Sent: 12 February 2020 13:58
Subject: RE: Recent rejection of Gateway submission for ACP
Thank you for your email on behalf of North Queensferry Community Council, and for your information on appendix D of CAP1616.
CAP1616 is a guidance document that allows airports of different sizes to apply for an airspace change. This means it may be interpreted differently by each airport, but the process allows for this with the submission to the CAA Gateway as the place to justify the approach and tell the story of engagement.
Whilst we are disappointed and disagree with the CAA's decision, our feedback from the CAA on our submission was around telling a more detailed story of our engagement. We are in a position where the work has been done, but we need to provide more evidence and commentary around some of the stages of our programme to the CAA to resubmit. We are currently working with the CAA to determine what gateway is best for that.
Bruce, as you are writing this email on behalf of North Queensferry Community Council I'm confused by the line 'a spirit of engagement that has not been seen to be reciprocated'. Edinburgh Airport invited representatives of North Queensferry to participate in the Stage 1 Engagement, including yourself and your wife to attend a session together as both representing North Queensferry Community Council; a representative of North Queensferry at the focus groups in the initial workshops, and yourself as a representative of North Queensferry Community Council attending the recall workshop. There was also representation at the separate EANAB workshop. I'm confident that we captured the views of North Queensferry, that those views were considered and ultimately influenced our thinking in formulating design principles.
We look forward to continuing this engagement and dialogue as we move through the process.
Once we've agreed our approach with the CAA for resubmission, I'll communicate to all of our stakeholders regarding the next steps forward.
-----Original Message---From: Bruce FInlayson
Sent: 09 February 2020 19:23
To: Gordon Robertson
Subject: Recent rejection of Gateway submission for ACP
Following the rejection by the CAA earlier this week of the first Gateway step, could you explain to communities what steps you will now undertake to more adequately engage with them before any resubmission of the ACP to the first Gateway.
We note that although not specific in detail the CAAs response has been to agree with the contentions previously outlined by ourselves. Specifically we indicated that the exercise undertaken in the name of engagement by Progressive Partnerships on your behalf fell well short of a two way informed process.
Communities have limited resources which have til now been generously offered in a spirit of engagement that has not been seen to be reciprocated. Communities have now been backed up by the CAA on the two decision points to date, the rejection of the initial ACP and the stage 1 gateway of the present ACP. We therefore respectfully request that you now engage in a fully informed, open and respectful process that goes well beyond previous attempts by ensuring expert advisers be available for engagement rather than a marketing company with no knowledge of what is a broad and complex subject.
Please read CAP 1616 Appendix D below, and explain how you now intend to proceed with this next phase of community engagement.
Airspace design principles
Why is this activity included in the process?
D1. Different local areas will have different geographies, population distribution, environmental considerations, economic considerations, and so on. To apply a local context to changes, including the preferences and expectations of different stakeholders, a local conversation is needed to establish a qualitative framework for the design of the change.
Key terms to check in our glossary
How to undertake this activity
D2. The design principles are an opportunity to combine local context with technical considerations. There are contextual trade-offs that the change sponsor must consider upfront with stakeholders, in particular with the communities that could be impacted by the change.
D3. The questions a change sponsor might ask stakeholders to inform the development of the principles could include the following (these are offered as an example and this is by no means an exhaustive list):
• are there noise-sensitive buildings that should be avoided, and if so what and where (i.e. hospitals, care homes, schools, higher education establishments, and so on)?
• how should the minimisation of overflight, or of night noise, or the difference between multiple respite routes and concentrated routes be traded off against one another?
• if multiple routes are considered in order to provide respite, what might constitute a sufficient period of respite?
• how should the needs of passengers be considered alongside the needs of communities at different times of day?
• are there areas in which efficiency from a whole airspace perspective or expeditious routeing (shorter or faster routes) take precedence and areas in which other factors should take precedence?
D4. In having this two-way conversation with relevant stakeholders, the change sponsor must be clear about the technical considerations that will inform the development of the designs, including:
• the operational aim of the proposal
• safety constraints or opportunities
• operational constraints or opportunities • technical constraints or opportunities • economic constraints or opportunities • the policy and regulatory framework with which the proposal must comply.
D5. Other than the principle of improving or maintaining safety, these factors are in no way immutable and, as a part of the process for the establishment of the airspace design principles, should be challenged as part of the ongoing dialogue with stakeholders.
D6. The outcome of this work will be a shortlist of principles to inform the development of airspace design options and against which they can be qualitatively evaluated. Some of the principles may contradict one another and some may be prioritised over others: this will be an iterative process and a qualitative one rather than a purely numerical exercise with binary answers.
D7. The outcome will also record other design principles that were suggested by stakeholders but not shortlisted for the final set of principles, with reasoning as to why this was the case.
D8. The CAA would therefore expect to receive the following output from this activity:
• a list of those stakeholders engaged
• the methodology applied to identify them • an explanation of the engagement methods employed • a chronology of the engagement activity • an explanation of the issues raised during the engagement process and of how stakeholder feedback influenced the final set of principles • evidence of a two-way conversation, i.e. copies of all related correspondence between the change sponsor and stakeholders • the design principles chosen • the rationale behind the decision to adopt those principles including evidence of which of the principles chosen were agreed by stakeholders and, if universal agreement is not achieved, which were not; where design principles have not been agreed, objections must be clearly set out and attributed to relevant parties, as well as a clear rationale for the change sponsor’s decision in light of this feedback (for example, a matrix or table illustrating how the design principles have evolved).
Technical design principles
D9. The design of airspace structures and instrument flight procedures that falls subject to the airspace change process must conform to various national and international standards and recommended practices.
That said, within that framework, there are many design techniques available to airspace designers. A change sponsor must therefore be able to justify the techniques being applied, especially where those techniques have a direct impact on local communities.
Environmental design principles
D10. The CAA is required to follow the Secretary of State’s Air Navigation Guidance 2017. Within that guidance, there is a strong emphasis on taking into consideration local circumstances, especially when considering such matters as the potential value of respite routes. It is vital that the change sponsor takes into consideration the views of local communities when establishing airspace design principles, as set out above.
Bruce and Mari Finlayson
North Queensferry Community Council
Edinburgh Airport Limited (EAL) supplementary consultation. Response from North Queensferry Community Council 25th June 2018.
“Please give us your views on E7a flight path and any local issues we should be aware of.”
This response has been prepared on behalf of North Queensferry Community Council (NQCC), a community council constituted in terms of the Local Government (Scotland) Act with the statutory purpose of representing the views of the residents of North Queensferry.
A considered response, informed by the interests of, and on behalf of the over 1500 residents in our area is a challenging task in the short time extended by this supplementary consultation. As well as the amenity of present residents NQCC must also take into account the future impact of change on those residents and the large and increasing numbers of visitors attracted to our community which lies at the historical crossing point between Edinburgh and Fife, a location which links ancient centres of Kingdom, Commerce and Religion on either side of the Forth.
North Queensferry is the commencement of the Pilgrims Way with the present day opportunity to join in the footsteps of past spiritual pilgrims. It is the northern landfall of the World Heritage Listed Forth Bridge and within the buffer zone of the World Heritage Area. It is the start of the Fife Coastal Path to which many visitors both local and from further afield are drawn on account of its tranquillity and its beautiful and peaceful coastal landscape with opportunities to explore a location rich in Scottish Heritage, touch the past and to observe nature. Any increase in noise is detrimental not only to neighbourhood enjoyment but also to that of the growing number of pilgrims, walkers and nature observers.
On most days, away from the immediate noise of the rail services the soundscape is tranquil.
The takeup of E7a flight path is likely to make a huge detrimental change in this tranquillity.
At present there are no planes overhead with most on the existing routes bypassing the village to the north by several miles and only on those 30% of days when the winds are in the east. There are presently no planes at all on days when the wind is in the west.
From the maps given, the route changes proposed appear to indicate that there will be many future flights almost directly overhead of North Queensferry every day when the D0 route is also taken into account.
Uncertainty arising from vagueness of the presentation material
From the presented information in any of the consultation documents, it is very difficult to reach an informed view on how bad this impact will be because the existing nominal route has only vaguely been followed in recent times and some planes already fly closer to North Queensferry than in the past. The changes, of late, on the existing route, the huge lateral spread of planes, the varying height, varying type of plane and consequent varying noise patterns make impressions of future impact very difficult to assess. This is only made more difficult by the obscure and changeable measures used (various maps are confusing, Leq, Lden, LAmax, SEL; none of which are presented to measurement limits and none of which show aggregated impacts). The resultant simplistic noise maps presented in the consultation documents do not even extend to North Queensferry.
However, such information as is presented is, in any event, fundamentally flawed. It has been disclosed, as the result of a Freedom of Information request, that the Noise Maps which are included in the consultation materials (and which, for the reasons stated above are inadequate in themselves) are based upon noise measurements obtained at Gatwick Airport, and there would appear not to have been any attempt locally to calibrate the maps to the terrain, existing flight patterns, including rate of ascent, and other conditions affecting Edinburgh Airport and its surrounding, affected area. It seems to have been assumed that the Gatwick experience of noise is directly transferable to Edinburgh, when examination of the actual noise recorded on monitors shows that it is not. In particular, the Gatwick derived models significantly underestimate the level and impact of noise in the Edinburgh area.
The result of this is that there is a failure properly to inform affected residents of material information which is necessary for them, and this community council, to be able adequately to exercise their right to be consulted on decisions on which they have been consulted.
A further critical issue reference to which is almost absent from the consultation documents is that relating to any significant evaluation of the health impacts arising from the changes of Routes. Studies from elsewhere indicate that increased noise does have impact on the physiological wellbeing of residents exposed to that noise. Although noise is itself inadequately discussed in the consultation documents, the overall concern of people for information on how that noise will impact their health is almost entirely missing. Medical Practitioners at public meetings attended by more than 100 people have expressed alarm at their inability to address these issues with the information available in the consultation documents.
Impact on and from other routes:
This supplementary consultation refers only to flight path E7a but that flight path cannot be taken in isolation from its impact on the remaining distribution of flights out of Edinburgh. It is clear from the documents supplied that there will be changes to all other proposed routes from what has been previously consulted on; yet the residents in those affected areas have not been informed of these changes, nor given an opportunity to respond to them; nor has any information been presented on the aggregated impacts of other routes together with route E7a. In the case of North Queensferry this particularly applies to the aggregated impact of having planes fly over the village every day when route D0 is also taken into account.
For the present extended consultation to be a meaningful one, there requires to be provided aggregated noise maps for the North Queensferry area. Those maps really need to show the area down to the limits of resolution and be provided along with maps describing the variability to be expected.
Furthermore, as explained above, it has now also come to light through Freedom of Information requests that even those maps that are presented may be based on information that has now been independently checked and has been found significantly and materially to underestimate noise arising from aircraft operating out of Edinburgh Airport.
Any consultation based upon these data will be fundamentally flawed. If any meaningful opportunity is to be given to residents to participate in the consultation, there is no real alternative but to withdraw the existing maps and suspend the consultation until new and properly validated maps have been published. The whole consultation should then be recommenced, founded upon properly validated new maps.
When accurate information becomes available we would also call for a full report on the health impact arising from the proposed changes.
Much of the impact on populated areas could be avoided by flying aircraft further out into the Forth before turning. The effect of this would be that the aircraft will already have a climbed to a higher altitude before overflying populated or tranquil coastal regions.
Although at the recent Inverkeithing Public Meeting, this suggestion was rather dismissed by the representatives of Edinburgh Airport, nonetheless, we consider it necessary for there to be a full investigation and analysis of this option which has the potential to produce an outcome which will both protect the peace, health and environment of affected communities and residents, and yet also enable EAL to pursue its commercial objectives. In dismissing this option at the meeting, representatives of Edinburgh Airport Limited made some passing reference to the claimed existence of military airspace in that direction. Although, of course, the existence of military airspace may be a material factor, there is a clear and present need to ensure that the proposal is fully investigated to ascertain whether it cannot avoid impinging on military airspace. Passing comment was also made about what was claimed would be the attitude of the CAA. Again, there was no indication that this response was other than a superficial and unresearched view. With respect, a one line dismissal is not sufficient. North Queensferry Community Council would seek to require that there be carried out a full and thorough investigation of this option.
Uncertainty as to what will be contained in any fresh application to the CAA.
Last year, in consultation 2, EAL indicated there would be 41-49 flights per day on Route E. Then in August, 2017, EAL applied to the CAA to use the route for 96 – 111 planes per day. There was no opportunity for people to respond to this doubling of the flights applied for. Now in this supplementary consultation reference is made again to 41-47 flights per day, but no maximum is mentioned.
Verbal assurances were given at the time that maximum numbers of flights would not be exceeded without a new application to CAA.
We have no confidence that EAL will not change its mind again, and apply for a changed or increased number of planes per day without any further consultation with the residents affected.
Lack of Community Support for change:
In previous consultations there was a response rate of less than 1% from affected areas. This most certainly cannot be taken as evidence of apathy or disinterest in the affected communities. Rather, it speaks eloquently of the flawed nature of the consultation process. We refer here not so much to the bringing to the attention of residents of the consultation materials (though there was some criticism voiced at the public meeting of that exercise) as, rather to a lack of information set out simply, with clarity, in appropriate detail, and (critically) accurate information which is not in its nature misleading. In the face of the present consultation materials, many people have expressed that they feel disempowered by what appears to them to be a tick box exercise in which positively framed feedback, such as suggestions for new, alternative, flight paths are dismissed and ignored.
It is clear from EAL’s own numbers that their proposals for flight path change have been rejected by the communities impacted by them. In the 2016 consultation on flight path swathes, the overall response was 60% against any flight path changes. In 2017, the overall negative response to the flight path F2A routes was 69%, with only 22% positive, D0 was 64% negative, 18% positive. There is no measure for E7A to indicate it has any better acceptability.
Overall concern from previous consultations was mainly about noise but the second major concern was the consultation process itself. The reasons for this have not been acknowledged nor dealt with and remain: there is a persistent appearance of tokenism in the process; information is dense, obscurely presented and difficult to assimilate; and now, critically, it appears that the whole consultation may be based on fundamentally flawed noise maps as the basis for both community feedback and consequent planning of the flight paths.
In these circumstances, the present consultation process is not fit for purpose and North Queensferry Community Council calls for it to be halted, and to be recommenced only when there can be guaranteed conformity with those requirements of clarity, accuracy and comprehensibilty which are required to enable a properly informed response from the public.
Edinburgh Airport: Airspace Change Programme (ACP) Summary by North Queensferry Community Council 14 March 2018
The ACP has three proposed routes that affect North Queensferry -routes D, E and F. In combination these routes will see flights over/very close to North Queensferry 365 days a year. Over 600 responses were submitted from the wider area to these routes during the consultation last year, mostly in opposition.
Consideration of the ACP application was suspended by the Civil Aviation Authority (CAA) in September last year as route E was found not to be flyable. The new route E is much closer to North Queensferry than the one they consulted on and the fact the Airport have made this material change without further consultation has been raised by Lesley Laird MP with both the Airport and the CAA. There are also issues with the way the noise impacts have been assessed (models assume aircraft will be on a centreline), which again have been raised with the Airport and the CAA.
It is understood the ACP process is to re-start this month, with the Airport hoping for a decision by October/November.
Noise Action Plan (NAP)
The NAP was launched for consultation on 20th February and the consultation runs until 2nd April. The NAP is a statutory document and only takes into account areas close to the runway, not areas such as North Queensferry which experience almost no noise for long periods, with relatively high levels at other times.
At the drop-in session in Dalgety Bay last week, the Airport confirmed that they are looking for ideas on how to reduce noise impacts in areas not previously covered by the NAP in view of the fact the number of flights is set to increase over the coming years.
Noise Advisory Board (NAB)
The Board meets every month and has a principle aim of reducing noise in affected communities. It is independent from the Airport but the Airport do (or have said they will) provide funding to appoint contractors and for installation of noise monitors etc. Progress to date has been slow but a work programme is now being developed with sub-groups looking at the best locations to install noise monitors, the analysis of historic flight data to ascertain what changes to flight paths have already taken place and problems with the use of noise modelling.
The NAB was not consulted on the Noise Action Plan and the Board do not agree with the way the Airport has described the NAB within the document. A letter has been written to the Chair of Edinburgh Airport's Board asking for the NAP consultation to be withdrawn.
BF and MF attended a meeting with EAL and other Community Council representatives at Edinburgh Airport on 25.09.17:
Edinburgh Airport gave a presentation on their application to CAA. At that stage CAA had suspended EAL’s application and EAL intimated that the changes required were minor which was in contradiction to the actual published letter from CAA which indicated serious issues with the applied for routes.
The application prior to suspension was substantially different from the proposals in the second consultation. In the proposal document during east winds which occur approximately 30% of the time there were 45 flights a day proposed on Route E6 over the bridges to the south of us with a spread overhead of us and S Queensferry. In the actual application there were up to 111 directly over the villages on Route E7 at 4-7000ft. At this height flights will be more than loud enough to interrupt conversations on the ground in the village. At the meeting presentation this was not highlighted and flights on route D0 in west winds also over the village were stated as occurring only in peak morning hours up to only 6 flights per day. They also stated in the presentation that any changes to approved flight paths after the application would require a new consultation.
In later correspondence however EAL apologised that this was incorrect and that the morning overflights would be up to 11. Other Community Councils expressed concerns that this is not a consultation in the true sense of the word. They indicated that they had already seen changes to flight paths. This EAL categorically denied. EAL have since communicated that the 111 flights a day are not a significant change to North Queensferry because we already have 99 flights a day affecting us in east winds. This refers to the flight path to the north of us and over Dalgety Bay where currently flights over the village are at 10,000 feet. We and several other Community Council representatives feel that EAL “stretch the truth” and only present the facts in a light which omits community concerns.
The Environmental Report accompanying the application is completed. The'Tranquillity Report' - says 'minimal effect'. Action MF to contact S Queensferry CC re combining efforts and consolidating with other CCs.
Noise levels were discussed - well respected programmes have been used for predicting noise - but these do not take account of the local environment. Night flights, which are restricted over London, will not in general be restricted at Edinburgh but for now Route D0 is morning peak 6.00am to 10.00am only and E7 is from 6.00am to 11.00pm.
DD stated FC on side of communities - but there is not enough expertise to make a judgement. Sufficient resources are required for a proper independent Environmental Assessment to challenge Edinburgh Airport. Any costs for commissioning such a study needs to be shared with other councils.
Flight paths are a UK matter and Noise Management is a devolved issue but nevertheless the Scottish Government has shown no appetite to support the local communities. Action: invite MP Douglas Chapman to speak to NQCC.
As at 8 May 2017: see www.letsgofurther.com for the proposed flightpath over Inverkeithing to Rosyth. (Route D) . The request for response to the Consultation has now closed but if there are incividual incidences of excessive noise, contact details are on the website on the FAQ tab if a member of the public wishes to make a complaint.
North Queensferry Community Council (NQCC) has made an objection to the Flight Path Consultation. A councillor represented NQCC at a round table discussion at the Scottish Parliament with other Community Councils on 20 April 2017 prior to the submsission of the Objection.
A copy of the final objection is in the Document Library (Correspondence May 2017).