Albury Parish Council’s response to the Stansted Draft Noise Action Plan 2024 – 2028

This reponse relates to the Stansted Airport Draft Noise Action Plan 2024-2028 (click to view in new window)

Albury Parish lies within BUZAD NPR. Within the proposed Noise Action Plan (the “Plan”), we do highlight that many points of the Plan refer to the areas within noise contours of the airport ground handling with less focus on the NPR areas. We would like to request that for the Plan to be more effective in those rural residential areas in NPR’s, the following points require consideration, planning and implementation.

Chapter 8.

In regard to the question for responses to how adequate noise controls are within the Plan, we submit the following:

Incentives for airlines to provide quieter fleets should be implemented over the Plan period, with a fixed start and end number of fleet upgrades, for both passenger and cargo. A target needs to be set for a % improvement of a quieter fleet at a minimum of 25%. The airlines should set these targets and strong financial incentives put in place to encourage compliance, such as increased fines for noise infringements/use of an older aircraft fleet and regular measurement of noise on NPR routes via monitors.

Night flights should cease within the Plan period, this action would immediately act as the most impactful noise control. 

Albury Parish Council and Albury parishioners, expect the airport to demonstrate year-on-year improvements against empirical targets. 

Chapter 9.

NAP 4 -In regard to the question, are arriving aircraft noise controls adequate within the Plan, we submit the following:

Arrivals on BUZAD NPR only benefit from CDA with 65% of night flights CDA being compliant and hardly any CDA on day flights. As the CDA can be an issue due to other aircraft, we are to understand from the consultation that CDA would not be achievable during the day until the Future Airspace modernisation is complete. This is not an action point, just a statement of fact. We believe that CDA should be a focus within this Plan, irrespective of future modernisation and all endeavours are made to increase CDA on a daily basis. Therefore, this Plan lacks any credible focus for improvement in our view. For the  Plan to be of real, measurable benefit, other measures should be implemented ahead of the modernisation program. Setting targets and improving the number of CDA arrivals during the day to a minimum of 25% of flights for example and then increasing CDA at night from 65% to 90% would be a specific goal that would improve the noise issues. Within the Plan as stated, more effort should be placed in order to increase CDA on day flights. However, if this action point is challenging, then we also believe that the noise controls placed on night flights to decrease noise, such as the pilot-specific actions used within the restrictive period, should therefore be applied to the day flights as an immediate mitigation.

Chapter 11.

NAP 15 – In regards to the question of departing aircraft noise controls being adequate within the plan, we submit the following:

There is no mention within this area of the Plan to add/create respite periods for NPR areas. Respite is planned in Heathrow, Gatwick and other airport NPR areas. We believe this Plan should include an appropriate respite provision, with particular focus on the main overflown path of all NPR swathes.

The BUZAD NPR has most flights concentrated on the western flank of the centre line If respite cannot be achieved, another important action point to add to the Plan would be to review the residential areas within the swathe as indicated on an OS map. Use of PBN to create the concentration of aircraft over the agricultural not residential areas could be achieved. We believe that there are opportunities within an NPR to use PBN with particularly good effect in rural areas. This is a proven action point that Stansted itself has achieved in another location. This action we believe, would remove a significant part of the population from the biggest impact of noise. We believe that by using PBN within this Plan, a potential 6,500 population of the villages of Little Hadham, Hadham Ford, Much Hadham, Albury and Furneux Pelham could be potentially removed from the worst impacts. Albury Parish Council would be willing and give full support to trial this, including the placement of permanent noise monitors within the Parish and active participation in any trial implemented. 

The measurement needs to be relevant to the village locations (BUZAD NPR), as opposed to the airport) as this is where Albury Parish is experiencing issues/concerns and with year-on-year targets for reduction and including frequency of occurrence, loudness. 

NAP 17 – NO fly zones. We challenge the proposal to continue to have a NO fly zone over St Elizabeth’s Centre, on the basis that whilst it has been appropriate on previous plans when the centre had permanent residents, since November 2022 all residents are now removed. Removing this site from the NO fly zone would aid PBN and the improvements as previously detailed. The fact that the NO fly zones have remained unchanged over the previous two plans demonstrates that a comprehensive review of what is happening at ground level has not taken place. This is of great concern, as the SSSI within our Parish, clearly alongside other potentially new and current sensitive sites are not flagged, considered or protected. 

The airport needs to spread the burden of noise equitably across those affected. 

NAP 19 – Within the Plan, the limit of daytime noise has not been adjusted, therefore it provides no impact on noise levels. The limit should be adjusted to lessen the noise impact in line with the anticipated fleet change over to quieter aircraft. To surely have an actual positive effect, each action point must set targets to improve on the previous one. 

Chapter 12.

In regard to the question of night noise controls and are they adequate within the Plan, we submit the following:

All night flights should be phased out within the Plan. Whilst this phasing period is in operation, CDA should be in use on night flights 90% of the time as detailed in our response to NAP 14. 

Chapter 13.

In regard to the question, if mitigation controls are adequate within the Plan, we submit the following:

Mitigation controls within the Plan require more focus on real targets to improve, with real measures of improvements in percentage terms. We do not believe the current controls to be adequate. Mitigation controls require SMART KPIs governing noise in Albury Parish, i.e. an empirical data capture that measures the duration, frequency, and loudness of noise, coupled with a set of targets that demonstrate a year-on-year improvement in noise performance.  

Chapter 14.

In regards to the questions on monitoring and reporting controls being adequate within the Plan, we submit the following:

NAP 34 – The Plan to place more noise monitors is welcomed, each NPR should have a permanent noise monitor available on Webtrak and feedback periodically. The current suite of noise monitors is concentrated within the airport contour area. As Albury Parish has a SSSI, it would be appropriate that a monitor within this area is permanently installed to fully monitor the impact on this protected sensitive site. There should also be provisions to measure noise elsewhere in the Parish.

NAP 36 – All information from noise monitoring should be emailed to stakeholders as well as made available on the Website. This information should be clear and specific to each NPR and airport noise contour area.

NAP 38 – Within the Plan, the information regarding the independent auditor requires clarification. We would also remark that NPR areas should have the opportunity to converse with the independent auditor at regular intervals for a transparent and objective audit to take place.

Chapter 15.

In regards to the question on the effectiveness of communication within the Plan, we submit the following:

NPR routes, in particular those within East Herts, have not had the level of communication from Stansted that we feel is adequate. The public and/or their representatives should have a quarterly face-to-face opportunity to discuss, share and understand the current and future plans of the airport.

The complaints procedure set by the airport leans heavily on a complainant being competent to report issues via links and emails. The addition of an option to speak with a representative more easily would be more inclusive and welcomed. Whilst complaints are responded to within adequate timeframes, the information provided can be extremely technical. A more user-friendly response, with less technical language and clear maps, would be preferential. It is also noted that complainants that submit more than one complaint within certain timescales set by the airport are flagged as potentially ” NIMBY” public. It is logical that NPR areas would generate more complaints than non NPR areas, and we ask to have greater tolerance of complaint numbers in NPR areas. Complaints from NPR’s should be seen as crucial feedback from the communities who are the best placed to monitor if the Plan is working effectively. The grounds for legitimate complaints should also be re-evaluated; currently, residents are discouraged from submitting complaints where aircraft are within noise targets and guidelines, but the frequency and loudness of overflight are materially impacting the quality of life. 

There has been a significant increase in the number of complaints made to the Albury Parish Council over the last two years regarding aircraft noise, location, height and flight paths and especially frequency of overflight.