Chiltern Countryside Group Response to LLA Planning Application

Below is a copy of the document submitted by Chiltern Countryside Group in response to the London Luton Airport Ltd Planning Application 21/00031/VARCON February 2021. You can use this information to help with your own objection.

The Chiltern Society also objects to the Luton Airport expansion, highlighting the plan does not stand up to scrutiny.

The new application seeks to vary Planning Conditions 8 (passenger throughput capacity); 10 (noise control), 22 (car parking), 24 (travel plans) and 28 (application plans and documents) all of which were given consent under planning ref. 15/00950/VARCON dated 17 October 2017.

CCG comments below specifically on Planning Conditions 8, 10 and 24, noting that the two previous applications made by LLA on these matters have now been withdrawn.

The Chiltern Countryside Group is strongly opposed to an increase to 19 million passenger numbers per annum at London Luton Airport. They give their reasons for this decision below:

  1. An unchanged view:
    It is the considered decision of the CCG that the reasons stated for any further expansion of passenger numbers at London Luton Airport (LLA) prior to the planned expansion to be sought later in 2021 as a Nationally Significant Infrastructure Project under a Development Consent Order are totally unsubstantiated and are unacceptable to the airport’s impacted communities.In January, 2020, the CCG submitted strong objections based on valid, factual evidence against LBC granting permission for any increase in passenger numbers p.a. over the 18m ppa permitted in 2012, which was in itself, subject to planning conditions.The CCG’s position has not changed.  We remain opposed to any increase in permitted passenger numbers (pn) or other expansion.  We therefore attach a further copy of the Group’s January 2020 response giving our reasons for objection to that planning application, which remain in situ for this revised application.

  2. Breach of Planning Condition 15/00950/VARCON:
    LLA has admitted breach of planning condition 10 and rather than work towards meeting that condition, seeks to have it varied.  This is unacceptable and  modification should not be granted.LLA has demonstrated that the operating airport cannot fulfil its statutory duties regarding noise contours (Condition 10). How can overflown communities be confident that any new planning conditions will be met? Rather than seeking to vary these, LLA should concentrate on ensuring all conditions, which were put in place to protect and minimise impact on overflown communities, are fulfilled.
  1. When will the quieter, more modern aircraft promised in 2012 come on stream?
    The CCG does not accept or find supporting evidence to the claim that noise impact for overflown communities will be lessened by airlines acquiring quieter, more modern aircraft.As the application acknowledges,  the international COVID19 pandemic has heavily impacted aviation, with major airlines struggling to survive. On 8 October, 2020, EasyJet, LLA’s main carrier, posted an £800m loss (BBC News 8.10.20).This is a huge loss for any airline to absorb.  We consider it be highly unlikely therefore that funds will be found to invest in the new quieter aircraft, promised by LLA in its expansion application of 2012.
  1. Is consent to increase passenger numbers necessary?
    As EasyJet, a major carrier at LLA has predicted a shortfall in passengers of 75% in 2021, (BBC News 8.10.20), we find it totally unnecessary for the airport to seek consent for increased pn pa.We do not accept that demand from 1 million more passengers per annum will materialise in the near future or even within the 3 years anticipated in the application. Therefore we consider that the airport would be better advised to consolidate and improve the travelling experience for those passengers, for whom they already hold consent to transit.
  1. Increase and/or operational changes to flights
    Unless aircraft are expected to fly without a full complement of passengers, which is unlikely as profit margins have historically always been squeezed by the low-cost carriers, such as EasyJet and Whizz, then any increase in passenger numbers will inevitably mean (a) more flights and/or (b) larger aircraft, both of which will increase visual, aural and air pollution over the Chilterns and its AONB. This is unacceptable.The application states that there will be increased impact on people and the natural environment (5.2.5 p63).  The only ‘mitigation’ which is offered is more passengers per flight and larger aircraft, both of which will cause more operational noise and increased road traffic. More heavily laden planes are more likely to cause greater noise, take longer to become fully airborne to clear for eg. the Bovingdon stack and make more noise at the lower levels required over the Chilterns and its AONB as they make final descent to approach touch down.Therefore, the overflown communities of the Chilterns are highly likely to experience far greater aural, visual and air quality pollution.

    In these precarious economic times, especially for airlines, are airline operators going to acquire new, larger aircraft? Or will they revert to older, noisier aircraft which hold more passengers? Neither of these will reduce noise impact.

    LLA discusses operational routes for North America. These will inevitably mean larger, noisier aircraft and more passengers arriving/departing simultaneously, putting even greater pressure on already busy public roads.

    The Consultation documents refer to operational changes and flight schedules. This is of serious concern to already impacted communities in the Chilterns. The National Air Traffic Service (NATS) has just completed consulting on operational changes at LLA & Stansted, which closed on 5 February 2021. Thus any application presently is premature and presupposing the outcome of the NATS Consultation. This is undemocratic and fails to support the principles of consultation.

  1. Night flights and re-scheduling
    The CCG remains extremely concerned that rescheduling of flights will increase operations during the night time and early morning/evening shoulder periods, which are highly sensitive for community impact.Whilst LLA operates a quota system for night flights, in practice this means that if daytime flights increase, then so proportionally can night flights. This is of grave concern. Without concrete and substantiated data, communities cannot possibly be reassured that their right for undisturbed sleep will not be compromised.LLA’s application states that total number of movements will increase by 0.8% but it is unclear whether this applies per hour, per day or total movements per annum. For eg. Fig 2.3 p19 of the Environmental Statement shows that between 23.00 and 1.00am there are already on average between 10-15 arrivals per hour (1 or more every 6 minutes). For the overflown community trying to sleep, that is a huge disruption.

    Further, it states there will be no changes to the number of movements at peak times. Therefore, it is clear that (a) aircraft operating during peak hours are likely to increase in size and capacity with consequent increased impact and (b) operations will increase at other times, ie day time, morning/ evening shoulder periods and at night.

    These changes will increase the number of people overflown and fail to address the requirements of statutory legislation.

  1. How would any consent affect the future?
    Despite the statements made in the application,  CCG remains extremely concerned that by seeking consent for an increase in passenger numbers now, any such consent will undermine and compromise the validity of the Development Consent Order planned for submission later in 2021.We would sincerely hope that LLA does not intend to continue seeking consent for incremental increases in passenger numbers pa in anticipation that therefore the major expansion which would require a Development Consent Order from the Secretary of State for Transport becomes irrelevant.The Group would still like reassurance on this key point.
  1. Environmental Statement
    Page 14 of the Environmental Impact Assessment accompanying the previous application (January 2020)  discusses the landscape of the Chilterns and its AONB and in particular, the airspace between Ivinghoe and Berkhamsted. This states that Easterly arrivals into LLA are at or above 4000 ft at this point and at 8000 ft for Westerly departures.We challenge these figures. Operations during 2020, whilst extremely reduced due to the pandemic, continue to overfly the Chilterns at levels below 4,000 ft. We hold substantial documented evidence, supported by LLA’s Environmental Office, that commonly Easterly arrivals during the daytime shoulder period and at night consistently fly below 4000 ft at this point. Indeed, they are more commonly nearer to 3000 ft, and a few below that.Therefore we still find that overflown communities some 17 miles from LLA which lie either within, or abutting, the Chilterns AONB are heavily impacted by LLA’s operations and this will only increase as passenger numbers and aircraft size grows.
  1. Protection of the Chilterns AONB
    The application demonstrates inadequate regard to the statutory obligations of public bodies to protect and conserve AONBs, as enshrined in the Countryside and Rights of Way Act 2000 s85 (CROW Act). As LBC is a public body and the decision-making authority for this application, it should fulfil its statutory obligations as described above and reject these proposals, which if granted, would have negative impact upon the overflown landscape of the Chilterns AONB.

Visit Luton Borough Council Planning, then enter the ref 21/00031VARCON to make your response or visit: https://planning.luton.gov.uk/online-applications/applicationDetails.do?keyVal=QMRHGXKGFQH00&activeTab=summary.  

DEADLINE for responses to this third application is 18 FEBRUARY 2021.