Transport CommitteeWritten evidence from the Chiltern Countryside Group (AS 82)

The Chiltern Countryside Group (CCG) welcomes this opportunity to contribute to the Transport Select Committee’s Inquiry into Government strategy for aviation and aviation capacity in the UK.

Within this paper, we outline the Group’s considered views on these important issues and request that the Committee take these fully into account in preparing their report from this Inquiry.

The Group believes that whilst aviation remains firmly part of people’s lives in the 21st century, the world’s population holds collective responsibility for reducing their need to travel and that when we do so, we should aim to choose the most environmentally-sustainable transport mode available. With this qualification, therefore, we respond to the questions posed by the Committee’s Inquiry.

The CCG’s mission statement is “Preserving the peace of the Chilterns”. However, the operation, impact and benefits of aviation are not restricted to this area of SE England. Indeed the questions raised by the Committee consider the whole of the UK. We, therefore, respond to this Inquiry from a national perspective which has been informed by our experience of aviation in the Chilterns.

Since its foundation in 2008, the CCG has made several submissions to Government, the Department of Transport, the Civil Aviation Authority and the National Air Traffic Service’s different aviation Inquiries and Consultations. The Group has also made submissions to the most recent Noise Action Plan Consultations conducted by Heathrow Airport and London Luton Airport. We find that much of the contents of these submissions remains relevant to present strategy and challenges; therefore, we have drawn upon these earlier papers in the preparation of this document. Where relevant, we have given original source references.

Acknowledgements

The CCG Steering Group wish to give particular appreciation to their colleagues in the Steering Group, Capt. Gwyn Williams, Dr. Marilyn Fletcher and Prof. Colin Waters for their invaluable professional knowledge and expert contributions in the compilation of this paper and its Appendices.

Executive Summary

1. The need for a National Transport Strategy

Since CCG was founded in 2008, the Group has been calling on Government for a properly researched and designed overall national Transport Strategy, so that major proposals as outlined below are appropriately integrated within a wider strategy which aims to (a) meet the UK’s genuine needs and (b) give an optimum environmental balance. Only then can Government ensure that available funds are deployed in the wisest, most efficient and effective manner. We remain doubtful that any programme for any transport mode can achieve its optimum aims if planned and delivered in isolation.

The CCG share the Transport Select Committee’s concerns expressed in that Committee’s Report following their May 2011 Inquiry into High Speed Rail that, despite their earlier recommendations for a proper Transport Strategy on a national level, this has yet to be achieved by the Department for Transport (DfT). The CCG finds this unacceptable for public accountability and use of taxpayers’ money, as it fails to provide an adequate base or structure on which to base any decisions on policy or the future of major projects such as airport expansion or the current proposals for the High Speed 2 railway.

An appropriate balance must be achieved between the economic, social and environmental costs and benefits of aviation. Within this balance, unconstrained growth of aviation is not an option. Nor is it likely to be required in the future with increased take-up of electronic communications, pressure on disposable incomes, increased public awareness of environmental implications and operational costs, including fuel. The priority should be to make UK’s airports better, but not bigger, for all, not just for users.

2. Reducing Environmental Impact

Aviation plays a key role in helping deliver Government’s carbon reduction goals. However, Government should not abdicate its own responsibilities towards supporting and facilitating the contribution which the aviation industry is challenged to make.

Noise pollution reduction should be a key element of Government and aviation’s environmental targets.

Improved operational procedures and new technology can and should facilitate better use of existing capacity, reduce or eliminate stacking and make a positive contribution to minimising local environmental impacts, particularly noise over densely populated and sensitive areas.

The CCG welcomes the Government’s recognition that poor air quality has a negative effect upon individual health & is taking steps to reduce aviation’s impact. However, we remain concerned that achieving compliance with legally binding European standards on pollutants is yet to happen.

Should the Government’s proposed new high-speed railway line (HS2) go ahead and the predicted small modal shift does occur from domestic flights to high speed rail, the aviation industry must take an environmentally responsible position by not re-allocating any vacated short-haul flight slots. If it does re-allocate these slots, particularly to long-haul, then any environmental benefits from HS2 will be negated.

3. Valuing the Importance of Areas of Outstanding Natural Beauty and National Parks and Reducing Aviation’s Impact

Relatively tranquil landscapes such as Areas of Outstanding Natural Beauty (AONB) and National Parks, together with other locally sensitive “green spaces”, are scarce and important resources which should be protected now and in the future. Impact and intrusion of aviation noise can be significant but is not adequately addressed by either Government or aviation policies. In its recent Scoping Document on Developing a Sustainable Framework for UK Aviation, the Department for Transport continued to ignore the important issue of aviation impact on AONBs and National Parks. Impact and intrusion of aviation noise can be significant reducing the environmental and economic value of such land.

Government should be in on-going dialogue on national and regional transport planning infrastructure with relevant bodies, including those such as AONB Conservation Boards, so that “joined-up” measures are put in place to reduce adverse environmental impact on sensitive areas from all modes of transport.

4. Capacity and Connectivity

Proper analysis and impartial modelling based on scientifically proven methodology needs to be carried out to underpin any concept of lack of aviation capacity in not just the SE, but the whole of the UK. Only then can accurate assessment be made of where needs are and from that, what constraints apply and how these might be overcome.

International aviation capacity and connectivity needs to be considered in a more environmentally-sustainable way, not just simply from a UK perspective, but from a world view.

International aviation connectivity is important but it should be driven by need and demand, based upon accurate and scientifically substantiated modelling evidence.

Some elements of the business community comment on lack of international connectivity. The CCG suggests this more accurately refers to lack of regional international connectivity and frustration with the time-consuming and costly need to travel to the SE to travel overseas.

It is essential that “removing barriers in sectors where there are clear opportunities for growth and where the Government can make a difference” (ref. DfT) is not at the expense or disadvantage of the well-being of the UK’s residents, including existing communities, or of the natural and irreplaceable resources of our nation, such as protected or locally strategic landscapes.

Maximising capacity at any airport in the UK must be balanced against the environmental impact, particularly that of noise, of its operations upon the communities and landscapes under its flight paths. It should be recognised that in practice such impact can still be experienced over 20 miles distant.

Regional connectivity throughout the UK and internationally by air is a key issue for overall transport strategy. This does not necessarily need to be London or SE-centred.

The CCG believes that a different non-London or South East centred approach could make a significant contribution. This would not move the noise or emissions impact elsewhere, but provide opportunities to reduce individual carbon footprints, enabling travellers to fly to/from an airport closer to their journey’s destination/origin. Transporting people around the UK to London airports (or indeed other airports) for them then to fly overseas increases their carbon footprint, time and use of resources.

5. Aviation and Noise Pollution on Communities

The CCG does not accept that when technological advances, modern equipment, quieter aircraft and efficient operational procedures including airspace management are all brought together intelligently, they cannot, in the 21st century, simultaneously fulfil the twin aims of local and global environmental impact reduction. We do not accept that one has necessarily to be at the expense of the other.

Night noise is a significant issue which is not as yet addressed nationally or adequately by Government or the aviation industry.

Government does recognise night noise from aviation has major impact on overflown residents. However, this recognition is too narrow as controls are not national and vary from the strict regulations in place for Heathrow, Gatwick and Stansted with full 24/7 operations permitted at others. London Luton is the only London airport which is not regulated on night flights. This is an unacceptable anomaly.

The CCG believes the number of people affected by significant levels of aircraft noise has increased over the past 30 years. The aviation industry has grown during that time, as has the UK’s population, particularly around cities, near to or where most of the UK’s airports are sited.

The concept of an airport noise envelope may lead to airport growth if, due to improved technology or operational procedures, noise output of individual aircraft or the overall airport performance fell. This would not allow for a reduction in airport noise but rather provide for opportunity to expand.

6. Changes to Operational Procedures can make a Real and Positive Difference

Airspace management nationally and internationally should be a key component of Government aviation strategy.

Technological changes are not local, regional or even national considerations. Aviation is a global concern and technological changes need agreement and support at this level.

Changes to operational procedures on take-off and arrival, together with removal or repositioning of restrictive stacking holds, have significant potential to improve the noise environment.

Improved operational procedures and new technology should contribute to better use of existing capacity, but equally of importance, should make a positive contribution to reduction of local environmental impacts, particularly over densely populated areas and those which are sensitive, such as Areas of Outstanding Natural Beauty and National Parks.

Question 1: What should be the objectives of Government policy on aviation?

1. The CCG is challenged to perceive a definitive objective in current Government thinking on aviation. The Group is unable to discern a clear policy which is based upon realistic and sustainable objectives which the nation can afford and which are truly in the whole nation’s best interests.

2. To achieve realistic and sustainable objectives, an appropriate balance must be set and implemented between the socio-economic and environmental costs and benefits of aviation. Within this balance, unconstrained growth of aviation is not an option. Nor is it likely to be required in the future with increased take-up of electronic communications, pressure on disposable incomes, increased public awareness of environmental implications and operational costs, including fuel. The priority should be to make UK’s airports better, but not bigger, for all, not just for users.

3. A key Government objective should be to facilitate ways of making the UK’s airports better for all: users; surrounding and overflown communities; more efficient use of airspace with integrated management and communication internationally; reduction in energy demand from aviation and thus environmental impact/cost; policies, schemes and targets for reducing air, visual and aural pollution on communities and sensitive areas.

4. Technological changes are not simply local, regional or even national considerations. Aviation is a global concern and technological changes need agreement and support at this level.

5. Aviation plays a key role in helping deliver Government’s carbon reduction goals. However, Government should not abdicate its own responsibilities towards supporting and facilitating the contribution which the aviation industry is challenged to make.

6. This responsibility should not be restricted to carbon pollution, but extended to reducing aural pollution from aviation. Society has become noisier and busier; rural landscapes are becoming more valuable places where people can experience essential peaceful respite and relaxation. Noise pollution reduction should be a key element of Government and aviation’s strategy and environmental targets.

7. Relatively tranquil landscapes such as Areas of Outstanding Natural Beauty (AONB) and National Parks, together with other locally sensitive “green spaces”, are scarce and important resources which should be protected now and in the future. Impact and intrusion of aviation noise can be significant but is not adequately addressed by either Government or aviation policies. The Government continues to ignore the important issue of aviation impact on AONBs and National Parks. Impact and intrusion of aviation noise can be significant with detrimental effect upon communities, visitors and in reducing the environmental and economic value of such land. Tranquillity is a finite resource in our small island.

8. The CCG’s considered view is that Government and the aviation industry should work in partnership to identify, address and facilitate reduction of impacts on local environments by aviation, without compromising safety. This is of prime importance in areas such as the Chilterns which are impacted by flights from more than 1 airport.

9. International and regional connectivity throughout the UK by air is a key issue for overall transport strategy. This does not need to be London or SE-centred.

(b) How important is international aviation connectivity to the UK aviation industry?
(e) Where does aviation fit in with an overall transport strategy?

1. The focus of question (b) should not be on the importance of such international connectivity to the UK aviation industry but to the UK, its wider business community and residents.

2. Government needs to develop a rigorously researched and planned overall transport strategy of which aviation is part. International aviation connectivity can then be considered more effectively and in a more environmentally-sustainable way not just simply from a UK perspective but from a world view.

3. International aviation connectivity is important but it should be driven by need and demand, based upon accurate and scientifically substantiated modelling evidence. A key issue which CCG considers later in this paper is the weighting of connectivity towards the SE.

4. If the UK’s aviation industry becomes largely dependent upon international connectivity, then it becomes even more imperative that a national approach is taken. Government and airlines need to move away from a SE-based approach and think more widely about the passenger base.

5. Transferring passengers using a UK hub do not mind where this is in the UK, providing the flight and transfer time, cost and actual transfer experience is positive. It is the direct, easiest and most cost-effective connection which is the motivator for the passenger and the shortest distance flown which should be the motivator for the air operator. For eg, the USA has many airports where it is possible to transfer onto national or international on-going flights; the UK should be evaluating more broadly and not perceive only one congested airport in the SE as the only option.

6. Relatively tranquil landscapes such as the Chilterns Area of Outstanding Natural Beauty (AONB) are scarce and important resources which should be protected. Intrusion of aviation noise onto relatively tranquil areas can be significant but is not adequately addressed by Government or the Civil Aviation Authority (CAA). This issue is discussed further later.

7. It is a complete nonsense that as one form of transport works to reduce its noise impact upon a community, another different, but noise intrusive, mode is introduced.

8. We give an example of how this anomaly currently manifests: In a consultation (January 2012) on their Environmental Programme, “Improving Aviation’s Sustainability Now and for the Future”, the Civil Aviation Authority (CAA) sought to reduce aviation’s environmental impact, recognising the value of our AONBs and National Parks. As the TSC has identified, a notional monetary value should be placed on natural capital of this kind. Simultaneously, in another arm of the DfT, plans are under way for a new railway route (HS2) which will adversely and irreversibly impact on the Chilterns AONB, thus increasing the environmental damage and long-term pollution.

9. Therefore, the Government should be in on-going dialogue on national and regional transport planning infrastructure with relevant bodies, including those such as AONB Conservation Boards, so that “joined-up” measures are put in place to reduce adverse environmental impact on sensitive areas from all modes of transport.

10. Airspace management nationally and internationally should be a key component of Government aviation strategy. This is discussed further in Q2.

Question 2: How to make best use of existing airport capacity?
2(a), (b)

1. It is essential that “removing barriers in sectors where there are clear opportunities for growth and where the Government can make a difference” (ref. DfT) is not at the expense or disadvantage of the well-being of the UK’s residents, including existing communities, or of the natural and irreplaceable resources of our nation, such as protected or locally strategic landscapes.

2. Improved operational procedures and new technology should contribute to better use of existing capacity, but equally of importance, should make a positive contribution to reduction of local environmental impacts, particularly over densely populated areas and those which are sensitive, such as Areas of Outstanding Natural Beauty and National Parks.

3. The aviation industry’s future strategic policy has a vital role in the nation’s infrastructure development. The Government’s National Planning Policy Framework (NPPF) appears to indicate a presumption in favour of sustainable development, based on the predicate that expansion equals better and greater progress nationally. The CCG questions whether economic growth and development are mutually exclusive; investing finite resources to improve what is already present may, in these uncertain times, be the wisest and more widely advantageous option, both for the short and longer-term.

4. If London and/or the South-East are not the ultimate destination of long-haul travellers into the three main SE airports (ie Heathrow, Gatwick, Stansted), why do we need to encourage/facilitate flights into this already congested airspace? A more creative—and potentially environmentally advantageous—approach could be investigation into a shift towards regional long-haul flights so that both leisure and business travellers travel the shortest distance between their destinations.

5. Heathrow and Gatwick Airports’ trans-Atlantic long-haul flights overfly a considerable portion of the UK’s landmass at the end/start of their journeys, using fuel & adding to the burden of pollution in the air and on overflown land. Many of their passengers may not have London or the SE as their ultimate destination but they have no option but to fly in/out of a SE airport.

6. The CCG believes that a different non-London or South East centred approach could make a significant contribution. This would not move the noise or emissions impact elsewhere, but provide opportunities to reduce individual carbon footprints, enabling travellers to fly from an airport closer to their journey’s origin. Transporting people around the UK to London airports (or indeed other airports) for them then to fly overseas increases their carbon footprint, time and use of resources.

7. Regional connectivity by air throughout the UK is a key issue for overall transport strategy. Government identifies that “UK’s connectivity needs will change...in response to global economic and social trends...wants to ensure ... those ... needs can be met in an environmentally responsible way”. (ref. DfT Consultation Developing a Sustainable Framework for UK Aviation: Scoping Document 2011).

8. The Sustainability Commission (2011) has recommended to Government on transport that: “policy-makers [should] prioritise reducing demand for transport; encouraging more sustainable modes of transport and improving the efficiency of existing modes of transport over increasing the capacity of the transport system”. (ref: http://www.sd-commission.org.uk/pages/fairness-in-a-car-dependent-society.htm). The Commission further states: [what is needed is] “more distributed development and local jobs rather than encouraging people to travel longer and longer distances”.

9. The CCG endorses these recommendations. Maximising capacity at any airport in the UK must be balanced against the environmental impact, particularly that of noise, of its operations upon the communities and landscapes under its flight paths. It should be recognised that in practice such impact can still be experienced over 20 miles distant.

10. The question is posed: “How to improve the passenger experience?” Passenger experience and choice is in practice restricted by the aviation industry itself. Presently, there is a financial incentive for passengers to choose flights at anti-social & night time hours. We suggest that passengers would not choose to travel at these hours unless there was the compelling reason of a cheaper seat. Until this is regulated, airlines will continue marketing in this way, ignoring the greater aural and pollutive impact of flights outside conventional daytime hours (EC. 6.00am-23.00pm).

2(c) How to improve surface access?

1. Improvement of surface access to airports should be planned and delivered within the context of an overall national transport strategy as outlined above. A more creative approach is needed than currently demonstrated where surface routes, regardless of transport mode, frequently run North-South, or for public transport, use London as an interchange, when it is not the passenger’s ultimate destination.

Question 3: What are the constraints on increasing the UK’s aviation capacity?

1. Before the subject of constraints can be properly evaluated, Government requires scientifically proven and researched evidence that aviation capacity in the UK needs to increase. A diverse range of views exists currently with a premise of the need for increased capacity being driven by the aviation industry itself, hardly an unbiased assessment.

2. Some elements of the business community comment on lack of international connectivity. The CCG suggests this more accurately refers to lack of regional international connectivity and frustration with the time-consuming and costly need to travel to the SE to travel overseas.

3. Proper analysis and impartial modelling based on scientifically proven methodology needs to be carried out to underpin any concept of lack of aviation capacity in not just the SE, but the whole of the UK. Only then can accurate assessment be made of where needs are and from that, what constraints apply and how these might be overcome.

(a) Are proposals to manage the impact of aviation on the local environment sufficient particularly in reducing the impact of noise for local residents?

1. No, they are not.

2. Aural pollution is probably the most immediate source of adverse impact on local communities and individuals; airports’ Noise Action Plans (NAP) more often concentrate on monitoring rather than pro-active response and implementation of noise-reduction measures.

3. The House of Commons Transport Select Committee’s findings from its earlier Inquiry on the Use of Airspace (ref: Findings from House of Commons Transport Select Committee in the Inquiry into the Use of Airspace (July 2009) http://www.publications.parliament.uk/pa/cm200809/cmselect/cmtran/163/163/pdf.3) reported that: “tranquillity is a key factor in sensitive areas such as National Parks and Areas of Outstanding Natural Beauty. Current guidance appears to allow unchecked increases in aviation activity over these areas. Without some level of constraint, the noise environment in these areas might degrade progressively as traffic increases.”

4. And further that: “The DfT and the CAA should examine the case for adopting maximum limits on noise levels and the number of aircraft permitted per hour over sensitive areas such as National Parks and Areas of Outstanding Natural Beauty. The DfT should fund exploratory research on evidence-based limits.” The CCG is unaware of any such measures or actions being implemented.

5. Negative impacts on a community will be manifested in diminished health for some residents and their families. This will place a burden upon health and social agencies, funded by Government. It is therefore in the Government’s own interests to ensure such negative impact is minimal; their response should facilitate, support and may indeed, drive the aviation industry’s own efforts.

6. The CCG’s considered view is that Government and the aviation industry should work in partnership to identify, address and facilitate reduction of impacts on local environments by aviation, without compromising safety. This is of prime importance in areas such as the Chilterns which are impacted by flights from more than 1 airport. For example, Government can legislate against night flights; urgently put in place operational procedures which reduce/eliminate stacking; and additionally, those which reduce noise on landing approach or take-off; restrict or prevent low level flights over sensitive areas, including AONBs and National Parks; restrict number of overflown flights during a given time period; place restrictions or legislate against flights operating at anti-social hours at all airports.

7. So far as we are aware, only three UK airports (Heathrow, Gatwick, Stansted) have noise regulations controlled by the CAA; this is a matter of some concern. As other airports seek to expand and airspace is managed differently, the CCG would expect the CAA to be pro-active in establishing a regulatory noise role over all the UK’s airports. It is unrealistic to expect individual commercial airports to make the same independent value judgements of their environmental impact upon overflown communities. The CAA is, and should be, best placed to fulfil this obligation.

8. The CCG accepts that aircraft generally have become mostly quieter as assessed by manufacturers and operators, but this does not always translate into a quieter experience for those being overflown. More work is needed.

9. Without any other change, greater uptake of the quietest aircraft should reduce local noise on take-off/landing including at approach. Operational procedures should reduce this further and fuel saved will not only improve air quality locally, but should contribute to overall global improvement.

10. Intelligent planning of strategic air space around airports so that air traffic controllers (ATC) can, and do, implement the best environmental balance for both aircraft and overflown community should be a priority for both Government and the aviation industry.

11. Certainly the experience of residents in the Chilterns is that they are impacted more often and by more noise in recent years from Heathrow operations than in the past. In the 1970s we would estimate that very few residents in the Chilterns even saw a Heathrow aircraft, let alone heard one. Now it is a daily experience with frequent heavily laden, low-flying aircraft flying directly over the hilly terrain and peaceful market towns of the Chiltern Hills. Stacking presents an additional problem over the Chilterns and as flights have increased, so has the need for stacking. There is no cause here for complacency—quite simply, the expansion of Heathrow has had a truly negative impact on the Chilterns.

12. Additionally, this pollution has been increased hugely by the expansion of operations at LLA which compound the complexity and challenge of managing this already congested airspace safely. The CCG offers suggestions on operational changes which would help reduce pollution without compromising safety in Appendix B of this paper.

13. In particular, whilst Government identifies the impact of night noise on overflown communities as a significant issue, it is not as yet addressed nationally or adequately by Government or the aviation industry. Night is recognised by the EC as between 23.00pm and 6.00am.

14. When the World Health Organisation (WHO) has for years identified sleep disturbance caused by noise as a significant contributory negative element affecting the individual’s health, it is unacceptable that some airports, such as London Luton Airport (LLA), still have no night time flight restrictions. This is even more unacceptable for overflown communities when an airport is pro-actively seeking to expand, as LLA currently are. (ref. http://www.london-luton.co.uk/en/content/8/1171/Masterplan.html)

15. Government recognises the major impact of night noise from aviation on overflown residents. However, this recognition is too narrow as controls are not national and vary from the strict regulations in place for Heathrow, Gatwick and Stansted with full 24/7 operations permitted at for eg London Luton. This is unacceptable.

16. Night operations at all UK’s airports should have similar restrictions and parameters. The CCG therefore recommends that in addition to consultation on night noise for the three major London airports, that an integrated or parallel public consultation also be conducted for all airports in the SE, and in particular for those which have no controls in place currently.

17. The DfT, the aviation industry and NATS should recognise the detrimental impact on silent communities of intermittently scheduled flights throughout the night time period and take pro-active and positive steps to reduce such pollution.

18. Averaging of noise intrusion events gives a monitoring reading which is quite different from that experienced by the overflown resident.

19. Quotas are a very poor means of regulating night noise as an airline operator which has performed well and not used its noise quota is able to pass the surplus to another operator, which may well be failing in achieving noise reduction.

20. Currently, for example, residents within a c20 mile radius of LLA suffer from the night time operations (EC hours) of budget and charter flights throughout the year but particularly during the main April-October holiday period. These flights are scheduled by operators throughout the night, together with regular freight aircraft. Such scheduling is not driven by customer demand who, we suggest, would not choose to travel in the middle of the night without a cost incentive to do so.

21. The CCG believes this to be an unfair social balance. A far greater burden is imposed 24/7 upon local residents whose sleep is disturbed intermittently, but significantly, throughout the night, which they cannot choose to avoid, whilst the individual traveller incurs short-term inconvenience at their own choice. As there are currently plans in progress to expand passenger numbers and operations at LLA, the anomaly that this London airport has no night flight restrictions unlike its London counterparts, including London City, should be urgently addressed. A ban over core night hours, or at minimum, a cap to bring LLA in line with other London airports, should be given highest priority by NATS and the CAA.

22. The CCG makes further and detailed comments on noise impact and how this might be reduced in Appendix A of this paper.

23. Light pollution from night time operations is ignored by the aviation industry, its regulators and Government. It is significant and should be included in targets to reduce environmental impact.

24. The CCG believes it is imperative that the CAA and NATS establish an on-going dialogue, not just with the aviation industry, but with environmental bodies and community groups, such as AONB Conservation Boards, to achieve the optimum balance between the UK’s aviation operations and their consequent pollution on communities and landscapes.

25. For eg, it has been encouraging that over past months, in response to dialogue with communities in the Chilterns, trials to operational procedures for certain arrivals into LLA have been carried out by NATS, which are intended to reduce local noise impact. The CCG suggests that more opportunities which have potentially positive outcomes for both operator and community should be facilitated soonest.

26. The CCG makes further comments and suggestions relating to the impact of aviation over designated land (AONBs and National Parks) in Appendix C.

(b) How to reduce carbon emissions and manage impact of aviation on climate change? How can aviation be more sustainable?

1. The CCG’s responses to Q2 are also relevant.

2. Government has expectations that “in the longer term, demand for domestic aviation and ...near-European short-haul aviation could be met by high-speed rail”.

3. Should the Government’s proposed new high-speed railway line (HS2) go ahead and the predicted small modal shift does occur from domestic flights to high speed rail, the aviation industry must take an environmentally responsible position by not re-allocating any vacated short-haul flight slots to long-haul. If it does re-allocate these slots, then if there are any environmental benefits from HS2, these will be negated.

4. The CCG notes that Government recognises the significant effects on health of poor air quality and is taking some steps in working with relevant other parties to monitor and improve this. Achieving compliance with legally binding European standards for ambient levels of pollutants thought to be harmful to human health and the natural environment must be an absolute priority.

5. During the period in April 2010, when UK airspace closed due to volcanic ash from Iceland entering the atmosphere, researchers gathered data on pollutants around Heathrow. They reported that: “This period of unprecedented closure during unexceptional weather conditions has allowed us to demonstrate that the airports do have a clear measurable effect on NO2 concentrations and that this effect dropped almost to zero during the period of closure, leading to a temporary but significant fall in pollutant concentrations adjacent to the airport perimeters.” These findings should not be ignored in targeting emission reduction. (ref: Preliminary analysis of the impact of airport closures due to the 2010 Eyjafallajokull volcanic eruptions on local air quality: Barratt, B and Fuller, G W. 01/05/2010 London Air Quality Network.)

6. There is extensive scope to influence people and industry to make choices aimed at reducing climate change impact from aviation. The CCG suggests, as a start, wider consumer education on the increased environmental impact of night flights and the minimisation of price incentives to choose these over daytime flights—these are industry, not consumer led.

7. Research in 2006 (ref: http://www.leeds.ac.uk/news/artile/517/cutting_night) showed that whilst only 1 in 4 flights over the UK were at night, they accounted for at least 60% of the climate warming associated with aircraft condensation trails (contrails). As not all UK airports are restricted on night flights, this figure could have risen in the 5 years since the data was originally published. Consequently, greater incentives for air operators to reduce or eliminate night flights could lead not only to less noise pollution for overflown communities, but a wider environmental benefit also.

8. It is encouraging that in 2010, British Airways, NATS and BAA collaborated successfully to operate the UK’s “first perfect flight between Heathrow and Edinburgh.” This was “the most fuel efficient through efficient ground taxiing, aircraft climb and descent and optimal flight profile ...saving 350kg of fuel and a tonne of CO2 [total of 10%] compared to a normal flight on the same route”. (ref: http://anil-padhra.suite101.com/air-traffic-control-)

9. Aviation professionals identify that better flight management as above which involve air traffic controllers has potential to reduce aviation emissions by 5–8%. Having demonstrated it can be done, these improvements can now be integrated targets in airports’ Master Action Plans for carbon emission reduction. Government could help to progress this more rapidly.

10. Stacking wastes fuel and increases carbon emissions. he location of stacking “holds” such as the Bovingdon Hold for Heathrow arrivals places restrictions, which would otherwise be unnecessary, upon operations of neighbouring airports, such as LLA. These cause greater noise/air pollution on communities which, without the Hold’s requirements, might not occur. The CCG discusses the question of stacking holds further in Appendix B.

Question 4: Do we need a step-change in UK aviation capacity?

1. The Group’s responses to earlier questions are relevant to Q4.

2. The CCG believes that taking a whole UK approach has potentially greater benefits, than concentrating simply on the SE.

3. The CCG remains firmly opposed to any expansion of operations at Heathrow airport. We give some of our reasons earlier in this paper.

4. Neither do we find that Heathrow currently makes an appropriate level of response to minimise its present operational impact, especially in tranquil areas as the Chilterns and other significant green spaces, such as Kew Gardens. (ref. CCG response to Heathrow Noise Action Plan Consultation 2009.)

5. Therefore we have no reason to be confident that any expansion will bring anything less than greater pollution and adverse environmental impact on overflown communities and landscapes.

19 October 2012

APPENDICES A, B AND C

The CCG includes the following Appendices which formed part of the Group’s response to the CAA Consultation on “CAA and the Environment: Improving Aviation’s Sustainability now and for the future” April 2012 and the DfT’s Consultation on “Developing a Sustainable Framework for UK aviation Scoping Document” October 2011. We find they are relevant to the aims and outcomes of this Inquiry and ask that they be considered fully in its analysis and eventual outcomes.

APPENDIX A

NOISE

Response to Specific Issues on Noise

The Scoping Document concentrates its considerations to the areas around airports and directs the Government’s response to the problem to the requirements of the Environment Noise Directive. These are limited to the major airports (greater than 50K annual movements) and the requirement for the production of noise action plans.

(1) Great emphasis is put throughout this section on the need for local participation on the setting up and agreement to these noise action plans. The concept of setting a “Noise Envelope” around the major airports is mooted with a view to defining an area within a limiting noise area. Aviation growth up to this limit would be permitted. This sounds very similar to the limit on Heathrow noise set by the various Public Inquiries that the area within the 57 dB(A) Leq,daytime not be increased. Further detailed questions need to be answered before such a concept can be properly considered.

What metric or methodology would be used to define the envelope.

Would the bounds of the envelope exceed the present noise limits (eg the 57 dB contour at Heathrow).

What constraints would be placed upon the airport to maintain the envelope.

What sanctions would be available to prevent breaking of the envelope.

(2) One aspect of the airport envelope concept would be that as technology or operational procedure improved the noise output of the individual aircraft or the overall airport performance then airport growth would be permitted. Such a concept would not allow for a reduction in airport noise but would seem to be designed to consign an area to continued noise pollution without any intention to provide overall mitigation.

(3) Night noise is accepted as being a major environmental issue and one that causes significant environmental problems. A respite period is suggested during the night but warning is given that this would probably mean an increase in movements either side of this period. This has no real difference from the current night flying restrictions that are currently in place.

(4) The Government has issued air navigation guidance to NATS to seek to concentrate routes so as to avoid overflying populated areas as much as possible. This approach completely misses the point that such routes will thus fly over the quietest areas and thus have the most impact over the low ambient levels. Noise from down the route operations and from stacking procedures will continue to have significant impact and this problem is not addressed in the document.

(5) The document places some weight upon improved technology reducing the problem of aircraft noise. However, noise reducing technology may be at odds with other environmental concerns. One example is the open rotor technology that offers significant fuel advantage will increase the down the line noise of overflying aircraft. Technological changes are not a local, regional or even national consideration. Aviation is a global concern and technological change needs agreement and support at this level.

Changes are very slow in being implemented. The planned reduction in aircraft noise set out by ICAO by 2020 has shown that technological changes cannot reach the targets. It is operational change that must be implemented. Low energy approach, continuous descent, total route planning from “Gate to Gate” are some of the changes that must be made.

(6) As environmental expectations increase the extent of “local impacts” increase. Noise is not confined to the areas immediately around and airport but is being considered as a regional issue. In this regard much more control must be taken over noise emissions with strong government representations at international level for the early implementation of lower noise aircraft and operational procedures. Local planning control over development close to airports and a system of measurement and assessment of noise that includes night time noise levels should be activated.

(7) Noise contour maps may give an inaccurate indication of the level of noise actually experienced on the ground.

(8) Such airport master plans are useful in concentrating the minds of airport operators. They could be made more effective by giving local communities additional powers of control over the content of these plans. This would give scope for further discussion; certain actions should be vetoed if not considered to be effective or extensive enough.

(9) This concept appears to be very similar to the current Heathrow restrictions. The removal of Concorde from the airport fleet allowed the increase of movements that arose through growth while still maintaining the area of the 57 dB contour. Some control on the extent of noise exposure at airports is obviously needed. However the establishment of a noise ghetto without an inbuilt plan to reduce its extent over time is not a good idea.

(10) It is better to minimise the number of people affected by noise by reducing the level of noise exposure of the overflown population. This is a huge question and not one capable of a simple answer. Route planning for overall noise adverse effect reduction must include consideration of background level, stability of the route plan, etc. not merely a simple population count.

(11) NPR place heavy burden of impact on overflown population and if/as routes change, this impacts on different communities who may previously have been unaffected. It is an unfair socio-economic balance to impose maximum noise impacts on the same few communities, whilst many from different communities use the facility causing the problem.

(12) However, whilst spreading the noise may give welcome relief for some, the impact is simply transferred, not lessened or withdrawn. Government and the aviation industry should be seeking to reduce or eliminate total noise impact not simply move it around.

(13) Over-flying relatively tranquil areas at low levels will cause greater impact than over already noisy areas, but that does not justify increasing those noise levels, which may then become intolerable. This would be particularly true for areas of high daytime noise, which then also became affected by noise from night flights.

(14) No flying at night, arrival or departure, should be allowed for any aircraft not fitted with the latest noise control technology. There should be no movement of freight aircraft at night. Aircraft which fall into either or both of these categories should not fly between the hours of 23:00 to 07:00. Additionally no aircraft should be held in any stacking area between the hours of 22:30 and 06:30. These measures would ensure that only the quietest aircraft operated at unsocial hours and delays on arrival at the airport area are prevented by proper on-route planning.

APPENDIX B

PROPOSALS FOR CHANGES IN AVIATION OPERATIONAL PROCEDURES TO REDUCE ENVIRONMENTAL IMPACT

(1) For most people the greatest environmental impact of aviation is noise from aircraft departing and arriving at airports particularly within approximately 20 miles of an airport. Some alleviation can be achieved by the use of “optimum” routes in and out of airports called “noise preferential routes”; these can help but do not solve the problem because the noise is merely moved laterally elsewhere.

(2) Significant improvements in the noise environment can however, be gained by adjusting the vertical profiles of departing and arriving aircraft. The perceived noise at ground level reduces markedly as aircraft altitude (height above mean sea level ) increases so that in most circumstances aircraft flying above about seven thousand feet are barely heard at ground level. The sooner departing aircraft can reach this altitude and the longer arriving aircraft can maintain at or above this altitude then the better is the noise environment at ground level. How can this be achieved?

(3) It is common practice for commercial aircraft to use less than full engine power for take-off and to employ a technique called a “reduced power take-off” so that, depending on ambient conditions, only sufficient power is applied to achieve a required, safe climb gradient. This is a safe and perfectly legal procedure and there are commercial advantages for operators in the use of less than full power but it does mean that aircraft do not achieve the best rate of climb of which they are capable.

(4) A compromise power setting, at say, somewhere between the “reduced power” setting and full power would enable aircraft to achieve a steeper initial climb gradient than at present. Reaching seven thousand feet sooner would significantly reduce the noise footprint. Such procedures, if adopted, would not be popular with the airlines because they would incur higher operating costs as a result, but they could be very beneficial in relation to noise footprints. They would almost certainly need to be mandated by the aviation regulatory authorities.

(5) Steep and continuous aircraft climb profiles are sometimes currently impeded by the local air traffic control (ATC) environment when for instance, crossing tracks or holding patterns require departing aircraft to stop their climb early to achieve safe separation with other traffic. A review of the ATC procedures and airspace organisation at specific locations where such conflicts currently exist could greatly improve the noise footprint by allowing aircraft to climb quickly without hindrance.

(6) A good example of this situation has been highlighted by CCG in a previous consultation (TCN 2008) in relation to aircraft departing westwards from Luton Airport and routing over the Chiltern Hills and below the Bovingdon (BNN) holding stack.

(7) The minimum altitude in the BNN holding pattern is seven thousand feet. Northbound departures from Heathrow (LHR) and Northolt also route underneath the BNN hold but because ATC require a minimum vertical separation of one thousand feet between conflicting aircraft their climb is restricted to six thousand feet altitude. In practice heavy, trans-Atlantic departures from LHR, which may also have used reduced power for take-off, can often only climb to five thousand feet by the time they reach BNN. Westerly departures from Luton are thus required to stay even lower at four thousand feet until they are some twenty miles from the airport and have crossed the Chiltern Hills which rise to nearly one thousand feet altitude.

(8) In this instance removal or repositioning of the BNN hold and slight re-routing of LHR/Northolt departures would facilitate unimpeded climbs by Luton westerly departures.

(9) For arriving aircraft, the optimum type of final approach is a constant descent approach from about four to five thousand feet and approximately 10 to 15 miles out from the runway; this results in low engine power settings, reduced fuel consumption and reduced noise. Although it is the flight crew who actually fly such approaches they can only be achieved with the active involvement of ATC controllers who vector aircraft from the airway system towards the airport and decide on its vertical profile.

(10) However, in the modern ATC organisation such “area” controllers are usually located at a remote central control centre rather than at or near a particular airport and thus may have little knowledge of local topography and noise sensitive areas. Moreover, when there is little ATC activity, controllers often give arriving aircraft early descent and direct routings to the final approach point because this can save time and fuel.

(11) While this may suit airline operators the downside of these procedures is that populated areas can be subjected to higher than normal noise levels by overflying aircraft. Some visual indication on their radar scopes of the location of centres of population near particular airports would enable controllers to prevent this happening by vectoring aircraft away from them prior to final approach and descent. If implemented such procedures could significantly reduce the noise footprint in the vicinity of airports, particularly at night.

APPENDIX C

IMPACT OF AVIATION ON DESIGNATED LAND (AREAS OF OUTSTANDING NATURAL BEAUTY AND NATIONAL PARKS

Low Over-flight of Designated land

(i) Sustainable aviation is one of the Department for Transport’s (DfT) Business Plan priorities, not only in terms of carbon but also in terms of local environmental impacts, particularly noise (ref. Sustainable Framework for Aviation Scoping Document Oct. 2011, 1.10). The Aviation Scoping document told us that the previous government gave insufficient weight to the local impact of aviation in The Future of Air Transport White Paper, 2003 (ref. Ibid 1.14). In contrast the Coalition government’s Scoping document stated that reducing global and local environmental impacts is “The key challenge for the aviation sector now” (ref. Ibid 2.1).

(ii) The CCG welcomes the rightful concerns of the DfT for the impact of aircraft noise on the environment. This is necessary and commendable and reducing aviation impact should be a priority. However, the CCG remains concerned that the current plans by the DfT/HS2 Ltd to build a new high-speed railway line (HS2) through the heart of the Chilterns gives insufficient weight to the special and protected status of the Chilterns AONB. HS2 may well minimise any positive effect which air operators may try to achieve.

(iii) It is not acceptable to take a position that if noise is present, a little more will not matter. In today’s society, we all have a responsibility to preserve environments which are national assets from which many may benefit.

Over-flight of Areas of Outstanding Natural Beauty and National Parks

(i) The CCG was set up four years ago when low over-flight for many miles was planned over the Chilterns AONB—threatening the AONB’s tranquillity.

(ii) The CCG recognises the importance of the aviation sector to the UK economy. However, it also welcomes the Coalition government’s stance on the need to place sufficient weight on local impacts. Conserving the tranquillity of AONBs and National Parks should be considered among those impacts.

(iii) The CCG notes that nationally designated land does not appear to be mentioned in either the Consultation document: CAA and the Environment Improving Aviation’s Sustainability Now and For the Future, or in the CAA’s Insight Note 2: Aviation Policy for the Environment. This is surprising considering: AONBs and National Parks are nationally-important designated lands; the government’s stance on reducing the local impacts of aviation as a priority; the government’s indication of its renewed commitment to protecting AONBs and National Parks in included in the National Planning Policy Framework.

The Civil Aviation Authority’s Duty towards AONBs

(i) The Countryside and Rights of Ways Act 2000 s85 is concerned with conserving and enhancing AONB landscape. Section 85 of the act states “in exercising or performing any functions in relation to, or so as to affect, land in an area of outstanding natural beauty, a relevant authority shall have regard to the purpose of conserving and enhancing the natural beauty of the area of outstanding natural beauty.” The Civil Aviation Authority (CAA)—and thus NATS—are amongst those specifically listed as relevant authorities (Schedule 1 Part II Section 14e).

Statutory Designation Criteria of AONBs and National Parks

(i) In considering the local impact of aviation on designated land it is important to consider the method used for assessing land for designation as AONBs and National Parks: the land must meet the Statutory Designation Criteria set out in Appendix 1 of Natural England’s Guidance for Assessing Landscapes for Designation as National Park or AONB in England. (ref. http://www.naturalengland.org.uk/Images/B1DesignationGuidanceMar11_tcm6–26242.pdf ) This is embedded in the following laws: National Parks and Access to the Countryside Act (1949 s5) (for National Parks) and the Countryside and Rights (2000 s82) (for AONBs).

(ii) Of the Statutory Designation Criteria, a sense of relative wildness is given as an important factor in assessing land for designation as AONBs and National Parks where a sense of remoteness and a sense of a relative lack of human influence are given as important sub-factors.

(iii) Relative tranquillity is also given as an important factor in assessing land for designation as AONBs and National Parks where presence and/or perceptions of birdsong, peace and quiet, and natural sounds are given amongst the contributors to tranquillity, and low-flying aircraft is given amongst the detractors from tranquillity. Given this, low over-flight over an AONB or National Park diminishes the value of the relative wildness and relative tranquillity factors of affected land. Put simply, the reason for the affected land’s original designation is greatly reduced.

(iv) Please note that National Park and AONB landscapes are of equal value but are designated as a result of differences in size, scale and aims (National Association of AONBs) (ref. http://www.aonb.org.uk/wba/NAAONB/naaonbpreview.nsf/Web%20Default%20Frameset?OpenFrameSet&Frame=Main&Src=%2F__80256cd200319c8e.nsf%2FPublishedContent%2F823f5de80ad3429580256cc2007292cc!OpenDocument%26AutoFramed

Purposes of an AONB and Tourism

(i) AONB status protects the finest examples that remain of small-scale landscapes in England and Wales (National Association of AONBs) (ref. http://www.aonb.org.uk/wba/NAAONB/naaonbpreview.nsf/Web%20Default%20Frameset?OpenFrameSet&Frame=Main&Src=%2F__80256cd200319c8e.nsf%2FPublishedContent%2F823f5de80ad3429580256cc2007292cc!OpenDocument%26AutoFramed

(ii) The purposes of AONBs are laid down in the Countryside and Rights of Way Act (2000 s87). The primary purpose of an AONB is to conserve and enhance the natural beauty of the landscape. The secondary purpose of an AONB is to meet the need for quiet enjoyment of the countryside. These purposes jointly foster tourism as a function of AONBs.

(iii). A further secondary purpose is to have regard for those who live and work in the AONB.

Low Over-flight of Designated Land Impacts on Tourism

(i) Low over-flight reduces the amenity value of designated land in terms of tourism. Tranquillity and wildness are reasons why tourists should seek out AONBs and National Parks for daytrips and holidays. Clearly, low over-flight strongly detracts from the attraction of designated lands.

(ii) The Countryside and Rights of Way Act (2000 s87) charges Conservation Boards with promoting the understanding and enjoyment of AONBs. The Boards’ Management Plans are embedded in the Countryside and Rights of Way Act (2000 s89). The Chilterns Conservation Board Management Plan, for example, contains many references to providing land where quiet leisure pursuits can be enjoyed or peace and quiet can be sought as an interlude or temporary respite from urban life (ref. http://www.chilternsaonb.org/downloads/management_plan/Understanding_and_enjoyment.pdf )

Designing Flight Paths over Designated Land

(i) In preparing guidance to those who design flight paths it is important to recognise that the economic and environmental value of designated land is gained through maintaining its tranquillity.

(ii) Development is restricted in designated land: AONBs and National Parks are designated as such because of their landscape qualities—these would not exist if there were many houses on such lands; PPS 7 paragraphs 21 and 22 prevent major development in designated land other than in exceptional circumstances; Green Belt and AONBs are often contiguous around London and other major cities—development is restricted in Green Belt.

(iii) Those designing flight paths should not interpret the sparse population of AONBs and National Parks to mean that such land is therefore a good place to put low flying aircraft. As noted, this would considerably reduce the ability of designated land to serve the purpose for which it has been set up—a nationally-important facility offering relative wildness and relative tranquillity. Such air-traffic design decisions affect the proper functioning of AONBs and National Parks.

Guidance to the Civil Aviation Authority on Environmental Objectives Relating to the Exercise of its Air Navigation Functions

(i) The Guidance to the CAA on Environmental Objectives is embedded in s 70(2) (d) of the Transport Act 2000. The CCG values paragraphs 45 and 46 of the Guidance to the Civil Aviation Authority on Environmental Objectives Relating to the Exercise of its Air Navigation Functions—but see below. (ref: http://www.caa.co.uk/docs/7/DTLREnvironmentalGuidance.pdf

(ii) The CCG recognises that airspace can be very congested. However, it would like to see greater observance of the recommended altitude for over flight of AONBs that is given in the Guidance on Environmental Objectives: minimising flying below 7,000 feet where possible (paragraph 45).

Guidance on Low Over-flying of High Terrain

(i) The Guidance to the Civil Aviation Authority on Environmental Objectives Relating to the Exercise of its Air Navigation Functions does not appear to give any guidance to those designing flight paths that the height of terrain should be taken into account.

(ii) In 2008 a flight path was designed from London Luton Airport so that aircraft could fly SE at 2,300–2,400 feet agl for many miles over half the length of the Chilterns Hills. This experience shows that consideration should be given to amending the Guidance on Environmental Objectives to include the suggestion that the height of the terrain should be taken into account. In this context it is worth noting that nearly all AONBs and National Parks are formed from raised terrain—hills, plateaux and mountains.

(iii) The CCG therefore suggest that serious consideration should be made to incorporating taking the height of terrain into account for environmental reasons when designing low-altitude flight-paths in the Guidance to the CAA on Environmental Objectives Relating to the Exercise of its Air Navigation Functions.

Clarification Required

(i) Paragraph 45 of the Guidance to the Civil Aviation Authority on Environmental Objectives Relating to the Exercise of its Air Navigation Functions states “Government policy will continue to focus on minimising over-flight of more densely populated areas below 7,000 feet. However, where it is possible to avoid over-flight of National Parks and AONBs below this altitude without adding to the environmental burdens on more densely populated areas, it clearly makes sense to do so.

(ii) Experience has shown that this wording is not clear (ref: http://www.publications.parliament.uk/pa/cm200809/cmselect/cmtran/163/163we11.htmMore densely populated” can be interpreted to mean either: “congested”—the word used in the next paragraph (paragraph 46); or in the comparative sense of “more densely populated” to mean that flight paths should be sited so aircraft over-fly wherever fewer people live—as occurred when airspace over the Chilterns was being designed in 2008.

(iii) The inevitable result of pursuing the policy of over-flying less densely populated areas interpreted in the comparative sense is that as airspace is increasingly utilised, flight paths would eventually become clustered over National Parks and AONBs. This is clearly not what the government intends.

(iv) The CCG suggests that clarification of paragraph 45 of the Guidance to the CAA on Environmental Objectives Relating to the Exercise of its Air Navigation Functions is made by replacing the words “more densely populated” with “congested” (as is used in paragraph 46).

CAP 725—The CAA’s Guidance on the Application of the Airspace Change Process

(i) The CCG does not believe that CAP 725 (Appendix B Section 8 page 27) (ref http://www.caa.co.uk/docs/33/CAP725.PDF) is an adequate reflection of paragraphs 45 and 46 of the Guidance to the Civil Aviation Authority on Environmental Objectives Relating to the Exercise of its Air Navigation Functions.

(ii) CAP 725 does not state that Government policy includes minimising flight below 7,000 feet over AONBs and National Parks (without adding to the burdens on more densely populated areas). This is despite the DfT’s Guidance on Environmental Objectives clearly stating this is Government policy (paragraph 45).

(iii) The only instance when CAP 725 discusses AONBs and National Parks—as far as we are aware—is to say that over-flight of such land is not precluded (CAP 725 Appendix B paragraph 120). This is by no means an adequate or full representation of the DfT’s Guidance on Environmental Objectives of over-flight over designated land.

(iv) In the context of tranquillity CAP725 says it is difficult to measure, apparently complicated and insufficiently researched (Appendix B paragraph 120). It concludes that no formal guidance on tranquillity can be issued to those designing flight paths. Why? With regard to low flying aircraft the subject of tranquillity would appear to be fairly simple: noise from aircraft can be measured; low-flying aircraft are visual detractors from tranquillity in the statutory document: Guidance for Assessing Landscapes for Designation as National Park or AONB in England (Appendix 1).

References

Guidance for Assessing Landscapes for Designation as National Park or AONB in England—Appendix 1 http://www.naturalengland.org.uk/Images/B1DesignationGuidanceMar11_tcm6–26242.pdf

National Association of AONBs http://www.aonb.org.uk/wba/NAAONB/naaonbpreview.nsf/Web%20Default%20Frameset?OpenFrameSet&Frame=Main&Src=%2F__80256cd200319c8e.nsf%2FPublishedContent%2F823f5de80ad3429580256cc2007292cc!OpenDocument%26AutoFramed

The Chilterns Conservation Board Management Plan—Understanding and Enjoyment http://www.chilternsaonb.org/downloads/management_plan/Understanding_and_enjoyment.pdf

Guidance to the Civil Aviation Authority on Environmental Objectives Relating to the Exercise of its Air Navigation Functions http://www.caa.co.uk/docs/7/DTLREnvironmentalGuidance.pdf

Transport Select Committee Inquiry—Use of Airspace July 2009 Memorandum from Marilyn Fletcher B.Sc. Ph.D. AIR 10 Part 3)

http://www.publications.parliament.uk/pa/cm200809/cmselect/cmtran/163/163we11.htm

CAP 725 (Appendix B Section 8 page 27) http://www.caa.co.uk/docs/33/CAP725.PDF

Professional Background Information

Dr. Marilyn M. Fletcher B.Sc. Ph.D.

Dr Fletcher is a Biology researcher and a graduate of the University of Sheffield. After qualifying for her Ph.D. at the University of London, Dr Fletcher lectured to under-graduates at the university for 15 years. She also supervised post-graduate students for Ph.D. and has published papers in biology and histology.

She is now an independent researcher specialising in the environment and sustainability.

Prof. Colin Waters B.Sc(Eng) MSc C Eng MRAeS FIOA

Prof. Waters is Principal of Colin Waters Acoustics and has professional consulting experience in this field for over 40 years. He has been a Director of Ove Arup and Partners Ltd with responsibility for environmental acoustics of that firm. He has carried out and directed major infrastructure environmental acoustics projects in both the national and international field.

Prof. Waters has advised the Chinese Civil Aviation Authority on associated airport noise problems and their assessment.

He is Visiting Professor of Airport Environmental Acoustics at Manchester Metropolitan University.

Captain Gwyn Williams

Capt. Gwyn Williams has 40 years experience in aviation both as a military and civil pilot.

A graduate of the RAF College, Cranwell, he trained as a fast-jet pilot and saw active service in the Middle East and an operational exchange tour in North America in the air defence roll.

He qualified as a flying instructor and subsequently commanded the Advanced Flying Squadron of the RAF Central Flying School training instructors. His final posting was to the MoD Inspectorate of Flight Safety.

After gaining a civilian Airline Pilot Licence, Capt. Williams acted as a pilot instructor and examiner, flew business jets and then schedule and charter flights with several airlines operating B757, B777 aircraft and Concorde for its last 10 years in service.

As a Flight Operations and Training Inspector for the Civil Aviation Authority he was responsible for the monitoring of a number of major UK airlines; for the testing and approval of flight simulators and for the training of the airlines’ own training captains.

Prepared 24th May 2013