TEDDINGTON ACTION GROUP PRESENTATION
To receive a presentation from a Teddington Action Group representative.
Minutes:
Stephen Clark from TAG and No 3rd Runway Coalition gave a brief presentation on the Heathrow Consultation and the main key points were as follows:
Ø Air Navigation Guidance 2017 set out the government’s key environmental objectives for aviation. They were:
o Limit and where possible reduce the number of people in the UK significantly affected by adverse impacts from aircraft noise.
o Ensure aviation sector made a significant and cost effective contribution towards reducing global emissions.
o Minimise local air quality emissions and in particular ensure that the UK complies with its international obligations on air quality.
Ø Noise minimisation had to be prioritised up to 4,000ft (unqualified) and 7,000ft (balanced with carbon).
Ø What did ‘significant adverse impacts’ mean? ANG states:
o Total adverse impacts should be limited/reduced, not numbers of people in any particular noise contour.
o Adverse impacts were health and quality of life costs.
o Adverse impacts grow as noise levels increase.
Ø Health impact costs were not nebulous – the fell back on quality of life, created urban blight and were a cost to the UK’s economy, falling back on the NHS and social services.
Ø How did the UK compare internationally?
o UK policy was based on the CAA’s Survey of Noise Attitudes SoNA (2017).
o WHO 2018 advise was for far lower levels of noise
o The WHO day threshold was 45 dBLden, roughly the equivalent to circa 43 dBLAeq.
o That was a vast difference to DfT’s 51 (LOEL) or 54 (significantly annoyed) dBLAeq.
o 3dBLAeq was equivalent to roughly doubling the number of noise events.
Ø Why did the UK have much poorer standards? The CAA was responsible for promoting aviation growth in the UK. It was funded by aviation and the DfT (it was not impartial). Yet it was given responsibility for undertaking the UK’s aviation noise survey. TAG’s criticisms of SoNA included:
o Unrepresentative sampling.
o Defensive approach having regard to unsustainable legacy noise policies
o Failure to recognise the importance of changes in the use of airspace on community annoyance.
o The above were fatal flaws as SoNA and webTAG (based around SoNA) were used to evaluate the impact of new runways and airspace changes in the UK.
Ø Heathrow’s Airspace Consultation – Q6. Factors for designing 3rd runway flightpaths:
o The noise envelopes were too low.
o Overflight – there would be insufficient space between many routes to achieve effective noise separation.
o Some areas suffer arrivals and departures
o They all relied on PBN for which there were no successful precedents in the world over densely populated areas.
Ø The presentation gave visual examples of international experience of concentrated flight paths.
Ø Heathrow’s Airspace Consultation – Q7. Better use of existing 2 runways:
o Affected areas will suffer both arrivals and departures with IPAs.
o IPAs will be at their busiest between 6 and 7am – 25 arrivals in the hour
o Due to be introduced in 2022 – if Heathrow doesn’t proceed IPAs could become permanent
o IPAs are based entirely on PBN – which would make areas unfit for human habitation.
Ø Heathrow said about PBN in 2016, in response to a European airspace modernisation consultation:
o Whilst Heathrow Airport Limited fully supports airspace modernisation, this document does not support current UK CAA guidance and is not in line with current UK airspace projects such as LAMP. The timescale suggested here is unrealistic and could jeopardise these projects. In addition, as subsequent comments highlight, we have the following comments:
§ The Social Impact of PBN trials in the UK has been enormous, therefore this should be considered and not dismissed in one sentence.
§ There does not appear to be an environmental assessment of this prolonged change in terms of noise.
§ The Benefit Section takes no account of the cost of airspace consultation which results in an incomplete assessment.
§ Mixed conventional and PBN operations are not supported by the UK CAA.
o Consequently, this NPA is not supported by Heathrow Airport Limited.
Ø Heathrow’s Airspace Consultation – Q1. Local Noise Objective:
o Unacceptable – seeks to qualify noise limitation against commercial considerations.
o This is counter to established UK Policy in ANG 2017.
o The acceptability of the respite proposals is unproven.
o Generally no health impact due diligence had been undertaken on the acceptability of any of Heathrow’s proposals – surely that should be an essential prerequisite to any airspace change (including development a 3rd runway).
Ø Heathrow’s Airspace Consultation – Q2. Respite:
o Heathrow’s proposals are unacceptable.
o Proposed respite is far less than today – only 4-5 hours break is offered a day.
o No research findings had been published on what level of respite was needed for health and wellbeing.
o No research had been published on whether sufficient separation between routes could be achieved technically.
Ø Heathrow’s Airspace Consultation – Q3. Operational Preference:
o This question is divisive – communities around Heathrow must stand together.
o Any change to operational preference should only be contemplated if Heathrow completely changes its approach to noise management.
o Heathrow should commit to using ‘best endeavours’ to minimise all significant adverse environmental impacts and to making all areas in its catchment properly fit for human habitation.
o The airport should also commit to fair and equitable noise sharing between all communities and work towards WHO standards.
Ø Heathrow’s Airspace Consiltation – Q4. Morning Operations:
o Neither Heathrow proposal in the binary question is acceptable.
o Alternation from day to day or week to week will in any event lead to broken sleep patterns.
o Medical advice for adults is 8 hours uninterrupted sleep; children need much more.
o Not acceptable to embed a 5.30am ‘wakeup call’ for all local communities effectively forever.
o Heathrow’s proposals even seek to erode the government’s 6.5 hour proposal by nit-picking on time in the air and ‘scheduled’ timings.
Ø Heathrow’s Airspace Consultation – Q5. Quieter aircraft at night:
o A night flight ban should mean a complete ban.
o Heathrow’s scheduling encourages concentration of departures late at night and consequently late running.
o There should be heavy financial penalties imposed on the airport for all flying at antisocial hours – these should relate to its health and wellbeing impacts under the ‘polluter pays’ principle.
o Heathrow’s charges to airlines on late evening and early morning flights should be based on the noise created, not charges per passenger.
Ø Final Thoughts:
o Heathrow’s consultation material is complex and potentially highly confusing.
o It asks the public to respond to inappropriate yes/no binary questions some of which are set to divide communities.
o Heathrow’s airspace design is based on PBN which is unacceptable over densely populated areas and its respite proposals are at best unproven.
o Due to this – and non-adherence to agreed Government adopted ANG policy the current airspace consultation should be called in from the CAA by the DfT and abandoned.
o IPA is being used to seek 25,000 additional flights before expansion. This was not included in the NPS nor subject to any previous consultation nor put to Parliament. This proposal should be dismissed by the Government.
The Community Protection Principal thanked Stephen Clark for attending the Forum and stated his coalition were in a similar position to that of RBWM so it was good that the two organisations were coming together. The Council echoed the sentiments that the Borough and TAG should revisit the noise envelopes and noise health studies. The current situation was unacceptable and the Cranford Agreement needed to be revisited. It was proportional and cost effective but Heathrow had shelved it. He added it was interesting because the results of the consultation depended on where your postcode was. You could input your postcode and get one set of results, but then put in a postcode of two streets away and get a completely different set of results. It needed to be reworked. Councillor Hilton endorsed the Community Protection Principal’s comments as he had noticed the same thing. You could put in the postcode of the Town Hall and get a different answer to that than if he was sitting at home and the Borough needed to make that representation. It should go out to Heathrow with a signature from the Leader on behalf of the Borough. The Community Protection Principal confirmed that action had been delegated to the Chairman of the Aviation Forum.
Councillor Hilton asked if the whole premise of the consultation was flawed, how can any individual respond and what was the factual truth. The Community Protection Principal confirmed it was the divide and conquer strategy so, Heathrow divided Windsor into three zones and coded the highest impact in green and the lowest in red. The postcode specific system did not show the holistic picture. The impacts would be shown differently to different areas that were just a couple of streets away. John Holstock stated he took part in a phone in on BBC Berkshire and it was evident the whole trial of Heathrow was to deceive the public. The benefits were that residents would get longer periods of respite and there was no mention of an additional 25,000 flights and no mention of pollution which caused 40,000 unnecessary deaths per year. The public had been told when Heathrow built Terminal 5 that it would be the last thing they constructed so it was evident, they could not trust anything Heathrow said.
Residents told the Forum that whenever anyone complained about noise, the government said to contact Heathrow. With this consultation, if complaining, complaints were to be sent to Heathrow, but there was no way of making those go wider than HR. Councillor Hilton stated he did not believe Heathrow was living up to its responsibility. The DfT was meant to be in charge of airspace but there was a big vacuum which was due to the DfT. Heathrow had said they would give communities technical support so they could challenge the data but, that support hadn’t come forward.
The Chairman stated there was a single person responsible for the noise, and that was the pilot as he controlled how the aircraft was flown and how much power was used and which direction the aircraft will be flown in at. Councillor Hilton said he put a post on Facebook about the consultation and it received 7,000 views and it was the highest interaction on social media any post had received. He explained to people how they could submit their comments in response to the consultation.
The Community Protection Principal stated he was taking two actions away from the Forum which were:
1. Draft a response to the consultation.
2. Produce a crib sheet from TAG and the No 3rd Runway Coalition.