The Airports Commission Report Follow-up: Carbon Emissions, Air Quality and Noise Contents



64.The Airports Commission made several recommendations for mitigation and compensation measures to reduce the impact of noise on local communities. These included: predictable respite; a night flight ban; and operational and technological improvements, including steeper approaches and a ban on flights between certain hours, known as a ‘noise envelope’.105 Our previous report concluded that the Government should not approve expansion until the airport can demonstrate that it accepts and will comply with the Airports Commission’s conditions.106 The Airports Commission also proposed an independent aviation noise authority to monitor and advise on aircraft noise.107 In our interim report we recommended this authority carry out a survey of attitudes to aircraft noise, something we discuss again in the final section of this chapter.

Mitigating Measures

65.In its Statement of Principles, Heathrow outlined its proposals for each of the Airports Commission’s major measures, including predictable periods of respite and a ban on night flights between 11pm and 5.30am.108 In its Blueprint for Noise Reduction the airport also outlined the technical and operational improvements it will carry out to reduce noise, and referred to its recent trial of steeper descents.109 110


66.In our interim report we noted concerns that, with expansion, respite would decrease from half the flying day to one third—and to one quarter for some.111 In its Statement of Principles, Heathrow also said it would publish a timetable of respite, whilst ensuring there would be “some respite” for everyone living under the final flight path.112 In its announcement the Government referred to a “predictable timetable of respite for those living under the flight path.” However, boroughs close to the airport were concerned that the Government had not published, alongside the announcement, any further information on its work to understand respite.113

67.On guaranteeing local communities a break from overflying, the Secretary of State told us that the crucial reason the extension of the Northern Runway was not accepted was that it would not allow for the provision of respite. Therefore the key element of the new, third runway was that it could provide “respite at all”.114 He told us that there are two options to manage expanded airspace:

You can either have aircraft following a very defined single route, in which case one group of people is affected all the time. You can put in place—indeed, we already have—noise mitigating measures for people on that route. The alternative is to spread them out and therefore give people much more respite, but of course in that situation far more people are affected and you are much less able to provide noise mitigation measures. That is an essential part of the consultation.115

68.The Government published its Draft National Policy Statement on 2 February 2017. This contained a summary of the mitigation measures that could be used to reduce the noise impact of an expanded Heathrow. On respite the NPS states:

Predictable respite—a runway alternation scheme, to provide communities with predictable periods of respite. The timings, duration and scheduling should be defined in consultation with communities and relevant stakeholders.116

Night Flights

69.The Airports Commission recommended that there should be a ban on all scheduled night flights in the period 11:30pm to 6:00am.117 In its announcement the Government said that it would propose a six and a half hour night flight ban, but the timing would be subject to consultation. Heathrow supports the introduction of a legally binding ban on flights “from 11 pm to 5.30 am, when the third runway opens”.118

70.According to London Boroughs close to the airport, Heathrow’s proposed timings for the ban would only mean retiming a maximum of four flights per night out of 16–18 nightly arrivals. They describe this as “disingenuous” and an approach that “does nothing to build bridges” with the local community.119 120 When questioned on this figure, Mr Grayling told us that the number of flights rescheduled would depend on the final timings adopted. He argued :

“There is a clear objective. We have a complete ban on scheduled flights for six and a half hours. Those that would fall within the current six and a half hour bracket would end up having to move.”121

71.The Governments Draft National Policy Statement addressed the issue of a night flight ban stating:

The Government expects a ban on scheduled night flights of six and a half hours between 23.00 and 07.00. The operation and timings of such a ban should be defined in consultation with local communities and relevant stakeholders in line with the requirements of EU Regulation 598/2014.122

72.We are concerned that the Government’s National Policy Statement has provided no further clarity on how predictable respite will be achieved or on the specific timings of a night flight ban. The Government must carry out further work on respite which should form part of the NPS process, alongside plans for a live timetable of respite to be published beginning when the new runway is operational. We welcome the Government’s commitment to a 6.5 hour night flight ban. However as the Government’s case for expansion has relied heavily on the Airports Commission’s work; it would appear inconsistent to reject its key recommendation on the precise timing of a night flight ban. The Government must consider this recommendation alongside consideration of the health aspects caused to residents, in line with the requirements of EU Directive 598/2014.

Like-for-Like Comparisons

73.In its final report the Airports Commission argued it would be “possible to agree a noise envelope for an expanded Heathrow that would ensure that the total number of people affected by noise under expansion would be no higher than it is today”.123 TfL was critical of the Commission’s statement that its proposed mitigation measures could ensure noise did not exceed current levels, arguing this is contrary to the DfT’s Transport Appraisal Guidance methodologies for assessment, which require a comparison between doing something and doing the minimum for the same future year.124 In our interim report we recommended that:

The Government needs to demonstrate that, in assessing the case for expansion, it has based its decision on whether an expanded Heathrow would be noisier or less noisy than a two runway Heathrow at the same point in time-taking into account respite and the need for predictable flying.125

74.The Government’s Draft National Policy Statement does not appear to be in line with our recommendation. In the Appraisal of Sustainability, when considering the increased number of people affected by noise, it refers to data collected by the Airports Commission. Which measured the increased number of people affected compared with today, rather than with the number that would have been affected compared to a two runway airport in 2030.126

Fewer People Affected than Today

75.The Commission said a noise envelope should be agreed and Heathrow must be legally bound to stay within these limits.127 In its announcement on expansion the Government said it proposes legally binding noise targets, adding that: “the Airports Commission concluded, even with the extra flights added by the airport’s expansion, fewer people would be affected by noise from Heathrow by 2030 than are today”.128 This was supported by Heathrow Airport who told us that “we have designed our expansion plans to ensure that fewer people are impacted by significant aircraft noise than today”.129

76.Some London Boroughs told us, however, that this aim was “totally disingenuous” and communities would lose improvements in noise reduction that they would have seen without expansion due to new technology and operational techniques.130 The Mayor of London also pointed to like-for-like analysis undertaken for TfL which found:

A three runway Heathrow would result in an increase in the number of people exposed to significant aircraft noise (at 55dB Lden) of over 200,000 compared to a two-runway Heathrow (applying similar assumptions). Heathrow Airport Limited claimed a new runway could lead to less noise, but only by not comparing like with like.131

77.The Civil Aviation Authority carried out analysis on behalf of the Airports Commission to consider three future airport operational scenarios. Considering the scenario that maximises respite it found, at 54dB LAeq 16 hour contour, in 2030 and 2040 three runways were shown to affect fewer people than two. Similarly, on the 55dB Lden 24-hour metric and the ‘maximise respite’ scenario, an expanded airport was shown to affect fewer people than a two runway Heathrow in 2030, 2040 and 2050.132

78.The Transport Secretary, responding to views that the Government’s targets were unambitious, said:

The interesting thing of course, is because you have six rather than four flight paths, the impact in noise of a plane flying overhead and the benefits in noise reduction terms will still happen.133

One of the reasons we chose the north-west runway option rather than the extended northern runway option was that this allows us still to provide respite to people on the routes—not quite as much as before, because of the configuration of an extra runway that operates in mixed mode, or an element of mixed mode that inevitably has to happen when you have three runways rather than two or four.134

79.The Government’s Draft National Policy Statement has provided no further clarity on the legally binding noise targets it proposes. The Appraisal of Sustainability states:

Noise envelope–should be tailored to local priorities and include noise performance targets. The design of the envelope should be defined in consultation with local communities and relevant stakeholders with suitable review periods.135

Technological Improvement

80.We heard that advances in aircraft technology may provide some noise mitigation in future. Sustainable Aviation told us that UK aviation would be able to accommodate significant air transport movement growth to 2050, whilst at the same time achieve a reduction in the total noise output of UK aviation compared to 2010. It added that future noise reductions would be achieved through changes in aircraft technology and operational techniques, but would require Government assistance and policy certainty in order for improvements to be effective.136 In a recent report, SA acknowledged however that some technological changes may result in an overall decrease in noise impacts, but that noise levels under that flightpath may be increased. 137

81.Daniel Moylan, the former Mayor’s aviation adviser, told us during our 2015 inquiry, however, that:

Much of the noise improvement has already been achieved, and the aero engine manufacturers confirm that they do not expect to see very much more. It takes time for that to arrive on the airfield, because [...] planes have a life of about 30 or 40 years, so you will expect to see some improvement continuing as existing modern technology is rolled out into the fleet, but there is a limit to it.138

82.On the impact of technological improvement Mr Grayling told us:

[...]if you are on the flight path into or out of Heathrow over the coming period, as we see more and more of those new generation planes coming to Heathrow, the noise levels above you will drop.139

83.Mr Grayling added: “Steeper approach is definitely one option [to reduce noise]. This is part of the airspace consultation.”140 Heathrow carried out a trial of 3.2 degree descents between September 2015 and March 2016 which was, reportedly, “successful, meeting all objectives with no adverse impact on the daily operation.” However, the technical report reveals that the magnitude of the benefit is small (c.-0.5dBA) and unlikely to be perceptible on the ground.141 This report considers attitudes towards aviation noise in more detail in the following section.

84.The Government’s draft National Policy Statement argues that there have been reductions in noise over recent decades due to technological and operational improvements; it adds “further opportunities for noise reductions are expected in the next decade as part of the UK airspace modernisation programme”.142

85.The NPS does not lay out the technical and operational improvements the Government expects or requires Heathrow airport to carry out. It states: “It is recognised that Heathrow Airport already supports a number of initiatives to mitigate aircraft noise, such as developing quieter operating procedures [...] The applicant is expected to continue to do so, and to explore all opportunities to mitigate operational noise in line with best practice”.143


86.The stated goal of “fewer people [...] affected by noise from Heathrow by 2030 than are today” shows a lack of ambition. Without Heathrow expansion, local communities would have seen a decrease in aircraft noise as new technology and airspace management techniques were developed. A number of scenarios in the Airports Commission’s technical report showed that an expanded Heathrow in 2030 could be quieter than a two runway airport at the same time. The Government and Heathrow have argued three runways will allow the airport to manage its airspace more efficiently. The NPS does not clearly lay out the nature of the legally binding noise targets and it only compares an expanded airport in 2030 with noise levels today, it does not compare noise levels in 2030 with a two-runway airport at the same time. The Government should publish a comparison between projected three and two-runway noise levels in 2030 as well as with noise levels now. The Government and Heathrow should work towards a goal of less noise than a two runway Heathrow would create in 2030.

87.The Government has argued that, with more effective use of airspace and new technology and operational techniques, noise levels will fall. There is a trade-off between carbon emissions reduction and noise reduction. The Government should work with the sector and public to set its priorities. If the Government plans to rely on future technical improvement to reduce noise impacts, then it must provide the aviation industry with support by setting a clear strategic direction for the industry and guarantee policy certainty for investment.

Independent Aviation Noise Authority

88.In its announcement on Heathrow expansion the Government proposed new legally binding noise targets. Heathrow airport supports this Airports Commission recommendation in its Statement of Principles.144 During oral evidence the Secretary of State said “this [noise targets] is something that we need to consult on. It would also be part of the remit of the new independent noise body that I intend to set up”.145

89.In our interim report we supported the Airports Commission’s recommendation for the establishment of an Independent Aviation Noise Authority. We concluded:

This body will need a more up to date understanding of people’s attitudes to noise if it is to be credible. One of the first tasks of such a body should be to undertake a survey of people’s attitudes to aviation noise. The results of this survey should underpin both its own work and future Government policy on managing noise. In particular, they should form part of a piece of work to develop a set of metrics to assess noise impact.146

90.The Mayor of London emphasised the importance of an Independent Aviation Noise Authority for helping to “restore people’s trust” in the regulation of aviation and its noise impacts.147 A lack of trust has manifested itself in response to Heathrow’s offer to spend more than £1 billion, including £700 on noise insulation, in the community. Richmond Heathrow Campaign previously noted that it took Heathrow five years to invest £4.8 million in refitting schools and community buildings, and they questioned how long it would take to invest £700 million.148 The airport has promised to administer its noise insulation in phases over a period of twenty years, beginning one year before operations on the new runway begin.149

91.In response to our interim report the Government told us that it:

Believes in the principles of an independent aviation noise commission and will consult on this shortly. Such a body could usefully carry out such surveys [on noise attitudes] on a more regular basis. Research is one of the functions which the Airports Commission proposed it should have.150

92.The Secretary of State confirmed to us “I fully intend that there should be an independent aviation noise body; what we will be consulting on is its remit rather than its existence.” Caroline Low added: “the role of the independent noise authority, which is potentially a national role, not just around Heathrow, will be captured in the [NPS] airspace and noise consultation”.151 With regards to the role of this body, the Transport Secretary told us that:

At the moment the enforcement body is the Civil Aviation Authority. There may not be a lot of logic in changing the enforcement powers, but it is a question of defining exactly what remit the new organisation should have.152

93.In light of the publication of the ‘reforming policy on the design and use of UK airspace’ consultation, this Committee is concerned with the apparent downgrading of the proposed Independent Aviation Noise Authority to an Independent Commission on Civil Aviation Noise. The consultation document sets out the Government’s preference for the governance and structure of this body. It states that it will be “an independent body within the CAA”; its Terms of Reference, appointment process for the Commissioner and Board members, and funding will all be decided by the Secretary of State; and it should be “classified as a function of Central Government”. We are concerned that these features make this body an instrument of the Government, preventing it from being independent or credible.

94.Of most concern, however, is the role envisaged by the Government for this body. The consultation document outlines eight functions of this body. These eight functions all refer to this body as having a solely advisory nature. We do not have confidence that a purely advisory function would enable it to have a sufficiently meaningful impact on aviation noise policy.153

Noise Attitudes Survey

95.The Government was previously criticised for failing to provide clear noise guidance for the Commission to base comprehensive recommendations on. In our interim report we recommended a survey be carried out of people’s attitudes to aviation noise to determine whether the onset of significant annoyance had changed from 57dB to 55dB and to inform future Government policy on managing noise.154 In response to our report the Transport Secretary wrote:

In 2014–15 IPSOS/MORI conducted, on behalf of the Department for Transport, a survey on noise attitudes which focused on noise from civil aviation near to major airports in England. Results are currently being analysed with the view to publishing a report early next year.155

96.Caroline Low told us that:

The Commission looked at the full range of metrics, because on the 57Lden, which is the number that has been used historically and is quite helpful for looking back for historical comparisons, we agree with the WHO that the onset of annoyance is now probably further out than the 57 contour, so the Commission looked at a much wider range of contours and indeed different metrics.156

97.Stakeholders in the aviation industry have emphasised the importance of a noise attitudes survey to understand the “noise challenge and how people react to aircraft noise events”.157 Sustainable Aviation told us in 2015 that such a survey would allow the industry to respond better to public concerns and reduce the number annoyed by aircraft noise.158 The London Boroughs we heard from were critical of the IPSOS/MORI survey because they said it had been under “peer review” for several months and not subject to any public consultation.159

98.During oral evidence the Transport Secretary explained the apparent three-year delay in publication:

It is part of the process that leads up to the publication of the national policy statement. [...] We [the Government] have not currently taken a decision [...] we have made a recommendation. [...] what we do now is set forward all the evidence for consideration as part of the process that happens over the next 12 months. 160

99.On 2 February 2017 the Government published two consultations: its draft Airport National Policy Statement; and its UK airspace policy framework. Documentation published alongside these included the results of the Attitudes to Noise Survey and an Appraisal of Sustainability. There is an apparent inconsistency of the reporting of the metrics being used to measure noise at Heathrow airport on which mitigating measures are to be based.

100.The draft National Policy Statement recognises that people’s sensitivity to noise has increased in recent years.161 This is in line with the results of the Attitude to Noise Survey. This concluded: that adverse effects of annoyance can be observed down to 51dB LAeq 16hr; and that sensitivity to aircraft noise has increased, with the same percentage of people being highly annoyed at 54dB LAeq 16hr as there was at 57dB LAeq in the ANASE study previously used to inform aviation noise policy.162

101.Despite this evidence that noise attitudes have changed, and annoyance has increased, the Appraisal of Sustainability, on which the draft National Policy Statement is based, states “this report focuses on the 57 dB LAeq 16hr threshold, and the expected changes in population exposed to this this threshold [...]”.163


102.To improve trust further between communities and the airport the Airports Commission recommended a new Community Engagement Board be created, alongside the Independent Aviation Noise Authority, “with real influence over spending on compensation and community support and over the airport’s operations [...] set up under an independent chair”.164 Heathrow has stated its support for the creation of this body which it promised to set up “after the Government approves Heathrow expansion”.165 The Government, in response to our interim report, stated it would “require Heathrow to develop a Community Engagement Board, including the appointment of an appropriate independent chair, in consultation with local authorities and local communities, and for this body to be in place to participate in the consultation on a draft airports NPS”.166

103.We heard from Caroline Low that the process of creating this body is already under way and that it was being considered whether “an existing body can be developed into that, because that may be more efficient, or whether they need to set up a new body”.167 When questioned on the remit of this body Caroline Low told us that it is currently not being “established as any sort of statutory body with spending powers. Will it have influence? Absolutely. We would expect it to be collecting the evidence from the community and helping the airport and us to understand what the right package is”.168

104.We questioned the Transport Secretary about the concerns about engagement and trust between Heathrow and local communities, and the doubts raised over the ability of the airport to fulfil its promises for insulation in our interim report. Mr Grayling told us that commitments made by the Airport will be enshrined in the planning conditions, but that the Government has not yet considered the logistics of rolling out the £700 million for noise insulation, nor has it considered what would happen if the funding ran out. He added that these concerns would be addressed as part of the NPS consultation.169


105.The importance of the Government’s proposed Independent Aviation Noise Authority is demonstrated by the lack of ambitious noise targets and the necessity for a body to enforce the mitigation and compensation measures proposed by the Government and Heathrow. We are concerned that the Government has downgraded the proposed Independent Aviation Noise Authority to an Independent Commission on Civil Aviation Noise. The proposed structure and role of this body would prevent it from having an authoritative role, and may raise questions about whether it is truly independent and credible. The Government must create an Independent Aviation Noise Authority with an independent chair, the ability to enforce its policy recommendations and the remit to monitor and enforce Heathrow’s commitments to provide respite, including the live timetable; its compliance with night flight scheduling; and the schedule and investment timetable for rolling out the promised noise insulation.

106.We are concerned with the inconsistency of the metrics used to measure noise attitudes. The Government has recognised that the level of significant annoyance has reduced and the number effected increased, yet it bases its conclusions on the out of date 57 dB LAeq 16hr contour. The Government must ensure that the NPS process is informed by the most up-to-date noise metrics, in light of the Attitudes to Noise Survey we expect the Government to consider 54 dB LAeq 16hr as the onset of significant annoyance.

107.We continue to support the Airports Commission in its recommendation of a Community Engagement Board, but emphasise that this body must have real influence and act as a bridge between the airport and communities during the NPS process. We question whether Heathrow’s 20 year timetable for rolling out noise insulation is reasonable. We believe that communities affected by noise in 2026 should not have to wait 20 years for insulation.

106 Environmental Audit Committee, Airports Commission Report, ch.4, HC 389

109 Heathrow Airport Limited, Blueprint for Noise Reduction,

110 Heathrow Airport Limited, Slightly Steeper Approach Trial Report

111 Oral Evidence, Daniel Moylan TfL, 14 October 2015, Q67

113 Hillingdon, Richmond, Wandsworth, Windsor and Maidenhead, para 3.6

114 Oral Evidence, 30 November 2016, Q103

115 Ibid. Q102

118 Heathrow Airport Limited: Statement of Principles, page 25; see written evidence also

119 Written Evidence. Hillingdon, Richmond, Wandsworth, Windsor and Maidenhead, ACR0002, para 3.7

120 The Mayor of London told us, with expansion, there would be a net increase in flights of at least 30% between 11pm and 7am

121 Oral Evidence, 30 November 2016, Q104

123 Airports Commission Final Report, page 279, para 14.18

124 Transport for London, ACR0075, para 4.5

125 Environmental Audit Committee, Airports Commission Report, page 24, HC 389

126 Appraisal of Sustainability, page 77 (see footnotes)

129 Written Evidence, page 5, para 6.5

130 Written Evidence. Hillingdon, Richmond, Wandsworth, Windsor and Maidenhead, para 3.3

131 Letter from Mayor of London to the Committee, 17 November 2016

132 Civil Aviation Authority, Noise Modelling for the Airports Commission: Compendium of results, June 2015, table c4

133 Oral Evidence, 30 November 2016, Q88

134 Ibid.

136 Written Evidence, pages 4–5

137 Sustainable Aviation, ‘UK Aviation and Air Quality: our contribution, the challenges and opportunities’, p40

138 Oral Evidence, 14 October 2015, Q67

139 Oral Evidence, 30 November 2016, Q88

140 Oral Evidence, 30 November 2016, Q107

141 Heathrow Airport, Slightly Steeper Approach Trial Report, page 60, para 140

143 Ibid. page 51

144 Heathrow Airport Ltd: Statement of Priniciples, para 2.3

145 Oral Evidence, 30 November 2016, Q89

146 Environmental Audit Committee, Airports Commission Report, page 22, HC 389

147 Written Evidence, page 7, para 4.19

148 Environmental Audit Committee, Airports Commission Report, page 25, HC 389

149 Heathrow Airport Limited: Statement of Principles, page 26, 33

150 Letter from Chris Grayling to the Chair, 8 November 2016

151 Oral Evidence, 30 November 2016, Q97, Q98

152 Ibid. Q98

154 Environmental Audit Committee, Airports Commission Report, page 22(73), HC 389

155 Letter from Chris Grayling to the Committee, 8 November 2016

156 Oral Evidence, 30 November 2016, Q89.

157 Sustainable Aviation, Written Evidence, page 5

158 Written Evidence, Sustainable Aviation, page 5

159 Written Evidence. Hillingdon, Richmond, Wandsworth, Windsor and Maidenhead, para 3.2

160 Oral Evidence, 30 November 2016, Q91 & 93

164 Airports Commission Final Report, page 10

165 Heathrow Airport Limited: Statement of Principles, para 5.4.4

166 Letter from Chris Grayling to the Committee, 8 November 2016

167 Oral Evidence, 30 November 2016, Q115

168 Oral Evidence, 30 November 2016, Q117

169 Chris Grayling, Oral Evidence, 30 November 2016, Q112–123

20 February 2017