Greg Hands MP Heathrow Submission on Airspace and Future Operations
I am responding to this consultation as the Member of Parliament for Chelsea and Fulham; a community that has been subject to intense noise disturbance from Heathrow for many years.
As someone who resigned from Government in order to vote against proposals for a third runway, and who has campaigned against the expansion of Heathrow Airport for more than a decade as a Member of Parliament, I have made clear that I am against an expanded Heathrow and the subsequent increase in flights (including and in particular night flights) that I believe will occur as a result.
For the past twenty-seven years, I have lived beneath the Heathrow flight path and, like many hundreds of thousands of Londoners, I am frequently woken up by aircraft noise. These Londoners have jobs to do and families to look after, for which they require a good night’s sleep. Accordingly, not only are people losing sleep because of being disturbed by aircraft noise during the night, but their daily lives are being indirectly affected by it.
Essentially, my belief remains the same as during the previous consultation: that there should be a comprehensive ban on night flights at Heathrow Airport between 11pm and 6am. I have made this as clear as possible in the submission that follows.
While I would in theory support the concept of a noise objective, Heathrow must be clear on whether their priority is to reduce and limit the number of people significantly affected by aircraft noise, or whether it is to prevent additional people being overflown that are not currently situated along a flight path. Widening the envelopes may allow Heathrow to provide longer periods of respite for some communities but may also result in additional communities being overflown. These two aims may be contradictory, and it is not clear which takes precedence. Heathrow are yet to provide information on which areas will get more noise or experience noise for the first time.
With an extra 25,000 flights before the third runway has even been built, this noise objective seems incompatible with the proposed increase.
Additionally, I am concerned that the terms ‘proportionate’ and ‘cost-effective’ are vague. Such language allows the goalposts to be moved and gives Heathrow total autonomy in setting the threshold for what is considered proportionate or cost-effective.
It is crucial that the Government definition of noise annoyance (defined as above 54dB [LAeq]) is maintained as the metric against which Heathrow measures noise disturbance.
I understand the point at which planes lower landing gear is approached differently by different airlines. However, this has a major impact on noise (and indeed affects communities further away when landing gear is prematurely lowered) and it is therefore my belief that Heathrow should enforce rules around when and at what altitude landing gear can be lowered.
Respite through runway alternation
A third runway would most likely reduce respite for people in West London and mean others face continual operations – with no respite – for the first time.
It is also important that departure flight paths do not coincide with arrivals, so that no community is subjected to both. I am concerned that with a third runway, some areas of West London would experience departures for the first time ever.
However, I also understand that making better use of a second runway could allow for flights to begin later. I am totally opposed to night flights (before 6am, which is still very early) and would therefore support efforts to increase the number of hours for which the night flight ban is effective. However, this must not come at a cost to those living under the flight paths and should not be used as an excuse for reducing available periods of respite during the day.
I would like to see the removal of the current Westerly preference which I believe will split the burden of noise disturbance more equitably across London. However, whether the priority is reducing the number of people overflown or increasing the period of respite for those already overflown is something Heathrow need to provide clarity over, particularly as the first objective seems incompatible with removing the Westerly preference.
There may be other consequences of removing the directional preference (e.g. safety implications, a possible increase in the number of Westerly flights during the day or at unsociable hours) that the consultation does not fully address, if at all. Heathrow need to provide further information on which communities would be most affected by a change in directional preference and whether this will have an adverse impact on noise levels and/or pollution.
Night flights 1 – early morning arrivals
The Government have requested that the ban on night flights is increased from 5 hours to 6.5 hours. This is a move in the right direction. While a longer duration of respite during the night and early morning is welcome, I am concerned that flights will be concentrated and intensified in order for Heathrow to deliver an increased number of flights in a shorter day. Again, this should be considered carefully and avoid causing a loss of respite.
I am sceptical as to the real value of delaying arrivals by just 15 minutes, particularly if this results in a greater number of flights arriving in the early morning period, or if more communities will be overflown as a result.
It is concerning that Heathrow have not yet indicated whether a longer ban on night flights would change the time of the first departure (rather than arrivals).
Additionally, the timings apply only to when aircraft arrive at or leave the stand, not when they land on or take off from the runway. A first arrival of 5:30am will mean some communities nearby will still be experiencing noise as early as 5am.
Furthermore, flights are very frequently delayed. At present the ban only extends to scheduled flights, as opposed to flights that are delayed. This is deceptive to many communities, who believe there will be no flights taking place during this period.
Night flights 2 – other night restrictions
I believe more stringent restrictions on noisier aircraft should operate during night time, such as allowing only certain quieter planes to fly during this period. Additionally, landing charges and those for the noisiest aircraft should be increased significantly.
All aircraft landing at night should, in my opinion, be required to pay an additional charge, with the revenue collected by this being used for improvements to community mitigation measures.
Airspace Change 1
Chelsea and Fulham are highly residential areas – and two of the most densely populated boroughs in London – a factor which needs to be taken into account when considering the number of people who will benefit or be impacted from changes to night flights, directional preferences and aircraft requirements for noise. Being a highly residential area means there is less likely to be other external noise present. It also follows that respite will be more highly sought, particularly on weekends, when most people expect to be able to sleep beyond the typical start-time of a working day.
Airspace Change 2
Independent Parallel Approaches (IPA) is likely to result in significantly more noise for communities living below it; indeed the CAA have described it as creating a ‘noise canyon’.
It appears that the use of IPA will result in people being overflown in both directions for the first time.
I understand IPA would cease if the third runway comes into existence, but few of my constituents will find this reassuring. Instead, it may be seen as an underhand way of operating at near-expansion capacity. By casting this as just one part of the broader consultation, it obfuscates the real impact.