Heathrow Night Flights Consultation ...
    ... Or Just Con ?

Noisy nights (ack to LB of Hounslow)

The government is working on its proposals for revised night flying restrictions at Heathrow, Gatwick and Stansted'.

The consultation was in 2 stages. The first stage has been completed - see details below.

The government is now dealing with responses to the second stage consultation. The consultation document can be seen on the DfT web site (www.dft.gov.uk/aviation/). The end date for responses was 16th Sep 05.

All our comments on the first stage consultation, which was about the framework and the scope of the night flights regime, were ignored in the second stage document. The second stage consultation proposes a regime that has all the shortcomings we highlighted, but which the government clearly intended all along.

The key proposal is to increase the number of night flights. The movements limit will be increased by about 11% between the present and 2011. But this understates the problem. The airlines currently do not take up the the full quota. This means that the limit for 2011 is in fact 16% higher than the actual current number.

The 'noise quota' will be reduced slightly, but this is no consolation. The noise quota is an artificial construct based on noise energy summed over the night period. The summed noise energy is largely irrelevant as far as sleep disturbance is concerned - it is the number of noisy planes that matters. The noise quota is used misleadingly by the government to try and show that noise nuisance is decreasing when it could, in fact, be increasing. See section 8 of our response (Word document) to the consultation.

Almost as disturbing is the way the government keeps asserting the economic value of night flights and using it as an argument to retain or even increase them. In fact there no real evidence has been given and the government is desperately tying to find some in order to justify its continuation of night flights. See section 12 of our response (Word document) to the consultation.

West London FOE has made a detailed response to this second stage consultation. See our response (Word document; 20 pages). We give below a summary of the points made in the response.

While the government is planning an increase in the number of night flights in the short term, it is also plotting to remove the limit on numbers entirely in the longer term. See how your MPs voted

Summary of West London FOE response

1. The scope of the consultation remains far too narrow. Night flights are an actual or potential issue at airports all around the country, so the consultation should be addressed to all airports and all communities around them.

2. The consultation does not give a full range of options for comment, for example a ban on night flights.

3. While we do not disagree that the period for the review should be 6 years, this should not imply that limits should remain constant (or nearly so). The 6 years is an arbitrary period, during which limits should be progressively reduced towards the longer term aim of eliminating nuisance.

4. The historical information provided is too limited and there is an absence of projections and estimates of the impact of a range of regimes. This means that respondents are unable to make fully informed responses.

5. While we do not disagree with the specific 'environmental objectives' that are stated, they are far from adequate. They are not stringent enough to ensure that the noise climate gets no worse, let alone that it gets better.

6. The night period should be defined to be at least 8 hours, not the present 6½ hours. Better, there should be separate limits on each period (or on the core night and shoulder periods).

7. We do not accept the presumption that if the night period is extended, the limit movements and noise quota should be relaxed.

8. We consider that there ought to be a ban on night flights, expect for emergencies and for those planes that do not appreciably disturb (in practice only small propeller planes).

9. Recognising that an immediate ban would not be practicable, there should be a schedule for progressively tightening the limits. The absolute latest for a ban should be 2030.

10. The quota count classes should be extended downwards with sufficient new bands such that there is reasonable assurance that any aircraft falling below the lowest band will not cause disturbance.

11. The halving of quota count for a reduction of 3dB in the noise band is flawed because reduction of 3dB results in a decrease in perceived noise of about 1.23 and not 2. As a result, the mix of aircraft could be changed such that the total perceived noise was much greater while the overall noise quota was unchanged. For this reason we strongly oppose the quota counts as currently defined.

12. We strongly oppose any increase in the movements limit at Heathrow. With the current definition of quota count, it is likely that an increase in movements will cause an increase in perceived noise and nuisance even if the quota limit reduces somewhat.

13. Evaluations, baselines and limits should be based on the latest research and recommendations, especially the World Heath Organisation (WHO).

14. The consultation says, in effect, that it will ignore WHO guidelines for the foreseeable future. We utterly reject this approach. The government should be planning to achieve the guidelines, especially as they have signed up to them. This review period should be used to make progress towards achieving the WHO guidelines.

15. As well as indicating that it will not act to meet WHO guidelines, the consultation quotes a figure for disturbance (90dB SEL) which, implies that the WHO guidelines are not valid. If the government does not accept the WHO's work, it should say so.

16. The night flight regime and the limits should be backed by measurements of actual noise around Heathrow, not just on theoretical work based on 'certificated' noise of aircraft.

17. The noise contour maps are very misleading because they imply that only those areas within them are affected by night noise. Contours should have been drawn for levels well below the 48 and 50dB cut-offs shown. This would show the far larger areas and populations that are really affected.

18. Leqs and noise contours have very limited use in assessing night noise and night flight regimes. People can be woken up by a single noisy plane, irrespective of averages such as Leqs. The use of a criterion for noise insulation based on the nosiest aircraft (SEL) could be used for other purposes such as environmental objectives.

19. It is clear that the government has no real evidence of the economic benefits. Information on the possible impacts on a small subset of revenue from a couple of airlines cannot be generalised to the impacts on the UK economy.

20. The 'contribution' of aviation to GDP is irrelevant to its overall impact or influence to the economy. Quoting such figure without explaining this major limitation is misleading for consultees.

21. If economic benefits are to be used as a justification for continuing with night flights, there must be a proper independent and validated study to ascertain those benefits. Decisions must not be based on studies by the industry which has a vested interest in showing high figures for national economic benefits.

22. If economic benefits are to be used as a justification for continuing with night flights, then all disbenefits, especially the external cost of noise, must be assessed and subtracted from the benefits.

23. We are concerned that the government is desperately trying to find more evidence on the economic benefits of night flights. This indicates a bias in the consultation; the government has already decided not to bear down on noise (at Heathrow) and is now looking for justification of its decision.

24. The consultation claims that respondents who wanted a longer night period or a ban either " either under-estimated, or did not sufficiently consider, the economic benefits from these operations." This is both patronising and unjustified. Given the manifest failure to demonstrate economic benefits of night flights, the respondents' views are entirely justified.

25. Without prejudice to a ban or to any restrictions (movements and noise quota), additional charges should be levied on night flights. They should be proportional to the noise of the aircraft concerned, in accordance with the 'Polluter Pays Principle'. The charges should be at a level which will give a real incentive to airlines to reduce the number and noisiness of flights and should ensure that the full 'external cost' of noise is paid.

West London Friends of the Earth produced a detailed response. (Word document; 14 pages.)

Detailed study of this consultation has convinced us that the consultation is biased and misleading: " .. it is hard to avoid the conclusion that the consultation is systematically biased towards increasing, or at the very least maintaining, the number of night flights. The government should re-consult on these issues."

Nothing that we have seen in the second stage causes us to change this view. The government has taken virtually no notice of the points that FOE or most other respondents made. The proposal is to allow a slight increase in movements, entirely consistent with our predication.

The key points we made were:

• Hiding of the government's desire to remove the movements limit
• Defining quota counts for individual such that more flights with more perceived noise will show no increase in total quota count
• Insisting on using only certificated data to set the night flights regime, knowing that measurements of actual noise are likely to show a worse noise climate
• Excluding from night quota statistics flights which are scheduled in the day period but which are delayed into the night period
• Attempts to show that WHO noise guidelines are not serious
• Absence of any proper independent analysis to back up assertions about the economic benefits of night flights
• No consideration of 'economic instruments', noise-related charges, polluter pays, etc

This is not just the view of Friends of the Earth. At a public meeting in Ealing Town Hall on 19 Oct 04, Colin Stanbury, officer for the local authorities' noise group, spoke. He explained how the consultation was badly flawed. Three councils, Richmond, Wandsworth and Windsor were so incensed they took the government to court in the form of a 'Judicial Review'.

The case was heard on 14th Dec, but the judge threw it out. This is most unfortunate, not just because it weakens the position of those who try to address aviation impacts by legal means, but because it sends a message that the government can spin and mislead with impunity.

If you do not have a copy of the 2nd stage consultation, you can get one from the web at the DfT web site (www.dft.gov.uk/aviation). (The document with annexes is well over 100 pages and includes maps, so it will take a while to download it all without broadband. The main text can however be readily viewed or downloaded.) A paper copy can be ordered by phoning 020 7944 5796.

The consultation is in two stages. Responses for the first stage finished on 29 Oct 04 - see above or our full response.

See top for comments on the second stage or seperate page for our full response.

But whether you respond or not to these consultations, always remember you have a vote. You could decide to vote in future elections for a party that will ban (or strongly constrain) night flights and, conversely, not vote for ones that won't.

Links

See or download second stage consultation document (www.dft.gov.uk/aviation/)
How your MPs voted
Back to Heathrow introduction
Back to air transport introduction

(Updated Sep 05)