Pre-consultation on 19 million passengers

Trojan Horse pre-consultation now closed

The pre-consultation on this Trojan Horse project is now closed and the Airport will consider the feedback gleaned from a trivial Survey Monkey. What they’re hiding beneath the claims that this is “only a million more” is far more environmentally unfriendly: to set aside the noise footprint planning limits so they can fly 50 noisy planes per 24 hours more than are properly permitted under the planning agreement they signed up to.

What are they doing and is it justified?

Luton Airport’s operators LLAOL have now completed a pre-application consultation to increase capacity to 19 million passengers. Their aim is to break through the democratically agreed planning limit capping them at 18 million passengers until 2028, and exceed the noise footprint limit instead of attracting quieter aircraft. These limits were designed to protect quality of life for local residents and to ensure balanced growth of the Airport.

During the past 7 years, the Airport has been incentivised by Luton Council to grow faster than the balancing noise reductions could keep up with. As a direct result, the Airport broke its noise footprint limits in 2017, 18 and 19. COVID-19 has reduced passenger numbers, but over the expansion period the net result is about the same as if the Airport had expanded at the rate it originally consulted on. In 2013 they claimed this would deliver jobs and local economic benefit, so any increased limit is clearly not needed.

Certainly there is no need to increase the planning limits due to pressure on resource or any constraints currently being reached. Passenger numbers are reduced and the post-COVID recovery period gives a chance to build a better aviation industry, not constantly to prioritise a bigger one.

And as we all know, climate change is an increasingly serious issue which affects everyone, and aviation is a major contributor to carbon emissions. 96% of Luton Airport’s emissions are from aircraft and vehicles carrying passengers. In the short term, the only way it can control these emissions is to control passenger capacity, which is what the current planning limits do.

What questions were they asking?

The pre-consultation asks the following top-level questions:

  1. What comments do you have on our plans for increasing the airport’s capacity from 18 to 19 million passengers per annum (mppa)?
  2. Do you have any comments on how we should manage the effects of our proposals on the environment and local communities?
  3. What opportunities are there to enhance the local area through our proposals for 19 mppa?
  4. Do you agree that the proposals will help to support regional prosperity and economic growth?
    a. Yes
    b. No
  5. Do you have any comments on any of the documents provided as part of this consultation?

The questions need to be answered carefully. For those concerned about the need to control noise, emissions and traffic levels, we’ve given a top-level example response below, followed by some more detailed information for those who are interested. We now call on the Airport to take this feedback on board and cancel the project.

  1. What comments do you have on our plans for increasing the airport’s capacity from 18 to 19 million passengers per annum (mppa)?
    The proposed increase is unjustified and we strongly oppose it. Planning permission in 2013 set limits on passengers and on the noise footprint, and government policy requires balanced growth. Luton Airport committed to noise mitigations which it has not yet delivered: instead it knowingly breached its noise contour limits in 2017, 18, 19. Until the Airport shows that it can operate at 18 million passengers within its noise limits, further capacity growth is unwarranted.

    Climate change is an increasingly important concern, and the Committee on Climate Change made clear last year that aviation growth targets must be at least halved to achieve net zero. Luton Airport has had seven years of over-rapid capacity growth; it has benefited commercially from that; now it needs to rebalance and focus on becoming more environmentally responsible rather than continuing to seek to grow. Luton Borough Council has declared a climate emergency and this must inform decision-making regarding the Airport, a major source of carbon emissions.

  2. Do you have any comments on how we should manage the effects of our proposals on the environment and local communities?
    Your proposals should be withdrawn for the reasons given above. “Managing the effects” has no meaning – and the Airport has failed for the last 7 years to “manage the effect” of its over-rapid growth. Noise limits have been breached, therefore noise management has failed. No credible plan has been put forward to reduce noise. The Airport has knowingly been operated in contravention of its Noise Action Plan (which commits it to operate within noise contour limits). In short, LLA has no credentials whatsoever for claiming it can manage noise and environmental impact. All it can offer is noise insulation for those living closest to the airfield – which is of no use when they are outside or want the windows open – and bribes by way of community funds.

  3. What opportunities are there to enhance the local area through our proposals for 19 mppa?
    There is no need to enhance the local area by adding further capacity: the planning consent in 2013 for 18 million passengers gave ample opportunity for additional jobs and revenue, as the consultation reports at the time explained. The proposals will cause additional pollution from extra passenger journeys, put additional strain on surface transport when numbers of commuters rises to pre-COVID levels, and encourage the use of larger aircraft which are noisier and when not fully laden less efficient than smaller aircraft. To enhance the local area, the proposals should be withdrawn and LLA should focus instead on demonstrating that it is reducing its noise and emissions.

  4. Do you agree that the proposals will help to support regional prosperity and economic growth?
    a. Yes
    b. No

    No. Keeping people awake at night due to 9,500 night flights, waking people early in the morning at 6:00 or before, permitting late-running arrivals to land until the early hours of the morning all damage the local economy by causing tiredness and ill health.

  5. Do you have any comments on any of the documents provided as part of this consultation?
    Much of the information is presented in a selective and unbalanced way.

    The Consultation Document talks extensively of “sustainability” but it redefines sustainability as “taking a balanced and considerate approach to environmental,economic, and social aspects of the work we do, with an aspiration to be leaders in sustainability.” This is a circular definition with no measurable goals, and no evidence is provided of any balance or consideration to date – see above. Luton Airport has not delivered “sustainable growth” in its over-rapid expansion since 2013, and provides no evidence as to how it will do so now.

    It also states that this is the only publicly owned major UK airport. In that case LLA ought to be above reproach, yet its behaviour and that of its owner have been reprehensible since 2013. Despite appointing LLAOL to run the Airport, the Council chose to interfere in the growth and type of airline customer through its Growth Incentivisation Scheme. Despite a legal commitment to scrutinise the Airport’s performance against its Noise Control Scheme, the Council turned a blind eye as the noise conditions were breached, and the Airport failed to account for the breach in a truthful manner.

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Further comments on the Consultation Document

We oppose the plans on grounds of the adverse environmental impact and lack of justification for any change to the existing planning limit of 18 million passengers until 2028. We summarise our comments on the Consultation Document as follows:

Page 3 says the Airport is “committed to working closely with our neighbours to balance the economic benefits of the airport with the impact it has on people who live nearby.” The evidence of the past 7 years shows this to be untrue, since the Airport knowingly breached its noise limits in 2017-2019. No evidence is given as to how balance will be achieved.

The document talks extensively of “sustainability” but at the end it redefines sustainability as “taking a balanced and considerate approach to environmental,economic, and social aspects of the work we do, with an aspiration to be leaders in sustainability.” This is a circular definition with no measurable goals, and no evidence is provided of any balance or consideration to date – see above. Luton Airport has not delivered sustainable growth in its “dash for cash” since 2013 and provides no evidence as to why it will do so now.

Pages 4 talks about the economic benefits of the Airport to the local area, and the need to plan for growth. In 2013 the Airport told the same story about the economic benefits which would accrue as it expanded to 18 million passengers over 15 years. In its greed to expand twice as fast as that, in an unbalanced way, economic benefit has been delivered too soon to be sustainable, and the COVID impact has been worse as a result. The Airport now needs to return to balanced and sustainable growth on the originally permitted trajectory.

An “update to noise contours” is not an operational change, it is a fundamental shift in the balance between commercial growth and the mitigation of environmental impact. The government requires these two to stay in step – Luton Airport clearly disagrees.

Page 8 states that this is the only publicly owned major UK airport. In that case it ought to be above reproach, yet its behaviour and that of its owner have been reprehensible since 2013. Despite appointing LLAOL to run the Airport, the Council chose to interfere in the growth and type of airline customer through its financial incentivisation deal. Despite a legal commitment to scrutinise the Airport’s performance against its Noise Control Scheme, the Council turned a blind eye as the noise conditions were breached, and the Airport failed to explain the breach in a truthful manner. Neither can be trusted, and this matter should be reviewed by the Secretary of State.

Page 9 mentions the LLAL plans to expand the Airport to 32 million passengers, which if successful would sweep away the need for any short-term measures. This current exercise should be halted until the Development Consent Order (DCO) proposed by LLAL has either been been cancelled or has been completed, submitted and decided. Given the drop in passenger numbers post-COVID there is no requirement or justification for short-term expansion it, and indeed it looks like a cynical move which will create “consultation fatigue”.

Page 10 states that the application will be decided by the Council’s Planning Committee – yet the Council is fatally conflicted by being both the owner and planning authority for the Airport. The External Auditor has already demonstrated that there is inadequate clarity in Council decision-making in relation to the Airport, and the actions of LLAL in gagging Councillors on its Board have exacerbated this.

Page 12 shows pre-COVID forecasts for 2020. These are completely meaningless now and serve simply to mis-inform consultees. Condition 10 (noise contours) is mentioned, and the Consultation Document misleadingly states that passenger numbers cannot be increased to 19 million within the limits. This is untrue: the Airport has produce a strategy for reducing the noise contours below the current limits for 18 million passengers by 2028, thus providing headroom in due course. The only reason for wanting to rush ahead now is commercial greed, out of balance with environmental impact.

Page 13 purports to trivialise the impact of the noise contour increase. It alludes to measure which proved ineffective in avoiding the breach in 2017, 18, 19 and it only uses one measure (Leq) to characterise the noise impact whereas it is well-known that multiple measures (including for example numbers of aircraft at different peak loudnesses) are required to give a fair and balanced picture.

Page 14 indicates that two planning conditions relating to parking limits and parking areas will also be affected, but gives no information about what the new Travel Plan or Car Park Management Plan will be. Hence it is not possible to provide any comments, except to note that any increase in parking provision goes against the commitments to achieve a modal shift onto public transport.

Page 15 talks vaguely about Air Quality but gives no information about air quality breaches on the airfield site. Neither is there any firm indication of when the DART will open (its finances are in some jeopardy). There are aspirational statements about car usage but no firm commitments, or indication of how passengers will travel east/west to and from the Airport without using cars or taxis.

Page 16 ignores the clear warning from the Committee for Climate Change in 2019 that aviation must reduce its growth aspirations by at least half to achieve net zero. It also ignores Luton’s own Climate Emergency declaration. This proposal involves an unnecessary and unwarranted increase in emissions and should be withdrawn. The resources should be diverted instead to completing the FASI(S) Airspace Change project and demonstrate a significant reduction in emissions and noise at Luton Airport as a result.

Page 17 states that Luton Airport is conducting an assessment of human health effects of expansion. This is crass: the effects of aviation noise an emissions on health are well documented and are being researched by experts including Kings College London and the WHO. And if Luton is doing its own study it should await the outcome before considering further growth. Otherwise it is clearly predetermining the issue.

Page 18 is essentially hogwash from start to finish: weasel words crafted to make it look as if the Airport has done all it can to reduce the impact of noise, whereas since 2013 that impact has increased year-on-year in line with its faster-than-permitted growth (because it caused a breach of planning conditions). Demand was self-inflated by reducing charges to airlines – this was not due to “pessimistic forecasts”. Page 18 proves that Luton Airport does not care about actually reducing its noise impacts, but believes very much in pretending it cares.

Page 19 is equally untruthful: all of the mitigations have been tried and yet the noise contour breaches got worse. The latest so-called “less noisy” A321neo aircraft are actually measured as being noisier. the only reason the Airport has been “compliant with planning limits in 2020” is due to the reduction in passenger numbers due to COVID. So it is clear that a reduction in passenger numbers is what is required until the Airport has delivered provable mitigations.

4 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!

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