Night flights noise abatement objective consultation
In May we responded to two consultations. The first was on the subject of night flights. The Government were consulting on what their noise abatement objective should be when formulating long term night flights policy from October 2025. A consultation specifically on this is expected later this year.
The draft objective:
Response from Stop Heathrow Expansion
www.stopheathrowexpansion.co.uk
Contact information: info@stopheathrowexpansion.co.uk
For the purpose of the regime to commence in October 2025, we now seek views on using the following night-time noise abatement objective:
Whilst supporting sustainable growth and recognising the importance to the UK of maintaining freight connectivity, to limit and where possible reduce, the adverse effects of aviation noise at night on health and quality of life.
This night-time noise abatement objective would apply to all 3 of the designated airports (Heathrow, Gatwick and Stansted) and would apply to the night period (11:00pm to 7:00am). This objective sits under our national aviation noise policy statement.
HEATHROW
7. To what extent do you agree, or disagree, with our night-time noise abatement objective for Heathrow airport?
Strongly agree
Agree
Neither agree nor disagree
Disagree
Strongly disagree
Don't know
8. Provide a reasoning for your answer.
We strongly disagree with the proposed objective.
We do not believe the objective gives sufficient weight to the disbenefits to public health. It is thus unfair to the many people affected by noise form aircraft noise between 2300 and 0700 around Heathrow.
The proposed objective continues to place the balance very much in the airport and airline operators’ favour. Research demonstrating the negative impacts of noise and disturbed sleep is well-known and must be the leading factor in the objective which is set.
The proposed objective prioritises "sustainable growth", and requires noise only to be "limited", which is defined to mean mitigated and minimised, and "where possible reduced". Given the Government has made clear, for example through its Jet Zero Strategy, that it regards all currently forecast aviation growth as being sustainable, the objective could allow unconstrained growth in night flights that would have significant community impacts.
Given the extremely questionable economic benefits of night flights, we believe that the objective must be balanced in favour of health impacts to those who are impacted by aircraft noise at night.
Evidence shows the economic value of night flights is minimal and, in many cases, negative. The critical question should be how many aircraft need to fly at night and priority should be given to transfer these flights to the daytime period.
Operational issues such as ensuring aircraft are in place for the next day or for flights operating within the daytime period are issues for airlines and should not be allowed to affect the large number of people impacted by night time noise.
Cargo flights at Heathrow are rarely time critical and could take place during the daytime period. This is likely to be much easier to facilitate at Heathrow due to extra available capacity because of reduced demand for business flights both due to the pandemic as well as the advent of technology such as video conferencing. An assessment of the impact of slightly increased cargo volumes during the day as a result of moving night flights to the day should be undertaken. Previous research has indicated that less than 10% of freight is time critical.
9. Would alternative wording be preferable for the night-time noise abatement objective?
Yes
No
Don't know
10. Provide a reasoning for your answer.
11. Provide alternative wording on a night-time noise abatement objective.
The night noise objective should be the following, as proposed by the Aviation Environment Federation:
1) To avoid, prevent or reduce on a prioritised basis the harmful effects of aircraft noise at night.
2) To ensure that services at night are only provided if there is a conclusive economic case for them (having considered all available evidence and taking a precautionary approach in relation to their adverse impacts) including that they are of critical necessity, that they could not be provided at less harmful times of day, and that they could not be satisfied by other means.
3) To ensure that flights at night are priced at levels that incentivise flying at less harmful times and that reflect their full costs to society on all occasions in line with the polluter pays principle.
4) To ensure that total aircraft noise and noise impacts at night are reduced progressively and materially at all times and against clear time phased targets.
5) Under no circumstances shall there be an increase in the number of permitted aircraft movements during the night noise period.