Clarification on noise? Clear as mud

You will know that RSP themselves realise that their statements and publications on noise in relation to their plans have been far short of crystal clear.  In an attempt to clarify their position, they issued the statement below.

Our committee members have made clear what No Night Flights thinks of this ‘clarification’.  The NNF response is below with the RSP statement below that.

 No Night Flights’ response RSP on this ‘clarification’

Regarding your “Statement on noise” of 19 February (pasted in below) which your Director Mr Freudmann promised would clarify the position regarding night flights.

It does not clarify the position.  It actually adds to the confusion.

The basic problem all through your various consultations is this:

  • the paperwork said that there will be night flights
  • your Directors said that there would not be night flights.

The confusion has been made a lot worse because the local MPs have emphatically backed the Directors.  This has left the public wondering what to believe – the black and white in front of them or the fifty shades of grey from the Directors.

Weasel words

The latest statement implies that the cargo flights won’t be scheduled to fly into Manston at night.  But it adds – in a list beginning with delays and emergencies – that  “flights carrying time-sensitive cargo with a very specific delivery window” “cannot be ruled out”.

But “flights carrying time-sensitive cargo with a very specific delivery window” actually defines the commercial Charter sector of the night-time cargo market!

They may not be scheduled flights but they will still be flights.  If you really do intend – as your Directors promise – to avoid a business model that entails cargo night flights, then why not say that there will be no commercial flights – scheduled or charter – at all?

The formulation of your statement is apt to mislead the public.  It amounts to saying little more than that scheduled night flights cannot be ruled out and fails to mention your cargo market and chartered flights – what kind of clarification do you call that?

Please note that a crate of wilting green beans from Nairobi is not an urgent compassionate reason to wake up thousands of men, women and children in Thanet and Herne Bay.  Please don’t insult us and our families by pretending otherwise.

Novel flight paths?

Your talk about aeroplanes no longer needing to land in straight lines (i.e. over Ramsgate) is intriguing but lacks substance.  Are you saying that it has any material effect on the calculations of environmental impact that you have put forward on a statutory basis, or not?  And where precisely are these areas of “sparse population”?  Towards Sandwich and Dover?  Towards Herne Bay?  Or do you want to obliterate the wildlife of Pegwell Bay?  What are you talking about?

Also, you do not say if you have any authority from the CAA for leading the public to expect novel landing schemes at Manston.  Without CAA approval it is difficult to see that any weight can be attached to your blandishments.

It is unclear why you have chosen to present these new considerations at this time and in this flimsy and anecdotal way.

ATMs or QCs?

No reference at all is made to the figure of 8 flights per night which you have assured us just days ago, is the basis for all the calculations of impact on which you invited comments from the public and statutory consultees.  You have lead the public to believe that eight flights at night on average is the maximum but have committed to this nowhere.

Your statement mentions a figure for night-time passenger ATMs but skips over the question of limiting night-time cargo ATMs to 8 per night.  Instead, it refers to your bid for 4,000 (plus 2,000) Quota Count points annually. The inference is that the QC system will be used to control cargo night flights, not any nightly figure of ATMs.

Your QC figure would permit many more night flights than 8 per night.  Therefore the PEIR is not presenting a realistic worst-case scenario.  You don’t say anything about this.  Why not?  It has been drawn to your attention.  Do you not agree that the public need to know very clearly what is the realistic worse case scenario?  That is the law, or so we have been told.

QC4 aircraft?

Nor does your new statement on noise impact mention your position on QC4 rated aircraft.  Those are now totally banned at night at Heathrow on noise grounds.  Yet the PEIR says that you plan to welcome them to Manston at any time.

Your latest statement doesn’t mention any changes here so one remains confused as to how you feel able to present your permissive regime as “noise mitigation”.

Plans to welcome aircraft in 20 years time which are already regarded as too noisy to be allowed into Heathrow cannot reasonably be described as “noise mitigation” can they?

There are hints in your statement that you are up for horse-trading on your QC bid for 6,000 points – and that you appear to expect to get knocked back by the Government and the local authority.  That kind of talk is totally inappropriate and confuses the issue.  What we want to know – and have a statutory right to know –  is WHAT PRECISELY DO YOU AS  DEVELOPER PROPOSE TO DO?  We want you to come clean, not dodge and dissemble. This is what the consultation should have been telling us.

 Summary

We think that RSP needs to clarify, actually clarify, the following:

  • Whether they stand by their statement (12.9.70) that their plans mean a major and permanent adverse effect on local communities during the night?  Yes or no?
  • Whether their wish to route aircraft over “areas of sparse population” materially affect any of the statements in the PEIR just presented to the public? Yes or no?
  • Whether their plans include any clear limit on the number of night ATMs?  Yes or no?
  • Whether they still propose to allow planes into Manston at night which are already banned at Heathrow?  Yes or no?

RSP STATEMENT ON NOISE

Published on February 19th, 2018

As aircraft noise is the most perceptible effect from an airport, this issue has naturally caused the most concern for local residents. This is the case particularly for the noise generated by night flights. This statement sets out the current position and how it will be finalised.

We are designing Manston so that our customers are both able and incentivised to fly during the day. The airport is being designed so that capacity comfortably exceeds demand in order, principally, to provide a high quality of service to customers by reducing close to zero any delays. This means that there will always be capacity to operate flights during the day with a lack of capacity being the main reason that cargo flights take place at night at other airports. Furthermore , the capacity of the airport will mean that very few aircraft will have to hold in the air or on the ground, thus reducing noise impact. Incentivisation for daytime flights will come from the fact that we will charge carriers considerably more to fly at night. Nevertheless, some non-scheduled night flights cannot be ruled out, whether they are delayed daytime flights, medical emergencies, or flights carrying time-sensitive cargo with a very specific delivery window. Additionally, our market testing suggests that up to five passenger flight departures and one passenger flight arrival may be necessary between 6am and 7am, but no passenger flights at all between 11pm and 6am.

We have developed a noise mitigation plan of commitments to control aircraft noise, which forms part of our January-February 2018 consultation. This includes an annual quota count (where noisier aircraft have a higher quota count and use up more of the quota) of 4000 for flights from 11pm to 6am and 2000 for flights from 6am to 7am. In addition to the commitments that are made in the noise mitigation plan significant investment is planned in state of the art navigation equipment. This will allow a high degree of noise preferential routing such that arriving and departing aircraft are able, as much as possible, to route over areas of sparse population.

Note that our Preliminary Environmental Information Report describes two ways of assessing noise impacts – the weighted average noise that residents and others will hear over a day or a night (which appear as ‘LAeq’), and the maximum noise level from each aircraft, which could be a single aircraft in one night (which appear as ‘LASmax’). Our mitigation proposals will control both maximum and average noise levels and will be provided to those exposed to the highest noise levels, in common with other airports and in accordance with government noise policy.

We will consider all the responses to the consultation now that it has closed, but given the representations already analysed we are likely to lower the quota counts further when we come to make our application (plus consider any new or amended measures that have been suggested). Look out for the revised version of the noise mitigation plan that we submit with our application to the Secretary of State for Transport in March, as well as our full Environmental Statement on how we will deal with all environmental impacts.

After our application is submitted, there will be a further opportunity to comment on it by sending representations to the Planning Inspectorate. There will then be a six-month examination of the application by one or more Inspectors appointed by the Planning Inspectorate, and there is very likely to be a day-long hearing on aircraft noise during that period (although that will be up to the Inspectors to decide, not us). As well as several opportunities to make written submissions, this will be the main chance to address the Inspectors directly on night noise.

Up to six months after the end of the examination, the Secretary of State will decide whether to grant the application or not. If he or she grants it, the decision may well contain further changes to the noise mitigation plan, as a result of weighing up our case and the other submissions made. This will be the final set of commitments that we will be bound by in planning terms, although the Civil Aviation Authority may impose other conditions on the airspace change proposal that is also required.

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