Full response to Night Flights Consultation
Night flight restrictions at Heathrow, Gatwick and Stansted airports beyond 2024 plus national night flight policy
Response from Stop Heathrow Expansion
September 2021
1/ Your:
Name? Justine Bayley
Email? info@stopheathrowexpansion.co.uk
2/ Are you responding:
As an individual?
X On behalf of an organisation?
3/ You are responding as:
A representative of a business or firm?
A representative for a trade body?
A representative of an academic or research organisation?
From a community group? X
Another organisation?
4/ What is the:
The number of people your organisation employs?
The main business or activity of the organisation?
To campaign against expansion at Heathrow Airport, either in the form of runways or any increase in flights beyond the current cap. We also work to reduce both air and noise pollution from Heathrow Airport and related road traffic, as well as to preserve community life and heritage in the villages near Heathrow, and to end the repeated threats and impacts to the area arising from Heathrow operations.
5/ In what region of the United Kingdom is your activity predominantly based?
Evenly spread across the United Kingdom
North East (England)
North West (England)
Yorkshire and The Humber (England)
East Midlands (England)
West Midlands (England)
East of England (England) X
London (England) X
South East (England)
South West (England)
Wales
Scotland
Northern Ireland
Outside the United Kingdom
6/ What airport affects you most?
Aberdeen
Belfast City
Belfast International
Birmingham
Bournemouth
Bristol
Cardiff
Doncaster Sheffield
East Midlands
Edinburgh
Exeter
Gatwick
Glasgow
X Heathrow
Inverness
Leeds Bradford
Liverpool
London City
Luton
Manchester
Newcastle
Newquay
Norwich
Prestwick
Southampton
Southend
Stansted
Other
7/ What are your views on the:
findings of the night flight dispensation review?
proposals for the night flight dispensation review?
The review of night flights dispensations is inadequate. The review found a number of ‘grey areas’ on granting dispensations, particularly those granted by airport operators, which have been abused, to the disbenefit and annoyance of many communities under Heathrow flight paths and those living immediately around Heathrow Airport; the consequences of granting a dispensation – an extra night flight – is discussed in question 58. The lack of accountability of those who grant dispensations is unsatisfactory. The ability to use unexpected but not exceptional circumstances, such as true emergencies, as grounds for dispensation is nothing short of abuse. There is no discussion of fines for airport operators for granting so many dispensations in ‘grey areas.’ That is something which should be introduced at the earliest opportunity.
It is extremely concerning that the Government does not have significant concerns relating to how airports have used their powers to grant dispensations, given the ‘grey areas’ that are highlighted in the review. It is not adequate to simply dismiss any grey areas as not of significant concern as the impacts of any night flight operations are borne by extremely large numbers of people living underneath Heathrow’s flight paths and around the airport.
8/ Should disruption due to local weather qualify for dispensations?
No.
Exceptions should be made in truly exceptional circumstances. Seasonal weather such as snow, ice or strong winds should not be deemed exceptional. Any dispensations that are given for genuinely exceptional weather should be decided by Met Office guidelines not by an airport. Weather dispensations should be granted by the Secretary of State and not by an airport.
9/ Should disruption due to en-route weather qualify for dispensations?
Weather conditions in other countries should not negatively impact communities around an airport in the UK and alternative arrangements and scheduling will need to be made for flights to land in the UK during the daytime period if weather overseas is exceptionally bad.
10/ Should disruption due to foreign airport weather qualify for dispensations?
No.
Our answer to question 9 should also be applied to exceptional weather events at overseas airports.
11/ Should disruption caused by ATC industrial action qualify for dispensations
No.
Industrial action is a matter for airports and the industry; communities around airports and living under night flight paths must not be negatively impacted through greater aircraft noise throughout the NQP because of industrial disputes, especially at airports such as Heathrow which has a relatively high number of industrial disputes. Airport operators should include the possibility of such disputes during operational planning so they should not constitute an exceptional circumstance for which a dispensation should be granted.
12/ Should disruption caused by industrial action by airport staff qualify for dispensations?
No.
Please see our answer to question 11.
13/ Should disruption caused by industrial action by airline staff qualify for dispensations?
No.
Please see our answer to question 11.14/ Should network capacity delays qualify for dispensations?
No.
The consequences to the aviation industry of ineffectively managing capacity issues during the daytime period should not mean the large number of communities around Heathrow and under its flight paths should be subjected to additional aircraft noise during the night period.
This point is of great concern to people in the immediate areas around Heathrow Airport who not only experience additional noise from planes that qualify for dispensations but also the associated ground noise (and light pollution) generated by flights that have been granted a dispensation.
15/ Should delays caused by serious criminal or terrorist activity that affect multiple flights qualify for dispensations?
Yes, but any major incident must be declared by a public authority and not by the airport operator.
16/ Should cumulative delays qualify for dispensations?
No.
Heathrow, prior to COVID-19, was operating at 98% of its flight cap. The small amount of spare capacity available leaves little room for when delays occur. However, due to the impact to communities of the large number of flights that operate during the daytime period, any delays that fall into the NQP must not quality for dispensation. Communities around airports must not experience further disruption from aircraft noise during the NQP.
17/ Should dispensations be permitted for flights delayed to the NQP due to a medical emergency that has passed?
No.
Communities should not be impacted by a delayed flight entering the NQP, however unfortunate the reason, unless it is airborne and there is a technical emergency that requires the aircraft be landed as soon as possible.
18/ Should dispensations be permitted for flights delayed to the NQP due to a police emergency (for example a disruptive passenger) that has passed?
No.
Communities should not be impacted by a delayed flight entering the NQP, regardless of operational issues within the airport.
19/ Should dispensations be permitted for the repositioning of emergency service (including medical transplant) aircraft?
No.
The number of these flights is likely to be very small compared to the total number of night flights and should be accommodated within existing allowances.
20/ Should dispensations on the basis of reducing carbon emissions be permitted?
We find this question difficult to answer. Whilst we support the efforts to reduce emissions, it would come as a disbenefit to communities under (night time) flight paths if flights were permitted to land early, slightly reducing their carbon impact. Equally, flights spending longer in the sky are also disruptive to communities further afield from Heathrow and, therefore, disruptive. Ultimately, schedules should be planned so no dispensations are required for this reason.
21/ Should pre-emptive dispensations be permitted?
No.
Pre-emptive dispensations should not be given. Heathrow should manage their operations so this is not necessary. Current practice granting these dispensations should not continue.
22/ Should dispensations be granted for information technology failures?
No.
Failures of technology are the responsibility of the aviation industry and its results should not be felt by communities around airports, particularly large airport such as Heathrow.
23/ Supply any further views or evidence on the guidance allowing airport operators to grant dispensations you may have?
Airport operators should be required to appear before their local authority and neighbouring local authorities to take questions and explain every permitted dispensation, why it was given and what action is being taken to prevent the need for dispensations on that basis in the future. A Night Noise Reduction Plan should be compulsory. Residents living within the 48dbLaeq (but ideally a 40dB Lnight) night noise contour should, at the very least, be provided with updates on dispensations by the airport operator who should host regular public engagement meetings – not closed, industry-led forums – so they can understand the impacts that operations at night truly have. The airport operators should also aim to reduce requests for dispensations in the future in areas where the airport is responsible, should they still be permitted to grant dispensations. This would improve accountability of the airport to the community, which is currently extremely limited and on night flights is effectively non-existent.
24/ What are your views on government dispensations overall (provide evidence to support your view)?
We do not support the Government granting dispensations in the majority of circumstances. Visits from dignitaries and associated sporting event traffic cannot be justified. If the Government wishes to become more popular in communities overflown by airports as large as Heathrow, it should not permit any dispensations, regardless of the reason. There are plenty of other airports around the UK with a considerably lower noise footprint at night time, where an exceptional dispensation could be granted. Repatriation flights may qualify in truly exception circumstances.
Review by the Government of criteria for any dispensations that continue to be granted should take place frequently, every four to five years as a maximum. This is so when any trends emerge, and especially where grey areas have occurred (as referred to multiple times in Annex E), new guidance can be introduced. Overall, the Government should seek to provide as few dispensations as possible.
25/ What length should the night flight regime beyond 2024 be?
Since Government has already announced a new regime from 2022-2025 this question is effectively irrelevant.
26/ How do you think the length of regime will affect you (provide evidence to support your view)?
A meaningful review every four to five years will increase transparency and accountability, take into account new evidence that may be available and, most importantly, give communities the opportunity to regularly put forward their views.
27/ Do you think that QC is the best system for limiting noise at the designated airports?
No, it is clear from data produced in CAA, ERCD reports 1801 and 1901 that there has been a significant increase in the number of disturbing night-time noise events and that the QC system, despite the introduction of quieter planes, is failing and must be replaced by a more robust system that favours communities rather than the industry.
28/ What do you think are the:
advantages of changing to a new system?
disadvantages of changing to a new system?
It is difficult to say what the advantages or disadvantages of a new system would be
as there appears to be no other currently available system that is superior
The QC classification system was introduced by the government in 1993. To date there has been no alternative system proposed that is both consistent with the government’s legal obligations (to base noise- related operating restrictions on ICAO certification data) and superior in practice to that currently in place (CAA, CAP 1894 – p. 4)
Any new system must only be introduced if it reduces the noise on the ground ensuring distinct improvements for local communities.
29/ Do you have evidence of other noise management regimes being used elsewhere and how they compare with the current system?
We are not aware of any other noise management regimes.
30/ Should we introduce an additional QC category for quieter aircraft in the longer-term?
No.
If such a category were to be introduced, it must be accompanied by appropriate operational regulations, incentives and fines to ensure that aircraft are flown in a manner that causes the least disturbance.
31/ Should the government reintroduce an exempt category?
No, all aircraft produce noise and therefore disturbance to communities.
32/ Please provide evidence to support your position.
We maintain there should be a complete ban on night flights. If there is no complete ban, then every aircraft should be counted in any quota count/movement allowances as set out in WHO (2018) Environmental Noise Guidelines for the European Region https://www.euro.who.int/__data/assets/pdf_file/0008/383921/noise-guidelines- eng.pdf
33/ Do you think we should re-baseline the night quota system in the longer- term?
We do not think this will make a lot of difference in practice, except to make it easier to understand. However, any change must not increase the number of aircraft or the noise at night.
34/ What factors should we consider when anticipating how to best future proof a re-baselined QC system?
Ensure that QC ratings are as accurate as possible.
35/ What costs, if any, would you anticipate in re-baselining the QC system?
We do not know what the costs, if any, might be.
36/ Would you be impacted if the NQP was extended to 23:00 to 07:00?
Yes, in a beneficial way.
37/ Provide evidence to support your view.
Communities would have a better chance of an uninterrupted 8-hour period to sleep. However, instead of just extending the NQP there should be a complete ban on night flights from 23.00-07.00, as set out in WHO (2018) Environmental Noise Guidelines for the European Regionhttps://www.euro.who.int/__data/assets/pdf_file/0008/383921/noise-guidelines- eng.pdf
38/ Do you think night flights in certain hours of the NQP have a greater impact on local communities than other times of the NQP?
No, all hours of the NQP have an impact on local communities as each disturbance is one too many.
39/ Provide evidence to support your view.
Flights at any time during the NQP impact local communities. For instance, someone woken by an aircraft movement at 1.00am has their sleep disturbed as much as that of someone woken by an early morning arrival at 4.30am. It does not matter what hour of the NQP it is, the impact is still a night-time disturbance.
For communities in the immediate vicinity of Heathrow, ground noise is a constant disturbance throughout the night. Ground noise should be taken seriously and should be taken into account in any future night time regime.
There should be a complete ban on night flights from 23.00-07.00 so that communities have an uninterrupted 8-hour period to sleep.
40/ Would a mechanism that disincentivises aircraft movements in periods of the night that are more sensitive for communities impact you (provide evidence to support your view)?
Yes, although communities experience sensitivities in all periods on the night quota (see responses to Q38 and Q39).
41/ Provide evidence to support your position
We contest the idea that some periods of the night may be more sensitive than others for communities; please see our answer to question 39.
Any mechanism that disincentivises aircraft movements in any period of the night would be of benefit to communities and, in the absence of a complete ban on night flights, any such mechanism should be brought forward at the earliest opportunity.
42/ What would be the impact on you if QC4 rated aircraft movements were banned between 23:00 and 07:00 after October 2024?
Banning QC4 rated aircraft movements would benefit all those spared the noise of these flights. There should be a complete ban on operating QC4 rated aircraft once the current regime has ended in October 2022 and should not wait until October 2024. This should be for the full eight-hour period each night (23.00-07.00). The number of QC4 rated aircraft operating from Summer 2015-Summer 2019 during the night-time period are low enough that we believe such a ban would be hugely beneficial to communities whilst having virtually no impact on the industry.
43/ What would be the impact on you if a scheduling ban was placed on QC2 rated aircraft movements between 23:30 and 06:00 after October 2024?
Banning QC2 rated aircraft movements would benefit all those spared the noise of these flights. There should be a complete ban on operating QC2 rated aircraft once the current regime has ended in October 2022. This should be for the full eight-hour period each night (23.00-07.00). Whilst the number of QC2 rated aircraft operating from Summer 2015-Summer 2019 during the night-time period are more than QC4 rated aircraft, the overall total of QC2 rated aircraft operating in comparison to those with a lower QC rating are also low enough that we believe such a ban would be hugely beneficial communities whilst having a minimal impact on the industry.
44/ What would be the impact on you or your business if a scheduling ban was placed on QC2 rated aircraft movements between 23:00 and 07:00 after October 2024
See answer to question 43.
45/ If bans are introduced should the implementation be staged?
No.
46/ Please provide evidence to support your position.
There should be an immediate and complete ban on all night flights once the current regime ends in October 2022.
This should be for the full eight-hour period each night. We believe that such a ban would be hugely beneficial to communities in terms of physical and mental health and quality of life, whilst having minimal or very limited impact on the industry.
If a complete ban on night flights is not imposed, then scheduling bans should be implemented immediately and not staged as there will be plenty of time between the decision being made and the new regime taking effect.
We do not believe bans on particular categories of aircraft should be considered only if aircraft fleet replacements allow. Any new regulations and action should incentivise improvements rather than waiting for them to happen.
47/ In a future regime how should we manage the number of aircraft movements (detailing the airport or airports relevant to your view)?
There should be an immediate and complete ban on all night flights once the current regime ends in October 2022. This should be for the full eight-hour period each night. We believe that such a ban would be hugely beneficial to communities in terms of health, mental health, and quality of life, whilst having minimal or limited impact on the industry.
If night flights are allowed to continue at Heathrow, then these should be limited and targets should be set to reduce the number of aircraft movements within the next regulatory period.
48/ In a future regime how should we manage an airports’ noise allowances (detailing the airport or airports relevant to your view)?
In the absence of an immediate and complete ban on all night flights once the current regime ends in October 2022, the noise allowances at Heathrow must take account of the noise level on the ground. Permanent noise monitors should be placed at more sites further from the airport – up to 20 miles at least – so the full impact of night operations on all communities who experience disturbance can be demonstrated.
49/ Should we remove the movement limit and manage night flights through a QC limit only?
No.
50/ Provide evidence to support your view.
If there is to be no complete ban on night flights, then the QC limits and movement limits should remain in tandem to minimise the disturbance caused by night flights.
A QC limit on its own would not be a completely reliable metric, since differences have been found between ICAO QC certification and the CAA Quota Count validation study at Heathrow Airport - CAP 1869:
“Finally, it should be remembered that the 3 EPNdB-wide bands mean that aircraft within the same QC band can have noticeably different certificated (and measured) noise levels. It is also possible for an aircraft’s measured result to fall entirely above or below a QC band despite being only marginally noisier or quieter than its certificated level (i.e. if its certificated noise level lies at the very top or bottom of the QC band).” (CAP 1869 – page 14)
“Conclusions...
...For the majority of aircraft types monitored, including new aircraft designs such as the Airbus A350 and Boeing 787, the operational arrival and departure noise levels correlated well with the QC classifications. However, large differences between the operational noise levels and the QC classifications were observed for some aircraft types, including some relatively new aircraft designs.” (CAP 1869 – page 22).
Aircraft with a QC0 rating would potentially be able to operate at night time and not be counted, whilst still creating noise disturbance to residents on the ground.
Managing night flights only through a QC limit has the potential to lead to more movements per night and thus an increase in the number of individuals disturbed by noise. Whilst a QC0 aircraft may be “less noisy” than a QC2 aircraft, for people on the ground it is still a noise event which disturbs sleep.
51/ Should we introduce a ring-fencing mechanism to ensure night slots are available for:
No.
52/ Provide evidence to support your view.
There should be a complete ban on night flights, therefore a ring-fencing mechanism should not be necessary.
If there were to be no ban on night flights, any ring-fencing mechanism should only be introduced if it reduces the detrimental impact on communities.
53/ Should an airline be able to use unused allowances later in the season?
No.
54/ If the government decided that unused allowances should be returned to the airport’s pool, what would be the impacts on:
• communities?
There is the potential to impact communities negatively. The unused allowances from the pool could be used by airlines that operate “less noisy” aircraft and could potentially create more movements by lower QC rated aircraft if the QC limit has been reached but the movement limit has not.
To allow an airport to increase traffic from unused allowances will cause more noise impacts, negatively affecting physical and mental health.
airports?
airport users?
airlines?
business in and around airports?
55/ Do you agree or disagree that the current carry-over process benefits you?
Disagree.
56/ Provide evidence to support your view.
The carry-over process does not provide for any regularity for communities on the ground. To carry-over from one season to another has the potential for up to 6-months of uncertainty for communities and an increase in the concentration of movements at night time with no regulation in place to limit the number of flights in the carry-over period.
57/ What changes, if any, would you like to see to the carry-over process and how would this impact you?
The carry-over process should not be allowed to continue for the reasons stated in question 56.
58/ How fair a balance between health and economic objectives do you think our current night flight approach is?
We do not believe the current night flight approach gives sufficient weight to the disbenefits to public health. It is thus unfair to the many people affected.
The current approach by the Government has failed to take account of the strong evidence now available, demonstrating the health impacts of exposure to noise from night flights. That is a significant failure of Government, particularly given the number of people who live under flight paths at designated airports, especially Heathrow, which operate night flights.
The balance appears very much in the airports and airline operators’ favour. The health of residents in areas around airports and under flight paths appears to be of little or no concern to those regulating aircraft movements – despite recent research demonstrating the negative impacts of noise and disturbed sleep.
59/ What are your views on the health impacts of aviation noise at night, including potential impacts on different groups in society (provide evidence to support your view)?
A wealth of evidence exists on the negative impacts on physical and mental health from exposure to aircraft noise at night. A useful summary is provided by the Aviation Environment Federation https://www.aef.org.uk/uploads/AEF_aircraft-noise-and- health_FINAL_Web-1.pdf.
Other evidence looks at impacts on children and adults on exposure to aircraft noise at night, with some of the case studies conducted specifically around Heathrow Airport. Key papers include:
C. Clark, Aircraft Noise Effects on Health, (2015) https://assets.publishing.service.gov.uk/government/uploads/system/uploads/ attachment_data/file/446311/noise-aircraft-noise-effects-on-health.pdf
‘Aircraft noise and self-assessed mental health around a regional urban airport: a population based record linkage study’ D. Wright, K. Newall, A. Maguire, D. O’Reilly, Environmental Health (2015) 17:74
‘Longitudinal effects of aircraft noise exposure on children’s health and cognition: A six-year follow-up of the UK RANCH cohort’
C. Clark, J. Head, S. Stansfeld, Environmental Psychology (2013), 35, 1-9‘The West London Schools Study: the effects of chronic aircraft noise exposure on child health’
M. Haines, S. Stansfeld, S. Brentall, J. Head, M. Jiggins, S. Hygge, Psychological Medicine (2001) 31, 1385-1396‘Night time aircraft noise exposure and children’s cognitive performance’
S. Stansfeld, S. Hygge, C. Clark, T.Alfred, Noise & Health (2010) 12:49, 255- 262We would like to draw particular attention to chapter 3.3 of the World Health Organisation (WHO) Environmental Noise Guidelines for the European Region (2018).
These guidelines strongly recommended reducing noise levels by 5 decibels at night, demonstrating that large numbers of people are affected by lower levels of noise at night. They show that 40dB Lden is the maximum “safe” level of night time aircraft noise; higher levels than this are considered to have an adverse effect on sleep, and a host of other negative health impacts.
The WHO, as well as the other sources referenced above, note that these negative impacts to physical health can occur from exposure levels as low as 33dB Lnight. Conditions include:
Cardiovascular disease
Cognitive impairment
Hearing impairments and tinnitus
Quality of life
Mental wellbeing
High blood pressure (including in children)
Reading skills and comprehension in children
Prevalence of a highly annoyed population
The Government should use more meaningful noise metrics to measure the impact of night flights that better reflect how night time noise is experienced. We support the WHO’s use of Lden and Lnight. See also part of our answer to question 71 which discusses measurement of impact of night time aircraft noise.
Additionally, Stansfeld et al (2010) noted, that:
Night time exposure to aircraft noise was also significantly associated with impairment of recognition memory and performance. Tasks which involve central processing and language comprehension, such as reading, attention and problem solving and memory, appear to be most affected by exposure to noise.
Primary age children attending noise-exposed schools usually live in noise exposed homes. It seemed possible, therefore, that aircraft noise exposure outside school hours, perhaps especially in the early morning or late at night, might also have an impact on children’s learning and school performance.
The effects on performance have been demonstrated in adults, which persist after the noise exposure is over.
Aircraft noise exposure at night, largely in the shoulder hours, might disturb sleep and cause after effects on children’s school performance, the next day.
The reduced number of flights during the pandemic has led to the noise from each individual plane being separately noticed by many residents, rather than being part of a background continuum. Despite the reduction in the number of daytime flights, there still appears to have been a significant number of night flights, and ground noise from the airport has still been significant. The impacts from exposure to aircraft noise therefore may not have reduced.
The Government must consider the very latest evidence on the health impact of night flights. It cannot simply assume that it is balanced out by supposed economic benefits – the physical and mental health of large numbers of people demand this fundamental reassessment.
60/ What are your views on the economic value of night flights, including the potential value on different businesses and aviation sectors (provide evidence to support your view)?
Evidence cited below 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 transferring these flights to the daytime period.
A study by CE Delft which assessed the economic benefits and disbenefits of night flights at Heathrow, found that:
A ban on night flights at Heathrow is likely to be beneficial to the economy as the economic costs of the ban will be outweighed by the savings made by the reduced health costs of the sleep disturbance and stress caused by the noise of the night flights.
CE Delft estimate that night flights sustain 1,330 jobs, but that it is false to assume that 1,330 jobs would be lost in case of a night flight ban. They argue that:
A loss would only occur if all current night time passengers stopped travelling to Heathrow once a night flight ban was introduced. That however is highly unlikely.
In terms of passengers, CE Delft state that the most likely scenario is that a proportion of passengers will continue to use Heathrow, but during the daytime period. Therefore, a night flight ban would bring economic benefits to the overall economy due to a significant decrease in the costs associated with sleep disturbance, as well as a smaller decrease in the costs of air pollution from aircraft and local traffic.
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 could take place during the daytime period. This is likely to be possible at Heathrow as extra capacity is available because of reduced demand for business flights, due both to the pandemic as well as the increased use 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 (CE Delft).
61/ What are your views on changes to aircraft noise at night as result of the COVID-19 pandemic (provide evidence to support your view)?
The pandemic has led to a fall in demand for flights. It is currently unclear as to when, or if, demand at Heathrow may return to pre-pandemic levels. Therefore, in the years immediately ahead, available capacity in the daytime period, particularly in the period immediately prior to and after the NQP applies, should be used to reduce the number of flights operating at within the NQP, which would minimise disruption to the airport’s operations at night. Perhaps airports operators could be incentivised to alter schedules while reduced demand permits (if not in the long term) in order to achieve this and reduce the ongoing disruption to communities from night time noise.
62/ In your opinion what are the advantages or disadvantages that the emergence of new technology will have in relation to night noise from aircraft within the next 10 years (provide evidence to support your view)?
Developments in technology must be used to benefit communities impacted by night flights, rather than being used as an excuse to justify additional night flights or granting more dispensations. However, we believe that night flights should be banned and therefore any improvements in technology – at best likely to be marginal in benefitting residents – are not relevant to our position.
63/ Should we include a reference to night noise when we publish a revised aviation noise objective?
Yes.
64/ What factors relating to night noise should we include if we do introduce a noise reference in our revised aviation noise objective?
We do not support night flights but if they are to be maintained, any wording of a reference to night noise in the aviation noise objective must be clear and unambiguous. It must be accompanied by enforceable powers to ensure that airport operators and airlines cannot misinterpret the statement.
Wording should state the extremely minimal economic, but strongly negative physical and mental health impacts of operating flights between 2300 and 0700 and therefore, were night flights to be maintained, they must meet stricter criteria to justify their impact on the large numbers of people living under airport flight paths and around airports.
65/ Should the government set criteria for airport designation?
Yes.
66/ What do you think are the:
advantages to the government setting criteria for airport designation?
disadvantages to the government setting criteria for airport designation?
For this question we refer to the answer provided by the Aviation Communities Forum, with which we strongly agree:
“The appropriate question is not whether setting criteria for designation has advantages or disadvantages to the government but whether it is necessary to achieve effective regulation of aircraft noise. Current regulation of aircraft noise is weak, disjointed, ineffective and confusing. Multiple bodies have some involvement, but none is accountable. No person or entity has an explicit remit and the authority to achieve a long-term, sustained reduction in aviation noise, and the health impacts it causes, and for promoting, delivering and enforcing individual initiatives in pursuit of that goal. There is a regulatory vacuum.
“Designation offers a solution to those issues if it is accompanied by the development of robust, effective arrangements for the regulation of aircraft noise using the powers the Civil Aviation Act 1982 Act provides. Please see our answer to question 71 for further detail.”
67/ What factors, if any, do you think we should consider when setting criteria for designation?
The critical criteria for us would be to consider the number of people impacted by aircraft noise, as well as the emissions that are generated not only by the aircraft but by the airport’s complete operations.
68/ How should any criteria for designation be agreed?
The Department should develop a draft set of criteria for designation and discuss them informally with stakeholders through its normal engagement channels, before consulting formally on them.
69/ What impact, if any, do you think the designation of an airport have on:
communities?
airports?
airport users?
airlines?
business in and around airports?
See answer to question 66.
70/ What impact, if any, do you think the de-designation of an already designated airport (Heathrow, Gatwick, Stansted) will have on:
communities?
airports?
airport users?
airlines?
• business in and around airports?
See answer to question 66.
71/ Any other comments?
A unique side-effect of night flights in the areas immediately around Heathrow is disturbance from ground noise associated with night flights. This relates to both noise from planes when not airborne as well as associated ground traffic noise from flights operating in the night period. Communities within the London Borough of Hillingdon, such as Harmondsworth and Sipson, located immediately north of the airport and Longford, to the west, are affected by such noise. Anecdotal evidence from many people living in these areas suggest great annoyance at regularly being disturbed between 23.00 and 07.00, and particularly before 06.00. Harlington is also affected by ground noise, but to a greater extent as its road network acts as a more major thoroughfare to other parts of west London. Communities in the London Borough of Hounslow, such as Cranford and Bedfont, are similarly affected.
The noise contours in Annex G do not truly represent the numbers of people impacted by night flights. In the case of Heathrow Airport, significant communities in both South and East London are seemingly unaffected. Despite that, local community groups exist to campaign on this very topic and local politicians receive casework on this issue. The contours do not include communities immediately north of Heathrow Airport which experience noise from ground operations at the airport and associated activities such as ground vehicle movements.
We take this opportunity to note the recent Night Flight Restrictions at Heathrow, Gatwick and Stansted Decision Document July 2021 (p. 24):
Government Response
The government recognises the need to protect communities that are overflown by aircraft at night from the negative impacts of night time airport operations. Aviation noise can negatively impact health in a number of ways including sleep disturbance, increased risk of cardiovascular disease and other health impacts, and can also impact amenity/annoyance levels.
Since the Government recognises the need to protect communities and the regime has been rolled over until 2025, the time from 2022-2025 MUST now be used to carry out extensive research to quantify the impact of aviation night noise on communities.
We agree with the recommendation in Survey of Attitudes (SoNA) 2014: Aircraft Noise and Sleep Disturbance Peer Review that a proper study be undertaken to understand better the relationship between night exposure and the effect on sleep – especially in light of the fact that the data was extrapolated from a wider study into daytime noise and the sample size was not large enough to provide robust evidence. Government should go further and undertake research into the effect on the health and wellbeing of communities from all forms of aviation night noise – not just departing and arriving aircraft.
ENDS.