Aanvullende raadpleging Balanced Approach Schiphol

Reactie

Vraag1

As local and international stakeholders, including professional service providers and individuals which use Schiphol Airport to connect with the rest of Europe and the world for business, we are deeply concerned on the proposed updated package of measures and the whole reasoning behind this “forced capacity reduction” approach initiated by the Dutch State since June 2022.
As we would like to submit a constructive consultation response, given the explosive nature of our findings and conclusions summarised above, we suggest to stop this update process, withdraw the current package of measures and design a new one along the following principles of the formal Balanced Approach procedure:
1 “ noise at source” include all historical and “standard” fleet renewal since 2002
2. “land use” include restrictions on new housing developments at/near the border of the 58Lden noise contours etc. and be consistent in using latest “woningbestand” with many new houses realised since 2002 just outside the LIB restriction area’s, which will fall into noise contours with small scenario changes (due to modelling effects) and will further limit capacity for aviation.
3. “operational measures” fly quieter procedures as more CDAs / NPDAP2 % in noise calculations by consultants instead of current “worst case” approach
4. only as a last a final resort, consider if capacity restrictions are required and proportional to reach a transparent and full realistic argument new policy objective:
a) marginally compliant Ch3/Ch4 restrictions (13dB) night or night & evening period
b) night restrictions in volume (27k or something from night package after impact analyses)
c) cap restrictions during actual off-peak periods during afternoon or late evening
d) generic cap restrictions Lden period
see other 7 pages of our full consultation response for more details, arguments, questions and suggestions.

Bijlage