All Party Parliamentary Group on Heathrow and the Wider Economy
INQUIRY INTO HEATHROW’S NEW FLIGHT PATHS AND NOISE IMPACT
SUBMISSION BY THE RICHMOND HEATHROW CAMPAIGN
August 2014
This submission is the response from the Richmond Heathrow Campaign to the Inquiry by the All Party Parliamentary Group on Heathrow and the Wider Economy into Heathrow’s new flight paths and the noise impact of Heathrow with three runways. The contents of this submission are not confidential and we have no objection to its publication.
The submission is structured under the three section headings: (i) a brief description of the Richmond Heathrow Campaign; (ii) a brief comment on Heathrow Airport Limited’s noise assessment for its proposed third runway; (iii) our answers to the Inquiry questions.
RICHMOND HEATHROW CAMPAIGN
The Richmond Heathrow Campaign (RHC) represents three amenity groups in the London Borough of Richmond upon Thames: the Richmond Society, the Friends of Richmond Green and the Kew Society, which together have over 2000 members. Those members are adversely affected by noise from HeathrowAirport’s flight paths, particularly at night.
The RHC therefore favours a ban on night flights and opposes the introduction of mixed mode and the development of additional runways at Heathrow.We nevertheless recognise the importance of air transport and the need to make provision for the handling of additional air passenger numbers. We have therefore sought to make positive responses to consultations by the Airport Commission and others, with detailed proposals for making better use of the existing capacity at Heathrow and other airports in South East England without the need for additional runways.
NOISE ASSESSMENT BY HEATHROW AIRPORT LIMITED
Heathrow Airport Limited (HAL) have published a noise assessment of their proposed third runway by AMEC Environment & Infrastructure UK Limited [1], with significant input from the Environmental Research and Consultancy Department (ERCD) at the Civil Aviation Authority.
In the time available we have not been able to analyse fully the evidence and arguments in the report. Nevertheless the report does seem to be based on a number of questionable assumptions (for example, the scope for and rate of change to less noisy aircraft and population densities within the noise contours). We comment on some of these where they are relevant to the Inquiry’s questions. We also show that even if accepted at face value, HAL’s evidence indicates that the noise impact of a third runway would be worse than the assessment concedes
Transport for London commissioned the ERCD to undertake a noise assessment of Heathrow with three runways which reached very different conclusions than the AMEC report about the scale of the noise impact of a third runway. We would not wish to express a view at this stage as to which of the two assessments is the more accurate. But their different findings clearly have to be reconciled; and, in particular, the assumptions on which the two assessments were based have to be compared.
RESPONSE TO INQUIRY QUESTIONS
A. The recent and future trends in air traffic noise levels at Heathrow to 2025
Question 1. By what margin - in terms of the number of people affected - does the present noise from Heathrow’s existing flight paths exceed the World Health Organisation’s community noise guideline values in the day/evening period (0700-2300) and in the night period (2300-0700)? How does this compare with other airports within the UK and the EU?
World Health Organisation
So far as we are aware, neither the Department for Transport nor HAL has published an assessment of the extent to which the noise from Heathrow’s flight paths exceeds the World Health Organisation’s guideline values for community noise. It is however possible to make a rough estimate of the level of exceedence by applying the guideline values to the published noise data for the flight paths.
The table below sets out the population numbers at Heathrow that were exposed in 2012 to the noise values which the Environmental Noise Directive (END) requires to be assessed (see our response to Question 2 for more details on the Directive). The populations for the END values have been multiplied against the WHO values in order to arrive at estimates of the number of people whose exposure exceeded the WHO values. We accept that our figures are a somewhat crude estimate, but we consider that in broad terms - and in the absence of any official figures - they are relatively indicative of the scale of the WHO exposures for the purposes of the Inquiry.More details on the WHO values and our calculations are set out in the appendix on the final page of this submission.
It can readily be seen from the table that the differences between the two population figures are large. The explanation appears to be that the WHO values are set at a level to protect members of the population who are vulnerable to noise, such as children, people with hearing sensitivities, the chronically ill and the elderly [2]. By contrast, the need to protect vulnerable groups is not recognised by the END values [3]or by the UK’s 57 decibel contour (see our response to Question 2 for more detail).
Over 24 hours / END noise values / WHO noise valuesDecibels (leq) / Population / Decibels (leq) / Population
0700-1900 / 55 / 430 000 / 50 / 1 428 000
1900-2300 / 55 / 388 000 / 50 / 1 278 000
2300-0700 / 50 / 197 000 / 40 / 2 096 000
Air traffic noise at Heathrow and at other airports
The table below sets out the number of people who were affected in 2006 by air traffic noise - as measured by the LDEN noise indicator in the Environmental Noise Directive (see our response to Question 2 for more details on the Directive) - in the day and night periods at Heathrow and other major airports in: (a) London; (b) the United Kingdom; and (c) at other EU hub airports[4].
The table shows that the number of people exposed to air traffic noise is far larger at Heathrow than at any other airport in London or in the United Kingdom; or at the other EU hub airports with which Heathrow is said to be in competition.The proponents of expansion at Heathrow readily invoke economic and operational comparisons between Heathrow and other airports. We consider that it is important to make noise comparisons between airports for a balanced view of the merits of the arguments for a third runway.
London Airports / UK Airports / EU Hub AirportsHeathrow / 725 500 / Heathrow / 725 500 / Heathrow / 725 500
LondonCity / 12 200 / Manchester / 94 000 / Frankfurt / 238 700
Gatwick / 11 900 / Glasgow / 63 600 / Paris (C. de G.) / 170 000
Stansted / 9 400 / Birmingham / 47 900 / Amsterdam / 43 700
Luton / 8 600 / Aberdeen / 16 300 / - / -
- / - / Edinburgh / 15 000 / - / -
- / - / Southampton / 12 100 / - / -
Question 2. Does the Environmental Noise Directive enable the UK to meet fully the criticisms that were made in the Heathrow Terminal Five Public Inquiry Report that the 57 decibel noise contour was by itself an inadequate measure for assessing the full impact of air traffic noise?
The Planning Inspector who presided over the Heathrow Terminal Five Public Inquiry (Roy Vandermeer QC) was - in his report and recommendations to the Secretary of Statein 2000- highly critical of what he saw as the undue reliance that the Department for Transport placed on the 57 decibel contour as the sole indicator of the impact of air traffic noise. Specifically, Vandermeer found from evidence to the Public Inquiry that:
-people living in areas outside Heathrow’s 57 decibel contour were affected by air traffic noise;
-research at Heathrow did not support the claim that annoyance from air traffic noise is significant only at and above 57 decibels;
-the 57 decibel contour did not reflect the impact of the large increase that had taken place in the number aircraft movements at Heathrow;
-the 57 decibel contour did not measure the benefit of runway alternation at Heathrow in providing periods of respite;
-the 57 decibel contour did not evaluate noise from movements in the night period (2300-0700).
The Environmental Noise Directive(adopted in 2002[5]) requires major airports to undertake five-year noise assessments based noise maps with the LDEN contour: 55 decibels for the day and evening periods (0700-1900 and 1900-2300) and 50 decibels for the night period (2300-0700). Although the LDEN contour shares some of the weaknesses of the 57 decibel contour that were identified at the Heathrow Terminal Five Public Inquiry, the Directive stipulates only the minimum criteria to be used for noise assessments. National Governments can therefore set lower values for noise mapping (e.g. the WHO values). Furthermore, the Directive acknowledges that it may be advantageous to use supplementary noise indicators for special cases, with several examples listed in Annex 1 to the Directive. The Directive therefore permits national Governments to supplement the noise contour maps with other noise indicators.
The Department for Transport has accepted that 57 decibels is not the cut off point below which air traffic noise does not have any adverse effect, but it has not suggested a lower value. The Department has also invited airport operators to adopt supplementary noise indicators;but it has not suggested upon what such indictors should be based, apart from the 57 decibel contour. And the Department itself appears to have drifted back to sole reliance on the 57 decibel contour, despite the evidence of its shortcomings from the Heathrow Terminal Five Public Inquiry
Therefore, in answer to the question, the Directive has put in place a framework that would enable the UK to set lower values for the contours on noise maps and to set supplementary indicators for noise features that the contours cannot capture. But unfortunately the Government has not used these powersto address the weaknesses in the 57 decibel contour identified by Vandermeer., and the debate about the noise impact of a third runway is being dominated by thediscredited 57 decibel contour.
Question 3. What are the prospects for significantly less noisy aircraft at Heathrow over the next ten years and are the prospects in any way dependent on the development of the proposed third runway? To what extent is there a conflict between the optimum reduction of aircraft noise and carbon emissions?
Noise Reductionversus Carbon Reduction
It has not been possible in the time available to research the extent of which there is a conflict between optimum reductions in emissions from aircraft of noise and carbon. But this issue is important and must not be over-looked in the third runway debate. Specifically for the APPG Inquiry, it is important to establish whether the forecasts for reductions in noise and carbon are based on the same set of assumptions or have different sets of assumptions.
The risk from using different sets of assumptions is that unduly optimistic forecasts are produced for reducing both noise and carbon emissions at the discussion stage, whereas in reality only one reduction or the other may be deliverable due to technological incompatibilities between the two policy objectives. In terms of their relative importance, reducing carbon must be given the priority. But that means (a) accepting that aircraft noise cannot be reduced to the extent that it is theoretically possible, and (b) producing noise forecasts that reflect the limitations of what can be achieved in practice.
Less Noisy Aircraft
According to the Government’s aircraft noise matrix (the 57 decibel noise contour), Heathrow’s air traffic noise peaked in the late 1970s (mainly due to the impact of Concorde) but decreased dramatically to 2004 (when Concorde was withdrawn from service and Chapter 2 aircraft - the next noisiest class of aircraft - had completed their ten-year phase out). But the situation has been somewhat different since 2004. It can be seen from the table below that the size of the contour contracted by less than 1 km² per year over the nine years between 2004 and 2012, with an irregular trend of increases in some years.
Year / Size of 16-hours 57 dBA contour / Number of aircraft movementsKm² / % / 16-hours / 24-hours / calendar year ( 000)
%
2004 / 117.4 / 100.0 / 1 263.0 / 1 300.5 / 476 (470) / 100.0
2005 / 117.2 / 99.8 / 1 248.7 / 1 309.7 / 478 (472) / 100.4
2006 / 117.4 / 100.0 / 1 248.0 / 1 306.8 / 477 (471) / 100.2
2007 / 119.6 / 101.9 / 1 258.2 / 1 317.8 / 481 (476) / 101.1
2008 / 123.1 / 104.9 / 1 264.8 / 1 308.7 / 479 (473) / 100.6
2009 / 112.5 / 95.8 / 1 230.5 / 1 276.7 / 466 (460) / 97.9
2010 / 108.3 / 92.3 / 1 263.8 / 1 246.6 / 455 (449) / 95.6
2011 / 108.8 / 92.7 / 1 268.6 / 1 317.8 / 481 (476) / 101.1
2012 / 110.1 / 93.8 / 1 255.1 / 1 297.8 / 475 (471) / 99.8
Sources: Civil Aviation Authority: Noise Exposure Contours for Heathrow Airport for the size of the aircraft noise contour and the number of aircraft movements per 16-hour day (mid-June to mid-Sept). Civil Aviation Authority: UK Airport - Movement, Passenger and Cargo Statistics for the number of aircraft movements per year. The number of aircraft movements per 24-hour day (Jan to Dec) have been calculated from the number of movements per year.
Notes: The percentage columns for the size of the noise contour and the number of movements take 2004 as the base year for observing the extent of subsequent changes. The numbers marked in bold indicate that there was an increase in the size of the contour and/or in the number of movements compared with the preceding year - see comments below). The numbers in brackets in the column for the number of movements per year are the numbers of air transport movements (i.e. engaged in the transport of passengers, cargo or mail).
As we explained in our response to Question 2, Vandermeer’s Terminal Five Public Inquiry Report was critical of the reliance that the Government placed on the 57 decibel contour for assessing the noise impact of air traffic. But even the 57 decibel contour now suggests that the noise climate at Heathrow has not improved by much over the last nine years.And if the rate of reductionin the contour size over the past nine years were to continue, it would take another 110 years before the contour disappeared.
In their evidence to the Heathrow Terminal Five Public Inquiry, the Government and the aviation industry advised that there would be limited scope for further reductions in noise per aircraft after Concorde and Chapter 2 aircraft had been phased out.That advice appears to have been born out by the 57 decibel figures since 2004. But HAL’s noise assessment for a third runway has put hope in “quieter aircraft” (i.e. less noisy aircraft) back on the agenda.
The table below shows HAL’s forecast contour sizes for two runways (480 000 movements in 2030 and 2040) and for three runways (570 000 movements in 2030 and 740 000 movements in 2040). The table shows that under all scenarios the contour size would be smaller than in 2012 (110.1 km² - see table on previous page). However, the adverse gap - between the two runway scenario on the one hand and the three runway scenarios on the other hand - would be wide in 2030; and even wider in 2040.
Runway scenarios / 2030 / 2040Km ² / Index / Km ² / Index
Two runways / 69.5 / 100.0 / 66.1 / 100.0
Three runways - Option R (maximise respite for people overflown) / 85.0 / 122.3 / 95.8 / 144.9
Three runways - Option T (minimise total number of people overflown) / 87.8 / 126.3 / 99.1 / 149.9
Three runways - Option N (minimise number of people newly overflown) / 91.7 / 131.9 / 103.4 / 156.4
Source:Heathrow’s North-West Runway - Air and Ground Noise Assessment, Table 5.2 (page 39).We have made the comparison on the basis of the size of the exposed area rather than the size of the population within the exposed area on account of the uncertainties about HAL’s population estimates that we have commented on in our general remarks on HAL’s noise assessments. We have made the comparison on the basis of the ANCON forecasts in Table 5.2 because it is HAL’s preferred matrix and for the sake of simplicity.
The table below looks more closely at HAL’s assessment of the timing of the introduction of less noisy aircraft. It must be inferred from the figures that the air fleet would have largely changed to less noisy aircraft by 2030, hence the contour forthe two runways would be down by 40.6 km² compared with 2012, but then down by only a further 3.4 km² by 2040. These rates of change are equivalent to an annual reduction of 2.3 km² over the eighteen years between 2012 and 2030 (compared with an annual reduction of less than 1 km² in the nine years between 2004 and 2012) and an annual reduction of less than 0.5 km² in the ten years between 2030 and 2040.
The foregoing analysis suggests that HAL may be unduly optimistic about (a) the scope for significantly less noisy aircraft and (b) the rate at which they would replace the existing air fleet. In particular, HAL needs to explain by what proportion the less noisy aircraft would have replaced the existing air fleet before the first full year in which a third runway would be in service.
Runway scenarios / Km ²2012 / 2030 / +/- / 2040 / +/-
Two runways / 110.1 / 69.5 / - 40.6 / 66.1 / - 3.4
Three runways - Option R (maximise respite for people overflown) / - / 85.0 / - / 95.8 / + 10.8
Three runways - Option T (minimise total number of people overflown) / - / 87.8 / - / 99.1 / +11.3
Three runways - Option N (minimise number of people newly overflown) / - / 91.7 / - / 103.4 / + 11.7
Source: As for the previous table.
Question 4. Are there additional operational procedures for noise reduction and respite at Heathrow that could be introduced within the next ten years; or are any such noise improvements being held back for the development of a third runway?
Chapter 4 (Mitigation Strategy) in HAL’s noise assessment sets out a number of proposals for reduction and respite from air traffic noise, ground noise and road traffic noise.
Ground and Road Noise Proposals
In the time available we have been able to concentrate only on air traffic noise, which is the key noise impact on communities within the London Borough of Richmond upon Thames. We nevertheless recognise that communities more adjacent to Heathrow are affected by ground and road traffic noise associated with the airport.
In our view, too little attention has been paid to the impact of ground and road traffic noise, particularly where the areas affected also suffer from air traffic noise We therefore ask the APPG to ensure that ground and road noise are not overlooked and that there is early engagement with the communities likely to be affected (including those areas immediately adjacent to the proposed third runway) to re-assure them that the potential impacts are being taken seriously.