Application for 19 million passengers and more noise

This application has been called-in for determination by the Planning Inspectorate

Luton Airport applied in 2021 to increase its noise footprint and permitted numbers of passengers. It seeks this permission in order to legitimise its three-year breach of noise planning conditions, which started in 2017 and was only halted by the pandemic. The steadily worsening breaches were caused by over-rapid growth before sufficient less noisy aircraft had been introduced.

Luton Airport’s owner, Luton Borough Council, benefits financially from the Airport and along with its airport company Luton Rising incentivised the Airport operator to sign up “growth” and “super growth” airlines. The capacity grew twice as fast as the Airport operator’s original commitment, resulting in non-permitted noise impacts on residents, extra emissions from as-yet unmodernised aircraft, and excess emissions from thousands of passengers still travelling in cars.

Nevertheless Luton Borough Council agreed in December 2021 to relax the planning conditions designed to protect residents and the local environment, justifying this decision on economic grounds. It overlooked the fact that the 2013 expansion plan to reach 18 million passengers was confident of delivering sufficient economic benefit and jobs in and around Luton until 2028.

People concerned about quality of life around the Airport overwhelmingly objected to this application. This is not just about “another million passengers”: the permission they seek would allow excess flights and emissions to continue.

Many people recall waves of aircraft starting before 06:00 and running on into the small hours of the night, with barely a couple of minutes between them at busy times. Others moved to the area when it was bearable, but the rapid increase in flights, noise and traffic congestion near the Airport really reduced their quality of life. People are frustrated and angry by the lack of control, feeling that the Airport chases commercial opportunity regardless of its promises to balance growth by measures which reduce noise.

Reasons people opposed the application

The additional environmental impact is against planning policy
Luton’s Local Plan policy LLP6 states that the Airport should achieve noise reduction, or no material increase. This application would cause significant noise increase for 1,877 homes. LLP6 requires appropriate mitigation. The application offers noise insulation which does not work if people need to have windows open at night.

LLP6 requires effective noise control, but the Airport has been operated in breach of its noise controls for three years. LLP6 also requires significant diminution over time of the effects of airport operations on the amenity of local residents. This application would increase those effects for years to come and never achieve the noise footprint reduction originally agreed to.

This application should be rejected because it does not conform to the Local Plan LLP6.

Aircraft noise at night is harmful to health
Many research studies have concluded that aircraft noise at night is directly harmful to health. The largest increase sought by this application is to the permitted “noise footprint” at night, up by 5.7sqkm compared to 2.2sqkm by day. There has already been a 6-fold increase in night flights, up from 500 to 3,000 between 2013 and 2019.

In 2019, when the Airport reached its 18 million passenger capacity limit, early morning flights started before 06:00, waking people up. Arrivals went on into the late evening and the small hours of the night, disturbing sleep. Cargo flights during the night also wake people up. All this increases stress, leading to high blood pressure, strokes and heart attacks. The chances of accidents on the road or at work are also increased if people are tired.

This application should be rejected because it would harm public health.

The Carbon Reduction Plan omits aircraft emissions
Carbon emissions are a critical issue because of climate change. Luton Borough Council is committed to becoming carbon neutral by 2050. Most people travel to the Airport by cars and taxis because public transport links are limited. Adding further to surface transport emissions, and to aircraft emissions which count towards the national carbon budget, is against the advice of the Climate Change Committee and the UN IPCC.

This application should be rejected because it is unsustainable in climate change terms.

The need for the application has not been justified
Luton Airport is only half way through the 15-year growth plan it agreed to in 2013, which included legal agreement to noise control conditions which required growth and economic benefit to be balanced by mitigation.

By 2019 there were supposed to be just 12.9 million passengers: in fact there were 18 million, the number projected for 2028. COVID-19 reduced passenger numbers to around 6 million in 2020 and it will take some years to recover. Going forward there should be a properly controlled and noise-mitigated operation within its planning controls.

The Airport operator has already promised but not yet delivered environmental impact mitigations such as more of the less noisy aircraft, more passengers using public transport, and continuous climb for all departures

The application should be refused because it exceeds what is permitted or necessary.

The Council has unresolved conflicts of interest
Luton Borough Council and its airport-owning company LLAL financially incentivised the over-rapid growth which led to Luton Airport breaching the Council’s planning conditions. The Council undermined its role as Local Planning Authority responsible for enforcing planning conditions to protect residential amenity.

The Council did not provide governance arrangements to ensure separation of roles: the Board of LLAL comprises Council Members, and Robin Porter was simultaneously the Chief Executive of the Council and Chief Operating Officer of LLAL.

Members of the Council who sit on the Board of LLAL are prohibited from publicly criticising any of its decisions, yet LLAL oversees the spending of tens of millions of pounds of public money without any public scrutiny or accountability.

This application should be rejected because it arises from a failure of scrutiny and proper enforcement by a conflicted Local Planning Authority.

The application is not sustainable
Over-rapid capacity expansion has led to additional disturbance, noise, air pollution and carbon emissions before balancing mitigations were in place.

The airport has not yet introduced the necessary proportion of aircraft with modern, more fuel-efficient and less noisy engines to operate at 18 million passengers within its agreed noise footprint, let alone 19 million.

The carbon impact of this imbalance has been exacerbated by a failure to deliver airspace redesign so aircraft can climb continuously. Departures are often held low for up to 15-20 miles causes additional noise, emissions and low-level air pollution.

The modal shift of passengers from cars and taxis to public transport has not yet occurred sufficiently to have an impact on the 97% of its emissions over which the Airport has no direct control.

COVID-19 has delayed airspace modernisation and aircraft fleet modernisation. There is no clearly evidenced plan or timeframe in the application for reducing environmental impacts: forecasts in the application are already out of date.

The application should be rejected because it does not provide certainty over reducing environmental impacts of noise and emissions. Government policy clearly states out that environmental impacts must be addressed in parallel with growth.

Economic benefits can be delivered without this capacity expansion
Airport growth can create jobs and local economic benefit, and the scale of those benefits were described and agreed when planning permission was granted in 2013 for a 15-year steady expansion to 18 million passengers.

The windfall additional revenues caused by the recent double-rate growth should be invested in diversification, given the economic impact of COVID-19 and the risk to prosperity in Luton by over-reliance on the Airport.

Luton’s economic future would be more sustainable if it diversified rather than pouring yet more money into an Airport which is not well sited, has poor east-west transport links, and has failed to show that it can be relied on to deliver environmentally balanced sustainable growth.

The economic benefits of growth to 18 million passengers were agreed as sufficient in 2013, and the Council should refocus on achieving that in a way which is economically resilient and environmentally sustainable.

This application should be rejected because it does not evidence why an 18 million passenger capacity is insufficient for economic benefit.

The Council failed adequately to scrutinise the Airport
The Section 106 legal agreement requires the Airport to pay the Council £15,000 each year for the Director of Planning to monitor its performance against the Noise Control Scheme. The Council failed to do this adequately and did not step in quickly enough to prevent noise limits being breached.

By 2019, over-rapid growth brought the Airport up against its passenger throughput limit as well. Despite its attempts to regain control, it failed to do so – in fact only the COVID restrictions have brought the operation back inside its legally agreed limits on noise and passengers numbers.

This application should be refused, because to permit it would bring local planning control into disrepute.

The application is premature and ill-founded
The application includes a Master Plan for the Airport, which has not been separately reviewed by external stakeholders or consulted on. The evidence used to underpin its proposals, including whether mitigations are adequate, has not been shared.

A Master Plan should dovetail with a Noise Action Plan. Luton Airport’s 2019 Noise Action Plan contains incorrect statements that the Airport will be operated within its noise contours, made at a time when it had already breached them.

It is unclear when demand for air travel will return to pre-COVID levels, and the forecasts quoted in the application are already out of date. Without accurately based forecasts, there can be no certainty attached to outcomes.

The application should be rejected on grounds that it is premature and ill-founded, and its forecasts cannot be relied on with any confidence.

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5 comments

  1. Wizz Air are still aggressively adding new routes to their offering. There are spare slots available at Gatwick, so Luton is desperate to show it still has headroom if numbers return to pre-COVID levels. This is a cynical move to eliminate any disincentive for introducing new flights from Luton, and smooth the transition into a post DCO nightmare of rapid growth towards 32 million passengers a year. It’s the thin end of the wedge towards non-stop growth without a second thought for the residents who these five threatened planning conditions were designed to protect. Shame on Luton Borough Council for incentivising this reckless growth!

  2. Thank you for this page. I shall make a donation.

    Here are my responses , which may be of use to others.
    Q1.
    I object strongly to this. Already, Luton Airport exceeds acceptable noise contour limits and increasing the airport’s capacity will make this worse. Your Masterplan refers to likelihoods eg of ‘more modern and quieter aircraft’; these are not certainties and therefore offer no assurance that there will not be a further increase in noise levels under your proposals.
    With regard to the impact of the aviation industry on climate change, and in particular the effect of the rapid growth of Luton Airport, a further increase in the airport’s capacity can only have a detrimental effect. I believe that Luton Airport should show more responsibility to the environment, recognising that aviation growth targets must be at least halved to achieve net zero, as the Committee on Climate Change has made clear,.

    Q2.
    The only way is for you to withdraw your proposal. In your masterplan you admit that ‘the generation of airborne sound is an inevitable consequence of airport operations’. This is driven home to us every day in the early hours by the noise of aircraft flying to and from Luton Airport over St Albans. How much worse it must be for people living closer to the airport.
    The masterplan makes no clear or credible plans to reduce noise; instead it relies on ‘increased utilisation of new generation aircraft [to] be a principal means of … meeting the noise requirements’. As pointed out above, this offers no certainty. The masterplan also admits that ‘the 19 mppa increases the number of dwellings exposed’ and further that ‘it is not considered that the proposed increase to 19 mppa is not expected to result in significant noise effects at most noise sensitive receptors’ ie that significant noise effects can be expected. Your proposed solution to this is to increase your contribution to the Noise Insulation Fund (masterplan 6.2.14). This is of no use to residents who want to spend time outdoors and have their windows open.

    Q3
    There are none. You should withdraw the proposals and instead work on reducing your present noise levels and impact on local traffic.

    Q4
    No

    Q5
    They are dense and demanding to read thus not easily accessible to us, the public, who are affected by your proposals. They are also couched in language that obfuscates, for example the double negative quoted in my response to Question 2, and include little in the way of measurable goals or evidence to show a commitment to reducing the environmental impact of Luton Airport.

  3. EXAMPLE RESPONSE – DON’T FORGET TO USE THE SURVEY LINK OR EMAIL ADDRESS FROM THE PAGE TO SEND IN YOUR RESPONSE TO THE AIRPORT!
    Q1. These proposals are deceptive. Whilst apparently seeking a minor increase from 18 mllion to 19 million passengers, they are in reality a Trojan Horse to nullify and get round the noise limits set down in conditions to the planning consent granted in 2013.
    It seems bizarre to consult on any proposed expansion, however minor, at a time when it is by no means certain that air travel can or indeed should return to the levels prior to Covid let alone increase beyond that level.
    Climate change is a greater concern now than ever before and aviation should first seek to be environmentally responsible before seeking further growth. It is generally accepted that post Covid there will be a ‘new normal’ and we will not simply return to the situation before the pandemic – and that includes air travel and aviation.
    Q2. Your proposals should be abandoned for the reasons above. The airport has failed in the past to “manage the effects’ of its over-rapid growth. To operate knowing that planning conditions were being flouted suggests that management in the future would be no better than management in the past. Presumably the airport will again rely on speculative forecasts for the introduction of new and quieter planes at a time when all airlines are struggling financially and unlikely to increase investment in new planes.
    Q3. The 2013 planning consent gave ample opportunity for extra jobs and revenue. A minor increase in passenger numbers can only bring minor benefits while doing nothing to mitigate the noise polution and environmental damage caused by the wilful flouting of planning conditions.
    Q4. No. It is an old saying – avoid putting all your eggs in one basket. Supporting regional prosperity and economic growth by seeking to expand an industry suffering severe economic problems with an uncertain future is simply short-sighted and widely optimistic. Creating further environmental damage in the area will only discourage the development of other worthwhile economic activity. Property values will decline along with the physical and mental health of local residents.
    Q5. The documents appear one-sided and designed to support a cause rather than present facts. No evidence is provided as to how the airport will deliver sustainable growth even after a re-definition of sustainability. There are no attempts to set targets or measure the effects of the proposals.

  4. If there is any truth in the concerns over the environment, one would NEVER consider making the problem worse. Why should ANY of us be cutting our personal emissions if the government is allowing and the airport operators are requesting any increase, massively worse than what we collectively produce? It is pure unadulterated greed by Luton Borough Council, who were only a few months ago were begging for a government bailout because of their collapse in revenue! There is now a massive oversupply of slots not being used at Gatwick, Stanstead, Heathrow and Luton, so besides the above arguments it simply does not add up!

  5. As a resident of Childwick Green I wish to register my objections to recent proposals regarding extension of the airport, the flight path and the resulting horrific increase in flights.
    The increased impact of noise and pollution will have a profound effect on residence in the surrounding area.

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