GACC response to night flights consultation: “Ban all night flights by 2030, and cut the noise at night”

GACC (Gatwick Area Conservation Campaign) has produced its response to the DfT’s night flights consultation. The response has been put together after discussion with GACC’s committee members, so that others who want to submit a reply can make use of it, if they wish.  Some of the points are copied below, but there is more detail with references in the full response which anyone interested is advised to read. Some of the points made by GACC are that the claims of the economic benefits of night flights at Gatwick are flimsy and not substantiated; there should be a thorough analysis within the next 2 years of the balance between the economic benefits and the health impacts/widespread disturbance of night flights, leading to a reduction in both the number of flights and noise quotas; there should not be an increase in the number of night flights in winter; GACC supports the reduction in noise quotas to match (and go below) existing usage, encouraging purchase by airlines of less noisy planes; many GACC members feel strongly that there should be a total ban on all night flights; GACC agrees with Stop Stansted Expansion that government should announce that night flights will be phased out by 2030; GACC strongly supports the suggestion that the noise quotas may be reduced by 5% a year so as to be 20% lower by 2022.

Ban all night flights by 2030, and cut the noise at night 

GACC responds to consultation.  Read the response.

GACC has produced its response, after consultation with its committee members, so that others who want to make a reply can make use of it, if they wish.  Some of the points are copied below, but there is more detail with references in the full response

Some of the points made by GACC are:

The consultation has been delayed: it was originally expected in October. That means that the consultation period has been cut short, to under seven weeks instead of the normal three months.

We welcome the aim to encourage quieter aircraft. However the aim should be to reduce the number of people significantly affected – delete the weasel words ‘to limit’ (which in DfT speak can mean to increase but not too much).

It should be made clear that this objective (of encouraging the use of less noisy aircraft to limit or reduce the number of people significantly affected by aircraft noise at night) can only be achieved by quieter aircraft not by merely introducing more concentrated flight paths.
Although the consultation refers to the existing benefits of night flights there is no attempt to quantify them. It is stated in paragraph 1 that aviation ‘directly supports around 230,000 jobs … and contributes over £21 bn annually to UK GDP.’ but that is exaggerated and misleading: it includes flights at all times of day; it also includes aircraft manufacture and aerospace which are irrelevant.


The economic benefits of night flights at Gatwick are small. There is little or no freight which requires night-time delivery. Most of the night flights are to or from holiday destinations with no special justification on business grounds. We understand the argument that night flights allow airlines to make more use of their aircraft with three rotations a day but that is a doubtful argument: it is not applied to most other commercial operations such as noisy factories or retail deliveries which have their working hours firmly controlled by planning conditions.

Any calculation of economic benefits is suspect unless it takes into account the hidden subsidy to airlines as a result of paying no fuel tax and no VAT, the benefit of which is about four times the revenue from air passenger duty.

In so far as there are economic benefits, in some cases they could be achieved by better scheduling. If aircraft to middle-distance destinations were scheduled to depart before 11.30 pm and scheduled to return after 6.00 am the benefits of three rotations could be achieved without flights at Gatwick during the night quota period.
We are content with the proposed five years [as the proposed length of the next regime].   However a thorough analysis of the balance between the economic benefits and the health impacts / widespread disturbance of night flights should be made within the next two years, leading to a reduction in both the noise and number quotas.
We are shocked that there has been no fundamental review of the night flight regime since 2006.  Thus the opportunity for environmental improvements has been lost. Until 2012 there was a progressive year-by-year reduction in the level of noise permitted at night at Gatwick. A clear indication that this progressive reduction would continue was given in a Ministerial Statement by the then Aviation Minister: “The government will take into account the freeze in quota limits during this extension period when setting the next regime and expects
airlines to continue to improve their environmental performance in the interim.” [Rt Hon Theresa Villiers. 12 March 2012]
We strongly disagree [with the proposal for movement limits to remain unchanged at Gatwick]. They should be reduced. As shown above, the economic justification for them is weak. At the very least the aim should be to achieve a steady year-by-year reduction.
We support the call by Stop Stansted Expansion for the Government to announce that all night flights will be phased out by 2030.
The winter movements quota is not fully used. Paragraph 2.19 of the consultation paper says:  ‘There is however still capacity in the winter period and given the constraints on airport capacity in the south east, the Government does not think it appropriate to constrain this further’.  That is alarming, inaccurate and silly.
Alarming because it indicates that the Government is prepared to accept a 60% increase in the number of night flights in winter.  Inaccurate because with Stansted and Luton operating at little more than half capacity there are no real constraints on airport capacity. And silly because it is unlikely that any airline would want extra winter night-time slots when none are available in summer.
Instead, as a minimum, the winter movements quota of 3,250 movements should be reduced to match the actual usage in the past five years of under 2,000.
Many of our members feel strongly that there should be a total ban on all night flights. There is growing evidence of the adverse effects on health of aircraft noise at night.
Heathrow [if permitted a 3rd runway] is to have a total ban so why, it is said, should the same not apply to Gatwick and indeed other airports  Nevertheless the widespread demand for a total ban illustrates the strong hatred of all night flights.
Indeed it is anger at the failure to cut the number of night flights which has led to the request that a proper assessment of the economic benefits is made, followed within two years by a reduction in the movements and noise quotas.
We support the aim to reduce the noise quotas to match existing use. This is a change which GACC urged in 2012 and in 2014 and we are delighted that it is at last being implemented – at least for the summer quota. It removes the potential for a large increase in noise at night which would be unacceptable. Having a large surplus of noise points has meant that the noise quotas have been totally ineffective in their aim to encourage quieter aircraft.
The proposal to reduce the summer noise quota to 4870, which is slightly less than the actual use in the past three years, would fulfil this aim.
We are amazed, however, that the new noise quota for the winter is proposed at 1,655 which almost double the actual use in two of the past three years. That would negate the aim of setting the limits to match existing use, and would mean that the noise quota would be totally ineffective and would provide no incentive for the use of quieter aircraft. The new winter noise quota should be set at around 900.
We also strongly support the suggestion in paragraph 3.25 that the noise quotas may be reduced by 5% a year so as to be 20% lower by 2022.
That would represent a big improvement in the situation at Gatwick, especially for the
communities close to the airport which suffer the worst noise. It would put pressure on airlines to buy and to operate quieter aircraft. In the long run this type of measure is what encourages manufacturers to design quieter aircraft.
We are, however, worried that this [the cut by 5% of noise quotas] is only described as ‘hypothetical’ and that it is not included in the summary of measures being proposed. Indeed in paragraph 4.6 it is stated that: ‘we would only adopt a reduction in noise quota if evidence suggests this would act as a realistic incentive for airports and airlines to use
quieter aircraft rather than to penalise them with unrealistic targets.’   If this were to mean only reducing the noise quotas after the airlines had bought quieter aircraft it would provide no incentive.
We trust that the Department will resist lobbying from the aviation industry to water down this proposal.  Only if the noise quotas actually put pressure on airlines to buy and operate quieter aircraft will they be beneficial: as Lewis Carrol said; ‘Medicine has to taste nasty!’ We therefore hope that this proposal can be up-graded to a definite policy when the Government announce their decisions.
We are appalled at the suggestion in the consultation paper (paragraph 1.38) that noise at night only affects some 4,300 people at Gatwick (the number within the  48 Leq.night contour). We are glad that the consultation uses the 48 Leq.night measurement rather than the discredited 57 leq, but it still measures the average noise which is almost meaningless at night.
Some 50,000 people live in the northern part of Crawley and 20,000 in Horley, and many of them are affected by ground noise, especially the roar at start of roll and the use of reverse thrust. It is also our experience that complaints about night flights come from a far wider area, up to twenty miles around the airport – because of the low background noise in rural areas.
Indeed the table in Appendix G paragraph G5 shows that the footprint of an A320 approaching from the east creates over 60dB for 20,000 people. That is above the WHO health recommendation.
A recent research study for GACC carried out by the Dutch research agency To70 found that: ‘The percentage of annoyed residents is likely to be higher in areas with low ambient noise than in high ambient noise areas. It can be misleading to compare noise annoyance between different airports, when these local differences are not taken into account. Hence, the local difference between ambient noise levels should always be taken into account when calculating the annoyance.’
Another factor is the increase in traffic on local roads at night time generated by the flights during antisocial hours. All the local roads to and from the airport are busy through the night and this must affect the sleep of people living near those roads, even if their homes are not overflown.
We are concerned at the suggestion in paragraphs 3.3 – 3.5 that the present controls on night flights by the DfT may be replaced by ‘bespoke’ controls imposed locally, possibly through the planning system. The planning authority for Gatwick is Crawley Borough which benefits substantially from employment at Gatwick whereas other nearby councils suffer worse noise. Any new system should involve all the councils around the airport.
Paragraphs 2.28 – 2.32 in the consultation paper refer to land use planning.  They are largely meaningless unless local planning authorities can have an assurance that there will be no change in flight paths over the 50-100 year lifespan of new houses, schools or hospitals.
We would wish to see a longer night quota period. Six and a half hours is too short for anyone to get a good night’s sleep – even if they go to sleep on the dot of 11.30 pm and are not woken up by the bunching of early arrivals and early departures before 6.00 am. The World Health Organisation (WHO)’s Guidelines on Community Noise suggest that night should be defined as 11.00 pm to 7.00 am.

Read the full response by GACC (Gatwick Area Conservation Campaign) at

The DfT night flights consultation document is at
Responses have to be submitted before 28 February.
The Department would prefer you to use the online web form at
Otherwise email your response to


See also

Stop Stansted Expansion says DfT plans on night flights do not go nearly far enough

Following the publication of the DfT’s night flight regulation consultation, SSE is urging urging local district, parish and town councils and individual local residents to respond, to try to get the noise impacts of Stansted night-time flights reduced.  Stansted currently has permission for 12,000 night flights a year, more than twice as many as are permitted at Heathrow. The 12,000 annual limit applies only to the 6½ hours from 11.30pm to 6.00am whereas the normal definition of ‘night’ is the 8 hours from 11.00pm to 7.00am. Moreover, a large number of Stansted’s night flights are large, noisy cargo aircraft, many of which are very old. Unsurprisingly, these give rise to a disproportionately high level of noise complaints. SSE welcomes the DfT intention to remove the current exemption for less noisy aircraft and adjust the movements limit accordingly – but the DfT proposes to maintain the present night limit on Stansted aircraft movements.  The number of exempt aircraft has been increasing, and they need to be included in totals. SSE wants an unequivocal Government commitment to phase out all night flights at Stansted by 2030, except in the case of genuine emergencies. SSE also wants the annual flight limit  to apply, not just from 11.30pm to 6.00am, but from 11.00pm to 7.00am, so that ‘night’ truly means ‘night’.

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