lutonairport@hitchinforum.org.uk www.hitchinforum.org.uk Chairman: Mike Clarke Member of: Hitchin Initiative President: Brian Limbrick MBE Campaign to Protect Rural England Historic Towns Forum

Ms Wendy Rousell

Development Control,

Luton Borough Council,

Town Hall, George Street,

Luton,

Bedfordshire LU1 2BQ

12th

February 2013

Re London Luton Airport Expansion Plans (LBC Planning Application no 12/01400/FUL)

Dear Ms Rousell

Hitchin Forum objects to the proposed expansion of Luton Airport. Our objections fall under 3 broad headings;

1. The increase in flights will give rise to significant adverse noise impacts, the effects of which

are not sufficiently mitigated to satisfy the demands of national and local policy.

2. There will be a significant increase in traffic on roads in North Hertfordshire with no

provision for mitigation within the application.

3. The benefit to the local economy is over-stated.

1. Increase in Flights and Noise Using selected quotes (e.g. from the Draft Aviation Policy Framework para 4.34, quoted in Planning Supporting Statement para 7.7), the application claims to be in line with requirements to control and reduce noise laid down in national and local planning documents. We believe that the Application does not satisfy these requirements because

• few proposed noise mitigation measures have clear measurable targets, deadlines for their

achievement and actions in the event of failure to achieve them. (Appendix 1)

• such ‘targets’ that are set, when applied to flights in 2012, would result in fines for

insignificant numbers of aircraft (all less than 1% of flights for the year – Appendix 1) and

therefore have little deterrent value

• by using a grossly over-estimated predicted figure (60.6km2) for the area enclosed by the

48dBLAeq,8h night noise contour in 1999, the proposers argue that noise levels will

comfortably meet the requirements of the Luton Local Plan, Policy LLA1 subsection (iv). If

the actual figure (37.2km2) is used, the requirement is not met. (Appendix 2)

• the review period for the Noise Action Plan is too long (5 years) to ensure that it reacts to

changes in e.g. economic conditions, airline change, fleet change etc

• the standards used are based on a measure (LAeq) which does not fully reflect the

perception of noise under the flightpath, and is acknowledged as such by industry experts

(Appendix 3)

• the standards are not readily understandable by the general public (see quote from ANASE,

Appendix 3)

Using TraVis readings for December 2012, we have conducted an investigation of noise events at the Frogmore Bottom NMT (see summary and the associated commentary, Appendix 4). Assuming a 58% increase in aircraft movements we estimate that, by 2028, there will be more than 160 noise events per day at Frogmore Bottom, each lasting half a minute or more, with (assuming no fleet improvement) maxima up to 79dBA. This is in December – far from the busiest time of year. These may affect residents within the 57dBA contour – an estimated 6700 people. Fleet improvements resulting in quieter aircraft are likely to result in marginal benefits, and depend on, among other factors, the economic situation as to whether they happen at all. The inevitable consequence of these proposals will be to increase the adverse impact on the area and the people living there. In addition, the proposal takes no account of the inevitable decrease in recreational amenity value of the area to walkers and cyclists. At present, the area is already marred by frequent over-flights, but the area affected will increase and be less appealing if approval is granted. Although well outside the 57dB(A) contour, people in Hitchin already experience noise annoyance, especially at night. This is not simply anecdotal. It is clear from the Airport’s own information (see Appendix 5) that a significant number of easterly departing flights are vectored-off the NPR and fly over central Hitchin. With a larger number of ATMs, flights of this nature will inevitably increase in frequency. Again, we see no clear mitigation measure designed to address this issue. 2 Road Traffic Impact in North Hertfordshire The Traffic Report acknowledges that the main impact is likely to be born by Hitchin. (Para 14.7.6 table 83) but argues that due to the anticipated popularity of very early morning departures (itself a cause for concern with regard to both traffic and aircraft noise) the impact in congestion terms is unlikely to be significant. Increases of 103 (4.00-5.00am), 202 (5.00-6.00am) and 59 (6.00-7.00am) vehicles passing through Hitchin are predicted. These figures only relate to private cars, so are under-estimates of total increases. Irrespective of route used, this increase will adversely affect traffic noise for many Hitchin residents, and those living in the Offley Road in particular. The report claims that any impact on afternoon peaks will be negligible. Alarmingly for those living in villages such as Lilley, Whitwell or Codicote, para 14.7.9 suggests that drivers will choose other routes, thus reducing the impact on strategic roads further. Whilst much is made of provision of better public transport arrangements (between the airport and Luton Parkway, for instance), we can find no proposal to do the same from either Stevenage or Hitchin stations. 3. Economic benefits. A significant feature of the planning application is the predicted benefit to the local economy and the potential to generate new jobs. Aviation operational efficiency has increased. Budget airlines in particular have already reduced employee to passenger ratios by cutting baggage and employing automated check-in systems. Such trends are only likely to continue as competition becomes fiercer. In the case of Stansted, successive planning applications show higher than actual job predictions (see Appendix 6). We believe job growth at Luton is similarly over-estimated, based on unreliable assumptions about fuel costs, environmental regulation and efficiency.

A decision to grant approval to the airport expansion plan fails to satisfy the requirement that ‘..decisions should aim to avoid noise from giving rise to significant adverse impacts..’ (DAPF para 4.34). Other planning policies make similar statements. The number of flights will increase. The provisions of the Noise Action Plan are insufficiently robust to protect local people from the adverse impact. The few measurable targets are unclear, are so ‘realistic’ as to be unchallenging, and will be infrequently reviewed. They will not drive down adverse noise impacts. There would be a significant increase in traffic on towns and villages in North Hertfordshire, and through Hitchin in particular. This would pose an unacceptable threat to environmentally sensitive green belt areas to the south and west of the town if further road-building were to be proposed to deal with it. We do not consider that there is sufficient evidence that economic benefits from the proposal are sustainable throughout the duration of the expansion period, nor do they outweigh the negative impact on quality of life for many of the airport’s neighbours. The application should therefore be rejected. Yours sincerely,

Appendix 1 Noise mitigation measures

Hitchin Forum requested responses to questions about the new noise mitigation measures

1.3, 4.3, 5.1, 5.2 and 5.3, to which Terence O’Rourke provided the answers below.

Questions and answers

Questions and answers

Appendix 1 (continued)

Appendix 1 (continued)

Comment

The most demanding of the daytime limits from measure 5.3 is not due to be imposed until

2020, and yet, when applied to 2012 flights, only 138 would have been fined. This is one

aircraft every 2.5 days. Assuming the limit to have been effective in encouraging the pilot to

fly it in such a way as to avoid the fine, the difference to anybody on the ground would be

imperceptible. This limit is insufficiently demanding to drive down noise. In the case of

measures 4.3 and 5.3, not only are the limits ineffectual because they are unchallenging,

they are also unclear. There is no mention of the location of the noise monitor used to make

the measurements and there is no statement of exactly what the measurement to be taken

would be – whether a single reading in excess of 80dB(A) or whether a reading of in excess

of 80dB(A) for a period of 10 seconds would be applicable.

In the case of other noise mitigation measures, there are no demonstrable targets, few are

time-limited, and it is therefore unclear how their success could be assessed.

Appendix 2

Planning application Noise Report, para 2.29 and table 7.

Policy LLA1

The Borough Council will grant planning permission for development at London Luton Airport (identified as such on the Proposals Map) provided that it:

…..

(iv) results in an aircraft noise impact that is below the 1999 level;

Comment

It is entirely reasonable to assume that the valid figure to measure noise impact against

should be the actual area enclosed by the 48dB noise contour (37.2km2) rather than the

predicted value of 60.6km2.

Appendix 3

Industry expert comment on noise measurements and standards

'If parties are to have confidence in the indices used to measure the noise climate they need to be

founded on a sound basis of up-to-date research. Unfortunately the Department’s (i.e. DoT) own

evidence suggests that this does not apply to the use of LAeq, in spite of their argument that research

had guided the choice of noise indices since 1967'

(Report of the Inspector at the Heathrow Terminal 5 Inquiry, December 2000 paras 21.3.35).

and

‘Overall, we consider that while LAeq continues to be a good proxy for measuring community

annoyance at a point in time, the relationship between LAeq and annoyance is not stable over

time. An NNI (Noise and Number Index) – type measure appears to offer a stronger

basis than LAeq for estimating future levels of annoyance in response to changing numbers

and types of aircraft.’

Attitudes to Noise from Aviation Sources in England (ANASE)

Executive Summary for Department for Transport In Association With John Bates Services, Ian

Flindell and RPS October 2007 Para 1.4.13

Appendix 4 Noise Monitoring Terminal (NMT) Readings

We have carried out a simple investigation using data taken from the Luton Airport TRAvis

system. Our investigation looked at the maximum noise readings registered by each flight by

the airport’s NMT at Frogmore Bottom. We investigated two 13 hour periods starting at 23.00

hrs on Thursday December 6th (all arrivals) and Thursday December 13th 2012 (all

departures).

Noise events recorded at Frogmore Bottom NMT summary

December 6th/7th (all flights arrivals)

December 13th/14th (all flights departures)

Night time (23.00 to 06.30) Total flights 13 7 Maximum recorded noise during night time period

78.8dBA (twice at 01.46 and 04.11)

76.1 dBA (at 23.49)

Average recorded maximum noise during night time period

72.6 dBA1 69.9 dBA

Daytime (06.30 to 12.00) Total flights 44 53 Maximum recorded noise during day time period

79.0 dBA 70.7 dBA

Average maximum recorded noise during day time period

74.0 dBA 76.1 dBA

Totals (23.00-12.00) Total over-flights 57 60 Average recorded noise event maximum

72.6 dBA 1 70.6 dBA

Estimated duration of noise above background (for average event)

70s 30s

Maximum hourly frequency (overflights per hour)

14 (7.30-8.30) 13 (9.30-10.30)

Notes 1 The average is calculated from the 10 flights on the 7th as the NMT appeared not to be working until midnight on the 6th. 2. Noise events in the range 70-80dBA are generally described as equivalent to busy traffic at 1 metre, a noisy restaurant or a quiet vacuum cleaner. Noise events in the 80-90dBA range are equated to heavy city traffic at a distance of 7-14 metres, a vacuum cleaner or a heavy truck.

Appendix 4 (continued) Noise Monitoring Terminal Readings

Commentary

Context

The Frogmore Bottom NMT is within the 57dBALaeq noise contour. Over 6700 people are

therefore currently subjected to a similar level of impact (Table 10, Noise Report).

The noise experience

Our figures show that for two 13 hour periods commencing at 2300hrs on two selected

consecutive Thursday evenings in December 2012, people living to the east of the airport

and within the contour were subjected to at least 57 noise events. At the NMT, each noise

event lasts an estimated 30 seconds (on ascent) and 70 seconds on descent. Those living to

the west of the terminal would have been subjected to a similar number of equally annoying

events. The average maximum noise event is just over 70dBA with arrivals being louder than

departures at the NMT because the altitude of aircraft passing over the NMT is lower on

descent. The maximum recorded readings were 79.0dBA during the day and 78.8dBA (for

two flights) at night.

The future

The expansion proposals will result in a 58% increase in aircraft movements (Environmental

Statement Technical Appendix H para 4.37). 57 noise events over 13 hours equates to

approximately 105 noise events each day at the Frogmore bottom NMT, which we regard as

already excessive. Assuming a 58% increase in ATMs, this equates to more than 160 over-

flights per day, at a time of year which is far from the busiest. Fleet improvements resulting

in quieter aircraft are likely to result in marginal benefits, and depend on, among other

factors, the economic situation as to whether they happen at all. If they lead to bigger

aircraft, there may be no difference to individual noise events. The inevitable consequence

of these proposals will be to increase the adverse impact on the area and the people living

there.

Appendix 5 Flight Tracks

Noise Preferential Routes and actual flight tracks for easterly departures on September 23rd

2012 taken from the Environment Report for July- September 2012 show that a significant

number of aircraft flew over central Hitchin. Very few used the noise preferential route to the

south of the town. We estimate that approximately 12 aircraft flew over Hitchin from these

tracks.

Appendix 5 Flight Tracks (continued)

Noise Preferential Routes and actual flight tracks for westerly arrivals on September 30th

2012 taken from the Environment Report for July- September 2012, shows that some aircraft

flew over central Hitchin. There are no NPRs for approach. We estimate that about 5 aircraft

flew over Hitchin on approach to Luton on this occaision.

Appendix 6

The link between employment and passenger numbers.

The Planning Application makes claims for a number of economic benefits, particularly citing

the number of new jobs predicted to result from increased passenger throughput. The

received wisdom is that increases in passenger numbers result in increases in both direct

and indirect employment. In fact the relationship between passenger numbers and jobs is

very complex. Predictions are often based on questionable assumptions and reflect local

circumstances in order to receive a favourable response from planning authorities. In its

October 2006 Masterplan (see below), Gatwick Airport suggested a total growth in jobs over

the period 1997 to 2015 from 41,000 to only 41,850 in spite of an increase in passenger

numbers from 25mppa to 40mppa. The modest claim may be because the airport wished to

avoid alarming councillors about the potential for a demand for more housing development in

an area where any new development is fiercely contested. The predominant trend, however,

is to over-estimate job growth (see for example the figures for Stansted’s employment

projections overleaf), and we believe Luton’s application to have done this.

Extract from Gatwick Masterplan 2006.

Appendix 6 (continued)

Aviation, Jobs and the UK Economy

Stop Stansted Expansion, August 2011

http://www.aef.org.uk/downloads/Aviation_economics(1).pdf