High Weald Parish Councils

HIGH WEALD PARISH COUNCILS AVIATION ACTION GROUP (Chiddingstone, Hever, Leigh and Penshurst Parish Councils)

Contact: Mrs Louise Kleinschmidt, 2 Bothy Cottages, Threshersfield, Chiddingstone, Kent. TN8 7NE Tel: 01892-871651 Email: [email protected]

The High Weald Parish Councils Aviation Action Group was formed in 2013 due to the common need to campaign against excessive aircraft noise, low flying aircraft, night flights and the threat of a second runway at Gatwick Airport. The group consists of local residents and representatives from Chiddingstone, Hever, Leigh and Penshurst Parish Councils, and these Parish Councils have passed resolutions to allow the High Weald Parish Councils Aviation Action Group to respond to consultations and to campaign on behalf of their communities. Our Kent County Councillor for Sevenoaks South and also a representative from the Gatwick Area Conservation Campaign both attend our meetings, and their support and knowledge has been invaluable.

As a whole, the High Weald Parish Councils Aviation Action Group represents a population of 5,902, and an electorate of 4,650 across the four parishes.

14th January, 2014 London Airspace Consultation Harrow HA1 2QG

High Weald Parish Councils Aviation Action Group Response to the London Airspace Consultation

A summary of High Weald Parish Councils Aviation Action Group, from here on referred to as the Group, view is below:

 We oppose the realignment because there is insufficient information to make a reasonable judgement. Being under a realigned flight path would blight any community.  We propose a further round of consultation after the realignment has been decided.  We propose multiple routes on a rota basis (not a multiple of 7)  We propose that CDA is enforced.  We propose that height levels of aircraft should be maintained at the maximum height through the controlled area in accordance with safe landing.  We propose that given the aims of AONB, NT and other heritage properties in the group area they suffer unduly from visible and noise impact of aircraft and should qualify for greater respite.  We propose that affected individuals and communities and businesses should be compensated financially.  We propose that a new metric for measuring aircraft noise and impact is found that takes account of tonal change and ambient noise. The current measure is obsolete.  We propose no increase in night flights and preferably a reduction to no night flights.  We oppose a second runway at Gatwick. This response has been completed in the same format as the NATS Questionnaire.

1. Gatwick Airport is seeking to realign all Runway 26 departure routes below 4,000ft to help make best use of the existing runway. Please indicate the extent to which you support or oppose this objective to realign all Runway 26 departure routes below 4,000ft to help make best use of the existing Runway. The Group opposes the realignment for Runway 26 departures.

Please state the reasons why you support or oppose this objective. The Group opposes it because there is no information on where the new flight paths would go.

2. This proposal is considering extra routes to enable periods of respite. This would mean implementing two routes in a particular direction instead of one, with a schedule for using each route to provide periods of relative respite for people living in the area beneath the routes. While this would provide respite, it would also increase the geographic area regularly exposed to noise. Please indicate the extent to which you support or oppose this objective of providing respite routes, given that it potentially impacts more people in order to offer respite. The Group supports respite routes.

Please state the reasons why you support or oppose the objective of providing respite routes. We support identifying as many respite routes as possible in the controlled area. Being subjected to occasional noise is tolerable being underneath a single flight path or single respite route through any of the Group area would be intolerable.

3. Please indicate which, if any, place(s) or area(s) within the consultation swathes you think require special consideration in the on-going design process. Please describe the characteristics of these locations, stating whether they should be considered due to concerns about noise impact, visual impact and/or any other impact.

 High Weald Area of Outstanding Natural Beauty: The primary purpose of the AONB designation is to conserve and enhance the natural beauty of the landscape, with two secondary aims: meeting the need for quiet enjoyment of the countryside and having regard for the interests of those who live and work there. The noise and visual impact of a large number of aircraft is inconsistent with the purpose of this designation.  There are a number of properties and businesses in the Group area that we know suffer severely from the noise and visual impact of aircraft. These locations have all responded to the consultation and we support their case for special consideration. o Hever Castle o Penshurst Place o Chiddingstone High Street as National Trust property. o Chiddingstone Castle.

4. In what, if any, geographic locations should options be considered for altering routes for respite purposes? What should the criteria be? The Group supports the concept of multiple respite paths on the existing vectored broad swathe approach to touchdown to minimise the noise impact in the controlled area.

5. Altering routes to fly around environmentally sensitive areas rather than overhead is likely to mean more fuel burn and more CO2 emissions because the altered route would usually be longer. In general, which should take precedence - minimising overflight of sensitive areas by flying a longer route around them, or flying the direct route overhead the area to keep the route shorter and minimise fuel burn and CO2? What, if any, factors should be taken into account when determining the appropriate balance of flying around environmentally sensitive areas versus overhead (for instance the altitude of the aircraft may be a factor, or the frequency/timing of flight)? Flying longer routes around environmentally sensitive areas should always have greater precedence than flying overhead on shorter routes which minimise fuel burn/ CO2.

CO2 burn can be offset, noise cannot. All environmental impacts should be considered. The Group would welcome an idea of the extra fuel required and would support GAL offsetting this extra fuel burn with a compensating measure.

6. This proposal is seeking to change the way aircraft use airspace by developing a system for managing arrivals based on Point Merge, rather than the holding stacks/vectoring currently in use. Please indicate the extent to which you support or oppose our objective of providing a future arrival system based around Point Merge.

 The impact of the flight path from Point Merge to landing will be extremely detrimental to the communities under the new flight path.  Point Merge as proposed will impose an intolerable burden if a single path is chosen as a result of this process.  The consultation asks for an opinion on a concept but the Group needs to see how that concept would work in practice. There must be a second round of consultation after this has been decided.  Until such time as a flight path or paths are shown with respite routes the Group will oppose it.

Please provide any additional information you think is relevant to our objective to redesign arrival routes around a Point Merge system. The Group believes the following points should be addressed:

 Multiple routes( as many as possible in the controlled area)  Rigorous enforcement of 3%CDA  Keeping aircraft as high as possible for as long as possible within safety limits  Greater efficiency during the day should be compensated for by no more night time flights and preferably a reduction to zero.  Compensation for those individuals and communities affected. CT and Rate rebate.

7. Procedures for accommodating operators who are not compliant with the RNAV1 standard are yet to be finalised. Accommodating non-compliant operators will reduce overall system efficiency for the majority of the fleet which is RNAV1 approved. To what extent should non-certified aircraft be accommodated (NB you may wish to highlight more than one of these options)? A short timeline should be given for the exclusion on all non-compliant aircraft.

What, if any, comments do you have on accommodating non-certified aircraft? No comments.

8. Should fuel for the Point Merge arcs be considered part of the contingency fuel uplift, or part of the flight plan fuel uplift? Please state the reasons why you believe fuel for the Point Merge arcs should be considered part of the contingency fuel uplift or part of the flight plan fuel uplift. No comments.

9. This proposal seeks to reduce overall fuel burn across the fleet by as much as possible even if it means some individual routes may be less fuel efficient as a consequence. Please indicate the extent to which you support or oppose this objective. The Group oppose this objective in as far as the environmental and economic benefits of lower fuel burn need to be understood and managed in the context of other impacts of the objective. In this case no consideration is given to a greater noise impact and economic blight on house prices and other businesses under the shortest flight path. Furthermore fuel burn will increase with the greater number of flights into Gatwick. The Group supports reducing fuel burn through restricting the number of flights to the current level and greater fuel efficiency by aircraft.

10. This proposal is seeking to lower some areas of controlled airspace to accommodate arrival flows. To what extent would the proposed changes affect General Aviation (GA) operations? Would they have a large impact, a medium impact, a small impact or no impact at all? No comments.

If you believe it would have an impact, please describe the operation that would potentially be affected. No comments.

11. Please provide any other information that you feel is relevant to the on-going development of the airspace covered by this consultation. The Group considers the following points are relevant and should be addressed in the consultation and acted upon thereafter;

 Measuring Noise: UK Civil Aircraft Noise Model (ANCON) in assessing noise disturbance caused by overflying aircraft is flawed. In the Summary of Responses to the Draft Aviation Policy Framework Consultation, recently published by the Department for Transport, the consensus of public opinion was: “The 57 dB LAeq, 16h contour is the wrong means of measurement because it is outdated / represents an average / is ineffective. In summary, there is no confidence in this contour as the (sole) basis for taking decisions regarding aviation noise.”  The Group supports the retro fitting of vortex generators on all of the A 318/319/320 series of aircraft to eliminate the high pitched whine created on the underside of the wing by the pressure equalisation vents for the fuel tanks. Lufthansa have done this already and Easy Jet need to.  Types of aircraft noise: In addition the Leq57dBa Contour has failed to recognise the tonal effects of airframe noise from so-called quiet aircraft such as the Airbus A 318/319/320/321 series. This problem has now been formally publicised by the CAA some eight-years after they were first made aware of it. On the 16 October 2013 the CAA confirmed: “Following concerns raised around Heathrow airport in 2005, the issue of tonal noise emanating from the A320 family of aircraft on approach was brought to the attention of Airbus by the CAA. Complaints of a high pitch “whine” which could be heard on the ground at relatively large distances from the airport (Greenwich). Measurements undertaken have confirmed the tonal noise is due airframe noise not engine noise and is on all present A320 family variants.” The CAA went further and acknowledged that the sound was deafening enough that it could only be masked close to the airport “by noise from landing gear, flaps and the higher thrust required in the landing configuration.” They continue “Tone is emitted around 500-600Hz, close to peak sensitivity of the human ear, hence it is very perceptible. Very audible during intermediate approach phase 7-15nm from landing.”  Night flights. There should be no night flying into Gatwick. The World Health Organisation considers that sleep disturbance can lead to fatigue, hypertension, greater risk of heart and respiratory problems, poor performance at work or in school, greater difficulty in concentrating and thinking clearly, an increased likelihood of accidents, depression, anxiety and drug and alcohol abuse. The EU Noise Directive commits the EU to developing a long- term strategy to reduce the number of people affected by noise. Night flights are not essential to the United Kingdom economy.  The Group opposes a second runway at Gatwick.

Louise Kleinschmidt