City Airport Masterplan - Response

 In response to the City Airport Masterplan consultation, the Forest Hill Society has written a detailed response. Below is the text of the covering letter:

We do not consider that any increase in permitted flight numbers should even be considered until the noise problems that the Airport created in 2016 with its low altitude concentrated flight paths have been addressed, together with the low flying and crossing of flight paths with Heathrow. You have told us this would mean not until 2025 at the earliest. It is disappointing that the Airport has not seen fit to make a public statement setting out objectives to resolve these problems and that the Masterplan makes no little or no mention of them. We consider that a Masterplan should set out clear objectives on issues that will impact the residents of the thirteen overflown Boroughs, if necessary cross referenced to the Our Future Skies project to, for example:-

    Fly higher over urban populations
    Give respite or relief from noise to the overflown by alternating flight paths
    Fly a new, higher continuous descent approach over SE London
    Reduce or eliminate crossing of flight paths with Heathrow.

We also oppose any more early or late flights, and any longer operating hours over the weekend.

To view the full response from the Forest Hill Society please download from here. We are pleased that this includes comments and endorsement of our response by the London Borough of Lewisham and by Ellie Reeves, MP for Lewisham West and Penge.

Heathrow Airport’s Flight Path Consultation

By Tim Walker, Forest Hill Society’s Flight Path Group

Many people are bothered by noise from aircraft heading over our area to Heathrow and London City airports, though research shows that the decibel level and frequency of aircraft at which people become significantly disturbed varies. Surely, some aircraft noise is part and parcel of living in London? When planning huge expansions, airports are under environmental pressures as expectations rise for less noise and pollution. How then should Forest Hill ensure that its interests are taken into account?

In August 2018, I published a report on aircraft flying over our area, entitled No respite from aircraft noise in SE23. This explained how two airports, Heathrow and London City, combine their aircraft’s flight paths over Forest Hill, with each airport’s planes flying different paths and changing flight direction in different wind conditions. One of the report’s surprising findings was that south east London was unique in getting this double overflight situation; there was never a day when we did not get either one airport or the other’s planes, and quite often we get both at the same time. The Times picked up on this recently, name-checking Honor Oak and Forest Hill when the London Assembly reported on the issue.

London City airport controls the lower-level airspace over Forest Hill. In February 2016 residents along a line from Sidcup to Catford, Forest Hill, Dulwich, Herne Hill and north to Vauxhall noticed a sudden change: Aircraft that were previously dispersed were now flying along a very precise path over the same homes and schools at or under 2,000ft. People living under this relatively new low-altitude concentrated route are now affected significantly worse than before.

Until 4th March Heathrow is running a huge consultation, the first of several, on a complete redesign of the higher -level airspace they control over London. A third runway is planned for 2026 and, whether or not it is built, the airspace that has evolved piecemeal over 70 years will be redesigned.

After these issues were discussed at the last Forest Hill Society AGM, a group of members has been intervening where it has seemed effective, for example by:

• Taking a seat on behalf of the Society on the Heathrow Community Noise Forum
• Approaching Lewisham’s councillors and environmental protection officers to see how Lewisham might engage more — and act on our behalf on consultations like Heathrow’s
• Discussing shared issues with the Dulwich Society
• Briefing London Assembly members and members of the new Heathrow Community Engagement Board on south east London’s overflight issues
• Preparing a guide for south east Londoners on the current Heathrow consultation

We’d like to see regular breaks from aircraft noise for all communities, planes flying higher for longer and an end to the crossing of flight paths above us. We'd also like to make sure that the voices of Forest Hill and neighbouring south east London communities are heard on plans that affect us. Each individual can make a small difference by participating in consultations and by complaining, when disturbed by noise, to airports.

Aside from our overflight issue being noted by The Times, it has also been acknowledged by London City airport, which has for the first time carried out some initial noise monitoring in our area; and by Heathrow airport, whose consultation specifically mentions the need to address the double overflight situation. 

Heathrow Airport: Flight Path Consultation

Below is a guide to the consultation by SE Londoners, for SE Londoners responding to the Heathrow Airport flight path consultation.

• Heathrow is planning for a  third runway in 2026 and, whether or not that goes ahead, it is redesigning all its flight paths. Where you live in London probably affects how you view this. We each have until 4th March to complete their online questionnaire. If you’ve ever been woken by planes from before 5am, or had use of your home disturbed by planes overhead many miles from Heathrow, this is a chance to join everyone else in having your say.
• Please don’t be put off  from saying anything by the length or detail of what Heathrow says. It’s doesn’t need to take long and it seems important that SE London interests are properly represented by each of us.
• Thinking about how Heathrow and London City airports affect our environment by flying over us, we’ve made some suggestions as to how SE Londoners might want to respond to individual questions. If you use these, great, if you don’t agree or have additional points that’s fine too.
• We hope that our suggestions bring out a lot of the key points for our area and that this might be helpful for those who don’t want to spend too much time on this.
• For each of Heathrow’s questions we’ve put a few brief comments from a SE London point of view, with suggestions as to what you might say. Our comments are in the yellow boxes on the following pages.
• Worth noting that there is significant opposition to Heathrow from London Councils and environmental groups, but the principles established in this consultation are expected to be used whatever happens so it seems worth getting our SE London voices heard.
• Links to the Consultation and Other Useful Sources
• The link to the online Heathrow consultation is here:- https://afo.heathrowconsultation.com/

Question Number	Our Recommendation	Additional Information
1a	Yes	It seems essential that Heathrow does have a noise objective.
1b	“In its noise objective, LHR should put the health and well-being of London’s overflown communities as a high priority. Cost benefit to the wealthy airline industry is a lower priority than the long-term health and wellbeing of millions of overflown Londoners.”
2c	“We would like rotation/alternation of airspace and runways so that early morning wake-ups do not happen more than, say, once per week. They are currently from around 05:00am in SE London. There should be managed dispersal or several rotating routes in each noise envelope and these should be as far apart from each other as is possible. For weekends and evenings we seek the longest durations of respite possible to allow enjoyment of open windows and the outdoors.”
3a	“No”	Click on your preference, but we feel none of these options works well for SE Londoners and we think the answer should be “No”. We explain why in 3b.
3b	“Westerly operations means all  Heathrow arrivals will pass over north east and south east London including the very early morning flights from before 5am which wake us up and the evening flights which spoil enjoyment of the outdoors and continue to 11.30 at night. We feel it essential that flights are dispersed more fairly between east and west, and a westerly operations preference will disadvantage SE London and anywhere east of the airport. Westerly operations also overfly the low altitude route of London City Airport in our area, meaning that we are given no respite from one or the other.”
3c	“Yes”	We think prolonged periods of single direction operation day after day require intervention if wind strength and direction allow.
3d	“This flexibility provides a particularly useful way for Heathrow to avoid periods of simultaneous overflights with London City Airport. It also may prevent SE London having the early morning wakeup flights day after day when winds are set in one direction for days on end, and allow Heathrow to provide relief and sharing of impact.”
3e	“We feel strongly that London City and Heathrow Airports should immediately begin planning flight paths together, co-ordinating operations and directional planning very closely to avoid crossing of flight paths and double overflight of SE London communities as both airports increase flight numbers.”
4a	Probably “Option 2”
4b	“These early morning start times are for communities near to the airport, SE London overflight will be approximately 10 minutes earlier. We think the later the better for everyone’s undisturbed sleep but there is not much difference here.”	From Heathrow’s presentations we believe that Option 1 will allow rotation so that we will get 2 weeks out of 3 with no flights 05.50am over SE London which is better, in those weeks, than we get now.
4c	“There must be opportunity to commence operations much later than this if the 3rd runway goes ahead. Airline industry business objectives to accommodate early morning flights cannot and must not be at disproportionate cost to the health and wellbeing of the communities over which they fly. We think it unreasonable for SE London, many miles from Heathrow, to endure any overflights before 06:30 am.”
5a	“We believe Heathrow should have and enforce the most stringent of aircraft environmental standards that will protect overflown Londoners as much as possible from commercial aircraft noise and pollution. London Heathrow should adopt a world leading position on this issue.”
5b	“We feel that the currently proposed night flight ban of 6.5 hours is inadequate on health and well-being grounds. Our preference would be for a night flight ban of 8 hours duration.”
6	“Much of SE London (e.g. Sidcup, Mottingham, Catford, Forest Hill, Dulwich, Herne Hill, Stockwell, Vauxhall) are overflown by both London City and Heathrow planes, sometimes at the same time. The two airports should work together now on revising both airports’ flight path design so that crossing of flight paths is minimised, and simultaneous overflight ended. Heathrow planes should fly higher whenever crossing London City flight paths, so that London City planes can fly higher than the current 2000ft.”	This is about three runways, from 2026. The main local factor we think is the interaction with London City flight paths over SE London as both airports have strong growth plans that affect SE London.
7	“Much of SE London (e.g. Sidcup, Mottingham, Catford, Forest Hill, Dulwich, Herne Hill, Stockwell, Vauxhall) are overflown by both London City and Heathrow planes, sometimes at the same time. The two airports should work together now on revising both airports’ flight path design so that crossing of flight paths is minimised, and simultaneous overflight ended. Heathrow planes should fly higher whenever crossing London City flight paths, so that London City planes can fly higher than the current 2000ft.”	This is about two runways as at present. The points about double airport overflight in SE London seem the same as in Q6, whether Heathrow has two or three runways. To repeat, the main local factor we think is the interaction with London City flight paths over SE London as both airports have strong growth plans that affect SE London.
8	“Fly higher for longer in South London – flights arriving over most of SE London need to be higher than proposed in order to reduce noise and create additional space for the low flying London City planes beneath. As a general principle disperse flights fairly over all London communities so that noise and environmental impact is shared. Concentrated flight paths should be separated as widely apart as possible with frequent rotation to give periods of relief to those on the ground.”
9	You may wish to consider any of the following issues: Aircraft noise disturbance •       Enjoyment of outdoors – loud enough to stop conversation. Summer evening activities •       Enjoyment of indoors too, when doors/windows are open •       Early morning wakeups from before 5 am (Heathrow) •       Late night arrivals to 11.30pm (Heathrow) Concentrated flight paths using new technology •        Across the world have created noise corridors, replacing aircraft dispersal and sharing of noise •       Create high frequency of overflights, same homes every time - London City 15 per hour at peak Low altitude •       Low flights create louder disturbance. London City only 2000ft over SE London. Heathrow higher over SE London, but much bigger, louder planes. Environmental pollution •       Low at ground level in east London, but will increase as the two airports expand