Hertfordshire County Council London Luton Airport Expansion 4 th December 2019
Scope of WSP Review − Preliminary Environmental Information Report − Surface Access Strategy − Draft Employment and Skills Strategy − Compensation Proposals − Outline Need Case 2 − Scheme Development Report − Airspace Modernisation Note
Preliminary Environmental Information Report − 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 3 in order for them to provide informed views − Final findings will be presented in the Environmental Statement (ES) to be submitted with the DCO application.
Noise 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; 4 • Emerging policy (Aviation 2050) proposed full insulation at 60 dB L Aeq,16h , 3dB lower than enhanced mitigation proposals.
Noise Airborne Noise: • Two stage impact criteria (> or < SOAEL) could lead to anomalous conclusions; 5 • 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 L Aeq,8h contour to 31.6km 2 by 2028, but 2039 DN contour is predicted to be 38.7km 2 . According to the condition, this is not permissible;
Noise Airborne Noise (cont.): • The actual 2017 48dB L Aeq,8h night-time noise contour for 63.3 daily movements is 38.7km 2 . The modelled 2039 DS 48dB L Aeq,8h night-time noise contour for 63 daily movements is 38.7km 2 . 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? 6 • 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.
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 7 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)
Traffic & transport − 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 8 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 − Public Transport Assumptions: − Insufficient information about the specification and level of bus/coach provision needed 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 9 to meet the targets − Forecasts could have a large impact on the outcomes of the traffic modelling exercise and the junctions identified for mitigation and the type of mitigation required
Traffic & transport 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 10 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
Air quality − 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 11 − 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.
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 12 zero by 2050 (due Sept 2020) in ES. − Social and political approach to carbon emissions is rapidly changing
Health & community − 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 13 − 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.
PEIR Summary & Recommendations 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 14 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.
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