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1. Noise Pollution: We reject the planning application due to the massive negative impact on all areas of human health and sleep in this area, added to the fact that there has been historic negligence in maintaining noise levels. Flights will go throughout the day and night with only respite between 5.30am – 6.30am. This is a huge negative impact for the community in all aspects of our wellbeing.

   • The proposal has hidden the true impact of night and early morning flights in the documentation, which demonstrates that the public is right not to believe in the ‘good faith’ which Luton Rising claims to be showing to the local communities.Luton Airport's measurements fail to account for the actual noise levels and frequency of pollution when planes fly overhead, resulting in almost constant noise exceeding 70dB for 22 hours a day. The claim in the report that we will be within the 45dB contour is based on inaccurate data, as it includes days when planes approach from different angles and no noise is reported. We strongly disagree with this analysis.

   • When planes flew over us in 2019, the official recorded noise levels ranged from 69dB to 75.5dB for each plane. This means that on over 40% of days in a year, we would experience noise levels averaging 71.5dB every few minutes for 22 hours a day, for at least 130 days annually. This invasion of our privacy, home life, and civil liberties cannot be mitigated by noise insulation in our homes, and discussions with Luton Rising suggest limited access to such insulation in this area due to their interpretation of noise levels. The detrimental impact on our sleep, hearing, mental health, and cardiac health is scientifically proven. World Health Organisation said in 2009 “sleeping satisfies a basic need and the absence of undisturbed sleep can have serious effects on human health”. The WHO’s 2018 Environmental Noise Guidelines indicate that noise can cause many Critical negative health outcomes. 

   • Are the assumptions for how noise contours will affect us correct? Have the plans taken account of the impact that climate change will have on the changing thermals and wind directions? Recent weather patterns this year have been unusual and so in these villages we have had more aircraft overhead than usual at this time of year. Have the planners taken this into account?

   • When people ring in to complain about airport noise, it is rare that they get acknowledgment of this. Are the complaints accurately monitored. In addition, talking to local people, there is an apathy in reporting due to the lack of engagement by the airport authorities. We question whether the true level of interference to our lives is acknowledged by the airport. 

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2. Air Pollution (NO2 etc): We reject the planning due to the real impact that increased pollution levels from aircraft and traffic will have on heart disease, lung disease, cancers, stroke, mental health and respiratory conditions. ( NO2, Ozone, microparticles, kerosene particulates, etc). 

   • We do not believe that the planning has taken this into adequate consideration, particularly the serious health burden of increasing levels of pollutants. If there are 60% more flights, there is a 60% increase in these pollutants and with increased traffic numbers (at least 60%), there is an additive effect. Thus, this will seriously impact the health of those living near the airport.  The health impacts of increased levels of these pollutants is well documented in Prestigious journals such as the BMJ, high and increased concentration of these pollutants have a direct negative impact on respiratory diseases, such as asthma and lung cancers. In addition there has been recorded cell damage at the DNA level, as well as an increase in heart disease and stroke. 

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3. Air Pollution (Greenhouse gases): We reject the planning application due to the significant negative impact it will have on the climate emergency and greenhouse gas levels. The proposed expansion would result in a dramatic increase in emissions, including ozone, with associated health impacts. This expansion is unnecessary, and emissions will rise by at least 60% in all areas, contradicting the country's zero-carbon goals. Furthermore, there is no foreseeable significant improvement in airport/airline technology over the next 20 years, indicating a continuous rise in pollution as a direct result of this expansion.

   • ​​It is also apparent that the economic demand appraisal for the project is hopelessly optimistic. Although there has been recovery in aviation demand post-covid, the industry has been hit by a doubling in the cost of aviation fuel in the year running up to October 2021 (Financial Times 21/10/2010), and is now exacerbated by political instability in eastern Europe, a key market for the airport. Furthermore, a recent report by the New Economics Foundation estimates that, as a result of adjustment of the government’s carbon values in September 2021, the cost of cleaning up emissions from departing aircraft have doubled. In the case of Luton Airport, this cost has risen from £2,615m to £5,231m pa, even before expansion is considered. Effectively none of the eight UK airports currently seeking expansion will now be able to meet 2050 net zero emission targets (New Civil Engineer 28/1/2022).

4. Road Traffic The massive increase in road traffic and probable expansion of the road systems has not been taken into account by the Luton rising (Luton Borough Council) as well and so the figures are a considerable underestimation of all forms of pollution – noise, air and climate. 

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5. Impact on Nature: We reject the application due to the potential negative impact on nature and wildlife. The proposed expansion would significantly disturb the delicate balance of nature in the Area of Outstanding Natural Beauty and the conservation areas of the Chiltern villages. The area is home to rare birds of prey, various owl species, rare butterflies, wild orchids, ponds, the source of the river Ver, as well as Whipsnade Zoo, Whipsnade Tree Cathedral, and protected trees outside St Mary's Church in Kensworth

   • These natural elements will be stressed and disrupted by the noise, pollutants, and airflows caused by the expanded airport operations. 

   • The suggested 2km zone of influence is inadequate considering the nature of an airport and the low-flying planes over residential and environmentally sensitive areas. Moreover, the increased traffic will impact areas beyond the 2km radius from the airport. 

   • This doesn't even go into the details regarding the destruction of Wigmore Park, and all that it gives to the local community and natural world. This will be gone. Looking at the environmental assessments, they did not appear to be anywhere near as comprehensive as we assumed they should be, and this is telling but the amount of changes and additions they have recently made. However, there is a real necessity for the inspectorate to get a full independent assessment of all the environmental assumptions, as just from a lay person's view, surely the area should have been monitored over a full year, not just tiny snapshots, when much would have been missed.

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6. Is there still a Justifiable demand for the increase in flights to this level. Is the data the airport are relying for this proposal now outdated?

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7. Agreements between LBC and Luton Airport unclear. The proposed expansion plans for Luton Rising should address the agreement with the Airport consortium and the impact of contract renewals, recently rescheduled, to 2032 from 2031. It is important to establish a clear link between potential renewals and LBC (Local Borough Council) and Luton Rising before the community can make an informed decision. The existing expansion permission, which still has 7 years remaining, has not fulfilled its promises regarding noise reduction. Both LBC and the airport have violated Section 106 of the Noise Control Agreement and have failed to rectify the situation for three years. These oversight, regulatory, and management failures are insufficient grounds to justify further expansion.

   • In the latest annual report by Luton Rising (uploaded 10 June), it is apparent that Luton Rising has agreed certain passenger number growth with the airport operators and is financially liable if the agreed numbers are not be met. What are these numbers? In addition, £45m of local authority money  was paid to the airport operators as 'special force majeure' payments, yet in an emergency budget the council had to make cost savings of £21m. Why is the Council shoring up the airport operators at the expense of the local community? In addition the airport operators paid themselves £5m and £10m in dividends in 2020 and 2021, while pleading poverty and getting payments from the Council!

   • How important is airport expansion to the continued agreement between Luton Borough Council and the airport operators, and has LBC made assurances to LLAOL, that are not in the public domain, which would be materially significant? 

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8. Financial obscurity: We object to the application due to the lack of financial transparency and uncertainty regarding the returns on investment for LBC and Luton Rising. The absence of fully audited accounts from LBC since YE 2017/18 raises concerns about the value for money of this expansion. The substantial costs associated with the name change and presentation of the expansion (>£16m) raise further questions about its justification and feasibility. Luton Borough Council has provided loans exceeding £500m to Luton Rising and its previous form, yet the lack of audited accounts since 2017/18 leaves taxpayers uncertain of how this money has truly been utilised and what the returns have been.​ In addition looking at their statement of accounts, it appears that no auditors have been paid for the past 2 years.

   • In contrast, while substantial funds have been allocated to Luton Rising for the airport, relatively small amounts have been invested in poverty alleviation, education improvement, and broader economic development in Luton. This raises questions about whether the council's pursuit of aggressive expansion has left behind the very people who ultimately fund it.

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9. No apparent significant positive impact on local jobs: We object to the planning application as there are only estimated to be an increase in 0.6% of local population employed by the airport. The documentation has used actual numbers to try to make it look better, but percentages of the population show the impact is limited. There are spurious arguments listed regarding bringing jobs to the area, and the country would be better served by moving air traffic away from the over congested skies around London and the South East. There appears to be little real contribution the economy, much less the Luton economy with jobs from Luton residents to the airport only estimated by the application to increase by 1,100 from 3,100 to 4,400, hardly a bonanza. This is only 0.5% of the estimated future Luton population! 

   • Unpicking some of these descriptions by Luton Rising in their documentation shows the obscurity the planners are using: see 2 examples below:

   • ‘As a result of the Proposed Development, the total operational employment supported by the airport in the Three Counties in 2043 is forecast to grow to 22,600 jobs, an increase of 6,100 jobs over 2019.’    This means that only 6100 new jobs would be created over 20 years or 305 jobs per year, and a maximum of 0.6% of the local population (or less on a per annum basis). 

   • Documentation claims ‘It is also 8,600 more jobs than would be supported by the Without Development Case in 2043.  claims ‘It is also 8,600 more jobs than would be supported by the Without Development Case in 2043.  – so there is likely to be a lowering of airport staff by only 2500 over 20 years (125 per year).

   • Surely encouraging new and better industries into the area be a far better way of increasing job opportunities to the local population?

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10. Incomplete transport strategy means the planning case can't be looked at in the round: We object to the planning application due to the absence of a comprehensive transport strategy, which is currently labelled as 'emerging.' This lack of clarity prevents our community from fully evaluating the future impact of airport expansion, rendering the application incomplete and potentially invalid. We reject the application as there is no adequate transport planning in place to accommodate the anticipated influx of 32 million (+14m from current levels) passengers at the airport, nor is there concrete research of this on the potential impact on the surrounding population. Without a proper transport strategy, it is impossible to make an accurate assessment of the proposal.

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11. Over-reliance on one company has risks: Government has also told LBC to reduce its dependence on the airport, this has history, the overreliance on the car industry had a devastating impact on Luton and Dunstable in past. 

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12.  We reject this proposal as the Planning was not adequately advertised in our local villages, and thus there was not adequate consultation to the population of three local villages Kensworth, Studham and Whipsnade, all of which are in the direct and low flight path of Luton Airport. Indeed, although many of us responded to planning whenever it arises, usually very few are emailed when new planning issues arise (such as this) - I was notified by a friend rather than Luton Rising, which is concerning.

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13. The initial form we had to fill in for the previous round of planning online, was problematic and not easy to manage for people and to some extents obstructive. This was admitted by the CEO of Luton Rising when I questioned him about it one to one at the ‘Question Time’ in Luton.  In addition, once the form was filled in and uploaded, we did not get an email confirming the application had been received, so those who filled in the form have no record that it was done or that it would be looked at.  

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14. Inadequate publicity for this latest DCO application: We did not hear about this further DCO opening for discussion and registering as an interested person from Luton Rising or Luton Airport, but only by word of mouth. It has not been advertised adequately, and still there are many people who do not know about this next stage of consultation. 

15.  We reject the application as there appears no Real need for expansion – the Draft Need was one sided and did not present a properly balance or evidenced case. The strategies do not adequately reflect the post-Brexit, post-Covid economy. In addition, the impacts of the Climate Change Act do not appear to have been taken into account, and there is no comprehensive planning Statement. 

16. The argument for Economic Value does not stack up: The airport always seems to state that the reason for further expansion is for ‘jobs and economic value’, this argument was made in 2013, yet there will not be a significant boost in job numbers. The main reason behind this seemed to be more to do with securing a huge upfront cash windfall, which was used for the airport rather than helping alleviate the deprivation within LBC. There is one runway, so surely only one terminal is needed?

17. The fact that Luton is a priority for levelling up, is not relevant to the airport expansion. Luton Airport has expanded exponentially over the recent past, but Luton per se does not seem to have benefitted much, and remains a deprived area. The £600m+ that has been given to the airport by LBC over the past few years, could arguably have been used in a more beneficial way for the community, and had it done so, Luton may not be highlighted as being deprived. The financial obscurity around LBC and Luton rising is also worrying as no formal accounts have been signed off for the past 4-5 years, which rings alarm bells.  

18. Excessive and incomprehensible documentation: We acknowledge that the current documentation for the Luton Airport expansion plan has grown to over 15,000 pages, with 1,538 pages dedicated to feedback on the 2019 consultation. The sheer length of this extensive documentation raises doubts about its validity and suitability for its intended purpose. It becomes challenging to comprehend and analyse such a vast volume of information, leading to concerns about its accessibility and effectiveness.

    • This marks the third consultation on the Luton Airport expansion within four years. By presenting the documentation in such an extensive manner, it seems that Luton Rising has made it difficult for everyone (particularly for the general public) due to lack the time and resources available to thoroughly review its contents. Despite my efforts, I have found no evidence within the documentation that disproves our concerns or adequately addresses them. This further strengthens our serious objection to the proposed airport expansion.​

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For the points listed above and many others, we strongly object to the further expansion of Luton Airport, and believe that to expand would blight the lives of people who live and work in the area both in terms of their human rights, health and mental well-being.