1. Introduction
This document is intended to form part of the position taken by ARAG with respect to the Geneva airport curfew proposals by CRINEN and the subsequent observations made by interested parties. It contains a proposal for a logical and consistent method for the rules and methods used to plan aircraft movements in the early morning and late at night. This proposal is intended to improve the overall situation by discouraging movements which are excessively late, sometimes even early, and which cause a significant (above average) noise. It will not in any way penalise movements which are planned in a reasonable manner, use modern quiet aircraft and take place very close to their scheduled time.
The world-wide economic recession of the past 18 months has caused great difficulties for aircraft operators. However, from the point of view of the residents living around Geneva airport, the effect has been a drastic reduction in the number of night flights. The exact reasons for this reduction may be many and varied: reduction in the number of scheduled flights, an improved overall punctuality due to less overcrowded skies and better air traffic control techniques are probably two major factors involved in this beneficial effect.
As with financial affairs, it is now important that, when the recession is over, we do not return to the extraordinary growth in night flights which characterised the years just prior to this recession. Rather, we should adopt measures which, whilst allowing controlled growth where justified, will remove some of the highly unacceptable aspects (very loud movements of old aircraft very late at night) and ensure that any growth is regulated in the interests of the residents living around the airport.
This document does not try to make a judgement of which, if any, of the different curfew possibilities envisaged by CRINEN should be adopted. Equally, it does not try to rebut systematically some of the arguments put forward in the various reports (EMPA, SH&E and the AIG) to try to discourage any curfew restrictions, although some of the comments on the proposition do effectively indicate areas in which ARAG feels that these various reports do not necessarily reflect the current reality.
2. Executive Summary
The essential concept of the proposal is that for jet aircraft used for commercial scheduled and charter flights, all aircraft which are not in the AIP noise class V (the least noisy aircraft) will have a reduced daily time window in which they may operate. For class IV aircraft the reduction will be one hour morning and evening, whilst for classes I, II and III the reduction will be two hours morning and evening.
For departures of commercial aviation which forms part of general aviation (primarily business jets) the daily operational window for class V aircraft will be reduced by one hour morning and evening, whilst for the other, noisier classes, it will be reduced by two hours morning and evening. In other words, the AIG would be expected normally to refuse requests for commercial isolated departures in the first or last hour of the operational day (although derogations might be applied in particular exceptional and unforeseeable circumstances). Note, however, that there would have to be a dispensation for arrivals after an overnight flight, for which noise class III aircraft are still often used, and which may arrive early as a result of meteorological ccircumstances.
For all other aviation, including non-commercial jets, the reduction will be two hours morning and evening.
It is also proposed that there be a noise surcharge on arrivals which take place in the delay margin window (currently between midnight and 00h29) for all aircraft. This noise surcharge should be sufficient so as to be a genuine penalty for such arrivals. In addition, the operator responsible for any movement operating in the delay margin window, both arrivals and departures, conjointly with the AIG, should be required to submit an explanation of why this was necessary.
As a counterbalance, the AIG could request the right to waive noise surcharges, for both departures and arrivals, for the same reasons as those allowing derogations to be given to movements outside the operating window, i.e. in cases of exceptional and unforeseeable events. As with derogations currently given for commercial movements after 0h30, the reason for each waived surcharge should be documented by the AIG and submitted to OFAC.
Finally, the monthly “Relevé des nuisances sonores”, which is distributed to the CCLNTA and other various interested bodies, should document all the above cases for which a report has gone to OFAC. This would be an important step away from the current situation, in which neither OFAC nor the AIG will allow people residing around Geneva airport to know why they may have been disturbed by very noisy and/or late (or even early) aircraft.
It si also assumed that, as has been proposed and agreed in principle already some years ago, the noise classification of aircraft should be revised to reflect modern standards of quietness for aircraft. This would have the effect of demoting various aircraft types into a lower class. The aircraft operators would then have the option of using quieter aircraft, rescheduling their flights or of risking that flights outside the shorter operational window would have to be cancelled or diverted.
In order to explain further the proposal, it will be assumed to be applied to the current OFAC rules and guidelines. These specify that for landings of commercial aircraft the daily window is from 05h to 24h, with an additional delay margin of 30 minutes after midnight. For takeoffs of commercial aircraft the window is from 06h to 24h, again with an additional delay margin of 30 minutes. For non-commercial aircraft, as well as for particularly noisy jet aircraft, the window is from 06h to 22h.
3. Details of the proposal
Standard commercial airlines produce detailed timetables (twice a year here in Geneva. With one notorious exception, these schedules do not include departures after 22h, nor do they include arrivals after midnight. They normally also include what type of aircraft the operator proposes to use. Of course, these schedules may be modified during the 6 months of validity. I understand that the AIG is consulted before these schedules are finalised.
Individual non-scheduled movements, both charters and general aviation, must be agreed with the AIG, who may take into account the availability of slots and the noise class of the aircraft concerned. The demand should also specify if the movement is commercial in the sense defined by the OFAC regulations.
With the proposal as specified earlier, the planning by AIG would have to take into account the noise class of the aircraft to be used. Thus, for aircraft in class IV, planned arrivals for commercial airlines or charters would have to be between 06h and 23h, whilst planned departures would have to be between 07h and 23h (preferably between 07h and 21h, leaving a two-hour gap until the start of the delay margin time). For general aviation commercial movements of aircraft in class IV these windows would be 07h to22h (arrivals), 08h to 22h (departures) and 08h to 20h (departure guidelines).
Once the scheduling is done in a reasonable manner, then it is important that the schedules are adhered to. If they are not adhered to, without this being the result of the type of exceptional and unforeseeable events which let AIG grant derogations for movements outside the normal operational hours of the airport, then there should be some meaningful consequences. These consequences should discourage operators from proposing over-optimistic schedules which assume that everything will always operate to perfection (by far not always the case). Thus, in addition to the existing takeoff surcharges, there would be a noise surcharge for landings in the delay margin window, plus the requirement that there be a published explanation for all movements in the delay window. For commercial flights for which the AIG has not declared there to be exceptional and unforeseeable reasons meeting the requirements for a derogation, this explanation should come from the operator for the flight.
The logic behind the slightly tighter restrictions for commercial movements in the general aviation category, in particular in the case of business jets, is that the residents around the airport can justifiably be annoyed by very late, or even very early, movements of aircraft which can make the same noise as large commercial aircraft but carrying only a very small number of privileged passengers. This would be actually one step on the way towards what the AIG has already mentioned as a future development, namely the suppression, between 06h and 22h, of takeoffs and landings for the complete category of general aviation.
4. Exceptions
There are already exceptions laid down in the OFAC rules and regulations, which are laid down in article 39d (Dérogations) of the OFAC “Ordonnance sur l’infrastructure aéronautique”. Included in this article is the possibility for the AIG to grant derogations for cases which would not normally qualify for one, but the rule is that these may only be granted in cases involving exceptional and unforeseeable causes. Obvious examples might be extreme meteorological events, industrial action (strikes) in major airports or countries, breakdowns in air traffic control systems and so on.
One case which could reasonably request special treatment is that of what are normally the first and last movements each day, namely the flights of Swiss Airlines to and from Zurich, which acts as a genuine hub through which passengers may transit to a connecting flight with automatic transfer of baggage.
It has to be recognised that on some occasions an airline operator may justifiably claim that there were exceptional circumstances which make it rather unfair on them to have to pay a significant noise surcharge. For instance, in the cases of exceptionally heavy snow during the winter of 2009/2010, the AIG has justifiably felt able to grant derogations for flights after 00h30. In such circumstances, it might be permissible for the AIG to waive the extra noise surcharge payments. This, if permitted, should require that the AIG inform OFAC of each aircraft movement for which the noise surcharge has been waived. The same detailed information for each movement should be recorded in the monthly report distributed to the CCLNTA.
5. Unwelcome exceptional movements
The monitoring done by the ARAG movements monitor has shown up a number of exceptional, and highly annoying, events which have produced an unacceptable level of noise late, sometimes very late, at night.
The most longstanding of these exceptional movements has been that of the departure of an Airbus 340-300 to Mauritius. This is an aircraft which, when full for a long-distance flight, can climb only slowly and noisily: measurements show that when it leaves on runway 23 over Vernier it is virtually always by far the noisiest movement of the day. Furthermore, statistics show that it is late by an average of over one hour.
During the winter of 2008/2009 this was a direct flight to and from Mauritius, scheduled to leave Geneva at 18h30 every Friday night. However, during the winter of 2009/2010 it has been scheduled to come to Geneva via Frankfurt, and then depart at 22h30, sometimes twice per week. The inevitable result has been numerous departures very late (after midnight, even well after the 00h30 delay margin limit.
If the proposition detailed here were adopted then the flight should normally be scheduled before 20h, and the limit for a departure without derogation would be 22h30. This would then force Air Mauritius to decide to schedule a direct flight, to and from Geneva, Frankfurt or elsewhere. If it were elsewhere then Geneva passengers would use an intermediate flight (as is very normal accessing intercontinental flights).
The second case of an exceptional movement was that of a cargo flight to China by a Boeing 747-400 of Jade Cargo International. Despite being described on the AIG web site as being “of a new generation and therefore producing less noise and less pollution”, this aircraft, which is in noise class II, makes even more noisy than the Airbus A340-300 of Air Mauritius. In addition, it sometimes took off well after 22h. In response to a query, OFAC stated that since the departure had been scheduled for 21h55 the aircraft could actually depart until the end of the delay margin period, i.e. 00h30.
As with the flight of Air Mauritius, with this proposition it should normally have been scheduled for 20h at the latest, with a limit of 22h30 for takeoff without a derogation. This would evidently have been possible, since the last recorded departure of this flight in 2009 was at 13h42 on the 11th December.
6. The effect on airlines based in Geneva
It is natural to wish to evaluate the possible effect on the operations of airlines based in Geneva, since they would be likely to be affected. Currently (February 2010) there are three such companies: Baboo, Easyjet and Swiss Airlines. By using the data gathered by the ARAG movement identification system , an evaluation has been made for the whole year (2009), for the first two months of 2010 and for an individual week in 2010 (February 15-21 2010). The details of this analysis are contained in a separate document, from which the following remarks are extracted.
6.1. Baboo
Baboo has 5 aircraft based in Geneva: two DHC-8 turboprops and three ERJ-190 Class V jet aircraft. These aircraft normally make three rotations per day, for which they are not usually airborne for more than 10 hours. They are not scheduled to leave before 7h and are often scheduled to return before 22h. Their overall punctuality record is quite reasonable, so the effect on Baboo of these propositions would be very minimal.
6.2. Easyjet Switzerland
Easyjet Switzerland currently has 9 aircraft based in Geneva, of which 8 are Airbus A319, the other being an Airbus A320 used for longer distances. All are very modern Class V aircraft.
About half of the aircraft make three rotations per day, the others making 4 rotations. They are scheduled to be in the air for 12 hours per day on average (much more than Baboo and Swiss Airlines) and the scheduled turnaround time (the time between scheduled arrival at an airport and scheduled departure) averages just over 30 minutes.
About half of the aircraft are scheduled to leave between 06h and 07h, with the other half leaving in the following hour. In terms of arrivals at the end of the day, almost all are scheduled between 22h and 23h, the remainder being prior to 22h.
Because of the commercial desire of Easyjet to have all aircraft airborne as much time as possible, with very short intervals between landing and takeoff, the punctuality record of Easyjet flights leaves much to be desired. In particular, the fact that about one third of returning Easyjet flights, scheduled for around 22h30, actually land after 23h00, is disappointing. Thus, to reduce significantly the number of late, sometimes very late, Easyjet movements, the company would have to rethink its scheduling policy.
6.3. Swiss
Swiss Airlines appear at the moment to have three aircraft based in Geneva: an Airbus 319, an Airbus 320 and an AVRO RJ100. All are in noise class V and all do typically three rotations per day. However, on average they spend less than 11 hours per day in the air and their turnaround time is about 45 minutes. This permits some catching up of small delays, so that the overall record of punctuality for Swiss Airlines aircraft is very good.
As already mentioned, the Swiss Airlines flight LX2818 from Zurich, scheduled to arrive back at 23h15, may be considered as a special case. It is. This flight has an exceptionally good punctuality record: in the whole of the 356 recorded landings in 2009, 37.3% were ahead of schedule, 48% not more than 15 minutes late, 9.2% between 15 and 30 minutes late and 2.8% between 30 and 45 minutes late (i.e. before midnight). On only 6 nights did it land after midnight, and on only one of these 6 was it after 00h30 (19 December 2009, a very weather-disturbed evening).
7. Considerations for the future
It is expected that new aircraft will be more efficient and create less pollution and less noise. The airlines would surely be encouraged to move rapidly to these newer aircraft (at least for Geneva flights) if they had to assume that the noise classification will be reviewed on a regular basis and may include demotion of certain older aircraft.
One major concern is the announced intention for the building of a new terminal for long distance flights. It is envisaged that newer, smaller, aircraft with long-distance capabilities may mean that some routes could become economically viable for a smaller number of passengers. However, even these smaller aircraft will probably carry upwards of 200 passengers, plus a full load of fuel. Experience with the current noise measurements shows that, even for aircraft in Class V, the noise at takeoff is noticeably greater for long haul flights than that for short haul flights around Europe.
A further worry is also the stated intention to negotiate flights to Asian destinations. Quite understandably in view of the time differences, such flights tend to be scheduled as late as possible in the evening (this is also frequently the case for departures towards the south!). As an example, for such departures from Zurich there are typically about 5, which are scheduled between 22h30 and 23h every night. However, fortunately for the residents living around Zurich airport, they tend to have a good record for departing on time!
At Geneva, as explained above, the current experience of long haul flights leaving late at night has been nothing less than disastrous: noisy aircraft and departures frequently well behind schedule. It should therefore be a priority that the management of the AIG be obliged to discuss the details of routes and aircraft BEFORE the exact schedules are fixed (to avoid a fait accompli!). In this respect, the open letter to the Director, Robert Deillon, sent on the 29 November 2009, represents an attempt to create a reaction: so far, there has been none.
8. Conclusions and summary
It is believed that he proposal described above would have a beneficial effect and would contribute greatly to ensuring that the level of nuisance caused by early or late aircraft movements, in particular those performed by aircraft not in the class of least noise, would not show any significant rise from current 2009/2010 levels: it might even fall.
It is also believed that the proposal is in no way incompatible with the various proposals for different curfews which are under discussion.