Detailed comments on the consultation questions

5) Which of the following best reflects the extent to which you support or oppose the expansion of London Luton Airport? Please select one option: Strongly support, Slightly support, Neutral, Slightly oppose, Strongly oppose, Don’t know. Please provide us with the reasons for your response.

We strongly oppose the further expansion of capacity at Luton Airport. Existing expansion to 18 million passengers is not yet complete, and the promised noise mitigations have not been delivered. Further significant expansion would have very great environmental impacts which are not justified by the claimed economic benefits. The existing cap on passenger numbers was stated in 2013 to be sufficient to underpin the local economy: now Luton Borough Council should diversify the local economy in a genuinely sustainable response to its own declaration of a Climate Crisis.

Capacity at Luton Airport expanded very rapidly between 2013 and 2019, financially incentivised by Luton Rising and Luton Borough Council. This expansion was not properly managed or scrutinised, and failed to deliver the promised noise mitigations to balance growth. The airport operator broke its noise contour planning limits, and rapid growth contributed to serious congestion on local roads, and caused fly parking all around Luton. Releasing too many slots before quieter aircraft had been introduced has led to airlines being able to hold the airport to ransom with the threat of going elsewhere if additional growth is not offered. This is not appropriate justification for further expansion.

People living closest to the airport were hardly able to cope with the incessant noise starting before 6am and going on until the small hours. The only mitigation offered was double glazing for those closest, which required them to keep their windows closed on hot nights in the summer. The Luton Local Plan requires noise reduction before further expansion, but was ignored. The Council set a passenger cap of 18 million per year until 2028 to protect residential amenity. This was also ignored – the airport operator applied for an increase to 19 million and the Council agreed it in 2021. Because of the conflicted position of the Council as owner and financial beneficiary of the airport, this lack of control over the non-permitted development of the airport does not appear to meet the high standards of probity expected under Localism.

Luton Rising has consistently pressed for far greater passenger numbers than is reasonable for Luton Airport given its close proximity to local communities, its compact site, and its location on top of a hill. The business case for this proposed expansion to 32 million passengers is questionable, as are significant amounts of public money spent on investments such as the DART monorail. Luton Rising takes its decisions in secret and as a private company is not publicly accountable, yet the money which the airport generates is public money.

The Committee on Climate Change and the Intergovernmental Panel on Climate Change both strongly recommend urgent measures to reduce demand for air travel. Aviation has been the fastest-growing source of carbon emissions. Its emissions are three times more damaging to the environment because they also lead to contrails which add to warming, and release high-altitude pollutants. Aircraft engines burn huge quantities of kerosene and create ultra-fine particles which damage health. Noise at night also damages health. Traffic emissions damage health. An unstable climate caused by global warming damages people’s well-being. Yet Luton Rising is proposing a 78% increase in airport capacity at Luton.

Encouraging people spend money abroad by taking more and more cheap flights directly harms the UK economy, as well as the climate. Aviation’s contribution to the balance of payments deficit in tourism was £30bn in 2019 – far more than the local beneficial effects claimed for this project. If this proposal succeeds, Luton’s main income would continue to depend on a noisy and polluting industry which is not environmentally sustainable. It would benefit the local economy far more to be diversified towards developing renewable energy, battery technology and the skills to tackle the carbon footprint and heat loss from older housing stock, for example.

Concreting over the second-largest park in Luton to build a new terminal, extra car parks and aircraft stands is not Green growth – it amounts to destruction of a County Wildlife Site. Wigmore Valley Park was given to local residents as compensation for development and as an open green space to act as a buffer between houses and the runway. Its ancient hedgerows and wild orchids cannot be replaced by sterile farmland.

Why grow?
6) Do you have any comments on our Draft Need Case which sets out the reasons for our proposal to expand the airport?

The Draft Need Case is one-sided and does not present an up-to-date, balanced and properly evidenced case. Much of the information is based on out-of-date strategies which have not been properly reviewed to reflect the post-Brexit, post-COVID economy, nor the clear pressures for more urgent action on Climate Change called for by the IPCC. Much is made of the Oxford-Cambridge Arc, a project which is being called into question. Levelling up is a national policy, not just a rebalancing between the airports around London. The Jet Zero consultation results have not yet been published. However, the impacts of the Climate Change Act do not appear to have been taken into account, and there is as yet no comprehensive Planning Statement. Luton Airport is made out to be a centre of tourism and business travel, but at the same time it is admitted that the majority of passengers are visiting friends and family – no doubt migrant workers.

The Draft Need Case proposes to continue to invest in yesterday rather than to invest in tomorrow. The main reason it gives for further expansion is the “jobs and economic value” case. The same case was made in 2013 and it was agreed that capacity expansion to 18 million passengers per annum by 2028 would suffice. By expanding at twice the permitted rate, the Council and Luton Rising secured a huge up-front cash windfall which could have been invested in alleviating poverty in Luton and providing a broader local economic base. Instead, some £500 million was sunk into so-called strategic investments including the DART.

At some point the supporting infrastructure of an area applies a natural limit. In Luton Airport’s case, that limit is the transport network. To get to and from the airport from east or west relies on country roads or rat-runs through the housing estates of Luton. Currently only 14% of passengers use public transport. This is far below the aspiration of 40% with no clear indication how or why the predicted modal shift will be achieved. It is certainly not clear why having a monorail instead of a bus to ferry passengers to and from Luton Airport Parkway Station would persuade such large numbers of them to switch to using public transport.

The world is facing a climate crisis, and the UK Government has committed to achieving net zero by 2050. It has not yet addressed the question of how and where carbon reduction will occur, but aviation expansion will need to be considered as part of that. The Jet Zero consultation was based on aspirations that new technology will emerge that significantly reduces emissions from flying. The result of that consultation – and its effects on policy – have not yet been announced, and therefore its statements cannot be regarded as “policy” as the Need Case attempts. Neither is it yet clear whether and when a third runway at Heathrow will be built. What has been made clear is that “levelling up” is not intended to imply spreading aviation passengers between the near-London airports as Luton Rising claims.

It is also clear that:

  • ‘Sustainable Aviation Fuel’ is more expensive, and uses biomass which is required for animal feedstocks, so this is not sustainable
  • The post-Brexit, post-pandemic, climate-crisis world is a different place, with less business travel, less migrant workers and people thinking twice about flying
  • Luton Airport is very badly located for site expansion – it’s on a hill, and every time the infrastructure is extended, huge amounts of earth need to be moved
  • Luton Airport claimed that the jobs and economic benefits of the expansion in 2013 would sustain the local economy until 2028, by which time it would have mitigated the environmental impacts – it’s failed to do that
  • Luton Rising has borrowed hundreds of millions of pounds from the Council and has to service huge interest payments on the debts – now is not the time to be gambling on an uncertain future
  • Luton Rising has no firm idea how the £2bn of proposed work to develop the airport will be paid for

Much is made of the government’s Making Best Use policy for existing runways. If all airports made best use of their runways there would be far more capacity than the demand would support. All major airports are currently trying to cram in as much expansion as they can before policy wakes up to the need for restraint. Luton’s case is not attractive by comparison – this project is hugely expensive and comes with a track record of failed promises and broken noise controls. So-called ‘Green Controlled Growth’ simply repeats the broken promise of the past: having fixed limits past which the airport will not go did not work in 2017, 2018 and 2019 so there’s no confidence it will work now.

The expansion claims to be in line with emerging policy, but earlier this year the airport argued that emerging policy and policy trends on climate change could not be used to oppose expansion since they did not have any force. Luton Rising cannot have it both ways.

The plan promotes Luton as being at the centre of the Oxford Cambridge Arc, with economic projections of many thousands of jobs. It’s easy to produce such projections – it was done in 2013, and the predicted benefits of adding 9 million passengers were clearly not delivered otherwise there would be no need to continue adding more. Recent reports in trade press suggest that the Oxford Cambridge Arc project has failed to deliver and is falling from favour.

Benefits of expansion
7) Do you have any comments or suggestions for how we might maximise employment, skills, community and social benefits and training opportunities to help benefit neighbouring communities?

We oppose relying on expansion of capacity at Luton Airport in order to maximise employment skills, community and social benefits and training opportunities, because the aviation industry is currently unsustainable, and no new technology which provably makes it sustainable is yet available to the commercial low-cost airlines using Luton. To create a genuinely greener future Luton Rising should promote and develop skills and opportunities in areas that will help to avert the climate crisis, not contribute to making it worse. Luton Council has democratically declared a Climate Emergency. The stance of the Luton Councillors acting in the guise of Luton Rising in continuing to spend hundreds of millions of pounds of public money on airport-related projects and a DCO application to encourage a further £2 billion development of a kerosene-based industry, is fundamentally incompatible with that declaration.

The proposal plays up an investment in making the airport ground operations less energy intensive. Only 3% of the carbon emissions from the Airport are under its control – the rest depends on airlines which have already invested in aircraft technology which is not going to change significantly over the 20 years of this project. All energy-intensive business operations need to focus on reducing their carbon footprint – it would be far better for Luton Rising to invest in achieving that at Luton Airport without dwarfing any possible benefit by significantly increasing carbon emissions from the flights.

Luton and the Oxford/Cambridge Arc and the Local Enterprise Zone would be better served by investment of those hundreds of millions of pounds in creating new jobs in cutting-edge green technologies such as more efficient car batteries and heat exchangers for homes. Better to insulate houses against heat loss than to have to insulate them against ever-increasing aviation noise. Luton Rising is apparently squandering the money which Luton tax payers have a right to see invested in a sustainable future, with no democratic accountability.

Our proposed design for the airport
8) We have made changes to our design since the 2019 statutory consultation. Do you have any comments on our design proposals for the scheme?

During the non-statutory consultation, the overwhelming response from the public in more or less every category of question – despite the questions being unfairly loaded – was “no further expansion”. This reflects what people all over the region, feel: enough is enough. There have been too many broken promises and lack of probity over the conflict of interest between the Council as Local Planning Authority and the Council and Luton Rising as financial beneficiaries of the Airport in the last 10 years that we oppose further expansion and reject the designs Luton Rising is proposing.

In particular:

  • We oppose the sacrifice of Wigmore Valley Park, a County Wildlife site and an Asset of Community Value, which Luton Rising still proposes to concrete over and turn into a Terminal, aircraft stands and car parks
  • We oppose the plan to increase capacity to 32 million passengers per annum, which is almost as environmentally damaging as increasing to the previously suggested 36 million, for reasons already given
  • We oppose the addition of aircraft stands and a new Terminal in order to increase throughput and facilitate 45 flights per hour instead of the existing 33 due to the unacceptable noise and emissions impacts

Getting to the airport
9) Do you have any comments on our proposed Getting to and from the airport – emerging transport strategy? Do you have any suggestions for how we can maximise access to the airport by public/sustainable transport modes?

Luton Airport is badly sited for access by public transport. There is no east-west rail link and the north/south link is an already busy commuter line with no fast trains serving just the Airport. The Airport Operator has failed to achieve a meaningful modal shift and still only 14% of passengers use public transport, despite drop-off charges being substantially increased. How people choose to travel to it is not under the control of the Airport, and established patterns are unlikely to change substantially. No evidence has been provided as to why the DART would achieve the targeted modal shift. We oppose further expansion on the grounds that it would encourage additional surface traffic into an already congested local road network, increase pollutants and decrease air quality.

Building our airport
10) We propose to construct the scheme in two phases. Phase 1 would include expansion of the existing Terminal 1 and additional aircraft stands and car parking. Phase 2 would the see the construction of Terminal 2 and associated facilities. Do you have any comments on our proposals for constructing the scheme?

In opposing further expansion, we oppose additional development of the infrastructure. The existing expansion permission, granted in 2013, still has 7 years to run and has not yet delivered on its promised noise mitigations. The Airport and the Council have betrayed the trust placed in them, by breaching the Section 106 Noise Control Agreement and for three years failing to remedy that breach. The breach occurred as a result of rapid growth incentivised by Luton Rising and the Council, and by mismanagement of the rate of slot release by the Airport Operator. Such failures of oversight, regulation and management do not justify further expansion.

The existing Section 106 Agreement requires:

  • Operation of the Airport within its noise contours and 18 million passenger limit (also a 2019 Noise Action Plan commitment)
  • Production of a strategy to reduce the noise contours to defined lower limits by 2028
  • Mitigation of noise through the introduction of modernised less noisy aircraft

None of these things has been achieved, therefore it is inappropriate to expand capacity yet further.

11) Our proposals also include a Draft Code of Construction Practice which sets out in draft the measures we will take to minimise the effects of construction. Is there anything else you would like us to consider as part of this?

In opposing further capacity expansion we oppose the further construction which would facilitate it, and which itself would add to local emissions and and increased carbon footprint through the use of significant quantities of cement.

The environment
12) Do you have any comments on the environmental effects of expansion and how we propose to manage and mitigate them?

The overall effects on the environment, taking account of the aircraft emissions in flight, would be significant and detrimental. The additional noise impacts at source are not under the direct control of Luton Rising nor of an airport operator. Airlines choose which planes they will buy and fly, and fleet modernisation cannot be legislated. Luton has already experienced a problem with the latest A321 aircraft with more fuel-efficient engines, which are supposed to sound less noisy than the older types but in fact sounds just as loud. Pilots have suggested this is due to the comparatively short runway length. Therefore the community derives no benefit while the industry benefits from greater fuel efficiency.

The Noise and Vibration chapter 16 document confirms the unacceptably large noise impacts (our emphasis added):

16.9.80 The difference in air noise during the daytime period is due to an increase in commercial flights (freight and general aviation movements are unchanged) of approximately of 62%. The total increase in aircraft movements during the daytime period is forecast to be approximately 48%.

16.9.81 At assessment locations with air noise levels above the night-time Lowest Observable Adverse Effect Level (LOAEL) in the Do Something (DS) scenario, the difference in air noise during the night-time period at the locations presented in Table 16.17 resulting from Phase 2b of the Proposed Development is predicted to range from +1.4 to +2.7 dB LAeq,8h.

16.9.82 The change in air noise during the night-time period is due to an increase in commercial flights (freight and general aviation movements are unchanged) of 37 flights (ATMs) during the summer night-time period. This is equivalent to an increase in commercial flights of approximately of 76%.

16.9.83 By 2043, the majority of the fleet are forecast to be made up of new generation aircraft so the fleet composition for Do Nothing (DN) and DS scenarios are similar. The total increase in aircraft movements during the night-time period is forecast to be approximately 70%.

16.9.84 Due to restrictions on movements during the night quota period (from 23:30 to 06:00) the increase in movements during the night-time period will mostly occur in the periods from 06:00 to 07:00 and 23:00 to 23:30. These restrictions will be retained in future as part of the Noise Envelope (see Section 16.10).

16.9.85 There is a difference in population of +25,650 during the daytime period and +30,350 during the night-time period that experience DS noise levels exceeding the LOAEL but not exceeding the Significant Observable Adverse Effect Level (SOAEL). Changes in air noise are predicted range from +1 to +3 dB at all assessment locations. Consequently, based on criteria in Table 16.12, the population experiencing daytime noise between the LOAEL and the SOAEL are predicted to experience a Negligible to Minor Adverse effect, which is not significant.

16.9.87 There is a difference in population of +1,350 during the daytime period and +3,300 during the night-time period that experience DS noise levels exceeding SOAEL. Differences in noise are predicted to be range from +1 to +3 dB. These locations are illustrated in Figure 16.23 of Volume 4 of this PEIR by the area within the SOAEL contour experiencing a change in noise between 2 and 2.99 dB. This is equivalent Moderate Adverse effect for population experiencing noise levels above the SOAEL, which is significant.

This means by 2043 there would be 70% more flights at night (between 11pm and 7am) and 50% more during the day. 30,000 people would experience a noise increase at night above the level at which adverse effects on health and quality of life can be detected. 3,300 people would experience a significant adverse effect. We agree with many local people that this as an unacceptable environmental impact, adversely affecting lives and well-being.

The claim that the annual night flight numbers would be held constant at 9,650 is misleading since this refers to the ‘short night’ quota period between 23:30 and 06:00. Luton Rising plans to significantly increase the number of flights scheduled between 6:00 and 07:00 (the early morning shoulder period) and between 23:00 and 23:30 (a period where nearly all the flights are arrivals and are notorious for being delayed). There would therefore be a substantial increase in night flights (11pm-7am) which the brochure is not transparently clear about. Departures at busy times would start at 05:00 which is anti-social and unreasonable. Hiding such impacts in the detailed documents demonstrates that the public is right not to believe in the ‘good faith’ which Luton Rising claims to be showing towards communities.

13) Do you have any comments on our Green Controlled Growth approach?

Green Controlled Growth proposes that capacity expansion is permitted only when environmental limits are met. Recent experience has shown that neither the Airport Operator nor the Council (whose members run Luton Rising, or as it was then known LLAL), respected the existing planning limits. Therefore there is no reason to expect similar limits to be respected in the future, even though control under a DCO is by means of legislation rather than a Section 106 agreement. A legal agreement is a legal agreement in both cases, and it was broken in 2017, 2018 and 2019.

We oppose any further expansion of capacity at this airport at least until all the existing limits and commitments have provably been met and any new development would respect the Local Plan.

Open space
14) Do you have any comments on our open space and landscaping proposals? Is there anything else you would like us to incorporate?

The open space proposals are completely misleading. It is simply not the case that providing a strip of farmland, albeit slightly larger in area than the Community Wildlife site to be sacrificed, recompenses the community, respects the ecology or provides equivalent amenity.

It does not, particularly because:

  • It would take decades to mature, and would not in any case host the original flora and fauna which cannot be transplanted
  • It would no longer be located within easy access of local residents for whose benefit Wigmore Park was provided
  • It would remove the open green noise and pollution buffer between local housing and the airfield

We therefore oppose the open space and landscaping proposals on grounds that they would be to the significant detriment of the local community and of biodiversity and habitat.

Compensation and Community First Funding
15) Do you have any comments on our proposed compensation policies and measures?

We oppose further expansion of the airport, but would support compensation for those people who were significantly adversely impacted by the non-permitted development which occurred in 2017, 2018 and 2019 and led to the breach of planning condition 10 (noise contours).

16) Do you have any comments about our proposals for the Community First scheme?

We oppose further expansion of the airport, but would support Community First payments to all communities which were significantly adversely impacted by the non-permitted development which occurred in 2017, 2018 and 2019 and led to the breach of planning condition 10 (noise contours). In 2019 the airport generated £55 million of concession revenue. Rather than spend this on a project for further airport expansion which goes against its own Climate Crisis response, Luton Borough Council should have invested this money in sustainable ways to diversify the local economy and to alleviate poverty in Luton.

Further comments
17) Do you have any other comments about our proposals to expand London Luton Airport?

Instead of considering further expansion of Luton Airport, Luton Rising should ensure the airport operator and the airlines are incentivised to operate within its existing permissions as it recovers from the effects of the pandemic, and to put in place all measures necessary to reduce the carbon footprint of the airport.

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