NATS recently responded to our last newsletter about Fair & Equitable Dispersal. I'd encourage you to read both their message, and our reply above it, sent on Friday.
I think this is the first time a discussion has taken place with NATS in such a public forum and despite the criticisms they make in their message, I greatly welcome the opportunity they have created for such public debate. When we started way back in 2014 we had trouble getting an email answered; now they're in the room in every sense and that can only be welcomed.
Our mission statement, as above, has been unchanged on our website for a very, very long time.
Everything we do has one single aim: improving airspace use in line with our statement.
It is my mantra at all times and this discussion is a part of that.
Thank you for your recent email, copied in full below.
Our newsletter very deliberately referred only to NATS and not you or the NMB. Everyone recognises the considerable input you personally have made. I am very happy to make that clear and apologise if you felt this was a personal affront to you. I look forward to making this clear face to face.
There was and is a very clear gentleman's agreement that the contact details of officers at NATS were not widely distributed (apart from the CEO's, which is already in the public domain) and we have rigidly stuck by that. However you have chosen to open this dialogue with your response to our newsletter by copying in the NMB and we greatly welcome this opportunity for open, direct communication with NATS, to be published widely, as you request. We have previously offered our substantial communication platform for NATS and other industry bodies and that offer is repeated now. We are also copying in Tom Tugendhat MP in this reply.
You suggest in your email that communities should be appreciative of the work NATS has done, and you emphasise the importance of constructive working relationships.
Communications and constructive working relationships are indeed vital. As you recognise, we at GON have attended numerous industry meetings over the last 18 months covering a great range of topics and we remain ready to do so, even though we, unlike you and your colleagues, receive no remuneration for doing so.
Before addressing some of the detail we think it's important to remind ourselves why we're having this discussion at all.
Some time in early 2013 NATS and Gatwick, with the CAA's acquiescence, decided to increase the minimum ILS join point and to narrow the permissible range of joining points. The motivations for this remain disputed, but what we do know is:
- the data used to support and defend the joining point changes, specifically on go-arounds due to unstable approaches, was unreliable, subjective and unaudited. It did not, in our view, provide a sound basis for the decision that was taken;
- there was no consultation, indeed no thought at all seems to have been given to the impact on communities in the affected area. Indeed, since then, the industry has talked of "unintended consequences";
- the changes made ignored government policy in several respects: they resulted in significant over-flight of the most densely populated areas of west Kent and they caused more people to be significantly affected by aircraft noise than previously. That also appears not to have been considered in your decision-making;
- in any event the result was that tens of thousands of people have been, and continue to be, severely impacted by prolonged, intensive, aircraft noise.
In any other industry these failings could have been addressed through regulation and legal process. But aviation is of course exempt from relevant legal action and regulation of the sector is ineffective. Only overwhelming public and parliamentary pressure, including the JR process, has brought the industry to the table and achieved the limited change we have seen to date. But even now, four years on, we haven't seen any sign of formal remorse or regret from NATS, let alone an apology for the blight inflicted on communities.
So, I hope you'll understand why, although we're in favour of constructive working relationships, we don't feel the need for very much appreciation. NATS and its partners in the industry created the issues communities are suffering from; you can hardly expect overwhelming gratitude when you partially address some of them.
You say our newsletter was "disappointing" in several respects. "Disappointing" is one of the mildest words we hear used to describe the industry's efforts since 2013.
Let's turn to what NATS - and the rest of the industry - has and has not done. We acknowledge that, over the quieter winter months, progress was made in dispersing ILS_joining points_ as shown by the diagram in your email. Of course, we welcome any progress towards achieving the goals we've defined. But even in this narrow respect the position is disappointing. The diagram below, taken from the same source as yours, shows that peak ILS join point concentration in 2011 was 10%. The best you've achieved so far in 2016/17 (from the data currently available to us) is 13%, a reduction from 2015 but a 30% increase in peak aircraft concentration since 2011.
Regrettably, however, as we've now all come to realise, and we think you accept, improved ILS joining point dispersal does not necessarily mean substantially improved dispersal across the rest of the RMA: aircraft can still be concentrated in the approach swathe and then disperse as they join the ILS. So, for example, Helios' data shows that peak concentration along the East Grinstead to Tunbridge Wells gate was 33% higher in 2016 than 2011.
Addressing this wider concentration is where we feel that NATS' performance has been disappointing. Our consistent aim, and the commitment made by the industry in the Arrivals Review, is clear:
"The intended impact of this action [IMM:10] is to recreate a greater geographical dispersal of arriving aircraft tracks, so that they are more closely aligned with the arrivals tracks which existed at Gatwick prior to 2013. The benefit is expected to be a reduced concentration of arriving aircraft in the swathe, prior to joining the final approach track, supporting the fairer and more equitable dispersal of aircraft sought by many communities."
For many months NATS seemed to interpret its responsibilities under this part of the Final Action Plan as being limited to changing the permitted ILS joining point and some associated awareness raising. But what's always been required and expected is the achievement of the outcome set out in the review, as above and more recently quantified by the community groups. It seems to us to have taken much too long for NATS to grasp the fact that more was needed and to commit to doing it. At NATS' request, we the community noise groups, have sought to define FED for you, only for it to be repeatedly rejected. While we welcome every opportunity for input of course, we are not the airspace professionals and always found it a little bizarre that this critical responsibility was left entirely to us. We believe NATS could be a lot more proactive in working with us in defining fair and equitable dispersal.
More recently, we agree, there has been a more positive approach. But even now the industry's collective approach is hedged around with preconditions and caveats. The starting point seems to be that some of the factors identified as being responsible for concentration are givens, for example higher volumes of aircraft and more larger aircraft. We don't agree. You and your industry colleagues can of course presume that industry interests should always take precedence over community interests, but that is a choice not an inevitability. The concept of trade offs between noise impacts and industry profit maximization seems to be one you, GAL and your industry partners don't yet acknowledge, and which DfTis unwilling to assert. You also seem to regard the dispersal of aircraft as being largely out of your control, driven by externalities and uncontrollable factors.
Again, we don't agree. We believe the nature and extent of dispersal is very largely determined by employees of the industry, both NATS controllers and those who decide on scheduling and traffic volumes. If the industry wished, the pre-2013 traffic patterns could be almost wholly replicated now.
This brings us to two final points, including the one highlighted in our newsletter. First, we remain surprised that NATS isn't doing much more to understand why the extent of dispersal varies so significantly over time. On several occasions, at what seem to be busy times, you manage to achieve degrees of dispersal consistent with the targets we've proposed. But these are then followed by wholly unacceptable periods of concentration. We would like to see you do far more to understand why this happens and to seek to replicate the conditions that enable the former and discourage the latter. It's a surprise that you are no longer receiving dispersal data from GAL/Helios, but equally surprising, and disappointing, that you haven't insisted on it: one implication is that you're not serious about achieving the targets we've proposed: things that aren't measured certainly aren't managed.
Finally, and these points may be linked, we don't understand why you are not doing more to influence controller behaviour in terms of swathe dispersal. NATS has gone to extraordinary lengths to enable Gatwick to achieve world record throughout; we believe it should go to equally extraordinary lengths to achieve more acceptable dispersal of aircraft, as pledged. We are not convinced that is happening or even that you accept that it's your responsibility to do so: offering "help and advice from a technical ATC perspective" simply isn't enough.
If you can now confirm that NATS has instructed its Air Traffic Controllers to proactively engage with full dispersal over the arrivals swathe we would be absolutely delighted and would immediately amend any assertion that NATS has failed to instruct its ATCs to fully engage with FED.
As I've said on many occasions, until NATS do so, we cannot see how they can possibly hope to achieve the pledge "to recreate a greater geographical dispersal of arriving aircraft tracks, so that they are more closely aligned with the arrivals tracks which existed at Gatwick prior to 2013…"
We are more than happy to meet to discuss any of these points, either one-to-one or in a wider context, be that at NATS or elsewhere, now or later. We absolutely believe in constructive engagement and look forward to fully engaging with the 2017 work plan. We also look forward to changing the tone of our newsletters when it becomes clear that NATS accept their critical responsibility to fully engage with the Arrivals Review Final Action Plan overarching purpose, which was to examine whether:
"Everything that can reasonably be done to alleviate the problems which local communities are raising is in fact being done, whether this involves action by the airport or by other parties most closely involved - National Air Traffic Services (NATS), UK Civil Aviation Authority (CAA), Department for Transport (DfT), Air Navigation Solutions (ANS) the tower air traffic provider, or the airlines;"
In other words, doing everything NATS can to reduce the impact of their operations on our communities, including by achieving the targets we've proposed.
Gatwick Obviously Not
From: JOPSON, Ian
Sent: Wed, 19 Jul 2017 14:15
Subject: GON's 'Hot & Bothered?' Newsletter
Dear Martin, (cc members of the Gatwick Noise Management Board)
I was recently sent a copy of GON's 'Hot & bothered?' e-newsletter about Fair and Equitable Dispersal (FED). I have to say that my colleagues and I were rather disappointed with the tone of the newsletter and some of the content which I believe is misleading. With this in mind NATS felt that we should write to you about this and I would appreciate it if you could share the response below with your GON members.
As you are well aware from your participation at the Gatwick Noise Management Board (NMB) we have been working intensively with air traffic controllers at Swanwick to inform them about the IMM-10 trial, including individual briefings to all controllers making them aware of the impact of the arrivals swathe on communities, and its subsequent permanent status. This work included close engagement with the CAA's Safety Regulation Group during all stages over the 9 month trial period. Indeed, NATS provided a paper about this to the Noise Management Board (NMB/3) last November (I have attached that paper to this email). The minutes from that meeting record this as below:
'12. NMB/2 Action 7 Briefing of Controller Instructions related to IMM–10 implementation and CAA conditions. a. IP–05 provided to NMB/3, incorporated the required information. Action Closed'
In addition to the numerous briefings detailed in the paper I presented to the NMB, during the trial we received IMM-10 performance data on a monthly basis, passing this information to the Operations teams at Swanwick including General Managers, Deputy General Managers, Watch Supervisors and Deputy Supervisors and other teams. NATS will continue to monitor performance as long as we are requested to, although I do note that now the trial is complete we are no longer receiving that data feed from Gatwick/Helios. It may be that GON via the NMB would like to request that the data continues to be analysed and if so I would be happy to ensure it continues to be sent to NATS operational teams so they can monitor their performance
NATS would also like to correct what GON's e-newsletter says about the achievement of FED to date. You will have seen the most recent data from Helios and this clearly shows a significant shift in aircraft joining positions, and this current dispersion of traffic more closely emulates that of 2013 than prior to the implementation of IMM-10. The chart below shows what has been achieved since IMM–10 was introduced in August 2016.
I think that we all agree that there is more to be done to further improve FED and NATS are working with NMB to explore the best ways of achieving this. Indeed, you and a number of other community groups have been present at working group meetings and workshops with NATS and Gatwick teams during and since the IMM-10 trial. My recollection is that you were also present at the most recent of those meetings, where NATS presented the results of an internal review of options to further influence the distribution of the aircraft in the arrival swathe (the 'NATS Matrix on FED Options'). At this same meeting we also discussed at length why there has been a drop in the number of straight in approaches to runway 26, as a consequence of the TIMBA STAR change in February 2016. I had thought that there was a general feeling at that meeting that community groups were appreciative of the work that we had done to evaluate options, but this does not seem to be reflected at all in your newsletter.
You will know that NMB/7 will be finalising its annual work plan and that FED is a key part of this. To inform that NATS are holding internal workshops to explore in further details the NATS Matrix on FED options.
In accordance with the NMB's code of conduct, the approach of the NATS team throughout the discussions to mitigate the impacts of aircraft noise on local communities has, I believe, been wholly constructive. We have tried to listen, understand community perspectives and offer help and advice from a technical air traffic control perspective. I do not think that it is helpful to circulate statements among your members that are, in my view, factually incorrect – claiming that 'they [NATS] have not asked their Air Traffic Controllers to do so'. The implication here is that NATS has not done anything to support the FED solutions. Such statements can serve to undermine the constructive working relationship that I had thought we have built. I hope you will recognise and accept this, and continue to work with NATS and other NMB members in a more constructive manner.
Head of Environmental & Community Affairs