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Representation by Emma Blau

Date submitted
17 September 2018
Submitted by
Members of the public/businesses

I have, for 6 years, owned a home in Ramsgate on Vale Road (CT11 9LT) which is directly under the proposed flight path.

The applicant has presented an underestimate of the potential negative effects of noise from their proposed development and has disguised their true intentions on night flights, including:

  1. No caps on flight numbers • Applicant states proposed runway and 19 stands are capable of handling 83,000 freight Air Traffic Movements (ATMs) annually but bases its “worst case” noise assessments on its estimate that a figure of 17,170 ATMs is more likely. However, as no cap on the number of ATMs is propose, the lower figure is not “worst case”. • Nor is any cap proposed on the number of night flights, only an overall noise quota of 3028 QC points a year. This would permit very extensive night flying, well over three times the “worst case” assumptions for night flights used in RSP’s Environmental Assessment (based on 8 flights per night).
  2. Dubious noise modelling and assumptions • The applicant has paid insufficient attention to ‘real time’ official noise measurements from past airport operations and their noise contours over Ramsgate are impossible to reconcile with the noise contours presented by a previous operator in 2011, applying for a much smaller operation. They also appear contradicted by CAA noise measurement of the first 17 months of Boeing 787 operations at Heathrow Airport, where no reading at 3.8km from the end of runway was less than 90 SEL dBA -how could noise levels over St Lawrence (1.6km distant) and central Ramsgate (3.2km distant) be much lower? • Independent noise experts engaged by the local authority in 2010 when a previous operator at Manston applied for a QC night budget of 1,995 concluded “the populations predicted to be within the 85 dB(A) contour by such departures ranges from 14,722 [people] for MD11 departures, up to 30,903 for the Boeing 747-400.” • The applicant’s baseline noise measurements are flawed and unsatisfactory and their noise modelling includes some questionable assumptions, e.g. it will secure runway choices that will reduce the historic aviation noise exposure of Ramsgate residents. That is not “worst case”. • The noise modelling also uses a technical standard (SONA 2014) intended for an airport already operating (which Manston cannot be without planning consents) rather than the DfT WebTAG standard. • The applicant put forward a spurious metric for assessing significant effects of aircraft noise at night.
  3. Unclear intentions on Night flights • Despite the applicant’s insistence locally that he “neither wants nor needs” any night flights save emergency and humanitarian exceptions the veiled business logic of the application appears to favour capturing the bottom of the freight market viz. noisy night flights, witness:
  • proposal to accept night ATMs rated at QC4 - prohibited from the London airports on noise grounds
  • failure to address disturbing impacts from noisier aircraft
  • asserting free night flights as the top reason operators would choose Manston above East Midlands Airport
  • their response to the public consultation comments favouring night flights repeatedly states that RSP “welcomes support for night flights” As most of UK cargo flights are night flights it is especially important to be clear about what is a realistic worst-case night flight scenario and about the human costs of that proposal. Other implications from night time freight handling do not appear adequately to have been addressed, e.g. light pollution.

I would also like to point out that, considering the scale of the proposed cargo hub and the magnitude of impact communities, it is questionable whether RSP took sufficient steps to ensure the maximum number of residents were aware of their plans for Manston, or the consultation process, as follows:

  •  Notices in media relied on the public purchasing newspapers whose circulations are falling significantly.

  •  RSP claim in several parts of the submission that they sent postcards to every household under the flight path by mail; elsewhere they use the term ‘delivered’.  These claims have been widely disputed by the residents of Ramsgate. The ‘delivery’ of postcards omitted whole streets. I can confirm I have to date received no literature at my own address.

  •  In a letter following the consultation events the local authority for Herne Bay, Canterbury City Council, who are also under the proposed flight path and whose residents RSP claim to have consulted extensively, expressed “concerns regarding the adequacy of the consultation process”. (Doc 6.2 Consultation Report Appx46).

In addition, I have concerns about the following issues which I also intend to submit, with supporting evidence, and am outlining below for your reference:

  • Economic viability/benefits of the proposed development
  • Funding
  • Impact on people's health
  • Safety
  • Impact on Ramsgate Heritage Assets and Ramsgate Heritage Action Zone