Noise mitigations “affect less than 1% of flights”

An official response by Terence O’Rourke to questions raised by the Hitchin Forum proves that the so-called noise mitigations proposed by Luton Airport are so feeble as to be almost worthless. The much-vaunted commitments to take seriously the noise concerns of local people have been exposed as hollow by the Airport’s own planning consultants.

Just look at what the Airport said in its September 2012 Master Plan – we have added emphasis to show the commitments which the Airport told us it would be making:

“10.13 The current national aviation policy is the Future of Air Transport White Paper 2003 (FATWP). In this White Paper, the government supports development at
the Airport which makes full use of its single runway on condition that the overall environmental impacts of such development will be carefully controlled and adequate mitigation provided.” (Master Plan Sep 2012)

“10.17 Regarding land use planning and management, paragraph 4.34 states that ‘planning policies and decisions should aim to avoid noise from giving rise to significant adverse impacts on health and quality of life as a result of new development, and mitigate and reduce to a minimum other adverse impacts … including through the use of conditions’. As demonstrated in section 9, we are incorporating a robust package of noise mitigation as part of the proposed development, which aligns fully with the APF.”

Now look at Terence O’Rourke’s responses to the questions raised by Hitchin Forum:

Q: How many flights would have been affected in 2011 by the Chapter 2 ban?
A: Less than 1% of night flights would have been banned in 2012.

Q: How many aircraft in 2012 exceeded the 82dB(A) night noise violation limit and would have exceeded the proposed 80bd(A) night noise violation limit?
A: In 2012, less than 1% of aircraft (3) exceeded the 82 dB(A) night time noise limit.
In 2012, less than 1% of aircraft (14) would have exceeded an 80 dB(A) night time noise limit.

Q: How many aircraft in 2012 were vectored out of the NPR swathes below 4,000ft?
A: LLAOL estimates that less than 1% of flights are currently vectored off NPR swathes between 3,000 and 4,000 ft.

Q: How many flights in 2012 would have exceeded the proposed daytime noise limits?
A: The total number and percentage of aircraft that would have exceeded each of the three proposed daytime noise limits in 2012 is summarised below. • 85 dB(A): 29 (less than 1%) • 82 dB(A): 62 (less than 1%) • 80 dB(A): 138 (less than 1%)

And in case you’re wondering, “less than 1%” is developer-speak for miniscule fractions of a percent: for example 138 aircraft per year in 2012 is about 0.1% of the total. And as a further insult to our intelligence, they describe the above as “a robust response”…

You can read the full set of questions and answers by clicking here >> Hitchin Forum Q&A

Noise footprint “could affect twice as many people”

The noise footprint from Luton Airport could affect twice as many people by 2028 as it does now, according to figures in the Airport’s planning application. The number of people affected by the so-called annoyance threshold of 57dB is set to rise from 6,726 in 2011, to 11,784 by 2028 in the worst case scenario. But this figure assumes no more houses will have been built in the noise threshold area, so it could easily reach double the 2011 levels.

The “worst case scenario” assumes that the airlines will not have substantially modernised their fleets to quieter planes, or fitted quieter engines to their existing aircraft. But in this economic climate – particularly with the ruling that airlines have to compensate passengers for delays – it is not a certainty that fleets would modernise. And even if they did, it is not necessarily the case that the planes would be quieter, since larger planes tend to be noisier than smaller ones of the same class. Airport operators cannot make binding predictions about what airlines might or might not do, and when money is tight economies are made.

These proposals are certainly not in line with government policy. The DfT’s 2012 Draft Aviation Policy Framework 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”. It proposes to retain the objective set out in the 2003 Future of Air Transport White Paper “to limit and, where possible, reduce the number of people in the UK significantly affected by aircraft noise”. Luton’s planning application fails to maintain this balance and fails to limit or reduce the number of people affected by aircraft noise, and therefore should be rejected.

Noise Footprint

HALE responds

HALE today issued its hard-hitting response in opposition to the consultation on Luton Airport’s revised Masterplan for expansion. In it, HALE strongly opposes the plans for 60% extra flights and focuses particular attention on the Airport’s Noise Action Plan and six new noise mitigations, showing that they are too weak to have any significant impact on the noise footprint even of current flight levels, let alone if flights are increased by an extra 160 per day as proposed.

HALE draws on the Draft Aviation Policy Framework of July 2012 to show that current attitudes to airport noise are substantially changing, and that the government is challenging planners and airport operators to pay much more heed to the detrimental impact of aircraft noise to health and quality of life. HALE points out that the policy places significant emphasis on a tougher noise management regime including independent and transparent monitoring and enforcement, and realistic noise limits linked to penalties which incentivise noise reduction.

The policy also states that Noise Action Plans are intended to describe actions to reduce noise impacts, and attention is drawn to the National Planning Policy framework which says that planning policies and decisions should avoid noise from giving rise to significant adverse impacts on health and quality of life. The consultation response includes quotes from people living all around the airport who have simply had enough of the growing noise burden.

“Through very clear and explicit guidance, the Draft Aviation Policy Framework emphasises the need for airports to act in order to reduce noise, not just to pay lipservice in order to tick political boxes. Provision after provision – for example working with local communities to develop acceptable solutions, changing routes and aircraft height, striving for continuous improvement in mitigation of noise, review of departure noise limits and setting significantly higher penalties, setting lower noise limits, greater investment in noise monitoring and a more independent overseeing of noise management by the CAA and Consultative Committees – make it absolutely clear that this is an issue on which action is required that leads to significant improvement, not just monitor, publish and forget” says Andrew Lambourne of HALE.

Given this context, HALE has provided in its response opposing the expansion plans a detailed critique of the current Luton Airport Noise Action Plan and its six new noise mitigation measures. Both are judged to be weak and ineffective, and HALE’s verdict is that the noise management measures proposed by Luton Airport are simply not tough or explicit enough to deliver any significant improvement in the noise burden experienced by local communities.

“Any action plan genuinely intended to change something has to have clear and definite objectives and deadlines” says Andrew Lambourne. “Luton Airport’s Noise Action Plan is long on monitoring and discussion, and very short on delivering noise reduction. In fact, there is not a single tough action which will have a significant effect on the noise pollution which this airport produces. Where are the deadlines by which the noisiest aircraft will be banned? Where are noise violation limits which will actually bite into the top 10% of noisiest flights?  Where are the actual noise targets, reducing year on year, which the airport will meet? The answer is that there are none. In a so-called Noise Action Plan of 55 measures, the word ‘monitor’ appears 7 times, ‘review’ 11, ‘reduce’ none. 44 of those 55 measures involve monitoring, reviewing and liaising – none of them delivers tough and definite action to reduce noise.”

HALE delivers the same verdict on the six new noise mitigations incorporated into the Masterplan. “Most of them are just vague and meaningless – or deliberately ineffective: like setting a new lower noise violation limit which is actually well above the noise levels of 97% of the flights. It just proves the Luton Airport does not yet take the noise issue seriously enough – we want that to change. People living all around the airport demand better than that – and they deserve better than that.” concludes Andrew.

The full HALE response can be downloaded by clicking this link.

Luton Hooey!

Just when we thought airport expansion proposals could not get any crazier, they have. The Policy Exchange think tank has put forward a proposal to demolish Luton Hoo and build a 4-runway airport there, just up the road from Harpenden. London’s Heathrow and Stansted airports would then close, transferring their flights to the new hub airport along with substantially extra services to the new locations in China and the developing world. Passengers would fly in from around the UK and Europe to transfer on to long-haul flights to the new economies, and business people from China would fly in to Luton and set up their headquarters there.

Quite apart from the almost incredible arrogance of the proposals in dismissing at a stroke the interests of the local communities, they miss such obvious practical issues that it’s clear they’ve been produced by a lot of web-surfing rather than an actual first-hand appreciation of the area being discussed and its existing infrastructure. One could almost imagine the date was 1st April not 5th October.

Hills: For a start, the whole area around Luton Airport is very hilly, and while the report acknowledges this it seems to suggest it would be reasonably achievable to level it all off so that new runways could be planted.

Noise: The author blithely asserts that the noise nuisance from each aircraft will be reduced, massively. This assertion is utterly without foundation, and in fact because they are talking long-haul, the larger heavier planes will be inherently noisier and will take longer to climb to altitude and so the noise will last longer as well.

Trains: The suggestion is made that there would be fast trains every 5 minutes to London on the existing 4 tracks. Brilliant – that means that the current semi-fast services on which Harpenden and St Albans rely would be just swept away ?

Flight paths: The planes taking off from Luton Hooey Airport would normally be facing in the wrong direction to get to China – the prevailing wind is from the west, so they take off to the west and would then need to turn to head east – and because they’d be starting from a more southerly position, their tracks would go directly over Hemel, St Albans and Welwyn. on the way out. Fantastic proposal we don’t think!

Oil: The oil that fuels planes is a finite resource. Before long – if not already – the good people of planet Earth will have passed the peak of oil production capability and then the supplies will start to run down. So arguing for more and more increases in airport capacity rather flies in the face of the economic logic which says that dwindling resources start to get more expensive, and then the demand reduces.

Carbon: The government’s own website says that aircraft contributed 6.4% of the UK carbon footprint in 2006, and this will rise to 10% by 2020 if nothing is done to reverse the trend. Climate change is not going to be slowed down by furthering the myth that nobody can do business unless it involves flying.

Roads: Are the M1, M25 and the A1 quiet roads with very little traffic and no tendency to snarl up? Er, no. So how would they be affected by adding the combined traffic from Heathrow, Stansted and Luton airports plus further expansion? Er, very badly.

Just in case anyone is crazy enough to take these proposals seriously, we’d all better write yet again to our long-suffering local MPs Peter Lilley, Ann Maine, Mike Penning, Stephen McPartland and Grant Shapps – see Contacts Page for details.

You can find the think tank document at this link: click here

Expansion plans

The revised expansion plan for Luton Airport has been issued today 3rd Sep and can be downloaded from the airport website by clicking the link at the end of this article.

Compared to 2011 the main measures include:

  • More planes – a 58% increase in the number of flights
  • More often – frequency up 17% to one every 90 seconds at peak
  • More intrusive – the peak time at 06:00-08:30 will become longer
  • More traffic – an 87% increase in passenger capacity from 9.6m to 18m
  • More emissions – the airport ignores emissions once a plane is airborne
  • More impact – a new 4-storey carpark is to be built on the top of the hill

Mitigation Plans and Action Plans abound, but these involve monitoring rather than aggressively tackling the issues which affect local communities even with the current level of flights and passengers: noise, pollution, night flights and road bottlenecks.

The Environmental Impact statement has not yet been published, so the detail on what these proposals will mean to the local environment in terms of air quality and climate, water quality and usage, landscape and visual impact, noise and vibration, traffic and transportation is still not clear.

HALE is working closely with other campaign groups as well as local councils, however everyone can play a part by ensuring that their views are sent to the airport and to local councillors, and making other people aware of how to feed back their opinions.

Glyn Jones, MD of Luton Airport Operators, has claimed that their previous plans are “broadly supported” by 2/3 of respondents. Since many of the proposals (to improve the terminal facilities, speed up security and baggage collection and make the drop-off easier) are generally welcome, there is a risk that “support” could be misinterpreted. Local people need to make it very clear that the surrounding community experience counts just as much as the passenger experience.

A 6-week public consultation starts today, and there are some local meetings planned – see Public Exhibitions for a timetable.

Luton Airport website link describing plans with download available: click here

Comments can be emailed to: londonslocalairport@ltn.aero

Double whammy

Luton Airport owners and operators have kissed and made up, with a deal now signed which extends the current operating franchise to 2031 subject to an application to increase airport capacity to from 10 million to 18 million passengers per year. This represents a combination of the two separate plans discussed earlier in the year.

In almost doubling the passenger throughput, Luton Airport would add something like 100 flights a day, and would pack many extra flights into the already busy 6am-9am morning peak, delivering a plane every 90 seconds to fly over local residents.

What’s farcical is that they try to claim this is “sustainable growth” when clearly it is the exact opposite. The Directgov website has some very relevant things to say about air travel and its impact on the environment:

Air travel is a growing contributor to climate change and can have an impact on local traffic emissions and noise. You can help reduce your impact on the environment by choosing to travel by air less. In 2006, air travel accounted for 6.4 per cent of the UK’s emissions of carbon dioxide (CO2), the main greenhouse gas causing climate change. Forecasts suggest that this could grow. If no action is taken, carbon dioxide emissions from aviation could make up around 10 per cent of the UK’s total CO2 emissions by 2020. 

  • consider video or teleconferencing, instead of flying to business meetings
  • think about taking a holiday within the UK
  • taking one longer holiday will have a lower impact than going on several short trips if you are flying each time

When making journeys in the UK, and even internationally, there is often the option of getting there without flying.

Click on Directgov for the complete set of guidelines.

The point about taking holidays in the UK is very important, since it boosts the UK economy if we spend our money here rather than overseas: in 2011 the balance of payments deficit due to more people going overseas for holidays than coming to the UK was £13billion. So we can all help create jobs in Britain by flying less, not more.

Public consultation on the plans starts on September 3rd and it is essential for eveybody who cares about this issue to contact their local MP and councillors to express their views, as well as responding to the consultation questionnaire when it is published.

Angry of Luton

HALE has been given permission to publish this open letter from a South Luton resident to Robin Harris of Luton Borough Council and Mark Turner of LLAL. It makes grim reading:

Hello Mr Harris and colleagues,

I write to express my dissatisfaction at both yours and Neil Thompson’s absence last Saturday morning from the Breachwood Green HALE meeting.

Despite their invitation, I understand you were not there as the meeting took place outside Luton. It was a missed opportunity for you to put forward your side re the expansion of Luton Airport. As someone who works for the tax payers of Luton – I would like you to have been there. I was and so were other people from Luton. This type of planned expansion negates any county boundaries in my opinion.

The residents of this part of Luton are not all in favour of the expansion despite the spin in the media, and the line toed by the council. On that note, trying to sell it to us by saying what a great neighbour the Airport is – reducing our council tax, creating thousands of jobs (which I don’t believe), and bringing our economy up, is not fair.

The Airport is not a good neighbour. Swathe changes, unbearable noise, night flights, air pollution – these things cannot be mitigated against. Any expansion would see this become worse.

I would like my Council tax to go up please. I have no problem with my money being spent on good causes to bring this town up to the levels of some of our Hertfordshire neighbours.

There may well be several hundred new jobs created at the Airport. How many top jobs would go to the people of Luton? None. They would be offered the menial jobs. All the management people would come from outside; wouldn’t live here, wouldn’t want to live here what with the unfair press our town gets and the fact that it is kept in a deliberate perceived state of deprivation. They wouldn’t want to shop here – there are so very few decent shops in Luton.

People flying out are not going to pop into town to shop. The only view they would have of Luton is as they fly off and back again. Exactly how is that improving our economy?

I appreciate a planning application has yet to be submitted and at that point we are going to be asked our opinions – what a pity you chose not to come along to the meeting and allay fears we all have about the proposals. And I include our neighbours in Hertfordshire. Being over the border makes their voice no less important.

Dacorum council I am led to believe are behind the residents as far as is possible. Harpenden council is sending a questionnaire to residents. What a shame we haven’t been offered that. By the time that planning application is submitted it will be too late for us. The expansion will come whatever we think.

We are having so much forced upon us in this part of Luton. J10a ‘improvements’ – we all know that expansion is for the Airport regardless of how it is otherwise sold to us. 18 months of roadworks to look forward to. And the Airport have contributed not one penny to that project I am told.

We have the awful vanity project guided busway coming soon. Still haven’t met one person who says they are going to use it.

We have LBC’s planning dept giving permission for people in our Conservation Area to convert large family homes to HMO’s with all the trouble that brings. And now, building in back gardens.

I think the Airport should be willing to compensate us – those of us who haven’t moved yet. I have never seen so many houses in this area for sale in all the time I have lived here. Isn’t that sad. I imagine I and my neighbours are looking at a substantial decrease in house prices once the Airport expands.

Who wants to live here with the prospect of noisy smelly planes overhead every 90 seconds. The windows in my 100 odd year old house rattle when planes fly over. The cost to replace those in wood or dreaded plastic runs into £1000′s. Are the airport, as a good neighbour going to pay to have all our windows replaced and our homes insulated?

Or, how about they buy all our homes at the going market rate?

Luton airport is simply not in the right place to expand. The road infrastructure, rail etc cannot cope with it as it is. To expect up to 30 million people pa to use the airport is pie in the sky. 1/2 the population of the UK coming through there every year? Simply ridiculous. The proposal for 18 million is bad enough. That would double the current usage.

The skies are full already. You could put people’s safety at risk – in the air and of course us residents.

Regards,

HC (name supplied)

Triple or bust

Herts County Council has just discovered that Luton Airport’s owners are hatching plans to increase capacity not just to 18m passengers per year – double current levels – but to 30m : triple what the airport currently handles. Their pre-application to the National Infrastructure Planning body refers to a planning application as early as end of 2013.

LLAL have indicated from the start that they would eventually like to see the capacity increased to 30m passengers per year. Yet the planning consultation they put forward publicly only talks of 18m. The current airport operators made it very clear that even this would consitute over-investment, and that a realistic maximum for this “local” airport would be more like 16m passengers per year, given that it is only a quarter of the size of Stansted in land area, and only has one runway.

Yet behind the scenes it now seems that LLAL do indeed intend to apply for a further huge hike in passenger numbers.

A serious proposition to grow Luton Airport to 30m passengers a year – triple the current numbers – would massively disrupt the M1 and rail transport infrastructure, as well as blighting local communities with increased noise, pollution and night flights. It would seem very unlikely that the necessary development could be contained on the existing site, and the project would trigger being called-in by government.

It would then become very clear exactly what this govenment’s priorities are in planning and development terms: rational growth based on sound judgement, or support for a ludicrous airport expansion proposal in the middle an already crowded airspace and an already congested urban area, with insufficient transport infrastructure to meet even its current needs.

The pre-application details can be found by clicking on this link. Herts County Council’s press release can be downloaded by clicking here.

Latest details to emerge: minutes of a meeting between LLAL’s consultants and the Infrastructure Planning Commission can be accessed on this link.

Your voice?

The London Luton Airport Consultative Committee (LLACC) is a key forum for those affected by the airport. As its website says: “The aim of the Committee is to ensure that as wide a range of views as possible is made available to the London Luton Airport management team so that they can take account of the issues which are of concern to those using the airport, working at it or living around it.”

LLACC’s response to the LLAOL expansion consultation is a carefully worded letter which welcomes development of the airport provided it can be balanced with being a good neighbour, though it expresses a number of significant reservations. Those reservations cover:

  • the impact on the local road network if capacity is expanded
  • whether the terminal improvements would be adequate for more passengers
  • the increase in noise, numbers of flights and likely increase in night flights
  • the need for a tighter noise policy and more noise mitigation measures

You can read the letter for yourself by clicking LLACC MasterPlanResponse.

Members of the Committee are drawn from local councils and campaign groups, and their role is to represent the views of local people. A full list of members can be viewed by clicking LLACC List of Members and Representation October 2011.

The aims of the Committee are ”to represent as wide a range of views as possible“. It’s therefore important for the representatives on the committee to hear people’s views so that they can be adequately taken into account at this crucial time.

HALE would like to hear whether you were aware of the LLACC. Do you know how to contact your representative? Do you support its response to the airport? Do you have any suggestions having read more about its work?

You can share your views by posting a reply below.

Stealth fighter

Luton Airport’s operator LLAOL has announced its own plan for expansion over the next 15 years, to rival the one proposed by its owners Luton Borough Council. We believe they are trying to get this in “under the radar” while people are distracted in fighting LBC’s plans. Key aspects of the LLAOL plan are as follows:

More traffic: LLAOL plans to increase capacity by nearly 60%, to 16 million passengers per year over the next 15 years. That’s an extra 6 million people travelling to and from the airport each year, or 16,000 EACH DAY on the already congested road and rail systems.

More planes: LLAOL will increase the number of flights by 33%, ie 37,000 extra flights a year or 100 more flights EACH DAY, with planes coming over EVERY 90 SECONDS at peak times.

More noise: they propose to use even bigger planes which are heavier and therefore noisier. The percentage of flights above 76dbA has already DOUBLED in the last 5 years, and this trend looks set to continue.

More sleepless nights: they say the proportion of night flights will reduce, but we can safely assume that the NUMBER of night flights will actually increase, otherwise they would have made this clearer.

More hours of plane pain: very weasel words are used to break the bad news that the early morning “peak time” for flights (currently 6am till 9:30am) will be extended, and they carefully avoid being clear about whether it might start EVEN EARLIER.

More overflights: there is no commitment in the plan to avoid overflying towns and villages around the airport. Stevenage for example gets the arrivals coming in directly over the town. Hitchin, Welwyn, St Albans, Hemel Hempstead, Harpenden, Gaddesden Row are all affected NOW.

More pollution: there is already great concern over nitrogen dioxide levels in the air, and jet engines in particular create more of this pollutant. The plan talks of carbon footprint reduction at the airport but we believe they are not including the biggest carbon footprint of all – from the planes themselves!

So in summary it looks like 100 extra planes a day, 16,000 extra people a day on road and rail, planes every 90 seconds, more noise, a longer peak time, more night flights and more pollution. Thanks, Luton Airport!

To fight this, post us a reply below and contact the Airport by emailing londonslocalairport@ltn.aero to officially register your objections by 24th April.