NO 3RD RUNWAY COALITION GIVE FURTHER EVIDENCE
7.3.2018 (Teddington Action Group – TAG)
The Government’s claims in the NPS are quite simply wrong and the sooner they admit it the better. Heathrow already affects more people with noise than any other airport in the World.
The full text of the evidence is reproduced at
Some sections of the long document are copied below:
No Third Runway Coalition-supplementary written evidence (NPS0093)
- The NPS states that no more than an extra 92,700 people will be significantly affected by noise (i.e. falling within the 54 dBLAeq contour) in 2030 if the Heathrow NWR scheme is developed. This is based on a “minimise total” scenario, assuming concentrated flight paths to reduce the measurable number of people impacted.
- Yet the NPS fails to represent the CAA’s economic analysis, which uses the DfT’s webTAG appraisal model (which was made available on 31 January 2018 following a Freedom of Information request). This shows that more than 420,000 people, who are already impacted over the 54 dB LAeq ‘significance threshold’, will receive 3 dB of extra noise – equivalent to doubling of the number of flights experienced daily.
- Moreover, in this study’s Noise Workbook a summary of the monetised health costs and quantitative results states that 972,957 households will incur an increase in daytime noise at the forecast year (2060 – by which time it is assumed in the NPS quieter planes will have been introduced). This would mean that, based on the CAA’s average dwelling occupancy, by that time 2,238,000 people will experience increased noise with a third runway. During the early years after opening the effects will be even worse.
- These figures together with the implications of embedding forever a six-and-a-half-hour night (ending at 5.30 am), a lack of research into the impact of respite (which will be halved) and the introduction of super concentrated routes (using PBN) are not highlighted or addressed by the NPS. Flight path strategies have not been considered; no one knows who will be affected or by how much.
- This is a totally unacceptable basis for engaging with the public or asking Parliament to make a decision of such significance. It is symptomatic of a lack of check and balance in aviation governance, which should be reviewed in the light of the NPS.
- This submission reflects information arising from the TSC’s oral hearings where it received evidence from Heathrow Airport, the Secretary of State for Transport (and his officials), the CAA and airline representatives on 5, 7 and 20 February.
- It also assesses evidence that has come to light from:
- The webTAG workbook used by the CAA to calculate noise impacts reflected in the NPS together with its assumptions regarding fleet transition.
- Matters discussed at the Heathrow Community Noise Forum Working Group Meetings on 13 and 15 February 2018 relating to Heathrow’s draft Noise Action Plan, the CAA’s SoNA and the airport’s noise contour reports.
Conclusions and Recommendations
- The NPS conceals the real level of noise impacts that will impact a very large area of London and the South-East with a third runway at Heathrow by a huge margin. By the time the airport is fully operational, it is quite likely more than 3 million people will experience more noise and approximately half a million who are already ‘significantly affected’ at 54 dB LAeqwill experience double the number of overflights. The NPS omits entirely to provide information entirely on the numbers of people who will fall within the LOEL 51 dB LAeqcontour, adopted in 2017 by the DfT in Airspace Management Policy.
- The level of impact of a third runway is not made clear at all in the NPS – the above data has been extracted from the CAA’s webTAG analysis only made available to us on 31 January 2018 following a freedom of information request, a long time after the closing date for submissions to the TSC.
- The NPS only appraises the Minimise Total flight path scenario. Based on the AC’s analysis this is likely to lead to a substantial under prediction of noise impacts, once practical flight path options become identified. At this stage, no one knows how many people will be affected, where the impacts will be and how much additional noise there will be over specific locations. This is an unacceptable basis for public consultation or political decision making.
- In addition, the DfT and Heathrow have failed to carry out essential research on health and quality of life impacts particularly arising from concentrated flight paths, respite (the routes which have been considered may not even be technically possible) or embedding a six-and-a-half-hour night period ending at 5.30 am on a vast population. Given that more than three million people will experience increased noise and while considering even those benefitting from some reduction will still be impacted, it is not unreasonable to anticipate expansion of Heathrow could impact adversely the lives of many millions of UK citizens.
- We have identified crucial flaws in the CAA’s noise modelling that require existing contours to be reworked. On the same basis for reasons explained in this submission SoNA should be independently peer reviewed and if necessary the work should be repeated.
- The current situation, epitomised by the NPS, has arisen due to unacceptable governance arrangements for aviation in the UK. The DfT has sought to construct an evidence base to justify expansion of Heathrow rather than independently and impartially assessing all the facts. The regulator, the CAA denies it has responsibility for protecting UK citizens from aviation’s adverse environmental side effects. No one else accepts accountability for this. There is no trust between communities the DfT, the CAA, NATS or Heathrow airport. In future aviation should be overseen by a parliamentary oversight committee with members representing the departments of health, environment, education, treasury, BIS as well as transport.
- Against this background the NPS should be withdrawn pending comprehensive independent review or alternatively rejected entirely.