LADACAN’s advice

We are still formulating our response to the consultation, a process which is being hindered by NATS’ apparent reluctance to clarify its proposals.

However, we believe there are a number of objections to the proposals which can already be made. There is no “one size fits all” response as individual circumstances vary enormously but we hope you will find some of the following points worth making even if, overall, you are inclined to support NATS’ proposals.

We will be adding to and modifying this list so, if you have not yet responded to the consultation, please check back to see how our thoughts are developing.

Air traffic growth

NATS’ objective in proposing these changes is to allow for more air traffic over all of us. This will impact our quality of life and particularly the few tranquil areas in this crowded part of the country.

Shifting noise disturbance

The proposals for Luton move most of the aircraft noise from some areas to others. The claimed net reductions in numbers of people overflown are small compared with the numbers to be newly overflown and are probably illusory: greater reductions could probably be achieved by applying the mandatory ceiling of 4,000 feet to the current Luton Noise Preferential Routes (NPRs) and long-planned new housing at Stevenage will negate the claimed reductions.

The situation at Luton contrasts strongly with the impacts around the other large airports in the area. While the population to be newly overflown by departures from Heathrow is equivalent to 4 per cent of the population currently overflown and that for Stansted 5 per cent, a massive 50,000 people or 66 per cent of the current population overflown by Luton traffic will experience aircraft overhead for the first time.

Such a massive change is contrary to the DfT guidance to CAA which (para 35) "recognises the importance of the long-term stability of the route structure in the vicinity of airports". It is also unfair that those threatened by the proposal have not been informed directly and that the consultation publicity and process have been inadequate (see below).

Absence of proposals for mitigation

Despite making proposals which will impose aircraft noise on large numbers of people who have not previously been overflown at low altitudes and will increase the noise experienced by many more, NATS has failed to include measures which would mitigate the impact on the quality of life. Such measures must include limited hours of operation, particularly at night, stringent aircraft noise abatement procedures, schemes for providing noise insulation grants and financial compensation for loss of property values.

Access to the consultation process

The general public has, in effect, only one means of access to the consultation: the Internet. This is only usable by those with broadband. The alternative access through libraries has proved very unreliable and the numbers of feedback forms provided is derisory.

The publicity surrounding the consultation has been totally inadequate and positively misleading. Piles of leaflets have been dumped on Parish Councils who usually have no means of distributing them and Councils have been supplied with leaflets for areas in which their residents will have no interest.

Counts of populations overflown

Although few details of these calculations are provided by NATS, it appears that these counts are too simple to have any value in assessing the overall noise impact of the planned or existing routes insofar as they appear to include no weighting for air traffic volumes or for the typical altitude of overflying aircraft. To design flight paths over heavily populated areas based on such unsophisticated metrics is grossly irresponsible.

Application of P-RNAV

PR-NAV technology should not be blindly applied in such a heavily populated area as that surrounding Luton. The consequences of the PR-NAV design constraints for the areas to the ends of the runways, which may be inherent in the technology, are unacceptable.

Page archived 20 June 2008- no further updates

Luton & District Association for the Control of Aircraft Noise - site updated 06 July, 2008