The consultation closed on Wednesday 24th August 2011.
Our response is as follows:
'We do recognise that consultation events took place at various locations in June and July. However, we are concerned about the low-key nature concerning potential changes in night flying policy that we believe will overall have a detrimental environmental effect on the population.
We welcome the reduction of the night noise violation limit from 87db - 85 db. However, the revision of annual limits for ATMs annually based on the previous 5 years is worrying. Despite showing noise trends of a reduction of noise impact on the population, there appears to be no commitment or strategy to reduce overall noise levels at night. Exempting Quota Count 0 aircraft which in themselves can have a noise classification of anywhere up to just under 84 EPN dB, and therefore the vast majority may have a noise of for example 83.9 EPN dB. The increase in frequency of aircraft (particularly now there is a runway extension) can possibly outweight the general welcome shift towards lower quota aircraft that has occurred. It is also surely reasonable to give projections of noise impact on the population; in business, financial and non-financial projections of operations have to be made and therefore there is very little rationale to not do something similar for projections of noise levels and impact.
Solihull Friends of the Earth believes that to assume that noise levels have to increase or decrease based on recovery or recession is not part of a commitment to decrease noise levels and its impact on the population.
Solihull Friends of the Earth don’t believe that there is an insufficient strategy to attempt to mitigate for increased noise levels. It’s very well to respond that any fines collected from exceeding the noise violation limit is put into ‘community projects’ but it is necessary to know what is going to be done as a result of increased noise because of the actual change in the night flying policy.
We would also like to learn more about the number and type of flights that have moved from Coventry Airport to Birmingham as a result of the closure of that facility. We welcome the news that a new consultation period would be put in place if flights were ever to recommence from Baginton. We would appreciate if more detailed information and greater clarity could be provided regarding this issue.
Finally, we do have some concerns about removing the seasonal splits in ATMs (76% Summer and 24% Winter), and therefore would appreciate any greater clarity though we do also appreciate the reasons why Birmingham Airport are proposing this.'
Our response covers the important points and expresses our dismay of a almost non-existant strategy of noise reduction and/or reduction of the impact of noise on the surrounding areas. The presentation of data by Birmingham Airport showing an overall reduction in noise impact on the local population in the last ten years shows little relevance as to the impact on noise as a result of the changes resulting from the proposals in the consultation document.
Did you respond to the consultation ? Do you have any comments to make concerning this issue or is there anything to add? Please feel free to make comments either via the blog or emailing us at solihullfoe@gmail.com.
