East Surrey MP Peter Ainsworth has responded to the Consultation paper ‘Gatwick Airport: Draft Noise Action Plan 2010 – 2015.’

The consultation was required by the Environmental Noise Directive.

As part of the consultation Mr Ainsworth wrote to Andy Flower, Managing Director of BAA Gatwick.

Key points raised include:

• No noise limit being proposed on arriving aircraft;

• Nowhere is there a commitment to cut the overall nuisance caused by aircraft noise;

• No assessment is made of the increased nuisance caused to people under existing flightpaths by plans to ‘concentrate’ flights;

• No account is taken of the effects of the planned proposed increase in the capacity of the North Terminal;

• “Performance Indicators” which measure Gatwick noise nuisance against other international airports are not “remotely relevant, or meaningful, to people in my constituency whose tranquillity and sleep patterns are wrecked by excessive aircraft noise.”

Commenting, Peter Ainsworth said:

“I am sorry that BAA Gatwick has not taken the opportunity to set out, in terms which everyone can understand, a commitment to becoming quieter.”

He added, “The Consultation document is very technical, and may have put people off responding. But BAA Gatwick, and the Department of Transport, need to understand that the noise generated by Gatwick is of concern to many thousands of local people who are affected day and night. Whilst there are clear economic benefits, including employment opportunities, to be gained from Gatwick, there are also serious environmental consequences which must be properly taken into account.”

A copy of Mr Ainsworth's letter can be seen below.

Mr Andy Flowers
Managing Director
BAA Gatwick
7th Floor, Destinations Place
Gatwick Airport Ltd
West Sussex   RH6 0NP

1st October 2009

Dear Andy,

Re: Gatwick Airport Draft Noise Action Plan 2010 – 2015

Thank you for the opportunity to comment on the Draft Noise Action Plan. I am sending a copy of this letter to the consultation department at Chelmsford, and I would be grateful if you might accept it as my formal response as Member of Parliament for East Surrey.

As you will know, my constituency borders Gatwick Airport to the North (Horley) and to the East (Smallfield, Burstow, Horne, Outwood, Newchapel, Lingfield, Dormansland, Crowhurst, Gosdstone and Oxted are all, to a greater or lesser extent, affected by noise from Gatwick). I declare an interest as a resident of Lingfield.

I have read the submissions to the above Consultation from Tandridge District Council and the Gatwick Area Conservation Campaign. I endorse the content and detailed observations made by both of these bodies, and I do not intend to repeat at length what they have already stated.

As an overall comment, however, I would like to say how difficult the Consultation document appears to the non-professional reader. I appreciate that there are complex and technical issues involved, and I welcome the lengthy period afforded to those wishing to respond; however, the fact remains that a great deal of the detail in the document is opaque, and will mean little to the non-specialist whose quality of life may be affected by the outcome of the Consultation. In addition, the short survey which correspondents are invited to complete at the end of the document is too vague to allow a proper representation of views.

In other words, I acknowledge that the Consultation ticks the statutory requirements which caused it to be issued; but I rather doubt that it fulfils the spirit of those requirements. In consequence, it may result in a relatively low response rate. If this is the case, neither BAA Gatwick, nor the Department for Transport, should be misled into believing that the noise generated by Gatwick Airport is of little concern to the many thousands of my constituents whom it affects on a daily – and nightly – basis.

Whilst there are clear economic and practical benefits, including employment opportunities, deriving from the proximity of a major international airport, there are also serious environmental consequences, including noise pollution. It is essential that these are fully taken into account if a good relationship is to be established between the airport – under whatever ownership – and the local population in the future.

I notice that in your foreword to the Consultation you state that the document “is not a consultation about future noise or an expanded airport.” This conflates three separate issues in an unhelpful way. Firstly, the Consultation is indeed about ‘future noise’, since the period under consideration runs to 2015; secondly it is also about an “expanded airport,” since an application is currently before Crawley Borough Council to expand the North Terminal; and thirdly the question of a future second runway is a completely separate issue and is, rightly, deemed irrelevant.

The Consultation should have taken into account the implications of the current plans to expand the capacity of the North Terminal. The absence of any reference to these plans is misleading, and also fails to comply with Defra guidance which indicates that future planned developments should be taken into account.

One key test of the Consultation, and of any future actions, is whether they comply with the aim of the 2003 White Paper “The Future of Air Transport” to “limit and where possible reduce the number of people in the UK significantly affected by aircraft noise.”

Nowhere in the Draft Noise Action Plan is this issue addressed. There is no statement of the total number of people who will benefit from the measures proposed. Without a clear undertaking that the total number of people affected by aircraft noise will fall over the next five years, it can reasonably be assumed that the existing problems will get worse as a result of airport expansion.

The Draft Noise Action Plan also fails to address at all the impact on people currently affected by aircraft noise of proposals to concentrate flight paths. This should be made explicit, and those affected should be given an opportunity to respond, through a separate and targeted consultation. There is a real risk that the present Consultation, being both technical and vague, will result in impacts on specific communities which have little or no knowledge of what may be decided.

It is a remarkable failure of the Draft Plan that it includes no proposals to cut the maximum noise limits on take-off; and that there are no plans for noise limits on arriving aircraft. The majority of complaints which I have received over the years about aircraft noise have been related to arriving aircraft. I appreciate that this is a matter ultimately for the Department, but many of my constituents will think it unacceptable that a Draft Noise Action Plan fails to include noise limits, and penalties, for arriving aircraft.

Similarly, one of the most intrusive environmental problems in my constituency is the noise of night flights. It is extraordinary that the Draft Noise Action Plan contains no commitment at all to a reduction of nuisance from night flights. This is especially the case since the current quota arrangements for night flights are due to expire in 2012 – well within the period covered by the Draft Plan.

As I have said, I endorse the submissions made by Tandridge District Council and the Gatwick Area Conservation Campaign, and I will not repeat their detailed comments. In short, I do not believe that the Draft Noise Action Plan is nearly robust enough to ensure that my constituents affected by aircraft noise are treated fairly.  I do not think [Q1] that Gatwick Airport’s approach succeeds in targeting the important issues in relation to aircraft noise. I do not think that the Draft Plan [Q2] provides a suitable framework to manage aircraft noise; and I think that the proposed ‘Performance Indicators’ [Q3] are  meaningless because they are entirely voluntary, and would not bind any new owner of the airport (which is currently up for sale). In addition, I do not think that Gatwick’s goal “to be within the top fifth of airport companies for best practice in international noise management” [Q4] is remotely relevant, or meaningful, to people in my constituency whose tranquillity and sleep patterns are wrecked by excessive aircraft noise.

Whether the noise levels around Gatwick are ‘better or worse’ than around Kuala Lumpur is a complete irrelevance to residents of Horley or Dormansland.

I am sorry that BAA Gatwick has not taken the opportunity, afforded by its statutory obligation to consult over the future noise problems, to set out in terms which everyone can understand a commitment to becoming quieter.

Yours sincerely,

Peter Ainsworth