LADACAN has run a Fact Check on the expert evidence which influenced Luton Councillors to vote 7-2 for airport expansion at the development control meetings on 30 Nov and 1 Dec 2021. The meetings were recorded so you can play the media files and check for yourselves against the planning documents. Each statement carries the elapsed play-time at which it was made:
Meeting 1: https://www.youtube.com/watch?v=iRwnTEdegl8
10:16 – the verbal report dismisses LADACAN’s challenge over noise contour accuracy by saying one contour related to accredited noise values, the other to corrected noise values. WRONG! Our objection was nothing to do with this. We had found two identical outlines on the same maps which were reported as enclosing two quite different areas: both can’t be correct, hence (as we said) the contour data should all have been double-checked.
26:14 – the expert claimed that number of aircraft movements to achieve 19 million passengers is only 0.7% higher than in 2019. MISLEADING! In 2019 the airport was flying too many aircraft and in breach of Condition 10, so this is not a valid comparison year – as he went on to emphasise below.
27:10 – the expert explained that a 43.5% increase in flights would only give rise to a change in noise level of +1.57dB. He said this was a minor change which would not normally be considered to give rise to significant impact. THIS IS UTTERLY MISLEADING. In the context of noise , the term “decibel” without any qualification is taken to mean a representation of the loudness of perceived sound. The airport publishes measurements of it aircraft noise, which range from about 60-80dB depending on where you live.
Any noise expert knows that noise contours plot a completely differently measured value – LAeq – a logarithmic average of noise measurements over a specific time. The expert should have made clear to Councillors who were already confused by his use of technical jargon (“ATMs” instead of “flights”), that he was talking about a difference in specialist noise averages, which is not comparable in any way to the conventional use of “decibel” to represent perceived noise.
In this case the difference being dismissed as “not significant” relates to an average 120 or so flights per day, each of which has an impact of 60-80dB depending on where you live. LADACAN deplores the aviation industry’s persistent mis-use of noise terminology in this way as utterly misleading.
35:44 – the expert explained that the eventual reduction of noise levels below those originally predicted has been delayed for 3 years by COVID. MISLEADING! A reduction of noise levels could also be achieved by flying less aircraft in the period from now until 2028: this scenario was not considered.
38:47 – the expert claimed that our concern about “with” versus “without” development cases is answered by not using 2019 for comparison (because it was non-compliant) but by comparing to the 2018 Condition 10 limits. EXACTLY! That’s exactly what we said, but the Environmental Statement documents do not make clear how or indeed whether this comparison is made for each year from 2022-2028. It’s not sufficient just to compare for the Condition 8 limits – you also have to ensure that the Condition 10 contour limits are always respected too.
43:37 – the expert said that the Environmental Statement does not present the noise case in a manner that is clearly understandable to all readers, and that the use of forecasts which do not seem to match reasonable short term expectations is ‘unhelpful’. CORRECT! In our view the “Environmental Statement” is a shameful shambles constructed so as to hide the truth about this application and why it’s being made.
44:12 – the expert said that the application offers no remedy for the excess noise experienced by the community since 2017 and expeced to continue for some years into the future. CORRECT! The Airport has taken all the financial benefits of it incentive-induced aggressive growth disregarding the conditions, the community and its commitments – and is now back asking for a futher £45million over three years from the Council. Why??
44:36 – the expert claimed that extending the analysis beyond 2028 to show the noise reduces below original limits brings it in line with government policy and the excuse is the delay caused by COVID. MISLEADING! The reasonable alternative option of limiting the growth in flights to bring the limits under control by 2028 was not been explored. No evidence has been given to demonstrate that COVID has delayed fleet modernisation.
Meeting 2: https://www.youtube.com/watch?v=G7qzjEiUU48
13:40 – SILENCE! LADACAN had requested that legal advice be given to the development control meeting regarding whether financial incentivisation by Luton Borough Council of the airport operator to achieve “growth” and “super growth” was legal. We highlighted the apparent disregard for noise control conditions and the Council’s obligation to scrutinise performance against the noise control scheme. We pointed out that the incentive scheme might be found to be improper influence of the operation of the Airport in respect of Section 17 of the Airports Act 1986. And we noted that the scheme may be regarded as an improper subsidy under prevailing EU legislation. Yet no legal guidance was given in the planning meeting on these issues.
13:48 – the expert claimed that the contour mismatch LADACAN identified is a misunderstanding because there are no figures which relate to the 35.5sq km contour area, only tabulated data. WRONG! Page 3, Section 8 Noise, of the revised ES chapter 2 states “This updated chapter should be read in conjunction with the updated associated Appendices appended to this chapter (they continue to reference Volume 3 for consistency with the original chapter). The Figures within Volume 3: Figures and Appendices do not change.” Volume 3 clearly contains the Figures (ie charts) we referred to.
In the revised ES chapter 2, Appendix 8E, on page 8E5, is a table giving the area of the 48dB night noise contour for 19mppa in 2028 as 35.5sq km. But in Volume 3: Figures (still valid, as per the above statement) is a 19mppa contour plot for 48dB 2028 night in Figure 8.10, dated 2020, and its outline is the same as one in the previous screening report which quotes the area as being 29.9sq km. They can’t both be right! So somewhere along the line, the information which has been provided is wrong.
If you spot other errors in what was said in the planning meeting versus the documentation, or any other clearly misleading statements, email us and we’ll check them and add them to the list. Councillors rely on this evidence to make their decision, and if it’s wrong, the decision is likely to be wrong too.