I'm writing to you regarding my concerns over the proposed plans for a Cargo Hub at Manston Airport put forward by Riveroak Strategic Partners (RSP). And more importantly the night flight situation that will see more than 16 flights a night, every night of the year.
I've been made aware that there has been a period of consultation but I believe that process was flawed because as a resident of Ramsgate and directly under the proposed flight path, I've had no formal and written notice of it taking place? Was this information posted through resident's doors? How was it made available? How were people informed of the meetings and how frequent were the meetings? Allowing people who live but work in London, as I do, to attend.
I have seen various pieces of documentation on social media that gave no clear answers to people's very direct and concerning questions.
I believe for any pre-application consultation process applicants are advised to include sufficient preliminary environmental information to enable consultees to develop an informed view of the project… in that the information presented must provide clarity to all consultees. I don't believe I've seen anything that clearly states what impact the cargo hub and night flights will have on the town of Ramsgate, it's residents and indeed the environment.
As part of this process RSP is obliged to produce a Health Impact Assessment (HIA) that sets out what effect their cargo airport is going to have on our health and our life expectancy. RSP has failed to do this. 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." With insufficient evidence, how are we to make an informed decision?
This means that we are being consulted but that RSP is not giving us the information to help us to assess whether or not we're happy with the health implications of the project. RSP is intending to submit its HIA with its DCO application... which means we won't be allowed to consult on it as we don't get to consult at that stage.
This simply isn't good enough.
Conversely, there is a wealth of evidence that demonstrates that living near an airport is bad for your health.
On another note, there is the issue of how the airport will receive the fuel for the cargo planes. Again I've seen documentation on social media, but not been formally advised of how this will work. What I've seen so far is a very negative response from the Road Haulage Association:
On 31st January 2018, a spokesperson for the Road Haulage Association, talking about Operation Stack, said of the old airport site at Manston:
“It’s a completely unsuitable location as the road network in that part of Kent is not geared up to accommodating hundreds of HGVs.”
In Table 3.8 RSP estimates that the HGV movements associated with a cargo business of 257,000 tonnes will total 38,072 HGVs a year in Year 20. This lacks all credibility. East Midlands Airport, handling 300,000 tonnes of freight p.a., estimates that it has 500 HGVs a day, i.e. 182,500 HGV movements a year. These actuals demonstrate that RSP is misleading the public when it estimates that a similar tonnage can be shifted in and out of Manston with 21% of the HGV traffic. RSP needs to rethink these numbers and tell the public exactly what this could mean for us, the local area and a road network that the Road Haulage Association says is not geared up to hundreds of HGVs."
And finally, in 2012, Thanet District Council conducted a survey which showed that 73% of residents were opposed to night flights. How much weight have you given this finding? Why are we not being listened to? Why are residents having to trawl through social media and Facebook groups for answers? Why are TDC not stepping in to support and help residents understand the impact of such a proposal?
This really is a sorry state of affairs. The handful of jobs that would be created at Manston, and it really would be a handful, bears no comparison to the huge detrimental impact this will have on the town. I cannot see who benefits from this proposal other than Riveroak Strategic Partnership. To allow this to go ahead would be the final nail in the coffin for Thanet.
Adequacy of consultation
We note your comments regarding the consultation process. 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 1
We would therefore advise that you contact your local authority with any representations regarding the adequacy of the consultation process carried out by the Applicant.
Health impact assessment
We note your comments regarding health impact assessment (HIA). There is no requirement under the Infrastructure Planning (Environmental Impact Assessment) Regulations 2017 (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.
Preliminary Environmental Information (PEI)
The 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, as advised above. You may also wish to consider registering as an Interested Party should an application be made and accepted for examination. For information about how and when you can have your say, please read our Advice Note 8 series: attachment 2
The Applicant will need to provide its assessment of effects on human health as part of any application for development consent made to the Inspectorate.
Weight given to findings
At present the Inspectorate has not received an application for a Development Consent Order from the Applicant, and therefore has no view (positive or negative) on either the acceptability of any application or the merits of any application that may be forthcoming. Should an application be made and accepted for examination, you will be able to register as an Interested Party and raise your concerns during the examination process, as advised above.