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Representation by Luton Council (Luton Council)

Date submitted
23 June 2023
Submitted by
Local authorities

Re: Planning Act 2008 (as amended) Application by London Luton Airport Limited for an Order Granting Development Consent for the London Luton Airport Expansion project Luton Council welcomes the opportunity to be able to provide a relevant representation for the proposed Development Consent Order (DCO) submitted by London Luton Airport Limited and accepted by the Planning Inspectorate, on 27 March 2023, for examination. The purpose of this relevant representation is to outline the main issues which the Council, as one of five host authorities, believes should be considered as part of the process. The development plan for Luton is the Luton Local Plan 2011-2031, adopted in November 2017. The Local Plan includes numerous policies that are relevant when considering the airport growth, with a site specific policy for the airport itself, namely policy LLP6. The Luton Airport Expansion NSIP obviously envisages development extending beyond the plan period and therefore the Examining Authority will need to take this into account when determining what weight should be attached to specific policies within the Local Plan. The promoter has identified a whole raft of Government policy that is relevant to the consideration of the Luton Airport Expansion DCO, noting that whilst the Government supports airports making best use of their existing runways, it also identifies that there can be positive and negative impacts. Government aviation policy emphasises that relevant considerations should be taken into account, particularly economic and environmental considerations and proposed mitigations. These, we anticipate, will then be the main issues for the Examining Authority to consider in relation to the Luton Airport Expansion DCO. Luton Council identifies the following as the main issues relevant to this authority for consideration by the Examining Authority: • The socio-economic impacts, not limited to the creation of jobs and boost to the local and regional economy, but also the wider socio-economic benefits of aviation. • Surface access, including the impact upon the local and strategic highway network, upon public transport and a modal shift, as well as the implications for emissions associated with transport to and from the airport. • Noise impacts associated with the increase in the number of passengers and consequently the number of vehicular and aircraft movements at Luton and compliance with the Government aim to limit, and where possible reduce, the number of people affected by aircraft noise. • Climate change and greenhouse gas emissions from airport operations and surface access. • Air quality, consideration of pollutant concentration levels that may affect human health and appropriate mitigation measures. • Public health and wellbeing of local residents (all of which will be influenced by the issues above) • Mitigation measures, controls and enforcement, including the operation of Green Controlled Growth and measures to ensure that the benefits of growth are shared with the local community. There are other areas that the Promoter has identified in its application documents, but these either have been addressed by the Promoter with appropriate mitigation to the satisfaction of Luton Council (such as the historic environment), or they have lesser impact upon Luton (for instance green belt and landscape and visual impacts). Under separate cover we shall provide the Examining Authority with what we consider to be the Principal Areas of Difference (PAD) with the Promoter. This has been informed by work undertaken by outside consultants appointed by the five Host Authorities and our own internal technical specialists. Whilst the outside consultants’ work was commissioned by the Host Authorities, Luton Council does not necessarily agree with all of the conclusions from that work which may be presented in the Relevant Reps of some of the other Host Authorities. Luton Council is proactively engaging with the Promoter in addressing the issues raised above, prior to the production of the Council's Local Impact Report (LIR). We are working constructively with the Promoter to ensure that this will be subsequently reflected in a Statement of Common Ground (SoCG) to be submitted to the Examining Authority.