Local Plan

The local planning authority (LPA) for the Airport is Luton Borough Council (LBC) which, through its subsidiary company London Luton Airport Limited (LLAL), also owns the Airport site. Any application for planning permission in respect of the Airport will be determined by LBC in accordance with the policies in its Local Plan unless the Government “calls it in” for determination by the Secretary of State for Communities and Local Government. If the Planning Bill currently before Parliament is approved, major infrastructure projects such as airports will be determined by an independent planning commission.

The main Local Plan policy relating to the Airport is LLA1:

The Borough Council will grant planning permission for development at London Luton Airport (identified as such on the Proposals Map) provided that it:

(i) is airport related; and
(ii) is not in conflict with national or regional government aviation policies; and
(iii) is in accordance with the most recent airport development brief agreed jointly by Luton Borough Council and London Luton Airport Operations Limited; and
(iv) results in an aircraft noise impact that is below the 1999 level; and
(v) incorporates sustainable transportation measures that will be likely to make an appropriate contribution to the achievement of the targets for the modal shift of passengers, visitors and staff travelling to the airport as set out in the most recent Surface Access Strategy; and
(vi) provides car parking facilities that comply with the most recent Surface Access Strategy with regard to: (a) the number and size of spaces; and (b) the location and management of the car parks.

As far as we are aware, LBC has yet to apply this policy to the many planning applications being lodged by various companies based on the site which are helping to fuel expansion of the Airport by stealth. LBC appears to take the view that the policy is only to be considered for applications by the Airport operator, a peculiar and perverse interpretation.

National and Regional Government Policy

Government policy for UK airports is set out in the White Paper “The Future of Air Transport” (December 2003), also known as the Air Transport White Paper (ATWP). The policies were confirmed in the Progress Report (December 2006).

For Luton, the ATWP acknowledges the existing planning limit of 10 million passengers per annum (mppa) but beyond this “supports the growth of Luton up to the maximum use of a single full-length runway based broadly on the current alignment”. We believe that this remains the policy - LADACAN’s successful challenge in the High Court which negated the overt support given by the ATWP for the extension of the existing runway did not alter this.

However, in November 2007 the Department for Transport published updated air traffic projections for all UK airports in which it assumed ”a terminal expansion and limited improvements to the taxiways”. None of these developments was mentioned in the ATWP or, like the extension of the existing runway, in the consultation which preceded it. While it is comforting that Government appears to have accepted that Luton will not expand beyond its current perimeter fence, it does create some ambiguity about national policy.

The policy in the Regional Spatial Strategy (RSS) for the Eastern Region (known as the east of England Plan) in respect of Luton states that national policy will apply. In publishing the Plan, the Government responded to submissions by LADACAN by acknowledging that the ATWP does not support the maximum use of the existing facilities at Luton.

Airport Development Brief

Luton Borough Council adopted the Airport’s Development Brief as supplementary planning guidance in 2001. The Development Brief was intended to take passenger traffic up to the planning policy limit of 10 mppa, a figure which is expected to be surpassed in 2008. The Development Brief was not accompanied by an environmental assessment but, despite this, a number of its proposals have been implemented as permitted development (ie without planning permission), helping to exceed the 5 mppa figure on which the most recent (1997) planning application was based.

There are, therefore, no proposals available which could guide the public in respect of future plans for the Airport.

Aircraft Noise Impact

The policy in clause (iv) of policy LLA1 requiring noise to be lower than the levels achieved in 1999 was imposed by the Inspector who conducted the inquiry into the Local Plan during 2004. Representations to the inquiry by LADACAN, among others, successfully argued that 1984, the noise benchmark preferred by LBC, was far too permissive.

In fact 1999 is also too generous as, unbeknown to us at the time of the inquiry, there were still aircraft operating at Luton which were classified as Chapter 2 for noise purposes. These were subsequently banned from operating in the European Union to reduce the noise burden on communities near airports. If, as in the past, LBC uses only the average noise (L_eq) noise indicator to assess predicted noise impact, the noise “budget” associated with these Chapter 2 aircraft within the 1999 noise estimates will permit a huge increase in aircraft movements, with a consequent huge increase in noise nuisance, without increasing the average noise levels. This would, of course, negate the intention of the EU ban even on the basis of average noise indicators.

Bizarrely, LBC is proposing to do worse than this: its planning officers have indicated that they will interpret clause (iv) of Policy LLA1 as referring to the predictions for 1999 which the airport operator submitted with its application for planning permission for expansion of the airport in 1997. These were even higher than the actual levels achieved for 1999, particularly at night, and would allow a massive growth in air traffic.

LADACAN was in communication with the head of planning at LBC when he left his post in September 2007 and will take up the issue again when his successor is appointed.

Surface Access

Transport of passengers and staff to and from the Airport is a major challenge: there is no direct rail access to the terminal and restricted space for road access. The proportion of passengers travelling by car is much higher than at the three major airports in the south east.

Although the Surface Access Strategy is a high-level, vague document, it espouses a clear aim of increasing travel by public transport. However, little is done to try to achieve this:

• the access road which is due for completion (at taxpayers’ expense) by mid-2008 has used the land which had been reserved for a dedicated public transport link to the central area;
• the dedicated busway (formerly Translink) planned for the Luton-Dunstable conurbation has been cut back so that it will not even extend from the Town Centre to the Airport Parkway Station; and
• a charge for the bus running between the Parkway Station and the terminal has been introduced.

Without effective action to encourage the use of public transport to the Airport, passengers coming by car will continue to clog up the main artery to east Luton, even after the expensive works now under way at public expense are completed.

Luton & District Association for the Control of Aircraft Noise - site updated 06 July, 2008