Ramsgate Town Council’s view of RSP’s proposals

A No Night Flights’s member enquired via FOI request as to Ramsgate Town Council’s (RTC) view of RSP. In 2017 RTC submitted this:

RIVEROAK STRATEGIC PARTNERS MANSTON AIRPORT 2017 CONSULTATION

The committee considered the consultation feedback form and the responses below were RESOLVED to be sent to River Oak Strategic Partners;

Q1 To what extent do you agree with our proposals for Manston Airport?

Strongly Disagree.

Q2 Do you have any comments on our Outline Business Case for reopening Manston Airport?

There is a serious lack of information; no costings of how this will be delivered in funding terms; no details of who will deliver the project; Ramsgate Town Council challenges the methodology used by Sally Dixon which states that there is a lack of freight capacity in the south-east regional airports, as it believes this to be adequate.

Q3 Do you have any comments or suggestions about how we could maximise the social and economic benefit of reopening Manston Airport?

As Ramsgate Town Council strongly disagrees with the business case it does not believe that there will be any social nor economical benefits of reopening Manston Airport as a cargo hub.

Q4 Do you have any suggestions about how we could support the Spitfire and Hurricane Museum and the RAF Manston History Museum?

Ramsgate Town Council is aware that the current owners have gifted the land to the two museums and expect this to be honoured as well as the current footprint of the land as gifted.

Q5 Do you have any comments or suggestions about the potential impacts of the Project and our proposals to limit them?

Ramsgate Town Council considers there to be a lack of information for the mitigation proposals mentioned; no noise assessments; no flight path details; no environmental impact studies. Ramsgate Town Council believes this to be based on old out of date information and not on projection.

Q6 Do you have any comments on the possibility of limited night flights at Manston Airport?

Ramsgate Town Council considers night flights to be unacceptable as it is proven that residents living under flight paths experience damage to health. Ramsgate Town Council considers scheduled night flights to be unacceptable between 11 pm and 7 am.

Q7 Do you have any other comments about our proposals for re-opening Manston Airport?

Ramsgate Town Council considers there to have been insufficient consultation of Ramsgate residents; insufficient evidence of impact on highways, including Lord of the Manor; HGV movement impact; information on pollution from that many aircraft movements; no information on the teardown facility and what it will look like; misleading and contradictory information; information misleading on the number of jobs created locally; insufficient information on the impact on the Local Plan.

Ramsgate Town Council considers there to have been insufficient consultation of Ramsgate residents; insufficient evidence of impact on highways, including Lord of the Manor; HGV movement impact; information on pollution from that many aircraft movements; no information on the teardown facility and what it will look like; misleading and contradictory information; information misleading on the number of jobs created locally; insufficient information on the impact on the Local Plan.

NNF is glad that the town council that represents the majority of people most severely impacted by RSP’s proposals are firmly against them.

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.

Thank you to you all

We’ve had lots of contact from you and many of you have been copying us in to your submissions to RSP.  It’s clear exactly how much time you’ve put in – not only in going through their documentation but in writing your own responses.  Thank you!

Thank you also to those of you have have contacted us to thank the NNF team for the submission that we have put in on behalf of all NNF members and supporters.  We won’t lie, it has been a mammoth undertaking and it’s been lovely to receive your thanks.

One of our members has reminded us today of the fact that RSP acknowledge themselves the negative impact on Ramsgate.  We’ve heard so many people taken in by the slogans, the myths, the sound bites, it’s always good to remind people that RSP know exactly what impact this would have.

During the day:

“12.9.68 Considering that the impact is permanent and that a large number of dwellings within the communities are subject to moderate to major adverse impacts, significant adverse effects have been identified at the communities of Ramsgate, Pegwell Bay and Manston as a result of the Proposed Development. The effect would be characterised 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 daytime.”

During the night:

“12.9.70 Considering that the impact is permanent and that a large number of dwellings within the communities are subject to moderate to major adverse impacts, significant adverse effects have been identified at the communities of Ramsgate, Manston, Wade and West Stourmouth as a result of the proposed development. The effect would be characterised 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. “

Don’t forget, any opportunity you have to let your elected representatives know your concerns, please do take them.  And ask what their position is.  Ask them what they think about the ‘significant adverse effects’ and how they intend to preserve the lives, communities, schools, heritage, culture and more of the people who elected them.

Night flights – lots of them

It’s been a busy week as NNF volunteers have taken to the streets, literally, in an attempt to let as many people as possible know about the threat that RSP’s proposal is.

We’ve had people out on the doorstep delivering over 50,000 leaflets. We’ve had people thanking us for letting them know – completely unaware until the point at which they got our leaflet.  For a statutory consultation, you’d expect them to contact everyone under the flight path but RSP seem to have taken an extremely laid back approach to this consultation.  We’ve heard them trumpeting via social media of the millions they’ve spent so far on it.  It hasn’t been spent on delivering leaflets to homes to alert you as to what they are planning though, has it?

We’ve also been in the streets of Ramsgate telling people about what the proposals would mean in terms of health, noise, schools, the environment and tourism.

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Roger Gale has again been all over the media saying there won’t be night flights.  Well, that’s not what RSP’s documentation tells us.  Buried in there, they are asking for a Quota Count (QC), basically a night time noise budget, that is bigger than the one Heathrow has.  Does that sound like no night flights?  In addition, their business plan is based on two 12 hours shifts.  Why would you need that unless you were planning on working through the night? Does that sound like no night flights? In the documentation it makes clear that they would like Manston to be able to accept planes with a QC of 4.  That’s a noisier plane than is allowed to land at Heathrow during the night.

They don’t want night flights? Come on.  They are trying to pull the wool over our eyes.

Last Saturday, whilst over 50 of us were in the town centre, we had others on the beach raking out in huge letters NO NIGHT FLIGHTS.

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Brilliant effort and one the BBC came down later that afternoon to film.

Make sure you have your say and contact RSP before the end of today.

manstonconsultation@bdb-law.co.uk (RiverOak)

Copy in:
Cllr-Chris.wells@thanet.gov.uk (leader of TDC)
Iain.livingstone@thanet.gov.uk (head of planning)
Madeline.homer@thanet.gov.uk (chief executive)
Adrian.Verrall@Thanet.gov.uk (Officer head of local plan )
Manstonairport@pins.gsi.gov.uk (planning inspectorate)

For Herne Bay Residents
Ian.brown@canterbury.gov.uk (head of planning and regeneration)
Simon.cook@canterbury.gov.uk (leader of Canterbury City Council)

Also if residents could send us copies of the emails or even just to say you have sent one to the above addresses that would be great. the email address for Nnf is now no.night.flights140@gmail.com