Ad description

An ad in a current affairs magazine and a poster on the London Underground for Luton Rising, owners of London Luton Airport (LLA):

a. The magazine ad, seen in March 2024, featured an image of an aircraft marshaller signalling to an aircraft and text that stated, “If we miss our environmental limits, our expansion will be stopped in its tracks. If London Luton Airport breaks the environmental limits set out in its expansion proposal, it won’t mean an apology, it will mean further expansion is stopped. Our unique Green Controlled Growth framework will introduce limits for the airport’s noise, carbon, air quality and road traffic impacts. These would be legally binding, and independently monitored”. Text alongside the Luton Rising logo stated, “our airport, our community, our planet”.

b. The poster, seen in April 2024, featured the same image as ad (a) and text that stated, “If we miss our environmental limits, our expansion will be stopped in its tracks. Learn more about the expansion of London Luton Airport, with its unique Green Controlled Growth plan. This has legally enforceable, independently monitored environmental limits”. The same Luton Rising logo and accompanying text as ad (a) appeared at the top of the ad.


The complainants, who included Adfree Cities and the Group for Action on Leeds Bradford Airport (GALBA), challenged whether the ads were misleading because they omitted significant information about the environmental impact of the expansion.


London Luton Airport Ltd t/a Luton Rising said the purpose of the ads was to show people that mitigating environmental impacts were central to the airport’s expansion plans. A fundamental part of their plan was to grow London Luton Airport (LLA) sustainably, and not at the expense of the environment. If expansion was approved, Luton Rising would implement its Green Controlled Growth Framework which placed limits on noise, air quality, emissions from the airport’s operations and road traffic, that would halt expansion if breached or there was a risk they might be breached. That approach was summarised in the ads.

The phrase “our environmental limits” in the ads referred to the limits set out in the Green Controlled Growth Framework, which appeared in more detail in the second paragraph of ad (a). That information had not been included in ad (b) for legibility reasons, but the ad invited consumers to find out more information on Luton Rising’s digital channels. They highlighted that neither ad had made claims LLA was a “green airport” or the “greenest airport”, or that no environmental impacts would arise from the proposed expansion. The Green Controlled Growth Framework made clear which emissions it included – those carbon emissions generated by the airport’s operations and by staff and passengers travelling to and from the airport by road.



The CAP Code stated that the basis of environmental claims must be clear and that unqualified claims could mislead if they omitted significant information.

The ads were in support of the proposed expansion of LLA and featured the headline claim “If we miss our environmental limits, our expansion will be stopped in its tracks”. They made reference to a Green Controlled Growth Framework which contained legally enforceable and independently monitored environmental limits. Ad (a) explained that those limits included restrictions on the expanding airport’s noise, carbon, air quality and road traffic impacts. Ad (b) provided no further information about the limits.

The ASA considered people would understand the main aim of the LLA expansion was to facilitate an increase in capacity at the airport, which would include expansion in the volume of flights the airport could support. The purpose of the ads was therefore to reassure people about the efforts being taken to mitigate the environmental impacts caused by expansion. We considered people would understand from the ads that the proposed expansion was subject to environmental limits and that if they were breached the expansion would stop.

Ad (a) included information about the limits in the Green Controlled Growth Framework, which included limits on the expanding airport’s carbon impact. The ad also referred to the expanding airport’s “noise impacts”, which under the proposals included noise from air traffic movement (i.e., landing take-off cycle, and the climb, cruise and descent phase) resulting from the expansion. This would be likely to be understood, in the context of an airport, as meaning noise from both the airport’s ground operations, and from the air traffic movement. We considered the term “carbon impacts” would also be understood in that context, and that people who saw ad (a) would therefore interpret the reference to “carbon” as meaning carbon emissions from both the expanded airport’s ground operations and from the increase in air traffic movement.

Ad (b) did not provide further information about the limits included in the Green Controlled Growth Framework. We considered people who saw the ad would understand, from references to “environmental limits” that they would include emissions of carbon dioxide and other greenhouse gases (GHG). They were also likely to assume that limits relating to emissions from an airport would include those from air traffic movement, and would therefore interpret the phrase “environmental limits” in that context as meaning the limits included carbon emissions from both airport ground operations and emissions from air traffic movement. We considered the image of an aeroplane taxiing on a runway in both ads contributed to the impression that emissions from air traffic movement would be a key factor into the Green Controlled Growth Framework.

The proposed expansion was due to happen in two phases – in the first the current LLA terminal building would be expanded, and in the second an additional terminal would be built and later expanded. The project was due to take place over a number of years, with monitoring of the different limits on expansion conducted annually. The Green Controlled Growth Framework identified three principal sources of GHG emissions arising from the proposed expansion – airport operations, surface access and air traffic movements. However, although the Green Controlled Growth Framework included limits on noise from all three sources, only the first two were included in the environmental limits on expansion for carbon emissions, with air traffic movements excluded. We understood that in 2019 LLA’s total GHG emissions stood at 1,341,235 tonnes CO2e (carbon dioxide equivalent), of which 83.7% were from air traffic movements and around 1.3% were from airport operations. That meant the majority of LLA’s overall GHG emissions came from air traffic movements. We further understood that this figure did not include non-CO2 emissions such as soot particles, nitrogen oxide and water contrails from air traffic movements.

As noted above, people would understand the main source of emissions from LLA’s expanded operations would come from additional air traffic movements, and so they would likely expect environmental limits on carbon emissions to include those derived from that source. They would therefore not expect those emissions to have been omitted from the Green Controlled Growth Framework’s limits. Notwithstanding the reasons given in the Green Controlled Growth Framework for excluding air traffic emissions from the expansion’s environmental limits, we considered their exclusion was material information that was likely to affect people’s understanding of the ads’ overall message, and should have been made clear.

We concluded the ads omitted significant information and were therefore misleading.

The ads breached CAP Code (Edition 12) rules 3.1, 3.3 (Misleading advertising), and 11.1 (Environmental claims).


The ads must not appear again in the form complained of. We told London Luton Airport Ltd t/a Luton Rising to ensure future claims were adequately qualified and did not omit material information about the environmental impact of London Luton Airport’s expansion.


3.1     3.2     9.2    

CAP Code (Edition 12)

3.1     3.3     11.1     1.3     4.5    

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