AEF members raise concerns over airport expansion and noise
25th April, 2025
The interaction between aviation policy, planning and environmental protection can be complex. AEF uses our members’ experiences and local knowledge to help inform our approach to these areas. Recently, an AEF webinar allowed members to voice their concerns on the topic of airport expansion. The questions were broad-ranging: noise, environmental boundaries, international policy and legal challenges were all touched upon. Read on to find out more.
Noise
Question: Regarding noise – we have a local issue whereby any mobile noise monitoring (which is a s106 condition of the planning permission for Farnborough Airport) only deals with the traffic from the airport in question. I know this is an industry standard, but it doesn’t take into account the air traffic which has been displaced due to the recent airspace change at Farnborough, for example. Are there any plans to measure total aviation noise in an area, rather than noise at one specific airport? Is there any organisation that would do this, for example?
This is a common criticism of noise modelling because the operational data is only selected for the airport in question. But for noise measurement, the monitoring equipment should pick up all events in the receiving environment regardless of the airport of origin. It needs a manual log to annotate the results to say whether they were Farnborough movements or other traffic. We do argue for total aviation noise measurements to be taken, as members often experience overflights from more than one airport or airfield.
Question: Bearing in mind the southeast is now the busiest aviation area in the world, when will monitoring noise out with noise contours and above 7,000 feet become normalised?
A fair point. In theory, noise models don’t have an altitude cutoff; they only have a noise exposure cut-off, e.g. not modelling contours below 45dBA Leq. This means that regular overflights that are still regarded as noisy but less frequent are often not captured.
Question: When will the Government make the distinction between daytime and nighttime noise? Will the threshold for nighttime noise be lowered as it is more harmful to human health?
Government policy does distinguish between a 16-hour day (normally 0700-2300) and a night period, and noise contours are produced at major airports for both periods. We don’t foresee any change in policy, unfortunately. Parallel to AEF’s work is its Airspace Noise and Community Forum (ANCF). The ANCF has been engaging with Government directly through its consultative bodies, forums, and the CAA. There are lots of research studies in the pipeline. There is a study to re-evaluate the relationship between noise and nuisance and noise and health, including night noise. Our best guess is that until we start seeing the results from these studies, it is going to be difficult to persuade the Government about the need to change the thresholds. We are asking for initial evidence from these studies to be released early so we can at least see the general direction of the results at a crucial time for airspace modernisation and airport expansion decisions, but it seems unlikely in 2025.
Current noise policy is not adequate, which is why it takes up a significant chunk of the AEF’s agenda for 2025.
International policy
Question: Is part of the problem that most of the emissions are international, and has there been an agreement on which country ‘owns’ those emissions for international flights?
That’s a great question. The reason why international emissions weren’t included in the Kyoto protocol in 1997 was because of this dispute over who should take ownership. The Intergovernmental Panel on Climate Change (IPCC), which provides climate advice for reporting all international emissions, provides a really clear set of guidelines. And in that it states that emissions should be attributed to each country based on all departing flights from that country. So the UK has been including its international aviation emissions in its reporting to UNFCCC since 1997 on that basis.
That said, if you look at the carbon implications from a particular airport, e.g. Gatwick, the New Economics Foundation has created quite a powerful case for considering the carbon that leaves the airport on the outbound flights, but also the carbon that arrives on inbound flights: both define the emissions that will be created by an airport expansion project. So it doesn’t work for international inventory accounts (as there would be double-counting), but there is a case for calculating flight emissions this way when looking at individual airports.
Environmental boundaries
Question: What do you think of the Government continually emphasising so-called ‘green’ growth over environmental goals?
I think it is much bigger than just aviation. This was the number one priority of this Government coming in and I think the media has continually poked and provoked the Government to indicate where this growth will come from. They chose to back airport expansion as this source of growth, despite the uncertainty.
Even if planning went ahead and the compulsory purchase of the land happened, the construction was successful and not held up by legal challenges, it is really hard to see how this third runway could be operational before 2034. So I think the argument that the growth will be evident over the next 10 years is not realistic. If you want growth, you are looking in the wrong place.
Question: Do you think the Carbon Budget Delivery plan (due before May 2nd*) is going to help us in terms of limiting airport expansion?
*Postscript: the court has extended the deadline for Government to comply with the ruling to submit its revised plan until the end of October 2025
At worst, the CBDP will simply reinforce the Jet Zero strategy and we will need to continue to highlight its shortcomings, including the legal challenges brought by Possible and Galba which were heard by the High Court in April 2025. But there is an opportunity for the Government to re-evaluate the likely contribution of SAF, efficiency measures, zero emission aircraft and demand measures, and to reset aviation decarbonisation policy.
Question: Do you think the ‘4 tests’ from Labour are still in play?
Certainly a version of the original four tests, (referenced by the caveat to Rachel Reeves’ support for Heathrow by Ministers), that it must meet the Government’s climate objectives. But the four tests were always ambiguous in terms of how they should be measured.
Question: The Government’s advisors, the Climate Change Committee (CCC), have recently published its seventh carbon budget, which includes aviation’s trajectory towards net zero in 2050. Does the CCC’s projection of potential aviation expansion (37%) include a reliance on SAF to meet emissions goals? Or is it mainly around other efficiencies?
It includes some SAF, but importantly, they think SAF will only represent 17% of all aviation fuel in 2040, lower than the Department for Transport’s SAF mandate volumes that plan for 22% in the same year. CCC calculated 54% of emissions savings would come from demand management (through the industry paying for decarbonisation which will feed through to ticket prices), 33% would come from SAF and 13% from efficiency savings.
Legal challenges
Question: What options are left for delaying tactics if an application is granted, and how much would they cost?
Legal challenges are an obvious route if there are strong grounds. Submitting a Judicial Review may not be straightforward – and remember a JR can only challenge the way a decision was made, and not the substantive decision itself. There can also be significant costs in preparing for a hearing if the court application succeeds. The defendant’s costs, if brought by an individual, can be capped at £5,000. There is always an opportunity to explore how rational it is for the Government to go ahead with Luton, given all the uncertainty referenced in this webinar (e.g. in the absence of an ANPS review, “new” Jet Zero strategy, airspace modernisation, etc.).
These questions and answers were taken from a webinar discussion held in March. This was the first in a series of webinars commemorating AEF’s 50th anniversary.
Interested in this series? Become an AEF member and receive notifications for these events.