TAG suggestions for responding to the Heathrow Airspace and Future Operations Consultation

The Heathrow Airspace AND Future Operations Consultation runs from 8 Jan until 4 Mar 2019.

Here’s the link to the consultation https://afo.heathrowconsultation.com/consultation/

and there are the usual upbeat little videos which fail to point out the very real horrors we face under their proposals.  The question numbers go 6,7,8,1,2,3 and 4 – apparently to coincide with the links. There are lots of detailed documents there to read which explain all this in greater depth.

Question 6: Factors to be aware of when designing flightpaths for third runway.

Suggested answer: I don’t want low and concentrated flightpaths over my home. No planes should go over at 1000 or 1500ft this far from the runway and never with arrivals layered on top.  These proposals are about cramming too many planes into too congested an airspace and then pitting communities against each other. You are not limiting or reducing noise by your proposals and will harm our health and quality of life irreparably. Communities around Heathrow up to 30 miles from the airport are being sacrificed to line the pockets of Heathrow’s foreign shareholders.

Question 7: Factors to be aware of when designing new arrival paths to make better use of existing 2 runways.

Suggested answer: We are already severely impacted in Teddington when on Easterlies and won’t get runway alternation for several years. We do not want any extra planes going over this densely populated area. Our health is already being damaged by aviation noise and pollution and any expansion is incompatible with climate change.

Question 8: Any other comments

Suggested answer: A third runway is estimated to add an additional 54,000 cars a day on local roads, and this will increase the toxic air for residents. Scientific evidence has shown that particulate matter is found under flightpaths 10km from airports and this can raise the risk of miscarriage and dementia. Also, a study in 2017 found a particularly high number of airborne nanoparticles of heavy metals, harmful to human health, in the grounds of Montreal Airport. Putting more planes in the sky over such a densely populated area will cause its own dangers.

Question 1a: Do you support our proposals for a noise objective?

Suggested answer:  No

Question 1b:  Comments on proposals for noise objective

Suggested answer: The local noise policy does not conform with nationally adopted health and environmental protections. National aviation policy makes noise minimisation the top priority at low altitudes – this can’t be qualified by aviation’s commercial considerations. If Heathrow wanted to limit and reduce the effects of noise on health and quality of life it wouldn’t be expanding Heathrow or trying to add 25,000 more planes now. No-one believes that an expanded Heathrow will be quieter than 2013 no matter how much the noise footprint is manipulated. No-one, especially children, should be kept awake late into the night or woken around 5am by planes.  The World Health Organisation (WHO) recommends 8 hours of undisturbed sleep and current operations prevent this for many of us already.

Question 1c: Any other comments on developing a package of noise measures

Suggested answer: The way noise measurement is averaged out is meaningless – single noise events are what wake people up. The WHO strongly recommends reducing average noise levels to below 45decibels as aircraft noise above this level is associated with raised blood pressure, cardio-vascular disease, stress etc. Protecting communities from aviation noise should always take priority over commercial interests.

Question 2a:  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? Please tick one of the following options:

  • A longer period of respite, but not every day
  • A shorter period of respite every day
  • I don’t know

Both options are unacceptable.  The best they seem to be offering are breaks from “overflight” but how low or how far away a plane has to be to be considered overflight took the CAA 38 pages to clarify and there remain many areas of uncertainty.

Question 2b: Reasons for your preference

There is no research on what constitutes an acceptable period of respite, whether this can be achieved at Heathrow or penalising the airport for failure to adhere to respite.

Question 2c: Any other comments on runway or airspace alternation

Neither of the respite periods suggested are long enough to prevent harm to health and there are no formal governance structures planned to enforce respite arrangements.

Question 3a. 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?

Suggested answer: Yes.

Question 3b: Please tell us reasons for your answer

Suggested answer: Planes are louder on take-off because they have to climb and carry heavy fuel loads. Westerly preference was created to protect the greatest number of people from the severest impacts of louder departures. This should not be changed. If any variations were to be considered it would have to be accompanied by very clear legally binding rules including comprehensive compensation for those communities that will be impacted, as historically people would have moved to areas to avoid Heathrow’s impacts.

Question 3c: Should we sometimes intervene to change the direction of arriving and departing aircraft to provide relief from prolonged periods of operating in one direction – even if that means slightly increasing the number of people affected by noise?


Question 3d:

No – unless Heathrow were to adopt a completely different approach to noise management including flying much higher and quieter, and accept legally binding obligations to minimise its significant adverse health impacts. It would need to commit to noise sharing between communities on a fully fair and equitable basis and crucially to making all areas in its catchment fit for human habitation having regard to independent health advice (such as WHO).

Question 3e:

Please see above

Question 4a: To help inform our consideration of the options, we want to know whether you would prefer for us to:

Please note the exact times are subject to further evaluation of the options.

  • Option 1 – Use one runway for scheduled arrivals from 5.30am (runway time 5.15am)
  • Option 2 – Use two runways for scheduled arrivals from 5.45am (runway time 5.30am)
  • I don’t know

Neither of the options are acceptable. Areas under departures such as ours experience no scheduled departures before 6am and as a minimum this threshold must be maintained for all departures (the question relates to arrivals). However, for arrivals, it is apparent Heathrow is even seeking to erode the proposed 6.5-hour night flight ‘ban’ by excluding taxiing time before planes take off or disembarkation, due to its own ‘scheduling’ considerations.

Question 4b: Please tell us reasons for preference.

Suggested answer: Internationally accepted medical advice is that 8 hours sleep a night is necessary for good health. Scheduled flights should not start before 7am so that the community, and particularly children, can attempt to get closer to the recommended 8 hours of sleep for good health.

Question 4c: Any other comments on morning arrivals

No suggested answer. A night flight ban should mean no flights whatsoever and not be eroded for ‘scheduling’ or other operational reasons. Late evening departures should stop at 11pm and stringent sanctions must be imposed for overrunning (contingencies should be built into the timetable to avoid late departures).

Question 5a: Please provide comments on how to encourage use of quietest aircraft at night (outside proposed scheduled night flight ban)

Suggested answer: There should be effective restrictions on the noisiest aircraft, with much higher charges at night. These should relate directly to the health damage done to communities under the universally accepted ‘polluter pays’ principle. Any operational bans or methods of “encouragement” require a formal governance structure, limitations on Heathrow operations to prevent environmental blight on communities miles around the airport must be formalised and no longer a voluntary option for Heathrow.

Question 5b: Any other comments on night flights and restrictions.

Suggested answer: Late-running planes have been a far too common occurrence, and this is often caused by far too many planes being scheduled from 10.15pm onwards. This is an abuse of the system and results from the ‘voluntary nature’ of Heathrow’s operational restrictions.  Over scheduling has blighted the lives of communities on both sides of the airport for years and must be stopped.

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  1. Lester Hewett
    3rd March 2019

    Thank you

  2. Mo
    3rd March 2019

    Truly helpful and saved a lot of time!

  3. Carolyn f nunn
    2nd March 2019

    Thank you for compiling such a helpful and intelligently researched responce. Especially helpful to break through the jargon of the form itself.
    Kind Regards
    Carolyn Nunn

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