Representation by PAIN (People Against Intrusive Noise) (PAIN (People Against Intrusive Noise))
- Date submitted
- 23 June 2023
- Submitted by
- Non-statutory organisations
DCO Application to Expand Luton Airport Capacity to 32million passengers per year. Summary of Relevant Representations by PAIN (People Against Intrusive Noise) PAIN is a non-profit making Notified Body which represents the interests of communities to the west of Luton Airport and seeks to minimise intrusive noise from aircraft. We actively participate in the London Luton Airport Consultative Committee, and its Noise and Track Sub Committee. PAIN opposes the Luton Rising DCO application on grounds that substantial expansion of Luton airport would create substantial overall harms which outweigh its claimed benefits. PAIN’s concerns are summarised below in the format requested, and information to substantiate these points will be provided in Written Representations. We respectfully urge the Examining Authority to ensure that all of these issues are thoroughly assessed. • PAIN believes that any benefits arising from the airport expansion are more than outweighed by the increased levels of noise. Increased aircraft noise will affect both people living close to the airport and further away. The adverse effects include adverse health effects, increased annoyance, reduced amenity, and reduced house prices. • The noise levels presented by the Applicant to support the proposed Development Consent Order (DCO) and in ES Chapter 16 form a crucial part of the evaluation of the noise impact of the airport expansion. The noise levels are predicted using a theoretical noise model (AEDT). A validation exercise was undertaken by the Applicant which showed i) that there are unexplained systematic noise level differences for some aircraft types, and ii) after correcting for the said differences, the measured noise levels at some noise monitor locations agreed well with the predicted levels, whereas others do not. • No satisfactory explanation has been given for the above differences. It appears that data from those noise monitor stations where agreement was not obtained were removed from subsequent data analysis, with “justifications” that are questionable. Until this matter is resolved PAIN has little confidence in the predicted noise levels, and the findings obtained using those predictions. • There are concerns about the Noise Envelope approach that is being proposed by the Applicant. The proposed approach is not consistent with the recommendations given by the NEDG (which contained local representation). • There are further concerns about the general thrust of the GCG approach, in particular that there is a lack of timely control to be able to halt inappropriate airport expansion, and the process favours industry and the airport operator in almost all respects. For example, the “sharing” of benefits seems to have been interpreted by the airport operator to allow using quieter aircraft as a mechanism simply to enable additional aircraft movements. • Several of the Applicant’s approaches appear to be contrary to local planning Policies, and aviation Policies. • With regards to ES Chapter 16, PAIN believes that a material omission has been identified from Section 16.12. That is, increasing temperatures caused by global warming will cause a reduction of air density that reduces proportionally engine thrust, and lift. To create the same rate of aircraft climb (to minimise the ground level noise at any given point) requires increased engine power, which will result in increased noise levels. Such increased noise levels will inevitably occur near to the airport runway, and also further afield as the aircraft climbs. • The Applicant uses predicted noise levels to justify Luton airport’s growth (ES Chapter 16 and Appendix 16.1). Since the above physical mechanism increases those levels, PAIN believes this concern needs to be considered and addressed by the Applicant.