Noise Action Plan 2010 to 2015
Analysis and response to consultation
1. This report sets out a comprehensive analysis of the responses received to the
consultation on Bristol Airport’s Noise Action Plan 2010 to 2015: Draft for Consultation,
September 2009. The report also sets out Bristol Airport’s responses to the points made.
Overview of consultation responses
2. A total of 19 responses were received. This included responses from three campaign
groups, six parish councils, Bristol City Council and seven individuals. In addition a
response comprising a general review of airport noise action plans with comments was
received from the Institute of Acoustics and a response specifically considering the Bristol
Airport Action Plan was received from Environmental Protection UK, a registered charity
that brings together organisations from across the public, private and voluntary sectors to
promote understanding and solutions to environmental problems. The draft Noise Action
Plan was considered by consultants acting for North Somerset Council as part of the
process of determining the planning application for development of the airport submitted
in June 2009.
3. The draft Action Plan invited consultees to provide their views on four questions. Whilst
many consultees answered these questions, most responses were in a detailed form
covering a wide variety of issues.
Analysis and response to general points raised by theme
4. The general points raised by consultees are considered below on a point by point basis.
4.1. The relationship between the Noise Action Plan and proposals for
development of Bristol Airport
The draft Action Plan included a number of references to proposals for major
development of the Airport set out in a planning application submitted to North
Somerset Council in June 2009. This application had not been determined when the
draft Action Plan was prepared and this remains the case today. This creates some
uncertainty regarding the future operation and development of the airport and the
draft Action Plan indicated that the plan was based on the existing facilities and
operation and would be revised and reissued in the event that the planning application
was approved. Many respondents expressed the view that the Noise Action Plan
should include consideration of the increase in flights that might arise from the
proposed development and the coincidence of the planning application and noise
action plan processes was clearly a source of confusion. Specific issues raised included:
The Noise Action Plan (NAP) should include a forecast of the increase in noise that
would result from any expansion of the airport expected by 2015. The Parish
Councils Airport Association (PCAA) wanted this to include a statement that,
unless firm action was taken, noise at and throughout a large area around Bristol
Airport will get worse. Some, but not all, Parish Councils that subscribe to the
PCAA reflected the same view.
The most important problem with aircraft noise will be the increase in flight
numbers anticipated (with the proposed development).
Noise deflection panels need to be used around the car parking areas and arrival
area (these would protect properties from noise sources that do not specifically
fall under the noise action plan scope).
We are of the view that the Directive is clear that the Action Plan is to be based on the
noise mapping results. The data available to inform the Action Plan therefore does not
include information regarding future noise levels and there is therefore no basis for
generalised statements about the future noise climate. Detailed information has been
provided within the Bristol Airport planning application but in view of the confusion
that has been generated section 9 of the Action Plan will be expanded to include more
information about the future proposals and the mitigation measures that are planned,
subject to planning consent being granted. The Action Plan will be updated when a
change in the planning consent is implemented.
4.2. Night flying
Issues relating to night flying were raised by 10 respondents. Night flying was also one
of the main topics of discussion at the public sessions. The particular issues raised were
The NAP should include a commitment to work towards a total ban on night flights
by a steady reduction in the night noise quota;
‘Night’, being the period during which the night quota period applies, should be
defined as 23:00 to 07:00;
The Airport should set out a commitment to reduce noise and a reduction in the
night noise quota points would be the best way to achieve this;
The NAP should acknowledge the WHO recently published Night noise guidelines
for Europe (which were published during the consultation period) and seek to
reduce the impact of evening/night aircraft noise accordingly;
Night and early morning flights create noise problems and disturbance;
The NAP must adequately monitor, and regularly report on, evening and night
noise from aircraft, using the EU default definitions of evening as 19.00h to 23.00h
and night as 23.00h to 07.00h. There is a discrepancy between the ENDS night
period of 23:00 to 07:00 and the night quota period of 23:30 to 06:00.
The night quota system does not provide for a movements limit in terms of
numbers as is the case at the major London airports. The proposed night quota
could provide for a substantial increase in night movements.
Flights after 22:30 and before 08:00 are disruptive to sleep.
Place absolute caps on numbers of flights per night and per year.
The airport should take positive steps to ban noisier flights, especially during the
A levy should be imposed on all flights between 22:00 and 07:00 to help reduce the
financial incentive for Bristol Airport to increase flights in this period. The premium
for night flights has the effect of encouraging Bristol Airport to actively pursue
airlines which depend upon flights during the premium (charging) period. The
noise premium is a fundamental part of Bristol Airport’s business model and
therefore leads to greater noise within the night period.
Bristol Airport would respond to these points as follows.
The Guidance to airport operators stresses the need to strike a balance when managing
the environmental noise that arises from aircraft. Night flying restrictions not only
affect night time movements, they also affect daytime movements as the same aircraft
flies these sectors. Removal of the night flight puts at risk the day flight. Night flying
restrictions also affect the viability of flights that occur close to the time the restrictions
start. An airline will not operate services that risk being diverted or cancelled as a result
of operating restrictions. The night flying restrictions at Bristol are stringent by
comparison with other UK airports and the noise mapping results or complaints
statistics do not provide evidence for restricting them further. Draconian restrictions as
suggested by some consultees would act to reduce and restrict the benefits of air
transport from Bristol Airport. This is also an area that overlaps with the planning
application proposals, where Bristol Airport have undertaken to work within the existing
night flying restrictions set out in the 1995 planning consent for the Terminal Building
ensuring that the effects of night flying do not exceed past levels. In addition a limit on
the number of night movements has been proposed.
The question of the definition of night in relation to the night quota system was
considered in detail when the Government reviewed the system in operation at
Heathrow, Gatwick and Stansted Airports in 2005/2006. It was concluded that an
extension of the night quota period could result in more of the night movements
operating in the very early hours of the morning resulting in a deterioration of the noise
climate. The overall conclusion was that the existing definitions of night should be
retained. Bristol Airport proposes to follow this approach in the NAP.
The conclusions, (by one respondent), that Bristol Airport’s business model is based on
the promotion of night flying is a perverse interpretation of the night charging system.
Airlines are acutely cost conscious and the charging system is there to discourage flying
during the night period. The pattern of night flying over recent years would suggest that
this has been achieved.
The NAP will be amended to:
Acknowledge the WHO recently published Night noise guidelines for Europe;
Include an action to report movements in the evening and night periods;
Highlight the movement limits proposed through the planning application; and
Include historical information on night movements and quota point use.
4.3. Aircraft noise and annoyance
Respondents included detailed comments about limit values used in PPG24 to define
the onset of significant community annoyance. Many referred to the findings of the
ANASE report and the lack of guidance from Government arising from it. Respondents
suggested that Bristol Airport should undertake regular surveys of community
annoyance. Further research by Government would allow airport operators to better
understand their noise impact and determine what is acceptable. There was reference
to the Directive’s mention of field surveys in connection with the definition of
annoyance suggesting that this imposed a requirement on Bristol Airport to undertake
surveys. The use of the 57dBA Leq measure to determine the onset of significant
community annoyance was discussed in some detail by respondents who felt this did
not accurately reflect the community response to aircraft noise.
The discussion about limit values and 57dBA Leq appears to have been prompted by the
planning application documentation as the NAP only refers to this measure in the
context of planning policy in section 5. The NAP makes no judgement on annoyance in
the community however in view of the debate this point has generated we share the
view that more research is needed and would recommend that Government acts to
address the uncertainty that has arisen following the ANASE report. However we feel
that this is an issue that would be more appropriately left to Government research and
guidance. Community annoyance is measured through the noise complaints system but
nevertheless the NAP will be amended to include an action relating to periodic public
attitude surveys to be undertaken every two years by telephone survey.
Similarly there were comments about the use of the 69dB LAeq 16hr indicator as a
threshold for action. This indicator is referred in the defra Guidance to Airport
Operators and no properties are exposed to such noise levels at Bristol Airport.
However this factor has not constrained the scope of the NAP.
4.4. Noise measurement and monitoring
The PCAA wanted more noise measurements taken around the airport. Supplementary
noise indicators – LAmax and SEL should be measured and reported. Another respondent
wanted the range of noise measurements made and modelled to increase to cover
those recommended by the WHO, in particular LAmax, SEL and noise weightings more
closely matched to human perception. The proposed noise limit of between 85dB to
90dB was considered by the PCAA to be too high. There was much discussion in the
responses about the need to take into account of maximum sound levels as well as
equivalent continuous sound levels.
Noise from arriving and departing aircraft is monitored at each end of the runway. In
addition the track taken by aircraft is monitored by the Tracker system. This
information, taken with the results of the strategic noise mapping is considered to be
adequate to formulate appropriate actions within the Noise Action Plan. Any additional
continuous monitoring is felt to be of little or no benefit and experience has shown that
it is difficult to differentiate aircraft noise from background noise further from the
airfield. A portable monitor is available to record noise in the wider area when required.
The noise monitors record Lamax and Leq and these measures are reported to the
Airport Consultative Committee.
The purpose of the noise limits is to penalise poor performance and equipment; by so
doing they create an incentive for improvement. They are not intended to impose a
general increase in aeronautical charges. The noise limits stated in the NAP are
consistent with limit levels in place at airports in the UK at the location where noise is
The NAP will be amended to make the indicators used clearer and to include the regular
reporting of the noise monitoring results.
4.5. Noise mapping
A number of respondents commented on the noise mapping. The input data was
queried – was this based on a chosen mix of ideal aircraft types and did it include all
movements? The noise contours relate to 2006 and may not reflect the current
situation. The mapping results did not seem to correspond with the noise monitoring
figures reported by Bristol Airport which appeared to be higher. The noise mapping
process should be repeated, perhaps on a monthly basis. The NAP does not explain how
the maps were derived and further explanation was requested regarding the
comparison with the noise maps provided in the planning application.
The Institute of Acoustics (IOA) pointed out that the noise mapping and population
exposure data is of considerably greater accuracy than that used for roads and railways.
The consistency of the data provides a clear picture of the relative noise burden for each
airport. The Lden data may be difficult to interpret but it is an overall indicator of noise
disturbance, day evening and night. The IOA also welcomed the publication of full eight
hour noise contours. They identify Bristol Airport as one of ten airports to have
published Lnight 48 dB contours, but the IOA believes that Lnight contours should be
produced down to 45dB. It should be noted that the strategic maps were published by
Defra and the contours provided to Defra by Bristol Airport did in fact include 45 dB Lnight
The NAP will be amended to include further explanation of the noise mapping and to
clarify the points raised. The noise mapping has been based on 2006 as required by the
END. There are a number of reasons which might account for the difference between
the measured noise levels, recorded through the noise monitoring, and the modelled
noise levels. The correlation between the two data sets is good at the Felton monitor
but the noise contours indicate noise levels around 3dB lower than the measured results
at the Congresbury monitor. The reasons for this might include the following:
The measured noise levels consider all noise sources whereas the calculated air
noise contours only consider noise from aircraft movements. The Congresbury
monitor is quite close to the A370 so it could be recording road traffic noise.
The air noise contours are based upon standard arrival and departure procedures,
aircraft manufacturer and noise certification data. This information may not
exactly reflect actual aircraft operations in all cases.
Modelled air noise levels become progressively less accurate below 57 dB(A).
Taking into account the above factors it is felt that there is generally good agreement
between the modelled and measured results.
With regard to the frequency of preparing noise maps the END envisages this being
undertaken every five years. Bristol Airport has proposed to prepare two intermediate
sets of maps to provide a better understanding of the effects of noise and the areas
most affected. The preparation of maps on a monthly basis would be administratively
burdensome and of no further value in informing the Action Plan. In any case the noise
indicators are based on annual averages.
4.6. Bristol Airport as the competent authority
A number of respondents queried the appointment of Bristol Airport as the competent
authority to prepare the noise mapping and the Action Plan. There was a perception
that there was a commercial business conflict and a call for defra and the DfT to take a
more active role in the drafting and enforcement of NAPs and to provide meaningful
guidance on acceptable noise levels. It was suggested that defra might undertake
benchmarking exercises, prepare a code of conduct and establish a forum for the
presentation and discussion of best practice. Alternatively it was suggested that North
Somerset Council should have prepared the NAP. Allied to this respondents reflected a
concern that Bristol Airport does not take local concerns seriously and has a lack of
regard for the quality of life of the local community. The Action Plan is the result of a
statutory requirement rather than a genuine attempt to address the real issues of noise.
Commercial interests may limit the scope of the plan. It was suggested that an
independent, community based, appeal body be set up with powers to investigate and
adjudicate in any disputes that may arise should the NAP fail to achieve any of the
objectives of the END.
The draft NAP has been prepared as set out in the Regulations. On a practical level it is
difficult to see how any organisation other than the airport operator could take
responsibility and ownership for the NAP. However we would support the suggestions
regarding benchmarking, and a forum for the presentation and discussion of best
practice. The NAP will reassure stakeholders that Bristol Airport does take the concerns
of the local community seriously.
4.7. Noise insulation grants
The PCAA suggested that the question of noise insulation grants should be reopened. It
should be applied to residents over a wider area and should include the updating of
insulation for houses where insulation was installed years ago.
The criteria for noise insulation are set out in the Future of Air Transport White Paper
and all dwellings in the area concerned were eligible for a grant in the previous noise
insulation grant scheme, which operated at a condition for the A38 Diversion Project.
Maintenance of the dwellings is the responsibility of the owner and there is no question
of Bristol Airport taking on this responsibility. There is provision to review noise
insulation through the condition relating to increases in noise in the A38 Diversion
consent. The wider issue of future grants for noise insulation is also a consideration of
the planning application for development of the airport, through which all impacts of
future growth are addressed.
4.8. Road and construction traffic
A number of respondents expressed concern that the NAP did not consider the effects
of noise from road traffic or construction activities. These effects fall outside the scope
of the NAP as set down in the Regulations. However they have been considered in the
planning application for development of the airport and this includes proposals for
Construction Management Plan which will include noise protection measures. The
effects of traffic are addressed through the Airport Surface Access Strategy. A small
number of properties neighbouring the airport are affected by noise from activities in
the airport car parks.
A reference to these issues and the actions proposed will be included in the NAP. A
specific action to address car park noise will be included.
4.9. Noise complaints system
There were a number of comments expressing a lack of confidence in the noise
complaints system. Improvement of complaints management forms a specific action in
4.10.Quiet areas and Mendip Hills Area of Outstanding Natural Beauty
The draft NAP omitted to refer specifically to the need to protect Quiet Areas in
agglomerations. This will be addressed in the final NAP which will include acknowledge
the emerging work by Bristol City Council and defra and a commitment to liaise with
defra, BCC and its neighbouring authorities to protect quiet areas within the
agglomeration, as far as practicably possible, from noise from aircraft using Bristol
Similarly the draft NAP did not include any references to the need to consider and avoid,
where possible, overflying of National Parks and Areas of Outstanding Natural Beauty
(AONB). In the context of Bristol Airport this would include the Mendip Hills AONB. An
appropriate action will be added to final draft to address this point.
4.11. Operational initiatives
The draft NAP included an action to review approach and departure procedures with a
view to identifying measures to reduce noise impacts in conjunction with ATC and the
airlines. A number of suggestions were made for initiatives that should be considered as
part of this process, including:
Steeper glide paths;
Higher approaches over Bristol;
A ban on Chapter 3 High aircraft; and
Variation of runway direction.
Bristol Airport considers that there is little scope for varying the runway direction.
However the use of steeper glide paths and higher approaches is worthy of further
consideration and these will be included in the list of initiatives to be considered with
ATC and the airlines.
Environmental Protection UK were concerned that little attempt had been made to
relate the NAP process clearly to that being followed by NATS in airspace redesign for
the CAA. The only airspace redesign that Bristol Airport is aware of relates to the South
East airports and this has no impact on Bristol Airport airspace management. However
the NAP will include an action to continue to liaise with NATS on airspace management
Very few Chapter 3 High aircraft operate from Bristol Airport. There were 15 such
movements in 2008 and none in 2009. Whilst the Civil Aviation Act 2006 gives powers
for an aerodrome operator to establish a noise control scheme which may prohibit
aircraft of specific descriptions from taking off or landing at the aerodrome during
specific periods the current flying programme means that such an approach is
4.12. Miscellaneous matters
There were numerous miscellaneous detailed comments about the drafting of the NAP
Confusion about the use of the term ‘tracking’ in the context of noise and track
Comments on the time periods for restrictions on the use of APUs and engine
Suggestions to tighten up the actions;
Requests for technical terms to be explained;
Requests that quarterly reports on key KPIs should be provided to the Airport
Consultative Committee; and
Queries and suggestions regarding the scale and scope of penalty charges and
apparent low sums of money involved.
These comments have been carefully considered and the NAP has been adjusted where
Responses to consultation questions
5. Many respondents chose to provide detailed comments on issues that affected them rather
thandid responding in detail to the consultation questions. However the responses to the
questions, where answered, are summarised below:
Q1: To what extent do you think that the noise strategies outlined in the Draft Noise
Action Plan are targeting the most important problems in relation to aircraft noise at
The PCAA felt that the plan was too weak to achieve the objectives of the END. Night noise
was identified as the most important problem. There was concern about the lack of
mention of the Directive’s objective concerning the health impact of noise. Backwell Parish
Council felt that the most important problem was the proposed increase in flight numbers
associated with the planning application for development. Congresbury Parish Council felt
that the draft NAP did not address the stated proposals of the plan in relation to the people
of Congresbury. There was a concern that there was no meaningful commitment to noise
reduction. They felt that their concerns regarding noise were not taken seriously. Other
respondents reflected the concern about a commitment to noise reduction.
Individuals who responded to the consultation were divided in opinion. One individual
reflected the view of Congresbury Parish Council, whilst others appeared generally satisfied
with the Plan. Environmental Protection UK felt that the noise actions were targeting the
right areas but noted that there was no prioritisation of actions either by the most
important or in terms of protecting the most exposed areas in the surrounding
The main points raised have been addressed in section 7 above. We believe that the NAP is
consistent with the END objective of noise reduction where possible. Indeed Bristol Airport
has committed to maintain noise levels at or below the levels experienced prior to 2006
through presentations to the Parish Councils on the airport planning application. Comments
about engagement are disappointing, however we would seek to reassure the local
community that our intentions remain as set out in the draft NAP. The actions will be
prioritised as suggested in the final plan.
Q2: To what extent do you think that the Draft Noise Action Plan provides a suitable
framework to manage aircraft noise?
The PCAA felt that a wider range of measurements need to be collected and published,
referring to number of noise events and monitoring of LAmax and SEL noise levels. These are
in fact inherent in our approach. The PCAA were also concerned that there was no means
for the public to judge whether environmental noise quality is being maintained, where it is
good. The suggestion that the noise mapping would be repeated in 2012 and 2014 should
however, provide some reassurance on this. Congresbury Parish Council felt that the Plan’s
emphasis was on monitoring noise and lacked practical measures to control, limit or reduce
Environmental Protection UK agreed that the draft NAP provided a framework to Bristol
Airport to manage its noise impact but pointed to a number of measures that were missing.
These have been referred to in section 7 above. They also pointed to the lack of
Responses from individuals did not add to the above.
Q3: In order to manage our noise impacts, we have established a series of performance
indicators for our noise actions. To what extent do you think these performance
indicators are sufficient?
The PCAA felt that the indicators were too weak and narrow in scope. The main text of the
response referred to maximum sound levels and number of noise events. These measures
are reported through the noise monitoring undertaken by Bristol Airport. Proposals to
widen the noise monitoring have been considered in section 7 above. The proposals to
repeat the noise mapping appear to have been overlooked by the PCAA in responding to
The response from Congresbury Parish Council focused on the use of the 57db Leq indicator.
This is a feature of planning policy and not a primary performance indicator in the NAP.
Backwell Parish Council identified the noise from the car parks as a source of disturbance.
Although this noise falls outside the formal scope of the NAP an action related to it is now
Environmental Protection UK felt the indicators were sufficient to enable the performance
of the individual actions to be understood. However they also suggested that figures
relating to QC point usage should be provided. This requirement is reflected in the KPIs for
the actions to manage the effects of noise from airborne aircraft.
Individuals expressed a general concern about reliance on statistics.
Q4: Do you have any other comments on Bristol Airport’s Draft Noise Action Plan?
The PCAA used this question as an opportunity to query the conflict of interest of Bristol
Airport as the competent authority for the preparation of the NAP. Congresbury Parish
Council included comments about the process for preparing the NAP; the ANASE study, PPG
24 and the measurement of noise; night flying; track keeping and confidence in the noise
complaints system. These points have been addressed in 7 above.
Backwell Parish Council queried the reference to infrastructure in section 9 of the Plan with
a concern that not all infrastructure has been addressed. This assumed to be a reference to
off site transport infrastructure. The use of 69dB as a threshold noise level was queried
when there is general airport noise through the day and night. They suggested the use of
noise deflection panels in the car park (these are included in the planning application for
Comments from individuals expressed concern about the effectiveness of consultation and
whether the NAP was a genuine attempt to address issues of noise. The mapping process,
the method of calculation, night flying, the World Health Organisation guidelines and the
noise complaints system were also referred to. These comments have been addressed in 7
Environmental Protection UK referred to the detailed points in their response.
The following organisations were consulted:
North Somerset Council
Bath and North East Somerset Council
Bristol City Council
Backwell Parish Council
Brockley Parish Council
Chew Magna Parish Council
Cleeve Parish Council
Congresbury Parish Council
Winford Parish Council
Wrington Parish Council
Yatton Parish Council
Responses to the consultation were received from:
Bristol City Council
Parish Councils Airport Association (representing 24 local parish councils)
Stop Bristol Airport Expansion Limited
Campaign to Protect Rural England
Backwell Parish Council
Brockley Parish Council
Cleeve Parish Council
Congresbury Parish Council
Dundry Parish Council
Wrington Parish Council
Yatton Parish Council
Environmental Protection UK
Institute of Acoustic