Please refer to the objections document that can be downloaded here: Link

  1. Aviation emits 2.8% of global man-made GHGs.[1] Carbon dioxide emitted by airlines increased by 32% from 2013 to 2018. The UK (population: 66 million) has the world’s third largest CO2 emission from aviation after China (population: 1,393 million) and the US (population: 328 million). [2]  
  2. Plans to expand air travel will increase aviation CO2 emissions until non-hydrocarbon power is commercially available.  This could be decades away. On 16 November 2020, over 20 associations collectively representing the entire European aviation ecosystem announced a joint commitment to work with policy makers to achieve net zero CO2 emissions by 2050.[3]
  3. The UK tested its first green (i.e. renewably produced) hydrogen powered aircraft, a six-seater Piper M class, at Cranfield airport on 24 September 2020. Clearly the industry is years away from scaling this up to replace the current global fleet of airliners, while the infrastructure to fuel ships with non-hydrocarbons is currently in its infancy.  European coalition Airbus has recently launched three futuristic concept designs for zero-emission aircraft with hydrogen as the primary power source, claiming (NB Not guaranteeing) that they could operate commercial flights by 2035 – with support from governments.
  4. Any airport expansion plan based on current technology will add GHG emissions. This could be illegal under current UK law and under the UK’s Paris Agreement commitments to cap and cut CO2 emissions.
  5. The Luton airport proposal, along with the other proposed regional airport expansions, represents a free-for-all, uncoordinated approach, in clear breach of the UK Government’s Aviation 2050 Strategy which enshrines “developing a partnership for sustainable growth which meets rising passenger demand, balanced with action to reduce environmental and community impacts.”[4]
  6. As the influential thinktank Transport and Environment’s Dr Lucy Gilliam put it recently, “It’s clear that for the time being there are few options to fly in a climate friendly way so airport capacity must at a bare minimum be capped until technological solutions are viable and on the market.” [5]
  7. The World Health Organisation Regional Office for Europe (WHO Europe) published environmental noise guidelines in October 2018. Following a comprehensive review of the scientific evidence linking noise to health impacts, WHO Europe made source-specific recommendations for noise from aviation, road traffic, rail, wind turbines and leisure (such as personal electronic devices). For aircraft noise, the relevant guidelines are as follows: For noise exposure averaged across the day, evening, and night (Lden), the guidelines strongly recommend reducing noise levels to below 45 dB Lden, as aircraft noise above this level is associated with adverse health effects. For night noise exposure, the guidelines strongly recommend reducing noise levels to below 40 dB Lnight, as aircraft noise above this level is associated with adverse effects on sleep. To reduce health effects, the guidelines recommend “that policy-makers implement suitable measures to reduce noise exposure from aircraft in the population exposed to levels above the guideline values for average and night noise exposure.”[6]
  8. Luton airport is in breach of noise limits already. The night noise contour planning condition has been breached since 2017, the airport operator LLAOL is trying to have the existing planning condition set aside, and Luton Borough Council has failed to take any enforcement action. In its response to the application by the Airport to have the legally-agreed planning condition set aside so that it could continue to profit at the expense of local residents, Hertfordshire County Council said in July 2019: “the Airport has betrayed the other partners, particularly those communities currently suffering from the adverse consequences of the breaches of planning control. The County Council is of the view that the actions of the Airport have fallen considerably short of Government expectations.”[7]
  9. C.A.L.F. contends that the Luton airport expansion plan has not taken WHO Europe’s guidance into consideration.  Instead residents are told to expect a ‘significant’ impact from noise.  The CAAs own guideline videos on youtube show that aircraft similar to the A220 and B737 airliners commonly used by the likes of easyJet and Ryanair at Luton would both be noisier than WHO Europe’s guidelines when overflying communities on the descent path. 
  10. Currently Luton and Stansted share two stacks, LOREL and ABBOT. The London Stansted Noise Factsheet states, “The minimum height of aircraft in the stack is 7,000 feet so the noise from aircraft in the stack should not cause a nuisance on the ground. However, sometimes people are still disturbed. This tends to be more often when a stack is over the countryside, where there is very little background noise and so the aircraft are more noticeable.”  C.A.L.F. contend that the Luton proposal overflies a number of small rural communities where the noise will be “more noticeable” – indeed in breach of WHO guidelines. Figure 4 – Stansted / Luton Airport Shared Stacks[8]
  11. The CAA has published requirements and guidance on assessing noise impact for the purpose of proposing a change to the design of airspace. The Luton airport proposal does not clearly follow these.[9]
  12. Local Air Quality Reports from Luton Borough Council show that Luton has a higher percentage of adult deaths (5.8%) related to long term exposure to air pollution than the rest of England (5.1%).  According to the Borough Council report, the main source of air pollution in Luton is road traffic which will increase substantially if Luton Airport is allowed to expand. Road traffic along the A1 in our area already reduces air quality in Sandy and Biggleswade as well as Potton.  As these towns are well with the Luton airport catchment area, we can expect more traffic and lower air quality as a result, leading to health problems and potentially more deaths due to air pollution. Similar issues can be expected along other trunk roads across the Luton Airport catchment area. An increase from 18 to 32 million passengers a year will add millions of car journeys in our area.
  13. The proposed expansion could be illegal under UK environmental law. It probably breaks WHO Europe guidance on noise and its consequent increase in road traffic potentially will breach air quality legislation around the airport and throughout its catchment area.

[1] Global Carbon Project. (2019). Supplemental data of Global Carbon Budget 2019 (Version 1.0) [Data set]. Global Carbon Project. https://doi.org/10.18160/gcp-2019

[2] Graver B, Zhang K, Rutherford D, “CO2 Emissions from Commercial Aviation, 2018” ICCT Working Paper 2019-16

[3] https://canso.org/eu-aviation-maps-a-sustainable-post-crisis-future-in-round-table-report/

[4] https://www.gov.uk/government/consultations/aviation-2050-the-future-of-uk-aviation

[5] Dr L Gilliam in correspondence to Shipping Strategy Ltd, October 2020.

[6] https://www.euro.who.int/en/publications/abstracts/environmental-noise-guidelines-for-the-european-region-2018

[7] Quoted by LADACAN, https://ladacan.org/luton-airport-in-breach-of-noise-limits/

[8] Aircraft Holding Stacks: London Stansted Noise Factsheet

[9] https://publicapps.caa.co.uk/modalapplication.aspx?appid=11&mode=detail&id=8128, https://publicapps.caa.co.uk/modalapplication.aspx?appid=11&mode=detail&id=8127

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