LADACAN believes the FutureLuToN project is designed to make more cash for LLAL at the expense of quality of life and the environment in the whole surrounding area. There are many reasons why this Nationally Significant Infrastructure Project would not be in the public interest, and we have summarised some of them below.
DO THE ALLEGED BENEFITS OUTWEIGH THE ADVERSE IMPACTS ?
Local communities already suffer the noise impacts of the recent doubling of capacity – an additional 90% flights a year on one route. Aircraft have got bigger and noisier, and the number of quieter-engine planes has been offset by introducing more larger noisier ones.
We strongly oppose any further expansion of capacity at Luton Airport because the Applicant has not shown the alleged economic benefits outweigh the increased environmental impacts on communities all around the airport.
300-450 planes a day already fly at very low altitude over Hertfordshire causing noise, loss of sleep and negative health effects which impact people’s well-being. Recent doubling capacity from 9 to 18 million passengers between 2013 and 2019 has not been mitigated: departing planes are still held low for up to 16 miles, aircraft have got larger and noisier, and the Airport has breached its noise contour limit since 2017. All of this has already seriously degraded quality of life in Hertfordshire, over which all of Luton’s arriving and departing aircraft must fly.
Although the Aviation National Policy Statement appears to favour aviation growth, it does not call for any further growth at Luton Airport, and the DfT’s 2017 Aviation 2050 growth predictions achieves its projections with Luton capacity at 18 million until 2050. The Applicant fails to demonstrate any national need for further expansion at Luton.
The Applicant has not justified why the ICAO balanced growth and mitigation principle, supported by the National Planning Policy Framework, does not apply at Luton Airport. Since 2013 capacity has doubled but no significant noise mitigation has been delivered – no airspace redesign has occurred to mitigate noise (in fact the reverse – flight tracks were concentrated in 2015 with the effect of increasing the perception of noise); the fleet has got noisier year-on-year as shown in the Airport’s Annual Monitoring Reports; and Luton Airport has breached its night noise contour since 2017 because night flights have doubled in the past 5 years from 8,000 to 16,000 per year.
Luton Airport’s current expansion project Curium was subject to public consultation and local democratic debate on the basis that it would run until 2028 as a balanced project to deliver not just growth and economic benefit but effective noise mitigation and a reduction over time in the noise envelope. Instead, its noise has been permitted to increase into breach. The Applicant has not justified a short-circuiting of this balanced process in favour of yet more growth on a trajectory of increasing noise until 2039. Permitting this DCO to proceed will destroy local trust in the planning process.
HAS THE APPLICANT TAKEN ACCOUNT OF CLIMATE CHANGE ?
Aviation has a strong adverse effect on climate change, not just from carbon emissions and high-level NOx pollutants, but the contrails which cause additional clouds. The UK Committee for Climate Change has written to government making clear that aviation growth must be at least halved to reach net zero by 2050. The UN has highlighted the lack of effective action to reduce carbon emissions.
We strongly oppose any additional expansion of capacity at Luton Airport because the Applicant has not demonstrated that its proposals adequately respond to the concerns of the Committee for Climate Change, or the United Nations, regarding global warming.
In 2019 the Committee for Climate Change wrote to government saying that airport expansion must be slashed by at least 50% in order to meet the commitment to net zero carbon emission growth by 2050. The Applicant proposes to add 28 million passenger journeys per annum to and from Luton Airport, and 80,000 flights a year, without giving any certainty that its emissions mitigation will achieve a net carbon reduction.
Aviation is one of the most energy and carbon intensive forms of transport, whether measured per passenger km or per hour travelling. In the UK, aviation’s share of emissions is predicted to grow from around 6% today to 25% by 2050, even if the sector is successfully capped at level of 37.5 MtCO2 (equivalent to 2005 levels) as been recommended by the Committee on Climate Change.
Aircraft emit CO2, NOx and harmful particulates while taxiing on the ground and while airborne. The most recent evidence indicates that other non-CO2 effects due to release of high-altitude NOx and formation of contrail clouds could double the warming impact of aviation.
Newer engines are only about 15% more fuel efficient. Official UK forecasts predict annual fleet carbon-efficiency improvements of less than one percent between now and 2050.
Luton Airport has already doubled in capacity in just the last 7 years. It is not appropriate for it to continue this trajectory because no proven and effective mitigations for noise, pollution and increased carbon emissions have been delivered.
HAS THE APPLICANT MITIGATED ROAD AND RAIL IMPACTS ?
14 million more passengers a year will lead to some 80,000 additional journeys to and from the airport each day, double during peak season, loading already congested road and rail services and causing more pollution. Luton Airport has a poor track record of passenger use of public transport, and the effectiveness of the DART is unproven.
We strongly oppose any additional expansion of capacity at Luton Airport on the grounds that the Applicant does not show how the disbenefits of significant further congestion on local roads and rail services are outweighed by the alleged economic benefits:
Surface transport by road and rail to and from Luton Airport is busy and often very congested, with no east/west public transport provision. An extra 30,000 passenger rail journeys a day would degrade our already inadequate rail services.
In just the last 7 years, 9 million additional passengers a year have already been added to the road and rail networks feeding Luton Airport, which equates to more than 80,000 passenger journeys a day allowing for drop-off, at busy times.
There is no east/west rail connection to Luton, and the east/west road links are country roads. The main M1 north/south link is heavily congested at busy times and gridlocks if an incident occurs. Trains are often standing room only at Harpenden and further south in the rush hour, and from London going north during the evening peak.
There are significant disbenefits to other businesses in the local and wider economy due to the likely increased commuting times, increased commuter discomfort due to having to stand in trains, reduced productivity due to tired staff kept awake by aircraft noise, and possible staff displacement. The Applicant has not shown how the proposal is justified.
ARE THE APPLICANT AND THE LOCAL PLANNING AUTHORITY CONFLICTED ?
The application is made by London Luton Airport Ltd (LLAL) which is wholly owned by Luton Borough Council (LBC), the Local Planning Authority. LLAL makes significant money from the airport operator London Luton Airport Operations Ltd (LLAOL).
The pre-application is being made by a private company which is owned by a Planning Authority which is dividended some £20m per annum from the airport operation. This creates a clear conflict between the protection of residential amenity and the aspiration to make more money.
Luton Airport is owned by Luton Borough Council, its Local Planning Authority, via a private company LLAL which is governed by a board made up of officers and members of the Borough Council, yet is not publicly accountable.
Robin Porter is the CEO of Luton Borough Council (which sets and has failed to enforce a breach of Luton Airport noise planning condition 10 caused by rapid growth). Robin Porter is also now the CEO of LLAL (which currently receives £55 million per year from the airport operators and benefits directly from airport growth). In 2014, LLAL set up a financial incentivisation scheme to stimulate rapid growth at Luton Airport (see p16 of the London Luton Airport Ltd 2016 annual accounts).
Since then, the airport capacity has grown at unprecedented rate, with numbers of passengers doubling in just 7 years, flights up by 40% overall, and yet no balancing mitigations have been delivered. Departures are still held low for up to 16 miles because expansion has rushed ahead of airspace modernisation. Noise impact has increased year-on-year since 2013 because expansion has rushed ahead of fleet modernisation. Night flights have doubled from 8,000 to 16,000 in 5 years and the night noise contour planning condition has been breached since 2017 with no enforcement.
This unbalanced expansion is entirely at odds with the government’s Aviation Policy which states that the benefits of aviation growth must be shared with communities. Over the past 7 years expansion at Luton, driven by LLAL through financial incentivisation, has delivered significant cash benefits to the airport owners, worse environmental impacts for local communities through increased noise, emissions and congestion,and no mitigation. 8 years remains of that project and the owners need to be constrained to deliver redesigned airspace, continuous climb, an overall quieter fleet, and noise and emissions reduction to redress the imbalance.
Even though the decision about future expansion at Luton will be taken by the Planning Inspectorate, the past history of expansion shows that Luton Borough Council has proved ineffective in dealing with the conflict of interest arising because it receives significant cash dividends from the airport but at the same time has a responsibility to protect residential amenity. The fact that it has not enforced against the breach of noise planning condition 10 which was predicted in 2016 and was at least partly due to the rapid growth incentivisation by LLAL, highlights the conflict.