ACR0052
Written evidence submitted by Communities Against Increased Aircraft Noise
1. This shows by the governments' own measurements and from the Airports/Davies Commission's own work that an expansion of Heathrow will produce less than £10 billion of economic benefits over a cumulative 50 years. In fact, the absolute number could even be negative:
http://www.aef.org.uk/uploads/Economic-impact-of-expansion-under-a-carbon-cap-FINAL.pdf
2. We have been given a "No Ifs, No Buts, there will be no expansion at Heathrow Airport" guarantee from the Primwe Minister:
https://electionleaflets.org/leaflets/full/52186/
3. The ICAO is responsible for setting noise certification methods. There is unfinished work required to improve matters, as described in CPRE Kent's response to the Davies Noise Discussion, shown below. As the UK was supposedly chairing this process it should be easier to get real change and to more accurately reflect what people are genuinely suffering. something the airline/airport industry are deliberately suppressing.
Relationship of ICAO certification Noise Levels to actual in-use noise levels
The HACAN Response to the CAA Consultation on Future Airspace Usage15 referred to: 'a letter from Dr Darren Rhodes of CAA/ERCD, 10th March 2005 saying that: '...ICAO is currently reviewing the noise certification process; the UK is chairing this task. Whilst this is naturally a long-term initiative, one item identified is consideration of a possible supplementary approach noise certification point more distant from the airport, where the aircraft would be in a configuration (different from that) required by the current demonstration test.' Subsequently, we understand, the ICAO work was discontinued at the request of the industry. It should be restarted.'
For approach noise, the ICAO certification is based on testing the noise the plane makes at a monitor 2km from touchdown - i.e. in the vicinity of the airport. That may not be appropriate to discriminate between planes for communities who suffer disturbance from approach noise at considerably greater distances from the airport.
The Committee on Aviation Environment Protection (CAEP) 7th Meeting, Montreal, 5 February 200716, included the 'Report of WG1 Task concerning the future of the Noise Certification Scheme', and as Dr Rhodes suggests,
it appears that the WG agreed that the current classification system does not work well for points "more distant from the airport" ,(page 22/55:
“4.5 For arriving aircraft there are two locations at which significant numbers of people are highly annoyed, between 0 and 3 km and between 9 and 12 km. The certification point at 2 km is representative of the first location. The group recommends that the “problem” of noise arising from arriving aircraft at locations far away from the airport be studied by WG2. “ A report from the WG2 on this inconsistency has not been found.
The data showing very little difference between approach noise from the A380 and 747 planes over Barnes and Chiswick proves that there is a serious issue with the current ICAO certification relating to new, and supposedly less noisy planes. This also confirms previous CAA work which showed that aircraft of similar Certification rating could have noticeably different noise emissions in actual use.
15 www.hacan.org.uk/resources/.../caa.airspace.response.from.hacan.pdf )
16 http://www.tc.gc.ca/media/documents/ca-opssvs/caep7_wp34.pdf
4. In statements like "“Airbus’ 21st century flagship A380 is the quietest long-haul aircraft flying today, generating 50% less noise on departure than its nearest competitor – all while carrying 40% more passengers.”, it is important to remember that the industry means 50% less noise energy (i.e. a 3dBA reduction). Because human hearing is non-linear in response to noise energy, this is the minimum difference in noise level which we can perceive in the real world. (we manage 1 dBA under laboratory conditions).
To be 50% quieter, the noise energy would have to be reduced by about 90% (10dBA) which is probably impossible and certainly so without a fundamental redesign of aircraft.
Two other points to note:
i) Manufacturers design to both the ICAO certification method and the UK's QC system for night flights at Heathrow, probably its only significant (but minimal) effect.
ii) ICAO's "Chapter" noise classifications permit larger aircraft to emit more noise to achieve the same rating as smaller ones.
5. Other than in Heathrow-commissioned polls, in reality polls the British don't want expansion at Heathrow, full stop. Nor at Gatwick, either, but in a new location altogether. The best places would be in the Thames Estuary or, more boldly, and taking a 100-year plus bold and strategic view, in the Midlands and then have a HS2 hub there, linking the Northern Powerhouse to the rest of the UK to it, with links to the NE/NW/SE/SW of the UK from this new super-hub.
6. The new programs of noise abatement are simply box-ticking and have no discernible difference to noise on the ground. The trialling of a 3.2 degree aircraft arrival glide scope from the current 3 degrees is one such case in point. To see the difference, simply walk 385 metres against the flight path and your noise reduction 'difference' is realised. Less than 1 dB(A). And no-one can control this either. This is simply another smokescreen for the bystanders & others easily-fooled to demonstrate efforts being made by the industry to abate noise.
It's simply following a world-wide blueprint handbook “Building an airport and keep the protest small. Follow the checklist here" Our colleagues in Frankfurt and the USA have had exactly the same situation. It doesn't work.
All, As requested, please find a list of potential topic areas for any formal response to the Davies Commission report.
Although some are relevant to the Airports Commission, it is clear that Davies has not heeded many aspects and the commons select committee will be a new audience to re-fire certain aspects that Davies has seemingly chosen to ignore. Personally I see no danger in utilising anything relevant as to why LHR must not be given the green light:
7. Why Heathrow expansion will never be the answer:
- Noise anger, resentment and disruption has been badly and unreliably estimated and gauged by the Airport Commission report and must be robustly dependably and permanently resolved. This can only be genuinely done by relocating Heathrow Airport.
- Air and noise pollution has severe consequences on heart health
- Congestion
- A sticking plaster to apparent 'demand' however much the 'predict & provide' model is tuned up
- Massive public subsidies required
- Not a UK-wide benefit, quite the reverse as it'll consume public investment and cannibalise emissions allowances from other UK business & airports therefore preventing their future expansion
- Continuing low/no taxation stifles the growth of high speed inter city & inter continental rail competition, which is less emitting
- The 'chameleonic' adaptation of Heathrow's submission to suit the audience. For example, 'up to' 180,000 new jobs and 'up to' £211 billion were supposed to be achievable, yet the apparent 'jobs' figure has now dramatically been reduced to 70,000 which is still considered a 10-fold estimate of what is likely to materialise. This was presumably in response to the concern over available housing infrastructure, yet the purported 'economic benefits' were extrapolated from its' data. It cannot have it both ways.
- Airport competition - initially BAA was broken up & now a new virtual (privately-owned) monopoly will be re-imposed
- Actually leads to a jobs deficit rather than surplus - read http://www.aef.org.uk/uploads/Airport_jobs___false_hopes_cruel_hoax.pdf
- Heathrow's operations ought to be subject to external audit (to see whether full at all) and competition - flight patterns looked at (some destinations flown to over 30 times every day, 30% empty planes, cheapest flying is done by flying more miles, not less, to the same destination, freight can happen from any airport, grandfather rights & non-freeing up of slot allocations, 75% of flights are short-haul etc etc) This will prove that the airport is actually not full, or doesn't need to be so but chooses to be.
- The Davies recommendations are already being unpicked by Heathrow, and that's before the government make their decision on the airport. If the government were to announce such a move, every one of the other recommendations will slowly be refuted, circumnavigated, diluted or simply ignored, as the past 20 years of Heathrow promises have proven. Read http://www.foe.co.uk/sites/default/files/downloads/heathrow_broken_promises.pdf
- If the government does not make the right decision now for the whole of the UK and acquiesces towards LHR 3 (and irrevocably LHR 4) it will be the biggest peacetime mistake made by any UK government in history.
- The government must not take an expedient route but the right route for the UK. It must make a 100-year plus decision and realise that it must be built away from main conurbations. The Thames Estuary is one such place, however a super-hub could be located in central UK, with HS 2 directly linking the NW/NE/SE/SW of the UK giving HS2 a real purpose. This could also link into the current Northern Powerhouse. This can then possibly close one or more of Birmingham/Coventry/East Midlands airports (if desired). Ideally Heathrow as well, for much-needed housing space along with some light industrial, commercial & high-tech employment
8. Other Davies observations made by Colin Stanbury at LAANC:
The Davies report was heavily biased and contained serious gaps:
•The benefits methodology adopted by the Commission was flawed and dramatically overestimated the benefits. But even with 50,000 fewer job being created under the revised scheme analysis the burden being placed on all neighbouring authorities to build 5,000 new homes each to accommodate 70,000 new workers was impossible. That local unemployed would benefit from a jobs bonanza was also hotly disputed.
•There was incredulity that Sir Howard had allowed Heathrow’s claim to stand that the massive cost of surface access changes would be picked up by the taxpayer on the basis that improvements to transport infrastructure would be needed even without a third runway.
•Air quality claims in the report were considered beyond common sense. The suggestion that higher pollution on London’s Marylebone Road somehow lessened the impact of Heathrow on the UK meeting air quality targets was dismissed.
•The lack of information on Flight paths was a glaring omission which, in the view of LAANC would require yet another consultation. Many, many people who perhaps had little interest in expansion of the airport currently were about to impacted. The aborted flight path trials had proved that this topic alone could tie up a new runway for years.
•The lack of a freight assessment, another key omission, rendered the impact on local roads void.
•The recommendation that night flights should be banned under a Third Runway approval. Heathrow had already indicated it would not accept Sir Howard’s recommendation for a ban on night flights.
•The council rejected claims that, with two out of three runways operational at any time, controlled periods of respite would be possible as claimed. "Respite" will be reduced in practice.
3 September 2015