FarnboroughAirportConsultationTrottonResponse.docx Page 1 of 2

TAG Farnborough Airport additional airspace consultation This paper is the response by Trotton-with-Chithurst Parish Council to the consultation by TAG Farnborough (TAGF) on

its airspace change proposal.

We object to this proposal on two sets of grounds:

1. The consultation process: we believe this has been inadequate in a number of ways and believe it should be extended to give residents more time to study, discuss and respond properly

2. The airspace change proposal itself: we object strongly, on several grounds, to the proposed routing of much heavier air traffic over our parish and over the South Downs National Park (SDNP) in general.

Part one: the consultation process

The TAGF consultation was launched during the summer holidays, so that many residents, councils and other interested

parties were unaware of the first public consultation meeting in Midhurst on Thursday 1 September 2016. As a result,

TAGF extended the consultation period by four weeks to 2nd November. However, there seems to have been very little

determined publicity for the consultation process and many interested parties have only become aware of it in the last

few weeks – leaving little time to study, consult and discuss.

In the specific case of parish councils, which should be a main conduit in the current area of consultation, most of have

no meeting in August, so were unaware of the issues until our September meetings. Many of these agreed to look at the

issues and delegated this task to a sub-committee, working group or individual. The conclusions (if it were possible to

reach any – see below) would then typically need to be discussed at a meeting in November (many rural parishes meet

only every two months) – after the end of the consultation period. For such an important proposal, launched only in the

summer holidays, there has simply not been enough time to go through the proper process of preparing facts and

consulting residents fully.

Furthermore, the consultation documents were, in our opinion, woefully inadequate for the purpose of consulting

normal householders and parish councils (which do not have funds to employ professional advice without notice. The

official documents are extremely hard for lay people to understand and do not give adequate, clear information for

residents and councils to judge issues such as:

- Where are the existing and proposed areas of controlled airspace (maps are not clear)?

- What exactly are the existing and proposed routings for inbound and outbound air traffic (maps are

unnecessarily complex for residents to understand)?

- What are the proposed flight paths vertically over each part of the consultation area (ditto)?

- How many flights are there currently and how many would be expected over each area in peak and non-peak

hours and what would be the likely increase in noise levels of each – ie impact on SDNP tranquillity policies?

- How many flights would be expected in hours of darkness compared with the current numbers – ie impact on

SDNP dark skies policy (which was not even addressed)?

In our view, therefore, the consultation period, publicity for it and information given in the official consultation

documents were all woefully inadequate for residents and their representatives to be able to assess the impact of the

proposals without professional advice. The information available at the parishes meeting in Elsted on 18th October was

much better, but still left too many questions open and, even if it hadn’t, was too late to give parish councils a proper

opportunity to consult and respond

We therefore urge the CAA to insist on a further extension of the consultation period, allowing at least 6 weeks from

the date when better information is made available.

FarnboroughAirportConsultationTrottonResponse.docx Page 2 of 2

Part two: The airspace change proposal itself

As we understand them (and, as outlined above, we do not feel we were given enough information to understand them

fully), the proposal would channel outgoing traffic entirely outside the consultation area – and thus our parish - so we

do not object to this!

However, we understand that the proposal is to concentrate all arriving TAGF traffic into an air “corridor” three miles on

either side of the route shown in appendix A. Currently, 60% of the traffic is routed East of Midhurst (primary); 30% is

dispersed over an area approximately 20 miles wide in which we are central; and 10% is well to the West of us. This

implies that some 10% of all inbound traffic (one third of the 30%) is currently using the area 3 miles either side of us,

and this will increase to 100% - a ten-fold increase. In addition, TAGF is currently running at less than half its allowed

traffic so, if this doubled to the full allowance, we would be seeing 20 times today’s traffic levels.

Furthermore, this proposed “corridor” will channel air traffic over some of the most open, attractive areas of the South

Downs National Park (SDNP), including the Goodwood and Grovers Estates, the West Dean valley and Singleton open air

museum, the Kingley Vale nature reserve, and the Trotton, Iping, Stedham and Midhurst commons.

While the proposals are apparently guided by government policies that favour concentrating air traffic and other noise

rather than dispersing them, the plans would focus noise over areas previously known for their exceptional

peacefulness - as shown by Appendix 1, the route actually flies over several of the most tranquil parts of the whole of SE

England. It would seem much more logical to move the “corridor” to go above the A3 or other main roads, where

existing noise levels would massively reduce the impact.

The TAGF team were unable to give us any figures for the number of flights that would use the proposed route in the

hours of darkness but, as appendix 2 shows, the proposed route would also fly right over some of SE Englands most

notable areas of “dark skies”.

We note that the SDNP was not even mentioned in the proposal but we would point out that the SDNPA gives as its

third most important priority (behind only enhancing the natural beauty and ecosystem of the national park) to “Protect

and enhance tranquillity and dark night skies”. Under the government’s own ‘Sandford principles’, “Where

irreconcilable conflicts exist between conservation and public enjoyment, then conservation interest should take

priority". Yet the TAGF proposals appear to violate this principle not for the sake of large proportion of the country’s

residents, or for the overall national economy, but for the narrow interests of a tiny number of the rich and famous –

and for the benefit of TAGF and NATS!

At this point, we should also note that the proposal is apparently to be assessed by the CAA, which owns a large

minority share in NATS, and can thus be considered to be an interested party, rather than a neutral judge of the

proposals. We propose to consult other local interests and suggest urging our MP to press for a neutral third party to

assess such airspace change proposals when there is a clear benefit to NATS (and thus, indirectly, to the CAA).

In summary, we object to the proposals, primarily because they would increase noise and air pollution over an area

famous for many decades for its tranquillity and clean air as well as violating the SDNPA dark skies policy and the

government’s ‘Sandford principles’.

On a wider front, we will also be urging the SDNPA to push for a blanket ban on all commercial air traffic flying over

the SDNP below 5,000 feet.

Primary route (approximate)

APPENDIX 1Areas of relative tranquillity [map 3.1 from “State of the national park, 2012]

Proposed route crosses some of the most tranquil parts of the SDNP

Primary route (approximate)

APPENDIX 2Light pollution [map 3.2 from “State of the national park, 2012]

Proposed route crosses some of the darkest parts of the SDNP