In my
submission to PINS 1 I included a section on Public Safety Zones (PSZ) in
section 3 and I quote
“Our submission
notwithstanding that 10000 ATM’s are unachievable RSP should have considered
whether Manston Airport needs a PSZ because they state that the potential
number of ATM’s is 83220 and they also state they will not cap the number of
flights. The logic says that both 83220 and PSZ’s are potentially capable they
should be considered together (worst case scenario)”1
However
since the submission RSP have responded to a number of questions from the ExA
and the answer to questions AQ1.18 and AQ 1.19 are relevant to the point of
PSZ’s and their “worst case scenario”.
In particular the answer to the number of flights is being
capped at an annual 26,468 (as opposed to the potential capacity of 83220 which
was an exercise in foot in mouth publicity). This however doesn’t change the
dynamic of PSZs which are an absolute requirement for any airport which
proposes more than 1500 Air traffic movements (ATMs) per month or 18000
annually.
“Given the concern
expressed about this issue in relevant representations and the Examining
Authority through its questions, and since the Applicant does not expect the
number of ATMs assessed in the ES to be exceeded, it is now adding an annual
limit of ATMs equivalent to the number assessed in the ES, namely, 17,170 cargo
plus 9,298 passenger movements, i.e. 26,468 movements in total. This cap has
been included in the revised Noise Mitigation Plan (TR020002/D3/2.4) being
submitted at Deadline 3. This total includes the movements generated by the 3
recycling stands but does not include general aviation movements.”
There are several issues here however it doesn’t invalidate
the original statement from my original submission as both are above the 18000
annual ATMs.
Firstly I make the point that at no time have RSP/ROIC ever
consulted with the population most affected about either 83220 or 26,468 ATMs,
neither have they ever made this a “worst case scenario.
“It is not the role
of the ExA to consider RSP’s consultation process. NNF understands that.
However, the proposal now before the ExA is not the proposal that RSP consulted
on (we deal with this in our submission NNF01 Section B). In addition, RSP’s
habit of systematic misinformation during all of its consultations casts doubt
on the extent to which the developer is fit and proper to own and operate an
infrastructure project of national significance. In our view, this is an issue
that should be considered by the ExA.”2
Secondly the point that more than 18,000 ATMs is now the cap
on flights should mean a PSZ at both ends of the runway should be a major part
of the Environmental Impact Assessment (EIA), and should therefore be part of
any compensation offered to those residents impacted within the PSZ.
As one end (to the West) extends over relatively open
countryside I have limited the area of PSZ to the East where most residents
live. I have also modelled the area of Manston Green (785 houses given Planning
Permission but yet to be built) onto the PSZ. The blue triangle indicates the
1:100000 risk contour and the red the 1:10000. This is modelled on the Bradford
/ Leeds airport but is similar to many regional airports.
3 THIRD PARTY RISK NEAR AIRPORTS AND PUBLIC
SAFETY ZONE POLICY
Conclusion
It is apparent that there is a reason that RSP/ROIC have
consistently refused to discuss PSZs in their consultations and in their DCO
submission and that is the possibility that compensation payments would create
a cash flow problem as Manston Green (Southern) falls under the 1:10000 contour
where under normal circumstances no building would be allowed. Even inside the
1:100000 restrictive planning legislation would make compensation much more
likely and therefore less affordable to RSP/ROIC. 4
2.
NNF12 (available on PINS as a zip file)
3.
Appendix 1 (THIRD PARTY RISK NEAR AIRPORTS
AND PUBLIC SAFETY ZONE POLICY)
4.
Appendix 4 (Control of planning within a
PSZ)
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