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UK Airspace Policy consultation: Gatwick Airport Limited

response, 25 May 2017

1. Overview of response

Gatwick Airport Limited (GAL) agrees with Government’s objective to ‘support

airspace modernisation in order to deliver benefits for the UK economy, for

passengers and for communities affected by aircraft noise’. It is broadly supportive of

Government’s proposals for:

o Greater transparency in decision making and the way noise is handled;

o Increased focus on engagement and locally-informed solutions;

o Improvements to the evidence base which informs how airspace decisions

are made, particularly evidence on the noise impacts; and

o Clarity and consistency in the level at which decisions are made.

GAL has, over the past 1-2 years, sought to make a step change in how it

communicates with and consults local communities on noise and airspace issues.

Government airspace policy should enable and encourage such airport initiatives to

deliver a balanced approach to noise management and economic benefits.

GAL aims to continue to develop the airport to meet the growing demand for air

travel, and in doing so to enhance the resilience of airline services operating from

Gatwick. To achieve this will require GAL to invest substantially in airfield and ATM

infrastructure and process, and to complement these with innovative changes in

airspace management over time.

GAL supports reform in UK airspace policy which would encourage this long-term

investment. It is important that when implementing its UK airspace policy, the

Government should put forward clear guidelines for airspace modernisation that

would take proper account of the legitimate interests of local communities. Such

guidelines should also allow the development of an airspace structure that best

meets the country’s economic needs, following a transparent and proportionate

consultation of those affected by aircraft noise.

Reaching a consensus on the balance between the benefits to passengers of

aviation growth and the costs to communities in terms of noise impacts can be

contentious. GAL supports the Government’s objective of delegating consultation and

decision-making to the appropriate local or regulatory level. However, GAL also

encourages the Government to set out clear strategic guidance that can help reach

conclusions at the airport level, and which avoids fostering endless unproductive

debate. The Government should recognise, and build into the architecture for

airspace change, that – at each stage – there needs to be a final decision-maker.

Furthermore, beyond clear guidelines there is a clear need for DfT leadership, as

emphasised in the GAL response to the Transport Select Committee Call for

Evidence, to ensure that the scale of change necessary for airspace modernisation in

the South East is delivered in a form and timescale that ensures the air traffic

network remains safe and efficient.

The changes in the Airspace Policy Framework (and CAA guidance) must be

supported by the deployment of suitably qualified technical expertise in appropriate

numbers within the regulator to mitigate risks to the management of the new process.

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2. UK airspace policy – GAL’s initial comments

GAL welcomes the Government’s policy consultation on airspace change at this time

of important planning for the future of the UK’s aviation infrastructure. Gatwick, as the

world’s busiest single runway airport and operating within the London Terminal

Manoeuvring Area (London TMA), one of the world’s most complex and busiest

airspaces, is highly dependent upon a safe and effective means of managing and

modernising airspace locally, regionally and at a European level.

Gatwick’s plans for future growth in traffic from the current runway infrastructure will

need a robust and transparent framework for airspace change, in which airport and

airlines, air traffic control, and communities affected by noise can collectively reach

well informed views of the options. In this context, Gatwick aims for open dialogue

with local stakeholders, and seeks a fair and equitable distribution of noise, and a fair

balance between the benefits to passengers of growth in traffic and reductions in

local noise and other environmental impacts. In the near term, airspace

modernisation could help deliver improved flight efficiency and noise respite benefits

to affected communities, sooner than is feasible under current regulatory procedures.

Airspace changes made in the coming decade to enable the proposed third runway

at Heathrow to come into operation must not constrain the growth potential at other

South East airports, including Gatwick in either its current configuration or, if the

Government were to support such a development, with a second runway.

It should be recognised that in addition to the sustainable growth objective for

airspace modernisation, set out by the Government, there are also airspace changes

that are required in order to keep the UK in line with international safety and

interoperability protocols.

In taking forward the proposals for airspace change, the Government should

recognise fully at the outset the challenges inherent in delivering benefits to the

economy and environment in this field. Most recently, the UK’s Future Airspace

Strategy (FAS) has not made the progress to date which it had the potential to do.

The flaw in the delivery of UK FAS is the revealed gap between the laudable

aspirations of the strategy, on the one hand, and on the other the leadership and

capability to deliver the necessary supporting programmes at sufficient pace to

achieve timely change. Stronger Government support is necessary to shape and

drive this airspace change.

As the UK prepares to leave the European Union, the Government should seek to

retain the benefits to UK aviation which currently flow from the UK’s membership of

EUROCONTROL and the EU Single European Sky programme. The UK’s

relationship with EUROCONTROL should be independent of the UK’s membership of

the EU. The UK should ensure that future arrangements for the collaborative

management and development of the broader European airspace take full account of

the UK’s needs, both through its membership of EUROCONTROL and through

establishing a legal relationship with EU Single European Sky projects. Such projects

are vital to enable Gatwick and other UK airports to deliver air traffic management

enhancements.

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UK airspace policy – GAL response to consultation questions

GAL response:

The proposal helpfully goes some way to clarify the respective roles of the Secretary

of State and the CAA, recognising the broader remit of the Government to balance

UK-wide economic and societal interests.

Tier 1 airspace changes are, by definition, of national strategic importance. As such,

they inevitably entail complex and far-reaching judgements which balance a range of

potentially competing economic, environmental and operational factors. The

Government must provide clear overarching policy guidance on how it would

approach such changes, setting out the evidence it would use and how it would

weigh such evidence. Without such policy guidance, there would be a risk that

potentially beneficial strategic airspace changes could founder and lose momentum if

they are not seen to be in alignment with a clearly stated Government policy in the

national interest.

The suggested criteria for Secretary of State call-in require further work to define

better the triggers, taking into account factors such as location and other sensitivities.

First, the focus on the net number of people affected by aircraft noise arising from a

specific airspace change overlooks the potentially much larger numbers of people

who may be newly exposed to significant levels of noise, offset by others who may

be relieved of noise impacts. For example, an airspace change could result in

100,000 people being newly affected by noise and 91,000 relieved of significant

noise impacts, resulting in a net impact of 9,000. In this case, a substantial airspace

change affecting a very large population would not meet the criteria for political

oversight and decision-making. Alternatively, this metric could encourage perverse

behaviours which allow sponsors to break down airspace changes into smaller

components in order to ensure change proposals fall below any set threshold.

Netting off implies a comparable noise tolerance of each group, which may not in

practice be a reasonable assumption. Some of those living with aircraft noise will

have demonstrated through their home location decisions a tolerance of noise which

is likely to be higher than for the population as a whole. Conversely, the newly

affected population groups are likely to be self-selected more sensitive residents who

chose to live in a relatively quiet location, compared to those who chose to live in a

noisier area that has been noisier for many years.

Second, the single measure of those affected, the daytime 54dB threshold, may miss

some people significantly affected, and hence fail to be in line with Government noise

1. Changes to Airspace

a. Tier 1 airspace changes

Views on the proposed call-in function for the Secretary of State in tier 1 airspace changes

and the process which is proposed, including the criteria for the call-in and the details

provided in the draft guidance.

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policy to limit the number of people significantly affected. For example it may miss

changes in night noise.

Third, if a threshold were to be set, a net additional 10,000 people affected seems

high. By way of reference, there were 11,300 people exposed to noise above Leq

54dB around Gatwick in 2015. It also appears high considering the Secretary of

State’s role in determining planning applications for other noise-producing

infrastructure, such as road or rail improvement schemes, whose effects may be very

local in comparison.

In refining the criteria for Tier 1 change, GAL would caution against adopting a UK

Aeronautical Information Publication (AIP) change as a criterion to define Tier 1

change. AIPs are changed for a variety of reasons, from relatively minor tactical

modifications to aircraft operation procedures up to and including changes necessary

to implement major strategic airspace changes. The fact of AIP change in and of

itself would not justify a Tier 1 categorisation. Conversely, though, a Tier 1 change

would be very likely to be associated with one or more implementing AIPs changes.

Finally, the Government could helpfully consider further the potential for differentiated

approaches to assessing the different categories of Tier 1 changes: permanent

planned changes, temporary changes for special events, and trials of changes which

may become permanent. In order for the UK aviation sector to be able to achieve the

sustainable growth potential outlined by the Government, then airspace

modernisation needs to proceed at an efficient pace. Trials of novel airspace design,

technology and concepts can contribute to airspace change by providing more rapid

feedback and data to airspace change promoters on operational and noise impacts.

These data in turn enable better informed policy decisions on the proposed change.

These benefits of trialling airspace changes could be lost if the process of assessing

trials of Tier 1 changes became so onerous as to deter the use of trialling, thereby

slowing the overall pace of airspace modernisation.

GAL response:

GAL supports this proposal in principle, as part of an overall strategy of greater

transparency and consultation with local communities, and thereby enhancing public

confidence that an appropriate balance between economic benefit and environmental

and noise impact has been struck. In implementing this policy, there is a need to

ensure that the cost benefit appraisal reflects the full range of relevant factors

(operational efficiency, safety, environment, noise), without unduly privileging one

factor (such as noise) over others. It will also be important that change process

enables the balance between these factors to be set in light of local circumstances,

rather than conforming to any national expectation on the distribution of benefits.

1. Changes to Airspace

b. Tier 2 airspace changes

Views on the proposal that tier 2 airspace changes should be subject to a suitable change

process overseen by the CAA, including the draft guidance and any evidence on costs

and benefits.

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The consultation process, to be specified by the CAA, should be proportionate to the

scale of the change proposed. Consultation should ensure that changes are at the

very minimum communicated effectively to affected communities and that these

groups have the opportunity to comment, before implementation, with greater

degrees of consultation on top of this minimum depending on the nature of the

proposed change. The CAA policy on appropriate change processes for tier 2

airspace changes should encourage existing industry best practice, such as

Gatwick’s Noise Management Board.

Options analysis should helpfully support the process of consultation, by enabling

airspace change proposers to explain the pros and cons of options in a consistent

and structured manner to those affected. It should also provide a firm framework for

incorporating evidence arising from consultation into the decision-making process,

and demonstrating to local stakeholders and to the CAA how such evidence has

been weighed up. The fact of consulting on options should not lead those affected to

consider that they have a vote or a veto on the options.

Whilst supporting the requirement for a more robust process and better definition of

consultation processes for changes of this type, GAL’s view is that a consequence of

this enhanced guidance is likely to be to slow the process of delivering noise

management initiatives at the local level, even where consultation is channelled

through an effective noise management board.

Although Tier 2 appears targeted at air traffic management and operational changes,

the example used of a Manual of Air Traffic Services Part 2 change is too imprecise

an example to define tier 2 changes. It could also imply that changes are only those

related to an ANSP, which we believe is not the case. It should also be noted that

many changes in MATS Part 2 are driven by higher-level regulatory changes in air

traffic operations, most of which would not have a material impact on noise and

hence should not be subject to the proposed Tier 2 consultation proposals.

Some clear examples and/or scenarios would help the definition of all of the tiers of

change.

GAL response:

GAL supports this proposal in principle, as part of an overall strategy of greater

transparency and engagement with local communities, and thereby enhancing public

confidence that an appropriate balance between economic benefit and noise impact

has been struck. It could be helpful for this Tier 3 to be described as changes in

1. Changes to Airspace

c. Tier 3 airspace changes

Views on the proposal that tier 3 airspace changes should be subject to a suitable policy

on transparency, engagement and consideration of mitigations as set out by the Civil

Aviation Authority.

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usage of airspace as a result of differing patterns of operational demand, which may

have implications for local communities, rather than as planned changes in airspace

design or operational procedures.

The guidance should therefore be clearer in reflecting Tier 3 as an information and

engagement process rather than as part of a consultation process leading to decision

making. Once again, examples may assist with clarity between tiers.

The CAA should put in place a clear and practical policy for airports to engage with

affected communities, but not be overly prescriptive or require formal consultation at

Tier 3. At this level of operational change, there are likely to be occasions when more

efficient airspace outcomes could be achieved through a series of linked Tier 3

changes, where the results of one change influence the design and implementation

of the next. Operational flexibility could be unduly restricted if each stage in the

process were subject to formal consultation, including the scope for parties to appeal

to the CAA for resolution of disputes.

Consideration should be given to a decision making process which would define the

tier of change at a sufficiently early stage. It should be recognised that those

opposed to a particular change may seek to frustrate it by challenging the

categorisation of change between Tier 3 and 2, e.g. by seeking to press for formal

consultation as a Tier 2 change rather than simply information provision and

engagement under Tier 3. To avoid the scope for nugatory airspace change

proposals, the CAA should be able to provide, on request, a ruling as to the category

of airspace change, Tier 2 or 3, to guide subsequent information sharing and/or

consultation on change.

1. Changes to Airspace

d. the airspace change compensation proposals:

Change the policy wording to remove the word ‘development’ in terms of when

financial assistance towards insulation is expected so that compensation is

applicable regardless of the type of change (infrastructure or airspace change);

Change the policy wording to allow for financial assistance towards insulation in

the 63dB LAeq level or above to be applicable regardless of the level of change

that causes a property to be in that noise contour level (i.e. remove requirement for

a minimum 3dB change);

Inclusion of additional wording in the policy to encourage an airspace change

promoter to consider compensation for significantly increased overflight as a result

of the change based on appropriate metrics, which could be decided upon

according to the local circumstances and economics of the change proposal.

Include a requirement of an offer of full insulation to be paid for by the airport for

homes within the 69dB LAeq or more contour, where the home owners do not want

to move.

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GAL response:

GAL agrees with the overall aim of the Government’s proposals in this area, to

improve fairness and make compensation policy more transparent, and broadly

supports each of the four specific changes in policy proposed. There are, however,

several aspects of the compensation proposals which should be refined further.

As noted below, GAL would encourage the Government to clarify the distinction

between its compensation policy, on the one hand, and the proposals for quantifying

the impacts of noise in airspace change processes, on the other. Quantification for

the purpose of options appraisal will encompass a much broader swathe of (lower)

noise impacts than the noise thresholds above which airports provide compensation

payments to affected residents. It is important to make clear the distinction between

compensation for severe noise impacts, and quantification and monetisation of

adverse noise impacts.

The discussion on compensation refers only to noise insulation which does not

mitigate all the significant noise effects, and hence does not consider other forms of

compensation in line with Government noise policy more generally. Wider forms of

compensation should be considered, as for example they are for new or widened

highways or railways that generate increased noise effects. These might include

community infrastructure fund payments, Council Tax support, compensation related

to house prices, and support to move home.

GAL notes that no change is proposed to the Leq 63 threshold for noise insulation.

This appears to be supported by the results of the Survey of Noise Attitudes (SoNA)

2014, which shows the same proportion of the population, 23%, highly annoyed at 63

LAeq 16h dB as in previous studies (ANIS 1982). The latest evidence on attitudes to

noise also shows a small increase in the degree of annoyance at lower noise levels

(9% highly annoyed now at 54 LAeq 16h dB, rather than 57 LAeq 16h dB in 1982).

GAL considers that the proposed removal of the +3dB change requirement is likely to

be manageable for noise insulation schemes set at the absolute level of 63dB. For

wider compensation schemes, however, at lower noise levels, the threshold of +3dB

should be maintained, because it ensures that only people experiencing a significant

increase in noise, as a result of the airspace change, are compensated. Changes of

less than 3dB are not generally and universally perceptible and should not warrant

compensation. If any increase in noise were required to be compensated, then this

would be problematic to administer given noise modelling and monitoring limitations.

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GAL response:

GAL supports the principle of a risk-based approach to the estimation of noise

impacts, and the objective of enabling the noise impacts of airspace options to be

compared in a robust and understandable manner. In implementing this approach,

though, the Government should ensure that the methodology used to appraise

options does not in practice lead to a systematic bias towards one approach to

airspace design over another, for example, concentration versus dispersion. Any

such bias could well act against the local preferences of some communities affected

by particular airspace changes.

GAL agrees with the Government’s proposals to broaden the range of noise impacts

which are quantified and weighed when considering an airspace change, and with

the proposed LOAEL metric and threshold values for assessing day and night noise

impacts.

The consultation suggests (5.51) that the N65 metric should be used as a

supplementary measure of daytime noise. It is not clear why this is considered

preferably to N70, which was derived on the basis that noise events creating LMax

level above 70dB outside properties are sufficiently high to disturb noise-sensitive

daytime activities inside. This may be appropriate, but with the proviso that it will be

increasingly important to consider noise from non-aviation sources when assessing

newly affected populations. It is likely that many residential properties (for example,

those facing onto busy roads) will already experience day LMax levels above 65dB

from other sources.

N65 Day and N60 night are noise metrics, not levels, so it will be important for the

guidance to specify above what number of events, for the day and night,

assessments should report. The N60 night 20 event level may be appropriate given

other guidance on numbers of night noise events and sleep disturbance.

2. Assessing Noise in Airspace Decisions

a. Views on the proposal for assessing the impacts of noise, including on health and

quality of life. Please provide any comments on the proposed metrics and process,

including details provided in the draft guidance.

i. the number of people experiencing adverse effects as a result of aviation noise

should be limited and, where possible, reduced. Adverse effects are

considered to be those related to health and quality of life. These adverse

effects should be assessed using a risk-based approach above the LOAEL

(lowest observed adverse effect level) … 51 dB LAeq 16hr should be regarded

as the LOAEL for daytime noise. We also propose that a LOAEL of 45 dB

Lnight should be set for assessing the impact of aviation noise during the night.

ii. the CAA’s metric for overflights should be used for this purpose as a means of

understanding and explaining how noise will be experienced by those on the

ground and that for night noise, N65 daytime and N60 night time metrics should

also be used.

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The CAA’s metric for overflights may also have a role to play but requires further

specification: the choice of viewer angle (48.5 or 60 degrees, as left open to a

Government decision in CAP1498) will need to be clear, and there will need to be a

clear cut-off for noise levels, or as a proxy the upper boundary for altitude (4,000 or

7,000 feet). Analyses of changes in overflights do not necessarily reflect changes in

noise, and could in some cases give misleading results (e.g. if a proposed new route

was lower in the sky but nearer a community). It will be important that analyses of

changes in overflight do not overrule the analysis of changes in noise impact.

GAL would encourage the Government to reconfirm that the definition of noise

impacts for purposes of its compensation policy is distinct from its proposals for the

quantification and monetisation of a wide range of noise impacts for the purpose of

assessing options for airspace change. Quantification of a noise impact in airspace

options appraisal does not imply that compensation would be paid by the relevant

airport.

GAL response:

GAL supports the objective of enabling noise impacts of airspace options to be

compared in a robust and understandable manner. It is important, however, to

recognise that the main parameters in such appraisals (safety, airspace efficiency,

noise) present their own challenges in terms of measuring impacts. There are also

further challenges in consolidating this analysis across the three dimensions to arrive

at a single rounded assessment. The Government could build confidence in the

aviation sector, and among community noise groups surrounding each airport, by

explaining clearly, and by best practice example, how such options analysis could be

efficiently conducted.

GAL agrees that options analysis should be carried out as part of change processes

for airspace. It should be recognised though that such analysis can be both

conceptually and technically challenging, and therefore the methodology adopted

and the results can be subject to differing professional judgements. For example,

GAL is currently discussing with its affected local communities, via the Noise

Management Board, the concept of ‘fair and equitable’ distribution of noise impacts.

This is a normative political debate (a subjective discussion through which different

perspectives are expressed by various stakeholders and communities) in which there

is no one technically correct answer. The outcome of this debate will affect GAL’s

approach to airspace design in future, for example in terms of dispersal or

concentration of routes, and in the balance between newly affected and relieved

communities. Even if a consensus emerges, the translation of an agreed policy into a

quantified options appraisal will also raise questions of interpretation which could

provoke further debate.

2. Assessing Noise in Airspace Decisions

b. Views on the proposal to require options analysis in airspace change processes, as

appropriate, including details provided in the draft guidance.

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The analytical tool proposed for airspace options appraisal is WebTAG, the

Government’s generic transport appraisal framework. It is acknowledged that this has

not been developed with airspace change in mind, although it does include a module

for assessing the impact of aircraft noise. In order to provide clarity and confidence

for the aviation sector and the communities affected by aircraft noise that WebTAG is

indeed fit for the purpose of airspace change options appraisal, the Government

should commission the CAA now, and ICCAN subsequently following its

establishment, to develop guidance on the use of WebTAG specifically for airspace

change. Such guidance might demonstrate best practice examples of how a previous

airspace change could have been appraised using WebTAG. It could also

demonstrate how in practice an appraisal of options could bring together evidence

from a range of fields (safety assessment, operational efficiency, noise impacts, etc.),

and present a balanced picture of qualitative, quantitative, monetised and non-

monetised factors.

To enable the principle of decision-making informed at the local level to be put into

practice effectively, WebTAG will need to be configured to allow locally-based

judgements and weighting to be incorporated into the process. In particular, the

calculation of costs and benefits of concentration and dispersal will need to be able to

take into account local circumstances as well as the desires of local communities.

As summarised at paragraph 5.13, Government policy is to reduce the number of

people significantly affected by noise, and paragraph 5.16 illustrates how this might

apply to concentration or dispersal choices. To operationalise this policy, however,

the Government must define significantly affected (SOAEL). Each airport can then

map its SOAEL zone now and with each of the airspace change options. The

Government helpfully acknowledges (at paragraph 5.16) that, within the SOAEL

zone, concentration of flight paths may best comply with policy by minimising those

significantly affected and keeping flight paths unchanged (and mitigating and

compensating those significantly affected as necessary). Outside the SOAEL zone,

though, dispersion may help alleviate existing noise effects at the expense of

introducing newly affected populations, but as such newly affected populations will

not be significantly affected, such an airspace change would comply with policy.

Discussions on flightpaths and routings relate ‘primarily to options for departure flight

paths’ (as noted at paragraph 5.18). Gatwick has been studying arrivals noise in

recent months and has found that not only is arrivals noise increasingly important (as

noted in paragraph 3.11 noise footprints of new aircraft are shrinking less for arrivals

that for departures), but historic patterns of dispersal are important to local

communities.

GAL response:

GAL supports the Government’s proposal for the functions of ICCAN.

In parallel with the establishment of ICCAN, the Government should clarify the

relationship between the CAA Board and ICCAN, and between the CAA staff and

3 Independent Commission on Civil Aviation Noise

a. Views on the Independent Commission on Civil Aviation Noise’s (ICCAN’s) proposed

functions.

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budget and ICCAN’s own staff and resources. For the CAA to take a balanced and

informed view of airspace change proposals, it would need to retain some capability

to assess both this evidence produced by sponsors of airspace change proposals

and the independent advice which it will receive from ICCAN. The proposed ICCAN

sunset review period is set at 5 years. Given the significance of the introduction of

ICCAN consideration should be given to a shorter period of review, perhaps 3 years,

to allow lessons in the early years to be learned and provide aviation stakeholders,

including communities, greater empowerment in shaping the work and functions of

ICCAN.

GAL response:

GAL broadly agrees with the proposed structure and governance, to the extent that

the Government has defined these so far. GAL would welcome more detail and

clarity on aspects of ICCAN’s role and its interaction with CAA, Government and the

aviation industry.

In GAL’s view, the Government could helpfully clarify ICCAN’s role as follows:

o Advisory to CAA and the Secretary of State, not statutory decision-maker

o ICCAN board to be balanced, including individuals with experience of aviation,

public health, community engagement, natural environment, as well as DfT

official(s)

o ICCAN board supported by permanent and dedicated secretariat, research and

policy staff

o ICCAN board connected to airports across UK via stakeholder advisory board,

comprising representatives from local noise management boards (or equivalents)

o ICCAN funded by Government grant, not by levy on aviation industry (as for rest

of CAA)

o CAA current noise expertise (Environmental Research and Consultancy

Department ERCD) divided between ICCAN staff and residual CAA noise

expertise and consultancy function.

3 Independent Commission on Civil Aviation Noise

b. Views on the analysis and options for the structure and governance of ICCAN given in

Chapter 6, and the lead option that the Government has set out to ensure ICCAN’s

credibility.

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The suggested relationship between ICCAN, CAA, Government and the aviation

sector is illustrated in the following diagram:

In the process of introducing ICCAN, the Government and the CAA should be mindful

of the need to continue to make available to the aviation sector sufficient resources

and policy leadership to enable airspace changes to be processed efficiently and

effectively. Without this, there is a risk that attention within both newly established

and existing organisations could be focused overly on the management of change, to

the detriment of immediate requirements to contribute to airspace changes.

GAL response:

GAL agrees with this proposal.

4. Ongoing Noise Management

a. Views on the proposal that the competent authority to assure application of the

balanced approach should be as set out in Chapter 7 on Ongoing Noise Management

and further information at Annex F.

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GAL response:

GAL agrees with the aim of the Government’s proposals, that Government

involvement should be determined according to the significance of the decision,

rather than by the identity of the airport in question. With the right combination of

effective local consultation by airports, clear guidance from the CAA on airspace

change processes, expert advice from ICCAN on noise aspects, and ultimate

decision-taking by Government for strategically significant changes, the aviation

sector and local communities can have confidence that airspace changes are well

founded.

In this context, GAL has taken steps in recent years to improve the structure and

content of its engagement with local communities affected by aircraft noise, through

the establishment of an independently chaired Noise Management Board. The NMB,

now into its second year of operation, has helped to inform and influence GAL’s

approach to airspace change. The text box below sets out the NMB’s purpose and

membership.

GAL therefore agrees that Designated Airports should take responsibility for setting

noise controls (other than operating restrictions). However, notwithstanding the good

progress by the NMB to date and the greater trust thereby built up among community

groups, we note that the views of representatives of local communities around

Gatwick, strongly expressed on this point, are against the handing over of noise

controls for management by the airport, whilst appreciating the flexibility of locally

informed noise controls. GAL will seek to allay these concerns through clear

explanation of its own position with regard to Noise Preferential Routes and other

aspects of airspace policy which are currently determined by Government with

respect to Gatwick as a Designated Airport.

4. Ongoing Noise Management

b. Views on the proposal that responsibility for noise controls (other than noise-related

operating restrictions) at the designated airports should be as set out in Chapter 7 on

Ongoing Noise Management.

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GAL response:

GAL agrees that ownership of Noise Preferential Routes should be transferred to

each of the designated airports.

GAL already publishes on its website a range of information on aircraft tracks and

performance, to enable affected communities to monitor flight activity attributable to

Gatwick Airport. GAL’s flight performance team publishes quarterly and annual Flight

Performance Reports, which summarises evidence on airport operations, runway

usage, track keeping, continuous descent operations performance, community noise

monitoring and complaints. However, we are always seeking to improve the

information we share and would welcome the exchange of best practice across the

industry.

Gatwick Noise Management Board

Purpose of the NMB

The core role of the NMB is to develop, agree, oversee and maintain a co-ordinated noise

management vision and subsequent strategies for Gatwick on behalf of stakeholder

organisations. The main aim of this work is to reduce the impact of noise on the local

community.

Membership

The Noise Management Board is made up of a wide range of industry experts and

stakeholders. There are 13 seats on the Board, some of which are shared between a

voting member and an alternate (back-up) member who have one vote and actively attend

alternate meetings. The NMB has representation from the following members:

Gatwick Airport Ltd (GAL)

Civil Aviation Authority

DfT

NATS

Air Navigation Solutions (providers of air traffic services in control tower at

Gatwick)

Airlines

Chair of GATCOM (Gatwick Airport Consultative Committee)

East Sussex and West Sussex County Councils

Surrey and Kent County Councils

8 community noise groups

The Board is chaired by Bo Redeborn, a senior air traffic control expert who is

independent of GAL.

4. Ongoing Noise Management

c. Views on the proposal that designated airports should publish details of aircraft tracks

and performance. Please include any comments on the kind of information to be

published and any evidence on the costs or benefits.

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GAL’s flight performance reporting is overseen by the Noise and Track Monitoring

Advisory Group (NATMAG), a sub-group of the statutory consultative committee

GATCOM. NATMAG brings together representatives from the DfT, ANS, NATS,

airlines, Gatwick Airport and local authorities. The group discusses a wide range of

noise and track-keeping issues and monitors track-keeping performance, night

engine testing and ground noise complaints.

GAL provides additional information to local communities on a timely basis via its

airspace blogs, published on its website, which detail developments affecting

particular routes as well as other matters of interest.

GAL accepts specific complaints from individuals affected by aircraft noise, and has

implemented a dedicated web-based noise complaint tool (Caspar), in addition to

receiving complaints by post.

GAL response:

There is to an extent a natural alignment between the commercial incentives of the

aviation industry to improve the fuel efficiency of each flight and the goal of

minimising aircraft noise, as noise is one form of wasted energy. For example,

measures such as continuous descent operations help both to improve flight

efficiency and to reduce noise impacts on the ground.

The demand for aviation in the UK is forecast to grow significantly in the coming

decades. As highlighted in the Airspace Policy Framework consultation, without

modernisation of the UK airspace, this growth will be restricted by rapid increases in

operational delays. Therefore, to achieve growth, the aviation sector must work

closely with the CAA, Government, and affected local communities to design and

implement required airspace changes. The Government, CAA and ICCAN (once

operational) will ensure that the aviation industry is incentivised to adopt current best

practice in noise management, by setting the standards for evidence and analysis on

noise impacts, and by defining the process by which options are appraised and

affected communities consulted. Only by meeting these standards on options

appraisal and consultation will airports be in a position to secure the airspace

changes necessary for their respective growth ambitions.

As well as setting appropriately exacting standards for the aviation sector to meet in

terms of evidence, analysis and consultation on aircraft noise, Government should

work consistently over time to provide strategic leadership for maintaining and

implementing the national policy framework and plan for airspace development. This

plan should provide the wider context for consideration of individual airspace

changes, and would help the aviation sector to press forward with complex and

costly-to-implement changes, in the confidence that these would be assessed by

4. Ongoing Noise Management

d. Views on whether industry is sufficiently incentivised to adopt current best practice in

noise management, taking into account Chapter 7 on Ongoing Noise Management,

and the role of the Independent Commission on Civil Aviation Noise in driving up

standards in noise management across the aviation sector.

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CAA and ultimately Government in light of an agreed national vision for UK airspace.

Without such leadership, there remains a serious risk that individual changes which

have a strong national strategic component could be held back by more localised

assessments of costs and benefits. Such a risk could deter and slow down the pace

of airspace changes brought forward at each airport.

GAL response:

Overall:

In line with GAL’s earlier comments on the Airspace Policy consultation, GAL

considers that the draft Air Navigation Guidance could helpfully be made more

specific and detailed in order to provide a clearer picture to all those engaged in

airspace change about the processes to be followed. This would also help inform

expectations of all those engaged in consultation with airports around noise and

airspace management. The guidance should also clarify how any differences of view

between airports and their local communities about the nature or category of

changes proposed can be resolved effectively by the CAA, prior to consultation

and/or engagement with local communities on the substance of the changes

themselves.

Chapter 1

The Government’s environmental objectives

The policy objective ‘to limit and, where possible, reduce the number of people in the

UK significantly affected by aircraft noise’ focuses only on the absolute numbers of

those affected - not on the distributional impacts across different locations, nor on the

balance between those newly affected and those benefiting from noise reductions

and/or temporary respite. These dimensions of quantifying the extent of noise impact

are very relevant to assessing the impacts of airspace change, and the

Government’s environmental aviation noise objectives should recognise these extra

dimensions of noise impact.

In particular, the objective as drafted would result in a sole focus on the net number

of people affected by aircraft noise arising from a specific airspace change,

overlooking the potentially much larger numbers of people who may be newly

exposed to noise, offset by others who may be relieved of noise impacts. Netting off

implies a comparable noise tolerance of each group, which may not in practice be a

reasonable assumption.

Roles and responsibilities

The roles and responsibilities are set out clearly in the diagram on page 9.

Terminology

There seemed little need for the content on page 11 which could have been set out in

a short footnote or in the glossary

5. Noise Management Guidance

Comments on the draft Air Navigation Guidance: guidance on airspace & noise

management and environmental objectives published alongside this consultation.

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Chapter 2

Tier 1, 2 and 3 definitions

The guidance should go further in clarifying definitions of each tier, including

illustrative examples perhaps highlighting how specific historic changes would have

been categorised to each tier. It should also specify how contested categorisations

would be assessed and settled, and the process of appeal for airports, community

groups and other stakeholders.

Tier 1 changes would require an Aeronautical Information Publication (AIP) update to

implement the proposed change. Conversely, however, not all AIPs would represent

a Tier 1 airspace change.

Tier 2 in particular needs to be more clearly specified, with regard to the magnitude

of the changes and the materiality of their impacts, to avoid the risk that many minor

changes could be inadvertently caught up and subject to the full consultation

process. The lower boundary of Tier 2 and upper boundary of Tier 3 in particular

should be clarified as far as possible, via guidance in advance. Recognising that

guidance will not always be definitive, and that some stakeholders will disagree with

an airport’s proposed categorisation of a specific airspace change, the CAA should

be encouraged to provide timely and clear-cut advice in advance on Tier 2/Tier 3

categorisation, to enable efficient processes of consultation or engagement

thereafter.

For Tier 3, the guidance itself should address the question of how to treat a series of

linked changes planned over a period of time, each of which on its own would be

categorised as Tier 3 but which together could be viewed as a Tier 2 change: when

and how should such a series of changes be deemed to be Tier 2, and therefore how

should consultation be conducted? There should also be clear signposting that Tier 3

is an information exchange process of engagement rather than a decision-making

process. The CAA could also helpfully set out good practice on informing

communities about a proposed airspace change.

Replication of flightpaths with new PBN-based procedures

The guidance could go further in spelling out the factors to be assessed when

considering the introduction of new PBN-based procedures intended to replicate

existing conventional procedures, and how these might be weighed to reach an

overall assessment.

Chapter 3

Altitude based priorities

Paragraph 3.3 bullet point 1 (4,000ft and below) refers to considering noise above

51dB Leq 16 hr and 45dB Lnight, but bullet 3 (4,000 feet to 7,000 feet) refers to only

51dB Leq 16 hr. This should also refer to 45dB LNight.

Considering the noise implications of proposed airspace changes

The guidance might helpfully justify the proposed noise impact levels, by reference to

previous decisions in the aviation sector and more recent decisions applying to other

transport sectors.

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On a point of accuracy, paragraph 3.10 notes that ‘below 4,000ft there is a strong

likelihood that aircraft noise could create levels of noise exposure above the LOAELs

identified above’. This will depend entirely on how many aircraft are flying and their

average noise footprint, and may thus not be true of smaller airports which handle

smaller numbers of quieter aircraft. This guidance should be applicable to airports

across the UK, so this statement may need to be modified.

Assessing impacts across communities, at paragraph 3.13 the guidance states: ‘As

well as overall impacts, the CAA should also verify that sponsors have adequately

taken into account how communities will be differently affected as a result of change,

including the number of people in different noise contours and the change in noise

exposure different communities will experience’. This is helpful guidance as it should

encourage a full analysis of impacts across communities, rather than simply netting-

off of newly affected and newly-removed. It is noted that the WebTAG appraisal tool

allows for monetisation of either the net effects or the positive and negative effects

separately.

For communities further away from airports, the guidance introduces, at paragraph

3.13, the use of N65 Day and N60 night noise metrics, but fails to state to what levels

(i.e. numbers above) they should be reported. This is essential if the guidance is to

be used consistently.

Single and multiple routes

The guidance and supporting options appraisal tools should encourage and enable

an unbiased assessment of single versus multiple routes. However, GAL would be

concerned if the appraisal tool WebTAG was likely systematically to favour

concentration over dispersal. This would run counter to many views expressed by our

local communities and would reduce the ability to deliver solutions tailored to local

circumstances.

In weighing up single versus multiple routes, airspace change sponsors should be

encouraged to consider the metrics by which the implementation of options would be

judged. It should be recognised that no route design will achieve 100% conformance

in practice, and that different routes may have different likelihoods of conformance.

The success criteria for each route design should be clarified at the options appraisal

stage.

The guidance, at paragraph 3.18, advises ‘preferred options should normally be

based on those which result in fewer people significantly affected as measured by

the approach outlined above.’ However, the term ‘significantly affected’ is not

mentioned or defined in the preceding section: this gap in the guidance should be

remedied. In completing this aspect of the guidance, the Government should ensure

that it remains consistent with its wider noise policy, by basing options appraisal on

populations above SOAEL (and not LOEAL), as it is those above SOAEL that are the

focus of Government policy to reduce the number of people ‘significantly affected’.

The Government should provide guidance on SOAEL metrics to a comparable level

of specificity as used for other transport sector projects.

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Paragraph 3.19 refers to considering numbers of overflights at lower noise levels.

These lower noise levels should be above the LOAELs previously defined.

Taking account of local circumstances

At paragraph 3.28, the guidance states that: ‘Sponsors should demonstrate that they

have taken on board the views of communities where possible when developing

options’. As drafted, this places a very high premium on communities agreeing a

single noise-preferential route and then on sponsors adopting this solution. This

would place noise as the dominant factor in what should be a more multi-dimensional

options appraisal, considering a number of other factors. It also seems to imply that

community agreement should be secured for the preferred option. This may not

always be feasible, not least because different communities take different views on

proposed airspace changes.

Assessing the noise impacts of airspace changes

At paragraph 3.30, the guidance states that: ‘the CAA should ensure that any

recommendations from ICCAN on appropriate metrics and views from communities

are taken into account when noise impacts are being assessed’. This could be

viewed as setting up a mandatory hurdle for the CAA to cross in its airspace change

process and places ICCAN, by association, as a quasi-statutory body. In so doing,

the guidance creates the risk that the pace of airspace change could in practice be

limited by the rate of output which ICCAN is able to achieve. The guidance could

clarify that specific advice from ICCAN on each and every proposed airspace change

is not a necessary pre-requisite for the CAA to proceed with its own decision-making

process.

The role of the Independent Commission on Civil Aviation Noise (ICCAN)

At paragraph 3.33, the guidance states that: ‘[ICCAN] might also usefully produce

research and publish best practice guidance on compensation’. GAL would caution

against ICCAN straying too far into this territory. Each airport’s noise compensation

scheme has been designed to meet the specific needs of the local affected

communities. Such schemes are generally stable over time, and set expectations for

major household investments such as home purchase. ICCAN involvement may

inadvertently precipitate a UK-wide ‘race to the top’ inflation in compensation terms.

At paragraph 3.35, the guidance states that: ‘CAA should ensure that a sponsor can

demonstrate ICCAN’s best practice has been considered in arriving at design

principles’. As drafted, the guidance is unclear as to whether such design principles

should be agreed with community groups, whether they should be the same for all

Gatwick airspace changes, what the duration of such principles should be, whether

they should be refreshed for each airspace change process, and how any conflicts

between Gatwick’s design principles and those of other airports should be resolved.

Management of aircraft noise

Airspace design

At paragraph 4.9, the guidance states that: ‘The Government expects the CAA to

encourage the use of new and innovative approaches to managing aviation noise

through airspace design such as the provision of respite to communities already

significantly affected by aircraft noise.’ Providing respite may not be possible without

moving noise to affect other communities significantly, which would contravene the

overall policy aim of reducing the numbers of people significantly affected. As noted

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above, netting off newly (significantly) affected populations with newly (significantly)

removed populations to demonstrate compliance with this policy may not be justified,

given potential differences in noise tolerance between different communities which

has developed over time. It would be helpful if this part of the guidance was defined

in this context.

National Parks & Areas of Outstanding Natural Beauty (AONBs)

At paragraph 4.15, the guidance affords special status to these areas, and the CAA

is to encourage, where it is practical, to avoid over-flight of National Parks or AONBs

below 7,000 feet. There are two further developments of this guidance which should

be considered. First, in the National Planning Policy Framework (NPPF) paragraph

123 notes:

“Planning policies and decisions should aim to…:

• …

• identify and protect areas of tranquillity which have remained relatively

undisturbed by noise and are prized for their recreational and amenity value for this

reason.”

The NPPF notes the importance of protecting tranquil areas referring to their amenity

value, not just that they are quiet. Therefore the amenity value of the particular part

of a particular National Park or AONB overflown should be taken into account, for

example the extent to which is used. Second, there are other open spaces, notably

the Royal Parks in London, which provide a similarly important amenity to those living

in or visiting the city – preserving green space away from surface transport and other

urban development. The Government should extend its guidance on National Parks

and AONBs to encompass also Royal Parks.

Noise Sensitive Buildings

Paragraph 4.19 mentions Noise Sensitive Buildings. The list of building types is not

complete - for example schools are omitted.