Transport Page for the Harpenden Society

2023/24 Annual Report

Transport - Looking back

The proposals to expand Luton Airport took up considerable time in 2023. In October, the Secretaries of State for the Environment and Transport approved the airport operators application to grow the airport to 19 million passengers per annum (mppa) and Luton Rising’s Development Consent Order (“LR DCO”) examination took place between August 2023 and February 2024.

A decision on the latter should be forthcoming by August 2024. Whatever the decision on the latter is, short term, the airport will expand under one or other of the permissions, if demand (which remains constrained post-Covid) recovers. Longer term, the LR DCO examination (and other analyses) showed that there are considerable economic risks associated with the building of a second terminal (Phase 2 as it is called) and the expansion to 32 mppa.

In September, the Society held a public meeting on Transport in Harpenden, following the publication of a report we commissioned from the University of Hertfordshire. We will be following up on the report’s recommendations in 2024. One of the recommendations of the report, the setting up of a transport forum is under consideration and we hope that will provide a foundation for addressing the report’s other recommendations.

The proposal to improve Station Road (and Station Approach) which we reported on in last year’s annual report was canned due to a lack of funds.

The was no progress on Luton Airport’s flight paths, in fact it appears that we are going backwards following an announcement (November 2023) that the DfT and CAA are considering changing the whole process to a Single Design Entity (whatever that means). The prospect of flight paths changing before 2030 appears to be receding.

Looking forward

Free from the ongoing saga of Luton Airport’s growth, we will focus on transport issues in Harpenden, in particular congestion during peak periods and parking, not only its availability but also the cost. We will also keep abreast of the local walking and cycling strategy which the district council approved late last year (although there doesn’t appear to be any funding available presently to implement any of the proposals).

Karl Wingfield

Society's Response to SADC's new parking proposals

The Harpenden Society’s has submitted the following response to SADC’s parking proposals for central Harpenden.

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Fundamentally, the Society believe that the current proposals are not fit for purpose.

Local retailers argue that the imposition of the proposed charges “will be damaging to the local economy and will directly and adversely affect the residents and their decision to shop locally” where trading conditions are already challenging as a result of changes in consumer behaviour and the cost of living crisis. We fully recognise this is a significant risk.

Furthermore, the provision of 20 minutes free parking meets no one’s needs as the enforcement will prove to be extremely difficult. The consequence is that residents will ignore the time limits, much as they do now.

The result is likely to be more chaos and potential damage to the Town Council’s strategic objective of supporting a vibrant High Street, an objective we fully support.

Nevertheless, we do accept that there are legitimate issues to be addressed, both in terms of the need for SADC to secure additional income to fund its budget deficit, a real need for standardisation of parking time limits and charges, and the dire need for a substantial improvement to central Harpenden’s chronic traffic and parking problems.

As regards SADC’s income requirements, we believe there needs to be more transparency. From our analysis, the parking proposals (which include changes other than the imposition of on-street parking charges) appear, at face value, to raise far more than that needed to cover the costs of the district’s parking services.

If this is the case, there is a legal obligation firstly to apply any such surpluses to improving such services, before funds are available to meet the Council’s budget deficit.

HTC’s own view is that no permanent changes should be made until a thorough review of parking has been undertaken. We support this but also recognise that SADC may well have to press ahead with some parking charge changes to meet their budget deficit for 2024/25.

If SADC do press ahead, we believe that for a limited time only (to end March 2025 - by which time a proper review of parking in Harpenden should have been undertaken), the following changes should be considered:-

One hour’s free parking in all town centre parking bays should be allowed (both the retailers and HTC have said this should be the minimum allowance).
One further hour in the above bays should be available at a cost of £2.50, thereby extracting a premium over the equivalent car park charge for 2 hours. This should encourage the use of car parks for such longer stays, with an added benefit of delivering a greater turnover of on-street parking.
Parking permits, for which a modest annual charge can be made, should be offered to all residents, not just senior citizens, allowing a maximum of up to 3 hours free parking in the car parks, as is the case in many other parts of the country.
Finally, SADC should start to invest in technology and additional Community Enforcement Officers across the town centre streets and car parks and be seen to be visibly adopting a ‘zero tolerance’ approach to illegal parking – particularly parking on double yellow lines and on pavements.

Our hope is that, even at this stage, SADC recognise that parking is a complex matter with a host of issues yet to be resolved, and will defer any permanent changes until a full review has taken place.

As members of HTC’s transport forum, the Society is more than happy to be involved with both SADC and HTC in this review.

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The Society also encourages all members to make their own views on the new parking proposals known to SADC.

You can email your response to parking.development@stalbans.gov.uk

The consultation document can be found online at https://consultation.appyway.com/

The closing date for responses is Aug 14 2024

Jeff Phillips

Chairman, The Harpenden Society

3rd August 2024

Society's response to:

Harpenden Railway Station

East Car Park Development Proposals

Planning Ref: - 5/2024/0796

By Solum

Whilst the applicants, Solum, may be correct in stating that the site and development proposals do not fall within the Statutory Guidelines that would require an Environmental Impact Assessment to be undertaken, there is no doubt that the scheme will be the largest to be undertaken within the town centre for a considerable period, and will have significant widespread implications.

For this reason, The Harpenden Society considers the proposals must be subject to the widest scrutiny to ensure all aspects are fully understood and that appropriate steps are taken to minimise adverse environmental consequences.

As Solum state this scheme would take approximately FOUR years to complete and during that period current users of the car park will have to find alternative parking which will invariably add pressure on the adjacent residential streets. Yet no comment or proposals have been made by Solum as to how this aspect will be addressed.

The Public Health Services Dept at HCC have stated that even if SADC decide an EIA is not required, the Council should still ensure the application is supported by sufficient biodiversity, landscaping and other environmental information in order to assess the impact of the proposals.

The development proposals represent significant changes to the built environment which may have unintended negative impacts.

As the only access to the station is via the town centre, we challenge the claim by Solum that effects of the construction traffic over the 4-year period will not be significant.

We could not find any reference in the reports submitted by Solum to the trees that will need to be remove near the entrance.

Even Solum acknowledge that there is potential for adverse effects, relating to noise, transport and air quality, but these would apparently be mitigated through strategic strategies and the overall effect would not be significant.

There are currently a number of planning applications for large residential development schemes under consideration in and around the town, some of which may be approved during the car park development period, all of which will add considerable pressures on the town centre and the need for commuter car parking. Solum may have deduced from their earlier limited study that the demand on station car parking has reduced since Covid lock-down but this needs to be re-evaluated following recent reports that office occupation has started to increased and that the car park is already at or near capacity during the week.

It cannot be overlooked that the proposals by Solum for the redevelopment of the car park will have widespread and potentially adverse significant effect on the local environment and we consider they must be required to submit with any future planning application, a detailed Environmental Impact Assessment.

The Harpenden Society

Luton Airport Expansion Inquiry

Picture above by Dean Bernardin

As members who are participating in the Luton Airport Expansion Inquiry will know, the 22nd August was the deadline for the submission of Interested Parties detailed concerns about Luton Rising’s airport expansion proposals.

The Society’s submission covered the following areas: climate change, noise, the need for the development and the funding position.

Climate Change

On climate change the Society proposed that, if the development is given the go ahead, it can only begin on the basis of the terms proposed by the Committee on Climate Change (in their report to Parliament 28 June 2023), i.e. “No airport expansions should proceed until a UK-wide capacity management framework is in place to annually assess and, if required, control sector greenhouse gas emissions and non-CO2 effects. A framework should be operational by the end of 2024. After a framework is developed, there should be no net airport expansion unless the carbon-intensity of aviation is outperforming the Government's emissions reduction pathway and can accommodate the additional demand.” The recent headlines re: the impact of climate change on ordinary lives serves to remind us that we have to redouble our efforts to tackle increasing global temperatures. Stopping aviation expansion, which otherwise would increase its emissions up to 2050, is a sensible and measured step.

Noise

On noise, the Society demonstrated that Luton Rising’s expansion plans will not see any reduction in the noise that communities suffer presently over the course of the development and beyond as Luton Rising’s proposed noise limits will remain at a higher level than the long term noise limits agreed when the airport’s application to grow to 18 million passengers per annum was approved. We believe the Inspectors should require Luton Rising to achieve, at a minimum, the long term noise limits previously agreed and also pass an equal share of engine technology benefits to affected communities.

Funding

Finally, the Society emphasised that the development is highly speculative, with few economic benefits to offset the clear environmental harms and there is no evidence to suggest that either Luton Rising or Luton Borough Council can fund the development or that a third party investor is willing to underwrite the development, except, possibly, on terms that will undermine the social benefits that Luton Rising is claiming the development will provide to Luton.

The detailed examination will now begin with a number of Issue Specific Hearings taking place in September, after which the Examining Authority will issue a series of questions to Luton Rising and other parties. At this stage we will get a clearer idea of the key concerns of the Examiners. The Society will continue to reinforce its position throughout the Inquiry, at every opportunity.

Background

London Luton Airport (LLA) is situated 7 miles north of Harpenden town centre on the southern edge of Luton. It has grown rapidly in recent years: passenger numbers were 6.2 million in 2000, 8.7 million in 2010 and 18.0 million in 2019. Whilst the airport is easily accessible to Harpenden residents, its growth in recent years has resulted in a significant increase in the downsides associated with airports, namely aircraft noise, air pollution, clogged up local transport networks and, of primary importance presently, climate wrecking CO2 emissions.

Furthermore, because Luton Borough Council (LBC) is conflicted, it both owns the airport (and therefore has a financial interest in its success) and is the planning authority for the airport, the explosive growth in the last decade has resulted in planning conditions that were put in place to safeguard local communities being breached and no enforcement action taken. For example, the LBC planning permission for growth to 18million passengers was conditional upon staging expansion over a period to 2028 which allowed for quieter and lower emission aircraft to be introduced. However, LLA took no notice, and the 18million limit was achieved in 2019.

The Society's Strategy

Strategically, the Society is fully supportive of the Hertfordshire County Council (HCC) 'Sustainable Hertfordshire Strategy 2020' which includes 'clean air for all by 2030' yet would be impossible to achieve should LLA expansion plans be realised. Against this background, the Society, working with Bim Afolami MP, local campaigning groups and government agencies, principally the county and district councils, engages with the airport operating company London Luton Airport Operations Lit (LLAOL) and LBC to try to enforce planning conditions and ensure its future plans don't damage our community. Even to delay the process is positive for Harpenden as it allows for the introduction of quieter, lower emissions aircraft.

Local campaigning groups include:

Harpenden Sky

http://harpendensky.com/

LADACAN (Luton and District Association for the Control of Aircraft Noise) https://ladacan.org/

Current situation

Presently, there is one live planning application before LBC and four consultations at various stages of completion.

Open planning applications

Application to vary condition 10 of planning permission 15/00950/VARCON

This planning application is intended to regularise breaches of planning conditions established when the airport was granted permission to grow to 18 million passengers by 2028. The planning conditions were put in place to ensure that those places most exposed to increasing aircraft noise as the airport grew would benefit from strict limits on the number of aircraft that could fly and from increasing use of more modern quieter aircraft. These planning conditions have been systematically breached by the airport for the last three years (and no enforcement action has been taken). The planning application seeks to set aside these conditions at least until 2024. Currently, this application is awaiting a decision by LBC. The Society and all other local community groups, Hertfordshire County Council and St Albans District Council have strongly objected to this planning application. It has not been considered by LBC yet and is now expected to be rolled into the planning application below to increase passenger numbers to 19 million per annum.

Open consultations

October 2020 Changes to London Luton Airport Arrivals

This consultation outlines a proposal to separate the Luton and Stansted airport arrival flightpaths. Presently, Luton and Stansted airport arrivals share the same arrivals routes and the same holds. Whilst the proposed separated arrivals flightpaths go over central Bedfordshire, this consultation is relevant to Harpenden residents as includes dispersed or concentrated flightpath options. A concentrated flightpath is similar to the flightpath that was implemented between Harpenden and St Albans in 2016 which has resulted in all westerly departures heading towards eastern Europe following a narrow flight path, which means those within 2km of the flight path hear every aircraft, rather than intermittent aircraft noise as was previously the case with dispersed flightpaths.

Further information about this consultation can be found here: https://consultations.airspacechange.co.uk/london-luton-airport/ad6_luton_arrivals/

An helpful analysis of the consultation can be found on the LADACAN website here: https://ladacan.org/consultation-on-arrivals-flight-paths/

The closing date for the consultation is 5 February 2021.

The Society will be responding to the consultation in due course.

October 2020 ICCAN's emerging view on the future of aviation noise management

ICCAN was created in January 2019, as an impartial, non-statutory body to rebuild trust between airports and their communities.

ICCAN has produced a document which can be accessed here:

https://iccan.gov.uk/future-aviation-noise-management/

which outlines ICCAN's emerging view on the future of aviation noise management, as well as their vision and goals over the next three years.

ICCAN is seeking your feedback on this document via a survey that can be accessed through the link above. The closing date for this consultation is 18 December2020.

The Society will be responding to this consultation in due course.

Recently closed consultations

February 2019 Luton Borough Council as owner of London Luton Airport Limited (LLAL) 'FutureLuToN'

This consultation outlines the airport owners plans to grow annual passenger numbers from 18 million to 32 million. The original consultation has closed and LLAL [an LBC owned company] has advised that it is considering the feedback and plans to submit a Development Consent Order to the government in 2021. The Society and all other local community groups, Hertfordshire County Council and St Albans District Council have strongly objected to this proposal, given the detrimental effect such growth will have on our climate and local communities.

The December 2020 Supreme Court decision to allow Heathrow Airport to apply for planning permission for a third runway has consequences for LLA insofar as Ministers have been advised by their Climate Change Committee colleagues that in order to keep emissions within latest Government policy commitments including Net-Zero, then Heathrow should only expand if regional airports contract.

There is also the conundrum that the Heathrow third runway planning application will now dictate the pace, so we need to ensure LLA is unable to advance their development consent application to the Planning Inspectorate until the Heathrow third runway status is decided. This position is several years away and not aided by Heathrow having disbanded their third runway team and a simultaneous plan by the Civil Aviation Authority (CAA) to modernise flight paths across the south of England (FASI-S). This delay again will allow for 100s of quieter, lower emissions aircraft to be introduced.

November 2020 London Luton Airport Operations Limited as operator of the airport pre-consultation on increasing passenger numbers to 19 million

This consultation (which has also closed) outlines the LLA plans to ask LBC l to increase the number of passengers travelling through the airport annually to 19 million in the short-term. In addition, the airport operator is seeking to have the planning conditions referred to above set aside and new weaker noise conditions introduced which would mean noise levels wouldn't reduce until 2027, at the earliest.

As above, the Society and all other local community groups, Hertfordshire County Council and St Albans District Council have strongly objected to this proposal, not least because there's no evidence that passenger numbers will even return to their pre-Covid-19 level (18 million) for the foreseeable future and because of the proposal to weaken the existing noise conditions. This LLA application would, if successful, lead to another c8,000 flights per annum intruding into Harpenden airspace.

Further information

If you require further information about the airport please email transport@harpendensociety.org