Tuesday, 4 October 2016

Manston Airport another update

I would guess by now most people know that the Avia report into the viability of Manston airport has been published, if you want to read all 86 pages of it here is the link https://www.thanet.gov.uk/media/3500741/Final-Report-for-TDC-Manston-Airport-Viability-Oct2017_2.pdf

If you are using one of these largish pdfs on a pc and trying to make something of it, pressing Ctrl and F at the same time brings up a search box so you can find individual words in the document. I and I guess most of the journalists started by doing this with the word conclusion and at first reading the report seems to come to the conclusion that Manston as an airport just isn’t viable.

This does beg the question. What are RiverOak trying to achieve by mounting a DCO? By this I mean that they must think for some reason that Manston could be viable, have spent a considerable amount of money on perusing acquiring the site.

I wrote to RiverOak’s boss the other day

Hi George. I am chasing this one up again as it is getting to be rather a long time for a reply to what appear to me to be straightforward questions.
I am assuming that by now you must be in a position to answer at least some of my questions, and I guess if you could just answer the ones you can it; would be a start.
As you will appreciate, being in business yourself, uncertainty over the future of any major project isn’t good for the economy of the area surrounding the proposed project. As the expected deadlines extend forward in time, combined with uncertainties like the number of night flights we could expect, I am concerned about the effect on the local house prices and businesses which in turn has an affect on my business.
Frankly anything that removes some of the uncertainties is likely to have a positive affect, and from your own point of view, should you eventually become a stakeholder in a major local enterprise, you probably appreciate the healthier the local economy the more profitable it would be likely to be for you.   

Best regards Michael  

And here is the reply I got

Good afternoon Michael,

My apologies for the delay in this response.

Unfortunately, your questions are still pre-mature for me to answer in the specificity you seek.  There is still a long road to travel for the DCO process and all of your questions will be answered as we progress.  I’m not trying to create uncertainty.  I just want to be sure that when I answer your questions about night flights, valuation methods, company domicile and any number of our issues you have raised that I answer you with the kind of clarity that you, and every other resident of Thanet deserve.

Have faith, we are getting there.  And thanks for reaching out.

Best regards,


I also wrote to the DFT

Hi Susannah

I am primarily writing to you to see if there has been any update on the Manston CPO, particularly in terms of the timeline.

There is some confusion about when the application is expected to be submitted with The National Infrastructure Planning website saying this will be in Q4 2016 see https://infrastructure.planninginspectorate.gov.uk/projects/south-east/manston-airport/?ipcsection=overview while RiverOak who were saying up until very recently that the formal consultation would start about now “Autumn 2016” and now saying that this has been delayed to an unknown date, in fact they don’t even seem to give an approximate time period, see http://www.riveroakinvestments.co.uk/riveroak-investments-responds-comments-stone-hill-park/#more-1157

I think underlying the effects of this delay are related to RiverOak’s failure to respond and communicate, I haven’t – for instance – had an answer to my questions about ethical company practice and registration, which I first asked in early August. I really think this is an issue that should have been resolved by now, inasmuch as if RiverOak, as a company, don’t meet the basic ethical and registration criteria that would allow the DFT to accept the DCO application, then this presumably is a waste of everyone’s time including my own.

A much more significant issue however is the number of open environmental questions now in the public domain that RiverOak have failed to respond to. The most significant being the maximum number of night flights, the affects of noise on Ramsgate with its large number of listed buildings, which would be difficult to insulate, the already high level of particulate air pollution in Thanet and how cargo hub movements would impact on this.

Obviously there may be solutions to these issues, but without any dialogue, I – for instance – having heard nothing from Oliver Gardner, am becoming concerned that the uncertainty related to the DCO will blight the area.

A further difficulty is that because of RiverOaks unclarified relationship with local groups, that started as protest groups when the airport closed and then became focused on saving the airport, RiverOak has become associated with saving the small regional passenger airport once there.

Obviously saving a small regional airport, which was convenient for local people to fly from is very different to building a major airfreight hub, and I think it is only recently that local people are becoming aware of the significance of this.

There is and was strong local support for saving the airport, but this support appears to be mostly related to saving what we had historically and not a freight hub with uncertainty and no obligation within the criteria of the DCO that there will be any passenger service flying from Manston, should the freight hub ever open there.

Obviously were RiverOak a known aviation related company with a track record that could be found on the internet, then it would be possible to predict approximately what to expect, both in terms of what to expect in the way they engage in the DCO process and what they could or would eventually achieve in terms of a freight hub.

Could you please clarify the situation over the timescale and criteria for the pre application stage of a DCO? To expand on this. Does the pre application stage run in perpetuity if the application stage isn’t reached? Are there circumstances in which an applicant at the pre application stage can be rejected? Are there any criteria that an applicant must fulfil to reach or remain at the pre application stage?

Obviously the pre application stage of DCO already has measurable local financial impacts, with RiverOak attempting to block and presumably succeeding in delaying the use of ex aviation facilities for wider industrial use through the planning system and TDC engaging in a further and expensive assessment of Manston’s future viability as an airport.

Conversely there has also been an effect on the site owners plans for housing and light industry generating about 2,000 direct local jobs, inasmuch as local environmentalists didn’t make any objections to their plans on environmental grounds, presumably because they saw the Stone Hill Park plans as blocking the potentially far more environmentally damaging threat of an airfreight hub.     

Best regards Michael

And got this reply

Dear Mr Child,
Thank you for email of 3 October 2016. As you will have noted from Susannah’s out of office, she is on leave this week. My response is largely confined to responding to your comments regarding the application process and project timelines, which I am familiar with. Susannah may wish to add further comments on her return.
The anticipated date of submission for an application is included on the Planning Inspectorates website and updated periodically when new information from the Applicant requires that we do so. If the Planning Inspectorate meets with prospective Applicants it is common for such meetings to address the Applicant’s anticipated date of submission and their likely dates for commencement of pre-application statutory consultation. The notes of any such meeting(s) will be published on our website and will be saved at the link below (as promptly as possible) following the meeting: https://infrastructure.planninginspectorate.gov.uk/projects/south-east/manston-airport/?ipcsection=advice
The decision about when to carry out statutory consultation in the pre-application stage and when to submit an application for a Development Consent Order is entirely with the Applicant. The Planning Inspectorate has no further comment to make regarding the Applicant’s intended submission date at the present time.
With regards to ethical company practice and registration I am unable to add anything further to Susannah’s comments at the present time.
With regards to environmental questions, the Applicant is currently in the process of preparing their environmental impact assessment (EIA) to support their application and has received an EIA scoping opinion from the Secretary of State. The EIA process is an iterative process whereby the design of a project is developed and refined, informed by the results of environmental studies. As stated above the Applicant has not yet entered into formal statutory consultation but when they do so they will be required to consult on their Preliminary Environmental Information (PEI).
PEI is required to include ‘information referred to in Part 1 of Schedule 4 (information for inclusion in environmental statements) which -
(a) has been compiled by the applicant; and
(b) is reasonably required to assess the environmental effects of the development (and of any associated development)’
The PEI is not expected to replicate or be a draft of the Environmental Statement to be submitted with the application. Further information regarding the Applicant’s consultation duties and the preparation of PEI are provided in our ‘Advice Note 7: Preliminary Environmental Information, Screening and Scoping’, which is avaible at:  https://infrastructure.planninginspectorate.gov.uk/legislation-and-advice/advice-notes/
At present, the most detailed environmental information available is the Applicant’s Scoping Report
(https://infrastructure.planninginspectorate.gov.uk/projects/south-east/manston-airport/?ipcsection=docs ), which sets out the Applicant’s current understanding of environmental information and their proposed EIA methodology.  
I am unable to comment on the Applicant’s relationships with local groups, except to say that the Planning Inspectorate encourages Applicants to engage widely with relevant stakeholders and with other organisations in an effort to be open and transparent, where possible.
Sections 14 and 23 of the Planning Act 2008 (as amended) provide the criteria for Airport development that qualifies as a Nationally Significant Infrastructure Project (NSIP). Neither the Planning Inspectorate nor the Secretary of State will provide legal advice to Applicant’s regarding any proposed developments status as an NSIP (see paragraph 1.7 of the Secretary of State scoping opinion). On submission of an application the Secretary of State will consider the proposed development in light of the criteria specified in the Planning Act 2008 (as amended). If the Secretary of State does not consider that the proposed development meets this criteria then this would provide grounds for the Secretary of State to refuse to accept it as an application for examination.
The timescale for pre-application is unlimited and in many cases runs to a period of years. Applicants must have undertaken the formal statutory consultation prior to making an application. Again I would direct you to Advice Note 7 in this respect. The Planning Inspectorate’s role in the pre-application stage is primarily as an advisor to the Applicant and stakeholders regarding the process. Once the application is made the Planning Inspectorate’s role changes and we then become more prominent in directing the process. In the first instance following an application there is a 28 day acceptance period in which the Planning Inspectorate supports the Secretary of State to consider whether or not to accept the application for examination on the basis of the tests set out in the Infrastructure Planning (Applications: Prescribed Forms and Procedures) Regulations 2009 as amended.
With regards to other applications, the Planning Inspectorate is aware that the site is subject to a Town and Country Planning Act (TCPA) application by Stone Hill Park Limited for mixed use development, which has been submitted to Thanet District Council and is available on their website. That application is a matter for Thanet District Council to consider. As with any application under the TCPA act for development consent, members of the public or other organisations may make representations regarding an application. It is for the local authority and its members to determine the application, according to the statutory timescales. Any studies, such as airport viability, that the council engage in are strictly at the discretion of the council and subject to the local authorities funding arrangements. For further information please refer to the Thanet District Council website https://www.thanet.gov.uk/the-thanet-magazine/news-articles/2016/july/manston-viability-study/
I hope that this responds to your comments. If you have any further comments, please do not hesitate to contact the Planning Inspectorate.
Yours sincerely
Richard Hunt

Trying to make some sense of what for me is rather too much documentation it does seem that RiverOak haven’t met with planning inspectorate since mid July and that not very much is happening.

I have to admit trying to compose something to send to the DFT that didn’t sound like it was written by a conspiracy theorist was surprisingly difficult.  


  1. Michael, You say, "I think underlying the effects of this delay are related to RiverOak’s failure to respond and communicate, I haven’t – for instance – had an answer to my questions about ethical company practice and registration, which I first asked in early August. I really think this is an issue that should have been resolved by now, inasmuch as if RiverOak, as a company, don’t meet the basic ethical and registration criteria that would allow the DFT to accept the DCO application, then this presumably is a waste of everyone’s time including my own."

    Michael, at the risk of being frank I imagine that RO consider they must answer to DFT, and not to you.

  2. John I think – and frankly the DCO process isn’t something that is easy to follow so I may be wrong – that the DFT continually stressing that other people’s and my questions should be put to RiverOak during the pre application stage, combined with continually stressing that a DCO is a front loaded process all means that RiverOak should be engaging in a dialogue with interested parties.

    The DFT seem to be saying we can’t insist on an answer at this stage, however if RiverOak don’t produce answers to reasonable and pertinent questions raised by members of the public at this stage then there will be no next stage.

    Putting all of the airport questions to one side though I think the question about RiverOak fulfilling the basic company registration i.e. where is the company registered? And the question about the ethical criteria i.e. do the fulfil the basic criteria for the DFT to receive monies from them in terms properly recoded accounting, should be of considerable interest to everyone concerned regardless of where they stand on the future of Manston.

    It certainly puts RiverOak in a very weak position e.g. RiverOak’s latest press release is basically rubbishing the Avia report. Well Avia are a properly registered company with a strong record of dealing with large aviation companies and governments including the UK government, while RiverOak just won’t say what they are and have deleted all of the references to previous aviation activity from their US website.


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