NOISE!VIOLATIONLIMITS! · PDF fileA9501

Report to London Luton Airport Operations Ltd Navigation House Luton Airport Luton LU2 9LY A9501-‐R03-‐JGC/B 15 May 2015

LONDON LUTON AIRPORT

NOISE VIOLATION LIMITS

NEW PLANNING CONDITION 11i

L.A. Ref: 12/01400/FUL

BAP Ref: A9501-‐R03/B

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Bickerdike Allen Partners is an integrated practice of Architects, Acousticians, and Construction Technologists, celebrating over 50 years of continuous practice.

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CONTENTS Page No

1.0 INTRODUCTION ........................................................................................................................... 5

2.0 PLANNING CONDITION 11i & 11j ................................................................................................. 6

2.1 Current Noise Violation Limits ..................................................................................................... 6

2.2 New Noise Violation Limits: Planning condition 11j .................................................................... 9

2.3 New Noise Violation Limits: Planning condition 11i .................................................................. 10

3.0 APPROPRIATENESS OF CONDITION 11i ..................................................................................... 13

3.1 Impact on Luton’s Airline Operators ......................................................................................... 13

3.2 Aviation Policy Framework (APF) ............................................................................................... 18

3.3 The Aerodromes (Noise Restrictions) (Rules and Procedures) Regulations 2003 (SI No.1742) . 18

3.4 National Planning Policy Framework (NPPF) ............................................................................. 19

4.0 CONCLUSIONS ........................................................................................................................... 21

Figures

Figure 1: Noise Monitor Locations

Tables

Table 1: Departure Noise Levels 2007 – 2014

Table 2: Summary of Noisiest Departures by Aircraft Types – 2014

Table 3: Summary of Departure Noise Levels of Key Aircraft Types – QC0.5/1.0

Table 4: Summary of Departure Noise Levels of Key Aircraft Types – QC0.5

Table 5: Relationship of Measured Departure Noise Levels and QC Ratings

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Appendixes

Appendix 1: Glossary of Acoustic and Aviation Terminology

Appendix 2: ICAO Noise Certification

Appendix 3: GINFO Database Extract

Appendix 4: Past Noise Monitoring Results: Airbus A300 & A321

Appendix 5: Alternative Planning Condition 11i

This report and all matters referred to herein remain confidential to the Client unless specifically authorised otherwise, when reproduction and/or publication is verbatim and without abridgement. This report may not be reproduced in whole or in part or relied upon in any way by any third party for any purpose whatsoever without the express written authorisation of Bickerdike Allen Partners. If any third party whatsoever comes into possession of this report and/or any underlying data or drawings then they rely on it entirely at their own risk and Bickerdike Allen Partners accepts no duty or responsibility in negligence or otherwise to any such third party.

Bickerdike Allen Partners hereby grant permission for the use of this report by the client body and its agents in the realisation of the subject development, including submission of the report to the design team, contractor and sub-‐contractors, relevant building control authority, relevant local planning authority and for publication on its website.

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1.0 INTRODUCTION Planning consent was granted in June 2014 by Luton Borough Council (LBC) to application 12/01400/FUL submitted by London Luton Airport Operations Ltd (LLAOL). The consent was subject to the imposition of certain planning conditions with respect to several matters including noise. Noise was specifically addressed in planning conditions 11, 12, 13 and 14.

LLAOL submitted a detailed report to discharge planning conditions 11, 12, 13 and 14. This was approved by LBC on the 2nd March 2015. In light of that the new noise violation limits will become effective in September 2015 (6 months after approval of the Noise Control Scheme).

LLAOL and London Luton Airport Ltd (LLAL) have also entered into a Section 106 Town and Country Planning Act 1990 (as amended) Agreement with LBC which includes obligations with respect to noise, given in Schedule 1 Noise Mitigation of the agreement.

The Section 106 Agreement requires LLAOL to submit a draft Noise Management Plan, the draft Residential Noise Insulation Scheme and the draft Non-‐Residential Noise Insulation Scheme to LBC for approval. It also requires LLAOL to operate a Noise Violation Penalty System.

Separate to these matters the Airport operates, in accordance with The Environmental Noise (England) Regulations 2006, a Noise Action Plan (NAP) approved by the Department for Transport (DfT) and the Department for Environment, Food and Rural Affairs (Defra). The current approved NAP includes 55 noise related measures. The Airport also operates in accordance with the Luton Byelaws approved by the Secretary of State for Transport.

LLAOL in accordance with their approved Noise Action Plan actions 16 and 18, reduced the existing noise violation limits on the 1st April 2015 to 80 dB(A) during the night-‐time period (23.00 – 06:59) and 82 dB(A) during the day period (07.00 – 22.59).

This report considers the appropriateness of planning condition 11i which addresses the noise levels arising from the departing aircraft as they overfly the airport fixed noise monitors. These monitors are at approximately 6.5 km from the locations from which aircraft start their departure rolls.

In this report where the noise levels from individual aircraft movements are discussed they are the maximum noise levels, LAmax,T. Appendix 1 provides a glossary of acoustic terminology, and also some aeronautical terms.

This report explains in Section 2, the current Noise Violation Limits (NVLs), those introduced by the recent planning condition 11j, and those introduced by the recent planning condition 11i.

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The report in section 3 discusses the appropriateness of planning condition 11i with respect to the impact on Luton’s airline operators, the current Aviation Policy Framework (APF), and the National Planning Policy Framework (NPPF) specifically paragraph 206.

The report concludes in Section 4 with the conclusions with respect to this technical analysis of condition 11i.

2.0 PLANNING CONDITION 11i & 11j The Airport operates a sophisticated Aircraft Noise and Track Monitoring System. This System includes a network of three permanent noise monitors that measure the noise of individual aircraft movements and the system is also directly connected to the air traffic control radar that collects aircraft flight tracks. The airport will continue to maintain, calibrate, and operate this System or an updated one.

LLAOL will continue to carry out noise monitoring at the following locations:

(i) Pepsal End Farm, Pepsal End, Bedfordshire;

(ii) Grove Farm, Slip End, Bedfordshire;

(iii) Frogmore Bottom, Hertfordshire.

Or, if these locations become unavailable or not appropriate, alternative locations agreed with the Local Planning Authority (LBC).

Figure 1 illustrates the locations of the three noise monitors.

2.1 Current Noise Violation Limits

The Airport has operated for many years a noise violation policy, whereby a surcharge of the Landing and Navigation Service Charge is applied to any take-‐off which causes noise levels at any of the three fixed noise monitors to exceed specified noise violation levels, specifically:-‐

For Day Flights 94 dB(A) 06.00-‐22.59 Local Time (Monday to Saturday) 07.00-‐22.59 Local Time (Sunday)

For Night Flights 82 dB(A) 23.00-‐05.59 Local Time (Monday to Saturday) 23.00-‐06:59 Local Time (Sunday)

In 2011, 2012 and 2013 there were no violations of the daytime noise violation limit. One violation occurred in 2014.

In 2011, 2012 and 2013 there were 11, 3, and 4 violations respectively of the night-‐time violation limit. In 2014 there were 3 violations of the night-‐time limit.

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Recently (1st April 2015), the specified noise violation limits were reduced to:-‐

Daytime 82 dB(A) [a 12 dB reduction]

Night-‐time 80 dB(A) [a 2 dB reduction]

Table 1 illustrates the annual spread of departure noise levels in 2007 to 2014.

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Year (D/N)

Number of Departures in Noise Band, dB LAmax

<70 >=70 <73

>=73 <76

>=76 <79

>=79 <82

>=82 <85

>=85 <88

>=88 <91

>=91 <94

>94 Total

2007 Day

7,400 17,093 17,046 3,277 345 77 36 11 0 1 45,286

2007 Night

456 622 613 224 44 6 1 0 0 0 1,966

2008 Day 9,006 17,421 12,559 3,020 295 49 15 5 0 0 42,370

2008 Night

511 545 466 158 47 14 2 0 0 0 1,743

2009 Day

3,759 10,935 18,175 4,940 537 70 12 3 1 0 38,432

2009 Night

226 352 473 225 47 11 1 0 0 0 1,335

2010 Day

5,388 9,940 16,179 4,997 631 55 32 8 1 0 37,231

2010 Night 370 489 532 262 84 20 4 1 0 0 1,762

2011 Day

4,374 9,316 15,795 3,684 262 41 22 7 0 0 33,501

2011 Night

330 575 609 147 44 10 1 1 0 0 1,717

2012 Day

3,698 10,654 17,207 4,879 340 34 21 11 0 0 36,844

2012 Night

290 530 579 215 39 3 0 0 0 0 1,656

2013 Day

5,009 9,310 19,039 4,529 297 37 22 13 0 0 38,256

2013 Night

405 358 530 235 36 4 0 0 0 0 1,568

2014* Day

5,253 8,404 22,365 5,699 341 21 13 5 1 1 42,103

2014* Night

417 382 705 298 31 3 0 0 0 0 1,836

* 2014 values are BAP estimates rather than official LLAOL numbers.

Table 1: Departure Noise Levels 2007-‐2014

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As illustrated in Table 1 the departure noise levels fall mainly in the bands from 70 to 76 dB(A). There are also many aircraft producing noise levels equal to or in excess of 76 dB(A), e.g. in 2014 during the day 6,081 and during the night 332.

The noise violation limits at Luton for daytime operations has been set for many years at 94 dB(A), the level still adopted by the Department of Transport for the other major London Area Airports (Heathrow/Gatwick/Stansted); it is now 82 dB(A).

The noise violation limit at Luton for night time operations has been reduced in stages from 87 dB(A) in 2006, to 85 dB(A) in 2008, to 82 dB(A) in 2010, and recently to 80 dB(A) in 2015. The limit set by the Department of Transport for night time is still 87 dB(A). Stansted and Birmingham have adopted that level to apply during the period of their Noise Action Plans from 2010 – 2015.

As illustrated for 2014, 85% of the aircraft departures do not exceed the most stringent new limit, 76 dB(A) which arises from planning condition 11i. That leaves approximately 6,400 departures in a year, that do exceed that level. That occurs due to a mixture of aircraft types, see Table 2. It is estimated (as detailed noise certification information to settle QC ratings is not universally available, e.g. for foreign registered aircraft) that 4900 of the exceedances of 76 dB(A) relate to aircraft rated as QC 0.5 and below. Most of these relate to operations by the main airlines at Luton.

With this limit in place, from September 2015, the situation over noise violations will be radically altered. Whereas in recent years, there have been few violations during daytime, and about 6 annually relating to night operations, it is forecast that violations will occur for daytime and night-‐time operations, many times a day.

LLAOL for night-‐time noise has progressively reduced noise violation levels reflecting the noise reduction trends in the aviation industry. The sudden introduction of the 76 dB(A) noise limit is incompatible with the trend in noise reduction which awaits the use of the even quieter re-‐engined narrow bodied single aisle transports.

The noise violation limits set by LBC apparently took no account of the noise levels that would be expected and had been experienced in recent years.

2.2 New Noise Violation Limits: Planning condition 11j

With grant of the new planning permission (June 2014), planning condition 11j becomes effective, it states;

“Within six months of the commencement of the development, a progressive reduction in the daytime (0700-‐2300) maximum NVL by the noisiest aircraft shall be implemented, as follows:

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85 dB(A) from the date of the commencement of development

82 dB(A) from 1st January 2015

80 dB(A) from 1st January 2020”

This planning condition is interpreted by LLAOL as applying to all departing aircraft not just the noisiest on any day.

The recent introduction of a daytime limit of 82 dB(A) is challenging, as for instance in recent years many departures exceeded this level, see Table 1, e.g. for 2012 66 departures, for 2013 72 departures, and for last year 2014 37 departures.

This condition will require considerable work with the airlines with the noisiest aircraft as without aircraft replacement, to ensure departure noise levels do not exceed 80 dB(A) in 2020, will be difficult. This is a significant challenge but one that it is considered can be achieved in the next five years.

2.3 New Noise Violation Limits: Planning condition 11i

With grant of the new planning permission (June 2014), planning condition 11i becomes effective, it states;

“Within six months of the commencement of development and in accordance with the approved Noise Control Scheme the maximum Noise Violation Limits (NVL) for all aircraft, as recorded by departing aircraft at the fixed noise monitoring terminals, shall be reduced to values which are determined by the noise classification of individual aircraft as follows:

Aircraft Classification on Departure NVL (dBA)

QC 4 (Daytime only) 85

QC 2 82

QC 1 79

QC 0.5 and below 76”

Appendix 1 describes the Quota Count (QC) classification of aircraft used by the UK Government.

Condition 11i therefore requires a near immediate reduction of departure noise levels for both daytime and night-‐time. Many of the resident airline fleets operate QC 0.5 aircraft. They are currently required to meet a daytime noise violation limit of 82 dB(A), but this condition will require them to meet within six months of the development a daytime noise violation limit of 76 dB(A). In a similar manner at night they currently have to meet a night-‐time noise violation

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limit of 80 dB(A) but within six months of the development will have to meet a night-‐time violation limit of 76 dB(A).

Details of 2014 Noisiest departures

The breakdown of the noisiest departures in 2014 by aircraft type is given in Table 2. They are given in three bands which differ slightly from those used in the AMR, and consequently in Table 1, in that the lower threshold of the band is greater than the values as opposed to greater than or equal to the values. So for example in Table 1 a value of 79 dB(A) will fall within the >=79 <82 dB band whereas in Table 2 it will fall within the > 76 <= 79 dB band. This change is so the Table 2 values reflect the number of departures that exceeded the NVLs in Condition 11(i). It results in fewer movements within the > 79 <= 82 dB band in Table 2 than in the >=79 <82 dB band in Table 1 due to the 79 dB(A) events falling into a different band.

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Aircraft Type Designation QC

Number of Departures in Noise Band, dB LAmax

> 76 <= 79 > 79 <= 82 > 82

Cargo AN12 2 0 0 1

Cargo A306 2 84 9 0

Pass A319 0.5 399 10 0

Pass A320 0.5-‐1.0 1908 38 0

Pass A321 0.5-‐1.0 345 6 0

Execu. B732 1.0-‐2.00 3 4 26

Pass B734 0.5 193 60 1

Pass B738 0.5 2105 140 0

Pass B752 0.5-‐1.0 52 2 0

Pass B763 1.0-‐2.0 22 6 0

Cargo C130 0 0 1

Execu. F900 0.25 59 8 1

Execu. FA50 0.50 20 9 4

Execu. FA7X 0.25 90 11 1

Execu. GLEX 0.25 45 3 0

Execu. GLF3 0.5-‐1.0 1 3 4

Pass MD83 1.0-‐2.0 0 0 2

Pass MD87 1.0 0 4 3

Others -‐ 196 12 0

Total -‐ 5,522 325 44

Table 2: Summary of Noisiest Departures by Aircraft Type, 2014

The suitability of this new very stringent conditions 11i is discussed in Section 3 below.

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3.0 APPROPRIATENESS OF CONDITION 11i

3.1 Impact on Luton’s Airline Operators

QC 4 Aircraft

Currently no QC 4 aircraft operations occur at the airport, and therefore imposition of the QC 4 (daytime only) noise violation limit of 85 dB(A) has no relevance to Luton’s operators.

QC2 Aircraft

The QC 2 limit, of 82 dB(A) applying at night-‐time arising from Condition 11i has been in place for several years, and therefore places no additional impact on Luton’s operators. In fact LLAOL have already adopted a more stringent night noise violation limit of 80 dB(A).

A QC 2 limit, of 82 dB(A), applying during the daytime will be in place, due to the proposed LLAOL interpretation of new planning condition 11j. Post 1st January 2020 the proposed interpretation of the condition will require all aircraft including QC 2 aircraft to operate within a more stringent limit of 80 dB(A). This would place some difficulties on operators of the only aircraft type with regular QC 2 operations currently operating regularly at Luton, the Airbus A300 freighters. Appendix 4a illustrates the recent departure noise levels for this aircraft.

QC 1 Aircraft

The new QC 1 limit, of 79 dB(A), is currently (2014) exceeded by at least 369 departing aircraft per year. This is expected to consist of the QC 2 aircraft operations and some QC 1 aircraft operations, although only the approximate distribution is available, see Table 2. By inference some QC 1 aircraft operations will be subject to a penalty for exceeding the daytime/night-‐time noise violation limits. The sudden imposition of these limits allows no reasonable time for operators to take measures to meet the new requirement for long established operations of their totally legitimate current aircraft. The condition is clearly inappropriate.

Appendix 4b illustrates the recent departure noise levels of one of the QC 1 aircraft types, the Airbus A321. This aircraft produces average departure noise levels of about 74-‐75 dB(A), and for instance in 2014 only exceeded 79 dB(A) (the new limit for QC 1 aircraft) on six occasions.

QC 0.5/1.0 Aircraft

Study has been made of the past departure noise levels achieved by the main narrow bodied single aisle transport aircraft manufactured by Boeing and Airbus. The Boeing aircraft, B734/B737/B738 are rated in the Noise Supplement AIP 010/2015 as having QC values of 0.5 or 1.0. The Airbus aircraft, A319 and A320, have values ranging from 0.25 to 1.0. It has been possible for some of the aircraft to determine which QC value is appropriate. Table 3 summarises the Boeing results.

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Aircraft Type

Year Departure Noise Levels, dB LAmax

Number of Departures in Noise Band, dB LAmax Total

Number Average StDev > 76 <= 79 > 79 <= 82 > 82

B734

2011 75.4 3.00 128 35 1 424

2012 76.5 2.47 266 64 1 533

2013 76.4 2.68 200 55 5 435

2014 76.2 2.46 193 60 1 486

B737

2008 71.9 2.30 742 10 0 16968

2009 73.6 2.24 872 12 0 8887

2010 73.6 2.31 883 12 0 6543

2011 72.7 2.33 93 2 0 1984

B738

2008 74.3 2.38 139 7 0 587

2009 75.5 2.21 2234 130 0 5203

2010 75.5 2.52 1973 262 4 4946

2011 75.3 2.27 1903 77 0 4627

2012 75.8 1.92 2377 101 0 5120

2013 75.2 2.13 1781 93 0 5358

2014 75.5 2.09 2105 140 0 5483

Table 3: Summary of Departure Noise Levels of Key Aircraft Types – QC 0.5/1

For the Boeing 737-‐400 the average maximum noise level has been consistent at around 76 dB(A). This is explained by these aircraft mainly being operated by a single carrier, Blue Air. The published generic information indicates that they can either be quota count 0.5 or 1. The detailed certification certificates have recently been provided by Blue Air for their eight Boeing 737-‐400 aircraft. This indicates that six are related to QC 0.5 on departure, two as just QC1. The latter have a departure mean level of 90.1 EPNdB;QC1 requires a departure level in the range 90-‐92.9EPNdB. Compared to a NVL of 76 dB(A) for a QC 0.5 aircraft on departure, the number of events producing greater levels of noise is high, often more than 50%. Compared to a NVL of 79 dB(A) for a QC 1 aircraft on departure, the number of events producing greater levels of noise is still significant, around 12% in recent years.

For the Boeing 737-‐700 the average maximum noise level has been consistent at around 73 dB(A). This is explained by these aircraft mainly being operated by a single carrier, easyJet. The published information indicates that they can either be quota count 0.5 or 1, however

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inspection of data on EasyJet Boeing 737/700 aircraft, 10 examples, indicates that they were QC 0.5 types. Compared to a NVL of 76 dB(A) for a QC 0.5 aircraft on departure, the number of events producing greater levels of noise has ranged from 4 to 14%. Compared to a NVL of 79 dB(A) for a QC 1 aircraft on departure, the number of events producing greater levels of noise is low, under 1%.

For the Boeing 737-‐800 the average maximum noise level has been consistent at around 75.5 dB(A). This is despite these aircraft mainly being operated by three carriers, El Al, Ryanair, and Thompson. The published generic information indicates that they can either be quota count 0.5 or 1. From information on departure weights it appears that those operated by Ryanair, around 75% of the total, are quota count 0.5. This has been confirmed by copies of noise certificates provided by Ryanair. The majority of the other Boeing 737-‐800 operations are made by Thomson aircraft. Inspection of their noise certificates indicates that their aircraft are rated as QC 1.0 as their mean departure levels are 90.2 EPNdB;QC1 requires a departure level in the range 90-‐92.9EPNdB. Compared to a NVL of 76 dB(A) for a QC 0.5 aircraft on departure, the number of events producing greater levels of noise is high, at around 40%. Compared to a NVL of 79 dB(A) for a QC 1 aircraft on departure, the number of events producing greater levels of noise is much less, around 2%.

QC0.5 Aircraft

Consideration has been given to the aircraft fleet operated by easyjet, 43% of aircraft total movements at Luton in 2014. These were made mainly, by the Airbus A319 aircraft with most of the remainder the Airbus A320. Inspection of the noise certification data for the Easyjet Airbus aircraft indicate they are all rated as QC 0.5 on departure. The data for the two Airbus types is given in Table 4. The Airbus A320 aircraft is also operated by other airlines. On receipt of the noise certification results for aircraft operated by Wizz Air and Monarch it is established that their A320 aircraft are also rated at QC.0.5.

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Aircraft Type




A319

2008 71.8 2.07 41 1 0 4015

2009 73.3 1.65 251 5 1 9160

2010 73.4 1.72 305 9 0 8257

2011 73.3 1.62 235 5 1 11205

2012 73.4 1.51 314 9 0 12712

2013 73.5 1.51 373 6 0 12293

2014 73.6 1.49 399 10 0 11927

A320

2008 72.6 1.87 114 4 0 5187

2009 73.1 1.70 175 8 1 6250

2010 73.3 2.11 573 14 1 8420

2011 73.1 1.90 403 4 0 8880

2012 73.3 1.81 761 19 0 11208

2013 73.7 1.86 1052 23 1 11874

2014 74.3 1.68 1908 38 0 14862

Table 4: Summary of Departure Noise Levels of Key Aircraft Types – QC 0.5

For the Airbus A319 the average maximum noise level has been very consistent at around 73.4 dB(A). This is explained by these aircraft almost all being operated by a single carrier, easyJet. Compared to a NVL of 76 dB(A) for these QC 0.5 aircraft on departure, the number of events producing greater levels of noise has been around 2 to 3%. This equates to 1 exceedance per day with current levels of activity.

For the Airbus A320 the average maximum noise level has been increased slightly from around 73 dB(A) to around 74 dB(A). This may be explained by the relative combination of the operations by the different operators of this aircraft type, in particular Wizz and easyJet. Compared to a NVL of 76 dB(A) for these Q C0.5 aircraft on departure the number of events producing greater levels of noise has increased to over 12% in 2014. This equates to 5 exceedances per day with current levels of activity.

Appendix 2 illustrates the noise certification process, and past and future ICAO standards, Chapters 2, 3, 4 and 14. The certification data for the Airbus A319 shows that all models meet the ICAO Chapter 3 aircraft standard with a large cumulative margin. They are therefore not

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marginally compliant. They in fact achieve the noise performance required for both ICAO Chapter 4 aircraft, and ICAO Chapter 14 aircraft. The ICAO Chapter 4 standard applies only to new aircraft types from 2006. The more stringent ICAO chapter 14 will apply to new types, post December 2017. In essence Easyjet are operating aircraft that meet current and future noise performance standards. Appendix 3 provides the published noise certification results for one Airbus A319 aircraft.

The measured departure noise levels spread around the average result. This is due to many factors including variations in the engines fitted, the route being flown, weather conditions etc. such that without any specific action taken by the pilot or the airline measured noise levels will regularly exceed the 76 dB(A) noise violation limit. The spread about the average will be as much as 8 dB(A). Based on the 2014 results over 400 Airbus A319 departures exceeded 76 dB(A).

The noise violation limit for QC 0.5 operations will therefore be exceeded by those modern aircraft which meet even the newly settled ICAO Chapter14 standard and are flown normally. That is unreasonable on the operator.

This unreasonableness of the QC 0.5 limit will be highlighted to operators at Luton, when they note that the same aircraft can be operated at Stansted, Gatwick, and other airports without risk of penalty. The same aircraft has to operate within a 94 dB(A) noise violation limit at Stansted compared with 76 dB(A) at Luton.

The noise violation limits selected by the Local Authority appear to take no account of the noise levels measured from QC 2, QC 1 or QC 0.5 aircraft operations at Luton. So in effect the Local Authority appears to have selected arbitrary levels not related to local circumstance. That would appear unreasonable, see Table 5 below.

Aircraft Type Average Measured Departure Noise level at Luton (dB LAmax,s)

Typical QC Value(1)

Airbus A300-‐6 73.6 2

Airbus A321 75.2 1

Boeing 737-‐800 75.5 0.5

Boeing 737-‐400 76.2 0.5

Airbus A320 74.3 0.5

Airbus A319 73.6 0.5 (1) The QC values vary between different variants of generic aircraft types.

Table 5: Relationship of Measured Departure Noise Levels and QC Rating

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3.2 Aviation Policy Framework (APF)

The Central Government policy on aviation noise was recently stated in the APF (2013), paragraphs 3.6 and 3.7.

“Our policy on aviation noise will be consistent with agreed international approaches and we will comply with relevant European laws. 90

The Government fully recognises the ICAO Assembly ‘balanced approach’ principle to aircraft noise management.91 The ‘balanced approach’ consist of identifying the noise problem at an airport and then assessing the cost-‐effectiveness of the various measures available to reduce noise through the exploration of four principle elements, which are:

• Reduction at source (quieter aircraft);

• Land-‐use planning and management;

• Noise abatement operational procedures (optimising how aircraft are flown and the routes they follow to limit the noise impacts); and

• Operating restrictions (preventing certain (noisier) types of aircraft from flying either at all or at certain times).

90 Currently these include Directive 2002/30 on the establishment of rules and procedures with regard to the introduction

of noise-‐related operating restrictions at Community airports; Directive 1999/28 amending the Annex to Council

Directive 92/14/EEC on the limitation of the operation of aeroplanes covered by Part II, Chapter 2, Volume 1 of

Annex 16 to the Convention on International Civil Aviation, second edition (1988); and Directive 2002/49 relating to

the assessment and management of environmental noise (the Environmental Noise Directive).

91 Given effect in EU law through Directive 2002/30”

It would be expected that LBC would have started with a consideration of the levels currently being generated and would then seek to reduce noise through encouraging the use of quieter aircraft. The latter appears not to have been done; the resultant conditions on noise violation limits do not encourage the use of quieter aircraft.

3.3 The Aerodromes (Noise Restrictions) (Rules and Procedures) Regulations 2003 (SI No.1742)

Directive 2002/30/EC was transposed into The Aerodromes (Noise Restrictions) (Rules and Procedures) Regulations 2003 (SI No. 1742). The regulations introduced discretionary powers to Airports to restrict the operation of marginally compliant aircraft. It also required Airports to adopt a balanced approach to noise management.

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It is not clear that the local planning authority have adopted the “balanced approach” in promoting this condition that places penalties on normal aircraft operations by very modern aircraft meeting all International noise performance standards.

3.4 National Planning Policy Framework (NPPF)

Paragraph 206 of the NPPF states that planning conditions should only be imposed where they are:-‐

(i) necessary;

(ii) relevant to planning;

(iii) relevant to the development to be permitted;

(iv) enforceable;

(v) precise;

(vi) and reasonable in all other respects.

The use of noise violation limits at major U.K. airports is common, and they have been used at Luton for many years, and therefore appear necessary. The planning permission (June 2014) continues the use of noise violation limits at Luton in two planning conditions 11j and 11i. The former relates to daytime noise in the period 2015 to 2020 and beyond. The latter relates to both daytime and night-‐time activity. It appears necessary as condition 11j only applies to daytime to have similar condition 11i to address separately night noise, which could for example have more stringent noise violation limits. This could continue the policy at the Airport of progressively seeking to incentivize the airline operators to operate as quietly as possible, and particularly at night. That is not the current version of condition 11i which penalises the operators for operating normally their aircraft which meet the latest international noise standards and provides no incentive to operate during the daytime rather than at night. A suggested alternative is given in Appendix 5.

The imposition of condition 11i is not compatible with a progressive reduction of the years. It, instead, calls for a not achievable change by September 2015.

The use of appropriate noise violation limits as part of a noise control scheme is relevant to planning and to the development permitted here.

The regime promoted by condition 11i could theoretically be enforced but would require considerable time for operators and LLAOL and considerable effort and cost to implement. The determination of the measured noise levels can be readily achieved using Airport sophisticated noise and track keeping system. One difficulty arises with determination of the QC rating for all departing aircraft. For instance, the most common Luton aircraft, the Airbus

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A319, can be rated as either QC 0.25, QC 0.5 or QC 1 dependant on the engines fitted, the maximum take-‐off mass. It will be necessary to determine the QC value appropriate to each individual aircraft.

As evidenced by the 2013 Annual Monitoring Report, the Airport has operations by in excess of 100 subsonic jet aircraft types. Many of these types, such as the Airbus A320, have various versions which may have slightly different QC values. Although in time the proposed system could be made to work there are many challenges yet to be discovered and addressed. Implementation over a period of years might be appropriate, i.e. well in advance of the noise situation of 2028 about which the planning permission relates.

Condition 11i is precise in the perception of experts in aviation noise but due to its complexity may not be clear to the general public, i.e. not sufficiently precise.

Condition 11i is not reasonable for the reasons given above, and because it conflicts with condition 11j. A QC 1 aircraft operation is required during the daytime to achieve a noise level less than 80 dB(A) by condition 11j, and less than 79 dB(A) by condition 11i. A QC 0.5 aircraft is required during the daytime to achieve a noise level less than 80 dB(A) by condition 11j , and less than 76 dB(A) by condition 11i. It is unreasonable to have different requirements relating to the noise violation limits in two planning conditions. Condition 11i also has the feature that an aircraft departure rated as quieter (having a lower QC value) has potentially tougher restrictions (a lower NVL) applied to than a noisier departure. This is unreasonable and does not incentivise the use of aircraft with quieter operations.

Table 5 illustrates the lack of a simple relationship between the measured noise levels of departing aircraft at Luton and their QC values, which arises from how they operate during noise certification trials differing from how they operate at Luton. It should be appreciated that noise levels determined under specific weather conditions and with specific operational requirements during noise certification testing, will not be simply repeated with aircraft operating at any Airport. It appears unreasonable to select Noise Violation Limits in an arbitrary manner.

Condition 11i incorrectly assumes a simple relationship between QC values and measured levels which does not and will not exist. It should be noted that QC values are expressed in 3dB wide bands, and therefore could not be used to prescribe specific noise levels measured at the monitors, these will be a function of both the noise characteristics of the aircraft and the varying propagation conditions between the aircraft and the ground. The latter matters are not within the pilot’s control, and so consideration should have been given for the inherent variability due to factors outside the pilot’s control when setting limits.

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It would have been desirable to incentivize the use of modern, quieter, more efficient aircraft at Luton. In effect Condition 11i gives no advantage to airlines seeking to operate the quietest aircraft; all face fines. That is even those that meet ICAO noise standards that are determined but not yet enacted (.ICAO Chapter 14).

4.0 CONCLUSIONS The noise violation limit for QC 0.5 operations will be exceeded by those modern aircraft which meet even the newly settled ICAO Chapter14 standard and are flown normally. That is unreasonable on the operator.

This unreasonableness of the QC 0.5 limit will be highlighted to operators at Luton, when they note that the same aircraft can be operated at Stansted, Gatwick, and other airports without risk of penalty. The same aircraft has to operate within a 94 dB(A) noise violation limit at Stansted compared with 76 dB(A) at Luton.

The noise violation limits selected by the Local Authority appear to take no account of the noise levels measured from QC 2, QC 1 or QC 0.5 aircraft operations at Luton. So in effect the Local Authority appears to have selected arbitrary levels not related to local circumstance. That would appear unreasonable.

As illustrated for 2014, 85% of the aircraft departures do not exceed the most stringent new limit, 76 dB(A). That leaves approximately 6,400 departures in a year, that do exceed that level. That occurs due to a mixture of aircraft types. It is estimated (as detailed noise certification information to settle QC ratings is not universally available, e.g. for foreign registered aircraft) that over 5,000 of the exceedances of 76 dB(A) relate to aircraft rated as QC 0.5 and below. Most of these relate to operations by the main airlines at Luton.

With this limit in place, from September 2015, the situation over noise violations will be radically altered. Whereas in recent years, there have been few violations during daytime, and about 6 annually relating to night operations, it is forecast that violations will occur for daytime and night-‐time operations, many times a day.

It is not clear that the local planning authority have adopted the “balanced approach” in promoting this condition that places penalties on normal aircraft operations by very modern aircraft meeting all International noise performance standards.

Condition 11i is not reasonable for the reasons given above, and because it conflicts with condition 11j. A QC 1 aircraft operation is required during the daytime to achieve a noise level less than 80 dB(A) by condition 11j, and less than 79 dB(A) by condition 11i. A QC 0.5 aircraft is required during the daytime to achieve a noise level less than 80 dB(A) by condition 11j , and

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less than 76 dB(A) by condition 11i. It is unreasonable to have different requirements relating the noise violation limits in two planning conditions. Condition 11i also has the feature that an aircraft operation rated as quieter (having a lower QC value) has potentially tougher restrictions (a lower NVL) applied to than a noisier departure. This is unreasonable and does not incentivise the use of aircraft with quieter operations.

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FIGURE 1: Noise Monitor Locations

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APPENDIX 1

GLOSSARY OF ACOUSTIC AND AVIATION TERMINOLOGY

ACOUSTIC TERMS

Sound This is a physical vibration in the air, propagating away from a source, whether heard or not.

The Decibel, dB The unit used to describe the magnitude of sound is the decibel (dB) and the quantity measured is the sound pressure level. The decibel scale is logarithmic and it ascribes equal values to proportional changes in sound pressure, which is a characteristic of the ear. Use of a logarithmic scale has the added advantage that it compresses the very wide range of sound pressures to which the ear may typically be exposed to a more manageable range of numbers. The threshold of hearing occurs at approximately 0 dB (which corresponds to a reference sound pressure of 2 x 10-‐5 Pascals) and the threshold of pain is around 120 dB.

The sound energy radiated by a source can also be expressed in decibels. The sound power is a measure of the total sound energy radiated by a source per second, in Watts. The sound power level, Lw is expressed in decibels, referenced to 10-‐12 Watts.

Frequency, Hz Frequency is analogous to musical pitch. It depends upon the rate of vibration of the air molecules which transmit the sound and is measure as the number of cycles per second or Hertz (Hz). The human ear is sensitive to sound in the range 20 Hz to 20,000 Hz (20 kHz). For acoustic engineering purposes, the frequency range is normally divided up into discrete bands. The most commonly used bands are octave bands, in which the upper limiting frequency for any band is twice the lower limiting frequency, and one-‐third octave bands, in which each octave band is divided into three. The bands are described by their centre frequency value and the ranges which are typically used for building acoustics purposes are 63 Hz to 4 kHz (octave bands) and 100 Hz to 3150 Hz (one-‐third octave bands).

A-‐Weighting The sensitivity of the ear is frequency dependent. Sound level meters are fitted with a weighting network which approximates to this response and allows sound levels to be expressed as an overall single figure value, in dB(A).

Environmental Noise Descriptors Where noise levels vary with time, it is necessary to express the results of a measurement over a period of time in statistical terms. Some commonly used descriptors follow.

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Ambient Noise Usually expressed using LAeq,T unit, commonly understood to include all sound sources present at any particular site, regardless of whether they are actually defined as noise.

Background Noise This is the steady noise attributable to less prominent and mostly distant sound sources above which identifiable specific noise sources intrude usually expressed using LA90,T unit.

Maximum Noise Level The maximum A-‐weighted sound pressure level, normally associated with a time weighting, F (fast), or S (slow), and expressed using the LAmax,T parameter.

Sound Transmission In The Open Air Most sources of sound can be characterised as a single point in space. The sound energy radiated is proportional to the surface area of a sphere centred on the point. The area of a sphere is proportional to the square of the radius, so the sound energy is inversely proportional to the square of the radius. This is the inverse square law. In decibel terms, every time the distance from a point source is doubled, the sound pressure level is reduced by 6 dB.

Road traffic noise is a notable exception to this rule, as it approximates to a line source, which is represented by the line of the road. The sound energy radiated is inversely proportional to the area of a cylinder centred on the line. In decibel terms, every time the distance from a line source is doubled, the sound pressure level is reduced by 3 dB.

Factors Affecting Sound Transmission In The Open Air Reflection When sound waves encounter a hard surface, such as concrete, brickwork, glass, timber or plasterboard, it is reflected from it. As a result, the sound pressure level measured immediately in front of a building façade is approximately 3 dB higher than it would be in the absence of the façade.

Screening And Diffraction If a solid screen is introduced between a source and receiver, interrupting the sound path, a reduction in sound level is experienced. This reduction is limited, however, by diffraction of the sound energy at the edges of the screen. The best results are obtained when a screen is situated close to the source or close to the receiver.

Meteorological Effects Temperature and wind gradients affect noise transmission, especially over large distances. The wind effects range from increasing the level by typically 2 dB downwind, to reducing it by typically 10 dB upwind – or even more in extreme conditions. Temperature and wind gradients are variable and difficult to predict.

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AVIATION TERMS

Air Transport Movements Air transport movements are landings or take-‐offs of aircraft engaged on the transport of passengers, cargo or mail on commercial terms. All scheduled movements, including those operated empty, loaded charter and air taxi movements are included.

NPR Noise preferential route – departure flight ground tracks to be followed by aircraft to minimise noise disturbance on the surrounding population.

Dispersion Due to the effect of the wind, aircraft speed, and pilot choice differing aircraft tracks about the nominal track are flown; this is known as dispersion around a nominal track.

Start Of Roll The position on a runway where aircraft commence their take-‐off runs.

Threshold The beginning of that portion of the runway usable for landing.

Radar Vectoring Aircraft are provided by Air Traffic Control with various instructions which result in changes of heading, altitude and speed. The controller affects safe separation from other traffic by use of radar.

Nominal Tracks Using recognised international design techniques, tracks across the ground can be delineated for departing and arriving aircraft. These tracks are nominal because they can be influenced by the wind, ATC instructions, the accuracy of navigational systems and the flight characteristics of individual aircraft. In UK it is usual to permit a 1500m swathe to be established about the nominal track for the purposes of assessing whether an aircraft has stayed on track.

AAL Height of aircraft above aerodrome level.

Altitude Height of aircraft above sea level.

Night Period The period from 23.00 to 07.00 hours.

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Night Quota System A system developed for the noise designated UK airports, Heathrow airport -‐ London, Gatwick Airport – London, and Stansted Airport – London, to limit the amount of noise at night. The details of the latest system are given in the LONDON HEATHROW, LONDON GATWICK AND LONDON STANSTED AIRPORTS NOISE RESTRICTIONS NOTICE which is a supplement to the current UK Aeronautical Information Publication (AIP).

Night Quota Period The period from 23.30 to 06.00 hours (Local time).

Quota Count This means the amount of the quota assigned to one take-‐off or to one landing by an aircraft, this number being related to its noise classification.

Noise Classification (QC Value) Aircraft taking off or landing are described as follows: (a) Exempt aircraft;

(b) Aircraft having a quota count of 0.25;

(c) Aircraft having a quota count of 0.5;

(d) Aircraft having a quota count of 1;

(e) Aircraft having a quota count of 2;

(f) Aircraft having a quota count of 4;

(g) Aircraft having a quota count of 8;

(h) Aircraft having a quota count of 16.

Exempt aircraft are those aircraft which on the basis of their noise data are classified at less than 84 EPNdB. The quota count of remaining aircraft on taking off or landing is to be calculated on the basis of the noise classification for that aircraft on take-‐off or landing as appropriate as follows:

Noise Classification Quota Count 84 -‐ 86.9 EPNdB 0.25

87 -‐ 89.9 EPNdB 0.5

90 -‐ 92.9 EPNdB 1

93 -‐ 95.9 EPNdB 2

96 -‐ 98.9 EPNdB 4

99 -‐ 101.9 EPNdB 8

Greater than 101.9 EPNdB 16

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APPENDIX 2

ICAO NOISE CERTIFICATION

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APPENDIX 3

GINFO DATABASE EXTRACT

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APPENDIX 4

PAST NOISE MONITORING RESULTS AIRBUS A300 AND AIRBUS A321

Aircraft Type




A30B 2008 75.6 3.17 263 86 9 785

A30B 2009 77.2 2.68 225 108 7 495

A30B 2010 77.3 2.85 185 107 18 450

A30B 2011 76.9 2.57 157 58 11 348

A306 2012 75.0 2.90 131 25 0 392

A306 2013 74.1 3.07 123 14 1 502

A306 2014 73.6 2.80 84 9 0 521

Table A4A: Summary of Departure Noise Levels of Key Aircraft Types – QC 2

Aircraft Type




A321 2008 73.8 1.98 109 2 0 1247

A321 2009 74.2 1.90 112 0 0 1105

A321 2010 74.6 2.11 221 6 0 1044

A321 2011 74.6 1.89 152 2 0 914

A321 2012 75.6 1.75 431 6 0 1025

A321 2013 75.5 1.95 402 11 0 979

A321 2014 75.2 1.72 345 6 0 1201

Table 4B: Summary of Departure Noise Levels of Key Aircraft Types – QC 1

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APPENDIX 5

ALTERNATIVE PLANNING CONDITION 11i

“Within six months of the commencement of the development, a progressive reduction in the night-‐time (2300-‐0700) maximum NVL by the noisiest aircraft shall be implemented, as follows:

82 dB(A) from the date of the commencement of development

80 dB(A) from 1st April 2015

79 dB(A) from 1st January 2020

77 dB(A) from 1st January 2028”

Documents

NOISE!VIOLATIONLIMITS! · PDF fileA9501