Representation by Elizabeth Graham
- Date submitted
- 22 June 2023
- Submitted by
- Members of the public/businesses
My main points are below. I may have further comments later in the process. References are to the non-technical environmental impact document unless otherwise stated. No comments on National Policy are intended. 1. I strongly object to this application due to the significant adverse noise impacts on surrounding communities. a. Any expansion of Luton Airport has a high impact on noise levels in the surrounding communities where I live. The topography and location of Luton Airport is such that surrounding (often large and built-up) communities are unavoidably overflown on take-off and landing. Airspace congestion keeps flights lower and noisier than would be the norm elsewhere. The preponderance of low-cost airlines at Luton leads to a high proportion of night-time flights. b. Noise levels in Stevenage (under the westerly landing and easterly take-off flight paths) have been unacceptable since 2005, i.e. before the 2013 expansion. I previously lived for many years in Stevenage directly under the landing path 7 miles from the airport. There are no mitigations in this situation other than reduced numbers of flights as there is no technological solution for landing noise and no alternative route. Eventually we moved out of Stevenage to escape the disturbance. c. Noise levels in Knebworth (under easterly take-off flight paths) have also become unacceptable since the 2013 expansion. I cannot hold a conversation outside at work when planes are going over. I am kept awake or woken up at night by swathes of planes taking off until midnight and starting again before 6am. Planes during the night also wake me up. To keep the noise down, I must close the windows at night. Heatwaves are frequently associated with high pressure and easterly winds, so coincide with flights taking off over Knebworth. Hence I cannot sleep with windows open during hot weather, which is very uncomfortable and leads to more sleep disturbance. Each plane passing overhead also breaks up the TV signal. These are all attributes of ‘above SOAEL’ noise levels. The proposed expansion will exacerbate all these issues, in particular the increased night flying. Sleep disturbance from planes has already been a contributory factor in moving house and [REDACTED]. The application does not acknowledge that there are already noise issues in places such as Knebworth and seeks to trivialise the impacts of its expansion on these places. d. Every time the airport wants to expand, it argues that, as modelled, the noise will not get much worse or may even get better due to quieter planes cancelling out the increased number of flights, redesign of the airspace and so forth. This expansion makes the same arguments (e.g. paras 16.1.3 and 16.1.5). e. In previous expansions, my experience is that, whilst the number of flights always seems to increase faster than predicted, the ‘quieter planes’ always take much longer to enter service than assumed and, when they do arrive, they are not noticeably quieter. f. The proposed redesign of airspace is problematic, has been going on for years and is unlikely to deliver comprehensive change any time soon. Recent consultations have simply tweaked holding patterns. The last major NATS consultation was in 2008 with the proposals subsequently abandoned. g. I note that actual 2019 noise contours are taken as the baseline but these noise levels exceed the supposedly binding conditions agreed as part of the 2013 expansion. No enforcement action has been taken to keep noise levels within the agreed limits. Surely the baseline should be the condition agreed as part of the previous expansion? h. Theoretical noise contour modelling does not reflect my experience on the ground. There is very limited calibration of actual levels away from the immediate airport area. Our monitoring suggests that noise levels at around 7-8 miles out are noisier than modelled. For example, in Knebworth which is under the easterly Dover/Clacton/Detling flight paths, we record aircraft over 70dB, but Knebworth does not feature in the charts of aircraft over 65dB in drawing LLADCO-3C-AEC-00-00-DR-YE-0009 (5.03 Environmental diagrams Chapter 16). Further, a methodology which trades a reduction in individual flight noise for more flights does not translate into the same experience for the overflown. Two slightly less noisy flights are worse than one slightly noisier flight if all three flights are loud enough to cause disturbance, regardless of the maths. i. The proposal is for single daytime and night-time noise envelopes covering both easterly and westerly operations (16.2.6). The dominance of the latter means that the proposed contours take little or no account of the easterly operation flightpaths, even though these will be used on average 23% and even up to 37% of the time, during the busier summer months (Table 6.42 at 5.02 Appendix 16.1 Noise and Vibration Information 6.15.1). This is a crude approach which ignores the substantial impacts of expansion on the communities such as Knebworth under the easterly flightpaths. A more meaningful approach to managing noise would be to have separate envelopes for easterly and westerly operations and for summer and winter operations (so eight envelopes in all). j. Paragraph 16.2.7 basically says that the airport operator has no idea how it will manage to keep the noise within the noise envelopes. The only factor fully within its control is the number of flights, Recent experience with the previous expansion suggests that if noise conditions are breached there will be no question of reducing flight numbers; the solution will be to weasel out of the condition. If Luton Rising are truly committed to this approach, why do they not introduce it for the current operations and conditions they have already signed up to? k. The proposed mitigations do not address my concerns as they will not make any meaningful difference. For example, the allowed number of night flights may remain the same but replacing business flights in smaller planes with domestic flights means larger planes and more noise. The distribution of flights across the night slot and across the months of the year will also have an impact. This approach places no restrictions on flight numbers in the shoulder periods of 2230 to 2330 and 0600 to 0700, when most people will still be trying to sleep. The proposed noise envelopes do not cover where I live and work, or indeed much of Stevenage, which is already blighted by plane noise. Insulation and ventilation are only offered over a very limited area, which does not include Knebworth or Stevenage. In any case, the age and construction of my property make it unlikely that any effective alterations could be made to reduce aircraft noise. Air conditioning and funding of TV services unaffected by planes are not offered. Nothing can be done about outside noise. 2. I strongly object to this application because of its adverse impacts upon emissions and its promotion of climate change. a. We have a climate emergency requiring drastic steps to reduce CO2 and other emissions by 68% by 2030 and achieve net zero by 2050 in order to keep global warming to 1.5C. Recent evidence (e.g. rapid heating of the world's oceans) suggests that even this may not be enough. b. Aviation is a huge emitter of CO2 and other pollutants such as nitrogen oxides. International aviation is not included in any global targets, yet its substantial emissions still impact on global warming. c. Construction of the second terminal will result in the destruction of a green space with many mature trees. In addition to the loss of amenity and detrimental impact on wildlife, it will take decades for replacement trees to absorb the same levels of CO2 as the trees being lost. (12.2.2). d. The proposal places a heavy reliance on the development of new technologies to mitigate the expansion impacts (e.g. 12.2.2b, 16.1.4). However, it is generally accepted that there is no green and sustainable form of aviation commercially viable at present. For example, the Royal Society’s ‘Net zero aviation fuels: resource requirements and environmental impacts report’ concludes that there is no clear or single net zero alternative to jet fuel able to support flying on a scale equivalent to current use. Progress towards SAF (which does not require new planes) in the UK is driven by government policy, which is still in its infancy. This is clear from the March 2023 consultation document ‘Pathway to net zero aviation: Developing the UK sustainable aviation fuel mandate.’ Other technologies such as hydrogen and electric planes are even more problematic. It would be foolhardy to permit a massive expansion relying on these highly uncertain developments which are outside the control of the airport operator and its owners. e. Carbon offsets are also inadequate as a mitigation for this expansion. A young tree planted today will not remove significant carbon from the atmosphere for many decades (assuming the land is available to plant the tree and the tree is maintained to maturity). Meanwhile the carbon dioxide emitted by the flight stays in the atmosphere causing global warming. f. Flying is a privilege reserved for the few. Most aviation is for leisure purposes and is not essential but a nice-to-have. Every flight taken by a rich person uses up scarce carbon budget which is required for truly essential activities such as heating or cooking. The proposed expansion encourages more people to fly, but, unless and until there is a truly sustainable form of commercial aviation in place, more flying should not be encouraged. g. It is admitted that this application will result in an 89% increase in CO2 emissions alone, mostly from aviation (12.3.3). The UK government is not on track to meet its emissions targets, let alone have any headroom against those targets. Therefore, any project predicted to increase emissions by this order of magnitude is contributing to the UK missing its targets and should not be allowed. 3. I strongly object to this application because Luton Rising and the airport owners Luton Borough Council (LBC) cannot be trusted to keep their commitments. a. LBC, the planning authority, owns the airport and is financially dependent upon it. This huge conflict of interest has led to weak controls compared to other airports. For example, there are no restrictions on overflying neighbouring conurbations and only very limited restrictions on night flights. b. In previous airport expansion consultations, the airport operator and LBC have offered solutions or mitigations based on things they cannot control, such as changes to fleet mix or airspace reorganisation. I see the same disingenuous tactic going on here, including the availability of SAF and aircraft which can use this. Even when the solution is something which LBC can influence, such as the DART railway, it takes years to arrive (nearly 20 years in the case of DART). c. When supposedly binding controls are breached by the airport operator, they are not enforced by the planning authority. Recent breaches of the noise condition merely resulted in multiple applications to vary the condition, which were then approved by LBC, resulting in a national planning inquiry. LBC could have enforced the condition by instructing the operator to reduce the number of flights. d. I therefore find it impossible to accept any of the assurances given about mitigation, independent assessment and so forth. My experience is that these organisations are not held to account on their promises, leaving surrounding communities damaged. This should not be permitted to happen again.