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London Luton Airport Master Plan Response Letter from Harpenden

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London Luton Airport Master Plan Response Letter from Harpenden 7th February 2006 Ref: E19/25510/CH/ASP London Luton Airport Operations Limited Project 2030 Navigation House Airport Way Luton Bedfordshire LU2 9LY Dear Sirs RE: LONDON LUTON PROJECT 2030 - HARPENDEN TOWN COUNCIL’S FORMAL RESPONSE The draft letter that was sent to you on the 26th January 2006 was considered at the Full Council Meeting on Monday 6th February 2006. Please find below our formal response. FORMAL RESPONSE Harpenden Town Council herewith submits its written response to London Luton Airport Operations Limited (LLAOL), in respect of its published draft Master Plan, which we understand when finalised, will be submitted to the Government, this leading from the previous publication of the White Paper, The Future of Air Transport. Before examining the detail of the proposals, we would wish to say that the ‘predict and provide’ policy of the government, is in our opinion fatally flawed, as whereas The White Paper presumes no restriction on demand, air travel, especially low-cost passenger transport, is very sensitive to price variations, and other factors like the present absence of VAT on aviation fuel, and accordingly, predicted future demand could well have been overstated. In particular, air travel from London Luton Airport (LLA) sucks in many passengers from the Midlands, who could be better catered for by expanded services more locally, such as at Birmingham and East Midlands airports, thus saving the already heavy usage of the road network. Whilst we recognise that there is a local need for both business and pleasure air traffic movements from LLA, and not being against modest and reasonable expansion of these services, we are nevertheless, only in favour of some increased local supply, purely to meet these needs. We are certainly not in support of LLA becoming a hub airport in the East of England Region, , which would blight the area beyond recognition, which is what the proposals would undoubtedly bring about. We recognise there is a local employment factor, which would increase with expansion, but we do not believe this to be a valid argument for proposals which would in themselves lead to such massive local environmental degradation. It is our opinion that LLAOL in presenting its Project 2030 proposals has well exceeded its governmental brief, by proposing an additional new runway and southern terminal, with the new runway being 950m south of the existing runway, which by default would provide the option of a two-runway airport in the future should passenger growth justify this. This goes further than the White Paper, which supported the growth of LLA up to the maximum use of a single full-length (3,000m) runway. This could be said to imply either the extension of the existing runway or the construction of a replacement runway. It is noted that the official view of LLAOL is that existing runway will be utilised as an emergency runway and during periods of essential maintenance, as at London Gatwick today. However it is our understanding that because of the close proximity of the two runways at London Gatwick, it is impossible to operate from both runways at the same time. This would not be the case at London Luton Airport. Aviation Emissions The Government itself admits that aviation emissions could amount to about a quarter of the UK’s total contribution to global warming in 25 years’ time, as other industries clean up their act. Between 1990 and 2003 greenhouse gas emissions from British Industry fell in line with the Government Kyoto targets. But greenhouse emissions from air transport rose by more than 85%, according to the Office for National Statistics. This is not sustainable and will present a major dilemma to a Government that is still actively promoting large-scale airport expansion, whilst trumpeting its concern over greenhouse gas emissions and global climate change. Furthermore, in 2008 an EU directive will come into force that will set tight new limits on emissions of nitrous oxides, that could well be exceeded in the Luton area following the planned expansion. The Government White Paper when supporting the growth of London Luton Airport up to the maximum use of a single full length runway based broadly on the current alignment, added that this was on condition that the environmental impacts will be carefully controlled and adequate mitigation provided where necessary. Aircraft Noise Of particular concern to Harpenden Town Council and our residents, would be the increased noise contours affecting the Town, with Kinsbourne Green at its northern extremity being only some 3.5km from these, with this distance estimated to reduce to only 2km by 2030. Also of concern is the fact that the position of possible new flight paths are not available at present, and it is important that these should be available at the planning application stage. Whilst the proposed new runway positioning would allow for improved noise conditions for a large number of residents in southern Luton and Caddington area, other residents of the areas further south, including more residents of Harpenden would be exposed to significant noise impacts for the first time, not a scenario the Town or the residents would welcome, and this certainly would blight areas of North and Central Harpenden, and Kinsbourne Green much more substantially than at present. The effect of night flights would also impact on this area, particularly as there appears to be an uncontrolled increase in the number of night flights from the airport. The number of people affected by night noise within the 48dBA contour is projected to increase from 6,731 in 2004 to 16,010 in 2030. Of concern is the projection that 40% of night flights will take place during 06.00 to 07.00, this being a particularly sensitive time for residents of our Town some of whom who will be even more affected by aircraft noise. There should, more importantly, be constraints on the number of night flights permitted as LLA expands, in a similar way to the current control of night flights at Heathrow, Stansted and Gatwick, and it would be hoped that this aspect would be better covered when the planning applications are submitted. Infrastructure It is noted that a number of surface access improvements are proposed that should improve access to LLA and the south and east of Luton, including a new tracked transit system from Luton Airport Parkway Station to the airport, with other surface access improvements at the planning stage including a coach interchange and park and ride facility at J10 of the M1 and improvements to the A505 north of Luton and Dunstable. However, we do not consider they go far enough as there is a lack of good road infrastructure serving east-west routes, which if improvements are not made will place more pressure on inappropriate routes such as the B653 through Wheathampstead and Batford. Is there not a case for a full Transport Assessment covering a wider area than is currently being considered, with serious thought being given to possible mitigation measures to minimize the impact? Can the planned infrastructure match the growth forecasts; it is reliant on infrastructure schemes developed by others? One of the present improvements is the widening of the M1, but this is to cope with current congestion and the planned additional housing in South Bedfordshire and Milton Keynes. It would not meet the increased demands of traffic to LLA. Already, when there is an accident on the M1, the local roads, including the A1081 become gridlocked due to diversions. As regards travel to and from LLA by rail, the Thameslink line is already at maximum capacity during peak times of the day, and any upgrade will only take care of the present overcrowding, not allow for a doubling or trebling of airport related passengers. Whilst the airport operators will no doubt be called upon to fund some of the airport related access infrastructure improvements that directly benefit them, we expect this would be minimal, with the taxpayer picking up the major portion of the cost, whilst the main beneficiaries would be the airport operators and Luton Borough Council (LBC). On the latter aspect we still have a problem with the apparent conflict of interest where LBC is the owner of the airport, a beneficiary in any increased turnover, plus also being the Local Planning Authority. Green Belt Your preferred Option D gives serious concerns as it involves the loss of a large area of well-appreciated Green Belt land, much of it categorised as Landscape Conservation Area, and spread across South Bedfordshire and Northwest Hertfordshire. The other three runway options require much less of a land grab. Much of the Option D enclosed area will end up covered by concrete and consumed by car parks and other infrastructure, as has happened at Stansted, causing a major blight on the land. Added to this, whilst the continued expansion of LLA will bring further employment prospects, this would increase the need for more housing development and additional pressure for development in the Green Belt. Site There are strong arguments why Luton is the wrong place for expansion on the scale envisaged: The government’s own calculations show it is the least cost effective location It is the only option without a direct rail link into the airport People would have to come by car: Luton derives more of its revenue from parking than any other London airport It is closed by bad weather more than any other London airport, being at 520 ft The airspace overhead is more crowded It is nearest a built up area It would involve a huge loss of Green Belt land (as already stated) In conclusion We cannot support the expansion on the scale as projected.
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