Written evidence submitted by Richmond Heathrow Campaign (ASM0029)

INTRODUCTION

This is the written response of the Richmond Heathrow Campaign to the Parliamentary Transport Committee Inquiry titled ‘Airspace Management and Modernisation’; this Inquiry is in reference to the DfT’s public consultation on ‘UK Airspace Policy: A framework for balanced decisions on the design and use of airspace’, which ends on 25 May 2017.

The Richmond Heathrow Campaign (RHC) represents three amenity groups in the London Borough of Richmond upon Thames: The Richmond Society, The Friends of Richmond Green, and the Kew Society, which together have over 2000 members. The members of our amenity groups are adversely affected by noise from Heathrow Airport’s flight paths, poor air quality and road and rail congestion in west London.  We acknowledge Heathrow’s contribution to the UK economy and seek constructive engagement in pursuit of a better Heathrow. We are an active participant in the Heathrow Community Noise Forum.

Our premise is that it would be preferable to aim for a better Heathrow rather than bigger Heathrow and to capitalise on the world beating advantage of London’s five airports, in particular by improving surface accessibility to all five airports, which would be a major benefit to users. But this is not the place to expand on our preference.

Over recent years we have undertaken extensive research on Heathrow and submitted a large number of papers to the Airports Commission (the Commission) and others - all of which can be found at www.richmondheathrowcampaign.org and www.rhcfacts.org. 

We are still in the process of assessing the DfT’s consultation on UK airspace policy with a view to responding to the DfT by the close of its consultation on 25 May 2017.   It would be premature for us to comment in detail or in conclusion on our assessment and we would have preferred to have had an opportunity to provide evidence and opinion to the Transport Committee when we had completed our assessment. We therefore respond to three of the Transport Committee’s eight questions:

Question 2: The need for modernisation, in terms of the economic and environmental sustainability benefits, and the risks for the aviation industry and wider economy from maintaining the current airspace structures.

Question 3: The essential changes that need to be made to UK airspace, particularly those associated with the development of an additional runway in the South East.

Question 5: The barriers to modernisation of airspace, including the environmental and community considerations arising from changes to the current arrangements for managing UK airspace.

We focus our response on airspace and noise but recognise that emissions and safety are also important issues. We have not responded at this time on the five questions that deal with the decision process.

Richmond Heathrow Campaign Response to the Transport Select Committee

Question 2: The need for modernisation, in terms of the economic and environmental sustainability benefits, and the risks for the aviation industry and wider economy from maintaining the current airspace structures.

1. Sustainable Growth in demand is over-estimated
1. In principle, we support the premise that the UK economy needs the support of aviation and that economic growth is desirable. But we add that it is essential that aviation growth is sustainable. There is increasing evidence that there are constraints to aviation growth from the negative impact on health, quality of life and productivity caused by NOx, particulates and noise emissions.  The Government has for some time recognised there is a constraint on growth due to carbon emissions and the negative impact on climate change. The Airports Commission’s preferred scenario was carbon capped. We are concerned the NATS’ estimates of demand growth fail to adequately recognise the environmental constraints and their full cost.

2. We submit that there is a tendency to over-estimate the rate of noise reduction from aircraft and rate of change of the aircraft fleet and that there is an under-estimate of population growth under flight paths.  The measurement of noise has not adequately reflected the effect on the population, partly because of unsatisfactory choice of metrics and partly because the metric levels applied are too high. Air quality and its impact on people is worse than thought.  Steps to mitigate carbon emission generated by aviation are far from proven and potentially inadequate.

3. We have yet to complete our assessment of the growth in demand assumed by NATS in estimating systemic delays and the cost of not modernising. However, The NATS estimate of 3.25 million flights a year by 2030 seems high compared to the estimates by the Airports Commission of around 2.5 million flights. Both exclude the impact of Heathrow expansion. The 30% higher figure used by NATS needs to be reconciled, especially since the ‘delay’ calculations assume exponential growth in delays per flight.

4. We are concerned that the opening premise by the aviation industry and the Government is that there is a need for a 3rd runway at Heathrow and that therefore there is a need for more airspace capacity.  We do not accept the opening premise and we repeat here the comments we made in our recent submission on the draft NPS to the Transport Committee:

1. International-to-international transfer passengers.  Were transfer numbers to be reduced (for example, by removing their Air Passenger Duty exemption) then this could free up 30% of Heathrow’s capacity.  Heathrow is not efficiently full.

2. There are around 74 million passengers a year currently using Heathrow compared to runway capacity of 94 million.  Heathrow is not full - growth in Total Passenger numbers is set to continue without NWR expansion through use of larger aircraft and higher occupancy.

3. Heathrow claims to be able to raise traffic throughput by 25,000 flights a year without impact on resilience of the hourly throughput. 

4. Heathrow is a high frequency airport with many popular routes but often less than full use. Three quarter empty planes to and from New York is an example of misuse of existing capacity.

2. Questions on the delay calculations produced by NATS include the following:
1. The calculations are said to be high level. We question whether the calculations are sufficiently granular across the UK, where there could be significant variations in the demand/capacity relationship. Given the delay to demand ratio is said to be exponential there could be substantial over-estimates of future delays if the whole of the UK is treated as a uniform hot spot.

2. Delays are calculated in relation to schedules. But the schedules themselves may not be the most efficient use of airspace and management systems used in manufacturing, for example, use stochastic techniques for optimising throughput. We submit that delays, as defined, may indicate failure against expectations based on schedules but could well be a distorted indicator against optimum performance and efficient use of air space.  To illustrate the point, we understand the stacks at Heathrow fill up early in the morning because pilots rush to be at the front of the queue and the holds are not the result of delays.

3. We accept there are inefficiencies in the use of the airspace but we are not convinced by the evidence that there is a shortage of capacity now or by 2030.  Heathrow has said they can add 25,000 flights a year without negatively impacting hourly resilience. 

3. Technology

We support the use of technology in improving efficiency of airspace use in terms of both airspace structure and operations  and in reducing environmental harm such as is caused by noise and other emissions.  But there are associated costs such as using PBN to concentrate flight paths which may then lead to increased noise impact on the population; these costs must be taken into account.

4. Conclusion to Question 2

We stress our conclusion is a preliminary assessment and may be revised and added to when submitting our response to the DfT on their Airspace consultation. But our view at the moment is that the risked case to modernise airspace to increase capacity is not proven - the demand growth appears overstated; using delays as an indicator of inadequate capacity is questionable; and the environmental costs of expansion have not been fully taken into account.  In our response to the Transport Committee on the draft NPS we also included a section that seriously questioned the economics of expanding Heathrow but this did not rule out expansion elsewhere in the UK. The NATS evidence does not demonstrate there is insufficient regional airspace capacity to allow this to happen.

There is a stronger case to use new technology and techniques to improve the efficiency of airspace use, whether or not this increases capacity at the same time. Improved safety, reduced costs and reduced environmental impact are all good reasons to improve efficiency whether through structural or operational changes.  However, it is imperative to weigh up the benefits and costs and their allocation because the changes, for example, that affect noise are likely to be more about re-allocation of noise amongst the population rather than reduction in noise and this is a very sensitive issue.

Question 3: The essential changes that need to be made to UK airspace, particularly those associated with the development of an additional runway in the South East.

1. Essential changes need for a 3rd runway at Heathrow

Richmond Heathrow Campaign has developed a computer airspace noise model to examine airspace design principles and specific flightpath proposals (perhaps it is presumptuous to call it ANCON lite but its aims are similar). The model’s Study Area centres on Heathrow airport and is 8,000 square km and up to 4 miles high. There are some 32,000 noise cells, each 500 by 500 metres. The model is 4 dimensional (lateral, vertical and time) and is built from individual flightpaths starting with the existing 30 arrival and departure flight paths. The model has an interrogation capacity allowing flight paths to be added, deleted, changed and operational procedures to be changed, such as aircraft climb profiles, speed, etc.  We are not detailing the results here but make some general comments about airspace use. We must stress here that the following discussion should not be interpreted as favouring concentration or dispersion of noise or conclusions on respite.

2. Capacity Increase.

An increase of 50% in the number of flights from Heathrow with a 3rd runway  could mean in theory adding 50% throughput to each of the 30 existing flight paths in and out of Heathrow.  The hourly LAeq noise contours of each flightpath would be extended - substantially increasing the area exposed to noise. In practice, some routes are near capacity (e.g. arrivals of 40 ATMs an hour in segregated mode).  The noise impact from increased overflights on existing routes depends on the number of flights and height.  The decibel increase as a function of the number of overflights is asymmetric, so that there is a bigger increase in decibels with flight numbers increasing from say 2 to 4 ATMs an hour compared to 38 to 40 ATMs an hour.  Notwithstanding the variation in acoustic impact, it seems likely many people will resist a 50% increase in the number of flights overhead. 

Either because the existing flightpaths cannot take more flights or because the increased noise impact is too great, there would need to be consideration of adding flights to less well used flightpaths and to creating new flight paths.  Besides considering use and capacity of individual flightpaths it will be necessary to consider the Heathrow network as a whole (e.g. aircraft lateral and vertical separation) and its interaction with the networks from other airports, such as for Gatwick.

3. We are concerned that even with new technology it will be very difficult, if not impossible, not to substantially increase the population exposed to aircraft noise from Heathrow expansion and over the long term.  Population growth and slower introduction of less noisy aircraft are likely to prolong the blight. There is a legacy of noise and any change either by increasing the total noise energy or it allocation is surely going to be hugely controversial. Even without Heathrow expansion and with the headroom from less noisy aircraft, modernising the airspace will be very controversial.

4. Lateral dispersion

It has been suggested that concentration might be diluted to reduce the noise effect on the ground. PBN and other technologies that are being introduced to improve efficiency tend to concentrate overflight compared to the more random distribution hitherto.  One suggestion discussed in the consultation and elsewhere is the increased use of scheduled respite.  For a start, for those under the final arrival paths legacy respite is likely to be cut in half. Elsewhere, it may be possible to rotate multiple flightpath use, thus providing scheduled respite. From our modelling to date we question whether there is enough airspace to introduce multiple flightpaths and still provide full respite. We find from our modelling that the flight path footprints are of such a size that the footprints may have to overlap resulting only in partial respite.  Clearly, the footprint size varies with noise level measured but we strongly believe a WHO 50 decibel daytime level should be considered when designing flightpaths. Arguably, an ambient level of say 45 decibels should be used. We might add that our modelling assesses noise across four timeframes (single event, hourly (which reflects the throughput numbers), daily (which reflects respite) and annual (which reflects the easterly/westerly mix)). Furthermore, splitting a flightpath into say two flightpaths results, for example, in a 3 decibel reduction in the original single flightpath but a 7 decibel increase over a wider area. This is the result of the asymmetric maths of noise dispersion. It is then a question (in this example) of whether a reduction from say 57 decibels to 54 decibels for some people is equitable with an increase from say 45 decibels to 53 decibels for a larger number of people.

5. Vertical dispersion

We doubt the often suggested benefits of steeper climb and descent rates.

6. Conclusion to Question 3

We believe from third party evidence and our own modelling of airspace design that expansion of Heathrow will prove extremely controversial from a noise point of view. No matter how much consultation and independent opinion is input into the decisions, the fact is that a 50% increase in noise energy cannot be mitigated to any meaningful extent in such a heavily populated area as London.  The rate of introduction of less noisy aircraft is offset by population growth (37% between 2011 and 2050 according to the Mayor’s London Plan). Compensation and insulation, while of course welcome, will be a woefully inadequate response.  According to the Airports Commission the number of people exposed to noise from Heathrow within the 55 LDEN (24 hour) would reduce in a 2 runway case from 725,000 in 2012 to 588,900 by 2040 compared to 618,100 with three runways (carbon capped Total optimised). Heathrow would remain by far the noisiest airport in Europe. We believe that the contours actually underestimate the noise effect on people under each flightpath.

We should point out what we believe to be an error in the comparison between Commission’s two and three runway cases, whereby the Commission optimised the airspace design for 3 runways but not for 2 runways, which means the incremental Webtag valuation for a 3rd runway is substantially overstated. 

A major decision process issue arises in that flightpath design for Heathrow (with or without a 3rd runway) is unlikely to be published until around 2024 - several years after a development decision on a 3rd runway will have been taken. In the meantime London will be blighted by the existing noise and uncertainty of the location and use of future flightpaths. It is unclear how a development decision can rationally be taken without there being a planned airspace structure.

Question 5: The barriers to modernisation of airspace, including the environmental and community considerations arising from changes to the current arrangements for managing UK airspace.

1. The Objectives

The Government’s objective is ‘To limit or reduce the number of people significantly affected by aircraft noise. We agree there is a need for some such objective but the one proposed is seriously flawed. 

1. It is not clear whether the word ‘limit’ applies to some existing measurement or to zero or some future growth.
2. The use of a threshold (significantly affected) has serious drawbacks.  In absolute terms what do the words ‘significantly’ and ‘affected’ mean.  Is this a societal objective or applicable to individuals? Any noise above ambient levels can be intrusive and we have seen the dangers of relying on a metric threshold of 57 LAeq. We prefer to consider a marginal cost continuum of impact above ambient - ambient being the true threshold.
3. The number of people above a single threshold fails to reflect the fact that the affect increases above this threshold. Aircraft noise management is very much about the allocation of noise not just between those significantly affected and those not so affected but between those significantly affected.

Our approach to changes in noise climate is to prioritise a reduction in noise for those most affected and avoid as far as possible anyone experiencing an increase in noise.  We should remember that the rate of reduction in noise from source is much slower than it used to be and it may take decades for improvements to be noticed across a whole fleet of aircraft. 

2. The Balanced Approach

We broadly accept the ICAO Balanced Approach for managing aviation noise. But reduction in noise is far too slow. The four elements of the Balanced Approach are listed below. The aim is to ensure that operating restrictions are employed only as a last resort after full consideration has been given to the other dimensions of the ICAO Balanced Approach, namely:

• Reduction of noise at source

• Land use planning and management

• Noise abatement operational procedures

• Operating restrictions

A. Reduction of Noise at Source - Less Noisy Aircraft

We refer to evidence provided by the All Party Parliamentary Group on Heathrow and the Wider Economy (APPG) in their Inquiry Report ‘Noise from Heathrow Airport 18 December 2014’. The report refers to Heathrow using an annual 0.1dB annual improvement in their noise estimates (para 3.5). Respondents to the Inquiry said that ‘noise reduction achieved by new aircraft is not as great as sometimes implied’ and they provided the example of the A380. The Consultation refers to the expected improvement from the new aircraft with their footprint being 50% smaller on departure and 30% smaller on arrival, but we believe these estimates should be treated with caution, especially given the over-optimistic footprint forecast for the A380. The APPG also said that ‘future improvements in noise reduction on landing are likely to be materially less than on take-off’.

On the subject of fleet replacement it was said by the APPG that ‘fleet replacement is an allocation of aircraft from each airline’s international fleet and is not solely governed by Heathrow requirements.’ Heathrow assumes most of the current Heathrow fleet (around 3,500 aircraft) are phased out by 2030, which would appear to be a significant shortening of the fleet life to just over 15 years compared to the historic 25 years.

B. Land Use Planning and Management

The replacement of the planning guidance PPG24 with a new National Planning Policy Framework and Localism Act has thrown into some confusion the ability of local authorities to prevent new buildings when noise levels are high. Combined with the demand for new housing, schools, etc. on account of population growth in London (37% growth from 2011 to 2050 according to the London Plan), the pressures to build are probably paramount except close to Heathrow. The precautionary approach would be to assume that everyone in a radius of 40 to 50 kilometers from Heathrow will be impacted by aircraft noise.

C. Noise abatement operational procedures

The operational measures can improve performance or reduce noise or a combination. We believe that individually the measures tend to have relatively small impact on reducing noise on the ground but in aggregate should have some positive impact. But, the Heathrow APPG in its Inquiry report ‘Noise from Heathrow Airport December 2014’ said ‘Generally, respondents expressed the view that changes to operational procedures were likely to deliver marginal noise reduction benefits, if they were indeed feasible at all.’

D. Operating Restrictions

The various flight path restrictions such as NPRs and height bands are important and need careful attention in modernisation of the airspace.   The change process is also important.

3. Noise measurement and metrics

We recommend that the objectives should include a commitment that operations at Heathrow Airport will move towards compliance with the World Health Organisation’s limits on noise (individual noise level and average noise level). Such a commitment is long overdue, bearing in mind that noise from air traffic is still a major disruption for many people living within audible distance of Heathrow’s flight paths.

13 April 2017