Representation by David Keith Graham
- Date submitted
- 22 June 2023
- Submitted by
- Members of the public/businesses
I oppose this application as it will: A. Cause myself and many others significant extra noise disturbance that will prevent enjoyment of the natural world (E.g., simply leaving a window open, sitting in the garden or walking in local countryside.) and will likely cause health problems as a result and also as a result of reduced hours sleep. B. Reduce my and others ability to participate in active travel. C. Cause an increase road congestion over a wide area which will further reduce our freedom to walk and cycle, increase journey times and increase the pressure to convert yet more green space to tarmac road. D. Prevent practical use of normal “freeview” through the TV arial. E. Significantly increase the problems of global warming and the over use of natural resources. F. Hinder the conversion of the UK airfleet to become carbon neutral. G. Reduce the country’s natural assets and either or both biodiversity and food security. H. It is also liable to cause some in society to become much more radicalised as they see their environment being ruined by an uncaring organisation, and, with no effective control mechanism to which they can appeal. I further object on the grounds that: 1. This airport is four times worse than Stanstead in terms of noise impact on local communities per plane so expansion in this region (if permitted at all) should be better placed at Stanstead, which is also better geographically placed for a national hydrogen pipework and has a much bigger site so is more likely to have room for the future Hydrogen storage needed. 2. Many parties who might like to object if they were aware of the impact of this development will be unaware because the documentation does not take an even-handed approach and only presents the numbers it wishes you to see. For example, from looking at the noise data you would be unaware that Knebworth will be overflown a hundred planes per day at noise levels exceeding 70dbA and that would occur for many weeks at a time in the hottest of weather until a westerly wind returns, whereupon Knebworth will return to quiet. The report completely dismisses areas such as these. 3. The applicant states that they have corelated the noise contours from actual measurements however it is clear that the measurement position in Stevenage was chosen to avoid the tricky part of the contour they find it difficult to predict, that area being where the planes finish turning to arrive on a straight trajectory, rise to meet the glide path from below and drop their undercarriage. All this happens on the East of Stevenage, where they know from previously taking measurements at Marriotts/Nobel school that plane noise can exceed that at the permanent monitoring station which is mid-way between Nobel school and the airport. They instead positioned the monitoring point in the central/west where the planes return to simple glide mode and are thus more predictable. It is thus clear that noise levels are being under predicted. 4. I am aware from having measured the noise of aircraft passing over my house that the noise levels normally peak at something just over 70dbA (measured on fast setting). The background noise is around about mid 40s. Luton airport need to get 20db off each overflying aircraft if I am not to hear them. Yet their intention is to fly more bigger (and thus noisier) aircraft at a higher frequency, so increasing occurrences of disturbance. Note that even if they can get the noise levels down, I will still notice them as the TV breaks up for approx. 20 seconds as each plane passes over. 5. The assessment of change in noise levels appears to be based on an illegal baseline. They presented actual 2019 data as an acceptable baseline which they can compare against. In 2019 they were operating in breach of planning restrictions which they had agreed to. They should be using the restrictions to which they should have been working to and not what they actually did. 6. The operator has history of signing legally binding noise obligations and then never being held to account when exceeding the limits. From the Public perspective, they appear to have never even tried to maintain operations within the law. 7. The operator claims there will be a reduction in people affected by significant adverse effects but have been very selective in how they calculate this. In the past their predictions on plane noise have been substantially lower that the aircraft actually achieved when flying from this airport. They have persisted however in accounting for theoretical improvements if their operators use the best aircraft. 8. In the night flying consultation for Stanstead/Gatwick/Heathrow the government has conceded that actual number of flights exceeding key values is a useful indicator of disturbance. No such figures have been produced in this application that I can find but it is undoubted that all are going to be significantly worse. 9. The operator intends to keep the number of night flights the same (23:30 to 06:00). This sounds initially as good news as surely aircraft will be getting quieter, but they intend to fly more noisier aircraft so the number of awakening events is proposed to get even higher from the current unacceptably high level. The number of night flights needs to be reduced and the number of flights in the night period 23:00 to 7:00 should be reduced below 2016 levels, with no increases in numerical awakening events from 20:00 to allow sleep of children. 10. The application in section 12.3.5 of the non-technical summary of the environment statement concludes that this development “would not materially affect the UK’s ability to meet its carbon reduction targets, including carbon budgets”. The statement is clearly wrong, gives the wrong impression as to the current UK performance against its targets and is beyond the responsibility of the developers to decide what should be permitted. The airport authorities could be responsible and help the secretary of state make the value judgement by comparing the carbon footprint of these multiple foreign holidays (which also result in reducing UK GDP) with other wished for developments such as new schools and hospitals but it doesn’t, it implies it affects nothing else which is very far from the truth. 11. The application does not seriously plan ahead for de-carbonising the airfleet. There would need to be a period when storage of both normal aviation fuel (or SAF equivalent) and hydrogen would be required. No hydrogen fuel facilities are planned and as the airfleet would require the hydrogen to be supplied at low temperature under pressure this is not an insignificant undertaking and even if not required until the mid 2030s the lack of planning in a plan that goes through until the 2040s shows that the airport has no intentions of flying greener aircraft. 12. This application is driving a demand for an activity which with today’s climate crisis is being deemed by more and more as morally unethical, trivial holiday flying should be scaled down until that time where it can be achieved ethically. This would give time for developing the technology to fly the planes more quietly and in an ethically acceptable (not putting life on planet at risk) manner. Aircraft manufacturers have enough work supporting economic development of the global south and in developing “green technologies”. To furnish the excesses of the richest of the rich “north” would over extend them and distract from their more important quest to make flying sustainable, which if they fail in would prevent all future leisure flights and probably bankrupt Luton airport. 13. The assumption on continual future growth is suspect given the increasing media attention to the climate crisis and government subsidies on which the airlines rely. It is noted that some governments, notably France and The Netherlands, have actually started to place restrictions and enforce some reductions in flying. 14. The application intends to further degrade the food security of the nation by removing what it claims to be prime agricultural land and re-purpose it to enable it to claim an increase in biodiversity. It also points out that this decision could be reversed. It would appear that the simple truth is that biodiversity is going to be reduced by this application and they have simply performed some mathematical tricks so that they can tick a box to pretend otherwise. 15. Parties who may be affected by programmes that will be cancelled or activities suspended if this application is allowed, (so as to retain carbon emissions within compliance with national law) are unlikely to be aware of the existence of this plan. Many who are aware of this plan will be completely unaware that because the UK is failing to bring down its carbon footprint fast enough, to comply with law any additional major carbon emission source will need to be balanced with removal of an equal volume of carbon emissions. In this case not just to balance building but also to balance the flight emissions multiplied by the high-altitude effect that means effectively that the annual near million tonne budget, for this airport, will need to be balanced by removal of 2 million tonnes of emissions from other sources, such as hospitals and schools. 16. The impact of the following flight paths have not been considered, however very happy if LUTON only going to fly into the West independent of wind direction. Map of Easterly (07) Flight Routes (24 hour period) on page 25 of Luton Airport’s 2021 Annual Monitoring report