Response 687613252

Back to Response listing

About you

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

Please select one item
(Required)
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(name, location, respondent category, organisation, additional information - please note your email address will NOT be published if you choose this option)
Ticked 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 Considering the draft guidance overall, to what extent does it meet the following criteria?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?
This Consultation document is very difficult for most people to understand, especially if they're not specialists in the Aviation Industry; this makes it extremely difficult for ordinary people, who are adversely affected by aviation, to engage with the CAA. The Aviation Industry has had its own way for for too long and it's now about time that the population overflown is fully considered and listened too; the continual growth of aviation is not sustainable in terms of human health and wellbeing for those overflown and in terms of environmental destruction. The draft guidance encourages engagement and transparency from airports, but there is little means of redress if people feel that the communication has been inadequate, or if they doubt the accuracy of the information provided.
General observations
As long as the CAA considers its primary duty to be about facilitating aviation growth, it will be unable to make impartial judgements about airspace change that balance the public interest with that of airports and airlines. In a modern, civilised democracy, human health and wellbeing MUST take priority over the ambitions of big business, such as the aviation industry. The CAA must do all that is possible to protect the population overflown from ever increasing noise and pollution. Aircraft operations may be exempted from certain noise nuisance laws, but there is no legal immunity from an activity that is proven to damage human health and wellbeing. There is now a mounting body of evidence showing the adverse effects that aircraft noise has on those living close to airports and under concentrated flight paths. If it is known that excessive aircraft noise causes harm to human beings, then any organisation responsible for this, but which fails to act, would be putting human health at risk.

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 2: the guidance mostly meets this criterion Ticked 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
Everyone who may possibly be affected by airspace change should be able to comment at the earliest opportunity, from Step 1A, not just from Step 1B. COMMUNITIES MUST HAVE TRUST IN THE PROCESS.

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
In terms of 'cost benefit analysis', I feel that's it's wrong that people's health and wellbeing should be determined by monetary values. Human health MUST take priority and the main consideration should be the health and environmental concerns of those overflown, not the financial benefit to the aviation industry. The environmental assessment does not consider background noise levels. Many people are disturbed by aircraft noise when the background level is otherwise quiet and this is made worse when the number of flights increase, effectively creating a 'noise ghetto' where there is almost constant plane noise. Height-based priorities are not an honest way of determining whether or not noise impacts are significant. Let's be honest here: aircraft DO NOT become silent when they reach an altitude of 7000 feet and the noise from their engines and airframe is still objectionable, especially in rural and semi-rural areas. We really need to move away from these 'convenient' myths that the aviation industry keep using in order to justify their continual ambition for growth. Concentrated flight paths, even with aircraft well above 7000 feet altitude, are extremely disturbing to those overflown. It's not just the noise level of each individual aircraft, it's the impact of the number of flights (frequency) in any given period of time, that affects the health and wellbeing of those overflown. WITH EVER INCREASING FLIGHT NUMBERS AND CONCENTRATED FLIGHT PATHS, ALL THE OLD 'MYTHS' ABOUT AIRCRAFT NOT CAUSING DISTURBANCE AT 7000 FEET NEED TO BE SERIOUSLY RE-EXAMINED. DON'T JUST ACCEPT THE OLD 'FACTS' AS TRUTH, WHEN CLEARLY THEY'RE WRONG. The bottom line is that the aviation industry want ever increasing growth and profit and they want the CAA to help them achieve it; well, in our modern, civilised democracy, I say NO - the aviation industry can't have it all their own way at the expense of human health and wellbeing. The CAA MUST protect the interests of those adversely affected by the harmful increase in flight numbers and concentrated flight paths, before the purely financial interests of the aviation industry.

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
Anyone who may be adversely affected by changes to airspace should be provided with specialist support in order to effectively participate in any Consultation.

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

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 2: the guidance mostly meets this criterion Ticked 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 2: the guidance mostly meets this criterion Ticked 3: the guidance does not sufficiently meet this criterion
How to improve
It appears that the CAA will prioritise the aviation industry's demand for ever increasing flights in a given portion of airspace, when of course the CAA should consider the health and wellbeing of those overflown first. In reality there is no difficulty in getting the balance right here: you either believe that human health is paramount, or you think that profit for the aviation industry takes precedence. As a human being, I think the correct priority is perfectly clear and shame on anyone, or any organisation that thinks otherwise.

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

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 2: the guidance mostly meets this criterion Ticked 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 2: the guidance mostly meets this criterion Ticked 3: the guidance does not sufficiently meet this criterion
How to improve
There need to be robust checks and balances following any airspace changes; people overflown need to be assured that the aviation industry will be held to account if changes do not occur as planned and claimed. There should be very severe penalties imposed on all sponsors if airspace changes cause suffering to those overflown.

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
No
Ticked Don't know

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
Yes
No
Ticked Don't know

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
It would be really, really helpful if one felt that their response to a consultation was actually taken into account. I have responded to several consultations which just seem to fade into insignificance. The recent consultations for night flights and Heathrow Airport for instance: everything has gone quiet on those, just as if they were purely a box ticking exercise to show that the Government has asked the questions. I'm afraid that an ordinary person like myself, who cares passionately about the value of human health, quality of life and the environment, will never be able to make my voice heard above the selfish ambitions of the aviation industry.

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
The process should always prioritise the health and well-being of those overflown, rather than the financial interests of the aviation industry; this is the only way to move forward.

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 2: the guidance mostly meets this criterion Ticked 3: the guidance does not sufficiently meet this criterion
How to improve
90 days (3 months) is a long time for a change that has not been consulted on and there's nothing in the guidance to limit how often these changes may occur.

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 2: the guidance mostly meets this criterion Ticked 3: the guidance does not sufficiently meet this criterion
How to improve
Communities (citizens with equal rights) must be consulted at the earliest possible opportunity, certainly never later than industry stakeholders; it's our health and quality of life at stake - not yours to 'push around' as you want. Innocent people overflown should not have to experience a long period of new airspace arrangements before being asked for their view on whether or not they would favour a return to the previous airspace operations. Please think about the human impact of increasing flight numbers and changes to airspace: this is not a game, this is real life and real people may well suffer from the selfish demands of the aviation industry.

Tier 1: Spaceflights

17. On 21 February 2017 the Government published the Draft Spaceflight Bill. As the foreword to the draft Bill sets out, “This legislation will see the Department for Transport and the Department for Business, Energy and Industrial Strategy, the UK Space Agency, the Civil Aviation Authority and the Health and Safety Executive working together to regulate and oversee commercial spaceflight operations in the UK.” Do you have any views on whether this process could be used or adapted to suit future airspace change proposals to enable spaceflights, as anticipated in the Draft Spaceflight Bill?

Spaceflight
The World is on the brink of catastrophic climate change and in terms of CO2 emissions per person, commercial space flights are a disaster; how the Government can even consider this is unbelievable. I have little faith that the human race will survive to the end of this century if we don't take man's contribution to climate change seriously. The idea of commercial space flights is so stupid, it would make a cat laugh.

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
The process MUST be rigorous and all stages are necessary.

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
Yes
No
Ticked Don't know
Tier 2 - scaled reasons
I do not believe that altitude-based priorities are appropriate for scaling, as they do not realistically reflect the actual noise disturbance caused. ALL overflights can be heard, especially if the background level of noise is low, and frequent overflights on concentrated paths are disturbing, whatever the altitude of the aircraft.

20. Are there any other comments that you would like to make about the CAA’s potential Tier 2 process?

Tier 2 - other comments
Why has no draft guidance been prepared on this Tier?

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 2: the guidance mostly meets this criterion Ticked 3: the guidance does not sufficiently meet this criterion

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

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
Communities overflown should have access to historical flight data, enabling them to compare the current situation with that of previous flight operations.

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
The noise impact of Tier 3 changes must be robustly addressed; self-imposed restraints by the aviation industry based on 'guidance' from the CAA is simply not good enough. The aviation industry cannot be trusted to act in the best interests of those overflown.