10 October 2012

Project LLA Consultation
LLAOL
Navigation House
Airport Way
Luton
Beds
LU2 9LY / Our Ref:
Your Ref:
Contact Officer:
Direct Line:
Email: / PN 19.1.3
Project LLA Consultation
Lorraine O’Gorman
01462 474425
Lorraine.O’

Dear Sir/Madam,

Project LLA Consultation

Please accept this letter as formal response to the above pre-application consultation.

North Herts District Council welcomes the opportunity to comment on the pre-application consultation for the Project London Luton Airport which sets out plans to increase capacity of the airport to 18 million passengers per annum by 2031.

North Herts also welcomes the opportunity to comment on a single application in relation to the proposed airport increase in passenger numbers. Whilst there undoubtedly remains some confusion from local residents on the previous pre-application process from the owner and operator respectively, this improved relationship and single application provides an improved level of confidence in the process going forward. It should be noted however that much of this response remains as was for the previous pre-application consultations as concerns with regard to the Economy, Transport and Noise remaining as per the original pre-applications consultations.

In commenting on the Project LLA Consultation, this Council remains at all times concerned primarily with the impact which any proposal will have on the people and environment of North Hertfordshire. Safeguarding and promoting the quality of life of people in North Hertfordshire is the main concern of this Council.

As such, North Hertfordshire District Council has serious concerns about the pre-application details, particularly the actual and potential impacts on people in North Hertfordshire. It is expected these concerns will be fully addressed for the full planning application as to allow a thorough, informed response.

Economy

Whilst North Herts District Council welcomes a vibrant local airport, improved economic

prospects for Luton and the wider benefits this brings to our District, it is noted from the Surface Access Strategy that the number of people who work at Luton Airport who come from North Hertfordshire remains comparatively small compared to other areas such as Luton and Central Beds.

Whilst more jobs for North Hertfordshire residents are generally to be welcomed, it appears unlikely that a significant proportion of the new jobs created would in fact go to North Herts residents therefore having a limited impact on the local economy. In any instance North Herts would wish to see additional evidence accompanying the planning application on how these employment levels have been derived.

Transport

It is understood that a full assessment of the traffic and transport implications of the proposals will be undertaken. North Herts welcomes this and the opportunity to comment in greater detail on this assessment when the full planning application is submitted. It is essential that the impact of airport growth is both acknowledged to have an impact outside of the Borough of Luton and that this impact is mitigated for in some way. Acceptable modelling detailing this impact and proposed mitigation should form part of the Transport Assessment submitted and prior consultation on this with both the County Council and District is expected.

North Herts is currently planning its own local housing and employment growth and investigating the ability of our local network to accommodate such growth. The impact of increased traffic through North Herts from any airport development will have a significant impact on our network. Of key concern is the A505 through Hitchin where at peak times a number of junctions are already operating near to capacity. In addition the A1(M), managed by the Highways Agency, already suffers congestion and is a key major route that airport passengers may use to access the airport through North Herts.

Whilst significant additional investment in transport infrastructure to alleviate current congestion is detailed in the consultation, this investment is focussed around the Luton network and includes schemes that form part of the Luton Local Transport Plan which are scheduled to proceed independently of airport growth.

Previous comments provided on the Airport Surface Access Strategy highlighted that approximately 13% of passengers currently originate in Hertfordshire: however it is likely that a greater number of passengers travel through the district to access the airport from the east via the A505 through Hitchin and, and from the southeast via Codicote and Kimpton. This could include passengers from Greater London, Cambs and Essex as well as other County’s in the East of England.

The Surface Access Strategy takes no account of any growth proposals, even natural growth, and it is not detailed to any degree in the Traffic and Transport element of the consultation. This further highlights our concerns about its isolation as detailed in our consultation response on the draft. The Surface Access Strategy should be a key tool to mitigate the traffic and transport impacts of the airport and North Herts remains keen to have to have an input into its development and implementation.

In addition it is likely that a proportion of any traffic involved in additional infrastructure woks would pass through North Herts, Given work currently underway on the Hitchin Flyover, high levels of construction traffic are already being experienced and we would request to be involved with forward planning on construction traffic routes and times of operation.

Noise

The consultation details the noise contours as reducing in the future, even with the proposed increase in the number of aircraft taking off and landing. North Herts provided comments on the Noise Management Plan (published January 2012) in January 2010. At that time concerns were expressed with regard to the plan fully meeting the requirements of the legislation. As with the Surface Access Strategy, it is felt that comments provided were not taken onboard and noise disturbance to residents who live in the vicinity of the airport or live underneath/close to the flight path will increase significantly with proposed increase number of movements.

NHDC is aware that the County Council has consistently called for stringent limits on night flights to be introduced that reflect those imposed by Government at the three major south east airports, from which Luton is exempt. The dated planning consent with noise restrictions is considered to fall below expectations one would expect for a modern, progressive and responsible airport. NHDC will expect any planning application to come forward with positive proposals for improvements and mitigation.

Noise remains perhaps the most contentious to residents of North Hertfordshire, in particular night noise. Comments provided on the Environment Impact Assessment scoping report details our concerns about both the lack of acknowledgement of night noise even as a problem as well as the lack of details as to how this will be mitigated with increased numbers.

In conclusion North Herts remains concerned about the impact of any airport development which results in an increase in passenger numbers. The Project LLA Consultation proposals are not sufficiently developed for North Herts to provide detailed comments and there is a lack of co-ordination with existing strategies and policies such as the Surface Access Strategy and Noise Mitigation Plan. We trust our comments will be given due consideration and welcome the opportunity to comment on the full planning application.

An electronic copy of this letter has been submitted to you via email.

Yours sincerely,

Lorraine O’Gorman

Transport Policy Officer