Response 889923858

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

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(name, location, respondent category, organisation, additional information - please note your email address will NOT be published if you choose this option)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

General observations

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 Considering the draft guidance overall, to what extent does it meet the following criteria?

Comprehensible – it is clear to me what happens
Please select one item
1: the guidance is good and meets this criterion 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?
The draft guidance is remarkably long and detailed and challenging even for someone like me used to reading such documents at work. For the average citizen it is going to be daunting and incomprehensible. What is needed is a companion document that graphically illustrates what we need to know in easily understandable terms and doesn't require hours and hours of reading and study to grasp the essentials of what is being proposed.
General observations
How can the CAA expect the average citizen to review and respond to a 234 page document? It begs the question of whether you actually want citizen involvement in this consultation process, or if it's only meant to put off all but those who are being paid to respond (or those who are so aggravated by aircraft noise that they will prevail no matter what). Your Powerpoint presentation document does not provide an overview of the document's contents but rather gives an overview of the consultation process. Where is the PP for the overall document? That is what is so desperately needed to make this an effective consultation.

Tier 1a: Stages 1 to 7

2. Considering Stage 1 (Define) of the process , to what extent does the draft guidance on that stage meet the following criteria?

Comprehensible – it is clear to me what happens
Please select one item
1: the guidance is good and meets this criterion Ticked 2: the guidance mostly meets this criterion 3: the guidance does not sufficiently meet this criterion
Transparent – the activities are explained well and will take place as publicly as possible
Please select one item
1: the guidance is good and meets this criterion 2: the guidance mostly meets this criterion Ticked 3: the guidance does not sufficiently meet this criterion
Proportionate – the guidance strikes the right balance between detail as to what should happen, and flexibility to allow for different local circumstances
Please select one item
1: the guidance is good and meets this criterion 2: the guidance mostly meets this criterion Ticked 3: the guidance does not sufficiently meet this criterion
How to improve
The guidance defines affected stakeholders to be consulted as: elected community representatives, local community groups, the airport consultative committee and local aviation organisations or clubs. This poses a number of problems. 1) It defines the affected stakeholders far too narrowly by not opening the process to affected citizens not represented by any of these four categories. 2) It allows the consultation to be stacked in favour of the airport authority in areas where the elected representatives have tended to support the airport authority at the expense of the citizens, such as our area. In that scenario, three out of the four categories of stakeholders will dominate the consultation in favour of the airport authority. 3) The airport authority can hold closed meetings to which it invites only those it considers to be 'representative' groups, i.e. 'cherry pick' who they consult and exclude citizens and groups whose views they don't want entered into the official record. This has happened in our area, where Luton airport claimed to have consulted but almost no one concerned about the issue knew anything about a consultation, even local groups lobbying for changes. CAA needs to require open consultations where any affected stakeholder can give their views. At the moment the process is not open, fair or transparent, and appears to follow the 'Theresa May' model of pretending to visit constituents but cherry pick who attends. Everyone can see through that, it is not fooling anyone, and people are fed up with the emphasis on airport profits over citizens' quality of life.

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
The cost of noise and air pollution to those overflown -- businesses, organisations and people (especially children, pensioners and people in ill health) -- must be calculated. Airport authorities and flight operators need to pay for these costs to the UK Government, to local authorities and to local communities, and pass them on accordingly to their customers who are the ultimate beneficiaries. If people want to fly and create air and noise pollution, then they need to pay for this privilege and not assume that someone else should pay the cost. This needs to be factored into the process at this stage in terms of considering and selecting among the options. The contribution to climate change and cost in terms of meeting (failing to meet) the Paris climate accord also needs to be factored in. There is no reason the airport authorities, airlines and their customers should contribute to making the global climate worse for all of us and not pay the price for that.

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 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 to improve
Consultation needs to be open to all, widely published and communicated (print media, social media, broadcast media), and accompanied by simple-to-understand graphical materials that convey the content of the consultation in a way that the average citizen can understand. (In terms of reading level, that means anyone age 12 and above should be able to understand it.) The materials should not require a doctorate in physics or economics, as they currently seem to.

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 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 to improve
Despite the flowchart, the process is not at all clear to me. It seems vague and open to interpretation.

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 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 to improve
The public evidence session is far too late. By this time there has already been a great deal of time and expense sunk into the process and a far greater likelihood that public comments will be discounted and the proposal approved. Also, why should any environmental assessment be submitted and considered from the airport authority? This should be a completely independent assessment. The airport authority has a glaring conflict of interest and cannot be trusted to consider environmental considerations and costs. This is an extremely obvious flaw in the overall process.

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 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 to improve
It is not clear how the approved changes will be communicated with stakeholders. This has been very problematic in the past, with decisions made and not communicated to the communities that will be affected by the changes. If you're going to make a decision, then 'man up' and communicate it and take the consequences of doing so, i.e. public complaints, bad publicity, etc. This cannot be done in a non-transparent way, i.e. secretive, with the hope that people will find out later and just live with it. You are misjudging the mood of the country if you think that way, as the recent Brexit and general election voting have shown. And you cannot expect people who are stressed out from loss of sleep -- from being overflown by aircraft all the time -- to react positively to a decision that goes against them, especially if their concerns have not been taken into account in the process and if they are not compensated for the price they are paying.

8. Considering Stage 7 (Post-implementation review) of the process, to what extent does the draft guidance on that stage meet the following criteria?

Comprehensible – it is clear to me what happens
Please select one item
1: the guidance is good and meets this criterion 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 to improve
You need a proper 1) environmental assessment and 2) impact evaluation. Both need to be conducted by independent entities, at the expense of the airport authority that requested the change but commissioned by CAA. Again, those who benefit from the air travel need to bear the cost. The environmental assessment should measure air pollution and estimate the costs to people's health and NHS expenditures. The impact assessment should consider quality of life issues and include case studies of how people are affected. Again, it needs to be clear what kind of impact is being produced, who is benefitting and who is bearing a cost, and developing recommendations for ensuring that the outcome is fair to all affected (and not just benefitting the airport and flight operators with higher profits and air travellers with cheap or convenient flights while citizens bear noise and health costs).

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?
The Luton airport authority has shown that it cannot be trusted to consult fairly with community stakeholders. Relying on them to represent what they have heard when they want a proposal to go forward is ridiculous. The question is why the process is not conducted by CAA or an independent entity. It's like asking the fox to guard the hen house. If you need documentation, then require that they set up a public e-space where stakeholders can submit feedback and respond to the proposals and where the sponsors can put their collated summary of the feedback. Only if all of this is posted publicaly can it be considered a transparent process.

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
It should be compulsory and the facilitators should be assigned by CAA from a pool of assessed and approved independent facilitators.

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

Facilitator - which places
At any point that involves stakeholder consultation.

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
This is completely open to the sponsor's interpretation. They should be required to summarise all responses, and should not be involved in assessing them.

Tier 1a: Options appraisal

13. In paragraph E25 and E34 the CAA states that methodologies for the various aspects of the options appraisal should be agreed between the CAA and the sponsor at an early stage in the process, on a case-by-case basis. This provides flexibility for different local circumstances. Does this approach strike the right balance between proportionality and consistency?

Please select one item
Yes
Ticked No
Don't know
OA - explain re proportionality
The airport authorities have a very blinkered view of options, i.e. options that are going to allow them to operate in the manner that is optimal for their own interests. For example, Luton has been very slow to consider options such as flight paths that inconvenience citizens living in the Luton area in order to ease the noise for Hertfordshire residents, even though it is Luton residents who are getting greater benefits from the airport. Whenever you give the airport authorities 'flexibility' they take advantage of it because they are focused on profits and nothing else. The process must be more open. Options generation and appraisal should be broadened to include all stakeholders affected.

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
You need to have very clear graphics, bullet point lists, and summaries. People are inundated with information and cannot take in pages and pages of narrative.

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 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 to improve
Again, the problem is the change sponsor assessing the impact of the proposed change -- i.e. fox guarding the henhouse scenario.

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 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 to improve
Again, the change sponsor develops the evidence base for the changes. It's not clear what the CAA actually does in all of this other than review and approve what the airport authorities present. If the latter are the ones who provide the evidence that the changes they want are good, how is this any different than the tobacco companies presenting medical evidence that cigarettes don't cause cancer or food companies that crisps don't cause obesity?

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
Not informed enough to comment

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
This consultation is even more important in terms of impact. All of the comments made for Tier 1 above are relevant.

19. The CAA’s process for Tier 1a changes is scaled into ‘Levels’, based on the altitude-based priorities in the Government’s Air Navigation Guidance (i.e. where noise impacts are to be prioritised or considered alongside carbon emissions, a more demanding consultation is required). Could the future Tier 2 process also be scaled?

Please select one item
Yes
Ticked No
Don't know
Tier 2 - scaled reasons
By definition it involves noise impacts and carbon emissions.

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

Tier 2 - other comments
No

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 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 to improve
This guidance cannot be 'light touch' and 'best-practice guidance'. The airport authorities have already shown a disregard for impact on local communities and an active and ongoing default to commercial decisions. The guidance needs to be definitive and contain fines for violations. Luton keeps telling us we are not being flown over, when in fact we are being flown over all the time by their airplanes. You cannot trust an entity whose reason for existence is profits to regulate itself in a way that might affect profits. That is historical fact.

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
They are not a law unto themselves. They are accountable to all stakeholders and not just to shareholders. If they want to operate in an autocracy, tell them to operate in North Korea or Saudi Arabia, not in a democracy like the UK. There should be public consequences for a breach of trust.

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
Again, a public information campaign in which information is graphically communicated.

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
Be more specific and directive about what constitutes two-way dialogue, and make this dialogue available through multiple channels, e.g. public consultations, social media, email contributions.