TAG Responds to Matt Gorman on the Value of the HCNF

We attended a Heathrow Community Noise Forum meeting in September and Matt Gorman wrote to community groups to explain the valuable work it felt it delivered in engaging with communities after several community groups expressed their frustration which prompted this response from the Director of Sustainability and Environment for Heathrow. We followed up to the response clearly stating that we needed to see action, rather than more talk. This has not been the first time that community groups have raised questions over the seriousness of the HCNF. Both letters are below.


Dear TAG,

I wanted to write further to last week’s Community Noise Forum (CNF) which felt a little heated at times. I believe that shows the level of concern from community groups about the impacts of aircraft noise and a desire to see the industry take action, and, from my side, a passion for Heathrow to be doing the right thing.

Our intention in setting up the CNF was based on a genuine desire to improve our engagement on these issues and work with community representatives on finding ways to improve noise both now and also in the future with airspace modernisation. The nature of the issues we discuss mean this will be difficult at times but it is far better than the alternative, where there is no constructive engagement or challenge.

I have set out some of my own reflections on the CNF process to date and also proposed some tangible steps from our side to improve the process. This is a relatively new Forum for all of us and it is valuable to take stock and refine things as we go.

I have three main reflections on the Noise Forum process to date:

  1. Much of the conversation we have been having has been a two-way education process: the community educating the industry about the impacts of noise and the industry setting out how its different constituent parts (airlines, airport, NATS) work together and what we can (and in some cases cannot, at least immediately) do to improve things. My view is we are still building a common language to have that conversation.For much of 2015, a common message from community groups was that flight paths hadn’t reverted back to pre-trial patterns. The industry response was to look at a 2D map and say that they had. In reality some of the community concerns (leaving aside the “Compton Gate” change which affected some communities) were driven by underlying changes that in most cases had been happening over a period of years and were not related to the trials, but could nonetheless make a perceptible change to noise on the ground. These include for example, the average height of the aircraft getting lower in some areas, and more aircraft using some departure routes as a result of airline choice. We have now gathered more granular data on these issues which enables us to evaluate what can be done to improve things while avoiding unintended consequences. For me this shows the value of the process.
  2. It is absolutely right that Heathrow and the wider industry should set out a series of improvement actions that we are taking and that we are prepared to be held to account on. As I look at the work plan of the Forum, I see a number of tangible actions being taken which would not have happened if the Forum did not exist, or at least would not have happened as quickly or with the same degree of community involvement. These include:
    1. Installing 38 new noise monitors to total 50 instead of the current 12.
    2. Working with airlines towards a trial of different departure procedures and climbgradients to understand the noise impacts of aircraft departing higher.
    3. Creating a new set of metrics to better describe noise in terms that are meaningfuland relevant to communities.
    4. Looking at options to more equitably share late evening departures, whilerecognising that the long-term goal is to avoid late running aircraft.

As important is that the industry communicates clearly when things are not possible or at least not possible in the short term or without support from regulators or policy-makers. Not to do so creates false expectations and makes the community relationship worse in my view.

Taking the example of aircraft heights again, it is not clear from the evidence that we have to date that a steeper climb gradient would improve noise for everyone. Hence the commitment to model and trial it in real-life, to properly assess the community impacts (noise) and also industry impacts (e.g. increased fuel burn). Pushing for a change without good evidence and then discovering unintended consequences might satisfy some of those groups currently on the HCNF, but could make it worse for others.

If the evidence does provide a clear case for change on noise grounds, pushing up the minimum climb rate is not within our powers and will require the involvement of the CAA and the DfT. That should not be read as “inaction” but a recognition that of the complex system within which aviation operates. From a Heathrow perspective, you have my commitment that we will a) work to gather evidence and b) where the evidence supports it, champion changes to improve noise.

3. Going forward, I think it is imperative we consider how we reach consensus in the group, and indeed if that should be our aim. That is easier for less contentious issues, for example improving the metrics that we use to communicate noise. For other issues this will be more challenging since there may be losers as well as winners. An example from last week’s meeting is how we share late running departures more equitably while driving towards a goal not to have late runners. We need to consider how we can supplement discussions in the Forum with more structured consultation and where that consultation should extend beyond Forum members (of course any formal airspace change will be publicly consulted on). I firmly believe that the CNF can play a helpful role in building common ground wherever possible and that it can complement more formal consultation.

In terms of some tangible improvements, to start to address some of the points above, I propose to do the following

  •   First, we will share a status update against the Forum action plan a week before each meeting (I have reattached a copy for reference). That will provide an overview of the plan we developed and allow you to hold Heathrow and others to account for delivery.
  •   Second, I will establish a formal pre-meet with other industry representatives (airlines and NATS) before each meeting to ensure that the most appropriate sector is prepared to talk to elements of the work plan and respond to specific community questions that have arisen.
  •   Third, we will develop some options on the decision-making process within the Forum. That work will suggest which topics are likely to require more structured consultation of both Forum members and of the wider community.As I said last week, the HCNF is an influential Forum. Heathrow will continue to use it to shape our approach to noise management. Longer term the ultimate goal of the Forum is to ensure that airspace modernisation delivers benefits for both the community and the industry. This is a huge prize and a very different approach to that taken by airports that have already implemented PBN technology and seen huge challenge from their communities. I am quite sure that no other airport around the world is investing the same amount of effort that Heathrow is in engaging with communities to ensure we work together to find the best ways to implement the new airspace

technology. The steps we are taking and the work we are doing is breaking new ground. I encourage you to continue to use your engagement and influence to shape what we do in future.

Yours sincerely

Matthew Gorman
Sustainability & Environment Director

CC Community Noise Forum members

Dear Matt,

Community Noise Forum

Thank you for your letter of 26 September 2016 regarding the Heathrow Community Noise Forum. We agree that the discussion felt heated but this is an indication of the level of frustration that communities feel that despite the HCNF having existed for nearly two years, there has been absolutely no improvement in noise conditions to date.

In response to your three main reflections:

  1. It is deeply concerning that the industry is permitted to make a series of changes (overnight if they wish) without consultation and any assessment in advance of the noise impacts, but communities are expected to wait for years for analysis and evaluation of the changed noise environment to be undertaken. A far more valuable process from our perspective would be for proper analysis and consultation to be undertaken before any changes are made.
  1. In respect of the improvement plans that you refer to, these focus entirely on gathering more data and undertaking further analysis. They are not by any means concrete actions that will result in an improved noise environment, but instead could be construed as further delaying tactics while more changes are introduced by stealth. It is also impossible to believe when there is clear data (as per the results from the Strawberry Hill Noise Monitor) that planes are lower and louder, that a steeper climb gradient would not reduce noise. Your comment that the HCNF should avoid “pushing for a change without good evidence and then discovering unintended consequences” is extremely difficult to accept given this is exactly what the industry has done for the last two years in pursuit of its own objectives.

We appreciate that not all of the actions that communities want to see are within Heathrow’s control and agree with you that the DfT and CAA should be held accountable for their policies that have led to such widespread community unrest. However, this does not absolve airports and airlines from any responsibility and your comment that community impacts (noise) need to be balanced against industry impacts (e.g. increased fuel burn) is a significant cause for concern. It is established that new procedures have been permitted that result in lower flights 10- 12 km from the airport at altitudes between 1500 and 2000 feet. We understand that reduction in noise is the Government’s overriding priority at heights below 4000 feet and would ask what representations have been, or are proposed to be made, to government by Heathrow to redress this situation on behalf of communities?

  1. In terms of reaching consensus on difficult issues, how easy this is to achieve will be largely dependent on the industry’s willingness to balance the impact on communities with its desire for greater profit. To date, overflown communities have been expected to pay all of the costs of industry expansion.

Whilst we welcome your suggested improvements to HCNF processes, we are very concerned that you see the ultimate goal of the Forum as delivering airspace modernisation. This is not the reason why communities have given up their time to attend – which is probably exactly why so many groups are so dissatisfied with the process to date and are seriously questioning the value of their investment in time. If we are really expected to believe that the HCNF has any influence whatsoever, then we need to see improvements in the current noise environment – before any further steps towards airspace modernisation are implemented. To this end we would expect to see Heathrow come forward now with specific and tangible plans to achieve noise reductions.

Finally, given the unbearable situation many of our communities face today with existing flight numbers, we wish to put on record that we object in the strongest possible terms to an additional 25,000 flights per annum from Heathrow as was suggested at the last CNF meeting.

Yours sincerely,


Cc:       Tania Mathias MP

            Community Groups on the HCNF

            Isobel Pastor, Department for Transport

            Darren Rhodes, Civil Aviation Authority


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