Representation by John Michael Wilkinson
- Date submitted
- 24 May 2023
- Submitted by
- Members of the public/businesses
I am concerned about the big increase in air traffic movements (ATMs) and the consequent westerly extension of the noise contours. The Luton Rising (LR) consultation claimed that the 78% increase in passenger numbers would be achieved with an increase in ATMs of just 48%. This premiss is based on the assumption that the existing fleet will be progressively replaced during the life of the project with slightly larger aircraft operating at higher load factors. If this assumption proves to be over optimistic the number of ATMs will inevitably be greater. Despite the increased number of ATMs, LR's prediction is that there will be an overall reduction in the area and population covered by the relevant noise contours (SOAEL and LOAEL) during the life of the project. This premiss is based on the assumption that noise improvements predicted by the certification data for the new generation of aircraft that will make up the future fleet will be realised in practice. LR acknowledge that to date the actual measured noise data have demonstrated that not all of the predicted improvements have been realised, but they have nevertheless assumed that they will be by Phase 2 of the project. If that optimism is not justified and the noise improvements aren't achieved, then clearly the noise envelopes will be larger. Even if all the optimistic assumptions are realised, the size of the noise contours is not the only consideration. This is because the predicted noise improvements of the new generation of aircraft relate mainly to a reduction in noise emitted on departure. The noise of arriving aircraft is not expected to change very much. The noise contours are made up of a combination of arrival and departure noise and because departure noise levels are greater, any reduction in departure noise will result in a disproportionate reduction in the noise envelope area. Consequently it is quite feasible that the overall noise envelope could reduce in area even with more ATMs, but those additional ATMs will result in an extension of the contours over the final approach paths. This effect is shown quite clearly on the noise contour plots included in the consultation documents, where the western and eastern extremities of the contours have both been extended. Take for example the LOAEL night contour (45dB) where the western 2019 night-time baseline extends as far as the eastern edge of Whipsnade Zoo. The 2043 night-time 45dB contour corresponding to the 32mppa level of traffic would extend into Buckinghamshire as far as Dagnall. Kensworth would be within the 48dB contour instead of just the 45 dB one. So whilst the overall noise levels might reduce as predicted, there is a certainty that those villages under the final approach path will see a worsening of the current situation if there is an increase in ATMs, regardless of the anticipated noise improvements that are being attributed to the new generation of aircraft. The principal metric being used by Luton Rising is mppa. Whilst this is an important parameter for areas close to the Airport, for those towns and villages beneath the approach and departure flight paths the critical parameters are the number of ATMs and the size and shape of the corresponding noise contours. There are current limits for the permitted areas of 57dB daytime and 48bB night-time contours, a maximum of 9,650 per annum night-time ATMs and a maximum of 7,000 per annum ATMs between 6:00am and 7:00am. Even if all these limits were to be retained unchanged, this could still leave those villages under the final approach flight path exposed to a very significant and unacceptable increase in daytime overflying. If an increase in mppa is to be allowed, there must be a corresponding cap on the total number of ATMs, as well as a cap on the total passenger numbers and night-time ATMs. Also in addition to the maximum permitted areas of the critical noise envelopes, the extremities of those contours must not be allowed to extend beyond the 2019 baseline contours in any direction. Finally since the levels at which adverse effects start to be observed (the LOAEL) are 51dB daytime and 45dB night-time, those should be the critical contours and not the somewhat arbitrary 57dB daytime and 48dB night-time contours that the current planning consent refers to. Expansion must not be allowed to increase/extend beyond any of those individual caps.