Please refer to the objections document that can be downloaded here: Link
- Available and future ATC tech can handle more capacity without splitting stacks and possibly without using stacks at all by managing approach speeds from a point further away from the airport.
- According to Eurocontrol, a 43 nation membership organisation which includes the UK, “Air traffic management stands to benefit significantly from artificial intelligence (AI) by virtue of its reliance on repetitive activity – which lends itself to analysis and machine learning. In addition, much of the complexity is embedded in the driving factors that deliver safe air traffic control: for example flight planning, flow management, safety assessments and conflict prediction. It is no surprise the industry is adopting the technology to enhance both planning and operational activities, and early trials by EUROCONTROL reveal gains of between 20-30% in terms of predictability and efficiency.”
- The consultation documents say that the new stack is needed for safety reasons because of increased numbers of flights, but in fact this is reverse causation. Increased numbers of flights will happen above a certain level when or if capacity at Luton airport is expanded due to the construction of a second terminal. The safest thing to do, basis current environmental law, as upheld by the High Court in the case of Heathrow’s proposed third runway, is not to expand capacity at the airport.
- In the event that capacity is allowed to expand, the safest thing to do is to stagger arrivals using the latest ATC technology so that stacking of flights is unnecessary. New techniques for ATC including linear hold point merge and linear hold trombone, both promoted by NATS, would largely eliminate the need for this stack and its descent path. 
- The preferred solution in the consultation, namely the stack and narrow final approach path, is based on obsolete thinking and practice. The planners should be encouraged to think again based on the technology and best practice currently available to them.