Thursday 20 June 2019

Is a verbal promise worth anything

Right back at the beginning of the DCO process the museums on the Manston site were promised by RSP to be "fully respected" and although they may need to be moved because of the realignment of the road junction they would be "looked after"
Was this an empty promise?

Those oral promises by Tony Freudmann were made within the backdrop of Stone Hill Park removing the museum lease and giving them unfettered access to the land when they granted them the freehold of the site. However the museums wrote in support of RSP initially but it seems now to have been a poor decision in light of RSP's failure to communicate with the trustees.
To read this letter in situ go to the Pins site here

Further it seems that Riveroak and Tony Freudmann are paying lip service to the idea of protecting the historical assets on the Manston site
From a submission by the supporters of Manston is the following extract:

"This submission is based on the concerns over the retention and development of the historic features of Manston Airport. There are concerns about historic features that could be lost, or where close proximity of development may be detrimental to them. This is not intended to be a critique or opinion in regards to the current application outside of the heritage aspects of the current application which would apply to any future use of Manston airport.
We are concerned that the recent hearing held 3rd June 2019 on Landscape, Design, Archaeology and Heritage spent only around 15 minutes discussing non-designated assets when there appears to be disagreement or lack of agreement between the applicant and interested parties. We were also concerned although they were in attendance in the public area, it appeared that representatives from the museums were not included in the Interested Parties invited to attend and participate in the discussions for both their own futures and those of heritage features on the site. We are aware of further discussions on 7th June 2019 and there appears to be some way to go before agreement between the applicant and interested parties.
We have concerns that the applicant appears dismissive of the potential of at least some historic buildings/structures on Manston as stated by Historic England in response to Question HE.3.2 as part of the Deadline 7a Submission. It would also seem that further surveying and analysis must take place in order to document them.  We agree that the loss of the buildings and features cannot be largely mitigated by recording only, but it seems that protection of all of them does not form part of the development plans, contrary to The Airports National Policy Statement (2018) (ANPS)."
……..
"We would urge the inspectors to ensure sufficient measures are in place to make sure that surveying of all archaeological and historic features, known and unknown, is carried out in full consultation with interested parties. Further we would request that all existing features from the military history of Manston are protected. We would hope these sites are preserved and form part of a wider scheme of historic protection and education for the public as suggested by the KCC submission. At this point in time, it would appear that the applicant’s plans do not include the protection of all the potential heritage on the site."

Editor's note: Bold editors emphasis
You can read the entire submission here Submission regarding heritage aspects on the Manston Airport site by ‘Supporters of Manston Airport’,

Picture from Luftwaffe reconnaissance 1939
RSP needs, even at this late hour, to provide reassurance that the history in the Manston site is preserved for future generations to understand the role this frontline airfield had in the "Battle of Britain" and WW2

It is completely wrong that RSP seem to have made promises to preserve the heritage of the site and with just 3 weeks to go to the end of the examination it now seems that the heritage has been demoted to just a footnote in the DCO.

Monday 17 June 2019

Noise and why it matters

Noise tolerance is different for everybody, even different dependant on the situation (fire alarm Vs Alarm Clock) however much of it is tolerated as necessary. When it comes to aviation noise things are different.
It is different because it is far more difficult to mitigate noise from planes as you cannot build structures to deflect it as you can with motorways as the plane flies above your head. Noise from the same height sound different in an open park than it does when in a town surrounded by buildings.

It is also different as aircraft noise has many ways to measure the noise as there is no single method leaving people to wonder just why you cannot find one single way to measure the noise nuisance.

Current thinking from the Government is to use a standard that doesn't measure the impact of one single event but a measurement that averages the impact dependant on the mix of aircraft using the airport and frequency of the air transport movements then averaged over a 16 hour day (LAeq, 16hr). (in plain language that means how many 747's and how many Lear jets and then averaging the noise and then averaging again over a 16 hour day)

For most airports working out the contours is relatively easy because they have annual data to use in their modelling. Why this is important is that Manston is closed (and has been for 5 years) and the modelling RSP used was based on the Fleet mix within the discredited Azimuth Report which is turn was based on Dr Sally Dixon's unviable forecasts.

RSP's current proposal is to pay compensation at the 63Db contour which is based on an untested fleet mix and understates the individual impact of each event by about half.

This is the actual Data from Infratil (the last owners of an operational airport) showing the 85, 90, 95 db contour of a Boeing 747 landing over Ramsgate
This clearly shows that a 747 will impact a large area of Ramsgate now look at the new averaged Fleet mix and then averaged over a 16 hour day at 57, 60 and 63Db LAeq, 16hr
These contours were calculated by CAA's Environmental Research and Consultancy Department, (ERCD) on behalf of a local business and not by RSP who used an untried and untested company (stated at the local hearing on noise when Woods confirmed their expertise was in road transport and not aircraft)  to produce their contours which at 63Db looked like this
Using this 63Db contour RSP decided that only 232 houses might be eligible for soundproofing (which would have costed RSP £3.85M.
Compare this with the number of properties that occur within the 85Db contour for a single 747 landing over Ramsgate.
This is important because Noise Blight compensation must be secured BEFORE the DCO is granted and evidence of funds must be verified and to date that has still to be done.

Current Government thinking is that developers should move to the 60Db contour which is clearly marked on the locally funded contour map but not so easy to find within the application however today the examining authority sent the following map
This still differs markedly from the ERCD contours but does show many more people should be entitled to compensation.
This is what the ExA is proposing as new wording in the Statutory Instrument:


New R9b

Residential properties with habitable rooms within the 60dB LAeq (16 hour) day time contour will be eligible for noise insulation and ventilation detailed in Noise Mitigation Plan.”

Reasoning

The ExA is proposing this revised daytime threshold in order to align the daytime noise threshold with current and emerging policy including the Government’s proposed changes currently the subject of consultation. The Aviation Policy Framework (2013) paragraph 3.17 states that: “We will continue to treat the 57dB LAeq 16 hour contour as the average level of daytime aircraft noise marking the approximate onset of significant community annoyance.” The Civil Aviation Authority’s (CAA) recent findings on Aircraft Noise and Annoyance (February 2018) refers to UK policy in relation to an ‘annoyance threshold’ and highlights 57dB LAeq (16 hour) as marking the approximate onset of significant community annoyance. The third 3 paragraph page 6 states that: “The government published their Response to their Airspace Consultation in 2017 and acknowledged the evidence from the SoNA study, which showed that sensitivity to aircraft noise has increased, with the same percentage of people reporting to be highly annoyed at a level of 54 dB LAeq, 16hr as occurred at 57 dB LAeq, 16hr in the past.” Paragraph 3.122 of Aviation 2050

The future of UK aviation (December 2018) Cm 9714 states that: “The government therefore proposes the following noise insulation measures: to extend the noise insulation policy threshold beyond the current 63dB LAeq 16hr contour to 60dB LAeq 16hr.”
Clearly the level of annoyance to locals with an operational airport will be many times bigger than has ever been seen before at Manston
The highest number of air transport movements (Cargo) was 2003 at 1081 movements or 540 planes or 3 movements a day. The last 10 years before closure saw an average of 439 movements per year or 220 planes or just 4 planes a week.
Riveroak are planning for 17170 movements a year or 8585 planes or 23 planes  per day.
This bears no comparison with the past history of Manston and the noise this will generate will never have been felt by any current or past resident of the town.

Postscript:
Heathrow today announce their new compensation offering which will use the 57Db contour. Read their plan here. link to Heathrow plan