Response 603632794

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About you

A. What is your name?

Name (Required)
Robert McLellan

C. Where do you live?

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

D. Are you answering this consultation as:

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

E. Are you affiliated with any organisation?

Please select one item
Ticked Yes
No
Affiliation
Englefield Green Action Group (EGAG)
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
No

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

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(name, location, respondent category, organisation, additional information - please note your email address will NOT be published if you choose this option)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

General observations

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 Considering the draft guidance overall, to what extent does it meet the following criteria?

Comprehensible – it is clear to me what happens
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Transparent – the activities are explained well and will take place as publicly as possible
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Proportionate – the guidance strikes the right balance between detail as to what should happen, and flexibility to allow for different local circumstances
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
How would you improve?
The pressure of the airline and vested interest with considerable resources puts local communities at a severe disadvantage as they have to try to master a very biased establishment which was even reluctant to provide hard copies of the various documents. This issue is of critical importance to whole communities and the lack of easily obtainable facts and counter facts is lamentable. The DfT consultation exercise was not balanced and failed to follow the Gunning principles of open consultation. This gives little confidence that there is a genuine desire for anything other than ensuring the consultation box is ticked and hearing views of local communities is low down against the commercial interests of the aviation lobby. There should be public funding of local resident groups to obtain independent expert advice where there is proposed threshold of noise in excess of an agreed dB level.

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
As per the previous comments. "The pressure of the airline and vested interest with considerable resources puts local communities at a severe disadvantage as they have to try to master a very biased establishment which was even reluctant to provide hard copies of the various documents. This issue is of critical importance to whole communities and the lack of easily obtainable facts and counter facts is lamentable. The DfT consultation exercise was not balanced and failed to follow the Gunning principles of open consultation. This gives little confidence that there is a genuine desire for anything other than ensuring the consultation box is ticked and hearing views of local communities is low down against the commercial interests of the aviation lobby."

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
Cautious welcome. The environmental definitions are too narrow and it is does not adequately deal with an appeals mechanism. Good that there is a recognition that a 3dB increase is the equivalent of a doubling of sound energy. This is not commonly understood by the general public who can assume that 3 is a minimal increase which of course it is not!

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 Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
How to improve
We welcome the recognition that Stakeholders without technical knowledge should have information that allows them to understand the potential impact of changes. We also believe that hard copies of changes should be available and that a more robust way of local communication should be developed for those with limited IT access . The intervention of the CAA when local communities hear significant changes in noise impacts which they regard as unacceptable needs a better control mechanism.

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
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
Environmental metrics not clear. Also lack of noise maximum levels that can "call in"proposals.

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 Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Proportionate – the guidance strikes the right balance between detail as to what should happen, and flexibility to allow for different local circumstances
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
How to improve
It is essential that local communities are able to respond at the Stage 5 and that they are given ample opportunity to be attendees. There has to be qualitative as well as quantitive evidence that should be part of the decision process. Para 232 is not sufficiently robust and noise levels of 51dB LAeq over 16 hours and frequency N65 as well as the number of events metrics should be included.

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
Para 246 suggests that the sponsor should consider how to notify local community and other stakeholder groups. "They should consider contacting..... relevant community groups and local press - all that may be needed is a reference to the online portal." We do not accept that reference to an online portal is an adequate communication to community groups. The CAA should recognise that local residents need better direct briefing in the same way as planning changes for domestic properties are notified by post to those potentially afffected.

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
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
We welcome a variance report from that which sponsors predicted. 28 days may be too short especially if the only notification is via a web portal. The CAA does not seem to accept that local communities are not sitting by their computers waiting for the next sponsors proposals - there needs to be a better communications procedure. There should be an appeals procedure agreed on grounds of factual accuracy or where current pollution levels increase beyond legal limits.

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
What else to show two way conversation?
Understood the value of a tier 1b and 1c changes. However as per previous comments in this response we are concerned at the use of phrases such as "reasonable steps to inform communities and their representatives before any trial commences where the trial might affect the routes flown below 7000ft." Our view is the method of notification and the expected outcome and duration needs to be clearly stated. The previous flight trial out of Heathrow showed that the industry regards communication with residents being overflown as significantly secondary to their commercial and efficiency objectives. The CAA should have more regulatory teeth to insist on a detailed communication plan.

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
Any facilitator should insist on a balance of evidence and sponsors should accept their responsibility to ensure that their changes are made clear and easily understood by communities. The DfT consultation did not do that and was seen by many as an elaborate and dysfunctional PR exercise. Each change normally has positives and negatives and there should be a brief summary of these on all proposals which would shorthand a reasoned discussion rather than communities feeling that they were being treated as fools!

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

Facilitator - which places
Perhaps a training funding package for local communities could be organise and managed by a facilitator.

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
Categorisation - additional detail
Proposal supported. It is important that the process shows both negative and positive potential outcomes.

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
Ticked Yes
No
Don't know
OA - explain re proportionality
However, early intervention by communities is essential.

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
No - Safety is the priority and the changes of airspace must have this as the overall priority. We are concerned that with the potential of a third runway at Heathrow the risk of an incident over London will be increased to an unacceptable level and emergency contingencies are not sufficiently in place. We believe that research has shown that there is a 60% increase in the crash risk with an expanded Heathrow - This should either be confirmed or denied and the CAA estimate given.

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
How to improve
See previous comments on community engagement. "The pressure of the airline and vested interest with considerable resources puts local communities at a severe disadvantage as they have to try to master a very biased establishment which was even reluctant to provide hard copies of the various documents. This issue is of critical importance to whole communities and the lack of easily obtainable facts and counter facts is lamentable. The DfT consultation exercise was not balanced and failed to follow the Gunning principles of open consultation. This gives little confidence that there is a genuine desire for anything other than ensuring the consultation box is ticked and hearing views of local communities is low down against the commercial interests of the aviation lobby."

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
How to improve
See previous comments. "The pressure of the airline and vested interest with considerable resources puts local communities at a severe disadvantage as they have to try to master a very biased establishment which was even reluctant to provide hard copies of the various documents. This issue is of critical importance to whole communities and the lack of easily obtainable facts and counter facts is lamentable. The DfT consultation exercise was not balanced and failed to follow the Gunning principles of open consultation. This gives little confidence that there is a genuine desire for anything other than ensuring the consultation box is ticked and hearing views of local communities is low down against the commercial interests of the aviation lobby."

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 bill as presented offers the opportunity for the UK to be at the forefront of space technology. However it is in our view not a matter that should be confused with the modernisation of airspace. Any changes should ensure that they are part of a wider debate and linked to growth of our "Northern Powerhouse " Any pollution, safety or security issues should ensure that any developments are in neutrally affected areas of the UK.

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
Stage 5 Decide
Stage 6 Implement
Ticked Stage 7 Post-implementation review
None of these
Don’t know
Tier 2 reasons
The lack of a statutory legislation on minimum noise levels is unacceptable. Changes should be defied in terms of their impact on the ground rather than just by the technical nature of the change. The CAA should have the power to seek a progressive and material reduction in the impact of noise on people affected and the severity of impact. Those overflown should not be exposed to increased levels of noise and certainly not above the minimum levels recommended by WHO. The acceptance that there will be a noise impact below 7000ft and the navigation provider merely has to show that they have "engaged" with affected communities as "appropriate" is poor. If a manufacturing operation wants to increase production but will increase noise and pollution, they would be challenged and would be unlikely to achieve their expansion unless agreeing to reductions in the negative effect on the environment. We see no reason why the aviation industry should not be treated similarily.

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
Within each SID the dispersion within that SID does spread out the effects of concentrated noise to those overflown. We do not believe that changes should be made as life decisions on where to live were based on historic levels of noise. To redistribute where there are significant winners and losers is, in our view, totally unfair and unreasonable. PBN will give the opportunity for dispersed flights within current and proposed SIDs and should not be allowed to be used as concentration which will create noise sewers over existing or new areas.

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

Tier 2 - other comments
See above

Tier 3: Other changes to air operations affecting noise impacts

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

Comprehensible – it is clear to me what happens
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Transparent – the activities are explained well and will take place as publicly as possible
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Proportionate – the guidance strikes the right balance between detail as to what should happen, and flexibility to allow for different local circumstances
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
How to improve
We welcome a light touch working in conjunction with an independent body. We however have serious concerns on how the ICCAN can be truly independent when it reports to the CAA. The balance of membership should be weighted towards communities to counter the excessive power of the aviation vested interests.

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 definition of population needs to be transparent. The CAA have produced indicative flight paths which in Englefield Green ignore that there are circa 10 k students at Royal Holloway University with a plan to expand to over 13k. Challenge by communities is often derided by operators who ignore tranquil areas, historic practice and who broadly take the view that their commercial efficiency trumps noise and environmental concerns. We would support the CAA to redress the current imbalance.

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
See above. Any proposed growth or changes in air traffic movements at major UK airports should be conditional on a directly, proportionate and enforceable reduction on noise including night flights to match the Aviation Policy Framework that said "the industry must continue to reduce and mitigate noise as airport capacity grows."

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 devil will be in the detail - Multi-respite routes versus single concentrated routes. We are very clear that controlled dispersion is the most equitable way forward given that we do not believe, as a general rule, that noise and air pollution should be increased by the aviation industry.