Rural Heritage Society
OF LITTLE GADDESDEN, RINGSHALL, HUDNALL AND ASHRIDGE

AIRCRAFT NOISE

The latest news

The Comet newspaper in Stevenage has set up an e-petition calling on the government to call-in the Luton Airport planning application.   They need 10,000 signatures.

Getting the application called in will, we hope, subject it to more detailed scrutiny which is easier for campaign groups to engage with, and it will slow the process down - Luton Airport are in a tearing hurry to get this through quickly so they can recoup the investment costs over the maximum time period if successful.

You can access and quickly sign the petition at:

 http://epetitions.direct.gov.uk/petitions/44069

NB: only 450 people across the region responded to the airport  's last consultation (which is how they managed to tip the vote by pulling in 612 votes from airport staff etc). We need to do much better now the chips are down. So please go to the petition before you forget, and sign up if you agree.

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Following the latest proposals received from Luton we reproduce here the response from our Chairman

RURAL HERITAGE SOCIETY OF LITTLE GADDESDEN, RINGSHALL, HUDNALL AND ASHRIDGE

LONDON LUTON AIRPORT

RESPONSES TO DRAFT NOISE ACTION PLAN CONSULTATION QUESTIONS

Response to Question 1: What do you consider to be the most important problems relating to aircraft noise at London Luton Airport?

The inexorably increasing number of aircraft movements in and out of the Airport, resulting in “noise nuisance” for those living in the surrounding area and in the loss of “tranquility” in local recreational and nature areas, such as the Chiltern Area of Outstanding Beauty.

The problem of night flights also needs to be tackled by their restriction between the hours of 2300 and 0700 to nil.

Response to Question 2: To what extent do you think that that this Draft Noise Action Plan will help to further enhance London Luton Airport’s noise management strategy?

Rating: 1

There does not seem to be very much new here.

There is no indication as to how the problem of noise from the ever increasing number of aircraft movements will be dealt with.

There is no indication as to how the problem of noise from individual very noisy aircraft (which can cause major disturbance) will be dealt with, given the emphasis on “average” noise.

There seems no strategy identified in the document for actually managing the noise from aircraft movements. There should be a network of remote noise monitoring equipment which can be used to verify forecast noise levels in different areas and to identify the problem aircraft, not just 3 noise monitoring stations - which seems to be the current plan.

Response to Question 3: Are there any additional actions that you think we should be taking to control the noise impact from aircraft departing from or arriving at London Luton Airport?

See previous answer re night flights and the increase in number and geographical distribution of noise monitoring equipment. Also, it is unclear to what extent the noise contours take into account differences in ground levels between the Airport and the relevant geographical points. An aircraft flying at 3000 feet above Airport level or Markyate level is only 2000 – 2400 feet above the Ashridge plateau.

Response to Question 4: Do you believe that this Draft Noise Action Plan meets the requirements of the Guidance?

No.

Where is the identification of noise problems to be addressed and what actions are proposed to deal with them? The Draft looks like a pre-Consultation work plan defining the information to be gathered in order to draft an Action Plan. The requirement to produce an Action Plan has been known for many years and the noise data used in the plan is some 2 to 3 years old already. The preparatory work should have been carried out before now, not as part of the Action Plan itself.

How can the Action Plan be realistic in the absence of the new Airport Master Plan?

Virtually no publicity has been given to this consultation process in areas surrounding the Airport which are affected by Airport noise.

Response to Question 5: Do you have any other comments on the London Luton Airport Draft Noise Action Plan?

As an Action Plan, it fails miserably:

1. Aspirations are not actions

2. Consultations are not actions

3. Research is not action

4. Preparation is not action

The performance indicators specified in the Action Plan are not proper indicators of noise management.

Beta minus for this Draft. It needs a lot more work on it.

Rural Heritage Society of Little Gaddesden, Ringshall, Hudnall and Ashridge
c/o George Godar
The Old Rectory
Little Gaddesden
Berkhamsted
Herts
HP4 1PA

 

THE ORIGINAL NATS PROPOSALS AND HOW THEY WILL AFFECT YOU!

PROPOSALS

The following proposals will affect Little Gaddesden and Ashridge:

1. Luton Westerly Departures to the East - new route over Little Gaddesden and Ashridge at 2,000 - 3,000 feet (possibly 1,750 - 2,750 feet above ground level);

2. Luton Westerly Departures to the South East - new route over Little Gaddesden and Ashridge at 2,000 - 3,000 feet (possibly 1,750 - 2,750 feet above ground level);

3. Luton Westerly Departures to the South West - much the same as now, but possibly more houses affected;

4. Luton Westerly Departures to the North at 2,000 - 3,000 feet (possibly 1,750 - 2,750 feet above ground level), 1,000 feet lower than now;

5. Luton Easterly Departures to the South West at 3,000 - 4,000 feet (possibly 2,750 - 3,750 feet above ground level), 1,000 feet lower than now.

WHAT THIS MEANS

1. Instead of two direct take-off flight paths in the region of Little Gaddesden and Ashridge (Westerly Departures to the South West and Westerly Departures to the North) and another indirect and higher level flight path over Little Gaddesden and Ashridge (Easterly Departures to the South West), there will now be five routes: the two new routes are at low level (lower than any of the existing routes) and the three existing routes drop by 1,000 feet in height. All of this will dramatically increase the noise effect in our area.

2. There will be more aircraft flying at lower levels over the highest parts of the Chilterns Area of Outstanding Natural Beauty with an enormous visual and noise impact, as well as adversely affecting wildlife and air quality.

3. Moreover, the additional noise will be over an area of low ambient noise pollution (compared to a town) and therefore the perceived effects of the increased noise will be much greater.

4. The effect of the changes to Little Gaddesden and Ashridge is the same as more than a doubling of daily departures from Luton Airport with those departures consisting of much noisier aircraft.

5. For the future, aircraft movements from Luton Airport are set to triple from 200 to 600 a day by 2020. What NATS decides now will likely remain in force over this period. Once the proposals are adopted they will be here for a long time, designed as they are to allow for the expected expansion in air traffic.

6. NATS has chosen to give greater priority to minimising the number of people over-flown below 7,000 feet (below this height Government guidelines accept that disturbance is caused to over-flown populations) than to avoiding the over-flight at low levels of Areas of Outstanding Natural Beauty.

NOISE LEVELS

7. The noise level from a typical aircraft flying at between 2,000 and 3,000 feet is between 66 and 80 Db (decibels). At 1,000-2,000 feet, the equivalent noise level is between 69 and 88 Db. This noise level will be roughly between that of a car at 40 mph, 23 feet away (70 dB) and a heavy diesel lorry at 25 mph at 23 feet away (85 dB).

8. At peak times, one aircraft every six minutes (10 per hour) will be flying the new departure routes (that is between 6.00am and 11.00pm).

9. The noise will be at a level that you will be disturbed in your house and your enjoyment of the outdoors will be impossible. These proposed changes comprise an extremely serious threat to the nature of Little Gaddesden and Ashridge. They must be opposed vociferously.

10. Margaret Moran (MP, Luton South) states that “NATS itself says that the Luton airspace area will be worse off - indeed, it will be one of the areas worst affected by the proposals" and that “according to NATS' own estimate, the number of households adversely affected will increase by 111% under the plans".

ACTION TO BE TAKEN

11. Go online to NATS to add your voice to the complaints - the URL is http://www.consultation.nats.co.uk/feedback/27/your_comments.html.

12. However, it may be better to send your comments to NATS by mail because your options on the web site are limited but if you write you can give yourself maximum flexibility about what you can say. Send them to:

TCN Consultation, NATS, Freepost, NAT22750, Reading, RG1 4BR.

13. Among the points you can make are:

13.1 More aircraft from existing and new routes flying at lower altitudes over Little Gaddesden and Ashridge in narrower and more concentrated flightpaths.

13.2 The aircraft will be flying at 2,000 ft over what is already a high plateau, so in fact very low over Little Gaddesden and Ashridge.

13.3 Enormous noise impact which is unacceptable in a rural environment and an Area of Outstanding Natural Beauty which is used as a recreational area by people from a wide area.

13.4 The environmental impact or rerouting should be reduced as much as possible to maintain local air quality, to avoid loss of landscape and to minimise the impact of air transport on biodiversity such as disturbance of habitat and species.

13.5 Such a massive change to flight paths in the Luton is contrary to the Department of Transport Guidance to the CAA which (para 35) "recognises the importance of the long-term stability of the route structure in the vicinity of airports". It is also unfair that those threatened by the proposal have not been informed directly and therefore the consultation publicity and process have been inadequate.

13.6 NATS has failed to include measures which would mitigate the impact on the quality of life. Such measures must include limited hours of operation, particularly at night, stringent aircraft noise abatement procedures, schemes for providing noise insulation grants and financial compensation for loss of property values.

AIRPORT MEETING AT BERKHAMSTED 10th June 2008

Douglas Adams attended the meeting and sent the following comments via e-mail

Hi folks

Attended last night's meeting. Decent turn-out circa 200+ to hear in the main Michael Nidd (alphabet committee) beat the battle drums.

Points worthy of note:

1    We have sent our letter to NATS who are entrusted to summarise all objections in their submission to CAA (the arbiters). I think we should also send a copy of our letter to the CAA as well.

Quantity as well as quality of objection will be significant so we should continue to encourage those against to submit before 19th June (next week!)

Any change must satisfy the prime requirement of improving safety. Currently there are only 73 events in the airspace under review of which 69 present no risk to safety. We are therefore looking at 4 incidents per year which could be considered as near misses or in fact near hits depending on your viewpoint.

Luton's low flying is due to Bovingdon stack and Northbound departures fro LHR - this is the key problem forcing Luton departures to fly low.

Noise criteria are based on studies in the 1960's - suggestion is that these must be updated before any new parameters are set.

Mounting pressure to reclassify Luton as a City airport with associated night curfews and weekend restrictions.

We ought to consider as a PC whether to purchase (or lease) noise monitoring equipment. I'm happy to be "noise equipment monitor" monitor! Fiona - could you dig some prices up?

Sue Yeomans gave a short presentation on behalf of the the newly formed Chiltern Countryside Group who are looking to set up (?another) umbrella group. They are young, enthusiastic and would be a good initiative to support. Website up and running soon.

Keith Matthews on behalf of the Hospice who will probably directly affected by increased noise also gave a short presentation.

Overall feeling - these proposals will probably fail but the process will continue.

I think we have done a good job for the village (I gave Michael Nidd a copy of our letter) but we need to stay with this. I think our own noise monitoring could be a very useful weapon in the future.

Douglas Adams
Director
Radial Sports Publishing Limited
Kaim End, Hudnall Common, Little Gaddesden, Berkhamsted, Hertfordshire HP4 1QJ

telephone   +44 (0) 1442 843191  mobile   +44 (0) 7919 336697   e-mail   douglas@adams251.fsnet.co.uk

 

DACORUM BOROUGH COUNCIL SUBMISSION

Click this link to access further links to submissions - <http://www.dacorum.gov.uk/default.aspx?page=5447>

 

Submission from Ian and Paula Sayers which demonstrates a most effective response to the proposals and the consultation website

TCN Consultation,
NATS,
Freepost NAT22750,
Reading, RG1 4BR

17 June 2007

Dear Sir / Madam

NATS Airspace Change Proposals

As residents of Little Gaddesden, in the Chilterns Area of Outstanding Natural Beauty, we object to the proposals and do not believe that they should be implemented. Our reasons are as follows:

The proposals fail to take account of the difference between noise and nuisance

As we understand it, the proposals have been formulated to direct air traffic away from more densely populated urban areas and over less populated rural areas. We presume that the rationale behind this methodology is that, if less people are overflown, then society overall benefits from less intrusion from noise.

This is a fundamentally flawed presumption, as it takes no account of the actual impact (i.e. nuisance) that an increase / decrease in aircraft noise will have on the area concerned. Most importantly, it fails to take into account that the damage caused by an increase in aircraft noise in rural (and hence more tranquil) areas will be significantly greater than the benefits derived from reduction in the level of aircraft noise over more densely populated areas (where ambient noise levels are higher).

The consultation document openly acknowledges that no account has been taken of this due to the lack of a recognised methodology. However, common sense clearly suggests that a reduction in air traffic over an already noisy town such as St Albans will have a far less beneficial impact on residents than the damage caused to residents in more tranquil areas such as Little Gaddesden. Indeed, in my experience, aircraft noise in St Albans is often barely noticeable due to the surrounding ambient noise of car traffic etc.

The lack of an appropriate methodology does not justify proposals that fly in the face of common sense and will result, overall, in more people suffering nuisance from aircraft noise than less.

The proposals fail to take into account the status of the Chilterns Area of Outstanding Natural Beauty

The proposals appear to take no account of the fact that the Chilterns has been designated an Area of Outstanding Natural Beauty (AONB). This is critical to the proposals, as the designation as an AONB clearly demonstrates that the area is considered to be a civic amenity, of benefit and value to everyone, not just residents.

There are millions of visitors to the area each year. Indeed, before we moved to our current home, we used to come to the area frequently to escape the noise and hustle and bustle of town life. We know many friends who do the same now.

The principal attractions of the area are, of course, its visual beauty and tranquillity, both of which will be significantly damaged by the proposals. As a result, not only will residents suffer from these proposals, but so will all the visitors to the area.

NATS should be seeking ways to reduce the impact of existing air traffic over the area, not increase it.

The proposals will diminish choice over residential location reflecting lifestyle choices

Many factors influence where people choose to live. However, it is certainly not the case that all people want to live in the peace and quiet of the countryside. Some prefer the bustle of city life, others prefer the slower pace and tranquillity of rural living.

More importantly, people’s attitudes to these issues often change over time. Younger people without children may tend to favour town locations and then wish to move to more rural locations over time as their personal circumstances change. This was certainly a factor in our decision to move to Little Gaddesden.

Though it is not reasonable to suggest that people residing in towns and cities should bear all air traffic noise on the basis that they chose to live there, people who choose to reside in towns and cities (as stated above) are clearly less affected by aircraft noise due to the higher ambient noise levels. If noise is of sufficient concern, or personal circumstances change, they have the choice to move to a more tranquil area.

The proposals will remove this choice. As indicated above, the improvement to the quality of life in more densely populated areas, where ambient noise will still remain much higher than rural areas, will be marginal. The damage to rural areas will be significantly greater.

The proposals will therefore result in all areas, both rural and town, becoming noisy areas to live. There will be no where to escape to. The proposals therefore damage not only the interests of residents of rural areas, but also residents of towns who may wish to move to more peaceful areas later in life.

Other issues

We would also register our serious concerns over the online consultation process. In particular, this process demands that respondents answer a question on direct versus specified routes. The online form cannot be submitted without answering the question.

It is almost unheard of for a public consultation to demand a response to a specific question as a condition of submitting a response at all. This is against policy guidelines on good practice for public consultations.

This creates the following fundamental problems:

1. It acts as a barrier to responses, whereas the purpose of online consultation should be to facilitate responses from a wider audience. Many respondents will not have a specific view on this question, and it may even be the case that there is no answer they can give (as the answer may change depending on decisions taken elsewhere). As a result, they may have been inclined not to respond at all, in fear that their response on the specific question will be ‘held against them’ in the future.

2. It undermines the quality of the information obtained on the specific question. In some cases, people will have simply ‘guessed’ an answer to ensure that their main response is taken into account. If this is the case, this undermines the value of the responses on the specific question raised, which cannot be taken to be representative of people’s views.

We therefore believe that no reliance can be placed on the answers to this question and that this issue should be the subject to further consultation only once a decision has been taken on the other issues raised by consultation.

Yours sincerely

Ian & Paula Sayers

Oak Tree House
4 Church Farm Barns, Church Road
Little Gaddesden
Herts
HP4 1NZ

cc CAA

During October 2010 the Rural Heritage Society received the following comunication from NATS

"We said we would keep you updated on progress regarding the airspace change proposals in the area we call Terminal Control North (TCN) on which we consulted in 2008.

We said there would be no second consultation before the end of September 2010 and can now confirm that we do not plan to take the proposals forward in their current form and there will therefore be no consultation at this time.

The downturn in air traffic levels since the 2008 consultation means there is less urgency on capacity grounds to achieve the TCN changes to the original timescale. Current forecasts show that air traffic levels are not expected to return to the peak levels of 2007 until at least 2013/14.

This enables us to incorporate the TCN proposals into a wider review of airspace over much of southern England which is already under way. We believe we can deliver greater overall benefits than TCN, albeit on a longer timescale.

We valued the feedback received in our first consultation which is also a contributory factor in our decision; it helps that we now have less urgency to achieve change.

While the downturn in air traffic means we can take longer to ensure we have the best solution, we have always been clear that doing nothing is not a long-term option."

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