The Richmond Heathrow Campaign - Airspace Modernisation

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Responses to consultations on Airspace Modernisation

Date	Consultee	Title of Consultation/Presentation
2 Apr 2021	Heathrow Airport Limited	Heathrow Consultation on Slightly Steeper Approaches	RHC Response
17 Sep 2020	CAA	Draft procedure for reviewing the classification of airspace, CAP 1934, questionnaire, June 2020	RHC Response
26 Jun 2020	CAA	Proposed Criteria for Assessing and Accepting the Airspace Change Masterplan CAP 1887, February 2020	RHC Response
4 Mar 2020	CAA	Minimum Requirements for Noise Modelling Consultation questionnaire, January 2020	RHC Response
3 Mar 2020	CAA	Airspace classification review 2019–2020 questionnaire, December 2020	RHC Response
20 Nov 2019	HCNF	RHC Prsentation to Heathrow Community Noise Forum (HCNF)	RHC Presentation
7 Jul 2019	CAA	Airspace change: consultation on a decision-making process for PPR (planned and permanent redistribution of air traffic) proposals, CAP 1786, May 2019	RHC Response
4 Mar 2019	HAL	Airspace and Future Operations & Making Better Use of Existing Runways Consultation	RHC Response
9 Nov 2018	HAL	Independent Parallel Approaches (IPA) Heathrow Consultation	RHC Response
9 Sep 2018	CAA	Draft Airspace Modernisation Strategy CAP 1690 Consultation	RHC Response

Heathrow Airspace Principles Design - July 2018 Update

Consultation on the design principles that could be used as the basis for developing Heathrow’s future airspace design, and requests views and preferences relating to them.

The consultation can no longer be found on Heathrow’s website. You can access a copy of the consultation document from here on our website.

July 2018

RHC Response

Noise Objectives

Heathrow’s Airspace principles currently have three noise objectives:

(a) Limit and where possible reduce the number of people in the UK adversely affected by noise

(b) Share benefits from future noise improvements between the aviation industry and local communities

The Richmond Heathrow Campaign believes there should be the following two crucial updates to these objectives.

1. Amend Noise Objective (a) to incorporate WHO (World Health Organisation) guidelines, establishing their legal status, and a UK strategy and timetable for meeting them.

2. Add a fourth Community Noise Objective: Where there is a reduction in overall noise the benefit should be applied to those already most affected and where there is an increase in overall noise the dis-benefit should be applied to those already least affected.

Airspace Design Principles

The Richmond Heathrow Campaign’s response also makes 13 further recommendations on airspace design principles. These cover safety, flight dispersion, flight frequency, noise respite, flight path separation, flight path concentration and performance based navigation (PBN), less noisy aircraft fleet, ICAO* land use requirements, runway length and parallel operation, ICAO* flight operational requirements, London’s parks, night noise, and altitude based priorities.

* ICAO is the acronym for the United Nations International Civil Aviation Organisation.

Integrated Decision Framework

The Richmond Heathrow Campaign recommends that there should be an integrated decision framework to bring together design principles and stakeholder interests in order to minimise noise impact the share the costs and benefits of noise mitigation both rationally and fairly.

Summary of RHC response

Full RHC response

RHC presentation to Heathrow Community Noise Forum

Heathrow Airspace Principles Design

Consultation on the design principles that could be used as the basis for developing Heathrow’s future airspace design, and requests views and preferences relating to them.

The consultation can be found
on the Heathrow Consultation website.

Due 28th March 2018

RHC Response

1. The consultation does not make it clear whether it concerns airspace modernisation for a two runway Heathrow or a three runway Heathrow.

2. We believe it is important when designing flight paths to distinguish between communities experiencing reduced and increased noise and not merely to net them off.

3. The options provided in the consultation are descriptive and not sufficiently developed for objective response.

4. The topics are not linked into an overall decision framework making it impossible to discern and balance the priorities and assess the economic and environmental uncertainties and risks.

5. Objectives come before principles but the objectives are missing from the consultation and are in the process of being reviewed for possible change later in 2018.

6. The rate of reduction in noise from source is much slower than it used to be. It will be that much harder to re-structure Heathrow’s flight paths and even more difficult with an increase in flights and noise from a potential third runway.

7. We understand the consultation is being treated as the first portal of the CAA’s airspace change process. There is no statement of need as is required by the change process.

8. The foreword of the consultation establishes a bias without evidence in favour of a third runway. The consultation provides no evidence to support their positive statements, which we believe to be incomplete and misleading.

9. The claims by Heathrow regarding the environmental impact on communities are absent or misleading.

10. It is not clear how the Heathrow will use the results of the consultation. However, using this serial approach there will be no scope for going back to reconsider earlier decisions.

RHC response

Draft Airspace Design Guidance

Civil Aviation Authority (CAA) consultation seeking views on the new guidance that the CAA drafted following consultations in 2016 to support the new airspace change decision-making process.

The consultation can be found
on the CAA’s website.

Due 2nd July 2017

Summary of RHC response

Heathrow must follow a process regulated by the CAA for Permanent Change to ‘Notified’ Airspace Design, that is, lateral structure of flight paths defined as Tier 1. The CAA makes the change decision and includes noise and carbon emissions and safety. Communities are consulted. There is no Guidance yet for Tier 2 and 3 changes, which include vectoring and traffic volumes.

Guidance, as drafted, is not fit for purpose: it omits potentially harmful Tiers 2 and 3 and cannot be scaled up for multiple flight path changes anticipated by airspace modernisation and Heathrow expansion. The CAA is subject to conflicts of interest. The environmental objectives are flawed and Government decisions on expansion will be made before objectives are updated and there is a comprehensive process for airspace change.

Other deficiencies include altitude tests, noise metrics and flight path evaluation process. Choice of design principles and consultation should involve independent bodies and not depend on Heathrow.

RHC response summary

RHC answers

UK Airspace Policy Consultation

Department for Transport (DfT) consultation on the processes and policies that will govern the redesign of UK airspace to accommodate increasing demand.

The consultation can be found
on the DfT’s website.

Due 25th May 2017

Summary of RHC response

The DfT seeks modernisation and increased capacity of UK airspace, taking account of safety and harm from noise and carbon emissions.

The Richmond Heathrow Campaign focuses on Heathrow.

(1)		Noise Objectives - The National Aviation Policy Framework noise objectives are seriously flawed; unacceptable Airspace Policy is being adopted before objectives are reviewed in 2018.
(2)		Noise metrics and limit values are not fit for purpose - Government must clarify legal status of WHO noise guidelines and implement noise reduction plans. RHC proposes a set of flight path metrics.
(3)		Airspace Design Principles - RHC’s airspace noise model raises many design issues and major change to legacy airspace structure and use, including concentration, multiple flight paths and respite. Re-distribution of noise plus increased noise energy from larger aircraft and more aircraft from expansion will cause much community conflict across heavily populated London. There is insufficient airspace for expansion.
(4)		Balanced Approach to reducing noise - Slow reduction in aircraft noise at source and from operational improvements are likely to be offset by London’s population growth resulting in long-term blight up to at least 30 miles from the airport. There exists no good reason to lift the current operating restriction of 480,000 Heathrow flights a year.
(5)		Justification for Airspace Modernisation - Increased headroom between current use and capacity to improve resilience may be justifiable but not increased capacity for more flights.

RHC response