Heathrow Noise Action Plan 2019 – 2023 Response

Responses to the Heathrow Noise Action Plan Draft 2019-2023 are required by June 26.  Information about the consultation and how to respond is on the Heathrow web site here.

We encourage you to respond, and suggest some content for you below. Please either write to Freepost NOISE ACTION PLAN CONSULTATION or email NAP@heathrowconsultation.com.

The plan totally fails to address the noise issues for the overflown of South East London.  We are not even mentioned nor do we appear in the Noise Contours. The points listed here could be made as general comments in a letter of response.  Read our full response here.

  • The draft NAP uses Sound Exposure Levels calculated on a dB scale (Lden, Lday, Leve, Lnight, LaEq) that are shown within noise contours produced in 2016 by Environment Research Consultancy Department (ERCD), part of the CAA. These figures do not represent the significant increase in aircraft noise over SE London that has occurred since 2016.  This makes many of the measures listed in this document redundant for SE London.
  • The draft NAP is worthless for SE London unless it can show how to:
    • Use curved approaches that turn onto the ILS closer to the airport.
    • Use a herringbone approach algorithm so that consecutive planes do not follow one another into the ILS.
    • Gather statistics for noise that affects SE London from all plane traffic below 7000 feet to enhance noise data for a single airport (LHR).
    • Implement approaches that do not overlap with approaches to another airport below 5000 feet.
    • Decide if CDA is still a valid noise abatement measure where continual noise exists all day long such as in SE London – or would a stepped approach be better further out?
    • Employ a 4° approach angle that is known to be possible without detrimental effect or pilot training.
  • Plane noise is not about “discrete noise events” for SE London. It is CONTINUOUS. These are some example readings with timings from the Camberwell noise monitor and the proximity of the flights renders a continuous sound effect:
Time Model Noise
4.27am 388 67dB
4.34am 744 62Db
4.36am 744 62dB
4.38am 772 63dB
4.40am 77W  
4.41am 789 61dB
4.44am 772 64dB
4.46am 388 65dB
4.50am 77W 62dB
4.53am 388 66dB
4.27am 388 67dB
4.34am 744 62Db
4.36am 744 62dB
4.38am 772 63dB
  • The draft NAP takes pride in a reduction of area within its noise Contours , but SE London is not included in this new data and, until proved otherwise, has taken on the burden of noise that is no longer included by the Strategic Noise Mappings.
  • The draft NAP is only about Heathrow. The reality of aviation noise for SE Londoners is that they also endure noise from London City Airport.  This is not a problem for people living in west London, nor is it a problem for people living west of Heathrow. This multiple airport issue MUST be addressed within any NAP: in fact the whole principle of the NAP needs to be reassessed, such that collaboration with (in this case) LCY must be a part of the plan. An analysis of the cumulative noise burden must be presented together with input from the controlling authorities NATs, CAA and the DfT.  A Noise Action Plan with this missing element cannot be taken seriously as a description of how to manage noise over areas that are overflown by other airports too.
  • The draft NAP is long and repetitive. The wandering nature of the text suggests that the authors are unsure about the relevance of what they write and where to put content.  The document also gives the impression that its creators are still unaware of the reality of the noise that the overflown are suffering. 
  • Throughout, the document is self-congratulatory and fails to properly acknowledge that aviation noise is a highly disruptive and health-threatening problem for hundreds of thousands of Londoners.