Response 176581804

Back to Response listing

About you

A. What is your name?

Name (Required)
Rachael Webb

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)
Resident affected by aviation
Airline passenger
Member of the General Aviation community
Member of the commercial aviation industry
Military
Ticked 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
Bucks and Milton Keynes Association of Local Councils (BMKALC); London Luton Airport Consultative Committee (LLACC); Aviation Environment Federation (AEF); Airport Watch; People against Aircraft Intrusive Noise (PAIN); Protect Aylesbury Vale Against Noise (PAVAN).
Please select one item
Ticked Yes
No

F. Is there anything else that you would like us to know about you regarding this consultation?

Please enter any further details
I am responding just on behalf of BMKALC, a membership organisation serving Town, Parish and Community Councils throughout Buckinghamshire and Milton Keynes. I am not a Councillor or employee, but a co-opted member of their Executive Committee. I represent BMKALC on LLACC. My other affiliations are completely separate from BMKALC.

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(name, location, respondent category, organisation, additional information - please note your email address will NOT be published if you choose this option)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 Considering the draft guidance overall, to what extent does it meet the following criteria?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 2: the guidance mostly meets this criterion Ticked 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 would you improve?
a) Despite several readings and discussion with others, I remain unsure as to whether respondents are being asked to comment on and try to influence changes to the process itself, or just on how well the process-guidance is explained. Ever the optimist, despite 15 years of trying to protect our skies from increasingly excessive noise, I am proceeding on the former basis. b) The consultation document is very long and complex, with lots of pre-existing knowledge and cross-referencing required, requiring many redrafts of various responses as I ploughed through the document. Many technical terms and concepts are inadequately explained. It is perhaps the most prohibitively onerous and intimidating consultation I have ever come across. c) Airspace usage and management is very complex. It takes a long time for most people “on the ground” to get up to speed on the issue. Things that are clear to me will probably not be clear to all stakeholders. Even if a process and guidance are “clear”, quite often people don’t spot a gap in this information and they don’t know what questions to ask. So any improvements I and others might suggest here will never be sufficient. One possible solution to this conundrum is for an effective, i.e. with teeth, and truly independent, ICCAN, to be available at all stages of an ACP to analyse the information and ask the questions that would otherwise not get asked. See my response 2c as an example. d) By not asking all questions, previous airspace changes have sneaked through, to the detriment of communities, which is one of many reasons that we now have a trust deficit with the aviation lobby. e) Some issues I have raised in this response perhaps should have been included in my response to the recent DfT consultation, but it was only after studying this consultation, (after I had submitted my DfT response) that I realised this. I am sure I am not the only one, so I am formally requesting that the CAA forward all responses to this consultation to the DfT for them to consider during their own deliberations. f) The signing off of gateways by the CAA should be provisional and not absolute. If information comes to light later in the process that an earlier stage was not managed satisfactorily, either by the sponsor or the CAA, or documentation was flawed in some way, then signing off should be revisited and reversed if justified.
General observations
ai) Reviews of proposed airspace changes should be widened to include the overall ability of the system to handle increased numbers / frequencies of flights, for example, runway length and runway management. Luton Airport has squeezed more flights into its schedule thanks mainly to the Western Airspace Extension (2006), but now it appears that the runway cannot cope. The second 2017 May Bank Holiday weekend saw a rate of go-arounds of at least 0.75%, much more if the focus is just on 08 arrivals, compared to the average rate at Heathrow of about 0.2%. A go-around should be a last-resort safety manoeuvre, not a tactic of choice for expediency, and such knock-on issues should be examined during an ACP. bi) Currently, planning permission is granted for ground-extensions to airport operations before airspace requirements are finalised so the true impact of these extensions is not known in time. An ACP should be part of airport planning applications so that the true environmental impact can be assessed in a more transparent procedure. At the very least, a ministerial call-in for an ACP should be available, even when he/she has previously decided on the planning application, because at that time the true environmental impact would not have been known. ci) Airspace change processes should provide the opportunity to review operational issues such as limiting numbers of flights, banning night flights, and other such measures. It might be that some airspace changes would be more acceptable with such measures, and the change process might enjoy a smoother process under these circumstances. During Luton Airport’s Western Airspace Extension consultation process (2002-2005), I received a sizeable number of comments along the lines that Luton’s proposals would be acceptable providing there were no night flights and day-time flights capped at certain levels, etc.

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
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
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
a) Stakeholders should have the opportunity to scrutinise the Statement of Need before the Design Principles are drafted. This would be an invaluable opportunity for any fundamental misunderstandings to be identified and clarified at the earliest opportunity, and for hidden questions to be flushed out and answered as soon as possible before being lost in the passage of time or in the fog of information. b) The unquestioning acceptance that flights above 7000 feet are not intrusive sets the tone for the lack of transparency in this process. If Design Principles are predicated on this misconception then the true impact of the proposed changes cannot possibly be accurate. Large swathes of Buckinghamshire are rural and/or hilly with low ambient noise; in some atmospheric / weather conditions or with flight modes (e.g. rate of acceleration or climb, engine thrust for turns, etc.), planes much higher than 7000’ amsl are unacceptably intrusive to the point of causing stress and sleep disturbance. Stakeholders should be allowed to challenge proposed principles that they know from experience would be to their detriment, whatever DfT policy decrees. c) Regarding paragraph 90 – (… An airspace change is characterised by a change … Examples include … introduction of, or significant changes to, holding patterns, where “significant” means a complete re-alignment or re-orientation of the hold.) This proves the point I made at the CAA workshop in January. Arrivals to Luton Airport on runway 08 have, in the past few years, been directed increasingly often to use airspace above a cluster of villages (e.g. North Marston, Oving, and more recently Stewkley) as a reporting point in preference to LOREL, yet this possible use of airspace was not flagged during the consultation process for the Western Extension of Airspace and indeed has not been subject to any consultation process at all. Regardless of how these manoeuvres were incorporated into or assimilated with NATS’ airspace management guidelines, this airspace usage has increased from an occasional safety tactic or convenient expedience, to an established brand new reporting point with the consequent tangible environmental impact for several villages. To demonstrate that the CAA is serious about transparency and building trust, they should mandate that this use of Buckinghamshire airspace be subject to a retrospective Airspace Change Process to flush out the rationale, current and potential safety and environmental impacts and alternatives available. Stage 4 of this draft ACP also supports this request. And see my responses to 14 and 21.

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 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
a) It is not clear until paragraph 123 that one of the Options is a do-nothing option. This should be made more explicit earlier. b) There is inadequate flexibility in the options appraisal methodology to meaningfully take into account how noise impacts different people and different communities. Appraisals that take significant account of the number of people overflown are unacceptable, because then rural communities will always lose out, despite the fact that rural communities are impacted most by noise owing to low ambient levels. In addition, many people choose to live in rural areas because they are naturally less tolerant of noise, thus making plane noise even worse for them compared to urban environments. c) Assessing noise impact in terms of averages is a discredited methodology, especially in areas of low ambient noise where each plane is keenly heard as a series of disruptive single events. Alternative or a variety of methodologies each of meaningful and appropriate weighting, should be accommodated to improve the flexibility of the process. d) Use of airspace for Luton Airport flights often bears little resemblance to “official” flight paths or option designs from consultations – planes fly to and from the airport in all directions, and turn loudly over an increasing number of areas. Such possible variations should be made transparent during this stage of the consultation process to improve transparency.

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
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
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
a) Activities cannot be transparent if not everyone has access to them, and not everyone has any or easy access to the internet or the ability to use a computer (e.g. those on restricted incomes, educational or communication challenges, the elderly). Restricting communications to online portals is therefore discriminatory. An alternative format must be provided for those who need it. b) Consultation periods should be extended if new stakeholders are identified / come forward who for whatever reason missed the start of the process. c) Respondents should be allowed to submit more than one response, but be properly identified as a second or third etc. response, should they come across new information, or wish to modify or strengthen an earlier response. d) Withholding information by the Proposer / CAA should be avoided. A litmus test might be, if it is realistic that it would be made public, or be ordered to be made public, under an FoI request, it should not be withheld or delayed in the first instance.

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 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
As worded, there is too much scope for the sponsor to ignore some stakeholder responses as it suits the sponsor’s purpose. I understand that there cannot be a never-ending feedback loop of consultations, modifications and more consultations etc. The ICCAN should therefore determine whether the feedback appraisal is fit for purpose and the sponsor’s “final” design is justified, or whether further steps need to be taken.

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
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
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
a) Level 0 and Level 2 changes should also be subject to Public Evidence Sessions. In Airspace management terms the changes might be small, but in terms of impact on the ground, the changes could be significant – see my response to 2C. b) While ideally the ICCAN should be able to seek additional information or challenge conclusions at this stage, the fact that ICCAN is proposed to be part of the CAA means it is widely anticipated to be a PR / box-ticking exercise. Having experience of Luton Borough Council’s decisions when it comes to London Luton Airport operations (LBC owns LLA), I concluded a long time ago that so-called Chinese Walls do not exist! c) The criteria for a call-in by the Secretary of State is too limiting and predicated on economic growth over environmental impact – in breach of the Government’s own Sustainable Development Strategy. And see my answer 1ai re the injustice of denying a call-in request for an ACP when the Secretary of State has already ruled on a planning application. Planning applications are currently processed BEFORE any idea of airspace requirements are known or at least made public and publicly scrutinised, so the Secretary of State is duty bound to have a second bite of the cherry to improve justice of process and transparency. d) Judicial Reviews are not an option for many people because of they are prohibitively expensive, thus disenfranchising the majority of residents impacted by airspace changes. Judicial Reviews are therefore not a reasonable substitute for a robust and meaningful ICCAN and the option of a ministerial call-in.

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
The requirement for sponsors to heed and act on concerns of local people during the first year after implementation is inadequate. The ICCAN should act as a people’s champion to make sure proper concerns (e.g. planes off track, noise worse than advertised) are not ignored or belittled in the hope they will go away, as do many complainants at the moment. The number of complaints received by Luton Airport, for example, do not reflect the true feelings of local communities, because people rightly see that complaining doesn’t get them anywhere.

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
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
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 to improve
a) While the ICCAN should be involved in all stages, this stage in particular requires the expertise and impartial (theoretically) analysis and judgement of the ICCAN to ensure that any comments by residents e.g. that the noise is more intrusive than had been forecast, are investigated thoroughly and the correct decision taken as to the future of the new airspace arrangements. b) The Stage 7 Post Implementation Review should not be the end of the story. If subsequent airspace issues materialise after the review they should be referred to the CAA for formal investigation and corrective action to ensure that unadvertised changes do not sneak it by the back door. Refer to my comments in 2c as one example.

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?
All stakeholders should be encouraged to contribute their own data and opinions of the “two-way conversations”.

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
If the ICCAN is properly constituted and resourced there should be no need for another facilitator. The ICCAN could be called upon when needed by the community – and not just under limited circumstances as suggested in paragraph 100. What the CAA and change sponsors define as “higher impact” does not coincide with the perception of impact by communities.

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

Facilitator - which places
As stated earlier, the ICCAN should be available to assist and fight for communities at every stage of the process.

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
a) I don’t understand what the CAA hopes to achieve by categorising responses in this way. It shouldn’t matter if only 1 out of 500 respondents identifies a hitherto unstated problem, or suggests or inspires an improvement in design, the change sponsor should consider it meaningfully and conscientiously. Similarly, if 400 out of 500 respondents seek a design or changes to a design that would impact a different community, the numbers should not be the decisive factor in the ultimate decision, because otherwise rural communities would always lose out. b) And if a flaw in the consultation process for a particular ACP is identified by a respondent, steps should be taken immediately to rectify the issue for that ACP, and not kicked into the long grass for a later one.

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 communities and/or the ICCAN on behalf of local communities should be included in this process to ensure methodologies are appropriate. For example, measuring noise impact in low-ambient noise areas as averages (Leq) has long been discredited and is not be acceptable.

Tier 1a: Safety information

14. At each stage in the airspace change process that an options appraisal takes place, the sponsor will be required to submit a safety assessment. The sponsor will be required to provide a plain English summary of the safety assessment and the CAA will provide a plain English summary of its review (i.e. of the Letter of Acceptance, which forms the CAA’s review of the safety assessment) when it makes a decision. These documents will be available on the portal.   Do you have any views on specific information that should be included and/or excluded from the plain English summary of the sponsor’s safety assessment and the CAA’s review? 

Safety assessment
The safety assessment should include neighbouring airspace areas and the impact on relevant stacks/holds/reporting points. For example, during Luton Airport’s Western Airspace Extension, PAVAN pointed out that the consequent increase in air traffic would impact the LOREL hold so that should be included in the safety assessment. We were, of course, ignored. And what has transpired, is that Luton arrivals are routed away from LOREL whenever possible to avoid conflict with Stansted, and alternative areas in the Vale are used as reporting points, but without any consultation or safety assessment. Either the unmanageable burden on LOREL was not anticipated because an adequate safety assessment was not undertaken, or it was anticipated and this use of Vale airspace was always on the cards but was kept quiet from the public. Reprehensible either way. See my response 2c.

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
I have no experience of temporary airspace trials so will defer to Sally Pavey’s (re Gatwick) response to Qu 15.

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
a) As flights above 7000’ can also be intrusive, impacts of these should also be measured and measured meaningfully, and overflight swathes above 7000’ should also be publicised. b) The statement in B87 that there will be no requirement to measure the impact on tranquillity , for example, because such impacts are “expected to be negligible for such a short-term change that will affect only a small proportion of current traffic” is non-sensical. How can the impact of a proposed airspace change be assessed if the impacts are not measured during a trial? By definition, any increase in noise in a tranquil area is noticeable and intrusive – EU directive 2002/49 mandates that tranquil rural areas should remain tranquil (however inadequately it was transposed into English Law!).

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
Spaceflights, should be subject to the same if not more rigour than for regular flights owing to the far greater environmental impact per flight. In addition, spaceflghts will inevitably lead to regular aircraft being squeezed into less airspace, unless a more balanced view is taken and flights are capped in terms of times of day/night, frequency and overall numbers, which supports my response 1ci.

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
I do not agree with the differentiation between Tier 1 and Tier 2 changes, because the noise impact for communities can be just as bad.

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
See my response to 18

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

Tier 2 - other comments
As the impact from Tier 2 changes can be as bad as impacts from Tier 1, they should not be differentiated.

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
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
a) Any change that results in a noticeably worsening noise impact on the ground should be subject to thorough CAA oversight, retrospectively if necessary. I refer you once again to the situation I outlined in 2C, which would probably be classed now as a Tier 3, yet the impact on the ground is akin to that from some Tier 1s, if not now then in the not too distant future as Luton keeps growing. b) If the CAA does not have oversight in these situations, too many airspace management “tweaks” will be introduced at the expense of the local communities. c) I can anticipate that what might seem at first to be a Tier 3 has the impact of a Tier 1 (as above), in which case a retrospective examination of airspace requirements should take place. d) Even an increase in allowable flight numbers should be the subject of joint determination by local planning authorities and the CAA, because LPAs’ are not well versed in aviation safety and airspace management. e) The proposed “Best practice engagement with communities by airports but no formal CAA involvement” will not work. The current trust deficit is too big. Instead, the ICCAN should be involved in drawing up requirements and responsibilities that airports must live up to. f) Paragraph 303 states, “…to help to provide context as to why the noise effects they are experiencing may be changing.” This is a clear instruction for airports to do what they want whatever the impact, and just make sure they tell the communities. g) Paragraph 304 recommends flight tracking as a tool to improve community relations. This alone will not work if, when a resident acts a question arising from the tracks, the information they receive back from the airport is minimal, unclear or the explanations a white wash. For example, I recently asked Luton Airport to explain why there were so many go-arounds that last weekend in May. I was told what go-arounds were and when and why they might occur. And that was it. A couple of years ago I asked why there had been a spike in noise complaints from a certain cluster of villages (from 5 in a quarter to 64!) I was told that it was increased awareness and that time of year. Unfortunately these are not isolated incidents.

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 CAA should also publicly rebuke change sponsors at any level when they fall short of the standards required of them, either the quality of their documentation or how they handle consultation responses. Introducing fines would help focus minds!

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
It is not possible to anticipate an exhaustive list. So on a case by case / question by question basis, information and answers to questions should be provided promptly, clearly, fully, honestly and transparently, and perhaps an FAQ list regularly updated accordingly.

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
a) Tier 3 changes are being “sold” in this document as not as important as Tier 1 because they are outside CAA’s control or incremental or otherwise unavoidable. But the noise impact can be just as bad as Tier 1 and should be taken just as seriously by the authorities and the problems they caused addressed in a constructive way for the communities, not just tell us to be happy with additional dialogue. b) I therefore wish to echo Sally Pavey’s response: The CAA places too much emphasis on the travelling consumer and the demands of aviation and sponsors without equal emphasis on the impact aviation has on communities’ health, quality of life or home value. The CAA seems to take the stance that aircraft noise can be mitigated, which it cannot. c) The best mitigation is removing the need to mitigate, i.e. for someone to put their hand up to the aviation industry and say enough is enough. A good night’s sleep, a quiet afternoon in the countryside, is more important for health and wellbeing than a stag weekend in Magaluf, a shopping trip in New York, or a business jolly to an exotic golf course.