Name John Coates Email j.coates@richmond.gov.uk Organisation London Borough of Richmond Upon Thames 1. By what margin - in terms of the number of people affected - does the present noise from Heathrow’s existing flight paths exceed the World Health Organisation’s community noise guideline values in the day/evening period (07002300) and in the night period (2300-0700)? How does this compare with other airports within the UK and the EU? We understand that aircraft using Heathrow affect more people than around any other airport in Europe. Clearly the WHO values apply to every airport, but the scale of Heathrow means that more people are affected. Whatever metric is used, the noise impacts are compounded by Heathrow’s greater population density, the size of the area over flown and the greater frequency of flights. Although the ‘Air and Ground Noise Assessment’ from HAL indicates some options for reducing the number of people overflown, these are only possible by adopting new routes over new people. There is no certainty that these new routes are actually achievable or will pass the scrutiny of NATS. As the demand for extra capacity will not stop with a 3rd runway, it makes most sense to stop expansion now. We do not know the scale of the margin – but Heathrow has to get ‘better not bigger’. Greater recognition of WHO values has to be a good start towards achieving compliance. ‘Air and Ground Noise Assessment’ in http://your.heathrow.com/britainsheathrow/downloads/ 2. Does the Environmental Noise Directive enable the UK to meet fully the criticisms that were made in the Heathrow Terminal Five Public Inquiry Report that the 57 decibel noise contour was by itself an inadequate measure for assessing the full impact of air traffic noise? The limitations of the 57LAeq metric are well understood, and all but accepted by the Government, short of actually replacing it. Meantime the Lden metric has been adopted across Europe, enabling inter comparison. It is on the basis of this metric that we now know that Heathrow ranks as the worst European airport, in terms of the number of people affected. What is now needed is a metric that is sensitive to the increasing numbers of flights, together with a fresh social survey that can calibrate the metric, both with an initial value and as a longitudinal indicator of trend. From the surveys that have been done, we now know that people have become more sensitive to aircraft noise. We need a metric that can reflect such changes. What we then need is for regulators to appreciate what the metric indicates, and call a halt to unnecessary and harmful expansion development. 3. What are the prospects for significantly less noisy aircraft at Heathrow over the next ten years and are the prospects in any way dependent on the development of the proposed third runway? To what extent is there a conflict between the optimum reduction of aircraft noise and carbon emissions? Our understanding is that there will be some technological noise reduction improvements but that they are likely to be incremental rather than significant. The era for any step change improvements seems to be over and in any event eventually there comes a point where you cannot push a large tube of metal through the air any more quietly regardless of technology improvements. The trade-off clash between improvements in noise and climate change emissions seems set to continue. We cannot rely on a win–win on this to be just round the corner. Whilst reductions of both forms of pollution are important, we would certainly not want noise emissions to be allowed to get worse, in order to accommodate a greater than fair share of climate change emissions. The position is plain, that Heathrow has reached the limit of its expansion, and that ‘enough is enough’. 4. Are there additional operational procedures for noise reduction and respite at Heathrow that could be The scope for noise reduction from additional operational procedures seems more likely than from technological ones. However these procedural proposals require the greatest scrutiny, as they appear to reduce the margins of safety. We are with the introduced within the next ten years; or are any such noise improvements being held back for the development of a third runway? CAA on this one, that safety is paramount. However laudable it may be to find ways to reduce noise levels, it must not be at the expense of safely. Provided that safety is not compromised, it would be eminently sensible to introduce any procedural improvements as soon as possible, rather than to wait for the extra capacity of a 3rd runway. 5. Over what areas will the arrival and departure flight paths for the proposed third runway be routed, and which of those areas are not currently overflown by Heathrow air traffic, either at all or only occasionally? The ‘Air and Ground Noise Assessment’ from HAL indicates some potential new flight paths, based on minimising new people, minimising ‘total’ people or maximising respite. Depending on the option chosen, different minimum populations have been identified. The common theme between them is that each of the proposed routes involves approach paths which either curve or have a kinked off-set. HAL alleges that these new routes will fly over fewer people. As these are only desk top proposal routes, no real assessment has been carried out as to the real feasibility of the routes, nor how much extra noise will be made in the flying of tight turns or failure to fly a minimum noise CDA glidepath. Clearly there is a benefit to flying over fewer people, but that is a worse option for those who end up with a new flight path going overhead. This is a case of winners and losers, but only if unnecessary expansion is pursued. If it were possible to reduce the population affected without also worsening the impacts for some, then clearly it would warrant introduction soon, without a 3rd runway. 6. Would the flight paths for the third runway cause any alteration to the present routing of the flight paths for the existing runways; and if so, to what extent? Each of the new flight paths, as identified in Q5 above, involves changes to the existing flight paths, even the ones which minimise ‘new’ people. Understandably the exact routes would need very thorough assessments, and the ones given are only indicative. However, if the time comes to do a thorough assessment, it will have to be dovetailed in to the raft of other initiatives being pursued under the Future Airspace Strategy. 7. How would the proposed segregated mode respite periods operate with three runways, compared with the existing runway alternation arrangements (between 0700-2300 and 2300-0700)? Our understanding is that there could only be segregated mode on two out of the three runways at any one time. The 3rd runway would then be in mixed mode, and the two outermost runways, which can operate mixed mode, would alternate. For safety reasons, involving ‘go-rounds’, the central runway would not be able to operate in mixed mode. Each community would get a period of respite, but this would be on a reduced number of hours compared to the current arrangement. Whilst it is commendable that some respite would be retained by each community, that will be small comfort for the loss of some of the respite, which is so highly valued. Communities adversely affected would clearly prefer to retain their respite than to gain an extra runway. 8. Would the third runway enable Heathrow to operate without flights in the night period (2300-0700)? Our understanding is that Heathrow could operate without any flights in the night period (2300-0700), with or without a third runway. The calculations are that there is daytime capacity now, to take all of the night flights, so it should easily be possible to accommodate them all with a third runway. 9. How quickly would Heathrow with the proposed third runway reach its stated capacity of 740 000 aircraft movements (ATMs) per year? In view of the resilience difficulties at We have received mixed messages as to whether Heathrow will be full or only partially full by 2040. Depending on which one is correct will affect the noise levels and hence the accuracy of any modelling. Appendix J of the ‘Air and Ground Noise Assessment’ from HAL indicates the modelling results of noise exposure change. Although a composite contour is used, showing areas of improvement and areas of worsening, the modelling was only Heathrow with 480 000 ATMs (a problem not identified at the Terminal Five Public Inquiry), how much resilience would there be with 740 000 ATMs? 10. Would the proposed third runway hasten or delay the date by which the air traffic noise levels at Heathrow would not exceed the World Health Organization’s guideline values on community noise? assessed for 2030. So we have not been presented with the contour situation which we might anticipate, with the 3 runways running full. We would anticipate that an increase in flights from 2030, to when it is full, would be likely to expand the contours shown in Appendix J. On that basis, we can expect that there are communities that may suffer worse noise than is indicated. It would therefore be helpful if HAL would model the 3 runways, when they are running at maximum capacity, rather than partially full. It seems that a third runway would be likely to delay the date of achieving the WHO guideline values. In addition to achievement of these values, we need to remember that new metrics are needed, to account for the increases in frequency. Likewise, a level of resilience needs to be included from the start, so that congestion issues are avoided. If the airport were made to operate at a sustainable level of capacity, then the WHO levels would be easier to achieve. Noise is an important issue, and more than just an annoyance. Noise has an effect on health, which is why WHO treats it as significant. It is vital the HAL, the Airports Commission and the Government should take aircraft noise seriously.