ࡱ> 7 8bjbjUU .7|7|6l%%%8*&>&tT&&&&&&&&mToToToToToToT$V XxT&&&&&Tv5&&Tv5v5v5&R&&mTv5&mTv5v5h=R1T&& k %* R1T<T0TR:RY5dRY1Tv5Night Flying Restrictions at Heathrow, Gatwick and Stansted: Stage 1 of Consultation on Restrictions to apply from 30 October 2005. Revised Submission by West London Friend of the Earth Introduction 1.1 West London Friends of the Earth (FOE) is a network of local groups covering the borough of Hounslow, Hillingdon, Harrow, Ealing, Brent, Kingston, Hammersmith & Fulham, Kensington & Chelsea and Westminster. 1.2 This response covers issues which are common to significant parts if not all of the area covered by the network. Local groups may also submit responses which deal with particular issues or locations. 1.3 Although the immediate airport of concern for west London is Heathrow, it is a key and consistent feature of our policies that we are not nimby. Our response therefore does not just call for miminal night noise at Heathrow without taking account of wider issues. While particular cases and examples relate to Heathrow, the great majority of points relate the 3 London airports and to many other airports in the UK. 1.4 We do not feel that the questions posed (summarised in chapter 9) provide the most useful framework for responding. Our response is therefore arranged into subject order. However, brief answers are given to the questions, which mainly refer back to the sections of this response. 1.5 Contents: 2 Summary 3 Scope of the consultation 4 Period of the review 5 A ban on night flights 6 Context for evaluating options 7 Definition of night 8 The quota count system 9 Movements limits 10 WHO noise standards 11 Noise contours 12 Actual v certificated noise 13 The economy 14 Polluter Pays 15 General points on consultation 16 Answers to questions App 1 Critique of London Chamber report 2 Summary 2.1 The scope of the consultation is 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. 2.2 The consultation does not give a full range of options for comment, for example a ban on night flights. 2.3 We do not agree that the period for the review should necessarily be 6 years. The period is an important issue and it ought to be part of the consultation. 2.4 We do not accept the implication that the movements and noise quota should necessarily be constant throughout the review period, particularly if that period is longer than about 3 years. 2.5 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. We believe that the information provide fails to meet the requirements of Directive 20002/30/EC. 2.6 The night period should be defined to be at least 8 hours, not the present 6 hours. 2.7 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). 2.8 Recognising that an immediate ban would not be practicable, there should be a schedule for progressively tightening the limits. That is, not allow the same level for a 6-year period as proposed in the consultation document. 2.9 The regime should continue to be based on both a quota count' and a movements limit. 2.10 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. 2.11 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 quota count was unchanged. For this reason we strongly oppose the quota counts as currently defined. 2.12 It is important to retain a movement limit. The government signalled its desire to get rid of the movement limit in the White Paper, yet astonishingly, the issue is barely mentioned in this consultation. This omission of such an important and controversial issue calls into question the value of the consultation and the good faith of those who produced it. 2.13 Evaluations, baselines and limits should be based on the latest research and recommendations, especially the World Heath Organisation (WHO). 2.14 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. 2.15 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. We do not accept that this is disallowed by an EU Directive and we believe it is a legitimate matter for consultation. 2.16 We are very concerned that the government is hiding behind the EU directive because it knows that if actual noise measurements were to be used, the noise around Heathrow would be far worse than is currently admitted. We do not approve of such fiddles. 2.17 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. 2.18 Leqs and noise contours have limited use in assessing night noise and night flights regimes. People can be woken up by a single noisy plane, irrespective of averages such as leqs. 2.19 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. 2.20 If economic benefits are to be used as a justification for continuing with night flights, then the disbenefits, especially the external cost of noise, must be assessed and subtracted from the benefits. 2.21 Without prejudice to a ban or to any restrictions (movements and quota count), 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. 3 Scope of the consultation 3.1 We consider the scope of the consultation is far too narrow. It only addresses night flying restrictions at Heathrow, Gatwick and Stansted. Night flights are a major issue at many other airports around the country. Even in places where it is not yet a significant issue, night flights may well become so. This is due to government policy, stated in the White Paper, to support a massive increase in civil aviation up to 2030. The consultation should give the opportunity of communities in the vicinity of all airports to give their view on night flights near them. 3.2 Even in the limited context of regulation at Heathrow, Gatwick and Stansted, consideration needs to be given the whole system. Limits on the numbers of night flights at the 3 main airports can clearly affect the number of night flights at other airports. For example if there were demand for night flights at one or more of the 3 airports that cannot be met due to limits, it is likely they will be diverted to other airports in the SE and perhaps beyond. This is particularly the case for freight. 3.3 The scope is also too small in terms of the range of options presented. The thrust of the document is in terms of keeping or altering somewhat noise quota, night period, classification of aircraft, etc. There is no presentation of more radical or wide-ranging options, such as banning night flights or imposing stringent noise-related charges. The government may not be currently in favour of such options, but for the consultation to be open and effective, real options need to presented for comment. 3.4 The conclusion appear biased towards increasing, or at the very least maintaining, the number of night flights. The shortcomings need to addressed, otherwise public cynicism about the whole process can only increase, along with further loss of trust in the government. 4 Period of the Review 4.1 The consultation announces that the next regime should apply for 6 years until the end of the summer period 2011. The length of the period is an important issue and we are concerned that the government seems to have made up its mind. We consider that the government should have made this issue part of the consultation. 4.2 We understand that the government does not want frequent reviews which adds costs and administrative burden. The public and organisations would also prefer not to spend time on frequent consultations. We imagine the industry would like to have certainty over a reasonable period so they can plan properly. 4.3 The best period for the regime depends on the regime itself. If the period is short, it is more acceptable to have a movements and a quota limit near the present ones. But if the period is longer, this is less satisfactory. As we explain later, we believe that there should be at least a longer-term aim to reduce noise nuisance. If the next regime lasts until late 2011, and, say, the current limits are re-applied, 7 years will be wasted when they should have been used to reduce noise. 4.4 We suggest that the best way over the problem is to fix a reasonable period for the regime, eg 6 years, but not have quotas that constant over the period. The target should be a ban or at the very least meeting in full the WHO guidelines and the next 6 years should used to move towards that target. A quota reducing year on year would mean that progress would be made without the need for frequent reviews. If this principle is accepted we would agree to a 6 year period or perhaps longer. But if the government insists that the quotas remain constant over the period, we believe that the review period needs to be no longer than 3 years. 4.5 Whatever period is chosen, the government should formally retain the option to review the regime sooner if new information comes to light on the impacts of night flights. If, for example, the governments current study day were to report that disturbance was in fact significantly greater than hitherto assumed, it would not be acceptable to defer acting on this information until 2011. 5 A Ban On Night Flights 5.1 West London FOE considers that there should be a ban on night fights at Heathrow. The impact on the local population is severe and we do not consider they can be justified by claims of economic benefits. It is clear that any economic benefits from night flights must be minuscule compared with the benefits of day flights; there are only about 14 night flights at Heathrow compared with over 1000 during the day. But the disturbance and misery caused by the noise of night flights is far from miniscule compared with the disturbance from day flights. It is out of all proportion to the number of flights or any conceivable benefits. 5.2 We also consider there should be a ban at Gatwick and Stansted and at other airports in the country. There is no point in a nimby approach whereby even if local communities succeed in stopping flights at one airport, the flights are just diverted to another, disturbing that community. Nor do we wish to see a situation whereby the airlines play off one community against another and one council against another. Night flights should be recognised as generally unacceptable, being the exception, not the rule. 5.3 Banning night flights at all airports will give assurance to local communities and will give clarity and a level playing field to the airlines. It will prevent wasteful competition and will stop phoney competition arguments and economic distortions. It will instead allow all parties to concentrate on simultaneously achieving economic performance and social/environmental protection, this being the correct interpretation of sustainable development. (For more on economic and competition arguments, see 13 below). 5.4 A total ban is probably not needed as it is only the aircraft that wake people up and/or keep them awake that are of concern. There may be aircraft which are sufficiently quiet to avoid this, such as small propeller aircraft used for postal services. However, there must be some assurance that such aircraft do not disturb, not just lack of firm evidence that they do. That is, the precautionary principle should apply. 5.5 We recognise that there may be emergencies or special circumstances where exemptions from a ban are allowed. But it is important that they are genuine cases. For example, scheduling departure 10 minutes before the commencement of the night period and then having departure delayed into the night period would not be an exceptional case it can be predicted to happen often. There is particular issue at Heathrow. Aircraft are routinely scheduled to depart in the shoulder period before the start of the night period and routinely get delayed into the night period. However, these flights do not count against the night quotas. Since it is known by both the airlines and the airport operators that such delays will happen, there is no other way to describe the situation than a fiddle. If such flights were counted against the quotas, incentives to cheat would be removed. The real emergencies and special cases are infrequent enough to make little difference to the take-up of the quotas and thereby will not interfere with planning and scheduling. 6 Context for evaluating options 6.1 Night flights patently only occur because there is some demand for them. Simply quoting the existing number/noise of flights at Heathrow, Gatwick and Stansted gives insufficient insight into the need or demand for night flights. We need to know what is the unconstrained demand for night flights (ie if there were no restrictions) and how restrictions would affect the numbers, types and distribution (among airports) of flights. 6.2 In order to evaluate the options for night flight restrictions and make an informed judgement, consultees need to be shown the impacts on noise that would result from changes in flight patterns, these in turn resulting from a range of possible restrictions. The assessment in the consultation, document that if restrictions were removed, the noise would get significantly worse (Annex C, p51), is not adequate. 6.3 It is also necessary to know to what extent restrictions on night flights will change the number of flights in the shoulder periods just before or after the night period. This is because the shoulder periods are particularly sensitive as noted they should really be regarded as night. Furthermore, it is not possible to have informed debate about the merits of a 6 and 8 hour night without seeing the difference between them, namely the shoulder periods. 6.4 The consultation paper shows noise contours for both 6 and 8 hour nights. However, the weightings that are applied mean that direct comparison is not possible. We are not saying that the weightings that are defined by the EU do not have a role and should not be used. There should however be additional figures which show unweighted values for the 6 and 8 hour nights and the shoulder periods. 6.5 As important as the overall demand for night flights is the composition of those night flights in terms of the noisiness of the aircraft concerned. We need to know how restrictions on the noise quota is likely to affect both numbers and noisiness of the aircraft. Likewise how restrictions on movements will affect both numbers and noisiness. 6.6 It is necessary to see the changes in night flights and noise over time over a reasonable historical period to assess progress or otherwise. Such information should from the basis of future policy if, for example, the trend over a period has been getting worse, the highest priority may be to restore the situation to the earlier position. The tables in Annex C fail to do this, only giving data for the last couple of years. 6.7 Without such information, it is impossible to assess the effect of any regime. It is not possible to have an informed debate about any balances or compromises when the social/environmental impacts of noise and economic impacts have not been assessed. (Virtually the only argument put forward for the continuation of night flights is the economic one.) Annex 2 of EU Directive 20002/30/EC requires that environmental and economic effects of operational restrictions be assessed. The consultation fails to do that in any meaningful way. 7 Definition of night 7.1 There are two definitions of night used: 11.00pm to 7.00am 8 hours 11.30pm to 6am 6 hours 7.2 We not consider 6 hours is adequate period for night. Most adults need a longer sleeping period than this and children certainly do. Even 8 hours is barely sufficient; while 8 hours sleep is enough, it is unrealistic to expect everyone to go to bed, let alone get to sleep, in synchrony. 7.3 For these reasons, we believe that the night quotas should apply to an 8 hour period or longer. We also believe tha if the night period is extended to 8 hours, this must not be accompanied by a corresponding increase in the quotas from those currently in force for 6 hours. 7.4 If, despite our views, the government decides to retain quotas for a 6 hour night, we consider that there should be separate quotas for the shoulder periods. 7.5 We do not take a view on the precise timing of the night period, eg whether the 8 hour night should be 11pm to 7.00am or 11.30pm to 7.30am. 8 The Quota Count System (QC) 8.1 Each aircraft is assigned a 'quota count' according to how noisy it is (Annex A, Section d). The set of values is not ideal, because there are very few aircraft near the top of the range and therefore there is insufficient discrimination in practice. Furthermore, aircraft that are quieter than a specified noise level are exempt, despite the fact that they can cause annoyance. 8.2 For this reason, there should be a number of new quota counts going down to noise levels that can be shown not to cause appreciable annoyance to even small numbers of people. However, there must be some assurance that such aircraft do not disturb, not just lack of firm evidence that they do. That is, the precautionary principle should apply. 8.3 The government is suggesting that a new band QC/0.25 (84-86.9EPNdB) is introduced. We support the introduction of this band, but point out that this band may not be sufficient. In accordance with 8.2 above below, sufficient new bands must be added such that there is reasonable assurance that any aircraft falling below the lowest band will not cause disturbance. 8.4 There is a fundamental problem with the quota count system. As shown in App B on p45, the quota count is halved for every 3dB reduction in noise band. Because a reduction of 3dB corresponds to a halving of the noise energy, the quota count is proportional to noise energy. However, it is a fundamental feature of noise that loudness (ie how loud it sounds to the human ear), is not proportional to noise energy. The loudness only halves when the noise energy decreases by about 10dB. If the noise energy decreases by 3dB, the loudness decreases by only 1.23 (2 0.3), ie far less than 2. 8.5 This has major implications for the validity of the noise quotas. It means that aircraft with different mixes of noise band whose noise quotas total the same can give rise to quite different levels of overall perceived sound. Only the noise energy is constant whatever the mix. (The comments in 8.4-7 all ignore the fact the use of 3dB bands make all summations and comparisons approximate; however the issue set out here is not affected by this fact.) 8.6 Of particular importance is the fact a few noisier aircraft can be replaced by many quieter ones without changing the overall quota. For example, 100 QC/4 aircraft could be replaced by 200 QC/2 aircraft. However, because the perceived noisiness of a QC/4 is only 1.23 time as great as QC/2, there is a significant increase in perceived noise, 200/1.23 as against 100 or a 63% increase. 8.7 We are extremely concerned about the implications of this. The government understands these noise relationships full well and its proposal to remove the QC/4 band look suspiciously like an attempt to allow more noise, which would happen if the noise quota was kept constant but the movements limit was relaxed. Because we cannot rely on the government not to increase the movements limit and because we are not being invited to comment on it at this stage, we must state our strong opposition to quota count system in respect of the relationship between quota count and noise band. For the system to be valid basis for setting an overall quota, the quota counts should decrease by a factor of about 1.23 for successively lower bands, not a factor of 2. 9 Movements limit (ML) 9.1 There is currently a restriction on the total movements allowed (of non-exempt aircraft) as well as a limit on the total noise expressed in terms of the sum of quota counts for all the flights (Annex A, Section d.). The government is known to be keen to get rid of the movements limit and rely just on the quota count. This issue was hidden away in a paragraph in the White Paper on aviation. 9.2 The continuance or removal of a movements limit is an absolutely critical issue. It should therefore have been highlighted in the consultation and there should have been an explicit question to encourage respondents to give their views. That fact that a massive consultation document (nearly 100 pages or hundreds or Mbytes) barely mentions the issue is nothing short of outrageous. This can only increase the cynicism of the populace and reinforce their mistrust of the government, not just in respect of night flights or Heathrow, but as a whole. 9.3 If the government were contemplating removal of the limit, it should be honest about the effects and should give estimates of the number of flights. (This is a particular instance of the issue raised in 6.) This will people essential information to inform their responses. It is entirely unsatisfactory for people to have to rely on data such as a guess in The Times that night flights might increase 3-fold. 9.4 Removing the movements limit could open the floodgates to many more night flights. The movements limit is an essential part of the night flights regime as we show below the noise quotas alone (of the current form) do not and cannot properly protect people. We feel strongly that a movements limit is needed as well as a quota count. 10 World Health Organisation (WHO) Noise Standards 10.1 The consultation document give the current WHO guideline values for night noise (para 3.10): Inside bedrooms - 30 dB Leq (8 hour) and 45 LAmax, Outside bedrooms (window open) - 45 dB Leq (8 hour) and 60 LAmax. These values relate to conditions producing "no disturbance". They assume 15dB noise attenuation from open windows. 10.2 WHO considers the extent of the community noise problem is large. The consultation document quotes from the WHO: "When all transportation noise is considered, about half of all European Union citizens live in zones that do not ensure acoustical comfort to residents. At night, it is estimated that more than 30% is exposed to equivalent sound pressure levels exceeding 55dBA, which are disturbing to sleep. 10.3 But the consultation document goes on to say The guideline values are very low. It would be very difficult, if not impossible, to achieve them in the short to medium term without draconian measures - but that is not what the WHO proposed. The recommendation was that the Guidelines for Community Noise should be adopted as long term targets for improving human health. This is also consistent with the advice above. The UK Government is committed to take account of this. In respect of aircraft noise at night, the 30 year time horizon of the White Paper, provides a suitable time parameter for "longer term". 10.4 This is a blatant attempt to talk down the WHO noise standards. The statements in the paragraph are code for saying that the government will to all intents and purpose ignore the WHO guidelines for the foreseeable future. We profoundly disagree with both the interpretation of the WHO position and the governments attempts to ignore the guidelines. 10.5 The WHO had said there is a serious problem, it has set down guidelines for noise levels and the UK government has signed up to the WHO conclusions. It should therefore be seeking ways to implement the guidelines, not find excuses not to. 10.6 We do not accept that the WHO mention of longer term target means that the government s0hould ignore the issue in this consultation. It would be an entirely reasonable interpretation of the WHOs position to say that by 2030, the end of the period covered by the White Paper, there should be an objective of achieving the WHO standards. In todays world, 2030 is very much the long term. If the standards are to be achieved by then, a start needs to be made a soon as possible. The current review of night flights would take us over a quarter of the way to 2030 if the review period were to last to 2011 as the government proposes. It is therefore essential that the opportunity to start the move towards meeting the WHO standards which this review affords, is taken. 10.7 We also do not accept governments claim that the WHO supports its stance It would be very difficult, if not impossible, to achieve them in the short to medium term without draconian measures - but that is not what the WHO proposed. The WHO guidelines are about noise in general and do not discuss the merits of night flights bans or other restrictions. They do not say or imply that restrictions on night flights are draconian. This is simply government spin which attempts to show the WHO supports a policy of inaction. 10.8 The government in undertaking a new study of the effects of aircraft noise on sleep. The results of this should be a key factor in determining the night flights regime. (If it isnt, what is the point of the study?) But if the present review lasts until 2011, years will be wasted before the results of the study can be used. 10.9 Whatever figures and studies are used residents should be given the benefit of the doubt. If there is doubt on the impact of night noise, the 'precautionary principle' should apply. That is, if there is reason to believe that people are woken up, action should be taken. We should not have to wait for 100% proof. 10.10 Our position is clear. The WHO guidelines and any later studies should be taken seriously. There should be a commitment to implement the WHO guidelines by 2030, end of the White Paper period, and preferably well before. The current review should be taking at least the first steps to achieving this objective. If our objective of a ban on night flights is achieved, the WHO guidelines are of course met straight away (in respect of aircraft noise). 11 Noise contours (NC) 11.1 Noise contours have their uses, but there is great danger that they are misinterpreted. In particular, it has been claimed by government and industry that people outside a particular contour are not affected by noise. The most notable example is the 57dB contour used by the government to show the area affected by day flights. It is incontrovertible that people well outside this area are affected by noise. 11.2 In respect of night flights, the reality is that one noisy plane can wake you up, irrespective of what the contours show, which is the average noise over the night period, averaged over a year. It would be possible to have contour lines which reflect peak noise instead or as well as averages. But whatever the basis of contours, the night flights regime must be based on the actual effects on real people, not just on contour lines which show averages of averages. 11.3 It is well recognised that use of averages to assess night noise is very questionable due to small number or flights, but also due to uneven distribution. The latter point is particularly so at Heathrow were the noisy planes are concentrated around 4 or 5am. 11.4 The government currently uses data from a discredited study carried out nearly 20 years ago by Dr Ollerhead. This has been consistently used to try and show how little people are affected by night flights. Later and better research, such as the WHO's and the governments current study should be used as the basis for setting standards. 11.5 Notwithstanding these issues about the validity of using noise contours, there are serious shortcoming with the plots in Annex B. 11.6 The evenings and nights are given extra weighting to reflect the greater nuisance (4.4 of the consultation document). This implies that a single weighted 24-hour value (say 60dB) is as annoying as the same daytime unweighted level (60dB). Fig 1 of the consultation document shows contours, averaged over 24 hours, only down to 55dB. But the WHO considers that 50dB is the desirable target for noise during the day, not 55dB (let alone the 57dB the government has used up till now - 4.7). By the same token, the target for the 24 hour period should be 50dB not 55dB. 11.7 By cutting off the contours at 55dB the figure misleads about the area and the population that is affected by aircraft noise. The area enclosed by a 50dB contour will be an estimated 2 times greater than the area enclosed by the 55dB contour. 11.8 Even this is probably an under-estimate of the area really affected for a number of reasons: The WHO standards are for total outdoors noise, not just aircraft, so aircraft noise which itself is below 50dB but which pushes the total level up to over 50dB is still an issue. In an otherwise quiet area, eg away from streets, noise levels of 45dB may be annoying. A seasonal or yearly average can cover up noise levels which are very annoying but only for some days. The most obvious example of this is in parts of West London such as Ealing which are affected only by easterly take-offs. On the days when this occurs, typically sunny summer days, the noise can be most distressing. But because these days are averaged in with the larger number of days when take-offs are westerly, the average is below the value that is said to cause annoyance. For all these reasons the contour map that is presented in Fig 1 seriously misleads as to the area affected by noise. It should go down to 50dB and preferably lower. 11.9 There is a similar issue with the pure night noise contours in Figs 4 and 8. The weighting given to night flights is +10dB. So if the appropriate cut-off for daytime or 24-hour contours is 50dB, the cut-off for unweighted night contours should be 40dB, not the 48dB shown in the maps. A 40dB contour would enclose 3 times the area of the 48dB contour - a very large difference. For these reasons the contour maps that are presented in Figs 4 and 8 seriously mislead as to the area affected by noise. They should go down at least as low as 40dB. 12 Actual versus certificated noise 12.1 The consultation document states .. Article 4.4 of Directive 2002/30/EC and regulation 5(3) of SI No.1742 precludes the use of any system of noise classification other than that based on 'ICAO noise certification data'. It follows that, although the UK (and other Member States) may choose how to use the noise certification data when imposing operating restrictions, it has no discretion to substitute measurements of operational noise as an alternative to the noise certification data. That would have the effect of decoupling the classification of the aircraft concerned from their noise certification data. We are, therefore, not consulting on this issue. 12.2 We recognise that the Directive may make if more difficult or cumbersome to use measured, ie real, noise rather than certificated noise. However we do not believe that the EU regulations prevent use of measured noise as implied in the consultation. There is nothing to stop the UK using actual data to calculate contours, to calculate the real noise levels corresponding to quota counts or to set overall noise objectives, even if within the overall limits, certificated noise is used to allocate quotas. Nor do we believe that the UK government could not, if it were so minded, find a method which in practice took account of actual noise, while not being contrary to the letter of the Directive. 12.3 We suspect that the UK government is hiding behind the Directive because it does not want to use actual noise. The reason why it does not want to use actual noise is not hard to see. At Heathrow many of the aircraft are of types whose actual noise is higher than certificated. This means that the noise climate is worse than would be surmised from the quota counts and certificated noise. It is, to put it bluntly, a fiddle. We do support fiddles and we believe the government should consult on the issue. 13 The Economy 13.1 The reason given for not banning night flights given by the government is the importance of them to the UK economy. In fact no real evidence of this has been produced. The number of night flights is tiny compared with day flights so any economic benefit is likely to be insignificant. There has been no independent study of the benefit of night flights to the UK economy - the only 'studies' are those commissioned by the industry to support their lobbying to keep and possibly increase night flights. 13.2 British Airways (BA) produced an estimate of the economic benefits of night flights that was used for the case at the European Court. BA said that night flights contribute 2.2bn pa to the UK economy and support 9500 jobs. These were produced for lobbying the European Court not to ban night flights at Heathrow. BA's interest is their won financial interest not the same thing at all as the UK economy. 13.3 BA clearly has a vested interest in maintaining and perhaps increasing night flights. It therefore cannot be assumed that the figure for the national economic benefits is objective and unbiased. Indeed, it is obvious that BA would produce a high figure for the UK economy in order to support their case. There was no independent scrutiny or review of the estimates and those who might have been able to show the estimates were erroneous, such as Friends of the Earth, were not shown the calculations. 13.4 As before, the fact that there are jobs and economic activity associated with night flights does not mean that that amount would be lost to the economy. Most would probably just be substituted by day flights. Any economic activity that was lost to flying overall will be diverted to other economic sectors as people and business spend the money they have saved elsewhere. 13.5 For all these no credence should be placed on this or other BA estimates. 13.6 BAA has also quoted figures for the economic benefits of Heathrow and these may be used to infer a benefit for night flights. But again, such estimates are not and cannot be objective and unbiased. BAA clearly will use estimates of national economic benefit for lobbying purposes when its real interest is its own financial benefit not the same thing at all. For these reasons, no credence should be given to BAA estimates. 13.7 The London Chamber of Commerce & Trade (LCC) has also attempted to produce a figure for the economic benefits of night flight. The study is perfunctory to say the least and does not stand up to the slightest scrutiny. It does not in case add anything useful to the debate because it only discusses the benefit of all night flights in the London area and, by implication, the cost of banning all flights at all airports. It does not assess the benefits of night flights at Heathrow, Gatwick or Stansted and hence says nothing about the costs of restrictions or even bans at those airports. Further details are given in App 1. 13.8 Also, as in the BA and BAA case, the chambers interest lies in its members financial interests, not the national economic benefit. It should be noted that two of the biggest member and backers of the chamber are BA and BAA. In these circumstances the chamber can hardly be regarded as unbiased and objective. For all these reasons, no credence should be given to estimates from the London or other chambers of commerce. 13.9 If economic benefits are to be used as a justification for retaining night flights, it is essential that a proper unbiased study is undertaken by an impartial body. The result should be subject to peer review and open to scrutiny by groups such as Friends of the Earth. Instead, the consultation (7.17) specifically invites airlines and other users to include economic information. Reliance by the government on partial studies produced by vested interests in the industry are not a proper basis for deciding public policy. To do so will only increase cynicism and distrust of the government. 13.10 The estimates of the economic benefits in industry submissions are in terms of 'value added' or impacts on GDP. But these are not the only important measures. When public policy is being decided, economic studies are carried out which give valuations to things that affect the public at large, such as time saved, injuries, and deaths as well as more tangible external costs and benefits. These are treated as real and vital economic factors and are used to guide decision-making just as much as impacts on value-add or GDP. In the case of night flights, it is entirely reasonable to put an economic cost on the annoyance, the misery and even the ill-health caused by the flights and the the sleep disturbance they cause. It would be improper to take account of economic benefits of night, yet ignore the economic costs of disturbance. 13.11 While the issue of the economic cost is important is important for day flights, it is much more important for night flights. Whatever the right figures are, it is indisputable that economic benefits of night flights are far less than day flights. The disturbance from night flights is, however, not proportionately less. The ratio of economic benefits to economic cost of night flights is thus far less than for day flights. Importantly, there is no assurance whatever that the ratio is no less than one, ie the economic benefit of night flights exceed the costs. 13.12 The LCC, BA and BAA studies do not show a net or overall economic benefit, even if one accepts their workings and results. (We do not accept them, believing to be hugely over-stated for reasons explained.) For this reason alone, none of the industry bodies have made a convincing case for the economic benefits of night flights. 13.13 Great play is made of competitive effects when night flights (or any other aspect of aviation) are threatened with controls. If this is to be used as reason not to ban night flights, it needs to demonstrated by proper analysis of what the competitive effects would. It is totally unsatisfactory to rely on assertions from the industry, backed up by no real evidence. 13.14 A case in point is the passenger flights that come into Heathrow in the early hours of the morning. It these planes were not allowed to land until the start of the day period, it would make little difference competitively. Passengers coming to Britain from the far east would not chose to go to Frankfurt, Paris or Amsterdam just because they could arrive there a couple of hours earlier, because they would then have to spend far more time getting to the UK. The reason why the flights come in at these unsociable hours is because the airlines and BAA care more about the convenience of airports and passengers in the far east than they care about residents around Heathrow. 13.15 A further significant point is that pressure to constrain or ban night fights is by no means confined to the UK. There are very strong anti-noise lobbies in just those countries that are cited as competitors to the major UK airports. The government should be working with its european partners to achieve more uniform constraints and bans across at least northwest Europe. This would protect UK and EU citizens alike and would remove the problem of potential competitive disadvantage arising from unilateral action. The forthcoming UK presidency of the EU would be an ideal time to give impetus to this process. Stringent controls arising from the current UK review would provide an excellent example and would encourage other concerned countries to act. 14 Polluter Pays (PP) 14.1 It is a principle accepted by the government that a polluter should have to pay for harm done to third parties - the 'Polluter Pays Principle'. This was re-iterated in the White Paper. 14.2 Polluter Pays is part of more general principle, paying the 'external costs'. The advantage of Polluter Pays is that there can be a powerful financial incentive to reduce impacts, in this case night noise. This is irrespective of any limits imposed by regulation. It also can be shown to minimise any adverse economic effects, unlike regulation. The issue of Polluter Pays and the charges that would be applied to night flights as a result are serious omissions from the consultation. 14.3 There is an understandable concern by people about discussing charges on night flights because this might in some way legitimise them and be seen as a way for the industry to get more rather than less night flights. But this is not a valid reason to ignore the issue of charges. We believe that the right to a good night's sleep is a human right and is not negotiable. That is why we want a ban or, failing that, very strict limits. But we recognise that night flights may not be completely banned, certainly not in the short term. At least some disturbance may remain, even if the worst excesses are curbed. 14.4 For these reasons, we believe that noise-related charges should be introduced. The charges need to be high enough to influence behaviour. That is, they should give a real incentive for airlines to use quieter aircraft. In cases where the financial benefit of a night flight is marginal, the charge could lead to business decision to cease or re-schedule the flight. This would give obvious benefits in terms of night noise at insignificant cost. It should be noted that charging the correct external cost is necessary to give the give the optimal economic outcome. 14.5 The charges levied must be sufficient to cover the external cost of noise. To do this there must be proper, validated estimate or the cost. If the full cost is not paid, the Polluter Pays Principle is not satisfied. In a paper Valuing the external costs of aviation, the government estimated the economic costs of noise at only 25m for the UK, the great majority of that being at Heathrow. Observers considered this ludicrously low. Airport Watch estimated the cost using a recent european study and estimated the true cost at about 14 times higher. A major reason for the discrepancy was that the government had assumed that no-one who is exposed to less than 57dB is affected by noise and therefore there is no cost. This assumption was not supported by any other parties or by any of the european studies. It is notable that the government has not used 57dB as a cut-off in this consultation. 14.6 This implementation of a new night flights regime is the ideal time to introduce noise-related charges. The most effective method of addressing the problem of night flights is likely to be a package of measures which include both regulation and economic instruments. 14.7 In terms of reducing noise, the key factor is the nature and scale of charges levied on airlines or airports. But there is also the question of who the monies go to. A widely held view is that compensation should be paid to those affected. We believe that if night flights are to continue, full compensation should be paid to all people affected by them. This would be much more far-reaching than the present schemes, whereby double glazing cost are paid for in just the very noisiest areas. (this is actually mitigation, not compensation) and where donations are made to good causes of their choosing by BA and BAA. 14.8 We do not take a view as to the mechanism for compensation eg whether direct payments to householders, payments to people and organisations, council tax rebates or grants to local authorities. But we do believe that compensation should be realistic and substantial. Residents do not want night noise at all and token compensation might even be regarded as an insult. It should be noted that given the large economic benefits that are claimed for night flights, there should be ample money for generous compensation. 14.9 If compensation is not paid, the money should instead go to government where it could be used to improve public services or cut taxes. 14.10 As stated earlier, our primary aim is to ban night flights or at least reduce them to a level such that there is no significant disturbance. Where we ask for compensation, this is without prejudice to that position. 14.11 Many respondents to the White Paper said that they were not interested in compensation; they simply didn't want the noise. This was an entirely understandable reaction. (There has never been any suggestion that people gave up time and money to oppose noise nuisance and even went to the European court just to get compensation.) However, the government has subverted residents very reasonable position. The White Paper said that people didn't want compensation and therefore none would be given. But it would still give them the noise! This can only be described as a confidence trick. Such tricks must not be repeated if the government wishes to retain any trust. 15 General points about the consultation 15.1 There are a number of concerns about the consultation which have raised in this response. The most important are: Hiding of the governments desire to remove the movements limit 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 15.2 Taking these together, 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, either as supplement to the Stage 1 consultation, or perhaps as a part of an enlarged Stage 2. 15.3 Unless strenuous efforts are made to overcome these shortcoming, public cynicism about the whole process can only increase, along with further loss of trust in the government. 16 Answers to specific questions posed in consultation The consultation asks a number of specific questions, which are summarised in Section 9. Comments follow. References in the answers are to this response. Q1. Are there any other matters that you think we should cover in this consultation in addition to those set out in paragraph 2.4 of this paper? Yes, see 3, 4, 8, 9, 10, 11, 13, 14 above. Q2. Do you have any comments on the assessments described in Annex B of the consultation document? (4.1) Yes, see 14 above. Q3. Do you have any comments on the presentation of the noise contours and other information in Annex C? (see 4.2-4.13) Yes, see 6, 14 above. Q4.(a) Do you have any comments or suggestions for environmental objectives and specific noise abatement objectives for each airport? (6.6) (b) If so, please state for each objective the base case indicator against which it should be assessed. Pending the elimination of all (disturbing) night flights, there should be a progressive reduction of people affected, as measured by both night noise contours and by comprehensive and accurate measures of disturbance. See also 5, 8 above. Q5. Are you content that we should retain the QC system for classifying aircraft? (7.4) This is ok, as long as the night flights regime is underpinned by actual measurements around Heathrow and by the latest research findings on noise and sleep disturbance. Also, it needs to be combined with a movements limit. See 8, 9 above. Q6. Do you have any comments on the proposals to: (a) remove the weight limit for jet aircraft able to qualify as exempt but, at the same time, extend the QC system downwards by a further band to QC/0.25 (84-86.9 EPNdB)? Yes, the weight limit could be removed, but the QC may need extending by more than one band. See 8 above. (b) retain the minus 9EPNdB adjustment for arrivals? We not have a view on this. (c) prohibit QC/4 aircraft from operating between 2330 hours and 0600 hours? (7.10-7.23) Although banning a QC/4 aircraft removes one noisy flight, it is unclear whether this is advantageous if it allow several extra quieter planes to be added within the noise quota. Better research could give an insight into the trade-off between more flights and quieter aircraft. Q7. Do you have any comments on: (a) the value of there being common arrangements at the three airports? (b) retaining the same night quota period at the three airports? (8.1-8.11) We do not have a view on these. Q8.(a) Points relating to density of population and ambient noise seem more germane to issues concerning the size of the night quotas and the number of movements permitted, rather than to the length of the night quota period: do you disagree? Do not disagree. (b) Are you aware of any reason why we should not take account of the comment in the WHO Guidelines that responses to aircraft noise are less likely to be influenced by ambient noise than are some other types of noise? (8.12-8.13) We do not have a view on this. Q9. Do you have any suggestions for further controls on movements during the night quota period if it is extended? (8.14-8.17) Yes, there should be a ban on night flights. See 5 above. Appendix 1 - Critique of London Chamber of Commerce Estimates of the Economic Benefit of Night Flights 1 London Chamber of Commerce and Trade (LCC) note that civil aviation " .. contributing 1.4% of the UK's GDP itself." This is irrelevant to the debate on the economic value of air travel. Air travel does not have a value in its own right. The economic activity and employment are only useful insofar as they contribute to other aims, commercial or social. (This is exactly similar to, say, healthcare. Expenditure and jobs in healthcare are not of value in themselves, despite the fact they 'contribute' more to GDP than air travel. It is only their social and economic benefits of healthcare that are useful.) Therefore any suggestion that the direct contribution of aviation to the economy or employment is an argument for supporting night flights (or any other component of aviation) should be firmly rejected. 2 It should also be noted that if there was less air travel, it does mean that total GDP would be lower because part of the 1.4% currently contributed by air travel would have disappeared. Put simply, if people did not spend so much of their money on air travel, they would spend it on something else. (This has been noted by economists such as Barclay Hanover and Oxford Economic Forecasting). Whatever that something else was, it would take up the resources and jobs otherwise consumed by air travel. It would thus restore GDP to the same level. This confirms the point in 1 above - any suggestion that the direct contribution of aviation to the economy or employment is an argument for supporting night flights (or any other component of aviation) should be firmly rejected. 3 LCC says " .. when balancing environmental and economic issues .." This misses a key point about sustainable development , namely " .. meeting four objectives at the same time, ..social progress .. protection of the environment .. prudent use of natural resources .. and maintenance of high and stable levels of economic growth and employment .." (DEFRA web site 2004). It is emphatically not about balancing economy against environment - which means in practice trading off the environment for the sake of the economy. The whole basis of the LCC report is therefore flawed. 4 It is entirely possible to see how the (claimed) economic benefits of night flights could be reconciled, to a large extent at least, with environmental protection. It would be possible to retain the existing number of night flights, but encourage or require the planes to be among the quietest ones. This could be achieved by regulation (bans noisy aircraft) or economic instruments (penal landing charges for noisy aircraft). This would not affect the economic benefits of night flights since no actual constraint on night flights would have been imposed. The fact that LCC have not even attempted to reconcile economy and environment - ie they have ignored sustainable development - means that their submission should be disregarded. 5 LCC says " London's unique and unrivalled network of international air services would be degraded if night flying was further restricted as it would no longer be seen as a key interchanging hub. This would jeopardise London's position as a leading world city." In the case of Heathrow, this is not a convincing argument. The night flights which so disturb residents are just a handful of passenger flights which come in from the far east around 4 or 5 am. There are no night take-offs (except in special circumstances) so the arguments about interchanging, international competitiveness and suchlike are not valid. Flights at these unsocial times are for the benefit of the far east airports; not Heathrow or the UK economy. We do not offer comments on Gatwick or Stansted. 6 The LCC report discusses the volume of 'express' deliveries that use night flights. However, it is undoubtedly the case that many of these deliveries do not actually need night flights. They use night flights simply because they are there and might as well be used. In many cases there may well be no significant economic cost to using day flights. Without any assessment of what proportion of deliveries really need night flights and what the economic cost of not sending them overnight would be, no credence should be place the LCC case. 7 Without any such analysis, figures such as "express industry carried over 67 million shipments to, from, or within the UK in 2001. Express services transport over 8.5 billion of UK exports annually, accounting for 4.5% of total goods exports" are irrelevant. The LCC report gives statistics such as " Results of a recent CBI survey indicated that 64% of firms consider next-day express delivery services to be very important to meeting their commitments to clients. Approximately 87% of companies require their suppliers to deliver certain shipments to them by express delivery." But this does not mean that all or most of these require night flights. 8 The LCC report claims that 16% of respondents (not firms) said they would have to re-locate if next-day deliveries were not available and that GDP would be 5bn pa lower if express service were not available. But as noted above, availability of express services is not the same thing at all as having night flights. These figures are therefore largely irrelevant. 9 There is another major flaw in the GDP figures. If any component or sector of the economy disappears or is constrained, this does not mean that its entire contribution or its potential for growth must be subtracted from GDP. The reality is that resources are diverted into other economic activity; they don't just lie idle. This inevitably creates jobs in those sectors. These alternative economic activities into which resources have been diverted will, to a very large extent, offset any loss due to constraints on the express delivery. Thus GDP and employment will not be affected anywhere near the extent implied by the figures quoted by LCC. 10 The LCC case for night flights is couched in terms of some totality of night flights with no details of number, type or location. It is obvious that if night flights do in fact have an economic impact, that impact will depend on, among others: the total number of night flights allowed in the London area the distribution of those flight around the SE airports the timing of those flights the nature of those flights (eg passenger/freight, restrictions on weight or noise) 11 Most obvious is total number of flights. It is blindingly obvious that this will dominate any economic impact. 'Continuance of night flights' could mean continuing with the same quota, increasing the quota by some amount, lifting all restrictions, or reducing the quota to a fraction of the present value. A study which purports to quantify the benefits of night flights but which says nothing about the numbers required cannot have much value. 12 The distribution of night flights around airport is also important. There is no indication in the report as to whether, say, a restriction at some level at Heathrow would have an impact if the total demand for night flights in the London area could still be met. Of particular significance is that night flights are unrestricted at all airports in the London area except for 3. For freight in particular, it is not all obvious that a restriction at Heathrow, Gatwick or Stansted would have much impact, as cargo can be flown into a number of other airports and trucked from there. 13 The timing of flights is also important. The most restrictive definition of night flights is just 6 hours - 11.30 pm to 6.00am. It is probably the case that the vast majority of demand for express deliveries and passenger trips which are said to require night flights could in fact be met with flights in the 'shoulder' periods of 11.00 - 11.30 pm or 6.00 to 6.30pm, or of course using 'day' flights ie 6.30am to 11.00pm. 14 Finally, nothing is said about the nature of the flights. The main problem of night flights is the noise of the aircraft when people are trying to sleep (although there may be issues of lorries at night). One could remove most of the objections by simply insisting that only smaller or quieter aircraft were allowed to use the airports at night. There is nothing in the report or in other estimates of costs/benefits to suggest that the economic benefits of night flights would disappear if restrictions were placed on the noisiness of aircraft. The noise quota could apparently be greatly reduced without demonstrable economic impact in the terms used in the report. 15 The report only considers measure such as 'value added' and impacts on GDP. But these are not the only important measures. When public policy is being decided, economic studies are carried out which give valuations to time saved, injuries and deaths as well as more tangible external costs and benefits. These are treated as real and vital economic measures and are used to guide decision-making just as much as impacts on value-add or GDP. In the case of night flights, it is entirely reasonable to put an economic cost on the annoyance, the misery and even the ill-health caused by the flights and the sleep disturbance they cause. It would be quite improper to take account of economic benefits of night, yet ignore the economic costs of disturbance. 16 Whatever the right figures are, it is indisputable that economic benefits of night flights are far less than day flights. The disturbance from night flights is, however, not proportionately less. The ratio of economic benefits to economic cost of night flights is thus far less than for day flights. Importantly, there is no assurance whatever that the ratio is no less than one, ie the economic benefit of night flights exceed the costs. 17 The LCC report and other figures produced by BAA, BAA, OEF and others do not show a net or overall economic benefit (Even if one accepts their workings and results. We do not accept them, believing to be hugely over-stated for reasons explained.) 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