Representation by Kent County Council (Kent County Council)
- Date submitted
- 8 October 2018
- Submitted by
- Local authorities
Following the decision made by the Secretary of State on 14 August 2018 to accept the application made by RiverOak Strategic Partners for examination, Kent County Council requests to be registered as an Interested Party.
In accordance with the Planning Inspectorate Advice Note 8.2 , this letter provides a summary of the points which Officers of the County Council agree and/ or disagree with about the application, alongside the main issues and impacts.
Highways and Transportation:
• The draft Thanet Local Plan - 2031 and its accompanying Transport Strategy must be a material consideration when assessing this application, particularly given the strategic significance of the Manston Airport site. At present, the Local Plan is given very little weight or consideration within the Transport Assessment .
• At this stage, the approach to transport modelling within the Transport Assessment is not considered to adequately assess future traffic conditions in line with expected growth patterns and infrastructure delivery.
• The proposed masterplan for the Northern Grass Area and wider highway mitigation proposals conflict with draft Strategic Routes Policy SP47 (within the draft Thanet Local Plan - 2031) that seeks to safeguard key road schemes and junction improvements to support the Thanet Transport Strategy.
• There is a concern that the proposed development will generate a material increase in traffic on already constrained highway links surrounding the site such as the B2050 Manston Road and Manston Court Road. This could lead to increased levels of vehicle conflict to the detriment of highway safety, amenity and the free flow of traffic.
• The trip generation and distribution methodology presented in the Transport Assessment are heavily based on assumptions which are not adequately justified or referenced to appropriate ‘real world’ examples in a number of cases; notably Heavy Goods Vehicle movement profiles and load factors, and airport staff shift patterns and staffing requirements. This limits the ability of the Local Highway Authority to comment on their validity with a sufficient degree of confidence and to assess the appropriateness of the proposed highway mitigation strategy.
• The mitigation strategy should be considered within the framework of the draft Thanet Local Plan - 2031 and its supporting Transport Strategy. The site and junction-specific – rather than strategic – approach to capacity assessment taken in the Transport Assessment is considered inappropriate, resulting in highway mitigation proposals that deliver only partial benefits, and which do not align with, or incorporate, the robust, long-term solutions proposed by the Thanet Transport Strategy.
The County Council, as Local Highway Authority, continues to actively engage with the applicant with a view to resolving these matters.
Heritage Conservation:
Archaeology
• Paragraph 9.3.8 states that the evaluation results have been used to inform the Environmental Statement. However, it is difficult to see where this is included within the overall baseline provided although short reference is made in table 9.8. Given the detailed information now available to the applicant, the County Council would expect greater use of the outputs to inform the discussion of the baseline.
• KCC recognises that the Northern Grass Area has not been accessible to the applicant for the field survey and evaluation that it regards as necessary to understand the implications of development in that area.
• Table 9-4 refers to a teleconference on the 25 May 2018 with [Redacted] of the KCC Heritage Conservation team. To clarify the position stated in that discussion:
- KCC accepts as stated that the applicant has not been able to access the site for survey and investigation works.
- The investigations for Stone Hill Park provide an adequate picture for the archaeology (on the south side of Manston Road), within the parameters of the Stone Hill Park planning application. Areas such as the location of the helicopter facility in the south east of the site, and the area proposed for HGV access and earthworks north of the western runway, were not tested through trial trenching but had significant geophysical survey results. In addition, the proposed masterplan sets out an extensive arable area proposed for a contractor’s main compound that has not been surveyed or evaluated.
- The wording in the Environmental Statement does not fully convey the position agreed. There is a need to survey and evaluate the Northern Grass Area prior to development. In the Northern Grass Area and areas of the airport which have yet to be evaluated, there remains the potential presence of archaeology of a significance that could require preservation in situ as the desirable outcome. KCC would accept that this can be achieved post determination, as long as there is sufficient - and perhaps substantial - flexibility in the development design to enable preservation to be achieved. The applicant explained in the teleconference that this can be achieved in the Northern Grass Area through reduction of the area of business development if required, as that would not compromise the overall position of airport development.
- Given the above, a DCO requirement should cover the need to preserve the archaeology including through adjustment of development parameters as well as covering the necessary stages of evaluation and investigation. The requirements should also cover extensive investigation of those areas of the airport where archaeology will be affected by development but is not to be preserved in situ. The County Council welcomes the intention to agree a Written Scheme of Investigation for future archaeological investigations.
• Table 9.9 includes an incorporated measure of “flexibility inherent in the masterplanning process following any further investigations and survey”. The applicant should demonstrate this flexibility to ensure that it is fully understood in the examination of the DCO.
• Section 9.8 discusses the significance of the archaeological baseline and has drawn on the results of the Stone Hill Park evaluation. KCC has agreed that whilst there are substantial areas of the Stone Hill Park findings that can be mitigated through investigation and recording, there are also areas identified for preservation in situ including a WWII anti-aircraft battery, the remains of a Roman enclosure possibly associated with the Caesar invasions and the barrow cemeteries on Telegraph Hill, which are likely to be more extensive than the two evaluated. Most of the features would potentially be preserved in the proposed masterplan although their significance needs to be highlighted so that they are considered as plans evolve.
• Paragraph 9.8.15 discusses the approach to flexibility to enable preservation in situ. It does not explain how a substantial area or feature of high significance would be accommodated in the development planning if found in the Northern Grass Area.
Built Heritage
• Section 9.9 refers to Built Heritage assets within the site. KCC recognises the limitations that access to the site has caused in terms of surveying heritage assets. However, it is difficult to understand what will be unavoidably affected by the proposed development and what may be retained. Reference is made to a table in Appendix 9.1 listing the features in the airfield and to the construction description which does not detail what may be demolished.
• The County Council welcomes the intention to retain the museums and memorial gardens and would support any enhancement opportunities that can be delivered. The connection of these to the built heritage in a holistic way to ensure the historic sense of place of the airfield is recognised and important. Demolition of historic structures should be avoided where possible.
Noise:
• Chapter 12 (para 12.5.8) of the Environmental Statement describes the measures in the Noise Mitigation Plan and one of these is a voluntary quota count system that is welcomed. The Annual Quota Count is 3,028 (this is for noise emissions, not number of movements, between 23:00 and 07:00). In comparison, Gatwick’s night noise quota for October 2017 - October 2018 is 8,200 (although 75% of this is for the summer season, operating 23:30 to 06:00). The latest proposed quota allowance at Manston is far lower than the originally proposed figure of 6,000 for the 23:00 - 07:00 period and this reduction is welcomed. The proposed quota equates to approximately 8 quota count points per night and given that the Environmental Statement (para 12.7.40) states the forecast is to handle 7 aircraft during a typically busy night period, this is a reasonable figure (given a QC/1 aircraft would use one of those points).
• The airport, if operational for freighters, is likely to see the noisier aircraft serve it and for this reason QC/4 aircraft are not banned at night. Again, for comparison, these would be twice as noisy as the noisiest aircraft that currently operate at night at Gatwick. It is appreciated that the proposed operating model for the airport may necessitate these noisier aircraft, but the airport should be responsive to any future complaints about night noise and try to schedule such aircraft sensitively, for example at the start or end of the night period to cause least disturbance. The proposed Consultative Committee would be a suitable vehicle for such discussions, and the commitment to a Community Trust Fund tied to fines due to noise infringements is welcomed. The Noise Mitigation Plan currently has no dates on it, so it would be useful to know how long the voluntary quota count system will apply and when it would be subject to review, including any potential increase in night movements.
• The Dwelling Relocation Scheme and Noise Dwelling Insulation Scheme are important offerings to the local community, especially given that many people will have moved into the area since the airport ceased to operate. Research into the health impacts of aircraft noise (and indeed other noise sources) has moved forward so significantly in recent years, and it has been shown that people are more sensitive to aviation noise than they have been before so the assistance provided by these schemes is proportionate to the impact on those affected households. The thresholds for these schemes meet the expectations of Government policy, but the airport operators are encouraged to go beyond these levels as other airports have done. For example, Gatwick’s noise insulation scheme applies to the 60 dB LAEQ 16hr contour (63 dB proposed here).
• At Year 20 in the daytime, 115 properties are forecast to be within the Significant Observable Adverse Effect Level (SOAEL) and 8 in the Unacceptable Adverse Effect Level (UAEL - meaning above 69 dB LAEQ 16hr). Insulation for those in the SOAEL will reduce the noise exposure and remove them from the ‘significant’ category, and the relocation scheme will apply to those in the UAEL. Given the relatively small number of those residents in the SOAEL (63 dB LAEQ 16hr) and that they may still experience adverse effects (some more so than others, and retaining significant effects in their garden and with open windows), consideration should be given to extending the relocation scheme to those dwellings on a discretionary basis if they are not within the formal scheme. It is also important to note that in the night period (23:00 - 07:00) there will be 16,465 dwellings in the Lowest Observable Adverse Effect Level (LOAEL - above 40 dB LAEQ 8hr and below 55 dB LAEQ 8hr) and 225 in the SOAEL (above 55 dB LAEQ 8hr).
• Overall, the Environmental Statement (para 12.7.72) has identified “… significant adverse effects” at Ramsgate, Manston, Wade and West Stourmouth and this is described as “… 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 during the night-time.” It is also important to remember that although perhaps not in the observable effect levels, when approaches from the east are in operation, communities to the north east (Whitstable, Herne Bay, etc.) may report noise disturbance, and when departures to the east are in operation communities to the south (Wingham, Eastry etc.) may be disturbed.
Biodiversity:
• The County Council previously commented on biodiversity matters in its response to the statutory (Section 42 Planning Act 2008) consultations and has not identified any significant changes following submission of the application to the Planning Inspectorate.
• KCC would strongly encourage the applicant to ensure that consideration of biodiversity is also informed by other relevant chapters of the Environmental Statement e.g. air quality, noise and vibration, and traffic and transport.
Freshwater environment
• As Lead Local Flood Authority, the County Council has been engaged in extensive pre-application discussions with the applicant and the outputs are captured within the Flood Risk Assessment .
• KCC does not raise any issues with surface water management on the site of the proposed development.
For the avoidance of doubt, in accordance with legislation and Advice Note 8.2, the Relevant Representation form will be completed and submitted online via the Manston Airport project page on the National Infrastructure Planning website.
If you require any further information or clarification on any matter in this letter, then please do not hesitate to contact me.
Yours faithfully,
Barbara Cooper Corporate Director – Growth, Environment and Transport