Manston Airport Consultation Response, Air Pollution.

Over the past year I have looked at the potential air pollution problem that we would get if we had an airfreight hub at Manston.

One reason for this is that I have felt for years that the Thanet air quality was worse than I expected for a coastal area. I put this partly down to the prevailing wind direction and the direction of the major roads, partly down to the landmass that the wind often blows across, in a sort of long way from Cornwall to Kent type of way, partly down to the proximity of industrial Europe, partly down to the wind blowing from the port of Dover.

Anecdotal evidence is a difficult one, but people seem to agree with me and no doubt people who read this will have their own thoughts.

Coming back to the Manston issue, from about a year ago I started totting up the amount of jet engine fuel that would be expected to be burnt at Manston, if it became a freight hub. I followed this through into the health implications and I suppose didn’t like or quite believe the answers.

I have tried the figures on different people including some who are very pro any sort of aviation at Manston and so far no one has come up with a counter argument.

In terms of advice about completing the consultation pins or The Department for Transport have just allocated a dedicated email address for the Manston DCO which is manstonairport@pins.gsi.gov.uk

The picture is of particulate pollution levels around Los Angeles Airport.

Here is my draft response to the air pollution part of the consultation

The main issue with construction of an airfreight hub at Manston would appear to be the recent life expectancy reduction issues related to particulate pollution, this is the problem that has lead to the national government considering a diesel car scappage scheme.

In a general sense the fuel used in jet engines produces similar particulate emissions to the fuel burnt in diesel road vehicles and the particulates produced from tyres landing on and running along runways similar problems to road vehicles.

Where particulate fuels are burnt in commercial transport mitigation in terms of emission filtration becomes more economically viable with the larger engines in lorries and shipping. For smaller vehicles, cars and vans the shorter term solution looks likely to be moving to petrol with the prospect that in about ten years we will have moved away from fossil fuels in private transport.  

In environmental terms this is a different but related problem to global warming, in simplistic terms the focus has moved from rising sea levels drowning people in a hundred years time, to particulates killing people in significant numbers now.

With jet engined planes as detailed in the PEIR there has been some progress very recently the most encouraging being recent work by NASA see https://www.nasa.gov/press-release/nasa-study-confirms-biofuels-reduce-jet-engine-pollution the underlying problem being that filtration isn’t an option.

Most of the available studies showing levels of particulates produced at airports have been made at Los Angeles airport LAX, when using them for comparison it is as well to remember that LAX is a very busy airport and that Los Angeles is already a very polluted city, so everything is as it were scaled up. In terms of visualising the issue Los Angels has approximately the same prevailing wind direction as Manston.

Current mitigation in the UK is mostly focused on a reduction in ground movement fuel burnt. 

Expectations in the shorter 3 to 7 year period will probably include the use of bio fuels and the relocation of some activity from airports upwind of densely populated areas. 

Expectations in the longer 8 to 15 year period may be focused on alternative fuels and fuel storage such as hydrogen and electric motors.

My efforts to discuss this problem with the RiverOak environmental team have been unsatisfactory so far, I tried at the previous non statutory consultation and was given a contact at Amec Foster Wheeler but have had no reply from him to my first email 10.7.7017 also sent to pins.

I attended the statutory consultation at Canterbury where the environmental team members I spoke to appeared to have no concept of the volume of fuel burnt at an airfreight hub and seemed to equate it to that burnt at a busy road junction.    

Obviously the expected fuel burn figures at Manston are contained in the PIER in great detail, but for anyone trying to understand the problem and who isn’t conversant with large engines I have added the following paragraph to help with approximation.

The metric tonne and the imperial ton are almost the same weight, there are 250 gallons of fuel to a ton or tonne. A 747 type plane burns approximately 5 litres or 1 gallon of fuel per second so cargo plane allowances are usually measured in tonnes. The takeoff allowance for a 747 is 2.5 tonnes and the ground movement (landing or takeoff) allowance around 1 tonne.

The proposed Manston site has been designed to minimise the ground movement time, but with the on the ground part of takeoff and landing I think it reasonable to assume that in excess of a tonne of fuel will be burnt on the ground for each movement.

To put this in some sort of proportion a large diesel car does about 40 miles to a gallon and a large lorry about 10 so when thinking in terms of government concerns over road junctions, a car would have to travel 10,000 miles to burn a tonne of fuel.

The minimum number of freight plane movements at Manston, for the Manston project to qualify for a DCO is 10,000 per year so it would follow that the intention is to burn more than 10,000 tons of jet engine fuel per year at the Manston site.

The complexities of increasing flying activity dovetailing with aircraft emissions reducing over future years makes calculating figures for reduced life expectancy from projected activity difficult.  

The most significant aspect is probably the greater than expected distance drift of the smaller and most harmful particles from LAX, the only airport where the measurements have been made and published in a fairly comprehensible way.

This combined with the increased mortality rates related to particulates described in the PEIR and on reputable websites such as wikipedia means the freight hub would result in the premature deaths of a significant number of local, people i.e. kill them.

Discounting all of the other factors but burning 10,000 tonnes of fuel on the ground between when landing aircraft’s wheels touch the runway and leave it on takeoff, which would seem to be a very modest assessment based on 10,000 movements. Taking Thanet’s population as around 125,000 mostly located to the north and east of Manston. Taking the prevailing wind direction to be between south-westerly and westerly. Considering that there really is no lower safe limit for airborne particulate pollution, however significant mortality levels like those found near road junctions are being taken in the 10 to 20% ballpark when considerably reduced life expectancy and diesel car scrappage is being discussed, so this looks like a significant issue.

Obviously in situations where the problem already exists and mitigation efforts have already started then those involved can be seen as applying duty of care and so on.

In terms of embarking on a major project in the face of current scientific information appearing to say that the project would kill a significant number of people, there may be matters related to, duty of care, precautionary principle, liability to litigation and so on that would apply.

I have avoided a long list of citations and links to online documents but for search and reference assistance, the first LAX particulates pollution results were gathered by and the main work was by USC Assistant Professor Scott Fruin 2014, the most recent publicly available results of corroboratory testing and research, which also has links to the important sources is now available on line, here is the link to it https://www.researchgate.net/publication/311395120_Emission_rates_of_particle_number_mass_and_black_carbon_by_the_Los_Angeles_International_Airport_LAX_and_its_impact_on_air_quality_in_Los_Angeles  

FB comment added to modify res

Georgina Rooke Hi Michael, as i'm sure you know i'm very sympathetic to your views. i guess the concern i always have though with the particulates / life expectancy angle is why would the government treat Manston and less densely populated towns in Thanet any differently to London and Londoners? I think one way to strengthen your argument is to remind the government that the majority of freight is shipped in the belly of passenger aircraft. in other words, if you looked at fuel burned per ton of cargo it would be marginal when carried by passenger planes compared to dedicated cargo planes, because those planes are flying anyway and the fuel being burned to carry the weight of the plane is being burned anyway to carry the passengers. In the case of dedicated cargo planes all the fuel (and therefore all the pollution) can be attributed solely to the freight so the 'pollution per tonne' is higher for dedicated cargo planes

This then becomes a much stronger argument I believe. The government should encourage use of passenger flights for cargo and discourage dedicated freight planes as a way to mitigate the risks of particulates until the industry can move to Biofuels.