Tuesday, 16 August 2016

Manston DCO informal consultation my initial economic benefit v environmental detriment questions.

As I think most people with an interest know, but perhaps fewer understand the DCO process is “front loaded”. This doesn’t actually mean to put the load in the front like a wheelbarrow, but in this context; it means to arrange or plan a project, or process, so that a large portion of activity occurs in an early period.

The idea being that the people wanting to get the government to accept a DCO, in this case RiverOak, engage with the people who are for, against or just interested in the project, look for the snags and pitfalls and find solutions prior to making an official submission to the DFT.

I don’t think it matters that much if you are for or against building an airfreight hub at Manston, in fact I would say that if you are for it, now is the right time to play devil’s advocate.

The DFT are very good at replying quickly and informatively to correspondence and because the legislation relating to DCOs insists that it is an open and transparent process the DFT are very good at publishing information about the correspondence they get on their website at https://infrastructure.planninginspectorate.gov.uk/projects/south-east/manston-airport/

RiverOak on the other hand are not, their last press release is now a moth old, none of the correspondence and responses to their informal consultation have been published on their website. In fact to me it appears that they are out-to-lunch. Perhaps they have bigger fish to fry and will get around to Manston eventually, or perhaps they have all gone on holiday.

Anyway about a week ago I wrote to them a preliminary email, see http://thanetonline.blogspot.co.uk/2016/08/manston-airport-dco-update-and-reason.html ccd it to the DFT, got a response from the DFT but haven’t heard anything from RiverOak apart from an automated response, impying they are out-to-lunch.

Time is getting on with respect to the deadline for their unofficial consultation, which is – as far as I understand – the centre for front loaded dialogue, so I have roughed out another email for them, see below.

Before I send it off I am asking on my blog and on such related Facebook Groups what readers think, I will also send it off to the DFT before sending it to RiverOak, this is to make sure that I should be putting my questions to RiverOak.

Anyway, here it is:-

Hi at RiverOak (at the moment I am a bit confused about who to write to there)

With respect to the questions already I have put to RiverOak in my email 10.08.2016 I initially sent it to George Yerrall, partly because he appears as RiverOak’s Chief Investment Officer on both RiverOak websites http://www.riveroakinvestments.co.uk/ and http://www.riveroakic.com/ and partly because he was the first member of RiverOak to respond to me when I initially emailed them.

I got an automatic response to my email 10.08.2016

“           -----Original Message-----
From: George Yerrall <****@riveroakic.com>
To: michaelchild
Sent: Wed, 10 Aug 2016 10:08
Subject: Automatic reply: Manston DCO

I am currently out of the office and will only have intermmittent access to email and to phone service. “    

I assume he must be on holiday. So I forwarded the email to Stephen Denardo, who also appears on both website as CEO and a partner.

As I have had no response or acknowledgement from RiverOak, apart from the out of office, I have no way of knowing if they received my email or intend to reply to it prior to the deadline date of their initial consultation 05.09.2016.

As the CPO process is front loaded and I had hoped to enter into a meaningful dialogue with RiverOak, regarding the aspects of the project that concern me, as I feel that I can give some useful input about at this stage. I am starting this process without a reliable point of contact at RiverOak, so I am sending this information to you in the first instance and I hope you will be able to tell me if it is appropriate for me to then send it to RiverOak.

As a local businessperson and resident there are two aspects to the development of Manston that most concern me.

One being the economic growth and the resultant benefits to my own business.  

The other being the pollution generated by any commercial development on the site and the aspects of this detrimental to the local businesses and community.

I have skimmed through the scooping report and other documents now published at https://infrastructure.planninginspectorate.gov.uk/projects/south-east/manston-airport/ and there are aspects of the environmental strategy about which I would like further clarification prior to completing the informal consultation. 

First my initial questions about noise pollution.

My understanding is that the minimum activity generated by the airfreight hub would be 10,000 airfreight movements a year which equates to approximately 200 movements per week or approximately 30 movements in a 24 hour period.

I am assuming that there is also an optimal amount of freight movements per year, the scooping documents seems to indicate 20,000 per year, there would also presumably be a maximum figure envisaged, although I can’t find it.

Could you please clarify the optimal and maximum number of freight flights?

With respect to night time activity I can only find what appears a maximum of 18 movements per night, with night time being defined as after 23.00 and before 7.00. 

Obviously there is a great deal of information where noise measurement in dB is given, but for a layman this is difficult to interpret and would presumably depend on the sound insulation of the building you were sleeping in and the sound reflecting qualities of the surrounding infrastructure.

Could you please clarify the maximum number of  freight aircraft night movements? 

I am assuming that the aircraft type will be mostly the same as the previous Manston freight activity i.e. 747 series, can you please confirm this?

Can you please clarify how the number of flights, and night flights – detailed separately, relates to the number of people employed, directly and indirectly?

The town most affected by noise pollution will be Ramsgate as it is at the end of the runway, and this pollution can be divided in to daytime noise, mostly affecting production in local business, educational advancement in local schools, the local tourist industry and night time pollution which has roughly similar effects but is generally more damaging.

Ramsgate has nearly 900 listed buildings (one of the highest numbers for any uk town) and a considerable number of other buildings within the Ramsgate conservation area, residences, businesses schools and collages. This includes a number of language collages, which are significant contributors to the local economy.

Under normal circumstances the main mitigation for noise pollution is sound insulation, however with many listed buildings and buildings in conservation areas, effective sound insulation is expensive, difficult and sometimes impossible.

Please can you explain how you have addressed the problem of noise insulation as related to Ramsgate’s large number of listed buildings?

My first initial questions about air pollution.

As you are no doubt aware Thanet has good air quality apart from some isolated areas around road junctions and the background level of particulate air pollution that I mentioned to the environmental expert at the Canterbury consultation session.

Inasmuch as there are likely to be people reading this who hold administrative positions and are not conversance with particulate air pollution, I will first make a short explanation.

Firstly particulate air pollution is a fairly newly discovered problem, related in recent media articles to diesel cars now being a less desirable option. Secondly that collective impacts of multiple air pollutants interact in the atmosphere and impact on health. Thirdly particles associated with particulate pollution are very small and bury themselves deeply in lung tissue, causing reduced life expectancy from stroke, heart disease, lung cancer, and chronic and acute respiratory diseases, including asthma.

Thanet is already presumed to have annual 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 nearest monitoring station is at Southend-on-sea 11µg/m3 and the other monitoring station thought likely to have similar levels is at Eastbourne, which is also recording level of PM10s above WHO guidelines (PM10 21µg/ PM2.5s 15µg/m3)

This is thought to be due to the prevailing wind direction across southern England combined with the proximity of the industrial areas of Europe. PM2.5s are slow to disperse from the atmosphere.

The main sources of particulate air pollutants are Diesel engines, fuel oil and aviation jet engine fuel, 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 for PM10s and further for PM2.5s)

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

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

Are you planning to monitor particulate air pollution in Thanet prior to planning the number and type of aircraft movements viable at Manston?

Will there be any compensation scheme related to any reduction in life expectancy and serious health due to airport generated particulate air pollution?

Do you have any plans to mitigate the amount of particulate air pollution and its affects in Thanet?

My first initial questions related to water pollution.

Manston sits on top of the Thanet chalk aquifer, which for the layman means, the chalk can be seen like a large sponge, sitting on top of clay which is impervious and surrounded by seawater which holds the freshwater - gathered from the rain falling in Thanet - in place.  Although the water moves up and down freely, it hardly moves sideways at all.

Water is collected for the Thanet water supply by digging a well with a side tunnel under the water level, called an adit. One such adit runs most of the length of Manston runway, deep under the runway. Water sourced from the Manston catchment is also drawn from agricultural boreholes and used untreated for irrigation and food crop washing.

This means that the Manston runway can be considered as sitting on top of one of Thanet’s essential drinking water reservoirs. Thanet's potable (drinkable) water is blend of water from Plucks gutter (river Stour).  Lord of the Manor Source Protection Zone (SPZ) 1 and from the Wingham Well.  It's all then held at the Southern Water works near the Airport.  The Source Protection Zone (SPZ) 2 lies within the Manston site.  Dilution of potable water is becoming less and less available and more expensive, Southern Water and the EA say the Manston aquifer is essential to maintaining the Thanet water Supply.

Manston Runway and the majority of the hard standing was supposed to be drained into the sea at Pegwell Bay. In practice the pipe was a concrete sectional pipe and leaked at every join, meaning that in reality the drainage was into the aquifer south of Manston and dispersed by the pipe. 

At the consultation your environmental spokesperson assured me that the pipe would be lined with plastic.

I would imagine a worst-case scenario would be a spillage (of say 50,000 litres of jet engine fuel) on the grassed part of the site caused an air crash.

Have you in the first instance examined the water source protection safety measures taken at other airports that lie on top of essential drinking water aquifers?

Do you have an air accident fuel spillage a strategy?

Have you factored in the air accident fuel spillage environmental cleanup costs? 


  1. Michael, I noticed in the scoping doc p.16 that, regarding the allowing of water discharge to Pegwell Bay, the 'permit lapsed upon dissolution of the
    previous operators of the site, and that a new environmental permit
    would need to be sought by any new site operators.' I would have thought its status as a National Nature Reserve and Sssi could cause problems in that regard.

  2. LHA depends on the water treatment, when I asked at the consultation they said deicer through balancing ponds and oil through interceptors, which should make it ok if they are big enough.

    The real problem is a big spill during a rain storm, meaning that there has to room for the rain as well as the contaminant, especially if you can't separate it by it having a significantly different specific gravity to water. Works better for oil than antifreeze in laymens terms.

  3. Michael, you seem concerned about water pollution yet forget the site was used for aviation for 99 years up until its closure in 2014. I'm sure RiverOak will have contingency plans for aviation fuel spillage (from a crash, etc) just like the RAF, USAF, etc had. Considered the possible water pollution that could result from 2500 houses, and up to 5000 cars, being on the site? SHP have not accurately calculated the impact of waste water and sewage (as noted by Southern Water in their objection to the SHP plans) let alone the possibility of engine oil or petrol spillages. Add to that the industrial estate they also plan; there is an equal risk of the water table being compromised by this too.

    Far better to have the airport used for what it was originally built for, with the usual safeguards against water pollution, and have the maximum grassland available for rainfall to replenish the water table, than the plans for building a housing and industrial estate that will minimise this grassland area plus increase the risk of water pollution.

  4. Neil not really I went to the Environment Agency, Southern Water, Infratil consultations relating the issues relating to the airport drainage.

    The was basically that the airport operator wanted to get a proper planning consent for the airport so they could expand it as operating under just a S106 meant that they couldn’t.

    What they needed was an EP (Environmental Permit) to get the planning consent and the EA wouldn’t grant one until several million pounds had been spent on the drainage.

    Housing on the aquifer isn’t an issue as there is a lot already on aquifers and it is just a matter of building regs.

    The water pollution issue that concerns me relates not to a conventional airport but an airfreight hub and dismantling facility.

    On the air pollution front it is the particulate air pollution generated by freight aircraft for one movement (1 tonne of avderv burnt during 1 747 type moment landing or takeoff) related to particulate air pollution dispersal and the background level.

    I have had various discussions with RiverOak’s environmental consultants and they are working on the issue.

    Road traffic air pollution looks to be fairly similar with either freight hub or mixed use residential and light industrial.


Please note comments that may be libellous, comments that may be construed as offensive, anonymous derogatory comments about real people, comments baiting internet trolls, comments saying that an anonymous comment was made by a named real person, boring comments and spam comments, comments in CAPs will be deleted. Playground stuff like calling real people by their time stamp or surname alone, referring to groups as gangs, old duffers and so on will result in deletion. Comment that may be construed as offensive to minority groups is not allowed here either, so think before you write it, remember that the internet is a public place, that it is very difficult to be truly anonymous and that everyone who uses it leaves a trail of some sort. Also note the facility to leave anonymous comment will be turned of during periods when I am unable to monitor comment, this will not affect people commenting who are signed on to their blogger accounts. When things are particularly difficult on the commercial spam front I may turn comment moderation on for periods.

If you feel that someone has left a comment that is offensive and directed at you personally please email me (link on the sidebar) asking to have it removed, you will need to tell which post and the date and timestamp of the offending comment. Please do not reply to the offending comment as I will assume you continuing the dialogue as meaning that you want the comments left there.