Gatwick Area Conservation Campaign GACC

Developing a sustainable framework

for UK aviation.

EVIDENCE PAPER 9

Noise Envelopes

September 2011

GACC Evidence Paper 9

Noise envelopes

This paper is designed to provide an evidence-based response to the following question in the Scoping Document: 5.43 What are your views on the idea of setting a ‘noise envelope’ within which aviation growth would be possible, as technology and operations reduce noise impacts per plane?

  1. Based on our past experience, GACC would support this concept if, but only if,all of the following stringent conditions were met–
  2. the envelope was legally binding;
  3. it was set at the current level of noise;
  4. it contracted year by year so as to share the benefits of technology with local residents, and with the aim of reaching the noise standards set by the World Health Organisation;[1]
  5. the airport development should take place concurrently with the noise reduction, not in advance;
  6. a similar envelope was also set to limit and gradually reduce local pollution;
  7. compliance was monitored and enforced by an independent agency; and
  8. an immoveable ‘territorial envelope’ was set around the existing airport boundary.[2]

Why these conditions are necessary

  1. The aviation industry is proficient at indicating future intentions but these rosy intentions are frequently not fulfilled. Our experience at Gatwick has been that the only the only way to ensure that promises are kept is to express them in formal legal agreements.
  2. If the envelope were to be set at a size larger than the current noise level in order to accommodate future airport expansion that would imply an increase in present noise levels. A deliberate policy of increasing noise would not be acceptable.
  3. Aircraft noise is a serious environmental problem for tens of thousands of local residents within 15 – 20 miles of the airport. (See GACC Evidence Paper on Noise and Health). It would only be fair that, to quote the Scoping Document, “ as technology and operations reduce noise impacts per plane”, this benefit should be shared with local residents. Any noise envelope legal agreement must therefore contain clauses which ensure a steady reduction in noise. As the Scoping Document states: “The onus is firmly on the aviation industry to show how it will reduce its impacts.”
  4. These conditions create problems for the concept of a noise envelope. If the envelope is set at the present noise level, the development cannot take place until quieter aircraft are introduced. Thus the envelope concept would only be appropriate where small scale gradual development is envisaged, taking place in step with the introduction of quieter aircraft. If, however, an envelope is set at the current level, and then several years are allowed to elapse before the development is undertaken, so that with quieter aircraft noise levels have fallen, that would mean that when the new development takes place, the noise level is raised back to the present level. This would cause considerable anger.
  5. The new White Paper should recognise that the noise envelope concept will never be appropriate for new runways.

Case study A

An example of a beneficial noise envelope

  1. An example of a noise envelope was the 2001 Gatwick legal agreement, brokered by GACC. On 5February 2001 a Section 106 agreement was signed between Gatwick Airport Ltd on the one hand and West Sussex County Council and Crawley Borough Council on the other hand. It was endorsed by six surrounding District Councils.
  1. The local authorities in effect agreed not to challenge airport planning applications within the airport boundary. In return the airport agreed to some 36environmental safeguards. The most important, and the most relevant to any consideration of noise envelopes, was Obligation 4.6. With the aim of securing a reduction in the Air Noise resulting from the operation of the Airport during the period of the Agreement to use all reasonable endeavours working with the Department of the Environment, Transport and the Regions, NATS and airline operators to secure by 2008: ..... (ii) that the gross area of land within the actual 16 hour 57dB contour and the gross area of land within the 16 hour 57dB Leq contour as predicted for 2008 in the Sustainable Development Strategy are reasonably comparable.
  1. Put into plain English that was an undertaking to secure a halving of the area of land within the 57 Leq contour. Although the wording was somewhat woolly (‘all reasonable endeavours’), there was a legal obligation for compliance to be monitored annually by consultants employed jointly by the airport and the County Council. And, significantly, a legal obligation for the airport to take remedial action if not on course.
  1. In the event, by 2008, the target of halving the area within the noise contour was almost achieved. Most, if not all, people in the Gatwick area have benefited substantially.

Case study B

An example of an unsatisfactory envelope

  1. An example of an unsatisfactory noise envelope was the replacement Section106 agreement signed between the local authorities and Gatwick Airport in December 2008. Instead of a legally enforceable reduction in noise, the wording was: Obligation 8.1 The Company will no less frequently than every three years …. produce Action Plans specifying its prioritised programme of activities to address the following issues: Air quality; Noise; Water quality and drainage; Waste management; andUtility management.
  1. Since, however, there was no definition of what would be contained in the Action Plans, this pledge was almost meaningless. It is true that the agreement also provided for a consultant to submit to the Company and the Councils a report on: ‘whether the Action plan is fit for purpose, and whether and in what manner and to what end the Companyshould consider revisions to the Action Plan.’ But since there was no definition of what the purpose of each of the action plans was, the phrase ‘fit for purpose’ was meaningless.

Case study C

An example from Heathrow

  1. Another example of an unsatisfactory noise envelope was the condition setin the 2003 Air Transport White Paper that a third runway at Heathrow could be built if “it resulted in no net increase in the total area of the 57 dBA noise contourcompared to summer 2002.”
  1. In order to secure Parliamentary approval for the new runway, it had to be shown that these conditions would be adhered to. That involved the Government making a promise that the runway would only be usedat half its capacity, a promise that was not credible: it was obvious that in order to secure an economic return on the cost of building the new runway, and in order to relieve the congestion at Heathrow, after a few years the promise would not be kept. The history of Heathrow is littered with limits on the number of aircraft allowed to use the airport, each limit raised when reached. Moreover,because the development was planned to take place before the noise reduction, forecasts had to be made of future noise levels, and future aircraft types, which came under serious criticism.
  1. The proposed Heathrow envelope did satisfytwo of the conditions listed in paragraph 1 above: it was set at the current level of noise, and a similar envelope for local pollution was proposed. But the development was due to take place first and the putative noise reduction later; the ‘envelope’ was not legally binding; andwas not set to contract.
  2. These three case studies confirm that a noise envelope would only be practicable and acceptable if it complied with the conditions set out in paragraph 1 above. We request that the new White Paper will state that the noise envelope concept will only be pursued subject to these conditions.

1

[1] See GACC Evidence Paper on Noise and Health

[2] See GACC Evidence Paper on No New Runways

Cover illustration. Noise contours at Gatwick 2009