Representation by Chilterns Conservation Board (Chilterns Conservation Board)
- Date submitted
- 23 June 2023
- Submitted by
- Other statutory consultees
The Chilterns Conservation Board submits the following ‘registration comments’ in support of our application for registration as an interested party in the examination (notwithstanding our role as a statutory consultee). Our initial concerns about impact of the proposed expansion of London Luton Airport on the Chilterns AONB and its setting can be summarised as: • Direct impacts on the AONB and its setting of the physical infrastructure of the expanded airport. • Direct impacts on tranquillity (including both aural and visual intrusion) and air quality arising from increased overflying. • Direct impacts on tranquillity and air quality arising from increased traffic to/from the airport, including impacts on designated sites beyond the cordon considered by the proposal so far. • Indirect impacts arising from increased development pressures, including housing, employment and associated infrastructure, resulting from the increased economic activity that is part of the promoter’s justification for the airport expansion. • Wider impacts of increased carbon emissions, etc. (although we recognise the Government’s position on the relationship between their net zero ambitions and the continued expansion of air travel as a significant factor that undermines a climate emergency-led response to the proposal). • Impacts on the Chilterns chalk aquifer and the rivers Lea/Lee and Mimram. The examination into the DCO, and any decision based upon it, will need to comply with the duty imposed by section 85 of the Countryside and Rights of Way Act 2000 in having regard to the purposes of conserving and enhancing the natural beauty of the Chilterns AONB. The examination into the DCO should also take account of the proposed expansion of the Chilterns AONB, currently being investigated by LUC on behalf of Natural England. The area of search for the potential AONB designation has not yet been published, but is likely to include land in the vicinity of the airport. The current early stage of the designation process would suggest that limited weight should be applied to it. However that position could change as the DCO examination progresses. Both projects therefore need to take account of each other iteratively as they progress. However, CCB’s position is that the potential impacts on the existing AONB, it setting and associated habitats, such as the Chilterns chalk streams, should have great weight in the consideration of the DCO proposal, regardless of progress with any new designation. Overall, while recognising that it remains national policy for aviation to expand, even in a climate emergency and biodiversity crisis, CCB considers that any decision for the general expansion of aviation to take place in the vicinity of the Chilterns AONB, especially so close to the HS2 corridor, needs very careful justification and attention to detail in terms of mitigating, reducing, or preferably avoiding its obvious significant harmful impacts.