Since my damascene conversion and support for the vast
majority of local people who are prepared to sacrifice part of their lives,
their mental and physical health for a new airfreight hub at Manston, my
interest in the consultation process is unwavering.
To quote RiverOak aka RSP in their 2018 Preliminary
Environmental Impact Study (non technical summery) 1.1.108 “There is health
evidence drawn from the scientific literature that allows potential impacts on
mortality and rates of certain diseases due to changes in noise and air
pollutant exposure to be predicted quantitatively (in numerical terms). The
scientific evidence shows that, depending on the level of noise or air
pollution concentration, these may affect diseases of the heart, lungs and
circulation system, mental health and wellbeing, and the overall risk of
premature death.”
Bring it on I say, our forefathers made great sacrifices in
two world wars from Manston and I am looking forward to making my own small
sacrifice for the future of air cargo.
Oddly enough everything on the Manston DCO front seems to
have gone a bit quiet so I thought it a good time to publish my correspondence
with pins about the difficulty I had with the consultation process.
To expand on this, I had hoped that my own small
contribution would help to shape the great new cargo hub, but sadly I had great
difficulty with the consultation process, particularly with using the document
pack.
You may find this difficult to believe but there are a group
of local people, well to be honest most of the don’t seem to be Thanet born and
bred, who are not keen on suffering a debilitating disease, followed by
premature death and they are actually against the DCO process.
I should stress here that this post isn't about the pros and cons of the DCO but about the process being very difficult and you will see near the end of the correspondence pins do seem so suggest that expert advice may be available.
The
upgrade and reopening of Manston Airport primarily as a
cargo airport
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Mon, 26 Feb 2018 13:32
From michaelchild michaelchild@aol.com
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To
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manstonairport manstonairport@pins.gsi.gov.uk
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Dear Manston DCO pins team
I am
writing to you to complain about the Manston DCO consultation process, mainly
because it doesn’t seem to have been consultation process engaging with local
people to produce a viable and broadly acceptable project, but a promotional
exercise preconceived and broadly inflexible for an airfreight hub. The
approach has been much more like a conventional planning application that a
front-loaded DCO application with appropriate public engagement.
You will
have received my emails about this Fri, 16 Feb 2018 16:39 to the applicant and
Mon, 19 Feb 2018 16:26 to Iain Livingston TDC, as I copied them to you you.
As I
haven’t had replies to either of them I am now writing to pins.
With the
applicant this 2018 consultation seems to me to be just another case of talking
into the void, where one would normally expected a response leading to a
dialogue that would have produced solutions or partial solutions.
For
example, the issue of the website being published as unsearchable images of pdf
files, which could only be downloaded to become active, but when downloaded
were too big to run concurrently on any normal ITC could and would obviously
have been best solved by writing a navigable and indexed website, but could
have been partially solved by publishing them online as searchable pdf files.
In the same way as pins and virtually every other organisation published pdfs
online.
This
could easily have been done using fast reliable and cheap hosting and at the
very least the titles that appear on the document could have been included next
to the links as some aid to navigation.
As such
hosting will run in most internet browsers it means that all of the documents
can be run concurrently in different tabs and the computing memory and
processing is transferred to the hosting server. Obvious the main remaining
issues are that there is no index, normal website organisation and each tab can
only be searched individually and no the whole PEIR.
I have
done this as an example using the Google Drive hosting facility, which in this
instance costs about £5 for a month.
This
would at least have meant most local people could have run the consultation
documents on most of their devices. As it was I don’t really think that anyone
could use the PEIR document in any meaningful way, statutory consultees and
pins included.
Of course
if pins have found a way of running the PEIR documents on a computer in a way
that would have allowed any normal employed person with a reasonable amount of
spare leisure time to devote to responding to the consultation then could you
please tell me how this could be done?
Could
pins get their own itc department to look at the way the documents were
published, particularly in terms of the deliberately making the documents
difficult to use?
From my
point of view the applicant is also abusing the DCO application system by
failing to reply in any meaningful way to feedback made by respondents both
questions about the project but also to questions about the consultation
process.
The
overall affect of this failure to reply meaningfully, when combined with the
number of consultations, three so far and producing the documents in an
inaccessible way, is to deter people from engaging in the consultation
process.
I think
it should be understood that Ramsgate, which is the main concentration of
population that would be affected by the project contains some wards, which are
not only among the most deprived in Kent but in the whole of the UK.
This
means that many of the people who are likely to be affected will be less able
to engage than would normally be the case and my feeling are the information
and consultation sessions should have been held in the town centre, with very
clear descriptions of both the projects benefits and disadvantages.
Holding
the only consultation session in a hotel in one of the more salubrious
residential parts of the town has connotations of the Savoy Grill being open to
everyone, but everyone doesn’t use it in the way the would use say McDonalds.
I think
this constitutes a deprivation accessibility issue, which should be addressed
properly now and I wish to complain that this hasn’t happened, I feel that pins
and all government departments should be proactively addressing depravation and
should like your view on this issue.
While
publishing notifications in newspapers and on the applicant’s website sounds like
a good method of promoting the consultation, local papers here now have a
significantly lower circulation than was once was the case, with free paper
delivery no longer occurring. Distributing posters and leaflets to shops, pubs,
local information centre, hotels etc is now the norm and this didn’t happen
with any of the consultation events or general notification of the
consultation.
I also
believe that something went badly wrong with the leaflet distribution, as far
as I have been able to ascertain virtually no one actually receive a leaflet
and the leaflets apparently contained no details of the negative effects
related to the project.
Obviously
as the applicant’s own documentation contains details of severe and adverse
changes to life, this is a quote from the 2018 PEIR:- "in year 20,
significant adverse effects have been identified as being likely a result of an
increase in noise in the following communities which are in the vicinity of the
airport and flight paths: Ramsgate;„ Manston;„ Wade;„ West
Stourmouth; and„ Pegwell Bay.„ 1.1.83 In these communities aircraft noise
would increase to the point where there would be a perceived change in quality
of life for occupants of buildings in these communities or a perceived change
in the acoustic character of shared open spaces within these communities."
With this
in mind one would expect the local MPs to be actively helping local people to
understand and respond to the consultation, as it is one has an aviation
business and the other introduced the applicant to the local community.
The
future adverse affects will already be having an effect on the values of
properties and business in the above areas, partly because of the consultation
method not being clear and decisive and containing a comprehensive future
compensation plan that would protect future property and business values,
should compensation for this issue now be sought from pins or the applicant?
Obviously
I am aware that this is the first time that a DCO has been used for a project
affecting such a large number of people and the first time it has been used for
a major airfreight facility so one would expect issues. I am however becoming
concerned that the DCO process is proving unfit for this purpose, particularly
in terms of the effects of future property blight and the time taken by people
having to respond repeatedly to a poorly presented consultation process.
In view
of the size and scope of the project and its effects could you kindly set out
how the issue of compensation for time spent on responding repeatedly and
property blight will be addressed, both in terms of time scale and how to apply
for it.
In a
general sense I also think that pins should be making some effort to engage
with and support residents, particularly those in the most deprived wards
affected, who may neither be able to use the internet or understand the
implications of the application.
I think
it should be understood that our local council are in a state of some disarray,
mainly because of the ongoing DCO application, having rejected the local plan,
has just had the majority party split, leader resign and appear to be under
funded or resourced to properly assist people with the consultation process,
both in terms of depravation accessibility issues and problems related to
inadequacy of the consultation process. This is highlighted by the absence of
any reply to my email to them.
While I don’t think it was
the intention of the DCO process to destabilise local government, this is what
appears to have happened and appears to be just another costly aspect, which I
assume will ultimately appear as a rise in council tax.
Best regards Michael
To
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michaelchild michaelchild@aol.com
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CC
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Manston Airport ManstonAirport@pins.gsi.gov.uk
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Slideshow
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Dear Michael
Thank
you for your email.
As
you are aware, if an application is submitted, this and your previous
correspondences can be considered by the Secretary of State in addition to the
statutory acceptance tests.
“Could
pins get their own itc department to look at the way the documents were
published, particularly in terms of the deliberately making the documents
difficult to use?”
The
Planning Inspectorate cannot test the adequacy of an applicant’s consultation
until an application is submitted to it. The means by which the adequacy of
consultation can be tested are set out in section 55 of the Planning Act 2008
(PA2008).
“I
think this constitutes a deprivation accessibility issue, which should be
addressed properly now and I wish to complain that this hasn’t happened, I feel
that pins and all government departments should be proactively addressing
depravation and should like your view on this issue.”
“In
view of the size and scope of the project and its effects could you kindly set
out how the issue of compensation for time spent on responding repeatedly and
property blight will be addressed, both in terms of time scale and how to apply
for it.”
The
PA2008 regime recognises that a Nationally Significant Infrastructure Project
(NSIP) may create blight reducing land values. Section 175 of the PA2008 amends
Schedule 13 of the Town and Country Planning Act 1990 to enable owner occupiers
to serve a blight notice on the Secretary of State (SoS) requiring the SoS to
purchase their property in certain circumstances. These are where a National
Policy Statement (NPS) identifies a particular location as a potentially
suitable location for an NSIP (there is no NPS in this case) or if land is
blighted by an application being made for a Development Consent Order
authorising the Compulsory Acquisition of the owner occupier’s land or from
such authorisation being given.
Separately,
any interference with private interests may give rise to a right to make a
relevant claim. For further information see FAQ14 in our Community Consultation
FAQs and government guidance relating to Compulsory Acquisition procedures:
Kind
regards
Richard Price | National Infrastructure Case
Manager
Major Applications & Plans
Temple Quay House, Temple
Quay, Bristol BS1 6PN
Direct Line: 0303 444
5654
Helpline: 0303 444 5000
Re:
The upgrade and reopening of Manston Airport primarily as a
cargo airport
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Tue, 6 Mar 2018 16:50
michaelchild michaelchild@aol.comHide
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To
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ManstonAirport ManstonAirport@pins.gsi.gov.uk
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Slideshow
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Dear Richard
I think the issue that you haven’t replied to here is that the
application process itself, as distinct from the any blight caused by the
actual NSIP, is causing blight and other problems of its own.
Were this a conventional planning application for an airfreight
hub, I assume there would have been a distinct timeframe organised by the
planning authority, application, public enquiry, etc followed by a decision.
Most importantly there would have been some discernable end to the application
and the associated uncertainty.
As things are here, the timeframe of the preapplication stage
appears to be entirely dictated by the applicant and regardless of the result
of the application is having local impacts now.
We have now had two years of the applicant releasing contradictory
information into the local community and I am working on the assumption that
this can happen in perpetuity.
A prime example of this contradictory information is the night
flights issue, where for the bulk of this time the information has been there
will be no night flights, however in the latest PEIR they are applying for a
large nightime flying quota.
I am concerned by the application process’s impact on local
government here, I myself am not a supporter of leaving the EU so I didn’t vote
for UKIP, most local people who voted in the district council elections
however, did vote IKIP and until recently we had a UKIP administration at
Thanet Council, now we have a Conservative lead council.
It would appear that the root of this change of administration
stems from local councillors not properly understanding the situation relating
to the Manston site, CPO, CA, council cpo and therefore no longer being able to
agree enough to function as an administration.
More precise questions.
Can the preapplication stage continue in perpetuity?
Are there circumstances where pins can cause the applicant to
withdraw the application?
In terms of the deprivation issues relating to some parts of
Ramsgate that are on the direct flight path (within 1 to 4 km of the end of the
runway) and are also some of the most deprived wards in the uk, is there
anywhere the local community could look for expert support during the
preapplication and application stages?
Have there been any other DCO applications that have significant
similarities to the Manston one, that I could look at in terms of comparative
guidance?
Best
regards Michael
RE:
The upgrade and reopening of Manston Airport primarily as a
cargo airport
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Thu, 8 Mar 2018 14:56
Manston Airport ManstonAirport@pins.gsi.gov.ukHide
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To
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michaelchild michaelchild@aol.com
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CC
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Manston Airport ManstonAirport@pins.gsi.gov.uk
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Slideshow
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Dear Mr Child
Thank you for your email.
“Can the preapplication stage continue in perpetuity?”
“Are there circumstances where pins can cause the applicant to
withdraw the application?”
The Planning Inspectorate cannot compel an applicant to withdraw
an application. If an application is submitted to the Planning Inspectorate and
subsequently accepted for examination, it can only be:
· withdrawn by the Applicant; or
· decided, following due process, by the relevant Secretary of State.
“In terms of the deprivation issues relating to some parts of
Ramsgate that are on the direct flight path (within 1 to 4 km of the end of the
runway) and are also some of the most deprived wards in the uk, is there
anywhere the local community could look for expert support during the
preapplication and application stages?”
Any expert/ legal advice sought in respect of an application for
development consent would need to be procured by an individual/ interest group
or organisation by conventional means. Alternatively you could contact Planning Aid which offers
free independent, professional advice and support to individuals and local
communities wishing to engage in the planning process: http://www.rtpi.org.uk/planning-aid/
“Have there been any other DCO applications that have
significant similarities to the Manston one, that I could look at in terms of
comparative guidance?”
There have been no previous applications for development consent
made under s23 of the Planning Act 2008. However, most applications for
development consent will share similarities, to a greater or lesser extent, in
respect of the most common issues examined across the breadth of NSIP
development.
For decided applications a good place to start in identifying the
main issues that influenced an Examining Authority’s (ExA) consideration of the
case for development consent is, in each case, the respective ExA’s report to
the Secretary of State (SoS) and the subsequent decision and statement of
reasons issued by the SoS. ExA reports may assist in demonstrating to you, and
other members of the local community, how individuals and interest groups can
most helpfully and effectively make representations to an examination. Examples
of reports and decisions associated with all decided NSIP applications are
available to read on our website.
If you have any further questions about the process, please do not
hesitate to contact us again.
Kind regards
