Hertfordshire County Council

London Luton Airport Expansion

4th December 2019

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− Preliminary Environmental Information Report

− Surface Access Strategy

− Draft Employment and Skills Strategy

− Compensation Proposals

− Outline Need Case

− Scheme Development Report

− Airspace Modernisation Note

Scope of WSP Review

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− No statutory guidance on how detailed it needs to be or how complete the information provided should be.

− It is a snapshot in time only.

− Enable consultees to understand likely environmental effects of the proposed development in order for them to provide informed views

− Final findings will be presented in the Environmental Statement (ES) to be submitted with the DCOapplication.

Preliminary Environmental Information Report

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Baseline Conditions:

• Modelled noise 2017; measured noise 2018/19;

• Modelled noise summer period; measured noise autumn/winter;

• Baseline year reflects movements that breach current Planning Condition 10.

Mitigation Enhancement:

• Proposed revisions (see Compensation Proposal) cover daytime only;

• Current eligibility determined by night-time noise levels;

• Emerging policy (Aviation 2050) proposed full insulation at 60 dB LAeq,16h, 3dB lower than enhanced mitigation proposals.

Noise

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Airborne Noise:

• Two stage impact criteria (> or < SOAEL) could lead to anomalous conclusions;

• PEIR noise contours are approximate only and overstate impacts. Full validation using Luton departure profiles is essential;

• There is no clear analysis of highest noise level year. There are conflicting statements that this may occur in 2029/30 or maybe not until 2039, the full capacity year. If the latter, we would question whether the rate uptake of low noise aircraft ensures technology benefits are shared with the community.

• The assessment of future airborne noise ignores the constraints imposed by the current planning condition 10. This limits the night-time 48dB LAeq,8h contour to 31.6km2 by 2028, but 2039 DN contour is predicted to be 38.7km2. According to the condition, this is not permissible;

Noise

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Noise

Airborne Noise (cont.):

• The actual 2017 48dB LAeq,8h night-time noise contour for 63.3 daily movements is

38.7km2. The modelled 2039 DS 48dB LAeq,8h night-time noise contour for 63 daily

movements is 38.7km2 . Is this due to PEIR model overestimating the noise impact or will

aircraft not be quieter in future?

• Changes in noise levels are not expected to be

consistent at all locations in the community, with

higher DS vs. DN increases at Slip End. Why is this?

• 1,800 people are project to experience a moderate effect in the daytime and 2,500 in

the night time. Details on where this will occur are not given, or whether it is the same

people affected during the day as at night.

Other Noise Sources:

• Construction noise assessed for daytime only;

• Ground noise analysis results not presented;

• Surface access noise assessed for daytime only.

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Traffic & transport

- Based on initial modelling results

- Forecast modelling work is ongoing

- Increased traffic flows concentrated on the A1081 and south-east Luton and M1 Jn 10 and M1 northbound and southbound

- Current transport modelling identifies 3 junctions in Hitchin for minor carriageway widening / realignment coming forward during the latter stages (beyond 25mppa –post 2030)

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− Further modelling work and tests are ongoing

− Traffic Modelling Assumptions:

− Passenger mode share assumptions are based on 45% by Public Transport (14.4mppa will use PT to access the airport in 2039 / in 2016 this figure was around 4.8mppa)

− Employee Mode share assumptions are based on 54% by Public Transport, Cycling & Walking

− Traffic modelling assumptions for committed development and highway schemes and programme for implementation (eg, no account for emerging A505 study findings, underestimate of development compared to HCC COMET model, longer term schemes in Hertfordshire not yet in the planning system are currently excluded)

− Recommendation:

− Sensitivity tests on traffic impacts are identified using reduced public transport mode shares to present ‘worst case’ rather than ‘best case’ traffic conditions

− LAs review the uncertainty log to ensure the ‘included’ schemes for the modelling work reflect the currently expected timescales to ensure a robust forecast traffic model for the proposed expansion

Traffic & transport

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− Public Transport Assumptions:

− Insufficient information about the specification and level of bus/coach provisionneeded to meet the targets that have been set

− Insufficient information about the rail passenger demand and capacity forecasts by time of day to be able to review the robustness of the rail targets

− Recommendation:

− Review further information on the public transport forecasting assumptions to understand the proposed network and specification of additional coach/bus services to meet the targets

− Forecasts could have a large impact on the outcomes of the traffic modellingexercise and the junctions identified for mitigation and the type of mitigation required

Traffic & transport

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General Comments:

− Current transport modelling identifies 3 junctions in Hitchin for minor carriageway widening / realignment coming forward during the latter stages (beyond 25mppa – post 2030) – based on the assumptions in the current modelling – further sensitivity testing is expected

− Employee, visitor and goods access is not as well covered as passenger travel in the consultation documents

− Privately operated car parks outside the red-line boundary are not addressed. How these could be managed as part of the proposed expansion would provide completeness and reassurance in the mode share forecasts and management

− Local Authorities should look to identify other current congestion locations where they expect further mitigation may be required

− Further engagement with LLAL is expected on the modelling and mitigation

Traffic & transport

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− Further justification of use of national projections of emissions and rural background concentrations.

− A mitigation plan should be progressed to secure commitments to specific targets for reducing emissions to air

− Further justification should be provided to ensure the assessment is based on precautionary assumptions and takes account of uncertainty - particularly in relation to the assumed improvements in vehicle technology and air quality over time.

Climate change− Further detail to be provided regarding responsibility for mitigation

measures.

− Helpful to create a separate section on monitoring to make it clear what monitoring is recommended.

− Recommended that the assessment could be split down further by ‘asset class’ for ES.

Air quality

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Greenhouse gases

- Recommended that additional mitigation measures are identified (perhaps carbon neutrality commitments, and additional low carbon flight incentivisation).

- Return legs of flights should be re-examined in the context of a ‘realistic worse case’ assessment as part of ES.

Future Carbon Considerations

− Consideration of more stringent carbon budgets to meet net zero by 2050 (due Sept 2020) in ES.

− Social and political approach to carbon emissions is rapidly changing

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− Reference to several key policies and other guidance has been omitted. E.g. HCC Position Statement: Health Impact Assessment (HIA)

− Previous stakeholder comments, including those made at the Technical Workshop do not appear to be addressed.

− Assessment does not refer to a separate HIA, it would be expected that due to the scale and nature of development that a full HIA would be provided to accompany the DCO application.

Landscape / Replacement Park − Further information needs to be provided covering the European Landscape

Convention, Chilterns AONB Management Plan and Position Statement

− Assessment phases for both construction / operation and how these link to the development phases is unclear.

− The implementation of mitigation works based on the phases of the proposed development.

Health & community

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Need to acknowledge that PEIR is point in time and should assume that many aspects will be updated in the ES

Key Recommendations

− Greater clarity is required on the future baseline scenarios as these remain unclear.

− Clearer explanation regarding the phasing of the development

− Further detail should be provided as to how the mitigation measures would be secured.

− Helpful to create a separate section in ES on monitoring to make it clear what monitoring is to be carried out during construction and operational phases.

− LLAL to ensure closer engagement and dialogue with host authorities to address issues/clarify concerns.

PEIR Summary & Recommendations

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Draft Strategy

− Currently lacking in detail and content

− Any employment and training targets included in the final strategy should be discussed and agreed with the relevant authorities and key stakeholders.

− The strategy needs to ensure that opportunities are made available for everyone (in terms of geographical spread, hard to reach and vulnerable groups).

Economic PEIR Chapter

− Unclear where the data presented in the baseline information has been obtained.

− Unclear how the jobs and GDP for the three future baseline years have been calculated.

− The method of securing and implementing mitigation measures and with whom the responsibility for their delivery should be made clear.

Outline Employment & Training Strategy

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Hardship Scheme for properties in 66dB contour

− LLAL to confirm whether this covers only residential, or also commercial and agricultural – not clear.

Noise Insulation Scheme

− To align with emerging government policy, there is a case for the threshold for full noise insulation to be reduced from 63 dB LAeq,16h to 60 dB LAeq,16h.

− May then have implications for the lower noise bands for which a maximum financial contribution to insulation is proposed.

− Subject to addressing the night-time issue, the measures strike a fair balance.

Community Fund - FIRST

− Fund should be welcomed but - LLAL to undertake further engagement with the eligible local authorities to develop clear terms of reference providing details on eligibility criteria, governance processes, reporting and monitoring in relation to funding of future projects to ensure fit fir purpose.

Draft Compensation Proposals

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− Airspace change promoted by LLAOL – only have concession until 2031. Need to ensure relatively ‘short term’ interests fully align the goal to optimise long term benefits for the community arising from airspace changes.

− All airports in the South East will have to adhere to the CAA Masterplan for FASI-S, which is as yet unpublished but is expected to favour Heathrow in terms of airspace priority.

− While the suggestions are that noise impacts should be lower as a result of FASI-S, even if not optimised, it might be worth determining whether there is any means by which LLAL to commit to a betterment at this stage.

− One aspect of the airspace change that may be implemented during the DCOprocess is AD6 arrivals. Although it accepted that the DCO analysis shall be based on current flight paths, it might be feasible for the ES to include an analysis of the noise effects arising from adoption of revised AD6 arrivals paths, possibly as a sensitivity analysis at this stage.

Airspace Modernisation Note

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− Need case states that there is a gap in demand projections which the expansion project can help to meet. However, this will need to be reviewed in light of:

− Government’s response to Climate Change Committee.

− Publication of final UK Aviation Strategy (expected in Spring 2020)

− Any updated DfT forecasts published to support the UK Aviation Strategy

− Any further modelling work will also need to ensure it is based on the latest projections of the other London and UK airport master plans (e.g. latest Gatwick and London City projections are missing and if consented, would add additional c20mppa more than captured in need case – this would have implications for the catchment area Luton has identified.

− Given the uncertainty surrounding Brexit, it is recommended that further sensitivity analysis be included in any modelling

Outline Need Case/Scheme Development Report

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The documents provide a reasonable degree of detail regarding the proposed scheme

Greater clarity/further evidence is required in regard to:

− the various assumptions made throughout several documents

− how the project will be phased and how this links to the EIA assessment years

− Where certain mitigation measures are to be embedded as part of the project design

− how the mitigation measures will be secured within the DCO

− The robustness of the need case in light of Gov response to CCC and other competing airports bringing forward development

LLAL to ensure closer engagement and dialogue with host authorities to address the issues/clarify concerns.

Where required evidence and documentation is still outstanding, LLALshould set out a framework for document preparation and a clear programme for achieving completion of evidence.

Overall Conclusions

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Any Questions?