Heathrow Flight Paths Consultation

Heathrow Airport is consulting on proposed new flight paths, to make better use of the existing two runways and in preparation for the new third runway. The proposed changes are likely to lead to increased aircraft noise in Wimbledon. They held an initial consultation from 8th January til 4th March 2019, and Merton Liberal Democrats submitted the below response.

Full details of the consultation, including the questions, can be found on the Heathrow Consultation website.

Merton Liberal Democrats’ submission to the Heathrow Airspace and Future Operations Consultation:

Introductory comments:

We wanted to make a number of initial comments before turning to the specific questions (which could also be considered a response to questions 9 and 10 of the consultation):

  • The consultation seems based on the assumption that a third Heathrow runway will go ahead. We would take this opportunity to reiterate the firm opposition from the Liberal Democrats at all levels to a third runway at Heathrow, primarily on grounds of increased air and noise pollution.
  • We have concerns about the nature of the consultation. Whilst you are consulting on a complex series of issues, the amount of information is confusing, and in some instances it is clear that the policy decision has been made, and false choices are being offered up for choice.
  • The consultation fails to adequately consider the cumulative impact of changes at Heathrow, which needs to be addressed in relation to the growth in flights from other airports, most notably City Airport where the impact of noise is increasingly an issue for people in many parts of north east, east and south east London.
  • Merton does not currently experience any flight paths on the approach to Heathrow, and generally avoids aircraft noise (depending on the prevailing wind). An increase in flights over the borough would therefore have a disproportionate impact on noise and more air pollution.

Q1a.  Do you support our proposals for a noise objective?


  • Yes, but a radically different noise objective than that set out.

Q1b. Please provide any comments you have on our proposals for a noise objective


  • We feel that the stated objective should be an outright commitment to reduce noise levels overall, as the only real way to mitigate the effects of noise on health and quality of life, for the following reasons:
  • The proposals are only to “limit and, where possible, reduce the effects of noise on health and quality of life” as opposed to committing to reduce noise. Limiting the effects will presumably include measures such as sound-proofing for schools, workplaces and residential homes. This will only mitigate the effects as long as people remain inside. Children should be able to play outside as much as possible, and everyone’s quality of life is enhanced by the peaceful enjoyment of open spaces. 
  • Local residents need longer breaks from scheduled flights, particularly at night. There is little benefit in these breaks being regular or predictable if they are not long enough for people to enjoy uninterrupted sleep.
  • There should be no flight noise at all between 11pm and 7am. The objective should be to reduce or eliminate flights from 11pm until 7am, not “manage” their impact. 

Q2a. Would you prefer to have longer periods of respite less frequently or a shorter period of respite every day?


  • While recognising that people would have differing views on this issue, there does overall seem merit enabling people to have daily rest, and some time each day for the enjoyment of the outdoors and their local environment. 

Q2b. Please tell us the reasons for your preference.


  • Despite the above, it is vital that this policy is combined with an overall objective to reduce nuisance to local communities and take all possible measures to increase the hours of respite available to as many people as possible.

Q2c. Please provide any other comments or suggestions you have on runway and airspace alternation.


  • New flight paths should be coordinated with London City flight paths to avoid, where possible, areas being overflown by both sets of aircraft at the same time. 

Q3a. Should we prefer westerly operations during the day and easterly operations at night to reduce the total number of people affected by noise?


  • This is a false choice which Heathrow is suggesting must be made.

Q3b. Please tell us the reasons for your answer.


  • We feel that night flights should be ended entirely.  

Q3c. Should we sometimes intervene to change the direction of arriving and departing aircraft to provide relief from prolonged periods of operating in one direction – even if that means slightly increasing the number of people affected by noise?


  • Yes

Q3d. Please tell us the reasons for your answer.


  • We feel that “managed preference” has some advantages, and might enable better co-ordination with London City airport.

Q4a.  To help inform our consideration of the options, we want to know whether you would prefer for us to:

Use one runway for scheduled arrivals from 5.30am (runway time 5.15am)

Use two runways for scheduled arrivals from 5.45am (runway time 5.30am)


  • We don’t believe any of Heathrow’s runways should be used before 6.00 am.  

Q4b. Please tell us the reasons for your preference


  • The consultation does not offer clear evidence of the assertion that night flights make a “significant contribution” to the UK economy – just a vague reference to “independent studies”.
  • A trade off clearly exists: the economic impact of poor sleep and impact on the health of workers living near the airport should be taken into account. The health of people living near the airport should be the overriding priority.

Q4c. Please provide any other comments or suggestions you might have on early morning arrivals


  • We don’t believe any of Heathrow’s runways should be used before 6.00 am.  
  • But, the priority should be providing residents a lengthy break from noise on a regular basis.

Q5a.  Please provide any comments or suggestions on how we should encourage the use of the quietest type of aircraft at night (outside the proposed scheduled night flight ban)?


  • Implement an outright ban on any aircraft landing at night with older or noisier engines.

Q5b. Please provide any other comments you have on night flights and restrictions:


  • It is important that Heathrow understands the impact its operations are having right across the capital. Severe levels of noise disruption now being experienced by some of London’s residents are not acceptable, and urgent, decisive action is needed across the board to alleviate it.

Q6. Airspace – local factors. To answer this question, please look at the design envelopes for expansion online using the postcode checker or look at them in our document Heathrow’s airspace design principles for expansion. What sites or local factors should we be aware of in your area (or other area of interest to you), when designing flight paths for an expanded three-runway Heathrow? Please give enough information (e.g. postcode, address or place name) for us to identify the site(s) or local factor(s) you are referring to and tell us why you think it is important:


Q9 Having considered everything within the consultation, do you have any other comments?

Q10. Please give us your feedback on this consultation (such as the documents, website or events)

Responses to Q9 and Q10:

  • See the “introductory comments” above.

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