Back to list London Luton Airport Expansion

Representation by Transport for London (Transport for London)

Date submitted
22 June 2023
Submitted by
Other statutory consultees
  1. Introduction 1.1 This Relevant Representation is submitted by Transport for London (TfL) on behalf of the Mayor of London in regard to the Development Consent Order (DCO) application pertaining to the London Luton Airport Expansion project. The Mayor of London recognises the economic and connectivity benefits that airports bring to London – but also that the environmental and health impacts of aviation must be fully acknowledged and addressed. 1.2 Though Luton Airport lies outside London, it is an important part of the London airport system – with a significant proportion of passengers travelling to, from or through London – and as such, a holistic pan-London approach is required. The Mayor and TfL have an interest in this application with regard to its wider environmental implications, as well as impacts specifically within the London area in terms of surface access and emissions. 2. Summary of the Mayor’s position 2.1 The Mayor of London is greatly concerned about the environmental impacts associated with this development, and in particular with regard to carbon – both in terms of the significant increase in aircraft movements, as well as the very substantial additional highway trips. On this basis, the Mayor is unable to support the proposed development. 2.2 The aviation sector needs to play its part in meeting UK climate change targets. The Applicant fails to set out how its proposed 139% increase in aircraft movements compared to today can be compatible with these climate change commitments. 2.3 It is important that the Applicant also demonstrates how it intends to fully address the noise and air quality impacts that arise from the proposed development – with regard to the latter, both from aircraft and from the surface travel to and from the airport. 2.4 Indeed, securing sustainable surface access, for both passengers and staff, is essential to reducing the carbon and air quality impacts. The proposed sustainable mode share targets lack ambition. The proposed development should not be dependent on any increase in car trips or car parking and the Applicant needs to set out a concrete package of measures to ensure this. TfL is also concerned about the extent to which the Applicant has demonstrated the ability of surface access networks to be able to accommodate the extra demand, including on the corridors into central London. 2.5 We note the novel approach proposed in the ‘Green Controlled Growth’ framework that seeks to make sure growth takes place within environmental limits. However, this framework is only as good as the thresholds it applies. The basis for these need to be fully evidenced and stringent enough to ensure that it prevents additional environmental impacts, which it largely fails to do. 3. Carbon 3.1 The climate emergency requires significant and co-ordinated effort if greenhouse gas emissions are to be drastically reduced to keep global warming under the proposed 1.5ºC or 2ºC limits. Aviation consitutes a substantial and growing proportion of UK carbon emissions and the sector needs to redouble its efforts if it is to contribute to achieving binding climate change targets. In this context, it is deeply concerning that the proposed development is forecast to enable a 52% increase in aircraft movements compared to the future base case – and a 139% increase compared to today. The Applicant fails to set out how this could be compatible with UK climate change commitments. 3.2 Even the Applicant’s own estimates – based on a limited apportionment of total flight emissions – project an increase of around 1 MtCO2e which the Applicant states will require 0.774% of the UK’s carbon budget for 2033-2037. This is a significant proportion to be claimed by a single development at a single airport and this runs directly counter to the UK achieving its climate change obligations. The Applicant commits to achieving net zero airport operations on the ground by 2040, but this has to be set against the very significant emissions increase from aircraft operations in the air that it enables. 3.3 The ‘Green Controlled Growth’ framework sets limits for carbon emissions – but with these limits proposed at only 5% below the faster growth forecast, this allows for almost unimpeded growth and essentially relies heavily on action from other carbon emitters. Moreover, the use of four broad phases results in a series of substantial step changes in limit values between phases, but with the limit values decreasing in ambition over the duration of each phase; this could be addressed with a commitment to continuous improvement based on interim targets within each phase. 3.4 We do not believe it is appropriate to use offsetting for ‘Scope 3’ emissions, particularly with regard to surface access. The Applicant has substantial levers at its disposal to encourage sustainable mode shift – including varying parking and drop-off charges and DART fares – and offsetting reduces the incentive to fully tackle these emissions. 3.5 The Applicant should also set out concrete plans for reducing the emissions of aircraft, including detailed measures to increase use of sustainable aviation fuel and encourage newer, lower emission aircraft. These plans should also include achieving level 4+ of the Airport Carbon Accreditation (ACA) scheme. 4. Noise 4.1 Though the populations affected are generally outside London, we would expect the Applicant to fully assess and address the noise impacts of the proposed development. There is no escaping the increased noise exposure for local communities as a result of the significant proposed increase in flights. It is important that the benefits of new technology – notably new, quieter aircraft – are shared with local communities and the assessment rightly focuses on the comparison with the future ‘Do Minimum’ rather than current operations. 4.2 Assessment of a suite of noise metrics to better understand the impacts is critical and we welcome the Applicant’s efforts in this regard. It is also worth noting the World Health Organization (WHO) Europe guidelines which reflect the latest scientific evidence. For aircraft noise, these recommend 45 dB Lden for average noise exposure and 40 dB Lnight for average night noise exposure, as the limits above which there are adverse health effects. 4.3 Given the greatest noise impacts of the proposed development appear to relate to the night-time period – and given the particularly negative health impacts associated with sleep disturbance from aircraft noise – the Applicant needs, in particular, to set out its commitment to limit night-time movements. 4.4 Air noise insulation is a part of the mitigation strategy; the Applicant needs to consider whether the proposed thresholds are sufficient to include all those experiencing substantial noise exposure – and whether residents will be able to fund their share of insulation when only eligible for a contribution from the Applicant. 5. Air quality 5.1 The severe health impacts of air pollution have been brought into sharp focus in recent years and the Applicant must demonstrate how it is addressing this, including from aircraft themselves, in the vicinity of the airport, as well as surface access to and from the airport. 5.2 The Applicant’s assessment is largely limited to the Luton area. However, TfL is concerned that the Applicant has not sought to understand what the potential air pollution impacts are beyond that, and in particular within the Greater London area. London remains a key origin/destination for Luton airport passengers and the weakness of the Applicant’s approach to sustainable surface access (set out in the section below) raises concerns of increased highway flows with a detrimental effect on air quality – particularly on roads already close to or above legal limits. 5.3 As well as providing a more complete assessment of air quality impacts, it is essential that the Applicant goes much further in committing to measures that will reduce car trips to and from the airport, for example as set out in the section below. 6. Surface Access 6.1 Given the importance of securing sustainable mode shift, not least to reduce the carbon and air pollution impacts, the lack of ambition is of deep concern. The proposed limits sought by the Applicant in the later phases of the scheme – targeting 45% on sustainable modes – are only around 5% higher than currently. Recent months have witnessed transformative improvements in rail access to Luton Airport – notably the opening of the Direct Air-Rail Transit (DART), the increase in East Midlands Railway services to Luton Airport Parkway and the opening of the Elizabeth Line providing onward connections from Thameslink services at Farringdon. These will help to deliver a substantial uplift in rail travel to and from the airport in the base case – so any development proposal should be seeking to substantially exceed the base case rail mode share and be underpinned by no increase in car trips. 6.2 The aspirations for staff journeys likewise lack ambition, with a target of 40% by sustainable modes in the end phase, compared to around 31% pre-pandemic. It is also notable that the Applicant’s definition includes car sharing, as well as factoring in working from home. Given the proximity of Luton to the airport, the Applicant could commit to measures designed specifically to increase the proportion of staff travelling to work by walking (6%) and cycling (2%), in addition to taking concrete steps to encourage public transport use. 6.3 The net result is that, under the Applicant’s proposals, the majority of surface access trips will be by non-sustainable modes. Indeed, it is forecasting very significant increases in vehicle trips - 51% in the case of passenger AM and PM peak journeys. It is proposing a 77% increase in passenger parking capacity to support the increase in car trips. There is no justification for any increase in vehicle trips and such an approach is completely at odds with the airport’s environmental obligations. 6.4 The Applicant must set out a credible plan for driving sustainable mode shift, underpinned by committed measures. Rail has a key part to play but this should also include the instigation of new bus and coach services in corridors where rail is not a competitive alternative – including to London suburbs away from the Midland Main Line. The Applicant should detail how it will use charges for parking and drop off to reduce car demand in favour of sustainable modes – and be mindful of the potential cost advantage of cars for larger groups travelling together. The monies raised should be hypothecated to fund sustainable surface access enhancements. 6.5 We also seek clarification about the modelling of capacity on rail services – primarily Thameslink and East Midlands Railway services – but also onward connections to the Elizabeth Line. The modelling appears to use existing capacity levels and assume a 3% increase in passenger numbers each year. This does not align with the step change in passenger numbers proposed under the phased expansion and appears relatively primitive in its methodology. It appears to make assumptions about available capacity which are not necessarily warranted and to look at a limited snapshot of demand rather than seek a fuller understanding of demand across the rail corridor and the implications for crowding. 7. Green Controlled Growth framework 7.1 The Applicant has devised the Green Controlled Growth framework as core to its application. It is a novel mechanism for seeking to ensure that each phase of expansion can only proceed so long as environmental conditions are met and in principle, there is merit in such an approach. 7.2 However, the mechanism can only be effective if underpinned by ambitious limits which meaningfully address the environmental impacts. For the most part, the limits are not sufficiently challenging, rendering this framework, to a great extent, toothless. The basis for the limits needs to be fully evidenced and sufficiently stringent that additional environmental impacts can be avoided. 8. Conclusion 8.1 TfL requests that the Examining Authority considers the points raised in this representation and investigates these during the DCO examination process. TfL will welcome the opportunity to expand on these points at later stages in the process.