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 http://thanetonline.blogspot.co.uk/2014/04/manston-airport-air-pollution-admission.html
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 http://thanetonline.blogspot.co.uk/2016/08/manston-cpo-update-from-dft-and-bit-of.html
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 http://www.ethicalconsumer.org/ethicalcampaigns/taxjusticecampaign/taxhavenlist.aspx 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 http://www.riveroakic.com/ website
and that the corporate information there is different to the management
structure on the http://www.riveroakinvestments.co.uk/
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 <Susannah.guest@pins.gsi.gov.uk>
To: michaelchild <michaelchild@aol.com>
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
Susannah”
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
Susannah
There are also some newly published Manston DCO related documents
on the DFT website https://infrastructure.planninginspectorate.gov.uk/projects/south-east/manston-airport/?ipcsection=advice
See
and
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.
ReplyDeleteThanks 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.
ReplyDeleteSo far the responses I have received from everyone concerned have been helpful and as far as I can see they are taking me seriously.
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.
DeleteJust 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,"
I wonder when John became your critic Michael? It seems to have been going on a long time.
ReplyDeleteHi Barry, I was not criticising. I was merely trying to help in my humble way.
DeleteJust 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
DeleteDear Mr James,
DeleteI 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).