Birmingham Airport anti-Noise Group
Issues: Blight
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November 2004
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Birmingham Airport anti-Noise Group |
Issues: Blight |
November 2004 |
Response by BANG to Birmingham International Airport Master Plan Review Voluntary Compensation Consultation
Summary
1. Introduction
1.01 Birmingham International Airport (BIA) is required by the 2003 White Paper 'The Future of Air Transport' to 'offer assistance with the cost of relocating for households subject to 69dBA or more and to offer acoustic insulation for noise-sensitive buildings such as schools and hospitals exposed to 63dBA',[1] 'to offer to purchase those properties suffering both noise above 69dBA and an increase of 3dBA or more' and 'to offer acoustic insulation for residential properties suffering both 63dBA and an increase of 3dBA or more.[2]
1.02 In addition, the Government acknowledges that 'the prospect of airport development will in many cases have a wider impact on property values in the period before statutory protection is available'.[3] This is often referred to as 'generalised blight'. Although there is no statutory entitlement to compensation for generalised blight, the Government 'accept[s] that people should have access to some form of redress, for example to help them relocate before the development takes place, if they need to do so.'
1.03 Therefore, to complement the noise mitigation proposals referred to in Chapter 3 of the White Paper, the Government requires local airport operators to bring forward non-statutory schemes to deal with the problem of generalised blight where runways are supported by the White Paper or where land is safeguarded for future development.[4]
1.04 Generally, a property will be treated as blighted if the landowner has tried to sell it and found that they cannot, except at a price lower than its previous market value.[5] BIA's current proposals seek to address the problem of specific exposure to intolerable noise, not generalised blight. The 615 homes [6] which BIA estimates will be eligible for compensation are most likely the worst affected in terms of property values but they are by no means the only homes affected. We consider the omission of a specific scheme to address generalised blight, [7] and the general disregard shown towards residents who are suffering the effects of blight and noise/pollution today, to constitute major flaws in BIA's proposed compensation package.
1.05 Britain's first 'noise map' found that residents under BIA's flight path already suffer noise levels in excess of World Health Organisation (WHO) recommendations.[8] The Department for Transport (DfT) estimates that 81,000 people would find themselves within the 57dBA noise contour of Birmingham's second runway by 2020.[9] Birmingham Airport's figures, which take account of 'long term expectation of noise improvement', state that 103,000 people would be affected. [10] In 2003, a Transport Research Laboratory (TRL) study based on surveys of aircraft noise commissioned by the Council for the Protection of Rural England (CPRE) reported that the number of Birmingham people affected by 'unacceptable' aircraft noise by 2030 would be 133,100 across an area of 142km2, up from 22,400 people across an area of 31km2 today. [11]
1.06 BANG's position remains
very clear; we oppose and will continue to campaign against any major expansion
of Birmingham Airport, namely the proposed second runway and the proposed extension
of the existing runway. However, we welcome the opportunity to comment on the
two non-statutory compensation schemes. [12] BIA has put forward for
consultation and hope that our input will assist the process of ensuring that
homeowners are compensated fairly and adequately, should the development go
ahead.
2. Specific comments relating to the consultative process
2.01 The original document sent to residents was somewhat opaque and certain key concepts difficult to grasp. We are concerned that residents may have replied without fully understanding the choice before them. Preliminary analysis of a proportion of the responses presented to the Compensation Working Group in November seem to bear this out. In particular, the option of choosing neither scheme should have been explicitly provided.
2.02 BIA did not consult widely or effectively enough to dispel public confusion and anger. We are particularly concerned that the Airport Consultative Committee (ACC) had not discussed the compensation options prior to its meeting of 27th October, when 50-60 residents rallied outside Diamond House. The ACC will not meet again until January.
2.03 The consultation document should have been sent to a much wider audience and public meetings, staffed exhibitions and road shows organised to fully explain these complicated proposals. This task fell largely to voluntary residents groups such as BANG, Solihull Opposing Additional Runways (SOAR) and Save Elmdon Action Group (SEAG). A public meeting at the Ivy Leaf Social Club in Sheldon on 19th October organised by BANG, SOAR and SEAG attracted up to 500 attendees, virtually all of whom expressed dissatisfaction with they consultation and confusion about the options, yet the airport declined to accept an invitation to attend and put their case.
2.04 On Friday 17 September, Solihull Metropolitan Borough Council's Regeneration and Community Overview and Scrutiny Board meeting concluded that BIA's compensation consultation plans did not meet the expectations of residents and that the airport should reconsider its proposals. Councillor Ken Hawkins, who was present, said, 'told the meeting that BIA had wasted the time of many people who were representing residents and that many residents were sick with worry about the compensation consultation process.' [13]
3. Specific comments relating to noise measurement methodology
Weighted Leq
3.01 Throughout
the consultation document noise is measured using the decibel 'A'-weighted equivalent
continuous sound level (dBALeq). Although Leq is a universally recognised metric
of noise dosage for near-continuous sound over a given time period, it is not
well-suited to measuring the effect of aircraft noise. The ANCOM 1 model used
to generate the Leq 16-hour contours attempts to reflect actual experience in
that it uses noise measurements taken from aircraft operating at the London
airports, but it cannot take into account the effect of weather conditions or
runway alternation.
3.02 The greatest single criticism of the Leq approach is that it fails to give adequate weight to the number of aircraft movements. As the DfT accepted during the Terminal 5 Inquiry, the addition of a further 400 movements by light Chapter 3 aircraft (such as those which will predominately use BIA's second runway) would increase the Leq 16-hour by only 1dB. As the DfT acknowledged, even a difference of 0.5dB could be significant and the area enclosed by a contour would increase by 15-20 per cent for each 1dBALeq increase. [14]
3.03 The way sound is perceived by people on the ground does not correspond in a linear way to sound energy level. The relationship between what is heard and the level of sound energy corresponds to a logarithmic scale (the decibel scale is logarithmic). To double the number of aircraft is to increase the Leq by approximately three, or to decrease the average sound of each aircraft by 3dB would enable a doubling of the number of air traffic movements without increasing the Leq. For example:
'[G]iven that the current number of ATMs at Heathrow (427,000) is roughly equal to the numbers at Gatwick, Stansted and Luton combined, according to the Leq model the population around Heathrow would hardly notice if all the latter flights were transferred to Heathrow. This seems so patently absurd that it calls into question the whole concept of Leq as a tool for quantifying changes in the response of the population over time.' [15]
3.04 An even more striking illustration of this point concerns the retirement of Concorde. With respect to departures, Concorde's contribution to Heathrow's Leq was equivalent to that of the rest of the entire fleet put together. Overall, Concorde produces as much sound energy as 120 Boeing 757s, so if the Leq scale alone is used as a 'noise cap', as both BAA plc and British Airways are calling for, Concorde's retirement would allow for a further 120 Boeing 757s or 35 Boeing 747-400s (assuming the capacity existed at Heathrow for such an increase) without changing the Leq-based noise contour. Yet for most people, four hours of non-stop noise from Boeing 757s at a rate of one every two minutes would be very much harder to endure than two minutes of one extremely loud Concorde followed by 3hrs 58min of relief.[16]
3.05 Leq values fail to reflect how aircraft noise is experienced by people on the ground. Human reactions to aircraft noise are generally governed more by the short term events and their consequences (such as speech interference or annoyance) rather than the average levels. Leq does not indicate the maximum noise of individual events so it cannot indicate how many times, say, conversation is interrupted or sleep disturbed (by definition Leq 16hour excludes the night period) in a particular location. Since these are the very factors that cause annoyance, Leq fails to reflect the concerns felt by local residents. Put bluntly: 'If I hit you over the head with a hammer, but only every 30 minutes or so, would your response be to say - "Well, on average, over the day, it's not too bad"?' [17]
3.06 The limitations of Leq when applied to aircraft noise are internationally recognised, for instance by the World Health Organisation:
'Where there are no clear reasons for using other measures, it is recommended that Laeq, T be used to evaluate more-or-less continuous environmental noises. However, when there are distinct events to the noise, as with aircraft or railway noise, measures of individual events such as the maximum noise level (LA Max) or the weighted sound exposure level (SEL) should be obtained in addition to Laeq, T.' [18]
3.07 Continuing to use Leq as the sole determinant for assessing the impact of aircraft noise is clearly unacceptable. Therefore, we recommend that BIA when assessing noise impacts:
'A' weighting
3.08
The choice of the 'A' weighting to measure aircraft noise has been heavily criticised
by Heathrow campaigners HACAN Clearskies for not taking account of the low-frequency
(between 200Hz and 20Hz, the lower limit of human hearing) noise characteristic
of aircraft in flight.[21] Low-frequency sound travels further and is more penetrating
than medium or high-frequency sound but when the noise is at a low volume, generally
speaking, the low-frequency component is not distressing and an 'A' weighting
is appropriate. But when measuring high-volume noise, particularly when there
is a large low-frequency component, the 'C' weighting should be used. Measurements
carried out by HACAN Clearskies show that when low frequency noise is included
a plane passing overhead can be 8 decibels louder.
[22]
3.09 The WHO acknowledges the significance of low-frequency sound: 'Special attention should also be given to: noise sources in an environment with low background sound levels; combinations of noise and vibration; and to noise with low-frequency components.'[23] European Directive 2002/49/EC on assessment and management of environmental noise also refers to the low-frequency component: 'In some cases . . . it may be advantageous to use special noise indicators and related limit values [for example, when] the low-frequency content of the noise is strong'. [24]
3.10 It is true that aircraft have become quieter, but a lot of the improvements have been in the mid to higher frequencies. A large aircraft needs to generate a lot of power to remain airborne, even in the landing phase, giving rise to the characteristic highly penetrating roar. Even the most 'quietest' modern large aircraft, the Boeing 777, generates a great deal of low-frequency sound. [25]
4. Recommendations towards a future voluntary compensation scheme
Noise contours
4.01
In its deliberations with the industry, the Department for Transport decided
that airport operators should start compensating at 66dBALeq, rather than at
57dBALeq, the daytime noise level acknowledged by the Government as representing
the 'approximate onset of significant community annoyance'. [26]
4.02 There is clear evidence of welfare loss for residents within the 57dBA noise contour. [27] However, the World Health Organisation acknowledges that serious annoyance commences at 55dBALeq. WHO also state that, 'to protect the majority of people from being moderately annoyed during the daytime, the outdoor sound pressure level should not exceed 50dBALeq'. [28]
4.03 The Government argues that, as most aircraft noise originates from above, 'for the same amount of noise energy, contour values can be up to 2dBA higher than those of other sources' because of the effect of ground reflection. [29] But there is no scientific justification for this; what needs to be measured is what actually affects people, including any inevitable ground reflection. A person comparing traffic noise at 57dBA with aircraft noise at 57dBA is not going to conclude that the aircraft are in fact 2dB quieter because the noise comes from above and is therefore subject to ground reflection. It has been claimed that the onset of annoyance is statistically correlated with the 57dBALeq contour, but the scientist called on behalf of the Government at the Heathrow Terminal 5 Inquiry was forced to admit that the Government's own press release on the subject was misleading, and that this correlation is in fact statistically weak.[30]
4.04 Both BAA Stansted [31] and BIA [32] have cited the Channel Tunnel Rail Link compensation scheme as justification for using the 66dBALeq noise contour. However, it is inappropriate to equate rail noise with aircraft noise for two principle reasons. First, the direction of incoming and departing aircraft movements is dependent on the prevailing wind direction. As discussed in Section 3 above, a single noise contour that combines Leq figures for both north-westerly and south-easterly operations will fail to reflect the actual disturbance suffered by a particular area on the days when that area is being over-flown. No such modal split operates in the case of the rail operations and hence the level of noise experienced in a particular area is constant from day to day (see Modes of Operation below).
4.05 Secondly, for any given noise level, a higher proportion of people are annoyed by aircraft noise than by rail noise and therefore, a lower threshold should be set for aircraft noise. The research backing this conclusion is well documented and is proposed for adoption by the EU as a basis for assessing noise nuisance levels.[33] In summarising the findings of multiple research projects the EC (2002) finds that the percentage of people who report being annoyed and the percentage who report being highly annoyed at 65dBALden [34] are greater for aircraft noise than for both road and rail traffic noise: 48 per cent of people were annoyed and 26 per cent highly annoyed by aircraft noise compared to 23 per cent annoyed and 9 per cent highly annoyed at the same level of rail noise. [35]
4.06 The consultation documents only published the 66dBA and 69dBA noise contours for the second runway up to 2017. Our view is that the 2030 noise contours should guide the compensation process as the Government's policy recommendations in the White Paper use projections of growth in air transport up to 2030. The White Paper is clear that it expects airport operators to 'address the impacts of future airport growth' [36, emphasis in original] but does not specify 2017 as the date up to which this impact should be addressed. Presumably, BIA expects air traffic movements at the airport to increase between 2017 and 2030 and aims to increase the number of off-peak movements to peak-time levels, so there can be little reason not to include provision for properties who will be affected in 2030 and beyond.
4.07 BIA could use the case of the Highways Agency's Birmingham Northern Relief Road (BNRR) scheme as a precedent in this case. The BNRR scheme two dates were used: the Relevant Date (when the scheme opened to traffic and in the case of the BNRR Spring 2004) and the First Claim Day (one year after the Relevant Date; the beginning of the six year claim period during which claims can be made). Thus 'Compensation is concerned with depreciation in value as at the First Claim Day, caused by physical factors coming from use of the BNRR then and the extent to which that use might reasonably be expected to intensify' [37. emphasis added].
4.08 We therefore contend that 54dBCLden noise contours for 2002, 2017 and 2030 and for both proposed and existing runways (see below) are required to accurately determine the extent of aircraft noise disturbance and generalised blight. However, an approach based solely on discrete noise contours is undesirable. Noise contours exclude potentially eligible properties in a largely arbitrary way. That some homeowners have found themselves on the 'right' side of the line while their near-neighbours, sometimes in the same road, are not in line to receive anything amounts to major flaw in BIA's proposals. Considerable uncertainty exists in several areas outside the noise contour boundaries e.g. part of Catherine-de-Barnes and all of Hampton in Arden and Bickenhill together with parts of Elmdon, Sheldon, Marston Green, Barston and Eastcote.
4.09 It is not sufficient for BIA simply to shrug off the fact that 'there will always be some properties that fall outside the [noise contour] boundary when near neighbours are within it'. [38] Even BAA Stansted admits that a boundary based on noise contours 'can be no more than a proxy for where generalised blight might exist'.[39] It would be reasonable for BIA to insist on professional valuation advice to demonstrate that a property outside the contour had been devalued as a consequence of the development proposals but to arbitrarily exclude properties by drawing lines on a map is unjust. Noise contours can only serve as a general guide to eligibility and there must be the flexibility within the scheme to accommodate natural community boundaries and individuals' circumstances.
Modes of operation
4.10
Detailed information concerning modes of operation is required to produce accurate
noise contours but BIA states that it 'will not be in a position to determine
the preferred method of operation for several months [after the publication
of the consultation document] but the preferred operation will be included in
the draft Master Plan document'. [40]
4.11 Will the airport operate a mixed mode of operation where both runways used for takeoffs and landings or a segregated mode of operation where one runway is used for landings and the other for takeoffs? If the latter which way round and for what periods of time? Will the new mode of operation be different to those outlined in the 'Birmingham Alternative' and assumed by the White Paper? If the second runway is used, say, only for landings will it have to accept incoming flights between 11pm and 6am? This would be contrary to the promise in the 'Birmingham Alternative' that the runway would not operate at night.[41] If it is to be used only for departures will it have to be extended in future to cope with the predicted growth in air travel? If it is used for either take-off or landings will it have to take the older, noisier planes contrary to the promise in the 'Birmingham Alternative' [42] and the current consultation document [43] that this will not happen?
4.12 The effects of any runway alternation regime must be considered. Since the published noise contours are based on average conditions, those affected by runway alternation experience noise levels some 3dB higher while the flight path they live under is in use and 3dB lower when it is not. Including the periods of relief from noise an area experiences owing to a segregated mode of operation or runway alternation artificially shrinks the noise contour and gives a false picture of aircraft noise.[44] Separate sets of contours are needed for both operations together with an indication of the ratio between the two (55 per cent to 45 per cent at BIA).
4.13 Additional information is required concerning the positions of the second runway's noise preferential routes, the location and number of any new stacks, and arrivals routing. Noise contours assume a straight approach by all aircraft, but this is not what happens in practice. For example, Heathrow Airport is fed with approaching aircraft from four separate stacks.[45] Arrivals routing in particular has a significant bearing at the lower noise levels BANG is arguing should be used as the basis for determining eligibility for compensation.
Exclusion of existing runway
4.14
The map on pp14-15 of the consultation document only shows the noise contour
for the existing runway in 2002. How many properties will be affected by the
first runway's operation in 2017 and 2030? How will they be compensated, if
at all? BIA clearly expects to have completed an extension to the existing runway
prior to commencing work on the second runway.[46] Consequently, to not include
a noise contour projection for the first runway in 2017, let alone 2030, is
exceedingly remiss.
4.15 Although we acknowledge that the obligation placed upon BIA in the White Paper refers to the second runway only, we believe it is unreasonable that BIA should intend to limit eligibility for compensation to those properties affected by the second runway. The runway extension is designed to enable BIA to operate long haul services to such destinations as the western United States. Flying larger, more fully laden aircraft flying longer distances will almost certainly make a dramatic difference to the noise climate, especially given that the use of 'A' weighted Leq excludes the low-frequency noise component characteristic of large aircraft (e.g. Boeing 777).
4.16 It will clearly be very difficult, if not impossible, to separate the noise and generalised blight implications of developing and operating a second runway from those of developing and operating an extended existing runway. The impacts of expansion are best approximated by noise contours for the airport as a single entity rather than by assessing each runway as if the other did not exist.
Assumptions relating to the local housing
market
4.17
BIA proposes using two different Land Registry Indices to calculate the rise
in property prices since June 2002. Properties 'to the North of the proposed
new runway' [47] would be valued using the Birmingham Land Registry Index. This
would give a reduced rate of growth to the value of properties to the North
compared to those to the South. This is inconsistent and potentially divisive;
a single index, the one that gives the largest number of residents the best
deal, should be used.
4.18 Pearce and Pearce (2000) [48] show that house price differentials suggest residents value the aircraft noise nuisance around Heathrow airport at a minimum of £19 million a year, which translates to a cost of 36-40p per passenger. But clearly house price differentials do not capture the welfare loss of those who do not own their homes nor the detrimental impact on community activities. A study around Schipol airport [49] estimated that the monetary valuation of aircraft noise nuisance was considerably higher at 75p to £3 per passenger.[50]
4.19 The properties surrounding Birmingham Airport's northern perimeter are assumed to be mostly owner-occupied but a proportion may be owned by investors. The combination of owner-occupants and investors is a major factor in keeping any market buoyant and thus property values competitive. To maintain such a buoyant and stable property market all property owners must be treated equally and fairly.
4.20 Rented homes should be included in any new scheme. The landlord will have suffered a loss in the value of the property (which would reduce the amount of rent he/she could obtain in the market if he/she continued to rent) and the tenant may be in a situation where, faced with unacceptable noise levels, he/she is forced to relocate. Unless this anomaly is dealt with it could lead to a reduction in the number of properties being made available for rent in the local market. The landlord is entitled to protection in respect of the value of the property and the tenant is entitled to reasonable relocation expenses if he/she chooses to move.
Base date for qualification and trigger dates
4.21 Trigger dates
should be specified to operate at the earliest possible time as delaying them
prolongs uncertainty. The publication of BIA's Adopted Master Plan (Spring 2006)
would seem a reasonable trigger date (assuming, of course, that the second runway
forms part of the Master Plan's 'vision' for future development of BIA). This
would allow for residents to view and comment on the revised compensation scheme
as part of the Master Plan consultation process.
4.22 BIA should also reconsider the base date for qualification for the scheme: this should be the date of the granting of planning permission for the new runway. It should not be June 2002, immediately prior to the publication of the 'Consultation on the Future of Air Transport', nor December 2003, when the White Paper was published Neither of these documents is legally binding and there is a risk that estate agents' area searches might not pick up major airport expansion. For this reason, residents who moved to their present abodes after June 2002 should not be excluded. However, the value of the property should still be agreed at the outset by an independent valuation, based on the open market value of the property as if no runway had been proposed i.e. June 2002.
4.23 The scheme should not
be limited to 15 years, nor should it terminate when the new runway is operational.
Ideally, there should be no maximum term to any proposed compensation scheme
but, in practice, 2030 may represent the most reasonable limit.
Qualifying conditions
4.24
We can see no justification for the requirement that the homeowner demonstrate
the 'pressing reason[s] to move' [51] that BIA has included in the Home Value
Guarantee Scheme. Why should BIA turn down an application from a homeowner whose
pressing need to move is stress and anxiety caused by aircraft noise?
4.25 Nor can we see any justification for demanding that the homeowner must 'not have declined offers within 15%' of the 'realistic asking price'.[52] It is far from clear from the wording used in the consultation document whether this is intended to mean a 15% absolute reduction in value since July 2002 or a 15% reduction in the value after it has been index-linked upwards to arrive at an current (pre-blight) value.[53] Even if the latter were to apply, a 15% reduction in value would be an onerous and unreasonable pre-condition for eligibility. In the current market place, in many areas, vendors would expect offers to be close to the asking price, or even above it. It would be reasonable to expect BIA to include in any revised scheme an option equivalent to BAA Stansted's 'Early Moving Contribution' to help those homeowners who are able to sell their properties within 15% of the index-linked option price.[54]
4.26 BIA should instead provide a simple, straightforward guarantee to make good any losses incurred by any homeowner who wishes to sell his/her property where the value and habitability of the property has been adversely affected by the airport expansion proposals. In addition, here would be greater public confidence if an open and transparent independent body was given responsibility for administering whatever scheme is finally adopted, or if there was at least scope for appeal to an independent body.
Expenses
4.27 BIA does not appear
to have been as flexible or as generous as the Central Railways' Channel Tunnel
Rail Link scheme upon which it based its proposals. For the Property Protection
scheme BIA states that, 'No cost associated with removal, including legal fees,
stamp duty, estate agents fees or any other costs would be paid'.[55]
In contrast, the Channel Tunnel Rail Link scheme included an offer
to purchase any severely affected property and to pay Stamp Duty and reasonable
moving costs. Furthermore, Central Railways offered to increase the price stated
in the agreement in the event that the homeowner made improvements to the property
after the option price had been agreed. Both of these points are fair and reasonable
and should be included in any future scheme proposed by BIA.
4.28 If families
are being forced to move home as a consequence of airport expansion (if, for
example, they consider the prospect of a much noisier local environment too
much to bear) then surely BIA should accept responsibility for reasonable relocation
costs, in line with the list of qualifying payments defined in the 1973 Land
Compensation Act. Furthermore, BIA should follow BAA Stansted and offer to pay
owner-occupiers reasonable disturbance costs associated with their home move,
reasonable legal costs associated with the sale of their existing home and the
purchase of a new home, and an amount equivalent to the Stamp Duty payable on
their existing home.
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Risk
4.29
Even with a transferable guarantee of the agreed (pre-blight) market value,
there is a risk that the Property Protection scheme may not, in practice, achieve
its objective of protecting property values and ensuring market liquidity. If
the owner had marketed the property for at least three months on the open market,
but failed to find a buyer at the agreed (pre-blight) market value, the homeowner
should have the right to require BIA to purchase the property at the agreed
(pre-blight) market value and reimburse the owner's reasonable relocation costs,
including Stamp Duty, on an equivalent property. An additional clause to this
effect should be included in any future scheme.
'Stayers'
4.30
Some residents may decide to stay in their properties for personal reasons.
BIA is well aware of the shortcomings of the 1973 Land Compensation Act in respect
to those homeowners who may wish to stay put. The Act means that Part 1 Compensation
claims can only be made twelve months after the runway has opened and only for
the noise from aircraft on the runway not the noise of aircraft in flight. Therefore,
BIA needs to consider additional provision within any revised scheme to address
the problems uniquely faced by those residents who may wish to remain in their
present abodes. Equally, to avoid confusion, any reference by BIA to 'statutory
compensation' must make clear that the statutory scheme covers only noise disturbance
from ground-running aircraft. This distinction between statutory and non-statutory
compensation must be made explicit.
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5. Conclusion
5.01 As stated above, BANG's position remains very clear; we oppose the proposed second runway and the proposed extension of the existing runway. However, we hope that BIA will accept our comments as fair and reasonable. The creation by BIA of the Compensation Working Group was an important step forward in this process. We would welcome the opportunity to continue working with BIA as part of this group, or one similar, during the Master Plan consultation.
5.02 At present, we are unable to recommend Option 1 or Option 2 as neither option meets the reasonable expectations of local residents. Judging by a preliminary breakdown of responses presented to the Working Group on 22nd November, it appears that this view is shared by a majority of those residents BIA has consulted: 78 out 119 replies rejected both options.[56] Indeed, this figure may be artificially low, as the consultation document's response form did not allow for the explicit rejection of both options by respondents.
5.03 The view of BANG is that BIA should reconsider its proposals in the light of the comments detailed above and issue a revised consultative document for agreement with the Working Group before publishing its Master Plan. Needless to say, those residents who stand to benefit under the existing proposals should be no worse off under the revised proposals.
James Botham
Secretary,
Birmingham Airport anti-Noise Group (BANG), November 2004
Notes & References
[1] HM Department for Transport,
'The Future of Air Transport', December 2003, para 3.21.
[2] Ibid. para 3.24.
[3] Ibid. para 12.16.
[4] Ibid. para 11.41.
[5] Winkworth & Sherwood Solicitors and Parliamentary Agents, 'Briefing:
compulsory purchase and compensation', October 2003, p5.
[6] Birmingham International Airport Ltd., 'Master Plan Review: Voluntary
Compensation Schemes', August 2004, p10.
[7] Such as Stansted's Home Owner Support scheme: BAA Stansted, Home
Owner Support Scheme', September 2004.
[8] The Independent, 18th February, 2000.
[9] HM Department for Transport, 'The Future of Air Transport', December
2003, para 9.16.
[10] Birmingham International Airport Ltd., 'The Birmingham Alternative',
October 2002, p11.
[11] These figures relate to those people who are 'very much bothered'
or who experience 'unacceptable' levels of noise according to the most recent
UK survey of aircraft noise disturbance ('Flying to Distraction: Future growth
in air travel threatens to shatter the tranquillity of the countryside', Council
for the Protection of Rural England, June 2003).
[12] Namely, the Home Value Guarantee Scheme and the Property Protection
Scheme. We do not propose in this document to comment on the Assistance with
Relocation Scheme.
[13] See www.cllrkenhawkins.com
At a meeting of Solihull MBC Cabinet, 7 October 2004, cabinet endorsed the views
of the Regeneration and Community Safety Board. At Full Council, held on Tuesday
19 October, 2004 the recommendations from the (17th September) Regeneration
Overview and Scrutiny Board meeting and the (7th October) Cabinet meeting were
agreed.
[14] Roy Vandemeer QC, 'Heathrow Terminal 5 Inquiry Report', para 21.3.32,
quoted in Richard Hendin, 'The Quiet Con: 'A' weighted Leqs as the index of
aircraft noise annoyance', HACAN Clearskies, Oct 2003, p16.
[15] Dr Hugh Jones, Imperial College, 'Validity of Leq', Proof of Evidence
presented to the Heathrow Terminal 5 Inquiry, quoted in Richard Hendin, 'The
Quiet Con: 'A' weighted Leqs as the index of aircraft noise annoyance', HACAN
Clearskies, Oct 2003, p8.
[16] Richard Hendin, 'The Quiet Con: 'A' weighted Leqs as the index of aircraft
noise annoyance', HACAN Clearskies, Oct 2003, p8.
[17] Dick Wood, principal consultant with Acoustic Technology Limited, 'Aircraft
Noise and Annoyance', in 'Environmental Policies at Europe's Airports', Friends
of the Earth Netherlands, 2000, p19. See www.milieudefensie.nl/campagnes/mobicamp/publicaties/download/airportstudy.pdf
[18] World Health Organisation, 'Guidelines for Community Noise, Executive
Summary', Geneva, 1999, p2.
[19] HM Department for Transport, 'The Future of Air Transport', December
2003, p35.
[20] Richard Hendin, 'The Quiet Con: 'A' weighted Leqs as the index of
aircraft noise annoyance', HACAN Clearskies, October 2003, p18.
[21] Ibid. pp11-14.
[22] HACAN Clearskies, 'Take Off: The Journal of HACAN Clearskies', Winter
2004, p6.
[23] World Health Organisation, 'Guidelines for Community Noise, Executive
Summary', Geneva, 1999, para 3.10.
[24] EC Directive 2002/49/EC Annex 1.3, 3.Supplementary noise indicators.
[25] Richard Hendin, 'The Quiet Con: 'A' weighted Leqs as the index of
aircraft noise annoyance', HACAN Clearskies, October 2003, p13.
[26] HM Department for Transport, 'The Future of Air Transport', December
2003, p34.
[27] Sustainable Development Commission, 'Aviation and the Environment,
using economic instruments', July 2003, p16.
[28] World Health Organisation, 'Guidelines for Community Noise', Geneva,
1999.
[29] Planning Policy Guidance Note (PPG) 24: Planning and Noise, June
1997, Note 2.
[30] Roy Vandemeer QC, 'Heathrow Terminal 5 Inquiry Report', para 21.3.32,
quoted in Richard Hendin, 'The Quiet Con: 'A' weighted Leqs as the index of
aircraft noise annoyance', HACAN Clearskies, October 2003, p9.
[31] BAA Stansted, 'Homeowner Support Scheme, September 2004, p9.
[32] The Channel Tunnel Rail Link scheme is not cited in BIA's consultation
document but it was clear from the discussion in the Working Group meetings
that BIA had followed BAA Stansted in this respect.
[33] European Communities, 'Position Paper on Dose Response Relationships
Between Transportation Noise and Annoyance', February 2002. See europa.eu.int/comm/environment/noise/noise_expert_network.pdf
[34] Lden is sufficiently equivalent to Leq for the purposes of this
comparison.
[35] European Communities, 'Position Paper on Dose Response Relationships
between Transportation Noise and Annoyance' February 2002, Table 1, p4.
[36] HM Department for Transport, 'The Future of Air Transport', December
2003, para 3.24.
[37] Steve Hinton and John Ferguson, 'Compensation and the BNRR', Alliance
Against the BNRR an Associated Greenbelt Developments, March 2003. See www.birminghamfoe.org.uk/bnrr/BNRRComptalk.htm
[38] Birmingham International Airport Ltd., 'Master Plan Review: Voluntary
Compensation Schemes', August 2004, p4.
[39] BAA Stansted, 'Home Owner Support Scheme', September 2004, p10.
[40] Birmingham International Airport Ltd., 'Master Plan Review: Voluntary
Compensation Schemes', August 2004, p4.
[41] Birmingham International Airport Ltd., 'The Birmingham Alternative',
October 2002, p9.
[42] Ibid. pp9,12.
[43] Birmingham International Airport Ltd., 'Master Plan Review: Voluntary
Compensation Schemes', August 2004, p3.
[44] Richard Hendin, 'The Quiet Con: 'A' weighted Leqs as the index of
aircraft noise annoyance', HACAN Clearskies, October 2003, p5.
[45] Ibid. p6.
[46] Birmingham International Airport Ltd., 'Master Plan and Development
Strategy to 2005', July 1995, para12.8-12.13.
[47] Birmingham International Airport Ltd., 'Master Plan Review: Voluntary
Compensation Schemes', August 2004, p5
[48] D Pearce and B Pearce, 'Setting Environmental Taxes for Aircraft: A
Case Study of the UK', CSERGE Working Paper GEC 2000, p26.
[49] CE Delft, 'External costs of aviation', 2002.
[50] Sustainable Development Commission, 'Aviation and the Environment,
using economic instruments', July 2003, p16.
[51] Birmingham International Airport Ltd., 'Master Plan Review: Voluntary
Compensation Schemes', August 2004, pp7-8.
[52] Ibid.
[53]
BIA's Finance Director Joe Kelly confirmed the latter interpretation at the
Working Group meeting of 8th November.
[54] BAA Stansted, 'Home Owner Support Scheme', September 2004, p21.
[55] Birmingham International Airport Ltd., 'Master Plan Review: Voluntary
Compensation Schemes', August 2004, p10.
[56] Birmingham International Airport Ltd., 'Summary of responses at 18
November 2004'.