Heathrow's Noise Action Plan Consultation
Here’s our response to Heathrow’s Noise Action Plan Consultation, which we submitted on 17th July.
Heathrow Noise Action Plan Consultation
Response from Stop Heathrow Expansion
17 July 2023
a) Framework for noise management
Rating for the framework for noise management on a scale of 1 to 5
3 - Average
The framework should include a commitment for measurement of noise caused by clusters of aircraft at key points along the flight paths (e.g. joining points for final approach) so that the actual noise that local communities experience is considered rather than the continued reliance on certification numbers which do not reflect the reality on the ground.
Use of alternative noise metrics such as N60 and N65 are presented alongside LAeq contours, which will provide more comprehensive information about the totality of the noise impact caused by aircraft movements.
We would also like to see lower levels of noise modelled and included in the Noise Action Plan such as 40dB Lden during the night time period. This will make clearer the scale of the noise impacts caused by operations at Heathrow for residents in areas around the airport during the most disruptive times when many people are trying to sleep. We recognise that this would go beyond Government policy and the requirements set out under regulations but believe it would help Heathrow in being a better airport to its neighbours.
b) Quieter planes
Please rate our approach to incentivising quieter planes on a scale of 1 to 5 (tick one box).
4 - Below Average
We welcome the establishment of the Fleet Forecasting Forum. The findings from the forum should be made publicly available – and prominently – at the earliest possible opportunity.
We support higher landing charges on noisy aircraft, particularly those operating in the night period. The miserable figure of £81,500 for breaches of noise regulations acts as evidence that the incentive to avoid the fine is insufficient or is not being applied at a high enough level. Any money raised from noise fines should be reinvested into measures to reduce noise or, failing that, reduce the effects of noise.
The World Health Organisation recommends that people should get 8 hours of uninterrupted sleep every night to protect against undue stress, loss of productivity and learning deficiency in children. The health impacts are considerable and include increased stress, hypertension or higher blood pressure, dementia, obesity and increased risk of cancer. Cancer is alleviated by the body receiving sufficient rest to be able to fight cancer-creating cells, but for the population living under Heathrow flight paths, this does not occur. Aircraft and other noise must be managed and controlled to achieve the recommended standards.
The Noise Action Plan fails to acknowledge that even just one late running flight, for instance at 1am, can ruin a night’s sleep for up to millions of people under Heathrow’s flight paths.
The nighttime restrictions are measured from aircraft departing the stand or gate at 11pm or arriving at the stand or gate at 5am. It takes up to 30 minutes for aircraft to taxi to the runway, take off and still be a major noise disturbance over the local population, that is until 11.30pm. There have been many occurrences of aircraft operating until gone midnight just in the period that this consultation has run. It is unacceptable.
Similarly, for morning flight arrivals, aircraft are creating noise disturbance over the local population before 4.30am, before landing and taxiing to their stand or gate by the permitted time.
Therefore, what might be published as a 5.5-hour quiet period each night, is in fact considerably less. This is even before to disruption caused by the permitted number of night flights is taken into account.
c) Quieter procedures
Please rate our new approach to improving our operational procedures on a scale of 1 to 5 (tick one box).
4 - Below Average
The Key Action relating to noise fines is unclear as to why this review needs to take three years. It should be much quicker, and in the short term the fines should at the very least be increasing with the Retail Price Index.
It is all very well reviving the "Auxiliary Power Units (APUs), Ground Power Units (GPUs), Pre-Conditioned Air (PCA)" but pointless, unless strict conditions are added, setting out the time limit within which it needs to be connected to a docked plane – domestic planes at Terminal 501 - 507 can keep their internal jet running for hours after docking, waking up nearby neighbours such as in Longford as jet engine noise rockets across the flat taxiways straight into residents’ homes where people are trying to sleep, and with their windows open in summer.
Heathrow is regularly abusing its curfew permits. Aircraft in the air must be permitted to land, however these aircraft should not be permitted to take-off from their departure airport when it is known that they will NOT arrive and land at Heathrow before 11pm. This is a clear abuse of Heathrow permissions.
Operational preference by Heathrow is taking clear precedence over the health and well-being of the overflown local population trying to achieve necessary sleep, and it MUST BE STOPPED!
It is important that night-time flights are measured by incident, and not by averages over time spans, as this is how most people perceive aircraft noise – by event, rather than as an average disturbance over a night or other period of time.
d) Land use planning and mitigation
Please rate our new Noise Insulation Schemes on a scale of 1 to 5 (tick one box).
4 - Below Average
Heathrow must provide evidence that that they have ensured that each of their workers homes are fully insulated, so day-time flights don't disturb those night workers from getting 8 hours uninterrupted sleep and in line with the Government’s noise objective "where possible reducing the total adverse impacts on health and quality of life from aviation noise.”
If Heathrow seek easterly alternation, communities are going to require sufficient solid earth high mounds between the northern runway and Longford Village (exactly like those protecting Cranford from the hanger engine-test noise).
e) Operating restrictions and voluntary measures
Please rate our new approach to reducing night noise on a scale of 1 to 5 (tick one box).
4 - Below Average
Given that the majority of the fleet operating at Heathrow is already Chapter 14 compliant it would appear that the 2045 deadline for 100% phase out is unambitious. An earlier date would help to provide certainty for airlines and would enable Heathrow to support further stringent levels of noise standards for future aircraft while also providing an opportunity to demonstrate to local residents that they are serious when they profess that they want to be a better neighbour.
As "a global leader in noise management" Heathrow must urgently review its late night departure/arrival regulations. For instance, delaying an A380 till after midnight because of one or a small number of passengers being unfit to travel and having to wait for the police to remove them, or waiting for medical assistance for a passenger feeling unwell, is totally unacceptable.
We believe that if a plane misses its slot after 10pm, then it should not fly that evening.
Having a plane with just with one or two hundred passengers flying in low over London and waking up to a million or more Londoners in the process, because it was delayed in taking off from a short haul destination is unacceptable. Alternative arrangements must be sought for flights that haven knowingly taken off too late to land at Heathrow before 11pm. It is time that local residents’ sleep was prioritised in a way it has not been to date. Achieving this would give meaningful credence to Heathrow becoming a better airport.
f) Working with local communities
Please rate our approach to working with local communities on a scale of 1 to 5 (tick one box).
3 - Average
For this section, we agree with the areas of concern outlined by HACAN in their response:
· On key action 11B Progress report HACAN want to see an annual report detailing all reportable criteria in the NAP.
· We would like clarity on when the annual report will be published.
· The image on page 11 of Annex 4 comparing noise complaints between 2019 and 2021 could give a misleading impression given the lower levels of aircraft movements in 2021.
g) Any other comments
We share the concerns raised by HACAN about the relative lack of awareness of this consultation. It is a fairly brief consultation period of just six weeks. It may have been more beneficial to engage over a longer period, of, say 12 weeks, to ensure greater interest and response.
The structure of the consultation is, we feel, inaccessible to the average member of the public. The response form is structured confusingly, with key actions from different parts of the main consultation document. It would’ve been more straightforward to ask for responses under clear themes rather than referring readers to key actions from different parts of the main document.
It remains unclear how this consultation was presented to communities. There was a distinct lack of promotional activity across social media. The consultation webinars were poorly promoted, with one of them not open to the public (14 June), leaving just one which was (on 15 June). Having spoken to some of our supporters, we can report a lack of awareness which could have been address through a higher budget for promotional activity in the areas which are impacted by issues raised in the consultation.
To ensure that the pledges outlined in this NAP are met, we believe that there should be a public monitor of each Key Action Point, displayed extremely visibly online on Heathrow’s website – not on a page difficult to locate – and communities should be directed to it to ensure they can see when each and every Action Point is being met before 2028.