Gatwick Obviously Not.org

e-newsletter No.91


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You, me and the Dft

A week ago, in Newsletter No.90, I let you know about our loss of confidence in Gatwick's existing Noise Management Board and the Community Noise Groups (of which we are one) constructive proposals for effective new Terms of Reference.

Key to those new Terms of Reference is an acceptance from all sides that the benefits of the airport's recent and future growth are shared through proportionate, fair and balanced reductions in noise and noise impacts, in line with government policy.


The Wider Agenda

This newsletter is a copy of an update sent to a multitude of airport community groups this week on the noise policy and airspace modernisation workshops held by the DfT over the last few months.

It was written and sent by Charles Lloyd of Penshurst, a founding (and existing) member of Gatwick Obviously Not's 15-person strategy team in 2014.

However, rather more importantly in this context, Charles is the elected community representative on the government's Airspace and Noise Engagement Group, which is a formal channel of communication between the Department for Transport and airspace and airport noise stakeholders. The election was held across campaign groups from airports nationwide in 2017.

https://www.gov.uk/government/groups/airspace-and-noise-engagement-group

Charles is also the coordinator for all Gatwick Community Noise Groups.

I will not be testing you on this detailed update if I bump into you, but I would like you to understand the breadth, depth and quality of work going on by so many unpaid, non-industry professionals across so many groups to try and bring this industry to heel, and give those who would like it an opportunity to see some of the working papers in full.

This update also covers a couple of other points including a letter by Gatwick community noise groups asking the Defra Secretary of State to reject the airport's draft noise action plan because it does not quantify the impact of the airport's proposed actions in accordance with Defra's requirements. (My bold)

To make a Gatwick noise complaint, click here: -

http://flighttracking.casper.aero/lgw/complaint/


Here's Charles' update:

UPDATE 09/09/2018

DfT workshops

There have been four engagement sessions, three on aspects of noise policy (growth and noise reduction, regulation, and compensation) and one on airspace modernisation.

Noise policy issues

DfT is at least thinking about the key issues we'd like them to think about in each of the areas covered at the workshops. For example its hypothesis on regulation (this was designed to stimulate debate not as a statement of DfT policy) was that noise controls are inadequate and insufficiently enforced. Similarly its hypothesis on compensation included that aviation is not paying sufficiently for its societal impacts.

In general the views put forward by stakeholders were predictable. But there was more acceptance than I've heard before from the industry that noise regulation isn't working well, partly because no one seems to take responsibility for keeping it relevant and up-to-date and partly because the penalties for non compliance are "peanuts" as one industry representative put it. Sustainable Aviation also accepted without caveat the principle that the industry should meet all the external costs it imposes on society.

DfT was largely in listening mode. They are working on what they call a "licence to grow" approach, under which airports would be permitted to grow if they can achieve defined noise and other environmental targets. But the details of this, particularly the way targets would be set and enforced, and the targets themselves, are not yet clear.

Many of the core points made by community group representatives are captured in the attached position paper which has been sent to DfT to inform and, we hope, influence their thinking in the run up to the Aviation Strategy Green Paper expected in the autumn. We'll be emphasising these points, and trying to use them to drive the agenda, at DfT's Airspace and Noise Engagement Group meeting next week.

gon_140918_01a.jpg

(Click here or on the image to view the full document as a PDF)


Airspace modernisation

The airspace modernisation meeting coincided with the CAA's publication of its draft Airspace Modernisation strategy (CAP 1690). The meeting was intended to focus on the governance of airspace modernisation but we made a series of broader points including:

On governance we argued that communities needed to be represented at all levels of the programme, including on the proposed Airspace Strategy Board but also on technical groups where trade offs between noise and growth might be made. We put forward the idea of a communities adviser and have since sent DfT the attached paper elaborating on the concept.

gon_140918_02c.jpg

(Click here or on the image to view the full document as a PDF)


Invitation to the Aviation Minister

The Aviation Environment Federation and the Aviation Communities Forum are jointly inviting Baroness Sugg, the Aviation Minister, to speak at a community group event later this year or early next. We are keen to give her the opportunity to set out her aviation strategy and modernisation proposals and to hear from a wide range of community groups. We'll be in touch with further details if the invitation is accepted.


Sustainable Aviation press release

In July Sustainable Aviation issued a press release which asserted that "the industry has managed to decouple growth in aviation from noise". We asked them to explain what they meant by this and provide the data to support it.

Having studied the data our view was that it did not support the conclusion they had drawn, and that their press release was misleading and not a truthful representation of the underlying data. We have therefore written to Sustainable Aviation and I attach a copy of that letter.

gon_140918_03a.jpg

(Click here or on the image to view the full document as a PDF)


Gatwick Noise Action Plan

The Gatwick community noise groups have collectively written to Defra Secretary of State asking him to refuse to adopt the draft Noise Action Plan submitted by Gatwick and instead to require the airport to revise its NAP to address the points below, in consultation with all relevant stakeholders, and to resubmit it.

The groups' principal argument is that none of the actions in Gatwick's plan meet the long-standing requirement in Defra's guidance to set out "the reduction of the number of people affected … as a result of the measures in the Action Plan". In addition few, if any, of the proposed actions meet Defra's supplementary requirement that they should be "challenging" and only a handful are "quantified" in any form at all. The groups therefore believe that the draft NAP is non-compliant with Defra's guidance and should not be adopted."

Here is a copy of the letter sent:

The Rt Hon Michael Gove MP
Secretary of State for Environment, Food and Rural Affairs
Nobel House,
17 Smith Square,
Westminster,
London SW1P 31R

9 September 2018


Dear Secretary of State

GATWICK AIRPORT 2019-2024 DRAFT NOISE ACTION PLAN (NAP)

We are writing to ask you to refuse to adopt the draft Noise Action Plan submitted by Gatwick Airport and instead to require the airport to revise its NAP to address the points below, in consultation with all relevant stakeholders, and to resubmit it.

The principal basis on which we believe you should reject Gatwick's NAP is that none of the actions in it meet the long-standing requirement in Defra's guidance to set out "the reduction of the number of people affected as a result of the measures in the Action Plan". In addition few, if any, of the proposed actions meet Defra's supplementary requirement that they should be "challenging" and only a handful are "quantified" in any form at all. The draft NAP is therefore non-compliant with Defra's guidance and should not be adopted.

This is not simply a matter of technical non-compliance. The failure by Gatwick to quantify the impact of the measures it is proposing goes to the heart of whether its NAP is meaningful and likely to be effective. It is central to any understanding and evaluation of the NAP, both by impacted communities and by the government as regulator. It is surprising and disappointing that the government has in the past adopted NAPs that lack this key data. As well as setting out the reduction in the number of people affected we believe the NAP should set out the reduction in the intensity of noise for those who will continue to be impacted: the NAP should be proposing and quantifying actions that achieve both aims.

We note the proposal in the draft NAP that GAL will identify new noise metrics and more precisely describe the aims, targets and outcomes of the actions contained in the NAP as part of a "living document" approach. In our view this is not an acceptable substitute for complying with your guidance in the NAP itself. Defra's requirement that airport NAPs should set out the reduction in numbers of people affected as a result of the measures they propose has been in place since at least 2010. Gatwick's previous NAP included a commitment to develop new metrics by the end of 2011, which has not been met. There can be no reason to give the airport a further grace period to meet this central requirement of your guidance.

Secondly we believe you should reject the draft NAP because it is unlikely to be effective in delivering the aim of the Environmental Noise Directive, that is to avoid, prevent or reduce on a prioritised basis the harmful effects, including annoyance, due to exposure to environmental noise.

Our analysis of the draft NAP suggests that only nine of the 53 proposed actions have direct potential to reduce noise. Five of those actions are repeated from or comparable to actions in the current NAP, so their incremental impacts are likely to be low. A further two simply commit the airport to implementing proposals from its Noise Management Board but with no specificity as to what those will be or the outcomes they will secure. Most of the other actions commit GAL to consultation, reporting, monitoring, mitigation measures or complying with the law, or will redistribute (rather then reduce) noise. We support many of these actions, but they will not avoid, prevent or reduce the airport's noise impacts.

Given the absence of meaningful new actions and the lack of enforceable outcome targets, the draft NAP is unlikely to be effective in delivering the aim of the Environmental Noise Directive. Instead Gatwick's growth plans mean it is very likely that the noise environment around the airport will continue to deteriorate as it has every year since the current NAP came into effect (other than in 2017 when the effects of a one-off aircraft modification programme led to a small reduction in noise contours). It would, in our view, be inappropriate for you to adopt a NAP that is unlikely to achieve the outcomes it was intended to achieve.

We would of course be happy to discuss any aspect of this letter with you and your officials.

Yours sincerely


Peter Barclay, Gatwick Area Conservation Campaign
Martin Barraud (GON, Gatwick Obviously Not)
Ian Hare (APCAG, Association of Parish Councils Aviation Group)
Dr Irene Fairbairn (TWAANG, Tunbridge Wells Anti-Aircraft Noise Group)
Atholl Forbes (PAGNE, People against Gatwick Noise and Emissions)
Dominic Nevill (ESCAAN, East Sussex Communities for the Control of Air Noise)
Sally Pavey (CAGNE, Communities Against Gatwick Noise and Emissions)
Richard Streatfeild (HWCAAG, High Weald Councils Aviation Action Group)
Mike Ward (Plane Wrong)

The organisations listed above are the eight community noise groups represented on Gatwick's Noise Management Board together with the Gatwick Area Conservation Campaign.

CC:

Baroness Sugg, Parliamentary Under Secretary of State for Transport, Department for Transport
Stewart Wingate, CEO Gatwick Airport Limited
John Godfrey, Chair GATCOM
Bo Redeborn, Chair Gatwick Noise Management Board
Graham Lake, Secretary Gatwick Noise Management Board


Yours

Martin Barraud
Chair
Gatwick Obviously Not

www.gatwickobviouslynot.org
ask@gatwickobviouslynot.org


Airspace and Noise Engagement Group (ANEG)

A formal channel of communication between the Department for Transport and airspace and airport noise stakeholders.

https://www.gov.uk/government/groups/airspace-and-noise-engagement-group

The ANEG covers all aspects of national airspace and airport noise policy development. It acts as a sounding board to identify, discuss and, where possible, resolve airspace and airport noise issues that impact on the work of the department. Discussions are at a strategic policy level. The ANEG does not debate or attempt to resolve individual local issues. The ANEG is also an open forum for members to share their own relevant airspace and airport noise projects.

Membership

ANEG members include representatives from each of:


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September 14th 2018
 


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