CHIDDINGSTONE PARISH COUNCIL
/

Clerk to the Council

Mrs Louise Kleinschmidt

2 Bothy Cottages

Threshersfield

Chiddingstone
Kent TN8 7NE
Telephone: 01892-871651
Email:
www.chiddingstone.org

29th January 2014

Night Noise Consultation

Department for Transport Great Minster House (1/26)

33 Horseferry Road

London SW1P 4DR

Dear Sirs

Night Flying Restrictions at Heathrow, Gatwick and Stansted Stage 2 Consultation

The proposals in this consultation amount to do nothing until 2017. If they are implemented it would be represent a failure to deal with the known problems. An opportunity to protect thousands of people who live near Gatwick Airport will have been missed. The consultation paper reads as if the decision to do nothing has already been taken. Chiddingstone Parish Council request the Government to reduce the size of the number and noise quotas at Gatwick so as to ensure that there can be no worsening of the noise climate. This is the second time that setting a new night flight regime has been postponed. A year ago the reason given was the need to wait for the new White Paper. The White Paper has been published. Now the excuse for inaction, that it is necessary to wait for a decision on the location of new runway capacity, is not convincing. There will not be political agreement to implement the recommendation of the Airports Commission. Chiddingstone Parish Council’s stated aim is for no night flights. Nevertheless we submit the following practical suggestions for changes which could be made now.

Reduce the number quota. We believe the quota should match current use. The policy set out in the Aviation Policy Framework White Paper is: ‘to limit, and where possible, reduce the number of people significantly affected by aircraft noise.’

Reduce the noise quota. We believe the quota should match current use. The policy set out in the Aviation Policy Framework White Paper is: ‘to limit, and where possible, reduce the number of people significantly affected by aircraft noise.’ No reduction in quota alleviates the pressure to make aircraft quieter as stated in the first stage consultation document.

Further consultation: The Consultation on the introduction and operation of new flight paths in the absence of public information on the actual routes to be selected would be in conflict with its stated objectives of Collaboration and Transparency. There should be a second consultation after the routes have been selected.

Consultation document questions

Q1: Do you agree with our preliminary view as to the new studies on health effects?

No. We believe the current measures of noise are outdated and there is a requirement to understand the effect of specific noise rather than average noise on health.

Q2: Do you have any further views on the costs and benefits, including health impacts, which we should take into account in our decision?

Yes. We have considerable doubts about the economic benefit of night flights from Gatwick which are virtually all to tourist destinations. But whatever the benefit, there can be no justification for tolerating a situation which is ‘increasingly dangerous’ to public health. The very least that could be done would be to reduce the number and noise quotas to match current use, in order to prevent any worsening of the health risk.

Q3: Do you agree with the proposed environmental objectives?

No. A policy of reducing the number of people affected by noise is welcome if it comes as a result of quieter aircraft. We do not believe it is desirable if it comes as the result of narrower flight paths concentrating the noise on fewer people. That is equally true for night flights. Concentrating the misery may be more damaging to health than spreading it more widely.

The second objective is not relevant at Gatwick.

The third objective, to maintain the current Gatwick quotas unchanged would permit a 25% increase in night noise at Gatwick in summer and a 66% increase in winter. It contradicts the first objective.

We support the fourth objective, ‘to encourage the use of quieter aircraft during the night quota period so as to maintain the historic reduction in noise emitted per aircraft movement during the night quota period’.

Q4: Do you agree that the next regime should last until October 2017?

No. A new regime with reduced quotas should be introduced as soon as possible.

Q5: Do you have any views on the revised dispensations guidance?

No comment.

Q6: Do you agree that we should maintain the existing movement and noise quota limits until October 2017? If not, please set out your preferred options and reasons – this could include the noise and

economic impact of any alternatives.

No. We will campaign harder if we find the disturbance getting worse as a deliberate result of Government policy.

Setting the number and noise quotas to match the current use would adhere to government policy.

It is suggested in the consultation document (paragraph 1.6) that allowing an increase in the number and noise of night flights would allow ‘sustainable growth at Gatwick and Stansted back to pre-recession levels.’ The noise quotas fully used in pre-recession years: in 2007 the summer quota was only 80% used and the winter quota was only 60% used. The quota should match this in order to adhere to the policy.

Q7: Do you have any comments on our forecasts to October 2017?

Why is the Department forecasting an increase in night noise at Gatwick but taking no action to stop it?

Q8: Do you have any views on how the benefits of quieter aircraft can be shared in future between communities living close to the airport and the aviation industry?

Yes, by reducing the Gatwick noise quota now, and continuing to reduce it in future.

The Council supports the retro fitting of vortex generators on all of the A 318/319/320 series of aircraft to eliminate the high pitched whine created on the underside of the wing by the pressure equalisation vents for the fuel tanks. Lufthansa have done this already and all similar aircraft flying into LGW need to make the same modification.

Q9(a): Do you agree with extending the operational ban of QC/8 and QC/16 aircraft to the entire night period (23:00 – 07:00)?

Yes.

Q9(b): Do you agree with our assessment of the costs and benefits in the draft IA?

In section 4 of the Impact Assessment it is stated that: “even under high growth assumptions, our forecasts of actual movements and quota usage under the ‘do-nothing’ scenario remain below current movement and quota limits at Gatwick and Stansted up to the end of the three year regime. This implies that retaining the current movement and quota limits would not restrict activity in the NQP [Night Quota Period] at Gatwick or Stansted in this period, and therefore the costs and benefits would be likely to be negligible at these two airports.

That implies that the noise and number quotas have no impact, and no purpose. The Department should set quotas that have the desired impact in line with stated policy.

Q10: Are there any other changes to the regime which we should consider?

See reply to Q12.

Q11: Do you have any further comments on the scope for trialling new operational procedures which have potential noise reduction benefits in the period up to 2017?

The effect of the new procedures would be to further endanger the lives of a few to intolerable levels thereby negating any potential benefit.

Q12: Are there any other matters you think this consultation should cover?

A number of important issues were raised by GACC in their response to the Stage1 consultation which the Chiddingstone Parish Council endorse: We consider that there is a strong case for reducing the noise limits on departing aircraft. The case for having different limits at Gatwick than at Heathrow should be considered. Additionally we believe that a levy should be imposed on all night flights, with higher rates on the noisier aircraft. An illustration of how this would work was given in our Scoping Document response www.gacc.org.uk/aviation-policy (Night Flights paragraphs 35-38). This is particularly important at Gatwick because, in spite of a promise to incentivise quieter aircraft by differential landing fees, Gatwick Airport Ltd have in fact reduced all landing fees at night to zero.

Q13(a): Do you agree with the locations of the proposed new noise monitors at Heathrow? If not, are there alternative locations you would favour and why?

Q13(b): Do you agree with the proposal to apply runway-specific limit adjustments for easterly departures at Heathrow? If not, please give reasons.

Not relevant to Gatwick.

Impact Assessment questions

Question 1: Do you agree with our assessment of how movements and quota usage are likely to change over the period to the end of the summer season 2017 at Heathrow, Gatwick and Stansted?

No comment

Question 2: Do you agree with our assessment of the costs and benefits of option 1 at Heathrow, Gatwick and Stansted? Would you expect there to be any additional costs and benefits?

No. Option 1 is to continue the present number and noise quotas for a further three years. It is stated that: ‘At Gatwick and Stansted there are negligible costs to the regime as the quota limits do not currently restrict activity.’ This is not correct: there are substantial costs in terms of damage to public health.

Question 3: Do you agree with our assessment of the costs and benefits of option 2 at Heathrow, Gatwick and Stansted? Would you expect there to be any additional costs and benefits?

Option 2 relates to the operating ban on Q8 and Q16 aircraft. We have no additional comment.

Iain Durrant

Chairman

Chiddingstone Parish Council

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