Response from Smisby Parish Council to East Midlands Airport 2022 consultation on departure and arrival routes, phase 2. 8 Dec 2022
General comments
The range of options given in Phase 2 do meet the stated design criteria but no account appears to be taken of the effect of wind drift on noise-shadow. It is presumably accepted that routes which fly just 'upwind' of any noise-sensitive site will be less attractive and this should influence the choice of routes for each of these runways.
Runway 27 will be the favoured runway with any Westerly component to the wind, and Runway 09 with Easterlies and - although a relatively minor physical factor - our comments therefore take this into account since it will actually have a significant impact on our own noise issues owing to our close proximity to the airport.
The parish of Smisby suffers very badly from direct overflight and also from frequent noise/emissions nuisance, especially at night.
The Parish lies directly under the Daventry 27 departure route and also under the right-hand downwind leg for 09 arrivals from the South. It therefore suffers in all wind directions and from both arrivals and departures.
There is a considerable and growing body of unhappiness with the current arrangements amongst residents. Lying just a short distance north of Ashby it follows that our comments are probably also representative of Ashby de la Zouch, Hartshorne and Blackfordby. There is very substantial building activity just south of Smisby along the A511 and this means that rapidly increasing numbers of people will be affected by this nuisance in the near future.
The residents are very concerned not only about the existing poor choice of routes and associated nuisance but also by the frequent use of dirty and inefficient aircraft (emitting noise and physical pollution), by the inconsistent application of Continuous Descent Arrival procedures (by certain operators in particular) and by the unfortunate timing of many of the flights. It is commonly observed that many arriving aircraft fail not only to remain as high as possible but also fail to achieve a low-thrust arrival, tending to slow down and then fly for prolonged periods in a high drag/high thrust condition at low heights.
We are aware that the purpose of this consultation to consider only the selection of routes and not the other issues above - but we look forward to further improvement in those areas too.
The topic of ‘respite’ was aired at Phase 1 but is noticeably largely absent from the Phase 2 discussions. We feel that the concept of alternating routes to provide respite is good idea and one which should probably be discussed further. We note the comments regarding Performance Based Navigation capability in modern aircraft and presume that this would facilitate the use of such alternating ‘respite’ routes.
The Parish Council wish to stress that their priority task at this stage is to avoid direct overflight of the parish, ideally by the widest possible margin and downwind of the parish where possible.
Specific comments on those phase 2 proposed routes which affect Smisby Parish.
Runway 27 departures to the South East.
Option 5 is acceptable and would reduce noise nuisance somewhat. Options 1,2 and 3 are acceptable but worse than option 5 owing to noise nuisance. Options 4 and 7 are the least acceptable owing to noise. Comment: in Westerly winds the earliest possible turn is desirable since the noise will tend to drift somewhat with the wind
Runway 27 Departures to the South.
Option 1 is unacceptable due noise. Option 3 is most attractive for noise reduction. Option 2 is less attractive than 3 but is acceptable. A suggestion would be to introduce a fresh alternative which combines the early Southerly 'offset' turn depicted on option 7 (to benefit Melbourne) immediately followed by a continued turn to pick up the routes already shown as 2,3,4 or 5. This would overcome the likely wind-borne noise-shadow cast by options 6,7 over Ashby de la Zouch in westerly winds.
Runway 27 Departures to the South West.
All options are poor. Option 1 is unacceptable due noise. Option 4 is fractionally better than option 1 but still unwelcome. Options 2 and 4 are acceptable but still not attractive. We suggest two possible alternative routings which would be an improvement on all those currently shown.
Suggested alternative new option ‘4A' for southwesterly 27 departures would start with the early southerly offset depicted in option 4, but immediately continuing the turn to pick up the track of option 2. This would minimise noise.
Another suggested new option ‘4B' for southwesterly 27 departures would start with the early northerly offset turn (to benefit Melbourne) but instead of attempting to regain track 4 would route direct from approximately Foremark towards Tamworth. This would minimise noise and be would also be an efficient route
Runway 27 Departures West.
Option 2 is unacceptable. Options 3 or 4 are best. Options 1 and 5 are undesirable.
Runway 09 arrivals from the South.
Options 3, 4,11 and 12 are unacceptable due noise. The tracks are longer which is inefficient and although this consultation relates to routes only it should be borne in mind that not all operators successfully adhere to to noise/emission reduction techniques. It follows that shorter routes will tend to leave aircraft higher and at lower thrust settings - which will have an indirect but substantial noise benefit. Moreover these routes all pass more-or-less immediately upwind of the noise sensitive areas, which is contra-indicated.
Options 7,8,9 and 10 are not as bad as 3,4,11,12 but they fall between two stools being neither short and efficient nor avoiding noisy overflight very well.
Options 1, 2,5,6,15 and 16 are all acceptable for both noise and efficiency reasons, and additionally - based on regular observations of current operations - are likely to promote good housekeeping techniques by the operators
Runway 27 Arrivals from the South
Options 3,4,9,10, 11,12 are poor since they will tend to distribute noise over sensitive areas whilst consuming additional track miles to no advantage.
Options 1,2,5,6,7,8,13,14 are all better since they combine direct routings with a general avoidance of overflight and noise
Response from Smisby Parish Council to East Midlands Airport 2023 Consultation on Draft Noise Action Plan 2024-2028 31 July 2023
Introduction
All UK airports have ‘Noise Action Plans’ and these set out the airports’ strategies to mitigate the impact of aircraft noise. East Midlands Airport, like other UK airports, has recently issued its draft plan for the coming period (2024-2028) for comments. This 105 page document is available through the EMA website. The deadline for initial comments is 31 July 2023.
On an administrative note EMA airport does not directly include Smisby in the consultation although we have been invited, through our Clerk, to comment. It seems that despite being situated directly under one of the major flight paths we are not automatically included in the ‘Airport Parish Engagement Forum’ and it is suggested that it would be appropriate to be represented on that body.
This document will be posted on the Smisby Parish Council pages see www.Smisby.Org.uk
How to Make a Comment
Individual comments, over and above this Parish Council consensus comment, may be made through the link provided on the Noise Action Plan document, page 8. Anyone wishing to make a personal comment should go online to
https://www.eastmidlandsairport.com/community/local-environmental-impacts/noise/noise-action-plan/
and look for dropdown menu ‘Consultation Draft Noise Action Plan 2024-2028’. Then just open this 105-page document and on page 8 you will find the link to “NAP feedback form here”
Or you can email your comments directly to the airport at the following address.
Please mark your correspondence as ‘Noise Action Plan Consultation’.
General Observations
Airports derive their income from a variety of sources and this is typically proportional to the number of passengers, the tonnage of freight, the number of movements, the timing of those movements and any relevant penalties. Many of the penalty costs levied on violating aircraft are spent on local community funds and not retained by the airport.
Although the Noise Action Plan relates to aircraft noise and its mitigation it does, in effect, also relate to other environmental impact since there is a strong correlation between noise produced and fuel burnt – in other words carbon emissions and other pollutants. It follows that any efforts to reduce noise are likely also to reduce the other associated irritants.
Whilst the document contains a very great deal of information, much of it still provides an incomplete picture in this complex area, and in some places does appear to contradict statements made elsewhere. It would be extremely helpful to have some worked examples eg…. A300 aircraft weigh X tons, fall into QC level Y for takeoff and Z for landing and if used at night are penalised P pounds, or Antonov 124 aircraft fall into QC 4 and are banned from night operations. All UK airport noise action plans are similar in layout and content although clearly they tend to have different rules and interpretations. None of them is a particularly easy read, nor contains a straightforward summary, and all require cross-referencing to other complex documents in order to analyse their content. One possible suggestion would be to request a summary version which also includes the reasoning behind changes and supporting links or explanations.
The Appendices are perhaps the most concise and handy parts of this complex Noise Action Plan document:
Appendix A being a useful summary of the proposed 39 Noise actions for 2024-2028
Appendix B focusses on the proposed ban on the very noisiest aircraft (QC4 and worse) and shows that there has been a very substantial increase in the use of such aircraft since 2021.
Appendix C provides data on noise contour maps and estimated number of population affected by those contours. Note. The EMA noise monitor which has been temporarily installed in Smisby for this summer will enable this contour map to be updated if required, whilst the very substantial amount of building activity north of Ashby will presumably result in an increase in estimated population affected.
Appendix D summarises the progress with action items from the current Noise Action Plan
Appendices E and F show the current lateral routes (which are under separate review)
Appendix G is the actual questionnaire about the current draft plan.
Appendix H gives some funding information and Appendix I relates to sound insulation (not applicable to Smisby)
The link to the actual online feedback form can be found on page 8 of the Noise Action Plan, at the end of Section 2, ‘Public Consultation’
Aircraft noise and the measurement thereof
The ‘Chicago Convention’ Annex 16 sets out the noise guidance and the relevant parts are Chapters 2,3 4 and 14 each of which (in chronological order) established a fresh up-to-date baseline noise figure. Thus some aircraft are referred to as “Chapter 2’ (which basically means very old and very noisy), Chapter 3 (1908-2000, still pretty noisy), Chapter 4 (2000-2010, rather better but still definitely noisy) and currently Chapter 14 (relevant since 2017, getting much quieter). All Chapter 2 aircraft have been banned from European airspace since 2002 so the chapters relevant to us are 3, 4 and – increasingly in the future - 14
Additionally, each aircraft type or variant has an applicable noise certification value, expressed in units of decibels (dB). Note that the decibel scale is logarithmic therefore an increase of 3 equals double the noise whilst a reduction of 3 would mean a halving of noise: and an increase of 6 would imply a quadrupling of noise, etc. This certification number remains fixed for any given type/variant and will take into account the fact that some types can have different sorts of engines installed which may mean a different noise level and hence a different noise certificate values depending on the exact equipment fit.
Aircraft types are also sometimes allocated a ‘cumulative margin’ percentage which is a single overall figure taking into account the noise at take-off, on approach and on climbout. The cumulative margin is a practical way to determine how well the aircraft actually performs, noisewise, compared with the nominal ‘noise certificate’ figure.
On top of all that all aircraft types and variants (nb a type would be, say, Boeing 737 while a variant would be B737-800 or B737Max) are also allocated a ‘Quota Count’ or QC number. This is essentially a quick way to assess the nuisance value of the aircraft noise. Higher QC numbers are worse than lower, and for those airports where there is a maximum limit on the number of movements a QC4 aircraft will consume 4 times as many allowable movements. Some airports have night-time quotas while some have overall quotas and many have both.
QC 4 aircraft are certified to produce 96-98.9db of noise, QC2 are 93-95.9 and QC1 are 90-92.9 and QC 0.5 are 87-89.9dB, etc ie grouped in blocks of 3 dB. Note that many aircraft have different values of Quota Count for takeoff and for landing. There’s a reference document produced by the Civil Aviation Authority listing the QC values - UK AIP supplement 007/2023
In practice most airports employ blanket rules and also blanket charges which will apply to a given range of aircraft and this is mostly applied based either on QC value or on applicable ICAO Chapter number. Note that there is no direct correlation between say Chapter and QC number but as a good guide Chapter 3 is equivalent to QC2 and Chapter 4 equivalent to QC1.
Most of the aircraft which local Smisby residents would regard as ‘very noisy’ tend to fall into Chapter 3 or QC2 therefore any significant reduction in noise nuisance will require a significant reduction in movements of such aircraft. The airport ultimate goal is for Chapter 14 operations which will be broadly QC0.5 ie one eighth of the current typical levels. But this is only a nighttime goal, and the target is 2040.
Finally, there are often penalties which may be levied if the aircraft noise (as measured near but not on the airport) significantly exceeds the certified value, or the track-keeping is consistently poor, etc. Such penalties are paid into the airport community fund and spent locally by way of redress, and are not retained by the airport, so the airport does not profit from these surcharges. A comparison suggests that at face value EMA actually applies higher surcharges than BHX however they only do so to very much noisier aircraft. Again, an area where other airports appear to be taking the initiative.
Cumulative nuisance: The noise measures all relate to the passage of a single aircraft but there is no direct analysis which takes into account the number of times the disturbance occurs. Some other airport Noise Action Plans comment on this aspect and clearly recognise that there is a significant difference between an isolated noisy event and a regular series of sleep interruptions. This is particularly relevant at EMA where such sleep interruptions occur on a frequent basis throughout the night, and particularly in the period between 0200 and 0600, and thus cause sleep deprivation for anyone affected.
We know that people in Smisby who are upset by the aircraft noise are reasonably tolerant of isolated events but struggle greatly with the series of sleep interruptions which so regularly occurs. It is suggested that the effect of these multiple sleep interruptions should be accounted for perhaps by some mathematical product of the number of events times the noise value of each – this might give a truer picture of the nuisance and thus enable better targeting of mitigations. The findings of CAP1588, for example, may be pertinent.
Mitigation measures – in general and those proposed at EMA
1 Outright ban on very noisy aircraft. EMA is proposing to impose a ban on QC4 (or noisier) aircraft - but only at night – from January 2024. This will be helpful since there was an average of approximately one such movement per night during 2022.
For reference, during 2022 less than a quarter of EMA night flights met the Chapter 14 standard (which was introduced internationally in 2017).
The airport hope that all aircraft at EMA will be ‘Chapter 14’ compliant - but only by 2040 and only at night – which does not seem very ambitious. This contrasts, for example, with Birmingham Airport where aircraft with a QC of only 1 have already been banned from night operations since 2018, and as far back as 2015 operations had already been restricted to QC2. Gatwick airport has already banned QC4 aircraft since 2022, and Stansted since 2017. Heathrow has long since banned night operations by aircraft with QC4 or more. So EMA will be still willing to accept aircraft which are twice as noisy as BHX (albeit with noise penalties), and then only 6 years later than BHX banned them. It’s not very good.
2 Specific night time quotas. The EMA plan does not mention a maximum quota of night flights. There is presumably no limit. Birmingham has a quota. Heathrow, Gatwick and Stansted all have quota limits (which they fully consume). It is suggested that absolute limits, and quota limits of noisy aircraft exceeding QC2 would be beneficial in view of the current repetitive nature of night-time noise nuisance, and to accelerate the progress towards the target of complete ICAO Chapter-14 compliance.
3 Lateral route structure update, aka Future Airspace Programme, to which we are already contributing. This is a separate – and welcome – discussion running in parallel with the NAP. The current routes have not been re-evaluated for many years and are based on terrestrial navigation aids which have seldom been used in practice for the last 25 years. The routes overfly a number of noise-sensitive areas for no ongoing reason and are now under review. There is a direct conflict between some of the NAP remarks about concentrating flights into narrow areas, and future thinking (as expressed in the future airspace route structure study) whereby the concept of ‘respite’ (ie varying the routes and alternating between routes) would alleviate the suffering of the worst-affected residents. This plan has been commented on in detail by Smisby parish Council in their December 2022 response to that consultation.
4 Funding for community and sound insulation funds. These contributions have been increased but remain at a relatively low level overall. The sound insulation fund covers only a small area of terrain and Smisby is not within that area. The draft proposed EMA contribution to the community find is £55000 (comparison: BHX airport contributes £95000). In both cases the fund is also boosted by the amount of any noise surcharges.
5 Flight altitude restrictions and continuous climb/descent operations. It is noticeable that the extent of compliance with CDA procedures varies from operator to operator and certain patterns are readily spotted. Such CDA procedures are presumably monitored by the airport but apparently not enforced very vigorously. It would be worthwhile ‘naming and shaming’ the worst operators (and perhaps praising those who DO comply competently).
It is not immediately clear from either BHX or EMA airport Noise Action Plans how exactly they measure CDA compliance but both mention the need to avoid level flight in their notes to pilots and FlightRadar24 evidence suggests that – at least at EMA – this is often not achieved.
It is noted that CDA targets at EMA have been set at 95% since before 2018 but were never actually met – currently running at about 90% only and rising to 91% in 2022. The airport has recently set a goal of actually achieving its 95% target by 2028 and has an aspiration of 98% thereafter once new flight paths are introduced. This compares with nearby Birmingham airport which currently has a slightly more ambitious CDA target of 96% with 92% compliance. It is noted that Ryanair airline claim a consistent compliance rate of over 99% which – if true – suggests that there must be other operators who fall well below 90% and begs the question what is being done about this inconsistency?
EMA does produce a ‘Quiet Flight Report’ which is of some use in determining how operators perform in different areas but this is once again a separate document, although referred to in the Noise Action Plan, which requires considerable analysis to understand. The report was first published in 2022 and hopefully will enable a number of the desired responses to be monitored and/or accomplished.
6 Incentivising/fining operators to promote cleaner operations. The past EMA schemes of charges available on the internet suggest that a noise surcharge fee of £3028 would be levied on QC4 aircraft however for much of the current NAP period that surcharge has in fact been rebated and only gradually phased in. Thus it is difficult to determine what aggregate surcharge if any has actually been levied, since the NAP doesn’t give this figure. The figures given in Annex C suggest that the use of QC4 aircraft has in fact been rising steadily since 2021 despite the gradual introduction of the full noise levy: this in turn suggests that the levy has been insufficient to deter very noisy aircraft. It therefore follows that much higher levies must be charged in order for this deterrent to be effective.
For the coming period the NAP suggestion is that Chapter 4 aircraft will be banned altogether from 2024 and also there will be a surcharge of £3028 applicable to Chapter 3 or QC4 aircraft. This is a substantial raising of the bar compared with the previous plan and is therefore very welcome.
However by comparison BHX would charge £14.85 per ton for night noise exceedances (for a B777 this would be approximately £3500) so the EMA penalty seems to be much lower than BHX - which might have the effect of actually attracting the noisier aircraft rather than repelling them.
In short, it seems the noise penalties need to be really high to be effective, and certainly higher than any other nearby airport. Currently it seems that, despite the changes, they are not.
The East Midlands scheme of charges introduces a ‘banding’ of fee scales but these are broadly equivalent to noise nuisance capability.
7 Other pollution. Noise is not the only issue. Carbon-neutral operations are likely to be positively boosted by anything which limits noise. Numerous operation practices exist which carry ‘carbon-credits’ to offset operational impact. It is suggested that the details of any such schemes, and the way in which they have an impact on noise nuisance, should be reported in the Noise Action Plan for completeness.
References
Draft Noise Action Plans 2024-2028 for Gatwick, Stansted, Heathrow, Birmingham, East Midlands
East Midlands Airport Draft Noise Action Plan 2019-2023 Supplementary information
Current Noise Action Plans for Gatwick, Stansted, Heathrow, Birmingham, East Midlands
Schemes of fees and charges for BHX and EMA
EMA quiet-flight-performance-report-2022
UK CAA CAP 1588 Aircraft Noise and Annoyance: Recent findings
UK AIP SUPPLEMENT 007/2023
UK CAA CAP2302 Low Noise Arrivals
Overall Summary by Smisby Parish Council
This is a very technical document in places and the PC lacks specific expertise in the matter of aircraft noise mitigation. Nonetheless we have tried to analyse this Noise Action Plan and to compare it with those of other airports. We apologise for any errors or omissions, and for the rather late compilation of this report. It has taken a great deal of time and effort to read up all the different airport action plans and the supporting documents! Note – there are a significant number of references listed below – and no doubt others - which have been consulted in the compilation of this, Smisby’s first formal response to a Noise Action Plan.
The increasing level of noise complaints raised to the PC by residents suggests that we need to seek greater involvement and representation in this matter in the future.
Overall, this draft Noise Action Plan is better than those issued in the past and represents a significant step forward. It would however be really helpful for the document to be made easier to follow and to offer specific examples and also comparisons with other airports. It is regrettably a suspicion that this may not currently occur since EMA does appear at present to compare unfavourably with other airport operators – on the matter of noise nuisance - in virtually all regards.
In view of our location and the magnitude of the local noise nuisance it seems clear that Smisby PC should become part of the airport engagement forum – and other consultative bodies - and the airport should be invited to present to a PC or another public meeting asap
Many of the goals lack numerical target values and/or dates and therefore are more of a wish-list than actual achievable measurable goals. It is hoped that ‘smarter’ actions might be developed.
The specific banning of QC4 aircraft is excellent and this now replicates procedures which have already been in place in other similar airports for most of the last decade.
The noise surcharges for night operation in particular appear cheaper than other airports – or applicable only to much noisier aircraft - and are likely to generate quite a lot revenue for the community fund – but there is no evidence to suggest this has previously reduced noisy movements much, and therefore either the measure is ineffective or the levels are too low. The costs should be higher in absolute terms and also should increase steadily and substantially each year if they are to prove effective in incentivising the use of more modern aircraft.
Summary.
Overall, too little, too late. This is not a very ambitious plan.
Whilst we should be grateful for the forward steps there is comparitively little to be proud of in this document. We appear to lag the rest of the UK and the focus seems mostly to be on penalising noise rather than reducing it at source.
Specific responses to the 39 Draft Noise Action Plan 2024-2028 proposed actions from Smisby Parish Council are:
Noise Action Plan 1: Preferred runway direction. We will continue to maintain our preferential runway policy and monitor runway usage
Response: This is not in fact advantageous to Smisby, nor necessarily anyone else apart from Kegworth. It is unclear what benefit monitoring will incur.
Noise Action Plan 2: Continuous descent approach Improve our CDA performance to achieve a target of 95% CDA by 2028, rising to an increased target of 98% CDA following implementation of modernised airspace through our Future Airspace Programme by 2028.
Response: There is no analysis of why the previous target of 95% has never once been met over many years, nor why FAP might cause such a dramatic improvement. There is no information on offer about the varying performance of different operators, nor what is being done to assist them to improve – or penalize failure to do so. nb: this action is apparently identical to action 4
Noise Action Plan 3: Specified arrival routes. Through our Future Airspace Programme we will continue to explore with stakeholders the options for specified arrival routes to the airport using new satellite based navigation technology, seeking to reduce noise impacts. This will be reviewed and implemented through our Future Airspace Programme.
Response: This is good but nb the satellite based navigation (often called GPS) is not new. There are exciting possibilities for improved routes to reduce noise and other pollution and Smisby Parish Council has already responded in detail to that – separate, ongoing - consultation
Noise Action Plan 4: Low power, low drag approaches. Work with operators to improve compliance with the published low power, low drag procedure.
This is more or less identical to action 2 but without any numerical targets, rewards or penalties. No detail is given about how such ‘work’ will be performed therefore it will be impossible to measure success. The Quiet Flight Report refers but it is impossible with the data to hand to analyse this properly.
Noise Action Plan 5: Reduced-engine taxi. Continue to promote the use of reduced engine taxi at the airport where it is practical and beneficial to do so.
Response: more detail is needed. How does this excellent-sounding endeavour tie in with carbon offset schemes, and how might it be monitored, etc?
Noise Action Plan 6: Review effectiveness of ground noise procedures. We will carry out a review into the effectiveness of our ground noise procedures and explore options for how these can be improved. By 2026
Response: The timescale is far too slow and without specific goals eg percentage use of FEGP/APU therefore – once again – it cannot be measured.
Noise Action Plan 7: Engine testing. We will carry out a review of our engine testing procedures and explore options for how these can be improved to reduce noise impacts on local communities. By 2024
Response: It is good that such practices should be reviewed, and soon. It is unlikely to have an impact on Smisby but nonetheless clearly should be encouraged.
Noise Action Plan 8: Use of aircraft ground power. Work with our industry partners to identify and encourage quieter ways to service aircraft, for example through the use of alternatively fuelled vehicles and equipment.
Response: this sounds good but without targets, or a target date = not an effective or measurable action
Noise Action Plan 9: Use of intersection departures. We will continue to promote and encourage the use of intersection departures (see explanation on page 47), from Runway 27 at night to reduce ground noise for local communities. Other sources of ground noise can include vehicles and equipment used to service aircraft. This can be intrusive for people who live very close to the airport. This noise source can include the reversing beepers. We have worked with our stakeholders to reduce this noise, and vehicles now have an audible reversing system that still emits a tone that meets required safety standards, but doesn’t transmit the noise over such a wide area.
Response. The use of intersection departures might be good for Kegworth when 27 is in use but will be bad for Melbourne/Ticknall/Smisby/Ashby etc. Aircraft will lift off later and climb slower. Opposed. nb it is unclear what connection, if any, exists between reversing beepers and intersection departures. Should these remarks actually have been applied to item 10 below?
Noise Action Plan 10: Night time vehicle noise. We will continue to work with our business partners to identify and implement measures to minimise noise from vehicle movements on the airport at night.
Response: Clearly a good idea but an issue for Smisby. nb once again it lacks measurable goals.
Noise Action Plan 11: Departure track-keeping. Maintain our departure ‘on-track’ keeping performance target of 98% on departure routes (excluding the Trent departure route from Runway 09). Continue to monitor and report performance with and without the Runway 09 Trent route.
Response: this is a traditional goal which assumes the concept of Noise Preferential Routes is valid. We challenge that assumption and it does conflict with the Future Airspace Programme concept of ‘respite’ through alternating routes. Opposed. Similar to action 14
Noise Action Plan 12: Explore options to improve the effectiveness of NPRs. We will explore options for performance-based navigation procedures which will be implemented though our Future Airspace Programme.
Response: excellent that NPRs are being challenged – the Future Airspace Programme offers long-overdue improvements for all.
Noise Action Plan 13: Continuous climb departures (CCD). Explore with airlines and air traffic control, the opportunities to increase the use of continuous climb departures through airspace modernisation.
Response: this is excellent and offers long-overdue improvements in efficiency and emissions for all – see Future Airspace Programme. Again, no measurable targets are mentioned, which suggests that this may not presently even be monitored. This will offer benefits further away from the airport and is unlikely to be of direct benefit to Smisby but is nonetheless clearly welcome.
Noise Action Plan 14: Off-track departure fines. We will continue to monitor off-track departures, working with operators to improve performance and, where applicable, raising off-track departure fines to penalise airlines who are not working to improve their track- keeping and meet our published target (see action NAP11).
Response: Smisby would benefit from variation to the route so that not ALL the aircraft fly directly overhead. We would welcome some variation and indeed the Future Airspace Programme might offer us such respite. nb this is very similar to action 11. Unless fines are actually levied compliance is unlikely to be boosted. Remarks in the NAP suggest that this is not always the case.
Noise Action Plan 15: Noisy aircraft penalty scheme review. We will review our noisy aircraft penalty scheme, introducing a scheme which also applies during the day. By 2025.
Response: This very worthy goal but lacks targets and with a very slow timescale. Why can’t the nighttime rules coming into force in 2024 apply? Note the penalty scheme proposed will still apply only to aircraft which are more than twice as noise as, say, Birmingham
Noise Action Plan 16: Noisy aircraft penalty. We will continue to operate a noisy aircraft penalty scheme that penalises the operators of aircraft which exceed our published night noise limits. We will review our scheme in accordance with Noise Action Plan 15.
Response: same as action 15 but for night operations but without a deadline. Again the penalty threshold is very noisy indeed compared with other airports and the fines are unlikely to be enough to make a difference. No data are supplied to suggest why the current level of fines is successful
Noise Action Plan 17: Review effectiveness of noise related charges to incentivise the use of ICAO Chapter 14 compliant aircraft at night. We will carry out a review of our existing noise charges, changing them where required to incentivise the operation of aircraft in the daytime wherever possible and to promote the use of quieter aircraft on flights that necessarily take place at night. By 2026
Response: This is very good idea but with a very slow timeline. Past data suggest that the currently level of penalties has been wholly ineffective. More urgent action would be appropriate.
Noise Action Plan 18: Operational ban on QC4, QC8 and QC16 rated aircraft at night. From 1 January 2024, we will introduce an operational ban on aircraft with a QC4, QC8 or QC16 noise rating operating at night.
Response: This is long overdue and very welcome. Such a ban has already been in place in Birmingham since 2015 and other airports too since their current or previous NAPs.
Noise Action Plan 19: Night noise envelope. Monitor, manage and annually report on performance against the airport’s 55dB LAeq (8-hour) summer night-time noise contour, aiming to progressively reduce it and ensuring it does not exceed 16km2.
Response: a moderately worthwhile goal. How about seeking to reduce the footprint area rather than just monitoring it?
Noise Action Plan 21: Training Flights Report. We will continue to monitor and report performance with our training flight exclusion areas, identifying trends and compliance issues. We will address issues as necessary.
Response: lacking targets and dates but otherwise a good action
Noise Action Plan 22: Management of training flights. From 1 January 2024, we will reduce the number of hours available for training activities by commercial jet aircraft. Training activity will only be permitted from 08:00 to 12:00 and from 14:00 to 16:00 daily, excluding weekends and bank holidays. By 2024
Response: This does affect Smisby and is welcome
Noise Action Plan 23: Review of training flight procedures. We will carry out a review of training flight procedures, identifying and where possible implementing opportunities to minimise the impact on local communities. This will include investigating the possibility of balancing the number of training flights taking place to the north and south of the airport. By 2024
Response: This is helpful although not really a problem for Smisby at present.
Noise Action Plan 24: Sound Insulation Grant Scheme. We will continue to operate a Sound Insulation Grant Scheme (SIGS) to provide support to those people that are most exposed to aircraft noise at night.
Response: not applicable to Smisby owing to location but an excellent ongoing activity.
Noise Action Plan 25: Improved Sound Insulation Grant Scheme eligibility and grant values. We will improve our SIGS programme, updating the Scheme rules to reset the value of grant funding offered to properties 20 years after any previous grant was awarded. Additionally, we will increase the contribution available through grant awards by 10% on 1 April 2024, and apply CPI inflationary adjustments annually thereafter. The value of the grant will be rounded up to the nearest £100 after inflation is applied each year
Response: not applicable to Smisby owing to location but appropriate
Noise Action Plan 26: Sound Insulation Grant Scheme technologies. We will carry out a review of the sound insulation options available through our SIGS, with a view to improving the range of options for buildings eligible under the scheme. By 2025.
Response: not applicable to Smisby owing to location
Noise Action Plan 27: Community Fund. We will increase the airport’s contribution to the East Midlands Airport Community Fund from £50,000 to £55,000 from 1 April 2024, applying CPI inflationary increases annually thereafter. The value of our contribution will be rounded up to the nearest £1,000 after inflation is applied each year. Additionally, we will continue to contribute all the money raised from noise surcharges and noisy aircraft penalties to the Fund. The airport will continue to carry out regular reviews of the Community Fund to ensure it remains effective.
Response: the contribution to the fund is significantly too low to indicate a genuine commitment, and is roughly half what BHX pays. It does appear that EMA perhaps doesn’t
take it very seriously. No mention is made of the destination of route and CDA/CCD penalties.
Noise Action Plan 28: Community monitoring. Continue to implement a programme of community noise monitoring in consultation with the ICC.
Response: in view of the significant increase in noise nuisance and the very corresponding significant increase in issues reported by Parishioners, Smisby Parish Council asks to be included in this and any other consultative processes.
Noise Action Plan 29: Independent assessment of community noise environment. We will develop an approach to, an independent analysis of, the noise environment at our fixed noise monitoring sites. By 2025
Response: This is slightly unclear but the concept of independent noise verification is a ‘sound’ one. The analysis of actual nuisance level – rather than just the absolute noise level – should be included, as should links between noise, pollution and health.
Noise Action Plan 30: ‘Quiet flight performance’ reporting. Continue to publish annual updates of the Quiet Flight Performance Report, reviewing the metrics it contains, and updating the Report as necessary to inform stakeholders and support airlines in minimising noise impacts.
Response: This is a new initiative which has only recently started and is very welcome
Noise Action Plan 31: Identify smarter ways to work with industry partners in reducing noise. We will collaborate with industry partners through our Pilot Liaison Group and monthly performance reporting, identifying, and implementing opportunities to minimise the noise impact of operations at the airport.
Response: This is very vague. Of course this activity goes on but is it a valid actual measurable NAP ‘action’?
Noise Action Plan 32: Provide and regularly review effective engagement with communities. Continue to provide regular opportunities to engage with local people to understand their concerns and respond effectively to them, to include community outreach events and a community newsletter. Develop and review the effectiveness of our engagement programme regularly in response to Community Impact surveys.
Response: more action would be welcome please and Smisby Parish Council would like to be involved.
Noise Action Plan 33: Carry out regular community survey. Carry out a regular community survey to collect views on how effectively the airport is managing aircraft noise issues as well as other issues. Results from the survey will be shared with the East Midlands Airport Independent Consultative Committee, airlines, air traffic control and community groups and used to inform any future noise actions.
Response: more action would be welcome please and Smisby Parish Council would like to be involved.
Noise Action Plan 34: Noise related community investment. Provide specific information on aircraft noise-related community investment as an appendix to the annual airport Community Investment Report. This will clearly show how money raised from noise surcharges and penalties is used to support the communities affected.
Response: more action would be welcome please and Smisby Parish Council would like to be involved.
Noise Action Plan 35: Provide educational and skill development material on aircraft noise. We will continue to include educational material on aircraft noise management as part of our programme of educational visits to the airport.
Response: more action would be welcome please Response: more action would be welcome please and Smisby Parish Council would like to be involved.
Noise Action Plan 36: Noise Action Plan Progress Report. We will produce an annual report, presented to the East Midlands Airport Independent Consultative Committee, summarising progress made by the airport against this
Noise Action Plan.
Response: in view of the lack of progress and/or success with previous NAP targets suggest perhaps a 6-monthly report to maintain focus? Also, since the Future Airspace Programme may have a considerable impact on a number of the actions, it would be appropriate to review at least those actions as soon as FAP is finalised.
Noise Action Plan 37: Online noise portal for local communities. We will develop and introduce an online portal providing location-specific information about noise management and performance to local communities. By 2024
Response: This is welcome, current website access is rather cumbersome and links can be troublesome.
Noise Action Plan 38: Continually improve noise complaint and enquiry process. Regularly review our process for handling noise complaints and enquiries to improve the transparency and effectiveness of the system. This will include consultation with the East Midlands Airport Independent Consultative Committee. Our first review will be complete by mid-2024 with agreed actions implemented by the end of 2025.
Response: this is welcome but timescale is too slow. 18 months to implement the agreed actions???
Noise Action Plan 39: Develop and publish noise complaints policy. We will develop and publish a policy which explains the way in which we investigate and respond to noise-related enquiries from local communities. By 2025
Response: This is overdue and with a rather slow timescale but welcome
PTO
Smisby Parish Council responses to online Draft NAP questionnaire:
Appendix G – Consultation questionnaire
East Midlands Airport Draft Noise Action Plan - Feedback Form
We appreciate you taking the time to provide us with feedback on our Draft Noise Action Plan for 2024-28. This form will take approximately 6 minutes to complete. For more information on how we will use and store your data please visit www.eastmidlandsairport.com/privacy-notice
1. What is your name? Michael Cuming
2. Are you responding as an individual or on behalf of an organisation? ORGANISATION
3. What organisation are you responding on behalf of (if applicable)? SMISBY PARISH COUNCIL
4. What is your postcode? LE65 2TY
5. What is your e-mail address? We will only use this to contact you about the Noise Action Plan consultation
Chapter 8 - Noise controls
6. Are the actions we have identified in Chapter 8 ‘Noise controls’ adequate? NO. 7. If you have answered no, what actions should we be considering in Chapter 8 on Noise controls?
The action “Expanding the QC4 night noise surcharge to cover flights operated by Chapter 3 certified aircraft” Whilst the principle is sound, the actual limits imposed are not very ambitious. It appears that it would be cheaper to send a noisy aircraft to EMA than to BHX and thus the surcharges may not have sufficient deterrent effect. Surcharges will need to be much greater and rise rapidly in each year to have effect. The goal is primarily to deter noise not to raise money for the community fund.
Chapter 9 - Arriving aircraft
8. Are the actions we have identified in Chapter 9 ‘Arriving aircraft’ adequate? NO. 9. If you have answered no, what actions should we be considering in Chapter 9 on Arriving aircraft?
Actions 2 and 4 appear to be more or less identical. Monitoring and acting on CDA compliance appears to lack clear targets and deadlines, other than remarks to the effect that the airport has never once yet hit its target – yet nonetheless hopes to do better in the future. It is suggested that ‘naming and shaming’ the worst offenders should be considered, and that compliance data should be readily available. Perhaps lack of compliance should also carry a surcharge? The Quiet Flight Report is a good start and very welcome, but the whole area feels vague.
Chapter 10 - On the ground
10. Are the actions we have identified in Chapter 10 ‘On the ground’ adequate? NO. 11. If you have answered no, what actions should we be considering in Chapter 10 ‘On the ground’?
NAP goals 5-10 do not contain any specific targets nor any measure of success. In this respect they are simply nice ideas which can neither be verified nor measured. Specific target should be set if these are to be regarded as meaningful goals.
Chapter 11 - Departing aircraft
12. Are the actions we have identified in Chapter 11 ‘Departing aircraft’ adequate? NO 13. If you have answered no, what actions should we be considering in Chapter 11 ‘Departing aircraft’?
Actions 11-15 fall short of adequate surcharge structure and lack detail on how it is hoped that surcharges will work. It is suspected that at the proposed levels they will not. On the plus side, the Future Airspace programme offers significant hope for respite, or for alternative routes which might be quieter, more varied and with lower emissions - but this is running behind schedule so it is currently hard to assess its impact.
Chapter 12 - Night noise
14. Are the actions we have identified in Chapter 12 ‘Night noise’ adequate? NO 15. If you have answered no, what actions should we be considering in Chapter 12 on ‘Night noise’?
The current NAP falls short in terms of limiting actual noise. The surcharges appear less than other airports therefore are unlikely to have enough impact. Evidence of the last two years show increasing numbers of noisy flights despite higher charges so the surcharges aren’t proving effective at current levels.
Further, there is no account taken of the combined product of noise levels and the number of disturbance events per night, and in particular during the ‘window of circadian low’ when sleep should most be protected. There should be some mechanism for evaluating and mitigating this.
Chapter 13 - Training flights
16. Are the actions we have identified in Chapter 13 ‘Training flights’ adequate? YES
17. If you have answered no, what actions should we be considering in Chapter 13 on ‘Training flights’?
Chapter 14 - Mitigation schemes
18. Are the actions we have identified in Chapter 14 ‘Mitigation schemes’ adequate? NO. 19. If you have answered no, what actions should we be considering in Chapter 14 on Mitigation schemes’?
The airport fund contributions are low compared with other airports which suggests a lack of commitment. Moreover the real issue isn’t to buy off animosity with cash but rather to actually tackle the nuisance.
The insulation schemes are not relevant to Smisby owing to its location but it should be noted that insulation is of little value on summer nights when windows are likely to open
Chapter 15 - Monitoring and recording
20. Are the actions we have identified in Chapter 15 ‘Monitoring and recording’ adequate? NO. 21. If you have answered no, what actions should we be considering in Chapter 15 on ‘Monitoring and recording’?
The actions themselves are sound but they lack timescales and measurable achievable targets.
Chapter 16 - Effective communication
22. Are the actions we have identified in Chapter 16 ‘Effective communication’ adequate? NO. 23. If you have answered no, what actions should we be considering in Chapter
16 on ‘Effective communication’? PLEASE INCLUDE SMISBY PARISH COUNCIL IN THE COMMUNITY ENGAGEMENT FORUM AND KINDLY SEND A REPRESENTATIVE TO A PARISH COUNCIL MEETING AS SOON AS POSSIBLE. WE ARE BADLY AFFECTED BY SOUTHBOUND 27 DEPARTURES AND BY 09 LANDINGS IN PARTICULAR
Further information
24. When we finalize our Noise Action Plan we will be including a list of individuals and organizations who have responded to our consultation. Do you wish to be identified in the schedule of responses? YES PLEASE – as SMISBY PARISH COUNCIL
25. Are you interested in subscribing to the EMA Community Flyer - our quarterly e-Newsletter? YES
PTO
Additional remarks
The plan represents a significant step forward for which we are grateful however it does appear that EMA is significantly lagging other airports and is at present playing ‘catch-up’ with some considerable way to go.
Many of the actions appear to vague, and either lack timescales altogether or have very unambitious ones.
The focus seems to be primarily on penalising noisy aircraft but past evidence suggests that at the current - and proposed - levels this isn’t effective. The surcharges presumably need to be significantly higher – and set to rise even further in the future if they are to be successful in incentivising the operators to re-equip with better aircraft.
The community fund has been established to offset nuisance however the low funding levels tend to indicate a lukewarm commitment and risk masking the fact that the nuisance itself isn’t – yet – being tackled effectively at source.
No analysis is offered to explain why some past actions (such as CDA operations) have consistently failed to meet their targets, nor what might be done to remedy this.
There is no analysis at all of the overall effect of cumulative noise-nuisance impact ie taking into account not only the level of noise intrusion but also the number of times this occurs – especially at night. This merits study and action.
It has taken the Parish Council considerable effort to read and digest the plan details. It would be extremely helpful – and possibly essential – to offer a plan which contains more readily comprehensible summaries and conclusions as well as the technical data. We are simply unable to comment on the technical details but we do note that the various measures of noise, whilst technically no doubt correct, do not necessarily bear any relation to the actual nuisance suffered, nor the potential mental and physical harm to human health and the environment in general.
It would be extremely useful to see information included in relation to the secondary effects of noise, and their mitigation. Fuel burn, emissions of CO, CO2 and other noxious pollutants. There should be a clear and logical link between environmental policy in general and noise policy in particular. Such details are absent.
Smisby lies directly under the most common departure route from runway 27 and under the arrival route for runway 09 and is badly affected by noise. Most of the aircraft which local Smisby residents would regard as ‘very noisy’ tend to fall into Chapter 3 or QC2 therefore any significant reduction in noise nuisance will require a significant reduction in movements of such aircraft. The airport ultimate goal is for Chapter 14 operations which will be broadly QC0.5 ie one eighth of the current typical levels. But this is only a nighttime goal, and the target is 2040. This goal should be greatly accelerated.
From Smisby Parish Council, South Derbyshire, 31 July 2023
February 2024 EMA engagement survey
Page 1: Section 1 - CSR Strategy Awareness and Priorities
Q1
East Midlands Airport launched its CSR strategy in 2020 'Working Together for a Brighter
Future' Are you aware of our CSR Strategy?
Yes
Q2
Within the CSR Strategy we have three priority areas. Please use the arrow keys to
prioritise these in order of importance to you.
Local Voices – We are committed to addressing the local issues which matter most to the
people living near us, engaging local voices, addressing noise and local priorities.
1
Zero Carbon Airports – We are committed to cutting any remining reliance on fossil fuels whilst
working alongside our partners to reduce the wate and emissions related to our operations
2
Opportunity For All – We are committed to creating quality employment. We believe in providing
opportunity for all, in a safe, inclusive, and diverse environment
3
Page 2: Section 2 - Trust
Q3
East Midlands Airport is a good, honest, and trustworthy neighbour.
Disagree
Q4
When you have an issue relating to East Midlands Airport, you trust that the airport will
listen and resolve this issue.
Disagree
Q5
What initiatives or measures could East Midlands Airport put in place to further strengthen
your trust in the airport? Please explain further in the box below
It would be very helpful for citizens to get honest answers rather than ‘stock’ responses - for example I
know that people in my parish feel they are fobbed off with platitudes whenever they make a noise
complaint. And noise is our really big issue
Page 3: Section 3 - Local Voices
Q6
East Midlands Airport keeps me up to date with their work in my community and what they
are doing.
Yes
Q7
In the past year, which of these methods of communication have you used (tick all that
apply)?
Received our Community Flyer e-newsletter
Checked our website for latest information
Direct email
Attended a virtual engagement session e.g., MS Teams or Zoom
Q8
How can East Midlands Airport improve communication with you?
The channels of communication are ok, but the suspicion remains that questions aren’t truly answered.
This is not to suggest that the staff members are actively lying - but there is a strong feeling that only
part of the truth is ever told For example - fuller information about which operators get noise fines, and
why, would generate more trust.
Q9
Provide community investment and support - Investing Airport Community and
Sponsorship Funds in our local area to support our local community.
6
Q10
Maintain community relations - Our relationship with the people who live near and around
our Airport.
6
Q11
Noise - Managing noise from aircraft and airport operations.
10
Q12
Overall, East Midlands Airport responds well to the needs of the community
Disagree
Q13
Looking ahead to the next 12 months, how can East Midlands Airport better respond to the
needs of the community? Please state what those needs may be.
Genuine action MUST be seen to take place to reduce noise, and associated carbon footprint. It does
appear that East Midlands is sadly lagging compared to other uk airports - and yet gives the impression
of being complacent about this
Page 4: Section 4 - Zero Carbon Airports
Q14
Overall, the Airport is performing as an environmentally responsible business.
Disagree
Q15
Are there any other sustainability topics that you would like to see East Midlands Airport
address over the coming 12 months?
No new topics, just better action on the existing ones
Page 5: Section 5 - Opportunity for All
Q16
Local and regional economic contribution - Our economic contribution to our local and
regional areas.
6
Q17
Transport to and from the airport - Connectivity and movement of people to the airport by
road or public transport.
10
Q18
Fair and decent work - Employment and opportunities for work and careers that are
productive, secure and deliver a fair income.
6
Q19
Provide training, apprenticeship and skills opportunities - Covering multiple kinds of pre-
employability learning, skills development, and opportunities for job seekers.
6
Q20
Supporting young people - Engagement with education and inspiring young people about
the world of aviation in order to develop skills to unlock future employment opportunities
5
Q21
Diversity and inclusion - Support a diverse and inclusive culture and improve accessibility
for our customers and across the workplace.
5
Q22
Overall, the airport is doing well as a provider of opportunities for all
Neither agree nor disagree
Q23
Are there any topics not mentioned in the list above that you would like to see East
Midlands Airport address over the coming 12 months?
Respondent skipped this question
Page 6: Section 6 - Your relationship with East Midlands Airport
Q24
Are you responding to the survey as a private individual or as part of an
organisation or group?
Private individual
Q25
If you belong to an organisation, please let us know its name
Respondent skipped this question
Q26
Geographical location - please let us know your postcode below
LE65 2TY
Q27
How long have you had involvement with East Midlands Airport or lived in the local
community?
4-10 years
Q28
If you have visited East Midlands Airport in the past two years, please state the nature of
your visit in the box below. If you have not visited East Midlands Airport, please add 'no
visit' and move to the next question.
Passenger
Q29
If you or your organisation has been directly involved with East Midlands Airport, how
would you rate your experience?
Poor
Page 7: Section 7 - About You
Q30
What is your age?
65+
Q31
To which gender do you identify?
Male
Q32
What is your ethnicity?
White
Q33
Do you consider yourself to have a disability, as defined under the Equality Act
2010? You’re disabled under the Equality Act 2010 if you have a physical or mental
impairment that has a ‘substantial’ and ‘long-term’ negative effect on your ability to
complete normal daily activities.
No
Page 8
Q34
Do you have any additional feedback?
Sorry to sound negative but it’s not an airport to be proud of. Long queues as a passenger, very out of
date facilities, really poor environmental record. We travel quite a bit and it’s shocking to see how much
better foreign airports are. Although East Midlands is our nearest airport we don’t often use it, and would
normally opt for Birmingham or Manchester for a better experience (although neither of them is
particularly nice!) The impression we have is that East Mids is having to be dragged into the present day
and is not at all proactive in any respect. Sorry to have to say this.
Aircraft Noise Nuisance sent 27th September 2024
Dear Sirs
We write to follow up the increasing volume of comments made to the Smisby Parish Council regarding aircraft noise nuisance. Smisby lies just north of Ashby and is directly under several flight path routes.
We have already made active inputs to the Noise Action Plan and the ongoing Future Airspace programme and are involved with the EMA Parish Forum, since noise nuisance is a substantial issue in our Parish.
We now wish to enquire specifically about a very noisy aircraft which generated a lot of comment on the evening of 11 September at about 2315 local time. On closer inspection this is now known to have been a Boeing 747 aircraft (of noise quota count 4) which took off at approximately 2310. Moreover it appears to have accelerated to high speed (thus delaying its climb) whilst approaching Smisby and we understand this will have required specific approval from Air Traffic Control.
Crucially however, according to the current Noise Action Plan (section 12 Night noise) such aircraft are banned altogether from operations after 11 pm. Indeed the wording on page 52 states specifically that "an operational ban means these aircraft would not be able to take off from East Midlands Airport during the night period, even if delayed."
This rule does not appear to have been followed on the night of 11 Sept. But both the aircraft operator and the airport should surely have been aware of the rule, which suggests a rather lax attitude towards noise issues by at least one of them?
May we ask you to look into the matter and offer your comments?
Additionally may we ask you to check your flight records since 1 Jan 2024 and let us know how many other occasions there have been where the Noise Action Plan rules have not been followed?
Finally, we note that a noise surcharge was levied on this aircraft simply in view of its size. What additional penalties will apply to operations such as this event, which fall completely outside the absolute noise ban?
Thank you
Smisby Parish Council