On 10 June, Martin Dillon wrote on behalf of Much Hadham Parish Council to the Terminal Control North Consultation commenting on the Airspace Change Proposal.

Dear Sirs

Airspace Change Proposals for Terminal Control North

I am writing on behalf of Much Hadham Parish Council ("MHPC") to comment on the TCN Airspace Change Proposals (the "Proposals").

Difficulty in accessing the Proposals

The first point I wish to make is the difficulty MHPC, and no doubt many other Parish Councils and parties, have encountered in obtaining access to the Proposals. They consist of over 400 pages. They were available on your special website, but only to those with internet access. It is not possible to digest a complicated document of over 400 pages by reading it on screen. I do not have broadband or a colour printer; the maps are not comprehensible in black and white. I telephoned you and asked to be sent a hard copy. My request was refused. MHPC and some other local Parish Councils then asked our MP, Mr Mark Prisk, to write and ask for us to be sent hard copies. He wrote to the CAA on 12 March. His request was in effect refused in their letter of 20 March. This attitude is the reverse of helpful.

I understand that each MP has been sent a hard copy of the Proposals. I have no objection to an MP, for example, with a Scottish constituency being sent a copy - though I rather doubt whether his constituents will be interested in the Proposals which will not affect them – but I do consider that, for a proper consultation, all Parish Councils in areas affected by the Proposals should have been sent hard copies. It is not good enough to rely on copies in some local public libraries – there was a copy in the Bishop's Stortford library but not in the one at Buntingford – because if, as a Parish Councillor, you wish to discuss the Proposals with your fellow Councillors or with local residents, you need a hard copy so that you can show them maps and the relevant parts of the text. I have managed to persuade someone to print off what I believe are the parts of the Proposals relevant to Much Hadham, but I should not have had to rely on my friend's goodwill. I cannot escape the impression that the refusal to supply a hard copy to MHPC (and presumably to all Parish Councils) – whether the decision was yours or the CAA's – was driven by a desire to make access to complicated and lengthy Proposals difficult in the hope that this would reduce comments and complaints. In view of the time that you have taken over the Proposals, I assume that saving printing costs was not the reason for declining to supply hard copies.

Comments on the Proposals

There are some 2000 residents living in Much Hadham excluding those living and working at St Elibabeth's Home & School and excluding pupils and teachers from outside the Parish at St Andrew's Primary School. Much Hadham is in the East Herts and West Essex area. According to your website Much Hadham will, if the Proposals are adopted, be overflown by no less than 16 different flight paths.

The residents of Much Hadham have been and continue to be so annoyed by aircraft noise generated by aircraft landing at, and taking off from, Stansted Airport that MHPC decided to become a Rule 6 party at the Inquiry heard before the Inspector last year into the expansion of the existing runway at Stansted. No other parish Council was a Rule 6 party. As I write, a decision is awaited from the Government, though it will no doubt be made by the time the Proposals (whether or not modified following the consultation) are due to come into effect in 2009. Though you have made it clear in the Proposals that they are only to apply until 2014 and that they will need to be reconsidered if a second runway is built at Stansted and a third runway at Heathrow, you have not made it clear:-

1. Why you are making the Proposals when the skies are not full and decisions are awaited on a second runway at Stansted and a third runway at Heathrow; or
2. Whether the Proposals have been made on the assumption that BAA will obtain permission for a maximum of 264,000 ATMs at Stansted (an increase from the existing maximum of 241,000) using the existing runway.

As you will know, passenger numbers are falling at Stansted and so is the volume of cargo in metric tonnes. ATMs are also therefore declining. The latest forecasts for passenger numbers provided by BAA are set out below, with April 2007 forecasts for comparison:-

                     April 2007 forecasts                                       May 2008 forecasts
                                                                                        (quoted as 2008, 2009 and 2010
                                                                                 instead of 2007/08, 2008/09 and 2009/10)

2007/08              24.7mppa                                                                22.7mppa

2008/09              25.3mppa                                                                23.3mppa

2009/10              26.2mppa                                                                24.4mppa.

The latest information I have about ATMs at Stansted is for the twelve months ending March 2008 when, according to BAA, the number was 188,707, a decline compared with the 12 months ending March 2007. I appreciate that your concern is ATMs, not passenger numbers, though they are obviously linked, but as BAA is forecasting declining passenger numbers for the next two or three years, it is obvious that with a current permitted maximum of 241,000 ATMs and a current usage of under 190,000 ATMs, there is so much headroom that ATMs will perhaps not reach 241,000 before 2014. There is therefore no obvious operational need, so far as Stansted is concerned, for you to be redesigning flight paths for take offs and landings at Stansted. Certainly the forecast figures for arrivals and departures at Stansted in 2014 set out in your letter to SSE of 13 May 2008 now look too high.

The residents of Much Hadham are mainly annoyed by being overflown both by planes landing at, and taking off from Stansted, with planes taking off using the flight path known as Buzad. Aircraft using Buzad cause much more annoyance because Buzad is more heavily used and because more residents, including those at St Andrew's School, live near the centre line of Buzad.

The proposed new flight path and the use of a modified CDA for easterly arrivals at Stansted is welcome. There is at present no set flight path for such arrivals and aircraft have recently started more and more to fly lower and to save fuel by cutting the corner coming across Little Hadham and then the west of Much Hadham, so that they have been causing increasing annoyance. Much Hadham residents will therefore be pleased by the new flight path during busy periods for Stansted easterly arrivals to the west of Hertford, particularly as the use of P-RNAV is likely to result in few, if any, aircraft during such periods overflying Much Hadham.

Busy periods are likely to be between 06.00 and 23.30 hours. During other periods, particularly at night, aircraft on easterly arrivals at Stansted will, to save fuel and reduce emissions, be routed more directly to the airport. Night flights are predominantly used by older, noisier and more polluting aircraft. Do you have any information on the likely flight paths to be used by such aircraft and by other aircraft on easterly arrivals outside busy periods? Or is the position that Air Traffic Control will route the aircraft across a wide swathe using what they consider to be the most efficient means of landing, so that Much Hadham residents will from time to time still be overflown by aircraft on easterly arrivals at Stansted?

If the new flight path for easterly arrivals during busy times is good news for Much Hadham, then the proposed modification to Buzad is bad news for Much Hadham, particularly for those living in the north end of the High Street and at the north and east of the Parish. I have seen a map showing a suggestion you have made to STACC for a possible modification following a meeting on 9 April 2008; this map shows the centre line for the existing NPR for Buzad in blue, the centre line for Buzad in the Proposals in purple and the centre line for the suggested modification in red.  (I shall refer to the suggested modification of Buzad in the Proposals as the "TCN proposal" and to the possible modification as the "red" suggestion). The existing NPR of Buzad is already bad for Much Hadham. The situation would be made worse by the TCN proposal and worse still by the "red" suggestion.

The Proposals set out the options you have considered for rerouting easterly arrivals at Stansted (see figure G52 on page G78), but they contain no indication of the thinking that has led you to make the TCN proposal. Please explain:

(a) what options you have considered and what has led you to make the TCN proposal; and
(b) what options you have considered and what has made you make the "red"
      suggestion.

At present aircraft using Buzad may vector off having reached 3000ft. My understanding is that under the Proposals aircraft will now only vector off Buzad at 4000ft, so that the vectoring off level for Buzad will be the same as the level for the other NPRs from Stansted. Is it correct that aircraft may now only vector off Buzad at 4000ft? If so, this is welcome.

Aircraft using Buzad do not always keep to the centre line. They often fly too far to the west and thus over the more populated parts of Much Hadham; the FEU at Stansted may deny this, but the evidence is that aircraft are given some latitude, or at any rate fly off track, as is shown by the analysis exhibited to Mr Kevin McMullen's witness statements (see below). If aircraft on Buzad do use P-RNAV and keep more or less to the centre line of the TCN proposal, then residents in the north and east of the Parish will suffer from increased and persistent aircraft noise. If the aircraft fly within the new suggested swathe, then more residents over a wider area will suffer.

MHPC appreciates that the Government uses the 57 Leq (16hrs) dB contours to determine the level at which aircraft noise cause annoyance and that Much Hadham is outside both the current and the prospective 57 Leq contours. However, while the contours may be satisfactory as a guide to the continuous noise made by, say, a motorway, they are artificial when used to measure aircraft noise. They are calculated based on average noise over the 16 hour period, so that periods of silence are taken into account as well as periods when aircraft are overhead. Who has ever heard anyone complain about aircraft noise when no aircraft are overhead or are within sight?

It is the peaks of aircraft noise that cause annoyance and destroy tranquillity. These are determined by Lmax levels. The Proposals indicate that aircraft using Buzad and flying over the Parish of Much Hadham will be at a height of 2000/3000ft (above sea level), which is presumably the greatest height the aircraft can reach given the proximity to the airport. Table G5 on page G69 gives indicative Lmax dBA(A) levels for Stansted departures at 2000/3000ft of 64-84 decibels for a Boeing 737-800 and of 72-90 decibels for an MD11. If the TCN proposal is adopted, the levels may in fact be higher over the Parish because the aircraft will be using more thrust to gain height and will be banking and turning with the sound being projected downwards in the direction of Much Hadham High Street. The "red" suggestion would be worse because the swathe would then extend over the most populated parts of Much Hadham.

Most aircraft using Stansted are Boeing 737s in various versions. According to the table in the Proposals on page G70, a heavy diesel lorry at 25mph 23 ft away produces 85 decibels, a car at 40mph 23 ft away produces 70 decibels and a busy general office produces 60 decibels. 64-84 decibels are within this range. When Buzad is being used, departing flights start at 06.00hrs, with aircraft flying over Much Hadham every few minutes. You do not need to be a light sleeper to be awoken by an aircraft overhead emitting a noise of 64-84 decibels. The aircraft are also loud enough to interrupt normal conversations. If you are on a mobile, you have to stop talking until the aircraft is some distance away.

Quiet periods during services in St Andrew's Church are already disrupted by aircraft using Buzad. The TCN proposal will increase the disruption because the centre line will be nearer to the church. The "red" suggestion is quite unacceptable because the centre line will pass almost directly over the church. St Andrew's church is used not only for services but also for concerts  and other functions.

St Andrew's School is in the High Street. During the summer, when airline traffic on Buzad is traditionally at its peak, the teachers naturally open the windows. If aircraft fly closer to the School as the TCN proposal suggests – the "red" suggestion would bring aircraft even closer – then there will be more interruption to classes.

I expect that you are aware of the risk that aircraft flying overhead may cause for the monitoring system at St Elizabeth's. To elaborate, I enclose copies of the two witness statements dated 26 April and 8 August 2007 which Mr Kevin McMullen, who was at the time the chief executive of St Elizabeth's, made at the Stansted Inquiry last year.  BAA said that they did not accept all of Mr McMullen's evidence, but though they claimed that not all the readings which Mr McMullen had taken from BAA's website on which aircraft may be tracked were accurate, they did accept that some were correct and therefore that some aircraft had overflown St Elizabeth's when they should not have done. According to BAA's publicity material no aircraft should fly over St Elizabeth's below 4000ft (above sea Level), but you will see from Mr McMullen's second statement that BAA has its own particular interpretation of the meaning and effect of this restriction.

It was originally thought that it was aircraft on easterly arrivals at Stansted that were the likely cause of the risk to the monitoring system, but when BAA introduced their aircraft tracking website, it was discovered that aircraft supposedly using Buzad, but in fact flying off track, were the actual cause of the risk. If aircraft keep within the swathe of the current centre line of Buzad, they should not fly over St Elizabeth's, but the TCN proposal will slightly increase the risk of overflying St Elizabeth's and the "red" suggestion would considerably increase it because the swathe would then extend over St Elizabeth's. You will understand from what Mr McMullen has said the risks to residents at St Elizabeth's of the failure of the monitoring system. No changes to Buzad should be made which would increase those risks.

The hamlet of Green Tye is at present near the current centre line of Buzad. Green Tye is some 35 metres or about 100ft above Much Hadham, so that the residents are more effected by aircraft noise. Neither the TCN proposal nor the "red" suggestion would bring much, if any, relief to those living in Green Tye. I have been at a meeting in Green Tye when an aircraft flew overhead. The noise was so great that I automatically ducked. I am glad I do not have to put up with such an experience on a day to day basis.

From MHPC's perspective the best solution would be for Buzad to be rerouted between Hunsdon and Widford and then to sweep round to the west of Ware and Hertford. We appreciate that we do not have enough the information to know whether this would be practical, but the flight path would then more or less follow the proposed route for easterly arrivals at Stansted; there would be no risk of a clash because aircraft only use easterly arrivals at times when Buzad is not being used, and vice versa. Would this solution be practical? If not, then MHPC suggests that the centre line of Buzad should be kept in its present position. The "red" suggestion would not involve much improvement for Thorley and, as I have said, would be a disaster for Much Hadham. The position, however, could be improved both for Much Hadham and for Little Hadham if the centre line of Buzad were to curve nearer Bury Green shortly after the intersection with the centre line under the TCN proposal, so as to cut off the corner by passing to the east of Little Hadham before joining up with the proposed path to the north and east of Little Hadham in the region of Upwick Green. I enclose a plan showing the route MHPC suggests with a red line in dashes. Would this route be possible?
 
The Proposals involve changes to the flight paths for aircraft departing from Heathrow, London City, Luton and Northolt. The proposed Heathrow departures may not cause much annoyance in Much Hadham because if the aircraft do fly within the swathe over Much Hadham, then they will be at a height of 7000ft and so should not be much of a disruption to tranquillity. As I understand Figure G24 on page G39, the swathe for the proposed London City departures will hardly extend over Much Hadham. There are at present very few flights from Northolt – and it seems that this is not likely to change - so that the proposal that aircraft departing from Northolt should join the new flight path for Luton departures is not likely to make a noticeable increase in aircraft noise over Much Hadham.

The proposed new flight paths for both easterly and westerly departures from Luton to the east and south east are not welcome, though if aircraft keep within the black lines, they should not cause much annoyance in Much Hadham because they will be north of the A120 and above 5000ft. The risk is that the aircraft will fly outside the black lines but within the swathe. The edge of the swathes for current easterly and westerly departures to the south east probably do not extend over Much Hadham, but the Proposals would involve both swathes extending over Much Hadham. The proposed routes for easterly and westerly departures to the east will perhaps make little difference to Much Hadham compared with the current routes, because in each case the swathes extend over Much Hadham. However, the Proposals do involve a greater likelihood of aircraft departing form Luton flying over Much Hadham at about 5000ft. According to the G3 table on page G68, a Boeing 737-800 departing from Luton will produce between 58 and 66 decibels at 5000ft and an Airbus A300-600 59-75 decibels at that height. If aircraft departing from Luton do fly over Much Hadham, there will therefore be an increase in the loss of tranquillity and therefore increased annoyance.

More flights over Much Hadham will of course produce more pollution over Much Hadham. I do not have any evidence what effect the increased pollution will produce, but you will understand that given all the recent publicity, emissions are an increasing concern.

You will see that this letter contains a number of questions on which I look forward to hearing from you. To make it easier to answer, I have put the questions in bold.

Yours faithfully

M L G Dillon
Chairman of Much Hadham Parish Council

TCN Consultation
NATS, Freepost NAT22750, Reading RG1 4BR.

Cc CAA (DAP) (without copy statements)
Floor K6, CAA House, 45-59 Kingsway, London WC2B 6TE.

Cc Mark Prisk Esq MP (without copy statements)
House of Commons,
London SW1A 0AA.