Manston Airport

Representations received regarding Manston Airport

The list below includes all those who registered to put their case on Manston Airport and their relevant representations.

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Dover District Council
"Thank you for notifying Dover District Council (DDC) of the acceptance of the application for Development Consent Order regarding the proposed upgrade and re-opening of Manston Airport. The District Council wishes to register as an interested party and has set out below its position in respect of the project: Principle of the Proposed Development DDC welcomes and offers its full support to RiverOak Strategic Partners’ (RSP) proposal to re-open Manston Airport as an operational freight-focused airport and recognises the positive contribution it would make to the regeneration of the East Kent economy, as well as the UK’s aviation economy. The proposed development is supportive of the following motion passed by the District Council in July 2014 in relation to the former Manston Airport site: “The Council supports the campaign to retain Manston as an operational airport, recognising the role and place it can have in the UK aviation industry, making better use of regional capacity in accordance with the views of the South East Local Enterprise Partnership, while making a significant contribution as on the strategic priorities for regeneration of the East Kent area.” Maximising the potential of East Kent’s location as a gateway to continental Europe and its fast links to London, as well as a significant economic sub-region is essential in providing a strong platform for growth and responding effectively to the implications of a post-Brexit environment. The location of the proposed development site to Discovery Park and Kent Count Council’s (KCC) proposed Thanet Parkway Railway Station at Cliffsend, combined with commitments in investing in key infrastructure (e.g. strategic network improvements), will offer the opportunity to further enhance domestic and international connectivity and attract inward investment to East Kent. DDC wishes to work closely with the Applicant in maximising the economic potential of the proposed development for the Dover District, its businesses and residents, in particular to help support innovation, productivity and skills development across the wider East Kent sub-region. Technical Matters: Economy - The District Council supports the Applicant’s commitment to work closely with local councils to help to promote job opportunities for local people and wishes to build on this to ensure that the development of skills is supported to help deliver East Kent priorities. Further clarification is sought regarding the scope of work anticipated to ensure that the economic benefits of the proposed development for East Kent can be realised. With regard to the forecast generation of 2,655 jobs and 30,000 jobs by years 2 and 20 respectively, DDC notes the submission of the Employment Land and Housing Technical Report (Document 7.2: Planning Statement) and would welcome the opportunity to work closely with the Applicant and the relevant neighbouring authorities in assessing the implications of projected employment growth on development requirements for East Kent. Traffic & Transportation - DDC relies on the expertise of KCC – as Local Highway Authority – in assessing the impacts of the proposed development on the strategic highway network and the identification of associated mitigation measures. Landscape - The District Council concurs with the proposed sensitivity assessment for Landscape Character Areas within its administrative boundary as set out in the Environmental Statement (Document 5.2-2). With regard to the height of structures proposed as part of the development proposal (e.g. new Air Traffic Control facilities at 27m, cargo facilities at 20m and aircraft recycling hangars at 23m), DDC wishes to further engage with the Applicant as the DCO process advances to assess the landscape and visual impact of the proposals and alternatives from receptors located in the Dover District and to identify any mitigation measures, where required. To date, there has been no further correspondence on this matter beyond the formal consultation process however the District Council is currently in the process of negotiating a Planning Performance Agreement with the Applicant to enable this work to be undertaken. Noise - With regard to the Noise Mitigation Plan (Document 2.4, page 1), the proposed development site and intended flight paths indicate that the greatest impact from noise would be on areas located within the Thanet and Canterbury administrative boundaries. Given the proximity of the proposed development site to the northern boundary of the Dover District administrative area, in particular the area around Plucks Gutter, East Stourmouth and West Stourmouth, it is recommended that reference is made to noise impact on areas located within the Dover District. As part of the formal consultation process, the District Council submitted its comments in relation to the identification of adverse noise effects in 5 locations including West Stourmouth (located in the Dover District) where noise would increase to a point where there would be a perceived change in quality of life. Specifically, questions were raised in relation to the exclusion of West Stourmouth from baseline monitoring. Whilst, the Applicant has stated in its Consultation Report (Document 6.1) that undertaking long term noise measurements at all receptors would be considered impractical, DDC considers that more detailed noise measurements are required for the West Stourmouth and would welcome further engagement with the Applicant on this matter. Additionally, it is noted that properties in the Dover District fall outside of the noise contours as referred to in paragraphs 2.4 and 2.5 of the Noise Mitigation Plan (Document 2.4) concerning noise insulation funding. Specifically, this relates to ‘…residential properties with habitable rooms within the 63dB LAeq (16 hour) day time contour…’ and ‘…residential properties with bedrooms falling within the 55dB LAeq (8 hour) contour…’ and the provision of ‘…reasonable levels of noise insulation and ventilation for schools and community buildings within the 60dB LAeq (16 hour) daytime contour…’ It should be noted that these levels are greater than those given with respect to acoustic insulation under the Heathrow Expansion consultation in January 2018 which refers to 60dB LAeq (16 hour) contours for an inner zone and 57dB LAeq (16 hour) contours for an outer zone. In addition, the Civil Aviation Authority’s recent findings on Aircraft Noise and Annoyance (February 2018) makes reference to UK policy in relation to an ‘annoyance threshold’ and highlights 57dB LAeq (16 hour) as marking the approximate onset of significant community annoyance. This was reaffirmed in the Department for Transport’s Aviation Policy Framework (2013). Therefore, DDC recommends that the daytime noise contour of 60dB LAeq (16 hour) used for schools and community buildings is also used as the daytime noise contour qualification for noise insulation. Ecology - DDC relies on the expertise of KCC, Natural England and the Environment Agency in assessing the ecological impacts of the proposed development on environmentally designated sites. Heritage - DDC relies on the expertise of Historic England and KCC Heritage Conservation to assess the potential impact of the proposed development on the historic environment. Planning Performance Agreement The District Council is currently in the process of preparing and negotiating a Planning Performance Agreement (PPA) with RSP to ensure effective joint working and optimal outputs throughout the DCO process. With regard to maximising a functional effective approach, DDC would commend a joint PPA with our neighbouring authorities. I trust that you find all of the above comments useful and the District Council very much looks forward to continue to be fully involved in the plans by RSP to reopen Manston as a fully operational airport. Please do not hesitate to contact me if you require any further clarifications at this point. Yours sincerely, K Morris Leader of the Council "
UKIP and Independent Group Thanet District Council
"It is the contention of the UKIP and Independent group on Thanet District Council that the RSP application to PINS for a Development Consent Order for the Manston Airport site lacks the necessary coherence, evidence, and credibility to gain approval and create a genuinely functioning aviation operation which could be tolerated by the local community. There is no credible independent evidence across the range of documents produced by RSP to underpin the business case. The public consultations undertaken have presented a very different picture to the details of operation contained in the application itself. As a result it is almost farcical to entertain the notion of effective consultation. Rather the public consultation undertaken has deliberately presented a very different picture to that which emerges throughout the application; particularly in terms of noise, vibration, pollution, and impact upon residents. Furthermore, this ‘public relations’ aspect of what should be an honest appraisal of the proposal continues to mar the process. The local MP, [Redacted], known locally as the MP for Riveroak, constantly pumps out the message there will be only emergency night flights; the detail of the application tells a very different story. The current Leader of Thanet District Council,[Redacted], breached his powers when before becoming Leader he wrote undermining independent legal opinion and evidence about the consultation from his own Council Officers. This has been used by RSP to discount criticism of their consultation failings, and appears to have been accepted by PINS as real and substantive when it is at best a false interpretation of poor wording; at worst a bare faced lie. PINS itself, in its acceptance for examination letter, demonstrates clear awareness of the paucity of the application as presented, yet has still passed the application on to the next stage of the DCO process. This appears to many to be an abuse of process, undermining the credibility of PINS approach to DCO examinations for the future. There must be a number of private companies across the U.K. who are following the application rules and processes properly and fully who will question why it is that PINS go ‘easy’ on the detail of this application, bringing the whole DCO process into disrepute. In particular the lack of transparency and detail regarding funding and controlling influences; the flawed and incoherent public consultation processes; the ongoing dispute concerning the starting point to determine if this is a genuine NSIP or not; the suitability of the Directors track record for running airport operations; and a business case based on emotional and unsupported assumption about the current freight market, remain gaping flaws in the proposals before you. These flaws are flaws in the application itself, which should not take up Inspectors time at hearing, but should have been insisted upon as a form of completion for the application to be appropriate for submission at all. In this case PINS have clearly turned a blind eye to the sort of detail they ask for in other applications. Perhaps some of the PINS bureaucrats should be subject to questioning at public examination to explain their unusually lax view in applying their own rules and regulations. This proposal is so flawed, independent commentators will be questioning how it has progressed at all for years to come. We urge PINS to wake up and treat this application as they would any other. The stench of special arrangements hangs heavy over this application, as will the noise, pollution, and devastation stemming from the reality of freight operations at this level will hang over Thanet and Herne Bay for years to come."
Kent County Council
"Following the decision made by the Secretary of State on 14 August 2018 to accept the application made by RiverOak Strategic Partners for examination, Kent County Council requests to be registered as an Interested Party. In accordance with the Planning Inspectorate Advice Note 8.2 , this letter provides a summary of the points which Officers of the County Council agree and/ or disagree with about the application, alongside the main issues and impacts. Highways and Transportation: • The draft Thanet Local Plan - 2031 and its accompanying Transport Strategy must be a material consideration when assessing this application, particularly given the strategic significance of the Manston Airport site. At present, the Local Plan is given very little weight or consideration within the Transport Assessment . • At this stage, the approach to transport modelling within the Transport Assessment is not considered to adequately assess future traffic conditions in line with expected growth patterns and infrastructure delivery. • The proposed masterplan for the Northern Grass Area and wider highway mitigation proposals conflict with draft Strategic Routes Policy SP47 (within the draft Thanet Local Plan - 2031) that seeks to safeguard key road schemes and junction improvements to support the Thanet Transport Strategy. • There is a concern that the proposed development will generate a material increase in traffic on already constrained highway links surrounding the site such as the B2050 Manston Road and Manston Court Road. This could lead to increased levels of vehicle conflict to the detriment of highway safety, amenity and the free flow of traffic. • The trip generation and distribution methodology presented in the Transport Assessment are heavily based on assumptions which are not adequately justified or referenced to appropriate ‘real world’ examples in a number of cases; notably Heavy Goods Vehicle movement profiles and load factors, and airport staff shift patterns and staffing requirements. This limits the ability of the Local Highway Authority to comment on their validity with a sufficient degree of confidence and to assess the appropriateness of the proposed highway mitigation strategy. • The mitigation strategy should be considered within the framework of the draft Thanet Local Plan - 2031 and its supporting Transport Strategy. The site and junction-specific – rather than strategic – approach to capacity assessment taken in the Transport Assessment is considered inappropriate, resulting in highway mitigation proposals that deliver only partial benefits, and which do not align with, or incorporate, the robust, long-term solutions proposed by the Thanet Transport Strategy. The County Council, as Local Highway Authority, continues to actively engage with the applicant with a view to resolving these matters. Heritage Conservation: Archaeology • Paragraph 9.3.8 states that the evaluation results have been used to inform the Environmental Statement. However, it is difficult to see where this is included within the overall baseline provided although short reference is made in table 9.8. Given the detailed information now available to the applicant, the County Council would expect greater use of the outputs to inform the discussion of the baseline. • KCC recognises that the Northern Grass Area has not been accessible to the applicant for the field survey and evaluation that it regards as necessary to understand the implications of development in that area. • Table 9-4 refers to a teleconference on the 25 May 2018 with [Redacted] of the KCC Heritage Conservation team. To clarify the position stated in that discussion: 1) KCC accepts as stated that the applicant has not been able to access the site for survey and investigation works. 2) The investigations for Stone Hill Park provide an adequate picture for the archaeology (on the south side of Manston Road), within the parameters of the Stone Hill Park planning application. Areas such as the location of the helicopter facility in the south east of the site, and the area proposed for HGV access and earthworks north of the western runway, were not tested through trial trenching but had significant geophysical survey results. In addition, the proposed masterplan sets out an extensive arable area proposed for a contractor’s main compound that has not been surveyed or evaluated. 3) The wording in the Environmental Statement does not fully convey the position agreed. There is a need to survey and evaluate the Northern Grass Area prior to development. In the Northern Grass Area and areas of the airport which have yet to be evaluated, there remains the potential presence of archaeology of a significance that could require preservation in situ as the desirable outcome. KCC would accept that this can be achieved post determination, as long as there is sufficient - and perhaps substantial - flexibility in the development design to enable preservation to be achieved. The applicant explained in the teleconference that this can be achieved in the Northern Grass Area through reduction of the area of business development if required, as that would not compromise the overall position of airport development. 4) Given the above, a DCO requirement should cover the need to preserve the archaeology including through adjustment of development parameters as well as covering the necessary stages of evaluation and investigation. The requirements should also cover extensive investigation of those areas of the airport where archaeology will be affected by development but is not to be preserved in situ. The County Council welcomes the intention to agree a Written Scheme of Investigation for future archaeological investigations. • Table 9.9 includes an incorporated measure of “flexibility inherent in the masterplanning process following any further investigations and survey”. The applicant should demonstrate this flexibility to ensure that it is fully understood in the examination of the DCO. • Section 9.8 discusses the significance of the archaeological baseline and has drawn on the results of the Stone Hill Park evaluation. KCC has agreed that whilst there are substantial areas of the Stone Hill Park findings that can be mitigated through investigation and recording, there are also areas identified for preservation in situ including a WWII anti-aircraft battery, the remains of a Roman enclosure possibly associated with the Caesar invasions and the barrow cemeteries on Telegraph Hill, which are likely to be more extensive than the two evaluated. Most of the features would potentially be preserved in the proposed masterplan although their significance needs to be highlighted so that they are considered as plans evolve. • Paragraph 9.8.15 discusses the approach to flexibility to enable preservation in situ. It does not explain how a substantial area or feature of high significance would be accommodated in the development planning if found in the Northern Grass Area. Built Heritage • Section 9.9 refers to Built Heritage assets within the site. KCC recognises the limitations that access to the site has caused in terms of surveying heritage assets. However, it is difficult to understand what will be unavoidably affected by the proposed development and what may be retained. Reference is made to a table in Appendix 9.1 listing the features in the airfield and to the construction description which does not detail what may be demolished. • The County Council welcomes the intention to retain the museums and memorial gardens and would support any enhancement opportunities that can be delivered. The connection of these to the built heritage in a holistic way to ensure the historic sense of place of the airfield is recognised and important. Demolition of historic structures should be avoided where possible. Noise: • Chapter 12 (para 12.5.8) of the Environmental Statement describes the measures in the Noise Mitigation Plan and one of these is a voluntary quota count system that is welcomed. The Annual Quota Count is 3,028 (this is for noise emissions, not number of movements, between 23:00 and 07:00). In comparison, Gatwick’s night noise quota for October 2017 - October 2018 is 8,200 (although 75% of this is for the summer season, operating 23:30 to 06:00). The latest proposed quota allowance at Manston is far lower than the originally proposed figure of 6,000 for the 23:00 - 07:00 period and this reduction is welcomed. The proposed quota equates to approximately 8 quota count points per night and given that the Environmental Statement (para 12.7.40) states the forecast is to handle 7 aircraft during a typically busy night period, this is a reasonable figure (given a QC/1 aircraft would use one of those points). • The airport, if operational for freighters, is likely to see the noisier aircraft serve it and for this reason QC/4 aircraft are not banned at night. Again, for comparison, these would be twice as noisy as the noisiest aircraft that currently operate at night at Gatwick. It is appreciated that the proposed operating model for the airport may necessitate these noisier aircraft, but the airport should be responsive to any future complaints about night noise and try to schedule such aircraft sensitively, for example at the start or end of the night period to cause least disturbance. The proposed Consultative Committee would be a suitable vehicle for such discussions, and the commitment to a Community Trust Fund tied to fines due to noise infringements is welcomed. The Noise Mitigation Plan currently has no dates on it, so it would be useful to know how long the voluntary quota count system will apply and when it would be subject to review, including any potential increase in night movements. • The Dwelling Relocation Scheme and Noise Dwelling Insulation Scheme are important offerings to the local community, especially given that many people will have moved into the area since the airport ceased to operate. Research into the health impacts of aircraft noise (and indeed other noise sources) has moved forward so significantly in recent years, and it has been shown that people are more sensitive to aviation noise than they have been before so the assistance provided by these schemes is proportionate to the impact on those affected households. The thresholds for these schemes meet the expectations of Government policy, but the airport operators are encouraged to go beyond these levels as other airports have done. For example, Gatwick’s noise insulation scheme applies to the 60 dB LAEQ 16hr contour (63 dB proposed here). • At Year 20 in the daytime, 115 properties are forecast to be within the Significant Observable Adverse Effect Level (SOAEL) and 8 in the Unacceptable Adverse Effect Level (UAEL - meaning above 69 dB LAEQ 16hr). Insulation for those in the SOAEL will reduce the noise exposure and remove them from the ‘significant’ category, and the relocation scheme will apply to those in the UAEL. Given the relatively small number of those residents in the SOAEL (63 dB LAEQ 16hr) and that they may still experience adverse effects (some more so than others, and retaining significant effects in their garden and with open windows), consideration should be given to extending the relocation scheme to those dwellings on a discretionary basis if they are not within the formal scheme. It is also important to note that in the night period (23:00 - 07:00) there will be 16,465 dwellings in the Lowest Observable Adverse Effect Level (LOAEL - above 40 dB LAEQ 8hr and below 55 dB LAEQ 8hr) and 225 in the SOAEL (above 55 dB LAEQ 8hr). • Overall, the Environmental Statement (para 12.7.72) has identified “… significant adverse effects” at Ramsgate, Manston, Wade and West Stourmouth and this is described as “… a perceived change in quality of life for occupants of buildings in these communities or a perceived change in the acoustic character of shared open spaces within these communities during the night-time.” It is also important to remember that although perhaps not in the observable effect levels, when approaches from the east are in operation, communities to the north east (Whitstable, Herne Bay, etc.) may report noise disturbance, and when departures to the east are in operation communities to the south (Wingham, Eastry etc.) may be disturbed. Biodiversity: • The County Council previously commented on biodiversity matters in its response to the statutory (Section 42 Planning Act 2008) consultations and has not identified any significant changes following submission of the application to the Planning Inspectorate. • KCC would strongly encourage the applicant to ensure that consideration of biodiversity is also informed by other relevant chapters of the Environmental Statement e.g. air quality, noise and vibration, and traffic and transport. Freshwater environment • As Lead Local Flood Authority, the County Council has been engaged in extensive pre-application discussions with the applicant and the outputs are captured within the Flood Risk Assessment . • KCC does not raise any issues with surface water management on the site of the proposed development. ________________________________________ For the avoidance of doubt, in accordance with legislation and Advice Note 8.2, the Relevant Representation form will be completed and submitted online via the Manston Airport project page on the National Infrastructure Planning website. If you require any further information or clarification on any matter in this letter, then please do not hesitate to contact me. Yours faithfully, Barbara Cooper Corporate Director – Growth, Environment and Transport"
Thanet District Council
"Thanet District Council welcomes the opportunity to be able to provide a relevant representation for the proposed Nationally Significant Infrastructure Project (NSIP) submitted by Riveroak Strategic Partners and accepted by the Planning Inspectorate for examination. The purpose of this relevant representation is to outline the main issues which the Council believes should be considered as part of the process. Thanet District Council represents all stakeholders within the district as part of this process and will follow the duties and responsibilities as both District Council and the Local Planning Authority. Thanet District Council does not object to this development of the airport for aviation and has made significant efforts to support a functioning aviation use on the site. Weight should be given to the draft Local Plan within the NSIP process, as it is due for examination and expected for adoption prior to the decision on the NSIP submission. Any aviation function on the site requires the appropriate scrutiny to ensure that the economic benefits of the use positively affect local residents and businesses, with the need for all environmental impacts from its construction and operation to be mitigated to an acceptable level. The main issues for the Planning Inspectorate to consider should include: - The effect of the proposal on the Draft Thanet Local Plan, including but not limited to the potential for job creation to affect future housing requirements in the district. - Impact on the highway network, including the assessment of traffic and transportation and the need to provide the northern grass link road to Westwood Cross as part of the Thanet Transport Strategy and Local Plan. - Noise and vibration impacts for the construction and operation of the project, to include assessment methodology used, the assessment of effects stated and proposed mitigation outlined. - Air quality, including the need for an emissions mitigation assessment, assessment methodology and effects stated, and proposed mitigation. - Impacts on Land quality including scope of assessment, methodology, baseline, assessment of effects on human health, appropriate mitigation measures, public water abstraction, groundwater and coastal waters. - Landscape and Visual impacts from the development. - Impact on the historic environment. - Health and Wellbeing of local residents. - Socio-economic impacts, including but not limited to ensuring the local employment and training is provided from the project. The Council is seeking to constructively assist the applicant in resolving the issues raised on the above matters, prior to the production of the Council's local impact report. We will be working with the applicant proactively to ensure that this will be subsequently reflected in a statement of common ground to be submitted to the Examining Authority. "