RHC challenges economic need for night flights at Heathrow, when slots can be provided during the day

The Richmond Heathrow Campaign has submitted a detailed response to the night flights consultation. One particularly interesting point they make is that Heathrow does not actually need flights between 11pm and 6am or even 7am. The airport proposed adding 25,000 more flights per year, if it is given planning consent for a new runway, before the runway is built. That means there can be 25,000 more flights per year – around 68 more per day, or about 4 – 5 per hour more (half take offs and half landings). Heathrow says it is full, but would be able to fit in these extra flights, if it wants to. Therefore, if these slots are possible, some of the flights currently in the night period could be moved into the day period. However, there are concerns that the extra 25,000 flights per year would mean loss or runway alternation, that is seen as vital for those currently overflown by Heathrow approach flight paths. The RHC believes late running flights and increased numbers of flights between 6 and 7am are largely ignored by the consultation and people may wish to comment. For the sake of people’s health, the noise disturbance to sleep has to be ended, with no flights before 7am. There needs to be a ban on scheduled and unscheduled night flights starting by 2020, irrespective of any decision on a 3rd runway.



Richmond Heathrow Campaign response to Night Flights consultation – challenges economic need for them, when slots can be provided during the day


[From the RHC website and consultation response (extracts below selected by AirportWatch]

The current agreement on limiting night flights expires in October 2017 and the Government has issued a consultation. It largely ignores the evidence and views of residents. The proposal is for a five year regime to 2022 with no attempt to materially reduce night time noise.

The Government’s proposals for Heathrow continue to limit the number of flights to 16 between 11:30pm and 6am.  Controls are extended to quieter aircraft and noise limits are reduced to current actual levels – neither of which in practice will reduce noise. A suggestion to tighten the controls each year may slightly reduce noise over the 5 years. It is important residents show strength of feeling on night flights.

We encourage as many people as possible to respond. To have greatest impact, we suggest you may wish to focus your response on the following issues:

1. Night flight noise affects a large number of people – over 400,000 people around Heathrow.

2. There is no end in sight for those suffering from the noise. Government proposals for restrictions over the last 10 years have had little or no impact on night time noise and the current proposals will have little impact.

3. Each of us will have our own personal experiences of aircraft noise at night, which may be
raised in responses.

4. For many the night extends from 11pm to 7am. The issue is not just about the core night period from 11:30pm to 6am. Late running flights and increased numbers of flights between 6 and 7am are largely ignored by the consultation and people may wish to comment.

5. Richmond Heathrow Campaign seeks a ban on all flights between 11pm and 7am. We make the case that there is no loss from re-timing night flights into the day and there is daytime capacity to absorb all night flights. There is no other remedy for the high cost on peoples’ sleep and health.


We are disappointed that the Government has not faced up to the challenge and proposed material changes to reduce the excessive noise blight across London from Heathrow’s night flights. The Consultation proposes minimal changes to the restriction on night flights at Heathrow.

Over 400,000 people are affected and only a 10% reduction is forecast over the next 35 years and this is 50 years after restrictions were introduced.

The number of people affected increased by 8% between 2006 and 2015. [Largely due to increased population in the areas affected by Heathrow noise. AW comment].

Seventeen years after the WHO Guidelines were published there is still no measurement of the gap between these Guidelines and the far higher noise metrics used by the Government, let alone any attempt to meet the Guidelines.

For most of the first half of the 21 century, according to the Airports Commission, there is unlikely to be any significant reduction in night time noise 23:00-07:00, and given the lack of controls between 06:00 and 07:00 there is a risk noise levels will increase over this period.

The Government needs to get a grip on the pollution affecting so many people and stop making excuses for rolling over the regimes unchanged since 2006 until 2022. Firm action is needed now.

The thesis of our response is that:

1. there is no need for Heathrow night flights 23:00-07:00,

2. there are at least 25,000 day-time slots a year to absorb all re-timed night flights 23:00-07:00,

3. the Balanced Approach to noise management is inadequate in this case, and

4. night time noise levels are too high and reducing too slowly, especially in the early morning shoulder period, so that the only solution is a night time ban on all flights from 23:00 to 07:00.

Annex A sets out the evidence and case demonstrating that shifting to the day of around 16 flights arriving at Heathrow between 23:30 and 06:00 and around 25 arrivals between 06:00 and 07:00 and 40 departures in this hour can be achieved with minimal net commercial or economic cost. We believe the Airports Commission supports this assessment, at least for the period 23:00 to 06:00, and evidence is provided to that affect.

Annex B sets out the evidence demonstrating there is sufficient day time capacity at Heathrow to absorb a shift of all the night flights into the day. This is based on scheduled hourly use of Heathrow and the efficiencies being introduced to prevent delays and improve punctuality and resilience. Heathrow announced in September 2016 it can increase traffic by 25,000 flights a year without increasing delays.

Annex C demonstrates the failure of the Balanced Approach to sufficiently reduce night time noise, notwithstanding additional proposals made by the Consultation and by ourselves. Benefits from less noisy aircraft through fleet change and operational performance are partly offset by population growth. Land use planning is of limited benefit in reducing the impact of aircraft noise. Restrictions, such as additional QC bans and quota point limits have relatively small impact and none on the early morning shoulder period (06:00-07:00), which is a major contributor to the noise from night flights.

Annex D sets out the Environmental Imperative for a for a Night time Ban at Heathrow from 23:00 to 07:00. It is the only viable alternative and given the minimal value of retaining night flights and the feasibility of using day time capacity instead, it is the option we strongly recommend the Government now implement. We believe there should be a staggered introduction of a ban on scheduled and unscheduled night flights starting in the year 2020, irrespective of any decision on a 3rd runway.

Since the recommendation for a ban on night flights by the Richmond Heathrow Campaign and others on several previous occasions has not been fully addressed by the Government then or in this Consultation, we can only suppose a ban would not be implemented at the start of the next regime in October 2017. Nevertheless, we urge the Government to take steps to evaluate our proposals with a view to changes being made within the 5 year regime. We note that Directive 2002/30/EC governs rules on the adoption of operating restrictions before 13 June 2017, such as the night flight regime, and requires them to be no more restrictive than is needed to achieve the environmental objectives for each particular airport. Due to the delay in renewing the current regime, changes are now out of time for the transitional arrangements. But we expect the Government still to be able to introduce a ban in the next 5 year regime.


See the full RHC consultation response at



Government Night Flight Consultation 2017
Deadline Tuesday 28 February

The Department for Transport is currently carrying out its consultation on the Night Flight regime for five years to 2022.

The Government’s consultation

The Government’s questionnaire for your response

For more detail, see the Richmond Heathrow Campaign  Night Flights page.