I see that RSP did not submit their application for a DCO before the end of December 2017, as had been advertised on the Planning Inspectorate's website. I see that they now plan to engage in another round of consultation.
It has not been made clear how the new consultations will differ from the previous ones, or why new consultations are needed. One of the key issues with the previous consultations was the lack of clarity over what RSP is intending to do and how this was likely to affect local communities. The people staffing the consultations, who included senor directors of RSP, did not seem to be able to answer basic questions, such as whether there would be night-flights. Despite receiving many complaints about the previous consultations, the Planning Inspectorate has made no note of any criticism. If the Planning Inspectorate agreed that the previous consultations were inadequate, surely the organisation should have made some comment to RSP in advance of them repeating the consultation exercise?
Since meeting with the planning inspectorate, RSP has stated that they intend to introduce environmental controls on the levels of noise using a quota count system. None of this has been set out in black and white so that local people can read what they are planning to do.
It is very unclear what rationale there is for RSP's proposed controls. They have not produced any data to show how many flights there would be, what types of aircraft would be involved, the times of the day when these flights would be taking place and how much noise this would generate. This data, which would be an essential component of a statutory Environmental Impact Assessment, is needed before it is possible to decide which environmental controls are appropriate or required. In the absence of any companies who have said they would use Manston, I appreciate that the prediction of what will take place is difficult to achieve, but there are professional companies out there who specialise in making these kinds of projections. It would only require RSP to spend a small slice of the hundreds of millions to which they claim to have access to have a report prepared which would inform people about the likely environmental impact.
This brings me to my final. and most important point. The quota count system was devised at Heathrow to deal with the environmental impact of night-flights on local residents. It does not prevent night-flights from taking place, but restricts movements of the noisiest categories of aircraft and levies financial penalties on operators who breach the rules. It is the government which has imposed this system on the airport. However, it is not a perfect system and people living in the vicinity of the airport will confirm that it is nowhere near as effective as a total ban on night-flights such as they have at Frankfurt airport.
Who has decided that a quota count system is appropriate for Manston and will address the environmental issues which will arise from having freight aircraft overflying a historic seaside town at low altitude? Why is a quota count system being proposed when the local MP has been telling local people that RSP do not need or intend to have night-flights? The contradictions is glaring and ought to be resolved before any further consultation takes place.
In summary, the previous consultations were inadequate because the prospective applicants did not have an Environmental Impact Assessment including noise contour maps and projected noise levels over the residential areas adjacent to the site of the former airport. Can the Planning Inspectorate confirm that RSP will be required to produce this information in any new consultations? Can the Planning Inspectorate confirm that RSP will be required to confirm in writing whether or not their new freight depot will require night flights and, if so, the likely levels and patterns of this activity, before they engage in further consultation? Can the Planning Inspectorate confirm that RSP will be required to produce written details of their proposed quota count system before engaging in any further consultation? Can the Planning Inspectorate confirm that RSP will be required to discuss and agree their proposed quota count system with the local planning authority before presenting it to the public? (As far as I'm aware, RSP has not approached Thanet District Council to discuss their proposed quota count system).
If the Planning Inspectorate agreed that the previous consultations were inadequate, surely the organisation should have made some comment to RSP in advance of them repeating the consultation exercise?
The Planning Inspectorate cannot take a view on the adequacy of an applicant’s Pre-application consultation until an application is formally submitted to it. The Planning Inspectorate has therefore to date not tested the adequacy of the Applicant’s Pre-application consultation, has not ‘agreed’ that it was inadequate, or provided any advice to that effect. The Applicant’s rationale for carrying out a further round of consultation is explained on its website (attachment 1) and the Planning Inspectorate is not sighted on any further justification beyond that which is already in the public domain.
Can the Planning Inspectorate confirm that RSP will be required to produce this information [noise contour maps and projected noise levels] in any new consultations?
The Applicant summarised in its teleconference with the Planning Inspectorate on 22 November 2017 the materials which would inform its 2018 consultation exercise: attachment 2. The Planning Inspectorate cannot compel an applicant to include particular information in its Preliminary Environmental Information, which is defined in Regulation 2 of the 2009 EIA Regulations (and Regulation 12 of the 2017 EIA Regulations).
Can the Planning Inspectorate confirm that RSP will be required to confirm in writing whether or not their new freight depot will require night flights and, if so, the likely levels and patterns of this activity, before they engage in further consultation?
The position in respect of night flights remains the same as that outlined in previous advice issued by the Planning Inspectorate: attachment 3. The Planning Inspectorate has access to the same information as the local community and statutory consultees ie the Applicant’s Scoping Report states at paragraph 11.6.10 that “The airport will be operational during the day and may be operational to some extent at night. The noise generated due to this activity may give rise to potentially significant effects”. If night flights are proposed for the airport, the likely significant effects will need to be assessed by the Applicant as part of its Environmental Impact Assessment and presented in the Environmental Statement. The content of the Environmental Statement cannot be examined by an appointed Examining Authority until the Examination stage of the process.
Can the Planning Inspectorate confirm that RSP will be required to produce written details of their proposed quota count system before engaging in any further consultation?
Details of the Applicant’s proposed Noise Quota Count will be included in the application when it is formally submitted. This was confirmed by the Applicant in its meeting with the Planning Inspectorate on 2 November 2017. The strategy will be open to examination by an appointed Examining Authority, and members of the local community will be able to register to become an Interested Party and make representations to the Examining Authority about any mitigation strategies proposed by the Applicant. For more information about how (and when) to have your say please see the Planning Inspectorate’s Advice Note 8 series: attachment 4
Can the Planning Inspectorate confirm that RSP will be required to discuss and agree their proposed quota count system with the local planning authority before presenting it to the public?
The Applicant confirmed in the 22 November 2017 teleconference (link above) that its draft Development Consent Order (dDCO) would include provisions to secure its proposed Noise Mitigation Plan and Noise Quota Count. Applicants are encouraged to share draft iterations of their dDCOs with key stakeholders (including local authorities) at the Pre-application stage. See the Pre-application Prospectus: attachment 5. Local authorities are otherwise able to make representations to an appointed Examining Authority about the content of a submitted dDCO in the same way as the local community. They also have a special role in the Planning Act 2008 process as outlined in the Planning Inspectorate’s Advice Note 1 and Advice Note 2 (attachment 6.