I am writing with regards to the recent consultations about a potential cargo hub at the former Manston airport, Kent, and my concerns over the consultation process.
I bought my house two years ago and live at XXXXXXX, which is directly in line with the runway. As the airport was closed, at the time I bought my house, it was not an issue that I live less than 2 miles as the crow flies from the end of the runway, but I was surprised to find out, through a friend, that there were consultations in Thanet about a DCO to create a cargo hub, yet I, as a resident that will be effected greatly, was not notified of this.
I work 6 days a week and could not get to the Ramsgate meeting, instead I went to the Herne Bay one. There I asked several questions. Firstly, why my house / street / ward were not notified that there were consultations about this proposal? I was told, 'I found out anyway, and no one else had complained, it had been on the RSP website'. I didn't find that to be a satisfactory reply to my concerns.
I then asked why the Ramsgate meeting was shorter than the others, and why not the evening? I was informed that they thought that at the weekend most people could make it during the day and that they couldn't book the venue for longer. again, I find that answer wholly unsatisfactory. I have later found out that various areas in Thanet have been added onto the list of venues, and residents written to that do not live under the flight path, how is this deemed as fair?
I then asked about night flights, as cargo generally needs night flights. Two different people answered this question, both with different answers. A gentleman introduced as the business expert explained to me that they had assessed for night flights, but were not sure of they would be needed. When I questioned him further, he explained, that they might be needed as in his research companies wanted to bring in freight at night and that most of the companies that he knew used night flights. Again, pressed on this point, he said that RSP had no cargo companied lined up yet, so this was all in the future and they couldn't comment on it now. Yet, there was no information as to the potential impact on night time flying, the noise it would cause, health problems or so on. I was left with the knowledge that when the companies come and they want night flights, that is the problem that would be sorted out then. At another time, I causally asked another RSP employee about night flights, and was told 'Oh yes, we need them, but only want them to be for passengers', completely at odds with what I was originally told.
I asked about the information being in different languages for other people to access if need be and was told this wasn't necessary.
To not make this proposal accessible, to not notify people in the direct flight path, especially when night flights are a possibility and to give insufficient information at a presentation doesn't seem to me to be adequate as a robust consultation. At one point I was asked if I had been to their earlier consultation, to which I pointed out that I had indeed been to Riveroak's preliminary meeting, but as the company was now RSP, and no longer affiliated with that company I did not see how those two meetings could be linked.
I will be writing this to RSP directly, and I would like to send it to my council too, although I am unsure as to where to email it to. But firstly, as the potential to be the first DCO of an airport in the country I wanted to ask you about this as I feel that RSP have been wholly unprofessional with their format and making the game up as they go along. At the end of the day, this effects people at both ends of the runway and has great implications for schools, residents and so on, so think that a far more thorough process be put in place.
If/ when an application is submitted, the Planning Inspectorate, on behalf of the Secretary of State, has a statutory duty to invite comments from all relevant local authorities (see s43 of the Planning Act 2008) about whether an Applicant has complied with its statutory Pre-application consultation duties (see s42, s47 and s48 of the Planning Act 2008). Responses received are ‘Adequacy of Consultation Representations’.
All applications for development consent must also be accompanied by a ‘Consultation Report’. The Consultation Report is prepared under section 37 of the Planning Act 2008 and must give details of:
a) what has been done in compliance with sections 42, 47 and 48 of the Planning Act 2008 in relation to a proposed application that has become the application;
b) any relevant responses; and
c) the account taken of any relevant responses.
In the Acceptance period (ie the 28 days following the formal submission of an application) the Planning Inspectorate will scrutinise all of the application documents, including the evidence provided in the Consultation Report, applying the statutory tests set out in s55 of the Planning Act 2008. By the end of the Acceptance period the Planning Inspectorate (on behalf of the Secretary of State) must decide, in accordance with the tests in s55 of the Planning Act 2008, whether or not to accept an application for examination. In reaching this decision, s55(4) makes explicit that the Planning Inspectorate must have regard to the Consultation Report and any Adequacy of Consultation Representations made by local authority consultees.
On the basis of the above, I would advise for you to provide your comments to your local authority, copying-in the Applicant. This will enable your local authority to consider your comments in the preparation of its Adequacy of Consultation Representation; if/ when an application for development consent is submitted.