London Airspace Change Gatwick Local Area Consultation

1 London Airspace Change Gatwick Local Area Consultation 1. Introduction 1.1 In addition to previous communications dated 7 th and 12 th August 2014, the Warnham Parish Council and the Slinfold Parish Council (WS) have developed the following response to the Gatwick Local Area Consultation (GLAC), which is a part of the wider London Airspace Management Programme (LAMP) and the Civil Aviation Authority (CAA) Future Airspace Strategy (FAS). This response has been developed with the benefit of professional advice on Airspace and Air Traffic Management Policy and Planning, but for reasons which are explained later in this response, without the benefit of access to professional expertise on the distribution and effects of aircraft noise, or environmental impact. 1.2 As a part of this analysis and in order to validate the view of GLAC propositions, WS have sought to understand the context and impact of the changes planned by Gatwick Airport Limited (GAL), not only at a local level, but also from the wider UK perspective including the strategic objectives of the FAS. Taking into account the EU plans for the Single European Sky 1 (SES), including the European Air Traffic Management (ATM) Master Plan 2. As well as the impact and lessons learned from wider airspace efficiency initiatives at the global level, such as the ICAO Global Air Navigation Plan. 3 WS have also considered the existing performance of GAL as documented by the Eurocontrol Performance Review Report 2013. 4 1.3 The GLAC documentation is technically complex, it makes a number of unsubstantiated and sometimes contradictory statements. It offers weak or overly complex supporting material. It deploys dubious or misleading rationale in a number of areas and finally proposes a limited number of take it or leave it options without any adequate attempt to explore or explain the need for the options proposed. Neither does it seek to explain any alternative strategies or mitigation techniques available or planned by GAL, National Air Traffic Services (NATS) or the CAA. WS find this entirely unreasonable and completely unacceptable. 1.4 WS considers that expert advice on matters of Air Traffic Management, Noise Management and Environmental Protection is essential if a full understanding of the GLAC options, consequences and alternative strategies is to be developed, and most importantly, properly considered and responded, in this consultation. 1.5 The UK Government has established the Airports Commission to consider options for additional runway capacity in the South East of England, the Commission is due to publish its recommendations in summer 2015. The work of the Airports Commission and the interests of GAL negatively affect WS ability to make an informed independent assessment. GLAC contends that the work of the Commission does not impact this consultation. This contention is incorrect. 1.6 As a part of the on-going Airports Commission process, GAL, Heathrow Airport Limited (HAL) and Transport for London each has interest in the Government selecting their particular proposition, by rejecting their competitor s. Each, including GAL, is investing heavily in promoting their respective cases. Each has employed, on an exclusive basis, expert 1 http://ec.europa.eu/transport/modes/air/single_european_sky/ 2 http://ec.europa.eu/transport/modes/air/single_european_sky/doc/european_atm_master_plan.pdf 3 ICAO Doc 9750 AN/963 Fourth Edition 2013 4 http://www.eurocontrol.int/sites/default/files/publication/files/prr-2013.pdf

2 companies available to prepare detailed analyses of the various airspace, environmental and noise impacts of their own and their competitor propositions for London s airports. 1.7 These same experts are, due to conflict of interest, hence not available to WS or other communities invited to offer opinion to GLAC. The work of the Airports Commission is effectively eliminating the open availability of the independent expert advice necessary to adequately assess the impacts of the proposed GLAC and LAMP changes in the timescales proposed. The appropriate safeguards have not been put in place by GAL, NATS the CAA or the Department for Transport (DfT). This, in the view of WS, is a clear planning oversight which renders the GLAC process invalid. 1.8 In developing this response, WS have nevertheless sought to understand the implications of the GLAC proposals and how GAL operates today from an airspace and runway capacity standpoint. This is taken together with the trends and forecast growth in passenger demand and aircraft size. Further, WS has considered the report and recommendations of the Eurocontrol Performance Review 5 as it pertains to airports and any CAA policies that may be relevant. 1.9 WS have noted that GAL is already the busiest single runway airport in the world 6. Yet the objectives of the proposed GLAC changes to Runway 26 Departures are to increase the capacity of the already exceptionally busy runway 7. This suggests that the airport s declared runway capacities 8 are optimised to the more efficient Runway 08, which according to the GLAC material is used for only 27% of flights. This, rather than Runway 26, which with its lower throughput capability, is used most of the time due to prevailing winds. If this is indeed the case then GAL is not balancing its capacity and demand appropriately. 1.10 According to Eurocontrol, the performance of GAL is already among the worst in Europe for delays and excessive arrival manoeuvring of aircraft 9, indicating that the capacity declarations are overly optimistic and do not offer adequate operational resilience 10, particularly early in the day or for the 20 percent of the time when some form of adverse weather affects the airport operation 11. 1.11 WS have also noted that both GAL and NATS are both incentivised by the increased revenue potential of additional flights at the airport. 1.12 GAL is investing heavily in promoting the benefits of growth at the airport including a bid for another runway. WS will be recommending to the DfT and the CAA that airports proposing any form of development, including airspace changes, are obliged to set aside a fund to provide for the conduct of the fully independent assessment, analysis and reporting of any proposed options, for use by affected stakeholders. 1.13 Aircraft noise is blight. Clear impartial evidence should be available to all stakeholders through fully transparent process that all steps have been taken by GAL, NATS and the CAA to ensure that capacity growth and efficiency objectives are being delivered by optimum means. In particular, A-CDM, use of larger aircraft, and the balancing capacity and demand across the day, rather than further increasing the hourly use of an exceptionally busy runway. The GLAC does not explore any of these options or provide any of these assurances. 5 http://www.eurocontrol.int/publications/performance-review-report-prr-2013 6 http://nats.aero/blog/2013/09/how-gatwick-broke-its-own-world-record/ 7 GLAC Issue 1, paragraph 3.14 8 http://acl-uk.org/userfiles/file/gatwick%20summer%202014%20capacity%20declaration.pdf 9 http://www.eurocontrol.int/publications/performance-review-report-prr-2013 (Chapter 5) 10 http://www.caa.co.uk/docs/5/marketpowerannex.pdf (Section 3) 11 http://www.eurocontrol.int/publications/performance-review-report-prr-2013 page 83 fig 5-10

3 1.14 WS have also noted that the Airports Commission in its interim report has recommended the establishment of an Independent Noise Authority 12. Any decision that implies the redistribution or increase of aircraft noise disturbance in the context of improving London s available runway capacity, which the GLAC intends, should be deferred so as to benefit from the opportunity for independent analysis and reflection by this body. It is not clear why the GLAC has not drawn the attention of communities to this important preliminary recommendation of the Airports Commission. 1.15 The GLAC proposition is among other things clearly an attempt to increase runway capacity at GAL, despite the fact that NATS has advised the Airports Commission 13 that GAL has already reached or exceeded sustainable levels of Air Transport Movement (ATM) operation. 2 GLAC rationale for change 2.1 WS has noted that one of the objectives of the proposed airspace changes is for a realignment of the Standard Instrument Departures from Runway 26, directing aircraft to turn earlier after take-off, permitting the quicker departure of the following aircraft through use of specially reduced separation minima. This assumes that there is no interleaved arriving aircraft, that there is no overriding vortex wake separation requirement and that low visibility procedures are not in operation. WS has noted that GAL and NATS are developing a reduced separation standard to replace the existing minima 14. WS has also noted that the initial segments of the planned PBN departures for Runway 26 are designed to facilitate departure separation, not PBN compliance. The so called ADNID trials conducted at GAL in 2014 has brought into sharp focus for residents the likely negative environmental impact of any proposed changes to departure routings. 2.2 Importantly, the traffic profile at GAL has changed, reflecting both wider economic trends and the use by airlines of larger aircraft. Accordingly, the average number of passengers per aircraft at GAL has increased by 14% since 2003. See Fig.1 This trend will continue. 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 Movements* 243 251 261 263 267 264 252 241 251 247 251 ATM* 234 241 252 254 259 256 245 234 245 240 244 Pax (m) 29.9 31.4 32.7 34.1 35.2 34.2 32.4 31.3 33.6 34.2 35.4 Pax/ATM 127 130 130 134 136 134 132 134 137 142 145 Figure 1 Trend in aircraft movements and passengers per aircraft at Gatwick *000 s - source CAA statistics 2.3 The historical traffic figures are revealing for other reasons, several points are worthy of note. Firstly as noted in Section 1, in its Support to the Airports Commission, NATS 15 advises that GAL with one runway can sustainably support 250k Air Transport Movements per year. This figure was reached or exceeded in the years 2005-2008 and is likely to be exceeded again in 2014, suggesting that according to NATS the current busier operation is 12 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/271231/airportscommission-interim-report.pdf 13 http://www.wandsworth.gov.uk/download/downloads/id/9240/nats_support_to_the_airports_commissionsupport_to_the_assessment_of_potential_long_term_measures 14 CAP 493 Section 1 Chapter 3 15 See link at footnote #11

4 unsustainable. Secondly, note that the total number of Aircraft Movements at GAL, as opposed to Air Transport Movements, is 7k-10k greater each year. This reflects the use of GAL by aircraft not operating for air transport reasons. GLAC offers no discussion of the mitigation of local noise and other impacts possible by adopting policies that reduce this type of extraneous airport usage, although these movement numbers have apparently declined since 2006. 2.4 WS enquiries have revealed that the GAL base airlines easyjet and British Airways are both planning to introduce short haul aircraft with 20% greater passenger capacity in a rolling programme now underway. easyjet is progressively replacing Airbus A319 with the larger A320 aircraft 16 and through its purchase of Flybe slots in 2013 will replace aircraft of 78-110 seat capacity with 150-180 seat capacity. British Airways is replacing Boeing 737 short haul fleet at GAL with Airbus A320 aircraft effective winter 2014. This is an accelerating trend seen across the global airline community. It is analysed in detail and reported in the Airbus Global Market Forecast 17 and the Boeing Current Market Outlook 18. It is also reported in the aviation press (Fig 2). This trend has for instance been evident in Airbus single aisle gross orders since 2010, when the relatively even balance between the A319 and the much larger A321 began to tilt heavily in favour of the larger aircraft. In 2013 the A321 outsold the A319 by a factor of 20. Figure 2 Airbus single aisle order conversions 2.5 Demand for runway capacity at GAL varies extensively through the day. The highest demand is in the early morning as all the based aircraft depart for their first flight of the day. Demand and capacity balancing is a key component of the European ATM Master Plan for delivering runway efficiency and optimum environmental performance. This provides an obvious alternative to the complex plan for a reduction of departure separation minima currently identified in the GLAC, which it appears can be applied at all times of the day. 2.6 Even so the current Capacity Declaration at GAL (Fig 3) clearly indicates that the peak departure demand occurs only in the early morning. Note that more than 30 departures are planned in each of most of the hours between 05:00-09:00 local time. Yet the arrival stream is planned above 30 per hour only once in the day, in the evening. Also note that the 2013 plan has increased the number of planned departures in the morning peak period over 2012. If runway capacity is such a challenge, why has this been permitted? 2.7 Effective runway capacity planning is essential. Creating new departure routes to cope with the excessive demand by increasing theoretical runway throughput is not a requirement of 16 http://corporate.easyjet.com/~/media/files/e/easyjet-plc-v2/pdf/investors/results-centre/2014/2014-halfyear-results-analyst-presentation.pdf 17 http://www.airbus.com/company/market/forecast/ 18 http://www.boeing.com/assets/pdf/commercial/cmo/pdf/boeing_current_market_outlook_2013.pdf

5 PBN implementation, as implied in GLAC. Neither does this serve the SES objectives of increasing safety and reducing environmental impact 19. Increasing the number of aircraft cannot increase safety nor can it reduce environmental impact. The GLAC has not provided the clear information on these points in its supporting material that could permit an informed consultation to take place. Figure 3 Gatwick Capacity Declaration (Airport Coordination Limited} 2.8 The GLAC material identifies the objective of benefitting from the use of PBN capability in aircraft and the consequent enhanced route design. This reflects global, EU and UK aviation policy. The benefits off PBN 20 are clear. PBN together with other arrival and departure management techniques, will undoubtedly reduce the extent of arrival manoeuvring, and facilitate both Continuous Climb Operations (CCO) and Continuous Descent Arrivals (CDA) improving the noise & CO2 impact of individual flights at GAL and elsewhere. 2.9 Attempting to use the implementation of PBN routes as a justification for reduced departure separation minima for Runway 26 and an increased runway departure throughput as proposed in the GLAC material is highly questionable. The GLAC offers no discussion of the alternative options, or mitigating techniques for improving runway throughput that are identified in the European ATM Master plan, or published by NATS 21 such as A-CDM and improved scheduling and capacity planning. Further, the GLAC does not offer a definition of peak hour period, proposing instead take it or leave it options. 19 http://ec.europa.eu/transport/modes/air/sesar/doc/2012_10_23_atm_master_plan_ed2oct2012.pdf page 19 & http://www.caa.co.uk/docs/2408/fas%20deployment%20plan.pdf page 6 20 http://www.caa.co.uk/default.aspx?catid=1340&pageid=13333 21 http://nats.aero/blog/2013/11/five-ways-improve-airport-capacity-without-extra-runways/

6 2.10 Air Transport is an important contributor to the prosperity of any economy 22. Equally, responsible stewardship is essential to ensure that as air transport develops, its negative consequences are fairly and honestly managed. The GLAC process has failed to adequately explain or explore the alternative and mitigating technologies, procedures and strategies available or planned by GAL, NATS or the CAA. 2.11 These might include improving throughput of the airport by making use of: 2.11.1 Aircraft with greater passenger capacity 2.11.2 Re-categorisation of aircraft wake vortex criteria 2.11.3 Time Based Separation (TBS) for arrivals as planned at HAL 2.11.4 A-CDM 2.11.5 AMAN/DMAN 2.11.6 Improved Air Traffic Flow management 2.11.7 Elimination of extraneous flying from GAL 3 Conclusions 3.1 The GLAC documentation is technically complex, It offers weak or overly complex supporting material. It deploys dubious or misleading rationale in a number of areas and finally proposes a limited number of take it or leave it options without any adequate attempt to explore or explain the need for the options. Neither does the GLAC explain any of the alternative strategies or mitigation techniques available or planned by GAL, NATS or the CAA. WS find this entirely unreasonable and completely unacceptable. 3.2 WS considers that expert advice on matters of Air Traffic Management, Noise Management and Environmental Protection, is essential if a full understanding of the GLAC options, consequences and alternative strategies is to be developed and most importantly properly considered and responded, in this consultation. 3.3 The work of the Airports Commission and the interests of GAL negatively affect WS ability to make an informed independent assessment. The work of the Airports Commission is effectively eliminating the open availability of the independent expert advice necessary to adequately assess the impacts of the proposed GLAC and LAMP changes, in the timescales proposed. The appropriate safeguards have not been put in place by GAL, NATS the CAA or the DfT. This is a clear planning oversight which alone renders the GLAC process invalid. 3.4 WS have noted that GAL is already the busiest single Runway Airport in the world. Yet the objectives of the proposed GLAC changes to Runway 26 Departures are to increase the capacity of the already exceptionally busy runway. 3.5 According to Eurocontrol, the performance of GAL is already among the worst in Europe for delays and excessive arrival manoeuvring of aircraft, a cause of poor environmental performance. This strongly suggests that the runway capacity declarations at GAL are overly optimistic and do not offer adequate operational resilience. 3.6 Clear impartial evidence should be available to all stakeholders through fully transparent process that all steps have been taken by GAL, NATS and the CAA to ensure that capacity growth and efficiency objectives are being delivered by optimum means. In particular, A- CDM, use of larger aircraft, and the balancing of capacity and demand across the day, rather 22 http://aviationbenefits.org/

7 than increasing the use of an exceptionally busy runway at the busiest times of the day. The GLAC does not explore any of these options or provide any of these assurances. 3.7 Demand and capacity balancing is a key component of the European ATM Master Plan for delivering runway efficiency and optimum environmental performance. The GAL runway capacity declaration indicates that GAL demand and capacity is not optimised. 3.8 Forecast traffic growth should be met through use by airlines of larger aircraft, a trend reported by both Boeing and Airbus market analysis. The GLAC offers no evidence to justify an increase of the maximum number of flights per hour. The airport already has poor levels of runway resilience according to Eurocontrol. 23 3.9 Any decision that implies the redistribution or increase of aircraft noise disturbance in context of improving London s available runway capacity, including at GAL, which the GLAC intends, should be deferred so as to benefit from the opportunity for independent analysis and reflection by the Independent Noise Authority proposed by the Airports Commission. It is unclear why the GLAC has not drawn attention to this proposal. 3.10 NATS has advised the Airports Commission, in its analysis of the London Airports options 24, that GAL has already at 250k ATM per year, reached or exceeded sustainable levels of Air Transport Movement (ATM) operation. The GLAC proposals made by GAL and NATS would seem to contradict this advice. 3.11 The GLAC documentation has failed to provide adequate information and it is misleading and unbalanced. The GLAC process has been rendered ineffective by the parallel work surrounding the Airports Commission and is hence ill conceived and poorly timed. WS contends therefore that the GLAC is invalid and should be immediately withdrawn. 3.12 WS call for an independent review of the GAL proposals and the issues and alternative strategies identified in this response. 3.13 WS will be calling on the CAA and the DfT to require airports to set aside a fund to provide for fully independent analysis of any proposed changes that materially affect local communities, including airspace. 3.14 In the meantime WS is confident that GAL will be able to meet forecast growth in demand through the fleet policies of easyjet and British Airways, and the airline acquisition trends reported by Airbus and Boeing. The forecast provided in the GLAC also suggests that the growth forecast by GAL, will not require an increase in runway throughput. 14 th August 2014 23 http://www.eurocontrol.int/publications/performance-review-report-prr-2013 Chapter 5 24 http://www.wandsworth.gov.uk/download/downloads/id/9240/nats_support_to_the_airports_commissionsupport_to_the_assessment_of_potential_long_term_measures