Representation by Residents Against Night Flights (Residents Against Night Flights)
- Date submitted
- 7 October 2018
- Submitted by
- Members of the public/businesses
We strongly oppose the granting of a DCO 24/7 Freight Hub at Manston for the following reasons:
Night Flights
At the consultation in Ramsgate, in news media, through [Redacted] (MP), [Redacted] (MP) and via the local pro airport groups that they use to spread their message RSP are telling the public they don’t need/want night flights e.g.
[Redacted] (RSP): “. . . there are no plans for night flights”.
[Redacted] (RSP): “The old 106 restrictions meant there was no need for night flights apart from exceptional cases and we are not likely to need anything different.”
[Redacted] (MP): “To set the record straight RiverOak has confirmed that they have no plans to operate scheduled night flights.”
[Redacted] (MP): “. . . in respect of night flights, I have been assured by RiverOak Strategic Partners (RSP) that they are not engaged in any dialogue with carriers who want to operate at night and they plan to create more than enough infrastructure on the ground to accommodate all demand during daytime hours.”
Save Manston Airport Association: “They [RSP] spoke on night flights and they confirm they do not need night flights to make their plan work and they do not plan to have night flights.”
Yet the RSP DCO documentation seems to suggest otherwise:
“RiverOak’s business case is based on the potential need for night flights. . .”
“A cargo airport therefore needs more flexibility to allow the use of planes classified as QC4 at night. . .”
After reading RSP’s Noise Mitigation plan we are deeply worried that they intend to try to attract the bottom end of the cargo market by pricing themselves lower/undercutting other airports in terms of penalties for any carrier/freight plane that arrives late and into the night and allowing QC4 planes to fly in during the night period. The same QC4 not permitted to be scheduled, on noise grounds, for the night quota period at Heathrow. The same penalties which should be used to deter carriers, not attract them, and which are lower than those which were in place when the airport was previously operating.
Furthermore, RSP have suggested Manston is capable of handling 83,000 ATMs annually, yet they are basing their “worst case” noise assessment on a figure of 17,000 ATMs. Since there is no cap on the number of ATMs the figure of 17,000 is not the “worst case”.
We would also question RSPs noise modelling and how they have arrived at their figures, given the numbers they state are much lower and do not appear to be consistent with previous recorded noise levels when the airport was in operation. Previous independent noise experts commissioned by TDC concluded that “the populations predicted to be within the 85dB(A) contour by departures ranges from 14,722 people for MD11 departures up to 30,903 for Boeing 747-400”. Is this because RSP’s Noise Mitigation plan states that they will monitor noise 6.5km (2.5km out at sea) from roll out?
We are also concerned by the way in which RSP are assessing “significant effects of aircraft noise at night” through an “18 times a night” awakening metric.
Health and Well-Being
Given how close the airport is to Ramsgate, currently it begins 1.3km from the runway not 4km as stated by RSP and the height of planes flying over Ramsgate homes are so low, if the proposed development is allowed to go ahead a great many Ramsgate residents would suffer greatly with significant impacts to their health and well-being. RSP have stated that their proposals will have a detrimental impact on residents in their documentation:
“. . . significant adverse effects have been identified at the communities of Ramsgate, Pegwell Bay and Manston as a result of the proposed development. The effect would be characterised as a perceived change in the quality of life.”
Examining Authority
We would like the examining authority to look at why RSP’s DCO/business plan appears to be in direct conflict with what they are saying to the public - why is their business plan based on the potential need for night flights given that they have intimated/given a false impression that they do not need/want night flights for the airport to be successful in the press etc?
We would also like the examining authority to carry out an evaluation of RSPs approach to Noise Mitigation and the compensation that RSP have put forward for those who would be affected. If the development went ahead, we feel the proposals for mitigating noise are unrealistic and inadequate (comparing RSPs thresholds with where the Government says “Noticeable and intrusive noise occurs” (LOAEL)) and they do not cover the many thousands of people who are likely to be affected.
We would also ask for a full review of the impact the proposal will have on the health and well-being of the residents of Ramsgate and surrounding areas.
We believe the adverse effects on the communities of Ramsgate, Pegwell Bay, Manston and Herne Bay, as well as the impact on other areas e.g. tourism and the environment far outweigh the claimed economic benefits of the proposed development.