Draft Aviation Policy Framework – Noise and other local environmental effects

Draft Aviation Policy Framework

The section on Noise and local environmental effects is Pages 48 – 73

The many questions on this section are:

 8. Do you agree that the Government should continue to designate the three largest London airports for noise management purposes? If not, please provide reasons.

 9 Do you agree with the Government’s overall objective on aviation noise?

 10. Do you agree that the Government should retain the 57 dB LAeq,16h contour as the average level of daytime aircraft noise marking the approximate onset of significant community annoyance?

 11. Do you think that the Government should map noise exposure around the noise designated airports to a lower level than 57 dBA? If so, which level would be appropriate?

 12. Do you agree with the proposed principles to which the Government would have regard when setting a noise envelope at any new national hub airport or any other airport development which is a nationally significant infrastructure project?

 13. Do you agree that noise should be given particular weight when balanced against other environmental factors affecting communities living near airports?

 14. What factors should the Government consider when deciding how to balance the benefits of respite with other environmental benefits?

 15. Do you agree with the Government’s proposals in paragraph 4.68 on noise limits, monitoring and penalties?

 16. In what circumstances would it be appropriate for the Government to direct noise designated airports to establish and maintain a penalty scheme?

 17. In what circumstances would it be appropriate for the Government to make an order requiring designated airports to maintain and operate noise monitors and produce noise measurement reports?

 18. How could differential landing fees be better utilised to improve the noise environment around airports, particularly at night?

 19. Do you think airport compensation schemes are reasonable and proportionate?

 20. Do you agree with the approach to the management of noise from general aviation and helicopters, in particular to the use of the section 5 power?

 21.What other measures might be considered that would improve the management of noise from these sources?

 22. Do you have any further ideas on how the Government could incentivise the aviation and aerospace sector to deliver quieter planes?

23. Do you believe that the regime for the regulation of other local environmental impacts at airports is effective?

 24. Do you think that noise regulation should be integrated into a broader regulatory framework which tackles the local environmental impacts from airports?

 


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Noise

AirportWatch view, in summary:

Chapter 4: Noise and other local environmental impacts

The consultation posed some good questions re: noise. However, a two-tier system will emerge unless government is prepared to give some direction to all airports, not just confine its proposals to the designated airports.  At present there are few proposals in this chapter which give hope to residents around non-designated airports that the noise climate will improve.  Noise and other environmental impacts will not be dealt with effectively at the non-designated airports by leaving their management to planning conditions imposed by the local authority, noise action plans, master plans and “voluntary arrangements.” A particular concern is that a number of local authorities have a conflict of interest in that they own or part-own the airports. The Government envisages an expanded role for the CAA.  It could play a particularly important role at non-designated airports.

The 57 dB LAeq, 16h noise measurement should no longer be used.  It is at variance with the lower limits recommended by the World Health Organisation and the one used the European Union. The consultation floats the idea of using 55 Lden or 54 Leq.  Both are more in line with WHO recommendations and EU practice.

Noise maps using either of these metrics should be produced annually for both designated and non-designated airports.  They would make matters more transparent for the local community and would seem to be essential evidence for accurate decisions on any future growth.

People living with the burden of aircraft noise are wary about the concept of a noise envelope.  The fear is that it could be used to push through excessive growth.  The Government in this consultation has recognized and tried to deal with these concerns.  A carefully defined envelope, ideally containing a cap on the number of movements, could potentially give local residents faced with growth the sort of certainty they have not had before – but the devil would be in the detail.  Noise envelopes should aim to improve the noise climate year on year with the ultimate target being compliance with the WHO recommended standards.  Noise envelopes should be legally binding.

We welcome the principle of respite periods for residents but they must be introduced with local support.  It may need to be recognised, though, that at certain airports, only a reduction in flight numbers or even the closure of the airport will satisfactorily deal with the noise problem.

We support tougher penalties for airlines which break the rules.

We welcome the recognition that general aviation aircraft can cause real problems.  We support the option of Government intervention if problems cannot be solved locally. It is also very welcome helicopter noise is recognized as a problem. There is commitment to consider how to address noise from helicopters in the review of the 2002 guidance.

Questions on health impacts were not included in the consultation, but comments requesting that health should be included are below,  under Health

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Further comments made by AirportWatch members:

Noise

Planes are becoming slightly less noisy (a better term than “quieter) but the changes are small. Most people cannot distinguish a difference in volume between sounds less than 3 decibels apart. The 2003 Aviation White Paper admitted that, if growth continues at the present rate, the noise problems will become worse. The Government believes that “significant community annoyance” from noise only starts at around 57 decibels. However, other studies show that annoyance starts much below this. The ANASE study found that significant annoyance began at a lower level, but this study was shelved several years back, and has not been used – possibly in part as its findings were inconvenient.

  • The proposed noise policy is inadequate as a basis for ‘testing’ future capacity proposals for their sustainability.
  • The long term aim should be for no-one to live in areas exposed to noise at levels deemed harmful to health by the World Health Organisation.
  • In relation to annoyance, it is unacceptable for the Government to have failed to take forward the work begun by the ANASE study. While we would welcome noise at levels lower than 57 Leq being routinely mapped, we see no justification for the Government’s refusal to adjust downwards the figure marking the onset of significant community annoyance.
  • Local resolution in relation to noise has in many cases been ineffective in the past, so we welcome the suggestion that ‘noise envelopes’ might offer a way forward, by providing a set of environmental guarantees tailored to specific cases. Without indicating, however, what status these agreements would have in the planning process, how they would be drawn up, and what components they might have, the proposal cannot be regarded as a substitute for effective noise policy.

The Government, it seems, genuinely recognises that aircraft noise is a problem and is looking for solutions. Noise from General Aviation and from helicopters (which received no mention in the 2003 White Paper) is acknowledged to be problematic, and the Government’s opposition to the third runway is characterised as a response to evidence that the noise impact of the airport in terms of population affected is greater than at any other hub airport in Europe.

“The noise impact of recreational flying or training is clearly different from that of commercial flights, but the Government nevertheless recognises that this can be disturbing to those who are regularly affected.”

(Draft aviation policy section 4.83)

Aside from ongoing opposition to Heathrow expansion, however, there are very few new measures that the Government is proposing to tackle the problem. Despite acknowledging that “people are now relatively more sensitive to aircraft noise than in the past”, the Government is still unwilling to revise its estimate of the onset of community annoyance at 57 dB Leq. And while noting that noise can have significant health effects, including stress and heart attacks, no plans are set out in relation to WHO-recommended noise limits.

“International research carried out in recent years by the World Health Organization, European Environment Agency (EEA) and others seems to reinforce the finding that the level of aircraft noise exposure at which a certain level of annoyance occurs has decreased in the last 20-30 years.”    (Draft aviation policy section D.5)

Rather than setting out noise targets or limits itself, the Government’s preference is to delegate to the CAA the task of drawing up plans for the operation of ‘noise envelopes’ which could impose noise restrictions based on, for example, geographical area (such as at Heathrow) or numbers of people exposed. No detail is provided, however, about who would be responsible for drawing up these ‘envelopes’, or what status they would have in policy terms.

On the thorny topic of noise metrics, the proposal is to retain 57 dBLeq as the marker of significant community annoyance (and 69 Leq as the level at which airport operators should provide assistance with the costs of moving), but to include a contour capturing lower noise levels in the annual noise maps for Heathrow, Gatwick and Stansted (which are designated by Government for noise regulation): either 54 Leq 16 hour or 55 Lden (the metric used for noise mapping under the EU Environmental Noise Directive).


 

Question 8.  Do you agree that the Government should continue to designate the three largest London airports for noise management purposes? If not, please provide reasons.

Yes, they must remain designated.  All three airports are now separately owned.  If they were not subject to control by DfT, competition would result in a decline in environmental protection.

We do not believe that local authorities have sufficient technical knowledge to be able to impose an effective noise regime.  Nor, unless legislation were introduced, do they have the necessary powers.

The Draft Framework notes in paragraph 4.18 that ‘some Stansted stakeholders have questioned the need for continuing Government regulation of noise at Stansted, arguing that local authorities should play this role’.  In fact this was only one sentence in the response to the Scoping Document by Stop Stansted. and only referred to night flights.

We would be totally opposed to the control of noise, or the control of night flights, at Gatwick passing to local control.  The planning authority for Gatwick is Crawley Borough Council who have always been in favour of Gatwick expansion on grounds of employment, but Crawley suffers little aircraft noise.  Other councils – Mole Valley, Tandridge, Horsham, Reigate and Banstead – are the ones whose residents live under the flight paths.

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We are very concerned that much of the Framework document is focused around issues concerning the three designated airports – and that the needs of residents near non-designated airport, which collectively impact on hundreds of thousands of people, are being ignored. We suspect this is partly because the voice of those residents hasn’t been heard loudly enough in the consultation process to date.

 

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Question 8.  Do you agree that the Government should continue to designate the three largest London airports for noise management purposes? If not, please provide reasons.

There is a good case for that designation to be extended.  The document itself gives a clue as to why: it states that “At other airports, consistent with the Government’s localism policy, we take the view that noise controls should continue to be agreed locally rather than being imposed by central Government. Noise controls at these airports are based on local authority powers to impose planning conditions on new development.”  When the local authority happens also to be the airport owner, any notion of control, setting of limits etc. goes straight out of the window.  Luton, owned by Luton Borough, has no night-time limit on noise or movements: it may fine (and pocket the revenue from the fines) the noisier movements but they’re still there and with no control whatsoever on numbers.  Its revenue from the airport, derived from a capitation fee[1], provides every discouragement to restrict or manage numbers


[1] As at August 2012, £2.658p per passenger, arriving or departing, plus contributions for freight tonnage and bizjet movements: currently yielding over £20M p.a.


 

Question 9.  Do you agree with the Government’s overall objective on aviation noise?

We strongly welcome the intention to retain the objective to limit and, where possible, reduce the number of people in the UK significantly affected by aircraft noise.

It is, however, difficult to see how the Government is intending to implement the objective.  For example, the Gatwick master plan envisages an increase over the coming ten years of 28,000 flights a year, causing a 60% increase in the number of people within the 57 leq contour.

If the Government is serious about its stated intention, the Aviation Policy Framework should state that no planning permissions for airport expansion should be permitted unless it can be shown that there will be no increase in noise.

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Do you agree with the Government’s overall objective on aviation noise?

The wording of this objective, as stated in para 4.22 – “to limit and, where possible, reduce the number of people in the UK significantly affected by aircraft noise” – leaves open the possibility that the number could actually increase. At the very least, this objective should read:
“… to ensure there is no increase in the number of people in the UK significantly affected by aircraft noise.”

However, we would like the Government to commit itself to a specific reduction in the number of people in the UK significantly affected by aircraft noise over the next 10 years. We would suggest the Government should aim for a 10% reduction.

At the same time, it is not sufficient to limit the Government’s approach to aviation noise to striving to ensure there is no increase in or to reduce the number of people significantly affected by aircraft noise.

As the Aviation Environmental Federation (AEF) has pointed out, such a policy can act as an incentive for airports to greatly concentrate noise pollution within the narrowest possible corridor. This policy does nothing for those residents under a flight path and potentially increases the level of noise pollution which they suffer.

The report cites the approach to noise management taken by the Australian Government which attempts to ensure that aircraft noise pollution emanating from any airport is spread more evenly over a number of communities, ensuring there are also periods of respite from noise.

We commend this approach and believe that, in addition to ensuring there is an overall reduction in the number of people significantly affected by aircraft noise, airports should also be required to reduce the level and frequency of aircraft noise within the areas which are significantly affected.

Priority should be attached to reducing the level and frequency of aircraft noise at the airports affecting the largest populations, and at those which affect large populations, and also duplicate the services of an airport nearby.

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Do you agree with the Government’s overall objective on aviation noise?

In para 4.22 of the DAPF, the definition ‘to limit and, where possible, reduce the number of people in the UK significantly affected by aircraft noise’ is a less demanding objective than that required by the EU Environmental Noise Directive (‘END’).

Under the EU END, Noise Action Plans (‘NAPs’) should have the objective of ‘preventing and reducing environmental noise where necessary and particularly where exposure levels can induce harmful effects on human health and to preserving environmental noise quality where it is good’.

There should be added safeguards introduced to protect rural areas from noise exposure but the airports’ Noise Action Plans generally take no account of this. Most Noise Action Plans are little more than a ‘tick-box’ exercise which describes noise control and mitigation measures already in place, including legal and planning obligations, and contain no quantified targets for noise reduction.

The absence of substantive measures to improve and protect the local noise environment in the NAPs is counter to the objective set out in Article 1 of the EU END.

Examples of reasonable noise reduction objectives which should have been included in NAPs are:

Noise after take-off – Different noise limits could be set for different types of aircraft on take-off. It would be sensible not to have a proliferation of different limits, but perhaps two or maybe three depending on the traffic mix at each airport. It should be possible to introduce two sets of three limits, one for each of the day, night and night quota periods. That is to say a lower set for aircraft of QC 0.5 and below and a higher set for aircraft of QC 1 and above. The new sets of limits could be scaled from the existing limits.

Gradient of climb on departure (jet aircraft) – Currently a minimum gradient of 4 degrees is required up to 3,000 or 4,000ft.  It is considered that with the ability to perform Continuous Climb Departures (CCD) and the improved climb capability of more than 5degres of modern aircraft, this gradient angle should be increased.

Reverse Thrust – The only attempt to minimise the use of reverse thrust by aircraft landing at  X at night is the following request in the Airport Noise Abatement Procedures: ‘To minimize disturbance in areas adjacent to the aerodrome, commanders of aircraft are requested to avoid the use of reverse thrust after landing, consistent with the safe operation of the aircraft, from 2330 hours to 0600 hours (local time).’ This wording is not strong enough to discourage the use of reverse thrust except when safety dictates. At other European international airports, the guidance is more prohibitive, for example:

 Frankfurt: ‘Reverse thrust may not be used on the entire runway system of Frankfurt/Main Airport except for safety reasons in unavoidable cases. This does not apply to idle reverse thrust.’
Schiphol: ‘During night-time 2200-0600 (2100-0500): After landing, reverse thrust above idle shall not be used on any runway, safety permitting.’
Copenhagen: ‘Use of more than idle reverse thrust is allowed only for safety reasons.’

The Airport Noise Abatement Procedures should be strengthened to state that ‘reverse thrust above idle shall not be used between 2300 hours and 0700 hours except for safety reasons’.

Noise Abatement Departure Procedures (NADP) – These are set down by ICAO in ‘Procedures for Air Navigation Services – Aircraft Operations’. There are two types of procedure, one that minimizes noise close to an airport and one that minimizes noise further away. Depending upon which type of NADP is used, there is a small difference in fuel burn and a large change in the location of noise exposure on the ground. Close to the airport, noise reduction should take precedence over any fuel burn economies which are of marginal benefit in terms of fuel savings and emissions over the total duration of the flight.

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As stated in the now-discredited Air Transport White Paper of 2003, it is the”objective to limit and, where possible, reduce the number of people in the UK significantly affected by aircraft noise.”  A good motherhood statement and with which one could easily agree.  But the devil is in the detail: how is “where possible” determined – “fewer aircraft movements” seems not to be considered at any point throughout this Consultation.

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The Government’s objective for limiting and reducing the noise impact of air travel is welcome.  It must be recognised, however, that the delivery of the long term capacity needed to maintain the UK’s global connectivity may conflict with this objective.

It is important that the new Aviation Policy Framework prevents a deterioration in the local environment around airports and should provide further detailed guidance on noise exposure levels to support the strategic overview given in the Noise Policy Statement for England which currently lacks the detailed guidance needed on which planning decisions can be based.

The discussion in Annex D of the draft Aviation Policy Framework on the use of different noise contours is welcome. It is considered that given the choice between using 55 dB(A)Lden or 54 dB LAeq,16h contours, there is a preference to changing to the use of the 55 dB(A)Lden contour to align with the END strategic noise maps and noise action plans. For Gatwick, with year-round operation, and with a significant number of night flights, it is felt that Lden more accurately reflects the real situation.

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(Helicopters)

Yes, as long as it take into consideration the unique properties of helicopter noise.


 

Question 10.  Do you agree that the Government should retain the 57 dB LAeq 16h contour as the average level of daytime aircraft noise marking the approximate onset of significant community annoyance?

We welcome the recognition in the draft Framework (paragraph 4.26) that many consider the 57 leq contour too high.  This was a point made strongly by GACC in our response.

It is not correct to describe the 57 leq contour as ‘the onset of significant community annoyance’, for the following reasons:

  • the 57 leq contour originally referred to the area within which over 50% of the population were seriously annoyed, but areas outside the contour where perhaps 40% or 30% of the population are seriously annoyed could also be described as suffering ‘significant community annoyance’.
  • the measurement was originally based on surveys in towns.  There are strong reasons for believing that in rural areas the noise is likely to be more annoying, partly because of the lower background noise, and partly because of the greater expectation of peace and quiet.
  • As recognised in paragraph 4.26, with rising living standards, expectations of peace have risen.

 

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Do you agree that the Government should retain the 57 dB LAeq 16h contour as the average level of daytime aircraft noise marking the approximate onset of significant community annoyance?

Emphatically no.

The 57 dBA Leq16 contour – indeed any contour based on the Leq averaging system – is not a reliable measure of the extent of noise disturbance because, relying as it does on average noise over a length of time, it is insensitive to the frequency of noise events and it understates the impact of aircraft noise intrusion on local communities – especially in rural areas where ambient noise levels are very low and consist largely of pleasant, natural sounds.

The area enclosed by the 57dBA Leq16 contour at X is limited by planning condition but the area affected by aircraft noise annoyance was more than 100 times larger than the 57dBA Leq16 contour limit.

It is not only local airport community groups that have little faith in the Leq16 system for assessing aircraft noise impacts. The Inspector at the Heathrow T5 public inquiry stated in his report:

 ‘The survey on which the use of the LAeq 16-hour is based was carried out in 1982 and the relationship between the LAeq and community annoyance was statistically weak even at that time’ (para 21.3.32)

 ‘…it does seem likely that the weight attached to the 57dB LAeq by the Department [for Transport] as the measure of the overall noise climate is greater than the original research would support.’ (para 21.3.32);

 ‘…[the LAeq 16-hour index] was the subject of severe criticism much of which I consider to be well-founded. …I believe that it fails to give adequate weight to the number of aircraft movements’ (para 21.3.34);

‘Even the Department  for Transport recognized the deficiencies of the LAeq system. They also accepted that it is difficult to establish the true relationship between the noise of individual events and their number and that it would have been useful if further social surveys had been carried out’; (paras 21.3.32-33);

 ‘If parties are to have confidence in the indices used to measure the noise climate they need to be founded on a sound basis of up-to-date research. Unfortunately the Department’s own evidence suggests that this does not apply to the use of LAeq, in spite of their argument that research had guided the choice of noise indices since 1967’ (paras 21.3.35).

At the very least, and as a first step towards properly tackling aircraft noise disturbance, the Government should introduce an improved measurement system for aircraft noise, such as that described in the ANASE report.

Moreover the evidence gathered in the course of the ANASE study clearly showed that the DfT was not only relying upon the wrong system for measuring aircraft noise impacts but was also applying the wrong standards of what constitutes low, moderate and high levels of noise annoyance.

The Leq averaging system for assessing noise disturbance, based upon dose/response surveys in the early 1980’s is now wholly inadequate.

It is not sufficiently sensitive to the number of noise events (flights) and takes no cognizance of background noise levels against which each noise event is heard. The DfT should take forward the work of ANASE as a priority and develop a new framework for the measurement and control of aircraft noise impacts, taking full account of the recommendations set down in the WHO Guidelines for Community Noise.

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Do you agree that the Government should retain the 57 dB LAeq 16h contour as the average level of daytime aircraft noise marking the approximate onset of significant community annoyance?

No, in several respects:

The notion of the “equivalent” noise level has always been grossly misleading and inappropriate for aircraft noise events, whose characteristic is that of short periods of very high noise levels between which lengthier intervals of relative silence occur.  To average such events over a 16-hour day merely compounds the error.   Individuals do not experience “an average sound level”: what they experience is the number of individual noise events, which the average contrives to conceal. It becomes even more misleading when “equivalent noise” is presented in the form of a “noise contour – the blades of grass within an area do not suffer unduly from noise disturbance; what’s relevant is the number of inhabitants and dwellings within the area.

The decibel is a curious animal whose nature is logarithmic rather than arithmetical – so a numerical shift from, say, 55 to 58dBA, though a mere 6% numerical increase, represents a doubling in noisiness terms – hardly a help towards the “more transparency and independence in the enforcement of noise limits” referred to in the document.  Its logarithmic nature, coupled with the “equivalent noise” approach, is what gave rise to the nonsense which was revealed when Concorde was withdrawn from Heathrow – its one thunderous movement could be replaced by that of 120 by B757-type aircraft – with no change in the 57 dB LAeq,16h contour and thus, according to the “significant annoyance begins at 57 dB LAeq,16h paradigm,  with no change in community disturbance – a palpable nonsense.

Average values, whether over 16 hours (day) or 8 hours (night) are the equivalent of quoting a number which purports to represent the average of apples and bananas, and are meaningless to communities.  What is required, if “transparency” is truly an objective, is something on the lines of the Australian “N70” approach which gives the hourly number of noise events above a chosen level.

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We do not consider that the LAeq,16h metric is appropriate for measuring aircraft noise disturbance. Serial one-off aircraft events of aircraft flying overhead cannot be equated to a continuous steady state noise like a fan. As each aircraft passes overhead, attention is drawn to it and so the number of events is as important as the overall sound levels produced. The 57 dB LAeq,16h sound average disguises the much higher noise peaks created by the aircraft and gives a misleading impression of the annoyance caused. The Government should, therefore, use a lower level, e.g. the 54 dB LAeq,16h contour, as the average level of daytime aircraft noise marking the approximate onset of significant community annoyance. The alternative of the European level of 55 dB(A)Lden has its flaws as it is also based on the LAeq with the addition of weightings for evening and night time producing a rating level that has to be calculated rather than measured.

[We] therefore, urge the Government to undertake new research into the levels of noise and annoyance as the current threshold is too high.

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Do you agree that the Government should retain the 57 dB LAeq 16h contour as the average level of daytime aircraft noise marking the approximate onset of significant community annoyance?

(Helicopters)

No.  Average levels are completely inappropriate when measuring helicopter noise.

Helicopter noise is perhaps the best example of how inappropriate average noise levels are in describing the onset of “significant community annoyance”.  Therefore a different way of measuring and limiting helicopter noise needs to be introduced.  The  number of noise events is important, as well as their sound energy.  ??? The “blade slap” effect of helicopter noise and its low  frequency components  add to annoyance and need to be taken into account in a new metric. All metrics for measuring aviation noise – from fixed wing or rotary wing aircraft – should be easily comprehensible to the layperson. Without this clarity, discussion or consultation by airports and airfields with members of the public, the aspiration of working together better,  is doomed to failure and disatisfaction.


Question 11. Do you think that the Government should map noise exposure around the noise designated airports to a lower level than 57 dB(A)? If so, which level would be appropriate?

For the reasons set out previously, we believe it is imperative that the Government maps noise exposure at all commercial airports in the UK, and monitors noise exposure closely on an ongoing basis. However, it must also properly regulate noise exposure to ensure that it does not increase.

Noise mapping should include:
– noise contours, with maps and details of the affected populations, at the following noise levels:

50> LAeq 16h,

54> LAeq 16h,

57> LAeq 16h,

60> LAeq 16h,

63> LAeq 16h and

72> LAeq 16h

– and which also includes measurements which allow for and properly reflect the greater annoyance, disruption and health risk experienced by residents in the evening, night-time and early morning, and measures which reflect noise pollution caused by particularly noisy individual aircraft events (using Lden, LAeq 8h and LAMax Fast measurements) [with appropriate adjustments to the 16h metric where airports, like George Best Belfast City Airport, are not fully operational for 16 hours]

– details of all schools within the 54> LAeq 16h contours, and/or which experience noise events at 35> LAeq during class time [with appropriate adjustments to the 16 hour metric as above]

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 Do you think that the Government should map noise exposure around the noise designated airports to a lower level than 57 dBA? If so, which level would be appropriate?

If the Leq measure is to be kept, the 57 leq contour should be replaced by the 54 Leq contour.

Annex D asks for views on a choice between using 55 Lden or 54 Leq.  We would favour changing to 55 Lden in order to bring us into line with the EU, and because this measure will need to be used in future noise action plans.   For Gatwick, with year-round operation, and with a significant number of night flights, Lden seems to us a measurement that more accurately reflects the real situation.

There should, however, be a period of two years in which contours based on both measurements are produced in order to enable comparisons to be made between the periods before and after the changeover.

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 Do you think that the Government should map noise exposure around the noise designated airports to a lower level than 57 dBA? If so, which level would be appropriate?

Para 4.3.1. of the WHO ‘Guidelines for Community Noise’, states: ‘to protect the majority of people from being moderately annoyed during the daytime, the sound pressure level should not exceed 50 dBA Leq… indeed the lower sound level [40 dBA Leq] should be considered the maximum sound pressure level for all new developments whenever feasible’.

The Government has previously said that it will take account of the WHO ‘Guidelines for Community Noise’ as a long term (by 2030) policy goal and so, if the Government insists on continuing with the Leq noise averaging system, it should map noise exposure around existing airports to 50 dBA Leq16 and to 40 dBA Leq16 for all new developments.

Noise mapping is already undertaken for 24-hour Lden which provides a slightly better method than 16-hour Leq for assessing noise disturbance since it weights the sensitive evening and night periods.

However both methods suffer from the same fundamental flaw, which is the averaging out of a discrete number of noisy events over time. People do not hear average noise levels of aircraft over time; they hear each aircraft noise event, its duration and its low frequency components against ambient levels.

For example, school children near airports are adversely affected by what is termed ‘jet pause’ during aircraft flyovers.

The Lden metric should replace the Leq metric and be used as an interim measure with a 55 dB Lden level being the indicative level of onset of significant annoyance. Noise maps using Lden should be produced annually to enable the local community to monitor better how the airport is performing to avoid, prevent or reduce the exposure to noise.

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Do you think that the Government should map noise exposure around the noise designated airports to a lower level than 57 dBA? If so, which level would be appropriate?

Especially if that refers to Leq values, mapping would merely provide relatively meaningless information – without any commitment to act appropriately on it, the exercise seems pointless.  Airport Noise Action Plans, a consequence of the Strategic Noise Mapping exercise mandated by EU pursuant to Directive 2002/30 and 2002/49 have, universally, produced zero improvement in the noise climate around the airports.  55dBLDE is superficially attractive but, with the introduction of weightings for evening and night, even more obscure to, and utterly unverifiable by, members of a noise-afflicted community. If anything meaningful is to be mapped it should at the very least be on the basis of population numbers affected by Single Event Levels of sensible levels, though N70[1] has proved a very effective and well-understood descriptor in Australia.


[1] “Expanding Ways to Describe and Assess Aircraft Noise” Australian Department of Transport and Regional Services

 

 Do you think that the Government should map noise exposure around the noise designated airports to a lower level than 57 dBA? If so, which level would be appropriate?

(Helicopters)

This irrelevant with respect to helicopter noise away from airports.


 

Question 12.  Do you agree with the proposed principles to which the Government would have regard when setting a noise envelope at any new national hub airport or any other airport development which is a nationally significant infrastructure project?

We agree with the stated aims of a noise envelope, as set out in paragraph 4.35.  We would support a noise envelope based on the area within the appropriate noise contour, as in paragraph 4.38.  That was the basis of the 2001 Section 106 agreement at Gatwick which permitted airport development in exchange for an undertaking to halve the area within the 57 leq contour.

But, based on experience at Gatwick, the following conditions need to be added:

  1. the noise envelope should legally binding;
  2. it should contract year by year so as to share the benefits of technology with local residents, and with the aim of reaching the noise standards set by the World Health Organisation;
  3. compliance should be monitored and enforced by an independent agency.

We are strongly opposed to the concept of a noise envelope based on the average noise per flight, as described in paragraph 4.40.  That would give no assurance to local residents that the total noise would not increase.

If the concept of a noise envelope is to be included in the forthcoming National Policy Statement the words would need more precise definition.  Otherwise they may well become the subject of prolonged legal battles.  For example:

  • ‘to limit the number of people’ – does this mean ‘not permit to increase’ or ‘to keep any increase as small as possible’;
  • where possible reduce’ – seems inherently improbable for any new major infrastructure project;
  • a review of the limits contained in the envelope’ – does ‘review’ mean an increase or a decrease?

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 Do you agree with the proposed principles to which the Government would have regard when setting a noise envelope at any new national hub airport or any other airport development which is a nationally significant infrastructure project?

We reject this idea outright. The term ‘noise envelope’ is vague and whilst designed to convey the impression of containing noise impacts, it could in practice allow the number of flights to increase substantially even if there were just a slight reduction in the average noise produced per aircraft.

Local communities look forward to the time when aircraft become noticeably less noisy and less frequent, so they will suffer less sleep disturbance, less disruption to their enjoyment of their local environment and less general intrusion into their lives by overflying aircraft.

It would be totally unacceptable if these benefits were to be diluted or even neutralized by an increase in the number of flights in line with the average noise reduction achieved per aircraft.

As stated above, the Government’s first priority in seeking to address the problem of aircraft noise disturbance should be to introduce an improved measurement system for aircraft noise, which the public could have trust in, such as that described in the ANASE report

The Australian N70 type metric also has merit in that it was devised to represent ‘Number Above’ contours, combining information on single event noise levels with aircraft movement numbers.

It directly represents an assessment of the noise level of each flight and the number of flights. Other things being equal, if the number of aircraft movements over an area doubles, the N70 doubles.

Contours can be drawn for lower levels such as N60 at night. But the N70 type is a useful metric as it permits measured noise levels to be very neatly summarized for any given period. This metric should be considered in addressing an improved measurement system for aircraft noise. It is closer to what people actually hear and much easier than LAeqs to explain to the general public.

It is disingenuous to describe newer aircraft as being quieter.

Aircraft are inherently very noisy and the best that can be achieved is to make them less noisy.

A modern jet aircraft on take-off emits 140 decibels of noise and it is this high noise level together with the number of noisy events which causes annoyance.

The aviation industry claim that noise impacts are reducing because aircraft are becoming less noisy ignores the fact that the increase in the number of flights far outweighs the benefit of each flight being slightly less noisy.

Moreover, the improvement curve for the reduction of aircraft noise levels since the early 1960s has been flattening out and – in the absence of some new breakthrough technology – there are no grounds to expect the noise performance of aircraft to improve much further.

The industry statement in the DAPF pledging ‘a 50% reduction in perceived noise levels in 2020 compared to 2000’ is misleading.

A halving of sound pressure levels equates to a 3 decibel decrease but a reduction of 3 decibels is the minimum perceptible change under normal conditions.

It takes a reduction of about 10 decibels to achieve a 50% reduction in loudness and this level of improvement in aircraft noise performance by 2020 is not remotely possible, even for new aircraft.

Moreover, aircraft typically have a serviceable life of 20-25 years and so the aircraft coming off the production line today will still be in service in the mid 2030s.

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 Do you agree with the proposed principles to which the Government would have regard when setting a noise envelope at any new national hub airport or any other airport development which is a nationally significant infrastructure project?

Government must monitor and regulate noise properly and effectively at all commercial airports in the UK, and not just airports deemed to be of national significance. It must also regulate noise robustly at existing airports – and not just with regard to new airports or new infrastructure at existing airports.

The noise envelope proposals, as set out, are too vague. The UK should be seeking to make use of its existing aviation capacity in the most efficient and noise-efficient way possible, without further expanding the number of people affected by noise at a significant level.

We believe the Government should give serious consideration to the results of the EU-sponsored MIME study which developed a model of tradeable noise permits for airports.  If this was implemented by the UK, it would have the potential to act as a real incentive for airlines to take mitigation measures which would minimise or reduce the degree of noise exposure for residents.

The permit scheme could also take into account the type of traffic generated by a particular route; for example, flights on ‘bucket and spade’ routes to ‘sunshine’ destinations outside the UK, which merely suck tourist revenue out of the local and national economy, could be subject to a higher ‘price’ under this scheme.

We would strongly oppose the use of a noise envelope as a device to permit any increase in the amount, level or frequency of aircraft noise where a significant number of people are currently affected or will be affected at a level which is likely to have adverse health, education and/or quality of life impacts. The impact on schools must also be taken into account in this regard.

We would support the use of a noise envelope as a device to ensure that the level and frequency of noise pollution did not get worse and/or was reduced over time.

We believe that a noise envelope must include a mixture of both maximum noise levels and noise event thresholds, and restrictions on the number of flights and passengers seats offered for sale.

We believe it is totally unsatisfactory that airports are currently permitted to monitor and report on their own noise levels. However, while this system of self-monitoring pertains, it is essential to have in place tangible restrictions on the scale of airport operations which can be easily monitored and regulated externally.

It is also vital that any noise envelope contains additional restrictions on flight numbers, average noise levels and noise event thresholds for early morning, evening and night-time which properly reflect the additional negative impact on health and quality of life

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 Do you agree with the proposed principles to which the Government would have regard when setting a noise envelope at any new national hub airport or any other airport development which is a nationally significant infrastructure project?

The objective: to “limit the number of people significantly affected by noise from aircraft operations is laudable but somewhere along the road the European Noise Directive’s “ …. and reduce…” has been missed.  The essential feature of any scheme involving limit-setting is that the metric(s) used must be relevant, comprehensible to a lay audience and independently verifiable – ideally, by the same lay audience. It is aircraft movements which cause disturbance and, despite the industry hype, improvement in noise performance of airframes and engines is now asymptotic towards zero.  The genuine gains achieved by the introduction of high bypass-ratio turbofans are now history, and there is no such thing – especially at night – as a silent aircraft.

Some small improvements in flying technique: continuous climb departures, continuous descent approaches; may still be possible (though, for landings, there’s no possible gain for those living within the 7-mile glide-slope and airspace congestion, especially in the south-east, militates against continuous climb. Passenger limits appear meaningless in this context – they have relevance to local air pollution levels and surface access policies, but virtually none to noise.

 

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The principles seem appropriate, however, it should be recognized that while this approach may contain the overall noise levels and limit the number of new people affected, it provides little benefit to existing sufferers. People under the landing approaches will not see any improvement in their noise environment for the foreseeable future and these people should be compensated appropriately.


 

Question 13.  Do you agree that noise should be given particular weight when balanced against other environmental factors affecting communities living near airports?

Noise is the most serious local environmental impact, but that does not mean that other factors should be given a reduced weight.

We warmly welcome the recognition in paragraphs 4.58 – 4.59 that tranquillity in rural areas should be given greater priority, and that the importance of national Parks and AONBs should be recognised by the CAA.  The final version of the white paper should commend the recent CAA report on Tranquility (ERCD  Report 1207).[iii]

Mention should be made of an American study of 39 parks which found that the longer aircraft noise is audible, and the louder the aircraft noise with respect to background levels, the greater the percentage of visitors who felt annoyed and who felt the noise interfered with their appreciation of the sounds of nature.

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Do you agree that noise should be given particular weight when balanced against other environmental factors affecting communities living near airports?

In general, there is no conflict between attempts to reduce aircraft noise and attempts to reduce carbon emissions and other harmful aircraft impact. However, where aircraft need to take a flight path which produces more CO2 in order to reduce noise pollution, we believe the latter is by far the most important consideration, where a significant number of people are affected by aircraft noise at a serious level.

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Do you agree that noise should be given particular weight when balanced against other environmental factors affecting communities living near airports?

Yes.

The most negative local impact from airport operations is noise annoyance, especially noise in the late evening, early morning and overnight which causes sleep disturbance.

This is particularly the case around airports where the surrounding area is essentially rural in character and has low ambient noise levels. Claims that noise impacts are reducing because aircraft are becoming less noisy ignore the fact that the increase in the number of flights far outweighs the benefit of each flight being slightly less noisy.

Where trade-offs are necessary between reducing emissions and increasing noise in the vicinity of airports, priority should be given to reducing noise impacts provided this would not result in any exceedance of local air quality limits.

In making this point, we assume that there will be an overall carbon budget for UK aviation and so any savings in carbon emissions per flight would simply allow more flights to be accommodated within the carbon budget and give rise to even more aircraft noise.

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Do you agree that noise should be given particular weight when balanced against other environmental factors affecting communities living near airports?

Yes – “near” needs some better definition, however and should not be limited to, for example, “within the 57dBa LEQ(16) contour”.

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Noise and the frequency of the disturbances are considered to have the most serious local environmental impact for communities living near airports. However, that does not mean that other factors should be given a reduced weight. There is also a major concern about noise and air pollution from road traffic accessing airports via local roads and through village communities.


 

Question 14.  What factors should the Government consider when deciding how to balance the benefits of respite with other environmental benefits?

We support the concept of respite in relation to varying the point at which aircraft join the final approach path, subject to two conditions.

  1. So long as it does not involve putting flight paths over areas which are at present peaceful.
  2. So long as consultation shows that a majority of the people affected actually prefer the proposed scheme (eg twice as many planes on alternate days).

In relation to possible variation in take-off routes, as a result of PRNAV, we would only support use of alternate routes if they were used at predetermined times of day, or days of the week.  We would strongly oppose the simultaneous use of parallel routes.

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We are very disappointed that the section on respite refers solely to Heathrow. Most UK airports provide no such respite for residents and we would like the Government to include provision for respite within the far more robust system of noise regulation which we would like to see.

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We strongly welcome the Government’s commitment to providing respite to those affected by aircraft noise disturbance wherever feasible (para 4.52); its strong support for work being done by the industry to explore opportunities for providing respite (para 4.53); and its encouragement to airports and airlines to work with NATS and CAA to consider creative solutions to protect and enhance respite (para 4.54).

We note that London City Airport provides the following periods of respite:

 Closed every night, Sunday to Friday, from 10.00pm until 6.30am the following morning;
 Closed from 12.30 pm Saturday until 12.30 pm Sunday;
 Closed until 9.00 am on Bank Holidays; and
 Closed to all flights on Christmas Day.

We accept that it would be unrealistic in the short term to expect many other airports to adopt the same operating hours as London City Airport but the Government should encourage airport operators to explore opportunities for introducing similar respite arrangements in the longer term, on a phased programme, in consultation with the local community and its airline customers. Closure of the airport on Christmas Day would be a welcome – and symbolic – starting point.

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DfT’s interpretation of “respite” is inconsistent with its environmental guidance to CAA, which mandates concentrating aircraft taking off from airports along the fewest possible number of specified routes.   Spreading noise damage over two communities alternately gives meaningful respite to neither.

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The current Government policy is to concentrate flights along the fewest number of routes and that these routes should avoid densely populated areas. In the case of X the prevailing wind conditions mean that an average 70% of all landings come from an easterly direction creating significant noise disturbance to many local communities close to the flight path.

Respite is crucial for those communities affected by noise. The concept of respite is supported provided that it does not involve diverting flight paths over areas which are at present peaceful. Implementation of respite could mean negative impacts for some people and in such cases compensation should be offered to those suffering negative impacts or to those who have bought houses after investigating flight patterns and bought outside the major swathes.

[We] consider that the current noise preferential routes (NPRs) should remain. P-RNAV gives a great opportunity to fly more accurately, discover which is the most appropriate line, or use of lines on a rotation, to fly within the NPR.  P-RNAV also provides the opportunity to discover possibly better paths to fly that may be just outside the NPR, but affect fewer people.  This information could be useful when LAMP is introduced in 2018. It is highly likely that one size will not fit all when deciding the path to fly so respite needs to be investigated whether for departing or arriving aircraft. It may be possible to share the annoyance rather than concentrating on a specific population if an acceptable single route is unacceptable


 

Question 15.  Do you agree with the Government’s proposals in paragraph 4.68 on noise limits, monitoring and penalties?

We strongly welcome the proposal for a review of departure noise limits. A reduction in noise limits will benefit local residents and also encourage the manufacture and use of  quieter aircraft.

Again the wording needs to be clarified:  ‘review’ presumably means ‘decrease’.  As the March Hare said:  “You should say what you mean,”

“I do,” Alice replied; “at least I mean what I say, that’s the same thing, you know.”

“Not the same thing a bit!” said the Hatter. “Why, you might just as well say that “I see what I eat” is the same thing as “I eat what I see!”

We welcome the statement that the Government believes that the penalties for breaches of the limits should be set ‘significantly higher’.  They should be at least doubled.

At Gatwick we are satisfied that the penalties are fairly administered, and are reported in public at meetings of GATCOM.  We therefore see no need for additional transparency and independence.

We welcome the proposal that consideration should be given to imposing penalties on airlines which fail to comply with CDA and minimum height requirements.  This was suggested by GACC.  It can be expected that this proposal will be met with a howl of protest from the airlines and chorus of condemnation on the grounds that events, such as bad weather or ATM instructions, mean that breaches are not always within the control of pilots.  We recommend that the Aviation Policy Framework should make it clear that any penalties should be applied on the basis of annual averages for each airline as this would iron out individual fluctuations.

It has taken seven years of pressure from GACC to persuade Gatwick Airport Ltd to make public the annual performance of airlines in achieving CDA, thus enabling the best to be congratulated and the incompetent to be shamed.  It might be wise to allow this new arrangement to run for two or three years before introducing penalties.

We have suggested that the word ‘penalties’ is incorrect, since the limits are not legally binding:  ‘environmental charge’ would be more appropriate, and more acceptable to the airlines.

We welcome the proposal in paragraph 4.74 that more monitors should be installed under the approach path, as suggested by GACC.  We would also like to see the monitors recording the type of aircraft and name of airline.  In that way it would be possible to ascertain which airlines use best practice in noise reduction techniques.

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Do you agree with the Government’s proposals in paragraph 4.68 on noise limits, monitoring and penalties?  

Paragraph 4.68 states “Local communities need to have confidence that airport owners take noise impacts seriously.” That is not correct – what local communities need to have is the confidence that the Government takes noise impacts seriously. If the Government did take the impact of aircraft noise seriously, it would be designing and implementing a robust system of noise regulation which would actually address the problem properly.

Airports are commercial entities which exist to make a profit. It is unrealistic to expect airports to voluntarily implement an effective system of self-regulated noise management – and it is quite unfair to expect local communities to rely on the goodwill of their airport in order to have that effective regulation. As previously stated, it is the clear responsibility of the Government to regulate noise pollution effectively, just as it does with others forms of pollution, such as air and water pollution (and, indeed, other forms of noise pollution).

Moreover, paragraph 4.68 appears only to apply to the three designated airports as it refers to departure noise limits which do not apply, as far as we are aware, at most other airports.

We would certainly welcome the introduction of a robust system of departure noise limits for all airports which have a serious noise impact which affects a significant number of people. However, the system should be completely transparent and should be implemented by the Government rather than the airports.

Similarly, the Government should carry out its own monitoring and reporting of noise in affected areas around commercial airports. However, this should be carried out at all airports – whether or not they appear to affect significant numbers of people, and whether or not they are nationally designated.

This is because only a transparent and fully independent system of monitoring is reliable. It may well be the case that some airports do not have sufficiently accurate systems of noise monitoring and modelling, and under-reporting of the full extent of noise pollution may occur as a result. Airports and airlines should pay for the costs of the monitoring.

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Do you agree with the Government’s proposals in paragraph 4.68 on noise limits, monitoring and penalties?

Aircraft operating to/from many airports rarely infringe the noise control limits because the current limits are set at generously high levels which can easily be achieved by modern aircraft.

The limits should be significantly lowered and the penalties for breaching the limits should be substantially higher. We believe that a 10-fold increase in penalties is needed to act as a deterrent for the small number of ‘rogue’ aircraft which breach the limits.

The fact that it is often the same aircraft which breach the limits on a regular basis demonstrates that the present level of fines is not an effective deterrent.

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Do you agree with the Government’s proposals in paragraph 4.68 on noise limits, monitoring and penalties?

Largely, motherhood statements; “enhanced monitoring” is only of any use if it is coupled to independence of monitoring and with effective enforcement.  The proposals also miss completely the issue of arrival noise which, for communities within 7-10 nautical miles of the arrival end of the runway, is highly concentrated and usually worse than departure noise because the 3-degree glide-slope holds the aircraft lower, further out.  Typically, departures achieve around 8-degree climbs which quickly get the noise further away from the ears below.

An associated area is that of track-keeping accuracy.   Despite the almost-universal fitting of flight management systems which are capable of achieving track-keeping accuracy better than 100 metres, the accuracy with which Standard Instrument Departures (SIDs) are flown is universally poor and the “compliance attitude” which marks the upper limit of Noise Preferential Routes is universally set too low, affording the all-to-frequent “the flight was vectored” excuse for an overflight.  Speedy implementation of P-RNAV routes must be achieved and substantially greater adherence to SIDs mandated, with financial penalties for unauthorised departures from SIDs.

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The noise limits no longer provide an incentive to continue seeking improvements.  A redefinition of departure limits would encourage not only the manufacture of quieter aircraft, but for the benefit of local residents, the use of quieter aircraft.

The proposals in paragraph 4.68 on noise limits, monitoring and penalties are welcome. However, we consider that there is a need for a mix of measures to address sound level; number, time, duration, altitude and frequency of flights; noise signature of aircraft; predictability of flight paths; and reliable periods of respite, including for those suffering from approach noise.

The proposal to review the penalties for breaches of the limits is supported.  It is important that the new limits, with tougher penalties, are more effective with the desired outcome of containing the noise climate around airports. The proposal to give consideration to imposing penalties on airlines which fail to comply with CDA and minimum height requirements is also supported. Details of penalties imposed should be published on the airport website.

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(Helicopters)

None of these proposals will offer any protection or reduction in noise levels experienced by people living away from airports, who are still subjected to high levels of helicopter noise.  Helicopters, unlike fixed wing aircraft, fly low for the duration of their journey, thus affecting many more people on the ground than if they were merely noisy during their climb and descent.


 

Question 16.  In what circumstances would it be appropriate for the Government to direct noise designated airports to establish and maintain a penalty scheme?

Our understanding is that no Order (under the Civil Aviation Act 1982) has been made to establish the penalty scheme at Gatwick, but it has been introduced on the understanding that if not adhered to, the Government would introduce an Order.  If there was any case where an airport refused to set up a penalty scheme, or (more likely) where an airline refused to pay, then it would be appropriate for an Order to be made.

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If the Government is serious about establishing higher environmental standards at UK airports, it would be entirely appropriate for the Government to require all UK airports above a certain size – we suggest a threshold of 5 mppa7 – to establish and maintain an approved (by the DfT) penalty scheme for aircraft which breached airport noise control limits.

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More to the point, it would be appropriate for such a scheme to be established and maintained at all airports with activity levels above, it is suggested, 50,000 movements a year, not merely Heathrow, Gatwick and Stansted.  It would also be appropriate for ANMAC membership no longer to be confined to these three, ex-BAA, airports.

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Designated airports should continue to operate a penalty scheme.  If there was any case where an airport refused to set up a penalty scheme, or (more likely) where an airline refused to pay, then it would be appropriate for an Order to be made.


 

Question 17.  In what circumstances would it be appropriate for the Government to make an order requiring designated airports to maintain and operate noise monitors and produce noise measurement reports?

As above.

Again, we believe it would be entirely appropriate for the Government to require all UK airports above a threshold of 5 mppa to maintain and operate noise monitors and to produce – and publish – noise measurement reports. We suggest that airport noise measurement reports should be published quarterly and that they should be subject to independent verification/auditing by the CAA.

 

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Making best use of existing capacity is supported but measures need to be put in place to ensure the noise climate around airports is not made worse.  Greater use of differential landing fees will incentivise airlines to invest in quieter and cleaner aircraft. It is considered that there should be higher landing fees at night on the noisiest type of aircraft.

Lower landing fees for operating the quietest aircraft at night will incentivise airlines but this needs to be in conjunction with a meaningful movement and noise quota scheme.  The current night flights regime at Gatwick is not effective in winter as the quotas and movements limits have been set too high and are, therefore, underused providing little incentive for airlines to invest in or use quieter aircraft. These should be reduced to a level reflecting past use.

It is considered that the Government should acquire evidence on how landing fees are being used to incentivise the use of the quietest and cleanest aircraft. It is also considered that further research is needed into the impacts of differential landing charges to be undertaken in order that the optimum level may be achieved to reduce the negative impacts of noise for local communities, in particular, at night.

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As above: the requirement must be for all airports (perhaps, for all airports with activity levels above, say, 50,000 movements a year)


 

Question 18.  How could differential landing fees be better utilised to improve the noise environment around airports, particularly at night?

We made the case in our Response to the Scoping Document that the price regulation by the CAA keeps landing fees at low levels and thus prevents meaningful differentials.  We would welcome higher landing fees for noisy aircraft but it would be a nonsense if they resulted in more profit for the airport.

If landing fees are to continue to be kept down by regulation, a special charge (starting at say £1 per passenger during the day, more at night) should be levied on the noisiest type of aircraft, with the proceeds paid into existing schemes, such as the Gatwick Airport Community Trust, to benefit local residents.

Differential landing fees at night are probably less effective that a steady reduction in the night noise quota.  In our Scoping Document response we set out the case for a levy on night flights.

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How could differential landing fees be better utilised to improve the noise environment around airports, particularly at night?

The airport charging differentials should be substantially increased, so as to provide a greater incentive for less noisy aircraft and a greater disincentive for noisier aircraft.

At present, X Airport provides only a 10% discount on the Chapter 3 ‘Base’ landing charge for Chapter 4 and ‘Chapter 3 minus’ aircraft. This should be increased to a 50% discount.

For noisier aircraft, the airport applies a 50% surcharge on top of the Chapter 3 ‘Base’ landing charge for ‘Chapter 3 plus’ aircraft. This should be increased to 100%.

We would also like to see landing charges for helicopters being set at a level of not less than the landing charges for Chapter 3 fixed wing aircraft over 16 metric tonnes.

It is superficially tempting to suggest that airport charges should be substantially higher for night flights but this could weaken the case for tighter controls on the number of night flights. Our over-riding objective is the phasing out of all night flights over a reasonable timescale.

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How could differential landing fees be better utilised to improve the noise environment around airports, particularly at night?

Great caution is needed here. This, or something very closely related to it, has some perverse consequences: cargo aircraft returning to UK in the small hours and with too big a noise quota cost to be permitted to land at Heathrow, land instead at Luton where there is no noise quota whatsoever, and transit to their base at Heathrow later in the day.  That merely relocates, rather than solves, the problem.

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How could differential landing fees be better utilised to improve the noise environment around airports, particularly at night?

We are aware that some airports, such as Luton and Stansted, already operate differential landing fees, designed to encourage airlines to use quieter aircraft.

However, it is unlikely that other regional airports would take such a step voluntarily, if in competition with neighbouring airports.  Low landing fees are one means of attracting the airlines required for commercial survival. Doubtless, there are a number of UK airports which, due to being in close proximity with a neighbouring airport offering similar routes, compete on landing fees.

The current system of air passenger duty (APD) could be refined so that a higher rate is levied on early morning and night-time flights from airports which have a serious adverse noise impact on a significant number of people. In addition, flights from these airports which use quieter planes could be subject to a lower level of APD.

Alternatively, we note in para 4.76 that the Government does have the power to require airports to use differential landing fees to reflect environmental impacts and we therefore believe that, if APD is not used as an instrument in this regard, the Government should use its power to require airports to employ differential landing fees.

The term “night-time” must include the early morning period during which it can be assumed that most people would still be asleep i.e. “night-time” should include 11pm to 7am, and 11pm to 9am at weekends. Evening flights which disrupt children’s sleep should also be subject to differential APD or a differential landing fee.

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(Helicopters)

Helicopters should be charged at a higher level than fixed wing aircraft due to their higher noise impact.  This would improve the noise environment over a larger area than just around the airport.


 

Question 19.  Do you think airport compensation schemes are reasonable and proportionate?

No.  They could be made more generous by covering a wider area, ideally that within the whole 55 Lden contour.  Grants should be offered for the replacement of double glazing installed many years ago.

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Do you think airport compensation schemes are reasonable and proportionate?

The more pertinent question is not what we think of the compensation schemes offered by those few airports which go beyond what they are required to do by Government, but what we think of the Government’s requirements with regard to compensation.

Many airports will only offer to pay for noise insulation to homes affected at 63 LAeq 16h or above, in line with the Government’s requirement on insulation.

There is ample evidence  that people suffer tangible health, quality of life and, in the case of children, educational impacts at levels well below 63 LAeq 16h.

Insulation does not solve the problem of aircraft noise, because people still need to open their windows. However, it can help to mitigate the adverse impacts of noise, and it is ridiculous that house owners and landlords are currently forced to foot the bill where insulation is required primarily because of aircraft noise.

As with other forms of pollution, the ‘polluter should pay’ principle should be followed – and required by Government.  Where airports are required to fund insulation programmes, these should include a comprehensive package of noise insulation measures, and not just double or triple glazing.

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Do you think airport compensation schemes are reasonable and proportionate?

(i) Unfairness of the Land Compensation Act
The Land Compensation Act 1973 needs to be amended because it allows airport operators to exploit the so-called ‘golden rivet’ loophole and thereby avoid their obligation to compensate local residents for property devaluation arising from airport development.

An example of this relates to the approval, in July 1999, for Stansted to grow from 8 mppa to 15 mppa. BAA defined the physical infrastructure which would be needed for this expansion and, under the Land Compensation Act, local residents adversely affected by the airport’s near doubling in scale would be eligible to apply for compensation 12 months after the final piece of the physical infrastructure, ‘Taxiway Echo’, was completed. Passenger throughput reached 8 mppa in 1999 and it exceeded 15 mppa in 2002 but Taxiway Echo – the ‘golden rivet’ – has still not been built. In fact, BAA does not envisage needing Taxiway Echo until 2019/20 and so no-one will be eligible for compensation until 2020/21 at the earliest, by which time the airport is expected to be handling 35 mppa.

So, at best, Taxiway Echo will be completed – and compensation paid – 20 years later than local residents expected. Taxiway Echo may never be built and, if that is the case, compensation will never need to be paid. In compensation terms, local residents around Stansted Airport continue to live next to an airport handling less than 8 mppa.

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(ii) Generalized Blight
It is unsatisfactory that there is no legal obligation for an airport operator to introduce a compensation scheme to deal with the generalized blight which arises as soon as there is the prospect of major expansion at the airport.

In the absence of a legal requirement, an airport operator can introduce wholly inadequate arrangements and claim that he has addressed the issue, and – as we learned at Stansted in 2005 – there is no scope for the local community to mount a legal challenge to the terms of such a compensation scheme, no matter how unfair or unjust it is, because it is only a voluntary scheme.

The 2003 Air Transport White Paper (‘ATWP’) supported a second runway at Stansted and stated – with no legal force – that the airport operator would need to put in place a scheme to address the problem of generalized blight.

It was left to the airport operator to define the threshold for qualification, the basis for compensation and all the terms and conditions.

The result was a wholly inadequate and unfair scheme.

By setting the qualification threshold at 66dBA, fewer than 500 homeowners could qualify and they then had to demonstrate, inter alia, that they had marketed their property for at least three months on the open market at a realistic asking price, had not declined offers within 15% of that price and that they had a pressing reason to move.

BAA would not compensate for the first 15% loss of value. All of this was against a background where it could clearly be demonstrated from Land Registry data that, in Uttlesford alone, some £700 million had been wiped off property values as a result of the threat of a second Stansted runway, affecting some 15,000 homes.

Detached homes (47% of the housing stock in the affected area) had, on average, lost 17% of their value, semi-detached (31% of the housing stock) had lost 11% of their value and terraced homes (14% of the housing stock) had lost 9% of their value.

Conversely, the average price of flats and maisonettes (8% of the housing stock) increased 5% in value.

The Government should place a legal obligation upon airport operators to introduce fair and reasonable compensation arrangements when airport expansion proposals give rise to generalized blight. The starting point for this should be for the Government to consult on the arrangements which should be put in place, the threshold for qualification, the basis for compensation and all the other terms and conditions.

People living near Stansted look forward to contributing to such a consultation based on the very unhappy experience of homeowners in the vicinity of Stansted Airport in the aftermath of the ATWP.

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(iii) Qualification thresholds for acoustic insulation
The qualification thresholds at Stansted for acoustic insulation – whereby the airport operator will meet either the full cost of secondary glazing, or half the cost of double glazed replacement windows – are (i) the daytime 66dBA Leq16 noise contour (0700 hours to 2300 hours); (ii) the night 90dBA SEL noise footprint (2300 hours to 0700 hours); and (iii) within 600 metres of sources of airport ground noise but excluding properties south of the A120 and east of the M11.

The Leq noise averaging system is not a suitable basis for assessing aircraft noise nuisance, especially in rural areas, and so it should not form the basis for a qualification threshold for acoustic insulation.

The Government should introduce an improved measurement system for aircraft noise such as that described in the ANASE report and this should be used as the basis for compensation schemes.

As an interim measure, however, the Leq16 qualification threshold should be reduced from 66dBA to 55dBA, the threshold specified in the WHO ‘Guidelines for Community Noise, as marking the onset of ‘serious annoyance daytime and evening’.

Any household exposed to aircraft noise at night above threshold of 60 dB LAmax (fast) set down in the WHO Guidelines for Community Noise should also qualify for acoustic insulation.

Regarding ground noise, the current qualification boundary is clearly arbitrary. We do not have any firm view on what the boundary should be, but it should be based on a proper assessment of the actual impacts of ground noise upon residents who live in close proximity to the airport, especially the impacts at night.

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(iv) Airports’ Compulsory Purchase Powers

The current powers given to airport operators to compulsorily purchase land should be reviewed.

It cannot be right that an airport operator can compulsorily purchase farmland at its undeveloped price, (i.e. agricultural value), then develop that land as, for example, an airport car park, a business park or a warehousing complex, and then later sell the developed site at its full, free market commercial value, making enormous windfall profits in the process.

This is profoundly unfair to the original landowner and is, in effect, a hidden subsidy to the aviation industry.

There is also unfairness where an airport operator retains ownership of the developed site and rents it out because he can undercut competitors with similar premises (offices, warehouses etc.) available for rent outside the airport perimeter, who did not have the benefit of being able to compulsorily purchase the land for their developments.

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Do you think airport compensation schemes are reasonable and proportionate?

No.  “Government policy expects airport operators…..” needs “expect” to be replaced with “requires”, to be far more prescriptive as to the circumstances in which compensation must be made and to recognise that “mitigation”, if it requires householders to swelter behind closed windows, even if double- or triple-glazed, is not appropriate.  The suggestion that “Schemes should be reasonable and proportionate” allows far too much wriggle room; environmental damage continues to be systematically under-valued at every level, including that of reduction in property values as a result of increases in noise.

 

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It is considered that airport compensation schemes are not reasonable or proportionate. The noise levels at which compensation falls due are too high. Gatwick Airport has in place a noise insulation scheme for local residents as well as for other noise sensitive buildings.  It is considered that the current scheme could be more generous and should be applied to a wider area e.g. within the whole of the 57 dB LAeq,16h contour, all rooms within a house should be eligible, not just bedrooms, and grants should be offered for the replacement of double glazing installed many years ago.

If the idea of respite is to be taken forward then those who suffer the negative effects of changes to flight patterns should be considered for some means of compensation. In addition, it would appear that undefined “annoyance” is creating a noise problem and the first step should be to reduce the noise level of the 69 dB LAeq,16h to a much lower level. The high number of aircraft movements is making the average measurements over a period of time meaningless and is also responsible for the “annoyance” factor.

 


 

Question 20.  Do you agree with the approach to the management of noise from general aviation and helicopters, in particular to the use of the section 5 power?

Gatwick now handles no general aviation and few helicopters.  We have strongly objected to current planning application for the conversion of Redhill aerodrome from grass runways to a hard surface runway because we are aware of the very considerable annoyance caused by business and training flights, and by helicopters.  They also cause disproportionate climate change damage.

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It is not considered that there are sufficient local powers for adequate local resolution of noise from general aviation and helicopters, therefore, the application of the “section 5 power” is advocated.

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We would advocate that all UK airports with an annual passenger throughput of 5 mppa or above should be specified by the Secretary of State under s.5 of the Civil Aviation Act 1982.

This would require the CAA, in exercising its aerodrome licensing functions, ‘to have regard to the need to minimize so far as reasonably practicable – (a) any adverse effects on the environment, and (b) any disturbance to the public, – from noise, vibration, atmospheric pollution or any other cause attributable to the use of aircraft for the purpose of civil aviation.’

The Secretary of State has had the statutory authority to give the CAA this environmental duty for 30 years and we are disappointed that he has not once used these powers. We believe that the CAA could make a positive contribution to improving environmental standards at UK airports and so we would very much welcome the use of s.5 of the 1982 Act as a basis for giving the CAA a greater environmental role.

Many airports have significant and growing numbers of helicopter operations and these give rise to localized noise nuisance in settlements close to the airport which are commonly overflown at low altitude.

Civilian helicopters can now be over 2,500 horsepower and, in addition to engine and exhaust noise, helicopters produce a distinctive, low frequency blade noise.

Moreover, they fly at low altitude over rural settlements close to the airport and there is confusion as to whether the ‘500 ft rule’ or the ‘1000 ft rule’ applies.

There seems to be some reluctance on the part of both the CAA and the local airport management to be pro-active in seeking to reduce helicopter noise.

Helicopter noise impacts need to be reduced and a useful starting point would be to act on the recommendations of the 2008 DEFRA study ‘Research into the Improvement of the Management of Helicopter Noise’.

This study identified the need for further research on dose/response relationships to better determine annoyance to helicopter noise but as a general indication it considered that helicopters could be up to 15dBA more annoying than fixed wing aircraft.

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Question 20.  Do you agree with the approach to the management of noise from general aviation and helicopters, in particular to the use of the section 5 power?

The consultation draws attention to the fortunate (for aviation) circumstance provided by Section 76(1) of the Civil Aviation Act 1982 whereby even general aviation activities are immune from action under any legislation for noise nuisance.  Its emphasis is that “local environmental issues are best resolved at local level”, citing a CAA publication “Recommended Measures to help Reduce the Noise Related Nuisance from Light Aeroplanes” as an example of guidance in this area.  That publication refers to Noise Abatement Procedures (NAPS) but continues:

The publication of NAPs is one thing; the degree to which compliance is achieved or even monitored is quite different.

It goes on to refer to a guide produced by Wycombe Air Park which “might assist in enhancing the effectiveness of local NAPs and the aerodrome’s perceived standing in the community.”   It appears not to have done so: the present Aviation Minister is considering exercising the section 5 power in respect of that very airfield.

It continues: “the degree of sanction is clearly a difficult issue; aerodrome operators/licensees will not, for financial reasons if nothing else, wish to routinely deny the use of the aerodrome and its facilities. However, sanction is important, and it seems that the management at certain aerodromes strike a good balance in developing a rising scale of guidance culminating in penalty.”

In summary: management of noise from GA and helicopters is very poorly carried out, and in the particular case of helicopters it is virtually impossible for members of the public, unless located in the immediate vicinity of takeoff or landing point, to know sufficient about the aircraft to be able to report it – or to which agency.

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(Helicopters)

No.  The Governments approach focuses too much on “local” issues.  The section 5 power only covers “local” issues and, as it has never been used, it is clear the Governments use of it is ineffective.  The Government’s approach needs to consider the needs of those affected by helicopters away from airports and aerodromes, as well as those affected nearby.


 

Question 21.  What other measures might be considered that would improve the management of noise from these sources?

In the case of helicopters the planning rule that allows a field to be used for 28 days a year without permission should be amended to 4 a year.  The rule that allows unlimited use of the cartilage of a house should be reviewed.

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It is considered that legislation should be introduced to address helicopter noise. Given that helicopter noise has different characteristics and can affect a wide range of communities, close to both commercial and private helicopter landing sites, the Government should address helicopter noise through specific policies rather than within the general context of reducing noise from aviation.

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Requiring GA airfields to adopt the same sort of noise and track monitoring, reporting and management practice that exists at commercial airports. In practice, since it would not be cost-effective for such airfields to be radar-equipped, this would require use of “synthetic radar” equipment by the airfield and for all GA aircraft to fit Mode S transponders, wired through the battery master-switch so that they cannot be turned off during flight.

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(Helicopters)

A consideration of the need for the flights in the first place.  Recreational, sight-seeing and commuting type flights should be heavily discouraged especially when they have a negative impact on other people.


 

Question 22.   Do you have any further ideas on how the Government could incentivise the aviation and aerospace sector to deliver quieter planes?

At our suggestion, Gatwick Airport are introducing the publication of performance data, for example on track-keeping and CDA adherence, broken down by airline and aircraft type.  We are pressing them also to publish the results from the mobile monitors broken down by airline and aircraft type.  This will be important in ascertaining whether some airlines succeed in flying the same type of aircraft more quietly than other airlines.

The Aviation Policy Framework could usefully praise this initiative, and suggest it should be replicated at other airports.

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It is considered that the publication of performance data, for example on track-keeping and CDA adherence, broken down by airline and aircraft type, will incentivise airlines to improve their operating performance and ensure flight procedure best practice.

Differential landing fees based on noise emissions would encourage airlines to use quieter aircraft.

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There is presently no sign of any technological breakthrough which could significant reduce the level of aircraft noise nuisance and, in view of the long lead times for aircraft/engine development and the 20-25 year life cycle of aircraft coming off the production line today, it would take a very long time for the benefits of any technological breakthrough to be realized.

We believe that it would be far better for the Government to focus on improved noise control procedures rather than incentivising the aviation and aerospace industries to deliver less noisy planes.

There are many noise control measures (as in responses to questions above) which – given the political will – could be introduced at UK airports and which would reduce aircraft noise impacts.

We would therefore urge the Government to focus on tackling aircraft noise impacts at the operational level, rather than being drawn in to subsidizing industry R&D.

The Government should set ambitious but achievable noise control limits for UK airports and serve notice on the industry that these will be progressively tightened over the years, underpinned by strict enforcement and effective (i.e. substantial) penalties for non compliance.

That will provide a framework to encourage the industry to pay more attention to tackling its noise impacts.

Airports should also operate CDA on all landings.

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Question 22.   Do you have any further ideas on how the Government could incentivise the aviation and aerospace sector to deliver quieter planes?

Not without the regulatory powers to implement enforcement in relation to noise.  The CAA is concerned with aviation, not the environmental impacts of it.  It would be more appropriate for a department such as DEFRA to be involved.

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The stick will be much more effective than the carrot in this aviation sector.


Question 23.  Do you believe that the regime for the regulation of other local environmental impacts at airports is effective?

We note the recognition in paragraph 4.93 that air pollution (cars and aircraft) costs the UK up to £19 billion in reduced life expectancy.  That is considerably more than the economic output of the aviation industry.  The main theme of the section on air quality (paragraphs 4.92 onwards) is the need to meet EU standards.  We do not consider this sufficient.  The town of Horley, for example, lies downwind of Gatwick and suffers a level of pollution which although mainly below the EU legal limit, is nevertheless unpleasant and possibly dangerous to the health of some vulnerable people.

Airports should be encouraged to take measures to reduce pollution levels even when they are below EU limits.

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It is considered that the way  in which air quality and environmental impacts related to waste management and habitat are managed is also important in regulating airports.

As air quality at airports is closely linked to surface transport connecting to the airport, we welcome the commitment in the draft Aviation Policy Framework that the Government, as stated in paragraph 4.99, will “work with airport operators to develop low emission surface access strategies through, for example, improving rail access to airports and promoting lower emission vehicles”. The Council also welcomes the recognition of the role Airports’ Air Transport Forums can play in delivering surface access improvements.

Gatwick, like other airports, should be encouraged to take measures to reduce pollution levels even where they do not exceed EU limits. It is considered that aviation policy should focus on reducing aircraft particulate emissions (for example by reducing the amount of sulphur in aircraft fuel).

 

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No. We would like proper regulation and monitoring of air pollution from aircraft and of fuel dumping.

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We believe there are significant shortcomings in the following three areas:

(i) Air Quality – The DAPF states that the DfT’s policy on air quality is to seek improved international standards to reduce emissions from aircraft and vehicles and to work with airports and local authorities as appropriate to improve air quality.

We are not aware of any evidence to demonstrate the DfT’s commitment to improving local air quality at X.

The DAPF points out that airport operators have no legal duties in relation to the management of air quality but asserts that ‘this is not an impediment to action’ and it gives the example of the ‘Heathrow Air Quality Strategy for 2011-2020’ in support of this assertion. However this is a laissez faire approach and it does not constitute an effective national policy for alleviating the polluting effects of airport activities on the UK’s air quality.

Neither is it entirely correct to say that airport operators have no legal duties in relation to the management of air quality. For example, under the Environment Acts of 1990 and 1995 business operators who, in the course of their activities create pollution or annoyance that could be defined as a statutory nuisance, can be required to remedy the situation.

Local authorities have duties under the UK Air Quality Standards Regulations 2010 to monitor air quality and, if pollution is present, to draw up Action Plans (to be approved by the Secretary of State) for polluted areas, known as Air Quality Management Areas (‘AQMAs’).

While AQMAs may contain measures that can be locally enforced, local authorities have no powers to require an airport operator to modify its operations, vehicles or equipment, or any matters relating to aircraft movements that might help reduce airport emissions. Moreover, where there are air pollution problems in the vicinity of an airport, not only do local authorities not have the powers to deal with this, they do not have either the expertise or the other resources to apply effective air quality management policies in an airport environment. This is a very unsatisfactory state of affairs.

It appears to us that there is a lack of genuine commitment to meeting the EU air quality standards and so we do not find it surprising that the UK is failing to meet the targets for particulate matter (PM10) and Nitrogen Dioxide (NO2) required under the EU Air Quality Directive (2008/50/EC). The UK has been granted an extension by the EU to meet PM10 targets and has applied for an extension to meet NO2 targets since it does not expect to be able to achieve these by 2015

We believe that the EU statutory air quality limits would be more effective if the Government was more fully committed to achieving them, for example, by ceasing to treat NOx sampling exclusion zones as areas where the AQ standards do not need to be met, and by ceasing to keep looking for derogations and/or loopholes aimed at reducing the risk of infraction.

There is also a need for greater transparency on the air quality standards that are being achieved in the vicinity of airports and so we believe there should be a requirement for airports with a throughput of 5 mppa or above to have an approved AQ policy and to publish results quarterly, which should be subject to independent monitoring and oversight by the CAA.

Whilst NO2 and particulates pose the main risk to human health, other oxides of nitrogen (‘NOx’) are particularly harmful to vegetation, and the EU Air Quality Directive sets critical limits which must not be exceeded.

There is a need for much closer and far more transparent monitoring by the airport of NOx levels within these SSSIs.

(ii) Airport Surface Access – There is no meaningful regulation in this area. Airports are left to develop their own surface access strategies and, above all, these are focused on meeting their own commercial interests rather than on minimizing environmental impacts. An example of this at X – following a competitive tender – granted an exclusive franchise to one airport taxi operator and this results in almost a doubling of the requisite number of taxi journeys to and from the airport. Occasionally, local authorities can exert influence on an airport’s surface access strategy via planning conditions but this opportunity only arises when a planning application is submitted and determined locally.

We would encourage the DfT to re-visit the Integrated Transport White Paper ‘A New Deal for Transport: Better for Everyone’ which set out a range of policies aimed at reducing the environmental impact of surface access travel, including travel to and from airports.

Some progress has been made in implementing these policies but there is much more that could be done and we believe there is a place for regulation in order to assist in policy implementation. For example, tight limits on airport car parking – both for passengers and airport employees – would help encourage the use of public transport and reduce car journeys to/from airports. Tight limits on airport car parking could also encourage the development of distant park-and-ride facilities and, again, reduce the surface access impacts of airports.

The Government should set down a range of policies aimed at reducing and minimizing airport surface access and that these policies should, wherever practicable, be underpinned by regulation.

The Government should also consider using fiscal measures as a means of contributing to the delivery of its airport surface access policy objectives.

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(iii) Airport Ground Noise – In our response to Q.9, above, we referred to the weak regulation of airport ground noise. We encourage the DfT to introduce more effective regulation in this area, having regard to international best practice.

 

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Question 23.  Do you believe that the regime for the regulation of other local environmental impacts at airports is effective?

The attempt to sidestep European Directives on atmospheric pollution in the vicinity of Heathrow suggests that “No” is an appropriate response.

 


Question 24.  Do you think that noise regulation should be integrated into a broader regulatory framework which tackles the local environmental impacts from airports?

There is no legislation specifically dealing with the adverse environmental impact of airports.  We would like to see a Bill introduced covering all the environmental aspects of aviation – so long as this did not mean that necessary improvements were delayed indefinitely while waiting for Parliamentary time.

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Not if it takes attention away from the noise issue itself which, in areas within 10 miles of an airport or airfield, has the largest impact on the greatest number of people.

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Yes, noise regulation should be integrated into a broader regulatory framework which tackles the local environmental impacts from airports.

Airports by the nature of their activities will have an impact on their local communities e.g. commercial vehicles delivering/collecting air freight over which they currently have little or no regulatory control, therefore, there is merit to widening the framework.



 

On Health impacts

Health impacts – No consultation questions have been posed by DfT on health impacts. However below are the comments from one airport group:

The DAPF pays only scant attention to the effects of aircraft noise on health. We recommend that the final version of the aviation policy framework includes a ‘Health Impacts’ chapter.

This may cause some duplication of material, but the health implications of continued expansion of UK aviation needs to be properly addressed.

Moreover, the Department of Health should have been included in the departments listed for consultation on this document.

In 1999 EU members adopted the WHO ‘Charter on Transport, Environment and Health’ (17)which requires them to ‘ensure that the wellbeing of our communities is put first when preparing and making decisions regarding transport and infrastructure policies’.

In the same way that the Government respects and honours the 1944 Chicago Convention, we would expect it to respect and honour the 1999 WHO ‘Charter on Transport, Environment and Health’, to which it is a signatory.

The adverse health effects of aviation fall disproportionately on those who are vulnerable, i.e. children, the elderly, those with disabilities and those who are socially excluded.

The WHO Charter stresses the importance of carrying out environmental and health impact assessments (EIAs and HIAs) to ensure that noise and air quality levels are acceptable for environments such as dwellings, schools and hospitals.

The need for health impacts to be assessed and taken fully into account needs to be reflected in the final version of the aviation policy framework, and HIAs, like EIAs, should be mandatory for any major airport development proposal.

It is regrettable that the Royal Commission on Environmental Pollution (‘RCEP’) has been disbanded. In its report on the environmental effects of civil aircraft in flight (18)  it concluded that unchecked air travel would soon become a major factor in driving climate change, with serious consequences for air pollution, flooding, water scarcity and the potential for tropical diseases in temperate climates.

This was a major contribution to the debate over the need to address aviation’s growing climate change impacts and these RCEP conclusions – published ten years ago – still need to be taken into account.

So too should the conclusions of the RCEP’s 2007 report (19) which recommended that HIAs be incorporated explicitly in sustainability appraisals, strategic environmental assessments and EIAs.

Another report which the DfT should take into account when developing its aviation policy framework is the Government’s 2008 White Paper, ‘Health is Global’: a UK Government Strategy 2008-2013’, published by the Department of Health (‘DoH’).

This spelt out the principle that the Government would ‘set out to do no harm and as far as was feasible would investigate the impact of our domestic and foreign policies on global health to ensure that our intention is fulfilled’.

It emphasized that global health was determined by factors which showed scant respect for national boundaries, such as international trade, climate change and pollution. Endorsed by the then Prime Minister and subsequently by the Coalition Government, this report sets out a strategy which will focus over a period of five years on improving the health of people across the world including the U.K.

Clearly this has implications for aviation policy and the DfT should explain, in its final version of the aviation policy framework, the steps it is taking to ensure that the policies set down in the ‘Health is Global’ White Paper are being taken forward.

The current Air Quality Strategy for the UK (2007) estimated that poor air quality reduces life expectancy in the UK by an average of 7-8 months and this takes no account of the numbers of susceptible individuals sensitive to NOx or PM10/PM2.5 who are admitted to hospital annually.

Any activity liable to aggravate the situation should be required to take appropriate preventive action. The House of Commons Environmental Audit Committee (‘EAC’) reported on poor Air Quality in 2010 (20) and found that air pollution could be contributing to as many as 50,000 deaths per year and in pollution hotspots it could be cutting the most vulnerable people’s lives short by as much as 9 years.

The EAC recommended that a dramatic shift in transport policy was required if air quality is to be improved.

Recent research (21) has assessed the risks associated with aircraft emissions globally, emitted in the stratosphere and eventually transmitted by air currents to ground level.

It appears that these emissions are a source of particulate matter, PM2.5 and are therefore directly associated with the increased mortality risks highlighted in a report by the DoH Committee on the Medical Effects of Air Pollutants.(22)

The final version of the DfT’s aviation policy framework needs to consider all of the adverse health impacts of aviation – which have national as well as international implications – and set down policies to address these.

The Government – and in particular the DfT – needs to pay far greater attention to the impact of aircraft noise on children’s health and education.

There is a wealth of academic evidence, independently peer reviewed, which indicates that aircraft noise disturbance gives rise to significant adverse impacts upon community health and children’s education. We do not propose to go through that evidence here.

A good summary of the academic evidence is provided in a literature review published by the CAA in February 2010.(23)

 

References:

17  ‘Charter on Transport, Environment and Health’, World Health Organization, June 1999.

18  ‘The Environmental Effects of Civil Aircraft in Flight’, Royal Commission on Environmental Pollution, November 2002.

19  ‘The Urban Environment’, Royal Commission on Environmental Pollution, March 2007.

20  Environmental Audit Committee, Fifth Report 2009/10, ‘Air Quality’, March 2010.

21  ‘Global Mortality Attributable to Aircraft Cruise Emissions’, Steven R. H. Barrett, Rex E. Britter and Ian A. Waitz, Environ. Sci. Technol., 2010, 44 (19), pp 7736–7742, September 2010.

22  ‘Cardiovascular Disease and Air Pollution’, Committee on the Medical Effects of Air Pollutants, Department of Health, February 2006.

23  ‘Aircraft Noise and Children’s Learning’, CAA ERCD Report 0908, February 2010.

 

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Draft Aviation Policy Framework is at Draft Aviation Policy Framework (PDF – 618 kB)

The overview of the consultation, and link to the survey form, are at https://consultation.dft.gov.uk/dft/aviation-policy-framework/consult_view

and the online form to fill in is at Online Survey

End of consultation is 31st October 2012


 


 

There is more information on the consultation, and the other sections of it, at 

Draft Aviation Policy Framework consultation. Ends 31st Oct 2012