Our objection to LBA's planning application
Please note that this is a joint objection from Izaak and Emma. Jools must remain neutral as she is on the relevant Planning committee.
Quick summary:
We’re objecting because the airport’s application will likely mean more people are disturbed by more night flights.
The airport’s modelling shows, for example, that the number of people experiencing 15 or more very loud (60 dB+) noise events on an average night would rise from 600 to 30,400 if the application goes through as it’s written.
And yet the mitigation from the airport would help only around 1,000 households.
We want new Planning conditions that keep a limit on night flights as well as encouraging quieter aircraft, so residents get proper protection through the night.
Full objection:
We are writing to object to Planning Application 26/04635/FU from Leeds Bradford Airport.
Incentivising quieter aircraft is positive. But this does not justify replacing the existing movement limit rather than supplementing it.
Quieter aircraft are still aircraft, and the number and frequency of individual flights at night still matter. We hear very consistently from residents that individual aircraft disturb their sleep.
For context, our ward covers parts of Meanwood, Far Headingley, West Park, Ireland Wood, and Cookridge.
The airport should have planning conditions that incentivise quieter aircraft and retain a limit on the number of individual night-time flights.
Compared with the application's own 2030 baseline under the existing planning regime, the proposal increases the number of households exposed at every modelled noise threshold from the 45 dB Lowest Observed Adverse Effect Level (LOAEL) through to the 55 dB Significant Observed Adverse Effect Level (SOAEL).
Most worryingly, the modelling predicts increases at every reported threshold for the frequency of individual 60 dB+ noise events. The number of residents experiencing 15 or more separate 60 dB+ aircraft noise events on an average night rises from 600 under the 2030 baseline to 30,400 under the proposal. That is a shocking increase in residents' exposure to frequent night-time aircraft noise, with potentially serious consequences for sleep disturbance and public health.
Yet this enormous change in the frequency of individual noise events is not reflected in the application's overall conclusion that there will be no significant adverse noise effects. That conclusion relies principally on aggregate or average noise exposure. Changes in average noise can therefore be classified as 'negligible' even while tens of thousands more residents experience frequent individual 60 dB+ events.
The proposed conditions contain no limit designed to prevent or control this level of exposure to repeated individual noise events. Average noise is not the whole of residents' experience: individual aircraft noise events can cause awakenings and other forms of sleep disturbance. The frequency of those events matters too, and the planning conditions should control it.
This matters for noise insulation too. Eligibility is based on average noise exposure above the SOAEL threshold, rather than the frequency of individual 60 dB+ events. The vast majority of residents experiencing large numbers of individual night-time noise events will therefore receive no mitigation on that basis. The mitigation scheme is also limited to a maximum of 100 households per year.
We particularly object to concentrating the principal noise controls within the narrower 23:30–05:59 Night Quota Period. The application continues to define 23:00–06:59 as the Night Time Period, but the Noise Quota would not apply between 23:00–23:30 or 06:00–06:59. We are concerned this could facilitate increased activity during hours that the proposed permission itself continues to recognise as night time. Residents should have equivalent protection throughout the full Night Time Period.
The claimed air-quality and carbon benefits depend substantially on the proposal accelerating the replacement of older aircraft with newer aircraft. But the proposed conditions do not appear to require the particular future fleet mix assumed in the assessment. We therefore question whether those claimed environmental benefits are sufficiently secured.
We are also concerned about the weakening of monitoring. The existing condition requires monthly reporting of night-time movements by aircraft type. The proposal replaces this with a Noise Performance and Forecast Report every two years. Whatever information the airport chooses to publish voluntarily, frequent and enforceable reporting of the number, timing and type of night-time movements should remain a planning condition.
Underlining all of this is our concern about the public health impact of night-time aircraft noise on people living in affected communities.
The current system is imperfect. It controls the number of aircraft movements but provides insufficient incentive to use quieter aircraft. The proposal addresses that weakness, but does so by removing the numerical movement limit and concentrating the principal noise control within a narrower 23:30–05:59 period.
The airport's modelling shows why aggregate noise and the number of individual noise events are not interchangeable. Average noise can change by an amount classified as 'negligible' while tens of thousands more residents experience frequent individual 60 dB+ aircraft noise events.
Planning conditions should both incentivise quieter aircraft and protect residents from excessive numbers of individual night-time flights, with proper monitoring and protection throughout the full 23:00–07:00 night-time period.
The proposed conditions do not achieve that balance and, in their present form, we object to the application.
