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Representation by Plains of Waterloo Community Group

Date submitted
25 September 2018
Submitted by
Members of the public/businesses

MISLEADING NUMBERS REGARDING NIGHT FLIGHTS AND UNACCEPTABLE NOISE LEVELS FROM THE PROPOSED CARGO HUB

We, the undersigned, live directly under the flight path in central Ramsgate and would be adversely affected by noise and night time flying as proposed by this application. The applicant has sought to underestimate the harm this proposal will cause to our health and lives.

RSP has applied for a night time noise quota of 3028 QC per annum which will allow for a number of flights far in excess of the ‘worse case scenario’ of 8 flights per night assumed in RSP’s Environmental Assessment. Compare this to Luton airport where 2,645 QC resulted in 7,450 night flights per annum (CAA fig). Why apply for this very high number of QC points? No cap on night time flying has been proposed which contradicts the applicant’s insistence locally during the consultations, that they ‘neither need nor want’ night flights save emergency and humanitarian exceptions. As most cargo flights in the UK land during the night, the applicant’s policy is rather disingenuous.

The applicant baseline noise measurements are flawed and unsatisfactory. Insufficient attention has been paid to ‘real time’ official noise measurements from past airport operations (especially noise measurements considered by the then airport consultative committee - KIACC). The noise measurements also contradict CAA noise measurements of the first 17 months of Boeing 787 operations at Heathrow Airport (CAA doc CAP1191), where no reading at 3.8km from the end of runway was less than 90 SEL dBA. It is not unreasonable to say that noise levels over St Lawrence (1.6km distant from runway) and central Ramsgate (3.2km distant from runway) therefore cannot be much lower.

The Noise Mitigation Plan proposes to accept night ATMs rated at QC4 - prohibited from London airports on noise grounds. This would create unacceptable levels of noise. The applicant himself states in paragraph 12.7.55 of the Environmental Statement that by Year 2, 11,356 homes will experience noise levels of 80 decibels per night (although this figure is dubious - see previous paragraph).

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