The 2nd CONSULTATION DOCUMENT RESPONSE
A full background summary of what’s going on and a
suggested set of answers for you to use/ not use.
Firstly – what’s going on?
Gatwick Airport Ltd and the air traffic control company NATS consulted recently on London
airspace changes concerning several London airports (Gatwick, Stansted and London City).
This 1st consultation, which ended in January 2014, proposed several ideas for the re-design
of plane arrival and takeoff routes to Gatwick airport, but did not reveal where those routes
would be.
The present (2nd) consultation follows on from this and specifically concerns Gatwick routes
below 4000ft – above the very area we all live. The proposal is a fundamental shift away
from the current wide distribution of arrivals to a very precise and narrow ‘Superhighway’.
As residents of Kent approx.18 miles east of Gatwick, we are being asked to express our
opinion on this re-design based on a ludicrously vague .ppt map (map 35) and some very
technical jargon…. It is very confusing and the ‘consultation’ closes on August 14th.
The most important thing you need to know is this:
The present (2nd) consultation document still fails to show where the exact narrow
arrivals Superhighway route will be… it might be over us, it might be ½ a mile to
the west… who knows, Gatwick are not telling anyone enough to work this out.
We do know however that the Superhighway will be a curved line somewhere between East
Grinstead and Tunbridge Wells. In fact, Gatwick are proposing TWO Superhighways in our
area in this 2nd consultation: one for daytime flights and one for night flights. However,
please remember that in the long run, if Gatwick get their Second Runway, this particular
night/day configuration may change! Both Superhighways will run northwards from a single
‘merge point’, a junction in the sky that works like a fixed postcode address for the new
GPS’s being fitted on planes, and this merge point will be somewhere in the south –we
suspect possibly at Mayfield or Seaford.
All the planes arriving from the coast will funnel towards that merge point location at timed
intervals so that they can be assembled on to the Superhighway about 3 miles apart in
order to fly up and turn west to join the main western approach near HEVER and down
towards Gatwick in a continuous line. This is why the location of the merge point is
extremely critical for our area. The location of the merge point will determine the precise
angle of each Superhighway as it curves towards the main western approach line. Each
Superhighway will have ALL the arriving planes on it heading to Gatwick. On average this
will mean 250+ aircraft, 266 days a year, at between 2300 - 4000ft, day and night, without
respite. The daytime reality during the summer peak flight period will be up to one plane
per minute. The night flight reality will be up to 50 planes 11:30pm-6am, but the
Government are currently considering allowing Gatwick to fly more.
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How will your house value hold up under this?
From Map 35, it appears that Bidborough is on the edge of the proposed area and
for example, Penshurst is smack in the middle, but with the merge point at
present completely uncertain, both are in the firing line for maximum arrivals.
What’s more, the sheer scale of this concentrated over flight means that the ‘noise
cloud’ is expected to extend for at least 2km either side, just like with car
motorways. What’s more planes are louder when they turn. In other words, NO
ONE in our area will actually have respite from the planes except when the wind
blows from the east, which is very seldom. We at CAGNE East, alongside Parish
Councils, MPs, other campaign groups and residents and even Kent County Council (who are
still in favour of Gatwick building a second runway) have ALL overwhelmingly objected to
this concentrated proposal and the way in which this ‘consultation’ is being conducted. We
are also demanding more clarity.
BUT WE NEED YOU TO OBJECT TOO, EVERY SINGLE VOICE
COUNTS!
So, what’s the benefit of proposing this Superhighway?
Here’s the science bit…Precision Navigation (referred to as PBN or R-NAV) has already been
introduced on the existing NPRs (Noise Preference Routes or areas in the sky in which
aircraft approach and takeoff).
Guiding aircraft via Precision Navigation reduces the extent to which aircraft are distributed
(width) within the NPRs (areas where aircraft approach and takeoff). The 2nd Consultation
proposes that it should be introduced for arrivals to facilitate the handling of more aircraft
and to reduce noise impacts on a wide number of residents.
However: It is uncertain whether the noise impacts will be reduced as
the Superhighway is designed to handle MORE aircraft and Gatwick is
planning to grow bigger than Heathrow!!! It’s something often referred
to as a ‘slippery slope initiative’.
Anecdotally, Gatwick likens the noise under a narrow Precision Navigated NPR
Superhighway and between 3000-4000ft to: ‘being within 1 metre of a vacuum cleaner’. But
remember, that’s just talking about noise as an average. Both the aviation industry and the
Government are still averaging out plane noise using an out of date measurement system
devised in the early 1980’s, which takes no account of the number of planes overhead and
the actual human experience of the noise they make. Modern research shows this metric
system is biased towards aviation companies. The conventional level at which Gatwick and
the Government say ‘significant community disturbance’ occurs is at 57leqs, which is a 16
hour average value. To put this in perspective, with arrivals between 3000-4000ft and each
plane at 60-70dB that’s like saying that someone shouting at you continuously for 16 hours
is acceptable, and wouldn’t affect your daily life at all.
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What are you being asking to do?
Your views are being sought on several Precision Navigation ‘options’ and on ways in which
Precision Navigation should be employed in the routing of arrivals. Most of the questions do
not apply to our area, and are asking about departure NPR’s from the airport our sister
campaign group to the West of the airport CAGNE are fighting this. Our area is mainly
affected by eastern arrivals on ‘Runway 26’ and departures that fly east.
How can you respond?
•
Via the consultation questionnaire at:
www.gatwickairport.com/gatwickairspaceconsultation and by clicking on
Submit Your Feedback many of the answers are by multiple choice. If
you object to the proposals, or where appropriate, we suggest you select
‘other’ to be able to write in exactly what you want to say. Unfortunately
‘other‘ is not an option for questions beginning with ‘a’ (1a, 2a etc.) We
outline some suggestions below.
• Your response that can include fuller answers to questions beginning with
‘a’ can also be sent by e-mail to gatwickairspacechanges@ipsos.com
don't forget to include all your contact details
• Or by post to:
Freepost RSLG ATKL LBAE Gatwick Consultation, Ipsos MORI Research
Services House, Elmgrove Road, Harrow, HA1 2QG
Again, don't forget to include all your contact details
We have attached suggested responses, based on our
collective knowledge that best supports both our
neighbour’s communities and ours. We at CAGNE East have
made suggestions that support the recommendations from
GACC, Penshurst Parish Council and the High Weald
Council Aviation Action Group submissions.
Feel free to change anything you disagree with or simply don't understand –
and please feel free to contact us. We are more than happy to help:
cagne.east@gmail.com
TO BE CLEAR, THE DEADLINE FOR YOUR RESPONSE IS 14TH
AUGUST. WE URGE YOU TO RESPOND FOR THE
PROTECTION OF YOUR COMMUNITY AND FOR YOUR
FAMILY
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Our suggested responses to the 2nd consultation, based on
our collective knowledge that best supports ours and our
neighbouring communities
WARNING SOME ANSWERS TO ‘MULTIPLE CHOICE BASED QUESTIONS’ CAN ONLY
BE ANSWERED ONLINE BY CLICKING ‘OTHER’ TO ENTER YOUR OWN OPINION
Question 1a: Which ONE of the SIX alternative proposed options, if any, do you
believe provides the best balance of benefits for RWY26 departures?
Suggested answer:
For questions 1a ‘Don't know’, 1b, 1c & 1d I believe that as these proposals are not relevant
to our area, they are best responded to by those affected.
Question 2a:
Compared with today’s routes, do you believe the proposed realignment for
RWY08 departures to the east/northeast of Gatwick Airport is better or worse?
Suggested answer: ’yes probably’
Or in full via email:
I’m inclined to support the alignment that has been drawn up on the basis of feedback from
Kent County Council and others. This alignment is shown in Maps 26 and 27. My support is
based on the 500m NPR indication that a negative population figure of - 3900 will be
achieved against a 0 (zero) figure of those newly affected on the understanding that there
are real noise reduction benefits. However, some reports suggest Gatwick's population
counts are invalid and that this change will not in fact reduce noise for most residents
because of the noise cloud created by more concentrated flights. On balance, it is not really
possible to assess the overall impact of this proposal from the data provided.
Question 2b:
Which, if any, factors do you believe to be the most important for us to consider
when determining whether to realign the RWY08 departures to the
east/northeast?
Suggested answer:
I believe that many factors should be taken into account including:
Noise that affects health
Noise at night that disturbs people’s sleep
Noise in the day that impacts people’s quality of life
Noise in the daytime that affects our schools and community facilities
Noise over Areas of Outstanding Natural Beauty, National Parks and historic houses and
gardens
Question 2c:
If we were to implement the proposed route, what width NPR swathe do you think
is most appropriate?
Suggested answer:
I support the most practical width that causes the least disturbance to those being
overflown.
Question 2d:
If you answered question 2c, what were the reasons for your choice?
Suggested answer:
My support for this swathe is directly linked to the fact that there will be no increase in the
population that are affected and no increased intensity of over-flying for any population.
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Conversely, there will in fact be a decrease in the nuisance caused. It is my submission that
this fundamental principle (the need to ensure that there is no increase in the populations
overflown or the intensity of over-flying on any population) should be central to any of the
proposals
Question 3a: (This applies to Superhighway in our area)
Should we seek changes to the current DfT noise abatement requirements, so that
the proposed night time arrival respite route for RWY26 could be implemented (as
shown in Map 34 and Map 35)?
Suggested answer: ’yes probably’ (on the basis of replies to questions 3b and 3c)
Or in full via email:
I do not consider that a single respite route is appropriate. My position is that a multi
respite should be given priority through a tactically vectored broad swathe approach, as is
currently operational. I bring to your attention that in the original consultation question ‘On
Arrivals Based on Point Merge at Gatwick,’ of the online responses from the public only
8.5% strongly supported Point Merge, 17% tended to support but almost 75% did not
support Point Merge.
Question 3b: (This applies to the Superhighway in our area)
Which, if any, factors do you believe to be the most important for us to consider
when determining whether to seek changes to the current DfT noise abatement
requirements, so that the proposed night-time arrival respite route for RWY26
could be implemented?
Suggested answer:
These changes should only be considered if they form part of a multi respite path option day
and night across a broad swathe, as is currently operational. As it is stated that this
proposal is purely for nighttime respite, then clearly the reduction of noise is primarily for a
reduction in disturbed sleep.
Question 3c: (This applies to the Superhighway in our area)
What, if any, comments or suggestions do you have about the proposals for us to
seek changes to the current DfT noise abatement requirements, so that the
proposed night-time arrival respite route for RWY26 could be implemented?
Suggested answer:
I stand by my previous answer that this should not be about a single respite path. However,
if it was part of a multi respite swathe it could be supported if it was proven that there
would be a reduction in people adversely affected by noise nuisance and/or no increase in
those newly affected.
Questions 4a, 4b,4c
Suggested answer: ‘don't know’
Or in full via email:
Are not relevant to our area and are best dealt with by those affected.
Question 5a:
Should Gatwick Airport Ltd re-centre and narrow the published NPRs to take
account of aircraft performance on the modern PBN routes in place at Gatwick
Airport?
Suggested answer: ’probably not’
Or in full via email:
I have a neutral position on this given that the information suggests that it is purely a
cosmetic exercise. However, if the narrowing of NPRs could lead to a higher concentration of
noise for a minority of residents, GAL should NOT go ahead.
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Question 5b:
Which, if any, factors do you believe to be the most important for us to consider
with respect to re-centering and narrowing published NPRs to take account of
aircraft performance on the modern PBN routes?
Suggested answer:
NPR swathes should indicate potential noise impact from over-flights of nearby areas.
Question 5c:
What, if any, comments or suggestions do you have about the proposals for
Gatwick Airport Ltd to consider re-centering and narrowing published NPRs to
take account of aircraft performance on the modern PBN routes (please provide
any views you have on what the optimal width for NPR swathes should be)?
Suggested answer:
The optimal width should reflect the effects on the population below. However, I have seen
no environmental metrics used in this consultation process that would fill this objective and
reliance is purely made on population count within the NPR 4000ft ceiling.
Question 6a:
Should we implement shortened NPRs to take account of the observed climb
performance of the flights at Gatwick Airport?
Suggested answer:
‘Probably not’
Question 6b:
Which, if any, factors do you believe to be the most important for us to consider
when determining whether to implement shortened NPRs to take account of the
observed climb performance?
Suggested answer:
Although I am not in agreement with the proposal on balance, NPR swathes should always
indicate potential noise impact from over-flights of nearby areas.
Questions 7a, 7b and 7c
Suggested answer:
Are not relevant to our area and are best dealt with by those affected.
Question 8a:
Should Gatwick Airport Ltd consider NPR swathes with variable widths, dependent
on sharpness of turns on each route, as a more accurate portrayal of where
aircraft actually overfly?
Suggested answer:
Yes probably.
Question 8b:
Which, if any, factors do you believe should be the most important for us when
considering NPR swathes with variable widths, dependent on sharpness of turns
on each route, as a more accurate portrayal of where aircraft actually overfly?
Suggested answer:
NPR swathes should indicate potential noise impact from over-flights of nearby areas.
Question 8c:
What, if any, comments or suggestions do you have about whether we should
consider NPR swathes with variable widths as a more accurate portrayal of where
aircraft actually overfly?
Suggested answer:
Nothing further to add.
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Question 9:
What, if any, additional comments do you have that are relevant to this
consultation and that you would like to make?
Suggested answers, each have different points to make:
Specific Point Merge arrival corridors were not shown in the original consultation
documentation, nor was there any room for debate: only the existing broad swathes were
shown. The original consultation process made it clear that GAL was not going to publish the
flight paths from Point Merge. The follow-up consultation dated 1 May 2014, to which I am
now responding, also fails to give me the opportunity to address this issue, as there is no
specific question on this point. I therefore question the fairness of the “consultation”, and
whether it can on any analysis be considered a true consultation process.
The proposed concentrated flight path approaching Runway26 from Point Merge has been
positioned so that it overflies ‘noise sensitive areas,’ in particular the village primary schools
of Bidborough, Langton Green, Speldhurst, Fordcombe, Penshurst, Chiddingstone and
Hever. These quiet local schools, so important to the early development of children in
learning, personal and social development - will be bombarded with noise. Much of this
potentially disruptive disturbance can be avoided if a sensible and responsible approach is
taken by Gatwick Airport. I advocate retaining the broad swathe approach to Runway 26,
which is currently in operation as I believe this is the fairest way to spread the nuisance and
environmental damage of noise from aircraft movements.
Penshurst is now shown in the epicentre of the proposed concentrated flight path for
arrivals to Runway26, as are other listed villages. Our local economy relies on tourist
attractions of internationally important buildings and grounds such as Hever and
Chiddingstone Castles and Penshurst Place could be irrevocably damaged.
With the proposal of one concentrated flight path these historically important sites could be
irrevocably damaged. Gatwick Airport seems in total denial of the collateral damage of its
proposals to the West Kent tourist and leisure industries.
What is missing from this consultation are options that could give rise to a fairer approach
to sharing the burden of air traffic. Surely with the massive benefits of the Precision
Navigation it should be possible to vary approach routes easily with little or no
inconvenience to pilots as they would just input the new route instructions into their
navigation systems. I strongly advocate a policy of spreading the load over many routes so
there are no “big losers” and ensuring that other linked policies are progressed to get
steeper descent angles and point merge over the sea.
I, like many others, believe the environmental metrics used for airspace consultations in the
United Kingdom are seriously flawed. Once again the discredited ANCON Leq 57dBA sound
energy contours and their equivalents have been used. These have not been subject to the
scrutiny of modern-day scientific analysis. Noise contours and footprints do not take into
account of the vast majority of residents like me who are affected by aircraft movements at
Gatwick Airport.
In addition to this, aircraft noise disturbance from airports in the UK is not adequately
monitored. This has allowed Airbus A319/320/321 aircraft, which dominate aircraft
movements at Gatwick Airport, to cause severe annoyance with a high pitched whine
particularly noticeable along the low approach to touchdown from at least twenty-five miles
away causing day and night time misery from aircraft noise. The industry has known about
this design flaw since 2005.
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