Title 68

The Directive 2002/30/EC (`the Directive') has failed to achieve any significant reductions in noise, and without much stronger action, more people will be disturbed by increasing noise levels, contrary to the intentions of the Commission.

Therefore CPRE calls upon the UK Government to implement its intention to achieve WHO Noise Guidance Levels and to lobby the Commission strongly for an EU programme to achieve this by drawing up a staged programme to reduce aviation noise.

The Campaign to Protect Rural England (CPRE) welcomes the opportunity to comment on the Directive. CPRE has existed since 1926 and seeks to promote the beauty, tranquillity and diversity of rural England by encouraging the sustainable use of land and other natural resources in town and country. CPRE has over 60,000 supporters and has branches in every county in England. Aviation noise is a particular concern for CPRE due to its detrimental effects on tranquil areas of the countryside.

The theme of the Directive was to address the issue of aircraft noise for residents in areas “near airports” - the degree of nearness was not defined - by means of operating restrictions.

Directive 2002/49/EC (`the European Noise Directive') also sought to address the issue of noise, including aircraft noise, requiring the production of strategic noise maps and action plans around major civil airports (defined as those with more than 50,000 air transport movements per year) and in agglomerations with more than 100,000 inhabitants “in order to prevent, avoid and reduce the harmful effects (including annoyance) due to air traffic noise.”

In 2006 the EU Council adopted its revised Strategy for Sustainable Development which aims at “reducing transport noise at source and through mitigation measures to ensure overall exposure levels minimise impacts on health.”

Thus there is a general intention, expressed through these Directives, that the adverse effects of aircraft noise are addressed effectively - with the European Noise Directive specifically stating the need to maintain areas which are quiet and to reduce noise where it very noisy. In other words, to prevent any increase in noise.

Individual member States were free to implement the Directive in their own manner, and Commission Document COM(2008) 66 final.makes it is clear that airports have done so (p3, Section 3) and that there is doubt as to whether the Directive prohibits any form of restriction (p4, S. 3). The lack of clarity and the need for very detailed procedures in Annex 2 restrained some airports from introducing measures (p4, S. 4). One airport would only ban marginal Ch. 3 aircraft if it were mandatory across the EU. (p8, S.6).

The express carrier industry, which causes particular problems with its perceived need to fly at all hours of the night (e.g. East Midlands Airport), want the Directive to enhance and clarify the protection they feel the Directive should offer them, and for it to specifically allow Chapter 4 aircraft to fly at any time in the night (p8, S.7).

In UK it was decided (not without objection) that the “competent authority” would be the individual airport operator rather than, say, the Environment Agency. It may be as a result of this arrangement that, though a range of possible restrictions exists, with the exception of the three “designated” airports, (where DfT is empowered to set limits on noise and movements at night) the concentration has been on eliminating Chapter 2 aircraft. In fact, though the Directive also encouraged the withdrawal of “marginally-compliant” Chapter 3 aircraft - predominantly the Chapter 2 types fitted with the misleadingly-described “hush-kits” - to a large extent the Directive was already redundant. This is because the majority of the UK and European fleet consists of aircraft which already exceed the requirements of Chapter 4.

The Commission has, in effect, answered its own question, in terms of the extent to which the Directive has helped to achieve the objectives of the European Noise Directive and the Sustainable Development Strategy. The Commission's own conclusions in COM(2008) 66 final at page13, Section 11 ) include two fundamental statements of failure:

“More generally, the number of people affected by noise, particularly at night, has increased since the Directive came into force, due to a general increase in the number of movements, in spite of the possibility to introduce partial restrictions.

Table 2 (p11 S.10) shows a continual increase despite possible restriction scenarios, and they confirm that contour areas are expected to grow considerably particularly at night (p13 S10)

“Moreover, its impact in respect of marginally compliant aircraft is limited because the number of these aircraft is comparatively small due to their natural replacement”;

Formal acceptance that it would be necessary to limit the number of aircraft movements or the hours of operation so as to achieve the environmental objectives, particularly of the European Noise Directive requirements to maintain areas which are quiet and to reduce noise where it very noisy;

The inclusion of a clear requirement on national Governments to ensure that noise levels do not increase, and requiring them to implement measures (similar to Air Quality Action Plans) where noise has increased;

The UK Government has long stated its aim to achieve the WHO Noise Guidance Levels (e.g. paragraph 3.12 of Night Noise Restrictions at Heathrow, Gatwick and Stansted, July 2004), and its Sustainable Development Strategy requires improvement not mitigation. The night noise regime at the designated London airports has achieved some improvements, so a similar, but much stronger programme is needed for all airports;

Clearer statements as to the range of possible operating restrictions: movements caps; noise budgets; accelerated removal of marginally-compliant Chapter 3, etc. and that they are all permissible;

A deadline for Ch.4 aircraft only to be allowed to operate in the EU and for a clear programme for introduction of Chapter 5 aircraft and for the phase-out of Ch.4 aircraft;

more attention to population densities when defining flight paths (however this must include background noise levels, and not population alone) and to make maximum use of low noise procedures such as continuous descent approach (provided this is implemented properly without level flight during the descent);


	Pictures of E Hodgkins holiday in Ramsgate 1928 \| thanetonline blog More pictures Even more pictures Title 68 Review of Directive 2002/30/EC on noise-related operating restrictions at airports A response by CPRE to the DfT Consultation Document September 2008 Summary The Directive 2002/30/EC (`the Directive') has failed to achieve any significant reductions in noise, and without much stronger action, more people will be disturbed by increasing noise levels, contrary to the intentions of the Commission. Therefore CPRE calls upon the UK Government to implement its intention to achieve WHO Noise Guidance Levels and to lobby the Commission strongly for an EU programme to achieve this by drawing up a staged programme to reduce aviation noise. Introduction The Campaign to Protect Rural England (CPRE) welcomes the opportunity to comment on the Directive. CPRE has existed since 1926 and seeks to promote the beauty, tranquillity and diversity of rural England by encouraging the sustainable use of land and other natural resources in town and country. CPRE has over 60,000 supporters and has branches in every county in England. Aviation noise is a particular concern for CPRE due to its detrimental effects on tranquil areas of the countryside. The theme of the Directive was to address the issue of aircraft noise for residents in areas “near airports” - the degree of nearness was not defined - by means of operating restrictions. Directive 2002/49/EC (`the European Noise Directive') also sought to address the issue of noise, including aircraft noise, requiring the production of strategic noise maps and action plans around major civil airports (defined as those with more than 50,000 air transport movements per year) and in agglomerations with more than 100,000 inhabitants “in order to prevent, avoid and reduce the harmful effects (including annoyance) due to air traffic noise.” In 2006 the EU Council adopted its revised Strategy for Sustainable Development which aims at “reducing transport noise at source and through mitigation measures to ensure overall exposure levels minimise impacts on health.” Thus there is a general intention, expressed through these Directives, that the adverse effects of aircraft noise are addressed effectively - with the European Noise Directive specifically stating the need to maintain areas which are quiet and to reduce noise where it very noisy. In other words, to prevent any increase in noise. 2002/30 in practice Individual member States were free to implement the Directive in their own manner, and Commission Document COM(2008) 66 final.makes it is clear that airports have done so (p3, Section 3) and that there is doubt as to whether the Directive prohibits any form of restriction (p4, S. 3). The lack of clarity and the need for very detailed procedures in Annex 2 restrained some airports from introducing measures (p4, S. 4). One airport would only ban marginal Ch. 3 aircraft if it were mandatory across the EU. (p8, S.6). The express carrier industry, which causes particular problems with its perceived need to fly at all hours of the night (e.g. East Midlands Airport), want the Directive to enhance and clarify the protection they feel the Directive should offer them, and for it to specifically allow Chapter 4 aircraft to fly at any time in the night (p8, S.7). In UK it was decided (not without objection) that the “competent authority” would be the individual airport operator rather than, say, the Environment Agency. It may be as a result of this arrangement that, though a range of possible restrictions exists, with the exception of the three “designated” airports, (where DfT is empowered to set limits on noise and movements at night) the concentration has been on eliminating Chapter 2 aircraft. In fact, though the Directive also encouraged the withdrawal of “marginally-compliant” Chapter 3 aircraft - predominantly the Chapter 2 types fitted with the misleadingly-described “hush-kits” - to a large extent the Directive was already redundant. This is because the majority of the UK and European fleet consists of aircraft which already exceed the requirements of Chapter 4. What success has been achieved? The Commission has, in effect, answered its own question, in terms of the extent to which the Directive has helped to achieve the objectives of the European Noise Directive and the Sustainable Development Strategy. The Commission's own conclusions in COM(2008) 66 final at page13, Section 11 ) include two fundamental statements of failure: “More generally, the number of people affected by noise, particularly at night, has increased since the Directive came into force, due to a general increase in the number of movements, in spite of the possibility to introduce partial restrictions. Our prediction is that the number of people affected by noise will continue to grow although the situation may differ between airports.” Table 2 (p11 S.10) shows a continual increase despite possible restriction scenarios, and they confirm that contour areas are expected to grow considerably particularly at night (p13 S10) And one partial statement of failure: “Moreover, its impact in respect of marginally compliant aircraft is limited because the number of these aircraft is comparatively small due to their natural replacement”; So, as the Commission has concluded already, the provisions of the Directive as it currently stands require change, in addition to its scope,. CPRE considers that the following changes to the Directive are required: Formal acceptance that it would be necessary to limit the number of aircraft movements or the hours of operation so as to achieve the environmental objectives, particularly of the European Noise Directive requirements to maintain areas which are quiet and to reduce noise where it very noisy; The inclusion of a clear requirement on national Governments to ensure that noise levels do not increase, and requiring them to implement measures (similar to Air Quality Action Plans) where noise has increased; The UK Government has long stated its aim to achieve the WHO Noise Guidance Levels (e.g. paragraph 3.12 of Night Noise Restrictions at Heathrow, Gatwick and Stansted, July 2004), and its Sustainable Development Strategy requires improvement not mitigation. The night noise regime at the designated London airports has achieved some improvements, so a similar, but much stronger programme is needed for all airports; The inclusion of a staged programme to achieve the WHO Noise Guidance Levels by a fixed date such as 2015; The Directive should apply to all airspace and not just “near to” airports; Clearer statements as to the range of possible operating restrictions: movements caps; noise budgets; accelerated removal of marginally-compliant Chapter 3, etc. and that they are all permissible; A deadline for Ch.4 aircraft only to be allowed to operate in the EU and for a clear programme for introduction of Chapter 5 aircraft and for the phase-out of Ch.4 aircraft; Closer linking to the WHO work on effects of aircraft noise, which refer explicitly to the relevance of the number as well as the loudness, of noise events, and Initiation of work to review and harmonise definitions of aircraft noise disturbance standards and measurements. We particularly support the views of the Local and Regional Authorities who have told the Commission that they want (p9 S.8) (with our provisos in italics): more attention to population densities when defining flight paths (however this must include background noise levels, and not population alone) and to make maximum use of low noise procedures such as continuous descent approach (provided this is implemented properly without level flight during the descent); greater attention to WHO noise standards; compensation policies for those disturbed (but only for existing traffic- where increased traffic would increase noise that must be prohibited); more involvement of, and response to, local groups (including representation of environmental groups on Airport Consultative Committees); more restrictions on night flights to avoid sleep disturbance (including a total ban on night flights, including Ch.4 aircraft, between 11 pm and 7 am), and reduced urban degradation and impoverishment around airports. CPRE September 2008