Noise groups consider night flights consultation inadequate, as it fails to balance society costs against economic benefits
Campaigners against unacceptable levels of aircraft noise believe the current night flights consultation is unacceptable, because it prioritises the economic benefits of night flights over the costs to society of noise at night. The groups say people responding to the consultation should point out that the government’s role as regulator is to assess carefully the benefits and costs of night flights and strike an appropriate balance. Setting an objective of “maintaining the existing benefits of night flights” precludes such an assessment: the Government cannot start its options appraisal process by assuming what the answer should be, they say. The groups acknowledge that some of the Government’s proposals are helpful, such as the inclusion of currently exempt aircraft in the limits, and the potential reduction in the total amount of noise that can be generated at night. They believe the Government should implement its proposals for a two-year period only, and commit to carrying out a full assessment of the costs and benefits of night flights in that period. In the longer term the groups believe night flights should be eliminated entirely, as they may be at Heathrow, recognising the increasing evidence that they can have serious health consequences for people overflown. Some advice on how to respond to the consultation – more to follow soon.
Notes from discussions with campaign groups on the inadequacy of the current night flights consultation
Campaigners against unacceptable levels of aircraft noise have been working together for some time, and having meetings with the CAA and the DfT.
The issue of night flights is particularly contentious, because of any time of day to be subjected to plane noise, night time is by far the most disliked.
Recently two of the lead campaigners met staff from the DfT, to discuss the issues. They made the point that the objective the government has proposed (which states that its goal is to maintain all the current benefits of night flights), has precluded the carrying out of a proper assessment of the costs and benefits of night flights.
The DfT do acknowledge night flights are of greatest concern to communities, but they have not carried out a proper assessment of the costs and benefits, looking at the costs to those overflown as well as commercial benefits to the aviation industry.
As a result, the campaigners have told the DfT that the proposals it has made, on night flights, are not fit for purpose. They therefore believe the current night flights consultation (ends 28th February) should be withdrawn.
The DfT considers the consultation does question the presumption (the objective) of the economic benefits of night fights. But the campaigners point out that this is not the case. The consultation very much takes the position that the benefits of the economic benefits are agreed – a fait accompli – and the night flight proposals are based on this assumption.
The campaigners argue that without the assumption that the economic benefits of night flights must be retained, the whole consultation becomes invalid.
They say the right thing to have done would have been a two stage consultation process:
– first, agree the objectives
– second, the best means of achieving them.
The night flight consultation is, in practical terms, not adequate. However, the DfT would not be willing to lose face, and be seen to give way, in withdrawing the consultation.
Some sort of arrangements would need to be put in place from October 2017, when the current night flights regime ends.
The campaigners have told the DfT that they favour a short extension of the current arrangements, subject to inclusion of the exempt aircraft and noise quota reduction measures that are proposed in the consultation.
If that was best achieved not by withdrawing the consultation, but rather by this emerging as the conclusion arising from the consultation, that would be acceptable.
It would probably take several years for the night flights consultation to be re-done, because the DfT will be preoccupied this coming year with the Heathrow National Policy Statement (NPS), an airspace consultation, and consultations on various green papers, leading up to a new Airspace Strategy to replace the 2013 Aviation Policy Framework.
The campaigners would tolerate a further delay in the night flight proposals, provided that the quota numbers are reduced, to not allow further night flights, and to encourage airlines to use less noisy aircraft as soon as possible.
It is understood that Heathrow hopes to get favourable publicity for its 3rd runway bit, by agreeing to some slight reduction in the number of night flights, and slight extension of the hours with no scheduled flights.
The government – rather cynically – does not want to make any concessions on night flights before this, watering down the impact of the plans that are part of the 3rd runway proposals. It would not want to lost a good PR point.
Though this may be the politics of the situation, it should not stand in the way of a properly conducted night flight consultation.
It may indeed be possible for the next night flights regime to last for different lengths of itme at the three airports (Heathrow, Gatwick and Stansted), as their situations are different. These could range from 2 – 5 years.
The groups campaigning against aircraft noise are unhappy about the manner in which the consultation counts those negatively affected. They consider the consultation’s estimates of the numbers of people regarded as “main affected parties” as hopelessly wrong. The real world numbers, not merely those living within arbitrarily drawn average noise contours, are much higher than the consultation suggests.
As the DfT will not withdraw the current consultation, those responding to it should make a few particular points. (More guidance will be given to those in the Gatwick area, by their campaign groups, shortly).
The points to make are:
Question Q1a. How strongly do you agree or disagree with our proposed environmental objective for the next regime?
Points for replies: The objective is not appropriate. The government’s role as regulator is to assess carefully the benefits and costs of night flights and strike an appropriate balance. Setting an objective of “maintaining the existing benefits of night flights” precludes such an assessment, and the government has not carried one out. No meaningful options appraisal starts by assuming what the right answer is. By defining its objective in this way the government has unacceptably circumscribed the work done and failed to consider an appropriate range of options.
Question Q2a. How strongly do you agree or disagree with our proposal for the length of the next regime?
Points for replies: The proposed period is not appropriate. Given the limitations inherent in the government’s objective and in the work it has therefore carried out, the next regime should be set for the shortest period needed to carry out a proper assessment of the costs and benefits of night flights. We suggest no more than two years.
As the consultation as it stands is not adequate, people need to respond to say ultimately night flights should be reduced, even if there is a phase-out period lasting several years. If the consultation provides a proper balance between the costs to society of night flights, and the benefits of the aviation industry, it would be more credible.
Richmond Heathrow Campaign response
The Richmond Heathrow Campaign has submitted a detailed response, saying night flights are not needed at Heathrow. There is capacity in the day time to absorb all the current night flights. Their response is here and their guidance on how to respond to the consultation is here.
Gatwick has more night flights than Heathrow or Stansted – and that will continue for next 5 years
The Government Department for Transport (DfT) has released the long awaited night flight consultation documents (ends 28th February). The number of flights between 23:00 and 07.00 would not be reduced. The current number, and the one proposed for the next 5 years, is 3,250 in the winter and 11,200 in the summer, making an annual total of 14,450 which averages as 40 per night through the year. There will be a slight reduction in the quota count, as it is not being used – so the new figure will not change anything. This will be a reduction of at least 345 in the winter to 1655 [from 2000] and 1,330 in the summer to 4870 [from 6200]. Local campaign group CAGNE has commented about how unsatisfactory the proposals for Gatwick are. Sally Pavey, Chair of CAGNE said: “We would like to see a total ban on Gatwick night flights as this is a major cause of complaints we receive from communities. Summer nights especially when residents want to enjoy their gardens and have windows open on hot evenings.” CAGNE says it is regrettable that the government seems to “accept the economic case over the health implications of allowing night flights to continue.” Gatwick plans to continue to grow at perhaps 10% per year, meaning continually increasing noise.
DfT publishes disappointing consultation on night flight regime at Heathrow, Gatwick & Stansted
The long awaited consultation on Night flying restrictions at Heathrow, Gatwick and Stansted has now finally been published, for the 5 years to October 2022 (well before any new runway). It has been delayed for 3 years. Many people whose sleep is disturbed by night flights had been hoping for real prospects of the number of night flights being reduced. However, the consultation (that ends on 28th February) merely suggests keeping the numbers of flights between 23:30 and 06:00 the same at Heathrow and Gatwick, but increasing the number at Stansted. [“Night” is defined as 2300-0700 local time]. At Heathrow the number would remain at 2,550 in the winter and 3,250 in the summer (seasons based on dates the clocks change to/from summer time). That is an annual total of 5,800 which averages as 16 per night through the year. The figure at Gatwick is 3,250 in the winter and 11,200 in the summer, making an annual total of 14,450 which averages as 40 per night through the year. However, the DfT proposes reducing the total noise quota (points based on the noise of planes at night) at Heathrow Airport by at least 43% in the winter and 50% in the summer, ie. a reduction of at least 1,740 in the winter to 2,340 (from 4080) and 2,560 in the summer to 2,540 (from 5100). The cut in quota count at Gatwick would be 17% in winter and 21% in summer., ie. a reduction of at least 345 in the winter to 1655 (from 2000) and 1,330 in the summer to 4870 (from 6200).
CAGNE listens to residents of West Sussex and Surrey and joins the call for a night ban at Gatwick
The long awaited Department for Transport (DfT) night flight consultation was finally released on 12th January. It is intended the new regime will last for 5 years, and there will be no cut in the number of night flights in this time. There will be minimal, and theoretical, cuts in the quota count (a scoring system based on how noisy planes are). Commenting on the consultation, Sally Pavey, Chair of CAGNE said the deadline for comment of 28th February leaves too little time for residents to respond. The consultation continues to ignore the impact night flights have on people’s health. The government should, instead of just looking at economic benefits (largely to airlines) consider the health implications of high levels of noise at night, not allowing enough quiet hours for healthy sleep. Ideally CAGNE, along with other groups, would like to see the consultation halted, and revised to contain measures to genuinely reduce the burden of night flight noise. Instead, the consultation proposes allowing many more flights in the night period, in winter, at Gatwick. Gatwick already has the most night flights. In summer 2016, Heathrow had 2,949 (3,250 allowed), Gatwick had 11,303 (11,200 allowed) and Stansted 7,370 (7,000 allowed). This number of night flights is “simply unacceptable to residents around Gatwick.” They should be phased out, not increased.
Government’s plans on Heathrow night flights have been slammed by campaigners in Berkshire
Campaigners against Heathrow noise, in Berkshire, have sharply criticised the proposals by the DfT (published on 12th January) to make no effective cuts in the airport’s night noise. Local group RAAN (Residents Against Aircraft Noise) say members of the public will be extremely disappointed with the plans. Murray Barter, chairman of RAAN said: “If the government are serious on ending night flights, this is the first test of their sincerity in doing so. The elephants in the room are the many ‘unscheduled’ night departures that overrun past their scheduled departures which are allowed to continue seemingly unabated and unrestricted throughout the night. … the ‘night’ period is curtailed to six and a half hours, which is against the World Health Organisation guidelines of eight hours. … Nothing within this consultation or regarding Heathrow expansion will alter this for the better.” A carefully worded statement by the minister, Lord Ahmad, attempts to conceal the fact that the plans will do almost nothing to reduce the noise. There are no proposals for anything other than “business as usual”. There are no improvements planned for future years – other than changes that might, or might not, happen with a new runway.
Stop Stansted Expansion says DfT plans on night flights do not go nearly far enough
Following the publication of the DfT’s night flight regulation consultation, SSE is urging urging local district, parish and town councils and individual local residents to respond, to try to get the noise impacts of Stansted night-time flights reduced. Stansted currently has permission for 12,000 night flights a year, more than twice as many as are permitted at Heathrow. The 12,000 annual limit applies only to the 6½ hours from 11.30pm to 6.00am whereas the normal definition of ‘night’ is the 8 hours from 11.00pm to 7.00am. Moreover, a large number of Stansted’s night flights are large, noisy cargo aircraft, many of which are very old. Unsurprisingly, these give rise to a disproportionately high level of noise complaints. SSE welcomes the DfT intention to remove the current exemption for less noisy aircraft and adjust the movements limit accordingly – but the DfT proposes to maintain the present night limit on Stansted aircraft movements. The number of exempt aircraft has been increasing, and they need to be included in totals. SSE wants an unequivocal Government commitment to phase out all night flights at Stansted by 2030, except in the case of genuine emergencies. SSE also wants the annual flight limit to apply, not just from 11.30pm to 6.00am, but from 11.00pm to 7.00am, so that ‘night’ truly means ‘night’.