Report highlights night flights hype

Nights flights will not be the salvation of Manston airport, according to campaigners who say that a report from a leading transport consultancy backs their views.

Community groups say they do not believe allowing the flights would bring any economic benefit to the residents of Thanet, and may in fact bring harm to the area due to the impact of noise and air pollution.

Many also say that if the proposed operations went ahead, they could actually deter people who might be planning to move their businesses to the area or thinking of buying a home there. Dr Hilary Newport, of Protect Kent, the county arm of the Campaign to Protect Rural England (CPRE) said:

“Night flights will not be the airport’s salvation. Manston cannot sell all of its daytime slots, and disturbing the sleep of residents in Ramsgate and beyond is not the way forward.”

A report into the contentious issue - authored on behalf of Thanet District Council by Parsons Brinkerhoff, a leading transport consultancy - has just been published. CPRE casts doubt on the claim of airport operator Infratil that 3,000 jobs will be created if night flights go ahead and says that the impact of noise levels has been underestimated.

Andrew Ogden, campaigns manager for Protect Kent, said:

“This report, which is based on an examination of the documents submitted by Infratil, clearly brings into doubt many of their claims. Parsons Brinkerhoff indicates that Infratil’s views of the economic benefits are wildly over-optimistic, while the impacts of noise - the major concern of residents in the area - have been seriously understated. These two points alone vindicate the local opposition groups, whose concerns have been regarded by some as backward-looking and ‘nimbyism’.

The fact that Flybe are pulling out in March because they cannot fill planes is damning proof of the lack of demand for flights out of Manston. We simply cannot see how allowing night flights will help Manston grow as a passenger airport, and therefore generate both jobs and economic sustainability for the area.”

In light of this recent report, Protect Kent is asking for full public consultation before any night flights are allowed. It says this should be open and transparent, with all the facts available. Mr Ogden said:

“This will enable the people of East Kent to weigh up the benefits and disadvantages of night flights and lobby Thanet District Council accordingly. It is only right they be given this opportunity, as it is their communities and environment that will be significantly affected by the implementation of night flights.”

However, a report last year commissioned by Infratil said the flights would be beneficial. The first part of the Economic Impact Report, produced by York Aviation and published in May, suggested that the airport would directly employ 2,070 people and support a further 1,035 indirect jobs by 2018 if a level of night flights was allowed. It also estimated that the Kent airport would deliver almost £65 million a year to the local economy by 2018 if its Master Plan development was realised.

Today (25th Jan 2012), Clive Hart, leader of Thanet District Council, signed a decision notice, which states the council’s intention to carry out a focused consultation in-house for 28 days for isle residents and in particular for those directly affected by the airport’s proposals.

The decision follows clarification that the proposal submitted by Infratil is for consultation only and so does not require a planning application at this stage. The council says this means its role is therefore as a ‘consultee’ and it is not in a position to make a binding decision in respect of the night-time flying policy.

It is seeking advice as to whether the proposed night-flying policy could result in an “intensification or change in operation at the airport”. This could then require a planning application at some point in the future. Cllr Hart said:

“We’re committed to listening to our residents and will still provide the opportunity for people to comment on the proposals before we draft our response from the council, as well as people being able to provide their views directly to the airport. We’ve promised that we will seek residents’ views, and we’re standing by this commitment but on a more appropriate scale. This issue needs to be drawn to a conclusion for the sake of the community, the council and the airport.”

The public consultation is proposed to launch on Friday, February 3, for 28 days and will be open to all residents in Thanet. Responses to the proposals must be submitted in writing to Consultation, Thanet District Council, PO Box 9, Margate CT9 1XZ, or by email to consultation@thanet.gov.uk Full names and addresses must be provided with each response. To view the proposals, and for more information about the public consultation, visit www.thanet.gov.uk, where information will be available to view from Thursday, January 26.

kentnews 25th Jan 2012 Nick Ames, reporter

Council breaks its silence

Thanet District Council have created cock-up out of chaos - a half-arsed consultation, then playing put the genie back in the bottle. It would have been so much simpler just to bat Manston's proposals straight back to them, just as the previous administration did, and for exactly the same reasons.

Originally, the consultation was to last 90 days, be carried out by MORI (for example), and cost £50-£80k. Councillors and members alike have been getting twitchy about the cost, and so they've opted to do it in-house, i.e. on the cheap. There's no suggestion that this will produce a better consultation.

Manston have dragged their feet for years over this, to the extent that even the Council has been appeared quite nimble in comparison. Nonetheless, Clive Hart has tried to allay our impatience by acting swiftly. Personally, for an exercise of this importance, I would rather he did it right than did it soon.

Having just realised that the S106 agreement means that Manston can proceed with whatever night flight policy they like, TDC have decided to wait and see what effect the night flights will have. Erm, quite apart from what their native common sense should be telling them, TDC have now commissioned two independent reports, both of which conclude that the costs of night flights outweigh the benefits.

They are also waiting to see if night flights would result in an "intensification or change of operation" at the airport. Hmmm... tricky one. Currently: 16 hours a day, with scheduled night flights forbidden. Proposed: 24 hours a day, with no limit on night flights. You know what - I think there will be a difference.

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New approach to airport consultation

A new approach is to be taken by the council in response to Infratil’s proposal for regular night-time flying at Manston Airport. 

Leader of Thanet District Council, Cllr Clive Hart, has signed a decision notice, which states the council’s intention to carry out a focused consultation in-house for a period of 28 days for Thanet residents and in particular for those directly affected by the Airport’s proposals.

The decision follows clarification that the proposal submitted by Infratil is for consultation only and the proposal does not require a planning application at this stage.  The council’s role is therefore as a ‘consultee’ and it is not in a position to make a binding decision in respect of the night-time flying policy.

The council is seeking advice as to whether the proposed night flying policy, if implemented, could result in an intensification or change in operation at the airport. This could then require a planning application at some point in the future. However at this time, the council is only being asked to provide a consultation response to the proposals and is seeking the views of local people to inform its response. People can also submit responses direct to the Airport, via its consultation page.

The decision also comes after review of the findings of an independent assessment carried out by Parsons Brinckerhoff Ltd. on behalf of the council, which challenges a number of the environmental and economic claims of the airport. Cllr Clive Hart, said:

“Taking a new approach to our consultation is absolutely essential given this advice.  We’re committed to listening to our residents, and will still provide the opportunity for people to comment on the proposals before we draft our response from the council, as well as people being able to provide their views directly to the Airport.  We’ve promised that we will seek residents’ views, and we’re standing by this commitment, but on a more appropriate scale.  This issue needs to be drawn to a conclusion for the sake of the community, the council and the airport.”

The public consultation is proposed to launch on Friday 3 February for a period of 28 days and will be open to all residents in Thanet.  Responses to the proposals must be submitted in writing to Consultation, Thanet District Council, PO Box 9, Margate CT9 1XZ or by e-mail to consultation@thanet.gov.uk Full names and addresses must be provided with each response.

The proposals, and more information about the public consultation, will be available to view on TDC's website from Thursday 26 January.

Airport and Council to break silence

Charles Buchanan, CEO of Manston airport, has had the newly published Parsons Brinckerhoff report since Thursday. So far, he hasn't made any public comment and has stuck to the line that he is biding his time pending a more considered response.

Translating from the business-speak/PR jargon, I think this means he's been trawling through the report with a fine-toothed comb and a magnifying glass, looking for the good news.

Thanet Disctrict Council have, of course, also had the report since Thursday. They probably would have had at least one draft report before then. (If anyone would care to send me a draft, I would be intrigued to play spot-the-difference.) Similarly, they haven't made any public comment, although Bob Bayford - now settling into his opposition role as heckler-in-chief - has been pressing TDC Leader Clive Hart for "clarification".

The good news is that they will both break cover and go public tomorrow. Apparently. Allegedly.

I'm sure they've both got something to say, and lots of people want to hear it - this is no time to be shy.

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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Night Flights are for Freight

Parsons Brinckerhoff (PB) put Manston’s request in the context of increasing demand for aviation services, particularly in the south-east of England:

[p3] … the demand for aviation services is set to dramatically increase in the next 20 years. The conclusion is therefore that better use needs to be made of the existing facilities.

The obvious solution would be for Manston to use its daytime capacity, but this never gets a mention.

The PB report says Manston wants night flights for freight:

[p4] … the ability to operate at night will be a crucial factor in attracting a regular air freight service provider which will improve the financial viability of the airport in the short-term.

The PB report says Manston's forecasts in its Master Plan are unrealistic:

[p4] … despite the forecasts only being two years old, the airport is not achieving the level of forecast passenger growth

The PB report says short-term passenger growth would come from carriers based at other airports, which would not need a night flight facility:

[p5] Therefore, in the short term we do not believe that the airport can justify a night flying quota system to support passenger growth. 

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Next installment: Manston’s in the wrong place 

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Location, Location, Location

It's refreshing to see an independent review of Manston's present and future prospects that doesn't shy away from stating the obvious - a successful passenger airport needs plenty of passengers within a convenient distance, and a successful freight airport needs plenty of customers within a profitable distance.

The Parsons Brinckerhoff (PB) report says Manston airport is in the wrong place:

[p5] Given the geographic location of Manston it is unlikely that carriers would show much interest for inbound traffic from key European city links – we would argue this would only be relevant if Manston was strategically placed near to a large city or a region with a large catchment area.

Heathrow has queues of carriers wanting to use the airport, so they can afford to pick and choose who they let in. Over the short to medium term, Heathrow airport will carry less freight and more passenger traffic, as passengers are more profitable. This will displace freight traffic to other UK airports.

The PB report says York Aviation is wrong when it says that Manston is "ideally geographically located" to benefit from this displaced freight traffic.

[p5] Stansted, and Gatwick to a lesser degree, have significant capacity to accept additional freight volumes and are strategically better located close to motorways and major conurbations.  For this reason we would disagree with York’s contention that “It is for the relocation of these services that MIA is ideally geographically located”.  MIA, whilst only 50 minutes from the M25 at Junction 2, is not strategically positioned for freight to be dispatched anywhere other than the far South East of England.

On p15 of their report, York Aviation claim that a night time ban prevents Manston from accepting freight traffic from much of the rest of the world (based on an arbitrary departure time of 2300).

The PB report says Manston is only excluded from 9% of the scheduled air freight market...

[p6] … we do not believe that this provides a compelling argument for significant economic benefit to the region as a result of the introduction of a night flying quota system.

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Next installment: Jobs

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Employment - when will it ever grow?

Manston airport currently runs on a skeleton crew of about 100 - the bare minimum required to handle any number of flights. Quadrupling the present number of flights wouldn’t result in a quadrupling of the present staff numbers.

The Parsons Brinckerhoff (PB) report points out that there’s plenty of staff capacity to be taken up:

[p8] Given that Manston Airport currently employs a proportionately large workforce for a small throughput, growth of passengers and freight in the short term may not necessarily lead to a significant employment and hence economic impact.

The PB report also raises a very good point which, as far as I know, has never been addressed - how much slack capacity is there, how much more traffic can Manston handle before they have to employ more people?

[p8] We would therefore like to see more evidence of the ‘threshold’ whereby Manston Airport achieves a specified level of throughput such that additional employment is required.

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Next installment: Noise

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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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York Aviation: enthusiastic number-crunchers

York Aviation come in for a lot of flak. I’ve started a list of the explicit criticisms that Parsons Brinckerhoff (PB) make in the first few pages of their methodology, assumptions and conclusions… see how many more you can find.

York Aviation’s analysis is entirely based on a discredited Master Plan:

[p4] The basis of the analysis provided by York Aviation is the passenger and freight forecasts contained within MIA’s Master Plan published in November 2009.  We would note that despite the forecasts only being two years old, the airport is not achieving the level of forecast passenger growth

Inaccurate assumption:

[p4] … no adjustment has been made to the 2018 figure to take into account the downturn seen during 2009 onwards.  In our opinion it is highly likely that the 2018 planning assumption used is significantly overstated.

Reaching the wrong conclusions:

[p5] We would partially disagree with the bullets provided at 2.14 [of the York Report] that suggest the resultant effects of not having based units would be; fewer destinations, less likelihood of key European city links and fewer overall passengers.

Hidden assumption:

[p5] Without seeing the underlying analysis used by York Aviation to create Table 2.2 it is difficult for us to accurately assess…

Poor grasp of geography:

[p5] … we would disagree with York’s contention that “It is for the relocation of these services that MIA is ideally geographically located”.

Arbitrary assumption:

[p5] … there is no rationale provided as to why 23.00 has been used as a departure time.

Hidden assumption:

[p6] York Aviation have not provided any of their calculations used to estimate the annual freight loss of 40%... we would need to see the calculations and assumptions used in getting to 40% before this figure could be validated.

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Next installment: The Planning Mess

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Planning Problems

As mentioned before, TDC wasted their (our) money in asking Parsons Brinckerhoff’s (PB's) opinion on planning, given that PB conclude “Dunno, ask a pro”. However, they do describe the shambolic background to Manton’s current planning status, and mention in passing some interesting omissions on TDC’s part.

The airfield at Manston does not have “proper” planning permission - it has Certificates of Lawfulness (once known as Lawful Development Certificates or LDCs). These were obtained :

[p13] … by the Ministry of Defence the Ministry of Defence, in anticipation of the transfer of the site from the MoD to new owners who would operate it wholly as a civilian airport. The purpose of the LDCs sought by the MoD was to confirm that the anticipated use of the whole of the land as a civilian airport would be lawful and that it would not require planning permission to undertake the use.

The PB report says that two LDCs were issued in 1998, and another two in 1999, and that all four related to the use of land and buildings, but have no other specified details or conditions/restrictions relating to the operation of the Airport. Mind you, they haven’t actually seen the certificates, so nobody can be sure.

The S106 agreement was negotiated in September 2000, and is what my grandfather would have called “a right royal cock-up”.

It specifies that there will be:

[p14] … no night flying until such time as a night time flying policy has been prepared and lodged with the Council.

Note the wording - “prepared and lodged” - there’s no suggestion that anyone needs to agree to it…

[p14] The schedule sets out that the owners will consult with the Council, who in turn will be allowed time to consult on the proposed policy.  It is important to note that the wording of the S106 makes it clear that whilst the Council will be consulted and their views will be assessed, if the airport decides not to adhere to any views or suggestions as to changes to the policy, they are under no obligation to do so.

The PB report spells out the shocking implications:

[p14] In simple terms if the airport owners issue a policy and consult with the Council on it, they can choose to ignore any views set out by the Council and begin carrying out night time flying in accordance with the policy.  There is nothing in the S106 of itself that would enable the Council to prevent night time flying in this instance.

This is a demonstration of breath-taking stupidity and negligence on the part of the Council’s negotiators.

Another cause for concern is that TDC did not provide PB with several key documents:

[p13] It should be notes [sic] that in preparing this Report we have not seen copies of the original Certificates, although the Court judgements provided did make extensive reference to them. We have also sought clarification of any other planning permissions or Agreements issued post the Certificates by Thanet Council to confirm whether any such permissions or Agreements place any restrictions or conditions on the activities of the Airport.  This clarification is awaited at the time of drafting this Report.

Thus blindfolded by the Council, it is perhaps less surprising that PB couldn’t reach a clear conclusion on the planning status of the airfield and its application for night flights.

Nonetheless, PB do seem to be surprisingly certain about the contents of the LDCs that they haven’t seen:

[p14] The LDCs issued in relation to the airport contain no restrictions on night time flying, so no planning application or variation of condition etc is required to fly at night.  Similarly the S106 is written in such a way that the airport is not required to apply through the planning process to undertake night time flying.

In fact, the LDCs do restrict night-time use of the airport, but all this will come out when this goes to the High Court.

TDC have been seeking legal advice  - hopefully their barrister will be fully informed of the background. If not, TDC lays itself open to accusations of incompetence and worse.

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Next installment: back to the Introduction

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