Response to Night Flights Proposal

8/8/2019 Response to Night Flights Proposal

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Manston Airport

Proposed Night-time Flying Policy

and Noise Assessment Report

Response from

No Night Flights


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CONTENTS

Introduction ............................................................................. 3

Infratil's proposed night-time flying policy ................................. 4

Background ........................................................................... 4Master Plan ........................................................................... 4Market and Business Requirements ...................................... 6

Proposed Night-time Flying Policy ......................................... 8Impact assessment ............................................................. 13

Bickerdike Allen Partners noise assessment report ............... 15

1.0 Introduction ................................................................... 152.0 Site description .............................................................. 173.0 Aircraft movements at night ........................................... 17

4.0 Night noise assessment criteria ..................................... 195.0 Noise contour and assessment methodology ................ 226.0 Impact of night-time airborne aircraft noise .................... 23


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INFRATIL'S PROPOSED NIGHT-TIME FLYING POLICY

BACKGROUND

2. [.]Equally importantly, the operation and development of an airport mustbe acceptable to the resident and business communities within which it islocated.

No. The operation and development of an airport must be acceptable to the residentand business communities on which it has an effect.

3. Clearly the issue of night time noise is significant for residents in closeproximity to the airport. []

No. The issue of night time noise is significant for every resident affected by the night

time noise.

MASTER PLAN

The Master Plan states that "as the airport grows, the essential requirement toaccommodate delayed aircraft will remain" and the airport owners "will propose asystem of controls ... including a Quota Count System, restrictions on noisy aircraftand the adoption of a night time flying policy." There is no mention of schedulednight-time flying.

4. National Aviation Policy is set out in the Future of Air Transport WhitePaper (FATWP) in 2003. []Therefore the expected growth in the air market

for both passenger and freight traffic will need to be accommodated within theexisting runway capacity. This national policy position further increases theprospects for future demand at Manston.

The 2003 FATWP and its projections for growth in the air traffic market arerecognised to be out of date. Moreover, the High Court judge who presided over thehearing into Heathrows application for a third runway, Lord Justice Carnwath, saidthat the Government's attempt to rely on the 2003 White Paper in its planning forairport capacity was "untenable". He said:

"Common sense demanded that a policy established in 2003, before the

important developments in climate change policy ... should be subject toreview in the light of those developments..

It is clear from this that airports should not rely on the 2003 White Paper as arationale for pursuing growth. Growth estimates in the FATWP are nowhere nearborne out by current actual trends. Air passenger numbers have been below thelowest of the FATWP forecasts since 2008. UK air freight has been static for tenyears and has all the signs of being a mature, i.e. a non-growing, market. Therefore,there can be no rational expectation that there will be increases in the prospects forfuture demand at Manston. New custom for Manston will need to be won from other,more established, and better located, airports. So far, Manston has been unable to

do this.


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9. ln particular, the Master Plan forecasts that direct employment at the airportwill rise to 500 by 2018, and further to 1,000 by 2033, with total employmentgenerated by the airport (including direct, indirect, induced and catalytic)reaching 2,800 by 2018 and 6,150 by 2033.

Councillors need to be clear that this employment forecast relies on everything in theMaster Plan coming to fruition. It is not a forecast for an increase in jobs as a resultpurely of the night flights proposal. The airport needs to produce an estimate of thejobs it can demonstrate will be created purely as a result of the night flight proposal,so that the costs and benefits of this proposal can be assessed on their own merits.

10. The airport currently employs 111 staff, with a similar number directlyemployed on the site through other organisations. Of MSEs own employeesthe significant majority (61%] live within Thanet.

The airport has been in private hands for 11 years through the biggest aviation boomthe world has ever seen and has produced only 111 jobs, roughly 10 a year. This

figure of 111 jobs has been pretty stable over the last few years. The airport claims itwill have 611 jobs in 2018, i.e. that it will create 500 new jobs in 8 years, or 63 ayear. As well as the direct jobs the airport claims it will also produce 2,189 additionalindirect and induced jobs. These jobs can be located anywhere in the world certainly not just in Thanet. For example, an indirect job could be a job in a firm inthe Midlands or in Poland which supplies goods to the airport. The most importantthing to grasp here is that the airport is producing a nice, eye-catching, positivegraph that does not in any way represent the number of jobs created by thisapplication for night flights. This graph is the airports estimate of the jobs it mightcreate (and this in itself is flawed) if everything envisaged in the Master Plan for 2018comes to fruition exactly as planned.

On its own numbers, we can see that Manston thinks it can create 3.6 additional jobs(2189 611) for every person on its own payroll. That is an estimate, and estimatesof potential jobs created in the aviation industry are notoriously exaggerated.Stansted has already delivered jobs for its community and says that it has createdjust 0.3 additional jobs for every existing real job. Manstons job creation claims are amassive overestimate.

Our research using Stansteds data is reinforced by a recent study by Omega (TheEconomic Benefits of Aviation Technical Report, January 2009). This reportexamines the multipliers arrived at in a variety of studies into indirect and induced

employment at airports. The Omega study reports a range in multipliers of between0.3 and 1.16 used to calculate indirect employment generated by airports. This is afraction of the multiplier of 3.6 that Manston is suggesting that it can achieve.

The aviation industry itself recognises that increasing the number of flights does nothave a significant impact on the number of new jobs created. The Airport OperatorsAssociation has forecast that by 2030 an increase of 104% in the number ofpassengers passing through UK airports will produce only a 21% increase in jobs atairports.

When Charles Buchanan was part of the management team at London City airport,the airport promised that in return for permission to increase flights by 50% (thats36,000 flights), 3,135 new jobs would be created. The airport got their flights and by2008 had created only 726 jobs a fraction of what was promised. Of these, only


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30% were filled by local people. So, 36,000 extra flights delivered only 218 local jobs(726 jobs x 30% = 218). Manston wants just 8% of the flights London City requested(7.7 flights per night x 365 days = 2,810 flights p.a. and 2,810 36,000 x 100 = 8%).So, if we work with the track record that Charles Buchanan has of translatingpromises into jobs and apply it to the level of flights that Manston is requesting, we

arrive at a maximum of 17 to 18 local jobs for this night flight application (218 localjobs actually delivered at London City for 36,000 flights x 8% for the number of flightswanted at Manston = 17.4 local jobs). More jobs than this will easily be lost if just afew local businesses - hotels and restaurants - close as a result of night flights.

Weve spoken to workers at the airport who tell us there is plenty of capacityavailable at the airport to absorb the extra flights anticipated by changing shiftpatterns and using overtime. Their assessment is that no new jobs will be created asa result of the night flight application.

In their response to Manstons Master Plan the Campaign to Protect Rural Englandprovided figures that show that the average wage at Manston is lower than theaverage wage in Thanet. This suggests that a successful night flight application willproduce at most a few low-paid jobs at the airport, whilst risking the loss of manymore jobs in the local tourist industry.

In short, the airports job creation estimates are wildly over-optimistic and relate tothe entire Master Plan, not just the night flight application. They must be disregarded.

More generally, Infratil's forecasts are of questionable worth:

October 2008 Draft Master Plan: "Our forecasts envisage that there will be apassenger throughput of 1.2 mppa (million passengers per annum) by 2011."

November 2009 Master Plan: "Our forecasts envisage that there will be apassenger throughput of 100,000 passengers per annum by 2011."

MARKET AND BUSINESS REQUIREMENTS

15. Delays of this sort can accumulate over a flying day or longer period, andmay result in airports needing to operate outside their normal hours to servicepassengers, freight and aircraft. The reputation, and hence competitiveposition, of an airport is damaged when it is not able to meet such

fundamental customer needs.

The airport already has this flexibility and makes heavy and regular use of it. Thenumber of delayed aircraft should be small and certainly not allowed to become aregular operation.

16. This requirement to operate at night is recognised throughout the airportindustry and is managed at many sites through the implementation of a night-time noise quota system. This system provides the airport with a mechanismto accept night-time flights within agreed levels, while providing thecommunity, though the local authority, with assurance and protection from

excessive and unacceptable noise levels arising from uncontrolled activity.


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The only need that the airport has established above for any form of night flying is tocater for a few unscheduled delays. It has yet to make the case for scheduling nightflights.

This requirement is managed at some sites by a total curfew on night flying. On

others it is managed through a combination of tools such as a quota count systemoperating alongside a limit on the number of aircraft movements allowed at night anda system of fines for every breach of agreed decibel levels. Infratil is suggesting thatit needs complete freedom to fly what it wants and as many planes as it wants aslong as the QC allocation is not breached.

It needs to be recognised that controlled activity also produces "excessive andunacceptable noise levels".

17. Additionally, and in order for freight airlines to satisfy the needs of theirclients and ensuring that consignments meet delivery schedules, a smallproportion of traffic has to be scheduled to fly at night. For the airport to be

attractive to wide variety of freight airlines, serving a diversity of sourcemarkets, it is important to have the flexibility to schedule services during thenight-time, and to control and manage these in a manner acceptable to thelocal community. This need is anticipated in the existing Section 106Agreement, which calls for a Night-time Flying Policy to be developed prior tosuch regular operations commencing.

It is the possibility of a night flying policy that is anticipated in the S106, not therecognition that there is a need.

Manston has not demonstrated what small proportion of traffic has to be scheduled

to fly at night and why. It is impossible for the Council accurately to weigh up thecosts and benefits of this without having this information. The burden is on the airportto demonstrate why it needs what it is requesting.

Figure 1 Government Forecast of Freight Tonnage vs Actual Tonnage (CAA figures)


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UK air freight grew rapidly from 1970 through the 1980s and doubled in the 1990s. Itgrew from 580,000 tonnes in 1970 to 2.2 million tonnes in 2002. In 2003, theDepartment for Transport forecast that freight growth would grow even more rapidlyover the next decade. In reality, UK air freight has stabilised in the last ten years.The divergence between forecast and actual air freight volumes is widening.

There has been a small recent increase in belly hold cargo (see CAA aviationtrends). However, Manston is unlikely to attract this business as it relies on theairport having a thriving passenger business. Manston has produced no evidencewhatsoever to suggest that there is an actual or, indeed, a likely demand forincreased freight handling at Manston.

What does a wide variety of freight airlines mean? Recent experience suggeststhat Manston will attract the second and third tier operators such as MK Airlines (inliquidation for the second time), Meridian (banned from flying in EU airspace forsafety reasons) and Egypt Air (given a yellow card by the EU for its poor safetyrecord). These planes are typically older and noisier and many do not meet modernsafety standards. The airports strategy seems to be to turn Manston into a nightfreight airport, attracting the second and third tier operators unable to securefavourable slots at more successful airports. This has significant implications for jobcreation and for the negative impact on the local community.

This night flight application is a very poorly-made business argument. The argumentneeds better justification and an explanation of the sorts of services, markets,arrivals and departures envisaged. No case has been made for night operations.There is nothing in the Master Plan to link night flying to the successful developmentof the airport.

Successful airports such as Stansted, Heathrow and Gatwick are not allowed to dowhat Manston is requesting i.e. to schedule QC4 arrivals and departures at night. Itis clear from this that an airport can succeed without being allowed to have the nightflying freedom that Manston wants. There is a reason that very few airports allowscheduled QC4 flights at night: they are extremely damaging to the local community.

The local community spoke on what it would find acceptable at the public meeting atRamsgate Town Council on 25th October. In answer to the Chair of the AirportWorking Partys question what level of night flights would people be prepared toaccept? the unanimous and shouted response was none.

PROPOSED NIGHT-TIME FLYING POLICY

18. In order to regulate Night-time Flying at Manston Airport, it is proposed toadapt the Noise Quota system in regular and successful use at other airports(Bristol, Birmingham, Gatwick, Heathrow, Liverpool, Doncaster, Manchester,and Stansted) to the local circumstances and market needs for MSE.

Of the airports mentioned above, only Gatwick, Heathrow and Birmingham are asclose to densely populated areas as is Manston. Gatwick and Heathrow are bothcommitted to "a progressive decrease in the overall night quota". Birmingham places

an upper limit on the number of aircraft that can fly at night, has three noise monitorsat each end of the runway, and penalises night flying aircraft that exceed 87dB.


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The S106 Agreement says that the night flying policy will specifically address thefollowing matters:

1.2.3 the embodiment of the principles of UK best practice at the timeand the appropriateness of those principles to prevailing local

conditions.The key words here are best practice and the appropriateness of those principlesto prevailing local conditions.

This document is supposed to be putting forward a night flying policy. The onlysection of this document that proposes any measures is section 21 below which issolely concerned with quota counts. A night flying policy should contain many othermeasures. For instance:

differential landing fees making it more expensive to operate at night. The airportowners have said frequently that they do not wish to operate at night as it carries

no real benefit for them. If they are to be believed, then they must introducematerial differential landing fees to discourage night flights. To do anything lesswill be a demonstration that the airport owners wish actively to encourage nightflights in the hope of developing a night freight business that the vast majority ofUK airports are not allowed to develop

noise penalty schemes, for example at Birmingham the full runway charge ischarged again if 87db is exceeded; at Luton there is a 300% surcharge for noiseover 82db and over 85db attracts a 500% surcharge; East Midlands charges750 for the first db over the maximum and an additional 150 for each dbthereafter

allowing only "Chapter 4" aircraft at night, i.e. those that comply with the modernstandard for quieter aircraft

a limit on the total number of air traffic movements in a night.

19. This system allocates a Quota Count (QC) to each arrival or departure,based on the aircraft manufacturers certification operating at maximumweight. The total of these QCs, as set out below, gives the Annual QuotaCount.

Of course, this is how a Quota Count system shouldoperate. The airport suggests a

globally unprecedented alteration to this system whereby planes approaching fromor departing towards the west will count for only half their internationally recognisedQC points. Manston has neither the right nor the competence to tinker with thewidely-used QC system. This is so far outside normal practice that we can onlyassume it is a predetermined negotiating giveaway, to be given up in the interest ofsecuring the rest of the proposed policy.

20. In line with the comments received during the Master Plan consultationperiod from, amongst others, TDC's Airport Working Party and the AirportConsultative Committee, the proposed system has been devised to be simpleand easy to apply, straight forward to monitor and to provide clarity and

certainty for the local community, the Council and the airport operator.


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This might be the case if Infratil were not suggesting tinkering with the system. Thehalf counting for western movements means that the system becomes complicatedto the point of obscurity. Every arrival from or departure to the west offers the airportthe opportunity to increase how many planes might come in for the overall 1,995quota. We explain this more fully below. The community will have no certainty

whatsoever about how many times planes will fly over them during the night.

In addition, the QC system only works if it is monitored, and the last ten yearshistory of commercial flying at Manston tells us that monitoring and reporting are nota strong point.

Lastly, most other airports using the QC system use it alongside other measures andconstraints such as a limit on the number of movements and a series of decibel limitsand fines. The airport is staying completely silent about these usual accompanimentsto the QC system. There is no justification for this.

21. The proposed Quota Count System for Manston Airport is as follows:

a. Night-time Period will be 2300 to 0700 local time.

b. Night-time Quota Period will be 2330 to 0600 local time.

There is no explanation and no justification for this. No controls are offered for thetwo shoulder periods. This means that the airport can cram as many flights as therunway will allow into these hours. Experience with EUJet and careful records takenof their use of shoulder periods shows that full and regular use was made of theseperiods with unscheduled, but suspiciously regular, patterns of flights developing.The airport needs to offer a justification for lengthening the flying day by 1 hours aswell as some suggested controls to distinguish between daytime and the shoulderperiods. To get as many planes as it can for its annual QC allocation, it will be in theinterests of the airport to use that allocation for arrivals, delaying departureswhenever possible, and then scheduling them immediately after 0600 when they donot use up QC points, thus producing an early morning rush hour of departures.

The QC system should apply to the entire 8 hour night period from 2300 to 0700.

c. Annual Quota Count will be the sum of the individual Quota Counts (QC) ofall flights arriving or departing during the Night-time Quota Period within acalendar year (January to December].

Actually, it will be an unusual fudge of this because of the globally unique halfcounting system that Infratil proposes to operate to the west of the airport.

d. There will be no scheduling of aircraft of Quota Count greater than QC4within the Night-time Period.

This falls way short of current best practice, which, we must remember, the Counciland airport owners are obliged to match in any new night flight policy. Of thoseairports that allow night flights, none of the following allow scheduling of QC4 aircraft Gatwick, Heathrow, Stansted, Luton, Birmingham, Bournemouth, Bristol, Glasgow,Edinburgh, Leeds Bradford and Manchester (departures only). Some airports, suchas Charles Buchanans former employer, London City, and Belfast City allow no

night flights at all. There is absolutely no justification for any scheduled QC4 plane toarrive or depart at any time during the night into or from Manston.


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There should be a complete ban on the scheduling of QC4 and above both fordepartures and arrivals. Any unscheduled departure or arrival of QC4 craft must bepunished by the use of similar measures to those employed at other airports such asfines for breaching decibel levels etc.

e. Annual Quota Count not to exceed 1,995.This is absurd. This would cover the Master Plan projections for night flying up to2033. The suggested QC of 1,995 is weighted completely in favour of the airport andoffers neither protection nor assurance for the public. It gives no certainty to the localcommunity despite what is claimed in section 20 above. It is also vastly more thanthe airport can achieve for many years.

QC totals for the London airports, Manchester and Birmingham are set for aspecified period of time, typically 5 years. That way the local politicians keep somecontrol of the airport. If the politicians agree a very large quota at the outset theycede control of the airport for years and are failing in their duty to protect the public.

The airport claims in public that it will use nowhere near the QC for which it isapplying for the first few years of its existence. If that is the case, the Council mustreject this application and ask to see one that reflects the true business need of theairport for the next five years, i.e. a vastly reduced and realistic QC. If the airport isrequesting a QC that it admits it does not need, this points to an attempt to boost theairports attractiveness in the eyes of a potential purchaser, rather than request ingnight flights that this owner actually requires.

f. Preferred Departure Runway and Noise Abatement Routes as set out inclauses 4 and 5 respectively of the Second Schedule to S106 dated 26September 2000 (runway 10 for arrivals and runway 28 for departures) to be

used whenever possible during the Night-time Period consistent with safeoperations.

Having preferred routes is useless if they are not adhered to. Residents regularlyexperience off route aircraft and the airport has a history of failing to deal in anycredible way with complaints about this.

The Bickerdike Allan Partners (BAP) report is predicated on the mistakenassumption that every aircraft flies in accordance with the agreed routes. They donot. This means that the computer-modelled noise footprints in the BAP report bearno relation to what residents actually experience.

g. In recognition of the lower impact of movements approaching from ordeparting towards the west, movements which operate on such routes willcount towards the Annual Quota Count and Community Contribution at 50%of their certified rate.

This suggestion must be rejected out of hand. It is extraordinary, unprecedented,unjustified and unacceptable. If Infratil are choosing the QC system as their onlymechanism of constraint (and we argue that there should be others, just as there arein other airports), then they have to abide by that system completely. There is noreason whatsoever to imagine that people on the western approach/departure routeexperience the planes that fly over them as being half as noisy as they are agreed to

be everywhere else in the world. This is a patently absurd suggestion.


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This cynical ploy also has the effect of enabling the airport to use many more QCpoints than it has been given. Let us imagine that the airport gets its 1,995 QCallocation and that it can put around 50% of its night flights over the western route.Those 1,000 QC points used for movements to the west would cost the airport just500 points. This then boosts the total QC available for the airport by an additional

500 points, making the total 2,495. The more flights the airport can route to the west,the more flights it can have. Our technical expert has modelled this usingassumptions about the prevailing wind and has estimated that this could lead to aQC allocation equivalent to 3,000 way in excess of anything this airport has beenable to demonstrate that it needs.

If the wind is the usual westerly, and departures take place to the west, attracting justhalf the QC cost, this will boost the number of arrivals that can take place overRamsgate.

h. For movements exceeding QC4 during the Night-time Quota Period, theoperator will make a Community Contribution of 1,000 for each occasion tothe Manston Airport Environmental Improvement Fund (MAElF].

This is a transparently token measure. There are very few QC8 or QC16 craft left,and most of those are in the hands of the more dubious operators. There must be ablanket ban on these craft at any time between 23.00 and 07.00.

This suggestion about the level of fines is a retrograde step from the existing systemwhich was designed to discourage repeat offenders. There is also no mention offining planes that are off route or flying too low. Best practice is not to allowmovements of QC4 and above during the night quota period, and this is whatManston should be doing.

Relative to what it costs to fly the largest and noisiest cargo planes overnight halfwayaround the globe, a fine of 1,000 is trivial and falls well short of the fines structure atother airports. DHL tells us that it costs $160,000 to fly a B767 to the eastern USAand back. East Midlands airport, which has a very successful cargo operation, leviesa surcharge of 5000 for QC8 and 10,000 for QC16 for night operations.

i. MSE will guarantee minimum annual contributions to MAEIF of 10,000.

Our preference is to see a robust and effective fines system in place and enforced,and for the community fund to be empty because there have been no breaches. Exgratiaphilanthropic donations from the airport owners to the local communities would

be welcomed at any time.

22. To improve the current monitoring and reporting of night flights, each flightthat operates during the Night-time Quota Period will be reported monthly toThanet District Council and the Airport Consultative Committee.

23. The airport will publish monthly noise data on its website to ensure thatthis is accessible to members of the public.

This falls well short of best practice. We want to see proper monitoring and reportingalso on the use of the shoulder periods. We know from experience of EUJet thatthese are exploited thoroughly by the airport once approved, and an informalschedule of early morning and late night aircraft movements develops.


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Current monitoring and reporting is pitiful and falls well short of what is happening atother UK regional airports. The airport has chosen not to invest in systems thatwould give the community access to real data about individual flights. Currentcomplaints are dealt with by no more than a blanket assurance that everything wasoperating within standard operating procedure, regardless of what the complaint was

actually about. As no records of flight paths or heights of aircraft are kept, the airporthas no data to enable it to demonstrate that this is actually the case.

Noise monitoring is wholly inadequate. The airport was told years ago that bestpractice was for there to be at least two monitors at each end of the runway. Ideallythere should be three, as well as mobile monitors in constant use. There is still justone monitor at each end of the runway, and we know from local observation thatmany flights avoid the monitor in Ramsgate by veering sharply to the south halfwaydown the runway immediately after takeoff. Infratil currently is not equipped to doeven the most basic monitoring of night activity. The council must insist that theairport brings itself up to date and matches best practice by establishing accurate,

reliable, best practice monitoring systems for noise, and for monitoring andregulating flight paths and plane heights. This must be in place before there can beany discussion about the possibility of night flights being approved.

IMPACT ASSESSMENT

24. The airport has commissioned an impact study from Bickerdike Allen &Partners [.]This study has assessed the extent of noise contours that willresult from the proposed level of activity [.] when the ultimate level ofactivity is reached, projected to be by 2018. Further it considers the likelyperception of the community exposed to these levels of noise, in line with UKstandard practice.

We will deal with the many shortcomings of the Bickerdike Allen & Partners (BAP)report below. However, this assertion that the noise contours relate to traffic levels in2018 really must be dealt with here. It is important to note that the aircraft soundfootprints illustrated in the reports appendices already apply today. They are notdependent on the level of traffic that the airport hopes to reach by 2018. They arecomputer-modelled footprints that show the impact of a single aircraft on a singleapproach or departure as it would take place today.

Lastly, it is a condition of the S106 agreement that any future night flying policyshould be guided not by standard practice, but by best practice in locally relevantairports.

25. ln particular, this report suggests that consideration be given to thedevelopment of a dwelling insulation scheme, to be implemented for dwellingsthat fall within the 57dBLAeq,8hr contour calculated for the previous 12 months.The assessment contained in the report shows that currently no dwellings fallwithin this contour, but that some 318 may be expected to do so at the trafficlevels forecast for 2018.

There is no explanation as to why the report focuses on the previous 12 months. Thereports assertion that no dwellings fall within the 57 dB LAeq,8hr contour is also


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impossible to square with the airports recent objections to two planning applicationsin Ramsgate on the grounds that these buildings currently fall within a 60db contourand would therefore require a noise attenuation scheme.

East Midlands airport is the only airport with a night noise insulation scheme and so

sets the current standard. East Midlands offers sound insulation grants (SIGs) toeveryone within the 57 dB LAeq,8hr contour and/or within the 90dB(A) SEL contour. Tobe consistent with best practice, Manston airport would need to develop its soundinsulation scheme around the noise criteria in PPG24 and the EU Noise Action Planlegislation, where the threshold is set at 48 dB LAeq,8hr. This is because the 57 dB LAeq,8hr contour is the level formerly agreed to cause annoyance in the day (the mostrecent Government study, the ANASE study, sets this level for daytime annoyanceeven lower) whereas we are talking here specifically about night noise.

At a minimum, the airport needs to adopt the East Midlands approach and to supplysound insulation grants for any dwelling within either the 57 dB LAeq,8hr contour and/orwithin the 90dB(A) SEL contour. This would apply to thousands of dwellings aroundthe airport. To meet the S106 obligations to be in line with best practice, the airportneeds to supply sound insulation grants for any dwelling within either the 48 dB LAeq,8hr contour and/or within the 90dB(A) SEL contour. Of course, it must beremembered that many of the properties affected in Ramsgate have either listed orconservation status and sound insulation is particularly expensive to provide in thoseproperties if planning regulations are to be complied with.

Figure 2 Area of Ramsgate affected by 90dB SEL

26. The airport is committed to developing and agreeing such a scheme withTDC prior to any dwellings being encompassed by this contour.

This is an attempt to get night flights introduced whilst delaying for as long aspossible the introduction of a noise insulation scheme. The council must insist thatthe sound insulation scheme is negotiated, agreed and funded before anyapplication for night flights is approved.


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BICKERDIKE ALLEN PARTNERS NOISE ASSESSMENT REPORT

We have followed the same approach here of putting our comments under therelevant (italicised) extracts from the BAP report.

1.0 INTRODUCTION

The Second Schedule to the Section 106 Agreement dated 26th September2000 sets out requirements for the Night-time Flying Noise Policy and, inAugust 2009, a draft Night-time flying policy was submitted to the Council fortheirs and residents consideration. The policy is to be based on the Night-time Quota Count System that is successfully deployed at many major UKairports including Gatwick, Heathrow, Stansted, Manchester, Bristol andothers.

This suggests that the S106 dictates that the only measurement to control nightflights should be a night Quota Count (QC) system. The S106 does not suggest this.The S106 says that

the policy will specifically address the following matters:

1.2.3 the embodiment of the principles of UK best practice at the timeand the appropriateness of those principles to prevailing localconditions.

As we have said before, the important words here are best practice and local

conditions. It is an unchallenged fact that Manston has a town of over 39,000 peoplejust 1.3km from the end of the runway. Every landing from the east and take off tothe east flies directly over Ramsgate. At the other end of the runway is a village just5km from the end of the runway. Further to the west and still under the preferredflight path for night flights is Herne Bay, a town of over 35,000 people.

Any night flying policy needs to reflect best practice as it is laid out at airports wheretens of thousands of people are overflown on the approach and departure paths.

In recognition of the flexibility required in the scheduling of aircraft, and in thesensitivity of people to noise disturbance at night, the Quota Count System is

based around the hours of 23.30 to 06.00 and sets a quota against whicheach aircraft movement, a departure or a landing, is counted. The countvaries according to the noisiness of the aircraft. A count of 4 for example isnoisier than a count of 2. The details of this proposal are beyond the scope ofthis report but MSE have developed forecasts for their expected annualnumber of required night operations, both during the night-time quota countperiod (23.30 to 06.00 hours) and also the night-time period of 23.00 to 07.00hours.

Asking for a reduced night time quota period as well as an unrestricted shoulderperiod is an attempt to achieve more flights at night than would be allowed if the

night flight QC allocation were to apply to the full night time period of 23.00 to 07.00.These shoulder periods look anodyne, but are a way of lengthening the flying day by


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1 hours and result in people never having an assured 8 hour break from aircraftnoise.

Manston is a UK regional airport. Many UK regional airports use the standarddefinition of night, i.e. 23.00 to 07.00. Some have a night curfew that begins well

before this. Any attempt to chip away at this definition of night and to replace it with anight period from just 23.30 to 06.00 must be resisted. It is for the Council to decidewhat is the QC period, as well as what the quota should be. Airy assertions that theQC period can only be from 23.30 to 06.00, should be treated with suspicion.

This report considers the likely noise impacts from these forecast operationswhich are expected to be reached by 2018. This is done by taking the forecastnight-time operations and generating noise contours (in terms of the LAeq,8hindex) which depict the average noise levels expected over a typical nightperiod. In addition, noise footprints are presented for the most commonly usedaircraft at night that will feature the most in the noise environment. Theseprovide an illustration of the noise produced on the ground during a singleaircraft event, rather than an average. Contour areas, dwelling and populationcounts within contour bands are also presented.

The noise contours provided are illustrations only as there is inadequate noisemonitoring at and around the airport and so accurate data is hard to gather. Theillustrations take no account of factors such as land contours, low cloud cover,prevailing wind conditions and other factors that can amplify the level or the spreadof sound. It is normal when using this computer modelling system to check theaccuracy of the contours produced by taking a range of field measurements. Wewould like to know what field measurements the consultants have taken and inputinto the system.

Moreover, the illustrations of aircraft footprints are for a small fraction of the aircrafttypes that use Manston and some of them are missing, typically those to the halfprice west. These illustrations in no way match residents actual experience of thenoise generated by todays existing night time activity. The actual noise nuisance isexperienced well beyond the 85 dB(A) contours estimated by BAP, as we know fromhundreds of emails from angry residents. Given this, these computer-generatedillustrations have no bearing on the actual noise nuisance endured by residents.

Figure 3 A sample of actual (reported) noise nuisance


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2.0 SITE DESCRIPTION

Manston Airport is situated in the Isle of Thanet, a few kilometres to the westof Ramsgate town and about six kilometres to the south of Margate. In closeproximity to the airport, to the north and south, a number of small villages are

located such as Monkton, Minster and Cliffs End to the south, and Manstonand Acol to the north. The village of St Nicholas Wade is located about 6kilometres to the west of the airport.

ACTUAL distances from Manston's runway: Ramsgate 1.3km; Margate 5km;Monkton 3.2km; Minster 1.1km; Cliffs End 1km; Manston 0.8km; Acol 1.9km; StNicholas at Wade 5km.

3.0 AIRCRAFT MOVEMENTS AT NIGHT

3.1 Current Night-time Aircraft Movements

Night-time aircraft movements at Manston currently occur on an ad-hoc basisand involve aircraft of the type that are expected to fly in the future, forexample the B747-400. The number of movements that take place currentlyvary from week to week and month to month but are typically around 2 perweek at present.

Actually, current night movements are not that ad hoc. We can see a recognisableand regular pattern for some aircraft. This needs to be addressed.

3.2 Future Night-time Aircraft Movements

Up to the year 2018, MSE have developed forecasts for future night-timeaircraft movements that indicate the following number of movements over acalendar year and during a typical night:-

Night-time Aircraft Movements (2018)

Annual Typical night

Hours Passenger Freight Passenger Freight

23.00 23.30 1,016 157 2.8 0.4

23.30 06.00 (NightTime Quota period)

610 471 1.7 1.3

06.00 07.00 407 157 1.1 0.4

2,033 785 5.6 2.1

Infratils estimates of future flight levels have proved inaccurate before and we put noweight on the imagined split of activity shown in this table. The QC system wouldallow the airport to use its QC allocation however it chooses, with whatever mix ofaircraft it can fit in within the overall point allocation. There is no way in which Infratil

or anyone else can say with any certainty now how many flights of what nature they


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will have in the future, nor will the QC system constrain the airport to comply withdelivering any particular mix of flights.

For the Night-time Quota Count Period, the quota count sought for thecalendar year amounts to 1,995.

Actually, this is not true and we have dealt with this point in our response to Infratilsapplication above. Infratil is proposing that flights over the west will count for half oftheir recognised QC. This means that, in the extreme, the airport could secure theequivalent of a QC allocation of anything up to 3990. The vagaries of the weathermake it impossible to forecast what a full year equivalent QC total would be if thisunique adaptation of the QC system were allowed.

The above information forecasts that in 2018, an average of 7.7 flights pernight will take place with over 60% taking place during what are known as theshoulder periods of 23.0023.30 and 06.00 to 07.00 hours. It is generallyaccepted that the most sensitive time for people at night is the intervening

period and, from recent research, particularly during the hours of 01.00 to06.00.

There is no guarantee that this is how flights will actually be arranged over thevarious night periods. Infratil will be free to determine how many craft of what QCthey allow in any one period, the only limitation being the total number of QC pointsavailable within a whole year.

All night noise has a deleterious effect on those who are subjected to it. The airportis trying to suggest that, noise before 01.00 and after 06.00 has much less of animpact. This desperately underplays the message of all recent research and is

socially irresponsible. We cover this more fully in our comments on health below.The ANASE study for the Department of Transport in October 2007 found that,relative to the daytime, sensitivity to the same aircraft noise at other periods is asfollows:

2300-0300: 80% more annoying;

0300-0700: 35% more annoying;

1900-2300: 15% more annoying; and

1500-1900: 10% more annoying.

This demonstrates that the research quoted by the airports consultants is no longervalid.

The conventional manner of assessing night-time noise however relies on theconsideration primarily of the overall night period from 23.00 to 07.00 and it isthis 8 hour period that has been adopted, together with the associated aircraftmovement numbers, in the noise contours presented in this report.

However, let us be absolutely clear that the airport is using a different definition ofnight for its QC allowance, i.e. the much shorter period from 23.30 to 06.00. The

effect of this is that the airport averages its night noise over 8 hours whendetermining its estimated noise contours, but uses its entire QC in a period of just


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6.5 hours. No explanation or justification is given for this anywhere in either theapplication or in the BAP report.

4.0 NIGHT NOISE ASSESSMENT CRITERIA

There is one glaring omission that is worth drawing attention to: Table 2, whichdescribes the guidelines/experience associated with night time airborne aircraftnoise, is missing a couple of important lines.

The significance of PPG24 Categories C and D is this:

Category C - Planning permission should not normally be granted. Where it isconsidered that permission should be given, for example because there areno alternative quieter sites available, conditions should be imposed to ensurea commensurate level of protection against noise.

Category D - Planning permission should normally be refused

PPG24 guidelines state that the noise measurements used to determine Category Cand D status at night should be based not on average noise readings, but on singleaircraft movements that exceed 82dB: "Night-time noise levels (23.00 - 07.00): siteswhere individual noise events regularly exceed 82 dB LAmax (S time weighting)several times in any hour should be treated as being in NEC C, regardless of theLAeq,8h (except where the LAeq,8h already puts the site in NEC D)."

Note that this guideline applies to the whole night time period (2300-0700), not thereduced period that Infratil wish to use for monitoring purposes (2330-0600).

Readings from the monitor in Chapel Place, Ramsgate on 9th and 10th Augustexceeded 82dB. Infratil's own INM Assumptions document forecasts 30,903 people

in Ramsgate experiencing 85dB or more.


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Figure 4 Boeing 747-400 arriving. The outer blue line is the 85dB contour.

Figure 5 Boeing 747-400 departing. The outer blue line is the 85dB contour.

It would appear that a large swathe of Ramsgate within the 85 dB contour would fallinto Category C or D of the PPG24 guidelines, placing severe restrictions onplanning and development. The BAP noise assessment report fails to mention this.

The detailed and rather confusing 4 pages of technical analysis in this section ofthe report also fails to:

Introduce and deal with the most up to date research and guidelines available

Explain the current noise nuisance experienced by residents from Hampton Pierto Ramsgates seafront today

Provide an independent and unbiased assessment of the true impact of nightnoise.

It is for these reasons that in this section our response will not follow the out-of-date

and skewed data provided by the airport, some of which is three decades old, but willoffer instead a short summary of more relevant material available today.


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The Government claims that "the onset of significant community annoyance" startswhen the noise from aircraft averages out at 57 decibels, known as 57dB(A) LAeq.The World Health Organisation (WHO) puts the figure between 50 and 55 decibels(and about 10 decibels lower at night). On this basis, it recommends maximum noiseexposure levels of 55 dBA Leq to avoid the risk of people being significantly

annoyed. The ANASE study of 2007 suggests that the Government is optimistic inassuming that community annoyance begins at 57dB(A) LAeq, and that it most likelybegins up to 8 dB below that.

In the ANSAE study, residents near one of the four airports used in the PreliminaryQualitative Research Phase were more sensitive to aircraft noise at night thanresidents near the other airports. The airport concerned East Midlands has anunusually high proportion of its movements at night. Comparisons of viewsexpressed by a sample of residents near Gatwick with those obtained from EastMidlands suggested that differences in attitudes were related to specific features ofthe East Midlands operations notably, cargo movements by heavier, older and

therefore noisier aircraft that are concentrated at night. This is exactly what Infratilsays it needs for Manston a night cargo operation to pay the bills. We can see fromthis that residents find this kind of night operation more intrusive than any other.

The World Health Organisation recently reviewed available scientific research on theimpact of night noise on health and came to the following conclusions:

Sleep is a biological necessity and disturbed sleep is associated with poor health

There is strong evidence that night noise causes increases in heart rate, changesin sleep stage awakening and use of medicine

There is some evidence that night noise is related to hypertension, heart attacks,depression, changes in hormone levels, fatigue and accidents.

The report summarised the threshold levels of night noise above which a negativeeffect starts to occur. The threshold level for waking in the night and/or too early inthe morning is 42 dB, whereas the threshold for heart attacks was 50 dB.

Integrating these findings, the report proposed a guideline target limit of outdoornight noise of 40 dB (annual average defined as Lnight in the Environmental NoiseDirective). There was not sufficient evidence to say that the biological effectsobserved below this level are harmful to health but adverse effects are observedabove 40 dB. Above 55 dB cardiovascular effects become a major health concernand the report proposed that this should be the interim target for those countriesunable to meet 40 dB in the short run. However, this interim target must betemporary and only applied in exceptional local situations.

A large-scale statistical analysis of the health effects of aircraft noise was undertakenin the late 2000s for Germany's central environmental office. The health data of overone million residents around Cologne airport were analysed for health effectscorrelating with aircraft noise. The study concluded that aircraft noise clearly andsignificantly impairs health, with, for example, a day-time average sound pressurelevel of 60 decibel increasing coronary heart disease by 61% in men and 80% inwomen. As another indicator, a night-time average sound pressure level of 55

decibels increased the risk of heart attacks by 66% in men and 139% in women.


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Statistically significant health effects did however start as early as from an averagesound pressure level of 40 decibels.

More simply, we agree with recent European opinion that average noise levels arean unreliable way of measuring the disturbance caused by night noise. After all, it is

not, as airports would like you to believe, the average noise of your alarm clockthrough the night that disturbs your sleep, it is the single occurrence of noise that itcreates when it goes off. Local experience tells us that people are woken now by thenoise of planes going into and out of Manston. That is hard evidence, not theoreticalstudy. Average night noise levels may well be low because of the low level of nighttraffic. However, when night traffic does occur, local people are woken. Some will notbe woken, but their sleep will be affected anyway.

There are dozens of scientific studies about night noise, some of which contradicteach other. We think it is important to do two things to use the most up to dateresearch available rather than choosing research from the early 1980s and 1990s,and to stick to some basic and incontrovertible facts. If a plane is loud enough towake you up, it is too loud and should not be allowed to fly over a town or a village atnight. It doesnt take six flights to wake you at night one will do it. People do notactually have to be woken for the restorative power of sleep to be spoilt and theirhealth to suffer.

5.0 NOISE CONTOUR AND ASSESSMENT METHODOLOGY

5.1 General

The night noise contours and SEL footprints for Manston Airport have beengenerated using the Integrated Noise Model (INM) developed by the FederalAviation Authority. This software evaluates aircraft noise in the vicinity ofairports using flight track information, aircraft fleet mix, standard definedaircraft profiles, user-defined aircraft profiles and terrain. It is commonly usedto evaluate noise around airports in the UK and worldwide.

We repeat our point here that such computer models need to be checked by using arange of actual field measurements. We urge the Council to ask the consultants torelease these field measurements to the public.

A further short-coming in this report is the absence of "sound footprints" for most of

the aircraft that use the airport. For a complete picture, we need to see the soundfootprints for each and every aircraft type, for easterly and westerly arrivals anddepartures, i.e. four sound footprint pictures. This complete set of pictures has onlybeen provided for one aircraft type (Boeing 747-400).

Two other aircraft types (Boeing 737-800 and McDonnell Douglas MD11) are shownarriving from the east and departing to the west - we are missing the pictures forarrivals from the west and departures to the east.

The INM Assumptions document that supports the BAP report lists other aircrafttypes that are airport predicts will be making night flights: A300, A310, A320, A330,

A340, B747-800, B757, DC10, DC8, DH8-Q400 and E195. No sound footprints ofany description have been provided for any of these aircraft types.


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Noise contours have been generated using the INM for the year 2018 whichrepresents the date by which the full usage of the night operations sought atManston are expected to be achieved. The assumptions upon which the noisecontours presented in this report have been based are set out in Appendix A.This includes description of a representative mix of the number of aircraft

movements expected in the future. Current activity levels at the airport at nightlie below these levels so any increase will occur gradually over a period oftime.

6.0 IMPACT OF NIGHT-TIME AIRBORNE AIRCRAFT NOISE

6.1 Current Night Operations

Night-time aircraft movements at Manston currently occur on an ad-hoc basisand involve aircraft of the type that are expected to fly in the future, forexample the B747-400. The number of movements that take place currently

vary from week to week and month to month but are typically around 2 perweek at present. The night-time LAeq,8h contours for 2009 are presented inFigure 2.1. There are currently no dwellings located inside the 48 dB LAeq,8hnight-time noise contour, the area of which is just under 1.0 km

For freight aircraft, such as the B747-400, these are in operation today andare expected to remain so in the future. Issues concerning noise fromindividual departures and arrivals are therefore equally valid now as in thefuture.

This is exactly our point. B747-400 night flights currently disturb residents on bothtake off and departure at both ends of the runway. They will not become any less

disturbing in the future simply because they happen more frequently. Residents upand down the flight path have complained about the noise of these flights to no avail.This is a recognised current problem and cannot be allowed to become an evenbigger problem in the future.

As discussed previously, the area under the 95 dB(A) SEL contour indicates aslight risk of sleep disturbance provided the events are less than six per night.The numbers of dwellings beneath the aircraft footprints are given in Table 5.Appendix A provides further details of areas, dwelling and population countsfor all SEL footprints.

The assertion that six SELs of 95 dB will not disturb someone but that seven might,shows the lack of common sense in the technical reports that these consultants havechosen to support the airports flimsy case for scheduled night flights. We would bevery happy to demonstrate to councillors what this level of noise means in practice.

A copy of this document, and many others, can be found in theNo Night Flights Archive at:www.NoNightFlights.info
http://www.nonightflights.info/http://www.nonightflights.info/http://www.nonightflights.info/http://www.nonightflights.info/

Response to Night Flights Proposal

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Transcript of Response to Night Flights Proposal