Wednesday, 10 August 2016

Manston Airport DCO update and the reason why I am against building an airfreight hub at Manston.

I have to admit to being a bit of an anorak when it comes planes, boats, cars, busses, lorries and motorbikes, when a plane flies over my most likely reaction is to rush out the door with my camera, rather than to phone up the airline and complain.

I have however made some personal concessions to the environment, the main one being selling my 5.7 litre car, I still have the psychological wounds and hope everyone realises that I have suffered personally for our environment.

I expect some of you have noticed that scientists and engineers have started to say bad things about diesel engine emissions and where as once if you had a diesel car you were inclined to brag that it did 150 mpg now you are inclined to keep schtum awaiting more information.

These new bad things aren’t about global warming but about particulate pollution and when I went to the RiverOak consultation and I talked to their environmental consultant it was evident that they had missed the main issue with air pollution which is the PM2.5s, particulates 2.5 microns across that penetrate deep into our respiratory system.

Thanet already has levels of PM2.5s of 11µg/m3, which is above the World Health Organisation guidelines and around the threshold for a measurable related reduction in life expectancy. 

The main sources of this pollution is diesel engines and jet aircraft engines, a freight aircraft (747 type) movement, takeoff or landing burns one tonne of aviation fuel, the dispersion distance (the distance away from the fuel burn upwind where the particulate level returns to around the background level is around 10 miles)

Obviously added to this would be the lorry movements, considerable as Manston has no fuel pipeline.

Margate and particularly Broadstairs are upwind of Manston in terms of prevailing wind direction.

I don’t suppose I need to draw anyone a diagram, we are very close to one of the most densely populated parts of Europe and the prevailing wind is blowing the fumes from all of the traffic in southern England this way.

The, you shouldn’t have moved near to an airport if you didn’t want to die young from a stroke, heart disease, lung cancer, and chronic and acute respiratory diseases, including asthma argument doesn’t hold much water either. Most of this is new science and unless you moved here very recently the information just wasn’t available.

I’ve only been going on about it since April 2014 – it’s mi anorak don’t you know, see and the mainstream media since around the beginning of this year.

When I went off to the RiverOak DCO consultation this was the main thing I wanted to talk about, however the actual consultation was a strange affair and threw me a bit.

Frankly I didn’t feel I could respond to the written bit without resolving some of the things I was told by the RiverOak representative, so I wrote to the DFT and it was some time before I got a reply, see Monday’s post

Anyway today I followed the advice of the DFT and wrote to RiverOak’s, chief investment officer here is my email.

Hi George

I am writing to you with respect to the recent public consultations, I attended the Canterbury consultation with a colleague and while I gained useful and informative information, which will help me in responding to the written consultation, from the environment expert there, the information I gained from the RiverOak rep needs further clarification before I make a written response to the consultation.

I raised the issue of the recently approved Manston Green planning application, to which the rep replied that it wasn’t close to the runway and would have no effect on the proposed freight hub. I pointed out that the runway approach lights are within the Manston Green footprint but the rep said that this was a different site.

Could you kindly clarify this issue?

I went on to ask about cpo compensation, I assume that as an airport site Manston is 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.

The RiverOak rep seemed to think that the compensation wouldn’t be calculated on the value of the land but would be related to the nominal payment for the loss making aviation business that once owned the site.

Could you clarify RiverOak’s position on expected cpo compensation funds provision, detailing what classification you consider the land to be, brownfield, greenfield etc and what you consider to be the approximate value per acre of this type of land here in the southeast?

I then went on to ask about RiverOak as a company, I note the company’s address is in Connecticut, however RiverOak doesn’t appear in the Connecticut state company register. In the first instance I am concerned about ethical company practice, vide or just put, tax haven list, into into Google.

As I am sure you appreciate the ethical sourcing of funds is related to legislation which the DFT has to abide by.  

In the second instance, about deliverability. With a UK company I assume the minimum criteria for a company wishing to engage in a major project would be registration with Companies House with three years of published accounts and the names of all of the directors published there.

The RiverOak rep told me that RiverOak is a private investment company and as such has no public registration.

Obviously this would be a significant impediment to the CPO aspect of the DCO.

I think in this instance American company registration may be significantly different to that in the UK and that I am just unable to find it.

Please can you tell me where I can find RiverOak’s corporate information and accounts officially recorded on a government or official website? Or alternatively how the cpo criteria could otherwise be satisfied?

I then went on to observe that all of the information implying that RiverOak is a significant player in European and american aviation has been removed for the website and that the corporate information there is different to the management structure on the

The RiverOak rep said that this was due to a website update, can you please confirm this and tell me when or if the update will occur?

Obviously looking at the other aviation company practice where RiverOak are significant player will make it much easier to respond to this consultation.

Could you provide me with a list of aviation companies where RiverOak is a significant investor?

I noticed that several of the RiverOak reps at the consultation were members of a local protest group and or ex airport employees, apart from this making it much more difficult to express a candid view, it seemed to be out of focus with the objective of a public consultation, which I had assumed was to gather information from the public.

I have previously attended various Manston related public consultations, including the Stone Hill park one and the Infratil Environment Agency one related to Manston Airport being granted an EP (environmental permit) pursuant to obtaining conventional planning consent as an airport. So I was expecting a much more conventional consultation rather than what appeared to be a promotional or airport closure protest event, that I attended.

Can you explain RiverOak’s connection with airport closure protest groups and tell me to what extent the consultation responses and respondents personal details will be shared with protest groups?

Can you tell me if responses to the this consultation will be published on your website with personal details redacted, in the normal transparent and open fashion, which I believe is mandatory to Development Consent Order documentation?  

My stance on the future of the Manston Airport site and engagement in related consultations, is to try to get the most beneficial result for the local area and obviously in terms of employment and increased economic activity. Usually this is a balance between the benefits of growth and the environmental downside. So from the point of view of an ordinary local resident at the moment I consider taking part in consultations relating to Manston’s future very important.

The two main schemes on the table at the moment being the mixed use development proposed by the current owners and the RiverOak freight hub plans, requiring a DCO and associated cpo.  

I asked the RiverOak rep what he thought of the other scheme and how he thought RiverOak could compete with a company already responsible for the largest source of local employment in this area.

The RiverOak rep seemed to think that Discovery Park wasn’t significant, weren't responsible for significant local economic growth and then he went on to infer that they were somehow not operating in a proper and beneficial way.

Obviously as I run a bookselling and publishing business locally, many of my customers work at Discovery Park and if they are trading in some way that is either unsound or unethical it could have considerable implications for the local economy.

Could you kindly clarify this issue?

Initially I put the majority of the above questions to the DFT and have recently received their response:-

“From: Susannah Guest <>
To: michaelchild <>
Sent: Fri, 5 Aug 2016 18:45
Subject: RE: Manston Airport

Dear Mr Child
Apologies for the delay in responding to your emails of 29 July and 22 July 2016.
In your email of 22 July 2016 you raise some queries in respect of access to information about RiverOak, what checks are carried out by The Planning Inspectorate during the Pre-Application stage into applicants and noted an outline planning application in the vicinity of the Manston Airport site.
In respect of the first point, The Inspectorate do not hold any undisclosed information about this company or its financial dealings.  There is no legal requirement for an applicant to share such information with The Inspectorate at the Pre-Application stage.  However, where an application involves any compulsory acquisition of land, which RiverOak would do as part of their proposals for Manston Airport, the applicant would need to submit a Funding Statement with the application documents.
A Funding Statement should provide as much information as possible about the resource implications of both acquiring the land and implementing the project for which the land is required.  Applicants should be able to demonstrate that adequate funding is likely to be available to enable them to carry out the compulsory acquisition within a statutory period following a Development Consent Order being made, and that the resource implications of a possible acquisition resulting from a blight notice has also been taken into account. Unless an Examining Authority is satisfied that funding will be available both for the carrying out of the project within the statutory period and for the payment of compensation claims the compelling case in the public interest test required by section 122(3) of the Planning Act will not be met and the compulsory acquisition powers cannot be granted.
From your email it appears that you have verbally discussed these matters with RiverOak.  If you have not done so already, and noting your point about limited acknowledgement or feedback to queries, I would strongly encourage you to put your queries in writing to the company itself.
In respect of the “Manston Green” proposals, Thanet District Council have been aware of the situation at Manston Airport in coming to their decision to grant outline planning permission for this scheme.  Now the scheme has outline permission, RiverOak must consider any future development on that site as part of their environmental assessment.
In your later email you make some further observations about a recent consultation event held by RiverOak.  I would encourage you to make these comments known to RiverOak if you have not done so already to enable them to consider the points in advance of any statutory consultation.  Before that statutory consultation occurs, the relevant authorities (Thanet District Council and Kent County Council) must be consulted by RiverOak on the content of their Statement of Community Consultation. The role of the local authority at this stage is to provide expertise about the make-up of its area, including whether people in the area might have particular needs or requirements, whether the authority has identified any groups as difficult to reach and what techniques might be appropriate to overcome barriers to communication. The local authority may also provide advice on the appropriateness of the developer’s suggested consultation techniques and methods. The local authority’s aim in such discussions should be to ensure that the people affected by the development can take part in a thorough, accessible and effective consultation exercise about the proposed project.  You may also wish to send any observations to Thanet District Council in respect of consultation activity.
Kind regards
As you see, as well as telling me to address these questions to RiverOak, their response raises further issues and you may with to comment on these too.

I look forward to your timely reply, in view of the fact that we are approaching the consultation deadline.

Best regards Michael

I ccd the email to the DFT officer handling the case who I also asked for confirmation that the DFT didn’t know where RiverOak are registered as a company, if they are registered as a company or who the directors of RiverOak actually are.

Here is her reply.

Dear Mr Child

Thank you for sight of your email correspondence to RiverOak that thoroughly sets out your comments and questions directly to them.

We do not hold any corporate information about RiverOak.  Where we have received hard copy letters in respect of this project they have come from RiverOak’s legal advisors or consultant team.  It is not unusual on projects like this for the bulk of the correspondence to be undertaken by advisors or consultants on behalf of the applicant.

In terms of payment of fees, there is no due diligence that the Planning Inspectorate is required to undertake.  It is the payment and clearing of a fee in respect of a named case that triggers the required actions to be undertaken by The Inspectorate, for example on submission of the application and the application fee, the Planning Inspectorate has 28 days to determine whether an application will be accepted to progress to the next stage.

Kind regards


  1. Michael, In my view they might take you more seriously if you did not start your correspondence to them with the salutation 'Hi'. You will have noticed that they do not reply to you same way and instead choose the polite form of address. They are not your mates.

  2. Thanks for the advice in email etiquette John, I will take it onboard but I think on the whole I like to put people at ease whenever I can.

    So far the responses I have received from everyone concerned have been helpful and as far as I can see they are taking me seriously.

    1. Michael, You must do as you see best. I was simply working on my own and colleague's experience of receiving letters from the public. We were always wary of those total strangers who wrote to us as though we were their best mates. A polite business like approach seemed to work best.

      Just out of interest, every Govt Dept has an unofficial file labelled 'nutters'. I am not suggesting for one moment, Michael, that any of your correspondence would find its way there. As you rightly point out they are taking you seriously.

      As such you are unlikely to receive the dreaded reply. "Dear ....., I acknowledge receipt of your letter of (date) the contents of which have been noted. Yours sincerely,"

  3. I wonder when John became your critic Michael? It seems to have been going on a long time.

    1. Hi Barry, I was not criticising. I was merely trying to help in my humble way.

    2. Just ss you were humbly just trying to help when you posted in Loud Hailer. I'm sure you went up in people's estimation by your ingratiating way. Shame Hailer is a non entity as is SMA. Looking at Beau all alone at Minnis Bay people are so fed up with the machinations of Riveroak I am surprised at their continuing support from people who blindly follow. They should rename Freudmann as the Pied Piper of Manston

    3. Dear Mr James,

      I acknowledge sight of your posting the contents of which have been noted.

      Yours sincerely,

      John Holyer

      (note to self: now where should I file Mr James' post).


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