SASIG response to The Airports Commission Discussion paper 5, ‘Aviation Noise’
As set out in submissions SASIG has already supplied to the Commission, assessment of existing, and any new, aviation capacity must be predicated on an improved economic assessment such that a comprehensive, agreed methodology for calculating the economic value – in its fullest context, yields robust output for capturing the assessed economic gain.
In the context of aviation noise, such an improved economic methodology would inform the extent to which economic benefits can be maximised as it would have taken account of:
- compulsory purchase of properties, along with the associated loss of community;
- opportunity costs of sterilised land, i.e. reduced or zero development potential due to noise impacts;
- mitigation & compensation payments for noise impacts; and
- social cost of noise-induced health and welfare impacts.
This makes aviation noise impacts an integral element of looking at the UK aviation industry – not an after-thought to simply be dealt with through mitigation and compensation.
A greater understanding of the community response to aviation noise is an essential prerequisite for an improved aviation noise management and reduction regime. We recommend that the Government resource annual studies in order to inform, educate, advise and report this relationship, supplying robust annual surveys capable of supporting policy-making.
In this context, the ‘Government’ should at least include the Department for Transport (DfT), Department for Environment, Food & Rural Affairs (Defra), Department for Communities and Local Government (DCLG) and Department of Health (DoH). In addition, an appropriate way in which to involve the Research Councils and academic institutions should be considered.
At minimum, liaison with other Government Departments – Business, Innovation & Skills (BIS), Department of Work & Pensions (DWP) and HM Treasury (HMT) – is needed on the social and economic costs of aviation noise.
The metrics used to describe noise impacts on which noise management policy is founded must more accurately cover the affected populations, and illustrate the burden of aircraft noise. SASIG welcomes acceptance by the Government and the Commission that more people are annoyed by lower levels of aircraft noise than was previously understood to be the case.
Noise representation and analysis must be based on use of the ‘worst mode’ operations, as people hear each individual event and reply when questioned about their response to noise on the basis of the most disturbing, intrusive, disruptive events. Beneficial features such as regular, predictable periods of respite, operational techniques such as alternation of runway usage, etc. are valuable; however, they do not adequately address the negative impacts on people of aviation noise exposure.
Additional research is supplied for the Commission that shows the way in which levels of aircraft noise annoyance are underestimated by the current assessment process for airspace change processes; and the aims of the Government’s social response project, ANASE, that remain unaddressed.
Additional research is also supplied in the form of a recently published paper that may be valuable for progressing the debate about the monetisation of noise impacts, as well as showing how the ANASE study assists with this.
The advantage of LAeq noise contours in terms of the ability to make historical comparisons should not be lost, i.e. data for LAeq contours should continue to be collected and presented. However, the 57dB LAeq metric should have reduced prominence in policy-making on the basis of the acceptance that more people are annoyed by aviation noise at lower noise levels than was previously understood1, and the fact that people do not experience noise in an averaged manner.
Additional metrics and means of illustration should be applied in policy-making. For instance, ‘number above’, ‘frequency’ and ‘location specific’ measurements are useful as they reflect the fact that the number of flights is a factor in the annoyance response of the population affected adversely by aviation noise, along with a means of illustrating the aviation noise burden at given locations.
‘Noise efficiency’ scores should not be used in the noise debate. These scores could be used to compare activity at different airports, however, they do not inform comparisons of noise burden because: (i) they are based on the flawed 57dB LAeq metric; (ii) they incorporate numbers of passengers, which varies with load factor and type of aircraft but does not accurately represent numbers of flights, which is the vital element; and (iii) they do not take into account either the population spread, nor the ambient noise levels, around an airport – both important considerations when assessing aviation noise.
Flightpaths should not be moved from the existing noise preferential routes (NPRs) without full consultation of the communities affected. Whether concentration on specific paths within NPRs or dispersal routes across NPRs is preferable will vary between airport locations and between NPRs. These operational measures should be determined locally, for each airport, in accordance with the communities affected. It must be recognised that different policies will be needed at different airports.
An effective ‘noise envelope’ is one that reduces actual noise impacts, thus any application of this concept must be in a manner that reduces the actual noise burden experienced by communities, not simply in a manner that tracks upwards with increasing activity in the absence of a meaningful improvement in the noise climate.
Another issue omitted from the Discussion Paper is that of noise from helicopters, despite the need for tailored regulation and policy: statutory noise controls; bespoke modelling, covering the affected populations; UK-wide monitoring; incentives to phase out ‘noisier’ helicopters; and local regulations to be established through heliport consultative groups to reduce impacts on communities.
Ultimately, where clear gaps have been identified in the evidence needed to inform policy-making, not only should these gaps be filled, but in the meantime there should be a presumption in favour of the precautionary approach, applied relevant to each situation, in order to account for this lack of information.