Sunday, 16 July 2017

A bit of the Canterbury blitz and a minor ramble Manston draft consultation response 2

I bought a publication today that was published in 1942 about the bombing in Canterbury on 1st June 1942, I am assuming that the copyright has expired on this and so am putting some of the pictures here to mark the 75th anniversary albeit belatedly.

I spent most of today in Canterbury, hence the purchase, some of the time I spent fiddling with my watercolour from the downstairs window of Chocolate Café. This was mostly hazily sketching in figures so that perhaps a couple of watercolours down the line I can produce something that shows the perspective and gives the feel of the café customers in the foreground and the people in the distance.

I haven’t had much time for painting recently and it was a very pleasant bit of relaxation today, as well as the bookshop being busy at the moment I have this difficult and complex Manston DCO consultation which has to be competed and submitted by next weekend.  

Despite rsp emailing me promising to look into the problems with their consultation website not working properly, nothing has happened to improve it. Important webpages only show even numbered pages of documents for example.

As with my draft response to the business case, see I have published my draft about the noise compensation issue below. I should stress here that this is a daft and that any useful input would be helpful.     

Manston Airport DCO Consultation Draft response Noise Pollution and Compensation

My understanding from the PIER assumed flight paths, aircraft, engine types and so on is that.

1 The flight path over Ramsgate has to remain the same and changes to flight paths which may happen during later stages after the DCO submission will have no significant affect on overflying Ramsgate.

2 That the noise impact on homes and businesses within Ramsgate will be significant and that plans to mitigate them should be at a fairly advanced stage prior to DCO submission as the DCO process is front-loaded.

3 That aircraft noise mitigation in airport expansion is mostly a matter of compensation and as an application for a DCO that would authorise CA must be accompanied by a Funding Statement which should demonstrate that adequate funding is likely to be available to enable the CA within the statutory period following the DCO being made, and that the resource implications of a possible acquisition resulting from a blight notices should have been taken account of, I am therfore assuming that the whole compensation issue has to be presented in one consultation response.

4 That the issues related to the Ramsgate conservation zone and the number of listed buildings likely to be affected by noise should by this stage have been at least partially addressed in order to approximately assess sound insulation and cost with a view to determining compensation levels related to the resource implications. 

5 That negotiation related to sound insulation within the conservation area between rsp, English Heritage and TDC conservation officers is already occurring.

Due to issues with accessing the PEIR documents and consultation website, see my emails, ref (Ross RiverOak Strategic Partners Manston Airport consultation team) I am uncertain that I have managed to view all of the consultation documents. So please accept my apologies for saying that documents that should be there are missing are actually there, if this is the case.

Obviously I am no expert in airport expansion DCOs and have only been able to find examples of two which are expected to be submitted in the UK one being this Manston one and the other being for the third runway at Heathrow.

In terms of percentage expansion and therefore the difference to historic noise disruption the Manston project would the by far the greater civil aviation expansion based on previous activity at Manston.

In view of the front loaded nature of the DCO process and the expectation that there would only be small and unavoidable change after the application stage I had expected the PIER to be more compete in terms of already addressing solutions to known and fundamentally unalterable environmental problems.

Previous submissions for Manston expansion have included noise contour maps for unavoidable parts of the fightpaths, most especially related to the necessity to overfly the densely populated town of Ramsgate because of the location of the runway. I have been unable to find these within the PEIR. 

A comprehensive noise pollution plan would seem to be particularly important as the possibility of nighttime flying appears to be envisaged as part of the application.  

Although the Heathrow expansion is at an earlier stage in progressing towards the DCO I am assuming that their noise mitigation and compensation package would be broadly similar to the Manston one. Although I suppose that as Thanet is an economically depressed area and therefore has higher levels of poverty some less comprehensive scheme may be envisaged related to the population being poorer with lower levels of employment and home ownership.

I also asked about the funding and compensation issue at the previous non statutory consultation and followed this up by email to pins 5.8.2016, the pins advice encouraged me to write to RiverOak which resulted in an email correspondence between me and rsp director George Yerrall who said, email 32.8.2016:-

“Dear Michael,

Thank you for your patience in awaiting my response.  I was away on vacation with my family and I try to “unplug” when I am away.

Your list of questions is hard for me to process as it contains numerous requests to respond to something said to you by a “RiverOak rep” as well as a number of assumptions you have made that seem factually difficult to understand such as your assumption that the airport would be “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.”

However, as you know, the PINS consultation process is very transparent and all of your issues will be addressed and published in due time.  I understand that waiting for answers can be frustrating and that is not my intent.

Thank you again for your patience and I look forward to addressing all of your concerns in the near future.

Best regards,


From this I inferred that the statutory consultation document pack and website would contain, a site compensation plan, blight compensation plan, noise compensation or draft noise compensation plan. Having failed to find anything and having had no response from rsp about the issues with the consultation website and documents, I am providing the link to the Heathrow noise compensation plan for your information

Added to this would be the airport site value compensation I understand this is 283 hectares, designated brownfield. Independent valuation puts southeast non agricultural land prices, residential in the av £4m per hectare ballpark with the lowest in Dover at about £1.75m and industrial in the £1.1m ballpark. My assumption from your airfreight hub job forecasts is that your own assessment of the potential site value would be seen as profitable commercial, so that you would see the minimum site value as nearest equating to industrial. This would put your assessment of the minimum site value in the area of £300m, with the worst-case scenario rising to cover those parts of the site that the current owners intend for residential use being considerably higher. There is also the of course the situation where the airport was available as a failing business with no alternative viable commercial plans and could probably have been bought in the £10m ballpark so I assume this could be taken as a quasi best case scenario

In trying to comprehend how the CA and potential blight acquisition compensation could be covered by provably legitimately sourced investment that would be acceptable to the DFT and enable the publication of a transparent funding statement, which is an integral part of a DCO requiring CA, I have drawn some conclusions.  My understanding is that rsp isn’t an aviation company but an investment conduit and I find it difficult to see major investors attracted to a project with uncosted and potentially open-ended compensation liabilities. I am therefore assuming that potential investment, in the event of the airfreight hub scheme failing, would be covered by the potential residential site value of what I understand to be a brownfield site. I am also assuming that any blight acquisitions would increase in value considerably were this to happen.

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