Please find below a description on each of the topics and questions that Heathrow is asking about in its consultation, followed by a comment by the No 3rd Runway Coalition on issues you may wish to raise in your response.
Please note that some topics have multiple questions. You do not have to answer every question, and please do not be put off if you do not understand the technical nature of all the questions – it is still important that you share your views on how noise should be minimised and your opposition to Heathrow’s plans.
Consultation Topic: Managing Noise for an Expanded Heathrow
Questions: 1a, 1b, 1c
Heathrow is seeking views on the following proposed noise objective:
To limit and, where possible, reduce the effects of noise on health and quality of life and deliver regular breaks from scheduled flights for our communities during the day and night. We need to do this whilst making sure the measures we put in place are proportionate and cost effective.
Suggested points to make:
- With or without expansion, communities will suffer more noise under Heathrow’s plans – the noise objective is therefore at odds with the impact of the proposed increase in flight numbers.
- Heathrow has failed to provide detailed information on exactly which areas will get more noise or experience noise for the first time.
- Government policy on noise states that annoyance begins at begins at 54dB (LAeq). It is vital that this metric is applied to the proposed changes.
- ‘Proportionate and cost-effective’ mitigation measures is a vague promise that looks like an excuse for doing as little as possible – they need to be at least as comprehensive and generous as at any major world airport.
Consultation Topic: Respite through runway and airspace alternation
Questions: 2a, 2b, 2c
Respite is a continuous period of time where there is no aircraft noise.
Runway Alternation is the practice when during the day, when planes are landing and taking off to the west (westerly operations), Heathrow alternate the use of the two runways to provide local communities with respite.
Under an expanded airport, airspace alternation would be introduced. Depending on which runway is in use at the time, arriving and departing aircraft would use defined flight paths to fly to and from the airport. These flight paths would then alternate so that communities further away from the airport would get respite as well as those closer in.
Suggested points to make:
- A third runway would see a significant reduction in respite for people in West London – 260,000 flights more every year (700 more a day) clearly reduces the chance for genuine respite.
- Communities at either end of the runway used for take-off and landing will potentially experience a significant loss of respite as they experience noise for a longer period. Other areas will be subject to continuous operations for the first time.
- It is difficult to know the full impact of the proposed changes because at this stage it is not clear where the new flight paths will be, nor how any alternation would be operated.
- In any case, ‘respite’ is not a panacea. When you get respite, it means the planes are flying over another area, instead of you. And when they get respite, the planes fly over you. It is a zero sum game. This proposal may mean you have days with no planes overhead, followed by days with double the number that you currently experience.
Consultation Topic: Directional Preference
Questions: 3a, 3b, 3c, 3d, 3e
With expansion, Heathrow wants to introduce a procedure called managed preference. This would enable the airport to change the direction that aircraft are taking off and landing rather than following the principle of ‘westerly preference” as they currently do (aircraft taking off and landing into the wind). This is in operation approximately 70% of the time.
Managed preference would mean that the airport operates in a westerly direction during the day and in an easterly direction at night. It is Heathrow’s preferred option. It could be used to minimise the number of people adversely affected by aircraft noise.
Suggested points to make:
- The switching of direction of arriving and departing aircraft has impacts for all communities concerned - for example, switching from a westerly to easterly preference would split the noise impact more evenly between communities but would increase the total number of people affected by aircraft noise.
- The consultation does not explain what the safety implications of the proposed manged preference would be.
- Managed preference would result in a significant change to airport operations and potentially increase the noise impact for those communities immediately to the East and West of Heathrow.
- It is unclear which flight paths would be in place with an expanded Heathrow, thus the real impact of this proposal remains unclear. Despite the intention otherwise, the use of managed preference could result in an increase in the total number of people disturbed by aircraft operations.
Consultation Topic: Night Flights 1 – Early Morning Arrivals
Questions: 4a, 4b, 4c
As part of the Parliamentary approval for the expansion of Heathrow, the Government have requested that a 6.5 hour ban on night flights is introduced (up from 5 hours today).
Suggested points to make:
- Until the precise flight paths are publicly available it is not possible to judge the total impact of the proposal.
- The consultation also says nothing about whether Heathrow proposes to change the time of the first departure.
- The night flight ban timings refer to the time at which the aircraft arrives at or leaves the stand, not when they land on, or take off from, the runway. A first arrival of 5.30am will mean that communities nearby will still be experiencing noise as early as 5am.
- Similarly, the 11pm end is the time the aircraft leaves the terminal stand; the plane will still be audible even half an hour later, as the aircraft climbs away.
- There is no mention of whether flights that are delayed are included in the ban.
Consultation Topic: Night Flights 2 – Other Night Restrictions
Questions: 5a, 5b
Suggested points to make:
- It could be argued that even stricter restrictions on the use of the noisiest aircraft should be imposed at night – only the newest and quietest planes are allowed to operate in this period.
- The landing charges at night and those for the noisiest aircraft should be increased significantly.
- For night flights, all aircraft should pay an additional charge. It should be the job of the new Independent Commission on Civil Aviation Noise to advise on the appropriate level. However, we suggest that the charges could be as much as ten times higher; with the revenue collected ringfenced for improvements to community mitigation measures.
Consultation Topic: Airspace Change 1
Questions: 6 and 7
The consultation document that includes the proposed airspace design envelopes can be found here:
Suggested points to make:
- For Question 6, respondents should set out in as much detail as possible any concerns about the impact of the design envelopes on their local community.
- Question 7 is asking for similar views to 6) above but specifically to the proposed introduction of Independent Parallel Approaches (IPA) for the existing 2-runway airport.
- IPA is likely to result in significantly more noise for the communities underneath, indeed the Civil Aviation Authority (CAA) have described the impact as effectively creating a "noise canyon".
- The use of IPA effectively offsets the approaches so that both runways can be used at the same time - the likelihood is that respite for the people underneath the inward flightpaths will be substantially reduced.
- It seems likely that people will, for the first time be overflown in both directions.
- Opponents of expansion should oppose the introduction of IPA given the number of extra flights it will allow Heathrow to release.
Consultation Topic: Airspace Change 2
Question: 8
Suggested points to make:
- Respondents should raise any wider concerns about the principles behind the airspace change and the design envelopes.
- For example, the concentration of flight paths seems to impose an unfair burden upon those already blighted by aircraft noise.
