not just a West London issue- it concerns people across London, as Heathrow arrivals join the descent paths to the north and south runways up to 18 miles from the airport- over areas like Greenwich, Brockley, Lambeth and Walworth.
South East London receives no relief from plane noise in the way that West London benefits from the use of runway alternation. Planes cross swathes of South East London in a nose-to-tail frequency from before 4.30am until after 11pm. This is unacceptable. They cross and turn in a trombone shape to join the final approach and this blights people’s lives.
In an area where westerly winds prevail for over 70% of the time, Heathrow is simply in the wrong place – requiring arrivals to fly over densely populated residential areas across London. This has led to a situation where 28% of people suffering from high levels of aircraft noise in Europe are affected by one airport- Heathrow. Because of this, Heathrow is under a huge moral obligation to push every technical boundary to disperse flights, not concentrate them.
Airspace design principles
Principle 1 (A)
By forcing planes into narrow routes, the same people are affected more and this affects community wellbeing. The idea of minimising the number of people overflown, to free others from noise, is a crude utilitarian calculation that fails to respect the rights of people to live in an environment that is not overwhelmed with noise pollution. This proposal is not acceptable.
Principle 1 (B)
This proposal involves unacceptable concentration of flights over areas already blighted by aircraft noise. It would condemn those communities to increased levels of blight and becoming noise sewers. It fails to respect the rights of people to live in an environment that is not overwhelmed with noise pollution. It is not acceptable.
Principle 1 (C)
This proposal might have some merit in that it seeks to share aircraft noise over a wider area by using multiple flight paths and therefore reduce the overall impact on any one community. However, it is not made clear whether this proposal would involve the use of consecutive movements along the same route. If so, then this option equates to concentration along multiple routes and would be unacceptable. We would want to see genuine dispersal of flights to minimise intensity of overflying over any one community across the entire day.
Principle 2: urban and rural areas
We do not agree with the assertion that urban areas across the board have higher levels of noise. Many of the areas across South East London in which Plane Hell Action members are resident are in fact very quiet, and we benefit from a large number of parks and open spaces, with fewer major roads than many other areas of London. The intrusion of aircraft noise in our peaceful communities is therefore substantial and undermines our quality of life and wellbeing. We do not therefore regard the proposal to distinguish between urban and rural areas as meaningful in relation to the design of future flight paths, and would oppose any bias towards routing flights over urban areas on the basis of supposed higher noise levels.
Principle 3: urban areas
We do not believe that the suggested distinction between parks and residential areas is a meaningful consideration, given that both will be negatively affected by aircraft noise, and that noise is spread over such a wide area that routing planes over residential areas or parks is unlikely to make any significant difference to the number of people negatively impacted by aircraft noise across either. For us, the fundamental issue is whether Heathrow will commit to a radical redesign of flight paths, creating multiple approach routes, and using these to disperse flights, without the use of consecutive movements along the same approach route. Given such an approach, this would share the burden of noise very widely, making questions like this one less relevant due to no one area being blighted, and noise being distributed much more fairly across Greater London and surrounding areas.
Principle 4: noise and emissions
Our priority is the reduction of noise, through the creation of multiple approach routes, and using these to disperse flights, without the use of consecutive movements. We therefore oppose the prioritisation of reducing emissions over addressing noise. We want to see Flight Management Systems upgraded to allow many programmable routes for dispersal, as well as GBAS, which allows closer approaches to be used along with PBN. PBN that increases concentration is not acceptable.
Principle 5: technology and innovation
We strongly support the introduction of the latest Flight Management Systems and use of GBAS. We believe that older aircraft which cannot, or are not upgraded to, work within a new system of multiple approach routes, should not be permitted to use Heathrow. As stated above, 28% of people suffering from high levels of aircraft noise in Europe are affected by one airport- Heathrow. The airport therefore has a huge moral duty to use airspace modernisation for good. And that means creating multiple approach routes, and using these to disperse flights, without the use of consecutive movements along the same approach route. Were PBN used as per option 1(B) or (A) it would be an outrage and condemn communities to suffer depleted wellbeing within noise sewers. Heathrow has a moral duty to achieve the most technologically ambitious redesign of flight paths to ensure that it can disperse flights, and respect the rights of communities to be free from noise blight.
Principle 6: night flights
The commitment to 6.5 hours free of night flights is a move in the right direction, but most of us want to sleep for more than 6.5 hours. To that end, the proposal is inadequate and needs to at least reach 7 hours to begin to be meaningful in terms of the rhythm of people’s lives and allowing communities to enjoy a genuine night’s sleep free from disturbance.
Regarding use of the newest and quietest planes, Heathrow needs to focus on the quietest planes, not just new planes, as those such as A380s are not in any way quiet and are a source of intense noise pollution. Equally, Heathrow needs to do more than just ‘encourage’ the use of the quietest planes. It should be required, and violations should incur severe financial penalties which seriously deter airlines from violating this requirement.
END OF REPONSE
Deadline for response: 28 March 2018.
How to respond: A simple letter or email is as good as completing the Consultation response form.
or by letter: Freepost LHR Expansion Consultation
And please send a copy of your response to your MP