Forest Hill Society Response to Airspace Consultation

In December 2021 London City Airport presented to their Consultative Committee a set of completely new route options for their arrivals and departures over London. They shared detailed mapping of five potential alternatives for arrivals and departures but made it very clear that these were outline only. Before taking these to the next stage of the regulated process they asked Committee attendees to comment on these initial ideas.

In early March the airport gave us an early indication of the major points they are taking from the "27 Committee" and stakeholder responses received. They said that stakeholders favoured:-
-    The sharing of routes to provide respite
-    Planes to be kept higher for longer
-    A reduction in fuel and climate emissions
-    A separation of routes so that, wherever possible, the same area was not overflown by planes from different airports
-    Collaboration with other airports.

It will remain to be seen how the airport takes this feedback and translates it into new concentrated flight paths that will give us fair distribution of paths and associated noise from London City and Heathrow, two airports only 22 miles apart with runways pointing directly towards each other. We are particularly concerned that London City is proceeding to plan its own routes with no reference to Heathrow, when it seems obvious that they must develop plans together from the earliest stages.

The interlinking of Heathrow and London City low altitude routes over us is shown in the map below:-

Heathrow westerly arrivals cross the London City concentrated flight path at multiple points over SE London, from Dulwich/Brixton in the west and at least as far as Eltham in the east. Source flightradar24

 

We have published our full response to the airport here in the interests of sharing locally and in full the general concerns that we have. We have shared this with Environmental Health management at Lewisham and with MPs Ellie Reeves and Janet Daby. To summarise, we covered the following:-

1.    We welcomed that the airport seems to making some effort to understand the issues mentioned above. We expressed a major concern though, that designs seem to be being drafted independently of Heathrow, in the process compressing London City paths into a vertical and geographical space that reduces options for London City departure and arrivals routes and also climbing and descent angles. We believe that a publicly transparent dialogue at an early stage with Heathrow on the joint problems to be solved will enhance public confidence in the processes.

2.    We expressed a concern that  the new concentrated paths from City and Heathrow will end up crossing each other, with
-    some communities being under both a London City takeoff and arrivals flightpath
-    some communities being under two different London City flight paths in different wind conditions,
-    the same communities being under one or more  London City and Heathrow arrivals paths.

3.    We asked that the unpopular single concentrated arrivals route low over SE London introduced in 2016 be addressed, potentially introducing alternative or ‘respite’ routes. Over Lewisham, a respite route might look like that shown below, to spread or alternate the arriving air traffic.

 

Possible easterly arrivals routes over SE London. Source LCACC meeting Dec 2021.

 

4.     4.    We pushed hard for a steeper approach route over SE London using a Continuous Descent Approach (CDA). Currently arrivals are in almost level low altitude flight from Dartford and then west across SE London. Air Navigation Guidance says CDA is best practice for all airports, yet London City does not practice it.
5.    Air Navigation Guidance also requires that the height of hills is taken into account. With our highest point near Horniman Gardens at 345 ft, City planes are sometimes only 1255 ft above residents in the Tewkesbury Estate. London City does not yet seem to be taking our hilly terrain into account in their route planning.
6.    Finally, both Heathrow and London City have adopted similar route design principles, after consulting with overflown resident groups from across the city.

Heathrow: - ‘avoid overflying the same communities with multiple routes including those to/from other airports’ (draft Nov 2021)

London City: - ‘avoid overflying communities with multiple routes, including from other airports.’ (approved Design Principle)

We asked for early and public evidence that the two Airports are collaborating with each other on three-dimensional airspace design over London, and that they begin with a shared understanding of the impact not only of their individual but also their combined operations in different wind directions.

Finally, we said that only a complex overlay and creation of a very clear explanation of the joint noise and environmental impact on the ground of proposed plans will enable meaningful respite route planning and enable those on the ground - Local Authorities and public - to respond to flight path consultations in an informed way.

It looks as though public consultations will begin in 2023. But meanwhile we continue to try and influence the two airports and encourage them to be transparent in public engagement and consultation while they make plans and submit them to the Civil Aviation Authority.

Flight Paths over Forest Hill

By Tim Walker

At the recent Forest Hill Society AGM the Mayor, Damien Egan, announced that the Council would henceforth engage much more proactively with Airports on the issues of flight paths and low aircraft over Lewisham. This is excellent news, and is something we have been campaigning towards for several years.

Where individual aircraft are flying to over Forest Hill isn’t always immediately apparent - London City and Heathrow Airports both overfly us at different times and in different wind conditions. It has been quiet during the pandemic but this summer noise returned and was all the more noticeable. The worst is in light east wind conditions when arrivals from both airports are overhead.

Two planes turn west towards Heathrow over SE London (at 4000ft) while another crosses their paths turning east towards London City (at 1700ft)

The Government seems intent on enabling airport and aviation expansion, and is putting its ‘Jet Zero’ policy forward to justify how climate change and aviation expansion can reasonably co-exist. A noise, emissions and climate emergency debate rages - a recent comment on that, from climate action charity Possible, said:-

‘Although the government’s recognition of the need to tackle aviation emissions is welcome, its scenarios to achieve net zero aviation by 2050 are fatally flawed. It relies on undeveloped, extremely expensive or unworkable technologies....’

At the same time Government has just abolished the Independent Commission on Civil Aviation Noise, which met with the Forest Hill Society several times in their brief 3 year existence as we worked to get our local double overflight problems onto the aviation policy agenda. And Heathrow night flights are to continue, exactly as they are, for at least three more years, giving us those late night and very early morning wakeups in SE London. John Doherty and I have been working with all this for some time now while representing the Forest Hill Society; this seems like a setback to us, and feels like very little progress at all.

But maybe these national issues are not for our local Society anyway. What can we actually influence? First, we’ve invested time meeting and putting our information and arguments to GLA Assembly Members, our MP’s and Councillors. Recently we have been delighted to see both Ellie Reeves MP and Janet Daby (MP Lewisham East who we met in a June Zoom call) ask questions in Parliament about flight paths, citing the low flying and unreasonable aviation noise experiences of Lewisham people.

For a few years now, I have been attending the London City Airport Consultative Committee, to keep Forest Hill and Lewisham on their agenda. I am pleased that Lewisham Cabinet Member Sophie McGeevor has also attended and has made it her business to strongly represent Lewisham’s interests there. Meanwhile I have also been attending the Heathrow Community Noise Forum, always trying to make sure that our very real issues with their flight paths over SE London are not drowned out by equally compelling issues from those living nearer the airport.

The next big issues that we can have any influence on in Lewisham are going to be the redesign of both London City and Heathrow flight paths. We need to make sure they coordinate their work, when there is little evidence of that in the past. Otherwise, we may end up with something similar to today or worse. I was invited to a workshop on flight path design principles at Heathrow in September. City Airport is expected to announce their development plans in December. We will be arguing for an end to double overflight from the two airports, and an end to the single low level concentrated arrivals path from London City, with introduction of alternative and rotating routes, so the same people don’t get the noise all the time.

London City Airport – current low altitude concentrated flight path over Lewisham

These are big issues not just for Forest Hill but for large parts of Lewisham and SE London. That is why we asked Lewisham to make preparations on behalf of all of us as these important flight path details are hammered out and consulted upon. Following recommendations from the Forest Hill Society the Mayor has confirmed that Lewisham Council will take up a place at the London City Airport Consultative Committee and the Heathrow Community Noise Forum. This will give officers regular up to date information on what is happening. We understand that the Council also plans to work closely with other SE London Councils, the No Third Runway Coalition and the Aviation Environment Federation, both non political bodies that will provide Councillors and Officers with high quality information to inform the Borough’s policy and timely responses to consultations and help them to influence flight path planning.

These are not big or costly things to do in themselves, but will help Lewisham to step up. We are delighted that Lewisham has responded by deciding to embed this work into the environmental health team, so that they can be best prepared at all times to contribute wisely on aviation issues where they affect Lewisham residents.

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