Response 248350014

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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 Considering the draft guidance overall, to what extent does it meet the following criteria?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
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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
Transparent – the activities are explained well and will take place as publicly as possible
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Proportionate – the guidance strikes the right balance between detail as to what should happen, and flexibility to allow for different local circumstances
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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?
I believe you fail to understand the nature of the current problem of aircraft noise and the nature of the failure of the industry in addressing it. Your approach needs to be able to address the current reality where Luton Airport can allow noise disturbance to grow in the neighbouring country of Hertfordshire and yet can claim to be powerless is resolving it.
General observations
Introduction The measure of success for future UK Airspace Policy will be whether it deals quickly and effectively with the current and increasing problem of noise disturbance from low-flying aircraft following take-off. The problem of noise disturbance is particularly acute over Hertfordshire, where the volume of low-flying aircraft, and the noise they generate has escalated to an unacceptable level over the last two years. This problem has highlighted two significant shortcomings in current UK airspace policy: 1. In delegating decision-making to local authorities, the Government has failed to recognise or take account of the conflict of interest between 1) Luton Airport and 2) its shareholder, Luton Borough Council – between 1) its commercial equity interests and 2) its responsibilities as the responsible public planning authority and corresponding duty of care to residents. The result has put in jeopardy the interests and wellbeing of residents in neighbouring Hertfordshire, who are impacted by increasing noise disturbance. 2. In failing to make progress on the modernisation of London airspace, and specifically in failing to resolve the problem of Luton departures – both westerly and easterly - being prevented from climbing towards 10,000ft as they fly over Hertfordshire, The combination of these two shortcomings means that Luton has been allowed to accelerate its expansion of flight volumes, while the issue of low-altitude flight paths across Hertfordshire remains unresolved. The measure of success of future airspace policy will be the extent to which the Government is then able to address these issues. The Government must take action to: - Recognise the conflict of interest between Luton Airport and Luton Borough Council, and exercise national oversight as a remedy - Move quickly with the priority elements of the London Airspace Modernisation Plan, thereby allowing departures from Luton Airport to climb to 10,000ft and beyond, immediately on departure. This will involve addressing the Brookmans Park bottleneck on east-bound westerly departures, as well as the other constraints impacting west-bound easterly departures. The problem The consultation proposes that the local authority should be the competent authority on planning applications for airport expansion. This fails to recognise the situation that has arisen in regard to Luton Airport, in which Luton Borough Council is a shareholder, and where the Council has a conflict of interest between 1) the commercial revenues it earns from airport expansion and 2) its responsibility as the public local planning authority for airport expansion. The issue of escalating noise disturbance from aircraft taking off from Luton Airport was the subject of a special meeting of St Albans District Council earlier this month. The chamber was filled – but with residents of Hertfordshire, not Bedfordshire. This is because Luton Airport minimises flight noise disturbance for Luton and Bedfordshire residents, by ensuring that ALL departures turn and fly SOUTH over Hertfordshire, not north over Bedfordshire. Even flights to Glasgow and Edinburgh fly to the south to avoid Bedfordshire. This minimises complains towards Luton Borough Council from its local electorate, but at the expense of residents in Hertfordshire. Having established this southerly flight pattern, Luton Airport has since embarked on an accelerated expansion plan. According to information presented at that St Albans meeting, the level of disturbance in Hertfordshire has increased rapidly over the last two years as a result of: 1. Luton Airport expanding its departure schedule much more rapidly than set out in its original expansion plans and confidential franchise agreement; and 2. Flights being prevented from climbing towards 10,000ft, as they fly the first leg of their route over Hertfordshire It is typical for flights to fly over Hertfordshire at a calibrated altitude of just 4,000ft - 5,000ft, as evidenced from flight records. The legacy air traffic arrangements for London mean that east-bound departures from Luton fly via “Brookmans Park”. Several other major of airspace routes also cross this point, and under these legacy arrangements, Luton departures are required to fly BELOW all the other routes, typically well below 10,000ft. Regardless of the original logic, decades ago, of placing Luton departures at the bottom of Brookmans Park, it is clear today that, given the unparalled increase in Luton flight volumes (heading towards 18m passengers per annum) and with the majority of expansion on easterly routes, this is leading to very high volumes of flights at very low altitudes across Hertfordshire, and therefore unanticipated and unacceptable levels of aircraft noise disturbance. Similar legacy restrictions constrain west-bound flights, meaning that on an easterly take-off, those flights fly directly overhead Harpenden, and its population of 30,000, often at 5,000ft or less. Remedies Firstly, the Government must recognise that the ambition to delegate air traffic planning decisions to local authorities is flawed and unworkable where there is a clear conflict of interest between commercial and public interests, and where the local authority is unaccountable to the residents most affected, as a result of aircraft being redirected into a neighbouring county immediately on take-off. Secondly, the Government must put in place an effective national planning and oversight arrangement to counter the local conflict of interest, and cap the growth in flight volumes until the Brookmans Park constraint is resolved for east-bound flights, and corresponding restrictions on west-bound flights are also addressed. Thirdly, national airspace governance must find a way to ensure that Luton airport distributes departures fairly between Bedfordshire and Hertfordshire, rather than divert all flights over Hertfordshire and away from its own Bedfordshire electorate. Fourthly, the Government must press ahead with the priority aspects of the LAMP programme, so that aircraft departing from Luton Airport are able to (and required to) climb to beyond 10,000ft immediately on take-off and before completing their initial turn over Hertfordshire. Capping the volume in flights from Luton, until the altitude constraints are resolved, will require bold reversal of current logic, but is essential to halt and resolve the noise disturbance that has been escalating across Hertfordshire. In summary, the priority for UK airspace policy must be to reduce the noise impacting communities from aircraft flying below 10,000ft by implementing changes to the management of airspace in the South East that ensure that, on take-off, aircraft climb immediately to 10,000ft or higher, before setting their course. The airspace sector has 40,000ft of airspace at its disposal – Government policy for airspace will have failed if it continues to permit airports to fly aircraft across neighbouring counties at altitudes as low as 4,000ft.

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?

How to improve
I think you need to test your approach against the real situation of excessive noise disturbance from Luton Airport affecting Hertfordshire residents - see my attached letter for more details.... At the moment, the current arrangements allow Luton Airport to increase noise with impunity and lay responsibility with aviation authorities