Representation by Stop Luton Airport Expansion (Stop Luton Airport Expansion)
- Date submitted
- 21 June 2023
- Submitted by
- Non-statutory organisations
As a volunteer I represent the group Stop Luton Airport Expansion (SLAE) and as the name suggests the group are opposed to the airport's DCO application for expansion. For clarity, we are not opposed to the airport operating at up to 18 million passengers and we do not oppose the airport 'as it currently is' but we oppose any expansion that takes away the current Wigmore Valley Park footprint. Our group was founded to save the park following a meeting when representatives from Luton Borough Council told members of our group that the park would not be built over for airport expansion. Two months later they then announced their expansion plans and that has created mistrust. We have attended the Century Park, the airport operator's passenger expansion to 19 million applications, the non-statutory and the two statutory consultations and throughout our message has been the same, no expansion. Although the applicant and Luton Borough Council (LBC) define a boundary between their Ltd company and Council, we do not believe this is clear cut. If it was, then Luton Rising (LR) would not be made up of council employees and the directors would not be councillors. The majority of the Luton Rising Directors are part of the Labour political party which has been the ruling party in Luton since 2007. Historically Labour have not had an elected Councillor representing the Wigmore Ward, which is the closest ward to the airport and so the party clearly do not represent Wigmore resident views. In January 2019 two Liberal Democrat councillors resigned their seats on the board of Luton Rising as they were not allowed to publicly disagree with and criticise the decisions with which they had a sincere and serious concern on, unless the Labour members of the board agree that they may do so. In March of this year, Anne Donelan (Labour Councillor) was not selected to represent Labour in Luton's Northwell ward and in her resignation letter from the Labour party she wrote, "Due to the incompetence and failure to follow rules and procedures which I observed on the planning committee." In August 2021 Luton Rising directors were invited by Friends of Wigmore Park (FOWP) / SLAE to visit Wigmore Valley Park to show what the impact of expansion would do to the park. One councillor did not know that the park existed whilst two others were not sure where the park was or how to get there without using SAT NAV. Of the current LR board, no Luton Councillor lives within the wards most closely impacted by the expansion. This asks the question as to whether if they are fit and proper to act as directors and as councillors and why are they making decisions that impact the Wigmore ward. During the coming DCO examination, SLAE asks that all those involved from Luton Rising, the applicants consultants and the councillors of Luton Borough Council who think it such a acceptable idea to expand the airport to live under the flight path in the ward of South Luton in un-insulated accommodation for the six month period. They will be able to 'walk the walk' and also truly experience the up to 18 million passenger experience and get a taste for what it will be like if the airport reaches 32 million. This is an ideal time as the summer season is upon us and local climate change temperatures mean that they would also want to open their house windows. SLAE also asks that the majority councillor directorship of Luton Rising consist of councillors living within the adjoining wards closest to the airport. A good understanding of the issues directly associated to those living closest to the airport is paramount for councillors who sit on the Luton Rising board to truly understand the Wigmore Ward airport experience. Councillors living in the other Luton wards actually believe the economic solution to all their woes will be resolved by airport economic and job growth and push the debt out of sight. Recently we wrote to the interim Luton Rising CEO asking for £65 million (the rumoured amount of funds set aside by Luton Council for the DCO application), to help us provide a balanced view of the airport expansion application. We felt it just, fair and appropriate to ask for equal funding to form a compelling case to counter application expansion and we could also fund competent experts to evidence why. Currently SLAE has around £700 in its account and we pay a £5.00 monthly subscription. We feel that the council should treat the airport and residents equally. Our request was turned down. Recently there has been the National Mental Health week and we feel that it is important to make provision for caring and welfare during the examination. SLAE would like to check with the Planning Inspectorate that the health and well being of all those involved (Applicants, Consultants, Planning Inspectorate and all 'Interested Parties') will be of prime consideration throughout the examination process. Can the Planning Inspectorate advise on what they would expect in reasonable hours for all of those involved to be? The wellbeing is of a concern as we know that there will be many people working outside of examination hours. There will be those paid, those unpaid, those working and those whose employers will not pay them wages or take kindly to any requests for holiday, or time off to attend the examination who will need to work late into the evening and early hours to catch up and respond, as well as perform their normal day jobs. In fact those living under the flight paths have more reason than those not to request this. Perhaps even a house swap is viable during the examination with those putting the case for airport expansion. It is suggested that health provision is made available and funded by the applicant. Reading the letters of support for the application SLAE are not sure that the difference between the current 18 million and proposed 32 million is clearly understood. Most of the letters of support identify the current financial benefits received. SLAE suggest that if 'Green Control Growth' (GCG) is going to be passed into into law, then so can a similar law be put in place to protect charitable financial benefits. SLAE are concerned that if DCO approval is given that financial benefits may change and are surprised that protection is not included in the DCO application in detail. Are these supporters aware of the origins of where the funding comes from and if any of the organisations providing this funding to them are in debt? SLAE cannot understand why airport donations to charities has gone down over the past few years and the council continues to cuts support to services which pushes more people to ask for charitable help. We ask if there will there be a report published with high level statistics on the numbers that have registered as an 'Interested Party', if they are in favour or not, the locations that they have registered from and general subject reasons? Moving onto the application, we note that at this stage you ask for comments and what we consider to be the main issues and impacts including anything that may affect our day-to-day lives. We have concerns that the application documentation is a long and difficult read by the majority population of Luton and this could put people off of registering. This is particularly so, as the applicant has documented that educational attainment is generally lower across Luton. We would also expect the applicant to name the audiences that the application is aimed at and expected educational attainment required to contribute. There are many repeated paragraphs in the application documents, paragraphs written that are impossible to understand without a clearer explanation. These documents are public documents and as such should all be created for and easily readable by the Luton public. There are also contradictions, incomplete sentences due to redactions and we ask how can a Luton resident be expected to understand technical jargon that is second nature to paid expert consultants? A lack of consistency is a general theme, with some documents having glossaries, others not, acronyms missing, some with references at the bottom, some throughout the documents and some a mixture. There are dated references over a decade old (discounting Government policy or laws). A resident should not need to sign up to websites and be expected to leave personal details when accessing a reference. There are even documents with the text "Error! Reference source not found". Documents obviously written in different styles, by different companies, some have competent experts listed and others don't. Does this mean those documents were not written by competent experts? Documents with no consistent titling depending on whether the source was written in Microsoft Word or other applications. Different formatting. Documents downloaded from the Planning Inspectorate then opening and showing different titles or different titles picked out from the file properties. No clear definition of what content is actual evidence or not. Some have a reference number with no reference found or not available when searching the reference material. It's a mess, and wastes time and suggests some of these documents were rushed. How come this has cost £60 odd million? I read all of the Statutory 2 documents and probably retained 1% memory of that reading. To recall the documentation from the SIFT exercise, all of the consultations, the DCO submission, the references and the Planning Inspectorate documents is probably beyond the educational attainment of a Luton resident. There are other missing sections that we would expect to see in a DCO application, perhaps they fall outside of Planning law, for example the Application quotes the National Planning Policy Framework (PPF) when it comes to home-based workers. There is no mention of home-based workers who work from home and suffer from the flight path noise interruptions. If you are a home worker with your own business then it would be difficult to be in a business that required conversation, listening and meetings. You would be exposed 24 hours each day. It could be this is covered in visits to homes by noise consultants determining insulation measures, though this subject is still not covered or recognised in the DCO application. With more people working from home than before Covid and unlikely to change, it's surprising that figures to demonstrate this are not shown. Working from home is now a key selling point in job ads when attracting applicants. Without adequate insulation from flight path noise an applicant would be hesitant to apply for a role with home working requirements and this could be seen as discrimination. It is evident that Desk-Based Assessments do not capture the ward knowledge that residents have and there are surprising omissions from the application. Those who live in the wards surrounding the airport know the issues and the times that they occur. From my own reading two local road issues are not captured and the new park and playground have not been properly thought about. For example, let us look at Green Horizons Park, which was New Century Park, until it was decided that New Century Park was no longer viable. New Century Park planning permission was granted by Luton Borough Council and we now find in the DCO application its name has changed and also its footprint size. The amended footprint size means that Green Horizons Park could now be built on brown belt land to the South West of the airport. This would allow a greater area of Wigmore Valley park to be retained, and could even involve a redesign of the airport expansion to save the County Wildlife Site. Because the public were never consulted on the re naming and re-sizing of Green Horizons Park, we were unable to suggest improvements. Due to the time span taken to get to this stage of the DCO application SLAE think it perfectly reasonable for another SIFT exercise to be carried out. We suggest that the DCO should be split by phases and after implementation of each phase another DCO application is applied for. This gives the applicant time to re-assess, re cost the development and be able to adapt to new laws both nationally, European and worldwide, particularly in this changing world of climate change we live in. If we look at the number of major revision changes from Statutory consultation 1 and 2 and this DCO application then we could see the application improve after each phase, perhaps even realising that expansion is not a good thing and realising the need to save the park and County Wildlife Site. Although we have no evidence yet to submit on the topics of Brexit, Covid, Volcanic Ash events, current economic situation and inflation rises, worker strikes, local, national and International climate change, huge local council job losses, and the war in Ukraine. All have an impact on the aviation industry, with the majority of those being unexpected and unplanned events. Aviation is very susceptible to unplanned and rapidly changing national and international events and with slow recovery periods it therefore makes sense to split the phases or have good back out options (not decided by Luton Rising or the Council's planning mechanism). In fact, in response to all of these unplanned events, Luton Rising's continuously delayed DCO submission has proven how susceptible aviation is and the need to re-visit the SIFT options. SLAE are also surprised to find that there is minimal provision found in the DCO application of how aviation susceptibility would impact the aviation economics benefits and impact on jobs. Many supporters of the airport expansion quote job creation as a key selling point, yet job loss is not covered. SLAE would expect greater detail included with and without Government intervention scenarios. SLAE do not see good options provided in the application if the minor, moderate or major significant scenarios end up in practice to be opposite to those documented and the true mitigation solution. It is noted that the documentation set is heavily biased towards 'minor'. SLAE understand that the Local Luton Plan is a legal document, however there are contradictions within and also the council seemly applies the plan when it wants to. All references to the Local Plan should be removed from the application. This raises the question over the word 'local' and what its true definition is in National Planning Law. Its use and meaning varies widely over what Luton Rising, Luton Borough Council, residents and groups such as ours want it to mean. For example a Ward resident may use the word 'local' to represent their Ward. LBC may use the word to mean the whole of the Borough and Luton Rising may use the word to mean all of the Bedfordshire and surrounding counties. Each referring to something different. A Wigmore ward resident would refute that by LBC using the word 'local' it also included Wigmore. SLAE ask that all references using the word 'local' be removed from the DCO application and all referenced material, or that the context of 'local' is explained and easily understandable in meaning. Investment in, and upkeep of Wigmore Valley Park has been left by the council over the years to make the land more attractive to the expansion and park plans by Luton Rising. Let's look at the Pavilion and the children's play area. The plans in the DCO do not cover adequate provision for the Pavilion and children's play area. They read well and look exciting, but insufficient thought has gone into the planning of these, and any new plans look appealing when the council has deliberately ignored investment. This leads us to think that any local amenities offered to the residents will be cut back when it comes to local planning decisions made after the DCO application process has completed. The majority ruling political party of the Development Control Committee always passes airport plans, none are ever refused. Residents can see this committee cutting back on any Wigmore Valley Park amenities as a result of cut backs, economic benefits and jobs, as decisions always do. SLAE note that the 'Green Control Growth' (GCG) application documents express that GCG will be passed into law. SLAE's take is that if GCG can be passed into law, so can Wigmore Valley Park amenities and protection, and not a later stage. The council has committed to progressing deed of dedication arrangements with the 'Fields in Trust' charity with the ultimate aim of protecting all Luton parks and green open spaces from development. The current Wigmore Valley Park must be top of the list and before the DCO application is decided. Are the application maps consistent? It doesn't appear so. There are numerous references to the Lead Contractor, SLAE assume this will be Ryebridge and ask that the application documents are updated accordingly so that the Lead Contractor can complete all those statements left open and close the many holes where there is ambiguity and indecision. And as evident, SLAE have challenges to nearly all of the subject material in almost all of the applicants documents which we are happy to explore during the examination. These include, Arboriculture, Adjoining Ward and Airport footprint Climate Change, Agricultural, Air Quality, Airport Access Road and Luton DART, Airport Boundary Plan, Alternatives and Design Evolution, Approach to the Assessment, Archaeological, Biodiversity, Bird Strike, Book of Reference, Chilterns AONB, Compensation, Construction, Consultation, Contamination, Crown Land Plans, Cultural Heritage, Landscape, Drainage, Due Regard tables, Eaton Green Landfill, Ecological, Economics, Employment, Training, Electronic Application Index, EMS Orchid and Invertebrate, Energy, Equality, Flood, Funding, geophysical, Green Controlled Growth, Greenhouse Gases, Habitats, Health, Community, Highway, Hydrogeological, Land, Soil, Landscape and Visual, Lechate, Light Obtrusion, Location Plan, LVIA Methodology, Major Accidents and Disasters, Mitigation, Need Case, Noise, Nuisance, Open Space, Other Developments, Outline Site Waste Management Plan, Oxford Economics Reports, Risks, Scheme Layout Plans, Scoping Opinion, Sensitivity Tests, Site and Surroundings, Soils and Geology, Statement of Reasons, Streets, Rights of Way, Surface Access Strategy, Sustainability, The Proposed Development, Traffic and Transportation, Tree Survey, Validation Reports, Vibration, Visual Representations, Waste and Resources, Water, Winter and Summer Viewpoint and Work Plans.