The Parish of Edlesborough (which also includes the villages of Dagnall and Northall), is currently only over flown during westerly operations by the northerly departure route from Luton.  According to the day ave/hr statistics contained in the Consultation Document, the northerly departure route accounts for about 9% of all Luton Noise Preferential Route (NPR) departures, with the easterly and south easterly routes handling approximately 38% and the south westerly route the remaining 53%.  Luton Airport’s 2006 Annual Monitoring Report (AMR) however, indicates that the northerly departure route is used by about 23% of Luton NPR departures, with the easterly/south easterly routes taking 35% and the south westerly route taking about 42%.  However, because aircraft using the northerly departure route are dispersed off the designated route during normal daytime operations once they reach 3000ft, only about a quarter of planes using the route actually pass over the Parish.  Using the AMR figures, this means that during westerly operations the Parish is directly over flown by about 6% of departing Luton aircraft at approximately 5000ft.

With the new proposed departure routes, the Parish would continue to be over flown by that 6%, but would also be directly over flown by all the aircraft using the new easterly and south easterly routes, making a total of 41% of Luton NPR departures.  In other words a seven fold increase.  That figure assumes that, aircraft using the new easterly and south easterly routes, will not be dispersed once they reach 3000ft, but will continue to follow a narrow swathe as shown on the consultation maps until they have reached the Stevenage area at the earliest.  It should be noted that this increase would have been even more dramatic if it had been calculated using the Consultation Document data rather than the AMR data.

Assuming the very conservative Luton Airport growth figure of 5.9% per annum from 2007 until 2014 quoted in Appendix D of the Consultation Document, the Parish will experience an eleven fold increase (1100%) in air traffic by 2014 instead of the 58% increase that would otherwise have been expected.

The Council fully understand the difficulties faced by NATS in endeavouring to balance the conflicting objectives of increasing the capacity of the existing controlled air space, reducing fuel burn and emissions, avoiding over flying population centres, not compromising the tranquillity of the countryside and yet continuing to have safety as the overriding priority.  However, as far as the two routes in question are concerned, the Council consider that NATS have failed to demonstrate that these fundamental changes are environmentally justified.  Furthermore, the Council contends that the proposed changes conflict with the Department for Transport guidance to the CAA (Appendix F Reference 2 of the Consultation Document).

It is presumed that the principal reason for the proposed changes is to relieve the congested traffic in the Brookmans Park area by diverting Luton departures to the north of Luton instead of the south as at present, rather than any safety or environmental objectives.  Although no specific population figures are identified for these two routes alone, it is assumed that NATS will claim that due to the shorter proposed NPR, the number of people under the new NPR would be less.  It must, however, be appreciated that the population beneath the existing routes have been subject to aircraft disturbance for many years and will of course continue to be subject to disturbance even if these two routes are moved.  The proposed new routes however, would over fly areas where the population is not accustomed to a great deal of aircraft noise disturbance.  As such the proposal fails to comply with para 46 of the DfT guidelines that "the DAP should pursue policies that will help to preserve the tranquillity of the countryside where this does not increase significantly the environmental burdens on the congested areas."

Paragraph 35 of the DfT guidelines stresses "the importance of the long term stability of the route structure in the vicinity of airports, since people need to know where significant aircraft noise will be experienced."  Subjecting people to an immediate seven fold step change increase in noise disturbance by completely altering the departure routes as proposed, clearly conflicts with that guideline.

Although the proposal claims to have endeavoured to avoid population centres when developing the proposed routes, it should be appreciated that the Parish of Edlesborough and the adjoining village of Eaton Bray constitute a community with a not inconsiderable joint population in excess of 5,000 and yet little or no effort appears to have been made to avoid it.

Finally, despite failing to demonstrate any significant environmental benefits other than a slightly shorter NPR, the two proposed new routes would be respectively 18 and 23 nautical miles longer than the existing routes which would inevitably result in significantly more fuel burn and emissions. Two elements that NATS should be seeking to reduce.

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