Back to list London Luton Airport Expansion

Representation by Philip Nalpanis

Date submitted
23 June 2023
Submitted by
Members of the public/businesses
  1. How on earth can Luton Airport even be considering expanding capacity, let alone by78%, in the middle of the Climate Emergency? Demand cannot be allowed to grow that much if the UK is to meet its Net Zero target. The Committee on Climate Change (CCC) report on aviation for the Sixth Carbon Budget [REDACTED] recommends the Balanced Net Zero Pathway as the optimal way forward and says about it: "The Balanced Net Zero Pathway does allow for some limited growth in aviation demand over the period to 2050, but considerably less than a ‘business as usual’ baseline. We allow for a 25% in growth by 2050 compared to 2018 levels, whereas the baseline reflects unconstrained growth of around 65% over the same period. We assume that, unlike in the baseline, this occurs without any net increase in UK airport capacity, so that any expansion is balanced by reductions in capacity elsewhere in the UK." Luton Airport's plan for expansion exceeds the case of unconstrained growth, and that to be achieved some 10 years before the 2050 target for net zero. Such expansion is simply and completely unacceptable in itself. All the potential measures to mitigate the emission of greenhouse gases (GHGs, principally carbon dioxide) on the scale of commercial aviation are at present unproven. There is no such thing as "sustainable aviation fuel" despite the claims of the CCC. Furthermore, since many UK airports have plans to expand within the next two to three decades, Luton Airport taking such a large share of that growth cannot be justified. Luton Airport achieved its 2028 growth target some 10 years early. They cannot be trusted to achieve their target 32 million passengers per year as late as 2040, so the GHG emissions from the additional flights are almost certain to make achieving Net Zero in 2050 far more difficult. However, with a growing realisation amongst the UK populace of the impact of flying (if not to the level of Sweden's "flygskam"), coupled with the discovery during Covid lockdown that much business can be transacted successfully without flying to meetings or conferences, there is no guarantee that there will be the demand for such expansion. Luton Airport's case appears to rest on "if we provide the capacity, they will come" but this is by no means guaranteed, especially as far out as 2040. The other key issue is noise. Luton Airport has shown no regard whatsoever for the residents of north St Albans and Sandridge (probably at least 10,000 residents), and probably other places too. Until the CAA have resolved the problems of capacity in SE England and provided flight paths out of Luton Airport that don't overfly such heavily populated areas, Indeed, it's not even clear that the CAA will make that provision. In short: there is an unacceptable noise problem now, which will only get worse if the airport's growth expectations are met. Until this matter is resolved satisfactorily, Luton Airport should not even be applying for a DCO. 2. As already stated, growth is neither needed nor compatible with the UK's Net Zero target. In any case, the future growth of air travel from Luton and more generally is extremely uncertain in the light of Brexit, Covid and increasing disinclination to fly - whether as a result of increasing awareness of the environmental impact of flying or businesses realising that flying to meetings is unnecessary and time-wasting. The local economy would be far better served by developing renewable energy industries. Regeneration of Luton should not be dependent on airport expansion; other ways of achieving it should be considered. Indeed, Luton Borough Council has been told to reduce its financial dependence on the airport. Expanding Luton Airport is the wrong investment in the wrong place. Contrary to the consultation document, the demand projections don't in any way take into account the carbon implications of growth since they seek such huge growth not only in passenger numbers but in flight numbers, which in turn will lead to unacceptable increases in GHG emissions. The airport has poor connectivity other than by road. Growth in passenger numbers will inevitably lead to growth in road traffic, to Luton Airport Parkway for the DART and to the airport itself. This too will contribute negatively to the UK achieving its Net Zero target. This growth will inevitably increase congestion on the roads leading to the airport; this will be exacerbated when problems occur on the M1. 3. The biggest benefit you can provide to neighbouring communities is social, namely to resolve the noise issue. Until this happens, further expansion should not be permitted. The desired benefits could be obtained in other ways, for example development of sustainable industries such as renewable energy. These should be considered holistically rather than focusing and relying on airport expansion. This would create a more diverse local economy. 4. You claim to be seeking to "be a good neighbour by minimising and mitigating environmental impacts including air pollution and noise ...". You aren't a good neighbour now to residents of Sandridge and north St Albans, so why believe this situation will improve? In 2021 or 2022 Luton Airport won the Greenwasher of the Month award. "Green controlled growth" is an oxymoron. Furthermore, existing "binding" limits for the airport's noise and its growth have already been breached, with the result that the airport has sought to have those limits raised rather than to remain with them. The airport cannot be trusted to remain within those so-called "binding limits". The composition, powers and degree of independence of the body tasked with ensuring the airport remains within those limits, year by year and not simply when the project is complete, are unknown and uncertain. The fundamental basis for the design of the expanded airport is seriously flawed in regard to the environmental impacts. A biodiverse habitat built up over decades or more, once destroyed, is lost for ever; it can't be "replaced" and new areas set aside to increase biodiversity will take years to mature. As loss/destruction of biodiversity is the other major environmental issue besides climate change, and is to be addressed by Biodiversity COP15 later this year, insufficient regard is being paid to existing biodiversity. 5. Targets for public transport mode share are all every well but people will choose the most convenient way of travelling to the airport. Since access from catchment areas away from the Midland Main Line is limited to buses, it is unlikely people who don't live close to a station on that line will choose to travel to the airport by bus. The airport has no control over how passengers travel there, so achieving 45% of passengers’ journeys to the airport being made by public/sustainable transport cannot be guaranteed. The Lower Luton Road is not suitable for the volume of traffic it currently carries. With the planend increase in passenger numbers, the volume of traffic on this road is likely to be unsustainable. (This is the road I use to reach the airport; I have seen traffic towards the airport backed up as far as Batford when the M1 was closed by an accident.) 6. The construction work will create noise, vibration, dust and emissions. Wigmore Valley Park, which is to be concreted over, is located on an old landfill site which contains oil drums and other toxic waste, hence is known to be hazardous. The construction activities on that site are likely to result in the release of toxic materials and flammable gases, posing unquantified and possibly unacceptable risks. The Code of Construction Practice needs to acknowledge those risks and spell out in detail how they will be managed. 7. The other environmental impacts - from travel to and from the airport, construction activities and ground operations - can be mitigated but not eliminated. The proposed development would be significantly damaging to people, the environment, local quality of life and well-being. This is already the case in Sandridge and north St Albans. The necessary increase the hours during which flights are permitted to take off will increase that damage to an unacceptable level. Overall, the environmental effects of expansion, in particular the increased number of flights and consequent increased emissions of greenhouse gases (not just in the vicinity of the airport but throughout the flight), will be extremely damaging, will make it more difficult for the UK to achieve Net Zero by 2050, and will be overwhelmingly negative whatever mitigations the airport seeks to put in place. 8. The planned growth in capacity cannot in any sense be considered green or controlled. It can't be considered green in the midst of the climate emergency and in the light of the Committee on Climate Change's report on Aviation (see 1 above and in particular my quote from the previous consultation report). It can't be considered controlled because Luton Airport and Luton Borough Council have failed to exercise control in the past and cannot be trusted to do so in the future. It's far from clear that the supposed independent control will be effective, for the reasons set out in 4 above. The supposed limits will, it appears, be set by Luton Airport to meet their growth trajectory and furthermore will be capable of variation if the growth trajectory is exceeded (as it has for the expansion planned to 2028). 9. Concreting over Wigmore Valley Park to build a new terminal, aircraft stands and car parks is detrimental to the essential open space which acts as a buffer between local housing and the airport. It also destroys valuable ecology in this County Wildlife site, which contains mature trees, ancient hedgerows and established wild orchids. A narrow strip of farmland further away from local houses is not adequate recompense to the community or the ecology. Agricultural farmland should in any case be preserved for food production. 10. The noise limits shown in the previous consultation report demonstrate how completely inadequate are the measures taken by Luton Airport to minimise noise impacts on residents further away from the airport, as the LOAEL and SOAEL are set at levels well above those which materially affect those residents' wellbeing and quality of life. No amount of monetary compensation, no amount of measures such as double glazing, can compensate for loss of wellbeing and quality of life. In the summer, people want to be outdoors during the day and have windows open at night (some may have windows open at night all year round), hence measures to mitigate internal noise will be of no value. Even in winter, aircraft noise is audible in my double-glazed house in Sandridge, especially late at night. Whilst the reduction in flights due to Covid has provided some relief, the anticipated recovery of air travel to pre-Covid levels and then growth in flights from Luton Airport will worse than nullify that relief. 11. Genuinely putting the community first would mean listening to the non statutory consultation response, in which people overwhelmingly rejected these proposals for significant further expansion of Luton Airport. The previous consultation document paints a very one-sided picture in favour of the expansion proposals. The environmental impacts are played down in favour of claimed jobs and economic benefits which themselves are over-stated and poorly evidenced. The whole project will add to UK carbon emissions and make it harder to achieve net zero, which is against government policy. There is no certainty about the noise impacts because limits and controls have not been provided.