Response 24350815

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About you

A. What is your name?

Name (Required)
Graeme Robertson

C. Where do you live?

Please select one item
(Required)
East of England
East Midlands
West Midlands
North East
North West
Northern Ireland
Scotland
Ticked South East
South West
Wales
Yorkshire and the Humber

D. Are you answering this consultation as:

Please select one item
(Required)
Ticked Resident affected by aviation
Airline passenger
Member of the General Aviation community
Member of the commercial aviation industry
Military
Government and / or other regulators
Representative or national organisation or institute
Elected political representative

E. Are you affiliated with any organisation?

Please select one item
Ticked Yes
No
Affiliation
Centre Line Action Group ( concerned with reducing aviation noise from Luton Airport )
Please select one item
Ticked Yes
No

G. Do you consent for your response to be published?

Please select one item
(Required)
Ticked Yes, with personal identifying information (name, location, respondent category, organisation, additional information - please note your email address will NOT be published if you choose this option)
Yes, anonymised
No

General observations

1. Considering the draft guidance overall, to what extent does it meet the following criteria?

Comprehensible – it is clear to me what happens
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Transparent – the activities are explained well and will take place as publicly as possible
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Proportionate – the guidance strikes the right balance between detail as to what should happen, and flexibility to allow for different local circumstances
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
How would you improve?
My observations are as a member of the public who is angered and frustrated by the indifference of the industry to the noise it creates close to Luton airport And I am motivated to respond to combat the indifference and failure to address and stop further damage caused by concentration of departure flights out of Luton that are concentrated and neither i nor my neighbours were made aware beforehand . Nor was there any direct communication or engagement plus no local media is distributed in our area. I am particularly concerned therefore that there needs be a priority Airspace Change Proposal to set mandatory and regulated lower levels of sound pollution. And an independent regulataor is set up to act on behalf of people like me who the airport operators are keen to ignore. Noise pollution is a safety and wellbeing issue for people on the ground, and needs to be strongly regulated in the same way as other aviation safety and wellbeing issues in the air. Noise pollution needs to be reduced as a priority as an Airspace Change Proposal And accordingly the appointment of an independent Aviation Noise Regulator should be a priority The growth of noise and sudden introduction of excessive noise as flights become concentrated is particularly unacceptable as has occurred under the R26 Match /Detling route out of Luton. This needs to be addressed quickly, and significantly faster than the 2-3 years it seems to take for airspace change And specifically to enforce compliance with lower levels of noise ICCAN needs to be empowered as the independent regulator, responsible for people's needs and the protection of the people on the ground suffering from noise (distinct from a CAA focus on aircraft industry needs) And in targeting, measuring and setting thresholds it's noise on the ground that needs to be measured rather than altitude on its own. Across all of this the general lack of transparency and clear proactive communication with the public needs to be changed. People need to be part of the process in a meaningful way It is unacceptable that the sudden changes come as an unpleasant surprise to the public. Therefore as is normal in consumer driven industry, the aviation trade must communicate directly and frequently with the public, and not pretend that a lowest cost approach is effective.it isn't good practice to depend on press releases to low circulation media plus a website nobody knows about. Consultation needs to be paid more than superficial lip service

Tier 1a: Stages 1 to 7

2. Considering Stage 1 (Define) of the process , to what extent does the draft guidance on that stage meet the following criteria?

Comprehensible – it is clear to me what happens
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Transparent – the activities are explained well and will take place as publicly as possible
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Proportionate – the guidance strikes the right balance between detail as to what should happen, and flexibility to allow for different local circumstances
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
How to improve
1 Public opinion and the needs of the local communities must be addressed as well as the needs of the sponsor/airport operator Discussions amongst the people affected and the airport operator must be at the heart of any decision making And the public need a peoples' champion in the shape of ICCAN to act on their behalfand sit alongside the airport operator in framing strategy An empowered ICCAN independent of CAA should be able to intervene/moderate the aviation industry decision making, and operate in the public's interests in mitigating noise. eg addressing issues like the Luton R26 RNAV implementation and its intolerable impact on the community underneath, where concentration of traffic into a narrow corridor has increased the number of people affected by noise.

3. Considering Stage 2 (Develop and assess) of the process, to what extent does the draft guidance on that stage meet the following criteria?

Comprehensible – it is clear to me what happens
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Transparent – the activities are explained well and will take place as publicly as possible
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Proportionate – the guidance strikes the right balance between detail as to what should happen, and flexibility to allow for different local circumstances
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
How to improve
1 Best advice suggests improved measures - LAeq over shorter period at busy periods and identify where acceptable thresholds breached Peak LAmax and average LAmax of flights under flight path at 2-3 miles from airport Nx contours 2 Luton departures are held low with resultant noise impact because of departures from Heathrow, and resolution of this requires collaboration, and a better, more joined up approach. How much progress is being made to resolve this? And will this be transparent to the affected public?

4. Considering Stage 3 (Consult) of the process, to what extent does the draft guidance on that stage meet the following criteria?

Comprehensible – it is clear to me what happens
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Transparent – the activities are explained well and will take place as publicly as possible
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Proportionate – the guidance strikes the right balance between detail as to what should happen, and flexibility to allow for different local circumstances
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
How to improve
To address sceptical perceptions that CAA is not the most appropriate judge on how accessible consultation might be , I would want an independent ICCAN as third party that would help represent lay stakeholders. For fairness I would not want a large conurbation getting a marginal reduction in a low level of noise, to be replaced by a village being swamped with very high levels of noise from concentration of flights. A fairer set of criteria needs to be set up so noise is shared, and not all dropped on a minority of heads. Environmental policies protect and constrain commercial and industrial growth, and the skies over our rural village areas deserve similar protection from the lack of constraint on aviation expansion

5. Considering Stage 4 (Update and submit) of the process, to what extent does the draft guidance on that stage meet the following criteria?

Comprehensible – it is clear to me what happens
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Transparent – the activities are explained well and will take place as publicly as possible
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Proportionate – the guidance strikes the right balance between detail as to what should happen, and flexibility to allow for different local circumstances
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
How to improve
CAA should ensure sponsors consult with stakeholders with an independent third party as an intermediary on the public's side

6. Considering Stage 5 (Decide) of the process, to what extent does the draft guidance on that stage meet the following criteria?

Comprehensible – it is clear to me what happens
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Transparent – the activities are explained well and will take place as publicly as possible
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Proportionate – the guidance strikes the right balance between detail as to what should happen, and flexibility to allow for different local circumstances
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
How to improve
1 Luton has expanded by proposing growth in increments each below thresholds to cause a call in. It would be fairer for any future Luton proposals to expand to be reviewed in the context of previous recent growth Thus trigger a call in for the Secretary of State to review if over ten years they in gross terms have exceeded a reasonable threshold. 2 An independent ICCAN again would be a useful point of appeal to review and regulate proposals where noise impact is a likely outcome

7. Considering Stage 6 (Implement) of the process, to what extent does the draft guidance on that stage meet the following criteria?

Comprehensible – it is clear to me what happens
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Transparent – the activities are explained well and will take place as publicly as possible
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Proportionate – the guidance strikes the right balance between detail as to what should happen, and flexibility to allow for different local circumstances
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
How to improve
Is it CAA or DfT who ensures the ACCs are being engaged with ACP sponsors?

8. Considering Stage 7 (Post-implementation review) of the process, to what extent does the draft guidance on that stage meet the following criteria?

Comprehensible – it is clear to me what happens
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Transparent – the activities are explained well and will take place as publicly as possible
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Proportionate – the guidance strikes the right balance between detail as to what should happen, and flexibility to allow for different local circumstances
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
How to improve
CAA hadn't the resources to assess noise impact arising from Luton R26 RNAV, so an independent third party eg ICCAN should be empowered to assess the noise impact of PIR Public stakeholders need a champion for this as they won't have technical capabilities

Tier 1a: Evidence of engagement

9. At certain stages in the process (starting with the development of design principles at Step 1b) the CAA will look for evidence of a two-way conversation to see that the sponsor has adequately engaged stakeholders. In paragraph C9 the CAA describes the evidence that we will look for as "detail of what sponsors have been told by their audiences; how they responded to this feedback; and how it has affected the proposals they are bringing forward".    Has the CAA adequately detailed what we would expect to see to know that a two-way conversation has taken place?

Please select one item
Yes
Ticked No
Don't know
What else to show two way conversation?
CAA should contact district and local government and the chairs of local ACCs to get help understanding how effective engagement has been and remedy the huge shortcomings, that indicate a high potential for failure in the future.

Tier 1a:Third-party facilitation

10. At various points in the process (starting with the development of design principles at Step 1b) the CAA suggests that voluntary use of a third-party facilitator could be useful. Should the CAA be more prescriptive as to how and when a facilitator could be used?

Please select one item
Ticked Yes
No
Don't know
Facilitator further detail
A third party faciltator should be made available at sponsor cost to assist community and stakeholders to engage in the process and have access to expertise.

11. Are there any other places in the process at which you feel that a facilitator would be useful?

Facilitator - which places
Facilitator would help assess and ensure outcomes of proposed change are robust, and have been rigorously tested on the local ground, especially where it's necessary to demonstrate full engagement eg where actual outcomes have not match expectations in PIR

Tier 1a: Categorisation of responses

12. In paragraphs 177 and C34-C36, and Table C2, we discuss the categorisation of consultation responses. The sponsor is required to sort consultation responses into two categories: i) those responses that have the potential to impact on the proposal because they include new information or ideas that the sponsor believes could lead to an adaptation in a lead design option or a new design option, and ii) those that do not. Is the CAA's explanation of the categorisation exercise and description of the categories sufficient?

Please select one item
Yes
Ticked No
Don't know
Categorisation - additional detail
An independent appraisal by expert independent third party would be useful to determine what 'new information' is required that would impact on the proposal

Tier 1a: Options appraisal

13. In paragraph E25 and E34 the CAA states that methodologies for the various aspects of the options appraisal should be agreed between the CAA and the sponsor at an early stage in the process, on a case-by-case basis. This provides flexibility for different local circumstances. Does this approach strike the right balance between proportionality and consistency?

Please select one item
Yes
Ticked No
Don't know
OA - explain re proportionality
Local ACC should be involved to increase transparency and increase community collaboration Baseline noise levels should be established in affected areas before change

Tier 1b: Temporary airspace changes

15. Considering Tier 1b changes, to what extent does the draft guidance on temporary airspace changes meet the following criteria?

Comprehensible – it is clear to me what happens
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Transparent – the activities are explained well and will take place as publicly as possible
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Proportionate – the guidance strikes the right balance between detail as to what should happen, and flexibility to allow for different local circumstances
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
How to improve
If noise impact is likely to be significant then consultation with stakeholders is essential

Tier 1c: Operational airspace trials

16. Considering Tier 1c changes, to what extent does the draft guidance on operational airspace trials meet the following criteria?

Comprehensible – it is clear to me what happens
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Transparent – the activities are explained well and will take place as publicly as possible
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Proportionate – the guidance strikes the right balance between detail as to what should happen, and flexibility to allow for different local circumstances
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
How to improve
it is just critical consultation with local stakeholders is executed thoroughly if there is an increased noiseon the ground that will disrupt the community

Tier 2: Permanent and planned redistribution

18. The Government proposals talk about a Tier 2 change as one which is likely to alter traffic patterns below 7,000 feet over a populated area and which therefore could have a potential noise impact for those on the ground. The key requirement is that the air navigation service provider must demonstrate that it has assessed the noise impact of the proposed change and engaged with affected communities as appropriate. Which stages of the Tier 1a airspace change process do you think are necessary for a proposal categorised as a Tier 2 change? Please select all those which apply:

Please select all that apply
Ticked Stage 1 Define
Ticked Stage 2 Develop and assess
Ticked Stage 3 Consult
Ticked Stage 4 Update and submit
Ticked Stage 5 Decide
Ticked Stage 6 Implement
Ticked Stage 7 Post-implementation review
None of these
Don’t know
Tier 2 reasons
Expansion of aviation is a major polluter in terms of noise and emissions There hasn't been a concurrent improvement in aviation technology to cancel out that pollution environmental impact, and the damage that does to peoples' health and wellbeing is increasing But going forward CAA will want to fulfil its duty of care to the public to reduce noise The communities affected and their ACCs will want to support the CAA in speeding up activities to address a reduction especially in noise So it is critical proper engagement occurs

19. The CAA’s process for Tier 1a changes is scaled into ‘Levels’, based on the altitude-based priorities in the Government’s Air Navigation Guidance (i.e. where noise impacts are to be prioritised or considered alongside carbon emissions, a more demanding consultation is required). Could the future Tier 2 process also be scaled?

Please select one item
Ticked Yes
No
Don't know
Tier 2 - scaled reasons
In a world where aviation growth is commercially inevitable, the industry must prioritise reduction of noise And for Luton that means gettingingdeparting flights higher sooner in collaboration other airports eg Luton and Heathrow Reduce the carbon emissions is an issue at higher altitudes, plus eliminating resource inefficiencies like stacking Efficiencies in both by adopting in significant volume new engine technology

Tier 3: Other changes to air operations affecting noise impacts

21. To what extent does the draft best practice guidance on Tier 3 changes (other changes that may have a noise impact) meet the following criteria?

Comprehensible – it is clear to me what happens
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Transparent – the activities are explained well and will take place as publicly as possible
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Proportionate – the guidance strikes the right balance between detail as to what should happen, and flexibility to allow for different local circumstances
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
How to improve
Where technology allows swathes of aircraft to concentrate, the aviation business must recognise it has an obligation to the people on the ground NOT to increase noise Experiece suggests that it seems to be something they can ignore cf the indifference Luton has to the afflicted people under recent RNAV Introducing PBN must be seen as a Tier 1 change with likely major noise impact, as it is probable that it will become the new motorway in the sky, ad will be a major shift in traffic and noise.

22. Where industry does not follow the CAA’s guidance in respect of Tier 3 changes, or where there is a clear breakdown of trust between an airport and its stakeholders, is it appropriate for the CAA to publicly draw attention to this?

Please select one item
Ticked Yes
No
Don't know
CAA action on Tier 3 further detail
The industry won't self regulate nor currently would the public trust it if it promised it would. CAA needs to assert its powers to monitor and be a strong regulator So CAA must capture, record and disseminate all the data relevant to trends affecting noise - numbers of flights, altitudes etc, and on the basis of that decide if a significant change has taken place And whether the chage of a scale requiring discussion with local planners ie if an airport has increased in size without any airspace change proposal.

23. Considering the list of potential information proposed, would you suggest any additions which would help stakeholders, including communities, understand the impacts of Tier 3 changes and enhance transparency?

Additional information on Tier 3 impacts
The role of an ACC is to protect its community from any l;ack of transparency CAA needs to monitor whether airports are being transparent and to be a place ACC can go to and appeal against any breach of transparency If this transparency and communication of an ACP is key, then the CAA must take responsibilty for enforcing that principle, and being ready to provide redress where there are lapses

24. In relation to mitigating the impacts of Tier 3 changes, our draft guidance says that the focus should be on exploring the options for mitigating the change through two-way dialogue, because of the local and often incremental nature of Tier 3 changes. Does the guidance need to give more detail?

Please select one item
Ticked Yes
No
Don't know
Tier 3 mitigation - reasons for Q24 answer
Where a major real change in scale of operation has taken place ie growth of airport, increased flight volume, change of departure patterns and altitude, more noise, more sensitive traffic at night time, then there must be intervention and regulation by CAA Growth by stealth and a soft regulatory culture is unacceptable, and the CAA has a duty to protect the public.