SI2 Land south of Stevenage Road

The allocation of SI2, which has long featured in earlier allocation/SHLAA documents, is welcomed. For the avoidance of any doubt, this site remains suitable, available and deliverable within the Plan period.

Mindful of the Regulation 18 consultation statement comments and in response to the subsequent policy bullet points, all three are acceptable as being appropriate and reasonable. Apart from scrub, the majority of the existing trees are along the boundaries of the site and both these and the right of way (to the east of the site) can be incorporated readily within any layout.

I write on behalf of our client London Luton Airport Operations Limited (LLAOL)
with regard to the current consultation on the draft proposed submission Local
Plan for North Hertfordshire district.
As highlighted within previous representations on the emerging Local Plan
(preferred options consultation paper) consultation in December 2014, London
Luton Airport (LLA) has a sphere of influence, which extends beyond its
immediate vicinity into surrounding districts, including North Hertfordshire.
The current consultation relates to the Draft Proposed Submission Local Plan,
and LLAOL considers it appropriate to refer to the test of soundness as outlined
within paragraph 182 of the National Planning Policy Framework (NPPF) as
follows:
"A local planning authority should submit a plan for examination which it
considers is "sound" - namely that it is:
* Positively prepared - the plan should be prepared based on a strategy
which seeks to meet objectively assessed development and
infrastructure requirements, including unmet requirements from
neighbouring authorities where it is reasonable to do so and consistent
with achieving sustainable development;
* Justified - the plan should be the most appropriate strategy, when
considered against the reasonable alternatives, based on proportionate
evidence;
* Effective - the plan should be deliverable over its period and based on
effective joint working on cross-boundary strategic priorities; and
* Consistent with national policy - the plan should enable the delivery of
sustainable development in accordance with the policies in the
Framework."
Should the Local Plan fail to acknowledge (to a suitable level), the presence of
LLA and its strategic importance, and not incorporate appropriate policies in
order to protect its on going and future operations, there is a risk that the plan
can be found unsound at examination.
LLA plays a pivotal role in the economy of the local area and surrounding subregions.
Along with the M1 and local railway connections, the airport provides accessibility for people and businesses alike. The accessibility that it facilitates helps to improve business performance and create jobs across all sectors.
In November 2015 Oxford Economics produced a report on "The economic
impact of London Luton Airport". The report found that in 2013 LLA sustained
16,000 local jobs contributing an economic value of £732 million to the local
economy (including direct annual business and expenditure, indirect supply
chain effects and the wages and salaries of workers). In the same year the
economic activity created by LLA contributed some £1.3 billion to UK GDP and
is estimated to have sustained 27,000 jobs.
It also stated that current growth proposals estimate that passenger numbers
will increase from 9.7 million in 2013 to 18 million in 2030, this will in turn
contribute £2.3 billion in UK GDP and is estimated to sustain 37,700 jobs.
Locally it is predicted that airport expansion will sustain 6,600 additional jobs by
2030.
The Aviation Policy Framework, March 2013, sets out the Government's
objectives for aviation. Paragraphs 1.1 - 1.3 states:
1.1 "The UK has always been an outward-looking nation - an island
economy that for centuries has owed its prosperity to the transport and
trade routes linking it with the rest of the world. With the increasing
globalisation of our economy and society, the future of the UK will
undoubtedly continue to be shaped by the effectiveness of its international transport networks.
1.2 We believe that aviation infrastructure plays an important role in contributing to economic growth through the connectivity it helps deliver.
For example, it provides better access to markets, enhances communications and business interactions, facilitates trade and investment and improves business efficiency through timesavings, reduced costs and improved reliability for business travellers and air freight operations.
1.3 There is broad agreement that aviation benefits the UK economy, both at
a national and a regional level. While views differ on the exact value of
this benefit, depending on the assumptions and definitions used,
responses to both the scoping document and the consultation
demonstrated that the economic benefits are significant, particularly
those benefits resulting from the connectivity provided by aviation. In
addition we believe there to be social and cultural benefits from aviation."
LLAOL fully supports this clear statement of the importance of aviation to the UK
economy and in general is happy that LLA's importance has been recognised to
an extent within the current draft of the Local Plan. However, LLAOL has
concerns regarding the strength of policies relating to protecting the interests of
LLA, by ensuring the development strategy for future developments do not
prejudice the airport's ongoing and future operations.
Having reviewed the draft submission Local Plan the following sections of this
representation highlight where it is felt the strategic importance of LLA should be
given further recognition.
Policy SP19: Sites EL1, EL2 & EL3 - East of Luton
As expressed in our previous representation LLAOL has no objection in principal
to the housing sites allocated within policy SP19. However, due to the proximity
of the sites to LLA (within 1,000m of the airport's boundary) there are a number
of points which should be addressed; specifically relating to noise and highway
impact.
Noise
The operation of LLA obviously has some implications with respect to noise.
With regard to housing proposals in close proximity to the airport, LLAOL wishes
to highlight paragraph 123 of the NPPF, of which bullet point 3 states:
"recognise that development will often create some noise and existing
businesses wanting to develop in continuance of their business should not
have unreasonable restrictions put on them because of changes in nearby
land uses since they were established".
LLAOL supports the inclusion of section j of policy SP19, which requires the
proposed housing sites to incorporate:
"j. Appropriate noise mitigation measures, to potentially include insulation
and appropriate orientation of living spaces;"
However whilst the inclusion of such a policy requirement is welcomed, LLAOL
does not believe that the current form of wording is strong enough to protect the
amenity of future residents or the interests of LLA in terms of noise. To that effect
we suggest the policy wording be amended to read:
"j. Sites EL1, EL2 and EL3 are within close proximity to London Luton
Airport, and therefore any schemes will need to demonstrate that
any noise issues have been appropriately addressed and internal
noise levels within any new homes are within relevant guidelines.
Appropriate noise mitigation measures should include insulation
and appropriate orientation of living spaces"
Highway impact
Given the close proximity to LLA, the potential impacts of the proposed
development sites (EL1, EL2 and EL3) on the surrounding highway network are
a key concern to LLAOL. Within the supporting evidence of the Local Plan
preferred options consultation paper, it was outlined that Transport Assessments
would be required for all three sites within policy SP19 in order to assess the
impacts of the developments upon Luton and the M1 motorway.
Within our previous representation LLAOL requested that these Transport
Assessments also consider the transport impacts of the proposed housing sites
on the accessibility and operation of LLA. As outlined, the airport currently has
planning permission to expand capacity to 18mppa. LLAOL's masterplan covers
the period to 2028, so this expansion would be delivered within North
Hertfordshire District Council's proposed Local Plan period. Any Transport
Assessment for the allocated sites will therefore need to consider this permitted
increase in operational capacity. We suggest the following wording is added to
policy SP19:
"As part of any development proposal a Transport Assessment must be
undertaken in order to assess the impacts of the development upon
Luton, the M1 motorway and London Luton Airport."
With regard to the above comments relating to noise and highway impacts,
LLAOL would also like to formally request to be involved in the master planning
process, in order to ensure that airport-related matters are appropriately
addressed during the design stage. This would help ensure that final master
plans are appropriate and consider all issues, and reduce the potential of any
future objections to the development proposals on airport-related grounds. We
therefore request that the following wording be incorporated within the policy
supporting text:
"During master plan development London Luton Airport Operations
Limited should be consulted in order to ensure that airport-related
matters are appropriately addressed."
Should such policies/paragraphs fail to be incorporated into the Local Plan, there
is the potential that the plan could be found un-sound during examination.
KW1: Land west of The Heath, Breachwood Green
Due to the location of the proposed Breachwood Green housing site (KW1)
noise is a key consideration for developments in the area. LLAOL therefore fully
supports the inclusion on paragraph 13.180 of:
"Breachwood Green is located on the approach and departure flightpaths
from Luton airport and any schemes will need to demonstrate that noise
issues have been appropriately addressed and that internal noise levels within
any new homes are within relevant guideline levels."
SI1: Land South of Waterdell Lane & SI2 Land South of Stevenage Road
Although these sites are located some way from LLA, they do lie under the
departure flight path and therefore have the potential to be impacted by noise
from airport activity. LLAOL therefore requests that a paragraph is included
within the supporting text that acknowledges the location of those sites under
the flight path and that development proposals take account of noise-related
issues. We suggest such a paragraph be worded as follows:
"St Ippolyts is located under the departure flight path from London
Luton Airport and any schemes will need to demonstrate that noise
issues have been appropriately addressed and that internal noise levels
within any new homes are within relevant guideline levels."
Conclusion
In general LLAOL supports the proposals within the North Hertfordshire Draft
Submission Local Plan 2011-2031.
Specifically, LLAOL wishes to support the plan's acknowledgement of the
airport's presence. However as stated LLAOL considers it to be of maxiumum
importance for the plan to recognise LLA's strategic significance, specifically its
existing and future contribution to the national and regional economy. It is vital
that this significance is properly reflected within local planning policy and that
future proposals for new development within the area do not constrain the
operation of LLA, either now or in the future.
LLAOL therefore respectfully requests that the considerations provided within
this consultation response be reflected within any further modifications of the
North Hertfordshire Local Plan.
We trust that these comments will be fully considered in the continued
progression of the Local Plan. Please do not hesitate to contact us should you
have any queries in relation to the content of this letter.