Government Aviation Consultation: summary of HACAN response

By John Stewart


This is a summary of the 12 key points HACAN and HACAN East will be making in response to part one of the consultation.  Feel free to use them in any response you may make.


The Government is consulting on its aviation strategy in two parts.  Part one was published in July.  The deadline for responses is 31st October.  It can be found on the Department for Transport’s website:  The second part of the consultation, asking for evidence-based submissions on whether will be a need for more capacity, particularly hub, capacity in London and the South East for it to retain its excellent connectivity to the rest of the world is expected to be published in the Autumn.


1. We believe the consultation has attempted an honest appraisal of the contribution of aviation to the economy.  However, there are areas which need further work including, an estimate of the cost to the economy of the tax-breaks the aviation industry enjoys in terms of tax-free fuel and its exemption from VAT; and the economic costs of the noise, air pollution and climate change gases aviation produces.


2. We support the fact the Department for Transport has started a piece of work to identify options to dealing with slots.  We believe the current way slots operate at Heathrow is a key barrier to both the airport being run more effectively and in theUK getting the most out of it economically.  If slots were more flexible there would be more chance of airlines concentrating on using them to operate more long-distance flights to the emerging economies of the world instead of holding on to their slots to near-Europe.


3.  We do not think that a convincing case has been made that climate change emissions can be reduced by simply relying on cleaner technology, the EU Emissions Trading System and the Single European Sky Agreement.  The Government needs to use every tool at its disposal.  It needs to include aviation in its carbon budget and it needs to endorse the target of cutting aviation emissions to at least their 2005 levels by 2050.


4. We welcome the recognition of the potential of tele-conferencing and of rail as alternatives to air travel.


5.  We welcome the recognition of the number of people affected by noise from Heathrow:


Numbers of people living with the 55 Lden contour

Airport                      No of people          % of people affected across Europe

Heathrow                            725,500                    28.5%

Manchester                          94,000                     3.7%

Glasgow                                63,600                     2.5%

Birmingham                          47,900                     1.9%

Aberdeen                             16,300                     0.6%

Edinburgh                            15,000                     0.5%

LondonCity                         12,200                     0.5%

Southampton                       12,100                     0.5%

Gatwick                  11,900                                 0.5%

East Midlands                     10,500                     0.4%

Stansted                                9,400                      0.4%

Luton                                    8,600                       0.3%

LeedsBradford                    8,400                       0.3%

Newcastle                             5,900                      0.2%

Liverpool                               5,700                       0.2%

Totals                                     1,044,300                41.0%

Source: European Commission, CAA. Figures based on the populations


* The table probably underestimates the numbers affected by London City Airport as the Lden metric can underestimate noise at airports without night flights.



 6.  We welcome the fact that over 30 pages are given over to noise and that the consultation asks questions that haven’t been asked for decades and opens doors previous governments kept firmly shut.  We argue that new noise policies shouldn’t just apply to the 3 designated airports (Heathrow, Stansted and Gatwick) but to all airports.


7.  We feel strongly that the Government should not retain the 57 dB LAeq, 16h contour as the way of measuring noise annoyance.  It does not tally with reality.  For example, at Heathrow, places like Fulham or Putney, both plagued by aircraft noise, fall outside this 57 decibel contour; and, atLondonCity, places like Leytonstone and Wanstead are outside the contour.  Nor is it consistent with the levels recommended by the World Health Authority, nor the method of measurement favoured by the European Union. The EU required member states to use 55 Lden to measure noise annoyance when drawing up their noise action plans in 2009.  The difference in the numbers affected at Heathrow compared with the 57 Leq method is enormous: over 725,000 people compared with just over 250,000.  The Government should either go for 55 Lden or 54 Leq.


8.  The Government should produce annual noise maps – using either 55 Lden or 54 Leq – for the designated airports and should ensure such maps are produced for all airports.   Consolidated maps should be required for airports where residents are impacted by two airports – such as Heathrow andLondonCity.


9. We are delighted that the Government has said quite clearly that, in the vicinity of airports, noise must be given priority: “the Government believes that at the local level, individual airports working with the appropriate air traffic service providers, should give particular weight to the management and mitigation of noise in the immediate vicinity of airports. Any negative impacts that this might have on CO2 emissions should be tackled as part of theUK’s overall strategy to reduce aviation emissions, such as the EU ETS. This principle will be particularly significant when considering changes to procedures such as noise preferential routes or the introduction of new procedures such as continuous climb departures.”


10. We are particularly pleased that the Government has recognized the need, where at all possible, for some respite from the noise for local communities: “For those who are already affected by noise, and especially where frequency of movements has increased over time, the Government believes that it is important to give respite wherever feasible.”  Those words describe exactly the situation experienced by hundreds of thousands of Londoners who suddenly found themselves with a noise problem in the mid-1990s when, without consultation or compensation, the point at which aircraft were expected to join their final approach path to Heathrow was extended 2-3 miles east. (It also affects residents across parts ofBerkshire and Oxfordshire, when the east wind is blowing).  The areas affected have never recovered.

See our video:

and publication:


11. Helicopters can be a real problem, particularly inLondon and the South East.  We welcome the recognition of this in the consultation and the commitment to consider how to address noise from helicopters in the review of the 2002 guidance. The Government should look at the possibility of charging helicopters per mile travelled (with emergency helicopters being exempt) to reduce the number of helicopters in the sky.


12. Airport Consultative Committees, as currently constituted, could not fulfil the wider role that the Government has in mind for them.  We welcome, therefore, the intention to review, update and consult on the 2003 guidance to consultative committees.  HACAN has made some practical suggestions on how consultative committees could be improved.


3 thoughts on “Government Aviation Consultation: summary of HACAN response

  1. The 57dB is greater thant 55dB EU standard but recently it seems that even 55dB does not reflect the real health impact. The existing limits apply the A curve which does not consider very low frequencies that are significant part of the aircraft noise spectrum. Why it is such important?
    While the modern windows and other protection means do block higher frequencies, the low frequencies are blocked very very poor, so there is
    no effective way to protect people inside the houses against very low freqs.

  2. I think it is true that even 55 Lden is too high. Certainly there are a lot of people in London impacted by Heathrow who live outside that contour. The World Health Organisation has found that ‘the onset of community annoyance’ starts at 50 Leq. But you are right about the low-frequency noise. It is not captured properly by any of these measurements because they are using ‘A’ weighted measurements when, in order to capture the low-frequency, they should use ‘C’ or ‘D’ weighted measurements. In this consultation we are supporting either 55 Lden or 54 Leq because both are a big improvement on the 57 Leq that exists at the moment

  3. Items 2 and 3 are somewhat contradictory I feel. Shifting slots to more long haul flights will increase carbon emmisions substantially, so we need to reduce carbon in some other way if we shift to long haul.

    The following is an extract of an article I wrote about this consultation. I was going to put it on a website that is no more, but this is probably the best place for it anyway:

    Last year the Coalition government embarked on a revision of the UK aviation strategy with a document that was unambiguous: “The previous government’s 2003 White Paper, The Future of Air Transport, is fundamentally out of date, because it fails to give sufficient weight to the challenge of climate change.” On matters carbon the Conservatives, and indeed Liberal Democrats, had come a long way in the previous ten years. But one year on the nearest there is to progress on carbon in the new draft strategy is a commitment to “continue to push for international agreement.” Despite firm advice from the statutory Committee on Climate Change no decision has yet been made to include aviation emissions in the carbon budget. It is instructive to imagine how the strategy would have been different were man-made climate change not to exist. You would hardly need to change a word.
    It may be that ministers hope that the Emissions Trading Scheme will create a cap on carbon and that a market in carbon credits will take over. In reality the credits are cheap, and it’s ‘business as usual’. Indeed some of the very airlines being encouraged to fly to the UK are refusing to take part in the ETS. The scheme is a huge step forward but it will require delicate adjustment of quotas, and vigilance to ensure that ‘off setting’ projects are genuine and would not have happened anyway. Even then more concerted effort will be needed to actually cut carbon, rather than just slow down growth. Only when we accept that carbon must be rationed across the globe will we be able to rely on trading of carbon credits.
    The future for airports in the South East, as well as for night flights, awaits further consultations, but airports in the rest of the country get the green light. Expansion is encouraged, as are subsidies of the kind that brought us flights for a fiver across Europe (only to leave second home owners stranded later when the bonanza ended.) So keen is the government to see new routes that they plan to open up regional airports to foreign airlines regardless of whether there are reciprocal deals in place to allow UK airlines to compete. Only in Britain is liberalisation put ahead of fair competition.
    In London at least we should be reducing the number of flights, if only to improve the customer experience. And who would object to that? Business would complain, but the UK could still have growth. And the Olympics will still have. We simply have to encourage expansion of other sectors of the economy which are more appropriate for our time, such as green energy. Business doesn’t need continual growth in travel. On the contrary, adapting to the use of telecommunications and regional operations will make business more competitive. As for leisure travel the economy would be better served by more holidaying in the UK.