Response to Night Flights Consultation

I wanted to share with you my response to the Night Flights consultation.


I am writing on behalf of local residents in my capacity as MP for Putney, Roehampton and Southfields.

Noise from aircraft is a major cause of concern for our community and the noise from aircraft at night is of particular concern. Residents regularly get in touch with me about the constant and significant disruption to their sleep from planes landing at Heathrow from as early as 4am. Many find it difficult to then get back to sleep before the next plane comes in. With aircraft landing as late as 11.30 pm, it means that in practice residents only get about 5 hours respite from noise each night and many say that affects their health and well-being. The impacts of persistent interrupted sleep are well known, most recently documented in the 2016 Aviation Environment Federation report ‘Aircraft Noise & Public Health: the evidence is loud and clear’, so it would make sense to minimise and ideally remove this issue if possible.

In relation to our own local community, our view is that a ban on night flights should be introduced immediately or gradually as part of the next regime currently proposed from 2017 to 2022. A night flights ban is a commitment as part of the permission for Heathrow to expand.

The Government announcement rightly recognised the impact of night time aircraft noise from night flights by stating: “....they still have an impact, which is why we will expect a six-and-a-half hour ban on scheduled flights each night to be a requirement for development consent. That would also see the airport held to clear and legally enforceable noise performance targets. ...". I welcome the Government's acceptance finally that a ban on night flights is necessary but believe that this policy should be proceeded with sooner not later.

In the past Heathrow has always been against any further restrictions on night flights. Even if a ban is now proposed for the future alongside expansion, this consultation presents an important opportunity to now demonstrate commitment to local communities under the flight path. We want to see the ban introduced in advance of any third runway and therefore the next restrictions should be the last required through including the phasing out of night flights by the end of 2020 at the latest.

As the DfT will be aware, the whole issue of Heathrow and its expansion has been characterised by little trust between local communities and promises made by Heathrow in relation to noise pollution. The planning consent for a fifth terminal came with an express condition of no third runway, which is not being adhered to.

Many of my constituents are deeply sceptical that Heathrow will ever be prepared to introduce such a night flights ban, but if put in place over this coming night flights regime, it would demonstrate some tangible commitment to residents’ well-being from the Department for Transport and Heathrow Airport Limited.

Overall pollution is already a significant problem for our community, with the air quality in Putney High Street of particular concern. Comments I have seen from constituents about this latest consultation mirror those from other consultations in relation to aircraft noise, broadly that the noise level from aircraft, particularly at night, remains unacceptably high. This latest consultation should not be another missed opportunity to address the issue of noise from night flights on behalf of the communities most affected by it.

In relation to the specific questions:

1a How strongly do you agree or disagree with our proposed environmental objective for the next regime?

Local residents generally do not agree with the continuation of the existing night flights as proposals. However, we agree that the use of quieter aircraft to limit the number of people affected by aircraft noise at night should be encouraged. Some constituents have commented that there should be a more robust system which would actively penalise airports that do not use quieter aircraft. 

The current proposals, however, only reduce Heathrow’s night noise quota to the level that it currently operates at, meaning there is no real practical change or improvement for our community from this measure.  By contrast, Regulation (EU) No 598/2014 indicates that measures should be taken within the Balanced Approach to improve the noise climate.  One of the new environmental objectives in this consultation states that “the next night flights regime at Heathrow should ensure therefore that the existing benefits of night flights at Heathrow are maintained, but also deliver the best improvement to the noise climate possible in the period before a new runway is in place”. However, this consultation is proposing that the effect of noise on local communities from Heathrow would remain the same as it currently is during the next regime.  We would like to see a more stringent noise quota in place that would actually continue to reduce practically the noise levels from aircraft and incentivise the continued use of even quieter aircraft, rather than simply bringing the noise quota in line with the noise levels under which Heathrow already operates. 

1b Do you have any additional comments on our proposed environmental objective for the next regime?

Most constituents would like to see an immediate ban on any night flights, or the introduction of a gradual ban over a final regime. They are concerned that even with the current night period of six and a half hours, there are unscheduled flights which overrun the scheduled departure from their destinations and therefore come into land at Heathrow during the night regardless of the current restrictions. Even that night period of six and a half hours still falls short of the World Health Organisation’s guidelines of a night period of eight hours.

I welcome the change in measurement to use a 48dB contour but this should be reduced still further to better reflect the impact on those who are affected by aircraft noise at night. The impact assessment of noise levels relied on in this consultation and previous regimes are out of date and from the 1999 World Health Organisation Guidelines on Community Noise.  The studies carried out for these guidelines were conducted in 1995 and as such the data this publication contains is over twenty years old and out of date.  The consultation recognises but ignores the recommendations from the 2009 World Health Organisation’s Night Noise Guidelines for Europe which indicates that populations should not be exposed to night noise levels greater than 40dB of outside noise, and instead point to the report’s interim target of initially reducing noise to 55dB.  Even this study is now nearly eight years old but it seems sensible that at, the very least, the more up to date 40dB limit suggested by WHO should be the standard used to measure impacts of noise pollution on communities which would rightly indicate that far more people are affected by noise from Heathrow Airport than this consultation suggests is the reality.

As a consequence of using out of date evidence, the noise contours drawn up in Figures 1 and 4 in Annex F do not accurately reflect the areas disturbed by noise from night flights which include our local community. It will be hard for informed decision making if the assessment of noise annoyance is based on something out of date and significantly less than the reality. This is of even greater concern going forward when new flight paths may be introduced as part of plans for a third runway and many more people will be affected by noise who are not yet aware that they will be.

The World Health Organisation is due to discuss further research on the effects of prolonged exposure to transport noise in April this year and I would hope that, given previous regime reliance on out of date World Health Organisation’s reports and guidelines, these newly published and up to date guidelines and data would be appropriately considered before finalising any recommendations for a new regime.

2a How strongly do you agree or disagree with our proposal for the length of the next regime?

It depends on the approach to introducing a ban which could be in place by 2020, in which case there would be no need for a five year regime this time, or for a further regime at all.

2b Do you have any additional comments on our proposal for the length of the regime?

The WHO 2009 report clearly identifies 40db – 55db (as set out in the evidence based section of the consultation) yet the consultation mapping does not reflect this, or drive government analysis, which would seem to be a shortcoming of the consultation approach.

3a How strongly do you agree or disagree with our proposal to introduce a new QC/0.125 category for aircraft to remain between 81 and 83.9 EPNdB?

I welcome the introduction of this new category which should mean that no aircraft that uses Heathrow at night will be exempt from the movements limit.

3b 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?

It is important that all aircraft quieter than this still count towards the airports movement limit as it is clear that the overall on-going noise from aircraft contributes towards residents’ experience of noise and sleep disturbance. It only takes one aircraft to wake up residents and, as this consultation states, “no aircraft can be completely silent” and “even the quietest commercial aircraft that will operate in the next few years will still produce noise levels which could lead to sleep disturbance”. It is also important that any outstanding discrepancies between assessed noise and actual noise from aircraft are investigated and confirmed. 

3c Do you have any additional comments on proposals for the Quota Count System?

I believe that the Quota Count System is important and should continue to be used as a means of placing pressure on airlines to continue to introduce quieter aircraft.  However, these new limits would largely reflect the existing slack in the system rather than driving down future noise. There are no significant penalties to breaches in practice, either for the aircraft operator or the airports for flights that breach noise limits in any way.

4a How strongly do you agree or disagree with the proposal for movement limits to remain unchanged at Heathrow?

Our community would like to see a ban on night flights brought forward. Although there was significant work on monetising the economic benefits, little, if any, comparable work has gone on in relation to monetising environmental costs.

4b Do you have any additional comments on our proposal for Heathrow’s movement limit?

I would like to see a regime that ensures a guaranteed respite period for residents and an end to night flights between 11pm and 6am. The current proposals appear designed to reset noise limits to match current levels rather than address the problem of noise. Heathrow Airport Limited has already said it could provide a six and a half hour night flight ban before any third runway becomes operational which suggests that there is sufficient resilience now to enable a ban to be delivered now, in advance of that, without undue harm to the airport.

It would seem that detailed cost-benefit analyses do not appear to have been carried out for different scenarios at each airport, for example an 8 hour night ban or a 7 hour night ban. 

7a How strongly do you agree or disagree with our proposals to encourage the use of quieter aircraft at Heathrow?

The proposals are sensible but ultimately there are no real sanctions, just a commitment to ‘encourage’ quieter aircraft. It seems unviable to rely on Heathrow to police its own customer airlines effectively in adhering to the night flight noise regime.

7b 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?

I believe that we need better assessment and monitoring of noise, ideally by an independent body, to ensure that local communities are protected effectively from the negative impact of noise on their lives. Strong enforcement needs to be in place so that airlines which breach the noise restrictions face significant sanctions or, if necessary in the case of persistent breaches, ultimately are no longer be allowed to use the airport. There is little credence in Heathrow wanting to be a "good neighbour" when there is no ability to deal with antisocial behaviour when it regularly happens from airlines and, realistically, it has a conflict of interest in that those breaching noise limits are its customers from whom it benefits financially.

Yours sincerely,

Rt Hon Justine Greening                                            
MP for Putney, Roehampton & Southfields