Representation by England's Economic Heartland (England's Economic Heartland)
- Date submitted
- 23 June 2023
- Submitted by
- Non-statutory organisations
England’s Economic Heartland (EEH) would like to register as an interested party to the Development Consent Order for the expansion of Luton Airport. EEH is the sub-national transport body (STB) for the Heartland region. We represent the transport authorities covering the area from Swindon, through Buckinghamshire, Oxfordshire, Milton Keynes and across to Cambridgeshire, and from North and West Northamptonshire councils, Central Bedfordshire, Bedford Borough, across to Luton and Hertfordshire. EEH as the STB is responsible for advising government on improvements to transport infrastructure and services in the region required for economic growth and achieving net zero. Luton Airport is the only major airport located within our region’s boundaries. It is a significant asset: as a key international gateway, a major regional employer and a key contributor to the economy. As one of the top five busiest airports in the UK, it is a focus for European services and a key hub for private business aviation services. EEH’s Transport Strategy, published in 2021, sets out the strategic ambition for the region. This includes a commitment to support net zero transport by 2050; improve quality of life and wellbeing through a safe and inclusive transport system accessible to all; support the regional economy by connecting people and businesses to markets and opportunities; and ensure the Heartland works for the UK by enabling the efficient movement of people and goods through the region and to/from international gateways, in a way which lessens its environmental impact. The strategy states that, 'as one of the world’s leading economic regions our continued success is dependent upon being connected globally’. Emissions from aviation were not considered to be in the scope of the transport strategy and we acknowledge that our local authority partners may wish to make their own representations, for example around the impact of expansion on flight paths. The EEH transport strategy actively encourages investment in improved, decarbonised surface access connectivity that addresses and reduces the environmental impact of international gateways. We are pleased that the proposal includes a surface access strategy. Delivery of the Direct Air Rapid Transit (DART) has improved connectivity between Luton Airport Parkway Station and the airport. Improving travel opportunities via national rail services stopping at Luton Airport Parkway is key to reducing the need to travel to the airport by private car. EEH believes that the proposal to expand Luton Airport should be viewed through the lens of the strategic ambition for the region, as well as within the context of national targets, including those in relation to decarbonisation of the transport system. To support the transport strategy EEH is currently developing connectivity studies that show what the most effective connectivity solutions are for key corridors across the region, including those that cover Luton Airport. The evidence captured will be used to shape investment proposals going forward, through EEH or in support of individual local authorities’ priorities. They are guided by the policies set out in the EEH transport strategy and steered by our local authority partners. The package of interventions identified will form a key part of our investment pipeline for the region. We believe the outputs from the connectivity studies, will provide useful evidence regarding future opportunities to improve surface access to the airport. EEH recognises the economic significance of the United Kingdom’s aviation network. The ability to connect regions economically has enabled trade links to be established both domestically and internationally. Such linkages support economic activity across the region and beyond, and bring significant benefits to our businesses and residents. The proposed expansion of the airport will create opportunities to generate benefits for the local economy and residents, especially in the use of a local airport, thereby providing relief to other parts of the wider South East airport system. However, the implications of the proposed expansion, including its environmental implications need to be carefully considered and appropriate measures put in place to ensure that the proposal is consistent with the wider strategic ambition for the region. We are pleased is a strategic surface access plan is included in the proposal. This must ensure the airport is accessible for workers, travellers, services and freight by more sustainable modes, and alternative fuels with a focus on decarbonisation to move away from dependence of combustion-engine vehicles for accessibility. The surface access strategy should be underpinned by the following principles: • Investment in the delivery of measures that improve local connectivity between the airport and the immediate surrounding area – those measures to be supported by proposals that actively engage airport employees (both existing and future) and encourage them to use active travel modes. The targets as a minimum should be to achieve pre-pandemic levels. It is noted that the current access is very vehicle focused with no cycling access and the walking route is up a hill and under the existing runway. • Investment in the delivery of public transport infrastructure including coaches and rail to provide an enhanced travel options for those accessing the airport from all areas of the EEH region. It should be noted that there are several areas close to Luton that have no direct public transport access to Luton airport. Connectivity east and west will be key to providing workers and passengers more sustainable travel options. • There should be ambitious targets for modal split both for workers and passengers that as a minimum are above pre-pandemic levels – with stretch targets to achieve more ambitious future modal split. • Funding should be provided to ensure that transport infrastructure and revenue funding is provided to meet modal shift targets to support alternative modes of travel to all parts of the region - not just the local Luton area. • Car parking – significant increases in car parking are proposed but increases to on-site car parking should only be considered once opportunities to improve local connectivity and public transport infrastructure and services have been fully exploited. • Investment in improved highway infrastructure should prioritise improvements that support local connectivity and public transport infrastructure and services. • Midland Main Line – the applicant should discuss with the East Midlands Railway franchisee the level of service required to enable Luton Airport Parkway station to serve as a gateway to the airport: the significance of rail will increase further as a result of the proposed expansion, and this must be reflected in the level of service provided with seamless connectivity with the DART. • There should be safeguarded links with future East West Rail and in particular identify what additional services might be required in order to offer additional travel opportunities through effective interchange between Midland Main Line services and East West Rail. • Bus and Coach Provision – the proposal to establish a new coach station and a new bus station is welcomed. However there is a need for the applicant to work with service providers to identify the level of services required in order that this is realised and should be supported by sufficient funding to increase existing service frequencies and the range of destinations served by buses and coaches, especially east and west connectivity. • The applicant proposes a range of different mitigation approaches to offset the impact of the airport expansion at surface level on the environment. Whilst these are welcome, there is a need for the applicant to quantify how they will ensure the proposal are consistent with the national targets to bring greenhouse gas emissions to net-zero by 2050. This is pertinent, not only for surface access to the airport but also given the need for the aviation sector to make its own contribution towards achieving the net zero carbon target for the UK by 2050. The Applicant should be consider its own and airside operations and how these can contribute to net zero. . Given the strategic significance of the airport as an international gateway and focus for economic opportunities with the wider EEH region, we therefore, are registering as an interested party to ensure that the expansion of Luton Airport provides positive wider benefits to the region and that the surface access strategy ensures connectivity with the rest of the region.