MANSTON
DCO – REGISTER AS AN INTERESTED PARTY?
1.
Visit the overview of the DCO at National planning here click on the tab for registering on line as
an interested party here
2.
Your name[1]….
who you are representing (“me/my family” is OK – don’t mention NNF if you definitely
want to speak yourself)…. explain your connection with the local area and how
you are affected by the proposals….then give a brief summary of the main
point(s) you want an Inspector to look into. Go for quality, not quantity. Limit is ideally 500 words. Be clear and
objective, not shouty. Say what evidence
supports you. Say why it matters to you.
Keep to what RSP have actually said in their application (all documents are on
the PINS site here ). You don’t need to use
technical language.
3.
The
following points could be useful - choose a few points that most worry you and
use your own words. This is about
quality and personal knowledge, not quantity.
4.
Registering doesn’t commit you to speaking
at public meetings. We can sort this out
later. Registering simply gets you in the game and tells the Inspectors what
you think. It helps the Inspectors decide what to explore with RSP in the
examination phase. Registering is about influence.
INDEX TO POINTS
A.
ECONOMIC
VIABILITY/BENEFITS OF THE PROPOSED DEVELOPMENT
B.
FUNDING
C.
NOISE AND NIGHT
FLIGHTS
D.
IMPACT ON
PEOPLE’S HEALTH AND CLIMATE CHANGE
E.
SAFETY
F.
IMPACT ON
RAMSGATE HERITAGE ASSETS AND RAMSGATE HERITAGE ACTION ZONE
G.
BIODIVERSITY
H.
TRAFFIC
I.
HERNE BAY ANNEX
A.
ECONOMIC VIABILITY/BENEFITS
OF THE PROPOSED DEVELOPMENT
Planning context
- No Government policy statement
has said the UK needs a new freight airport. The Department for Transport does
not predict any growth in the number of freight flights. Therefore, the application must establish a
clear and compelling case of need in the national interest if it is to be
granted a DCO. This it fails to do.
- RSP’s proposals come at a heavy economic and environmental
cost to Thanet District Council’s future supply of housing sites. The redundant airport site of 720 - 800 acres
forms the only large brownfield site with potential for housing development. It
was included in the officers’ recommended draft of the Local Plan with an
allocation for housing and mixed use development - a strong recommendation
overruled by a new Council in January 2018 on the misconceived rationale that this
would give time for the DCO to proceed.
One MP also commented that the decision to remove the site as a site for
housing would ensure the value of the site did not become unaffordable for RSP!
Below are initial representations that the economic
case does not stand up and cannot therefore outweigh the economic and
environmental harm the development will undoubtedly cause:
1.
Unsatisfactory
and inadequate evidence of business case
·
No financial
business case is presented to judge the strength of the commercial proposition (i.e.
with detailed financial justifications and including cash flow, profit and
loss, and investment predictions).
·
Central and crucial
forecasts of air freight, market demand, job creation, etc all rest on work by a
former close colleague of one of RSP’s principal directors, lacking
independence and experience.
·
Those predictions
and conclusions (in the Azimuth reports) ignore market trends to belly-hold freight
(and reasons for the shift) and lack credible supporting evidence. They require very careful scrutiny.
·
4 independent and
expert aviation opinions[2] disagree
that Manston can be viable and 3 directly challenge the Azimuth findings (the first
expert report predated Azimuth) e.g. “extremely optimistic, not credible or
likely, with negligible supporting evidence.” “Our overall conclusion is that
the RSP proposals and the Azimuth forecasts are deeply flawed. The outlook put
forward by RSP / Azimuth does not reflect market realities. We would expect
freight tonnage and freight ATM outturn at a reopened Manston to be
considerably below the Azimuth forecasts.” “A work of assertion rather than
evidence of systematic analysis of the potential market”. One (York Aviation) complained that Azimuth
had misrepresented York Aviation’s data and findings.
2.
Manston’s history
as a freight airport
·
Under three
private owners, freight formed the core component of the airport’s growth
strategy from 1999 until its closure in 2014.
Since Manston started operating as a commercial cargo airport in 1999,
the number of cargo flights (ATMs) across UK airports has shrunk, from 108,000
in 2000 to 52,000 in 2016. The most recent (2017) Department for Transport
forecasts to 2050 assume the number of freighter flights in the UK will remain
flat at 2016 levels. The market has halved and Manston failed when there was
twice as much business to go for. There is no evidence the market is going to
grow or requires a new freight airport.
·
In a falling
market for cargo ATMs, every ATM lured to Manston would have to be won from
another UK airport. So, any jobs created
at Manston will be at the cost of jobs at another UK air or sea port. They also come at the cost of Thanet’s current
heritage-dependent[3]
approach to local regeneration [see section E below plus new separate section,
under “development”]
·
The evidence
shows that there is sufficient existing and planned capacity to deal with
growth in air freight at existing UK airports.
Azimuth claims there is a pent up demand for air freight to come into
the UK. They say it now comes in by
truck because the freight airports are full. This ignores the considerable
spare freight capacity at East Midlands and at Stansted Airports, as well as at
a host of other operational UK airports.
It also ignores the fact that the majority of the air freight market is
long haul, and increasingly so, and that for domestic and short haul
destinations in Europe it is often cheaper, faster and more flexible to truck
freight to its destination. Freight
operators choose to truck freight short distance. They’re not doing it because
there is no flight option. If
additional air freight capacity was ever required, Manston is in the wrong place,
located at the end of a peninsula.
·
Successive expert
reports, plus analysis of the current and future UK air freight sector, say it
is unlikely that Manston could ever become a commercially viable
operation. A fourth failed attempt with
the same strategy to run Manston as a freight airport would prevent plans for
the site which offer serious and sustainable regeneration and job creation in
Thanet. [ca. 700 words]
B.
FUNDING
Planning context
- The application carries
a high level of risk and uncertainty. It
is a commercial operation that needs substantial infrastructure investment to
function. If it fails, the site is devalued - witness the previous sell-off of the site for
£1. Yet the potential commercial operation
is highly sensitive to and predicated on strongly disputed forecasts of
dedicated air cargo demand, and market share - forecasts that appear to have been dismissed
by every specialist aviation consultancy firm that has considered them[4].
- There is no business
plan by which to gauge the strength of the commercial operation. There will be very
high start-up costs coupled with any potential returns being very long
term. This increases the need to probe
the scale, origin, reliability and sustainability of funding sources over the
short, medium and long term especially given the high level risk that potential
investors would perceive given Manston’s dismal track record and poor location.
- This DCO is objectionable
in that RSP owns none of the necessary land and cannot show it has the hundreds
of millions necessary to bring this project to fruition. The application looks like an attempt to use
Government powers to permit a highly speculative adventure by a shadowy
offshore company with no substance or track record of operating a successful
freight airport. That is contrary to
basic property rights.
- PINS have said that the
Funding Statement does not comply with guidance and needs to be rectified early
in the Examination. The examination should
not proceed without the applicant demonstrating that they have access to
sufficient funding to acquire the land should they be successful.
Here are some initial representations that the sums do
not add up for this application:
1.
Costs
underestimated
The
price put forward to acquire the site via a CPO (£7.5m) massively underestimates
the value of that brownfield site. RSP claims this reflects qualified advice but
the estimate is wildly inconsistent with the 1961 Land Compensation Act, which
requires an ‘open market’ basis for valuation - taking full account of
potential use of the land acquired (e.g. mixed residential and other
alternative uses, and the ability of the land owners to do a similar scheme to
RSP’s).
·
The estimate for
noise mitigation measures (£5.6m) appears infected by the flawed noise contours
[see noise briefing below]. It should be
much higher.
·
Allowance should
be made, as a minimum, for compensation to the communities that RSP admits will
suffer permanent adverse effects (LOAEL) from their proposal
·
The estimate for
blight claims (£500,000) seems unduly optimistic.
2.
Unsatisfactory
information on investors and directors
·
The information
on the investors is so limited that no comfort can be derived regarding the
ability to access the £15m claimed, let alone a realistic figure. No evidence
of funding the development has been provided.
·
The principal RSP
Directors have been seeking compulsory purchase of Manston since early 2014. They were rejected twice by a Labour and then
a UKIP administration at TDC as potential indemnity partners in a CPO process
due to their failure to demonstrate financial credibility. They have failed
consistently to demonstrate that they can raise the necessary funds.
·
The applicant directors
have no track record in this sector, except failure, serial insolvency and
other issues. The representations
regarding the ability to raise finance must be tested using a fully prepared
investment appraisal and details of the investors. ·
·
The application
states “RSP anticipates that it will raise further equity and debt finance
following the making of the DCO in order to develop the authorised development”
but this makes this DCO akin to a landgrab[5]
and overlooks the damage done to the property rights of the land owner and
local residents whose interests will suffer as a result of this speculative
adventure. [ca 600 words]
C.
NOISE AND NIGHT
FLIGHTS
Planning Context
- The Government’s 2018 National
Policy Statement on airport capacity in the South East states that any
proposals for airport expansion should be judged on their individual merits,
including potential negative effects.
Noise levels are highlighted as a particular concern, requiring
examination[6].
Some initial representations that the applicant has presented
estimates that underestimate the potential negative effects of noise from his
proposed development, and has disguised his true intentions on night flights:
1.
No caps on
flight numbers
·
The applicant
states that the runway and 19 stands it proposes are capable of handling 83,000
freight Air Traffic Movements (ATMs) annually but bases its “worst case” noise
assessments on its estimate that a figure of 17,170 ATMs is more likely. However, as RSP proposes no cap on the number
of ATMs, 17,170 is not “worst case”.
·
Nor is any cap
proposed on the number of night flights, only an overall noise quota of 3028 QC
points a year. This would permit very extensive night flying, well over three times[7] the “worst case” assumptions for night flights
used in RSP’s Environmental Assessment (based on 8 flights per night).
2.
Dubious noise modelling
and assumptions
·
The applicant has
paid insufficient attention to ‘real time’ official noise measurements from
past airport operations[8] at
Manston and his noise contours over Ramsgate are impossible to reconcile with the
noise contours presented by a previous operator in 2011, when applying for a
much smaller operation[9].
They also appear contradicted by CAA noise measurement of the first 17 months
of Boeing 787 operations at Heathrow Airport[10],
where no reading at 3.8km from the end of runway was less than 90 SEL dBA -how
could noise levels over St Lawrence (1.6km distant) and central Ramsgate (3.2km
distant) be much lower as RSP claims?
·
Further evidence
casting doubt on the applicant’s noise predictions comes from independent noise
experts engaged by the local authority in 2010 when a previous operator at
Manston applied for a QC night budget of 1,995. The experts concluded “the
populations predicted to be within the 85 dB(A) contour by such departures
ranges from 14,722 [people] for MD11 departures, up to 30,903 for the Boeing
747-400.”
·
The applicant’s
baseline noise measurements are flawed and unsatisfactory and his noise
modelling includes some questionable assumptions, e.g. it will secure runway
choices that will reduce the historic aviation noise exposure of Ramsgate
residents[11]. That is not “worst case”.
·
The noise
modelling also uses a technical standard (SONA 2014) intended for an airport
already operating (which Manston cannot be without planning consents) rather
than the DfT WebTAG standard[12].
·
The applicant put
forward a spurious metric for assessing significant effects of aircraft noise
at night[13].
3.
Unclear
intentions on Night flights
·
Despite the
applicant’s insistence locally that he “neither wants nor needs” any night
flights save emergency and humanitarian exceptions[14] the
veiled business logic of the application appears to favour capturing the bottom
of the freight market viz. noisy night flights, witness:
-
proposal to accept night ATMs rated at QC4 - prohibited from the London
airports on noise grounds[15]
-
failure to address disturbing impacts from noisier aircraft
-
asserting free night flights as the top reason operators would choose Manston
above E Midlands Airport
-
his response to the public consultation comments favouring night flights repeatedly
states that RSP “welcomes support for night flights”
As
most of UK cargo flights are night flights it is especially important to be
clear about what is a realistic worst case night flight scenario and about the human costs of that
proposal. Other implications from night
time freight handling do not appear adequately to have been addressed, e.g.
light pollution.
4.
Unrealistic
approach to mitigating the noise problems caused
·
The applicant’s
proposals for mitigating the noise they will create for individual residents
show disregard for the noticeable and intrusive noise nuisance their
development will create: they would offer just £4,000 towards sound insulation
and only for people living where the applicant says people will experience over
63 decibels continuously, averaged over a 16 hour periods (55 decibels averaged
over 8 hours if from a bedroom).
Compare the applicant’s thresholds with where the Government says "Noticeable and intrusive' noise occurs
(LOAEL) [16]: 51
decibels (day) and 45 decibels (night)! [ca 900 wds]
D.
IMPACT ON PEOPLE’S
HEALTH. GREENHOUSE GASES
Planning context
- The Government’s 2018
National Policy Statement on airport capacity in the South East states that any
proposals for airport expansion should be judged on their individual merits,
including potential negative effects. Therefore,
adverse effects on community health from air quality impacts need to be given
full weight against claimed economic benefits of the proposed development.
Initial representations concern the human costs
arising from negative health impacts from noise, particulate and NO2 pollution
and greenhouse gas emissions:
1.
Noise
·
Aircraft noise
significantly impairs health as study after study shows. A daytime average sound pressure level of
60dB increases risk of coronary heart disease by 61% in men and 80% in women.
Significant health effects start at an average sound pressure level of 40dB.
Noise events cause significant increase in blood pressure levels in both men
and women. Aircraft noise significantly
affects the risk of hypertension. There is increased risk of cardiovascular
disease for those experiencing annual average daytime noise levels of 50dB and
above. Researchers have found a
statistically significant association between exposure to aircraft noise and
risk of hospitalisation for cardiovascular disease, particularly among older people
living near airports
2. Risk to children’s developing abilities
·
Children living
under flights paths have been shown to have deficits in long-term memory and
reading comprehension.
3
Particulate pollution
·
Particular
grounds for concern that particulate pollution from the proposed freight hub
would seriously endanger the health and wellbeing of local communities in the
surrounding towns and villages, including Minster, Manston, Margate and
Ramsgate, and would exacerbate the UK’s air pollution crisis in general.
·
RSP says:
“Concentrations of PM10 and PM2.5 [the tiny bits of various materials easily
absorbed by human tissue] around the airport are low, and the airport will be a
very small source of these pollutants.” But there are insufficient data
available to back up this claim. According to the Thanet District Council 2017
Air Quality Annual Status Report from June 2017, the Council does not currently
undertake any monitoring of PM2.5, and consequently there are currently no
measures in place to specifically address PM2.5 concentrations within the
District. So references to it being
within limits or not too severe in relation to the proposal at hand are unfounded.
PM10 is only being measured at two sites in Thanet, Birchington and Ramsgate, and
while they are currently under annual mean limits, both have been on the rise
since 2014. In addition, the capture rate in Ramsgate is only 83% so the level
of pollution could, in fact, be higher.
4. NO2 pollution
·
Contrary to RSP’s
claim that there is “scientific uncertainty about the health effects of NO2”. NO2 pollution alone has been linked to the
premature deaths of 23,500 people in the UK every year, with 90% of Britain’s
urban areas experiencing illegal levels of NO2 pollution since 2010. It is classified as a human carcinogen by the
World Health Organisation and is linked to lung cancer, asthma, and
cardiovascular illness. NO2 inflames the
lining of the lungs and makes them more susceptible to illnesses such as
bronchitis and asthma. Children are particularly vulnerable. If developing
lungs are affected the damage is life-limiting.
·
Road transport is
estimated to be responsible for 60% of all NO2 emissions[17]. Consequently,
it is not credible in the slightest that the additional contribution to air
pollution from the proposed development, including considerable airport-related
HGV traffic, will be “small”, “slight”, “moderate” or even “negligible”. To the
contrary, these plans would counteract urgent plans to tackle the current air
quality problems in the UK. It should be
taken into account that Thanet’s population is older than average and therefore
likely to be disproportionately affected by increased air pollution.
5.
Greenhouse
gases
·
Proposals to
reduce greenhouse gases are weak, often beyond the applicant’s control and, by
their own admission, only affect a tiny percentage of the emissions. He overlooks the fact that cargo planes are
usually older and more polluting that passenger planes and takes insufficient account
of the huge increase in heavy goods vehicles on the roads he will cause across
Thanet and beyond. The applicant’s claim that” there are no significant effects
for greenhouse gas emissions from the Proposed Development on the climate” is
repugnant to reason. The development would plainly lead to significant
increases in carbon emissions and contribute to climate change. This is not to be taken discounted in Kent,
where sea-level rise already threatens homes, farmland, and sites of
international nature conservation importance. [ca 800 words]
E. PUBLIC SAFETY
Planning context
- The applicant’s proposed
10,000-17,100 flights p.a. are below the 18,000 ATM threshold for requiring
Public Safety Zones (PSZ). However, the applicant says that the new airport
will have a capacity of 83,000 ATMs. Comparably sized UK airports show best
practice by having PSZs. The RSP proposal contains no mention of these, nor any
analysis of the 1: 10,000 or 1: 100,000 risk contours.
- Manston operated under a
Certificate of Lawfulness granted because it had civilian flights during its
time as an MOD property. A proper risk analysis would conclude that Manston
should not be given planning permission as an airport let alone a DCO. Given
the proximity of Ramsgate (population 40,000), the number of schools under the
flight path, the height of the aircraft over the town, the nature of cargo
aircraft, the lack of a local major A&E centre and past history at the
airport, the Major Accidents and Disaster Assessment and Mitigation Plan
(TR020002/APP/5.2-3) delivered by RSP fails to address risk factors
adequately.
The following are initial representations that the
applicant has not done enough to consider public safety:
1.
Lessons from
experience
·
At its peak in
2009, Manston handled 30,000 tonnes of cargo a year with only 435 flights and
yet we had a number of potentially fatal incidents that could have resulted in
major loss of life. With 10,000 flights, the risks increase dramatically.
·
The applicant proposes
that 70% of its take-offs will be over Ramsgate. Cargo aircraft are usually
older aircraft, often from countries where safety standards are poor. Previous
Manston customers include MK Airlines, Meridian and KAM Air, all now banned
from UK air space.
·
In August 2010, a
KAM Air plane “struck its tail on the runway and the grass surface beyond the
runway before becoming airborne during take-off from Manston Airport (United
Kingdom). Investigations of this serious incident by the United Kingdom
concluded that there were serious deficiencies with the operational control of
the DC8 fleet of Kam Air.” (para 14, COMMISSION REGULATION (EU) No 1071/2010). The Manston Green development of 785 homes is
500m from the end of the runway and directly under the flight path. It has
outline planning permission and this year, was awarded £2.5 million from the
Housing Infrastructure Fund. Any similar incident could result in major loss of
life at Manston Green and/or the Cliffsend homes 250m to the side.
·
In 2012, in a
vortex incident in Southwood Gardens (2.5km to runway) created as a plane went
over, the entire roof fell into a neighbour’s garden narrowly missing her. If
this had happened at nearby Chilton Primary School during playtime, there would
have been significant loss of life.
·
Ramsgate is not
4km from the runway as RSP contends. Currently, the built-up area begins 1.3km
from the runway and directly under the flightpath. It is 4km across Ramsgate from
the Marina to the runway. The town is atop two cliffs. There are 3 schools
directly under the flight path.
·
“In approximate
terms the aircraft will finally descent (sic) at 52m for each kilometre
travelled, such that at the Marina, aircraft would be 235m above the aerodrome
level (54m), or 289m above sea level.” (p14, London Manston Airport, Aircraft
Noise Assessment and Mitigation Report, June 2003)
School
|
Number
of Pupils
|
Distance
from Runway
|
Height
of Aircraft
|
Chilton
Primary School
|
422
|
1.8km
|
150m
(land dips)
|
Christ
Church Primary School
|
253
|
2.75km
|
185m
|
Chatham
& Clarendon Grammar
|
1372
|
3.5km
|
209m
|
When
Manston was operational, SEL readings from the noise monitor atop the Grammar
school consistently recorded levels above 90dB. 10,000 aircraft would cause
hearing loss and make teaching impossible. (Data sets available).
80,000 ATMs?
·
Total cargo
flights at all London airports in 2017 was only 14,588. Manston seems too far
from London to capture 68.5% of this market. York Aviation, Falcon Consultancy,
Avia Solutions and Kent County Council have all published reports stating
Manston will never succeed as an airport. The Davies Commission found no role
for it. The applicant’s talk of even a theoretical capacity of 83,000 ATMs
appears to be absurd but if RSP consider that anything over 20,000 ATMs is even
a remote possibility then they were required to include PSZs in their
application. [ca 650 words]
F.
IMPACT ON RAMSGATE
HERITAGE ASSETS AND RAMSGATE HERITAGE ACTION ZONE
Planning context
-Ramsgate
has around 450 listed sites and buildings and four conservation areas (Pegwell,
Montefiore, Royal Esplanade and Central Harbour). In 2017, we became one of Historic England’s
first Heritage Action Zones (HAZ), alongside cities like Coventry and
Hull. There are now 18 Heritage Action
Zones but Ramsgate is still the only HAZ in the South East Region. The HAZ is a 5-year programme covering the whole of
Ramsgate. Its aim is to use the
town’s heritage assets to achieve sustainable economic growth. As part
of this programme Historic England has carried out a series of surveys[18]
(not recognised in the developer’s application).
- Here are initial representations that
the applicant’s case fails generally to recognise the quality and significance
of Ramsgate’s heritage assets - and understates the impact of the development
upon them.
1.
Unsatisfactory
measurement of impact
·
Limited assessment
of the impact of proposed operations, reflecting applicant’s questionable
decision to ‘scope out’ any detailed environmental assessment beyond a
kilometre of the airport perimeter, scoping out Ramsgate!
·
Insufficient
weight given to noise data from the airport’s last operational use, reliance on
modelling based on optimistic and questionable assumptions.
·
Inadequate regard to Historic England guidance[19]
on calculating the effects of aviation on the historic environment (including
for example the physical damage caused by noise and low frequency vibration,
and the human response to noise).
·
Failure to
recognise key features of the area, e.g. that many of the most significant
listed buildings are residential properties and located in Central Harbour
ward, directly under the flight path.
·
Failure to weigh
the impact of disincentivising those whose time, energy and other resources are
needed to conserve and sustain most local heritage assets.
·
Failure to address
the visual impact of the proposals on heritage assets such as Ramsgate Royal
Harbour and on the reviving tourist industry, a major source of employment.
2.
Flight paths
·
Flight paths will
be fundamental to understanding the level and extent of noise and visual
disturbance to vulnerable communities and heritage assets. The applicant makes questionable
assumptions that he will secure runway preferences that will reduce the
historic aviation noise exposure of Ramsgate residents[20]. This
assumption, convenient for his noise contours, appears optimistic and in any
event not “worst case”.
·
Official data
from Manston's most recent operational period[21] establishes beyond doubt that most of the
town of Ramsgate is likely to experience sound levels in excess of 60dB SEL. Even if the operators prohibited older and
noisier aircraft - to the contrary, RSP’s Noise Mitigation Plan proposes to
welcome old QC4 rated ATMs - the levels of ATMs they propose greatly exceed
what was seen when noise levels in Ramsgate were recorded. Maximum sound impacts from aviation in
Ramsgate were regularly recorded at over 100dB, plus many of adverse effects
identified in the relevant guidance as requiring careful study.
·
The close
proximity to the proposed airport, its unavoidable location directly under the
principal flight path, and the intensity of its 24-hour operation, puts
Ramsgate at serious risk from the effects of noise, vibration, pollution and
visual disturbance. Collectively these factors would combine to make Ramsgate a
far less attractive town in which to live, work, and visit, adversely impacting
on much needed regeneration.
Landing Glide Path
·
The application
gives insufficient attention to the glide path on landing and the implications
of the height of aircraft above various parts of the built-up area. This is a
key factor in noise disturbance and in assessing the potential for physical
damage to building fabric.
·
Ramsgate is not
4km from the runway as the application wrongly states. Currently, the built-up
area begins 1.3km from the runway and directly under the flightpath. It is 4km
across Ramsgate from the Marina to the runway. The following diagram may
actually underestimate how close descending jumbos will be to historic Ramsgate
roofs. [ 600 words]
G.
BIODIVERSITY?
Planning context
- The Thanet Coast,
Sandwich Bay and Pegwell Bay complex is highly important for nature
conservation and biodiversity. Due to its importance it has been protected
under several UK, EU and International laws and conventions, as follows:
a.
Thanet Coast and
Sandwich Bay Special Protection Area (SPA) – under the European Union Directive
on the Conservation of Wild Birds, which requires member states to take
appropriate steps to avoid pollution or the deterioration of habitats or any
disturbance affecting the birds
b.
Thanet Coast and
Sandwich Bay Ramsar site – a wetland site of international importance as a
waterfowl habitat under the RAMSAR Convention, which requires the conservation
of wetlands designated sites
c.
Thanet Coast
Special Area of Conservation (SAC) – special area of conservation under the EU
Habitats Directive
d.
Sandwich Bay
Special Area of Conservation (SAC) – see above
e.
Margate and Long
Sands SAC – see above
f.
Outer Thames
Estuary marine SPA – see above
The
nationally designated sites are:
g.
Thanet Coast
Marine Conservation Zone (MCZ)
h.
Sandwich Bay and
Hacklinge Marshes Site of Special Scientific Interest (SSSI)
i.
Thanet Coast SSSI
j.
Sandwich and
Pegwell Bay National Nature Reserve (NNR)
k.
A new Marine
Conservation Zone at Goodwin Sands, put forward by DEFRA
-The applicant proposes to
overfly a complex mosaic of habitats of great importance and vulnerability,
especially known for its bird population, notably waders and wildfowl. There are over 30 nationally rare species of
terrestrial and marine plants, 19 nationally rare and 149 nationally scarce
invertebrate species. Breeding birds
that use the SSSI include Ringed plover, Oystercatcher and Little tern Sterna
albifrons, a species specially protected by law and listed on Schedule 1 of
the Wildlife and Countryside Act 1981.
Here are some initial representations that insufficient
consideration has been given both to direct impacts (e.g. increased noise
levels, disturbance by aircraft, night noise, deposition of pollutants such as
nitrogen oxides) and indirect impacts (e.g. cumulative effects, increased
traffic impacts or the impacts of infrastructure development associated with
the proposals).
1.
Cumulative
effects and impact on rare birds
·
The applicant
declares that “No significant inter-project cumulative effects are likely with
regards to air quality, biodiversity, freshwater environment, historic
environment, land quality, landscape, noise (construction period only),
socio-economics, traffic and transport, health and wellbeing, climate change
and major accidents and disasters.” However, cumulative impacts appear likely
from for instance, extension of the existing Thanet Offshore Wind Farm (Thanet
Extension), laying of cables by Vattenfall at Pegwell Reserve, Dover Harbour
Board’s proposal to dredge parts of the Goodwin Sands.
·
The report admits
significant adverse effects are likely as a result of increased noise in the
communities which are in the vicinity of the airport and flight paths
(Ramsgate; Manston; St Nicolas at Wade; West Stourmouth; and Pegwell Bay), but
still maintains that the proposal will not have a significant effect on the
European designated sites for vulnerable wildlife that border on these
communities. This is questionable.
·
Of particular concern
is the presence of wading birds, which are especially vulnerable to disturbance
as they have limited periods to feed on the mudflats each day due to tides. The
scientific research paper, “Exploring behavioural responses of shorebirds to
impulsive noise[22]”
indicates that increasing levels of disturbance directly impact breeding and
overwintering success of wading birds.
·
Concern must be
expressed for the airport site - with breeding bird species, such as the
skylark and grey partridge, and the barn owl, whose nests RSP propose to
relocate. Loss of habitat is identified as one of the top reasons why the UK's
wildlife species are decreasing in number.
2. Pollution
·
Drainage from the
proposed development will be via an existing outfall pipe directly into the sea
at Pegwell Bay. Whilst RSP have stated that pollutants, including hydrocarbons
(oil and fuel) and de-icer will be removed in a ‘dirty pond’ prior to discharge
down to Pegwell Bay, there is no detail provided. As spillages could occur at
any point on the hardstanding (aprons, taxiways & runway) it is unclear how
they will ensure that rain falling onto the site which currently discharges
directly into Pegwell Bay will be kept free from pollutants.
·
Concerned about
possible contamination of the aquifer, given the ‘Likely Land Quality Effects’
outlined in table 4.1 of the Non Technical Summary, particularly the
decommissioning of existing tanks and infrastructure on the Jentex site and the
construction of the proposed fuel farm. [ca
700 words]
H.
TRAFFIC
Planning context
- The applicant’s traffic
modelling appears incomplete and it must be questionable whether it can be
completed in time for examination.
Initial representations are that the applicant has not
presented a credible answer to the road congestion and fuel supply situation.
1.
Fuel tanker
movements
·
Manston Airport
does not have hydrant fuelling system and is not connected to the CLH Pipeline
System so has no secure supply of Jet A-1 fuel, the standard fuel for
commercial aircraft.
·
In the past
Manston airport activities were on a relatively small scale, easily served by
road tankers.
·
With the new
plans submitted by RSP for the total redevelopment of the airport (with a
stated theoretical maximum number of 83,000 flight movements ATMs) annually and
a planned target of 17,170 cargo ATMs) the safe supply of aviation fuel to the
airport becomes an important issue for the community at large.
·
RSP are proposing
to move the fuel farm (disused) which is currently on the Northern Grass to the
current Jentex site on Canterbury West Road in Cliffsend. It will be right at
the edge of a residential area. This move will require permission from the
Environment Agency.
·
As a high
percentage of the freight landing at the airport is predicted by the applicant
to be long distance, Manston will be an important refuelling stop. 17,170 ATMs
would require the delivery by road of at least 600,000 litres of fuel daily for
aircraft of the popular Boeing 737 type.
The 747 requires 183,000 litres. The 767-300 requires 90,770 litres, the
Airbus A330-300 requires 97,000 litres.
The fuel delivery figure could plausibly rise to 2,000,000 litres per
day, requiring 50 - 60 road tanker
deliveries every 24 hours.
·
Should RSP
increase their capacity closer to the 83,000 flight movements they claim they
could handle, the impact on traffic volumes would rise correspondingly. Such
traffic movements in a heavily built up and restricted road access area like
Thanet would pose serious dangers to the local population and the environment
as a whole.
2.
Freight
traffic movements to and from Manston Airport
·
Thanet is served
by only three main access roads, A28, A299 and the A256. Of these three only
A253 and A299 access the airport directly.
·
In the context of
BREXIT, the Government has already informed us to be prepared for major
disruption to traffic in East Kent, particularly around Dover. This disruption
has no time limit and could stretch long into the future. It would be likely to affect most severely the
A256 which could cease to function as a viable route out of Thanet, leaving the
A299 as the only major access road to the airport.
·
Is there an
alternative or secondary route to access the airport planned? Has RSP taken
steps to instigate and model special measures regarding the shipment of
dangerous cargos like aviation fuel? If so will this route run through the
village which one? Will they be using the B2050, B2190 road system?
·
The existing road
network around the airport is far from adequate at the present moment and has
been designed to restrict traffic and impede HGV's. Though RSP do mention
upgrading the roads it is unclear how and when this would be funded.
·
17,000 cargo ATMs
per annum (approximately 46 ATMs every 24h) implies a payload ranging from 115
tonnes at the very lower end (Boeing 737-300 weight max. 2,250 kilos) to a high
of 4,370 tonnes (Boeing 747F weight max. 95,250 kilos). As most air cargo
arrives in passenger planes it is doubtful if the airport would be handling a
steady flow of light shipments in the Boeing 737-300 class. Do we need this
level of detail?
·
Exclusive
airfreight hubs exist to handle heavy goods shipments and therefore it is more
than likely that the airport would be handling anywhere between 2,000 to 3,000
tonnes per day. I don’t understand that point. This implies haulage of between 120 to 166
HGV's assuming of course that each freight shipper was leaving with a full
load. As this is unlikely the true figure for HGV activity in and out
of Manston in any 24-hour period could be in the region of 400 to 500 HGV
movements, not including aviation fuel tankers.
·
Such heavy road activity
seems likely to entail significant environmental and health issues, along with
the potential for major incidents. These issues are exacerbated by the fact
that Thanet is surrounded on 3 sides by sea such that there is no realistic
alternative to the limited existing road system. [ca 700 words]
SPECIAL ANNEX
HERNE BAY
You
will have around 500 words to make your case.
The following are examples of issues which may be of concern. You can use any of these – or you may have
your own issues to raise. Nor do your
comments need to focus only on Herne Bay.
You do not need to write in technical language or use data.
If
you do not wish to make an individual submission, your views can be represented
by registering as a member of another organisation, such as No Night
Flights.
a.
PRE-APPLICATION CONSULTATION
I
would like the Planning Inspector to consider whether the consultation
adequately provided information to, and consulted the views of, the community
of Herne Bay. The proposed flight path
for Manston passes directly over Herne Bay from the extreme west to east – and
the standard ½ mile variation from that line by aircraft takes in virtually the
whole of the town, a population of 40,000.
INFORMATION: Considering the scale of the proposed cargo
hub and the magnitude of impact communities, it is questionable whether RSP
took sufficient steps to ensure the maximum number of residents were aware of
the plans for Manston, or the consultation process, as follows:
- Notices in media relied on the public
purchasing newspapers whose circulations are falling significantly.
- RSP claim in several parts of the
submission that they sent postcards to every household under the flight path by
mail; elsewhere they use the term ‘delivered’.
These claims have been widely disputed by the residents of Herne Bay. The ‘delivery’ of postcards omitted whole
streets and there is no evidence of any postcards having been posted to
addresses in the town.
- As a result just 90 Herne Bay residents
being identified in the RSP Consultation Report has having attended the
consultation events – 0.225% of the population.
- In a letter following the consultation
events the local authority for Herne Bay, Canterbury City Council, expressed
“concerns regarding the adequacy of the consultation process”. (Doc 6.2
Consultation Report Appx46).
Further,
at the Consultation Event held in Herne Bay, conflicting information was given
to residents on many topics, including:
- proposed flight paths – statements
including that aircraft would not pass over the town
- night flights – some RSP representatives
stating there would be none and others stating that they would be inevitable.
b.
NIGHT FLIGHTS
In
view of the considerable impact on Herne Bay of night flights (restricted at
other airports) I would like the Planning Inspector to establish the true
proposals of RSP. Night flights are included
in the application, yet RSP and its guest speakers (including a local MP)
continue to deny in public that they will happen. Meanwhile the majority of UK cargo-specific
flights are night flights and air cargo operations across Europe are heavily dependent
upon them. The 17,100 cargo flights
predicted for Manston would therefore suggest over 8500 night flights. Further, an overall noise quota of 3028 PC
points per annum means that there could be many more night flights. However, RSP’s Environmental Assessment
(table 9.1) bases its ‘worst case’ assumptions on only 8 flights per night
(2920 per annum).
c.
NOISE
I
would like the Planning Inspector to assess how accurately RSP estimates the
impact on Herne Bay of the proposals.
RSPs noise impact assessments (2.4 Noise Mitigation Plan) are based on
average noise, which it is now widely understood does not reflect the true
impact on a community, especially that from frequent night flights. In a poll conducted in 2012 regarding
proposed night flights at Manston, 181 Herne Bay residents responded, of whom
150 were against (83%), almost all citing noise/lack of sleep as the
reason.
I am also concerned to read that RSP
proposes to reverse the historic 30:70 split between the east and west ends of
the runway (so that 70% and not 30% of flights pass over Herne Bay). This will have implications not only for
Herne Bay and Beltinge but also for the villages between Herne Bay and the
airport such as St Nicholas and Minster, which is adjacent to the airport.
The
three locations selected by RSP to establish current normal noise levels are
all subject to higher than average levels of ambient noise (48-60dB daytime and
45-48dB night) and thus do not reflect the average for Herne Bay which is
largely residential. OBS2 Beltinge is on
a 200m wide strip of land between the A299 dual carriageway and the main
high-speed railway line. OBS3 Avenue of
Remembrance is one of the two central thoroughfares through the town. OBS 4 Studio Herne Bay (Studd Hill) is
adjacent to the main high-speed railway line.
Even
given that, the difference claimed by RSP between current average noise and the
projected levels resulting from the airport – ranging from +0.1-1.0 dB does not
reflect the true impact of the proposal.
Over Herne Bay the estimated height of aircraft is 2400 feet – at which
(NATS statistics) aircraft noise is at 66-80 dB. The World Health Organisation statistics on
aircraft noise describes ‘moderate community annoyance’ at a threshold of 50 dB
and ‘severe annoyance’ at 55 dB. Add to
that the estimate of 20 or more night flights and the effect on sleep, daily
life, health and education will be more than ‘severe’.
d.
TRAFFIC & TRANSPORT
I
would like the Planning Inspector to consider whether the application addresses
the real extent of impact on local road networks of the proposed scale of
operation. The proposal forecasts from
9,903 HGV movements in year 2 to 64,906 annual HGV movements by year 20. Yet East Midlands Airport says it has 182,500
HGV movements a year and RSP forecasts Manston will handle more freight than
East Midlands. The proposal
documentation shows little detailed consideration of the need for additional
road capacity beyond the immediate surrounding of the airport. However, the M2 and A299 – the only fast
access route to Herne Bay and Thanet – are both only two-lane and already busy
with HGV traffic.
e.
ECONOMIC IMPACT
Herne
Bay experienced a significant economic downturn typical of former holiday
resorts from the 1960s onwards – becoming the ‘poor relation’ to Canterbury and
Whitstable. In the past five years, the
town has seen a marked economic revival, thanks to increasing numbers of day
visitors and inward investment in leisure facilities including leisure
shopping. Rises in property prices have
followed, buoyed also by an overspill effect from London investors following
the success of Whitstable. This new
prosperity would be severely threatened by 24-hour aircraft noise and heavy
traffic.
The
contour below seems like a bit of a random addition?
[1] They will publish your name (though this can be kept
out if you are a member of a group).
They will keep your address confidential
[2] See reports by Falcon Consultancy, Avia Solutions,
York Aviation and Altitude Aviation Advisory.
[3] Viz: Heritage Action Zone designation
[4] Notably Falcon Consultancy, Avia Solutions, York
Aviation and Altitude Aviation Advisory
[5] See especially the Applicant’s plans to include the
so-called Northern Grass within the DCO footprint, which the applicant himself
concedes is not required as part of a functioning airport. Though the applicant says his interests are
strictly confined to aviation, previous speculative inquiry by one of RSP’s
principal Directors indicates the need for careful examination.
[6] June 2018. See
esp. paragraph 1.39: see https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/714106/airports-nps-new-runway-capacity-and-infrastructure-at-airports-in-the-south-east-of-england-web-version.pdf
[7] CAA data shows
that at Luton 2,645 QC points translated into 7,450 night flights annually
[8] Note that when Manston was operational, SEL readings
from the noise monitor atop the Grammar school consistently recorded levels
above 90dB. Data sets available – see also noise measurements considered by the
then airport consultative committee – see https://drive.google.com/open?id=0B96caduedt5sYXlmRHdJLThuWFE
[9] See 2011 noise contours available on line at
http://hernebaymatters.squarespace.com/nonightflights-blog/manston-aircraft-noise-maps.html
[10] See CAA
document CAP1191
[11] See footnote 1 to Table E3
inhttps://infrastructure.planninginspectorate.gov.uk/wp-content/ipc/uploads/projects/TR020002/TR020002-002426-5.2-9%20-%20Environmental%20Statement%20-%20Volume%209%20-%202%20of%202%20-%20Appendix%209.1%20-%20Envirocheck%20Report%20-%20Part%202.pdf
[12]
https://infrastructure.planninginspectorate.gov.uk/wp-content/ipc/uploads/projects/TR020002/TR020002-002431-5.2-12%20-%20Environmental%20Statement%20-%20Volume%2012%20-%202%20of%202%20-%20Appendix%2010.1,%20Appendix%20B,%20Part%202.pdf
[13] This is the
infamous “18 times a night” awakening metric described in Section 12.6 of
Chapter 12 Noise and Vibration.
Following repeated challenges, RSP claimed this value “has been informed
by emerging [emphasis added] best
practice and research into aircraft induced sleep disturbance, namely research
undertaken by Basner et al (2006)”. But
as RSP had later to confess, the Basner work points to a figure of 14 not 18 –
and it is unclear there is any academic consensus or official endorsement for
the “18 times a night” assertion.
[14] See
documentation already submitted to PINS regarding contemporary sound and other
verbatim recordings of these claims
[15] See Noise
Mitigation Plan submitted with the DCO application
[16] Official definition, says LOAL is where ‘Noise can be
heard and causes small changes in behaviour and/or attitude, e.g. turning up
television; speaking more loudly, having to close windows for some of the time
because of the noise. Potential for some reported sleep disturbance. Affects
the acoustic character of the area such that there is a perceived change in the
quality of life.'
[17] European Commission, 2016, Transport Emissions: Air
pollutants from road transport http://ec.europa.eu/
environment/air/transport/road.htm
[18]
https://historicengland.org.uk/services-skills/heritage-action-zones/
[19]
https://research.historicengland.org.uk/Report.aspx?i=15740
[20] See footnote 1 to Table E3
inhttps://infrastructure.planninginspectorate.gov.uk/wp-content/ipc/uploads/projects/TR020002/TR020002-002426-5.2-9%20-%20Environmental%20Statement%20-%20Volume%209%20-%202%20of%202%20-%20Appendix%209.1%20-%20Envirocheck%20Report%20-%20Part%202.pdf
[21] See data presented in section C above
[22] Wright et al in ‘Wildfowl’ 2010
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