I recently (03.02.18) discovered that there is a request for a 24/7 freight hub at Manston Airport! Not only have I only just been made aware of this, which came from a social conversation (not from, as I now know is RiverOak (RSP)), but I also discover I have the ability to make comment, but BY THE 18th of February!! I live in St Nicholas at Wade, West of the runway, where the approach flight path for runway 10 passes directly overhead.
As there is now insufficient time for me to gain a detailed view from the 3,000+ pages that are online (now I have found them at attachment 1 ), I have skimmed through it to ensure I can forward my comments in time, so these may not be my full and complete views on the proposal.
I have recently engaged with my Parish Council and can confirm that there has been no pre-application consultation communication with them. I have also spoken to many residents from our near 1,000 strong village, and despite being the last village before the runway to the West in the flight path, this village has had no notification, information or contact regarding this consultation.
My understanding is that Government advice for pre-application consultation is that applicants should “include sufficient preliminary environmental information to enable consultees to develop an informed view of the project…”. Therefore, RSP is obliged to produce a Health Impact Assessment (HIA) that sets out what effect their freight hub is going to have on our health, wellbeing and life expectancy, which they have completely failed to do. At 1.1.91 of the PEIR, RSP says: “The health-related effects are not assessed here as the HIA analysis has not been finalised and its results are unavailable."
In RSP’s own “Pre-consultation document dated July 2016” (attachment 2 ), it states “
RiverOak takes its responsibility to assess, manage and mitigate any environmental impact from Manston Airport extremely seriously and has commissioned a comprehensive Environmental Impact Assessment to understand the effects of constructing and operating a redeveloped Manston Airport”.
How can I fully either support or oppose this, if RSP is not giving the information, not only that is required, but also that they committed to do, to help, me or anyone else assess whether or not there may be health implications from this project. If RSP intend to submit its Health Impact Assessment with its DCO application, how is this inclusive and how does this allow affected residents to make an informed judgement.
Surely this is a failure to comply with the requirements of the consultation process. As residents whose health and well-being would be affected, should this be approved! We are arguably one of the most important areas that should be consulted with and therefore renders this latest consultation flawed in this most fundamental aspect.
In Thanet District Councils (TDC) Draft Local Plan (A – Thanet Preferred Options and before the CPO was deemed not possible by TDC- attachment 3;partid=6053940&sessionid=&voteid=), in Section 16.36 of the Aircraft Noise and Noise Sensitive Development, it states that “There is currently a degree of uncertainty regarding future aircraft noise levels at the airport, therefore the Council will adopt a precautionary approach in relation to aircraft noise and will continue to apply the contour predictions which formed the basis for the previous Local Plan”. To rely on the previous noise report, suggests that at present, even TDC do not have confirmed or updated evidence of the potential noise levels that could be applied should ‘night time period’ flights be granted.
I feel that RSP is deliberately avoiding proper consultation, most particularly on the areas of their plans that would have the most damaging impact on the health and well-being of me and other residents.
How can any significant development that would have an effect on health and well-being (evidence already exists to verify that such an operation would), get approval when one of the most important parts of the consultation (which I wasn’t aware of anyway), does not even exist.

Until an application has been received and accepted for examination, the Planning Inspectorate (the Inspectorate) has no views on the merits or acceptability of any Proposed Development.
Preliminary Environmental Information (PEI) and adequacy of consultation
The Infrastructure Planning (Environmental Impact Assessment) Regulations 2017 (EIA Regulations 2017) refers to PEI as information that:
(a) Has been compiled by the applicant; and
(b) Is reasonably required for the consultation bodies to develop an informed view of the likely significant environmental effects of the development (and of any associated development).
If you are of the view that this information has not been provided, you should notify your local authority in relation to the adequacy of consultation. If an application is submitted, relevant local authorities will be invited to make an Adequacy of Consultation Representation (AoCR) to the Inspectorate. The Inspectorate, on behalf of the Secretary of State, must have regard to any AoCRs received when taking its decision about whether to accept an application for examination. For more information please read our Community Consultation FAQ: attachment 4
Health impact assessment
We note your comments regarding health impact assessment (HIA). There is no requirement under the EIA Regulations 2017 to prepare a stand-alone HIA. Schedule 4 Section 4 of the Regulations requires “4. A description of the factors specified in regulation 5(2) likely to be significantly affected by the development: population, human health….”. It is for the Applicant to decide how to provide this information, which may be in the form of a separate HIA or integrated into the Applicant’s Environmental Statement (eg as part of noise and vibration and air quality assessments amongst other topics). This information would need to be provided with any application for development consent made to the Inspectorate and would be considered at examination, if an application was accepted for examination.
Night flights
At present the Inspectorate has not received an application for a Development Consent Order for the Proposed Development at Manston Airport. In absence of an application, we are unable to comment on any proposed night flights requirements that the Applicant may apply for as part of an application for development consent. Any application including night flights must include an assessment of likely significant effects associated with night flights and that such an assessment should be based on appropriate parameters taking into account relevant uncertainty including any applicable worst case scenario. This advice has been duplicated in response to a several enquiries and is available to read in a number of locations under the ‘s51 advice’ tab on the project webpage eg: attachment 5