ࡱ> 7 1bjbjUU .87|7|/l*-*-*-8b-v-c........bbbbbbb$d  gxb.....b=..b===...b=.b=H=:FR_ib.. `&(*-1 `ib4b0c`gz<xgib=Night Flying Restrictions at Heathrow, Gatwick and Stansted: Stage 2 of Consultation on Restrictions to apply from 30 October 2005. Submission by West London Friends 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, many of the 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 A content list follows. Sections 1 to 13 contain comments on a wide range of issues mentioned in the consultation document and issues arising from then. Most of the points are relevant to all 3 airports. Sections 14 to 18 deal more specifically with the proposals and in most cases only cover Heathrow. However, all sections equally form part of the response. 1.6 A summary of our comments is given in section 2. However, for the detailed explanation and the rationale behind these comments, the following sections need to be examined. 1.7 Contents: 1 Introduction 2 Summary 3 Period of the review 4 Scope of the consultation 5 General comments 6 Environmental objectives 7 Definition of night 8 Quota count system 9 Actual v certificated noise 10 WHO noise standards 11 Noise contours 12 The economy 13 Polluter Pays 14 Noise monitors 15 Ban on night flights 16 Ban on QC/8 aircraft 17 Proposed movement and quota controls 18 Noise insulation 19 Other issues 20 General points on consultation 21 Answers to questions 1.8 In this response, references are to the stage 2 consultation document unless otherwise indicated. References of the form 5.2 above or see comment in 7.3 refer to this response. 2 Summary 2.1 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. 2.2 The consultation does not give a full range of options for comment, for example a ban on night flights. 2.3 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. 2.4 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. 2.5 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 better. 2.6 The night period should be defined to be at least 8 hours, not the present 6 hours. Better, there should be separate limits on each period (or on the core night and shoulder periods). 2.7 We do not accept the presumption that if the night period is extended, the limit movements and noise quota should be relaxed. 2.8 We consider that there ought to be a ban on night flights, except for emergencies and for those planes that do not appreciably disturb (in practice only small propeller planes). 2.9 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. 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 noise quota was unchanged. For this reason we strongly oppose the quota counts as currently defined. 2.12 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. 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 significant progress towards achieving the WHO guidelines. 2.15 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 WHOs work, it should say so. 2.16 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. 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 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. 2.19 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. 2.20 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. 2.21 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. 2.22 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. 2.23 We are concerned that the government is desperately trying to find more evidence on the economic benefits or night. 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. 2.24 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. 2.25 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. 3 Scope of the consultation 3.1 We repeat our comment on stage 1 that the consultation is far too narrow and should address airports other than Heathrow, Gatwick and Stansted. See 3.1 of the stage 1 response. 3.2 We repeat our comment that even in the limited context of regulation at Heathrow, Gatwick and Stansted, consideration needs to be given the whole system. See 3.2 of the stage 1 response. 3.3 We repeat our comment that the scope is also too small in terms of the range of options presented. See 3.3 of the stage 1 response and also 15 below. 4 General comments 4.1 We are concerned at the constant reference to balance and fair balance in the consultation, eg 4.1 7th bullet point. This reinforces a stereotypical view that economic progress and environmental protection incompatible and that one has to be sacrificed to protect the other. This is not the case the governments Sustainable Development strategy makes it clear that economic progress and environmental protection have to achieved together, not one at the expense of the other. Nowhere in the consultation document is there any suggestion or discussion of how economic and environmental objectives can be simultaneously achieved; instead there is always an assumption that reducing noise will harm the economy, 4.2 The second stage consultation confirms what we said in the first stage; that the whole process is biased towards increasing the number of flights. There is a corresponding bias which attempts to show that there will not be an increase in noise nuisance when the number of flights is increased. There is an even more extraordinary assertion that the proposals are bearing down on noise when in fact, as we show in 8 below, it allows an increase in noise. Such biased and misleading statements do no credit to ministers or civil servants and can only foster public cynicism about the whole process. This in turn can only lead to further loss of trust in the government. 4.3 We noted in stage 1 a number of shortcomings in the information provided which meant that a range of options could not be properly evaluated: 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. 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. 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. We noted in stage 1 that 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. No further information on these has been provided in stage 2. 4.4 In our stage one response we said Without the foregoing information, it is hard to assess the effect of any regime. It is not possible to have a fully 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 effectively. As no further information on these has been provided in stage 2, we maintain this view. 5 Period of the Review 5.1 As noted in the stage 1 response, we consider it reasonable to fix a period such as 6 years for a review, but not to have quotas or movement limits 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 and/or movements limit reducing year-on-year would mean that progress would be made without the need for frequent reviews. 5.2 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. (4.7 4th objective for Heathrow does not appear to allow for an actual change in limits.) 6 Environmental objectives 6.1 In our view, the proposed objectives (4.7) are weak and unsatisfactory. They manifestly do not bear down on noise. Comments on the 4 objectives in 4.7 for Heathrow follow. 6.2 We agree that one should progressively to encourage the use of quieter aircraft by day and by night. Unfortunately the amount of genuine encouragement is minimal. 6.3 We agree that one should .. avoid allowing the overall noise from aircraft during the night quota period to increase above what was permitted in 2002-03. But this is not good enough. Night noise is already a significant problem and policies should be aimed to reducing the problem. It is interesting to note that when it comes to all sorts of other problem, eg crime, drugs, education standards etc, that the government never takes the line that preventing things getting worse is enough. It wants to make things better. We do not believe that aircraft noise (or environmental protection generally) should be singled out as not needing improvement. 6.4 We agree that one should support the principal daytime noise objective as set out in the White Paper, namely that if a third runway is built, the 57dBA daytime noise contour should not exceed its area in 2002 (127 km2). But again, this is not good enough. Because noise is already a big problem, the objective should be to reduce it. In this particular context it should to reduce the area of the contour year on year. 6.5 We do not disagree with an objective to meet noise-abatement objectives as adopted from time to time. (But see 5.2 above, last sentence.) 6.6 Following on from 6.3-4 above, we agree with the specific objective in 4.17 to limit the 6.5 hour 48 dBA Leq contour (for the winter and summer seasons combined) to 55 km2 by 2011-12., but consider it is totally inadequate. There should be a policy to progressively reduce the area within the 48dB contour. 6.7 We are concerned that the contours are expressed only in terms of areas. Far more meaningful are populations affected. We note this metric has been regularly used in the past by the government itself as well as other parties. We suspect the use of areas alone is an attempt to avoid drawing attention to the extent of the problem. 6.8 We welcome the fact that at least the possibility of contracting the contour area is discussed (4.19). However, the tone of the text suggests that unless the industry gives evidence to the effect that it would have little or no economic or operational benefits, this more stringent objective will not be set. This is wrong approach the more stringent target should be set unless the industry can demonstrate appreciable harm. As noted in 12.15,16 below, the industry has a vested interest in over-stating costs of environmental protection; it is hardly likely to assist the government in setting a more stringent target. 6.9 While a reduced contour area is discussed, the figures in annex C do not appear to show the effect. There is only one contour each for the two night periods at Heathrow, which are presumably the original proposed areas, not the reduced ones. 6.10 While we have commented on the specific contours proposed, it must be emphasised that we do not accept that these levels represent the limit of noise nuisance. See 10, 11 below for comments on this matter. 6.11 We agree with the principle which is implied in 8.10 if not actually stated, namely that it the noise of individual aircraft that is important, rather than some average such as Leq. Thus contours derived by averaging noise are of doubtful value and use of a noise contour based on Leq as the primary specific environmental objective at Heathrow (4.17) is illogical. 6.12 We consider that if contours are to be used, they should be couched in terms of the maximum noise LAmax or the related metric of SEL, rather than Leq. But separate contours in Leq and LAmax terms might be better still. 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 regulations should apply to an 8 hour period or longer. We agree with the implied position in the consultation that the core period of 11.30 to 6 is more sensitive than the rest for the full period of 11 to 7. However, we do not accept that that quotas and movement limits can only be applied to one period or the other. We see no reason why separate limits should not be applied to the core and full periods. Alternatively, separate limits should apply to the core and shoulder periods. (If the limits are chosen accordingly, it does not matter whether the full or the shoulder period is selected as the extra period over which limits are applied.) 7.4 Although having two periods over which limits are enforced is more complex than a single period, we cannot believe that the administrative burden is anything other than infinitesimal compared with those of day-to-day operation of an airport and its aircraft. 7.5 We do not accept the precept of the consultation that if the night period is extended, there should be a massive increase in the allowed movements and quota. We believe local residents should gain an advantage from an increase in the period defined as night. They should not have the potential advantage of a longer night period immediately offset by allowing a big increase in flights and noise over the night period. 7.6 On this basis, we do not agree that a higher noise quota should be permitted if the length defined as night is extended. Nor do we agree that there should be a far less stringent noise contour objective of 92 km2 at 50dB (4.24) as compared with 55km2 at 48dB (4.17). 7.7 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 the 6.5 hour night should be 11.30pm to 7.30am. 7.8 We are concerned that the interests of the airport and passengers are put ahead of residents with the current rules on disregards (6.12). The delayed and exceptional movements should be included in the movement and quota limit. This will give an incentive to airports and airlines to minimise such cases and, more importantly, discourage them from cheating by deliberately scheduling flights very close to the night period. 8 Quota Count system 8.1 The current 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 We therefore welcome the governments proposal to introduce a new QC/0.25 (84-86.9 EPNdB) band. However, this may not be sufficient. In accordance with 8.2 above, 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 of the stage 1 consultation, 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. 8.5 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. 8.6 This has major implications for the validity of the noise quotas. It means that aircraft with different mixes of noise band whose summed quota count total the same can give rise to quite different levels of overall perceived sound. Only the noise energy is constant whatever the mix. (These comments ignore the fact the use of 3dB bands make all summations and comparisons approximate; the issue discussed here is not affected by this fact.) 8.7 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. 8.8 We are well aware that when one wishes to add noise levels, the noise energies, not perceived noise levels, need to be added. Only when the summation of energies is done is it valid to convert to perceived noise or annoyance. (Put another way, one cannot add perceived noise or annoyance values.) However, this summation process is only valid when there are a lot of noise events so close together they tend to overlap, eg aircraft passing every minute or so with perhaps road traffic as well. This is absolutely not the situation with night flights. Here there are relatively few events that are well separated in time. Thus using relative energy levels as the basis for defining quota counts is inappropriate. 8.9 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 the government is proposing to increase rather than decrease the movements limit, we must register 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 a noise quota limit, the quota counts for individual aircraft should decrease by a factor of about 1.23 for successively lower bands, not a factor of 2. 8.10 We do not consider the fact that 80% of consultees said that the quota count system should be retained as particularly relevant. The great majority of respondents could not be expected to know that that perceived noise is not in at all proportion to the quota count (as described in 8.4-8 above) and is therefore a very poor metric. The absence of any mention of this key issue in the consultation smacks strongly of manipulation if one slants the evidence in a consultation, one is more likely to get the desired response. 9 Actual versus certificated noise In our response to stage 1, we challengd the assertion that the government could not use actual data, but only ICAO noise certification data. The court case confirmed that they could (3.12). We note the point made that actual noise levels will in fact be used insofar as noise contours are calibrated by measurement. However the basic calculations are still based on certificated, not the real noise of aircraft. Furthermore, the actual noise limit is in terms of a noise quota, which is based on certificated noise. The contour is not an actual limit; it is just a result the government expects, given the movements and noise quota limits. Our concerns about reliance on certificated noise therefore remain. 10 World Health Organisation (WHO) Noise Standards 10.1 The stage consultation document gave 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 stage 1 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 went 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 was a blatant attempt to talk down the WHO noise standards. The statements in the paragraph were 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 second stage consultation adds no more other than again to emphasise long term (4.7). This reference, placed at the head of the proposed environmental objectives, make it clear that the government intends to ignore WHO guidelines. 10.6 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. The government should therefore be seeking ways to implement the guidelines, not find excuses not to. 10.7 We do not accept that the WHO mention of longer term target means that the government should ignore the issue in this consultation. It would be an entirely reasonable interpretation of the WHOs position to say that by 2030 at the very latest, 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 as 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 which this review affords to start the move towards meeting the WHO standards is taken. 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. (4.7 4th objective for Heathrow does not appear to allow for an actual change in limits.) 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. The proposed limits do not do this. If anything, they go in the opposite direction. Of course, if our objective of a ban on night flights is achieved, the WHO guidelines are 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 can be 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 shortcomings with the plots in Annex C. 11.6 In the EU directive 2002/49/EC evening and night noise are given extra weighting to reflect the greater nuisance (4.4 of the stage 1 consultation document). The weighting given to night noise is 10dB. This implies that a weighted night-time value of, say, 50dB is as annoying as the same daytime unweighted level of 60dB. The WHO considers that 50dB is the desirable target for noise during the day. If one is to use an average noise (the problems with this are explained in 11.2-3), then the desirable target for night noise is 10dB less than day noise, namely 40dB. 11.7 By cutting off the contours at 48dB instead of 40dB, 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 3 times greater than the area enclosed by the 55dB contour and the population correspondingly so. 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 (weighted) but which pushes the total level up to over 50dB is still an issue. 11.9 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 40dB (unweighted) and preferably lower. It should not just show a single cut-off value. There should be contours for all the 5dB bands above the cut-off, as this is more informative end is easy to produce. 12 The Economy 12.1 The reason given for not banning night flights given by the government is the importance of them to the UK economy. No real evidence of this was produced in the first stage consultation and there is very little in the second stage, as we show below. 12.2 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. 12.3 In our stage 1 response we commented on the London Chamber of Commerce Estimates of the Economic Benefit of Night Flights (13.7 and App 1 of the response). Our comments are unchanged. In outline, the chamber had not provided any relevant quantitative evidence. It only gave figures relating to the value of express deliveries which by no means equate to night flights. Far less do they equate to night flights from just 3 London airports or to the value of flying noisier aircraft as opposed to quieter ones. 12.4 The government has presumably felt that the chambers estimates were not of sufficient relevance or validity to be worth putting forward as evidence. It has also not repeated BAs evidence which we mentioned and rebutted in 13.2-3 of our first stage response. Nor has it used BAAs figure (13.6 of our first stage response). We trust that if the government does not feel able to adduce these as evidence in a public consultation, it will not be influenced by them in private. 12.5 It is suggested in Annex E para 46 that there would be a cost of 10m in preventing QC/4 aircraft leaving Heathrow between 21.30 and 22.30. This is highly misleading. The cost of 10m is the cost of delayed flights. But there would be no delay and no cost if airlines chose not to use the very noisy QC/4 aircraft and thus delays were not an issue. The real cost is the cost of using quieter aircraft, assuming that is less. 12.6 Annex E gives some evidence that airlines have presumably given to the DfT. SAS says (Annex E para 85) that it would suffer a potential loss of 20m if it could not depart from Heathrow between 6.30 and 7am. But it notes only that flying later would be of less value. Without quantification of the less value, the 20m figure is meaningless. It should also be noted that a loss or revenue to SAS is not at all the same as a loss of profit. There would be considerable savings in costs to SAS in not running these flights. Finally, whatever the effect on revenue and profit might be on SAS, this does not mean there is an adverse effect on the national economy. 12.7 Similar issues arise from the other estimates. First Choice Airways may be correct in saying the revenue from one aircraft is 18m (Annex E, 85). But there is no evidence that it would actually be withdrawn, nor that no substitution of any kind anywhere was possible. And in any case, 18m in their lost revenue is not lost profit or loss to the economy. Ryanairs loss of efficiency of 20% Annex E, 88) has no use without the precise meaning of loss of efficiency in this context being specified and converted into economic impact. 12.8 Great play is made of competitive effects whenever 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 are likely to be. It is totally unsatisfactory to rely on assertions from the industry, backed up by no real evidence. 12.9 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 choose 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 apparently care more about the convenience of airports and passengers in the far east, where they dont want to takeoffs at night, than they care about residents around Heathrow. 12.10 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. 12.11 Annex E, para 14 says that the contribution of aviation to GDP is about 2%. This is misleading. What it actually should say is that aviation represents about 2% of economic activity, as measured by GDP. The word contribution implies that if this aviation activity were not present, the economy would be 2% smaller. That is not the case. Aviation may well have a contribution to the economy at large, but this is an entirely separate matter from the percentage of GDP that it represents. Sanitary ware, accidents and prisons all contribute to GDP, but this does not mean of itself that they are important or that we need more of them or even the same amount. 12.12 If the volume of aviation were less than 2% of GDP, the resources labour, capital, consumer spending, etc would simply be diverted into other economic activity. This is exactly the same with other economic activity - sanitary ware, accidents, prisons or anything else. Thus, there is no a-priori reason to assume that aviation adds 2% or any other figure to national GDP by virtue of it representing 2% of the economy. 12.13 Annex E also gives a rough estimate of the value of night flights of 700m pa, based on the numbers of passengers on night flights being 10% of all passengers and assuming that the value is proportional to this number. The 10% seems rather high, but this is not the main point. The key point is that the 700m, or any other figure, has very little relevance. It is not the value added to the economy and there is no reason whatever to assume that the economy would be 700m smaller without these flights. 12.14 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 sleep disturbance they cause. It would be improper to take account of economic benefits of night flights, yet ignore the economic costs of disturbance. 12.15 The government clearly accepts there is no real evidence for the economic benefits which are constantly asserted. That is the explanation for its plea for evidence (6.8-10). However, the industry has a vested interest in exaggerating the economic benefits both to itself and to the national economy, since it wants to retain and increase night flights. If new information is forthcoming, it must therefore be subject to proper validation. 12.16 Validation ought to be open to scrutiny by groups such as Friends of the Earth. Better, there should be a proper unbiased study is undertaken by an impartial body into the economic benefits of night flights. Reliance by the government on partial studies produced by vested interests in the industry is not a proper basis for deciding public policy. We note that the government would not dream of accepting, say, FOEs evidence on environmental impacts as a basis for policy without question or validation. So neither should it accept industrys evidence. 12.17 Whatever the economic benefits may be, it is indisputable that the (gross) 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 therefore likely to be far less than for day flights. Importantly, there is no assurance whatever that the ratio is greater than one, ie that the (gross) economic benefit of night flights exceed the costs. 12.18 We notice in Annex E the government is asking for airlines and users to indicate the financial effect on their business. But whatever the result, this is not the issue. In a decision on public policy, the overall economic impact is what matters, not the financial impact on a few parties. So unless the government intends to convert these private financial costs into public economic costs, it should not be asking the question. 12.19 We are disturbed by the plea for further information on the economic impacts of night flights. We note that the government does not seem interested in having more evidence on the adverse impacts which might lead to more stringent controls. It only seems interested in evidence which might enable it to justify less stringent controls. 12.20 Annex E 65 says Although many respondents did advocate a ban either 2330-0600 or over the whole night period, in our view these respondents either under-estimated, or did not sufficiently consider, the economic benefits from these operations. We find this comment both patronising and unjustified. The stage 1 consultation patently failed to give any convincing evidence of the economic benefits of night flights. That being so, the comment is unjustified; it treats respondents with contempt. 12.21 Para 4.9 says that we believe these objectives are consistent with, and proportionate to, the economic benefits (including benefits to passengers) which night flights produce. This is an extraordinary statement since no real evidence of economic benefits has been shown. Without any figure for economic benefits, it is likewise hard to see any rationale for the statement in 4.11, namely We do not believe that objectives requiring the elimination of all disturbance at night would be compatible with a fair balance with economic costs to airport users. 13 Polluter Pays (PP) 13.1 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. 13.2 In 14.2-5 of our stage 1 response we argued why noise-related charges (not fines for noise transgressions) should be introduced as part of a night flights package. No mention is made of this issue in stage 2. We re-iterate our point that the implementation of a new night flights regime is the ideal time to introduce noise-related charges. 13.3 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. See 14.7-11 of our first stage response for more on the issue. 13.4 Stage 2 does mention the Polluter Pays Principle, saying that the industry should fund such mitigation measures as noise insulation (8.3). We welcome that statement. However, Polluter Pays goes beyond the polluter paying for mitigation. It encompasses the polluter paying for all the damage and harm that is caused which remains after any mitigation. In the case of noise from Heathrow, noise insulation only removes a small proportion of the nuisance. It does nothing to address outside noise and it does nothing to help the thousands of people outside the narrowly drawn area where insulation will be provided. The complete absence of mention of these indicates that the government is not properly committed to Polluter Pays. We therefore have to reiterate our comment that this lack of commitment an only increase public cynicism and distrust. 14 Noise monitors We support the principle of having betting noise monitoring which, inter alia, means more noise monitors. However, we do not have the expertise to comment on the proposed locations. 15 A Ban On Night Flights 15.1 In the first stage response West London FOE said there should be a ban on night fights at Heathrow. Nothing that we have seen in the second stage alters that view. The impact on the local population is severe and we do not consider they can be justified by claims of economic benefits. No convincing evidence has been given as to a large the economic cost of banning night flights. 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. See 12 above for further comment on the economic impacts. 15.2 While the economic importance of night flights is very small compared with day flights, the disturbance and misery caused by the noise of night flights is not small compared with the disturbance from day flights. It is out of all proportion to the number of flights or any conceivable benefits. 15.3 As noted in the stage 1 response, 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 a local community succeeds 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. 15.4 As noted in the stage 1 response, 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 arguments, see 12 above). 15.5 As noted in the stage 1 response, 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. 15.6 As noted in the stage 1 response, 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 often happen, there is no other way to describe the situation than as 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. 15.7 We recognise that a ban on night flights would cause considerable disruption if imposed forthwith. We therefore would look to see notice of a ban at some future date. Ideally this would be such that the movement and quota limits for this review could then be set to enable the ban target to be reached by the end of the review period. In the fast moving world of air travel, 7 years is quite a long time. If the ban were set for at later date some time up to 2030 this review should be used to progressively reduce night flights toward the ban. 15.8 We have seen no convincing economic arguments as to why there should not be a ban. Neither, it appears, has the government. See 12 above for economic issues in general and 12.20 in particular. 15.9 It should be noted that our comments on the proposals and the support expressed for certain of the proposals are all without prejudice to our position that night flights should be banned. 16 Ban on QC/8 aircraft The case to ban the nosiest aircraft, QC/8, (4.12-13) is very dubious. Of course the nosiest aircraft cause a disproportionate effect that is why they carry a higher quota count. The object of an overall quota count is to discourage noisier aircraft, but in a more subtle and economically efficient way than arbitrarily banning a particular noise class. Only if an aircraft of a particular noise class had a disproportionate effect even after allowing for its quota count would the argument be valid. In fact, the reverse is true the noisier aircraft have proportionately less effect, taking account of their quota count. See 8.4-11 for explanation of this. The real reason for banning QC/8 aircraft is obvious from the proposed new limits it is to allow more night flights at Heathrow. 17 Proposed movements and quota controls 17.1 The foregoing sections have described in some detail our major concerns. In summary: Night noise is a severe problem and the aim should therefore be to reduce the problem, not merely prevent it getting even worse. The definition of noise quota is such that aircraft with lower quota counts have higher levels of perceived noise in relation to their count than aircraft with a higher quota count. Therefore a trend towards more aircraft with lower noise quota counts but within the same overall noise quota will lead to higher levels of perceived noise and therefore nuisance. The quota system (as currently defined) does not provide protection against an increase in perceived noise or noise nuisance. All it does it provide a limit on noise energy, which is no solace to local residents. Economic benefits of night flights have not been demonstrated in the round. Far less have the benefits of flying over the largest and most vulnerable communities, such as around Heathrow, or of using the more noisy aircraft been shown. Based on these principles, our comments on the proposed limits are as follows. 17.2 We are strongly opposed to any increase in the movements limits. As shown above, an increase in movements is not offset, as far as perceived noise and nuisance is concerned, by maintaining the quota limit. On the contrary, nuisance and disturbance can rise considerably. Only if the present movements limit is retained as well as the quota limit can there be any assurance that noise will not increase. 17.3 The government is known to be keen to get rid of the movements limit and rely just on the noise quota. This issue was hidden away in a paragraph in the White Paper on aviation. The proposal in this consultation is entirely consistent with that aim the movements limit has been raised but the quota limit held steady or lowered. 17.4 Given that night noise is already an appreciable problem we consider that, as an absolute minimum, the movements limit and the quota limit must be retained. To do otherwise means that noise disturbance is likely to increase. But that would be inconsistent with the principle of Sustainable Development (SD). It is pertinent in this context to note that it is not sustainable to sacrifice one aspect of SD environment or social - in order to promote another the economy. 17.5 We note that the noise quota is to be reduced by 1% and 9% in winter and summer respectively at Heathrow. While any reductions are welcome, there is no assurance that this will reduce perceived noise or noise nuisance. The shortcomings of the noise quota definition means that the increase in movements could well more than offset the decrease in noise quota. It would have been possible to perform calculations to show whether this is likely or not, although it would need assumptions to made about the trend towards quieter aircraft. The fact that no attempt been made to do this is suspicious. 17.6 We believe that the government should to use its own expression - bear down on noise. This can best be achieved by maintaining the movements limits and progressively reducing the noise quota. While the government proposes reducing the quota slightly at Heathrow, we believe that residents deserve a substantial improvement by 2011-12. Instead of reducing the quota by about 10%, it should be reduced by 20% at the very least. This should be part of a long-term objective to ban night flights by 2030 at the very latest. 17.7 The government accepts WHO noise targets as a long-term aim. A progressive reduction of noise quota by, say 20% (from current levels) in each 5-year review period, while retaining the movements limit, would ensure that WHO targets were met in a maximum of 25 years. We consider that 25 years is a reasonable interpretation of long term in the context of aviation and environmental regulation. 17.8 As stated in 15 above, we believe there should a ban on night flights, or at least a ban on all aircraft except those that are quiet enough to not cause appreciable disturbance. This being so, the debate should be framed in terms of how rapidly to reduce night flights and when to ban them completely. In this context, the proposal in 17.7 above seems modest. 17.9 We feel obliged to register our strongest objection to the overall package of proposals. Far from gradually eliminating noise nuisance, the thrust of the current proposals is to support an increase. Almost as bad, at least from the point of view of public policy and public trust, is the desperate attempt to conjure up evidence on the economic benefits of night flights. 18 Noise insulation 18.1 Para 8.3 says that the industry should fund noise insulation in keeping with polluter-pays principle. We welcome that statement. However, Polluter Pays goes beyond the polluter paying for mitigation; it encompasses the polluter paying for all the damage and harm that is caused which remains after any mitigation. See 14 above for more on this issue. 18.2 We are not convinced by the complexity argument used for not using a night-noise contour or not adding night noise into the criteria for defining the day noise contours (8.10). We do not think it would be particularly complex or difficult or do so. 18.3 We agree with the principle which is implied in 8.10, if not actually stated, namely that it the noise of individual aircraft that is important, rather than some average such as Leq. However, if this is so, use of a noise contour as the primary specific environmental objective at Heathrow (4.17) is illogical. The environmental objective ought to be couched in terms of the noisiness of individual aircraft. 18.4 Notwithstanding the above issues, we consider that the limit of 90dB SEL is far too high. SEL is generally taken to be about 10dB higher than the corresponding LAmax (the maximum noise as an aircraft passes). The WHO (World Health Organisation) gives a guideline value of 60 LAmax for night. That is, a massive 20dB lower. Even if the WHO is allowing for some margin of error, it obviously believes there can be sleep disturbance well below 80 LAmax . 18.5 The UK government has signed up to the WHOs conclusions. The comment in 8.10 - .. 90dB SEL footprint which appears to us to represent a good indicator of the vicinity in which the probability of sleep disturbance from aircraft noise events becomes significant is therefore odd. In fact it is deeply suspicious. 18.6 We note that the government has tried to distance itself from the WHOs guidelines by emphasising that they are long term targets and therefore, by implication, nothing needs doing to meet them just now. But the line whereby the government is, in effect, disputing the validity of the guideline figures, is another matter. This is done by implication in 8.10 and again, with more detail, in Annex E 61. If the government does not accept the WHOs figures, it should have the honesty to say so. 18.7 As disturbance can and does occur over the whole night period of 11pm to 7am, we consider that the criteria for insulation should cover the whole night period (8.16) Indeed, as children go to bed before 11pm, the criteria ought to extend into at least the evening period. 18.8 Paras 8.17-19 invite comment on the scope of the scheme in terms of the type of buildings and whether the whole building should be insulated. We take the view that the noise insulation should be generous and that residents and occupiers should be given the benefit of the doubt. Thus non-residential building should be included (where occupied at night) and whole houses should be insulated. This is particularly the case since the criteria for any insulation are so stringent (80 LAmax instead of 60). Also, relatively little of the external cost of noise is likely to paid by such a limited scheme. The cost is suggested to be of the order of 50m one-off, but the economic cost of noise, based on a report by CE Deflt, suggests that the cost of noise at British airports is around 500m pa. Of this the great majority is at Heathrow. 19 Other issues 19.1 We are totally opposed to the airport operator being the competent authority outside Gatwick, Stansted and Heathrow (3.6). It means there is no effective protection for the public. Giving an airport operator the right to set the objectives is about as sensible and democratic as allowing criminals to write laws and decide on sentencing! 19.2 The statement that the European Court of Human Rights .. decided that there had been no violation of Article 8 in Annex E 11 is subtly misleading, though not factually incorrect. In fact, the European Court of Human Rights found in favour of the residents; it was only the appeal court that found against. 19.3 Annex E, the Partial Regulatory Impact Assessment (RIA) has some useful information that does not appear in the main text or associated appendices. For example the relationship between proposed limits and the contours in the table following para 104 and the economic items in 85-88. These would seem important enough to be part of the main consultation, to be presented to respondents in their own right. By appearing only in the RIA, it appears as if the government is only presenting evidence to UK citizens because EU regulations require it. 20 General points about the consultation 20.1 There are a number of concerns about the consultation which have raised in this response. The most important are: No explanation of the relationship between noise quotas, quota counts and perceived noise or annoyance No mentioning the governments desire to remove the movements limit (signalled in the White Paper) 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 20.2 Taking these together, it is hard to avoid the conclusion that the consultation is systematically biased towards increasing the number of night flights and doing the minimum to reduce noise and protect the local populace. 20.3 Unless strenuous efforts are made to overcome these shortcomings in the decisions on the night flights regime and the justification for it, public cynicism about the whole process can only increase, along with further loss of trust in the government. 21 Answers to specific questions posed in consultation Q1. Do you have any comments on the proposals for environmental and noise abatement objectives set out in section 4? Yes, they are not nearly strong enough; see section 6 above. Q2. Do you agree that the QC/4 scheduling ban should continue to apply only between 2330 and 0600 as set out in paragraphs 5.32-5.37? No comments. Q3. Do you have any views on the definition of the night period and night quota period? (paragraphs 6.1-6.7) Yes; see section 7 above. Q4. Are you in favour of extending the night quota period if the movements limits and noise quotas were set precisely to accommodate current levels of night flying described in paragraph 6.11? No; see 7.1-7 above. Q5. Are you content to continue with the arrangements for disregarding movements? (paragraph 6.12) No; see 7.8 and 15.6 above. Q6. Do you agree with proposals to remove the rule on movements scheduled after 0630 but arriving before 0600? (paragraph 6.14-6.15) We agree. Q7. Are you content with the carry and overrun arrangements proposed? (paragraphs 7.8-7.18) No comments. Q8. Do you have any comments on the proposed movements limits and noise quotas for Heathrow, Gatwick and Stansted? (paragraphs 7.19-7.52) We have comments for Heathrow. In particular, we are strongly opposed to increasing the movement limit. See section 17 above and also supporting sections, especially 8 and 10. Q9. In relation to a noise insulation scheme, do you have any comments on: Q9a whether or not policy should be implemented through statutory regulations? Yes, it should be statutory, not rely on goodwill of the airport. Q9b whether to use a noise footprint or other criterion? It should use some form of footprint, but not the one proposed. See 18.2-1 above. Q9c if a noise footprint criterion is used, how to define it for each airport? For Heathrow it should me much more widely drawn, recognising WHO guidelines. See 18 above, especially 18.2,4. Q9d whether the scheme should relate to the whole night or the current night quota period? (paragraphs 8.8-8.21) The whole night period; see 18.7 above. l$q$&&)) < <<<Q==={>@QAAAIBBCmCFFoKsKKKSSTT}VV \ \\\ghj#kkkkk.l?ll nUn9o:oYopppppsxux3|L|шԉr|{Ůð^7۲5B*\ph 5CJ\ 0J6] 6]h0JH*hhH*>*H*5\6]CJ Qij  + , Q R a s ~ h`h$a$/0  4 L ` ~  " D ] ^ )*h`hde)*hizwxxy23\]h i !!}"~"##%%&&&&&''{(|()))/)0),,.7$8$H$..*5\5B*\ph:`abuv012MN=>^_/0vwst= 9r =>?WY|}~ <=TU & F 7$8$H$7$8$H$UXYVWWX'(yz{7$8$H$%&RST~_l4_ & F7$8$H$&56dpjWX 9r X5=v+,-./01 9r $a$,1h. A!n"n#n$n%  i8@8 NormalCJ_HaJmH sH tH 2@2 Heading 1$@&5\XBX Heading 4dd@&[$\$5B* OJPJQJ\^Jph3ZbZ Heading 6dd@&[$\$!B* CJOJPJQJ^JaJph3<A@< Default Paragraph Font>U@> Hyperlink57>*B*S*Y(\phff\^\ Normal (Web)dd[$\$!B*CJOJPJQJ^JaJphVV smalltextdd[$\$!B*CJOJPJQJ^JaJph*B"* Body TextCJL02L List Bullet$ & FPP1$ CJKHaJNBN QuotationhhPP]h^h6CJKHaJ&X@Q& Emphasis6]BbB Footnote Text PP CJKHaJ8&@q8 Footnote ReferenceH*@C@ Body Text Indentx^,@, Header  9r , , Footer  9r "W@" Strong5\:P@: Body Text 2$a$ 5CJ\18ij  +,QRas~4L`~ " D ] ^    ) *   de)*hizwxxy23\]hi}~!!"""""##{$|$%%%/%0%((**<+,./11144444z6{6`8a8b8~88293999q<r<>>>>??FAGACCDDEEGGGGGHH2HOHiHjHIIQLRLZM[MOOPPPPzR{R|R}RRRSS$U%UgVhVWWXXZZ+\,\^_aacccd dfff!g#ggghwhxh j!jllnnnnoosstt v v2x3x4xLxMxyy{{||1~2~~~/1TUЄфӅԅLjȈhi 01FGvwQRޮ߮`abuv012MN=>^_/0vwst=>?WY|}~ <=TUXYVWWX'(yz{%&RST~_l4_&56dpjWX5=v+,-.2000000000000000000000000000000000000000000000000 0 0 0 0 0 0 0 0 00 0 0 0 0 00 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 @0 0@0 0 0 0 0 0 0 0 0 0 0 0 0 00%0%0%0%0%0% 0% 0% 0% 0%0%0%0%0%0%004040404040400a80a80a80a80a80a80a80a80a80a80a80a80a80a80a80a80a80a80a80a80a80a80a80a80a8000G0G 0G 0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G00G00G00G0G0G0G0G0G0G0G0G0G 0G 0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0G0@00@000000@0000@0000@00@00@000000@00@000000@0000@0000@0@0@000@00@00@00@000000b0b0b0b0@0202@0202@0202@0202@0202@0202020202000@0@00@0?0?@0?0?0?0?0 0 0 0 000000000000000000000000000000000000000000000000000q0q 0q 0q 0q 0q 0q0q0q0q0q0q0q000000000000000000000000000000000000000000000000000001 .BRPbs=UX103;1;18cghk\f!##$#$%%++j,l,P-Z-33L;N;?? ?#?EFHFFFnGsGGGGGGGGG^P`P}UUWWXX]]bb?dHdddggggggggggHxJxA}J}~~ϊӊΌҌ`cĎzŖ9;ԗ֗"QSõqy02EH[^*-.3ad $792/>jw ,2R_s}~4;LU`g~ D O ^ e  ( * 2   em*1iy'(xy3<]giqM[~!'!7"B""""###|$$%%%!&$&&&( (((**;/]/114444{66999:n?p?`EEGGGGHHjHqHIIRL_LPPPP~RRSS%U,UhVrVXXXXZZ:[i[,\3\__`acd ddff#g,gxhh!j*j2l9llln nnnnooprss'stt vv4x=xMxXxx/yyyz{{{||2~G~~~1;U^Ƅфڄԅ߅ Ȉшit1< ŖGP wR[$iwW bk27NV>F_g 08$wcqt|cnKM =EU^YaW_X` $(3)0&1T_4=%dmkopsfi2333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333333SU` a b  Wh  .\0\__aacccc\](./@67zzpx.2 Mr N Ferriday[C:\My Documents\Heathrow and T5\Noise\Night flights consultation\WLFOE stage 2 response.doc Mr N Ferriday[C:\My Documents\Heathrow and T5\Noise\Night flights consultation\WLFOE stage 2 response.doc Mr N FerridayZC:\WINDOWS\Application Data\Microsoft\Word\AutoRecovery save of WLFOE stage 2 response.asd Mr N Ferriday[C:\My Documents\Heathrow and T5\Noise\Night flights consultation\WLFOE stage 2 response.doc Mr N FerridayZC:\WINDOWS\Application Data\Microsoft\Word\AutoRecovery save of WLFOE stage 2 response.asd Mr N Ferriday[C:\My Documents\Heathrow and T5\Noise\Night flights consultation\WLFOE stage 2 response.doc Mr N Ferriday[C:\My Documents\Heathrow and T5\Noise\Night flights consultation\WLFOE stage 2 response.doc Mr N Ferriday[C:\My Documents\Heathrow and T5\Noise\Night flights consultation\WLFOE stage 2 response.doc Mr N FerridayZC:\WINDOWS\Application Data\Microsoft\Word\AutoRecovery save of WLFOE stage 2 response.asd Mr N Ferriday[C:\My Documents\Heathrow and T5\Noise\Night flights consultation\WLFOE stage 2 response.doc ~v > t]!XSFT6/zML\&x!R3L4hC:QHx>&sUodT>g2, hh^h`OJQJo(h ^`OJQJo(h ^`OJQJo(oh pp^p`OJQJo(h @ @ ^@ `OJQJo(h ^`OJQJo(oh ^`OJQJo(h ^`OJQJo(h ^`OJQJo(oh PP^P`OJQJo(h ^`OJQJo(h ^`OJQJo(oh pp^p`OJQJo(h @ @ ^@ `OJQJo(h ^`OJQJo(oh ^`OJQJo(h ^`OJQJo(h ^`OJQJo(oh PP^P`OJQJo(h ^`OJQJo(h ^`OJQJo(oh pp^p`OJQJo(h @ @ ^@ `OJQJo(h ^`OJQJo(oh ^`OJQJo(h ^`OJQJo(h ^`OJQJo(oh PP^P`OJQJo(h ^`OJQJo(h ^`OJQJo(oh pp^p`OJQJo(h @ @ ^@ `OJQJo(h ^`OJQJo(oh ^`OJQJo(h ^`OJQJo(h ^`OJQJo(oh PP^P`OJQJo(h ^`OJQJo(h ^`OJQJo(oh pp^p`OJQJo(h @ @ ^@ `OJQJo(h ^`OJQJo(oh ^`OJQJo(h ^`OJQJo(h ^`OJQJo(oh PP^P`OJQJo(h ^`OJQJo(h ^`OJQJo(oh pp^p`OJQJo(h @ @ ^@ `OJQJo(h ^`OJQJo(oh ^`OJQJo(h ^`OJQJo(h ^`OJQJo(oh PP^P`OJQJo(h ^`OJQJo(h ^`OJQJo(oh pp^p`OJQJo(h @ @ ^@ `OJQJo(h ^`OJQJo(oh ^`OJQJo(h ^`OJQJo(h ^`OJQJo(oh PP^P`OJQJo(h ^`OJQJo(h ^`OJQJo(oh pp^p`OJQJo(h @ @ ^@ `OJQJo(h ^`OJQJo(oh ^`OJQJo(h ^`OJQJo(h ^`OJQJo(oh PP^P`OJQJo(h ^`OJQJo(h ^`OJQJo(oh pp^p`OJQJo(h @ @ ^@ `OJQJo(h ^`OJQJo(oh ^`OJQJo(h ^`OJQJo(h ^`OJQJo(oh PP^P`OJQJo(h ^`OJQJo(h ^`OJQJo(oh pp^p`OJQJo(h @ @ ^@ `OJQJo(h ^`OJQJo(oh ^`OJQJo(h ^`OJQJo(h ^`OJQJo(oh PP^P`OJQJo(<hh^h`56789:;<>*B*H*CJOJQJS*TXY(o(n sU>gt]R3C:L\&od S6/x>                                                                                           ls~-2@lsdQQ1`@UnknownG:Times New Roman5Symbol3& :ArialA& Trebuchet MSW& ??Arial Unicode MSTahoma?5 :Courier New;Wingdings"qh藦==$j$nn20d` 2Q Headline response (H)Nic Mr N Ferriday Oh+'0 $ @ L X dpxHeadline response (H)HeaNicicicNormalnMr N Ferridaypo28NMicrosoft Word 9.0 @T@2 l@2ɓ@4p$ ՜.+,0 hp|  -lj` Headline response (H) Title  !"#$%&'()*+,-./0123456789:;<=>?@ABCDEFGHIJKLMNOPQRSTUVWXYZ[\]^_`abcdefghijklmnopqrstuvwxyz{|}~Root Entry F1TablegWordDocument.8SummaryInformation(DocumentSummaryInformation8CompObjjObjectPool  FMicrosoft Word Document MSWordDocWord.Document.89q