Technical Note
Project:
London Luton Airport Planning Application Job No:
Prepared
Phil Abbott FIOA Technical Director
Approved
Nigel Triner MIOA Associate Director
Subject:
Review Variation to Planning Conditions
11i & 11j
Date:
60439565
19th August 2015
Hertfordshire County Council have commissioned AECOM to review a variation to a
planning condition as described in London Luton Airport, Noise Violation Limits New
Planning Conditions 11i, LA. Ref: 12/01400/FUL BAP Ref: A9501-R03/B, May 2015,
prepared by Bickerdike Allen Partners.
The aim of the review is to provide an opinion on the proposed changes to the Noise
Violation Limits Planning Condition 11i of Section 106 Agreement of the Planning
Application as described in Appendix 5 of the report.
The review will discuss the arguments put forward by the consultants for advocating
changes to the Noise Violation Limits and comment on their reasonableness and on
whether the proposed changes are acceptable.
1. Introduction
In June 2014, London Luton Airport Operations Ltd (LLAOL) was granted planning
consent from Luton Borough Council (LBC) with reference to planning application
12/01400/FUL. The purpose of the application is to increase the throughput of the
airport to 18 million passengers per annum by 2031. The consent was subject to
certain planning conditions which included noise. One measure to reduce the noise
impact from aircraft on neighbouring noise sensitive receptors (NSRs) is to introduce
progressively more stringent Noise Violation Limits (NVL). This scheme limits the
maximum noise level recorded at any one of three monitoring stations along the
departure route of the airport. Any aircraft exceeding these limits incurs a fine on the
airline company.
The next section discusses the existing NVL which currently operate at Luton. This
is followed by the system proposed in the planning condition as supported by LBC
and then by the system proposed by LLAOL.
The following section discusses these two approaches to establish which is the more
balanced approach and provides a more acceptable solution in determining NVLs.
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Technical Note
2. Noise Violation Limits (NVL)
The various Noise Violation Limits that are relevant to this review are set out as
follows:
a. Prior to 1st April 2015:
94 dB(A) – DAY [06:00 – 22:59 (Monday-Saturday); 07:00 – 22:59 (Sunday)]
82 dB(A) - NIGHT [23:00- 0.5:59 (Monday-Saturday); 23:00 – 06:59 (Sunday)]
b. Since 1st April 2015:
82 dB(A) – DAY [06:00 – 22:59 (Monday-Saturday); 07:00 – 22:59 (Sunday)]
80 dB(A) – NIGHT [23:00- 0.5:59 (Monday-Saturday); 23:00 – 06:59 (Sunday)]
c. Planning Conditions:
Planning Condition 11i:
“Within six months of the commencement of development and in accordance with
the approved Noise Control Scheme the maximum Noise Violation Limits (NVL)
for all aircraft, as recorded by departing aircraft at the fixed noise monitoring
terminals, shall be reduced to values which are determined by the noise
classification of individual aircraft as follows:
Aircraft Classification on Departure
NVL (dBA)
QC 4 (daytime only)
QC 2
QC 1
QC 0.5 and below
85
82
79
76”
QC is the Quota Count assigned to the taking off or landing of an aircraft and is
related to the noise certification level, for example an aircraft with a QC value of 1
on departure would be noise certified between 90 to 92.9 EPNdB on take-off. Note
that QC 4 aircraft are not currently operating at Luton Airport.
Planning Condition 11j:
“Within six months of the commencement of the development, a progressive
reduction in the daytime (0700 – 2300) maximum NVL by the noisiest aircraft
shall be implemented, as follows:
(i) 85 dB(A) from the date of the commencement of development
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Technical Note
(ii) 82 dB(A) from 1st January 2015
(iii) 80 dB(A) from 1st January 2020”
d. Alternative to Planning Condition 11i proposed by LLAO
“Within six months of the commencement of the development, a progressive
reduction in the night-time (2300 – 0700) maximum NVL by the noisiest aircraft
shall be implemented, as follows:
82 dB(A) from the date of the commencement of development;
80 dB(A) from 1st April 2015;
79 dB(A) from 1st January 2020;
77 dB(A) from 1st January 2028”
3. Discussion
The NVL values prior to 1st April 2015 follow those recommended by Department of
Transport’s Aircraft Noise Monitoring Advisory Committee (ANMAC) when reviewing
departure noise limits at London Airports in 19951. The night limits were further
reduced from 87 dB(A) to 84 dB(A). Currently the day time limit is set at 82 dB(A)
and at 80 dB(A) during the night as a result of the Noise Action Plans introduced by
LLAOL.
Under the planning conditions, Condition 11 sets out the proposed Noise Control
Scheme (NCS). The setting of the NVL values form part of the NCS. Planning
Condition 11(i) will impose, for the first time, NVL values based on the aircraft’s QC
value.
The limit values have been set 0.9 dB(A) below the upper ICAO noise certificated
value associated for that QC value assuming that there is a 13 dB(A) relationship
between the noise metric used for noise certification, EPNdB, and the maximum
noise level dB(A) used for NVL e.g. aircraft that are classified as QC 1 are noise
certified between 90 to 92.9 EPNdB leading an upper maximum noise level of 79.9
dB(A) and therefore a NVL value of 79 dB(A). This planning condition is to be
operational within 6 months of the commencement of the development and apply
throughout the day and night period.
This condition appears to be very demanding on airline companies operating at
Luton, in particular those companies with fleets which consist mainly of the quieter
0.5 QC aircraft. For these aircraft, the NVL value during the day will reduce from 82
to 76 dB(A) within 6 months of the commencement of the development and similarly
from 80 to 76 dB(A) during the night. The results in Table 4 show that under the
Review of the Departure Noise Limits at Heathrow, Gatwick and Stanstead Airports. CS Report
9539. Research and Development Directorate National Air Traffic Services.1995
1
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Technical Note
current regime, on average about 5% of the quieter A319/320 aircraft failed to meet
the 76 dB(A) threshold over the period 2008 to 2014.
It is perhaps not surprising that a relatively small number of 0.5 QC aircraft exceed
the 76 dB(A) NVL value as the 13 dB relationship between EPNdB and the
maximum noise level dB(A) is only an approximation and that the measurement
conditions during the monitoring of aircraft at the airport conforms with that when the
aircraft are noise certified. Thus in real world conditions there is inevitably a degree
of variation in this assumed 13 dB relationship. In addition, the monitoring of aircraft
noise is unattended, so any allowance of noise interference from other noise
sources is not possible, this is particularly relevant as increasingly lower NVL values
are introduced.
Examining the percentage of aircraft exceeding the NVL values in the higher QC
bands shows that only about 1% of the aircraft under the current regime will exceed
the NVL values introduced by planning condition 11(i). There is, therefore, lower risk
to airline companies in using noisier aircraft to avoid infringement of the NVL
compared with the quieter 0.5 QC aircraft. So condition 11(i) could be seen as
counterproductive.
A further problem with this condition is that it is not explicitly clear when the NVL
operates. If it is to operate during the day and night, as implied, then this condition
would allow QC 2 aircraft to violate the current NVL night value of 80 dB(A) which
would not be acceptable.
A possible way forward would to introduce the following scheme explicitly for the
daytime period to replace Planning Condition 11(j):
“Within six months of the commencement of development, and in accordance
with the approved Noise Control Scheme the maximum Noise Violation Limits
(NVL) for all aircraft, as recorded by departing aircraft at the fixed noise
monitoring terminals during the daytime period (0700 – 2300), shall be reduced
to values which are determined by the noise classification of individual aircraft as
follows:
Page: 4 of 6
Aircraft Classification on Departure
NVL (dBA)
From 1st January 2015
QC above 1
QC 1 and below
82
79
From 1st January 2020
QC above 1
QC 1 and below
80
79
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Technical Note
If the above is proposed for a daytime NVL then this should be compared with
Planning Condition 11(j) which is a progressive reduction in NVL during the day. The
main benefit provided by the above suggestion is that it will introduce some benefits
immediately without too much risk to the operator whereas; the proposed Planning
Condition 11(j) will not introduce any additional benefits until 2020.
If Planning Condition 11(j) is to control NVL during the day then Planning Condition
11(i) should control NVL during the night as proposed by LLAO (see section 2d
above).
The scheme proposed by the LLAO does not appear to be very stringent. During the
night period the operators should be operating the quieter aircraft i.e. 0.5 QC and
below. It has been shown earlier that these aircraft can met a NVL value of 79 with
little risk of infringement. It would seem unreasonable that a NVL value of 79 dB(A)
for the night-time cannot be introduced immediately.
As for the future, to introduce a 3 dB(A) reduction, from the current 80 to 77 dB(A)
over a 13 year period would seem very cautionary. Currently, about 5% of 0.5 QC
aircraft exceed 76 dB(A), it would seem reasonable to expect that most quiet aircraft
would not exceed a NVL value of 76 dB(A) by 2025.
It is therefore proposed that the following night-time Planning Condition 11(i) is
adopted:
“Within six months of the commencement of the development, a progressive
reduction in the night-time (2300 – 0700) maximum NVL shall be implemented,
as follows:
80 dB(A) from the date of the commencement of development;
79 dB(A) from 1st April 2015;
76 dB(A) from 1st January 2025”
4. Summary and Conclusions
A review of the variation in planning conditions as described in London Luton
Airport, Noise Violation Limits New Planning Conditions 11i, LA. Ref:
12/01400/FUL BAP Ref: A9501-R03/B, May 2015, prepared by Bickerdike Allen
Partners, has been carried out.
This AECOM review agrees with the report that the existing Planning Condition 11(i)
and 11(j) is confusing and potentially counterproductive.
The LBC proposed Planning Condition 11(i) will allow a relaxation in the current
night-time NVL by allowing QC 2 aircraft to exceed the current NVL of 80 dB(A) by 2
dB(A) to 82 dB(A), this is unacceptable.
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Technical Note
The LBC proposed daytime NVL Planning Condition 11(j) will not introduce any
benefits over the existing regime until 2020. It is therefore proposed that the
following daytime condition is considered as an alternative:
“Within six months of the commencement of development, and in accordance
with the approved Noise Control Scheme the maximum Noise Violation Limits
(NVL) for all aircraft, as recorded by departing aircraft at the fixed noise
monitoring terminals during the daytime period (0700 – 2300), shall be reduced
to values which are determined by the noise classification of individual aircraft as
follows:
Aircraft Classification on Departure
NVL (dBA)
From 1st January 2015
QC above 1
QC 1 and below
82
79
From 1st January 2020
QC above 1
QC 1 and below
80
79
This regime will immediately provide benefits without deterring operators from using
the quieter aircraft.
The night-time NVL Planning Condition 11(i) proposed by LLAO is not stringent and
very cautionary (there is in effect a 13 year delay in introducing an NVL of 77 dB
despite most 0.5 QC aircraft meeting the 76 dB NVL now), the following should be
considered as a more acceptable alternative:
“Within six months of the commencement of the development, a progressive
reduction in the night-time (2300 – 0700) maximum NVL shall be implemented,
as follows:
80 dB(A) from the date of the commencement of development;
79 dB(A) from 1st April 2015;
76 dB(A) from 1st January 2025”
This regime will introduce some benefits immediately with further achievable
reductions in the future but with little risk to the operator infringing on the NVL
values.
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