Council Report Pans Night Flights Proposal

It's grim reading for Manston, but it could be good news for East Kent - depending on Thanet District Council’s priorities. Yes folks, the Parsons Brinckerhoff report has finally arrived, and you can read, print and download your copy HERE. 

This summary is in handy bite-sized chunks - just click on the "next installment" at the end of each post to work your way through...

Shortly after Manston submitted their most recent night flying proposal last autumn, TDC commissioned independent experts Parsons Brinckerhoff (PB) to look at all the paperwork. Manston’s application was supported by a noise impact report from Bickerdike Allen Partners (BAP), and an economic assessment from York Aviation.

TDC’s brief to PB was:

[p2]  To assess the suitability of the methodology used in the application; To test the assumptions made; To review the Planning situation

I have no idea why they asked for the third point - this is clearly a matter for planning lawyers. PB spend about a third of their report rehashing the history of planning problems and then throw up their hands in resignation and say “ask a expert”:

[p22] It is recommended that Legal Council [sic] Opinion is sought on the question of intensification of use.

Some key findings from the PB report:

• Manston wants night flights for freight.
• If this was a planning application, it would be rejected.
• Having night flights will not generate passenger growth.
• The noise analysis supporting Manston's application is flawed.
• The economic analysis supporting Manston's application is flawed.
• The S106 agreement and the planning status of the airport is a shambles.

Incidentally, if you found this useful, do feel free to pass it on to friends, neighbours and colleagues - just use the "EMAIL THIS" link below.

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Next installment: It’s all about freight

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Noise Nuisance Under-stated

Manston's night flying application was backed up by a report on noise nuisance from Bickerdike Allen Partners (BAP). The BAP report assumes that house windows are closed all year, thus understating the decibels heard by residents by 27dB.

The Parsons Brinckerhoff (PB) report picks up on this:

[p11] This of course fails to consider the partially open window situation described in both WHO guidelines and PPG24, which might be expected in the late spring, summer and early autumn months of the year. This corresponds to the months of year covered by the summer timetable in which the bulk of activity occurs at most airports in the UK.

The PB report also correctly identifies the obvious flaw with Manston’s proposal to exclude parts of the night from the night quota period. This would inevitably result in a late-night and early morning rush hour:

[p11] In relation to the proposed QC quota, the exclusion of the shoulder hours from the night time period is out of step with other airports, and would result in a “cramming” of movements into the shoulder hours, times in which most of the UK population is attempting to get to sleep, or before they would normally wake.

(The night quota period is when they propose to monitor and limit aircraft noise - 2330 to 0600. The so-called shoulder periods - 2300 to 2330 and 0600 to 0700 - would be treated as normal daytime, and would not be included.)

The PB report says the assessment of noise impact completely under-estimates the noise impact - under any other circumstances this would be an unacceptable proposal:

[p11] ... the failure to consider the impacts with windows open, coupled with a mitigation scheme that potentially may not reflect the noise risks from larger aircraft movements at night, may not be as favourable to protecting the local amenity for nearby residents. Had the council been considering a planning application for night operations with 5338 properties above 48 dB, and 312 exposed to the 95 dB Single Event Level, it is unlikely that the application would be seen favourably unless there was a substantive economic argument for its approval.

The PB report says in summary:

[p12] The analysis of the noise impacts have, in our opinion, resulted in an underestimation of the potential adverse impacts on residents in the area.

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Next installment: York Aviation

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Manston dragging its heels over night flights

No haste = no need

OK, let's just make sure we've got this straight...

The night flights that Manston is hankering after have been portrayed as essential, crucial, make-or-break. Without them, so we are told, the airport won't be able to deliver on its fairytale Master Plan.

I find this VERY hard to square with (a) any facts in the real world, and (b) the airport's conduct over the last year. If night flights really did matter so much, why would they spend a YEAR dragging their heels?

Sep 2010: Manston submits its night flying proposal, backed up by the report it commissioned from Bickerdike Allen. A shambolic public meeting at Chatham House demonstrates the unpopularity of night flights, and makes Bill Hayton a household name for all the wrong reasons.

Oct 2010: Ramsgate Town Council has its own mini-consultation and rejects night flights.

Nov 2010: TDC get a technical review report from consultancy Bureau Veritas on the airport's proposals, which concludes that the costs outweigh the benefits. TDC cancels the public consultation on the day it was supposed to start, stating that Manston's proposals were too unclear and lacked economic justification.

May 2011: Local elections. Part 1 of the York Aviation report, commissioned by the airport, supposedly providing economic justifications for night flights is published.

Jun 2011: EasyJet snuggle up to Southend airport and launch a range of European services. Southend doesn't have night flights.

Aug 2011: Part 2 of the York Aviation report, commissioned by the airport, supposedly providing economic justifications for night flights, is leaked to the press and (presumably) given to TDC. No sign of it in public yet. Charles Buchanan appears on TV, predicting a night flight application "next month".

Sep 2011: It is next month. There is no application, yet. There is a meeting of the Airport Working Party on Wed 28th Sept. Surely, Manston isn't planning to release its next night flight application after the AWP meets? That could easily be seen as a crass attempt to exploit the Council's timetable.

TDC Airport Working Party

Marvellously convenient, and doubtless falling into an empty slot in your diary, the Airport Working Party will be re-convening their hastily cancelled meeting from last year. This will be happening on Thursday 20th January at 10:30am, in the Pugin & Rossetti Rooms, Cecil Street, Margate, Kent. Like I say - handy.

Special guest stars will be Bureau Veritas, the world famous sound consultants whose role in the unfolding drama appears to be that of the rain on Infratil's parade. BV's report, which had to be re-drafted a couple of times before being accepted by TDC, did not go down at all well with our chums on the tarmac at Kent's Irrational Airport. An embarrassing spotlight was focused on the typos in Infratil's proposal that skewed the story in their favour; the need to sound-proof Ramsgate was raised; and some crushing killer blows were landed:

the predicted number of people likely to be exposed to significant levels of average night-time noise is not sufficiently justified by the number of passengers and freight activity that are forecast to benefit from the proposals [i.e. it's not worth it.]

By all accounts, Infratil are still somewhat shaken, not to say battered, by the report and have been conspicuously silent since, which is rather surprising given that their entire future hangs on this, if they are to be believed. Anyway, as you can see from the Agenda below, Bureau Veritas will be there in the flesh to explain their report, and quite possibly answer questions from the AWP. A lot could turn on this, so be there if you can - and, following local tradition, do wear something red if you're against night flights.

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MANSTON AIRPORT NIGHT NOISE ASSESSMENT REVIEW - BUREAU VERITAS REPORT

To:                               Airport Working Party – 20 January 2011

Main Portfolio Area:     Economic Prosperity & Community Services

By:                               Environmental Protection Manager

Classification:              Unrestricted

Wards                          All

Summary                    Proposed night-time flying policy for Manston Airport, presentation by Bureau Veritas of its Manston Airport Night Noise Assessment Review dated November 2010

For Decision

1.0              Introduction and background

1.1       On 13 October, 2010, this Working Party received a report regarding the proposed Night-time Flying Policy application, made by Infratil, the owner of Manston Airport, on 28^th September, 2010.  The application was made within the context of the s.106 Planning Agreement between the Council and the owner of the airport.  The application was accompanied by a technical report produced by Bickerdike Allen Partners, titled Manston Airport Night Noise Contours Integrated Noise Model (INM).  Previously the application and noise report from Bickerdike Allen have been made available to Members.

1.2       Following from recommendations from this Working Party, and discussions with others including Canterbury City Council and Kent County Council, a programme of public engagement was produced.  However, it was considered inappropriate and unacceptable to commence consultation until the Council had commissioned its own, professional, technical assessment of the noise implications of the proposal made by Infratil.

1.3       Hence the report from Bureau Veritas has been produced, alongside a glossary of terms, to help the public understand, and interpret both the Bickerdike Allen and Bureau Veritas reports.

2.0       The Current Position

2.1       The Bureau Veritas report is attached at Annex 1.

2.2       Bureau Vertias will be attending the meeting to present the content of the report. There will be the opportunity for the Members to ask questions.

2.3       This meeting enables Members of the Working Party to receive information, which alongside the Working Party’s previous reports and in the context of visits being arranged to both East Midlands and Robin Hood (Doncaster) Airports will enable it to recommend a set of criteria against which any future application for night-time flying policy at Manston could be considered.

2.4       It is suggested that the working party develop a concept of appropriate consultation criteria that describe the threshold that will need to be reached before the council contemplates further public consultation on this issue. These criteria once agreed can then be recommended to the Overview and Scrutiny Panel for comment, and ultimately to Cabinet. Full Council will then be in a position to formally set the necessary criteria. Should Infratil wish to submit a night-time flying application this will be made the subject of a twelve week public consultation process, as previously proposed.

3.0       Options

3.1       The Working Party is obliged to report back to Overview and Scrutiny within the framework of the annual work plan of the Overview and Scrutiny Panel 2010/2011.

4.0       Corporate Implications

4.1.      Financial

4.1.1.   Council has set aside funding for both the Bureau Veritas report and, in due course, engagement of a public consultation consultancy. Contributions to funding have been committed by Kent County Council and Canterbury City Council.

4.2.      Legal

4.2.1.   The existing s.106 Agreement between the Council and the Airport Owner enables the Airport Owner to submit an application for a night-time flying policy.

4.3.      Corporate

4.3.1.   Growth of business, and employment at the airport is an important strand of the Council’s strategic approach to economic regeneration.  However, the Council has already made it clear that this must not be at the expense of unacceptable environmental impact.  In particular noise.

4.4.      Equity and Equalities

4.4.1.   In the opinion of the author there are no direct equity and equalities implications to this report.

5.0       Recommendation

5.1       That the Working Party receives the report and presentation from Bureau Veritas, in order that it can receive information contributing to a set of criteria the Airport Owner will be required to satisfy, at such time as a further application for a night-time flying policy.

6.0       Decision-making Process

6.1        The Airport Working Party makes recommendations to the Overview and Scrutiny Panel who in turn make recommendations to Cabinet and or Council

Contact Officer:	Penny Button - Tel: (01843)  (57)7425
Reporting to:	Madeline Homer, Interim Director of Community Services

Annex List

Annex 1	Bureau Veritas report
Annex 2	Manston INM Contour Comparison Map
Annex 3	Manston Airport Glossary of Terms

 Corporate consultation undertaken

Finance	Sarah Martin
Legal	Harvey Patterson

Public consultation: the next steps

Thanet District Council say:

The council will be carrying out a full twelve week public consultation to gather the views of as many local people as possible in the next couple of months. This will be facilitated on behalf of the council by Ipsos MORI. Please could I encourage you to take part in this process once it begins. I will ensure that you are contacted directly with full details on how to take part once this commences.

This formal consultation process is not due to start until two pieces of technical work have been completed to ensure that members of the public are aware of the potential impacts of the proposal. The first is an independent specialist technical review of the noise impact study produced for Infratil by Bickerdike Allen. The second is a Plain English guide to ensure that members of the public are able to access full information about what the proposal will mean, in terminology that is easy to understand. Both pieces of work will be published on completion and before the full public consultation begins, to ensure that local people have all the information on the proposal before giving us their views as part of the formal consultation.

In the mean time please visit www.thanet.gov.uk for further information and to view all of the documents submitted by Infratil.

Manston Noise Assessment

BAP filled with holes

Some of the more observant members of our team here at No Night Flights towers have been reviewing the Noise Assessment Report from Bickerdike Allen Partners. They have provided me with a detailed report which highlights issues such as presented on it, including seriously underestimating the numbers of dwellings that will be affected.  They have come up with the following observations:

• "The consultants report assumes that residents will sleep with closed windows."

• "I note that the consultant fails to mention the "half quota" counting of westerly departures and easterly arrivals claimed in the proposed Night Noise Policy. I doubt they would approve having stated that the QC system is "successfully deployed at many major UK airports including Gatwick, Heathrow, Stansted, Manchester, Bristol and others". Incidentally, there is no justification for this claim - the only part of the LHR, LGW and STN controls which could possibly be deemed successful is the limit on the total number of movements during the QC period which was successfully defended in the house of Lords when the government tried to abolish it."

• "They mention on page 3 that 'it is generally accepted that the most sensitive time for people....from recent research....is during the hours of 0100 to 0600'. On page 4 they state that 'One of the conclusions ...was that once asleep very few people living near airports are at any risk of any sleep disturbance due to aircraft noise'. This means either the earlier night period wakes people up and stops them getting off to sleep or it doesn't. You can't argue both ways".

• Bickerdike Allen have stated that SEL stands for "Single Event Level". Incorrect. It stands for "Sound Exposure Level" (CAA CAP725).

Onto the night time flying policy itself...

• "The suggestion that quota count scores be halved for departures in a westerly direction. What happens, for example, if/when development west of the airport occurs? This is absolutely NOT how the QC system was designed to work."

• "There needs to be a clause added to stop any carryover of unused quota from one year to the next."

• "Seeing as the Council and Infratil are still working with Planestation's S106 agreement and always refer back to problems with this not being their agreement, there should be a clause mandating a negotiation of a new S106 and night time flying policy if the airport were ever to change hands. "

• "The suggestion that Westerly arrivals/departures in the night cost "half" the normal QC point would be unique amongst all UK airports. This is effectively allowing the airport a QC count of 2,990."

We have a full report which points out many technical errors - it will be interesting if TDC's Peer Review identifies them all. If any council officers, councillors, or Consultative Committee members would like a sneak preview, please feel free to ask.

BAP report on Night Flights

At long last we're getting a clearer picture of what Infratil wants to do with our sky, and it doesn't make pretty reading: a 25-fold increase in night flights, and some sly counting to make it look less. The owners of Manton airport first started asking for more night flights at the beginning of 2009, during the BAWC débâcle. At the time, they claimed it was not just pressing, but urgent. Some 20 months have passed, during which they submitted another request, which was useless as it was missing key bits of information like... er... how many night flights, and how much noise.

Infratil (Manston's owners) have now got someone to help them type the numbers - Bickerdike Allen Partners. Charles Buchanan recently portayed BAP as being independent consultants with a record of even-handedness. Looking at their website, their emphasis seems to be more on acoustic design and sound-proofing buildings, rather than flight paths. But noise is noise, right?

Risking torture and death, my alarmingly effective spies have brought me BAP's draft findings, and they make grim reading:

• Firstly, these people reckon that currently there are 2 night flights A WEEK, on average. You may agree with this number. You may not.
• Secondly, they are seeking permission for 7.7 night flights A NIGHT, on average. You may regard this as acceptable, or even desirable. You may not.
• What really pees me off is the way Infratil are trying to move the goalposts by tinkering with the definition of "night". Across the UK, and throughout the aviation industry, "night" is 2300-0700 (or 11pm to 7am, in old money).

Infratil are fond of laying claim to 'shoulder periods' which simply have the effect of shortening the night. In the table below, you will see that Infratil are quite brazen about this manipulation. During the average night, 7.7 planes would be flying, but only 3 of them would count towards the Quota Count - simply and solely because Infratil have decided to designate 2330-0600 as the only period of time that would be subjected to Quota Count. Thanet District Council must nip this in the bud.

• Infratil's request for a quota count of 1,995 for the period 2330-0600 is enough for the three flights they are forecasting in that arbitrarily shortened time-frame.
• To cater for the 7.7 flights they are forecasting in the period covered by the standard definition of night, i.e. 2300-0700, they would need a quota count of 5,120.

Night-time aircraft movements at Manston currently occur on an ad-hoc basis and involve aircraft of the type that are expected to fly in the future, for example the B747-400. The number of movements that take place currently vary from week to week and month to month but are typically around 2 per week at present.

Future Night-time Aircraft Movements

Up to the year 2018, MSE have developed forecasts for future night-time aircraft movements that indicate the following number of movements over a calendar year and during a typical night:-

	Night-time Aircraft Movements (2018)
	Annual		Typical night
Hours	Passenger	Freight	Passenger	Freight
23.00 - 23.30	1,016	57	2.8	0.4
23.30 - 06.00*	610	471	1.7	1.3
06.00 - 07.00	407	157	1.1	0.4
	2,033	785	5.6	2.1

Warning to TDC and Infratil over Manston

Thanet District Council and Infratil, the owners of Manston Airport, have been warned they could end up in the High Court if the night-flights consultation process is botched. The warning has come from Paul Twyman, the chairman of airport watchdog the Kent International Airport Consultative Committee (KIACC).

An application from Infratil is expected to be placed in under two weeks and will detail the number of planes the company wants to be allowed to fly in and out of the airport between 11pm and 7am. There are concerns that any consultation will be undermined by lack of noise-monitoring data, an unclear policy about the routes that planes can take approaching and departing the airport, and the robustness of the consultation procedure.

The results of a noise-assesment report being prepared by consultancy Bickerdike Allen Partners, and commissioned by Infratil, should also be made available to the public before the consultation starts, many people are arguing. They say that any report is assessed and reviewed before a consultation starts – not during it. Mr Twyman said:

"I urge the council to think very carefully about they way in which they handle this consultation. If you go ahead with a half-baked process, if you make a hash of it, then I’m sure there will be people out there who would take a dim view of that – and I suspect there will be people who seek a judicial review. KIACC has spotted a pretty big hole here. It’s clear that in the last seven years a lot of nettles have not been grasped and now the time has come for KIACC to start to help the council to grasp those nettles. If the council go off half-cocked on this consultation, it could find itself in the High Courts. The night noise consultation could be starting in about 14 days and there are big issues around it."

The Section 106 agreement, a document that governs flight times and routes, is also out of date and needs to be revised, says Mr Twyman. The consultation will take place over a 12-week period and will involve meetings, phone polls, roadshow sessions and questionnaires. However, delays while reports are digested and analysed could mean that the process runs into Christmas. Brian White, Thanet council’s director of regeneration, said the local authority had not seen Infratil’s figures for the quota-count system, despite claims that people at the council had already seen them. When asked by Steve Higgins of the No Night Flights campaign if he had seen the proposed quota-count number, Mr White said:

"The Freedom of Information Act requires that anything the council holds it releases, but we haven’t got anything."

Nick Cole, of Monkton Parish Council, said: "It strikes me that there is probably a lot more work being done than we are being led to believe here:

"If the consultation is about to start in a matter of weeks, then I think it would be fair that some of the figures be given tonight. We must have an indication about how many flights we are talking about during night-time."

Charles Buchanan, the airport’s chief executive, responded by saying:

"I am not in a position to give a final number. You do not release half the specification in advance – you launch the whole thing when people can see the whole picture. They can see the benefits on one hand and the problems of the other. It would be misleading and diverting to look at just one part of it and that’s where we are."

At the meeting in public at the airport terminal on Friday last week, KIACC members voted against holding a meeting at the "other end of the runway" for villagers in places such as Monkton, Minster and St Nicholas-at-Wade. After a request for more information to be made available to more people, Mr Twyman proposed a series of meetings to inform the public in the villages and Herne Bay, but it was voted down. Conservative councillor Roger Latchford, Thanet council’s cabinet member who deals with the airport, voted against such meetings. However, a meeting on the application will take place in Ramsgate.

During the meeting it also emerged that the council’s mobile noise-monitor, which should be used to monitor the noise made by aircraft overflying areas such as St Nicholas, is still out of operation. Chris Wells, the council’s Conservative cabinet member for the environment, said it should be back in use – and in an airport employee’s garden – very soon as it had taken longer than expected to be fixed.

The airport’s application for a secondary radar tower has received planning consent. It will be built after the contract has been put out to tender. Four objections to the application had been received, but Mr White said that there were "no material reasons" why the application could not be approved, on Friday, August 6.

yourthanet.co.uk