Thank you for the opportunity to respond to the BAA consultation on Noise insulation and mitigation.

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1 Deputy Leader s Office Councillor Ruth Cadbury Freepost RSLU-TKHH-BGTH Heathrow Community Relations The Compass Centre Nelson Road London Heathrow Airport Hounslow TW76 2GW Democratic Services The Civic Centre Lampton Road Hounslow TW3 4DN Your contact: Ruth Cadbury Direct Line: PA: Fax: ruth.cadbury@hounslow.gov.uk Our ref: Date: 1 st August 2011 Dear Sir or Madam Review of Heathrow s Noise Mitigation Schemes A Heathrow Airport Consultation Thank you for the opportunity to respond to the BAA consultation on Noise insulation and mitigation. Please find attached the response of Hounslow Council to the above consultation. Should you have any queries regarding this matter please contact Rob Gibson, Head of Environmental Strategy the first instance, rob.gibson@hounslow.gov.uk, telephone Yours faithfully, Cllr Ruth Cadbury Deputy Leader London Borough of Hounslow

2 Introduction We welcome the publication of the Noise Action Plan for Heathrow and the steps that it takes to avoid the adverse impacts of noise. We recognise that noise insulation / ventilation is only part of the overall noise mitigation package and we encourage BAA to continue to attempt to reduce noise at source. With this in mind would like BAA to legally rule out the possibility of introducing mixed mode operations at Heathrow. This would be seen in the Borough as an offer of peace in our lifetime. We also are in agreement with the Aviation Minister who stated in relation to the revocation of the Cranford Agreement that:- I will look to BAA to ensure that proper consideration is given to appropriate mitigation and compensation measures for those likely to be affected by the proposals. 7th September 2010 Our concerns about the revised scheme The community have had to live with a scheme that is much less generous than other comparable airports; this consultation is an opportunity to redress this. The Council recognises that the proposed scheme is more generous than the current one but believes the boundary is not wide enough to redress, mitigate and compensate the effects of aircraft noise upon the local community. Our stance on this is based on the fact that noise directly affects our residents health including the often overlooked areas of mental health. Noise is therefore a well-being issue. We take this opportunity to draw your attention to the report published by the European Environment Agency (November 2010) Good practice guide on noise exposure and potential health effects. This work is designed to to assist policymakers, competent authorities and any other interested parties with practical and validated tools to calculate health impacts of noise in all kinds of strategic noise studies such as the action plans required by the Environmental Noise Directive (2002/49/EC) or any environmental impact statements. It links action planning to recent evidence relating to the health impacts of environmental noise and, among others, the Night Noise Guidelines for Europe as recently presented by the World Health Organisation. This guidance states that 27% of the population within a 55 Lden aircraft noise contour are highly annoyed (Table 6.1 page24). Based on this guidance it is our view that the 55 Lden noise contour should be the principal trigger for noise insulation / compensation for aircraft noise.

3 Given the BAA noise action plan is based on the Lden contour. It is out view that the noise insulation scheme should be based on this contour with the noise problems of the worst affected communities addressed first. We feel BAA s relationship with the local community would be enhanced if the revised noise insulation schemes were administered independently in a similar way to those related to American airports such as Chicago O Hare. Revocation of the Cranford Agreement The fact that BAA are consulting on aspects of this operational change leading up to a planning application to the London Borough of Hillingdon Is noted. We currently are evaluating the practical aspects of this change. In the case of residential properties, the proposals, as stated, do not provide sufficient mitigation or compensation for the revocation of the Cranford Agreement. As a result 15,000 plus households will suffer a 1dB or greater increase in noise disturbance. Residents have bought their homes on the basis that the Cranford agreement was operating. The revocation of the agreement means that their noise environment has unexpectedly deteriorated, thus the need for appropriate mitigation / compensation (at lower trigger levels than BAA suggest). We are also concerned about increases in ground noise at levels resulting from aircraft taxiing off the eastern end of the southern runway as this is a new operating practice. We believe that a 1dB increase is significant and mitigation / compensation should be available. This would be comparable to mitigation measures available by statute when roads are constructed. The loss of the Cranford Agreement needs to carry with it some form of compensation for the loss of amenity. However if BAA were minded to accept the Council s suggestion that the 55 Lden contour should be the trigger for mitigation / compensation, this point would have been resolved (for air-noise). We believe that it is in the interests of the community of Cranford for BAA to make their best efforts to provide mitigation / compensation before the Cranford Agreement is revoked.

4 Answers to your questions Q2: Are you in favour of our proposal to set the scheme outer boundary at the 63Lden noise contour? No. The Council is not aware that the 63 Lden noise contour represents any particular criteria for annoyance or health. As stated above 27% of the population within a 55 Lden aircraft noise contour are highly annoyed and on this basis. Based on this it is our view that the 55 Lden noise contour (2006) should be the principal trigger for noise insulation / compensation for aircraft noise. We also note that the precedent has been set for more generous schemes for example, the residential noise scheme for London City Airport. Q3: Are you in favour of our proposal to introduce a zoning structure, where households experiencing the highest aircraft noise impacts are eligible for the full noise mitigation offer? We are not in favour of the zoning principle and belie that all residents within the 55 Lden contour should be offered a full suite of noise insulation and ventilation measures. This is a precautionary approach so that the 27% of the highly annoyed people within this contour are protected from aircraft noise. Without prejudice to this position if BAA is not minded to reconsider providing 100% cost of the insulation we believe that a 25% band is not adequate and should be subsumed into the 50% band. Q4: Do you think that residents in Zone 1 should be the first to receive noise mitigation under the Residential Noise Insulation Scheme? Without prejudice to our answer in Q3 we would like to see those who suffer from the worst noise disturbance to receive noise mitigation / compensation more quickly, particularly those people living directly under a flight path and people living in Cranford. Q5: Do you think that for our existing noise mitigation schemes the range of products offered, quality and workmanship of the products, and follow up service has been of an acceptable standard? We are not in a position to directly pass comment on the range of products and quality of the service provided under the existing mitigation scheme. However, anecdotally, we have been told about concerns that people in the borough have with the lack of choice of supplier. We would like to see the compensation scheme made more accessible to the population affected.

5 We would like to see greater flexibility built into the scheme, especially in terms of choice of product. This would allow areas of the borough that are subject to specific architectural, planning and design criteria to be able to take advantage of the insulation offer within existing and future schemes. We would like to see post installation sound insulation testing to be undertaken on a 5% random sample of both residential and community buildings. The results of this to be reported to the Noise and Track Keeping working group and or / the HACC. Q6: Are you in favour of our proposal to continue with the existing Night Noise Insulation Scheme until the end of the current night noise control regime in 2012/13? There is an increasing body of evidence that night noise has direct consequences for public health. New research from Warwick Medical School published 8 February 2011 in the European Heart Journal shows that prolonged sleep deprivation and disrupted sleep patterns can have long-term, serious health implications which are: increasing risk of heart disease/ stroke; high blood pressure and cholesterol; diabetes and obesity. Night noise from aircraft is the biggest cause of community disturbance and annoyance from the airport. As such it is the Councils position that a night curfew should be instigated between the hours of 11pm to 7 am, emergencies excepted. The Council believes that there could also be operational, financial and carbon emission savings that could be made at the airport if such a ban were to be implemented. For the reasons above we ask BAA to consider their own position on allowing night flights at Heathrow The value of doing this for the sake of the community would be immeasurable. On the premise that the scheme is amended so that the trigger level for the new scheme is the 55 Lden contour we believe the existing night noise scheme should continue until 2012 / 13. If BAA is not minded to extend the noise insulation trigger point to 55 Lden the Council expects that a further night noise insulation scheme will be introduced. This should be based on the most up to date health related research and give due consideration to the precautionary principle. Q7: Are you in favour of our proposal to extend both the geographical area in which the Community Buildings Noise Insulation Scheme will operate, and also what is offered under this scheme? It is recognised that schools exposed to high levels of aircraft noise are not healthy educational environments. Aircraft noise also impairs cognitive development in children, specifically reading comprehension. We believe that no child in Hounslow and beyond should suffer any educational deficit due to the fact that they are educated in a school that is affected by aircraft noise.

6 It is vital that noise criteria, as defined by the appropriate British Standard or Building Bulletin standard, can be met. Therefore appropriate insulation must be provided for any premises where education is undertaken. We believe the boundary of this scheme should be 55Lden however if a school beyond this contour can demonstrate its premises are compromised by aircraft noise then they should also be able to apply for mitigating measures to be installed. We are of the view that adequate compensation for the extra expense of building / refurbishing schools is needed. This should be offered within the new noise insulation scheme 1. The support given to the community-led body which is responsible for making necessary decisions involved in administering the schools and community buildings scheme is variable at best. There are issues with the glazing supplied and, anecdotally, the quality of the installation. Q8: Are you in favour of our proposal to extend the area in which the Home Relocation Assistance Scheme will operate, and also to increase the maximum sum payable in Zone 1 (with a new payment also introduced in Zone 2)? We want better conditions for our community so that the possible desire to leave is reduced. In the circumstances that an individual resident can no longer tolerate the noise level they are subjected to it falls to BAA to provide relocation assistance. This should be at the market rate set by an independent body. We have some serious concerns about the loss of the Cranford Agreement. Whilst we are determined that this change does not lead to the depopulation of this part of the Borough we accept some residents may wish to leave in which case the above assistance should be provided at the market rate. Q9: Overall, do you believe that our proposals are fair and equitable? For residents in the Borough of Hounslow the daily reality involves flights overhead every 60 seconds, Indeed, the disturbances that occur in the early morning have been proven to have a serious affect on people s health and well being. We feel that the current mitigation scheme is driven by the economic imperative rather than the social and environmental need. Further work and Government backed research needs to be undertaken. Environmental impacts need a greater weighting. Greater consideration needs to be given to the economic benefits of environmental saving. As stated above the we believe that BAA should be referring to the European Environment Agency s Good Practice Guide when developing and implementation any noise related schemes including those within the Noise Action Plan and related to mitigation. 1 Our initial estimate is that 5% of the cost of the new build/refurbishment is due to the expense of noise insulation/ventilation. It is possible that the Borough may wish to revise this figure

7 The current Noise Action Plan and noise mitigation consultation document only give attention to aircraft noise in the air and effectively ignore noise arising from surface transport to Heathrow. This should be reconsidered and addressed. We are advised that that Heathrow airport operated under the auspices of the balanced approached. We feel that this balance is still weighted towards the national interest as highlighted above. This must be redressed and further mitigating actions investigated before a revised set of proposals can truly be considered fair and equitable.