Response from Broxted Parish Council to the DfT Consultation Document:
"Night Flying Restrictions at Heathrow, Gatwick and Stansted – Stage 1 of Consultation on Restrictions to apply from 30 October 2005"
Letter to DfT dated 26 October 2004
Department of Transport,
Aviation Environmental Division 2,
Great Minster House,
76 Marsham Street,
London SW1P 4DR
Night Flying Restrictions at Heathrow, Gatwick and Stansted
Stage 1 of Consultation on Restrictions to apply from 30th October, 2005
Broxted is a small, scattered village to the north-east of Stansted Airport. The parish is situated less than ¼ mile from the airport perimeter and all aircraft movements take place over the village. Aircraft noise and ground noise are of considerable concern to local residents and they welcome this opportunity to suggest ways to ameliorate the inconvenience caused by night flying.
The comments in this response are with regard to Stansted airport only.
The view of Broxted Parish Council (BPC) is that night flying should be allowed only in exceptional cases. Quotas and restrictions give the impression that night flying is acceptable if it is controlled and monitored - this is not the case. The aviation industry should take responsibility for the inconvenience it causes and accept restrictions on night flights.
Broxted Parish Council would like to make three general points in addition to the specific questions raised in the consultation document.
Firstly, the consultation document is a very ‘technical’ paper, and a great deal of its contents cannot easily be understood by the layman. BPC's responses to the questions raised are, therefore, based on its understanding of the current position and its hopes for reducing or eliminating the noise and inconvenience that is presently being suffered. It is to be hoped that the Stage 2 consultation document will be less technical, or at least contain summaries that can be understood by the layman.
Secondly, the Government's White Paper on the Future of Air Transport states that it would ‘bear down on night noise’ but there is nothing in the Consultation document that would indicate that this is a priority aim. Throughout the paper the intention seems to be to accommodate the aviation industry regardless of the implications that night noise has on residents near to the airport.
Thirdly, if the Government accepts, in principle, the WHO Guidelines for Community Noise, then it is wholly unacceptable to suggest that those guidelines will be phased in over a 30 year period. Action should be initiated immediately, with a view to having total compliance as quickly as possible. If the will is there BPC sees no reason why this process should take more than ten years, in any case a start must be made straightaway. This review gives an ideal opportunity to make that start.
With regard to the specific questions:
Question 1: Other matters in addition to those set out in para 2.4.
BPC remains unconvinced that there is an unarguable commercial case to justify many of the night flights. It would like to see research into the consequences of a total ban on night flying. It feels that too little regard is paid to the effects of noise, especially in a rural area, and particularly on the young and the elderly. There should be an independent monitoring of those effects. The principle of ‘the polluter must pay’ should be enforced and take into account noise pollution.
Question 2: Comments on assessments in Annex B of the Consultation Document.
A large proportion of cargo flights takes place during the NQP. Whilst accepting that a proportion of this will be mail and newspaper flights BPC feels that ordinary cargo flights are the most easy to schedule during the day, and would wish to see a ban on non-essential cargo flights at night.
Question 3: Comments on presentation of contours etc in Annexe C
BPC would question the predicted rate of growth at Stansted. It feels the present rate of growth is unsustainable and that future predictions are optimistic. It finds much of the information in this annexe complex and difficult to understand.
Question 4: Comments on environmental and noise abatement objectives.
As stated above, the WHO recommendations should be implemented as quickly as possible. Special consideration should be given to Stansted, which is set in a rural area where there is little ambient background noise. A timetable should be produced to steadily reduce night flights.
Question 5: Should the QC system for classifying aircraft be retained.
Yes, but as stated above, a timetable should be developed to achieve the WHO guidelines as soon as possible.
Proposals to remove the weight limit on aircraft able to qualify as exempt and extend the QC system downwards by adding a further band.
Provisionally in favour, but there is concern that a large increase in ‘less noisy’ aircraft would ensue, and that this would be as intrusive.
Retain the minus 9EPNdB adjustment for arrivals.
The majority of movements in the NQP at Stansted are arrivals and, although quieter than take-offs, they are still a considerable nuisance. The majority of movements between 0600 and 0700 are departures and these are particularly intrusive. BPC feels that more research is required to ascertain if the adjustment is accurate.
Prohibit QC/4 aircraft from operating between 2330 and 0600.
BPC feels that there should be a total ban on these aircraft during the NQP. Furthermore it feels that, with regard to Stansted, the NQP should be extended to at least 8 hours. As stated above, this airport is situated in a rural area where the background noise of the day, such as it is, begins later and ends earlier than in more built up areas.
Common arrangements at the three airports.
BPC feels that there should be a continuous ‘bearing down’ on night flights, and that there may need to be a different regime at each of the airports.
Retaining the same Night Quota period at the three airports
BCP feels that the NQP at Stansted should be extended to at least 8 hours and would suggest 2230 to 0630 with a Night Period of 2200 to 0700.
Question 8 a) and b):
Given the rural location of Stansted and the almost total absence of ambient background noise, full consideration should be given to extending both the Night Period and the NQP.
Question 9: Further suggestions on the control of movements during the NQP.
As stated above the NQP should be extended, and effective measures taken to reduce the number of flights occurring during the shoulder time. This is particularly annoying in the late evening period with aircraft arriving every two or three minutes for an hour or more. This is particularly disruptive to the sleep of children.
Vice Chairman - Broxted Parish Council