Stour and Orwell Society TCN Consultation

19June 2008

TGN Consultation

NATS

Freepost NAT22750

Reading

RG1 4BR

Dear Sirs

TCN CONSULTATION

This response is made on behalf of the Stour and Orwell Society (“SOS”).

1. SOS was established to promote the conservation, protection and improvement of the physical and natural environment of the Stour and Orwell part of the Suffolk Coast and Heaths AONB and the adjoining Special Project Area. SOS currently has approximately 200 members, some of which are themselves representative organisations such as Parish Councils. Our Patron is local resident and environmental campaigner Griff Rhys Jones.

2. The Stour and Orwell area has many unique environmental qualities. It is very largely unspoilt and has retained its outstanding natural beauty; hence its designation as AONB. We append a set of photographs of the area with which SOS is concerned to give an indication of its very special environmental qualities. This area offers many opportunities for quiet, informal recreation: sailing, walking the coastal paths, bird watching etc, for which tranquillity is a critical element of the experience. It is a resource enjoyed not only by its residents but by visitors from far and wide, including those who live in nearby large towns where such tranquillity cannot be found.

3. For SOS, the starting point for consideration of the TCN Proposals must be the 2004 Airspace Change. The consultation which preceded that change drew no attention whatsoever to the impacts which have, since its implementation, been visited upon the Stour and Orwell Area. Prior to 2004, our members confirm that little or no impact was experienced from either inbound or outbound air traffic. The 2004 Airspace Change was interpreted by all key consultees as being likely to lead to an increased concentration of overflying of the busy urban area of Ipswich, albeit at 10,000 feet and above, but no significant impact on the Stour and Orwell AONB south of Ipswich was ever foreshadowed or assessed.

4. In the event, the effect of the 2004 Airspace Change has been dramatic and highly adverse in the Stour and Orwell Areas. There has been persistent and intrusive overflying, which has undoubtedly detracted in a material way from the qualities which the AONB was designated to protect. Aircraft noise levels at 25-30dB above background have frequently been recorded. Many members have joined SOS in the hope that it will articulate the strong opposition which they wish to register to the current level of overflying of the Stour and Orwell AONB.

Comments upon the Airspace Change Proposal

Arrivals

5. The proposed segregation of Luton traffic and its routeing north of the Stour and Orwell Area is welcomed.

6. For Stansted, however, the devil is in the detail. If traffic is using the new Eastern Hold, then there can be no doubt that the impacts on the Stour and Orwell Area will be greatly reduced. Para. 5.1 (page D6) indicates that all arrivals have to plan to fly a route via a hold. However they may be directed by ATCOs on a different more direct flight path “if there is no queue”. Para. 5.3 (page D7) states that this will only happen regularly between midnight and 6am, with the implication that at other times of day direct routeing will be the exception rather than the rule.

7. The root of the problem of the damage presently being inflicted on the Dedham Vale and Stour and Orwell AONBs lies in the fact that the “direct” route from the waypoint IDESI in the North Sea to the start of final approach into Stansted takes aircraft on a flight path which causes them to overfly the full length of the two AONBs – the most damaging route which could be devised in this part of East Anglia, in terms of impacts on AONBs.

8. It is clear that the TCN Consultation envisages a change from the status quo which has obtained since 2004. We have compared very carefully Figures E8 and E9; E10 and E11; E12 and E13. We have also noted the changes in the positions of the black lines and the arrows in Figures E14 and E15; E18 and E19. It is considered that the only sensible interpretation of these Figures and the way in which the arrows move is that NATS has modelled the effect of the proposed changes and that the arrows are significant in identifying changes to the principal flows.

9. This conclusion has been reached notwithstanding what is said at para.11.32 (page D17) in the general section of the Consultation Document. For example, the SE arrow in Figure E8 could have remained unaltered in Figure E9 and still have pointed within the southernmost black line in that Figure, if it were anticipated that the principal flows from the SE would not be holding or heading North of Ipswich (and thus avoiding the Stour and Orwell Area). Likewise the orientation of the arrow in Figure E19 plainly implies that the principal flow will be headed North of Ipswich over Felixstowe and the A14 corridor. Para. 6.15 (page E30) supports this interpretation: “Stansted arrivals from the east will fly towards an area north west of Ipswich”.

10. These, then, are the assumptions (based upon a detailed examination of the document) upon which this consultation response is based. Thus the proposed pattern of overflying appears to offer relief for the Stour estuary and the potential for a reduced level of impact on the AONB within the Orwell estuary – with the opportunity for the principal concentration of flights to be directed over the busy Port of Felixstowe and the A14 corridor. This would, in the view of SOS, be good planning by NATS, as it would recognise the high ambient noise at these locations.

11. On this basis, SOS supports the proposed Airspace Change. If, in fact, the majority of arrivals traffic is concentrated between the new Eastern Hold and the southernmost black line on Figure E9, then this consultation will have been misleading, and SOS would have vigorously opposed the proposals, as they would not have reversed the highly damaging impacts visited without warning on this sensitive area since 2004.

12. The key to acceptance of the Airspace Change and the avoidance of future legal action is for NATS/CAA to implement a mechanism which ensures that the main flows do in fact occur where the reasonable person would expect them to occur in reliance on the Consultation Document.

Departures

13. Figure E2 demonstrates that, if only the direction indicated by the arrow pointing ENE were followed, then aircraft would generally (i) reach the North Sea at the earliest possible opportunity; and (ii) avoid overflying the extensive swathe of AONB, which runs from the Dedham Vale, across the Stour and Orwell estuaries and then up the remainder of the Suffolk Coast and Heaths AONB towards Lowestoft.

14. SOS asks that action be taken to deter aircraft departing for NE destinations (from the London Area and in particular Stansted) from turning north too early and overflying unnecessarily a very large area of statutorily protected landscape, when this could so easily be avoided by flying on to the North Sea before turning north .

The Proposed Eastern Hold

15. SOS notes that NATS has planned the new proposed Eastern Hold, having taking account of the position of nearby AONBs. This is welcomed. SOS is aware that opposition has been voiced against this proposal by villages affected by it, and in particular Lavenham. It is noted that such a village does not, on its own, have the characteristics of an extensive swathe of countryside, which is statutorily protected as AONB – a designation which is singled out for special treatment in the Secretary of State’s Guidance to the CAA on Environmental Objectives relating to the Exercise of its Air Navigation Functions. Nevertheless, study of the relevant plan suggests that a relatively minor modification might be made to avoid placing Lavenham on the direct line of the Hold. If this can be done without adverse consequential impacts on the AONBs, then SOS would support such a modification.

Conclusion

16. SOS asks NATS and CAA to consider very carefully the contents of its response and to act to ensure that the impacts of this Airspace Change Proposal provide genuine and sustained relief to the Stour and Orwell Area in order to remedy the damage which has been done to it by the unexpected consequences of the 2004 Airspace Change. This support offered by this response is expressly conditional upon the delivery of patterns of flying which reflect the arrows shown in the Consultation Document. If it is subsequently suggested that NATS has carte blanche to direct aircraft wherever it wishes in whatever proportion within the black lines on Figure E9, for example, then this consultation will have been fundamentally flawed in failing to draw attention with sufficient precision to the environmental impacts of the proposals (which vary dramatically depending upon where the principal flow of aircraft is directed).

Thank you for allowing the extended opportunity to respond to these proposals.

Yours faithfully,

Rodney Chadburn, Secretary

cc. CAA