Old Ramsgate photos, trying to make sense of the Manston DCO environmental assessment

 Here I am posting on the blog again, bit of a moan, another crack at trying to get some sense out of the RiverOak RSP people and anything else that comes to mind.

Fortuitously there is a pile of local postcards here, so some of the writing doesn't have to be mine. 

FaceBook and probably the other social media sites that I don't understand at all get more difficult every week, and this makes posting on the blog more difficult. A few years ago the Thanet internet mostly happened on blogs, now I think the local people with an interest in local history are trying to put their photos online and look at other people's photos on social media, mostly facebook.

On the other hand, and apart from four fingers and a thumb, FaceBook is primarily trying to extract money from people with advertising, while dodgy people have infested it like fleas.

Blogger has problems of its own, but at the moment at least seem to let you put up reasonable sized pictures. Part of the problem is that blogger is owned by Google and some sort of regulator stopped Google from prioritising their own sites in their search engine.

Of course Google are trying to make you look at advertising too so blogs like mine with no advertising on have stopped getting any ranking in the google search engine because they don't make money.

 Bookshop wise today some fairly unusual Penguins
This is the link

 I guess this is far enough down the blog for the Manston bit. The main issue with Manston is that the minimum activity to qualify for a DCO is 10,000 airfreight movements per year, which means burning around 30 kilotonnes of jet fuel on or near the ground in Thanet per year.

I don't think this figure is disputed by anyone, and as this fuel is burnt by jet engines there isn't any way to filter out the tiny 2.5 micron particles that kill people and cause the early onset of dementia.

So how the DCO environmental assessment handles the problem is fairly important to those of us who live here, I guess the recent fire at Westwood near to Manston was a bit of an indicator, if you could smell it then the particulates reached you.

With the prevailing wind direction it's Margate, Broadstairs and the villages on the north Thanet coast that get the worst of it.

So how are RSP RiverOak handling the problem of these little particles called PM2.5s?

Well as far as I can understand they seem to be saying that they behave in a different way to the way they do, essentially they seem to be saying they land on the ground within less than a mile and therefore people won't breath them in.

It's a fundamental flaw, like saying bananas are orange and oranges are yellow.

this is their latest email to me.

-----Original Message-----
From: manston@communityrelations.co.uk
To: michaelchild@aol.com
CC: manstonairport@pins.gsi.gov.uk ; manstonconsultation@bdb-law.co.uk ; manston@communityrelations.co.uk
Sent: Thu, 29 Nov 2018 12:33
Subject: RE: clarification about the dispersion

Dear Mr Child,

It is not clear to us whether the “dispersion figures” you ask for are graphs used for calculating concentrations, or a means of presenting the calculated concentrations, and so we respond on both of these points below.

If the first: we have not used a simple concentration/distance relationship to calculate concentrations. Instead, we use a software tool called ADMS, which calculates the transport and dispersion of pollution taking into account different wind speeds and directions as well as different amounts of turbulent mixing in the atmosphere from hour to hour. It uses five years of historical weather data, measured at the Manston Met Office station. This provides a high degree of accuracy in our forecast results.

If the second: Presenting concentrations as a line graph as a function of distance from the source is sometimes done for certain types of assessment, such as accidental releases of hazardous material to air from a point source. However, presenting results like this does not account for the difference in wind direction over the course of a year. For an accidental release, which is of short duration, it is common to make the worst-case assumption that the wind is blowing towards the sensitive receptors for the whole duration of the release. For sources where emissions occur throughout the year, such as at Manston Airport, this is not a sensible assumption.

In addition, the emissions from Manston Airport will come from several moving sources spread over several square kilometres, so the concept of “distance from the source” does not work well in this case.

Therefore, the usual graphical way of presenting the effects of dispersion is as contour plots of concentration. The concentration in ug/m3 at a given location (e.g. a residential property) can be read off the contour plot and compared against the legal limits or health guidance recommendations. Suitable contour plots for PM₁₀ and PM_2.5 are given in the Environmental Statement (ES) as Figures 6.16 to 6.19 (which can be found here:https://infrastructure.planninginspectorate.gov.uk/wp-content/ipc/uploads/projects/TR020002/TR020002-002414-5.2-4%20-%20Environmental%20Statement%20-%20Figures%20-%205%20of%207%20-%20Figures%204.1-9.6.pdf). These are in addition to the tables of concentrations at specific locations, chosen to include places where people are most likely to be exposed, also included in the ES – see Sections 6.8 to 6.10 of the ES for those locations where the impact is greatest, and Appendix 6.5 for the full set of modelled locations.  (Section 6.8 to 6.10 can be found here: https://infrastructure.planninginspectorate.gov.uk/wp-content/ipc/uploads/projects/TR020002/TR020002-002407-5.2-1%20-%20Environmental%20Statement%20-%20Main%20Text%20-%20Chapters%201-10.pdf , and Appendix 6.5 here:https://infrastructure.planninginspectorate.gov.uk/wp-content/ipc/uploads/projects/TR020002/TR020002-002418-5.2-6%20-%20Environmental%20Statement%20-%20Volume%206%20-%20Appendices%201.4-7.2.pdf.)

Regards,

RiverOak Strategic Partners

Manston Airport consultation team

0800 030 4137

And my reply to it. 

From: michaelchild
To: manston
CC: manstonairport ; manstonconsultation
Sent: Mon, 3 Dec 2018 13:07
Subject: Re: clarification about the dispersion

Hi RiverOak, Manston Airport Consultation Team.

Many thanks for your prompt reply.

I have already studied these documents and assumed there must be something else I had missed elsewhere in the application.  

I am assuming that you understand that there is a very large difference between the distance pm10s and pm2.5s travel when airborne.

Any simple non scientific explanation will express this.

Here is a link to the explanation on the US Environmental Protection agency website

https://cfpub.epa.gov/roe/indicator_pdf.cfm?i=19

And the relevant quote from it.

“Particles within the two size ranges behave differently in the atmosphere. PM2.5, or fine particles, can remain airborne for long periods and travel hundreds of miles. Coarse particles, or the subset of PM10 that is larger than 2.5 μm, do not remain airborne as long and their spatial impact is typically limited because they tend to deposit on the ground downwind of emissions sources.”

The various figures you quote for PM2.5s seem to take the dispersion distance from the fuel burn to be about 1 km max i.e. the distance for PM10s.

So to repeat with further clarification.

“I am seeking clarification about the dispersion figures you are using for airborne particulates, this would normally be expressed as µg/m3 against km from source, often presented in the form of a graph, could you kindly give me the figures you are using both for PM10 and PM2.5 particulates.”

I will be happy with the figure you are using for both PM10s and PM2.5s in km from the point of burn to 10% above background level if you are unable to provide dispersion graphs for both particle sizes.  

Best regards Michael  

How you correspond with them over this type of thing has been a tricky one all down the line, having used a very complicated computer program they seem to happy with the result. Essentially though if you tell a computer that bananas are orange and then are happy with the result it produces based on this information, it is very hard to talk about yellow bananas with you. 

Digging up the Pleasurama Mountain a Minor Manston update

Note how the digger appears to produce a flock of birds - there may be an analogy, I did make the animation from pictures taken late this afternoon.

pins answers to my questions are in red


From: Manston Airport
To: michaelchild
Sent: Fri, 8 Jun 2018 17:22
Subject: RE: Manston DCO

Dear Mr Child

Thank you for your email.

“Now the application has been withdrawn does this mean that it should be seen as at the pre application stage again?”

If an application is withdrawn at the Acceptance stage, and the Applicant clearly states its intention to resubmit at some time in the future, the project stage is moved back to ‘Pre-application’. This is indicated on the project status bar located on the top right of the Manston Airport project webpage.

“If so does this mean that as a person who would be affected by the development I should be maintaining a dialogue with both pins and with the applicant, or should I view the application as over until such time as the applicant starts the application again with a revised PEIR and consultation?”

Until an application is resubmitted, the Applicant should be your first point of contact. It will be for the Applicant to take a view about whether any further consultation and/ or revised documentation will be required before the application is resubmitted.

“Did pins receive an application fee as part of the application process that stopped just before the deadline?”

The Acceptance fee (£6,939) was paid by the Applicant, and is non-refundable. Any resubmitted application will be a new application for the purposes of the Regulations, and will attract a second Acceptance fee.

“The largest figure mentioned in the advice note is 83,222 ATMs, is this meant to be an annual figure? If it is it would mean 228 ATMs a day and wouldn’t seem viable given the infrastructure, history or the environmental implications.”

83,222 ATMs is an annual figure. Please contact the Applicant directly for more information on matters relating to the design and operational capability of its Proposed Development. The Planning Inspectorate cannot prejudge what any future resubmission may comprise.

“With the existing freight capabilities of the airport I am assuming that a baseline of the previous CAA licence which I think was in 23,000 ATMs ballpark would be a significant factor, could you please confirm that this figure is approximately right?”

The Planning Inspectorate does not hold this information. Please contact the former licence holder.

Kind regards

James

Manston Airport Case Team

Temple Quay House, Temple Quay, Bristol BS1 6PN
Helpline: 0303 444 5000
Email: ManstonAirport@pins.gsi.gov.uk

Web: https://infrastructure.planninginspectorate.gov.uk/ (National Infrastructure Planning)

Web: www.gov.uk/government/organisations/planning-inspectorate (The Planning Inspectorate)

Twitter: @PINSgov

I hope I asked useful questions withing the obvious criteria that pins are hevily restricted in what they can say. 

this is the full text of my email to pins 

"Sent: 08 June 2018 13:03
To: Manston Airport
Subject: Manston DCO

Hi Manston DCO team at pins

Could you kindly clarify the situation with some aspects of the RSP DCO for me, or failing that tell me who I should be asking?

Now the application has been withdrawn does this mean that it should be seen as at the pre application stage again?

If so does this mean that as a person who would be affected by the development I should be maintaining a diaogue with both pins and with the applicant, or should I view the application as over until such time as the applicant starts the application again with a revised PEIR and consultation?

Did pins receive an application fee as part of the application process that stopped just before the deadline?

I have read the pins advice note Meeting Update TR020002 and although I would doubt I properly understood it all and I am having considerable difficulty the ATM figures in it.

My understanding both from the application as described on the pins website “The upgrade and reopening of Manston Airport primarily as a cargo airport, with some passenger services, with a capacity of at least 12,000 air cargo movements per year.” and from attending the three RSP consultations, communicating with the applicant and with pins by email I formed the impression that is that something in the 12,000 ATMs ball park is what the project intended and not an expansion of the previous capacity. Am I mistaken in this assumption?

The largest figure mentioned in the advice note is 83,222 ATMs, is this meant to be an annual figure? If it is it would mean 228 ATMs a day and wouldn’t seem viable given the  infrastructure, history or the environmental implications.

I can see that pins main concern at this point would be the legal aspects of acceptance, but having the general impression of around 12,000 ATMs, which seems to be the sort of ballpark area that everyone I have discussed the project with assumed up until now. I am a bit concerned that the consultation process thus far was less informative than I had assumed.  

There is a sense in all of this that while pins can’t respond to questions about the project, you may consider commenting about what the project actually is. In terms of is it an intersection joining 2 major roads or 16?

There is also a sense in which pins seem to be instead of saying the project isn’t NSIP compliant, possibly by a factor of 8 times the project size, instead of rejecting the project pins appear to be trying unreasonably hard to help the applicant above and beyond the interested and affected parties.

With the existing freight capabilities of the airport I am assuming that a baseline of the previous CAA licence which I think was in 23,000 ATMs ballpark would be a significant factor, could you please confirm that this figure is approximately right?

Please appreciate in this instance I am not so much trying to ask pins if the figures arranged in some way make the project a NSIP but to gather the information to enable me to ask either pins or the applicant the right questions. One of which is is the project still seen as ongoing and front loaded?

Best regards Michael"

Manston Airport DCO update

The picture is of the Red Arrows at Manston in 1968

This mainly relates to the meeting between The Department for Transport and the DCO applicant RSP Riveroak Strategic Partners on 11th May 2018

Here is are the links to the documents on the pins website

Meeting Note 

Detailed record of the Inspectorate’s observations and advice.


OK early days in trying to understand what these documents mean

I think the main issue in the whole thing is about what constitutes a NSIP Nationally Significant Infrastructure Project and this boils down not to the size of the new RSP project but to the increase in size from when Manston was running before to what it would be after RSP had increased the amount of aircraft it could handle.

So I think that the planning inspectorate have taken the number of flights (strictly movements takeoff or landing) per year permitted under the previous CAA license around the 23,000 ball park and asked RSP to show they will increase the number to 33,000. Not worked it out yet but this looks around 60 flights a day probably with about 6 flights per night.

I think RSP took the Manston capacity as 0 and I don 't think this will work.

I also think that anyone who attended the consultations realised that there was an issue with notifying people that the consultations were happening, I think something went wrong with their postal drop, when I last discussed it with one of the RSP reps they seemed to have accepted that there had been a serious problem, but not worked out how serious.

For me all the way along the line one of the biggest difficulties has been that I can't find a good sound argument from anyone supporting RSPs plans. So mountains of technical guff, but simple stuff like why people wanting to fly themselves or freight would drive past the major London airports to Manston.

I think the funding statement is also a big hurdle for RSP I think they would have to prove that they had sufficient legitimately sourced money to at the very least buy the Manston site based on an open market valuation.

I see this as a very significant Thanet news story that none of the local news sites seem to be able to report, hardly anything on social media either.

Is this the end of the RSP DCO I wonder?

this is a blog post in progress

Sunday Ramble, photos old and new Ramsgate Canterbury Margate and inevitably the Manston DCO saga.

The main issue this week has been the withdrawal of the Development Consent Order to build an airfreight hub at Manston.

I think the most worrying factor here is that this DCO application was put together by a reasonably good and professional team with previous DCO experience and that the net result of the DCO process so far has been to change the Thanet District Council administration to Conservative and cause Thanet to produce no Local Plan giving something of a free for all for housing developers.

This (in big blue) is what the Planning Inspectorate have said so far:-

1. Any resubmission by the Applicant will be treated as a new application for the purposes of the process. The Planning Inspectorate would have up to 28 days to take its decision about whether the application could be accepted for examination.

2. The Planning Inspectorate called the Applicant’s legal representatives (BDB Law) on 1 May 2018, setting out its principal concerns in respect of the application documents. Those concerns included:

• An absence of sufficient information within the application documents upon which to the Planning Inspectorate could base a decision about whether the Proposed Development constitutes a Nationally Significant Infrastructure Project (NSIP) within the meaning in s23 of the Planning Act 2008.

• Gaps in the ecological, archaeological and ground investigation survey data presented within the Environmental Statement (ES) accompanying the application, which create uncertainty in the assessment of likely significant effects.

• Inconsistencies/ omissions in the noise and vibration assessment.

• The adequacy of the Transport Assessment accompanying the ES.

• The adequacy of the Funding Statement.

On 3 May 2018 a teleconference was held between the Planning Inspectorate, BDB Law and RiverOak Strategic Partners (RSP). During this teleconference the Planning Inspectorate repeated its principal concerns (above) in the presence of RSP, who confirmed their intention to withdraw the application. Subsequently the application was formally withdrawn by letter dated 4 May 2018.

Today (11 May 2018) a meeting took place between the Planning Inspectorate and the Applicant at which the Inspectorate provided more detailed s51 advice in respect of the concerns noted within the documents associated with the withdrawn application. A note of the meeting is being prepared and will be published in the usual way in due course.

Here is the link to this advice on the Planning Inspectorate’s website https://infrastructure.planninginspectorate.gov.uk/projects/south-east/manston-airport/?ipcsection=advice&ipcadvice=3755f4d631

Of course, we will have to wait to read the meeting note to grasp all of it, but with so much wrong with the application it is difficult not to assume that the applicant knew the application would fail when they submitted it and what has actually happened is what they set out to achieve. 

A few historic local pictures next 

The bookshop being closed on Sunday we went to Canterbury where we did some shopping and stuff. I spent about half the time in Chocolate Cafe and the other half in bookshops. While I am on the bookshop subject here is the link to the books that went out in the bookshop yesterday mostly children's Ladybird Books and books about old busses.

I took a few photos of Canterbury, here is the link 

Back to the DCO process I think the thing that hasn’t really been understood properly by people commenting about it, is that the process is front loaded and that this means that the applicant really has to have sorted out the issues before submitting the application.

I am assuming that the next stage will be another round of consultation with revised documents, but who knows they may just revise the documents but not consult anyone, as far as I can see Canterbury and Ramsgate councils didn't even get told about the last round of consultation, let alone get to the stage where RiverOak entered into some sort of dialogue with them.

Temporary withdrawal of Manston DCO application

RiverOak Strategic Partners has temporarily withdrawn its DCO application in respect of Manston Airport. This is not uncommon with DCOs and RSP is in dialogue with the Planning Inspectorate in order that the application can be resubmitted as soon as possible.

Click here to read the letter submitted to PINS on Friday 4 May.

http://rsp.co.uk/news/temporary-withdrawal-of-application/

Ms Susannah Guest
 The Planning Inspectorate
Temply Quay House Temple Quay
Bristol BS1 6PN
Your Ref Our Ref ADW/166055.0003 Date 4 May 2018
Dear Madam Manston Airport project reference TR020002 This letter is to notify you that our clients, RiverOak Strategic Partners Ltd, are withdrawing the application submitted on 10 April 2018 and are engaging with the Planning Inspectorate with a view to resubmission as soon as possible.

Yours faithfully

Bircham Dyson Bell LLP

This is a picture of a plane at Nash Road.

My understanding is that were RiverOak, RSP to apply for a DCO again they would have to start again. Of course where the intended result to be scuppering the local plan, which is a sort of developers charter, and changing the TDC administration to a Conservative one then the DCO application was very successful indeed.

This begs the question, was the application rejected? I guess the answer here is in the, did RiverOak suddenly decide that 11,000 pages wasn't enough or that they had made a mistake somewhere along the line and need to get busy with the tipex.

Decoding the latest Manston Airfreight Hub DCO news, some Margate pictures,

Since the clocks move to British Summer Time, it's light after work for me, this means I get out more but have less time for blogging.

(note the tilt in the horizon) No time you see.

Manston and the Development Consent Order is very prominent on the local social media at the moment. I think this is because up until the end of the first quarter of 2018 the information was that this would be submitted during the first quarter of 2018.

 Communications from RiverOak or RSP which are the firm that want to build the airfreight hub at Manston are not good. My own take here is that RSP are not a firm in the sense that we would understand. By this I mean they don’t have staff, offices, an address or anything that you would normally associate with a business.

This week they produced a press release, here is the link http://rsp.co.uk/news/riveroak-strategic-partners-confirms-breadth-of-herne-bay-consultation/ not as you would expect, “we are going to submit our DCO on such and such a date,” so what on earth does the press release mean?

 Well the DCO wosisname is supposed to be what the government call front loaded - translated from gov speak this means - all the stuff that would be sorted out, op council, by the planning department, needs to be sorted out by a process of consultation, inclusion and most of all involvement of the local councils.

 This consultation, public involvement and inclusion process worked out, managed and overseen by the local council whose patch the project it is on, with considerable involvement of the other councils whose patch will be effected. 

Anyway two of the councils whose patch is effected are Ramsgate Town Council and Canterbury City Council.

 The idea would be that RSP work closely with these councils at the consultation stage with TDC and RSP jointly managing and coordinating the process.

 What seems to happen in practice is that RSP's solicitors send a letter to TDC and then just fail to communicate further with TDC, producing a rather bizarre statement on the council's website.

 Then the other day Canterbury Council that runs Herne Bay (on the flight path) say they haven't heard anything from RSP about the 2018 consultation at all.

 I am trying to keep the links to a minimum and make this into a story that is easy to follow, RSP have twice produced thousands of pages of consultation documents as downloadable pdf files that normal computers are unable to run properly.

 But what they have failed to do is to produce a straightforward consultation website, this means that virtually no one has actually read the consultation documents, the people who say they are for the airfreight hub and the people who say they are against it.

 It also means that as local people and organisations battle with the documents, they discover whole rafts of information that just does not make sense.

 The latest of these seems to to be The Ramsgate Society.

 I think much of the problem is that while RSP respond to letters and emails, they don't actiually reply to them.

 I think that RSP think that providing they tick the right legal boxes then the DCO will go through, the government will take the land from the current owners and give it to RSP.

 For all I know this may be the case.

 Margate for us yesterday evening.

 So plenty of photos.

 anyway some of the pictures of Margate yesterday evening, they should expand if you click on them