TAG’s draft responses to DfT Night Flight Consultation

Below are the set of DfT questions with TAG’s draft answers. The first part (up to and including question 30) should be answered by 3rd March 2021. The remainder should be answered by the 30th May 2021. The DfT advises either using the response form online or sending an email to night.flights@dft.gov.uk .You can either send your responses to the set questions or you can send your own response

Full list of questions

Questions 1 to 5 ask for personal details, organisation details, region of the UK and local airport.

6/ Do you agree with our October 2022 to 2024 night noise objective for the designated airports?

No. The Government fails to operate the “Balanced Approach”, which in reality is not balanced at all. There should be a complete ban on all night flights between 11pm and 7am. It is perfectly possible to fly anywhere in the World by departing between 7am and 11pm while arriving between 7am and 11pm local time. Absolutely no specific details are given as to why “night flights are an important contributor” to the economy. They are attractive to particular airports which can squeeze in more flights for their own benefit, but the country can trade equally well using a variety of airports during the day.

The Government acknowledges that night flights create noise way above the WHO guidelines and that submitting people to noise and sleep deprivation is a major cause of suffering and illness, which itself reduces productivity.

The achievement of “maximum environmental benefit most cost-effectively while preserving potential benefits gained from aircraft related benefits” [ICAO Doc 9289] is not observed by breaching WHO recommendations, when it is perfectly possible to trade with any other country by avoiding night-time flying

The 48dB LAeq measure of achievement is woefully inadequate. The WHO recommendation is 40dB. How can this approach be “balanced” when the WHO strongly recommended maximum level is so blatantly flouted?

The statements in the Consultation that aviation directly provided around 230,000 jobs and that the sector contributed at least £22 billion annually to UK GDP are likely to be overstated. They are also not backed up with facts, but rather the references are simply “DfT analysis” of data. They are also not supported or followed by others. Thus, we have:

• The Department of Business Innovation and Skills saying that the UK aerospace industry employed 116,000 people and generated £9.2bn value added revenue. (BIS Research Paper 294)
• Dft saying that it is 230,000 jobs and a £22bn contribution (this consultation)
• Oxford Economics supported by the Airport Operators Association saying that aerospace supports 327,000 jobs and contributes almost £20 billion to UK GDP with inbound tourism contributing a further £19.6 billion gross value added – total £39.6billion (although why they ignore the money going out of the country via tourism out of the UK is not clear). (Economic Benefits from Air Transport in the UK)
• ACOG, Our Future Skies, a consortium of which the DfT is a member saying that nearly 960,000 people are employed in the aviation and aerospace industries, with the sector contributing over £50 billion to the UK economy each year. (Modernising the UK’s Infrastructure in the sky)

So; which is it, £9.2billion, £20 billion, £39.6 billion or £50 billion gross value added, with 116,000 jobs, 230,000 jobs, 327,000 jobs or 960,000 jobs? It seems that figures are picked out of the air.

If the benefits to the economy are so overstated, the likelihood is that the financial benefits (excluding health disbenefits both in suffering and loss of productivity) of night flights are also overstated. None of this addresses the assertion that all traffic anywhere in the World could be catered for by spreading the demand across the Country rather than concentrating it at one airport. It would also spread the economic benefits to other parts of the Country to their economic benefit.

The Government has failed to take account of the recommendations of the Independent Commission on Civil Aviation Noise (ICCAN). In December 2019 ICCAN reviewed the SoNA study of annoyance from aviation noise. ICCAN said of SoNA that “It is fair to say that SoNA has been a divisive document. It doesn’t just divide community groups from the aviation industry, it divides opinion between academics, acousticians and health experts”. ICCAN then recommended:

• A new, regular attitudinal survey is begun before the end of 2021, and repeated frequently.
• The new surveys should be commissioned, run and analysed independent of Government, regulators and industry. We consider it appropriate for ICCAN to take on this role, working closely with relevant stakeholders.
• ICCAN will find a sustainable and equitable solution to funding the surveys, which involves government and industry, but does not impinge of the independence of our ownership and management of the surveys.
• Improvements should be made for the new surveys using lessons learned from SoNA.
• ICCAN will run a development study to identify the best way to implement improvements for the new surveys.

What is happening with these recommendations?

7/ Do you agree with how our October 2022 to 2024 draft noise objective for the designated airports will be measured?

No; for the above reasons. If the Government considers that an outright ban is not possible now, it should work towards one and in the meantime:

1. return the situation so it is no worse than 15-20 yrs ago using noise metrics that are associated with sleep disturbance.
2. improve the noise levels further using modern plane technology with tighter controls.

To this end the WHO as long ago as 1999 said that sleep disturbance could occur with noise levels at 45dB LAmax inside and 60 dB LAmax outside. This was further developed in 2009 with the WHO Night Noise Guidelines which provided that the risk of heart attacks rose at 50 dB Lnight and the risk psychiatric disorders rose at 60 dB Lnight.

The WHO 1999 Guidelines provided that “For intermittent events that approximate aircraft noise, with an effective duration of 10-30 seconds, SEL values of 55-60 dBA correspond to a LAmax value of 45 dB”. Current noise levels in 2019 exceed those recommendations so progress has been all but non-existent. The quietest modern Boeing 787 was recorded by Anderson Acoustics (see below) at 68.8 dB LAmax, so it is clear just far adrift the UK is from long established WHO minimum health standards. A selection of extracts from the 1999 and 2009 WHO noise guidelines are attached

Extract from WHO 1999 Guidelines

8/ Do you agree that we should maintain the existing restrictions for two years from October 2022 to October 2024?

No; you should ban night-time flights or in the alternative take immediate steps to work towards a night-time ban. Suggested immediate steps towards a full night flight ban are:

For departures:

Ban any take-off after 11pm. Introduce a system of fining airlines per plane breaching a recorded noise level. Modernise the night time loudness control at 6.5km from start of roll, which has not been changed for many years. Planes not achieving 75dB at 6.5km from start of roll should be fined (e.g. £5000). Then record them at 7.5 km from the airport boundary by which time they should have reduced to no more than 60 dB LAmax with minimum rates of climb considerably more than the 4% required now (suggest 10% minimum rate of climb using the NADP1 procedure with reduced thrust and by keeping flaps down and not retracting them until 4,500’).

For arrivals:

– ban any flight arrivals before 6am.These should be the first flights to start getting back to the earlier position to that in place when the current regime started. It is grossly unjust that large swathes of SE, S and W London should be woken at 4.30am every day
– all night flights should arrive as far down a runway as possible (for example this could be 300-500m further down Heathrows long runways) so that flights in the air are higher than today.
– use 3.2deg or higher in final ILS approach so flights are higher than today
– avoid any level flight, in particular change definition of compliance to Continuous Descent Operation (CDO) at Heathrow where 2.5km of level flight is considered complying to CDO, to a real definition with the most being allowed of 0.5km or less of level flight

– steeper approaches up to 4.5 degrees and more should be used where possible within the routine to further reduce noise. The CAA in their “Steep Approach Approval Compliance Statement and Checklist” provide that “The majority of approaches are flown at glideslope angles of 3°. Angles up to 3½° are considered to be routine and within the capability of any certificated aeroplane. Approach angles greater than 3½°, but less than 4½°, are unlikely to produce significant problems in normal operations, and accordingly there are no specific requirements. Operators using these approach angles should consult the aircraft manufacturer and satisfy themselves that the performance and handling characteristics are acceptable.” Approaches into London City Airport are set at 5½⁰

– avoid banking in curves if banking will produce >60dB. This requires noisier planes to join ILS route much earlier but allows less noisy planes to join ILS later.
– provide respite to area beyond ILS joining point on arrivals by only approaching from e.g. North side stacks on northern runway one day and South another day when landing on southern runway.

9/ What would be the impacts to you should the government maintain the existing restrictions for two years, from October 2022 to October 2024 (provide evidence to support your view)?

Continued interrupted sleep and breach of article 1 of the EU Regulation 598/2014 which provides for the reduction in the number of people significantly affected by potentially harmful effects of aircraft noise.

Queen Mary University reporting to the Airports Commission in 2015 stated that “A recent study around London Heathrow airport examined risks for hospital admission and mortality for stroke, coronary heart disease and cardiovascular disease for around 3.6 million people living near London Heathrow airport (Hansell et al., 2013). Both daytime (LAeq 16 hour) and night-time (Lnight) aircraft noise exposure were related to increased risk for a cardiovascular hospital admission”.

The published conclusions in the BMJ of that study were “High levels of aircraft noise were associated with increased risks of stroke, coronary heart disease, and cardiovascular disease for both hospital admissions and mortality in areas near Heathrow airport in London.” 

Heathrow adversely affects more people with aircraft noise than any airport in Europe, with 28% of the people in the EU, adversely affected by aircraft noise, being affected by Heathrow. Yet the DfT are proposing to “maintain the existing restrictions”. That, we would suggest, is not limiting or reducing the number of people significantly affected by potentially harmful effects of aircraft noise.

10/ What would be the impacts to you should the government allow the night fight restriction in place at the designated airports to lapse (provide evidence to support your view)?

Substantial if night flights were banned – catastrophic if they were not. 

EU Regulation 598/2014 provides that there should be a balanced approach, as defined in the Regulation, and there should be regular assessments of the effects of noise under Article 6.

This consultation should form a part of such an assessment, which should then provide that there is no national economic reason to deny significant portions of the population a night’s sleep uninterrupted by low flying aircraft. The appropriate restriction on night flights should be introduced and due notification given under Article 8.

Article 1 provides for there to be an overriding objective that “where a noise problem has been identified, rules on the process to be followed for the introduction of noise-related operating restrictions in a consistent manner on an airport-by-airport basis, so as to help improve the noise climate and to limit or reduce the number of people significantly affected by potentially harmful effects of aircraft noise, in accordance with the Balanced Approach.”

The stated objective in the EU Regulations is “to facilitate the achievement of specific noise abatement objectives, including health aspects”. In effect that is all that we are asking for.

11/ Do you agree we should ban QC4 rated aircraft movements from operating at the designated airports between 23:30 and 06:00 from October 2022?

Yes

12/. Provide evidence to support your view.

We have no confidence in this whatsoever. QC2 planes are far too noisy for night flying and are every bit as noisy or nosier than QC4 planes. For example the A380 (a QC2 plane) is noisier than a 747 or A340 (QC4 planes) as shown by Heathrow’s noise consultants Anderson Acoustics.

13/ What are your views on the:

• findings of the night flight dispensation review?

Not a lot. Our experience of Heathrow is that late flights (up to 2am and beyond) are permitted for a variety of reasons that have nothing to do with the listed dispensations. These include simply bunching up too many planes last thing at night so they inevitably late run. Simply late running is used as an excuse for flying into the night and denying people their required sleep

• proposals for the night flight dispensation review?

Not a lot. Night flights should be banned for the reasons given. The reasons for late running are irrelevant when people are denied sleep. It just needs to stop.

14/ Should disruption due to local weather qualify for dispensations?

No. If the plane cannot take off because of the weather, it should wait until the following day

15/ Should disruption due to en-route weather qualify for dispensations?

No, unless there is danger to life or if the aircraft arrives in the night period but has departed on time without reasonable anticipation of the en-route problems

16/ Should disruption due to foreign airport weather qualify for dispensations?

No

17/ Should disruption caused by ATC industrial action qualify for dispensations?

No

18/ Should disruption caused by industrial action by airport staff qualify for dispensations?

No

19/ Should disruption caused by industrial action by airline staff qualify for dispensations?

No

20/ Should network capacity delays qualify for dispensations?

No

21/ Should delays caused by serious criminal or terrorist activity that affect multiple flights qualify for dispensations?

No

22/ Should cumulative delays qualify for dispensations?

No

23/ Should dispensations be permitted for flights delayed to the NQP due to a medical emergency that has passed?

No

24/ Should dispensations be permitted for flights delayed to the NQP due to a police emergency (for example a disruptive passenger) that has passed?

No

25/ Should dispensations be permitted for the repositioning of emergency service (including medical transplant) aircraft?

No

26/ Should dispensations on the basis of reducing carbon emissions be permitted?

No. It is up to airlines and ATC to plan sufficiently that this does not happen. It has been shown by ACI Europe in “A Route to Net Zero European Aviation” that “improved ATM and other operations” will give only a nominal improvement in decarbonizing (6% maximum in 2030 and 2050).

27/ Should pre-emptive dispensations be permitted?

No

28/ Should dispensations be granted for information technology failures?

No, unless the technology failure leads to an emergency causing a danger to life

29/ Supply any further views or evidence on the guidance allowing airport operators to grant dispensations you may have?

30/ What are your views on government dispensations overall (provide evidence to support your view)?

No such dispensations; these V.I.P.s can depart at an appropriate time to arrive between the hours of 6am and 11pm

31/ What length should the night flight regime beyond 2024 be?

If night flights are not to be banned outright, then the review period should be reduced to 3 years. Depriving people of sleep is a very serious matter and has not been treated with the due seriousness. There is ample evidence to show that depriving people of sleep can cause very serious health deterioration. There should be a program to abolish this practice if it allowed to continue

32/ How do you think the length of regime will affect you (provide evidence to support your view)?

For many residents affected by low flying aircraft out of Heathrow, night flights have had a very serious affect upon our lives since 2014 when the flight path patterns changed. In the case of Heathrow, the airport does not use the recommended ICAO procedure for departures so that aircraft are much lower on departures making more noise on the ground that would be the case if the ICAO recommended procedure were followed. 

33/ Do you think that QC is the best system for limiting noise at the designated airports?

It is abused and does not reflect reality. Because the noise measurements are done in EPNdB, which typically gives readings some 10dB above other metrics and which is “tone corrected”, defined by the International Electrotechnical Commission as “adding to perceived noise level an adjustment that is related to the degree of irregularity that may occur among contiguous one-third-octave band sound pressure levels of an aircraft noise”, distorted results are obtained, leading to noisier planes being rated as less noisy. A prime example is the A380 which is actually noisier on an Lmax reading than any other plane notwithstanding that it has a QC2 rating 

The QC system does not guard against or penalize aircraft operators for the noise suffered on the ground. There is no incentive to fly the plane in a way that reduces the noise impact on the ground. Data shows that there has been a relentless rise in the number of disturbing night-time noise events. From the uploads it can be seen that in 2006 the N60 figure of 10 or more (number of flights per night on average of more than 60dB LAmax) affected 837,000 people. By 2017 the number people affected by 10 or more flights had risen to 929,000 (11% rise). By the following year 2018, the number of people affected by 10 or more flights at N60 had risen to 974,000 (16% rise over 2006). All these people were affected by noise that according to the WHO is well above the “sleep disturbance” level and into the “psychiatric disorder” level.

It can be seen that the QC system has failed dismally to reduce the noise levels. Quieter planes have been developed but the number of people affected by seriously disturbing noise has continued to rise relentlessly. This is likely to be due to the way that they are flown and the lack of a proper noise abatement procedure at Heathrow

34/ What do you think are the:

• advantages of changing to a new system?

Getting realistic measurements

Getting a system that will give an incentive to airlines to record lower noise at ground level. Noise monitors could be set up along the route to record the noise level. Those airlines with aircraft recording more than a specified maximum that should face substantial fines – say £5,000 per infringement. Airlines failing to achieve the required noise level with several aircraft could face total fines of several hundred thousand pounds per night. This type of system is being trialled in Brussels

• disadvantages of changing to a new system?

None

35/ Do you have evidence of other noise management regimes being used elsewhere and how they compare with the current system?

Yes: LMax, Leq (not recommended for the 16 hour period), Lden, Lnight, N metric. The response of Parliament to the ANPS recommended a suite of metrics, which the DfT have failed to adopt.

36/ Should we introduce an additional QC category for quieter aircraft in the longer-term?

Yes, but not using the EPNdB metric

37/ Should the government reintroduce an exempt category?

No,

38/ Please provide evidence to support your position.

for the reasons given above – namely that there should be an absolute ban on night flights

39/ Do you think we should re-baseline the night quota system in the longer-term?

It might simplify presentation but is unlikely to make any difference in practice

40/ What factors should we consider when anticipating how to best future proof a re-baselined QC system?

Cease using the EPNdB metric

41/ What costs, if any, would you anticipate in re-baselining the QC system?

Not known

42/ Would you be impacted if the NQP was extended to 23:00 to 07:00?

Yes

43/ Provide evidence to support your view.

We might get a chance of uninterrupted sleep if there were no flights between these hours!

44/ Do you think night flights in certain hours of the NQP have a greater impact on local communities than other times of the NQP?

Yes

45/ Provide evidence to support your view.

Yes – but there should still be an uninterrupted period of 8 hours sleep. Sleep will be disturbed whether the person is woken at midnight or 4am. The evidence is the number of people affected by this.

46/ Would a mechanism that disincentivises aircraft movements in periods of the night that are more sensitive for communities impact you (provide evidence to support your view)?

Yes

47/ Provide evidence to support your position

Abolition of night flights for the reasons given. If not that then some real financial disincentives (and by that we mean large penalties which will hurt) should be introduced and should be related to noise on the ground, not some allotted QC category

48/ What would be the impact on you if QC4 rated aircraft movements were banned between 23:00 and 07:00 after October 2024?

Difficult to say when the noisiest aircraft flying now is a QC2 aircraft, noisier than the QC4 aircraft!

49/ What would be the impact on you if a scheduling ban was placed on QC2 rated aircraft movements between 23:30 and 06:00 after October 2024?

Potentially substantial but unlikely to be so in practice as Heathrow has so many “late runners” that scheduling seems to make little difference

50/ What would be the impact on you or your business if a scheduling ban was placed on QC2 rated aircraft movements between 23:00 and 07:00 after October 2024

Ditto

51/ If bans are introduced should the implementation be staged?

The ban should be outright

52/ Please provide evidence to support your position.

The ban should be outright so people can sleep! The WHO has produced very specific recommendations (“To reduce health effects, the GDG [Guideline Development Group] strongly recommends that policy-makers implement suitable measures to reduce noise exposure from aircraft in the population exposed to levels above the guideline values for average and night noise exposure. For specific interventions the GDG recommends implementing suitable changes in infrastructure”). Avoiding a total night-time ban on flights is nothing more than trying to avoid the “strong recommendation” of “implementing suitable changes in infrastructure” and avoid treating people properly

53/ In a future regime how should we manage the number of aircraft movements (detailing the airport or airports relevant to your view)?

An outright ban between 11pm and 7am since no commercial jet aircraft is going to get to 40dB Lnight

54/ In a future regime how should we manage an airports’ noise allowances (detailing the airport or airports relevant to your view)?

Not necessary if there is an outright ban. Otherwise relating to the above response on a transitional phase with penalties for noise measured on the ground

55/ Should we remove the movement limit and manage night flights through a QC limit only?

No. There should be an outright ban

56/ Provide evidence to support your view.

57/ Should we introduce a ring-fencing mechanism to ensure night slots are available for:

commercial passengers                 No

dedicated freight                             No

business general aviation              No

58/ Provide evidence to support your view.

59/ Should an airline be able to use unused allowances later in the season?

No

60/ If the government decided that unused allowances should be returned to the airport’s pool, what would be the impacts on:

• communities?

The carry over process should be removed. To sleep in one year and then be subjected to a year of intensive carry overs in the following year is hardly attractive!

• airports?
• airport users?
• airlines?
• business in and around airports?

61/ Do you agree or disagree that the current carry-over process benefits you?

Disagree

62/ Provide evidence to support your view.

The carry over process should be removed. To sleep in one year and then be subjected to a year of intensive carry overs in the following year is hardly attractive!

63/ What changes, if any, would you like to see to the carry-over process and how would this impact you?

Abolished along with night flights

64/ How fair a balance between health and economic objectives do you think our current night flight approach is?

Nowhere near a fair balance. There is clear evidence of harm to health. You yourselves acknowledge this. Heathrow do not have an international noise abatement procedure – just the miserable 4% climb that a fully loaded WWII Lancaster bomber could manage. There might be some justification for night flights if it were not possible to trade with other countries in the World, save by departing or arriving at night. That is not the case though. Night flights are done purely for the convenience of airports wishing to use themselves more intensively to increase their profits. Thus, to trade with Shanghai for example to arrive between 7am and 11pm there, a plane from Heathrow would have to depart between 7am and 1pm (assuming a 10 hour flight). For Johannesburg (say 12 hours) a plane could depart from 7am to 11am and then from 5pm to 11pm. Similarly, all these arrivals coming in at 4.30am and shortly after are planes being bunched up for people’s unnecessary convenience. Trade can continue as now, if there are adaptations as recommended by the WHO

65/ What are your views on the health impacts of aviation noise at night, including potential impacts on different groups in society (provide evidence to support your view)?

Very substantial. There are countless studies on this. Two recent ones are Munzel et al. and Saucy et al. (both uploaded)

Munzel et al study

Saucy et al study

66/ What are your views on the economic value of night flights, including the potential value on different businesses and aviation sectors (provide evidence to support your view)?

Nil value when you factor in the loss of productivity due to harm done

67/ What are you views on changes to aircraft noise at night as result of the COVID-19 pandemic (provide evidence to support your view)?

One of the few good things to come out of the pandemic for some people is the reduction in aircraft noise. However, the problem has not gone away since there is still excessively low flying and at Heathrow the two runway spread has been abolished in favour of using a single runway just for economic reasons without regard for the people underneath flight paths

68/ In your opinion what are the advantages or disadvantages that the emergence of new technology will have in relation to night noise from aircraft within the next 10 years (provide evidence to support your view)?

Some (but not all) planes are quieter than older ones. However, they are nothing like quiet enough. From Andersons attachment you can see that a Boeing 787 emits some 69dB compared to the WHO recommendation of 40dB. It takes just one noise event to wake someone up and there is difficulty in getting back to sleep

69/ Should we include a reference to night noise when we publish a revised aviation noise objective?

Yes

70/ What factors relating to night noise should we include if we do introduce a noise reference in our revised aviation noise objective?

No planes as the Balanced Approach would envisage compliance with WHO health objectives. If not how is it “balanced”? Otherwise a progressive program as we have said. Unless the law is going to be changed to the detriment of people affected, there is a positive duty upon the Government to regularly assess the effects of noise upon the communities affected (article 6 EU Regulation 598/2014). The Government is then obliged to follow the procedure laid down. The consultation process must ensure “openness and transparency” with interested parties who should include “at least local residents living in the vicinity of the airport and affected by air traffic noise, or their representatives and the relevant local authorities”. That will include most of London in the case of Heathrow

71/ Should the government set criteria for airport designation?

Yes

72/ What do you think are the:

• advantages to the government setting criteria for airport designation?

National control over environmental issues

• disadvantages to the government setting criteria for airport designation?

Very few although there could be greater costs in both regulation and increased standards, save businesses having to arrange their deliveries.

73/ What factors, if any, do you think we should consider when setting criteria for designation?

Noise measured on the ground (as opposed to a QC category decided on the EPNdB metric), night-time flights ban, emissions both pollution and climate change

74/ How should any criteria for designation be agreed?

It should be decided on whether the airport offers international flights

75/ What impact, if any, do you think the designation of an airport have on:

• communities?                   Reduced  noise, reduced pollution, climate change control
• airports?
• airport users?                    Improved facilities and standards
• airlines?
• business in and around airports?               Little effect, save businesses having to arrange their deliveries. For example, “just in time” deliveries might need transport from a regional airport, but with suitable infrastructure this should not be a problem.

76/ What impact, if any, do you think the de-designation of an already designated airport (Heathrow, Gatwick, Stansted) will have on:

• communities?

Substantial. Heathrow would run riot and do whatever it could to increase its business with little or no regard to the environment. In short, it would be disastrous for communities

• airports?
• airport users?
• airlines?
• business in and around airports?

77/ Any other comments?

The map of the noise contours for Heathrow is not thought to be accurate. Firstly, it should run for 8 hours to correspond with the 16-hour daytime period. The “Lnight” metric is defined as “A-weighted, Leq (equivalent noise level) over the 8-hour night period of 23:00 to 07:00 hours”. Secondly, even on a reduced 6.5-hour night period, it still cannot be correct. Twickenham and Teddington are not included nor are any other departure routes when we are bombarded at night with departing planes when on easterly take-offs. Thirdly, south and east London are not included, and they are bombarded with daily overflights on easterly arrivals/westerly take-offs from 4.30am. The absence of these illustrations indicates more than simply averaging out on the LAeq metric. There is something seriously wrong with the map. It may be based upon incorrect modelling.

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