CPRE Leicestershire

Press Release to local newspapers, September 26th, 2008: NO REALISTIC CONTROLS OVER ENVIRONMENTAL BLIGHTING BY AIRPORT'S ACTIVITIES

Members of a coalition of residents' and environmental organisations met this week with officers of North West Leicestershire District Council (NWLDC). Grievances are principally concerned with noise due to night-time flying. The coalition was made up of representatives of PAIN, DEMAND, CPRE and Melbourne Civic Society.

The implications inherent in the proposal by East Midlands Airport to extend the runway to just over 3 kilometres are a major concern, additional to the existing chronic night time noise disturbance.

Those already adversely affected by the airport's activities are worried that the controlling local authority (NWLDC) have not been given full information regarding the effects the current planning application will have. Representatives of residents' groups have asked that a full Environmental Impact Assessment should be carried out in order to assess the cumulative effects of the growth of the airport, including a succession of 'permitted developments', which do not require full Planning Permission.

During the meeting at NWLDC's Coalville offices it came to light that the local authority had written to Parliamentary Under Secretary of State Jim Fitzpatrick, requesting that he 'designates' East Midlands Airport for night-time aircraft noise controls under the 1982 Civil Aviation Act.

The Leicestershire Branch of the Campaign to Protect Rural England (CPRE) wrote to John Prescott in 2000 requesting 'designation' for the same reason, which was subsequently refused. Others have similarly tried to use this avenue of environmental control without success. The reason given by the Department for Transport is that 'local controls' must be sought. The power of designation, it seems, is good enough for the three major airports in the South-East but not for the East Midlands.

Of considerable concern is the state of an offer made to NWLDC in 2000, on behalf of the airport, to introduce a 'Quota Count' night-time noise control system as part of a further runway extension development. Such systems are in place at the 'Designated' airports - Heathrow, Gatwick and Stansted - and rely on a combination of movement and points-based noise limits for night-time flights, determined by the Secretary of State for Transport.

However, whilst the 2000 offer is still on the table - over eight years later - neither the planning authority (NWLDC), nor the airport's management, appear to have made any concerted effort to reach an agreement as to the implementation of the proposed scheme. Which party is at fault? Are both equally culpable? The public is entitled to an explanation.

East Midlands Airport did publish a 'Ten Point Plan' which claimed to tackle noise and other environmental impacts. This was subjected to close scrutiny by residents' and environmental groups and was found largely wonting in that the controls suggested by the airport were worthless in practical terms.

We expect a similar refusal by the DfT to 'designate' EMA, this time bolstered by the 2006 Civil Aviation Act, which has 'local controls' written into it. However, the 'competent authority' (NWLDC) has to recognise that the environmental problems caused by unrestricted night-flying are trans-boundary. That is, complaints come from Leicestershire, Nottinghamshire, Derbyshire and East Staffordshire.

It is perhaps difficult for people not directly affected by overflying aircraft during the night to appreciate the disturbance and discomfort due to interrupted sleep. One representative commented: 'If neighbours decided to start up petrol-driven lawnmowers at three in the morning, or if an all-night HGV business operated in their street, there might be a little more empathy!'

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In addition, the following comments have been sent to the Chairman of the East Midlands Airport Independent Consultative Committee (September 29th, 2008)

Two years ago, the Council of the EU adopted the Revised Strategy for Sustainable Development, the heart of which was aimed at 'reducing transport noise at source and through mitigation measures to ensure overall exposure levels minimise impacts on health.' Here in the East Midlands the issue of environmental noise due to aircraft operations at night is highly relevant and perhaps more so than anywhere else in the UK. The Commission's Report on Directive 2002/30/EC admits that the number of people in the Community adversely affected by aircraft noise, particularly at night, has increased. Not only this, the Commission predicts that the number of people affected in this manner will continue to increase.

Two invaluable reports on the effects of aircraft noise on exposed populations appear to have been sidelined. Certainly the ANASE Report was delayed, if not suppressed - i.e. 'Attitudes to Noise from Aviation Sources in England'. The other report, specific to East Midlands Airport, was Ian Diamond's research (The Diamond Report) carried out with others, among whom was Steven Stansfield. This was published eight years ago and its findings were clear. That is, it would be pointless to follow up that work with more expensive and time consuming research to define precise parameters for dose-response. Prof. Diamond sensibly recommended instead that follow-up work should instead investigate adverse health effects. Both reports are on the DfT website and follow-up work has been carried out, notably the RANCH and HYENA projects.

In fact, there is a welter of professionally refereed scientific research into the effects of poor sleep on health, caused by external noise events. Unfortunately, it is only the well-publicised research that gets into the popular press and radio/TV soundbites - such as RANCH and HYENA. It is now established beyond any doubt whatsoever that there is a causal relationship between cardiovascular disease and chronic sleep disturbance due to noise. More recent research correlates Type II diabetes with chronic noise related sleep interference. There are suggestions too that certain other diseases can arise from chronic noise-disturbed sleep.

This is a huge public health issue and given the research already published, it is a scandal that nothing realistic is being done to prevent this harm being caused on an epidemiological scale. The concept of sleep protection as a public health measure simply does not exist. East Midlands Airport surely poses a threat to the health of large populations exposed to noise at night from aircraft operations. The most recent WHO findings (2005) indicate that adverse health effects occur when average bedroom noise levels exceed 30dB(A)Leq. WHO also add that 'a limited number of events per hour with an energy exceeding the baseline level of LA max 45dB(A) level (inside bedrooms)' will induce adverse health effects. WHO also state that there should be a never-exceed peak level inside bedrooms at night of 60 dB(A) - of great significance to people living in Kegworth, Castle Donington and Melbourne. In the meantime, ICAO, IATA and governments all ignore the World Health Organisation recommendations. These health effects should be included, as per question 4 on page three of the DEFRA Environmental Noise Regulations consultation document.

Inextricably bound up with 2002/30/EC is the European Noise Directive (END). The intention behind this Directive is '...to prevent, avoid and reduce the harmful effects (including annoyance) due to air traffic noise.' Clearly, there is a mandate to consider adverse health effects due to the deprivation of restorative sleep. These issues are deliberately played-down in Section 3 of the DEFRA consultation. In fact, the comments in Section 3 appear to not just understate but misrepresent the current knowledge base regarding health effects. The Report from the Commission on 2002/30/EC (COM 2008, 66 Final, dated 15/2/2008, page 3) states that the intention of the Directive is '...to prevent a worsening of the noise climate and to limit or reduce the number of people significantly affected by the harmful effects of aircraft noise.' With reference to the state of affairs here in the East Midlands, there has been increased disturbance resulting from airspace changes over previously tranquil rural areas.

However, 2002/30/EC stipulates that any restrictions applied must be non-discriminatory and conform with the ICAO concept of a 'balanced approach'. Without any guidance on acceptable or safe levels of noise EMA will naturally continue to override the rights of residents living under arrival and departure routes to a decent Quality of Life.

EMA will need to re-model its historic noise contours, since the newer software version is deemed to be more accurate in determining cumulative noise levels. That is, there is a mismatch between the old and new Leq contour maps. Also, a target noise budget relying on a level set by a historic contour is not plain dealing, since fleet mixes have changed out of all recognition. This simply allows the number of less-noisy flights to grow and the frequency of disturbance to increase.

It is our understanding that the Express Carrier Industry have asked for 'protection' under this Directive to fly Chapter 4 aircraft at any time of the night. Until the findings of research into the ill-effects of sleep disturbance due to aircraft noise are given the recognition deserved there can be no 'balance' and once again, as happened following the close scrutiny of the Ten Point Plan, there seems to be little ground for agreement between key industry stakeholders and residents'/environmental interests.

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