Representation by Rob Payne
- Date submitted
- 23 June 2023
- Submitted by
- Members of the public/businesses
The plans for Luton expansion do not take into account the impact on the environment or those people living under the designed and redesigned aircraft design airspace, ie. AD6. The economic case does not stand up to scrutiny when the perceived economic gains have provably not been achieved to date and will not in the future. Luton Airport loses money. The council has over half a billion in loans to pay back. Luton is the most air-polluted town of its size in the country. But Luton council wants to increase passengers from last years 6.2 million up to 32 million per year. Previous expansions have not resulted in many extra jobs for local people. The arguments do not stack up when one consider that other European countries are cutting back the use of low cost airlines in recognition of the damage air travel does to the environment. I wish to object to the proposed expansion of Luton Airport, as set out in the application for the development consent order, on the following basis: - I have looked at the application document index, which runs to 23 pages and certain chapters of the ES. The volume of documentation and its technical basis makes it almost impossible for a resident to review and understand the application and come to a conclusion as to how they may be impacted by the prosed redevelopment. - I note that HS2 Ltd prepared Community Area Collections for each Phase of HS2, to assist residents in assessing how that development would impact upon and produced maps and plans to assist them. This type of summary has not been carried out for this application. - The Infrastructure Planning (Environmental Impact Assessment) Regulations 2017 require a non-technical summary (NTS) to be carried out. Whilst a NTS has been carried for this application, I do not think it is appropriate or adequate for a resident to understand the impacts of the proposed development on their home. - I believe Luton Rising should prepare Community Area Collections in relation to the application. Luton Rising should also inform residents how they are affected by the proposed development and what compensation is available to all those it has written to inform them that may be entitled to make a claim for compensation. Can you please require them to do this? - Having read at the Draft Compensation Policies, Measures and Community First document it appears that many households live within the area of noise contours for the proposed Noise Insulation Schemes. However, the base level on plan on page 28 of that document (Appendix A – Indicative Noise Map) is so unclear it is not possible for me to identify whether households are within the boundary for Scheme 2, 3 or 4. I would like Luton Rising to prepare a clear plan on a OS background, which enables individual properties to be identified so they can consider what Schemes they fall in and whether the proposed mitigation is adequate. I would also like a contractual commitment to provide appropriate mitigation and its maintenance. - It should be noted that I have not seen any consideration of how noise insulation would operate in the summer months when windows are open for ventilation. What proposals does the applicant have in mind for this? - The applicant also needs to consider and assess how those who work outside will be affected by the additional noise. No such assessment appears to have been carried out. Will the applicant be imposing respite periods for the residents of Bendish? The NTS and ES chapter on noise does not make that clear. - The application has not clearly set out why the additional capacity is needed. As a result it is not possible to balance the true need for expansion with the environmental impacts of the proposed development. - For example. The Planning Statement refers to the Need Case but this appears to be based on business travel. Luton Airport is not a business travel airport but a leisure airport. Only Heathrow and City Airport can be truly considered as a business airport. The proposed business case based on socio-economic facts for Luton are also nor adequately set out. The proposed development may benefit residents of Luton Borough Council as it is the owner but is that a valid reason for the expansion if it is at the expense if the wider environment. - Given the scale of the proposed expansion and the fact that Luton Borough Council owns the airport there needs to be a clear set of legal safeguards to deliver and maintain the proposed mitigation measures and requirements of the DCO. This should include third parties such as Bedfordshire and Hertfordshire County Councils as well as other authorities being able to require performance and not authorise further operations or development in the event of beaches. - For example, flight numbers should not be increased above carefully assessed thresholds until it can be demonstrated to those bodies that the mitigation has been delivered and is working. In conclusion, the application should not be granted consent until: - The impacts on homeowners are adequately assessed and presented to them; - The mitigation measures have been fully developed to be adequate all year round; - Details of the compensation that may arise are properly set out; - Respite periods are built in to the airport's operation; and - Adequate and independent enforcement measure are put in place.