LBA Airport response to extended night-time flights.
Response:
26/04635/FU Leeds Bradford Airport, Whitehouse Lane. LS19 7TZ – Regularising the Operational Controls Planning Statement.
Planning Application: 26/04635/FU
Planning response: Object.
Dear Sirs,
Wharfedale is the area most affected by flight operations at LBA. At least 77% of all Air Traffic Movements (ATMs) take place from runway 32. Some of these ATMs are the result of wind direction at LBA, but not all.
Planners should be aware that LBA operate a ‘preferential runway scheme,’ whereby the westerly runway (32) will be used for take-off and landing in preference to the easterly runway (14).
Our response to LBA’s Planning Statement 26/04635/FU is set out below, and follows concerns raised by residents of Burley in Wharfedale and Menston.
Summary response to proposals.
I have summarised our objections as follow. Full supporting evidence is found later in the document.
- Replacing older aircraft.
The aviation industry replaces aircraft according to strict criteria.
- Flight Hours: The total time spent in the air.
- Pressurization Cycles: One cycle equals one take-off, cabin pressurization, and landing.
- New aircraft cost hundreds of millions of pounds. To simply suggest collaboration with, and that “airlines would simply have no incentive to modernise their fleet at LBA any earlier than the ‘natural cycle’ of fleet replacement ”Is, to say the least, misleading.
2. Night-time Air Traffic Movements (ATMs).
All UK airports operate under almost identical night-time constraints as LBA.
To state that LBA are disadvantaged during the night-time period is FALSE. Doubling summer night-time ATMs would provide further economic advantage to LBA, above the figures stated herein.
LBA currently has, –
- There is currently 1 night -time ATM per 839 passengers, that is, there are at least twice as many night-time ATMs per passenger when compared with other regional airports.
- If the additional night-time flights are approved, there will be 1 night-time ATM per 538 passengers, 3 times more than any comparable UK airport.
- Based on a current night-time average there are three as many night-time ATMs per passenger when compared to other regional airports. That figure would increase to 6-fold if new night-time ATMs are approved at LBA.
LBA state that is has a night-time disadvantage, when compared to other regional airports, that is patently untrue. LBA has almost three times the average number of night-time movements per passenger than almost every UK regional airport, and proposals seek to increase that advantage.
There have been no consultation with residents affected regarding this application.
In conclusion LBA does not need to increase night-time ATMs to compete better.
- LBA state that “The flight controls have not, however, kept pace with other UK regional airports and place LBA at a competitive disadvantage.”
Here again, we notice that the Radar at LBA remains the 35-year-old Watchman SSR, supplied (borrowed) from NATS Claxby. This is in urgent need of replacement to ensure passenger safety ahead of all other considerations. Why has this situation not been addressed ahead of the commercial case?
- Airport health impacts.
There are associated airport health impacts, documented by the CAA in CAP2519. These are often not known to the public. Only one dimension is documented in proposals by LBA, that is noise. LBA only state the economic case, focus on noise and have not considered other socioeconomic factors.
There has been extensive health research carried out in the Netherlands at Amsterdam’s Schiphol Airport, a report which we’re currently analysing for research at LBA. Research shows that:
- Mental health and wellbeing.
- Cardiovascular effects, which are above base levels in Wharfedale.
- High blood pressure and diabetes.
- Reduced lung function.
- See: https://pubmed.ncbi.nlm.nih.gov/32402984/ which is supported by citation.
- Increased night-time ATMs will further exacerbate healthcare outcomes shown above.
- Preferential runway.
Planners need to be aware that LBA operate a ‘preferential runway scheme,’ whereby the westerly runway (32) will be used for take-off and landing in preference to the easterly runway (14).
This runway (32) is the first choice for both take-offs and landings. It is used when the runway surface is dry and the tailwind is no greater than 5 knots. This policy directs over 77% of all ATM’s, both departing and arriving flight paths, over Menston and Burley-in-Wharfedale.
- Home sound insulation and air conditioning.
- The soundproofing of affected properties is welcomed; however, the reality is that the cost of soundproofing/glazing could be unaffordable for most, rendering the subsidy moot.
- If the contribution is for air conditioning, there’s an associated ongoing cost to operate.
The benefit of sound insulation and air conditioning, whilst well intentioned, are not robust policies that address other healthcare issues faced by residents.
Supporting evidence for LBA’s Regularising Operational Controls.
Quad’s Executive summary – Replacing older aircraft & night-time ATMs
-
Replacing air fleet.
Bullet 2.26 in the Quad report, states, –
“Collaborating with airline partners to increase operations of newer, quieter and more fuel-efficient aircraft, which is heavily reliant on extending the operational hours to incentivise airline operators to use new generation aircraft where utilisation of those aircraft can be maximised. Without the greater operational flexibility, airlines would simply have no incentive to modernise their fleet at LBA any earlier than the ‘natural cycle’ of fleet replacement. To date Ryanair have introduced some B737 Max aircraft in limited numbers. “
The aviation industry replaces aircraft according to the following criteria:
Instead of chronological age, the aviation industry measures a plane’s life using two main metrics:
- Flight Hours: The total time spent in the air.
- Pressurization Cycles: One cycle equals one take-off, cabin pressurization, and landing. Repeated pressure changes cause metal fatigue in the fuselage over time.
Lifespan by Aircraft Type
- Short-Haul Jets (e.g., Airbus A320, Boeing 737): These fly multiple short trips daily, accumulating cycles quickly. They usually last 20 to 25 years or about 50,000 to 75,000 cycles.
This is not simply an argument about aircraft quota counts, rather a commercial case to replace outdated aircraft. Ordinarily the aircraft industry replaces aircraft based on strict criteria, these are based on life cycle, maintenance cost, and commercial replacement cost/loss.
New aircraft cost hundreds of millions of pounds to buy, for example an A321 NEO costs £98,000,000 to buy outright, and around £340,000 per month to lease. To simply suggest collaboration with, and that “airlines would simply have no incentive to modernise their fleet at LBA any earlier than the ‘natural cycle’ of fleet replacement ”Is to say the least, misleading. By way of an example see the Jet2 statement, and as I’m sure you are aware, Jet2 is LBA’s largest carrier:
“To support its ongoing growth and refresh their existing fleet, Jet2plc has a firm delivery stream of 146 new Airbus A321neo aircraft through to the 2035”
LBA have expanded their operation for commercial reasons, not simply to replace or update an old terminal building but to expand their operation. It is the commercial case that drives investment and that’s precisely the same for new air fleet, and not solely quota-counts.
Manchester Airport’s Policy strikes a careful balance between the interests of the local community and the demand from our passengers to fly. LBA’s report does not or has not considered the interests of residents within proposals.
-
Night-time Air Traffic Movements(ATMs).
The Quad report states that, –
Point 6 – Currently, LBA’s flight restrictions prevent many return flights, as aircraft may need to depart before 07:00 or risk returning after 23:00 due to minor delays. Airlines are therefore reluctant to base their most modern and efficient aircraft at LBA when there are less constrained alternatives available. In the short term, this leaves LBA operating older, noisier, less efficient aircraft whilst others benefit from the advanced technology.
Point 7 – Therefore, regularising the controls to modify the operating hours incentivises airlines to invest in modern, energy efficient and quiet aircraft at LBA where use can be maximised, and LBA can become an attractive base for return flights. This subsequently improves connectivity and supports further economic growth in the city region, whilst reducing noise and carbon emissions from air traffic movements.
Both statements are unfounded following closer examination. All UK airports have flight operations which include older, noisier air fleet, which render both points moot.
Having assessed all UK airport operations, we find the following detail extracted from UK airport’s night-time flight rules and regulations. These regulations; which are in operation across the UK, detail flights with a QC of 1.0 and higher. The fact remains that all UK airports operate under exactly the same noise constraints as LBA, and that therefore there’s no benefit or incentive to operate quieter more fuel-efficient aircraft at LBA at all. This can be dismissed as misdirection.
Major hub airports, Quota Counts and the night-time cap.
Most, but not all airports, operate hours from 06:00. The DfT designates London Heathrow, London Gatwick and London Stanstead as major hub airports with strict night-time operations between 23:00 and 06:00, subject to strict night-time caps.
Airport |
Seasonal period |
Movement flight limit |
Noise quota limit |
Heathrow |
Winter |
2,550 |
2,415 |
Summer |
3,250 |
2,735 |
|
Gatwick |
Winter |
3,250 |
1,785 |
Summer |
11,200 |
5,150 |
|
Stansted |
Winter |
5,600 |
3,310 |
Summer |
8,100 |
4,650 |
These airports, –
- continue to impose an operational ban on the loudest aircraft (QC8 and QC16 rated) during the “night period”, 23:00 to 07:00
- impose a new operational ban on QC4 rated aircraft movements (for example Boeing 747-400 on departure) during the “night quota period”, 23:30 to 06:00
- continue to encourage the use of quieter aircraft, through maintaining the QC0.125 category
- maintain transparency for communities by ensuring all aircraft movements are counted towards an airport’s limits, apart from movements that meet the government’s dispensation criterion, or Instrument Landing System (ILS) calibration flights.
Adverse weather dispensations were mostly applied for delayed arrivals between 23:30 and 00:30. However, some had been applied at Heathrow Airport as a pre-emptive measure for flights between 05:30 and 06:00 on poor weather days. Heathrow is the only airport to adopt this practice.
Regional Airports.
Councils covering Airports like Birmingham, Manchester, and Leeds Bradford set their own local planning conditions and noise caps regarding the 23:30 to 06:00 window, generally permitting standard departures and arrivals to resume promptly at 06:00.
It is disingenuous to state (point 6 above, of the Executive summary) that LBA is disadvantaged in the short-term or at all, given that other airports operate under similar constraints. (See below for other airports listed in LBA’s Noise Policy document).
Bristol Airport.
The night period is from 23:30 hours to 06:00 hours. Bristol Airport is restricted to 4,000 movements in the night period each year.
Each aircraft movement is also assigned a Quota Count based on its noise level. The sum of all these quota counts is calculated and restrictions are applied including:
- A summer period limit of 1260 quota count
- A winter period limit of 900 quota count
East Midlands Airport.
Prohibits airlines from scheduling and operating the noisiest aircraft types at night 23:00 – 07:00. These are classified as having a Quota Count (QC) of 4, 8 or 16. Any late running aircraft of these types are prohibited from operating during the night period, unless there are exceptional circumstances such as livestock or perishable cargo. Should these operations occur under exceptional circumstances, the operator would also pay a surcharge to the Airport Community Fund.
Birmingham Airport
THeir current Night Flying Policy year runs from 27th October 2025 to 25th October 2026.
The four key limiting mechanisms through which the Night Flying Policy serves to mitigate aircraft noise at night are:
- An annual Air Transport Movement (ATM) limit of 7,528 (7.3% of total movements)
- An annual Quota Count (QC) Limit of 2,800
- An annual scheduled departure limit of 877 between 23:30-05:00
- An absolute total departure limit between 23:30-05:00 (to include both scheduled and non-scheduled departures) of 1162.
This is in addition to an enforced nighttime noise limit of 81 dB and a restriction on scheduling noisier aircraft, with those classified as prohibited from operating during the night period.
Newcastle Airport.
The airport enforces strict local planning controls and noise limits during the night period (11:30 PM to 6:00 AM) to limit disturbance.
Newcastle does not operate a formal government-style night noise quota count (QC) system or strict movement caps like designated London airports, relying instead on a Noise Action Plan and preferential routes to manage community impact.
Manchester Airport .
Has operated on a 24-hour basis for over 60 years. Heathrow and Gatwick Airports operate at night too and like us have a Night Noise Policy, although Manchester’s is much stricter in several areas. Manchester’s Night Noise Policy restricts the operations permitted so that the noise climate is much reduced from daytime levels. The Policy strikes a careful balance between the interests of their local community and the demand from our passengers to fly.
NN3: – Between 23:00 and 06:59 no QC16, QC8 and QC4 aircraft will be allowed to arrive or depart.
NN4: – Between 23:00 and 06:59 all QC2 aircraft that do not hold historic slots at the end of Summer 2025 for the subsequent Summer, and the end of Winter 2025 for the subsequent Winter season, will not be permitted to operate during the 8-hour night.
Manchester operates several exemptions which allow QC2, QC4, QC8 and QC16 aircraft to operate within the night period, namely:
- Off scheduled movements during emergency situations;
- Off scheduled movements as a result of major disruption to air traffic;
- Off scheduled movements where significant distress may be caused to humans and animals;
- Relief flights where urgent needs exist;
- Military and support aircraft at time of war;
- Aircraft of British or foreign Royal Families and aircraft carrying Heads of State.
Night-time Air Traffic Movements(ATMs)
All UK airports operate under almost identical night-time flight constraints as LBA, although others are far more prescriptive.
It is noted that night-time ATMs at airports, when comparing passenger numbers at other UK airports, noted within the report, are disproportionately high at LBA. (See table below and Table 1, page 4 of the Noise insulation scheme).
| Airport name | Total PAX 2025 | Night-time quota | Passengers/night-time movement |
| EAST MIDLANDS INTERNATIONAL | 3,860,003 | No known | |
| LEEDS BRADFORD | 4,247,749 | 5,061 | 839 |
| NEWCASTLE | 4,535,241 | N/A | |
| BRISTOL | 9,453,219 | 4,000 | 2363 |
| BIRMINGHAM | 12,503,337 | 7,528 | 1661 |
| STANSTED | 28,208,371 | 7,600 | 3712 |
| MANCHESTER | 30,211,712 | 10,000 | 3021 |
| GATWICK | 39,811,877 | 14,450 | 2755 |
| HEATHROW | 79,561,354 | 5,750 | 13837 |
| Source CAA passenger numbers by Regional Airport. LBA’s current position with no additional night-time flights. PAX = Passenger numbers. | |||
To state that LBA are disadvantaged during the night-time period is FALSE. Doubling summer night-time ATMs would provide further economic advantage to LBA, above the figures shown in the above table.
The above shows that LBA has, –
- There is currently 1 night -time ATM per 839 passengers, that is, there are at least twice as many night-time ATMs per passenger when compared with other regional airports.
- If the additional night-time flights are approved, there will be 1 night-time ATM per 538 passengers, at least 3 times more than any comparable UK airport.
- Based on a current night-time average there are three as many night-time ATMs per passenger when compared to other regional airports. That figure would increase to 6-fold if new night-time ATMs are approved at LBA.
- The calculation is Total PAX / Night-time quota.
LBA state that is has a night-time disadvantage, when compared to other regional airports, that is patently untrue. LBA has almost three times the average number of night-time movements per passenger than almost every UK regional airport, and proposals seek to increase that advantage.
In conclusion LBA has no need to increase night-time ATMs to compete better.
- The calculation is Total PAX / Night-time quota.
The unanswered question at LBA is which aircraft breach exiting QC rules, the very issue that the airport makes in bullet point 6 of the Quad report.
Already contained within the existing night-time cap is the ability for 2,920 plus an additional 941 annual night-time movements for quieter aircraft, plus another 1,200 during winter. The total annual number of allowed night-time ATM’s is 5,061, and we note a proposed increase of summer ATMs in the order of 2,839. The ratio of passenger numbers per night-time movement; as detailed above, strongly favours night-time movements at LBA by a factor of at least 2 or 3 or more, on average, when compared with other regional UK airports.
If the new summertime quota is approved, night-time movements at LBA will be 3 to 6 times higher than at other UK regional airports.
The only affected operator at LBA appears to be Jet 2, who have 7 aircraft whose QC exceeds 1.0, as follow:
Reg Aircraft Type Config Delivered Age
- G-GDFG Boeing 737-300 Y148 Mar 2012 29. 5 Years
- G-GDFK Boeing 737-300 Y148 Mar 2012 28.3 Years
- G-GDFL Boeing 737-300 Y148 Jun 2012 28.6 Years
- G-GDFM Boeing 737-300 Y148 Feb 2013 27.7 Years
- G-GDFN Boeing 737-300 Y148 Apr 2013 28 Years
- G-GDFO Boeing 737-300 Y148 Feb 2013 28.5 Years
- G-GDFT Boeing 737-300 Y148 May 2013 28.3 Years
As stated earlier, Jet2 are already refreshing their fleet over the coming 9-years to 2035. That having been said, the argument for new aircraft is not predicated on quota-count alone, airlines operate in a commercial world, as does LBA.
Bullet 2.28 of the Quad report, –
“LBA have continually invested in the airport to respond to evolving passenger demands. The flight controls have not, however, kept pace with other UK regional airports and place LBA at a competitive disadvantage. This undermines the value of investment in the airport linked to the passenger experience, the commitment of airlines to routes and fleet upgrades, and the wider economic and environmental benefits for the City and the Region.”
Firstly, the notable absence within the above, is that it fails to consider the airport’s impact on health, and the associated socioeconomic cost. LBA focus solely on aircraft noise, ignoring other health receptors. This is perhaps the strongest missing case from LBA’s economic argument.
Secondly, and marginally less important, is air safety. Air safety ranks more highly than ‘evolving passenger demands.’
The Radar at LBA remains the 35-year-old Watchman SSR, supplied (borrowed) by NATS Claxby. This should be the first piece of equipment to be replaced at LBA. Secondary surveillance radar (SSR) is an air traffic control system that uses ground transmitters to interrogate aircraft transponders, which automatically reply with identity and altitude data. In the past, I have radar mapping produced at LBA showing aircraft departing from Yeadon Tarn, which illustrates an ongoing issue (below).
The question remains about accuracy of this equipment.
Furthermore, if LBA are collaborating with airlines, then why do we see carriers like Wizz air regularly operating beyond the permitted northern edge of the runway 32 swathe (Noise Preferential Route or NPR), shown in red?
Secondly, the public have no access to tabulated noise data at the airport, rather we are asked to take at face value the fact that LAeq 16h noise is being strictly monitored and adhered to. Where is the evidence to support/disprove this claim?
If we are to see expansion at LBA, after considering health impacts, then the priority should be air safety, then passenger experience, and in that order.
- Health impacts of Airports.
There are associated airport health impacts, documented by the CAA in CAP2519, see: https://www.caa.co.uk/publication/download/20404. The report details the health impacts associated with noise throughout 24-hour operations, increasing passenger numbers and night-time flights will further worsen health outcomes.
There are additional risks associated with sleep disturbance during the night-time period, noted by the Alzheimer’s Society. There is evidence to suggest that a lack of sleep may increase a person’s risk of dementia, but this needs further investigation.
Then there has been extensive health research carried out in the Netherlands at Amsterdam’s Schipol Airport, a report which I’m currently analysing to allow further research at LBA. Research shows that airports consistently have significant health impacts on those living within an airport’s noise and pollution footprint. Impacts include:
- Mental health and wellbeing (noise)
- Cardiovascular heart disease.
- High blood pressure and diabetes. (particulate matter PM5 and PM10)
- Reduced lung function. (particulate matter PM5 and PM10)
- See: https://pubmed.ncbi.nlm.nih.gov/32402984/
- Preferential runway disadvantages Wharfedale.
Residents in Wharfedale consistently complain about disturbed night-time sleep and being woken at 6:00am daily when departures commence at LBA.
Their concerns are real. Around 78% of all flights (arrivals and departures) take place from runway 32, over Wharfedale. This is often due to prevailing winds at LBA, winds from the West (W) clearly favour runway 32 but winds from the West Southwest (WSW) favour neither runway 14 or 32.
Planners need to be aware that LBA operate a ‘preferential runway scheme,’ whereby the westerly runway (32) will be used for take-off and landing in preference to the easterly runway (14). This runway is the first choice for both take-offs and landings. It is used when the runway surface is dry and the tailwind is no greater than 5 knots. It directs departing and arriving flight paths over areas like Menston and Burley-in-Wharfedale. See: https://www.leedsbradfordairport.co.uk/sustainability/noise-management
This area of Wharfedale is not semi-rural as it was a few decades ago. There has been and continues to be, significant expansion of housing in the area. Consequently, flight volumes over Wharfedale has a significant impact of both noise and health. Then there’s the Airspace Change Programme (CAP1616) which is governed by a set of Design Principles, key amongst which is DP1 – Safety, notably safety on the ground.
- Home sound insulation and air conditioning.
In respect to home insulation proposals at LBA, we wish to point out several observations and concerns.
Within Logika’s report, bullet 3.1, page 6, we note that “As a minimum requirement, the UK Government expects airport operators to offer acoustic insulation to noise-sensitive buildings, exposed to levels of noise of 63 dB LAeq,16hr or more.”
This raises the question of which areas of adjacent villages, towns and cities lie within the 63db footprint. There is no detail shown within proposals. This is a crucial information requirement for planners to understand the scheme’s parameters to evaluate proposals.
- The soundproofing of affected properties is welcomed; however, the reality is that the cost of soundproofing/glazing could be unaffordable for most, rendering the subsidy moot.
Then there’s the issue of hot summer nights, when glazing will not provide any sound reduction if windows are left open to allow fresh air into rooms.
- If the contribution is for air conditioning, there’s an associated ongoing cost to operate.
Regards,
Cllr Bob Felstead & Cllr Peter Cochrane
Bradford District Councillors (Wharfedale Ward)
