Support to CLSTRP for Heathrow Consultation

FINAL Answers 04/03/2019

1 About this note

Background
London Heathrow airport is currently conducting a public consultation to establish factors
and considerations to be taken into account when redesigning its airspace and operations
as a result the Heathrow expansion project approved by Parliament in 2018. The Central
London Sub-Regional Transport Partnership (CLSRTP) agreed that a collective answer of
7 authorities1 involved in the Partnership would be provided. Element Energy (EE) was
commissioned by CLSRTP to review and summarise the Heathrow consultation
documents, conduct analysis where appropriate, present the findings to the boroughs, and
draft a collective answer to the consultation topics.

Objectives
This note outlines the answers submitted on the portal. They are based on conversations
with boroughs and data provided by council officers. These answers have been submitted
on the consultation portal on the 4th of March 2019 by Element Energy.

Output
The Heathrow consultation covers six main topics as shown below.

• Managing noise at an expanded Heathrow

• Air space design
• Noise respite through runway alternation
• Noise management through runway use directional preference
• Night flights: Early morning arrivals
• Night flights: Other restrictions

Each topic consists of a series of questions. EE coordinated with CLSRTP borough

councils in order to reach a conclusion and answer the questions covered by topics 1 and
3-6. The collated answers to these topics are compiled in the first section of this note. The
collective answers are based on interviews and data provided by the following boroughs:
Kensington and Chelsea, Camden, Lambeth, Lewisham, Southwark, City of Westminster,
and Hackney.

The boroughs of The City of London, Wandsworth and Islington are not part of this
consultation.

The 2nd topic addresses the local factors that should be considered when designing new
air space use procedures. The questions are postcode specific and a collated answer
cannot be provided on the behalf of several boroughs. However, the online questionnaire
allows answers for multiple postcodes; one answer for each borough (mapped as one
unique postcode) will be provided. During the initial conversation, the relevant postcodes
for each borough were agreed. Borough-specific answers to address this topic are
provided in the second section of this note.

1The Royal Borough of Kensington and Chelsea, The London Borough of Lambeth, The London
Borough of Lewisham, The London Borough of Southwark, The London Borough of Camden,
Hackney, and City of Westminster

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2 Proposed joint answer to Heathrow Airspace and Future

Operations Consultation
In this section the joint answer was derived from the consultation with Central London
borough officers. Answers are grouped in sections (2.1, 2.2, etc.), each representing a
consultation topic. Each section starts with a short description of the consultation topic
(italicised) as provided in the Heathrow Consultation Questionnaire. This is followed by the
relevant questions (in bold). Joint answers are provided under each question and are
printed in blue.

2.1 Managing noise for an expanded Heathrow

We appreciate that local communities are concerned about the proposed expansion of
Heathrow and its potential noise effects. Whilst noise has reduced over recent decades,
we know we need to continue to make it a priority.

The Government has to make sure that ‘noise objectives’ are set for certain airports where
noise might be a problem. We have been engaging with the Government on the
development of proposals for a noise objective for Heathrow. Although it is for the
Government to set the noise objective, we are consulting on a proposal for the
Government to consider. Our proposed noise objective is as follows:

To limit and, where possible, reduce the effects of noise on health and quality of life and
deliver regular breaks from scheduled flights for our communities during the day and night.
We need to do this whilst making sure the measures we put in place are proportionate and
cost effective.

1a. Do you support our proposals for a noise objective?

• Yes
• No
• I don't know

1b. Please provide any comments you have on our proposals for a noise objective:

The answers provided to this survey are on behalf of 7 Central London Boroughs (The
Royal Borough of Kensington and Chelsea, The London Borough of Lambeth, The London
Borough of Lewisham, The London Borough of Southwark, The London Borough of
Camden, Hackney, and City of Westminster), part of the CLSRTP, but excluding The City
of London, Wandsworth and Islington who will submit a separate answer.

The general opinion of the CLSRTP Boroughs was that they have previously opposed the
Heathrow expansion, with some (e.g. Lewisham, Lambeth, Southwark) supporting the
expansion of Gatwick Airport. However, given that it was decided to expand Heathrow
instead, boroughs appreciate that Heathrow is putting in place noise objectives for
Government’s approval, as noise is an important issue for the residents of all boroughs
who may live under the aircraft flight paths. However, boroughs disagree with the
proposed objective as they feel that the proposed objective is too weak and generic and
insufficiently protective of residents. It offers no actual targets or measurable goals, being
significantly less strong than the general aims in the Noise Policy Statement for England.
Boroughs agree with the principle of having a noise objective, however a more robust
proposal is needed. This could be based on a strong commitment to avoid significant
adverse effects, minimise other adverse effects, and seek every possible opportunity to
reduce impacts from noise rather than just a weak unspecific aim to ‘limit’ effects. Specific

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measurable goals should be included, such as an aim to move as quickly as possible

towards the 2018 WHO Environmental Noise Guidelines for Europe, which strongly
recommend reducing aircraft noise to below 45dB LDEN and 40dB at night. Thus, a
stronger noise objective should be implemented at Heathrow in order to achieve these
noise targets as quickly as is reasonably practicable. Boroughs strongly recommend that
the proposed noise objectives will be included in statutory legislation, with clear penalties
for any measures not implemented and any noise emissions above the limits.

Specific details provided for each borough are provided under the Air space design topic.

1c. Please provide any other comments or suggestions you have on our proposed
approach to developing a package of noise measures for an expanded Heathrow:

Field left blank

2.2 Respite through runway and airspace alternation

With expansion we will be able to provide respite to communities affected by aircraft noise
in two ways:

• By alternating our runways, we will provide respite for those living closer to the
airport; and
• By alternating our airspace, we will provide respite for those living further away.

Respite means predictable relief from aircraft noise for a period of time. Airspace
alternation is not currently possible but with expansion we have the opportunity to provide
respite for communities further away from the airport that do not receive any respite today.
We want your feedback on two options for the delivery of respite to local communities
using our runway alternation pattern.

• Option 1: A pattern that delivers longer periods of respite, less often - For
example, we could use each operational pattern for a whole day, then move to a
different operating pattern each subsequent day. This would mean that
communities would get a whole day of respite every few days, but have
consecutive days of overflight (during the operational day) with no respite.
• Option 2: A pattern that delivers shorter periods of respite, more often - We could
use each of the four runway operating patterns during the day which would mean
that each community would have 4-5 hours respite every day. It is not possible for
every community to have longer periods of respite, every day.

2a. 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? Please tick one of the following options:

• A longer period of respite, but not every day

• A shorter period of respite every day
• I don't know

2b. Please tell us the reasons for your preference:

The view of the CLSRTP boroughs is “I don’t know” since such a question would impact
the general population of the boroughs and a preference in terms of the time length and
frequency of the respite periods cannot be established by the local councils. It is thus
advisable that the Heathrow Consultation uses the feedback provided by the residents to
answer this question. However, several councils noted that although they could not

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express any preference, it is generally accepted that any respite implemented must be
predictable, such that residents can plan their daily lives accordingly. Boroughs also
appreciate this question and acknowledge the importance that any future runway and
airspace alternation patterns must be fair and be built on the noise-sharing principle.

It must be noted that some boroughs (Southwark, Lambeth and Lewisham) thought that
runways should be alternated several times a day (second option) as this is in line with the
current Heathrow operations (although in the future there will be several additional
patterns and runway swaps per day), to which residents are already accustomed.

2c. Please provide any other comments or suggestions you have on runway and
airspace alternation:

One general common concern across all boroughs and their residents is about the
concentration of aircraft routes in a small section of the airspace, meaning that small
communities are overflown by a very large number of aircraft, particularly in South East
London (Southwark, Lewisham, and Lambeth) during the initial approach phase, when the
aircraft are turning towards Heathrow. This is seen unfair for the residents, who demand
that the air routes are revised, covering a wider range of airspace and providing respite
and relief to the affected communities. Measures to widen the air corridors and alternate
their usage should be implemented as part of the airspace alternation process.

2.3 Directional preference

With expansion, we want to use directional preference to manage noise. We have been
testing whether this means we should change the 'westerly preference' that is in place at
Heathrow during the day today. Our current thinking is that we should adopt a managed
preference which can adapt to circumstances over time.

Our work so far demonstrates that if we managed the preference with the objective of
minimising the total number of people affected by noise, this would mean requiring aircraft
to operate following on westerly operations during the day and easterly operations at night,
where there is a choice.

However, we also acknowledge that people value breaks from a certain operating
direction, and would like us to avoid extended periods where Heathrow flight paths overlap
with routes from other airports. This is why we are considering a managed preference so
that we could respond to extended periods of operations in one direction by intervening to
operate in the other direction to provide relief.

3a. 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?

• Yes
• No
• I don't know

3b. Please tell us the reasons for your answer

In general, the CLSRTP boroughs agree with the idea of making noise exposure fair and
with noise sharing mechanisms highlighted in the proposed “Managed Preference”
approach, however given their location East of the airport, boroughs feel like they would
rather avoid westerly operations (i.e. flights over Central London) if possible and when
wind permits. However, boroughs recognise that other communities, closer to the airport,
would be more affected by operations in any directional preference, and thus the
consultation should take into account the whole set of responses to this questionnaire.

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3c. 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?

Yes / No / I don't know

3d. Please tell us the reasons for your answer

In general, the CLSRTP boroughs agree that residents should be exposed to noise in a
fair way. Thus, providing relief to local communities affected by prolonged periods of
operating in one direction is in line with consensus. However, it is unclear how often such
an intervention would be implemented and where the people included in the “this means
slightly increasing the number of people affected by noise” would be geographically
located. More clarity in further documents would be welcomed, as the consultation does
not provide enough information, preventing a more detailed answer to this question.

3e. Please provide any other comments or suggestions you have on directional
preference:

Southwark put forward a preference for Easterly operations before 7am where possible in
order to reduce noise from early morning arrivals over densely populated South London.

The boroughs of Lewisham and Southwark pointed out that the implemented managed
preference is promising to address the interaction of Heathrow traffic flow with that of other
London airports, notably London City Airport (LCY), which is known to have negative
impacts on their residents. As an example, Forest Hill residents within Lewisham complain
of constant noise levels from aircraft flying to low on approach to LCY as they are forced to
do so due to passing traffic (at higher flight levels) inbound to Heathrow. Other areas
negatively impacted by LCY aircraft, include: the Brockley and Telegraph Hill areas within
Lewisham and Dulwich, Camberwell, Surrey Quays, Canada Water, and the Rotherhithe
Areas, all located in Southwark

Although the consultation text is unclear about the implemented measures to reduce noise
impacts from other traffic flows, Boroughs are recommending that the managed operations
will determine Heathrow arrivals to fly higher than currently around South East London,
thus allowing LCY-bound aircraft not to overfly the neighbourhood at such low altitudes.

A report pointing out the issue was published as part of the HACAN project and can be
found here: https://hacan.org.uk/4422-2/

2.4 Night flights - Early morning arrivals

For an expanded Heathrow with three runways, we are looking at opportunities to
schedule these early morning arrivals later, to provide a longer time without flights at night.

We still need to maintain the same number of pre-6am arrivals as we currently have, but
our aim is to start our operation later than today. This will mean we need to narrow the
window within which these flights land.

We want to know whether you would prefer us to use one runway for scheduled arrivals
from 5.30am (runway time of 5.15am - affecting fewer people), or two runways for
scheduled arrivals from the slightly later time of 5.45am (runway time of 5.30am - affecting
more people than the previous option).

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4a. To help inform our consideration of the options 2, 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)
• I don't know

4b. Please tell us the reasons for your preference:

The views of the CLSRTP boroughs on this question are widespread and it is
recommended that the Heathrow consultation follows the feedback provided by the
residents.

Several local views are presented below, but the general consensus is that both options
are not good enough, as neither provides enough respite to residents. A total 8-hour night
flight ban (23.00-07.00) should be implemented, and if such a ban is not possible,
boroughs would wish to delay the earliest arrivals for as long as possible.

For any period and timings when night flights are permitted, a total ban should be imposed
on all but the quietest aircraft so that it is highly restrictive which types of aircraft can land
in the night period.

Regarding the answers to the question, on one hand, boroughs under the final approach
path, when the aircraft is aligned with the runway heading feel like the first option would be
better since residents under the approach path of one runway would get a respite 2 out of
3 days and believe that a 15 min difference would not make a significant difference.

On the other hand, Lewisham, Southwark, and Lambeth (boroughs over which the aircraft
turn before establishing on the final approach path) are directly affected by aircraft
regardless which and how many runways are operated at any given time, since the same
turning procedure is used by multiple runways. As a result, these boroughs prefer the
second option as this would give 15 additional minutes of sleep to their residents before
the potential disturbance from overflying aircraft. This would also mean that the issues
associated with the disturbance will not be concentrated along one runway. In addition,
morning arrival routes, especially during the initial approach, should be dispersed as much
as possible, providing respite to communities.

The borough of Hackney have not expressed any view on this question, however they
noted they would follow the general consensus of the group.

4c. Please provide any other comments or suggestions you might have on early
morning arrivals:

Several boroughs also expressed views that morning arrivals would not be preferred at all.
Arrivals before 6am over South London are considered to have an unreasonable impact
on residents. However, since this is not part of the Heathrow proposal, it is viewed that
Heathrow should require airlines to operate quieter and newer aircraft for morning arrivals.

In addition, boroughs proposed that since the air traffic is not that congested in the early
mornings, Heathrow could have in place special procedures in which holding traffic (before
being allowed to commence the final approach) would be held in stacks at a different

2 Please note the exact times are subject to further evaluation of the options.

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location away from populated areas. At the same time, morning procedures could involve
higher overfly altitudes and steeper final approach descents (if allowed by aircraft
performance and safety standards) such that the impact to the sleeping population is
minimised. For any period and timings when night flights are permitted, a total ban should
be imposed on all but the quietest aircraft so that it is highly restrictive which types of
aircraft can land in the night period.

2.5 Night flights - Other night restrictions

A number of restrictions already exist for how we manage flights at night at the airport. In
this section we’re asking for your feedback on how late running flights are managed in the
evening after 11.00pm.

During the night period (outside of the proposed scheduled night flight ban) we are looking
to further encourage the use of the quietest types of aircraft with the following measures:

• A night quota system

• Restrictions on the most noisy aircraft
• Higher landing charges at night
• Higher charges for noisier aircraft

5a. 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):

In addition to the currently implemented lower landing fees, Heathrow could expand this
strategy more aggressively to late night departures and morning arrivals. During these
periods, the fees for quieter aircraft would be significantly lower than during the day, whilst
noisy aircraft would face elevated fees compared to day levels. Alternatively, an outright
ban on noisy aircraft or a much-enhanced quota count system would be preferred at night.

5b. Please provide any other comments you have on night flights and restrictions:

Boroughs suggested that alternative departure routes for flights operating during the
recovery period should be implemented, with the aim to avoid noise exposure to densely
populated areas. However, if this cannot be implemented, future airspace designs should
avoid over-concentrating flight paths over small geographic areas and disperse flight
routes.

3 Postcode-specific answers for each borough answering

the consultation
This section provides information about the local factors that must be considered when
designing the airspace changes due to the construction of the third runway and the
implementation of the Independent Parallel Approach (IPA) procedures. For each borough
a given postcode will be used to pinpoint the boroughs on the map. The postcode is either
central or a location where local noise-sensitive factors have been identified; the postcode
choice was validated with each Borough.

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The description of this section of the questionaire and the mapping tool is provided below.
Element Energy encouraged boroughs to try the online mapping tool and determine if any
additional factors should be included in the submited answer.

The postcode map tool below presents the geographic areas within which flight paths
could be positioned in the future – both for expansion, and to make better use of our
existing runways, through use of Independent Parallel Approaches (IPA). These areas are
known as design envelopes.

Once you have entered a postcode or area of interest to you, the design envelope(s)
which your location falls within will be presented, along with information on the number,
height and noise of potential flights over this area, to give you an understanding of the
potential impact of flights.

To help us design new flight paths we want to know whether there are any sites or
locations that you think require special consideration by us in determining where future
flight paths should be.

Please describe the special characteristics of these locations, stating why they would be
sensitive to flights overhead. For example, this could be because they would be sensitive
to noise or visual impacts associated with flights overhead.

You may be in more than one design envelope. Where this is the case the airspace design
will seek to ensure flight paths within different envelopes would not be in use over the
same area at the same time. This means that the ‘number of flights’ figure given alongside
each design envelope should be considered individually and not added together, unless
stated otherwise.

The associated questions include:

What sites or local factors should we be aware of in your area (or other area of interest to
you), when designing flight paths for an expanded three-runway Heathrow?

What sites or local factors should we be aware of in your area (or other area of interest to
you), when designing new arrival flight paths to make better use of our existing two
runways?

The table below shows the number of flights above 65 decibels (60dB is the noise intensity
of a conversation) that will be overflying the postcode within an hour (during operation
hours, not at night). A1-A4, D1-D2, and I1-I2 refer to future airspace design envelopes
related to arrivals, departures, and the independent parallel approach procedures. Note
that not all envelopes apply to the same geographic location.

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Table 1: Overview of flights above 65 dB overflying locations in each borough

Number of flights above 65 decibels per hour
Departure Two runway arrivals
Borough Post code Landmark Arrivals expansion
expansion with IPA
A1 A2 A3 A4 D1 D2 I1 I2
Camden NW1 8QL Camdem Town Tube Station 0- 1 0 - 32 - - - 0 - 17 0- 3 -
City of London EC3V 3LA Bank Tube Station 0- 1 0- 1 - - - 0 - 17 - -
Hackney E8 1FD Hackney Downs Train Station 0 0- 1 - - - 0 - 17 - -
Lambeth SW9 8HE Brixton Tube Station - - 0 - 32 0- 1 - 0 - 17 - -
Lewisham SE6 4RU Lewisham Town Hall - - 0- 1 0 - 0 - 17 -
Kensington and Chelsea W8 5SA High Street Kensington Tube Station 0 - 32 0 - 47 - - - 0 - 17 0- 6 -
Southwark SE15 4QL Camberwell Station - 0 - 32 0- 1 0- 1 - 0 - 17 - -
Westminster W1U 8EW Portman Square Private Park 0 - 32 0 - 32 - - - 0 - 17 0- 3 -

0 indicates there are overflying aircraft but below the 65 dB level - indicates airspace envelope not applicable to borough

For each borough, the response to the questions regarding local factors are given below.

Camden (NW1 8QL - Camden Town Tube Station)

A significant consideration for Camden are the potential negative environmental and health
effects from additional airport capacity at Heathrow. Based on the latest aviation forecasts,
which show that the number of passengers at London airports will continue to increase,
Camden Council is concerned about the negative impacts on its residents.

Increasing the number of flights over London will affect Camden residents although it
appears to a lesser extent than some other London Boroughs. Although aircraft noise is
not currently an issue of concern in Camden, as a council we expect that Heathrow and
other airports will implement robust mitigation measures. These measures should take into
account the latest research on aircraft noise effects on health and should be consulted
with local communities. We also would like to see the introduction of strict rules and
penalties for any outstanding noise emissions.

Hackney (E8 1FD - Hackney Downs Train Station)

Using the mapping tool for the Hackney Downs Train Station (E8 1FD), considered the
centre of the borough, the number of flights above 65 dB is seen as limited (0-1
flights/hour under the A2 airspace envelope). As a result, the Hackney council does not
have any strong views on noise-sensitive local factors that must be considered.

Kensington and Chelsea (W8 5SA - High Street Kensington Tube

Station)
The impacts on the Royal Borough of Kensington and Chelsea from Heathrow expansion
cannot be conclusively determined from the information provided both in terms of building
a third runway and introducing the IPA procedure. The Council’s position has hitherto
been that noise impacts of Heathrow airport should be reduced and limited, especially as
the entire borough is heavily populated with particularly vulnerable residents and
occupants being distributed throughout. However, given the magnitude of changes and
increased traffic as a result of a third runway and the introduction of the IPA procedure, it
is clear that disruption and noise in particular will be significantly greater than before.

Lambeth (SW9 8HE - Brixton Tube Station)

In previous consultations the Borough of Lambeth has opposed the expansion of
Heathrow with the following principal concerns:

• An expanded Heathrow airport will undermine London’s ability to meet legal air
quality limits and have significant consequences for people’s health.

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• An expanded Heathrow is likely to lead to more people affected by noise

compared to the present situation when this is already a serious concern for our
residents.
• An expanded Heathrow would make the airport the biggest emitter of carbon
dioxide in the country.
• Expansion at Gatwick would reduce the impacts identified above.

The borough maintains its positions and believes the consultation materials provided do
not allow a meaningful response as the mapping tool does not provide a comparison to
today’s noise levels.

Lewisham (SE6 4RU - Lewisham Town Hall)

The Borough of Lewisham has a population of 303,400 and experience continues
overflying aircraft during Westerly operation days. The Borough always opposed the
Heathrow expansion in consultations, favouring the expansion of Gatwick instead. Noise is
a sensitive issue for the residents of the borough.

Particularly, the residents of Forest Hill (SE23) have been complaining of elevated noise
levels due to overflying aircraft and have produced a comprehensive report through
HACCAN ( https://hacan.org.uk/4422-2/ ). The general complaints relate to Heathrow
(LHR)-bound aircraft flying too low, forcing aircraft bound for London City Airport (LCY) to
fly even lower, at around 2,000 feet above their houses. As a result, any future redesign of
the airspace should address this issue by increasing the altitude at which LHR-bound
aircraft fly such that flights for LCY can fly higher, reducing the noise impacts to the
neighbourhood. At the same time, due to current flights approaching Heathrow, traffic for
LCY is not only forced to fly lower but also in a rather narrow corridor, concentrating flights
over a few houses only. Future airspace designs should allow a wider geographic spread
of overflying aircraft (regardless of their destination) by implementing several flight paths
that would help share noise in the area and provide relief for the affected residents. As a
result, London City Airport and Heathrow should work together on flight path planning, to
prioritise and jointly provide noise reduction and respite to those residents currently taking
an unfair burden of their joint aircraft noise. These issues aren’t just limited to the Forest
Hill area, as residents in the north of the borough (particularly Brockley and Telegraph Hill
area) have also raised similar issues, also around early morning arrivals, with two recent
public meetings held with the MP for Lewisham Deptford.

In addition, in 2013 there was a lot of public concern from the residents of Brockley (SE4)
after Heathrow piloted their early respite scheme. It increased the number of aircraft over
Brockley significantly causing significant disturbance: https://www.bbc.co.uk/news/uk-
england-london-23692965 . Although such a flight scheme was never implemented,
Heathrow should be aware of this previous issue when designing new procedures that
may negatively impact the residents of Brockley.

Southwark (SE15 4QL - Camberwell area)

The London Borough of Southwark has a population of approximately 315,000, with some
areas significantly impacted by aircraft noise. For example, in 2018 27 complaints,
enquiries or cases relating to aircraft noise in the Borough were recorded, higher than a
typical year. Some of the residents are involved in a local campaign group, in contact with
the Council, local Councillors and MPs, particularly opposing to the increasing
concentration of flight paths and to early morning arrivals into Heathrow over the West of
the Borough (Camberwell area), supporting dispersal of flight paths that would allow noise

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sharing and provide respite to local communities over which flight paths are currently
concentrated .

The community feel that the mapping tool provides no mentions of respite or relief,
believing that that multiple flight paths will be concentrated over a narrow corridor, with
very fine-grained distances and with no lateral leeway between different flight paths. They
are concerned that this will lead to additional noise from adjacent flight paths that will be
operating in parallel for arrivals to the two runways. As a result, the borough feels that in
some circumstances a wide distribution of flight paths, covering a larger geographic area,
may mitigate this. In previous consultations, Southwark Council opposed the proposal to
expand Heathrow airport on the basis that the expansion is not environmentally
sustainable and will be detrimental to the environment of their residents and residents
across south and west London. Although the borough still holds their previous firm position
against expansion, in the event that the 3rd runway is approved, the Council considers it is
essential that any concentration of future flight paths that follows from the airspace change
process should allow for predictable respite periods for the areas over-flown. Furthermore,
any concentration of flight paths should clearly minimise significant and other adverse
effects from aircraft noise and provide clear overall benefit to total community aircraft noise
exposure. Finally, the airspace change process should allow for meaningful community
influence, including allowing for dispersal of flight paths where this is desired by the
affected communities, especially away from communities currently significantly affected by
flight path concentrations. e.g.
Camberwell area)

As a general principle, the Borough would wish to see avoidance of overflight of all
schools, hospitals and public parks during the daytimes and all hospitals at night.

Westminster (W1U 8EW - Portman Square Private Park)

The City of Westminster has a resident population of 247,000 and held a neutral position
towards the recent Heathrow expansion consultation and is looking forward for the
finalised airspace design (due to be issued in 2020) which will be based on the outputs of
this consultation. The borough hopes that the noise mitigation measures resulting from this
consultation will be translated into statutory legislation, with strict rules and penalties for
any outstanding noise emissions (the borough recognises this will be part of a
Development Consent Order (DCO) but the boundaries of the DCO may be unclear)

In general, the borough received no noise complaints related to airlines (with the main
source of concern being related to overflying helicopters). However, the borough is aware
of a resident group in the Paddington area that has expressed concerns about the
proposed airspace plans .

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4 Appendix
Are you responding on behalf of an organisation or group? By answering yes, you
are also confirming that you have authorisation to respond on behalf of the
organisation.

Yes
No

If yes, please specify the name of your organisation/group and a brief description of
its role and membership:

The answers included in this questionnaire have been submitted on behalf of the Central
London Sub-Regional Transport Partnership (CLSRTP) and were based on the collective
feedback from central London’s seven local authorities (The Royal Borough of Kensington
and Chelsea, The London Borough of Lambeth, The London Borough of Lewisham, The
London Borough of Southwark, The London Borough of Camden, Hackney, and City of
Westminster).

The partnership provides a borough-level focus on sub-regional transport priorities. In

addition to enabling regular collaboration and information-sharing between boroughs, the
partnership facilitates pilots, trials, demonstrations, policy, strategy and research.

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