Representation by The Harpenden Society (The Harpenden Society)
- Date submitted
- 16 June 2023
- Submitted by
- Non-statutory organisations
The Harpenden Society is a membership organisation of about 900 members. Growth a Luton Airport will significantly impact our community, villages nearby and our members directly, most notably through increased noise and congestion on the roads and railways and indirectly through increased greenhouse gases. Furthermore, the applicant, Luton Rising, has failed to articulate a reasonable balance between the economic benefits of growth and the clear and substantial environmental costs. In addition, Luton Rising does not have either the management skills or access to funding to achieve the applications proposals and there are considerable doubts as to the support of either the existing concessionaire or a different concessionaire to achieving the applications goals, not least because there is little evidence of the demand the application assumes, other London airports are planning to grow in geographic areas where Luton Airport needs to capture customers and there is considerable uncertainty as to whether the government’s Jet Zero targets can be achieved without demand management being introduced. Specifically: On noise, Luton Rising is essentially proposing that noise levels remain fairly consistent with noise levels that exceeded the extant planning consent limits in 2019, despite the fact the planning consent limits are scheduled to fall substantially until 2028 under the existing planning permission (and under the 19mppa planning application subject to call-in by two Secretary’s of State), thus the noise proposals fail to meet either the government’s policy aims of minimising and reducing noise levels or sharing the benefits of (noise reduction) technology between the aviation industry and communities affected by noise. So far as congestion on the roads and railways are concerned, the key access roads, the M1 and A1 and local roads such as the A1081 and A515, are already subject to severe delay during the morning and evening peaks but the application’s proposals for improving the road network are extremely limited (and makes assumptions about future motorway use may not be achieved given concern about smart motorways). On the railways, the story is similar, during the morning and evening peaks Thameslink trains are overcrowded between Harpenden and St Pancras and there is little or no scope for increasing the frequency of trains (especially if the rail freight depot at Radlett opens). We do not believe that Green Controlled Growth is an effective way of ensuring environmental conditions aren’t breached. Luton Rising is the trading name for London Luton Airport Limited (LLAL). None of the directors, nor any of the senior employees assigned to the company (but actually employees of Luton Borough Council), have any aviation experience. Furthermore, LLAL is financially challenged. It will not be able to undertake the development itself and will instead rely on the current concessionaire or another (post 2032). The current concessionaire, who pointedly is not the applicant, says it supports the application but this is subject to the “commercial arrangements” and the planning permission granted (if any). This is not a ringing endorsement of the proposals but more importantly it is clear that the commercial arrangements may be very different to the proposals being put forward by Luton Rising in support of its application. The uncertainty that is inherent in this application as a result of the inability of the applicant to make it happen and the reservations of the existing operator, subject to a future commercial agreement, suggest that the already highly speculative and cherry-picked benefits of the proposal are unlikely to materialise and the past willingness of Luton Borough Council (LLAL’s owner) to allow persistent breaches of existing planning conditions emphasise that the environmental costs will, in contrast, be felt fully, probably to a greater extent than those proposed and earlier than the phasing suggests will be the case (we note that the phasing is only for assessment purposes only which means there’s no certainty as to the timing of any development and communities will be faced with uncertainty for years to come). We believe the application should be declined. We will submit evidence to support our concerns by the appropriate deadlines set by the Examining Authority.