Manston Airport

Enquiry received via email

Manston Airport

05 January 2018
Michael Child

Enquiry

I have just revisited this application to check for any progress. Please excuse this email being a bit muddled and fragmentary but I am short of time at the moment and fitting writing it in between customers at work. I would respectfully remind you that while you get paid for responding to it I don’t get paid for writing it. As I am directly affected by having long delayed and unclear plans for a potentially significant national infrastructure project hanging over the town I live and trade in I am obliged to respond to it.
As far as I can see the majority of people living here have been subjected to ongoing cries of wolf mixed with confused objectives so that there is very little public awareness of the situation.
I think if asked most local people would like to save the local airport with a view to being able to fly locally to holiday destination and having historic air displays, which is roughly what has happened in the past.
The actuality of the result of any DCO would appear to be a highly polluting freight facility with very little likelihood of either leisure flights or airshows.
The actual DCO remit as stated on the pins website is. “The upgrade and reopening of Manston Airport primarily as a cargo airport, with some passenger services, with a capacity of at least 12,000 air cargo movements per year.” Without any more precise commitment at this level then I assume that would be applicant’s obligation. This has however been presented from inception as “saving Manston Airport” which is something very different, holidays in the sun, a boost to the local economy and additional leisure events.
My main concern from inception has been addressing pollution issues with respect to the amount freight movements that would be necessary to comply with DCO legislation.
At the moment there seems to be conflicting information as to whether it would be only necessary to build an airfreight hub at Manston with the capacity for 10,000 movements per annum, or whether it would be necessary to increase the airfreight capacity of Manston by 10,000 freight movements per annum to qualify for a DCO.
Further to this there seems to be some confusion as to whether the existing airfreight capacity of Manston would be taken as the capacity prior to its recent closure or whether some other figure is taken as the existing capacity.
Could you kindly clarify this?
My main concern from inception has been addressing air pollution issues with respect to the amount freight movements that would be necessary to comply with DCO legislation.
As per your recommendations attachment 1;ipcadvice=c2ba63ed60 “we would advise you to liaise directly with the Applicant, as the application for the proposed development is still in the process of being developed, and as such your views still have the opportunity to shape the application.”
I have copied my emails to the aplicant to you so I assume you will know that liaising seems to have presented difficulties for the applicant and so far they haven’t made any meaningful response to me and to honest I have now given up trying.
As the scientific journals relating to particulate air pollution enter the public domain I had been passing the information on, but without any connected response it is difficult to tell if the applicant was taking this information onboard.
The main November publications being related to abnormal sperm attachment 2 and pulmonary function of children attachment 3
In December another aspect that I hadn’t considered came up which is the affect of behaviour in adolescents, see attachment 4
Once again I should stress that it is the combination of burning at least 10,000 tones of jet fuel p.a. in a relatively small area, with a densely populated area immediately along the prevailing air flow direction and the onshore breezes action of reducing the air flow at the perimeter of the densely populated area, that looks particularly concerning.
With Ramsgate the other significant issue would be aircraft noise exacerbated by the difficulties associated with sound insulation in the conservation area with many listed buildings including several schools.
Do you know if there has been any progress in addressing this problem?
I am assuming that there would have to be a property compensation scheme in place prior to acceptance of the DCO, as dealing with the noise compensation property blight issue in Ramsgate is likely to be one of the more costly aspects of the project. Obviously as the applicant has to prove to pins that they have adequate legitimately sourced funding to qualify for a DCO then I assume the approximate costs have to be known to do this, can you confirm this is the case?
As a result of revisiting this issue I note that there will be further consultation events attachment 5 “Following the recent announcement that RiverOak Strategic Partners will be offering the public an opportunity to comment on its now fully-developed proposals for Manston Airport, prior to submitting the Development Consent Order application, RSP can now confirm the dates and venues for consultation events will be as follows:
23 January: Comfort Inn, Ramsgate 14:00-20:00
24 January: The Kings Hall, Herne Bay 14:00-20:00
Further details about the consultation period and how to respond will be provided in due course.”
In the first instance, I can’t find any notification relating to this consultation elsewhere, nothing on the pins website attachment 6 nothing posted up in the Ramsgate information centre, I registered my interest at both the previous consultations and haven’t had any notification from rsp. I run a retail business in Ramsgate and have asked some of my customers if the are aware of this consultation. I haven’t been able to find anyone who is aware of it.
I have been unable to find the “fully-developed proposals for Manston Airport” mentioned, do you know if the can be found online?
I also can’t fine any statement of community consultation relating to these events, either on the rsp website or the TDC one, as I now have accessibility issues, the time I have before the events to make arrangements to overcome them is important to me. Can you please tell me the last date the statement of community consultation has to appear before the consultation event?
In view of the large number of people, particularly under the unavoidable flight path in Ramsgate and the issue of having both to revisit extensive documentation and presumably read further new documentation I would think time is running out.
Can you please confirm that this is actually a third consultation and that there will be some point in interested parties like me attending it? To expand on this, will comments be collated in some way and count towards the decision to accept the DCO?
Personally I have developed tinnitus since this project started and I foresee that I would have considerable accessibility issues if the Ramsgate session is reasonably well attended. To expand on this, a lot of people in a confined space all talking at once would be very difficult if not impossible for me to attend.
The underlying issue here is that from a common sense point of view a freight hub at Manston progressively appears increasingly unlikely to be viable. The figures just don’t appear to add up, the site already has an experienced and enthusiastic ownership with plans to exploit its brownfield status, which would suggest site acquisition compensation around that of brownfield land value for southeast England making the site worth around £1bn.
Any compensation package for Ramsgate along the lines of the one proposed for London airport expansion would be very costly, unless of course it is envisaged that the freight hub would go ahead without reasonable compensation.
Conversely the applicant appears to have no other airfreight hubs in fact no airports whatsoever, no tangible existing business where one could see evidence of substantial and available funds, that would in some way be logically directed into a substantial freight business.
At the moment the only impact the DCO application appears to be having is a variable amount of localised economic blight dependent on the publicity related to the DCO and so perhaps this could be used for investment purposes.
So I think my main question relates to how I should proceed with this one, I have a limited amount of resources to put into responding to something that looks like an ongoing series of cry wolf in the hope that either there will eventually be no opposition, or the objective is not an aviation one.
Do pins consider that this application can remain open in perpetuity?
Have pins considered ways in which DCO application could be used to adjust an economic background for investment purposes?
As an interested party is there some way I can be notified about further consultations, or indeed anything I should read or respond to relating to this DCO?

Advice given

At the moment there seems to be conflicting information as to whether it would be only necessary to build an airfreight hub at Manston with the capacity for 10,000 movements per annum, or whether it would be necessary to increase the airfreight capacity of Manston by 10,000 freight movements per annum to qualify for a DCO. Further to this there seems to be some confusion as to whether the existing airfreight capacity of Manston would be taken as the capacity prior to its recent closure or whether some other figure is taken as the existing capacity. Could you kindly clarify this?
A teleconference between the Planning Inspectorate and RiverOak Strategic Partners was held on 22 November 2017, a note of which has been published: attachment 1;ipcadvice=05e3f8e2c6
In the teleconference the Applicant confirmed that the consultation documents informing its January 2018 consultation would set out the Applicant’s position on the baseline assumed in terms of flight numbers for the purposes of the capability test set out in the Planning Act 2008 (the PA2008).
The Planning Inspectorate, on behalf of the Secretary of State, cannot take a view on the Applicant’s approach in this regard until such time as an application is formally submitted and s55 of the PA2008 is engaged.
With Ramsgate the other significant issue would be aircraft noise exacerbated by the difficulties associated with sound insulation in the conservation area with many listed buildings including several schools. Do you know if there has been any progress in addressing this problem?
The Planning Inspectorate is unsighted on the detail of any updates in respect of the Applicant’s Environment Impact Assessment. The Applicant’s original Preliminary Environment Information Report is the only extant information about the likely significant effects of the Proposed Development in the public domain. The Applicant did confirm in the aforementioned 22 November 2017 teleconference that its draft Development Consent Order would include provisions to secure a Noise Mitigation Plan and Noise Quota Count; but any special provisions in respect of heritage assets have not at this stage been specified.
I am assuming that there would have to be a property compensation scheme in place prior to acceptance of the DCO, as dealing with the noise compensation property blight issue in Ramsgate is likely to be one of the more costly aspects of the project. Obviously as the applicant has to prove to pins that they have adequate legitimately sourced funding to qualify for a DCO then I assume the approximate costs have to be known to do this, can you confirm this is the case?
In respect of claims for compensation, the provisions under the PA2008 are set out in s44 and s55.
In its Environmental Statement, the Applicant will be required to provide a description of the expected significant adverse effects of the Proposed Development and include measures to prevent or mitigate them. Those measures must in turn be secured in the Development Consent Order. If a compensation package forms part of an applicant’s mitigation strategy then logically the associated cost would need to be factored-in to an applicant’s demonstration that adequate funding is likely to be available.
In respect of funding, paragraph 18 of the DCLG’s guidance related to procedures for the Compulsory Acquisition of land states that applicants should be able to demonstrate that adequate funding is likely to be available to enable the Compulsory Acquisition within the statutory period following the order being made, and that the resource implications of a possible acquisition resulting from a blight notice have been taken account of.
I have been unable to find the “fully-developed proposals for Manston Airport” mentioned, do you know if the can be found online?
In the 22 November 2017 teleconference, the Applicant stated that its consultation materials would include an updated full Preliminary Environmental Information Report (PEIR). The Planning Inspectorate would expect for the updated PEIR to be made available in conjunction with the Applicant’s formal notifications for its January 2018 consultation exercise.
Can you please tell me the last date the statement of community consultation has to appear before the consultation event?
The Applicant’s duties in respect of the preparation and publication of a Statement of Community Consultation (SoCC) are set out in s47 of the PA2008. The SoCC must be made available for inspection in a way that is reasonably convenient for people living in the vicinity of the land, and published in a local newspaper.
Can you please confirm that this is actually a third consultation and that there will be some point in interested parties like me attending it? To expand on this, will comments be collated in some way and count towards the decision to accept the DCO?
The Planning Inspectorate understands that the January 2018 consultation will be a second consultation carried out by the Applicant on a statutory basis. The first consultation undertaken by the Applicant was on a non-statutory basis. Anybody can make comments about the application to the Applicant in the same way as its previous statutory consultation exercise. As the consultation will be undertaken on a statutory basis, the Applicant will be required to have regard to the responses received as per the provisions in s49 of the PA2008.
Do pins consider that this application can remain open in perpetuity?
The PA2008 process is frontloaded, meaning the onus is on applicants to get their applications right before they are submitted to the Planning Inspectorate. On that basis, provided that the statutory procedures set out in the PA2008 are satisfied there is no limit placed on the number of Pre-application consultation exercises a particular applicant may choose to undertake, and it is not unprecedented or unusual for an applicant to carry more than one statutory consultation exercise.
Have pins considered ways in which DCO application could be used to adjust an economic background for investment purposes?
Speculation of this type does not fall within the remit of the Planning Inspectorate’s consideration of land-use development consent applications.
As an interested party is there some way I can be notified about further consultations, or indeed anything I should read or respond to relating to this DCO?
Applicants must publish a SoCC in the prescribed manner, as set out in s47 of the PA2008. Please contact the Applicant directly about any non-statutory means by which the local community can be kept up to date about its proposals.


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