Response 1024333097

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

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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 Considering the draft guidance overall, to what extent does it meet the following criteria?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
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Ticked 1: the guidance is good and meets this criterion 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
Ticked 1: the guidance is good and meets this criterion 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
How would you improve?
intro para 10. no legal enforcement re guidance. Guess what.. if people dont have to do something they wont if it will cost them money and slow things down getting in the way of profit. CAA or ICCAN must have ways to incentivise proactive noise reduction. Fine the airports if they dont. You must fully understand how a private company operates to appreciate how they will aim to do the minimum to maximize profit. CAA being a civil service does not 'understand' this.
General observations
yes later

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 Considering Stage 1 (Define) of the process , to what extent does the draft guidance on that stage meet the following criteria?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
A sponsor can be a community - how exactly is a community going to get safety and quality assessments done? Who will finance them? Ans: No one - so the statement is meaningless unless there is a fund from which communities can seek grants to themselves pro actively reduce the impact of 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 2: the guidance mostly meets this criterion Ticked 3: the guidance does not sufficiently meet this criterion
How to improve
para 53 "The CAA expects airspace change sponsors to be mindful of current best practice and to factor it into a proposal where relevant" .. way too loose. Needs far more force.. MUST do.. otherwise it wont happen. para 69. If you use prnav the altitude thresholds are wrong. eg between 7000ft and 11000 ft IF you overfly a population at every 3 mins .. thats 18-20 planes an hour .. then can you guess what will happen? People will be really upset. especially if it starts at 5.50am in the morning. The dft thresholds were set in a time before prnav. why are you not listening to the case from people who are experiencing this around gatwick? Policy thresholds are not fit for purpose when using prnav. para 69 What does over 7000 ft mean? .. does that mean minimum? on average? - ie 50% to be below or above? or? table 2 "A change that will not alter traffic patterns below 7,000 feet over a populated area" .. what does over mean? if a prnav line is moved within 2miles of a population centre this will be over? Should be reworded within 2 miles of a population centre. para 115. it should be mandated that one of the options is the mathematically calculated option to give minimal exposure to the sid swathe. We know how this can be done and it should be then a yard stick against which other options are compared to. a6. sponsor is 'advised' to consult the following guidance alongside 1378... why only advised? MUST. why is 1378 not policy? It should be used as part of way to find the minimum exposing route/routes for a given sid. b.28 use of leq as yardstick is Redacted text wrong for prnav implementation. use of n61lmax1hr MUST be used. Sensitive hours 5am to 7.30 and 10pm to 12 midnight to be shown in hourly expected events of at least the n61 metric. This is becausae WHO says an external loudness of 61dblamax is likely to wake people up. b.53. says .".the change sponsor may wish to use additional noise metrics " so as written the sponsor does not have to do this... are you stupid? This is a must if prnav is being used. WHY dont you learn from the mistakes in cap750 which had similar ' may wish to' language? If sponsors dont have to they will not - especially if by doing so it impairs the case of the change they are proposing. Why do you guys not see this point? b54 B54. says " In most cases, we would expect no assessment or portrayal of noise from aircraft above 7,000 feet", And what if this policy is wrong when prnav is being used? No discussion? Here is exactly why your threshold values are wrong when using prnav. At 7000ft you will get 63db lmax in a swathe 1.5 miles either side of a prnav centerline.. This happens every 3 mins with prnav. Are you saying this does not matter? You are wrong. If you are not prepared to change the 7000ft threshold, then you MUST change the wording of b54 to say noise assessments between 7000ft and 10,000ft must be performed where prnav is being used. If you do not do this - you will have failed to learn the lessons that are so apparent from the prnav gatwick implementation and you will be open to a charge of incompetence. b.58 Concentration is likely to change the distribution of aircraft noise over communities close to airports,... yes but as above you need to understand chances will be significant beyond close distances from airport. .. sponsor must show and analyse noise impacts to 10000 ft due to high frequency of noise events of planes using prnav. WHY does this have to be pointed out to you time and time again? You are not listening and you are not learning. e15. it should be mandated that one of the options is the mathematically calculated option to give minimal exposure to the sid swathe. We know how this can be done and it should be then a yard stick against which other options are compared to.

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
para 63 re online portal.. good. but what is the mechanism if i dont understand an issue in a proposal .. do i ask the question/clarification through the portal? Or what?

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
Ticked 1: the guidance is good and meets this criterion 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
Ticked 1: the guidance is good and meets this criterion 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
Ticked 1: the guidance is good and meets this criterion 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
I am left unclear as to how environmental noise factors are weighted against effeciency. all i read is ' the manner it thinks is reasonable having regard to them as a whole.' as a process for balancing them. This is clearly not transparent. It could be interpreted that effecieny trumps anything else? This whole area of balancing conflicting factors is still vague. Maybe it is because dft policy is not clear enough? ... but caa has to come up with some weighting system of factors and impacts that can be clearly seen as to how the decision is then made. It is fact that caa have historically made decisions weighted in favour of safety and operations at the expense of community noise impact. I cannot glean any sense of how you make it more transparent to more fairly balance . The added problem of your making is that you will not be aware of true magnitude of noise impacts to even balance as you are still ignoring sound generated above 7000ft as if it does not exist. It does - and with prnav it needs to be assessed - as getting 20 flights in one hour at 6am IS going to be a big impact at 7000-1000ft... yet you are blissfully negligently imo ignoring this.

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
Ticked 1: the guidance is good and meets this criterion 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
Ticked 1: the guidance is good and meets this criterion 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
Ticked 1: the guidance is good and meets this criterion 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
Ticked 1: the guidance is good and meets this criterion 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
Ticked 1: the guidance is good and meets this criterion 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
Para 254 PIR.. 1 year is too little time for evidence to be recorded and analysed eg by a community who is experiencing impact not predicted. 2 years should be the window... this allows for delays in recording the evidence objectively.

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
Ticked Yes
No
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
Ticked Yes
No
Don't know

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
If prnav is being used, more prescription is needed to ensure Nx metrics are produced for all altitudes up to 12,000ft It should also be a requirement for the sponsor to mathematically calculate the prnav line that will give the least exposure in a swath sid. If prnav is being used and it is likely that planes will be on the prnav line at 7000ft to 10000ft, then noise assessment impact need to be produced

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
Ticked 1: the guidance is good and meets this criterion 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
Ticked 1: the guidance is good and meets this criterion 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
Ticked 1: the guidance is good and meets this criterion 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion

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
Ticked 1: the guidance is good and meets this criterion 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
Ticked 1: the guidance is good and meets this criterion 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
Ticked 1: the guidance is good and meets this criterion 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion

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

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
the impacts of prnav have not been reseached and over time better metrics will need to be applied.

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
Ticked 1: the guidance is good and meets this criterion 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
Ticked 1: the guidance is good and meets this criterion 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
Ticked 1: the guidance is good and meets this criterion 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion