Feb 18th – deadline for comments on application by Luton airport to increase passenger cap from 18m to 19mppa

Luton Airport has submitted a planning application (21/00031/VARCON) to Luton Borough Council to increase the annual cap on passenger throughput by 5.5% from 18m to 19mppa. Also to expand the day and night noise contours by 11.3% and 15.3% respectively until 2028, when they would be reduced somewhat, but still a net growth from today’s levels. Annual plane movements are forecast to grow by no more than 0.8%. The deadline for responses is February 18th. The airport is arguing that more larger planes means that the extra passengers can be accommodated without a huge increase in plane numbers. They also claim the anticipated new planes will be less noisy and emit less carbon … (’twas ever thus…) These wonderful planes or technologies don’t yet exist. The motivation for the increase in the passenger number cap has been rising demand, before the Covid pandemic struck. Future air traffic demand is uncertain.  The “elephant in the room” is  the conflict of interest of Luton Borough Council being both the planning authority and the owner of the airport.  But Hertfordshire County Council is set to formally object to the plans, largely on grounds of noise nuisance.

See LADACAN website for details


Why people need to say no.

How to do so, before the 17th February 2021.

Luton Airport: Hertfordshire County Council to object to plans to increase passengers to 19m a year

One councillor said the proposals would create “utter misery” for nearby residents

By Deborah Price  and  Adam May, Multimedia Journalist  (Herts Live)

9th February 2021
Hertfordshire County Council is set to formally object to plans to increase passenger numbers at London Luton Airport.

Airport bosses already have permission to increase passenger numbers to 18m a year, which they weren’t expected to reach in 2027/8.

And now they are seeking planning permission to increase numbers further – to 19m a year.

Hertfordshire County Council is not the authority that will determine whether or not the latest application will be approved, but they have been asked to comment as part of the ongoing consultation.

And at a meeting of the county council’s growth, infrastructure, planning and the economy cabinet panel on Thursday (February 4), councillors agreed to object to the proposed increase.

Back in 2019, London Luton Airport Limited consulted on proposals to raise passenger numbers to 32m a year – although they did not go on to submit an application to do so, as had been expected.

And at the meeting, executive member for growth, infrastructure, planning and the economy Cllr Derrick Ashley said it was clear that London Luton Airport and Luton Borough Council had ambitions to drive forward the growth of the airport.

Cllr Sharon Taylor – who is also Labour leader of Stevenage Borough Council – spoke in support of the county council’s continuing objection.

And she stressed that residents in Stevenage, Hertfordshire, had supported the county council’s earlier objection to the “high levels of growth” at the airport.

She said: “In Stevenage it makes people’s lives an utter misery in the summer, when they are trying to sit in their gardens and they have literally got planes coming over every few minutes – very low because we are on the landing path.

“And any more of that – or the expansion that’s predicted – would be worse, I think. So we support your objection to that.”

Meanwhile, councillors also looked at proposed changes to the way aircraft arrivals are managed around Luton – in order to separate traffic headed to Luton and nearby Stansted.

Currently, aircraft heading to both airports are directed to the same ‘holds’ – circling above Royston and Sudbury.

But plans have been drawn up to separate Luton-bound and Stansted-bound aircraft, by creating a new “hold” for Luton-bound aircraft above Grafham Water, west of Huntingdon.

County council officer Paul Donovan told the panel the proposal stems from a safety issue, in that there was too much interaction between Luton and Stansted air traffic in upper air space.

But he said the creation of the new “hold” would change the “arrival patterns” to the airport.

And councillors have been consulted on options for those patterns – including one that would concentrate aircraft on a specific route and another that would spread the traffic slightly.

Members of the committee expressed a preference for the traffic to be spread across a wider area, to even out the impact for residents below.

Liberal Democrat Cllr Steve Jarvis said he agreed with the the recommendation that it was “better to spread a little of the pain more widely rather than have a lot of pain in a very restricted number of places”.

And that was a view backed by fellow Lib Dem Cllr Sandy Walkington, who said: “In the current climate crisis it is absurd that there is talk of this level of expansion for Luton.

“And as a moral issue I think if there are benefits in access to a cheap airport – to hop-off for European holidays, when that happens again – morally they should accept that they may need to suffer some of the consequences in terms of aircraft noise.

“But just to dump all of the problem onto one small section or line of route seems totally wrong.”

Meanwhile, Conservative Cllr Stephen Boulton stressed that the airport’s plans were looking “10, 20, 30 years” into the future.

He suggested that during that time-frame there may be quieter planes and alternatives to aviation fuel.

He also pointed to other factors that may impact on the plans such as the growing numbers of people living in the South and the changing relationship with the EU.

And he said he agreed that the proposals that would spread – rather than concentrate – air traffic would be ‘the best way to go’.

An objection to the proposals for the expansion of annual passenger numbers to 19m will now be drafted and shared with members of the cabinet panel.



From the 02/02/21  LLATVCC newsletter

This application replaces a pair which had much the same scope: the closing date for comment is 17th February.

Luton Airport Planning Application 21/00031/VARCON

This application, to vary among other items the passenger throughput cap and the noise contour areas, is accompanied by an Environmental Impact Assessment (248 pages), a Planning Statement (58 pages) and an Airport Master Plan (82 pages).

In essence, the airport operator wants to get another million more passengers through the airport each year.

The reasons for the current passenger cap and associated noise conditions set by Luton Borough Council include the need to safeguard residential amenity, and to align with the Government objective to limit and where possible reduce the level of aircraft noise.

Neither of these positions has changed. Nevertheless the airport operator is seeking to increase both the annual passenger throughput and the areas contained within the day and night noise contour areas.

The proposition is as follows:

The amendments are considered by LLAOL (London Luton Airport Operations Limited) to provide an appropriate balance between environmental protection and growth. When the airport was operating at its existing capacity of 18mppa there were breaches of the noise contours due to the higher than predicted growth in passenger demand, the delay in delivery of modernised aircraft (e.g. Airbus Neo and grounded B737 MAX) and disruption in European Air Traffic Control from significant weather events and industrial action resulting in flight delays.

Therefore the need to enlarge the noise contour exists independently of the proposed increase of the 18 mppa cap to 19 mppa.

The noise contours required for the 19 mppa would not be significantly different to the enlarged contours that would have been needed to operate at 18 mppa.

The proposed enlargement would apply until 2028, by when it is anticipated that the introduction of newer, quieter aircraft fleet mix would enable LLAOL to comply with a smaller contour albeit not as small as the contours under the existing condition.

The improvements in noise reduction facilitated by new aircraft will bring forward opportunities to reduce the areas covered by the noise contours in the future.

As to the “higher than predicted growth in passenger demand”:

we have frequently reminded the operator and the airport owner that this growth was far from unexpected: it was the direct result of financial incentives from Luton Borough Council to the airlines by way of cost reductions – given during 2013 and reported, rather inconspicuously, in the airport owner’s Annual Report for 2014.

As to flight delays having abruptly increased in extent, this claim is not borne out by what can be seen from Eurocontrol’s CODA (Central Office for Delay Analysis) system, which points out that at the great majority of airports late-evening and early night flights always experience the greatest delays, usually as the accumulation of a series of short delays during the day.

Airlines tend to be over-optimistic when scheduling flights, to get “that one extra rotation – more conservative scheduling would virtually cure this problem.

As to the replacement of the current fleet with less-noisy modern variants, this had been the promise from 2012 onwards, and that promise has not been kept.

Some of the newer variants have appeared at Luton, but the current picture is of predominantly older types and one of the newer models: the A321NEO, is not living up to the claims of lower noise levels on landing.

There is as yet no experience of the way the B737MAX will perform at Luton but it, like the A321NEO, is a larger aircraft and may show, on measurement, that it is no less noisy than its predecessor the 737/800 under Luton conditions.

This replacement rate has a profound effect on the estimates of noise in the Environmental Impact Assessment, and with the present financial climate the replacement rate is likely to be slow, and with several airports with the same noise issues as Luton there is competition between them to persuade or cajole their airlines to base the less noisy models at their airport.

In summary:

the Environmental Impact Assessment says, though not quite clearly enough, that there is no way that the present noise conditions can be met even with the various expedients in place to minimise the scale of the infringements, and that the size of the increase necessary to make it compliant at 19mppa is very little more than would be needed to achieve compliance at 19Mppa.

That sounds a bit too much like “if you want us to score a goal, you must let us move the goalposts”.

But it is not true that there is any need to enlarge the noise contour merely to make it possible for the airport operator to claim that it is now compliant. The contour areas could be left unchanged, and regular reports of the scale of infringement made: this would act as an effective reminder of the need for continuous scrutiny of both the various expedients in place to limit the extent of the infringement and of the airlines’ achievement in replacing their older noisier fleet with less noisy variants.

A more appropriate time to modify the noise contour areas will be during the work on “noise envelopes” which is a part of the work on LLAL’s Development Control Order application to virtually double the airport’s throughput.

However, from the Environmental Impact Assessment: The worst case-year for the number of dwellings above SOAEL (Significant Observable Adverse Effect Level) is 2022, when 724 additional dwellings would be predicted to experience noise above SOAEL during the night-time with the Proposed Scheme in comparison with the existing Condition 10 limits.

The number of additional dwellings above the night-time SOAEL remains constant until 2023 and then decreases thereafter. As mentioned above, this “worst case” position is an optimistic guess, and relies on the rate at which the less-noisy types are introduced as well as the rate at which passenger numbers rise from their present levels.

Whatever the case, we’re told that with the increase in passenger numbers as many as 746 additional dwellings will be significantly affected at night by more noise.

Other strands in the application: the airport claims that it can squeeze another million passengers through the existing facilities without further development, needing only to make changes to the arrangements for some queues, and it is suggested that the 5% increase in passenger numbers will not add to the congestion in the local road network, in part perhaps through the opening of the DART system, now believed to be opening some time during 2021.

The Planning Statement is atypically coy about any economic benefits of the proposed expansion; perhaps wisely, as it is known from Office of National Statistics data that UK travellers heading overseas spend more than do incoming passengers from abroad: before Covid the national balance of payments deficit in terms of tourism spending was £32 Billion.

Luton, with 60% of its travellers being UK residents rather than wealthy overseas folk hell-bent on Bicester Park or London’s West End, is likely to be doing exactly as described by New Economics Foundation when commenting on the proposal to expand Leeds/Bradford Airport – taking spending power and jobs out of the local economy through low-cost tourist flights: a point we have made at Luton’s Airport Consultative Committee but which seems to have escaped the minutes.

The application seeks “room to grow” to assure the airport’s existence and the continuation of its position in the local economic firmament, though that is not in doubt. What is in doubt is the rate at which demand for passenger leisure travel may recover.

The documents contain some optimistic estimates but in the present climate they appear not to be well-founded, and local communities have been the victims of previous optimistic estimates by airport operators and owners.

It is suggested that this application is at least a year premature and should be deferred until more certainty over passenger demand, and the replacement of the noisier aircraft types, is demonstrably under way.

It must be confirmed that any financial incentives from the airport owner are focused on accelerating the rate at which this is achieved, rather than attempts to accelerate the growth of passenger numbers. We suggest that this application is refused, for the reasons set out above



London Luton Airport submits plans for 19mppa

Luton Airport has submitted a planning application (21/00031/VARCON) to Luton Borough Council to increase the annual cap on passenger throughput by 5.5% from 18m to 19mppa and to expand the day and night noise contours by 11.3% and 15.3% respectively until 2028, when they would be reduced somewhat, but still a net growth from today’s levels. Annual plane movements are forecast to grow by no more than 0.8%.

The deadline for responses is February 18th.

The airport is arguing that their passenger forecasts support the application, that the growth of the number of larger planes means that these extra passengers can be accommodated without a huge increase in plane numbers, and that noise and greenhouse gas impacts will be sustainable because these new planes are cleaner and quieter.

Local communities have countered that the passenger forecasts are based on historic data and over-optimistic industry forecasts. They have also pointed out that the sustainability strategy relies on the prompt delivery of the larger, greener planes, which is not guaranteed. It’s planes not people that cause the noise, so an annual cap on plane movements makes much more sense.

The reason for the application, campaigners argue, is to relax the noise constraints and that the proposed increase in passengers is a red herring to please shareholders and make spurious claims about economic growth.

With larger noise contours, LLA will be under less pressure to secure the new planes, which will be in short supply for a while, and they can be more relaxed about scheduling, making the airport more attractive to airlines.

The elephant in the room remains the conflict of interest of Luton Borough Council being both the planning authority and the owner of the airport.