BIPLANE NEWS

The Department of Transport have, after some delay, commissioned a survey into night noise from aircraft. They are looking to draw up protocols for night flying for the next 5 years so this is particularly important. BIPLANE have submitted a response by email which you can see below.

It is vital that they receive as many responses as possible and this can be done by clicking on the link and answering the questions posed as best you can. This will be easier and quicker than formulating a more complex response as we have done but will still be invaluable. Gatwick are looking to increase night noise by various strategies which simply must not happen. Please respond by 25th Feb.

Link

We are working, along with all other community groups around Gatwick, very hard to improve the situation of the supposedly widened swathe. I know those of you who have taken the trouble to use the new complaints website have been discouraged by the lack of response but KEEP COMPLAINING. Each and every complaint has to be logged by Gatwick and they are some 6 weeks behind in responding! The Horsham area has around 270 complaints – we are next but trailing with only about 18. The address to complain to is on our website

If you do not have access to a computer or would prefer not to email then a letter to Gatwick Complaints will also be counted.

BIPLANE

6 February, 2017

RESPONSE TO

The Night Flight Restrictions

Consultation

2017

Introduction

BIPLANE is a community group representing the residents of Ifold, Plaistow, Loxwood and Durfold Wood, an area situated approximately 14 – 15nm west of Gatwick Airport, and 3-4 miles south of the ILS with a population of around 4500. It was founded in 2015 following the changes to easterly arrivals, which caused a new and unacceptable concentration of flights over our area. Our role is to provide a focus for local residents’ concerns over flight noise. We also facilitate the communication of proposed airspace policy changes and their impact on local residents, whilst ensuring community feedback is effectively coordinated.

As BIPLANE we have answered the questions posed by the DfT night flight consultation and have taken the opportunity to add additional comments at the end.

Q1a. How strongly do you agree or disagree with our proposed environmental objective for the next regime? (Encourage the use of quieter aircraft to limit or reduce the number of people significantly affected by aircraft noise at night, while maintaining the existing benefits of night flights.)

  • We strongly agree with the Government’s aim to encourage quieter aircraft as part of the environmental objective
  • However, we are very concerned with the wording “ to limit or reduce the number of people significantly affected by aircraft noise at night”. This can only mean an increase in the concentration of night flights. Given the devastating impact that flight path concentration has on individual communities we are firmly of the view that greater flight path concentration should play no part in the proposed environmental objective and that this objective should only be achieved by the introduction of quieter aircraft

Q1b. Do you have any additional comments on our proposed environmental objective for the next regime?

  • We strongly disagree with the Government’s desire to balance the economic benefits of night flights against the noise impact on communities. In our view, the health and welfare of local residents should always outweigh any economic benefits. The proposal currently favours the economic benefits of night flights over the cost to residents’ health. Recent studies have proven the very significant impacts sleep deprivation has on individual physical and mental wellbeing and it would appear that no value is being placed on the cost to individual health and the associated loss of productivity to the UK economy. No other industry would be permitted to change or introduce increased noise levels without consultation and planning control.
  • We would also dispute the economic benefits stated in paragraph 1 of the Executive Summary. It suggests that aviation ‘directly supports around 230,000 jobs … and contributes over £21bn annually to UK GDP.’ These statistics are both misleading and exaggerated. Not only do they include flights at all times of the day, but also quote GDP figures which include aircraft manufacture and general aerospace industries which are of no relevance to a consultation on night flights
  • With regard to Gatwick night flights we see very littlebenefit accruing to the UK economy. The vast majority of Gatwick’s night flights are carrying holidaymakers either departing to or returning from overseas destinations where no doubt they have contributed significantly to a foreign economy, but very little to the UK’s.
  • The economic benefits of night flights at Gatwick are clearly small and the impacts of sleep deprivation are very significant. Therefore, in order for the Government to ensure we prioritise the health of our residents, we would suggest that not only are quieter aircraft introduced, but night flight movements and noise quotas be reduced on an annual basis with a view to having a complete ban by 2030.

Q2a. How strongly do you agree or disagree with our proposal for the length of the next regime?

  • We agree with the proposed five years. However, a thorough analysis of the balance between the economic benefits and the health impacts / widespread disturbance of night flights should be made within the next two years, leading to a reduction in both the noise and number quotas.

Q2b. Do you have any additional comments on our proposal for the length of the regime?

National airspace and noise policy consultations together with a departures review at Gatwick will be taking place in the near future. With a background of such significant change we strongly feel that, although content with the next regime lasting 5 years, a process to allow interim alterations must be allowed to take account of significant airspace/noise developments. It is also worth noting that a year-by- year reduction in permitted night noise by Gatwick was in place from 2006 to 2012 in line with a Ministerial Statement by the then Aviation Minister. We see no reason why this downward trend should not be continued throughout the 5 year period of the next regime.

Q3a. How strongly do you agree or disagree with our proposal to introduce a new QC/0.125 category for aircraft between 81 and 83.9 EPNdB?

  • We strongly agree with this proposal

Q3b. How strongly do you agree or disagree with our proposal for all aircraft quieter than this to remain QC/0 but count towards the airports movement limit?

  • We strongly agree with this proposal.

Q3c. Do you have any additional comments on proposals for the Quota Count System?

  • The introduction of a new QC/0.125 category will ensure the newer and quieter aircraft which BA and EasyJet will be purchasing will be included in the movement count encouraging airlines to invest in quieter aeroplanes
  • At present there are very few QC/0 aircraft at Gatwick, but as the consultation paper indicates, there area large number on order. Including them in the movement quota will reassure the public that the system is comprehensive and by counting them as QC/0, airlines will again be encouraged to invest in the least noisy aircraft.

Q4a. How strongly do you agree or disagree with the proposal for movement limits to remain unchanged at Heathrow?

  • We strongly disagree

Q4b. Do you have any additional comments on our proposal for Heathrow’s movement limit?

  • This is of particular concern. Heathrow’s movements have a direct impact on Gatwick routings. As Gatwick arrivals have to remain below those of Heathrow, Gatwick is prevented from using CDA approaches in order to reduce night-time noise. We appreciate that a condition of Heathrow’s new runway is the introduction of a night ban, which will clearly allow Gatwick to make greater use of CDA approaches. However, given the new runway is some considerable time away, we would welcome an immediate cut in Heathrow’s movement limit thereby allowing Gatwick to increase their usage of CDA approaches.

Q5a. How strongly do you agree or disagree with the proposal for movement limits to remain unchanged at Gatwick?

  • We strongly disagree.

Q5b. Do you have any additional comments on our proposal for Gatwick’s movement limit?

  • There is growing evidence of the adverse effects on health of aircraft noise at night.[1] However, these scientific studies only confirm what the residents of Ifold, Plaistow, Loxwood and Durfold Wood already know – night-time arrivals are hugely intrusive and are severely affecting our physical and mental well-being. Arrivals are turning over our area at around 3,000ft virtually 24 hours a day leading to widespread sleep deprivation, fatigue and increased stress levels. There can be no doubt that sleep is a fundamental and basic human need which should never be compromised. Residents simply cannot survive on one or two hours of uninterrupted sleep per night.
  • As a result, the overwhelming view from the Ifold, Plaistow Loxwood and Durfold Wood areas is that there should be a complete and immediate ban on night flight activity in line with Heathrow. We recognise that an immediate ban may be too big a first step, but at the very least, the aim should be to achieve a steady year by year reduction in movement limits together with an immediate ban on departures between 11pm and 7am.
  • Ultimately the goal must be to ban all night flight movements and to that end we fully support “Stop Stansted Expansion’s” call for the Government to announce that all night flights will be phased out by 2030.
  • We are very disappointed with the proposal to leave Gatwick’s winter movement limit unchanged. Historically, Gatwick’s winter night movements have fallen well short of the current limit. Leaving the current limit in place provides Gatwick with the scope to increase winter night movements making an already horrendous situation even worse. We would therefore like to see an immediate reduction in the winter movement limit to levels in line with historic usage i.e. less than 2,000. We do not accept paragraph 2.19 of the consultation paper which says: ‘There is however still capacity in the winter period and given the constraints on airport capacity in the south east, the Government does not think it appropriate to constrain this further’. Thisis particularly alarming as it suggests the Government is prepared to accept a 60% increase in the number of Gatwick night flights in winter. For the reasons stated above we cannot accept any increase in night flight movements.
  • We would also urge the Government to re-define the “Night Quota Period” by bringing it in line with the 11pm – 7am “Night Period” as defined by the World Health Organisation.

Q6a. How strongly do you agree or disagree with the proposal to raise Stansted’s movement limits to reflect the current number of exempt aircraft in operation?

  • No comment

Q6b. Do you have any additional comments on our proposal for Stansted’s movement limit?

  • No.

Q7a. How strongly do you agree or disagree with our proposals to encourage the use of quieter aircraft at Heathrow?

  • We would strongly agree with the proposal to encourage the use of quieter aircraft at all airports.

Q7b. Do you have any additional comments on how you feel noise quotas can best be set in order to encourage the use of quieter aircraft at Heathrow?

  • No.

Q8a. How strongly do you agree or disagree with our proposals to encourage the use of quieter aircraft at Gatwick?

  • We agree with the proposal to reduce Gatwick noise quotas to match existing use. Current quota limits have clearly been ineffective in encouraging quieter aircraft. By removing the historic quota surplus, airlines will be more encouraged to invest in quieter aircraft and we will also avoid the potential for an increase in night noise, which would be totally unacceptable. The proposal to reduce the summer noise quota to 4870, which is slightly less than the actual use in the past three years, would fulfil this aim. However, we are amazed that the new noise quota for the winter is proposed at 1,655, almost double the actual use in two of the past three years. That would negate the aim of setting the limits to match existing use, and would mean that the noise quota would be totally ineffective and would provide no incentive for the use of quieter aircraft. The new winter noise quota should be set at around 900.
  • We are very supportive of the suggestion in paragraph 3.25 that noise quotas might be reduced by 5% a year so as to be 20% lower by 2022. However, we are very concerned that this appears only to be a Government suggestion rather than a formal proposal. Such an initiative would make a real difference to our communities who are so terribly impacted by night noise. We therefore hope that, when the Government’s new night flight policy regime is finally announced, this suggestion becomes formal policy.

Q8b. Do you have any additional comments on how you feel noise quotas can best be set in order to encourage the use of quieter aircraft at Gatwick?

  • We are staggered and frankly appalled by the suggestion in the consultation paper (paragraph 1.38) that noise at night only affects some 4,300 people at Gatwick. I can assure the Government that the residents of Ifold, Plaistow, Loxwood and Durfold Wood, (14-15nm from the runwayand representing circa4,500 people), are very much impacted by night noise. When on arrivals we are overflown by aircraft at approximately 3,000ft (some as low as 2,700ft) and vectoring, so noise levels are very significant. This horrendous situation is made worse by straight in approaches, which are routed directly over Durfold Wood in the early hours of the morning. As a result, during the summer, we have only one hour without plane noise. When the wind changes direction, we are then overflown by concentrated departures with large planes (Virgin & BA 747’s) flying at low levels, some below 4,000ft.
  • BIPLANE represents rural communities where ambient noise levels are low (30-35dB) and as a result noise impacts are exacerbated. A research study for GACC carried out by the Dutch research agency To70 found that: ‘The percentage of annoyed residents is likely to be higher in areas with low ambient noise than in high ambient noise areas. It can be misleading to compare noise annoyance between different airports, when these local differences are not taken into account. Hence, the local difference between ambient noise levels should always be taken into account when calculating the annoyance.’[2]
  • We would also suggest that the Government’s noise contouring ignores communities such as ours. Although some distance from the runway we sit under the arrivals swathe and therefore bear the brunt of night time plane noise.

Q9a. How strongly do you agree or disagree with our proposals to encourage the use of quieter aircraft at Stansted?

  • No comment.

Q9b. Do you have any additional comments on how you feel noise quotas can best be set in order to encourage the use of quieter aircraft at Stansted?

  • No.

Q10. Do you have any further views on our proposals, or their potential impact on the Government's ability to fulfil the requirements of the Public Sector Equality Duty?

  • We have no comments on the Public Sector Equality Duty, but do have the following further views:
  • We are concerned at the suggestion in paragraphs 3.3 – 3.5 that the present controls on night flights by the DfT may be replaced by ‘bespoke’ controls imposed locally, possibly through the planning system. The planning authority for Gatwick is Crawley Borough which benefits substantially from employment at Gatwick whereas other nearby councils suffer worse noise. Any new system should involve all the councils around the airport.
  • We note the extreme variation in the number of night flights, from 76 a night in some weeks in the summer peak to only 7 a night on some unpopular weeks in winter. Obviously 76 flights cause a great deal of disturbance especially if they occur on a hot summer evening when sound travels further and when people like and need to have their windows open. It might be worth considering imposing a maximum number of night flights per night.
  • We are disappointed to note that there has been no change to the current 10nm ILS minimum joining point. We would like to see the minimum joining point reduced to 8nm (in line with daytime arrivals), which would facilitate greater dispersal therefore sharing night noise more equitably.
  • We are concerned that the Government’s proposals focus too much on the areas closest to Gatwick at the expense of more rural communities. We live under the arrivals swathe and concentrated departure flight path and our physical and mental well-being is equally important. We therefore believe that the Government’s stated policy of significantly affecting as few people as possible is fundamentally flawed and that night flight traffic should, until it’s banned, be fairly and equitably dispersed to afford everyone the right to a healthy night’s sleep. During the summer, Gatwick operates virtually 23 hours per day, no-one, no matter where they live, can exist on one hour’s sleep per night.

[1] See Aviation and Public Health: AEF.

[2]