Representation by HarpendenSky.com (HarpendenSky.com)
- Date submitted
- 15 June 2023
- Submitted by
- Non-statutory organisations
There are 2 fundamental concerns [a] air quality degraded from significantly increased environmental pollution due to greenhouse gasses arising from Luton airtraffic eg PM2.5, CO2, NOx [b] noise disturbance above what are already intolerable levels due to Luton airtraffic at low altitude [eg 5,000 feet]. [a] Environmental Pollution: air quality degradation across Luton & Harpenden from 32m passenger airtraffic will lead to non-compliance with DEFRA Environmental Improvement plan interim targets, increased mortality particularly with vulnerable groups, non-compliance with Sixth Carbon Budget, non-compliance with Luton Council Climate Emergency, non-compliance with Herts County Council Sustainable Hertfordshire Strategy. [b] Intolerable Noise Disturbance: a significant increase in Luton airtraffic noise disturbance due to Luton flights at 5,000 feet which is too low. The altitude must return to the aim of LLAOL FL100 which determined 10,000 feet by rail line. More detail available at examination stage. Reference TR020001 NEDG Final Report According to CAA Guidance, CAP1129 & the NED Final report 12/2022 “For an envelope to function as intended, it is essential that full agreement is achieved between all stakeholders on the envelope’s criteria, limit values, means of implementation & enforcement” . We disagree with the unilateral alterations made by Luton Rising [LR] which critically weaken the NED & related controls by reducing the limit values used to assess noise impact & increase the threshold levels which trigger corrective action. Consequently, the necessary agreement between all stakeholders has not occurred & recommendations for robust enforcement have even been ignored, particularly bearing in mind the past LR/LLA performance which has been strewn with errors or misleading data. Due to this NED dilution by LR, the risk of noise limit breaches will inevitably increase & must therefore be formally reviewed more frequently & robustly at a maximum frequency of 2 or 3 years. The review must be conducted in conjunction with community groups & independent authority to firmly establish the standard of enforcement & overcome the difficulties experienced in the commercially restricted consultation process.