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Other past consultation responses


Night Flying Restrictions at Heathrow, Gatwick and Stansted Stage 2 Consultation (January 2014)

The agreement on limiting night flights expires in October 2014 and the Government has issued a second stage consultation. This largely ignores the evidence and views of residents submitted in Stage 1 last April. The proposal is for a three year regime to October 2017 with no attempt to materially reduce night time noise. Instead there is a proposal to have more arrivals before 0600.

The Richmond Heathrow Campaign’s response criticised the Consultation on the basis that:

1. No Option for a Ban on Night Flights

RHC and others in Stage 1 sought a phased Ban on Heathrow Night Flights between 2300 and 0700 but this option has been ignored. Instead the lack of incentives and restrictions during the last two year roll-over from expiry of the previous regime is perpetuated for another three years. The reduction in noise to World Health Organisation guidelines – which say the sleep period should be at least 8 hours for most people – will have been stalled for 5 years.


We say the Government should introduce a new 5 year regime with a Heathrow Night Flight Ban. At the very minimum there should be reduced average noise levels, further limits on the noisiest aircraft, and no scheduled flights before 0530 (instead of the current 0430). These measures are needed to reduce the negative noise impact on people’s health, quality of life and human rights and to achieve WHO standards by the prescribed year 2030.

2. A further 3 Years of current Night Flight Rules

The reason given by the Government for extending the present restrictions to 2017 is to enable the next Government to review them in the light of any recommendations from the Airports Commission. It seems unlikely the Commission’s report in 2015 on long term capacity will compromise a decision taken now to reduce the noise over a 5 year regime starting no later than 2015.


We say steps should be taken to revise the Heathrow regime now, in time for further consultation and decision before the general election in 2015, with implementation no later than October 2015 for a 5 year term.

3. Plans for More Flights before 6am

Subsequent to the publication of the Stage 2 consultation, the Airports Commission recommended that the number of movements permitted before 6am should be increased from its current limit of 16 so as to alleviate congestion and planes queuing in arrival stacks after 6am, and that this should be trialled by 2015 at the latest.


We say there should be no additional flights before 6am, even for a trial period. Reducing stack sizes and reducing the need to use both runways can be achieved by managing flight arrival times and smoothing schedules later in the day rather than increasing average night noise and early flight arrivals before 6am.


Night Flying Restrictions at Heathrow, Gatwick and Stansted Stage 1 Consultation (April 2013)

This Stage 1 Consultation was an open call for evidence to inform the development of proposals for the next Night Flights regime, and also to inform the work of the Airports Commission.

The DfT has now started analysing the responses and issue a Stage 2 consultation later this year. The new regime should be announced by spring 2014.

The Richmond Heathrow Campaign submitted a comprehensive response to the DfT, and also a Guide to 23 key questions which affect Richmond.

Overall, the Richmond Heathrow Campaign proposed a ban on all night flights, beginning with those between 11pm and 6am. In our view there is no credible economic justification for such flights. In particular, there is nothing unique or essential about the current sixteen or so flights which arrive each morning before 6am. There is daytime capacity for additional flights to replace any lost through a ban.

We therefore:

  • Requested a commitment that operations at Heathrow Airport will move towards compliance with World Health Organisation Guidelines on noise for each hour of the full eight hour night period (11pm to 7am).
  • Asked for the Stage 2 consultation to include the option of a complete ban on flights before 6am within two years.


RHC paper providing GLA evidence for the Davies Commission (2013)

The Richmond Heathrow Campaign responded to the GLA’s consultation that resulted in their report Airport capacity in London, which was submitted to the Davies Commission in May 2013.

Our response can be found here. In summary:

  • Heathrow runway capacity is only stretched because Heathrow has failed to deliver the number of passengers per aircraft forecast during the Terminay 5 Public Inquiry.
  • Heathrow’s hub status reduces the number of cities accessible from London. As the proportion of transfer passengers has risen from 26% to 36% since 1990, the number of routes has dropped from 264 to 211.
  • Restrictive slot allocation processes should be ended, air passenger duty should be charged on transferring as well as terminating passengers, and differential airport charges should be introduced to encourage airlines to spread their flights more evenly throughout the day.


DfT Draft Aviation Policy Framework (2012)

on 12th July the Government published their Draft Aviation Policy Framework. This covers liberalisation of the UK aviation market to develop routes at airports other than Heathrow, improvements to Heathrow operations, capacity usage, aviation emissions and noise levels, a new rail link to Heathrow from Reading, and improved border efficiency at Heathrow. We submitted our response on 31st October.


Independent Transport Commission (ITC): Aviation Futures (2012)

The ITC is Britain’s foremost independent land use and transport think tank. On 3rd July they published a consultation Aviation Futures: What are the strategic choices for aviation capacity in the UK?. We submitted our response also on 31st October.