GALBA has carefully analysed LBA's planning application and we explain the key issues below.
This application seeks to replace the current numerical limit of 4,941 annual night flights with a ‘noise quota system’ that would give LBA to permission to fly up to 7,733 night flights over the year from the mid-2030s. In addition, LBA wants to abolish the limits on night flight numbers in the winter and summer seasons, which means the great majority of night flights would occur in the summer season. LBA also wants to exclude flights between 6am and 7am, and between 11pm and 11.30pm, from any limit on numbers and to exclude all delayed flights from the ‘noise quota system’. Please read on for more explanation.
The basics: we do not call for LBA to be closed down. We just say it should not be allowed to significantly increase flights at night, in the early morning and during the day. That is what LBA’s seeks in this application.
Timescale: LBA’s application shows two scenarios to illustrate the health and environmental impacts of the proposed changes. Both scenarios are in 2030 but there is no attempt to explain the difference between today and a future when the impacts would be at their highest.
2030 is just three years after the proposed changes would take effect – that is a very short timescale for LCC to plan ahead. The mid-2030s and beyond are more realistic timescales to forecast the full impacts because LBA’s biggest airlines will have completed their fleet upgrades by then – see more below. As the application stands, it is impossible to assess the true extent of the impacts of LBA’s proposed changes barely 10 years into the future.
Health impacts: there is a wealth of medical research that identifies the harms caused to health, notably cardio-vascular illnesses, from nighttime noise, in particular frequent noise at night. There is also a growing body of evidence about respiratory illnesses, notably lung disease, caused by the ultra-fine particles released by jet engines, as well as other particles from road vehicles. The result of LBA’s application would be increased frequency of noise at night and in the early morning, and increased air pollution, from the increased flight numbers.
More frequent noise at night and early morning: using LBA’s own figures, the number of local people experiencing 15 or more loud aircraft noise events at night (at 60 decibels) during the peak summer season would rise from 300 in 2024 to 30,400 in 2030. That is not, as LBA claims, “negligible”. LBA can only claim that the noise impact is “negligible” because it chooses to measure noise as an average over 12 months.
That is emphatically not how human beings experience noise. People experience noise as it happens, not as an annual average. Annual average noise can change by a small amount at the same time as over 30,000 more people suffer at least 15 loud noise events from planes flying over their homes at night.
LBA’s economic claims: in section 7 of LBA’s Planning Statement, there is reference to potential jobs and economic growth. However, the Statement is clear that LBA believes it will expand (to seven million passengers a year in 2030) whether this application is approved or not – it makes no difference.
The Statement is also clear that the growth figures used in the application are taken from LBA’s own Vision 2030 business plan – they’re on p28. But Vision 2030 does not make reference to, nor assumption of, any changes to the night flight rules for the potential growth to occur. So based on LBA’s own Statement, there is no causal connection between the claimed potential growth and this application to change the rules.
Airline fleet renewal: LBA claims that changing the operating rules would incentivise the use of newer aircraft. However, LBA’s two largest airlines, Jet2 and Ryanair, are already upgrading their fleets because their current aircraft are reaching the end of their cost-effective lives. Both airlines will have completed their fleet renewal by the mid-2030s meaning that newer planes are coming to LBA regardless of the outcome of this application. Crucially, there is no requirement, anywhere in the application, that would ensure the early introduction of newer aircraft at LBA.
LBA has chosen 2030 for its scenarios – just three years after the airport would be allowed to make additional flights. Given that fleet renewal will be complete by the mid-2030s, that is the point at which forecasts of flight numbers, and all the associated environmental impacts (noise, air pollution, greenhouse gases), should be made. It is notable that LBA’s Vision 2030 also envisages significantly more flights in 2040.
Increased night flight numbers: by replacing the current numerical cap on night flights with a ‘noise quota system’, which is based on the noise rating of individual planes, LBA is effectively asking for permission to increase the number of summer night flights by 75% from the mid-2030s onward. This is a matter of simple arithmetic.
Every individual plane has a noise ‘quota count’ (QC) number, with lower numbers meaning the planes are relatively less noisy. LBA’s planning application wants a ‘noise quota system’ limit (with no numerical cap) set at 1,450 per year. That would mean LBA is permitted to fly at night:
The new generation of planes used at LBA will soon be a mixture of QC0.25 and QC0.125. So when half the planes flown at LBA are QC0.25 and the other half are QC0.125, then LBA would be allowed 7,733 flights at night over the year.
There are fewer night flights in the Winter Season (about 1,000), so the majority of LBA’s 7,733 night flights would be in the Summer Season. The current limit on summer night flights is 3,861 but if the application is approved that would rise to 6,733 – a 75% increase.
Without a numerical cap, or any other controls on the number of night flights, LBA would be permitted to make more and more night flights as newer aircraft have lower QC numbers. But remember: no jet engine is genuinely quiet and the frequency of sleep disturbance is a key cause of harm to human health.
Increased daytime flight numbers: LBA also wants the daytime to begin one hour earlier, at 6am, and end 30 minutes later, at 11.30pm. The application is clear that LBA wants this so that airlines can make more round trips (rotations) in a day but the application gives no estimate at all of how many more flights would result from this change. It is therefore impossible to quantify the impact on daytime noise, air pollution and greenhouse gas emissions that would be caused by this application’s proposals. However, all three would rise as the increase in total flight numbers would outweigh any reduced impact by a single flight.
Less noisy, less polluting planes – but a lot more flights: LBA states that the newer planes being introduced over the next 10 years will be less noisy and less polluting. This is true to an extent but any benefits from reduced environmental impacts per flight would be more than wiped out by the increase in total flight numbers.
It’s also notable that LBA describes the proposed changes as providing an “indirect incentive” to airlines to use their newer planes. As mentioned above, there is no requirement anywhere in the application (no condition or s106 agreement) on LBA or the airlines to use their newer planes.
Other airports: LBA claims that it wants parity with the operating rules at other airports. However, LBA is in fact seeking less strict operating conditions than other airports. For example, at Bristol, Birmingham, Luton and the London airports there are strict numerical caps on the number of night flights, along with noise quota limits.
At the London airports, the noise quota limit decreases over time to encourage the use of quieter aircraft. At Heathrow, the numerical cap on summer season night flights is 3,250, while at LBA it is 3,861 – nearly 500 more – and at Heathrow there are periods when there are no night flights at all.
At Manchester, to avoid excessive ‘bunching’ of flights in the summer season, there are separate noise quotas for summer and winter seasons. The restrictions in place at Manchester and the London airports provide no exemption for delayed flights from the noise quota, except when the delay is due to genuine emergencies or widespread disruption of air traffic.
LBA does not propose any equivalent controls.
The 6am daytime start: LBA wants permission to make more flights from 6-7am. This hour would be redefined as ‘daytime’ and therefore would not be subject to any controls on flight numbers. This is a time when many people, including school children, are still trying to sleep. Furthermore, when combined with the proposed increase to night time flying, many more flights would also be permitted to take off earlier than 6am.
Noise insulation: LBA has offered to pay “towards” (not all of) the costs for 750 households – in the whole of Leeds and Bradford – and has made no offer to help with the costs of running the proposed air conditioning. Those 750 households would receive help at a rate of roughly 100 per year, which means that hundreds of households would be waiting years for any help, while the increased night flights would be permitted from summer 2027.
LBA’s proposed eligibility for insulation is based on average noise exposure, rather than the frequency of aircraft noise events. The vast majority of local people experiencing nighttime noise from frequent flights over their homes would therefore receive no help on that basis. Householders would also have no choice over the builders used, as they would be contracted by LBA. Therefore, householders would have no direct recourse to action to remedy shoddy work.
Monitoring: the current system is not perfect as it relies solely on data supplied by LBA, with no apparent independent verification of the data by LCC. However, it does at least require LBA to supply monthly flight numbers to the Planning Dept. LBA proposes to abolish that and provide only one report every two years.
Leeds Bradford Airport is big enough already