Written evidence submitted by the Putney Society (HEN0070)

The Putney Society is the civic society for the residents of Putney and Roehampton.  Putney is a generally pleasant suburb, but we suffer substantial impacts from aircraft noise, as the approach to Heathrow`s southern runway (nine miles to our west) passes over the northern part of Putney, and the approach to the northern runway is also close.  At present, Roehampton suffers less severely.  In this evidence we will focus on  noise impacts, so responding in part to heads (d) and (g) in the Committee`s call for evidence.

The government consultation is in our view seriously deficient as regards noise impacts.  Many of the most important impacts are either not spelt out or will not be known until the current airspace re-design project is further advanced.

Significant cut in respite periods

At present we, and the other communities lying under the approach paths to Heathrow, enjoy a respite from aircraft noise for half Heathrow`s operating day, as landing aircraft switch between the northern and southern runways at 3pm each day.  Under the plans for three runway operation, aircraft will be landing on the southern runway for three quarters of the operating day on average.  So our respite period would be reduced from half of every day to a quarter of a day on average.

It is deplorable that the consultation doesn`t spell out this key change at all.  It only becomes apparent from para 2.13 of the draft HENPS Appraisal of Sustainability Noise Annex that with three runways the southern runway would be used a quarter of the time for departures, a quarter of the time for arrivals and half the time for a mix of both arrivals and departures.

Even Heathrow Airport Limited accept that the nine hours a day respite is greatly valued by all the impacted communities. Our view is that halving our respite is totally unacceptable.  We consider that the National Policy Statement should include a guarantee that all the affected communities should continue to have a period of respite for at least half Heathrow`s operating day.

This issue could well be affected by the work which the National Airspace Design Service are currently doing on a major airspace re-design, which could be implemented by about 2032.  We suspect the plan is in fact to retain nine hours a day of respite for most of the impacted communities, including Putney, by introducing additional approach routes which would converge with the existing straight-line approach somewhere closer to the airport. 

However, new approach routes would mean that aircraft noise would be inflicted on communities which do not currently suffer from it.  And this could well include areas such as Putney Vale and Roehampton if a new approach over Wimbledon Common and Richmond Park is chosen. 

A second major problem is that communities living closer to the airport, to the west of where a new route converges with the existing approach (likely in the Richmond area) would not receive any benefit from the new route.  So their respite period would be cut from nine hours a day to four and a half hours on average.  Of course, these areas are also those where the noise is particularly loud and obtrusive, because the planes are lower.  Similar problems will also apply to people living under the approaches to the proposed third runway, and could also apply for some years to people living under the approaches to the existing northern runway.  We cannot conceive any satisfactory mitigation for these circumstances, but would suggest that a package of acoustic insulation, air conditioning and monetary compensation should be regarded as a minimum requirement, and in the most severe cases a relocation package should be offered to the families impacted.

Again, the draft Policy Statement and the consultation say virtually nothing about any of this.  And we probably won`t be told anything more about new approach routes until the government consults on its airspace re-design proposals  We don`t even know when such a consultation might happen – maybe 2028, maybe 2029?  In our view it is essential that the airspace re-design consultation should be completed, and final decisions published, before a third runway promoter submits a planning application, for a very simple reason: until the airspace design has been fixed, we cannot see how the runway promoter would be able to conduct an adequate noise appraisal.  The noise appraisal supporting the draft HENPS is seriously deficient because it assumes no new approach routes, when it is clear that such new routes are one of the leading objectives of the airspace re-design project.

All this means that the government is asking Parliament to vote upon HENPS before they reveal where the greatest noise impacts will fall.  This puts many MPs in a rather difficult position.  All MPs whose constituency lies either under an existing approach (or departure) route, or under a possible new route, will not know whether their constituents will or will not suffer a seriously greater detrimental noise impact.

The government`s four tests

Aircraft noise is one of the Government`s four tests to be applied to Heathrow expansion.  The content of those tests has never been spelt out, until now.  Sadly, the test proposed regarding noise is so feeble as to be completely worthless.

The proposed control is that the noise impacts of Heathrow with three runways should be no greater than the actual impact level in 2024.  That may seem a fairly demanding target.  But it actually is not at all challenging.  The evidence for this conclusion is, again, buried deep in the detail of the AoS Noise Annex, which spells out, with admirable clarity, that large ongoing reductions in aircraft noise are absolutely guaranteed, as airlines replace their older aircraft with more modern and less noisy types.  And the next generation of new aircraft will be quieter still, for sure, because the manufacturers will always strive to reduce their fuel consumption, which means less fuel is needed for each flight, so less weight, so the engines can be smaller and lighter, and so the plane is quieter.

The noise appraisal concludes that the government`s proposed limit will easily be achieved, even on pessimistic assumptions, and without any effort at all from the government or Heathrow Airport.

We propose that a more demanding limit should be imposed, namely that the noise impacts of a three runway Heathrow should be no greater than the forecast future impacts of a two runway Heathrow.  That would mean a considerable absolute and ongoing reduction in the noise impacts.  Using the 43 dB LAeq 16h metric (for the reasons set out in para 5.14 of the AoS Noise Annex), the areas affected by this level of noise would be limited to 881 square kilometres in 2035, 710 sq kms in 2045 and 591 sq kms in 2055 (see Table 5-3 in the AoS Noise Annex).   Even these more demanding targets might be fairly easy to achieve; it is difficult to judge this until after a more satisfactory noise appraisal has been done, taking account of the airspace re-design conclusions.

The government`s proposed test, of the total noise impact being no greater than in 2024, would mean that up to 4,650,000 people would be affected by this level of noise, which would mean that nearly half a million people would be expected to be seriously annoyed by Heathrow aircraft noise.  These enormous numbers are a striking indication of just how appalling Heathrow`s existing noise impacts are.  The government should be seeking a considerable reduction in those impacts, rather than allowing them to be perpetuated for almost three more decades.

Ban on night flights

We acknowledge that the government is proposing one substantial mitigation, namely a ban on night flights.  Such a ban was recommended by the Airports Commission in 2015, and is incorporated in the existing Airports National Policy Statement which Parliament approved in 2018.

The new draft HENPS also includes a ban on night flights.  However, what it offers is too little and too late.  The government is proposing a ban for six and a half hours each night, the same as the 2018 policy.  We don`t know which hours this would cover: the 2015 Airports Commission recommended 23.30 to 06.00, but Heathrow Airport prefer 23.00 to 05.30.  Yet again, the draft Policy Statement says nothing about which hours, so we expect Heathrow will propose 23.00 to 05.30.

We think that the ban should be for seven hours a night, from 23.00 to 06.00. This would not be disruptive, as it is already the case that there are no flights scheduled to arrive or depart after 23.00; and before 06.00 there are only 16 arrivals and no departures.  But the great majority of people need more than six and a half hours sleep a night.  In fact a lot of people need eight hours of sleep, so we would prefer a night flight ban to be extended to eight hours as soon as that is feasible.

The draft policy statement does not appear to say when a night ban should come into force.  The relevant sentence just says “to be implemented”, full stop.  This is an astonishing omission.  We suspect that the government intend the ban to come into effect when a third runway opens. 

We think that the night ban should be implemented at a much earlier date.  The Airports Commission studied the night flights issue in considerable depth, and concluded that the only obstacle to a night ban is that at present Heathrow has no spare capacity in the daytime, so it would be very difficult to find new slots for the 16 daily arrivals which would be displaced from before 06.00.  So our view is that as soon as there is enough daytime capacity, and this could happen in the early 2030s, a seven hour ban should come into force.  If and when a third runway opens, this ban should be extended to eight hours a night.

We would like to emphasise three points about our proposal for a seven hour ban.  The first is that the 16 flights which arrive between 04.30 and 06.00 are exceptionally disruptive, waking people from sleep and/or preventing them from getting back to sleep.  Sleep deprivation damages people`s health, and it also damages their economic productivity, because their concentration and judgement are impaired.  Moreover, this disruption is particularly severe on hot summer nights when people need to keep their bedroom windows open in order to sleep.  Sadly, it seems clear that as global temperatures continue to rise over the coming decades (with aviation being a major contributor), the incidence of tropical nights in London is going to carry on increasing for a very long time to come.

The second point we would like to make is that the 16 arrivals won`t be lost, they will simply be shifted to slots during the day, so there will be little or no economic loss.  And the seven hour ban we advocate would not require any more daytime slots than the ban proposed by the Airports Commission.

The third point is that the new approach routes which are likely to form part of the airspace re-design are being introduced in order to facilitate a more intensive use of Heathrow`s existing two runways prior to any third runway opening.  The more intense operation, which could commence in the early 2030s, will generate additional slots, a small proportion of which will easily suffice to accommodate the 16 arrivals displaced from pre 6am.  Introducing a seven hour night ban at this point would be especially beneficial, because it would mean that the communities living under the new approach routes would at least have the consolation that they would not have to suffer night-time disturbance as well as daytime aircraft noise.

Steeper descents

As well as a ban on night flights, we want all planes approaching Heathrow to follow a steeper descent approach.  This would mean that when the planes pass over Putney they would be considerably higher in the sky, and so a good deal quieter as experienced by people down at ground level.  A similar benefit would of course accrue to all the communities living under the Heathrow approach routes. We accept that the details of this will need to be worked out in the airspace re-design which is currently under way. But we do think that the National Policy Statement should give a firm commitment to the principle of steeper approaches. 

Steeper approaches would deliver a significant reduction in the areas, and the numbers of people, affected by any given level of aircraft noise.  It is quite conceivable that this measure alone could deliver even the more demanding overall noise targets which we advocate above, let alone the feeble target proposed in the HENPS.  This reinforces the importance of finalising the airspace re-design before embarking on appraising the noise impacts of a third runway proposal. . 

Our overall conclusion is that the draft HENPS is feeble as regards noise impacts.  This is disappointing.  It is also surprising, because we are not talking about a few NIMBYs.  Rather, if the government persists with its current policies, millions of people will continue to be impacted.   And at least many hundreds of thousands of these people (and quite possibly over a million, we simply don`t know) will suffer serious adverse impacts as a result of the proposed Heathrow expansion, either thanks to a new approach route being imposed over their heads, or through loss of much of the respite from aircraft noise which people currently enjoy and value.  It is surely likely that a substantial proportion of the people in these two categories will be seriously annoyed.,  We would suggest that the government should, at the very least, be doing everything it possibly can to make those impacts less severe.

In summary, we are calling for:

●        guaranteed respite from aircraft noise for at least nine hours a day;

●        a condition that the total noise impact of a three-runway Heathrow should be no greater than the currently forecast impact of the airport without a third runway;

●        a seven hour night flight ban as soon as daytime capacity allows; to be extended to eight hours if and when a third runway opens;

●        a commitment in principle to steeper descent approaches.

July 2026