Manston 2017 | home
72 King Street
1 Consultation issues
This is my feedback to the RSP/RiverOak 2017 statutory consultation relating to their DCO application summarised on the National Infrastructure Planning part of the Department for Planning website as: - “The upgrade and reopening of Manston Airport primarily as a cargo airport, with some passenger services, with a capacity of at least 12,000 air cargo movements per year.”
My understanding is that there is a strong probability that the DCO would include a CA and that this means there would also need to be proof of legitimate and transparently sourced compensation funding for the DCO to be accepted.
Completing the consultation there is a sense that somehow communication and outreach to local communities isn’t and hasn’t been in proportion to the size of the project and that community engagement has been at the level one would expect for a new road junction at Manston, affecting people within a mile or so.
I attended two of the public sessions one at Canterbury and one at Ramsgate and the overall impression I formed wasn’t that of a company working towards building a major airfreight hub. It was much more that of a group of about four people who had brought along PR reps from some other companies and that their main objective was to trigger a DCO and then see what they could do once the had acquired the site, assuming that the possession of the DCO and associated cpo could attract investors.
I have since both spoken to and used the internet in various ways to communicate with other people who attended the consultations. The overall impression being that they were given conflicting information about the project and like me found that there wasn’t anyone available to answer many of the most basic questions.
In a similar way since the previous consultation held by RSP/RiverOak a year ago there has been an overall lack of response to basic and related questions sent to RSP/RiverOak directors and their advisors.
As a local retailer and resident I am aware that local awareness of the project existing is low and awareness of the magnitude and the implications the project would have to the local area are almost non-existent among the wider local community. Those aware seem to be mostly people who supported some sort of saving of the airport starting from when closed and those who opposed nightflights
There is an element of cry wolf to this as over the last ten years various airport operators have proposed large aviation expansion at Manston, which has failed to happen.
There is an element of economic musical chairs to Manston with the site having changed hands as an airport over the last 20 years for figures of around £1, £5m, £22m and so on. With airports having been designated brownfield and the potential for the site’s value as residential building land being in the region of £1bn the potential for the site owner to receive a windfall can’t really be discounted.
The issues with the consultation continue here to the point of competing it, having notified RSP/RiverOak 3rd July, about three weeks ago that their consultation website didn’t function properly and having eventually had emails from them acknowledging this and promising to try and put it right, nothing has actually been done to make work properly.
The most important issue here being that only the left half of the webpages are displayed meaning that only even numbered pages of major documents, show on most computers. With filling in the consultation the downloadable feedback form is a fixed document that I can’t write on with an IT device and send to you and in view of the existing website issues I don’t have confidence in the online form or ITC competence within RSP/RiverOak I am responding by email.
2 Business case.
I think for Manston to work as an airport it would need to be primarily operated as a heritage aviation tourist attraction perhaps based on a HFL grant and funding from aviation enthusiasts and focused around the expansion of the two existing museums. It is possible that at times this could work in parallel with the limited local aviation demands.
As was the case with many previous business cases for aviation activity at Manston, the main issue is a misunderstanding of the words “hub” and “southeast” hub in this instance should be close to the centre of the area it serves and southeast in the context Southeast England is a roughly triangular area the three corners, which are northwest Oxfordshire, southwest Hampshire and northeast Kent. In terms of forming a hub for the southeast these corners are the worst locations.
I think the main issue here may be thinking of a hub airport as planes flying along the spokes of an imaginary wheel, when in reality it is passengers and freight moving along the spokes to and from the airport by rail and road.
The best, most central location, to the southeast is the Greater London Surrey border, which has the two existing major airports, one at either end of it. As very little of the commercial or industrial activity in the southeast is located in the southeast corner of the southeast this means that virtually none this activity is closer to Manston than the two existing major and competitive airports.
Because of a combination of road layout (particularly the UK motorway layout) and geography of the southeast regions of: - Oxfordshire, Bucks. Berkshire, Hampshire, IOW, Greater London, Surry, Sussex and Kent, travelling to Manston from almost any significant location outside Kent would involve passing close to one or both of the existing major airports. So for example a journey from Brighton to Manston isn’t done by travelling northeast towards Manston, but either by road or rail, it is done by travelling north past Gatwick and then east.
I think part of the most recent problem, which was the failure of Infratil, a major NZ company to succeed with an airport at Manston, was the tendency to think in distances considered negligible in NZ, without properly understanding actual travel habits and infrastructure in the UK.
A further major disadvantage Manston has with its main potential competitors, Gatwick and Heathrow, is that it isn’t, and isn’t likely to be connected to the jet fuel pipeline. This would add both economic and environmental costs of fuel there.
The first attempts to operate commercial flights from Manston started in the late 1950s Silver City (Britavia) which moved to Gatwick in 1962, Air Ferries the first proper airline started flying from Manston in 1963 this went bankrupt in 1968, this was followed by a 60 year history airport operator failure on the Manston site.
This business case appears have been written by some members of the same team that put together the last Manston business case for the Infratil when the airport was still operational and appears to based on similar very optimistic assertions. I think it has to be appreciated that Infratil are a large experienced and profitable company which run Wellington Airport (5.5m passengers a year) at a profit and not only did they reject this case but sold the Manston site suffering a considerable financial loss, because they thought it unviable, both in terms of the real business they were able to attract and the potential business which was forecast.
I suppose the bottom line here is that local residents, like myself are only aware of the applicants website, there doesn’t seem to be a physical RiverOak or RSP company employing non executive staff at normal business premises producing something tangible or some tangible service. When RiverOak first appeared on the scene their website claimed they were experienced airport operators and as their company has evolved during the DCO pre-application stage, moving the Manston project from http://www.riveroakic.com/ where it featured as the main project of an experienced aviation company to www.riveroakinvestments.co.uk where it appeared to be the UK branch of an experienced company to http://rsp.co.uk/ which appears to have no physical address and no history.
Obviously a project of this magnitude whether it succeeds or fails would have a significant impact on this area and commenting on the business case related to a business and related businesses without any defined history, similar business assets is very difficult and quite different from a case where I was commenting on say a business case produced by an existing airport operator.
There is also a sense in which this is a choice between RSP and the site owners Stonehill Park where the business owners have a good track record of running a successful business locally that has resulted in a substantial amount of jobs and economic regeneration in this area.
3 Noise Pollution and Compensation
My understanding from the PIER assumed flight paths, aircraft, engine types and so on, is that:-
1 The flight path over Ramsgate has to remain the same and changes to flight paths which may happen during later stages after the DCO submission will have no significant affect on overflying Ramsgate.
2 The noise impact on homes and businesses within Ramsgate will be significant and that plans to mitigate them should be at a fairly advanced stage prior to DCO submission as the DCO process is front-loaded.
3 Aircraft noise mitigation in airport expansion is mostly a matter of compensation and as an application for a DCO that would authorise CA must be accompanied by a Funding Statement which should demonstrate that adequate funding is likely to be available to enable the CA within the statutory period following the DCO being made, and that the resource implications of a possible acquisition resulting from a blight notices should have been taken account of, I am therefore assuming that the whole compensation issue has to be presented in one consultation response.
4 The issues related to the Ramsgate conservation zone and the number of listed buildings likely to be affected by noise should by this stage have been at least partially addressed in order to approximately assess sound insulation and cost with a view to determining compensation levels related to the resource implications.
5 Negotiation related to sound insulation within the conservation area between rsp, English Heritage and TDC conservation officers is already occurring.
Due to issues with accessing the PEIR documents and consultation website, see my emails, ref (Ross RiverOak Strategic Partners Manston Airport consultation team) I am uncertain that I have managed to view all of the consultation documents. So please accept my apologies for saying that documents that should be there are missing are actually there, if this is the case.
Obviously, I am no expert in airport expansion DCOs and have only been able to find examples of two which are expected to be submitted in the UK one being this Manston one and the other being for the third runway at Heathrow.
In terms of percentage expansion and therefore the difference to historic noise disruption the Manston project would the by far the greater civil aviation expansion based on previous activity at Manston.
In view of the front loaded nature of the DCO process and the expectation that there would only be small and unavoidable change after the application stage I had expected the PIER to be more compete in terms of already addressing solutions to known and fundamentally unalterable environmental problems.
Previous submissions for Manston expansion have included noise contour maps for unavoidable parts of the fightpaths, most especially related to the necessity to overfly the densely populated town of Ramsgate because of the location of the runway. I have been unable to find these within the PEIR.
A comprehensive noise pollution plan would seem to be particularly important as the possibility of night time flying appears to be envisaged as part of the application.
Although the Heathrow expansion is at an earlier stage in progressing towards the DCO I am assuming that their noise mitigation and compensation package would be broadly similar to the Manston one. Although I suppose that as Thanet is an economically depressed area and therefore has higher levels of poverty some less comprehensive scheme may be envisaged related to the population being poorer with lower levels of employment and home ownership.
I also asked about the funding and compensation issue at the previous non statutory consultation and followed this up by email to pins 5.8.2016, the pins advice encouraged me to write to RiverOak which resulted in an email correspondence between me and rsp director George Yerrall who said, email 32.8.2016:-
Thank you for your patience in awaiting my response. I was away on vacation with my family and I try to “unplug” when I am away.
Your list of questions is hard for me to process as it contains numerous requests to respond to something said to you by a “RiverOak rep” as well as a number of assumptions you have made that seem factually difficult to understand such as your assumption that the airport would be “classified brownfield and that the cpo land compensation will be based on an open market valuation for brownfield land in southeast England., plus blight compensation.”
However, as you know, the PINS consultation process is very transparent and all of your issues will be addressed and published in due time. I understand that waiting for answers can be frustrating and that is not my intent.
Thank you again for your patience and I look forward to addressing all of your concerns in the near future.
From this I inferred that the statutory consultation document pack and website would contain, a site compensation plan, blight compensation plan, noise compensation or draft noise compensation plan. Having failed to find anything and having had no response from rsp about the issues with the consultation website and documents, I am providing the link to the Heathrow noise compensation plan for your information https://your.heathrow.com/takingbritainfurther/local-community/property-compensation/
Added to this would be the airport site value compensation I understand this is 283 hectares, designated brownfield. Independent valuation https://www.kent.gov.uk/__data/assets/pdf_file/0008/53882/Land-prices.pdf puts southeast non agricultural land prices, residential in the av £4m per hectare ballpark with the lowest in Dover at about £1.75m and industrial in the £1.1m ballpark. My assumption from your airfreight hub job forecasts is that your own assessment of the potential site value would be seen as profitable commercial, so that you would see the minimum site value as nearest equating to industrial. This would put your assessment of the minimum site value in the area of £300m, with the worst-case scenario rising to cover those parts of the site that the current owners intend for residential use being considerably higher. There is also the of course the situation where the airport was available as a failing business with no alternative viable commercial plans and could probably have been bought in the £10m ballpark so I assume this could be taken as a quasi-best-case scenario
In trying to comprehend how the CA and potential blight acquisition compensation could be covered by provably legitimately sourced investment that would be acceptable to the DFT and enable the publication of a transparent funding statement, which is an integral part of a DCO requiring CA, I have drawn some conclusions. My understanding is that rsp isn’t an aviation company but an investment conduit and I find it difficult to see major investors attracted to a project with uncosted and potentially open-ended compensation liabilities. I am therefore assuming that potential investment, in the event of the airfreight hub scheme failing, would be covered by the potential residential site value of what I understand to be a brownfield site. I am also assuming that any blight acquisitions would increase in value considerably were this to happen.
4 Air pollution
The main issue with construction of an airfreight hub at Manston would appear to be the recent life expectancy reduction issues related to particulate pollution, this is the problem that has led to the national government considering a diesel car scrappage scheme.
In a general sense, the fuel used in jet engines produces similar particulate emissions to the fuel burnt in diesel road vehicles and the particulates produced from tyres landing on and running along runways similar problems to road vehicles.
Where particulate fuels are burnt in commercial transport mitigation in terms of emission, filtration becomes more economically viable with the larger engines in lorries and shipping. For smaller vehicles, cars and vans the shorter-term solution looks likely to be moving to petrol with the prospect that in about ten years we will have moved away from fossil fuels in private transport.
In environmental terms this is a different but related problem to global warming, in simplistic terms the focus has moved from rising sea levels drowning people in a hundred years time, to particulates killing people in significant numbers now.
With jet engine planes, as detailed in the PEIR, there has been some progress very recently the most encouraging being recent work by NASA. See: https://www.nasa.gov/press-release/nasa-study-confirms-biofuels-reduce-jet-engine-pollution the underlying problem being that filtration isn’t an option.
Most of the available studies showing levels of particulates produced at airports have been made at Los Angeles airport LAX, when using them for comparison it is as well to remember that LAX is a very busy airport and that Los Angeles is already a very polluted city, so everything is as it were scaled up. In terms of visualising the issue Los Angels has approximately the same prevailing wind direction as Manston.
Current mitigation in the UK is mostly focused on a reduction in ground movement fuel burnt.
Expectations in the shorter 3 to 7 year period will probably include the use of bio fuels and the relocation of some activity from airports upwind of densely populated areas.
Expectations in the longer 8 to 15 year period may be focused on alternative fuels and fuel storage such as hydrogen and electric motors.
My efforts to discuss this problem with the RiverOak environmental team have been unsatisfactory so far. I tried at the previous non statutory consultation and was given a contact at Amec Foster Wheeler but have had no reply from him to my first email 10.7.7017 also sent to pins.
I attended the statutory consultation at Canterbury where the environmental team members I spoke to appeared to have no concept of the volume of fuel burnt at an airfreight hub and seemed to equate it to that burnt at a busy road junction.
Obviously, the expected fuel burn figures at Manston are contained in the PIER in great detail, but for anyone trying to understand the problem and who isn’t conversant with large engines I have added the following paragraph to help with approximation.
The metric tonne and the imperial ton are almost the same weight, there are 250 gallons of fuel to a ton or tonne. A 747 type plane burns approximately 5 litres or 1 gallon of fuel per second so cargo plane allowances are usually measured in tonnes. The takeoff allowance for a 747 is 2.5 tonnes and the ground movement (landing or takeoff) allowance around 1 tonne.
The proposed Manston site has been designed to minimise the ground movement time, but with the on the ground part of takeoff and landing I think it reasonable to assume that in excess of a tonne of fuel will be burnt on the ground for each movement.
To put this in some sort of proportion a large diesel car does about 40 miles to a gallon and a large lorry about 10 so when thinking in terms of government concerns over road junctions, a car would have to travel 10,000 miles to burn a tonne of fuel.
The minimum number of freight plane movements at Manston, for the Manston project to qualify for a DCO is 10,000 per year so it would follow that the intention is to burn more than 10,000 tons of jet engine fuel per year at the Manston site.
The complexities of increasing flying activity dovetailing with aircraft emissions reducing over future years makes calculating figures for reduced life expectancy from projected activity difficult.
The most significant aspect is probably the greater than expected distance drift of the smaller and most harmful particles from LAX, the only airport where the measurements have been made and published in a fairly comprehensible way.
This combined with the increased mortality rates related to particulates described in the PEIR and on reputable websites such as wikipedia means the freight hub would result in the premature deaths of a significant number of local, people i.e. kill them.
Discounting all of the other factors but burning 10,000 tonnes of fuel on the ground between when landing aircraft’s wheels touch the runway and leave it on takeoff, which would seem to be a very modest assessment based on 10,000 movements. Taking Thanet’s population as around 125,000 mostly located to the north and east of Manston. Taking the prevailing wind direction to be between south-westerly and westerly. Considering that there really is no lower safe limit for airborne particulate pollution, however significant mortality levels like those found near road junctions are being taken in the 10 to 20% ballpark when considerably reduced life expectancy and diesel car scrappage is being discussed, so this looks like a significant issue.
Expectations are that the government will produce incentives to ensure that flights are more environmentally cost effective in terms of more use of passenger belly space and empty return flights which may impact on the economic case.
Obviously, in situations where the problem already exists and mitigation efforts have already started then those involved can be seen as applying duty of care and so on.
In terms of embarking on a major project in the face of current scientific information appearing to say that the project would kill a significant number of people, there may be matters related to, duty of care, precautionary principle, liability to litigation and so on that would apply.
I have avoided a long list of citations and links to online documents but for search and reference assistance, the first LAX particulates pollution results were gathered by and the main work was by USC Assistant Professor Scott Fruin 2014, the most recent publicly available results of corroboratory testing and research, which also has links to the important sources is now available on line, here is the link to it https://www.researchgate.net/publication/311395120_Emission_rates_of_particle_number_mass_and_black_carbon_by_the_Los_Angeles_International_Airport_LAX_and_its_impact_on_air_quality_in_Los_Angeles ;
5 The museums.
My understanding is that the current owners have gifted the museum freehold to the Spitfire and Hurricane Museum, theoretically ensuring its security in perpetuity and that negotiations to offer something similar to Manston History Museum.
I would think that there could issues with trying to integrate two museums into a busy freight hub where parking, road space and security would be expected to be a premier consideration.
As a further note, my response to this consultation is neither as exhaustive nor as comprehensive as it would have been had the consultation website worked reasonably well, and had been presented in a navigable and searchable form, rather than how it is, or as a series of massive, unlabeled and unmanageable pdf files.
In terms of the content of my response, I am happy to offer citations and or explanations.