KENT INTERNATIONAL AIRPORT CONSULTATIVE COMMITTEE (K.I.A.C.C.)

REPORT FOR KIACC  -  2 DECEMBER 2008

THE ENVIRONMENTAL NOISE REGULATIONS 2006

1.0          Introduction

1.1       The European Union’s Environmental Noise Directive (END) 2002/49/EC was transposed into English law by the Environmental Noise (England) Regulations 2006 (2006 No. 2238).

1.2       The intention of the legislation is to avoid, prevent or reduce, on a prioritised basis, the harmful effects of noise – including annoyance due to exposure to environmental noise.

1.3       The Act introduces the concept of Action Plans, a proactive approach to noise control involving noise mapping around major development and urban areas.  Previously, the UK approach to noise control has been focused on statutory nuisance, the principle being that those responsible for noise amounting to a statutory nuisance could be held responsible for the nuisance. The 2006 Regulations effectively shift from the resolution of noise problems after they have occurred, towards accounting for noise when major development proposals are still on the drawing board and being costed.

1.4       This September, defra (the Government Department for Environment, Food and Rural Affairs) issued a consultation document on guidance for Airport Operators to produce Action Plans under the terms of the Environmental Noise Regulations 2006.  Further guidance on other sectors in the economy, major road networks, railways, urban areas above certain populations, etc., will be consulted on by defra and introduced in due course; but the consultation guidance on Airports is the first to emerge.

1.5       Under the Regulations there is a requirement for strategic noise maps to be prepared for all the UK’s main Airports that have over 50,000 air transport movements annually.  Therefore, the duty will not apply to Kent International Airport until 2013 when the obligation is extended to all Airports (and certain other major developments).

2.0       Content of the Draft Guidance issued by defra

2.1       All Members of KIACC have seen the consultation document, and will recall that its content is set out in four sections.  In summary, they are as follows:

2.2          Guidance for Airport Operators

·                     The responsibility for generating Noise Action Plans falls to Airport Operators.

·                     First, Airport Operators must produce noise maps.  These will chart noise levels caused by Airport activity.

·                     Secondly, noise maps will form the basis of Action Plans.  Each Airport’s Action Plan will address its particular noise map and seek to ‘limit’ and, where possible, reduce’ the number of people affected by aircraft noise.

2.3       General Requirements for Action Plans

·                     Address in particular harmful effects of noise on human health.

·                      Continue to protect ‘quiet areas’ identified by noise mapping.

·                     Include any limit values already in place, through Local Agreement, Planning permission or Section 106 Agreement.

·                     Cross-reference to long-term Airport development with reference to the format set out in the 2003 Air Transport White Paper.

·                     Summarise the results of noise monitoring and mapping.  To assist public understanding of the position, and therefore public consultation/ engagement.

·                     Cost-benefit analysis of potential actions, in terms of development and noise controls.

2.4       Guidance on actions to be implemented

·                     Each Airport Operator is to assess whether or not current noise impact is acceptable  

·                     And, if not, how is the Airport Action Plan to be amended.

·                     In evaluating acceptability, Airport Owners should take into account the physiological effects of noise, including stress, but this is to be balanced against the benefits of employment and passenger air travel.

·                     There is one number in this section of the guidance – it is that included in the 2003 Air Transport White Paper of 69 DBA Leg ³³, it being the average noise level at or above which assistance with the costs of relocating is to be offered.  The guidance states this should be the top priority.

·                      Effective complaint handling.

·                     Good communication with the Airport Consultative Committee.  In the case of KIA, this is the KIACC.

 

2.5          Process of Public Consultation Adoption and Publication

·                     The stages of public consultation are set out, with 12 weeks being the period for the consultation on a draft Action Plan.

·                     Consultative Committees should be involved in the process, and the Airport Owner should explain how the final Action Plan has been able to account for public interests.

3.0       The defra Consultation Process

3.1       The guidance recently out to consultation, had a deadline for return of responses to defra by 28 November.  To help produce feedback that can be structured and used to inform the content of the final document, responses were invited to four questions:

(i)            Support for the principle of addressing priorities for noise control on the evidence of noise mapping.

(ii)           Did consultees agree with the issues Airport Operators should take into account in preparing Airport Action Plans.

(iii)          Did consultees agree with the process set out in the guidance for the development and adoption of Action Plans.

(iv)         Is there additional guidance required in the final version of the document to assist the process.

3.2       As statute law becomes more complex, it is now common for primary legislation (the Regulations) to be reliant on the content of Government Guidance (referred to as Secondary Guidance) for its effectiveness.  Without guidance, the regulations literally cannot be applied.  The advantage of Secondary Guidance is that it can be revised and updated from time to time by the Government but without the need for regulations themselves to be changed.  Changes to primary legislation require parliamentary time, and this can be a difficulty.

3.3       Neither Thanet District Council or Infratil considered it appropriate to respond to the consultation process.

3.4       When defra issues its report on and responses to consultation, a further report will be provided to the KIACC.

4.0       Discussion

4.1       The guidance is in keeping with Government thinking that Major Development proposals have strategic economic, social and environmental implications, and therefore require a separate approach to decision taking.  Critics say that this favours Airport expansion, and supporters respond by pointing out the existing legal framework is too general and slow to be helpful in dealing with aircraft noise.

 4.2       The relationship between quiet areas and protection, as opposed to those areas beneath flight paths, introduces a potential debate about containment of noise.  Again, there are two viewpoints.  Containment may help focus attention, and simplify the costs and benefit of noise control.  On the other hand, communities beneath flight paths could believe that the varying of aircraft routes at least helps share the burden of environmental impact.  Preferred aircraft routes is already a subject of public interest in Thanet.

4.3       The question of acceptability, but without a national standard with numerical values, indicates that local arrangements on a case by case basis will continue to apply.  Previously standards, on matters like night flying, at the three major London airports, have set a sort of industry standard;  but the sheer volume of air traffic at those airports scarcely makes their scenario with small regional airports.  Instead, it is possible that communities, Local Authorities and Consultative Committees, will liaise and confer, alongside Airport Operators, on how acceptability should be defined in any particular location.  An interesting point here is how, if possible, social and economic benefit might be quantified and balanced.

4.4       Public engagement, and therefore accurate and well presented airport statistics, are going to be essential to the process of noise mapping and Action Plans.  Without information the level of debate and participation envisaged in the guidance will not be possible.  In this regard KIA has a reasonable starting position.  Because of the 2000 Section 106 Agreement, it has noise (and air monitoring) of greater sophistication than many other regional airports already in place.

4.5       Some Local Authorities have been critical that there is no explicit role for Planning Authorities, and no requirement that Action Plans are a pre-requisite of any planning application.  On the other hand, the usual practice in our country is for primary legislation to be subject based rather than integrated, the presumption being that decision takers will have regard to their own responsibilities, and a developer will need to collectively meet all of its legal obligations.

5.0          Conclusion

5.1       In accordance with the minutes of the October KIACC meeting, this report has been produced for information.

5.2          The guidance does set out the role of Consultative Committees.

B J White
Thanet District Council
Telephone:      10843 57007
E-mail:             brian.white@thanet.gov.uk