Representation by St. Albans Quieter Skies (STAQS) (St. Albans Quieter Skies (STAQS))
- Date submitted
- 22 June 2023
- Submitted by
- Non-statutory organisations
STAQS wishes to register as an interested party to represent the communities it serves to the north of St. Albans. St Albans Quieter Skies (STAQS) is registering as an interested party due to our concerns about the adverse impact of any further expansion of Luton airport on the residents of North St Albans, Sandridge and neighbouring communities. STAQS was formed following the previous expansion of the airport from 9.6 million passengers per annum (mppa) to 18mppa in the period to 2019. Whilst passenger numbers dropped in 2021 to 2022 we anticipate that passenger numbers will reach 18 mppa in 2024 if not before. It should be noted that when planning permission was given to expand to 18mppa the application was for 18mppa to be reached in 2028 and not 2019. The rapid increase in passenger numbers and therefore flights in 2013 to 2019 had a significant adverse impact on residents. Although outside of the contour area classified “significantly affected”, many of our members are significantly impacted by noise from aircraft departing Luton Airport. We regularly receive reports of night departures waking members from their sleep. Sleep is often cut short by the 6 a.m. rush to depart the airport and maximise the length of the working day for the aircraft. The tranquillity of our gardens is lost from the roar from above. Conversations are put on hold. Even an evening watching television is blighted by noise interruptions. Flight paths to and from Luton Airport impact communities often many miles from the airport. Currently there are no respite routes in operation. Further expansion of the airport with increased flight numbers from larger aircraft will make the situation even more frustrating. Mitigation LLA proposes mitigation in the form of noise insulation to those living closest to the ends of the runway. We will leave it to others to explore the effectiveness and desirability of this mitigation, which requires residents to live indoors and with windows closed. Many more, who live beyond the contours will be affected by overflights, including schools, businesses, care homes, and residential properties will suffer significant noise increases impacting health and quality of life. Fleet Mix and Modernisation The assumptions relating to noise are reliant on the modernisation and changes to the fleet of aircraft using the Airport. This is outwith the control of the airport and neither the fleet mix, nor the timescale for delivery can be relied upon. In terms of the claims of newer aircraft being less noisy, there is evidence that the A321Neo has not performed as expected when flying out of Luton Airport. Across this area, local Community Noise Reports show that A321neo is no quieter than the A321ceo model that it supersedes. The assumption that larger aircraft will be carrying more passengers and thus will reduce the overall number of flights is also unreliable and may be likely to lead to more noise with a greater size and load. Noise Modelling STAQS has concerns about the reliability of the noise modelling and the assumptions made. Previous noise modelling has not been accurate and there is a risk that the breaches of noise contours in three consecutive years (prior to Covid) may well be repeated. STAQS was a signatory to the community group feedback on the Noise Envelope Design Group (NEDG) report, which is included as an appendix to that report in document TR020001/APP/5.02 As set out in the following paragraphs in that response STAQS and other community groups consider that: 12) Community stakeholders have significant reservations about whether the current and limited exercise meets the necessary standard for consultation on a noise envelope design. 13) Most groups consider it unhelpful to blur the boundary between the noise envelope process and limits, and the separate topic of so-called Green Controlled Growth, and want to see the parameters and the controls for the Noise Envelope clearly defined in isolation. 14) Community stakeholders have little confidence that noise modelling will be accurate due to deficiencies in noise monitoring and modelling at Luton Airport (one already identified by Luton Rising) and a lack of transparency over the calibration of the AEDT model using the data from INM and from the Airport. 15) Community stakeholders have little confidence in forecast noise reductions because no information is provided about how the use of quieter aircraft will be incentivised; and next generation aircraft are not likely to be noise-reduced. 16) Community stakeholders note that in the period 2014-2019, the Airport took the commercial benefits of growth without delivering sufficient noise mitigation through introduction of less noisy aircraft, and that this deficit needs to be made good before Luton Airport is entitled to share in any future benefits as noise reductions occur through new technology. 17) Community stakeholders strongly disagree with the unilateral decision of Luton Rising to depart from the Noise Envelope design put forward in the NEDG interim report – particularly in light of information from the Airport Operator that more flights are likely to occur outside the 92-day summer period. 18) Community stakeholders are firmly of the view that effective and independent oversight and scrutiny is required given the recent planning history, and recommend that community representation is included. 19) Community stakeholders recommend an initial review after just three years. 20) Community stakeholders do not believe that the approach taken to this ‘consultation’ engenders trust. Balanced Approach The UK Government accepts the principle of the “balanced approach” advocated by the ICAO – that the introduction of quieter aircraft can be used to enable growth in aviation while maintaining a balance on the noise impact on communities overflown. The 2013 planning permission recognised this balance and forecast growth linked to the introduction of what were at that time known as “next generation” aircraft. Within weeks of planning permission being obtained, Luton Borough Council entered into a Growth Incentive Scheme to compensate the Airport Operator for accelerating growth by discounting fees to airlines, with the intention of achieving the permitted passenger cap of 18M passengers per annum by 2020. This scheme was successful in achieved the 18M passenger throughput in 2019, a full 9 years ahead of forecast and before the modernisation of the aircraft fleet that would be necessary to remain within the noise contour limits in the planning permission, based on growth forecasts to 2028. In consequence, the night noise contour planning condition was exceeded in 2017, 2018 and 2019, with the day noise contour being equalled in 2019. Luton Borough Council chose to take no enforcement action following these breaches. Having totally disregarded any attempt to deliver “balance”, the Airport Operator was invited to apply for increases in the capacity limit and the noise area contours to permit further expansion – at a time when the original permission had indicated that noise reductions could and should be delivered. Luton Borough Councils approval of a further increase was not surprising, but even before the Government has determined the outcome of the Inquiry by the Planning Inspectorate into that decision, we have this further application for a new terminal and a further near doubling of passenger capacity. As owners of the airport, and also the local planning authority, Luton Borough Council has demonstrated that they have no intention of maintaining a “balanced approach”. The impact on the wider population continues to be downplayed and the economic benefits overstated. Capacity increases are being justified on the basis of the noise impacts being “imperceptible” to the human ear, because of the logarithmic nature of the decibel metric. They hide the fact that that many additional flights can be flown (each causing annoyance) without the noise impact being what the noise experts classify as “perceptible”. Legislation and Policy In respect of noise impact overall, this proposal is contrary to National Planning Policy Framework, and the Aviation Noise Policy Framework for England, which aim to reduce the number of people significantly affected by the adverse impacts of noise. It is also contrary to Luton Local Plan policies and the Luton Airport Noise Action Plan 2019-2023 which variously states that LLAOL will, with respect to the night-time contour “Limit and where possible reduce the population within the contour over the course of the action plan” and will “operate within our agreed contour limits” and will “develop a noise contour reduction strategy to define methods to reduce the area of the noise contours”. For the above reasons, STAQS objects strongly to the proposed expansion of the airport. STAQS Committee June 2023