June 2016: Rerouting Unsatisfactory For Harpenden Residents

The new RNAV routing for Luton Airport westerly departures has not been successful with a 45% increase in noise complaints for the first quarter following the implementation [Source: Luton Airport Quarterly Monitoring Report]. HarpendenSky has been in contact with Luton Airport flight operations, the National Air Transport Service [NATS] and the Department of Transport to progress the issue.

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August 2015: RNAV Routing Implemented

We have received this Luton Airport confirmation of the route change.

"We've finally got some good news on our RNAV airspace application. The CAA have given it informal approval which means we can now make the relevant submissions to introduce the change in procedure, which should commence from 20th August 2015".

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February 2015: Latest News On Route Change Progress

The Operations Director of Luton Airport provided an update on the RNAV1 trial outcome to HarpendenSky.com & the next steps to achieve a permanent change to westerly departures flying across west, central and south Harpenden - these were the main points:

- Westerly Luton Airport departure route [Brookmans Park] applies to 70% of airtraffic leaving the airport

- The new routing that would apply once CAA approval is granted will use a GPS rather than beacon system

- The RNAV1 trial in 2014 was successful & there were 1,400 participants in the questionnaire of which 90% were in favour

- An additional RNAV1 benefit of lower fuel burn is a significant bonus to environmental & fuel cost considerations

- The CAA is due to report on the application for the route change to a far more concentrated flightpath which avoids Harpenden by end March

- If the outcome is positive, then the changes can be implemented within 2 months

- Once this change is completed, Luton has confirmed that further routes will be tackled using the same principles

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October 2014: RNAV1 Consultation Completed

We have heard from Luton Airport that they have finished the RNAV1 consultation to change the flightpath of Luton departing airtraffic away from west, central and south Harpenden. They have submitted the Airspace Change Proposal to the CAA. The process took a bit longer than anticipated to collate the data as they had such an overwhelming response to the consultation which ended in July, but that was positive and an indication of HarpendenSky.com campaign impact with fellow supporters.

Luton Airport will advise the next steps and timetable as soon as the CAA confirm that they are happy with the proposal which should be fairly straightforward as they would not have sanctioned the Luton RNAV1 2013 trials without agreeing the potential outcome in principle.

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May 2014: Vote For Changed Airtraffic Routing

We have just been informed that the request to call-in the Luton Airport Expansion Plan, as approved by Luton Town Council Planning Department, has been rejected and that the plan will now, in all probability, proceed taking Luton capacity to about 18million passengers which is double what it is today.

At HarpendenSky.com we have always believed that this would be the case as the construction and employment investment would be too tempting for the government, which is why we have focused attention on the Luton airtraffic with the RNAV1 consultation for permanent airspace change underway now which will benefit Harpenden significantly.

Mr Peter Lilley MP has been supportive all the way along this 4 year campaign and again he indicates his endorsement for HarpendenSky.com below.

SO PLEASE MAKE SURE YOU VOTE! And ask as many neighbours or friends in the town to do so as well. Many thanks.

Subject: A Message from Peter Lilley MP Re: HarpendenSky.com Luton Airtraffic Re-routing

"Luton Airport prodded by HarpendenSky - has been trialling new flight routes which result in planes avoiding built up areas of Harpenden and Redbourn, overflying fewer homes and reaching a higher altitude sooner. This promises considerable relief to many people currently affected by noise of aircraft taking off in a south westerly direction. These routes which are narrower and steeper are made possible by new technology and phasing out of old aircraft.

If you support introducing this new routing for all aircraft please respond as suggested by HarpendenSky selecting either 210 or 220."
Peter Lilley

VOTING INFORMATION

As previously reported we have been working for the past 3 years with Luton Airport Flight Operations to alleviate the impact of airtraffic over Harpenden with an initial focus upon airtraffic on the Dover/Clacton/Dietling routing which affects west, south, east & central Harpenden. After trials last year, which were very successful in achieving our aim, a formal Luton Airport consultation process has been initiated to gain your feedback on the proposed changes under the title RNAV1.

ACTION REQUIRED

Please go to http://www.london-luton.co.uk/en/content/8/1235/rnav-consultation.html and look at the proposal, then take the short online survey. We recommend you select either 210 or 220. Please complete the survey by 9th June.

We have focused upon this airtraffic routing as a "proof-of-concept" to understand the process and ensure we can achieve results in future. As you will see from the map on the Luton Airport website, the revised RNAV1 airtraffic routing will avoid Harpenden altogether. This is vital to ensure that the proposed Luton Airport expansion will not cause airtraffic misery for Harpenden residents. We look forward to your positive vote for RNAV1 implementation that will then enable us to work on further routes. Thankyou.

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May 2014: VOTE Before 9th July 2014: Luton Airtraffic Rerouting

As previously reported we have been working for the past 3 years with Luton Airport Flight Operations to alleviate the impact of airtraffic over Harpenden with an initial focus upon airtraffic on the Dover/Clacton/Dietling routing which affects west, south, east & central Harpenden. After trials last year, which were very successful in achieving our aim, a formal Luton Airport consultation process has been initiated to gain your feedback on the proposed changes under the title RNAV1.

ACTION REQUIRED: Please go to http://www.london-luton.co.uk/en/content/8/1235/rnav-consultation.html and look at the proposal, then take the short online survey. We recommend you select either 210 or 220. Please complete the survey by 9th June.

We have focused upon this airtraffic routing as a "proof-of-concept" to understand the process and ensure we can achieve results in future. As you will see from the map on the Luton Airport website, the revised RNAV1 airtraffic routing will avoid Harpenden altogether. This is vital to ensure that the proposed Luton Airport expansion will not cause airtraffic misery for Harpenden residents. We look forward to your positive vote for RNAV1 implementation that will then enable us to work on further routes. Thankyou.

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February 2014: Luton Airport RNAV1 Trial Update

We have been liaising with Luton Airport Flight Operations on the results of the RNAV1 trial which took place last year to determine if the airtraffic impact from Luton Airport westerly departures could be alleviated from central, west and south Harpenden by using the more precise on-board P-RNAV aircraft navigation systems rather than the beacon-to-beacon approach. This would enable residential overflights to be considerably reduced.

In November 2013 we were advised by Luton Flight Operations that the RNAV1 trial had been successful insofar as [a] noise complaints had reduced significantly during the trial [b] there was a 75% reduction in population overflights including Harpenden [c] there was an aircraft fuel burn reduction with a similar impact on CO2 emissions. This is a major success.

The next phase of action for a permanent flightpath change was due to start in Q1 2014 and we have just received this update from Luton Flight Operations "Subject to agreement with Director of Airspace Policy [DAP] we are looking to go to consultation next month, which will be for a minimum period of 12 weeks as defined in CAP 725. We are then required to review all feedback and submit this information to DAP for approval". Bear in mind that DAP had to approve the RNAV1 trial so there is already momentum established.

Strategically HarpendenSky.com has focused upon flightpaths not Luton airport expansion, and we are continuing to follow this approach. We will keep you updated.

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October 2013: Luton Airport 4-Runway Expansion

You may have read about the submission to the Airports Commission by Weston Williamson & Partners [dated 19 July 2013] recommending the development of Luton Airport into a London hub with 4 runways. One of the conditions of the change is that Stanstead Airport would have to close.

Harpenden Town Council has taken this application seriously & written to the Airports Commission in response to the submission with a thoroughly detailed protest. Don't hesitate to lobby your local councillor & MP on the subject - we understand Peter Lilly MP is quoted as saying "It won't get off the ground". Let HarpendenSky.com know if you want a copy of the Harpenden Town Council letter.

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Luton RVAV1 Airtraffic Rerouting Trial Completed

August 2013

The RNAV1 trial has completed in July and we are awaiting the outcome of Luton Airport analysis of the trial results. RNAV1 affected 40% of Luton departing airtraffic using the Dover/Clacton exit with the aim to concentrate the flights into a narrower corridor and thereby significantly reduce the impact of airtraffic to the west, centre and south of Harpenden. For more information go to: http://www.london-luton.co.uk/en/content/8/1212/rnav1-trials.html

HarpendenSky has received a sample analysis from Luton Airport showing the flight concentration and to receive a copy please click here to download.

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BREAKTHROUGH: New Luton Airtraffic Navigation Trials To Alleviate Noise Over Harpenden

March 2013

We are pleased to report that in the coming weeks the Luton airtraffic departure route influencing West, Central & South Harpenden [known as Dover/Clacton Exit] will run a trial to concentrate airtraffic into a much narrower swathe [reduced in width by 60%] & take the aircraft away from Harpenden. If the trial is successful then a formal application will be made for a permanent change.

The success of the trial depends upon the degree of positive response so please make sure you report your experiences back to Luton Airport during the following periods using either the telephone number 01582 395699 voicemail or email rnav@ltn.aero: 7th March to 18th April and then 19th April to 24th May.

If these trials are successful, Luton will then run similar trails for other airtraffic routes affecting Harpenden so your participation is vital.

HarpendenSky.com supported by Harpenden Council and local political figures, including Teresa Heritage and Peter Lilley MP, has been working with Luton Airport to encourage this progress for nearly 3 years so we now need your support in ensuring a positive outcome.

Please contact us if you have any questions.

mail@harpendensky.com

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November 2012: New Strategy On Luton Airport Expansion

HarpendenSky.com believes a new less confrontational strategy is required to satisfy both Luton airport expansion plans and Harpenden resident opposition to Luton airtraffic. For example, if the airtraffic impact on Harpenden residents could be alleviated then the airport expansion is much less of an issue. This is a strategy that HarpendenSky.com has been discussing with Luton who have responded positively and we will provide updates.
September 2012: Luton Expansion Plans Over Capacity

We at HarpendenSky.com have found a significant flaw in the London Luton Airport Operations [LLAOL] Revised Masterplan which is the basis for the Luton Council planning application for airport expansion. There is already the question of conflict of interest where Luton Council who is owner of the airport is also the planning authority.

[1] LLOAL Revised Masterplan
According to the LLOAL Revised Masterplan page 8 “By 2030 the Dept of Transport forecasts that demand for airtravel through London’s airports will have risen to 180million passengers per year. Within that market the DfT currently forecasts that passenger demand at Luton Airport will grow to 17million passengers per annum [mppa]”.

[2] DfT 2012 Opinion Of Passenger Numbers
We asked the DfT to confirm these numbers under Freedom of Information in Oct 2012 [1] the DfT UK Aviation Forecasts report published in 2011 says 15mppa under the “High” scenario not 17mppa as the LLAOL Masterplan [a 14% over exaggeration & already a reason to have the plan “called in” by the minister] but even more significantly the DfT commented as follows to HarpendenSky.com FoI request on 5th October:

“However, when publishing forecasts we are conscious of the inherent uncertainty in predicting the future state of the economy; this is why we always publish a range of demand scenarios. Table G3 (page 150) of UK Aviation Forecasts, 2011 shows an airport level breakdown of passenger forecasts under our central, low and high demand scenarios, and chapter 2 outlines the assumptions used (including economic growth) in each scenario. Given the widespread downward revisions in economic outlook since publication of this report you may find the information provided for the low demand scenario of interest.
Source DfT Jon Franklin 5October 2012.

[3] LLOAL Masterplan Flaw
The DfT UK Aviation Forecast “Low 2030 mppa” number for Luton Airport is 14mppa – this means that the LLAOL Masterplan has a +22% exaggeration on the mppa figures which must be called into question by the Luton Council planning authority or “called in” by the minister! Of course all the other related statistics in the Masterplan like income, employment etc must be similarly downgraded.

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Luton Airport Expansion
Luton Airport [LLAL] has been granted in July an extension of its contract with Luton Borough Council [LBC] to 2031 which enables the airport to make investments and progress both their vision and a consolidated planning application due to be discussed in September. The impact, should the planning be successful, would be an approximate doubling of Luton airtraffic.
  • An efficient airport, optimised within existing boundaries using the existing runway, with capacity for 18 million passengers annually by 2025/28
  • A sustainable airport with future-proofed opportunities beyond 2028
  • An approach that provides economic benefit to Luton and the region taking balanced steps to mitigate environmental Impacts
  • An appropriate commercial risk structure
  • An improved experience for passengers and for airline operators
Political Positions
Peter Lilley MP said to HarpendenSky.com: “LBCs plans for Luton airport expansion are subject to 2 tests [a] can the noise of additional flights be offset by less noisy planes and better routing [b] can the existing or planned infrastructure cope with the burden of additional passenger traffic”.

Councillor Teresa Heritage is very clear to HarpendenSky.com “I sit on the County Council as well as St Albans District Council and I have been involved with the drafting of the responses highlighting the problems with the plans of both the operator and the airport authority itself [now consolidated]. You are also aware that I have supported your group HarpendenSky.com for many years in relation to night flights and overflying - this is not just me speaking but all local conservative councillors”.

HarpendenSky.com Activity
HarpendenSky.com have a direct line to LLAL and have been in direct discussion on the point of separating the airport planning issue from airtraffic management with the prime focus upon the latter insofar as it affects Harpenden. We are maintaining our progress in a positive dialogue both politically and with the airport and will keep you informed.

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April 2012: This is the latest HarpendenSky.com bulletin including a copy of the response to the LLA consultation as their online questionnaire is so biased in their favour with no space for serious protest.

Luton Airport [LLA] Masterplan Consultancy Deadline 25April
LLA now has a Masterplan online at www.london-luton.co.uk/masterplan.
  • LLA Masterplan Format:
    There are 2 primary issues – the impact of the airport and airtraffic. Because LLA has almost no control over airtraffic this issue is not taken seriously as nowhere in the plan is NATS a contributor with a plan on how the airtraffic will be handled. The plan should be structured accordingly.
  • LLA Plan Item 2.1 Vision Issue DfT Forecasts:
    The LLA plan misconstrues the DfT strategy which is for major airport hub consolidation with the infrastructure that can be environmentally and economically supported and sustained. The area around LLA, on land and in the sky, cannot support another 8million+ passengers.
  • LLA Plan Item 3.20 to 3.25 & 9.26: Noise
    LLA has no direct control over flights [hence noise, pollution etc] as this is the responsibility of NATS. The EIA must include a plan from NATS demonstrating how the extra flights will be routed in terms of flightpath, height and frequency.
  • LLA Plan Item 9.22 & 9.25 Water Resources:
    Veolia Water already has Herts and Beds under drought restrictions and the River Lea is a major source of Harpenden water supply. Another 8million+ passengers in south Beds at the expanded LLA will significantly impact water supplies to Harpenden. The EIA must independently forecast the water consumption and confirm the resource impact and what will be the consequences for wildlife.
  • LLA Plan Item 9.14 to 9.17
    Jobs and the local economic consequences have been forecast in the LLA Masterplan by 2 organisations who stand to gain from the LLA plan execution. Independent research by Brian Sewell an ex-Treasury adviser suggests “The growth in airtravel is likely to lead to a net loss of a further 860,000 UK jobs by 2030. This loss of jobs will affect every part of the UK” Source: “Airport Jobs – False Hopes, Cruel Hoax” by Brendon Sewell. The LLA plan needs an independent assessment that takes Brendon Sewell’s insight into account.
Local Elections May 3 2012
For HarpendenSky.com members it is important that you ensure your district and local council candidates for the May 3 elections voice their support for our campaign objectives and those of aligned organisations Herts Against Luton Expansion [HALE covering Flamstead, Markyate & Redbourn] plus Save Our Skies in St Albans. This is an extract from a note to HarpendenSky.com from Theresa Heritage District Councellor after HarpendenSky.com engaged:

As you know I sit on the County Council as well as St Albans District Council and I have been involved with the drafting of the responses highlighting the problems with the plans of both the operator and the airport authority itself. You are also aware that I have supported your group [HarpendenSky.com] for many years in relation to night flights and overflying - this is not just me speaking but all local Conservative councillors.

It is unfortunate that you do not feel enough was said in the In Touch [mailer] by David [Heritage] and Rachel [Frosh], this was not intended as a slight of the importance of the subject but we have been consistent, as I have said, in our opposition and did not consider further expansion of the point. However we have listened and will make sure we will feedback more strongly to the community in the future.

You are obviously aware that the response to any Planning Application that is submitted to Luton Borough will be the most important document for us to respond to. The scoping consultation did not actually provide a robust enough evidence base so one did end up asking more questions than being able to answer any - when this comes and if I am in post at St Albans in my current capacity, I will ensure that a robust response is given and I am sure you will ensure an equally robust response from your colleagues.


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February 2012: HarpendenSky.com has been working with Peter Lilley on the subject of the proposed Luton Airport Expansion with the following result so far. HarpendenSky.com consider the key subject is aircraft routing which Mr Lilley has incorporated in his release.

LILLEY COMMENTS ON LUTON AIRPORT DEVELOPMENT
Peter Lilley, MP for Hitchin and Harpenden, told constituents that Luton Borough Council’s plans for expansion at Luton Airport should be subject to two tests: first, can the noise of additional flights be offset by less noisy planes and better routing; second, can the existing or planned infrastructure cope with the burden of additional passenger traffic?

He said: “I shall pay close attention to views expressed during the planned local consultation. I have always argued that expansion plans must be subject to these two tests but the consultation may raise other issues. It was clear that the previous plans to convert Luton into a long haul airport with a jumbo jet a minute disgorging an extra 25 million passengers failed those tests. So I was delighted when it was withdrawn.

“That does not mean we should oppose all expansion outright if environmental and infrastructure problems can be overcome. We need the jobs, business and travel opportunities that Luton can generate. But I am surprised Luton Borough Council and the Airport operator are proposing plans on this scale before they have tackled the massive congestion at the entrance to the airport.”


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November 2011: You may have read in the media that Redbourn and Flamstead are now embroiled in the pressure upon Luton to ensure airtraffic follows the centre line of the Dover/Clacton exit path to the West and South of Harpenden as originally inspired by the HarpendenSky campaign in 2010 and supported by Peter Lilley MP, Teresa Heritage Councillor and John Bagshaw Harpenden Town Clerk plus regular reporting in the Herts Advertiser.

This is the latest information on the flightpath centreline navigation trail inspired by HarpendenSky.com with your support, agreed by Luton Airport and being undertaken initially with EasyJet.

Luton Airport Airfield Environment Office To HarpendenSky.com 5 Nov 2011: I can confirm that the easyJet trial to help contain flight routes within the existing 26 Clacton/Dover/Detling Noise Preferential Route (NPR) corridor is still underway. We have been working very closely with easyJet to find the best solution to help minimise the direct overflight of all the most densely populated areas south of the airfield before incorporating other airlines.

However, we anticipate that Monarch and other airlines will be following revised procedures within the next couple of weeks and whilst a small number of Luton departures on this heading may still overfly Harpenden, as a result of revised vectors by NATS, the vast majority should soon be following flightpaths within the NPR corridor, between Harpenden and St Albans.

You will appreciate that the trial has involved ongoing liaison with our airline partners, NATS and the CAA, as well as initial simulation work and analysis of flight track data. Progress on the trial is being reported to the London Luton Airport Consultative Committee (LLACC) and the Noise and Track Sub-Committee (NTSC) - a list of Committee members can be found on the LLACC website www.llacc.com. End.


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July 2011: Update on Brookmans Park Turn Project trial from Luton Airport Airfield Environment Office received July 2011:

“I am pleased to report that easyJet are progressing with the trial, aiming to find an optimum flightpath along or just south of the NPR route centreline on the 26 Clacton/Dover/Detling flight route. This will then help avoid the direct overflight of Hemel Hempstead, Redbourn, Harpenden and St Albans, as is often the case with departures currently following this heading although Air Traffic Control may still, on occasions, tactically vector aircraft outside the NPR corridor at altitudes in excess of 3,000ft during the day or 4,000ft at night. We are still in the early stages of the trial but we continue to work closely with easyJet to find the best solution for all concerned before incorporating other airlines”.

Source: Luton Airport Airfield Environment Office 21 July 2011

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PRESS RELEASE FROM THE RT HON PETER LILLEY MP

Wednesday 25th May 2011

MP SUPPORTS LOCAL PROJECT TO MINIMISE PLANE NOISE OVER HARPENDEN

Peter Lilley has shown his support for the ‘Brookmans Park Turn Project’, which will ask pilots to hold to the centreline of the Dover/Clacton departure flight path. The Turn Project aims to alleviate the impact of air traffic on the daily lives of Harpenden residents by rerouting the increasing volume of air traffic currently over the town. When implemented, it has been estimated that it will take hundreds of Harpenden homes out of the noise zone.

Peter Lilley has paid tribute to the HarpendenSky.com campaign, which culminated in the Turn Project, saying: “I know from my mailbag that an increasing number of my constituents in Harpenden are being subjected to noise caused by aircraft overflights. I am very pleased that EasyJet have agreed to an initial trial to help improve track-keeping on this particular flight route.

“I hope that Luton Airport and EasyJet will come to a solution that will minimise noise to hundreds of Harpenden homes and have a real impact on the quality of life of Harpenden residents.”

“I wrote to Luton Airport to encourage the trial and am writing again to Glyn Jones, MD of Luton Airport, to thank him for this progress and encourage a positive outcome of the trial.”

ENDS
For further information, contact Annabel Palmer
palmerak@parliament.uk
Tel: 020 7219 4577

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We have been quietly working away on the Brookmans Park Turn Project that was agreed by Luton Airport as a consequence of the media and political campaign HarpendenSky.com ran at the end of 2010. The project will ask pilots to hold to the centreline of the Dover/Clacton departure flightpath which has caused such disturbance in the past. When implemented we estimate this will take 100s of west and south Harpenden homes out of the noise zone!

The project starts with an EasyJet trial and this is the latest information from Luton Airport dated 19th May 2011:
"With regard to the Brookmans Park project, I can confirm that, following detailed discussions and simulation work, easyJet are currently carrying out an initial trial to help improve track-keeping on this particular flight route. We will be closely monitoring the actual flown tracks of those aircraft participating in the trial and liaising with easyJet to find the best solution."
Regards
Karen Goodman
Airfield Environment Office
London Luton Airport


The HarpendenSky.com campaign culminating in the Brookmans Park Turn Project has had political support from Peter Lilley MP and Teresa Heritage District Councillor plus John Bagshaw Harpenden Town Clerk, all of whom were persuaded to write to Luton Airport and encourage the trial. Similarly HarpendenSky.com has received front page editorial from the Herts Advertiser. We will keep you posted.

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NEW BREAKTHROUGH: Brookmans Park Turn Project
Luton Airport are now running a trial with EasyJet to hold air traffic to the CENTRELINE of the Dover/Clacton Exit route which will alleviate disturbance from Luton departures for the majority of south Harpenden residents. This significant announcement came at a meeting between HarpendenSky.com and Neil Thompson Operations Director Luton Airport accompanied by Karen Goodman Luton Airport Airfield Environment Office. The more precise navigation routing is known as the Brookmans Park Turn Project and will be implemented from Spring 2011. Stay in touch with HarpendenSky.com for updates.

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NATS Terminal Control North Postponement
NATS state “The downturn in air traffic levels since the 2008 consultation on proposed changes in the Terminal Control North (TCN) area, means there is less urgency on capacity grounds to achieve the changes”. This is completely irrational for the following reasons:
  • Airtraffic Today: when TCN was originated and justified back in 2006 the airtraffic levels were similar to today.
  • Airtraffic Volume: the low cost airlines that predominate in TCN airspace are not seeing declines – EasyJet has just announced in October 2010 a record set of results with passenger traffic up 8% to 4.77million passengers and “There’s no trend towards staycations we have seen,” said spokesman Oliver Aust. “People took their foreign vacations.” Source: Telegraph 7 Oct 2010.
  • NATS Competence: Easyjet criticises outdated air traffic systems with CEO Ms Carolyn McCall calling for “European governments and the European Commission to modernise Europe’s outdated system of air traffic control providers” Source: Telegraph 7 Oct 2010.
  • CAA Safety Plan 2009-2011: In the plan statistics for “high severity occurrence rates” for large passenger aircraft show an alarming 250%+ increase by comparing 2009 to 2004 and it continues to increase with stats provided to www.HarpendenSky.com by the CAA under the FoI Act. This further endorses the www.HarpendenSky.com opinion that NATS decision on TCN is completely irrational when safety risk is growing so dramatically including across the crowded skies north of London.
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Luton Departure Short Cuts
Peter Lilley MP has joined the www.HarpendenSky.com campaign in taking up with the CAA CEO Andrew Haines the frequent “short cuts” across Harpenden being taken by Luton aircraft rather than holding to the centre of the Noise Preferential Routes like Dover/Clacton.

Luton air traffic control has predominantly been transferred to NATS at Swanick near Southampton and www.HarpendenSky.com believe they have no idea of the fury they are generating with this mis-direction of flights.

In addition these aircraft at being routed across populated areas of Harpenden at 4,000feet or less in direct contravention of government guidelines which require 7,000feet minimum.

In addition to noise and stress this is an environmental issue as extra tons of noxious gasses are being dumped on the town as aircraft engines burn fuel at a far higher rate when flying at 4,000feet or less than they do at 7,000feet and above.
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