Aviation Environment Federation response to DfT’s 2nd stage consultation on night noise
The DfT places restrictions on night flying at Heathrow, Gatwick and Stansted airports. These are reviewed every few years, though in 2012 it was decided to just extend the restrictions until October 2014. There have been two phases to the current consultation, for changes after October 2014, with the first consultation ending in April 2013 and the second phase ending on 3rd February 2014. The DfT believes it should take “account of the findings of the Airports Commission before making any changes to the night restrictions regime.” They therefore propose not making any significant changes till October 2017. The Aviation Environment Federation (AEF) has responded to the DfT’s 2nd stage consultation. They comment that there is a need for an evidence-based target to inform a long-term night noise policy. This should be to reduce night noise below the threshold recommended by the WHO to avoid damaging health impacts. Improvements are needed soon, and therefore they oppose the intention not to make changes before 2017. Greater emphasis needs to be given to the health impacts, on which there have been more studies. There also need to be supplementary metrics to measure the impact of night noise and the performance of the existing night noise regime.
AEF response to the DfT’s second stage consultation on night noise
Jan 31st 2014 (Aviation Environment Federation)
In it we highlight the need for an evidence-based target to inform a long-term night noise policy which should be to reduce night noise below the threshold recommended by the WHO to avoid damaging health impacts. We state that short-term night noise regimes should be making in-roads towards that target and so we oppose the DfT’s proposal to extend the existing night noise regime until 2017.
We responded in April 2013 to the first stage consultation and emphasised the importance of recognising WHO recommendations on the noise exposure thresholds for avoiding health impacts. While we welcomed the increasing seriousness that the Government is affording to the health impacts of aviation noise, we were disappointed that these did not inform either the regime’s proposed environmental objectives or changes to the regime itself.
We made several recommendations for improvements that should be considered when the regime’s environmental objectives are next reviewed, as well as the need to introduce supplementary metrics to measure the impact of night noise and the regime’s performance.
Consultation document questions
Q1: Do you agree with our preliminary view as to the new studies on health effects?
Q2: Do you have any further views on the costs and benefits, including health impacts, which we should take into account in our decision?
Q3: Do you agree with the proposed environmental objectives?
Q4: Do you agree that the next regime should last until October 2017?
Q5: Do you have any views on the revised dispensations guidance?
Q6: Do you agree that we should maintain the existing movement and noise quota limits until October 2017? If not, please set out your preferred options and reasons – this could include the noise and economic impact of any alternatives.
Q7: Do you have any comments on our forecasts to October 2017?
Q8: Do you have any views on how the benefits of quieter aircraft can be shared in future between communities living close to the airport and the aviation industry?
Q9(a): Do you agree with extending the operational ban of QC/8 and QC/16 aircraft to the entire night period (23:00 – 07:00)?
Q9(b): Do you agree with our assessment of the costs and benefits in the draft IA?
Q10: Are there any other changes to the regime which we should consider?
Q11: Do you have any further comments on the scope for trialling new operational procedures which have potential noise reduction benefits in the period up to 2017?
Q12: Are there any other matters you think this consultation should cover?
Q13(a): Do you agree with the locations of the proposed new noise monitors at Heathrow? If not, are there alternative locations you would favour and why?
Q13(b): Do you agree with the proposal to apply runway-specific limit adjustments for easterly departures at Heathrow? If not, please give reasons.
Impact Assessment questions
Question 1: Do you agree with our assessment of how movements and quota usage are likely to change over the period to the end of the summer season 2017 at Heathrow, Gatwick and Stansted?
Question 2: Do you agree with our assessment of the costs and benefits of option 1 at Heathrow, Gatwick and Stansted? Would you expect there to be any additional costs and benefits?
Question 3: Do you agree with our assessment of the costs and benefits of option 2 at Heathrow, Gatwick and Stansted? Would you expect there to be any additional costs and benefits?
Q3: Do you agree with the proposed environmental objectives?
First environmental objective: Limit and where possible reduce the number of people significantly affected by aircraft noise at night.
3.1 The objective: We strongly believe that the government’s overall objective on aviation noise, which is reflected in the first environmental objective, is effectively meaningless without a baseline or quantifiable target.
3.2 Assessment criteria: The consultation document suggests using the area and number of people within the 6.5 hour night quota period contours and particularly the 55dB contour. We believe that the LAeq metric used to produce the 6.5 hour night contour is useful for looking at trends over time in the average night noise. However, it is not effective for measuring the impact of the noise at night on communities. To measure this impact, two important factors that should be considered are loudness and the frequency of these loud events. To measure this, alternative metrics are required as outlined below.
3.3 Alternative metrics: We suggest the use of the LAmax noise metric to measure loudness and the likelihood of sleep disturbance such as awakenings; the L90 metric, which reflects the background noise for 90% of the time, to measure background noise (a combination of the LAmax and L90 will show the relative intrusion – for example, a lower LAmax may still be regarded as intrusive in areas where background noise levels are particularly low); and the NA (number above) metric to examine the frequency of events above a given noise threshold. We would recommend measuring NA63 as it is consistent with the recommendations on night noise exposure made by WHO Europe.
3.4 Measurement period: Notwithstanding our suggestion on alternative metrics, we would like to add our support to make the night quota period consistent with the commitment made in the APF to produce eight hour night noise contours. Monitoring and addressing the number of people within noise contours for the entire eight hours would better aid assessment of how many people are affected by night noise and would be more in line with EU noise mapping requirements and WHO recommendations.
Second environmental objective: Reduce sleep disturbance resulting from use of the noisiest types of aircraft
3.5 The objective: We would like to question what this objective seeks to achieve. If the objective seeks to reduce the number of the noisiest aircraft operating in night periods then that should be a standalone, albeit related, objective while reducing sleep disturbance should be another. We outline our reasoning below. We would recommend two new objectives: to reduce sleep disturbance in the night period; and to reduce the noisiest aircraft operating in the night period.
3.6 Assessment criteria: The consultation does not present any information to suggest that reducing the use of the noisiest aircraft (QC/4) will lead to lower sleep disturbance. The WHO recommends an LAmax limit of 42dBA indoor to prevent sleep disturbance, which translates using the WHO’s calculated average attenuation level to 63dBA LAmax (see footnote 4 for a full explanation). If QC/2 or below aircraft continue to emit noise above the LAmax of 63dBA then monitoring the number of QC/4 aircraft operating in the night period will not necessarily contribute to reducing sleep disturbance. While we support the removal of the noisiest aircraft without question, it may not be sufficient as an assessment criterion to achieve part of the objective.
3.7 We would further like to add that there is a well known challenge of reconciling the noise classification metric (EPNdB)16 used to produce the Quota Count with perceived noise on the ground and the findings of social surveys. This supports our conclusion that the proposed assessment criterion is unfit for purpose.
3.8 Recommended assessment criteria: To assess our two proposed objectives, we suggest that the DfT continues to monitor the number of movements of QC/4 aircraft as this is a relatively easy exercise and is fit for reducing the noisiest aircraft operating in the night period. To monitor steps towards reducing sleep disturbance, LAmax levels should be monitored for consistency with WHO recommendations.
Third environmental objective: Maintain a stable regulatory regime pending decisions on future airport capacity and, at Gatwick and Stansted in particular, to allow growth in movements up to existing night movement limits and within noise quotas
3.9 We do not regard this as an environmental objective and it should be removed. We refer you to our answers to Q6 for comments on the proposed regime.
Fourth environmental objective: Encourage the use of quieter aircraft during the night quota period so as to maintain the historic reduction in noise emitted per aircraft movement during the night quota period
3.10 The objective: We support the use of less noisy aircraft in the night period but it should not lead to an increase in the overall number of noise events that continue to exceed WHO Europe guidelines. Achieving the proposed objective would suggest that each individual aircraft may emit less noise but more aircraft could fit within the noise quota. As we outline in our answer to Q8, communities would not benefit from individual aircraft being marginally less noisy if it permits more flights at levels still likely to cause sleep disturbance. We suggest amending the objective to: encourage the use of quieter aircraft during the night period so as to reduce the overall impact of aircraft noise during the night period.
3.11 Assessment criteria: The assessment criteria proposed permits the objective to be achieved through gradual fleet turnover so that the average QC points per movement will continue to decline without intervention. We draw attention to our point with regards to the second environment objective that QC points do not directly reflect noise impacts on communities and need to be supplemented with the additional metrics we propose above.
3.12 Additional comments: As well as addressing the health impacts associated with night noise, we would like to highlight the increasing sensitivity of communities to aircraft noise and we would recommend that environmental objectives should be reviewed to take into account existing and new dose/effect studies.
Stop Stansted Expansion calls for reduction and phasing out of Stansted’s night flights
February 3, 2014
Stop Stansted Expansion (SSE) has made a detailed submission to the DfT consultation on night flights, calling for Government action to end the scourge of these flights. The government consultation proposes that Stansted should continue to be allowed 12,000 flights a year between 11.30pm and 6.00am. This is more than twice as many as are permitted at Heathrow and far more than are needed. The 12,000 cap was set in 2006, when Stansted was still expanding rapidly, and a 2nd runway was planned. However, today Stansted is handling 30% less traffic than in 2006. Logically allowing Stansted 12,000 night flights a year can no longer be justified. SSE argues that those living under Stansted’s flight paths should have the right to an uninterrupted night’s sleep, ie. a full 8 hours and not just the 6½ hours covered by the current restrictions. Stansted handled just over 8,500 night flights last year – well below the Government limit of 12,000. SSE is pressing for the limit to be cut to 7,500 night flights from October 2014 and then further reduced by 500 flights each year until night flights are totally phased out. The recent announcement by British Airways that it pulling the plug on its cargo operations at Stansted means that reducing the number of permitted night flights at Stansted from 12,000 to 7,500 should now be easily achievable.
Second stage consultation on night flying restrictions for the major London airports announced.
11 November 2013
The government announced on 26 March 2012 an extension of the restrictions on night flying at Heathrow, Gatwick and Stansted Airports for a period of two years until October 2014.
Our subsequent first stage consultation closed on 22 April 2013 and gathered evidence on options for the next regime. We are grateful to all who took the time to respond to this.
I am announcing today (11 November 2013) the publication of a second consultation which sets out our proposals for the next regime.
Many of the respondents to the stage 1 consultation suggested that we should take account of the findings of the Airports Commission before making any changes to the night restrictions regime. The commission’s final report is due to be published in summer 2015, preceded by an interim report at the end of this year.
As noise impacts are a key consideration for the commission, we agree that it would not be sensible to make any significant changes to the current regime before the commission has completed its work and the government has had time to consider its recommendations. We therefore propose to set a 3 year regime to last until October 2017 which will retain the main features of the current regime, in particular the numbers of movements and noise quota permitted.
I will place a copy of the consultation in the libraries of both Houses.