This open letter has been sent to the Chair of the CAA today, partly in response to the deluge of messages we are receiving about the narrowed flight paths, from all quarters of the south-east.
Gatwick Obviously Not.org
Dame Deirdre Hutton CBE
CAA House, 45-59 Kingsway
London WC2B 6TE
May 29th 2015
By post & email
Dear Dame Deirdre
Hear our Words.
Let there be no misunderstanding; there is a surging, unstoppable* sense of fury, despair and frustration from thousands of people because of the intolerable and unjustified changes the CAA have allowed in the airspace to the east of Gatwick, a fury only intensified by the recent stonewalling response from them and others in the aviation chumocracy.
In less than a week around 1,000 people have responded to our suggestion they respond to the very recent Air Quality Consultation from the Airports Commission.
This demonstrates our reach, their concern, and your need to listen.
As I will demonstrate below, the CAA can no longer object to the reversion to a broad arrivals swathe on the grounds of Go-arounds, the implementation of technology or Government policy.
This open letter is a polite request for you to hear our words, and kindly respond.
But first, here are some of yours:-
'…the trials to test FAS and changes to airspace have raised very considerable concerns from those being overflown and it would be no exaggeration to say that in the last six months I have received thousands and thousands of letters, emails and tweets from the general public. These have highlighted how important it is to consider the views of all stakeholders.'
'…we believe that new capacity will be facilitated most effectively by strong community engagement, a sharp focus on noise nuisance and a legally binding and comprehensive compensation and mitigation package.
We have a once in a generation opportunity to expand capacity. We must not lose it because of a failure to recognise the perfectly legitimate needs of those who live their lives under a flight path.'
'…there must be new thought on how airspace change is delivered and we look to industry not only to commit itself to taking airspace change forward, but also to commit itself to thinking about HOW the change is taken forward in a way that respects the right of third parties who are affected in a range of ways by the activities of aviation.'
(Your bold. Speech to the Aviation Club Lunch, 11th February 2015. Full script available here (PDF - 258kb) and on our website).
You speak of a need for 'strong community engagement' and 'recognising the perfectly legitimate needs of those who live their lives under a flight path'
I'm ready. Dialogue is inevitable so let's make it sooner rather than later. I can disseminate your message to the thousands instantly.
Actions speak louder than words, and your silence is almost as deafening as the planes.
Below, I'd like to discuss your public reason for narrowing the swathe, the potential (mis)use of technology and persuade you of the fast-growing opposition to the changes - both in place and proposed.
1. Why was the swathe allowed to be narrowed?
Narrowing the point at which the arrivals swathe to the east of Gatwick Airport joins the final approach path ('ILS') by a devastating 60% (from 7-12 nautical miles to 10-12nm's) has deeply affected thousands of people's lives. How do I know? They write to me and say so, sometimes copying you in, as you'll have noticed.
Compressing so many flights into such a concentrated area (without any consultation) then thrusting them below the departure routes east at the same time has naturally forced a huge and increasing quantity of aircraft into a tiny amount of airspace, and cumulatively nearer the ground than ever before.
Quart and pint pot come to mind.
Only this morning it has been extensively reported that an Aer Lingus A320 flew over Bidborough at 2,844 feet (21.10.56 hrs, 28th May), some 18 miles from touchdown.
Why stoke the fury by permitting such behaviour?
Your rationale for so heinously affecting so many lives does not stand up to scrutiny on 2 specific issues:
i. You say it was to reduce Go-Arounds (aborted landings) caused by 'Air Traffic Control induced rushed and potentially unstable approaches'.
"Since 2013, NERL's operational procedures have involved moving the minimum establishment point from 7 nautical miles to 10 nautical miles on both approaches. The reason for doing this was to minimise the potential for ATC-induced rushed and potentially unstable approaches, which may result in a missed approach ('Go-Around')… " 28th April 2015
However, we say it was to demonstrate that there is air space capacity for a 2nd runway, noting of course your bold view that 'We have a once in a generation opportunity to expand capacity'
There is no metric we can find in the official data for 'rushed and potentially' unstable approaches (only unstable approaches themselves), consequently we can only look to the quantity of overall Go-arounds reported.
And the core fact is Go-arounds overall have increased since the swathe was narrowed in 2013.
Let's look at the latest figures for the first 3 months of 2015:
||As a % of flights
||Before/after swathe narrowing
The 12 year average is 0.34%
The word we want you to hear on this is Proportionality.
Even if the CAA had managed to reduce the amount of Go-arounds to bring that figure nearer the 12 year average (that average itself dragged higher by the post-narrowing 2014 figures), even if the CAA had managed to dip below the average, the proportionally devastating effect on tens of thousands overflown far outweighs the infinitesimally small percentile difference in Go-arounds.
ii. Buried very deep in Annex 3 of the 'NATS Support to the Airports Commission - Appraisal Module 14: Operational Efficiency: Airspace Efficiency Report' document (discovered by our friends at GACC) is this map of 'indicative arrival and departure paths' for the 2nd runway.
The join point for the new runway is shown to be near Dormansland, only some 6.95 nm from Gatwick Airport. See our red arrow.
How can you say with any credibility that the present join point has been moved to beyond 10nm's to reduce Go-arounds, then allow your chums at NATS to indicate a join point at 6.95nm's for the 2nd runway? Doing so completely destroys the Go-around explanation.
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/371854/14-operational-efficiency-airspace.pdf page 39
Finally, on this point, please don't let anyone hide behind the Government's aviation policy which as you probably know is:
'to limit and, where possible, reduce the number of people in the UK significantly affected by aircraft noise'
Narrowing the swathe has only served to dramatically increase the number of people significantly affected by aircraft noise and will do so wherever you implement similar changes through out the UK, accompanied no doubt with subsequent storms of protest.
2. The (mis)use of modern technology
We have heard many times that Performance Based Navigation (PR-NAV/PBN) is coming, and we welcome that.
It is the way that it is implemented that is critical.
Stewart Wingate, CEO, Gatwick Airport, wrote this to one of our colleagues on 13th May this year in reference to the area NW of Gatwick:
'…the team are working hard to try to get the flying patterns back to similar patterns as was the case prior to PR-NAV being implemented. In the case that this can't be achieved then we have not ruled out reverting back to using the previous technologies.'
If reversion to previous flying patterns can be achieved in one area, they can technically be achieved in all areas, with or without PR-NAV/PBN.
3. You spoke at the Aviation Club lunch of the 'thousands and thousands of letters, emails and tweets from the general public' you've received.
We're not going anywhere and indeed, as I say in my opening paragraph, the storm is rising. Even NATS admit it, in their unusually frank (perhaps it was meant to be secret?) and relatively acronym-free document 'PBN in a High Density TMA', on page 17:
'Any changes to airspace are challenging, concentration of noise with no agreement as to what 'respite' actually means has created a perfect storm in the South of the UK. Aggrieved communities, record complaint levels and a complex political environment makes moving forward difficult and the industry voice is neither united nor strong enough. '
View the document "PBN in a High Density TMA" (PDF - 1.2Mb)
The phenomenal response we have seen to our request for people to respond to the Air Quality Consultation has come from across a very wide geographic area.
The genie is out of the bottle Dame Deirdre. Thousands are watching the aviation industry's every move because they have lost faith and trust in the regulators and operators.
For just one example you'll have heard that the boss of NATS is to step down. Is this as a consequence of their acutely embarrassing mea culpa to Heathrow in March this year, that they had indeed made changes to the Compton route (having previously denied it), Heathrow's CEO, John Holland-Kaye saying:
"I am very concerned that NATS made this change without informing the airport or affected communities about its potential impact, particularly given its effects on some of the same areas to the west of the airport that were affected by the airspace trials we ran last year. Because of the assurances we received, we in turn told residents in good faith that no changes had occurred. That is unacceptable and I unequivocally apologise to local residents."
"At my request, the Chief Executive of NATS has agreed to urgently review his company's processes to ensure that NATS shares this information with the airport to prevent this happening again in the future."
As you'll know, we at Gatwick Obviously Not raised over £110,000 in less than a week to commission a Judicial Review.
We - and our thousands of supporters - are not going anywhere.
You have an opportunity right now to restore that trust, and restore some tranquillity to our skies.
To bring some proportionality to the debate.
To put people before tax-free profit.
I have chosen not to put your email address on this open letter, which will be seen by thousands, in the hope you will respond and I don't need to raise the literary army of fury, of despair, of frustration to add to the thousands of messages you've already received.
But I fear when the summer schedule gets into full swing no one will be able to stop them if they sense that no-one is listening at the CAA.
Hear Our Words.
And act on yours.
You may send any message directly to me at this address we have created just for you:
*It's down to you