Government ignoring its own policy on Heathrow noise assessment
Having seen email correspondence between the DfT and the CAA, the No 3rd Runway Coalition says the Government’s Airports National Policy Statement (NPS) ignores its own policy on measuring noise, and CAA advice on how to assess the number of people impacted. The Coalition has called for a pause in the process of considering the Government’s Airports NPS, to ensure that the full noise impacts of the proposed expansion of Heathrow are properly evaluated. Although it is not possible to assess the negative consequences of a third runway without clear information as to the design of the accompanying flight paths, no such information has been presented in the DfT’s documents. (i.e. no indication as to which areas will be increasingly overflown, and which new communities will be adversely impacted by aircraft noise for the very first time). The DfT has confirmed that a full range of flight path scenarios must be considered at some stage; yet has opted not to reveal these before MPs are asked to vote on the NPS. The likely 51dBA LAeq contour and noise events at over the N>65dBLAmax contour have not been applied in respect of Heathrow’s noise footprint in the NPS, though the number of people likely to be affected is probably immense. The DfT is not applying its own policy, which is obfuscating the full impact of Heathrow expansion.
GOVERNMENT IGNORING ITS OWN POLICY ON AIRCRAFT NOISE
13.1.2017 (No 3rd Runway Coalition press release)
- The Government’s Airports National Policy Statement Ignores Its Own Policy On Measuring Noise and CAA Advice On How To Assess The Number Of People Impacted
The No Third Runway Coalition (1) today called for a pause in the process of considering the Government’s Airports National Policy Statement (NPS), to ensure that the full noise impacts of the proposed expansion of Heathrow are properly evaluated.
Although it is not possible to assess the negative consequences of a third runway without clear information as to the design of the accompanying flight paths, no such information has been presented in the Department for Transport’s documents. (i.e. no indication as to which areas will be increasingly overflown, and which new communities will be adversely impacted by aircraft noise for the very first time),
Freedom of Information requests obtained by the Teddington Action Group – a resident-led group who are members of the No 3rd Runway Coalition – have now revealed that the impact of flight paths is regarded as a risk area by the CAA, and that the flight path principles considered by the Airports Commission (and now included in the DfT’s NPS) are no longer supported by the wider aviation industry (2).
The revised NPS assumes only one flight path principle (known as “Minimise Total” (2)), which relies on the maximum concentration of flight paths, thereby mathematically minimising the number of people who can be assumed to be adversely impacted (3). With overflown communities unlikely to accept the adoption of this flight path principle (which – when adopted in other countries – has resulted in legal action and widespread community protests) (4), its presentation – at this stage – can only mislead decision makers as to the actual numbers who are likely to be adversely impacted.
Notably, the DfT has confirmed that a full range of flight path scenarios must be considered at some stage; yet has opted not to reveal these before parliamentarians are asked to vote on the NPS (5).
Furthermore, and despite adopting a policy of supplementary measures to assess noise impacts, in respect of airspace changes – including lower average noise thresholds of 51db (51dBA LAeq) and the assessment of individual noise events at over 65db the (N>65dBLAmax) (6) – they have not been applied in respect of Heathrow’s noise footprint in the NPS. Through this failure to apply its own policy, to what is likely to be the most significant aviation airspace change in the UK’s history, there can only be one consequence: the obfuscation of the full impact of Heathrow expansion.
Paul McGuinness, Chair of the No 3rd Runway Coalition said:
“It is now clear not just that the government has masked the true number of people who will be adversely impacted by an expanded Heathrow, but that they’ve ignored industry advice, and even failed to apply their own noise measuring policy, to pull it off”.
“This is a story of inappropriate and incomplete metrics, the abject failure to provide flight path details, and unrealistic assumptions – all to significantly downplay noise impacts, before parliament is asked to commit itself on the matter. This is simply not good enough. The NPS process should be paused until proper information is available, so that parliamentarians can at least make a judgement based on all of the facts.”
Notes (if pictures of emails are not showing under notes 2, 5 and 6, please get in touch):
(1). Members of the No 3rd Runway Coalition include:
Hammersmith & Fulham, Hillingdon, Richmond, Wandsworth, Windsor and Maidenhead Councils, Members of Parliament, over a dozen residents groups from across London, and several environmental organisations.
(2) The CAA’s FOI response (Appendix 1 Email 21 September 2017) confirms that for the purposes of the updated NPS, it was originally instructed by the DfT to evaluate the three flight path scenarios used by the Airports Commission (“Minimise Total”, “Minimise Newly Affected’ and ‘Maximise Respite’) but using the revised flight number forecasts issued as part of the revised NPS. However, the NPS, AOS and Noise Appendix only consider one scenario; Minimise Total number of people affected.
The Civil Aviation Authority (CAA)’s response to Teddington Action Group’s (TAG) Freedom of Information (FoI) request dated 22 December 2017 https://www.whatdotheyknow.com/request/aviation_policy_framework_metric_2?nocache=incoming-1088383#incoming-1088383
(3) Acknowledging that highly concentrated flight paths (which the “Minimise Total” option in the NPS entails) will NOT be acceptable over a densely populated area such as Heathrow’s hinterland, both the Heathrow and the DfT confirmed at the Heathrow Community Noise Forum on 22 November 2017 that they will consider a full range of scenarios in relation to flight paths, which will not be restricted to “Minimise Total”. So, Parliament is being asked to make a decision of huge impact on an evidence base the aviation industry does not support.
(4) UK Parliamentary Office of Science and Technology’s publication, ‘Aircraft Noise’ (2003), quotes from the Australian Senate Select Committee report on the third runway at Sydney, which concluded that the expansion “scarred a city” and “irretrievably complicated the future of airport development in Australia” as well as being an “environmental and social tragedy”. It also stated that the policy of concentrating noise pollution in one area was “a form of discrimination”.
In addition, the Australian Select Committee ‘found that Sydney residents felt they had been misled by the use of average noise contours’. It also stated ‘once noise reached a level high enough to be intrusive, the level of noise beyond would be irrelevant. This relates to the relative importance of the frequency of noise events against the loudness of individual events in determining annoyance’.
(5) The CAA’s FOI response confirms that for the purposes of the updated NPS, it was originally instructed by the DfT to evaluate the three flight path scenarios used by the Airports Commission. However, the NPS only considers one scenario: “Minimise Total number of people affected”.
(6) Within the Government’s response to the January – March 2017 consultation on the Design and Use of UK Airspace, in addition to lowering the average metric threshold to 54dBA LAeq and setting a new 51dBA LAeq level for lowest observable adverse effects level (LOAEL), there is a commitment to use supplementary metrics when considering all major airspace changes. These include numbers of individual noise events over 65dBLAmax and consideration of impact on an easterly and westerly mode only basis.
However, N>65 dBLAmax, 51dBA LAeq contour maps and single mode analysis are missing entirely from the NPS, AoS and Noise Appendix. Whether by accident or design, the failure to include measures now adopted by the Government in considering all major airspace changes, is instrumental in hiding the full extent of the impact of Heathrow expansion finally becoming clear.
It is notable that the FOI response reveals that the CAA advised the DfT that it should not produce 51dBLAeq noise contours as these had never been published before; advice the DfT accepted. However, this hides the fact that until flight paths are defined those potentially affected at the lowest observable adverse effect level (LOAEL) could be half of London’s population.
For more information:
Rob Barnstone: 07806 947050, Robert.firstname.lastname@example.org
Coordinator | No 3rd Runway Coalition