PPC Final Respose to Airports Commisssion Runway Capacity



Airport Commission Discussion Paper 07: Delivery of new runway capacity July 2014






John Cass, Chairman, Penshurst Parish Council, 7 August 2014




Chapter 2: Legal and Planning Issues


Question: What do you think of the options for securing planning consent on new airport capacity?


Q: Are there any others options that the Commission should consider?


PPC Response:


There is no obligation on the Airports Commission to endorse that any runways should be built.


In the interim report the recommendation is for one net additional runway to be operating in the South East of England by 2030 but this should not be considered as it cannot pass the environmental tests on noise, CO2 emissions, or economic balance within the UK regions as laid down in previous governmental White Papers. The aviation industry is already contributing a disproportionate amount of greenhouse gases in relationship to its contribution to GDP. In and close to the South East we have the highest concentration of airports in Europe: in a thirty-six mile radius we have Heathrow, Gatwick, Luton, Stansted, City, Southend and Biggin Hill Airports. Within this confined area around 140,000,000 passengers are being transported each year – many in transit.


Proposing Gatwick Airport for an additional runway in an area with one of the lowest unemployment rates in the country would create further division within the North – South divide encouraging government finance and infrastructure development away from deprived areas where unemployment levels are well above the national average and where development funds are most needed.



If an additional runway option proposed for the South East at Gatwick Airport reaches the planning stage then right-minded people will be shocked that commercial vested interest has once again prevailed over common sense. There is no gain for the vast majority of residents in these areas for additional runway capacity but so much to lose. There will be a huge drain on human resource outside of London which would mean a substantial mobility of labour; extensive building programmes in housing, schools and other related infrastructure developments particularly in transport much of which the beneficiaries (air travel industry) will expect to be financed from public funds.


If Gatwick was considered then many towns and villages in Surrey, west Kent and east Sussex would be blighted with no economic benefit but suffering disproportionately from noise nuisance of overflying aircraft and commercial loss due to drop in visitor numbers at internationally recognised cultural and heritage sites such as Hever Castle, Chiddingstone Castle and Penshurst Place. This area does not have the benefit that London has with so many historic buildings parks and other visitor attractions. Current flight movements at Gatwick Airport are already causing disruption to local tourism and loss of green space recreational value over the High Weald, a recognised Area of Outstanding Natural Beauty of which there are only 33 in the whole of England. It is also in these hills of the High Weald and in the tranquil river valleys and upper reaches of the rivers Rother, Arun, Medway, Eden and Ouse that are used for holidays and weekend recreations of hiking, boating, bird watching, horse riding, golfing and other quiet and peaceful pursuits. Many of its visitors, apart from local people in towns and villages, are day trippers from London and other built- up areas all seeking their own refuge from the intrusive noise of daily urban life. It is also a popular destination for our European neighbours. Any further increase in aircraft movements from Gatwick Airport would destroy much of the attraction of this area.


Positioning a second runway in South East is not a fair and equitable solution for an overriding majority of people.


Chapter 3: Local Communities

Q: What are the factors the Commission should consider in relation to local communities and the delivery of new airport capacity?


There seems to be little or no genuine engagement with local communities particularly from airport consultative committees which are often underrepresented by the wider community. This is contrary to the Airports Commission’s note at section 3 Under Local Communities. Commercial or local vested interests will often have an overwhelming presence on these committees. They appear ignorant of the true effects of noise nuisance from aircraft types and the distance from airports where communities are affected which in many cases can be twenty-five miles from touchdown. We also find that airports own consultation procedures are going through the motions but ignoring the opinion of the majority. Consultation processes are given government guidelines but no more than that – guidelines. There is no power of enforcement that we see in similar structures in Europe.


The weakness of the guidelines approach is clearly demonstrated in a letter dated 7 May this year sent to Sir John Stanley MP by the Rt. Hon. Patrick McLoughlin, Secretary of State for Transport, advising:

‘‘In the light of the publication of the Guidelines we have asked that all airport consultative committees were asked to review their terms of reference/constitution and their membership to ensure both they are consistent with the Guidelines and that they are representative of the current context of the airport. This includes making sure any communities that have been newly affected or affected to a greater degree by developments at the airport are, as far as possible represented on the committee. We understand GATCOM will be discussing this at a future meeting.’’

GATCOM did discuss this at the July 2014 meeting. The Kent County Council representative Mr Matthew Balfour requested of the chairman that a key stakeholder – Tunbridge Wells Borough Council, should have representation on the committee. The chairman replied that he ’was perfectly happy with the present arrangement.’ This endorses the claim of such committees failing to engage in a genuine consultation process and further amplified in the closing passages of the Secretary of State’s letter to Sir John:

’’However, I should make clear that the Guidelines are non-statutory and it is up to individual consultative committees to organise themselves according to local circumstances. I therefore have no powers to intervene directly in the running of airport consultative committees. The only statutory powers available to the Government in respect of airport consultative committees are in the designation of airports to have consultative facilities.

The above demonstrates how consultation procedures are loaded against those they are meant to help and play into the hands of the commercial avarice of foreign owned airports and their corporate shareholders. It is clear to the electorate that once again parliament has failed them and that is why issues such as additional runway capacity in the South East are likely to be the catalyst for dissent from disaffected voters across the political spectrum.

We have seen at Gatwick Airport, with regards to the London Airspace Consultation, that there has been little or no respect for the vast majority of stakeholders’ responses and in some cases key stakeholders views have been misrepresented. The process lacked vital information for an instructive view to be taken and the procedure had all the hallmarks of a vested commercial fait accompli. It is clear that Government has absolved itself from any responsibility in airport consultation processes and the electorate is angry. Decisions are being taken without the public’s true engagement. We believe that any announcement of a second runway in the South East will be met with significant protest from all groups with no barrier to age or political persuasion. The electorate will be determined to have its say.


Chapter 4: Role of the State

Q: What are your views on the potential roles of the state in enabling the delivery of new airport capacity?

Q: How can public and private sector interest be best coordinated to deliver new airport capacity as expeditiously as practicable?


The Airports Commission needs to focus on where the Role of the State has failed to engage with the CAA, airport management, airline operators and aircraft manufacturers to ensure that adequate energy sound environmental metrics actually translate to protecting the health of UK citizens and particularly children from the effects of continuous aircraft noise. This should have a higher priority than an agreement on funding and co-ordinating different elements for another runway which in any event should all be privately funded.


It will be seen that ICAO noise emission standards set down for aircraft certification and the resulting CAA Aircraft Noise Contour Model (ANCON) 57dBA Leq contour and its equivalents do not protect the public on nuisance and health impacts nor were they designed to. They were established to measure sound energy volumes in and close to airports. Communities, in some cases over twenty miles from touchdown and experiencing high volumes of jet engine and airframe noise, but less than the continuous 16 hour measurement, will not be shown within the contours. This will account for tens of thousands of people in the rural areas around Gatwick Airport but aggravated by the 10dB lower ambient noise perceived outside of towns and cities.


For too long the air travel industry, and the government, have sheltered behind the discredited ANCON metrics to allow uncontrolled expansion of flights and their noise nuisance. They are sleepwalking into potential medium and long-term health issues as forecast by the World Health Organisation that claims: ‘‘Noise is an underestimated threat that can cause a number of short- and long-term health problems, such as for example sleep disturbance, cardiovascular effects, poorer work and school performance, hearing impairment, etc.’’ It is also recognised:  ’’Impairment of early childhood development and education caused by noise may have lifelong effects on academic achievement and health. Studies and statistics on the effects of chronic exposure to aircraft noise on children have found: consistent evidence that noise exposure harms cognitive performance; consistent association with impaired well-being and motivation to a slightly more limited extent; moderate evidence of effects on blood pressure and catecholamine hormone secretion.’’


There have been a number of field studies in the UK on the effects on chronic aircraft noise exposure on children and we quote from The West London Schools Study conducted in 2001:




Children are a high-risk group vulnerable to the effects of chronic aircraft noise exposure. This study examines the effects of aircraft noise exposure on children's health and cognition around London Heathrow airport and tests sustained attention as an underlying mechanism of effects of noise on reading and examines the way children adapt to continued exposure to aircraft noise.


In this repeated measures epidemiological field study, the cognitive performance and health of 275 children aged 8-11 years attending four schools in high aircraft noise areas (16-h outdoor Leq > 66 dBA) was compared with children attending four matched control schools exposed to lower levels of aircraft noise (16-h outdoor Leq < 57 dBA). The children first examined at baseline were examined again after a period of one year at follow-up. Health questionnaires and cognitive tests were group administered to the children in the schools.


At follow-up chronic aircraft noise exposure was associated with higher levels of annoyance and perceived stress, poorer reading comprehension and sustained attention, measured by standardized scales after adjustment for age, social deprivation and main language spoken. These results do not support the sustained attention hypothesis previously used to account for the effects of noise on cognition in children. The reading and annoyance effects do not habituate over a one-year period and do not provide strong evidence of adaptation


When airports and airlines are taken to task by members of the public over aircraft noise they are often advised that the investigation has found the aircraft concerned was operating within the permitted rules. It appears there are few rules except that aircraft should operate within ICAO standards which are only supported within the confined ANCON 57dBA Leq contours. There is no contemporary scientific research that we have seen supporting these arcane methods of trying to determine the depth and range of where and who are affected by aircraft noise and nuisance yet the aviation industry in justification of its operations quote ANCON contours as a mantra. This is also true of some government departments sheltering behind these unproven metrics as though they were scientifically established to protect people’s health – and clearly they are not.


This consultation process has also had to quote the ANCON contours because there are no other so-called environmental metrics to adequately convey the affect and range of noise nuisance from aircraft and airports. Successive authorities have failed to recognise the irrelevance of 57dBA Leq contours on the vast majority of people affected by aircraft noise, or on their health and well-being and the economic impact that aircraft movements have on local economies outside of the ANCON contours – which are unrecorded in official statistics. This has played into the hands of the air travel industry and allowed its relentless expansion.


In addition, we have now seen solid evidence that the 57dBA Leq Contour has failed to recognise the tonal effects of airframe noise from so-called quiet aircraft such as the Airbus A 319/320/321 series. The use of this type of aircraft has grown significantly over the past few years and now accounting for over 50% of all movements at Gatwick Airports. Their debilitating high pitched whine is evident along a flight path stretching between seven and twenty-miles to touchdown. This problem has now been formally publicised by the CAA some eight-years after they were first made aware of it. On the 16 October 2013 the CAA confirmed: 


“Following concerns raised around Heathrow airport in 2005, the issue of tonal noise emanating from the A320 family of aircraft on approach was brought to the attention of Airbus by the CAA. Complaints of a high pitch “whine” which could be heard on the ground at relatively large distances from the airport (Greenwich). Similar concerns had also been raised around Paris and Frankfurt airports at around the same time. Measurements undertaken have confirmed the tonal noise is due to airframe noise not engine noise and is on all present A320 family variants.”


The CAA went further and acknowledged that the sound was deafening enough that it could only be masked close to the airport “by noise from landing gear, flaps and the higher thrust required in the landing configuration.” They continue and admit that “Tone is emitted around 500-600Hz, close to peak sensitivity of the human ear, hence it is very perceptible. Very audible during intermediate approach phase,’ which is 7-20nm from landing.  In other words it could have a distressing impact on all those that were within audible range yet neither the Secretary of State for Transport or the CAA have any powers to deal with it and so far the main operators of these aircraft in the UK have refused to make modifications that would reduce the misery for so many people in the UK and abroad. In Germany and France both Lufthansa and Air France have agreed to modify their entire fleets claiming it is a duty within their social responsibility programme. 


With thousands of these aircraft in service and with an operational life approaching 20 years there is a lot of misery ahead for UK residents from an industry that believes that UK airspace is their sole preserve to make profit irrespective of the impacts on the British public.


Until such time as the Government takes full responsibility for regulating the air travel industry on safe and far reaching noise controls and enforcement to protect health, well-being and local economies then it is premature to even consider the introduction of further runways anywhere in the United Kingdom. The fallacy that only people living within the ANCON 57dBA Leq contours are suffering from major noise nuisance has to be dispelled once and for all. This is the same message that emerged In the Summary of Responses to the Draft Aviation Policy Framework Consultation, published in 2012 by the Department for Transport where the consensus of public opinion was:


“The 57 dB LAeq, 16h contour is the wrong means of measurement because it is outdated / represents an average / is ineffective. In summary, there is no confidence in this contour as the (sole) basis for taking decisions regarding aviation noise.”




Q: Are these the right issues for the Commission to consider in relation to the expeditious delivery of any new airport capacity?

Q: Are there any others options that the Commission should consider?




We have demonstrated in the foregoing that the air travel industry in the United Kingdom is in its infancy of bearing responsibility for its actions on environmental, health and well-being, and protection of local economies within and outside of the so-called environmental metrics of the ANCON contours. Until such time as this industry is truly accountable to government or independent bodies with authority such as we see in France with the ACNUSA* (Autorité de contrôle des nuisances aéroportuaires) then it would be irresponsible of any independent commission to recommend the building of a second runway within the United Kingdom.


*ACNUSA’s opening mission statement as the principal independent administrative authority concerned with the environment in France : “ACNUSA's main missions are to reopen communication channels, rebuild trust, and ensure that the development of air transport does not penalise residents.”




Chapter 5: Next Steps – sets out how you can respond to this Discussion Paper and how the Commission will use responses to inform its ongoing work.


Submissions of evidence should be no longer than 15 pages and should be emailed to airports.delivery@airports.gsi.gov.uk clearly marked as a response to the ‘Delivery Discussion Paper’. Evidence will be reviewed thereafter by the Commission.