Bedford Park Society Advice On How To Complete Heathrow Consultation

Call on residents to oppose the airport expansion plans by responding soon

The Bedford Park Society has issued advice for residents who wish to complete the Heathrow Airport consultation document.

You can also read more on their website about the impacts of the airport's plans on local residents.

The deadline for the consultation is 4 March.

Suggested responses to Heathrow Airspace and Future Operations consultation - the answers recommended are in bold print.

NOTE: Please be aware that the numbering on the Heathrow online questionnaire is not sequential, so is not entirely consistent with the numbering below.

1a. Do you support our proposals for a noise objective? Yes/ No/ I don’t know

No.

1b. Please provide any comments you have on our proposals for a noise objective:

Whilst I fully support the regulatory constraints that are being placed on Heathrow with regard to the impact that its expansion plans may have on noise, air quality and traffic, I do not believe that the noise objective sufficiently reflects those constraints. So, I believe it should state:
“To limit and reduce the effects of noise on health and quality of life and deliver regular breaks from scheduled flights for our communities during the day and night, in accordance with the Balanced Approach to Aircraft Noise Management.”
This removes the words ”where possible” and the references to “proportionate and cost effective.” The proposed changes to airspace should not go ahead unless Heathrow can commit to control the environmental impacts to an acceptable level, including noise, and the cost of measures should not be a consideration – the quality of life for people overflown should trump economics and business considerations.

1c. Please provide any other comments or suggestions you have on our proposed approach to developing a package of noise measures for an expanded Heathrow:

I agree with Heathrow’s proposal, under the Balanced Approach, that non-restrictive measures (such as incentivising the use of quieter aircraft and requiring aircraft to use quieter operating measures) should be applied first, before any restrictive measures such as bans or quotas are used.
I welcome Heathrow’s proposal for Aircraft Noise that “the overall impact of aircraft noise must be limited and, where possible, lower than 2013 noise levels.” Given that there are currently no flight paths over the Bedford Park Conservation Area and surrounding neighbourhood (Postcode area W4 1) and we suffer extremely limited and rare aircraft noise, this means that the proposals to changes in airspace, which affect Bedford Park (design envelopes IP1, IP2, A1 and D2) could not be implemented without contravening design principles 6b and f.

Respite through runway and airspace alternation

2a. Would you prefer to have longer periods of respite less frequently (all day on some days but no relief on other days) or a shorter period of respite (e.g. for 4-5 hours) every day? Please tick one of the following options: A longer period of respite, but not every day/ A shorter period of respite every day Yes No/ I don’t know

A shorter period of respite every day.

2b. Please tell us the reasons for your preference:

Please see answers to 2a above. In addition I believe it is important for there to be some respite every day to minimise to the greatest extent possible the daily irritation from aircraft noise.

2c. Please provide any other comments or suggestions you have on runway and airspace alternation:

It is not consistent with design principles 6 b and f for any flight paths to be selected which would involve flights over the Bedford Park Conservation Area in London W4 1 and so in principle this question is not relevant to our area.
However, to the extent that our area could be affected by flights over neighbouring areas, I would prefer to have shorter period of respite every day.

Directional preference

3a. Should we prefer westerly operations during the day and easterly operations at night to reduce the total number of people affected by noise? Yes/ No/ I don’t know

No.

3b. Please tell us the reasons for your answer:

It is not consistent with design principles 6b and f for any flight paths to be selected, which would involve flights over the Bedford Park Conservation Area and surrounding neighbourhood in London W4 1 and so in principle this question is not relevant to our area.
If forced to choose in the unacceptable scenario of flight paths over Bedford Park, I would prefer to minimise westerly operations whenever possible, as this area would be particularly badly affected by these compared with easterly operations. I would, therefore, prefer easterly operations both by day and by night. However, I also note that the ban on night flights should mean very minimal or no flights at night.

3c. Should we sometimes intervene to change the direction of arriving and departing aircraft to provide relief from prolonged periods of operating in one direction – even if that means slightly increasing the number of people affected by noise? Yes/ No/ I don’t know

No.

3d. Please tell us the reasons for your answer:

The consultation paper states that a managed preference would be operated in accordance with “a set of criteria or rules designed to limit overall noise effects on communities and to help deliver periods of relief for them.” I would wish to see tighter rules so that it is absolutely clear where planes can and cannot fly and in what circumstances before being able to support any proposal of this nature.

3e. Please provide any other comments or suggestions you have on directional preference:

It is not consistent with design principles 6b and f for any flight paths to be selected, which would involve flights over the Bedford Park Conservation Area and surrounding neighbourhood in London W4 1 and so in principle this question is not relevant to our area.

Night flights
Early morning arrivals

4a. To help inform our consideration of the options, we want to know whether you would prefer for us to: Option 1 – Use one runway for scheduled arrivals from 5.30am (runway time 5.15am) Option 2 – Use two runways for scheduled arrivals from 5.45am (runway time 5.30am) Yes/ No/ I don’t know

Option 1.

4b. Please tell us the reasons for your preference:

Communities would benefit from a later start two out of every three days.

4c. Please provide any other comments or suggestions you might have on early morning arrivals:

It is not consistent with design principles 6b and f for any flight paths to be selected, which would involve flights over the Bedford Park Conservation Area and surrounding neighbourhood in London W4 1 and so in principle this question is not relevant to our area.
It should also be noted that for those living in the Bedford Park Conservation Area the soundproofing options are severely limited due to the restrictive listed building rules. In this respect the houses and buildings in the Bedford Park Conservation Area are “noise-sensitive buildings” as highlighted in the consultation document, and should be identified in the same way as other noise sensitive buildings.

Other night restrictions

5a. Please provide any comments or suggestions on how we should encourage the use of the quietest type of aircraft at night (outside the proposed scheduled night flight ban):
The measures Heathrow proposes for encouraging quieter aircraft appear to make sense. I am, however, sceptical of the possibilities of genuinely quiet aircraft. There is still an extremely long way to go to developing planes, which won’t wake up communities, which are overflown.

5b. Please provide any other comments you have on night flights and restrictions:

I do not support proposals for any night flights over the Bedford Park Conservation Area and surrounding neighbourhood, as this would prioritise economic considerations over the health of residents.
It states in Heathrow’s consultation document that in the interim consultation in January 2018:
• Local Authorities supported the night ban and over half said it should be longer
• The public supported the night ban and many said it should be longer
• Airlines expressed strong concerns about the economic impacts and indicated that a night ban would mean flight cancellations.
Heathrow should acknowledge the concerns of local communities, such as the residents of Bedford Park, and extend the proposed night ban to at least 7.5 hours, if not 8 hours, to enable communities to have a chance of sleeping for a healthy period each night. Whilst I note that airlines may encounter economic impacts, these should be of secondary importance and should not be allowed to trump the health of residents in the community.

Airspace – local factors

6. To answer this question, please look at the design envelopes for expansion online using the postcode checker or look at them in our document Heathrow’s airspace design principles for expansion. What sites or local factors should we be aware of in your area (or other area of interest to you), when designing flight paths for an expanded three-runway Heathrow? Please give enough information (e.g. postcode, address or place name) for us to identify the site(s) or local factor(s) you are referring to and tell us why you think it is important:

I object in the strongest terms to any new flight paths directly over or close to the Bedford Park Conservation Area and surrounding neighbourhood, and, therefore, to Bedford Park being covered by any design envelopes, and in particular two of the design envelopes for an expanded Heathrow A1 and D2.
The proposed design envelopes contradict the design principles Heathrow have agreed:
• 6b minimise the number of people newly overflown
• 6f minimise the total population overflown
There are currently no flight paths over the Bedford Park Conservation Area and surrounding neighbourhood, so new flight paths over this area would, by definition, add to the number of people newly overflown and would add to the total population overflown. Furthermore, it does not promote principle 6g, designing flight paths over commercial and industrial areas.
It should be noted that for those living in the Bedford Park Conservation Area the soundproofing options are severely limited due to the restrictive listed building rules. For example, the replacement of traditional glazing with double-glazing is normally prohibited leaving residents of such properties with limited scope to mitigate the impact of aircraft noise. In this respect the houses and buildings in the Bedford Park Conservation Area are “noise-sensitive buildings” as highlighted in the consultation document, and should be identified in the same way as other noise sensitive buildings. The flying of planes over Bedford Park at the heights, frequency and noise levels proposed would have a seriously detrimental effect on the health and quality of life of people living in this historic conservation area and the surrounding neighbourhood. This includes the approximately 2,200 children and young people attending the five nurseries and schools in Bedford Park, including the world-renowned Arts Educational Schools.

7. To answer this question, please look at the design envelopes for Independent Parallel Approaches (IPA) online using the postcode checker or look at them in our document Making better use of our existing runways. What sites or local factors should we be aware of in your area (or other area of interest to you), when designing new arrival flight paths to make better use of our existing two runways? Please give enough information (e.g. postcode, address or place name) for us to identify the site(s) or local factor(s) you are referring to and tell us why you think this local factor is important: Please tick the box if you would like your response to 6a to be copied as a response to 6b.

I wish to make the same points in relation to this question as in relation to question 6. However, the design envelopes relevant to the question are IPA A1 and IPA A2 and the relevant design principles are IPA design principles 6d, e and f. These are derived from your website, although your Making better use of existing runways document says the IPA design principles are yet to be agreed with the CAA.

8. Please provide any other comments you have relating to the airspace elements of the consultation:

I wish to highlight and re-iterate that the airspace proposals contravene the design principles Heathrow have agreed, in particular the principle to minimise the number of newly overflown people. I also wish to highlight that these proposals put economic and business interests above the health of local communities, and this should not be permitted. I, therefore, object strongly to the airspace proposals.

General comments

9. Having considered everything within the consultation, do you have any other comments?

I strongly object to the fact that Heathrow have failed to hold a consultation event in Chiswick, an area of some 35,000 people who will be so badly affected if the proposals were to be implemented, with so many newly overflown homes (should Heathrow fail to comply with its design principles), which leads me to question the validity of the consultation.
The consultation document includes proposed design envelopes to be used for independent parallel approaches (IPA A1-3). These design envelopes almost exclusively affect communities not previously overflown (contrary to principle 6b). The ability to route a flight path over one community (not previously overflown) as opposed to another community (not previously overflown) within these design envelopes simply exacerbates this impact. These design envelopes also require aircraft to bank steeply thereby needing more engine power and generating both more noise and pollution than would be the case on the present glide paths. These design envelopes should be ruled out and the new navigation technology should be used in a way that benefits not just the airport but also those living close to it.

10. Please give us your feedback on this consultation (such as the documents, website or events):

You state on your website that the questionnaire will take an estimated 45 minutes to complete. This is a huge underestimate if people are to read, digest and consider the material and respond thoughtfully. It is an enormous burden on individuals affected by these proposals and a serious impediment to participation. The consultation encompasses extraordinarily complex issues, which are not clearly enough explained to enable even extremely well educated readers to understand them (a difficulty shared by Heathrow representatives at consultation events), and includes questions that suggest binary answers are appropriate when they are not. As such, this is a deeply flawed process.

11. Please tell us how you found out about this consultation: Leaflet through your door Newspaper advert/ Online advert/ Billboard/Outside advertising Local radio/ Other (please specify):

National newspaper, then leaflet through letterboxes and local media website.
Signed:
Name:
Address:
Date:

February 13, 2019