EDLESBOROUGH PARISH COUNCIL

41 Pebblemoor

Edlesborough

Dunstable

Beds. LU6 2HZ

Telephone: 01525 220859

9^th May 2008

TCN Consultation

NATS

Freepost NAT22750

Reading

RG1 4BR

Dear Sirs

Edlesborough Parish Council thanks the TCN Consultation Team for their reply dated 29 April to the Council’s comments regarding the proposed airspace changes. Regretfully your reply has done very little to allay the Council’s concerns and we would make the following points in response to your letter.

Your reply makes no reference whatsoever to the apparent discrepancies between the data in the Consultation Document relating to the relative usage of the Luton departure routes and the corresponding data in the Luton Airport’s latest AMR. As detailed in the Council’s original comments, the AMR data indicates that the proposed changes would result in an immediate sevenfold increase in traffic over flying the Parish, increasing to an eleven fold increase by 2014. The data in the Consultation document however suggests that the immediate increase in traffic would be eighteen fold, increasing to twenty eight fold by 2014. Clearly these differences are very significant and without knowing which data to believe it is extremely difficult for residents to comprehend just how much the changes will affect them. It also raises the question of how much credence does the other data in the Consultation Document have, if the straightforward historical data is not even correct.

2. Northerly Departure Routes

Your point about the changes to the northbound route no longer passing directly over the Parish of Edlesborough is largely irrelevant because as previously stated, the majority of flights reach 4000ft before they reach Edlesborough. This of course means that they disperse from the NPR before reaching us such that only about 25% of them over fly the Parish. The Council has assumed that the proportion of northbound flights over flying the Parish will remain much the same as at present whereas you have predicted a smaller proportion. Since, as you state, aircraft will have to fly further west before being released from the NPR, this will mean that those planes that currently pass to the east of Edlesborough could well pass directly overhead in future. This might result in a larger, not smaller proportion of the northbound traffic passing over the Parish, but the Council contends that the effect will be minimal.

You state in your reply that Northall and Eaton Bray would be overflown more under the proposed design, but that Edlesborough would be less affected. What you apparently do not appreciate is that Northall is part of the Parish of Edlesborough and so is represented by Edlesborough Parish Council. Furthermore, whilst the Council accepts that the village of Edlesborough is just outside the black lines shown for the new easterly and south easterly routes, you must accept that aircraft noise travels horizontally as well as vertically. Whilst the village of Edlesborough might not be affected quite as acutely as the village of Northall, there can be little doubt that residents of both villages will be subject to a very disturbing increase in aircraft noise intrusion.

Whilst the Council accept that the DfT guidelines recommend ‘minimising over-flight of more densely populated areas below 7000ft’, NATS appears to have almost completely disregarded the DfT’s other guidelines relating to the ‘preservation of the tranquillity of the countryside’ and the ‘importance of the stability of the route structure in the vicinity of airports.’ The Council appreciates the difficulty in striking an acceptable balance between these often conflicting guidelines, but it would appear that NATS have not even attempted to strike a balance.

Your letter concludes with the statement that "in order to achieve the benefits in terms of safety, efficiency and the environment across the whole TCN region there is no practical alternative to routing the departures to the east and south east around the north side of Luton." Since by your own admission the changes will at best have a neutral effect on average fuel burn per flight for the TCN region, the severe environmental disbenefits to the population beneath the new departure routes must mean that overall, the proposed changes are environmentally negative. As far as the Council is aware, the changes would not bring about any measurable improvement in safety and so the sole purpose of the proposed changes is apparently to increase capacity within the TCN region. As it is now evident that this increase in capacity cannot be achieved without contravening the DfT’s guidelines relating to the preservation of the tranquillity of the countryside and the stability of the existing route structure, Edlesborough Parish Council must continue to object to the new departure routes in the strongest possible terms.

Yours faithfully

L.C. Sargeant (Mrs.)

Clerk to Edlesborough Parish Council