Louise Ellman

I don’t know Louise Ellman personally.  The only time we have spoken is when I gave evidence to the Transport Select Committee last year.  But it surprises and disturbs me that, as chair of the committee, she can write – or at least put her name to – an article of such stunningly poor quality as appeared in Politics Home on Friday.
http://centrallobby.politicshome.com/latestnews/article-detail/newsarticle/louise-ellman-mp-airport-decision-long-overdue-and-desperately-needed/

Let’s look at its low-lights.

Ellman starts: “For half a century, Britain has been paying an increasingly high economic and social price for the failure of successive governments to take decisions about how to expand London’s airports”.  

Come on, Louise!  For 50 years?  Since1963?  The year you turned 18; when I was a boy in short trousers; and Harold Wilson was still 12 months away from becoming Prime Minister for the first time.

More significantly, in 1963 Southampton was more probably important than Heathrow; ocean liners, not aircraft, were the mode of transport for inter-continental journeys.  Just four years earlier my dad, who had been teaching in Zimbabwe, retuned to the UK by ship.  He never considered the plane as an option.  Indeed, I don’t think he flew in his entire life. 

Let’s glance at the state of aviation in 1963.  Heathrow ruled the European roost even then.  This from Wikipedia: “In 1961 Frankfurt already had 2.2 million passengers and 81,000 take-offs and landings, making it the second busiest airport in Europe behind London Heathrow (my emphasis).” 

Charles de Gaulle was but a glimmer in the planners’ eyes.  It didn’t open until 1974.  But perhaps it’s Schiphol Louise had in mind.  1963 was the year the construction of the current airport began, to be opened in 1967 by HM Queen Juliana

Ellman’s gushing prose continues:  “Heathrow has been full for a decade.  This means that the UK has started to lose out to rival hubs in e.g. Paris, Frankfurt and Schipol.”

Her first sentence is simply wrong.  Heathrow’s runways are operating at about 99% capacity but it has the terminal capacity to cater for another 20 million passengers a year.  More passengers using larger planes remains an option for Heathrow Airport.

Ellman does acknowledge that our existing links with well-established markets are excellent.  She fails, though, to point out that this makes London the top city in Europe in which to do business.  Global property consultants Cushman & Wakefield’s 2011 The European Cities Monitor found London topped the league for the 22nd year out of 22. Cushman & Wakefield commented: “London is still ranked – by some distance from its closest competitors – as the leading city in which to do business. Paris and Frankfurt remain in second and third place respectively.”   London retained it position in 2012.

Ellman gushes on…..about Let Britain Fly: “The Campaign, which was launched last week, is the biggest and most influential business-led campaign ever created to address the issue of airport expansion. I was delighted to take part in the Launch and offer my strong support”.

It may be or may not be the biggest but to argue it is the “most influential” just weeks after it has been formed is, frankly, nonsensical.  Both Louise and I are both of an age to remember the early days of the Beatles (1961 I think it was – the era when Heathrow was allegedly already falling behind other European airports).  To have argued the they were the “most influential” band when they started out in the Cavern Club in Liverpool, a city Ellman has served conscientiously over the years, would have been meaningless.  They became influential.  Let Britain Fly might become influential.  Or it might crash land like it predecessor bodies:  Flying Matters and Freedom to Fly.  Her breathless prose doesn’t allow for that eventuality. 

The gush reaches its apex:  “Last week saw what I believe will prove to be a defining moment in the campaign to restore the UK’s pivotal status in the global aviation industry”.

Wow!  Breathless stuff Louise!  Pity is it would be better coming from a Mills and Boon writer of romantic fiction than the chair of Parliament’s Transport Select Committee. 

There is a debate to be had about future capacity needs.  There are serious discussions taking place in different fora a around the country.  It is a debate that HACAN seeks to take part in constructively.

But let’s debate on reasoned arguments rather than breathless prose; on factual statements; not bland assertions.  Mills and Boon has no place in this debate.

Fighting a 3rd Runway…..at Hong Kong

This blog is a bit different.  Last week I spent a day with Michael Mo, the young man who heads up the campaign against a 3rd runway at Hong Kong Airport.  He had a fascinating story to tell.   My knowledge of Hong Kong Airport was limited.  I knew that the old, city-centre airport had been shut down for safety and noise reasons and been replaced by a new two-runway off-shore airport.  But that was about it.

Michael explained what was happening.  A third runway is being proposed.  200,000 people would be under its flight path, experiencing noise for the first time.  The aim is to create a bigger hub: to increase interchange passengers from 30% of the total to 49%.  The Hong Kong authorities want the new runway up and running by 2023 but they face growing opposition.

As we shared lunch in the Five Bells in Harmondsworth – one of the pubs under threat if a Heathrow 3rd runway ever went ahead – Michael told me about campaigning in Hong Kong.  His biggest supporters are Hong Kong Friends of the Earth, who will publish a cost-benefit analysis of the expansion proposals by the end of the year.  But he also has support within the local aviation industry and from…..the Dolphin Conservation Society.  Michael noticed my bemused look.  He explained.  The famous Hong Kong White Dolphin is an endangered species.  There are only 65 left, down from 200 in 1998.  And a new runway might eliminate them altogether.  Hong Kong Greenpeace has yet to back the campaign.  Michael is threatening to join Greenpeace UK given the huge contribution it made to preventing a 3rd runway at Heathrow!

Bringing local residents on board presents particular challenges in Hong Kong.  Many believe they can sell up if a new runway is built.  But also a lot of the residents’groups in the areas affected are controlled by ‘pro-Bejing forces’ which don’t encourage rebellion.

The campaign is taking place within a wider policy debate.  What Michael called ‘the China camp’ tends to favour airport expansion, both in Hong Kong and on mainland China.  There is also a ‘high-speed rail camp’ which argues that a number of the regional airports built in China in recent years to boost GDP now stand virtually empty because of a lack of demand.

The campaigners also criticise the authorities for looking at the expansion of Hong Kong Airport in isolation from Macau and Shenzhen airports, both just 30 miles away.  And they are critical of the emphasis on the hub.

As we compared notes, it became clear that many of the issues we faced were similar.  And our campaigning methods are similar.  What was clear, though, is that a decade ago we would not have been sharing lunch.  Campaigners were not linking up across oceans in this way.  

As we said goodbye, it was clear to me that Michael is a man on a mission, believing he can succeed.  He’s buoyed up by the success of the Heathrow campaigners in winning against all the odds.  He senses success is quite possible.  I’ll drink to that.

Let Britain Fly

Let Britain Fly had a difficult birth today.  Its proud parent, London First, surrounded by a glittering array of big names from the business world, overdid the hyperbole.  Baroness Jo Valentine, chief executive of London First, said that it was not acceptable for politicians “to dither” over new runways “and let our economy wither.”   She even went on to ask somewhat over-dramatically, “Do we really want to become an also-ran in the global race?”

Baroness Valentine must know this is exaggeration, even scaremongering.  Whatever the pros and cons of expansion in the longer term, the facts are clear: there is no rush for a decision to be taken.  The Department for Transport has said that there is enough spare runway capacity in London and the South East until nearly 2030.  And survey after survey shows that London remains the top city for business in Europe because of its unparalleled air connections to the rest of the world. 

The annual, and influential, survey, carried out by global property consultants Cushman & Wakefield, The European Cities Monitor rates London the top city in which to do business in Europe.  In 2011, it found London topped the league for the 22nd year out of 22. Cushman & Wakefield commented: “London is still ranked – by some distance from its closest competitors – as the leading city in which to do business. Paris and Frankfurt remain in second and third place respectively.”  The survey found London owes its position to its excellent links to the rest of the world. It has the best external transport, best internal transport and top telecommunications.  The 2012 survey produced the same result.

Despite the alleged “dithering” more passengers fly in and out of London than any other city in the world.  Paris, its nearest European competitor, is in 5th place.

There is a genuine debate to be had about future airport capacity but Let Britain Fly – and his parent body London First – will lose credibility if it continues to exaggerate the urgency of the need for expansion.

London First and its backers also face another challenge. It is easy for London to make general calls for airport expansion without exploring its impacts on local communities.  We hear the obligatory words that the needs of local residents must not be overlooked.   But it has never publically faced up to the question: is there any occasion when the environmental and social impacts of expansion at any particular airport are so unacceptable that expansion should be ruled out, whatever the economic benefits?  It needs to do so if it is to engage fully in the debate.

Let Britain Fly will have a gilded childhood.  £500,000 is going to be spent over the next two years.  But its parent body and supporters need to get over the excitement of its birth, calm down and stop giving the impression that London’s economy is in crisis because of a lack of runways.  It is simply not true.   

Unsound measurements

They won’t know whether to laugh or cry this weekend, the residents of Sabine Road in Battersea.  Their street has been named one of the quietest in London“Sorry you did say ‘quietest’ didn’t you?”  They’ll be asking each other over breakfast as the next plane roars overhead.

Sabine Road, not far from Clapham Junction, is in an area where there have been countless complaints about aircraft noise the years.  It’s on the flight path to Heathrow.  

So what is going on?  

The researchers, from the noise consultancy firm 24 Acoustics have fallen into the classic trap of using the official UK method of measuring aircraft noise.  

“To determine the quietest streets, researchers used existing data to locate which ones were outside of the 57 decibel noise contours for airports, and had a night road traffic noise level of lower than 35 decibels”

This reliance on the 57 decibel noise contour has made a mockery of their results.  It has meant that aircraft noise can be heard in just about all their top quietest streets.  Streets in places like Fulham and Putney make it into the top 10.

http://www.standard.co.uk/news/london/silent-nights-the-capitals-10-top-quietest-streets-revealed-8928506.html

The blame lies not with the researchers.  I imagine that in good faith they accepted the official measurement of noise annoyance from aircraft.  It was a mistake waiting to happen.  For years HACAN, along with many other bodies, has argued the measurement is utterly misleading.

We wrote in our response to the Airport Commission’s consultation on noise:

“The current 57 db Leq contour – the official area which defines where community annoyance sets in – excludes places like Putney and Fulham in West London!  Not the real world!”

The European Commission agrees with us.  It requires member states to use a different metric – called 55Len – when drawing up their noise maps.  That is more realistic.  It extends the noise boundaries to places like Vauxhall and Clapham.  But even it does not cover all the places where people are annoyed.  The ANASE Study, commissioned by the last Government but quietly buried when it found the findings were not to its taste, found that there is significance noise annoyance well beyond the 55Lden contour.

Of course the current 57 decibel cut-off point suits the aviation industry down to the ground because it minimises and underestimates the numbers affected by noise. 

However, here are distinct signs the tide is turning.  Sir Howard Davies, who heads up the Airports Commission, is known to be looking seriously at a more realistic metric.  

In their responses to the Commission’s noise paper, MPs queued up to criticise the current cut-off point:

https://www.gov.uk/government/publications/stakeholder-responses-to-airports-commission-discussion-papers

Mary Macleod MP: 

“There is widespread evidence that the existing measure of the threshold of annoyance is inaccurate and misleading.”

Zac Goldsmith MP:

“The measurement of noise – and of noise annoyance/disturbance – needs revising. Currently it is misleading.  Any noise measurement that does not reflect reality lacks credibility”.

Former Transport Secretary Justine Greening MP: 

“I believe this strongly shows that taking a traditional 57dB approach to assessing the level of noise annoyance from any new aviation strategy will exclude a large number of people who will be annoyed and affected but live outside of the 57dB noise contours.”

John Randall MP: 

“Clearly, a 57dB threshold is unhelpful if it excludes population areas that are experiencing significant annoyance from aviation noise”. 

Murad Qureshi for the London Assembly Labour Group:

“The committee has previously recommended the adoption of an Lden measure and the use of lower thresholds for identifying the areas most affected by aircraft noise”.

Boris Johnson, the Mayor of London:   

“The development of a new noise metric is strongly supported. It must fully represent sensitivity to and the impacts of aviation noise and how individual aircraft events are experienced during different times of day and night”. 

Even the Government in its Aviation Policy Framework, published in March, recognised the current measurement was flawed:

“Average noise exposure contours are a well-established measure of annoyance and are important to show historic trends in total noise around airports. However, the Government recognises that people do not experience noise in an averaged manner and that the value of the LAeq indicator does not necessarily reflect all aspects of the perception of aircraft noise. For this reason we recommend that average noise contours should not be the only measure used when airports seek to explain how locations under flight paths are affected by aircraft noise.” 

 The Airports Commission has been charged with reassessing the way aircraft noise is measured.  A change to a more realistic noise metric could be the most lasting    decision it will make.  It will ensure that future aviation policy decisions are based on sound measurements.  

And it will save future researchers falling into the same trap that ensnared the benighted people from 24 Acoustics.  

Airports Commission Noise

There are rumours – just rumours – that Sir Howard Davies may be leaning towards a third runway at Heathrow, but only if he is satisfied that the noise problems can be mitigated.

If that is the case, the response to his Airports Commission’s noise paper will have given him considerable food for thought. 

A summary of the responses can be found at : https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/252998/Non-technical_responses_to_Noise_Discussion_paper.pdf

And the full report at

https://www.gov.uk/government/publications/stakeholder-responses-to-airports-commission-discussion-papers

The Commission revealed at the end of last week that the noise paper had generated more responses than any of its other papers.  And that, significantly, over 90% of those responses concerned Heathrow.  75%of respondents expressed opposition to further expansion of the airport.

Moreover, respondents doubted that the noise climate could be sorted.  Here’s what the Mayor of London wrote in his response:  “More runways would mean many more people exposed to noise – contrary to Heathrow’s recent pronouncement.It is misleading for Heathrow to suggest that a three runway airport would be quieter than the airport is today – a claim made in Heathrow’s long-term options submission to the Airports Commission. Thisclaim relies on the third runway being less than half utilised in 2030 and veryoptimistic assumptions on the rate of technological improvements”.

Already Heathrow is in a noise league table all of its own.  According to the European Commission over 725,000 people living under the Heathrow flight paths, that is, 28 per cent of all the people impacted by airport noise across Europe, more than Frankfurt, Madrid, Paris and Amsterdam airports combined.  Of the other London airports London City affects 12,200 people; Gatwick 11,900; Stansted 9,400; and Luton 8,600.

Howard Davies, a thoughtful and thorough man, has expressed the view that at least one more runway is needed to meet future demand in London and the South East.

http://www.theguardian.com/uk-news/2013/oct/07/britain-new-runways-airports-south-east-england

The response to the Commission’s paper suggests that Heathrow should be ruled out on noise grounds.

Views came in from residents, politicians and campaign groups alike.

In a spirited response, the former Transport Secretary, Putney MP Justine Greening, said, “The issue of noise has always been dominant in decisions regarding Heathrow expansion” adding “If Heathrow expansion is allowed I believe it will be one of the biggest planning and transport strategy mistakes of this century, irreversibly blighting Londoners quality of life forever”. 

Richmond and North Kingston MP Zac Goldsmith re-enforced that view: “A third runway at Heathrow would be a noise disaster and would lead to a serious further reduction in the quality of life for hundreds of thousands of London residents”. 

Fellow Conservative MP John Randall made a similar point: “a thirdrunway at Heathrow poses a real risk of endangering the quality of life, and possibly the life, of affected residents.”

Brentford and Isleworth MP Mary Macleod said, “The noise impact of Heathrow airport is already significantly affecting the quality of lives of local residents and any future plans involving an increase in aviation noise should not be tolerated.”

The London Mayor, Boris Johnson, put it cogently and concisely: “London is exposed to more aviation noise than any other city in Europe.”

Murad Qureshi, writing on behalf of the Environment Committee of the London Assembly: “Noise, as well as other environmental factors clearly swings the debate about airport capacityagainst any expansion of Heathrow”.

Noise has long been regarded as a Cinderella pollutant.  But in the case of Heathrow it could be what stops a third runway coming to the ball.

A third runway will be the death of you

The news last week that deaths from stroke, heart and circulatory disease are up to 20% higher in areas under the Heathrow with high levels of aircraft noise than in places with the least noise is startling.  But is it true? 

Dramatic findings, but true?

Within hours of the release of the report, Back Heathrow (http://www.backheathrow.org/), the Heathrow Airport funded body promoting the expansion of the airport, had countered by pointing out that just days earlier researchers had found that Richmond – right under the flight path – was the healthiest place in Britain.  A survey showed that men in Richmond could expect to enjoy 70 years of healthy living (women 72).  Wokingham, Surrey and Windsor – all places affected by aircraft noise – also featured high up in the list.

http://www.dailymail.co.uk/news/article-2424383/Richmond-Thames-place-long-healthy-life.html

Both pieces of research were carried out by credible researchers.  Can they be reconciled?  I believe they can.  Firstly, and most importantly, the researchers were looking at different things: it is quite possible to live in Richmond, Wokingham or Windsor and both expect to have 70 healthy years of life and have a 20% greater chance of dying of a stress-related illness.

High-quality research

And, secondly, the standing of the Heathrow flight path researchers – Imperial College – and the quality of their carefully-caveated research, covering 3.5 million people, makes the findings hugely important.  This is why it was extensively covered in the media.  So far, Governments have ignored all similar research which has shown a consistent link between aircraft noise – indeed noise generally – stress and ill-health.  They didn’t deny the findings but presumably felt that some ill-health and early deaths was a price worth paying for the economic benefits aviation brought. 

Influence Airports Commission?

It is too early to say whether this new research with its dramatic findings will suffer the same fate.  What is certainly does do, though, is raise the stakes, particularly at this time when the Airports Commission is considering expansion of airports in London and the South East.  Writing in the Independent the day after the research was released, Simon Calder argued, “48 hours ago a correlation between airport proximity and the risk of heart attacks or strokes was not in the public domain. Now that it is, the spectrum of harm from airports has extended from nuisance to a serious public health threat”

http://www.independent.co.uk/voices/commentators/a-health-warning-that-could-stall-debate-on-expansion-of-our-airports-8867388.html

No wonder Back Heathrow was so quick to tweet its rebuttal. 

When is a NIMBY not a NIMBY

I’m taking a risk with this blog.  So often campaigners are dismissed as NIMBYs.  And I’ve been campaigning for over 30 years.

The blog was prompted by this news story from India.  There are big local protests in Kerala, in the south west of India, against there are plans by a private company to build a large new airport, for low cost airlines, at Aranmula. The site is within 100 km of two international airports – at Kochi and Thiruvananthapuram. These airports bring in tourists to Kerala, and it is intended that it brings in pilgrims to a nearby site. The land at Aranmula is greenfield, and there are plans to take at least 350 acres, and perhaps much more for an aerotropolis. Local people fear it could destroy paddy 

land and damage the region’s water source. 

The IPCC report and ICAO

The IPCC Report should act as a wake call to the aviation industry

It is just coincidence.  On the day that the IPCC report, calling for immediate action to tackle climate change, is published ICAO (the International Civil Aviation Organisation) is continuing its leisurely deliberations in Montreal to find a way to reduce CO2 emissions from aviation that is acceptable to the governments of the world.

ICAO, an arm of the United Nations specializing in aviation, moves at a snail-like pace.  It has been considering aviation emissions for years but still no recommendations.  Its latest round of deliberations has been prompted by the recent inclusion of aviation into the European Union’s Emissions Trading Scheme which would have hit all planes using European airports.  But, since most of the rest of the world refused to play ball, the EU suspended the scheme and everybody crawled back to ICAO for yet more negotiations.

The words “urgent” and “ICAO” have never really gone together but today’s IPCC Report suggests that ICAO needs to take lessons from Usain Bolt and get sprinting.  

The words “urgent” and “ICAO” have never really gone together but today’s IPCC Report suggests that ICAO needs to take lessons from Usain Bolt and get sprinting.  Aviation is set to become a serious obstacle to the worldwide community achieving the reductions in global warming gasses required to prevent runaway climate change.

The industry keeps quoting the figure that aviation only accounts tor 2% of worldwide emissions.  That figure is utterly misleading.  It emerged in the early 1990s since when the number of aircraft in the world’s skies has mushroomed.  Although aircraft are becoming cleaner, a more realistic figure is thought to be between 3.5% and 5%.  And in rich countries it is higher.  The worldwide average is only so low because so many people in poorer countries never set foot in an aeroplane.  According to the WorldWatch Institute, only 5% of the world’s population has ever flown:

http://www.worldwatch.org/node/4346

But it is in the future that aviation will become the real culprit.  While every other industry believes it can find ways to cut its emissions, aviation will struggle.  This is not surprising since aviation is so dependent on oil.  But it means that aviation could account for 25% of UK emissions by 2050.  Worldwide, aviation emissions are set to triple by 2050.

Today’s IPCC Report should act as a wake-up call to the aviation industry.  It doesn’t mean the end of aviation as flying brings important cultural and economic benefits.  It ought to, though, focus minds on the tax-breaks aviation receives: tax-free fuel and VAT-free travel.  A sizeable proportion of flights are over short distances – for example 45% of flights within Europe are 450 kilometres or less.  http://www.foe.co.uk/resource/reports/planes_trains.pdf

Aviation emissions can be cut without crippling the industry.  The industry won’t do it of its own accord.  It needs Government action.  And fast.  That probably rules out the snail-like ICAO which will probably still be debating its next small step when half of Bangladesh lies under water.  Now there’s a thought:  shouldn’t ICAO move its meetings from Montreal to Dacca.  It may concentrate minds.  

European Aviation Campaigner’s conference

Last weekend’s conference in Munich showed just how vibrant the European movement against airport expansion has become.  On Saturday (22nd June) over 250 campaigners from across Europe packed the sports centre in the small town of Attaching, just outside Munich, sharing ideas and plan Europe-wide campaigns.

Ten years ago this sort of conference would not have taken place.  There was little Europe-wide contact between grassroots campaigners.  

But all that has changed over the past decade.  Campaigners have been in regular contact with each other, building up a European network.

And success has followed.  A third runway has been stopped at Heathrow.  Plans for new airports in Siena and Viterbo in Italy have been abandoned. The residents of Munich voted against a third runway in a referendum last March.  There is huge opposition to the proposed new airport for Nantes in Western France.  Tens of thousands of people have taken to the streets of Berlin to protest against airport expansion.  And, of course, every Monday night for the last 18 months thousands of people have occupied the airport terminal at Frankfurt to protest against the impact of the fourth runway.

People at the conference shared campaigning techniques, including an excellent session on the role of direct action, led by Plane Stupid.

But Saturday’s conference didn’t just hear stories of protest.  There were experts talking about the climate change, noise and air pollution impacts of aviation.  And a powerful talk from Alexander Mahler of the think-tank Green Budget Germany outlining the billions lost to the economy as a result of the tax-free fuel airlines enjoy.

The conference issued a manifesto.  Key demands included an end to night flights and an end to the tax-free fuel aviation enjoys.  These demands will form the basis of Europe-wide campaigns over the coming year.

Campaigners across Europe are forging links live never before.  They are determined to see the aviation industry tamed.

HACAN noise

Heathrow Airport’s proposals to reduce noise, published today, are welcome –http://mediacentre.heathrowairport.com/Press-releases/Heathrow-publishes-commitments-on-noise-reduction-measures-57f.aspx.  There is little doubt that, if they were implemented, they would cut noise for residents.  Measures such as respite periods, steeper approaches, improved sound insulation and the plan to fine the noisier aircraft will improve the noise climate.  Some of the proposals, of course, are dependent on the cooperation of other bodies before they could be implemented.  Steeper approaches, for example, would require permission from Government and the agreement of Air Traffic Control.  But the intent is there: Heathrow Airport is proposing concrete measures which will improve matters for residents.

Of course Heathrow understands that, unless it is shown to be dealing with noise, there is no possibility it will get approval for a new runway.  And that is part of the motivation of it producing them now and releasing them at this time – within a month it will be submitting its eagerly awaited plans for a third runway to the Airports Commission.

HACAN has worked with Heathrow on a number of its proposals – in particular the plans for introducing respite periods.  Whatever our differences on expansion (and on night flights), it is in the interests of our members for us to get improvements to the current noise climate at the airport.  We want to be able to point to practical improvements on the ground.

However, our belief remains that these improvements are unlikely to survive the building of a third runway.  The sheer number of planes would wipe out virtually all the benefits.  With a third runway, the number of planes which could use Heathrow would rise from 480,000 to over 700,000.  A fourth runway airport, such as the Policy Exchange is promoting (but which Heathrow believes is not necessary), would allow 960,000 aircraft to use the airport.

History suggests that it is the increase in flight numbers which causes the real noise problems for residents.  The big deterioration in the noise climate – and the big rise in HACAN’s membership – coincided with the last significant rise in flight numbers between about 1991 and 2001.  It was a time when individual planes became quieter but that was off-set by the sheer volume of aircraft flying overhead.  The chances are that the same thing would happen if a third runway was built.

Incidentally, the impact of a dramatic increase in flight numbers is not reflected in the annual noise contours published by the Government.  That is because the metric used to measure noise annoyance assumes annoyance levels will remain the same if the number of aircraft operations are doubled so long as the individual aircraft noise levels are reduced.  Not reflected in the reality on the ground.