London Borough of Sutton

Published Monday, 4th March 2019

Response to the Heathrow Airspace and Future Operations Consultation – 4 March 2019


The London Borough of Sutton welcomes the opportunity to respond to the latest consultation, following on from our comments on the expansion consultation on 20 March 2018. As highlighted in that response, the borough remains opposed to the expansion of Heathrow Airport to accommodate a third runway due to the impact of the proposals on neighbouring local boroughs, communities, surface access and the wider environmental footprint changes.

A motion of opposition first carried by members in 2009 ( remains unchanged, and in our new Local Implementation Plan we echo the comments by the Mayor of London in the Mayor’s Transport Strategy and new London Plan:

“The Mayor will continue to oppose the expansion of Heathrow airport unless it can be shown that no new noise or air quality harm would result, and the benefits of future regulatory and technology improvements would be shared fairly with affected communities. Any such development must also demonstrate how the surface access networks will be invested in to accommodate the resultant additional demand alongside background growth.”

Sutton sits approximately 9 miles to the south east of Heathrow Airport, and benefits from the existing westerly operations and flight routes which either skirt around the borough altogether or result in aircraft passing over at altitudes above 5,000 feet, resulting in a generally quiet experience for the borough and its residents. However, the draft proposals outlined in this latest consultation, both for making greater use of the existing runways and accommodating future changes to airspace for an expanded Heathrow, are likely to have more direct implications.

The proposal to adopt Independent Parallel Approaches for all or part of the day will result in significant changes to flightpaths for aircraft flying into or out of the airport, and there is also the risk of increased noise levels due to lower altitudes set out in a number of the design envelopes put forward. A number of the draft design envelopes for future flightpaths show aircraft descending to as little as 3-4000 feet over the borough, and with the use of independent parallel approaches and performance based navigation this has the potential to affect a number of communities that up until now have seen minimal aircraft movements overhead.

While the impact of these proposals will of course be subjective, and details of new flightpaths, future restrictions on aircraft types and operating patterns cannot yet be quantified, residents in the north and west of the borough have already expressed concerns at what it might mean for them.

Sutton was not offered a public event or an opportunity to host consultation material for residents to examine, and so we ask that this be considered for future consultations, particularly related to the more detailed planning of flightpaths. It would also be very helpful if more locally-focused resources and sample scenarios, such as noise demonstration videos, are made available for the public to gain a greater understanding of what the changes might mean for them. Without such direct comparison of existing noise levels and potential future noise levels with airport expansion and new flight paths in place, it is extremely difficult to assess the potential changes in any area.

Detailed answers to each of the consultation questions are contained in the appendix below.


Heathrow Airspace and Future Operations Consultation – response by the London Borough of Sutton

Detailed Responses to Questions

1.   Noise

Q.   Do you support our proposals for a noise objective?

A.   The borough supports the principle of the proposed objective, subject to clarification.  The wording ‘limit and, where possible, reduce the effects of noise on health and quality of life’ are vague and require more detail of any specific targets for reducing the effects of noise. Similarly, the potential obligation that “the overall impact of aircraft noise must be limited and, where possible, lower than 2013 noise levels” is unclear and does not show whether these levels relate to local ground running noise within the immediate vicinity of the airport or the approach paths.

The borough notes the 2013 baseline proposed for noise impact levels, at which time there were approximately 472,000 aircraft movements a year and since then these have risen to approximately 480,000. The proposals to make increased use of existing runways would increase this to above 500,000 movements per year according to the figures in the expansion consultation in 2018, but it was not possible to ascertain what impact further expansion in terms of a third runway would have if built. Given the proposal to continue with the existing overnight flight restrictions this appears to be a stretching target, even with the planned changes to approaches to land aircraft more quickly, and would benefit from further explanation as to how this would be achieved. The proposal for quieter aircraft types alone would not appear to be sufficient in its own right.

The borough would also welcome assurance that monitoring of the balanced approach, and progress against the noise objective goals, is undertaken with independent input to demonstrate fairness and impartiality.

2.   Future operations and respite

Q.   Would you prefer to have longer periods of respite less frequently (all day on some days but no relief on other days) or a shorter period of respite (e.g. for 4-5 hours) every day?

A.   The borough considers that a shorter assured period of respite every day would provide greater certainty for residents and communities. The borough recognises that the various envelopes proposed mean that operations will change at least a couple of times each day and this, coupled with the different flightpath options within each envelope and the distance of the borough from Heathrow, means that the risk of excessive noise in the borough is not expected to be high. However, we await the outcome of the more detailed flightpath proposals from 2020 onwards before offering a final view on this.

3.   Directional Preference

Q.   Should we continue to prefer westerly operations during the day and easterly operations at night to reduce the total number of people affected by noise?

A.   The borough supports this proposal, as it would continue to offer Sutton and neighbouring boroughs the most favourable option of aircraft operating under lower power settings and consequently less exposure to noise.

Q.   Should we sometimes intervene to change the direction of arriving and departing aircraft to provide relief from prolonged periods of operating in one direction – even if that means slightly increasing the number of people affected by noise?

A.   The borough recognises the need to alternate direction of operations due to respite for communities closer to Heathrow, and to accommodate favourable wind conditions or other airspace restrictions. However, we share the concerns of neighbouring boroughs that changes to the direction of flight paths could be dictated by those areas that already have significant noise issues, and directed over areas with existing low ambient noise levels such as Sutton. We would support a restriction on the number of runways used for easterly departures, and for aircraft to climb to altitude as quickly as possible in order to minimise the resulting noise footprint. In current practice it would appear that by the time easterly aircraft overfly the borough they have climbed beyond 4-5000 feet and so the borough is less affected than others, although we recognise this does have a resulting effect on larger communities in central London. Certainly aircraft taking off should not overfly the borough at any lower altitudes than at present.

4.      Night Flights

Q.     To help inform our consideration of the options, we want to know whether you would prefer for us to:

·         Option 1 - Use one runway for scheduled arrivals from 5.30am (runway time 5.15am)

·         Option 2 - Use two runways for scheduled arrivals from 5.45am (runway time 5.30am)

A.     The borough is inclined to prefer Option 1, as this would appear to minimise the number of people affected by noise for incoming flights between 5 and 6am. However, recognising the proposals for precision navigation to provide narrower flightpaths, the option should factor in opportunities to vary the flightpath used in order to ensure fairness and suitable respite for those communities most affected.

5.      Incentivising quieter aircraft (especially at night)

Q.     Please provide any comments or suggestions on how we should encourage the use of the quietest type of aircraft at night (outside the proposed scheduled night flight ban).

A.     The borough has no specific view on this over and above that already undertaken within the existing Noise Action Plan, although of course we would urge that the quietest possible types be used and a restriction be made on larger types such as A380 or 747 aircraft in the late evenings before the night restrictions take effect.

Given the need for aircraft to serve locations all over the world and within different regulatory bodies we assume that the CAA, ICCAN and the ICAO will specify future noise limits for new aircraft, as well as retro-fit ‘hush’ kits for older types where possible to allow them to continue operation.

Other Comments

Q.     Please give us your feedback on this consultation (such as the documents, website or events)

A.     There has been a good opportunity for borough officers and elected members to attend briefing events to find out more about the proposals. However opportunities for the public have been limited, and we are aware that residents in areas such as Cheam and Worcester Park have travelled out of the borough to events in Ewell or Epsom to find out more as no events were held in Sutton. Accordingly, the borough asks that for future consultation rounds greater consideration is given to providing local roadshows or opportunities in Sutton for the public to view the documentation at key locations, such as libraries or council offices.

Documentation has generally been comprehensive although in some areas somewhat difficult to navigate due to the volume and complexity of information provided, and links to potential resources (such as the NATS aircraft noise comparison videos) exist on the wider Heathrow webspace but are not specifically referenced within the consultation pages. This latter point is a particular oversight and should have been addressed at an earlier stage.

A major omission is a plan identifying, by area, a comparison of existing noise levels and potential future noise levels with new flight paths. This must be developed as part of the more detailed flight path planning and consultation to allow residents and local authorities to better ascertain the impact of the proposals and respond accordingly.

At the briefing session for borough officers and members on 8 February, attendees were asked to highlight any research, health or other establishments in the area using equipment or processes that would be sensitive to increases in noise. The borough is not aware at this time of any specific establishments that might be affected by aircraft flying between 3-4,000 feet. However, Sutton is home to a number of key health establishments including St Helier Hospital, the Royal Marsden and the Institute for Cancer Research. Future developments will see the ICR expand over the next 10 years to open the London Cancer Hub, which will employ over 6,000 staff as a national and European centre of excellence in cancer research and treatment. Consideration of these establishments and future proposals should be made when designing flightpaths.