Why is the second phase taking place?
The second phase is taking place because after narrowing down where new flight paths could go – there may be additional impacts on areas in Sussex, Surrey and Kent that were not previously known and therefore not consulted on.
Is this in reaction to Warnham?
Absolutely not. Under guidance from the CAA (Civil Aviation Authority) we are adding a second phase of consultation to consult with the local community on additional impacts as a result of the development of potential new arrival and departure routes using the feedback from the first consultation.
Was there always going to be a second phase?
Yes – it was always a strong possibility that additional impacts not covered in the first consultation would come to light as we assessed feedback and developed potential routes from the first consultation.
How is this and the second runway linked?
It is not at all. The changes we are consulting on will be delivered by the end of 2015 and will be operational many years before any potential second runway is built at Gatwick. If Gatwick is successful in being awarded a second runway, there will need to be further airspace changes and further public consultations.
Where can I get more info?
The consultation document contains all the information required to enable you to determine the potential effect of the proposal.
Feedback can be given using the feedback button on the website which will open up a questionnaire for you to fill in. You can also email us at gatwickairspacechanges@Ipsos.com.
Alternatively you may post a response to us at:
Gatwick Airspace Consultation
Research Services House
You refer to “environmentally sensitive areas”, “populated or other sensitive areas” and “populated areas and noise sensitive areas”; what is the definition of these terms?
Different communities or individuals may have different perceptions of what is sensitive and what is not, hence we have deliberately left these terms open for individuals to interpret as they see fit. Stakeholders are encouraged to give their views what areas may be sensitive to airspace changes, so that we can consider them in the ongoing design process.
Will it mean more flights overhead? Will I see/hear more flights?
This consultation is about how we modernise the existing routes to achieve the optimal solution operationally and environmentally. The consultation is not about the general trend of increasing numbers of flights (see later FAQ on “Why don’t you stop the number of flights from growing?”).
The net effect of these proposals will be less noise – aircraft will climb higher, more quickly on departure and stay higher for longer on arrival. However, flight paths will change – and this may mean some areas will be overflown more than today, others less, and some will not notice any significant change.
This consultation is your chance to feed information into the on-going design process about any local sensitivity to overflights so that it may be considered in the on-going design process.
What is the process for changing airspace?
The process for changing airspace is defined by the CAA in their publication:
CAP 725, CAA Guidance On The Application Of The Airspace Change Process, March 2007, CAA Directorate of Airspace Policy.
For further information on the legal framework for airspace changes in the UK, including government guidance, see Part A of the consultation document.
What will you do with my response? Will you be giving feedback on the results of the consultation?
We have employed IPSOS to independently collate all responses. They will analyse and feedback to us the issues, which we can consider in our on-going design process. A feedback report detailing the results of the consultation will be published on this website in September 2014.
Responses will be made available to the CAA as part of any Airspace Change Proposals submitted to them for changes covered by this proposal. This will allow the CAA to assess whether we have taken relevant information into account in the development of our final proposals.
Why should we believe what you say in your consultation document?
At NATS and Gatwick Airport Limited we take our responsibilities very seriously and whenever we present proposed changes we always seek to present the best available information.
Furthermore, the process for airspace change is regulated by the CAA. As part of this change process we will be required to analyse performance after one year and demonstrate that the change is working as anticipated. If the CAA determines this not to be the case then they may require us to make further changes to rectify the situation which would be costly and time consuming.
It is in nobody’s interest to have incorrect information in the consultation material.
Why has there been a recent increase in noise over my area? Why have you made these changes already?
NATS is required to go through the airspace change process, as documented in the CAA’s airspace change guidance, when proposing permanent changes to the airspace design. Permanent airspace changes cannot be implemented until a formal proposal has been submitted to, and approved by the CAA. An exception to this is trial procedures, designed to test technical airspace design issues. There have been no permanent changes during the consultation period and therefore any recent changes to the perceived behaviour of aircraft in your vicinity are not due to the proposed changes to the airspace structure.
Air traffic control is required to consider a range of factors when determining where aircraft fly, such as other traffic in the area, the aircraft types, wind direction and weather in general. This means that the way in which airspace is used may vary on a day to day basis, and even flight by flight basis (hence the wide swathes in which aircraft may be seen in route and flight path maps in the consultation document). This variation may contribute to a perception of changed airspace usage where the airspace structure has in fact remained unchanged.
It should also be noted that experience from previous consultations indicates that the consultation process sometimes leads people to take more notice of the routes that are already above them. It may therefore seem like a change has occurred when in fact it is more that the communities have become more sensitised as a consequence of the discussion around air traffic.
Questions regarding existing airspace design or airspace policy should be directed to the CAA.
Who are the CAA?
The Civil Aviation Authority (CAA) is, amongst other things, responsible for the planning and regulation of all UK airspace, including the navigation and communications infrastructure to support safe and efficient operations. The CAA is staffed by civilian experts from the CAA and military experts from the Ministry of Defence (MoD) with experience of commercial, business [private], recreational and military aviation. The needs of all users are accommodated, as far as possible, taking into account safety, environmental, economic and national security considerations.
How do I know that you have considered my response and that of others? I want to be able to see all the responses to the consultation.
At NATS and Gatwick Airport Limited we take our responsibilities very seriously; we will consider all responses and we will ensure that relevant points are fed into the ongoing design process.
To that end we have employed an independent company (Ipsos) to manage and report on the consultation responses. The consultation responses, analysis and subsequent design process will all be made visible to the CAA as part of any submission we make to them. They will only approve an airspace change if they have evidence to show that we have followed the correct processes.
Allowing open access to the consultation responses would raise data protection issues. Our integrity, that of Ipsos and ultimately the independence of the CAA as the airspace regulator provides the assurance that due process will be followed.
A feedback report which will provide analysis of the issues raised and numbers of consultation responses will be published in September 2014.
How will the consultation response be reported to Gatwick by IPSOS, such that responses (other than those using the on line form) have equal weight to ensure that everyone is represented?
All those who wish to respond to the consultation can do so via three possible methods 1) through the online response form found on the Gatwick consultation website; 2) by directly emailing the response to firstname.lastname@example.org; or 3) by sending a hard copy to Freepost RSLG ATKL LBAE, Gatwick Consultation, Ipsos MORI, Research Services House, Elmgrove Road, Harrow, HA1 2QG. Upon receipt the responses will then be securely booked in by Ipsos MORI’s Consultation team.
Analysis of the responses requires the coding of the information received. Coding is the process by which bespoke responses are matched against standard codes Ipsos MORI has compiled, so that their content can be classified and tabulated. Each of these codes represents a discrete issue or viewpoint raised by a number of respondents in their verbatim responses. When viewpoints arise, within a response, that have not been previously coded a new code will be raised to capture this view.
This same process is undertaken for all bespoke responses regardless of the method that the respondent used to respond (online, via email or via hard copy), ensuring that all have an equal weighting and will be duly represented in Ipsos MORI’s report that will be presented to Gatwick Airport Limited. Furthermore, consultations never set out to be representative surveys, referendums or opinion polls. Respondents are always self-selecting and can never be said to be representative of the affected population as a whole.
When will this be happening?
The proposal is subject to this consultation, adaptation following consultation and then assessment by the CAA before a decision is made on whether to implement it. This means that any significant change could not be implemented before Winter 2015. Changes may be phased over a period of time.
Why can’t the aircraft route over another area?
The airspace over East/South East England has routes into and out of the region’s airports. Getting aircraft to and from the region’s airports inevitably means some areas will be over-flown.
The consultation will help us determine where the optimal route positioning is.
I think concentrating traffic is wrong – why don’t you spread it around?
A system designed around performance based navigation (PBN) will tend to concentrate traffic along certain routes. This is in line with government guidance issued by the Department for Transport.
PBN is the cornerstone of the CAA’s Future Airspace Strategy and will improve both operational and environmental efficiency of the airspace as a whole.
NATS and Gatwick Airport are designing airspace in line with this strategy, which means that air traffic will become more concentrated.
However, PBN provides the opportunity to design routes better to avoid population centres and/or environmentally sensitive areas and also provides the opportunity to consider the introduction of respite routes to provide predictable periods where traffic will not be concentrated overhead. Overall PBN offers improved environmental performance, hence the introduction of PBN is a key objective of the Future Airspace Strategy.
This consultation is your opportunity to feed-back your views on our objectives, and on local details that we should take into account in the ongoing design process.
If you wish to discuss the Future Airspace Strategy or the objective of concentrating air traffic please contact the CAA or the Department for Transport.
Is this just Gatwick airport expansion by the backdoor?
No. These changes are intended to make the operation of Gatwick’s runway more efficient, reducing delay, fuel burn and emissions while managing noise more effectively for local communities. Runway usage for a single runway operation such as at Gatwick requires arrivals and departures to be interleaved – reducing the gap between departures provides no additional benefit to periods when successive departures are naturally split by the need to land an arrival in between.
Based on current demand profiles we would expect this to mean around 2-5 more departures per hour only during periods of high departure demand when the number of departures significantly exceeds arrivals – this is generally in the morning rush only and so does not represent a significant increase in overall traffic. Arrival rates are not altered by this airspace change as this is determined by existing separation minima and balanced by the demand of both arriving and departing traffic (an hour with less departure demand can see more arrivals handled on the single runway operation at Gatwick – as is the case today).
Why are you doing this? Please provide justification.
Aircraft today use very accurate navigation technology and new European legislation requires all member states, including the UK, to revise our airspace to maximise the use of these new technologies. Change is therefore inevitable; our focus in this consultation is on how best to enable that change.
Who will check that the development does what you say it will?
Should the proposal be approved and implemented, NATS and Gatwick Airport will be required to demonstrate to the CAA that the proposals are achieving the target objectives. In accordance with CAP725, NATS and Gatwick Airport will provide reports on the performance of the development against the target objectives in terms of delay, safety and environmental performance based on the first 12 months of operation.
The results of these post-implementation reviews are made available to the public on the CAA website.
For how long will this new airspace design be operational?
Airspace changes have no defined lifespan. If changes are required in the future, they will be introduced following the airspace change and consultation process. This includes any changes required to support the development of new runways; see Part A for details of how future runways would impact this proposal.
Will air traffic controllers be able to cope with rising traffic levels?
Safety is our first priority. The air traffic control system has procedures such that if traffic levels rise to a certain level, restrictions are imposed to stop further aircraft entering the congested area until such time as traffic levels have reduced to manageable levels. This is (in very simple terms) how safe levels of traffic are maintained. These restrictions cause aircraft to be held on the ground, which causes delays to flights. NATS has a good record of reducing delays over recent years. The LAMP project is an example of how NATS, Gatwick and London City Airports are being proactive in order to avoid an increase in delays that will occur if nothing is done now.
What are the legal implications of removing the statutory joining point requirement in order to allow night-time respite options for arrivals?
The airport has powers to issue penalties for non-compliance with any of the statutory noise abatement procedures made under section 78 of the Civil Aviation Act 1982, including the joining point requirement. The Government can also direct the airport to establish, revoke or amend any such penalty scheme. In practice the airport has never had a penalty scheme for non-compliance with the joining point requirement but has monitored and published data in its Flight Performance Reports.
Why have you not presented separate diagrams for the northern runway?
This runway is used when the main runway is out of service for maintenance or due to runway blockages. This runway is approximately 200m north of the main runway.
In the context of this consultation there is no significant difference between operations on the main runway and the contingency runway. This is because:
- The alignment of the northern runway is within the spread of traffic shown in our density plots (see overleaf).
- The northern runway is used as a contingency – this means occasional use at night when the main runway undergoes maintenance. The main runway is used most of the time and therefore flights using the main runway are the vast majority and are the significant contributors to any noise impacts.
- The straight out/straight in portions of any revised procedures on the northern runway will be no different than those in place today. Where there are new alignments for northern runway procedures they adjoin those from the main runway as soon as they have crossed the 200m gap. Therefore the only areas where northern runway procedures have new alignments is covering the 200m gap between the alignments of the northern and main runway extended centreline (ie the track covering the distance between the white and black lines on the map overleaf).
- There are no extant NPRS specifically defined for the northern runway
We therefore refer only to Runway 26 and Runway 08 throughout the consultation document, rather than adding to the complexity by having duplicate maps, data tables and descriptions for Runway 26 main and contingency and RWY08 main and contingency. If we had chosen to add this extra information it would have meant extra complexity to an already complex exercise, whilst presenting no significant new information on potential impact that is not already covered in the maps and data for the main runway.
Whilst we have covered the northern runway in the generic descriptions of operations of each runway direction, it should be noted that we are seeking to implement the procedure changes for both the main and the contingency runways.
However because there are no extant NPRs specifically designed for the northern runways we are not proposing new NPRs for it.
This approach to dealing with the contingency runway is summarised at a high level in footnote 6 on page 5 of the consultation document.
How has air quality been taken into account in the proposal?
Government guidance on airspace change states due to the effects of mixing and dispersion, emissions from aircraft above 1,000ft are unlikely to have a significant impact on local air quality. This is the case with our design options as there are no proposed changes affecting flight paths below 1,000ft. More information
Why is the consultation material complicated?
The management of airspace is a technical subject. This is further complicated by the established methods, specified by the CAA, for measuring and articulating impacts.
GAL has endeavoured to develop a consultation strategy and consultation material that provides the opportunity for stakeholder participation at a number of levels over an extended consultation period.
Firstly, we joined with NATS to present a broad consultation on the areas and likely impacts of the proposed changes (October 2013-Jan 2014). The consultation had maps on a website and generic information about potential noise impact. It asked local communities to identify areas that should be considered in the ongoing design process. There was also detailed technical information available for those that wanted it. This consultation was, however, criticised for being too broad, with not enough specific detail.
The current follow up consultation on specific impacts around the airport built on the initial consultation, providing the additional detail on the specific impacts of options for routes below 4,000ft. The DfT also required that the consultation covered specific details around changes to NPRs and other noise abatement criteria which have a legal basis. In the past, consultations have been legally challenged on the basis of not providing all the relevant information.
We have endeavoured to cover all the elements of interests to stakeholders and the DfT, covering the legal obligations while also keeping the material as accessible as possible. To this end we sought reviews from the CAA on initial drafts which are reflected in the published material. Rather than asking for less the DfT have actually stated that additional detail is required which is added in Appendices.
We appreciate that the topics that we are consulting on are complicated, and that an investment in time is required to fully understand this technical subject area. To this end we are also offering briefings to local community representatives which can help highlight the areas of particular interest to them.
Experience of previous consultations has shown that too broad a consultation is criticised for lack of detail and legal challenges may be threatened, whereas a detailed consultation is criticised for being inaccessible. Whatever level of detail we choose to provide, we recognise that the consultation material can be considered too complicated for some, and not detailed enough for others; however we believe that the consultation strikes the right balance between these viewpoints.
Why haven't you got details of my area in your consultation?
The current consultation is on the specific measures of impacts from aircraft flying below 4,000ft. If your area is not covered by this consultation it means that you would not be covered by these metrics. Note; the current consultation area has been simplified to a parallelogram shape and so some areas within this shape, particularly at its extremities, may also not be covered by these metrics. In either of these cases, please refer to the wider effects of the proposed changes which were covered in our preceding consultation, run between October 2013 and Jan 2014; this covered the potential impacts across a much wider area. This consultation is now closed, but the information relating to it can still be found at www.londonairspaceconsultation.co.uk.
Why aren’t you extending the consultation because of the clarifications and new information you have added since the start?
The consultation period is designed to enable time for stakeholders to be made aware of changes, seek clarifications and form an opinion on the proposed changes.
The corrections to the document and any additional information supplied by GAL for clarification during the consultation are part of the normal engagement cycle expected during a consultation process.
Furthermore, as this is a follow on from the wider consultation undertaken at the turn of the year, the CAA agreed that 8 weeks would be a sufficient time period for consultation as stakeholders across the region have already had 14 weeks of consultation on the subject of this change. By voluntarily providing 12 weeks for the follow on consultation Gatwick Airport is already offering stakeholders an 4 additional weeks over the consultation period agreed with the CAA.
How do the NPR population counts for the proposed options compare to those for narrowed NPRs around the existing routes?
We have not shown population counts for narrowed NPRs for the existing RWY 26 BOGNA and SAM/KENET routes in section 6 of the consultation document, nor for existing RWY 08 BIG/CLN/DVR and LAM routes in Section 7. This is because we are seeking to implement a package including both changed routes and revised NPRs.
Revising the NPRs on the existing routes does not achieve the operational requirements and is therefore not an option we are proposing.
Whilst we are not proposing this we have been asked for the theoretical comparison of narrowed NPRs on today’s routes vs the reduced NPRs on the proposed routes. This is shown in the tables in Appendix G available on the main downloads page.
Would narrower NPRs mean a narrower spread of overflights?
No. The NPR is just a way of showing where overflights are expected, and a way of monitoring navigational accuracy. The spread of overflights is determined by the technical specification of the route itself – not the NPR.
Having an NPR that accurately matches where aircraft will fly is beneficial because it will minimise the number of locations where a published NPR suggests there is regular overflight where in fact there are few.
Our general questions around NPR definition do not relate to where aircraft would fly, but instead to how best to represent the flight patterns. For example, do stakeholders want NPRs to represent any area that could be overflown, even if it is rarely. In this case some locations may have perceived blight when in fact the noise impact is relatively small. Alternatively an NPR definition that is too tight, so that it only shows the densest area of overflight, may not reflect the effects of overflights to either side.
Will shortened NPRs mean aircraft climb harder and are therefore noisier?
No. The NPR is just a way of showing where overflights are expected, and a way of monitoring navigational accuracy – they would not cause any aircraft to change their climb profile in any way. Shortening the NPRs is proposed only so that the climb performance of modern aircraft is accurately reflected. Having excessively long NPRs based on historical aircraft climb performance simply means that some areas may fall within the end of the NPR which in fact have no overflights below 4000ft – and may therefore be perceived to have more noise blight than is true in reality.
Will planes be closer together because of this change and the introduction of PBN?
PBN does not change the standard separation rules in controlled airspace above London and the South East; these are and will remain 3 nautical miles of horizontal separation or 1,000 feet of vertical separation.
Will it be safe?
Our first priority is safety. The proposals are being designed in accordance with all applicable safety standards and will be assessed by the CAA for their suitability prior to implementation.
Are the current flight paths unsafe?
No, we have one of the best safety records in the world. Safety is our number one priority in the current operation. Flights will be delayed from entering the system if controllers believe there is any threat to systems safety.