Introduction

Noise disturbance and noise levels from aircraft flying have been medically proven to cause significant health effects on humans and especially children.

Heathrow Airport has produced a legally required Noise Management Consultation for 2024 – 2028 and seeks comments from residents on their proposals. The Consultation ends at 23:55 on 17 July 2023

Another beautiful Summer made unbearable by the noise of aircraft

We have all been affected by the noise of aircraft flying overhead (aircraft overflights) which has jumped from 20% per month over Spring 2023 to 60% per month this Summer (based on Heathrow’s Monthly wind direction data).

This is unbearable and, it happens every year.

How do aircraft overflights affect the health and well-being of people, especially children?

Also, you may be aware that aircraft overflights have been shown by health professionals and researchers to cause sleep disturbances and a range of health problems including greater levels of sickness, earlier death, reduced work-related performance, and impaired learning and academic performance in children, sometimes with permanent effects.

Now that you know this, do you want to continue to live with these health issues and these audio toxins or, do you want to improve your life and the future of your children?

Clearly, steps should be taken to reduce this impact on Windsorians, and Datchet dwellers, especially if the issue is known about, and it has been for decades.

PS If you were not aware of the documented health impacts of aircraft overflights on humans, especially children, you might find this video which I produced in 2015 useful.

https://youtu.be/0QhtWBdw0LQ

The Opportunity and the Deadline

As it happens, as required by law, Heathrow Airport is currently consulting the public on its proposed Noise Heathrow Airport Noise Management Action Plan for 2024-2028.

The Consultation and Heathrow ask so, I would urge you to have your say by 23:55 on 17 July 2023

Getting straight to the point

To shorten your read, you can go straight to the key sections below, highlighted in orange, entitled “Our key comments; the good, the bad, and the ugly of the Heathrow Airport Noise Management” which includes our “Our proposed response to the Heathrow Airport Noise Management Consultation”

How to have your say?

You can read a summary of Heathrow’s proposed Noise Management Plan 2024 – 2028 and download their 55-page plan and 48 pages of Supporting Annexes plus other content including a webinar video from https://www.heathrow.com/company/about-heathrow/consultation/heathrow-noise-action-plan-consultation/About-the-Noise-Action-Plan-2023-2028

The consultation runs until 23:55 on 17 July 2023 and you can submit your comments by

• emailing quieter@heathrow.com *¹ or
• writing to FREEPOST Noise Action Plan *¹ or
• online at https://www.heathrow.com/company/about-heathrow/consultation/heathrow-noise-action-plan-consultation/Have-your-say

*¹ You can download a copy of the paper consultation form directly from Heathrow Airport at https://tinyurl.com/24v7dhuf

Our (WWRA) approach to the consultation is to prevent harm to the Residents of Windsor

My approach in this Consultation has been simple and focused and is, “to prevent harm to the Residents of Windsor from Heathrow Airports operation.”

Within this, I have focused on the impact on Health & Well Being as our suggestions will have a demonstrably positive impact on human health. Our health. And most will cost Heathrow Airport little in the overall scheme of things and, arguably, all of our suggestions will help Heathrow Airport with their own compliance in relation to their legal Duty of Care.

Remember that the tobacco industry knew about the problem they were causing smokers and now are open to lawsuits. Whereas here, Heathrow Airport only has to consider more carefully, take more positive actions, and spend a little more money to prevent increased sickness and death from aircraft overflights.

This will not materially affect their profits and, would arguable improve their share price as investors rate their Environmental, Social and Governance (ESG) value much higher than other competitors in the industry or sector.

So the question is, to Heathrow Airport, “Why wouldn’t you do it?”

Overview of Heathrow Airport Noise Management Framework

Heathrow Airport Noise Management Framework “Approach”

The Noise management framework seems to pick up well on the 5 areas for action which they call their “Approach” and explain as follows:

1. Quieter planes: As aircraft and technology improves and planes become quieter, we will continue to work to ensure that residents share in the benefits. We are committed to use the quietest planes currently available, including in the early morning period, through the use of differential continuing to provide a strong financial incentive for airlines charging fees.
2. Quieter procedures: We are committed to take full advantage of opportunities to manage airspace differently, working with local communities to identify changes that could benefit them. This will include trialling new air traffic management and operating procedures.
3. Land-use planning and mitigation: We are committed to continuing to help with noise insulation and mitigation through a new range of schemes. We will also continue to press the Government to provide more detailed guidance on planning around airports, and to restrict noise sensitive development in high noise areas. We are also committed to establishing a Memorandum of Understanding with local authorities to standardise the means of exchanging information on land use planning and airport operations.
4. Operating restrictions and voluntary measures: In line with the principles of the ICAO Balanced Approach, we agree that restrictions should not be considered as a first resort, and we are committed to developing voluntary measures through collaborative approaches. These can be quicker to implement and more effective. Where restrictions are in place, we are focused on ensuring that they are adhered to fully.
5. Working with local communities: At the heart of our work to address aircraft noise, we are committed to engaging openly and constructively with local communities to understand their concerns and to provide accessible information and an on-going dialogue.

How Heathrow Airport split their 5 point Approach into areas for action or “Measures Used”

Heathrow Airport split the 5 Approach issues listed, and explained above into 18 Measures Used as follows;

For more information, scroll down to the section, “More information to help you” which includes sections on;

1. Keep Heathrow on Speed Dial when the noise disturbs you
2. WWRA Comments cross-referenced to the Heathrow Airport Noise Management Noise Framework
3. Heathrow’s stated “Key Areas of Development”

Our key comments; the good, the bad, and the ugly of the Heathrow Airport Noise Management Plan

Our suggestions for extra actions based on their Approach and Measures Used

It is great to see Heathrow recognising the impact of aircraft overflights on health and well-being and, indicates that Heathrow Airport and its managers and owners have a Duty of Care to people affected by aircraft overflights.

A fundamental flaw

However, the proposal is problematic and the biggest fundamental flaw in their plan is this; they have failed to undertake the taxiway works that would allow aircraft to fly over Windsor and Datchet for only 50% of the day (i.e. full runway alternation) and not 100% as has been the case for most of the last three and a half months. Actually, Heathrow Airport could have permanently reduced the noise we suffer once they received their Planning Consent in February 2017 (see “The plot thickens” below); or indeed earlier as it in 2009 when they were granted leave by the then Secretary of State to first apply for planning permission to undertake such taxiway works.

Why did it take them so long to consider the noise and health impact after 2009 and to do something incredibly positive about reducing noise and introducing fair, and full runway alternation?

The plot thickens

It is worth noting that Heathrow was granted planning permission to start this very work on 2 February 2017 by the Secretary of State following a judicial review. Yet, Heathrow Airport management did nothing and let the planning permission lapse on 1 February 2020! One would expect that the same duty of care for health issues & suffering caused by overflights was due to residents in February 2020.

So, Windsorians have been suffering needless disturbance, and the associated health consequences, for the last 6 years since February 2023 due to the decision of Heathrow Airport’s management, and arguably the shareholders of Heathrow Airport.

Heathrow proposes to deliver full runway alternation by 2028 but, that would mean another 5 – 6 years of harm to Windsorians (12 years of harm since 2 February 2017 and 19 total years of harm suffered by Windsorians since they were first given permission to apply in 2009)

Remember that Heathrow is a large organisation with an annual turnover of £1.2Bn turnover and capital assets of £14Bn, with an annual Capex of £250 million, so there can be few questions about affordability.

• This failure to start the groundworks to allow a 50% reduction in aircraft noise for Windsorians is unacceptable given the affordable estimated cost of £60m and,
• The decision to let the planning consent then lapse in 2020 is objectionable.

We must insist that Heathrow Airport represents its previously granted planning application immediately, without haste, and that it plans to get the works done so full runway alternation can start before the end of 2024.

I would urge you to complete Heathrow’s survey to say so. They are relying on you to respond.

A second fundamental flaw

It must also be noted that the consultation form is generally too complex for residents to complete and the data and many technical aspects such as the L_DEN measurement of noise is not understandable by most people affected by the noise and disturbance. This issue is made worse because the impacts are so profound on humans especially children.

As a result, Heathrow should;

1. Reconsider their approach and conduct a more meaningful engagement exercise including open, honest, and simple language and reach out to ICBs such as Frimley Health NHS Trust, GPs, Schools, Education Authorities, Local Councillors, and other representatives of the people to get sober, accurante views of their operations etc..
2. They should give greater weight to these bodies and groups and set up special boards to discuss the issues before they finalise their Noise Management Plan for 2024 – 2028

I have received this complaint from many residents and seen this reflected in the proposed responses of aircraft monitoring groups such as HACAN.

And there’s more

But there are many more areas that cause for concern or where Heathrow Airport’s management could and should do better primarily in relation to noise levels, noise measurements, noise mitigations, residents’ compensation scheme, working with local Councils (give us teeth please), and understanding and repairing the health and well-being damage caused, especially to our children.

I have set out 29 suggestions that Heathrow should act on if they are serious about the concerns and improving the well-being of people under flightpaths, especially those living in Windsor, Datchet and Holyport.

Our 32 suggestions seek to;

1. Heathrow to immediately resubmit their lapsed planning consent to LB Hillingdon and plan for works to start within the 13-week statutory deadline for Councils – to allow aircraft to only fly over Windsor for 50% of the day during easterly operations – good weather days
2. Reduce the noise of aircraft overflights by changing operational parameters of aircraft during take-off and landing e.g. such as steeper glide angles on arrival/landing, more extensive use of the southern runway, lowering undercarriage later and after Windsor Castle.
3. Dramatically extend and improve the number of data collection and data points so we can better measure the amount of noise and where it is happening so we can tailor solutions
4. Set noise measures and targets that are relevant to health and not use averaging ones that ignore the medical triggers
5. Better incentivise airlines to stop them from causing noise i.e. Heathrow to levy heavy fees and fines from airlines who cross Windsor between 11pm and 7am and, such fines to go to the Council for use in Windsor, or directly to Windsor, Datchet, or Holyport residents
6. Better compensate residents and councils for inappropriately noisy operations  – Heathrow to pay for good noise insulation and air conditioning for Windsor residents – we are in the 40C summer heat envelope for decades to come now
7. Heathrow to allow scrutiny groups made up of councillors and residents to fine Heathrow where they do not make good progress on agreed issues with such money going to residents affected

Our proposed response to the Heathrow Airport Noise Management Consultation.

Click here to read our response to the Consultation which includes the detail of our 32 suggestions to Heathrow to improve their proposed Nose Management Plan 2024 – 2028 – it’s a Word document to help you use it to create your own response.

This also reflects the thoughts of the West Windsor Residents Association (To help us you can join the WWRA here https://www.westwindsorresidentsassociation.org.uk/join-wwra) which we will be submitting to Heathrow.

UPDATES We will update this during the week as we get further feedback from residents, Council, and local GPs and health professionals.

More information to help you

Keep Heathrow on Speed Dial when the noise disturbs you

Interestingly, on Page 8 of their report, Heathrow state, “Within the pillar. “A great place to live and work”, Objective 4 is called “Quieter nights, quieter flights” and contains a headline goal to “limit, and where possible reduce, the number of highly sleep-disturbed and highly annoyed people compared to 2019”

A key learning objective from this is to email or call them when you are disturbed

“Aircraft noise complaints can be made to Heathrow via our online form at www.heathrow.com/noise, by email to noise@heathrow.com or by calling 0800 344844”

Heathrow are depending on you to let them know when you are disturbed. Please don’t let them down.

WWRA Comments cross-referenced to the Heathrow Airport Noise Management Noise Framework

As previously said, Heathrow set out 5 key areas for their Noise Framework which include 18 topics for action and investigation. The Framework and its 18 topics seem more logical to the layman so, we have used these 18 topics as the basis for our 29 suggestions.

Heathrow Airport call these 18 topics “Measures used” and they comprise;

Our 29 suggestions to which seek to;

1. Heathrow to immediately resubmit their lapsed planning consent to LB Hillingdon and plan for works to start within the 13-week statutory deadline for Councils – to allow aircraft to only fly over Windsor for 50% of the day during easterly operations – good weather days
2. Reduce the noise of aircraft overflights by changing operational parameters of aircraft during take-off and landing e.g. such as steeper glide angles on arrival/landing
3. Extend and improve data collection and data points so we can better measure the amount of noise and where it is happening so we can tailor solutions
4. Set noise measures and targets that are relevant to health and not use averaging ones that ignore the medical triggers
5. Better incentivise airlines to stop them from causing noise i.e. Heathrow to levy heavy fees and fines from airlines who cross Windsor between 11pm and 7am and, such fines to go to the Council for use in Windsor, or directly to Windsor residents
6. Better compensate residents and councils for inappropriately noisy operations  – Heathrow to pay for good noise insulation and air conditioning for Windsor residents – we are in the 40C summer heat envelope for decades to come now
7. Heathrow to allow scrutiny groups made up of councillors and residents to fine Heathrow where they do not make good progress on agreed issues

Here is the table cross-referencing Heathrow’s Framework to my/our responses – click here to get a PDF copy of it.

Heathrow’s stated “Key Areas of Development“

Confusingly Heathrow set out a different set of 12 “Key areas of development” which are referred to in the 7 questions on their Consultation questionnaire. I have cross-referenced them here for your use.

#	Key areas of development	Actions	Consultation Question
1	Establishing a Fleet Forecasting Forum to predict the pace of future technology and likely take up at Heathrow	1A to 1C	2
2	Reviewing the landing charges structure in order to meet our sustainable growth objectives and to accelerate the transition to a Chapter 4-free fleet	2A to 2C	2
3	Establishing a Technical Engagement Forum to undertake a review and renewal of the Code of Practice supporting the achievement of the noise abatement objectives	3A to 3L	3 & 5
4	Developing and trialling operational practices aimed at increasing the level of predictable respite, particularly at night	4A to 4D	3 & 5
5	Identifying opportunities to enhance the collection and analysis of noise data in order to improve our understanding of the effectiveness of the noise abatement interventions	5A to 5D	5
6	Establishing a MoU with local authorities, providing our forecast outputs to reduce sleep disturbance at night, and supporting land use planning	6A	4
7	Launching the new Round 4 Noise Insulation Schemes in 2024	7A and 7B	4 & 6
8	Seeking to introduce a voluntary ban on non-dispensed operations after midnight and before 4:30am	8A	5
9	Developing and implementing a ground noise management plan which will include work with international partners to develop a standard for the use of pre-conditioned air where available	9A	5
10	Establishing a longitudinal noise attitudes survey, so we can enhance our understanding of our stakeholders and the effectiveness of our noise strategy	10A to 10G	5 & 6
11	Strengthening the independent scrutiny of our noise management strategy and providing independent insight, assurance, and transparency	11A to 11D	Feedback not requested?
12	Undertaking a review and enhancing our online information and tools to improve accessibility and provide greater insights in a more efficient way	12A to 12C	6

Conclusion – How are you affected by aircraft overflights?

Heathrow have clearly not acted as good neighbours to people living in Windsor & Datchet but, we have this window of opprtunity to let them know our views and also how aircraft overflights have affected you and your family.

For children, to whom is can cause permanent educational impairment, the Heathrow Airport Noise Management Consultation is a once ia liffetime to align Heathrow’s operations with the health needs of those young people in our care. I urge RBWM, schools, Frimley Health and local GPs to act on this.

Let’s step up and provide Heathrow Airport the feedback that they need, and are requesting from each of us.

Accountably yours,

Carole AND Wisdom

Cllr. Carole Da Costa AND Cllr. Wisdom Da Costa

cllr.c.dacosta@rbwm.gov.uk AND cllr.dacosta@rbwm.gov.uk

West Windsor Residents Association 

Clewer & Dedworth West