APPENDIX 5 12/01400/FUL Representations received from Parish Councils

Name Comments Key issues O/S Response

Michael Curry The Town is affected by easterly arrivals to London Luton Airport – the flight Town Clerk path following roughly the line of the Upper Icknield Way on the north Town Council western edge of the town - and westerly departures where the flight path is Increased flights Points noted and on the south eastern edge of the Town (broadly the line of Station Road). addressed in committee (Letter) Consequently any development at London Luton Airport generating the report potential for increased flights is of significance for Tring residents.

Tring is also directly affected by Heathrow departures passing south to north across the town and stacking hold for Heathrow at . The proposals should be considered within this wider context.

The Town Council considers:  that insufficient consideration has been given to extent of the environmental impact of the measures on the surrounding communities and designated areas Environmental impact  there is inadequate mitigation of the impact; and inadequate measures of control

The targets and objectives set out in London Luton Airport‟s Noise Action Plan 2011-2015 will be compromised should the proposal go forward. The imposition of vigorous, enforceable controls especially in relation to night flights must be a condition before any permission may be granted.

The applicant has proved an „Environmental Statement‟. When reviewing the statement:

 The coverage of which falls short of an appropriate Environmental Impact Assessment report (The use of the nomenclature “Statement” is indicative of this assessment when the industry norm is “Environmental Impact Assessment”)  An Environmental Impact Assessment is necessary to assess compliance with the National Planning Policy Framework's sustainability criteria  The Environmental Statement relates solely to the physical site of the airport and nearby viewpoints, with no consideration of overflown communities and the important viewpoints of the Chiltern Hills and its nationally significant AONB  Both aural and visual intrusion will be experienced over the sensitive landscape of the AONB. There is inadequate regard within the proposal to the statutory obligations of Government to protect and conserve AONBs, as enshrined in the Countryside and Rights of Way Act 2000 s85

158 APPENDIX 5 3.2.2 London Luton Airport to become a 'designated' airport under the same regulatory authority for noise abatement procedures as the other London airports of Heathrow, Stansted and Gatwick.

The scale of the proposal puts London Luton Airport on par with the other airports serving London. It should be subject to the same regulation. Regulation LLA is not a CAA Night flights are of particular concern as these have the greatest adverse “designated airport” in impact on communities when overflown, particularly by low-level arrivals. respect of night Whilst there may be a reduction in the proportion of night flights compared movements with total movements this does not preclude an absolute increase.

A voluntary approach to noise regulation is inappropriate for the scale and future development of London Luton Airport 's operations. To provide Night flights security to communities London Luton Airport 's night operations should be independently regulated by the CAA, a role it fulfils for other London airports.

3.2.3 Increases in average noise levels. The importance of average noise If LLA was designated, levels – the continued disturbance to residents - is underplayed in the the levels would be set application. Twice as many flights mean twice as much disturbance by the CAA and outside because of noise. any local controls. This could mean that any Reference is made to potential reduces in peak levels of noise (The real quota count stated benefits of new technologies that reduce noise will only be felt once the could result in a higher technology is in place throughout operators‟ fleets. This will take a long time quota count. especially cargo operators) but this does not offset the considerable impact of increased average noise levels of more flights and larger aircraft.

In addition to the Council‟s principle concern of the damage to the environment as a consequence of these proposals (The Town Council in Technology making this objection is aware of the potential economic benefits to the area Controls proposed to arising from the development of the airport but considered these did not encourage the use of outweigh the environmental costs of the development) wishes to raise the modern technology following objections in relation to the context of the proposal and its determination.

3.3.1 Determination of these proposals should be taken at the national level not at local Council level because:

 The scale of the proposal. It should be treated as a Nationally Significant Infrastructure Project because of the significant impact upon their local communities and nationally significant landscapes  The relationship between London Luton Airport Operations Ltd , London Luton Airport Ltd and Luton Borough Council e.g. ownership of LLAL by Luton Borough Council warrants determination nationally to best serve public accountability and Capacity report combined with 159 APPENDIX 5 transparency. In so doing this would also protect the proposer Capacity conditions, would ensure throughput 3.3.2 The application is premature. It prejudges the outcomes of: levels.

 the Department for Transport's Draft Aviation Policy Framework LBC remains the Local Consultation (2012) Planning Authority and  the Secretary of State for Transport's designated Davies has a separate role to Commission on UK aviation (due to report Summer 2015) other interests of the  and work currently being carried out by the National Air Traffic Council. Service on redesign of the controlled airspace in the SE: London Airspace Management Programme Aviation Policy Framework published National policy March 2013 refers to LLA and recognises its role as one of the main airports in the South East.

Davis Commission draft options due Dec/Jan

LAMP – current review only relates to Gatwick Katy Frayne-Johnson Failure to maintain the balance required by Government between benefits Clerk to St Paul‟s and costs relating to noise and climate change Points referred to in the Walden Parish Council report. Failure to comply with Luton BC‟s local Plan relating to noise Noise (Letter) Failure to ensure that the noise nuisance of night flights is stopped Night flights

Aircraft movements Failure to provide measures to control the number of flights

Transport Failure to ensure adequate transport infrastructure

On the above grounds alone the application should be rejected.

Maxine Hayes The main concerns of the Parish Council are the increased noise levels Noise In drafting national Clerk to Ivinghoe created by the significant increase in aircraft movements, although the policy, the DfT and CAA Parish Council application shows that the noise levels will not increase above an have long debated the acceptable level with any one movement it is the increase in disturbed time benefits and disbenefits (Letter) over a 24 hour period that is of concern. Our residents will have a higher of overflying towns or more constant background ambient noise level particularly in summer rural areas. Over rural months when they would naturally expect to be able to enjoy the quiet of Environmental impact areas the ambient noise their own private outdoor space. This coupled with the impact the increased levels are lower, but fight numbers will have on the many that utilise the Chiltern Area of less people are affected outstanding natural beauty (that is within our Parish) for recreation and the by noise, in comparison estate Ashridge (in part within our Parish) gives rise for with built up areas. 160 APPENDIX 5 concern and objection from the parish Council.

In particular are residents are concerned with the night time proposed Measures proposed increase in flights and would seek to see night time restriction on flights which allow for greater beyond what is proposed in the application. Noise disturbance is at its worst Night noise controls than currently for sleep patterns between 11 & 12pm and 6am and 7am when the majority in operation. would expect to being going to sleep and or be asleep on an average day. With increased numbers as proposed the disturbance in these hours will significantly increase. There should be greater restriction on these hours. Addressed in highway It has also been brought to our attention that there has been no traffic section. modelling carried out for the roads in Buckinghamshire across which many passengers using the airport will travel. We would ask that this is investigated before the application is determined. Traffic

Lynn Stuart c) The proposals ignore the impact on Buckinghamshire roads, despite a Traffic Chairperson tangible proportion of LLA passengers coming from B/MK, a very high Wing Parish Council proportion of whom use private car or taxi. In addition there is an unknown number who rat-run through the county on our secondary roads. The (Letter) problem is exacerbated by very poor public transport links between B/MK and LLA, and the issue is not satisfactorily addressed in the ASAS or this application (see 6b above).

d) Unless and until LLAOL produce meaningful traffic forecasts and an ambitious but achievable ASAS and public transport plan, we cannot Traffic monitored in comment on the suitability or otherwise of the proposed car parking AMR and ASAS. arrangements – on or off-site. LLACC consulted on ASAS and targets set. e) We are concerned that HGV movements through B/MK during construction have not been addressed CEMP covers areas around the airport. The A418 from Aylesbury passes through Wing bisecting the main Minerals and Waste residential areas and the recreation ground, dog walking facilities and areas sites generally have of historical heritage and tourist attraction.The road is the main link for traffic their own traffic routing from Aylesbury to Milton Keynes, Leighton Buzzard, Dunstable and Luton as controls. public transport to and from these areas is difficult and time consuming. As a consequence the volume of HGVs and cars is significantly high for a road passing so close to residential areas

The new A505 will be linked directly to the A418 via the Leighton Buzzard by-pass and offer drivers the most direct route to the M1 and Luton airport. This will lead to increased private vehicle and HGV use on a road already overstretched beyond its capacity.

Along with the objections raised by BALC about the impact of increasing the capacity of Luton Airport on Buckinghamshire, we should be grateful if you would consider specifically, how this development will detrimentally affect the quality of life for Wing residents and what steps could be taken to 161 APPENDIX 5 address this increasing problem. Linda Haynes Recognise the contribution that the airport makes to the local economy, but Economic benefit Central Services raise concerns relating to on-site traffic congestion, passenger drop off Officer and Mayor's arrangements, poor customer experience (security, immigration and Environmental impact Secretary baggage reclaim). Plans to address these issues are overdue and Town welcomed. Council Town Hall Consider that the Planning Inspectorate is more appropriate to determine Procedure Leyton Road the application in the interests of transparency with particular regard to Harpenden conflict of interest, pr

(Letter) Noise and specifically that the application fails to meet the requirements of Policy LLA1 - comments LLA1. addressed in report

Compliance with LLA1 in terms of the predicted and the actual contours. The capacity growth above current levels should be linked to surface access modal split to public transport and day and night noise impacts being within 1999 levels.

The S106 obligations should be more rigorous and demanding to reflect the airport‟s proximity to significant communities. A travel framework has Summary of general points - been submitted with the Conflict of interest application which Compliance with national and local policy (including consideration of NSIP) outlines the Impact on national transport infrastructure commitment. Noise impact over a wider area. If LLA were to become Modal split – by increasing car parking on the site this raises doubts over a designated airport, the commitment to modal shift. there are no guarantees that the level would be Concerns regarding the capacity of the railways and the need to provide lower than that additional train services earlier in the morning. proposed through the conditions. HTC consider that the Passenger Travel Plan should be submitted as part of the application. This is a commercial decision rather than HTC welcome the adoption of Quota Count methodology, but consider that something that can be LLA should become a “designated” airport and quotas set by DfT. influenced by the LPA. However, the proposed HTC consider that the airport operator should facilitate daytime growth. The constraints, seek to operator should be making some important choices about its business encourage model: freight, general aviation or scheduled/charter flights. improvements in technology and quieter HTC consider that the mitigation measures proposed are virtually aircraft. meaningless and feel that a more rigorous set of noise mitigations are required.

162 APPENDIX 5 Comments are made in respect of planning obligations relating to noise, submission of travel plan and to seek a greater contribution by LLAOL to the community trust.

Peter George We have studied the Transport Assessment ( "TA" ) as prepared by URS Traffic Whilst the main routes Chairman Infrastructure and Environment Limited. Clearly a great deal of detailed work can be modelled it is Lilley Parish Council has been undertaken but the document fails to understand the established difficult to influence practice of drivers using the unclassified lane which runs through our village driver behaviour (Letter) as a rat run between the A6 north of Luton at Streatley to the East of Luton through villages, and the Airport, via the A505. This route has been widely used by non local particularly where traffic to avoid the congestion from the A6 along Stockingstone Road, drivers have access to through Round Green to Airport Way. satellite navigation systems to avoid We appreciate from the TA that the existing and forecasted traffic to and congestion. from the Airport along the A6 from the North at some 3.6%, represents only a small percentage of the total airport traffic but fear that any general The TA suggests that increase in traffic congestion in Luton will only exacerbate the rat running. traffic levels would be dispersed as the "The contact with additional passenger traffic could be further diluted given distance from the airport that once beyond the Luton Boundary other routes are available away from increases. the strategic road network that some drivers may choose for their journey."

We do not find the comment encouraging.

Cllr David Mitchell Parish Council objects to the Luton Airport planning application Redbourn Parish because of the increase in flights it will bring. Council, Redbourn Parish 1. Noise pollution. Redbourn Parish already suffers from aircraft noise Noise Points noted and Centre, resulting in many complaints over the last few years. Any increase in flights addressed in the report. The Park, will add to the noise pollution. This isn't about increased volume but about Redbourn, the increased time Redbourn residents will be subjected to noise. This can lead to mental health problems.

(public access) 2. Air pollution. Increased flights mean more air pollution and given Air quality that there is likely to be an increase in flights at peak times, the air pollution will be very bad at these times. The physical health of our residents is at risk, particularly those who already suffer from asthma.

3. Night flights. There should be no night flights between 11.00 pm and 6.00 am, as is the situation with other London airports. Having your sleep disturbed on a regular basis can lead to mental health problems. Any Night flights later than 11.00pm or earlier than 6.00 am is definitely night time.

4. Lack of transport infrastructure. The highways are inadequate and cars already use country roads to get to the airport during peak times. Transport infrastructure

163 APPENDIX 5 John Ford As chairman of a parish council in the Chilterns Ridges and within the AONB Flight paths No changes to flight Rabbs Cottage, I am concerned that any expansion of Luton Airport does not change paths are proposed as The Lee, existing flight path patterns over this area because of increased air traffic. part of this application. Great Missenden, Bucks Any proposals for future changes will be subject (Public access) to further consultation by the promoter (eg LLAOL, NATS) Parish Clerk Number of people affected by noise will significantly increase, against Noise Parish policy: LLA1 and noise - Council comments addressed in PO BOX 287 Technical Appendix H of the planning application shows in Tables 10 & 17 report that the number of people within the 57dB LAeq,16h daytime contour would rise from 6726 in 2011 to 11784 in 2028 worst case, or 10268 with partial fleet modernisation. The Draft Aviation Policy Framework (DfT, July 2012) supports the growth of aviation ".within a framework which maintains a balance between the benefits of aviation and its costs, particularly climate change and noise" (para 1.1).

The predicted noise levels exceed the limits agreed in local planning policy: Clause (iv) of saved Policy LLA1 of the Luton Local Plan 2001-2011 states that the Council will grant permission for development at the Airport provided that it "results in an aircraft noise impact that is below the 1999 level". It can be inferred from the comments of the Inspector's report on this plan in May 2005 that the 1999 level is the actual level. The Environmental Statement accompanying the planning application perversely refers its comparisons to the predicted 1999 levels in Appendix H, which were substantially higher particularly at night.

There is inadequate noise monitoring, particularly on approach routes:

The planning application makes inadequate provision for monitoring noise on approach routes and should be rejected.

The planning application proposes an annual night noise quota count of 5000 for the period 23:30-06:00 ("the short night"). The equivalent 2011 value was reported by the Airport Operations Director to the December 2012 Night flights Quota counts – covered NTSC meeting as 3,500. Hence the night noise would be permitted to rise by conditions by 30% just in the short night, not counting the arrivals between 23:30 and 23:00 not included in the quota. A noise quota for the short night of 500, or 2500 for the existing night 23:00-06:00, would have been more appropriate, otherwise night noise levels and the number of night flights - including noisy cargo flights - could rise significantly. The planning application should be rejected on the grounds that it fails adequately to control night noise.

The planning application adopts an unreasonable definition of "night": The planning application defines "night" for noise quota count purposes as 164 APPENDIX 5 23:30-06:00. Appendix H Noise Appendix N(3) to the planning application Night period defined in states in section 7 that night noise contours are calculated between 23:00 report and 07:00 "As used by Central Government and in Luton Airport Annual Monitoring Reports". Shortening the night period for quota purposes is unreasonable, since it allows half of the 14 predicted average night arrivals between 23:00 and 23:30 and all of the 19 predicted average morning departures between 06:00 and 07:00 to be excluded from the night noise quota (see Figure N(3)-03). The planning application should be rejected on the grounds that it fails adequately to control night noise.

There will be an unacceptable increase in the numbers of night flights: Appendix H Noise Appendix N(3) shows in figure N(3)-03 that the average number of night flights between 23:00 and 07:00 will increase from 34 in 2011 to 52 by 2028. The graphs in sections 4.3 & 4.4 of the Luton Airport Annual Monitoring Report 2011 show that during the busiest month, flights per hour can be around 50% higher than on average. This could mean around 80 flights per night by 2028. Significantly more early-morning movements would also occur between 05:00 and 06:00. The airport operators are not able directly to influence re-engining or fleet modernisation, and it is unreasonable to expect local communities to tolerate such a significant increase in numbers of aircraft movements during the night hours 23:00-07:00. The WHO Charter June 1999 on Transport Noise and Health shows that night flights cause disturbance to sleep which contribute to health problems. The LLAOL Master Plan September 2012 commits to mitigating noise, not increasing it. The planning application should be rejected on the grounds that it would lead to an unacceptable increase in the number of flights and corresponding noise disturbance at night.

There will be an increase in traffic for which no provision has been made

Caroline Freer Luton Airport is situated in the wrong location for the level of operations it Clerk – carries out currently because it surrounded by a number of large towns and Parish small rural villages. Council Noise suffered by our community is already at an unacceptably high level and the projected increase in operations with inadequate noise mitigation Points noted and measures will make this an intolerable situation. Many of the measures put Noise addressed in committee forward are not substantiated or will make no material difference to the report. noise levels created by airport operations. The additional claim that re- engineering will reduce aircraft noise is neither substantiated nor within the control of the Operators.

Louder freight aircraft will continue to disturb sleep. The adverse impact of Night flights noise on sleep disturbance is well documented. The WHO report that night Consultation carried out flights cause disturbance to sleep and the CAA has itself issued a report by CAA but final only this month acknowledging the adverse effect on ill heath caused by document not expected noise so is advocating a ban on the noisiest aircraft at night for Heathrow, to be published until 165 APPENDIX 5 Gatwick and Stansted. Spring 2014

Traffic Congestion The bus link between An additional consequence of the location of the airport is that it has no Parkway Station and direct rail link so that the only means of access is by road. This will not be Transport infrastructure the airport is supported changed under the proposed developments which will generate extra traffic by other direct services. caused by the additional numbers of passengers and extra commercial vehicles servicing the Airport. Furthermore proposed changes to Airport In addition, works are Way will have no impact on the wider road network congestion. This is about to commence on already unable to cope with the existing volumes of traffic and the operator‟s the M1 J10a proposals for minimising these consequences by increasing the proportion Improvements which of public transport is incompatible with their proposals to increase are expected to be significantly the car parking facilities from which they derive a valuable completed before any source of additional income. significant change in passenger throughput. Economic issues The claim that the economic benefits of airport expansion will result in the The methodology for creation of thousands of jobs is both overstated and unsubstantiated. Employment employment levels Productivity in the aviation industry is improving. An alternative includes associated methodology used by a former government economic adviser calculates trades that provide a only a few hundred jobs at most would be created. role to the airport.

The DfT has just released an updated passenger demand forecast figures The application relates for 2030 reducing further the forecast it issued only 18 months ago by a to the onsite further 6% due to lower economic growth forecasts. The Operator‟s infrastructure to justification therefore for the expansion is reliant on forecast passenger Passenger throughput facilitate the growth. figures which are not only out of date but also on an overstatement of Luton The actual throughput is Airport‟s share of the total passenger forecast. dependant economic and marketing issues, Luton Borough Council Saved Plan not all in the direct There is a disparity between the reference in the Local Plan to actual 1999 control of the airport noise levels (where planning permission for development would be granted) operator. whereas the noise levels referred to in Appendix H of the application‟s Environmental Statement are predicted 1999 noise levels. The Operator‟s LLA1 refers to the predicted noise level would exceed the actual noise level limit referred to in Policy predicted contours. See the Saved Policy therefore permission should not be granted for this reason. committee report.

Finally, Flamstead Parish Council considers that it is wholly inappropriate to The LAMP review in consider any planning application in relation to expansion of operations at respect of this area has Luton Airport before the outcome of both NATS‟s London Airspace no set timescale at this Management Programme review and the Government‟s National Aviation present time. Policy Framework review are known. Until the impact these reviews will have on Luton Airport‟s current and expanded operations is known any The Airport Commission planning decision is premature. Airspace policy will report the first stage of work around For these reasons Flamstead Parish Council object to the planning Christmas. The final Application and would welcome a meeting with you to discuss our concerns. outcomes are not likely to be known until Spring 166 APPENDIX 5 2015. Elspeth Roberts We understand that at present planes approaching to land at Luton Airport Noise PR Nav is a recognised Rushden & Wallington have a 3 kilometre strip to fly along as they approach the Airport and that procedure operated at Parish Council they try to maintain a flight path along the centre line of that strip. the majority of major Ty Cottage airports. This results in Southern Green We further understand there is a system called PR Nav which enables flights following a planes to hold this centre line. We assume, but would like some evidence, defined route along a that this system would be of benefit to us. narrow swathe.

We are extremely worried about the fact that by increasing the number of The debate over passengers from 10.3m to 18m, the number of planes flying over this area concentration over will double which will in turn double the noise nuisance we suffer. dispersal of flights has been argued over many We therefore require as part of the planning process, investigations: years.

1. Into the installation and use by all planes of the PR Nav system. 2. By the CAA/NATS into the flight path of incoming aircraft which should in particular explain where the 3 kilometre strip and its centre line are at present and where it is proposed to place this strip and the centre line in relation to the increased number of aircraft.

Although there have been road improvements to provide better access from the M1 into the Airport for traffic coming from the west, there have been no Traffic The TA has identified improvements whatsoever in the road system providing access from the works that will be east and the present application does not contain any proposed required on identified improvements from the east. Indeed it is our view that these roads are junctions. These have unsuitable for any increase in airport traffic and, what is more, are incapable been covered either by of improvement. condition or within the S106. We therefore also require as part of the planning process a traffic impact assessment in relation to traffic approaching the airport from the east.

We are also of the view that the physical constraints of the site of Luton Airport are such that it does not lend itself to any increase in capacity and that the impact on the surrounding area will be such that it is unreasonable to expect the population of that area to live with it.

Parish Clerk Concern was raised about additional flights causing noise intrusion over the Noise Comments noted and Marsworth Parish village of Marsworth, Bucks particularly if night flights are permitted. Also, Night flights addressed in committee Council the increased volume of traffic generated by the proposal has not been Traffic report. Miswell Farm satisfactorily dealt with. Icknield Way Tring

Michael Fookes OBJECTION to planning application 12/01400/FUL for proposed alterations Comments noted and Committee Member, St and extensions to Luton Airport on the following addressed in the Albans Civic Society grounds:- committee report.

167 APPENDIX 5 1. Resultant increased aircraft noise levels in terms of volume, duration and (email) footprint, together with increased night flying. Noise

2. Resultant adverse effect on air quality, public health and enjoyment of environment in St Albans and surrounding countryside. Environment

3. Resultant detrimental impact on already congested road and rail network through and around St Albans. Transport infrastructure

4. Prematurity in view of yet to be published national aviation strategy. National Policy 5. Application constituting a nationally significant infrastructure project (as defined in Planning Act 2008) requiring to be determined by the Secretary of Determining authority State, not by the local planning authority.

Accordingly it is requested that planning permission is refused.

S P Dent I am writing on behalf of Parish Council to say that we Chairman Harpenden strongly object to the proposed development. In addition we consider that Rural Parish Council LBC has a major conflict of interest and therefore lacks the ability to Comments noted and determine the outcome of the application. addressed in the (Letter) committee report. Representations include letter of 15 February 2013 which was submitted to the Rt Hon Eric Pickles MP and Rt Hon Patrick McCloughlin MP.

The letter raised the following headline points - Infrastructure Infrastructure overload

Luton Borough Council‟s conflict of interest Determining authority

Noise Noise

Bill Duncan Villagers have been aware of proposals to expand Luton Airport and at last Comments noted and Chairman year‟s Annual General Meeting the issue was discussed. Villagers voted addressed in the Ayot St Lawrence unanimously in support of a motion that I should object to this proposal on committee report. Society behalf of the Ayot St Lawrence Society. Subsequent to the meeting Stocking Lane villagers have received details of the planning application lodged and I set Cottage below a summary of village concerns. Ayot St Lawrence 1. The proposal is in conflict with the Council‟s noise policy for the Policy Airport and in conflict with Local Plan 2001-2011 policy LLA1. (email) 2. The proposal fails to establish a balance between economic benefit and environmental cost as required by emerging national aviation policy and is in conflict with saved Local Plan 2001-2011 policy LLA1.

168 APPENDIX 5 3. The proposed night noise quota will lead to an unacceptable increase in noise in that the application appears to permit a rise of 30% Night flights between the hours of 23.30 and 06.00 which means the number of night flights many of which could be cargo will rise significantly. The application indicates an unacceptable increase in the number of night flights between 23.00 and 07.00 from 34 in 2011 to 52 by 2028 representing an increase of 47%. During the busiest months this could increase to 80 flights per night. The proposal fails adequately to control night noise and should be refused.

4. It is unreasonable to expect local communities including that of Ayot St Lawrence to tolerate such a significant increase in numbers of aircraft movements during the night hours 23:00-07:00. Night flights cause disturbance to sleep which contribute to health problems and will undoubtedly affect daytime concentration with potential consequences for employees in the workplace.

5. Daytime noise will inevitably rise and the violation levels ascribed would be inadequate to the task of ensuring compliance.

I understand that some villagers will be making representation to you directly, in similar vein to the concerns outlined here. On the basis of the concerns outlined above, I, on behalf of the Ayot St Lawrence Society, believe permission for this proposed development should be refused.

Carina Helmn Kimpton Parish Council has concluded that there are several important Clerk to Kimpton reasons for OBJECTING to the expansion of Luton Airport as being Parish Council proposed. Our comments are as follows:

Parish Room Noise Kimpton Memorial Hall We believe that more aircraft will result in an unacceptable increase in noise Noise Hall Lane over Kimpton and over all other communities within this Parish. Noise Kimpton mitigation proposals are not sufficient to counter the effect of increased air traffic due to increased capacity, which appears to be the objective of this Comments noted and (letter) plan. addressed in the committee report. We support all the concerns raised by neighbours and campaigners over this subject and share in particular the view that the upper limit projected of Capacity 18 mppa appears to be aimed at keeping expansion to less than 10mppa, negating the need for the application to be considered as a Nationally Significant Infrastructure Project (NSIP). Insufficient information is available to determine whether the theoretical capacity (capability) in the future would exceed this number.

We note that the proposals do not include controlled night-time periods, but lead instead to a substantial increase in the number of early morning and Night flights late night flights. Local residents would suffer significant noise nuisance and

169 APPENDIX 5 potential ill health effects. Kimpton Parish Council is against any increase in the actual number of night flights and is instead supporting a reduction.

Infrastructure Local road infrastructure to Luton airport as it appears in the plan would Transport alleviate current congestion, but this Council does not believe that it would support expansion even with extra lanes on Airport Way due to increased passenger traffic, as well as increased commercial and local services activities.

Rural lanes are unable to cope with any increase in usage by airport passengers and employees. Kimpton Parish would suffer increased road traffic, increased chances of accidents and injury to residents following increased use of B roads and rural lanes to the north, east and south of the Airport as “rat runs” by passenger, employees and commercial airport traffic.

As highlighted by the concerns raised by, for instance, Thames Water, the Highway Agency and Network Rail, Luton Airport is not suited to expansion and it is evident that the planning application cannot be determined until such issues as those raised by all consultees and objectors have been properly addressed at national level.

Increased risk of flooding in Kimpton Extra hard standing would cause an increase in water run off that would Flooding contribute to local flooding. In 2001 Kimpton Village suffered extensive flooding which was mostly attributed to the changes in the drainage from Luton Airport. Contaminated water run off going into the groundwater aquifer. We require more details of the water management proposals.

Exaggerated claims for increase in jobs in the area We believe that the figures presented in the application and so readily Employment embraced by the Luton Chamber of Commerce and Unite do not reflect realistic long term employment prospects. Kimpton Parish Council would like to see the evidence used to support the job generation statements made in relation to this application.

Air Pollution Capacity expansion will result in a reduction in air quality and increase in ground pollution due to the extra flights and airport traffic. Luton Airport is Air quality not suited to expansion due to its location on a hill neighbouring dense built up areas.

Results of Public Consultation We believe that the conclusions of the masterplan consultation are flawed as they include within supportive responses a 100% supportive response Employment from employees.

170 APPENDIX 5 The proposals are out of step with the Government‟s on-going review of aviation policy. We believe it would be better to wait for this to conclude so Policy that proposals could be made within this context.

Kimpton Parish Council also considers that the proposals are not sufficiently Environmental impact developed with unsatisfactory supporting analysis of the environmental, health and economic consequences of these plans and has deep concerns about the possibility that commercial gains by Luton Borough Council may prevail over all the concerns expressed above.

We trust that the above clearly indicates our reasons for objecting to this planning application and for its consideration by Luton Borough Council. Julia Warren 9 page letter submitted. The issues raised are – Clerk to  National Policy Context  Consultation Parish Council  Surface access Comments noted and  Aircraft numbers and noise addressed in the (Letter)  Night noise committee report.  Aircraft noise monitoring and mitigation proposals  Conclusion –  Insufficient information to assess impact on roads in Hertfordshire  Impact of larger noise contour  Increase in night flights  Failure over the years to proactive approach to building relationships with Councils in Hertfordshire.  Wheathampstead Parish Council requests that the application be withdrawn and submitted to the SoS for determination. Katy Frayne-Johnson Our preliminary objections are as follows:- Clerk to St Paul‟s Walden Parish Council Failure to maintain the balance required by Government between benefits and costs relating to noise and climate change:- National Pollution and climate (Letter) aviation policy states that Government will support growth provided a change Comments noted and th 8 March 2013 balance is maintained between benefits and costs, in particular costs addressed in the relating to climate change and noise. committee report.

This application would increase CO2 emissions by a substantial 70 per cent, and would therefore undermine the Government‟s efforts to meet the Climate Change Act targets. The development would increase the absolute levels of noise and increase the number of people affected by noise. This is the opposite of what the Aviation Policy Framework is setting out to achieve. Thus the proposal fails to achieve the necessary balance required by Government.

Failure to comply with Luton BC’s local Plan relating to noise:- The

development runs contrary to Luton Borough Council‟s local plan LLA1 – Noise because it would lead to noise levels exceeding the 1999 levels. Key

171 APPENDIX 5 aspects of the application have been presented in a misleading way, e.g.:- According to the Airport‟s planning consultants Terence O‟Rourke in a response to Forum - each of the claimed noise mitigations would in fact affect only fractions of a percent of flights per year; also the proposed night noise quota level would actually permit a significant increase in night flights, as indicated in the hourly movements graphs provided by the applicant.

Failure to ensure that the noise nuisance of night flights is stopped:- Significant numbers of people are already affected by night flight noise. The Night flights data also shows that the main wave of early morning departures would start to ramp up at 5am rather than 6am. This is completely unacceptable.

Failure to provide measures to control the number of flights:- The projections for future growth simply stop rather than tailing off, this is of course unrealistic and the planning application contains no measures to control the number of flights.

Failure to ensure adequate transport infrastructure:- The roads around Transport the airport are already over congested. Raising the number of passengers

from the current 10million per year to a projected 18million or more will have

an intolerable impact not only on road congestion and parking, but also on

bus and rail services especially at peak hours.

On the above grounds alone the application should be rejected

Roma Crosby The environmental impact will be enormous and will generate ill-health and Environmental impact ruin the quality of life for everyone in the surrounding areas. CLERK TO KINGS Comments noted and WALDEN PARISH Due to the excessively wide implications of the proposals the application Procedure addressed in the COUNCIL should be called in for a full Public Inquiry. committee report.

(Letter) The existing planning permission is for 5mppa so this application brings the 27 March 2013 proposed development well within the definition of a national infrastructure project in line with other nationally significant Infrastructure projects.

Luton Borough Council has the vested interest of increasing the revenue for the Council and should not be deciding and making the planning decision especially when other Councils have to cope with the unwanted effects.

The proposals do not accord with the Luton Local Plan LLAO1 that allows Policy development not exceeding the 1999 levels.

The claim of the creation of some 5000 jobs would seem to be inconsistent with the present figures of employment and in comparison with other Employment airports which suggest that the number would be nearer 1000 work places.

172 APPENDIX 5 The report that the "community involvement" during the public consultation produced figures indicating that 65% - 884 -supported the proposals has not been verified with regard to the way other responses were counted.

The airport is situated at the south eastern corner of Luton town. The perimeter of the airport land follows the contiguous boundaries of Beds and Herts counties and is adjacent to the boundary of the Hertfordshire Parish of Kings Walden.

At the western edge of the Parish of Kings Walden lies the village of Breachwood Green sited on the Breachwood Ridge above the level of the runway less than a kilometer distance from the end of the runway. The village has 400 houses and lies immediately under the flight path swathe and, along with the hamlets of Darley Hall and Diamond End, the residents are affected very adversely by the present operations. There is a climate of damaging noise levels, and pollution, that reduce the quality of life. In addition to overflying there is greatly intrusive noise created from the ground level operations with planes revving up and maneuvering between taxiways and parking areas.

The Draft National Action Plan Framework specifies that for development to take place the "growth must be balanced with control of noise and climate Policy change. Noise levels and the number of people affected must be limited and reduced" and "sensitive areas should be avoided".

The particularly sensitive areas flown over comprise the following: 1.. the Primary School with 100 plus pupils - at times the teachers have had to resort to speech amplifiers. Health impact 2. the recreation ground used by the school for children‟s sports and by adults for a variety of outdoor games. Note the air pollution monitor at the site indicated that particulates from planes overhead registered "off the clock". Figures produced are reduced to "averages". Averages do not indicate the particulates actually absorbed into the lungs when active and vigorous games are taking place. 3. the Village Hall where speech is drowned out and conversation has to cease against the din. 4. the Baptist Chapel where services are interrupted 5. the Youth Hut for young teens.

NOISE : Studies by the World Health Organisation identify that noise annoyance occurs at 55 dbA. and that heart and respiratory problems are Noise caused by intensive noise.

The existing noise monitors are sited 6.5 kms from the end of the runway - 3 kms further on from where there are dwellings. Consequently these monitors do not reveal the noise experienced by residents.

173 APPENDIX 5 The recent noise readings, copy of which you will have, produced by Bickerdike Allen Partners, at a site 500m south on the edge of Breachwood Green, reveal that noise levels range from 75.4 to 94.2 averaged out, with a reading for a B732 on departure of between 101.4 and 108.9 average SEL,dB, timed over a second.

The actual length of the intrusive level of sound experienced within the area caused by the peak level and rumbling noise which bears down persists towards one minute. With the anticipated movements at two minute intervals there will be a continuous noise slum.

The noise levels are also affected by the wind and weather conditions - on summer days or on a still summer night with little or no wind the noise is extremely disturbing and intrusive.

A noise meter needs to be placed permanently under the flight path within the built up area of the village to record the noise readings experienced.

NIGHT NOISE: the proposal to double up the number of movements during the night is diabolical. Sleep deprivation causes distress and adds to Night noise problems.

The intensive use of the early mornings from 6.00 to 9.00 am is particularly barbaric in that it prolongs the disturbance from over night and, movements at some two minute intervals, causes extreme annoyance, and brings on aching heads - not a good start to any day.

MODAL SPLIT: The modal split where Take Offs, which create the higher decibels, operate in proportion 70 to the west and 30 to the east has not Transport been the pattern for the last two years when the wind has been predominately from the east and thus causing more disturbance in Hertfordshire as aircraft take off into the wind..

NOISE MITIGATION PROPOSALS: The proposal to offer funds for noise insulation with a limited amount for each dwelling is worthless and no solution. Many older properties are not suitable for insulation especially Noise where there is no roof space - the roof is the bedroom ceiling and cannot be adequately sound proofed. Furthermore, the gardens and outdoor spaces cannot be protected.

The notion that planes will become quieter than present has not been borne out by aeronautical engineering - the fleets are unlikely to be replaced and extra movements will cancel out any reduction in noise levels.

Aircraft Taking Off and Landing at either end of the runway are in close proximity to dwellings, schools, busy roads, are increasing the safety risks. 174 APPENDIX 5

NOISE CONTOURS: There would appear to be no up-to-date maps indicating the spread of the noise contours. The recent noise readings by Bickerdike Allen Partners, referred to, seem not yet to have been mapped out indicating the areas involved.

The wider implications relating to road congestion and safety issues are being dealt with by other authorities.

The full Environmental Impact Assessment is still awaited.

COMPENSATION: If the proposals are proceeded with those people most vulnerable to noise disturbance should be fully compensated to enable them to move away as is the rule with road developments.

Cllr Isabella Fraser 1) Introduction Chairman 2) Summary a) The proposals‟ supporting statements are based on cherry-picked Comments noted and John Gibbs assumptions and data to predict the most favourable outcomes. This is addressed in the County Executive misleading and against the principles of sound science, so the proposals Policy committee report. Officer cannot claim to be a “sustainable development” per the Buckinghamshire and National Planning Policy Framework (NPPF). Milton Keynes Association of Local b) The actual design capacity of the proposals exceeds 18mppa and Councils 157,000 annual aircraft movements. The true capacity should therefore be Capacity County Hall revealed and impact statements reworked to take this into account. Aylesbury c) The Economic Impact Assessment does not discuss the current or future Economic impact destination mixes and options that would affect its current conclusions.

d) The Economic Impact Assessment is silent on the issue of tourism and LLA‟s contribution to the annual tourism deficit (i.e. drain on GDP) of £13bn.

e) B/MK faces a significant increase in noise pollution from these proposals but is unable to estimate to what extent because of LLAOL‟s continuing Noise refusal to be transparent on future airspace usage.

f) The proposals contravene the Local Plan 2001-2011 policy ENV 1 that Policy seeks to preserve the “special character” and “natural beauty” of the Chilterns AONB.

g) A reasonable interpretation (principle of English Law) of saved Local Plan 2001-2011 policy LLA1, clause (iv) concludes that these proposals contravene local policy.

h) The proposals contravene saved Local Plan Policy T2 because of the unsubstantiated aspirations of the Airport‟s Surface Access Strategy (ASAS) and assessments limited to arbitrary demand forecasts. 175 APPENDIX 5 i) The application is an issue of national importance and should be referred to the Planning Inspectorate for determination. We are writing to the DCLG Procedure in this regard.

3) Question: What if the forecast growth is exceeded? a) Answer: The proposed development can accommodate more than Capacity 18mppa and 157,000 annual aircraft movements by “peak-spreading” and more night flights, yet the environment and traffic impact studies do not cover this very possible scenario. The true design capacity of the proposals should therefore be clarified and impact statements reworked to take this into account. b) Aircraft movements could exceed 157,000, not only if passenger demand is higher than anticipated, but also if the passenger load factor is lower or the actual fleet mix means fewer larger planes. c) LLAOL claim in Chapter 8.2 that, “… the use of additional physical capacity is limited by the schedules of the airlines and the need to retain current customer experiences.” This is not a sufficient explanation, because airline schedules can easily change; and there is additional scope for “peak- spreading” and more night flights that would not compromise the customer experience. d) With reference to the 1997 planning application that so dramatically understated passenger capacity, LBC has already raised this issue with LLAOL (EIA Scoping discussions “Clarity of Submission”). We maintain that the issue has not been addressed satisfactorily in this application.

4) Economic Impact a) There are undoubtedly economic benefits that LLA brings to the area – for example 2% of LLA employees live in Milton Keynes – but a sustainable Economic impact development as defined in the NPPF must balance economic, environmental and social impacts using “sound science.” If either one of these three impacts is based on unsound science – which we conclude is the case for this application – then the development cannot be said to comply with national policy. b) The Economic Impact Assessment (Chapter 9) appears to be generic and independent of the type of current or future destinations. i) In paragraph 9.65 and elsewhere, LLAOL suggests future destinations such as New York and the Far East. It is reasonable to assume that the local economic benefit of these routes would be more tangible than many of those currently on offer; but it is not clear what route-mix or mixes have been factored into the economic assessment.

For example: (1) Annual Passenger Duty depends on the distance travelled: there is a big 176 APPENDIX 5 difference between Nice and New York. (2) Does the quality of jobs created (paragraph 9.2) depend on the quality of the destinations? This question has not been covered. ii) The economic assessment does not mention tourism – inbound or outbound. Nationally the annual tourism deficit (drain on GDP) is £13bn, but is expected to increase to and exceed pre-recession levels of about £20bn in due course. Given LLA‟s plethora of tourist destinations, a local analysis of this issue would have helped to add credibility to the economic assessment. We did notice that the Sustainability Statement waxes lyrical about the benefits of inbound tourism, but ignores outbound tourism.

5) Noise Impact a) The noise studies assume a maximum of 18mppa and 157,000 annual aircraft movements and ignores the possibility that either or both of these Noise Impact forecasts could be breached – see paragraph 3 above. b) We support the principle of decreasing the noise violation limits for departures, but note that the proposed noise violation levels would, if applied now, affect no more than 1% of day departures and 3.6% of night departures (about one a week). Given the promised introduction of quieter planes, these levels do no more than accommodate the status quo. Noise violation limits should be challenging, and the fines tangible, if they are to focus the mind and make real inroads into noise nuisance. c) There should also be noise violation limits for arrivals. There should be an S106 agreement for the provision of an additional fixed monitor to cover the noise of arrivals to the western end of the runway. d) Night noise is a particularly contentious issue, especially during the shoulder periods 11pm - midnight and 6am - 7am. Sleep disturbance during Night noise these periods can be the most ruinous to health and quality of life. So while we support the principle of a limit on night movements, the limits proposed still allow an increase on current movements and do not cover the shoulder period. The promised introduction of quieter planes does not change this: being woken up by a noisy plane feels the same as being woken up by a slightly less noisy plane. Other airports manage with more stringent night flight regimes and so should LLA. e) B/MK has been excluded from noise impact studies because the area is outside the official noise contours. However, noise levels of even the quieter planes are sufficient to cause disturbance in areas of comparatively low ambient noise. f) While our exclusion from noise studies might be legal, it is neither helpful nor transparent, because noise impact is still real for these communities and individuals (Appendix H, Appendix N2, page 3) and they should at least be 177 APPENDIX 5 given a qualitative indication of likely future impact. To do this, we need to know how many overhead flights are probable. To address this concern, LLAOL claims that there would be no new flight paths, but this is inadequate and, indeed, misleading as explained below. i) It is possible, according to local pilots and air traffic controllers, that a busier LLA would require the current airspace and flight paths to be used Airspace differently than now. ii) In addition, increased traffic might impact how flights are routed over the Chilterns AONB – even if they follow the same tracks as present but a Environmental impact greater proportion at lower altitude. This contravenes the Local Plan 2001- 2011 policy ENV 1, that seeks to preserve the “special character” and “natural beauty” of the AONB. iii) Future changes to NPRs are mentioned in the application, which would occur anyway without these proposals. Yet possible changes to arrivals as a Airspace changes direct result of these proposals are ignored. iv) While LLAOL dismisses the issue with a “no new flight paths” declaration, this conflicts with the advice from NATS. In their response dated 21 February 2013, they say that meeting the increased demand for airspace from LLA is dependent on the wider airspace review. v) On a multitude of occasions we have asked LLAOL, and LLAL, to include future airspace usage in any planning application so are very disappointed that our requests have gone unheeded. Indeed, airspace is not even listed as a possible constraint to development in the Sustainability Statement, despite the fact that airspace management is crucial to meet passenger demand, and for noise, fuel-burn and air quality control. g) The proposal potentially conflicts with saved Local Plan 2001-2011 policy Policy LLA1, clause (iv). This states that the Council will grant permission for a proposal which “results in an aircraft noise impact that is below the 1999 level.” There has been significant debate over the years about whether the 1999 levels should be those that were predicted when the Local Plan was drafted, or those that were actually recorded in 1999. i) In the absence of an explicit descriptor (e.g. for “1999 noise levels”) a reasonable person would assume that a measure was actual and not predicted. ii) Prior to the 2001-2011 Local Plan, aircraft noise had been monitored annually against 1984 actual levels: iii) The 2001-2011 Local Plan refers to 1999 levels that pre-date the Plan‟s implementation start by two years;

178 APPENDIX 5 iv) Government policy requires an actual improvement in the noise climate around airports. To demonstrate that LLA is complying with Government policy, it needs to demonstrate that current actual noise levels are lower than the actual 1999 starting point.

6) Surface Access a) We support the objective of improving surface access to and from the airport; but the impact assessments once again do not factor in passengers Surface access per annum greater than 18m (see paragraph 3) and the impact on the roads and public transport there from. b) The ASAS and planning application are both high on aspiration but low on specifics and fall-back solutions. Without realistic and empirical forecasting and planning, there is a high risk of inadequate public transport and even greater strain on the roads that even the proposed improvements fail to address. c) The proposals ignore the impact on Buckinghamshire roads, despite a tangible proportion of LLA passengers coming from B/MK, a very high proportion of whom use private car or taxi. In addition there is an unknown number who rat-run through the county on our secondary roads. d) Unless and until LLAOL produce meaningful traffic forecasts and an ambitious but achievable ASAS and public transport plan, we cannot comment on the suitability or otherwise of the proposed car parking arrangements – on or off-site. e) We are concerned that HGV movements through B/MK during construction have not been addressed. This could leave our residents open to more noise, air quality and sleep deprivation issues and should be addressed with Bucks CC as a matter of urgency.

7) Carbon Emissions a) We support the objective of expediting aircraft ground movements, because this should reduce emissions including carbon dioxide. Climate change b) We were surprised that LLAOL effectively dismissed the projected doubling of CO2 emissions because it was a comparatively small proportion of UK-wide emissions. We all have our part to play in combating climate change. c) We are unable to comment further on LLA‟s carbon emissions because it is not clear whether the Environmental Statement (Chapter 6 Air Quality, and Technical Appendix B) took into account high-altitude emissions and used the RFI multiplier1.

179 APPENDIX 5 8) An Issue of National Importance

a) An airport development that increases capacity by 10mppa meets the criteria for a Nationally Significant Infrastructure Project. While LLAOL Procedure claims that their proposed development would allow it to grow by 8m passengers per annum (ppa) to meet their 18mppa forecast demand; they fail to reveal the maximum throughput they would be able to manage should future demand exceed current forecasts.

b) London Luton Airport is a key player in the Government‟s Draft Aviation Policy Framework, in terms of provision of national capacity and Policy connectivity. To retain the integrity of this 1 The UN Intergovernmental Panel on Climate Change (IPCC) recommends that aircraft CO2 emissions should be multiplied by a factor of between 2.0 and 4.0 – with a suggested midpoint of 2.7 – to reflect the greater climate change impact of CO2 emissions at high altitude and the impact of non-CO2 emissions from aircraft engines. This multiplier is known as the radiative forcing index (RFI). RFI only applies to aircraft CO2 emissions. Necessarily holistic framework, the proposals should be scrutinised in the national context, the Davies Commission, and wider infrastructure issues such as road and rail provision.

c) The forecast increased traffic would impact on airspace management far beyond Luton‟s Terminal Manoeuvring Area. Given the response by NATS Airspace to this planning application), this application should be considered in the context of current and future airspace requirements of other airports as well.

d) Luton is a 24/7 airport which puts it at an unfair commercial advantage compared to other airports. The Government should look to level the playing field by restricting night flights at Luton in line with restrictions at Stansted, Heathrow and Gatwick.

9) Conclusion BMKALC objects to this planning application. While agreeing with some of the objectives, the anticipated benefits do not justify the environmental disbenefits so is unsustainable. In addition some crucial questions remain unanswered. Mrs Laurie Eagling We understand that the deadline for comments regarding the above for Clerk to Pitstone BMKALC members was extended until 4 March 2013. In line with this, Parish Council Pitstone parish council is writing to oppose the above application for the 9 Warwick Road, following reasons: Pitstone, 1. Referral of the application to the Secretary of State Luton Borough Council should not be the arbiters on this application, when Luton Borough Council itself stands to gain significantly from increased Procedure income from passenger capitation arising from any expansion via its ownership of the airport.

180 APPENDIX 5 2. Implications of the Planning Act 2008

The previous planning application in 1997 was actually for expansion from 3 million to 5 million passengers per annum (despite the fact that Luton airport throughput actually exceeded 10 million in 2008). Thus the current Comments noted and application for an increase to more than 18 million passengers per annum addressed in the exceeds the previous approval by more than 13 million passengers. The committee report. Planning Act 2008 stipulates that a proposed airport-related development becomes a Nationally Significant Infrastructure Project (NSIP) if it is “to increase by at least 10 million per year the number of passengers for whom the airport is capable of providing air transport services”. All NSIPs should be scrutinised by the Secretary of State, so we therefore urge this application to be submitted as such.

3. Stated Luton airport capacity

As the Luton airport throughput has in fact expanded to more than 10 million in 2008, despite the planning application being 5 million), we would need Capacity assurances that this current application is not in fact an application to expand to 30 million passengers per annum on an extrapolated total from the previous application, and that the application should be limited to a particular maximum for ppa and plane movements.

4. Flight path details In 2008, NATS advocated that it would be necessary to revise flight paths to accommodate the anticipated growth in Luton traffic, together with the increase in traffic associated with Heathrow and London City. Subsequently the changes were postponed following the downturn in Airspace air traffic resulting from the recession. The current planning application now increases passenger movements to 18 million per annum but states that this increase can be accommodated without any changes to existing flight paths. This statement clearly goes against the previous information supplied by NATS. Without an accompanying statement from NATS to clarify exactly what impact the growth will have on aircraft flying over the parish, neither our residents nor the parish council is able to fully appreciate the consequences and therefore comment accordingly. The consultation should be suspended until all the data is available.

5. Noise mitigation The current noise mitigation measures are not effective enough. The application states that LLAOL will work with operators to „encourage the voluntary phase-out of the noisiest aircraft‟ and the health Noise impact assessment cites „in the future the aircraft will be certificated to a better noise standard than those currently flying‟. However, no-one knows what these standards may be and if the as-yet-unbuilt aircraft will ever meet them. The current noise-violation thresholds at Luton airport are so high than virtually none of Luton‟s aircraft attract a fine and the last indicators show that both day & night time noise indicators have got worse year-on- year rather than better. The application includes a proposal to fine aircraft over 80dBA but this level is too high because if the measure was introduced 181 APPENDIX 5 now, it would only affect 2 night flights per week and 2 flights per day, so the noise-violation threshold needs to be set lower. LLAOL state within the application that they will „introduce a ban on aircraft with QC of above 2 at night‟ but there hasn‟t been an aircraft movement rated at greater than QC2 at Luton airport for the past 3 years so to be effective and include the removal of the current noisier bizjets and A300s, the ban would have to include aircraft lower than QC2, not above it. London City airport operates a night time ban covering the periods 22.30-06.30 and has a 24 hour curfew starting at 12.30 on Saturdays, but no such equivalent measure has been proposed for Luton.

The parish understands that Luton departures at busy times have to keep lower for longer to avoid traffic from Heathrow and London City, for example. More traffic at Luton can only worsen the situation in terms of frequency of noisier events and length of noisier periods. This particularly impacts the Chilterns AONB because of its elevation. The full details of this and other significant impacts from a busier Luton have been omitted from the planning application, despite the Chilterns having statutory protection, thus denying our residents the opportunity to fully understand the potential impact. Furthermore, many of the current flight trajectories to/from Luton are very wide, so there is considerable scope within the „same flight paths‟ for aircraft variations over different communities and our parishioners would need a clearer understanding of how Luton airport plan to utilise these trajectories before formulating a meaningful response.

6. Projections We believe that the basis of the forecasts for both passenger and aircraft movements are flawed, leading to an under-estimate of the possible adverse effects and an over-statement of possible economic benefits.

In summary, whilst we welcome the improvements to the passenger experience at Luton airport, the parish council can‟t support this application. Douglas Adams 1 Nationally Significant Infrastructure Project. Luton Borough Council Procedure is not legally able to consider this application and it should be referred to the For and on behalf of Planning Inspectorate. 2 Conflict of Interest. Given its clear conflict of interest, LBC cannot Comments noted and Parish Council be trusted or expected to make decisions impartially and in the public addressed in the interest. The revenue streams should be publicly declared and, as a matter committee report. of course and in accordance with good governance, LBC should declare an interest publicly and withdraw from further involvement with this application 3 Aircraft movements at night. Until mandatory Department of Transport night flying restrictions are put in place, similar to those imposed Night flights at Heathrow, Gatwick and Stansted Airports, Luton night movements will remain unregulated. For an airport of the size that Luton currently is, this is unacceptable. For an airport of the size that Luton wishes to become, this is inconceivable. 4 Airspace Change Proposal. Given the extent and scope of proposals made in 2008 by NATS, there are clearly many issues that are Airspace 182 APPENDIX 5 still to be resolved concerning the over-congestion of airspace in the South East. Until these have been satisfactorily resolved and can be demonstrated to have been resolved, expansion plans should not even be countenanced given the public health and safety risks and implications of already congested airspace. 5 Outdated airspace planning – Heathrow stacks. Change is not optional, it is a necessity. If the Bovingdon stack was repositioned and aircraft movements through Luton were not constrained by the need to fly at safe levels below it and sharper take-offs and landings introduced, the noise problems and impact created by Luton airport would be diminished considerably. The pollution issues regrettably would still remain. 6 Our final comments relate to traffic congestion and pollution both on the ground and in the air. There is great concern about the impact of Traffic aviation on the ozone layer and climate change both within the UK and worldwide.

The residents in Little Gaddesden very much share this concern given the dramatic expansion planned – a doubling of people affected by noise at night and a tripling of both passengers and air traffic movements. The cavalier approach being adopted by the airport operator would appear to be negligent with scant regard to the environment or people living within the environs of the airport or the surrounding transport infrastructure. I trust the views of our village will seriously be taken into account – particularly the impact of aircraft noise at night. As a community, we all would like to be able to continue to support the existing operations of the airport by day at its current level and overcome the hugely detrimental health impact of noise pollution on local families and communities at night. Mrs Marty Kilby Parish Council wishes to object to the expansion, as before Clerk to Ardeley Parish recorded. However if the application is allowed, we request that flight paths Flight paths Comments noted and Council be spread as far apart as possible so as not to cause huge noise addressed in the Mutfords, Hare Street disturbance to a very narrow band of people living in the area. committee report. , Herts SG9 0ED

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