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RSP SCC ? NNF Response Page 1 of 49
Statutory Community Consultation by
RiverOak Strategic Partners:
a response by No Night Flights
In Part One of this response by No Night Flights (NNF), we comment on the inadequacy of
RiverOak Strategic Partners (RSP)’s consultation process.
In Part Two of our response we comment on the substance of RSP’s proposals in so far as
we can, given the lack of clarity that RSP has provided about its proposals.
RSP SCC ? NNF Response Page 2 of 49
PART ONE – the consultation process..................................................................................... 3
The applicant’s obligation.................................................................................................... 3
Failure to take reasonable care that those affected by a new cargo airport at
Manston would find out about the proposals....................................................................4
Failure to provide clear, thorough and accessible information, such that people who
will be affected by the proposal can engage with the consultation............................... 9
EU Directive 2014/52/EU...................................................................................................10
Failure to treat residents’ concerns with respect and residents’ data with care....... 11
Misleading information....................................................................................................... 12
Lack of critical information to enable the public to assess RSP’s proposals............ 13
Failure to provide the necessary information to enable local residents to assess
the likely impact of the proposal on their lives........................................................14
Flight paths...................................................................................................................15
Night flights.................................................................................................................. 16
Public Safety Zones....................................................................................................21
Other planning blight.................................................................................................. 23
Other operational impacts......................................................................................... 24
“The Rochdale Envelope”..........................................................................................24
PART TWO – the substance of RSP’s proposals..................................................................29
Opaque and unrealistic business case............................................................................29
The impact of noise on human health............................................................................. 31
The impact of noise on the education of children..........................................................35
Environmental Issues: Air..................................................................................................36
Environmental Issues: Water Pollution............................................................................38
Environmental Issues: Water – impact on aquifer recharge........................................38
Increased building on greenfield land..............................................................................38
Traffic.................................................................................................................................... 39
Dubious Job Forecasts...................................................................................................... 39
Appendix One..............................................................................................................................44
Appendix Two..............................................................................................................................45
Appendix Three...........................................................................................................................46
RSP SCC ? NNF Response Page 3 of 49
PART ONE – the consultation process
The applicant’s obligation
The Department for Communities and Local Government’s Planning Act 2008: Guidance on
the Pre-application Process emphasises the importance of effective pre-application
consultation by developers, as part of their preparation before submitting an application for a
Development Consent Order (DCO). Paragraph 20 of the Guidance says: “Experience suggests that, to be of most value, consultation should be:
? based on accurate information that gives consultees a clear view of what is
proposed including any options;
? shared at an early enough stage so that the proposal can still be influenced, while
being sufficiently developed to provide some detail on what is being proposed;
? engaging and accessible in style, encouraging consultees to react and offer their
views.” Paragraph 24: “The aim should be to ensure that consultation is appropriate to the scale and nature
of the project and where its impacts will be experienced.” The developer is obliged to seek the views of the relevant local authority or authorities on the
developer’s suggested approach to its statutory consultation duties. The guidance says:
Paragraph 38: “The local authority’s aim in such discussions should be to ensure that the people
affected by the development can take part in a thorough, accessible and effective
consultation exercise about the proposed project.” Paragraph 42: “Provided that applicants can satisfy themselves that they have made reasonable
endeavours to consult with all those who might have a legitimate interest or might be
affected by a proposed development, it would be unlikely that their application would
be rejected on grounds of inadequate public consultation.” Paragraph 49: “Applicants will also need to identify and consult people who own, occupy or have
another interest in the land in question, or who could be affected by a project in such
a way that they may be able to make a claim for compensation.” Paragraph 53: “Local people have a vital role to play at the pre application stage. People should
have as much influence as is realistic and possible over decisions which shape their
lives and communities. It is therefore critical that they are engaged with project
proposals at an early stage.” Paragraph 55: “Applicants must set out clearly what is being consulted on.”
RSP SCC ? NNF Response Page 4 of 49
Paragraph 93: “For the pre-application consultation process, applicants are advised to include
sufficient preliminary environmental information to enable consultees to develop an
informed view of the project… The key issue is that the information presented must
provide clarity to all consultees.” The local authorities in this instance are Thanet District Council (TDC) and Canterbury City
Council (CCC). The site in question is in Thanet’s area and the former official flight path
covers both the districts of Thanet and Canterbury. In March 2017, TDC articulated a
number of concerns about the developer’s proposed Statement of Community Consultation.
In summary, those concerns were:
? There was insufficient information provided by the developer about flight paths,
timing of flights and physical development of the site. ? There was no delivery strategy for the project, no business plan and no
information about financial viability or evidence of investment. ? Given the scale of the project and its impacts, consultation should be extended to
eight weeks. RSP chose to ignore the Council’s advice on this point. ? The extent of postal consultation was inadequate. All residences and businesses
within 3km of the development should be included in the postal consultation and, given the lack of information about flight paths, a consultation leaflet should be
sent to all residences and businesses in Ramsgate, the Thanet villages and
Herne Bay. All residences and businesses within 1km of the proposed or
potential flight path(s) should be covered by a leaflet drop. RSP chose to ignore
the Council’s advice on this point. ? Newspaper advertisements should be taken out in Thanet, Herne Bay and
Sandwich. ? Given the extent of the population in Ramsgate that would be affected by the
proposed development, there should be two consultation events in Ramsgate. RSP chose to ignore the Council’s advice on this point and only held one, and it
was shorter than most at 4 hours. ? RSP should make sure that it informed “hard to reach” parts of the community. When asked at one consultation event what had been done to reach people
under the flight path who had mobility issues and who did not receive a local
paper, an RSP representative replied: “You can tell them.” ? There should be a consultation event in Minster or Birchington. RSP chose to
ignore the Council’s advice on this point. Instead, two weeks into the statutory
consultation period, on June 26th RSP announced on Twitter that there would be
an informal meeting in Minster on 27th June and in Acol on 28th June. On 3rd
July, halfway through the consultation, RSP announced on Twitter that there
would be a meeting at Birchington that night and one at Chislet on 6th July. Residents in Birchington and Chislet were also informed in writing about these
presentations. These were not formal consultation events. Failure to take reasonable care that those affected by a new cargo
airport at Manston would find out about the proposals
The population of Thanet District is around 140,000. The population of Ramsgate (directly
under the flight path and part of Thanet) is nearly 40,000 and the population of Herne Bay
(directly under the flight path and part of Canterbury district) is similar. RSP took out an
advertisement in the Isle of Thanet Gazette (2015 readership 7,810) and in the Dover
Express (2015 readership 5,798) setting out the details of the forthcoming consultation. Dover is not under the flightpath.
RSP SCC ? NNF Response Page 5 of 49
RSP took out a newspaper advert in the Herne Bay Times, a free paper that can be
collected from various shops and locations around the centre of town. The advert appeared
on the very day of the Herne Bay consultation event. When asked why RSP had not made a
better job of advertising the consultation to Herne Bay’s 40,000 residents, we discovered
that RSP believed Herne Bay was in Thanet. It is not. RSP says that it sent a consultation leaflet to all residential and business addresses within
2km of the airport, extended in some places to logical boundaries such as main roads. Despite being advised by the Local Authority to do so, it did not directly contact the tens of
thousands more people who live under the former airport’s official flight path. Having
leafleted this swathe of residents ourselves, NNF knows that this can be done for a total cost
of less than £2,500. Given the scale of RSP’s proposals and the often quoted budget for the
project of £300m, it is entirely reasonable to expect the developer to spend £2,000 to £3,000
on informing the people who will be significantly affected if RSP’s Development Consent
Order application were to be successful. This is clear evidence that RSP did not make reasonable endeavours to bring to the
attention of those who would be affected by RSP’s development either the fact of the
proposed development, or the impact that this development would have on these residents
and their daily lives and on local businesses, or the fact that RSP was carrying out public
consultation on its proposals.
In contrast, RSP wrote to residents in Birchington, miles from the flight path, to invite them to
a presentation by RSP. RSP has deliberately minimised contact with those who will be
affected by its cargo airport proposals whilst at the same time reaching out to those who will
supposedly experience no downside if the DCO application is successful. RSP has been
inconsistent about which residents it chooses to communicate with directly and has made a
deliberate choice not to communicate directly with the tens of thousands of people who will
be most affected by their plans. The map showing the extent of the direct communication that RSP intended to carry out is
shown in Appendix One. When questioned at consultation events as to why a 2km limit had been chosen for the
direct communication exercise, RSP said variously that “that’s what is normal for a DCO”, or, “it is only these people who would be affected”, or that “RSP wanted originally only to contact
those within 1km of the runway. TDC wanted RSP to contact those within 3km of the runway
and so RSP compromised on 2km which was enough”. RSP’s George Yerrall also said he
looked at TDC’s advice to leaflet residents under the flight path with details of the
consultation, but that it “wasn’t a command” to him and that he decided: “I didn’t need to do
It is patently unsatisfactory to say that a 2km communication zone is normal for all DCOs. The RSP DCO application is the UK’s first aviation DCO project. The nature of aviation is
that its noise impact is not restricted to a development site, in this case the airport and its
immediate surrounds, but that it extends for some miles beyond this along the flight path. This is self-evidently true. Indeed, deep within RSP’s PEIR is the statement that: “aircraft air
noise could extend up to 14 km along the westerly runway centreline (i.e. to Herne Bay
coastline) and 3.5 km along the easterly centreline (i.e. to Ramsgate coastline)”.1 Given this,
it is telling that RSP chose not to contact the tens of thousands of people who live either side
of this 17.5km centreline. It should be remembered that a flight path is a mile wide, so
aircraft noise will be experienced for some distance either side of the centreline as well. The RSP suggestion that only the few residents within 2km of the airport boundary would be
affected by noise pollution is, of course, entirely contrary to the actual experience of local 1 PEIR 12.7.42
RSP SCC ? NNF Response Page 6 of 49
residents during the years in which the airport was open. Ramsgate residents (and others)
packed meetings at Chatham House School to complain about the blight on their lives
created by the airport’s activities. Residents spoke of their anger and desperation at the
effect aviation had on their quality of life. It is important to note that this reaction was
provoked by an annual average of just 500 freight arrivals and departures at the old airport, compared to the 10,000-17,000 freight flights now being projected by RSP. RSP’s suggestion that few residents will be affected by noise is also in contradiction to the
wealth of factual material available which sets out the real noise nuisance impact on local
residents of an operational airport at Manston. The reports commissioned by TDC from
Bureau Veritas in 2010 and Parsons Brinkerhoff in 2012, to assess how many residents
would be affected by noise if scheduled night flights were to be introduced, make it clear that
noise nuisance is not confined to a small area within 2km of the airport. Indeed, Bureau
Veritas predicted that the population within the 85 dB(A) SEL contour affected by a flight
departure to the east over the centre of residential Ramsgate would be ‘up to 30,903 [people]
for the Boeing 747-400’. RSP has not let these people know that a much, much bigger cargo
airport is now being proposed in their neighbourhood. A series of noise contour maps produced by experts and easily available in the public
domain are shown at Appendix Three. It is astonishing that RSP seems to have ignored
them. RSP is also ignoring the noise nuisance map produced by No Night Flights which shows
clearly that actual noise nuisance from planes using the old airport spreads all the way from
the coast at Ramsgate in the east, through Herne Bay town to the coast at Hampton in the
west, as well as either side of the flight path. That map is shown in Appendix Two.
It would be disingenuous of RSP to claim that it did not know that the noise and pollution
impacts of an airport at Manston would affect far more people than RSP chose to inform
directly about its consultation. Mr Freudmann was MD at Wiggins/Planestation (the first
commercial owner of the airport) for many years. He represented the airport operator at the
regular meetings of its Consultative Committee. The committee was given regular reports of
complaints made by the public. Most complaints came from Ramsgate and Herne Bay. Those complaints were about noise, pollution, low-flying planes and repeated approaches. On occasion, Ramsgate residents also reported damage to residential roofs caused by the
wind vortices created by low-flying planes. Mr Freudmann, and therefore RSP, knows full
well that residents in Ramsgate and in Herne Bay will be heavily affected by RSP’s
proposals. RSP’s consultation has fallen far short of a reasonable endeavour to inform
people who might be affected by the development and operation of a cargo airport on the old
Manston site. RSP’s statutory consultation is fatally flawed and should be treated as
such. Similarly, it is surprising that the RSP Scoping Report ignores the actual decibel levels
recorded by various noise monitors while the airport was open. Again, these were reported
to the regular meetings of the Manston Airport Consultative Committee (MACC) and to its
later incarnation, the Kent International Consultative Committee (KIACC). Mr Freudmann, RSP principal, was a regular attendee at Consultative Committee meetings. Despite the
rather patchy coverage of the physical noise monitors, noise levels of 80 to 85 average
LMax dB(A) were regularly reported at Chapel Place in central Ramsgate, as were SEL
noise levels of over 100 dB. Chapel Place is comfortably outside the boundary within which
RSP informed people of the consultation. RSP’s Mr Freudmann is fully aware of this. We can see that RSP deliberately limited the number of people to which it reached out
directly in its statutory consultation. This is not what RSP should have been doing. The
government guidance is clear:
The aim should be to ensure that consultation is appropriate to the scale and nature
of the project and where its impacts will be experienced. [Our emphasis]
RSP SCC ? NNF Response Page 7 of 49
RSP failed to cover areas in which the impact of its proposals will be experienced. This fundamentally undermines the purpose of the public consultation part of the DCO
process, which is to consult with people who will be impacted by the DCO should it be
awarded. RSP should have followed TDC’s advice and extended its consultation activities so that it
communicated directly with all those living, working and studying under and either side of the
flight path, and with those in all areas from which there have been complaints about past
commercial operations at Manston and/or areas in which there have been high recorded
noise levels. This is especially important as RSP is now proposing a 24/7 operation. The
official flight path is a mile wide. It allows for a 10 mile approach to the airport in either
direction (we do appreciate that part of this approach for arrivals from and departures to the
east is over sea). This means that, at a minimum, RSP should have written to all households
within half a mile of the centreline for the flight path, for up to 10 miles to the west and to the
coastline in the east. As part of this communication, RSP should have set out clearly how
many flights it intends to handle a year; what kind of planes it will be using; and what hour of
day or night it envisages planes taking off and landing. The Planning Inspectorate has
already confirmed in an email to No Night Flights that this would count as “preliminary
environmental information” and that it would be reasonable to expect this information to be
made available to the public as part of this statutory consultation exercise. We note that RSP informed its support group, Save Manston Airport Association (SMAa), of
the public consultation events long before they were advertised elsewhere. We note that
SMAa vigorously urged members of its Facebook group to attend (even though many of
them would have to travel from outside the area) and to submit positive feedback. RSP did
not reach out similarly to community groups who have grave concerns about RSP’s plans, such as No Night Flights, until the first consultation events were already over. They also
failed to contact all of the organisations set out in Appendix 1 of their SoCC, as they have
not, to date, made contact with the group ‘No DCO for Manston’ despite this group having a
presence on Facebook and therefore being very easy to contact. All this would, of course, serve to skew the balance of attendees at the consultation events and the feedback
submitted to the consultation. Contrary to TDC’s advice, RSP held just one consultation event in Ramsgate. This event
was on a Saturday and lasted just four hours. This was the only consultation event for
Ramsgate’s 40,000 residents and it was a shorter consultation event than those held in other
areas. Ramsgate will be the area worst affected by a new cargo airport at Manston because
it is on the final approach to the runway that is used 70 per cent of the time. The final
approach takes planes the full width of Ramsgate from the sea to the runway. As planes fly
over the outer harbour, they are at a height of 289m. As they fly over the last houses in
Ramsgate before the airport, they are clearly lower than that as they descend towards the
runway. Tens of thousands of people (as evidenced by previous expert reports by qualified
noise consultants) live under this part of the flight path. RSP did not contact people in
Ramsgate directly to let them know about their proposals and about the consultation process. When questioned as to why only one, four-hour consultation event had been organised for
the tens of thousands of Ramsgate residents who will be affected by a new cargo airport if a
DCO is awarded, RSP said that it could “only get the venue for that amount of time”. This is
an astonishingly weak response and shows that RSP is not taking its consultation
responsibilities seriously. Another resident was told that the Ramsgate consultation event
was shorter because it was a Saturday and “more people can get there on a Saturday”. Again, this is a patently unsatisfactory response given that there is evidence in the public
domain that over 30,000 Ramsgate residents will be affected by a 747-400 flying over their
In 2016 NNF reported residents’ concerns about RiverOak Investment Corp.’s Non-Statutory
Consultation. We said:
RSP SCC ? NNF Response Page 8 of 49
The first five [consultation] events were held on a weekday between 1400 and 2000. No provision was made for people who work away from their home town and who
might not be able to get back in time for 2000. The Ramsgate event was held on a
Saturday. The choice of locations means that over half of the events were held in towns that are
either a long way from the flight path at Manston (Broadstairs, Margate and
Sandwich), or that enjoy an overflying exclusion zone (Sandwich), or both. One event
was at a location (Canterbury) that was very minimally overflown during the airport’s
commercial existence. The two towns that experience what it is like to live under the
flight path – Ramsgate and Herne Bay – had just one consultation event each. No provision was made for the villages that are close to the airport to have a
consultation event.”
It is disappointing that RSP has not attempted in any way to address those legitimate
concerns in this statutory consultation, but has chosen to repeat its previous choice of
events, and its previous errors.
In contrast, RSP took pains to write to people in Birchington, a town miles away from the
flight path, to invite them to a presentation. We are told constantly that 98% of Thanet wants to see an airport at Manston (what kind of
airport these people apparently want is never specified). However, in a recent poll being
reported by SMAa to RSP and to PINS, just 286 members of SMAa, of whom apparently
approximately 214 are from Thanet, cared enough to offer their views to SMAa about RSP’s
consultation. It took SMAa more than ten days to gather up this level of interest and support. This demonstrates that nowhere near 98% of Thanet supports RSP’s plans for a cargo
airport at Manston. Having seen this poll, on Friday 21 July NNF launched its own poll about the RSP
consultation. We let the poll run for a little under 48 hours. An on-line survey was advertised
to members of the NNF closed Facebook group and members on the NNF subscription list. 318 people had responded within two days. 89 per cent of respondents live under the flight path of the old Manston airport and would be
directly impacted by RSP’s proposals. A resounding majority, 89%, had not been directly
informed by RSP of this RSP consultation.
In the absence of the developer publicising its consultation, NNF tried to step into the breach
by distributing leaflets across the flight path. We were only able to do this after the
consultation events had taken place. This meant that the majority of people were unaware
of the consultation events and so did not attend. Of our 318 respondents, 206 had not been able to attend a consultation event. It should be
noted that our respondents were drawn from a pool of established NNF supporters who were
at least aware of the events. Even so, only 34% had been able to attend any of the
consultation events. This is a disgrace and demonstrates how partial RSP has been in its
promotion of this consultation. 98% of our participants felt that the consultation was not of
sufficient length given the scale and nature of the proposed project. Of those that did manage to attend an event: ? 87% felt the event was disappointing in terms of the information available
? 86% felt the event did not provide everything they needed to be sufficiently informed
about the proposal ? 82% felt the responses from staff at the event were unhelpful, lacking in detail and/or
? Only 14% felt the event provided ample opportunity to ask questions
? Only 14% felt the event was welcoming and non-threatening
RSP SCC ? NNF Response Page 9 of 49
? Only 4% felt the event provided sufficient information on which to form a judgement
regarding the proposal ? Only 4% felt the event was well-staffed by informed representatives. Survey respondents struggled to find and/or access critical consultation documentation. Some unable to do so. Even those who did manage to access the documentation struggled
to make sense of it. Only 29 of our 318 respondents found RSP’s documentation accessible
to read in language and length. Only 13 found it sufficiently informative. Just 2 of our
respondents said that they found RSP’s documentation sufficiently referenced through
sources accessible to them to be useful to them as members of the public. This
demonstrates that RSP has not met the bar for an engaging and accessible consultation. Regarding the business case and proposal itself, our survey highlighted real deficiencies. Only 258 respondents had been able to access and read the information/documentation. They described their experience as follows:
? 96% felt there was insufficient information on timings of anticipated flights
? 95% felt there was insufficient information on numbers and timings of scheduled
night flights
? 93% felt there was insufficient information on the environmental impact of RSP’s
? 93% felt there was insufficient information on noise contours
? 91% felt there was insufficient information on flight paths
? 90% felt there was insufficient information on the number and type of aircraft
? 90% felt there was insufficient information on the social and economic impact
? 89% felt there was insufficient information on pollution
? 89%felt there was insufficient information on mitigation for those most negatively
impacted. ? 88% felt there was insufficient information on hours of airport operation
? 83% felt there was insufficient information on evidence of investment
? 81% felt there was insufficient information on public safety zones
? 73% felt there was insufficient information on the delivery strategy
? 4% were satisfied that sufficient information was provided on all/most of the areas. The NNF survey is clear evidence that the statutory consultation failed to reach the vast
majority of people who will be most affected by RSP’s proposals. In addition, our survey
reports serious failings with regard to the consultation events, the staff available to the public
at those events, the information available, the business case and the proposal itself. The
vast majority of NNF’s survey respondents come from Ramsgate and Thanet and are
extremely unhappy with the way they have been treated by RSP and with proposals that lack
any real information or detail on which to form a judgement. Ramsgate Town Council also commissioned an on-line survey to help in the development of
a Neighbourhood Plan. Responses are still being analysed. However, it is notable that four
of the top ten most agreed with comments were about the Manston site. All were strongly
against plans to re-open the airport. Overall there were three times as many comments
against opening an airport on that site as there were in favour. Comments in favour of the
airport attracted at most three agreements while four comments opposed to RSP's plans
attracted over twenty agreements with many of the others scoring double figures. Failure to provide clear, thorough and accessible information, such
that people who will be affected by the proposal can engage with
the consultation
RSP’s consultation period ran from Monday 12 June 2017 to Sunday 23 July 2017.
RSP SCC ? NNF Response Page 10 of 49
A full suite of documents – over 2,200 pages – was released on-line on the day that the
consultation period started, Monday 12 June. Consultation events took place on 14, 15, 16, 17, 20, 22 and 24 June. This meant that
residents had between two and 12 days to read and make sense of 2,200 pages, most of
which comprise unfamiliar and highly technical information, before forming their questions to
take to a consultation event in search of answers. This is inadequate and is particularly
challenging for those residents who either work full time or who do not have access to the
Internet. We understand that when challenged on this, Tony Freudmann insisted repeatedly that if
any consultee had questions or concerns after the consultation events that he or she should
just put it in writing. When it was pointed out that RSP’s lack of response to concerns which
had been raised previously meant that this was likely to be a one-way process, Mr
Freudmann confirmed that RSP would not necessarily respond directly to the consultee prior
to the consultation period ending, but insisted that the only option open to consultees was to
“put their concerns in writing”. RSP did not staff the consultation events consistently. At some events there was nobody to
whom the public could address environmental issues. At others there was nobody to whom
residents could direct questions about flight paths. For example, at more than one event
residents found that the environmental representative was too busy with other residents to
deal with questions. People who attended more than one meeting noted that not all RSP
representatives attended all the consultation events. The on-line documents appear to be documents prepared for print and then loaded onto the
website. They are extraordinarily difficult to navigate and look at off-line. It is also impossible
to search each document for key words. The only feasible way of coping with them is to
download each one and to look at them on a personal computer. This really does limit the
accessibility of the consultation material to residents who have computers at home, fast
broadband access, and room for soft copy storage. People with limited or no access to online
versions of the documents were in an even worse position given that the documents
took many hours to print. Printing a version of one’s own proved prohibitive for many in
terms of access, time and cost. EU Directive 2014/52/EU
On 16 May 2017 the UK Government transposed into law the EU Directive 2014/52/EU –
see The Infrastructure Planning (Environmental Impact Assessment) Regulations 2017. This
improved the breadth and depth of public consultations on environmental impact and closed
various loopholes that developers had found in the previous environmental assessment
In the 2016 Scoping Opinion given to ROIC (the original DCO applicant), the Secretary of
State said:
Whilst transitional provisions will apply to such new regulations, the Applicant is
advised to consider the effect of the implementation of the revised Directive in terms
of the production and content of the ES. We note that RSP (the current DCO applicant) has taken no notice of this advice.
In its consultation around the new Directive, the European Commission referred to the need
to strengthen the protection of the environment and the quality of life for those affected by
major development. The deadline for introducing new standards was May 2017. Examples of
some of the higher standards relevant to this DCO include:
? a new requirement to consider the effects that there might be on the environment
because of the vulnerability of the development to risks of major accidents and/or
disasters. Our concerns below about the need for proper Public Safety Zones are
RSP SCC ? NNF Response Page 11 of 49
particularly pertinent here. The effects on the environment and on life of a plane
crashing in Ramsgate would be catastrophic
? tighter requirements on pollution investigations, bio-diversity and impact on the
? a thorough analysis of alternatives to the project. RSP has produced nothing of
substance here. This is particularly surprising given that the Government is in the
process of trying to divest itself of unwanted military airports, at least one of
which is nearer the centre of the country and also further from heavily-residential
areas than Manston. It is telling that alternative sites play no part in RSP’s
? a new requirement to use competent experts
? the decision to grant development consent should also now include, where
appropriate, monitoring measures. This would be critical to a DCO for a major
freight airport, but RSP has put forward no details as to how it would monitor the
environmental effects of its operation. We appreciate that there are transitional arrangements. We appreciate too that RSP feels
that it does not have to abide by the 2014 Directive because RSP requested a Scoping
Opinion before the Directive came into force this year. However, we note that, by RSP’s own
timeline, the very earliest that it would expect an airport to be operational on Stone Hill Park
is 2021. Given this, we think that the Secretary of State’s advice to RSP as quoted above
was sound – RSP should pay attention to the new Directive. RSP’s position seems to be that it has crept in under the line and that it can carry out a lower
standard of environmental assessment for a development that will go live in 2021 or later. This would be four years after the EU’s deadline for all countries to have brought the new
standards into play. If RSP persists with this strategy of relying on out-of-date environmental
regulations and treating local residents to an outdated and inferior standard of environmental
impact assessment, it would not be a surprise to see the matter determined at the
appropriate time by a Judicial Review. Failure to treat residents’ concerns with respect and residents’ data
with care
In 2016, ROIC held a series of non-statutory public consultation events. Despite telling the
public that these events were “a progress report only” and that they were not going to be a
part of the DCO process, they appear to have been reported to PINS as if they were actually
a first formal round of consultation. We reported at the time the concerns of a significant number of residents that, during the
2016 events, ROIC had allowed airport supporters to handle residents’ personal data;
steward the events; prevent residents from asking questions of ROIC’s representatives; and
that the atmosphere was unwelcoming and intimidating for those residents who expressed
concerns or challenges. TDC was so concerned about this that, in its response to RSP’s Draft Statement of Statutory
Community Consultation, it said: “There should be no intimidation or disregard of attendees
at consultation events and all those present on behalf of RiverOak should be from RiverOak
itself or consultants employed by it.” RSP responded by saying: “RiverOak confirms that
there has never been any intimidation or disregard of attendees at consultation events and
that there will not be any at the forthcoming statutory consultation events.”
It is appreciated that RSP did not use airport supporters as informal members of the RSP
team in the 2017 consultation events. However, RSP’s assurance that there had never been
any intimidation or disregard of attendees at the 2016 events, and that there would not be
RSP SCC ? NNF Response Page 12 of 49
any at the 2017 events, ignores the facts of the 2016 events and was not borne out by the
2017 events. Residents reported to us that RSP representatives said to them:
? “I don’t give a shit about night flights” ? “I don’t give a fuck about night flights” ? “Here you go again, just like last year”. Residents reported that RSP representatives referred to Thanet residents as “knuckleheads” and “a bunch of commies” and to TDC councillors and officers as “muppets” and “fuckwits”. Some residents reported RSP representatives standing around them when residents were
trying to ask questions. One said: “As I tried to put my questions or share my evidence, it
became clear that the job of the others was to laugh and to say that I was wrong.” Others
? “I felt intimidated by the circling heavies as I tried to put my questions” ? “It’s undermining to be openly scoffed at when you’re trying to raise concerns” ? “I told them I had spoken to Stansted and that I was told that there was plenty of
spare capacity for cargo there. They just laughed at me and said ‘You’re wrong’ and ‘of course that’s what they would tell you’. I can stand up for myself, but it’s
inappropriate to behave in this way in what should be a public consultation event” ? “Again and again I found myself asking someone questions only to be told, ‘I
don’t know about that, you need to speak to X’. But X was never available to
speak to. I came away with my questions unanswered.” A prominent SMAa campaigner and new Kent County Councillor, Paul Messenger, was seen
taking away from one consultation a box of what appeared to be completed feedback
questionnaires. We have grave concerns about the data protection issues implicit in this. We
also note that, as part of the 2016 informal consultation, ROIC had to accept that some
consultation forms that had been handled by airport supporters had been ‘lost’ and that it
never received them. RSP has laid itself open to the same challenge this year by allowing a
member of the public and a well-known and active airport supporter to remove forms from
the consultation. Misleading information
At the consultation events, RSP produced a large display panel. The first paragraph of the
panel ended with the claim that RSP’s proposal would create almost 30,000 jobs “in East
Kent”. This claim was spotted during the first hour of the first consultation event in Herne Bay
on 14 June 2017. It was brought to the attention of Dr Sally Dixon, the RSP team member
responsible for producing the freight and jobs forecasts. She accepted immediately that this
was not correct. Her claim is that RSP’s proposal will create almost 30,000 jobs somewhere
in the world. She said that she was embarrassed to be so misreported; that she understood
that it was misleading; and that she would get it altered. The panel was not altered during
the Herne Bay consultation event. On 15 June, in Broadstairs, the panel was there again, including the knowingly inaccurate
claim of creating 30,000 jobs in East Kent. Dr Sally Dixon was challenged on this again and
said “I feel like taking the Tippex to that myself”. The resident who raised this with her replied: “but you haven’t, have you?” pointing out the fact that the RSP knew about this important
error but had chosen to leave it uncorrected. On 16 June, in Cliffsend, the panel was there again, including the knowingly inaccurate claim
of creating 30,000 jobs in East Kent. George Yerrall confirmed that Dr Dixon had brought the
error to his attention “straight away” during the Herne Bay event. Mr Yerrall was invited, on
the record, to explain why he had allowed information that he knew to be inaccurate and
misleading to continue to be put before the public. He said: “I’m not going to jump through
hoops for you.”
RSP SCC ? NNF Response Page 13 of 49
On 17 June, RSP issued a statement on its website saying:
An omission was found on page 3 of the Overview Report, where it states: Thank you
for coming to our exhibition. We, RiverOak Strategic Partners (‘RiverOak’), are
proposing to reopen Manston Airport as a vibrant air freight hub with associated
business aviation and passenger services, creating almost 30,000 jobs within East
Kent by the airport’s 20th year of operation.” The end of this sentence should read: “creating almost 30,000 jobs within East Kent
and the wider economy by the airport’s 20th year of operation’. Please note, the correct phraseology was used on pages 8 and 42 of the report. The omission has now been corrected on the downloadable version of the document
and on the corresponding exhibition panel.
Importantly, the current version which is available on the RSP website does not
acknowledge or make it clear that it is an updated version. This is not transparent. At the Chislet presentation on 29 June, Sir Roger Gale talked about 30,000 jobs that the
RSP would bring to the local area. He did not clarify that this optimistic estimate refers to
30,000 jobs across the entire globe. Thanet is an area that suffers from high unemployment
and his assertion was met with vigorous applause. Many, many local people think that this
proposal will create 30,000 jobs in Thanet or in East Kent and RSP allows these
statements and beliefs to go uncorrected. This is extremely disturbing behaviour by RSP. At around 3pm on 14 June RSP knew that its
Overview Report and its biggest display panel were promising the creation of almost 30,000
jobs in East Kent. RSP accepts that, even by its own optimistic numbers, the East Kent jobs
that it actually forecasts that it could create are a fraction of that number. RSP chose to do
nothing to correct this until George Yerrall was challenged to explain on record why he had
chosen not to issue the correct information. Everyone who downloaded a copy or picked up
a copy of the Overview Report and all those people who attended the events in Herne Bay, Broadstairs, and Cliffsend will have seen the inaccurate information. RSP continued with the
inaccurate information long after it had accepted that to do so would be to mislead the public. This is deceitful. Lack of critical information to enable the public to assess RSP’s
RSP has provided very little information on how it arrived at its very optimistic freight
forecasts. Challenged as to which UK airport a new airport at Manston would be winning
business from, RSP responded in various ways: “We will attract business from Stansted. Stansted has no cargo capacity and they
want to use their cargo slots for passenger flights.”
“We won’t be trying to take business from UK airports. 2m tonnes of air freight is
currently being flown into European airports and then trucked here because there is
no capacity at Heathrow, Stansted or East Midlands.” RSP’s claim about the lack of capacity at Stansted does not match reality. NNF has been in
touch with the operator at Stansted. Stansted’s position is that it has capacity for more
freight flights; that it is investing in its cargo-handling operation and that it expects to expand
the amount of freight that it handles. Likewise, East Midlands Airport currently handles
around 300,000 tonnes of freight a year and says that it can handle an additional 900,000
tonnes with the existing runway. Heathrow, whose freight is mainly bellyhold freight, is
embarking on an £180m expansion plan for its cargo handling operation. RSP’s sweeping
claims of no air cargo capacity in the UK are not evidenced and simply do not add up.
RSP SCC ? NNF Response Page 14 of 49
At the consultation events, RSP’s Dr Dixon explained that her freight forecasts relied heavily
on a series of unpublished papers by Transport for London (TfL). It was put to her that this
was unacceptable. The public has no access to these documents and so cannot form an
informed view about RSP’s freight forecast. Similarly, a document produced for Kent County
Council by Dr Fragkiskos Fillipiaos is referred to in the documentation but is unavailable to
the public. Although in the narrative, Dr Fillipiaos’ work is referred to as a paper, in the
reference section it is referred instead to as a “lecture”. In discussion with residents, Sally
Dixon found it “curious” that the paper wasn’t available. Both examples given mean that the
consultation is neither “engaging” nor “accessible” for local residents. This suite of TfL
documents is apparently central to the calculation of RSP’s forecasts and is therefore critical
to its DCO proposal. By relying on secret documents, RSP has prevented the public from being able to
interrogate the underlying data. Dr Dixon agreed that the situation was “Not ideal, no” but
was unable either to quote useful information from these secret papers or offer any
assistance as to how residents might be able to access them. The public must have access
to the core information underpinning the business case if it is to be able to develop an
“informed view” as to the credibility or otherwise of what is being proposed. This is a recurring theme with this DCO application. In its non-statutory consultation last year, RiverOak Investment Corp. LLC also relied on papers not available to the public. We said
this in our response to the ROIC non-statutory consultation in 2016: “I spoke to Toby Gibb, RiverOak’s environmental representative. I asked him about
the metric that RiverOak has suggested to the Planning Inspectorate for assessing
night noise (para 11.7.23 of their Scoping Report). He said that the claim that the
impact of night flights on residents would only be significant if there were 18 or more
90dB flights a night comes from a Swiss study which says that we wake up 18 times a
night anyway. I’ve since identified that study (it’s German and refers to Leipzig airport)
but cannot get hold of a copy. I’ve asked him for one and have heard nothing back. Residents should be able to access information this critical to their future life under
the flight path, or how can we possibly give informed answers to the consultation?” We also said a year ago that “Any supporting studies or documents [must be] made
available to the public before the consultation begins.” Members of the public spent some
months trying to get a copy of the study referred to above, but were not able to do so. Amec
Foster Wheeler, ROIC’s and then RSP’s environmental adviser, refused to release it. This is
unacceptable. Failure to provide the necessary information to enable local residents to
assess the likely impact of the proposal on their lives
Under the Environmental Impact Assessment (EIA) regulations, Preliminary Environmental
Information means information referred to in Schedule 4, Part 1, which has been compiled
by the applicant and is reasonably required to assess the environmental effects of the
development and any associated development. The Planning Inspectorate (PINS) confirmed
to No Night Flights that it would be reasonable to expect that RSP would make clear to the
public the likely impact of its operations. The public could reasonably expect to be told
whether their home/business/place of work/school would be affected by the developer’s
plans. This would mean at the very least spelling out to the public:
? the expected flight paths
? hours of airport operation
? number and type of aircraft
? expected time of day or night of flights
? site lighting
? numbers of HGVs
RSP SCC ? NNF Response Page 15 of 49
? noise mitigation plans
? compensation plans
? pollution implications. RSP has failed spectacularly to provide this information as part of its pre-application
consultation process. We set out some examples below. Flight paths
It is of critical importance that RSP sets out clearly what it is consulting the public about. RSP must provide sufficient preliminary environmental information to enable consultees to
arrive at an informed view as to what the proposals are; what impact they will have; and
where and on whom that impact will be felt. RSP has failed spectacularly to do this. At the
consultation events RSP gave inconsistent answers to questions from the public about flight
paths, saying variously:
? The flight paths had not been determined
? The flight paths would in essence be the old flight paths
? RSP could only show potential ‘flight swathes’ ? The flight paths for a fully-loaded cargo plane would be as they were before, i.e. a
10-mile straight line approach to the centreline of the runway over either
Ramsgate or Herne Bay
? The flight paths would be different
? When pressed, Dr Sally Dixon agreed that given the orientation of the runway
and the overriding default being pilot consideration of prevailing weather
conditions and safety, the flight paths would be very significantly what they
always were – namely over Ramsgate and Herne Bay. People at the Ramsgate consultation were told that the flight paths were going to be altered
so that almost all of them were over Herne Bay. People at the Herne Bay consultation were
told that the flights would be altered so that they would be over the land between Herne Bay
and Ramsgate. Others were told the flight paths would be altered so that they would be over
Wingham and Preston. It really does appear as if RSP is seeking to conceal from the public
the unpalatable truth about the flight path. This in no way gives the public the information we need to be able to understand the impact
that a cargo airport at Manston would have on our lives. It is particularly troubling to see at
two different consultations that a former departure path towards the west 2
, peeling north
over Reculver, was being sold as the flight path for arrivals from and departures to the west. Residents have reported back to us that they heard other members of the public saying: “Oh,
if that’s the case, I’ll be happy with that, that’s not over me” and had to intercede, pointing
out that this flight path had only ever been for departures, not arrivals, and that a fully-laden
cargo plane would not, according to both the Civil Aviation Authority and RSP’s own
airspace expert, be able to use that path for arrivals from the west. It transpired that the RSP
team members pushing this flight path had no idea that this path was unidirectional when it
was previously in use by the old airport. It also transpired that members of the RSP team
thought that this flight path was the sole flight path and had no idea that planes approached
the runway from different directions. This is unacceptable. It means that members of the
public have been misled into thinking that there will be new flight paths that will not overfly
their home. This is all the more troubling when, buried at the back of volume IV of RSP’s PEIR there are
four flight paths shown. These are the flight paths that existed before (minus the path that
came north from the Dover beacon and then turned over Canterbury). These flight paths
should have been put front and centre of all RSP’s documentation and consultation events. 2 RSP’s PEIR volume 4, 3.32 d
RSP SCC ? NNF Response Page 16 of 49
Too many people have left various events and presentations believing that RSP’s a cargo
airport at Manston will not affect them in any way.
It is a fatal flaw of this public consultation not to be able to spell out clearly to people whether
or not they would be under a flight path. Aircraft noise is widely accepted, including by the
UK Government, to be the negative impact associated with aviation and with airports. RSP
has failed to tell people transparently whether or not they would experience aircraft noise as
a result of the operation of a new cargo airport at Manston. This renders the public consultation useless and therefore void. Night flights
RSP gave inconsistent answers to questions from the public about night flights, saying
? The estimate of eight flights per night given by RSP in its consultation material is
a finger-in-the-wind guesstimate with no evidence behind it
? “PINS made us put in a number for night flights” ? “The CAA made us put in a number for night flights” ? “It’s a guess to keep the Planning Inspectorate happy because they’re using us
as the pilot case for the London Heathrow DCO, and they said we had to put in
night flights.” This, of course, is entirely inaccurate as it was RiverOak Investment
Corp. (the original DCO promoter) who first raised with PINS in a meeting on 23
February 2016 the potential need for night flights. PINS has since confirmed to
NNF that it was indeed ROIC who first raised the possibility of night flights. It is
dishonest of RSP to pretend otherwise to the public
? There will not be any night flights
? RSP does not “give a shit” about night flights and RSP does not “give a f***” about night flights
? There will, of course, be night flights as planes will start leaving from 06:00, but
RSP does not know how many there would be every morning
? There will be unscheduled night flights as, inevitably, planes will arrive late
? RSP does not want night flights but accepts that cargo customers often prefer
night flights and will demand them, and RSP would have to look at that seriously
? RSP does not want night flights and all cargo customers will have a preference
for day slots
? The cargo will be perishables and so the planes will be “in and out quickly with no
need for night flights” ? The cargo will be coming in from areas of Africa in the same time zone so night
flights would not be needed
? RSP has no idea whether it would need night flights
? RSP has “assessed the potential for night flights”, but it depends on what freight
companies want to fly from Manston as to what times of day or night they will fly. When asked if RSP had any freight companies lined up, RSP replied “No”. The
business model representative then went onto explain that a lot of freight
companies wanted night flights and RSP will allow night flights but make them
more expensive. ? Dr Sally Dixon said to one questioner, “There will be no night flights. Flights will
not be scheduled until after 6am.” When it was pointed out that night in aviation
terms is 2300 to 0700, she said “The passenger flights we want to attract need
these ‘shoulder periods’ during the night to be able to maximise their flight
schedules.” ? Repeatedly, to various participants, RSP representatives said that night flights
would not be needed and that operations would be like “Frankfurt, where there is
a curfew on night flights”. This is something that has been repeated frequently on
social media as ‘evidence’ that there will be no night flights. RSP representatives
RSP SCC ? NNF Response Page 17 of 49
did not tell residents that, at Frankfurt, scheduled flights start at 0500 – just six
hours into what should be an eight hour night curfew. RSP has been wholly inconsistent in its handling of this critical issue for those tens of
thousands of people who live under the flight path. It is clear that RSP is intending to have
scheduled night flights. Question 6 on RSP’s consultation feedback form says:
As part of the development of the project, RiverOak have been exploring the potential
impacts and benefits of limited night flights at Manston Airport. Night flights will make
Manston Airport even more attractive for air freight and will allow us to explore more
opportunities for benefits in the region but come with additional impacts. RSP’s suggested staff shift system allows for 24-hour operation, which suggests that there
will be night operations. RSP says in its consultation documents that flights will be
“predominantly” during the day, which can only mean that the rest of the flights will be at
night. It also says that there will be “a small number of night-time flights, the details of which
will be determined as part of the ongoing project design”. This simply is not good enough. RSP needs to spell out to the public what this might actually mean for us, now, as part of the
statutory consultation. On 13th June 2017 George Yerrall told Kent News: “RiverOak will seek to minimise night flights and incentivise airlines to fly during the
day by levying additional charges and requirements on any night movements. However, we recognise that night flights might be unavoidable in certain operating
circumstances. Therefore, whilst our proposals work on the basis that air freight operations would be
predominantly during the daytime, we are assessing the possible impact of a small
number of night flights.” However, RSP is not assessing the possible impact of night flights as part of its statutory
consultation, because it is not giving the public the information we need as to how many
night flights there might be; at what time of the night they might happen; and how loud they
might be. RSP is quite obviously ignoring the facts about the air cargo market when some of its team
members claim that a new cargo airport will not need night flights:
? The first airport operator at Manston, Wiggins/Planestation, applied for scheduled
night flights saying they were essential for its passenger business
? The second airport operator, Infratil, applied for scheduled night flights saying
they were essential for Infratil to be able to lure BA World Cargo (BAWC) to move
its operation to Manston. BAWC had a set schedule that it wished to fly. That
schedule consisted of 1,144 night flights a year (eleven weekly turnarounds). The
fact that Manston had ample day slots available was of no interest to BAWC
whatsoever. The cargo operation was a night operation. ? The second airport operator, Infratil, then applied twice more for scheduled night
flights saying they were essential for Infratil to be able to attract any cargo
business to the airport
? The third operator told the Transport Select Committee on Smaller Airports that it
had been unable to attract some cargo operators to Manston because it could not
offer scheduled night flights. This was an important factor in the failure of the
airport to break even financially
? RSP is applying for a DCO to develop a dedicated cargo airport at Manston. 42
per cent of dedicated cargo flights in Europe take place at night 3
. In 2016, 58 per
cent of cargo flights at East Midlands, the UK’s biggest dedicated cargo airport, 3 Dependent on the Dark: Cargo and other night flights in European airspace, Eurocontrol 2009
RSP SCC ? NNF Response Page 18 of 49
took place at night 4
In 2016, 32 per cent of cargo flights at Stansted were night
? The Government recognises that air freight operators require night flights: “Stansted is also a hub for several large freight and express companies, which
require the flexibility to fly throughout the night in order to ensure timely next day
deliveries to key markets. Freight services make up approximately 35 per cent of
Stansted's night movements.6
RSP claims that night flights were only needed in the past because Manston had just two
cargo stands and so was constrained by how many cargo flights it could handle in a day. This argument does not hold water. In its last full year of operation Manston had 511 cargo
flights. This means that the airport only ever handled on average one to two cargo flights in
any 16-hour day. RSP, along with Wiggins/Planestation and Infratil, has always claimed that
Manston was extremely efficient and fast in its handling of air freight. However, if we are to
believe RSP’s new claim that Manston failed in the past to attract cargo customers because
it had only two aprons, and therefore could only handle one cargo plane at a time, the
implication is that the former airport operator took between half a day and one full day to
deal with each cargo plane and that is why it could not cope with more than one or two cargo
planes in a 16-hour day. This is not credible. We accept that having two aprons imposed a limit on throughput, but we know from former
airport staff that that limit was rarely met or exceeded. There were never traffic jams at
Manston, and hardly ever queues. One plane every 2½ hours through the daytime would
have been five times the traffic Manston actually handled. It is laughable to suggest that
Manston was doomed by an ‘apron bottleneck’ – the problem was never too many planes, but too few. The idea of an ‘apron bottleneck’ as the key constraint is made all the more unlikely when
one appreciates that, on many days of the week, the airport handled no cargo planes at all. It
would have had 16 hours clear capacity on those days – and still it failed to attract dedicated
cargo business. The more likely explanation for the old airport’s repeated failure is that it
failed to attract cargo business because of its location and because it could not offer
scheduled night flights.
It is a fatal flaw in RSP’s consultation that it has not set out a clear and credible picture of the
likely number of scheduled cargo night flights needed if its proposed cargo airport is to
succeed. In the consultation events, RSP representatives confessed that the company has
no firm business commitment from any air freight operator beyond a “we would consider
Manston” email from Atlas Air. Logically, therefore, RSP has no idea whether or not any
future potential customers will require night flights. Given that, RSP cannot say with any
certainty that there will be no night flights. What RSP should therefore have done as part of
its statutory consultation is to set out for the public a possible ‘worst case’ for night flights. The relevant evidence that RSP should have taken into account when putting together a
‘worst case’ is this:
? 42 per cent of cargo flights in Europe are night flights
? 58 per cent of cargo flights at East Midlands are night flights
? 32 per cent of cargo flights at Stansted are night flights. This understates the real
position as Stansted is using a 23:30 to 06:00 definition of ‘night’ ? Every previous operator of the old airport at Manston cited the need for
scheduled night flights if the airport was ever to be viable
4 EMA Consultative Committee, March 2016
5 10,475 night flights at Stansted of which 35% were cargo flights, making 3,666 cargo night flights out
of a total of 11,334 cargo flights in 2016
“Night flight restrictions at Heathrow, Gatwick and Stansted – Consultation document” – DfT Jan
2017. Paragraph 1.41
RSP SCC ? NNF Response Page 19 of 49
? In PEIR volume I RSP 7 has included in its freight estimates both integrators
(despite having told residents at the consultation events that it did not want
integrator business) and postal services. These types of customer invariably
require night flights.
It would be wholly reasonable therefore to assume that 40 per cent to 50 per cent of
dedicated cargo flights at a reopened Manston would be night flights, i.e. 12 to 20 flights on
average every night if Manston were to achieve its stated aim of 10,000 to 17,000 cargo
flights a year. This should have been put to the public as a possible scenario. RSP has failed
to set out for the people who would be affected by a new cargo airport what the likely impact
would be on them. This is unacceptable and another fatal flaw in RSP’s consultation process. As a footnote on night flights, it must be noted that the MP for Thanet North, Sir Roger Gale,
is a tireless champion for Mr Freudmann and whichever consortium or company Mr
Freudmann brings to the table in a bid develop a cargo airport at Manston. Sir Roger says
regularly in the local Press, in interviews, and at presentations to local residents that the
suggestion that there will be night flights is inaccurate and mischievous. Many residents
assume that their MP is telling them the truth. Given this constant stream of communication
from the local MP claiming that there will not be night flights, it is even more important that
RSP should come clean in this statutory consultation about the fact that there will inevitably
be night flights. Many local people who support the airport genuinely believe that they are
supporting a proposal for a little passenger airport with cheap flights to sunshine destinations
and no night flights. At the consultation events, RSP representatives have done little, and
sometimes nothing, to dissuade residents of this rose-tinted picture of what is being
proposed. Noise
RSP produced only very limited information about which areas of the district would be
affected by the noise created by the proposed nationally significant cargo airport. Chapter 12
of the PEIR, which deals with noise impact, is a highly technical document which is largely
focussed on the techniques to be used for assessing the impact of noise, rather than
clarifying what that impact will be. To clarify, pages 12-1 to 12-8 (48 pages) document the
technical assessment process, with only pages 12-49 to 12-51 (3 pages) documenting the
calculated or estimated impact. Additionally, there are no plans or maps showing the affected areas, despite them being
listed in paras 12.11.20, 12.11.21 and 12.11.22. When asked why a diagram had not been
included, RSP’s consultant said that this was because the impact assessments were only
preliminary. When it was pointed out that a diagram showing flight paths had been included, even though these were also preliminary, the consultant claimed these were somehow
different, but when further pressed could not provide an explanation. Furthermore, Chapter 12 of the PEIR is so full of acronyms that it is virtually impossible for a
lay person to read. Failure to provide clear and unambiguous information on the impact of noise, which is
arguably the most significant potential impact from the proposed development, is a major
failure. RSP also gave inconsistent answers at consultation events to questions from the public
about noise, saying variously:
? It was not necessary to produce noise information for the public consultation as
the consultation was “only about the infrastructure” ? It was not possible to say at this stage which residents would suffer a “significant
impact” from noise
7 Para 3.2.165
RSP SCC ? NNF Response Page 20 of 49
? There was no map or plan that set out the noise impact of RSP’s proposals
? Residents should look up the Government guidance as to what “significant
impact” meant
? RSP had looked at noise in an area about 1km to 1.4km around the runway
? RSP would pay for triple-glazing and “all residents whose house lost value
because of the new cargo airport would be compensated” ? When challenged by residents sharing their past experience of the many noise
events at the old, much smaller airport that were shown by the noise monitors to
be well over 80dB, RSP told residents that these were “isolated incidents”, which
is a gross distortion of the truth
? RSP had not appreciated that there are around 440 listed buildings in Ramsgate. Some of these listings represent a whole terrace of 15 or more separate
dwellings, so the real number of individual listed houses and other buildings is
much higher. RSP representatives were surprised to learn that their suggestions
of double or triple-glazing were therefore unlikely to constitute a workable solution.
It is self-evident that the developer needs to set out which residents will be affected by the
developer’s proposals; how those proposals will affect residents; and the extent of that
impact. RSP has completely failed in this statutory consultation to set out for residents what
the noise impact on them would be of a new cargo airport at Manston. RSP has in no way
equipped residents to understand what RSP’s proposals may mean for them and their daily
lives. This renders the consultation void. As a footnote, Table 12.8 of RSP’s PEIR volume III mentions an historical log of ATMs given
to the consultants by RSP. It says that the log covered April 2012 to September 2014. This is
troubling as the airport closed in May 2014. RSP suggests a “zone of influence” of 5km for noise
8 due to the operation of its proposed
cargo airport. This is inaccurate and RSP knows this. The noise contour maps produced by
previous noise experts, and the noise nuisance map produced by No Night Flights, make it
clear that noise resulting from the operation of an airport on that site constitutes a nuisance
far beyond 5km from the runway. RSP also admits this in its PEIR vol I section 12.7.42. Pollution
As we mention above, there was no information available about noise pollution and the area
that might be affected. RSP admitted that it has not yet started the assessment into the possible impact of run-off
into the nearby Site of Special Scientific Interest (SSSI) at Pegwell Bay and so it had no
information to offer. RSP claimed to have agreed a methodology for the design of the
surface water run-off treatment and discharge system, but conflicting information about its
design was provided by two separate RSP consultants. One claimed that the system had not
yet been designed. The other claimed that the design was completed – if that was indeed
the case, why was there no information provided about it as part of the consultation
Given the extreme sensitivity of the receiving water, Pegwell Bay, this is a considerable
weakness in the PEIR. Pegwell Bay is designated as a RAMSAR site, a Special Protection
Area, a Special Area of Conservation, a shellfish fishery and a Site of Special Scientific
Interest. It is an area in which there is significant local interest. No specific information regarding the impact of noise on the designated features of Pegwell
Bay has been provided. This is surprising, given the very clear link between aviation noise
and breeding and overwintering success in sea birds. Pegwell Bay is already under pressure
8 PEIR volume I table 5.1
RSP SCC ? NNF Response Page 21 of 49
due to the influence of other factors such as human disturbance, and so the additional
impact from RSP’s proposed development clearly needs to be properly quantified. Likewise, there is no information on the potential impact of sediment or other pollutants
which may be present in surface water run off which is to be discharged into Pegwell Bay. This will have a potential, but entirely non-quantified, environmental impact on the marine
algae species which are part of the designation for the receptor. One resident in particular had tried hard at the non-statutory consultation in 2016 to get
some answers on the topic of potential pollution and had followed up by email. Following
RSP’s statutory consultation in 2017, this resident reports on his blog that RSP seems to
have done no work on the issue since then. He says:
Their [RSP’s] main concerns seem to be related to conforming to the minimum
requirements required by The Department for Transport to initiate a Development
Consent Order… the representatives I spoke to just didn’t seem to have a good grasp
of the environmental impact of an airfreight hub. He goes on to talk about: … a recent change of attitude towards diesel road vehicles due to the discovery that
the tiny particles that come out of their exhaust pipes are killing people. […] It is
important to appreciate the government is very concerned about the effects on people
living upwind of major road junctions where as much as 10 tons of diesel is burn in a
year. RSP has not provided a full calculation of the number of HGVs implicit in its proposal, and
nor has it spelled out to the public the potential for diesel pollution on the roads near the
It is unacceptable that RSP should hold a statutory consultation about a potential new
cargo airport if it has inadequate information to give the public about noise and air
pollution. Public Safety Zones
No Public Safety Zone (PSZ) has ever been implemented for Manston. The area of a Public
Safety Zone corresponds to the 1 in 100,000 individual risk contour for an airport. The PSZ
tends to be two triangular shapes extending out for 3 to 4 kilometres from either end of the
runway. It is statistically more likely for an airport-related aircraft incident to occur on landing
rather than on take-off so the landing PSZ tends to be a longer triangle than the take-off
Infratil’s 2009 Master Plan acknowledged that a PSZ should have been implemented. However, no PSZ was ever implemented. By looking at other airports and knowing the
pattern of aircraft take-offs and landings at Manston it is possible to gauge the likely shape of
the PSZ that would affect Ramsgate. The prevailing wind direction means that 70% of the
landings are made over Ramsgate. Aircraft landing at Manston used to line up at just 289
metres above the harbour and then descend across the most densely populated area of
Ramsgate to the runway at the edge of town. Depending on the exact trajectory, they would
overfly one of three schools. The 1 in 100,000 contour would extend approximately 3.5km to 4km from the end of the
runway. It would cover a substantial area of Ramsgate right down to the harbour. Three
schools, Clarendon House Grammar School, Christ Church Primary School and Ellington
Infant School, are within the 1 in 100,000 risk contour. The 1 in 10,000 contour is estimated to be a triangle extending 1km to 1.5 km beyond the
end of the runway. If a PSZ were implemented now, we calculate that the 1 in 10,000 risk
contour would include a number of residential streets in Ramsgate (Kirkstone, Whinfell,
RSP SCC ? NNF Response Page 22 of 49
Drybeck and Kentmere Avenues and part of Windermere Avenue). If a PSZ were introduced,
the homes on these streets would need to be emptied: “The Secretary of State wishes to see the emptying of all occupied residential
properties, and of all commercial and industrial properties occupied as normal
allday workplaces, within the 1 in 10,000 individual risk contour.” 9
RSP’s responsibility as part of its statutory consultation is to make clear to a number of
residents that a successful DCO and airport at Manston could cost them their home. RSP
has failed to do this. The planning blight for Ramsgate of a proper PSZ would be significant. The implications of
the introduction of a PSZ have not been spelled out to local residents. “…there is a general presumption against new or replacement development, or
changes of use of existing buildings, within Public Safety Zones.” 10
This would substantially hamper much-needed regeneration of the town. RSP has failed to
warn residents about this. The Minister for Aviation’s letter of 28th October 2010 made it clear that proper PSZs for
Manston should be implemented. The letter stated that the threshold for PSZs is usually
1500 flights per month. In its Master Plan of November 2009 Infratil predicted that it would
cross this threshold in 2010. RSP’s plans are for 10,000 to 17,000 cargo flights; 10,000
passenger flights; and an unknown number of other flights. Even at the lower number of
freight flights, RSP’s business plan will take it comfortably over the threshold for a PSZ. However, residents who will be affected by new PSZs have not had this brought to their
attention. As of May 2014, Manston is no longer an airport. A new airport developed on that site would
need to be brought properly within the planning regulations. The old airport avoided this by
relying on its previous status as a mixed military and civilian airport before the military
withdrew and it transitioned to being a commercial airport. The necessary PSZ could have
financial implications:. “The refusal of planning permission on Public Safety Zone policy grounds does not
carry with it an automatic entitlement to compensation. But there may be a right to
compensation under a purchase notice if a site or property is incapable of being put to
any alternative beneficial use as a result of it being within a Public Safety Zone.” 11
Ramsgate residents have seen a rise in the value of their property since the closure of the
airport. It is estimated that roughly 4,500 households comprising nearly 10,000 people live
within the 1 in 100,000 contour. These people may well have a claim for compensation too. The number of flights is not the only risk factor that needs to be taken into consideration
when determining when the time has come to introduce a PSZ. The CAA
12 states that the
risk model looks at ‘three main factors’:
? “crash frequency – the chances of an accident happening near a particular
airport, taking into account the numbers and different types of aircraft using the
9 DfT Circular 1/2010
11 DfT Circular 1/2010
12 Proposals to Revise the Public Safety Zones at Bournemouth Airport, Annex C, CAA, August 2010, pops 7-8.
RSP SCC ? NNF Response Page 23 of 49
? crash location – the areas around an airport where a crash is more likely to
occur, taking into account the locations of previous aircraft accidents in the
vicinity of airports, and
? crash consequence – the probable size of the crash site and the likelihood of
people on the ground being killed.” As the aircraft are at a height of only 289 metres above sea level when they line up over
Ramsgate Harbour and then descend over a densely populated area, crash consequences
would be catastrophic.
It is the safety concern which is paramount. At least two houses in Southwood Gardens have
lost large areas of roof tiles as a result of ‘wing-tip vortices’ caused by an Ethiopian airliner
coming in to land. In one incident, a large section of roof narrowly missed one of the
residents sunbathing in her back garden. Five of the cargo airlines which flew into Manston
in the last few years of its operation were either banned from European air space or fined
heavily for safety breaches.
In August 2010, Ramsgate had a near miss with a heavily overloaded Kam Air flight which
demonstrates that the creation of PSZs is no empty exercise. As it tried to lift off, the Kam Air
plane struck its tail 35m before the end of the runway, continued onto soft ground and ran
over an approach light. The tail skid scored a 117m-long mark before the jet became
airborne. Kam Air was almost immediately banned from European air space. Thanet was
lucky to avoid a major disaster. Previous airport customers such as Meridian and Airlift International were banned from EU
air space and Egypt Air received a warning from the EU. MK was another regular customer
at Manston – an airline that attracted attention because of crashes in 1992, 1996, 2001 and
2004. The 2004 crash at Halifax, Canada, spread debris far and wide. Another Manston
customer, Atlas Air was fined $500,000 by the US Federal Aviation Authority for improper
maintenance practices. (It is unclear if this is the same Atlas Air that has expressed an
interest to RSP in operating at Manston. We hope not!)
RSP has not brought to the attention of affected residents in Ramsgate the substantial
negative impact on their homes and their freedom to develop those homes as and when a
proper PSZ is implemented. This is irresponsible and a fatal flaw in RSP’s consultation
process. Other planning blight
RSP has not set out the extent to which a successful airport on that site might prevent other
developments from taking place. The National Planning Policy Framework and the Noise
Statement for England say that exposure to noise at the “significant observed adverse effect
level” should be avoided. This is the level of noise exposure above which significant adverse
effects on health and quality of life occur. The NPSE has the following to say about this level: “Increasing noise exposure will at some point cause the significant observed adverse
effect level boundary to be crossed. Above this level the noise causes a material
change in behaviour such as keeping windows closed for most of the time or avoiding
certain activities during periods when the noise is present. If the exposure is above
this level the planning process should be used to avoid this effect occurring, by use of
appropriate mitigation such as by altering the design and layout. Such decisions must
be made taking account of the economic and social benefit of the activity causing the
noise, but it is undesirable for such exposure to be caused.” This means that large areas of Ramsgate could start to experience planning blight. TDC will
have to take planning decisions that take account of the need to avoid new development
near the airport if that development could put people into the position in which they would
suffer a significant observed adverse affect (SOAA) because the new development would
expose them to noise from airport operations. RSP should have set out for residents the
RSP SCC ? NNF Response Page 24 of 49
areas of the district in which future planning decisions might be constrained because of the
need to protect people from experiencing a SOAA as a result of airport noise. RSP has failed
to do this. Other operational impacts
At the consultation events RSP could not answer questions about:
? What a daily or weekly schedule of flights might look like
? What types of planes would be using the airport and what noise footprint they
? Site lighting at night and whether this would impact people in nearby Minster and
other villages
? The visual impact of the aircraft teardown and recycling operation and whether
there would be a queue of aircraft awaiting teardown that would be parked out in
the open and visible at the edge of the site (as used to be the case when the
airport was previously open)
? The impact of what RSP claims will be 65,000 extra HGVs on local roads (by our
calculations, this is a significant underestimate). Asked about the impact on the
road transport infrastructure, Tony Freudmann said that this was ‘someone else’s
problem’, meaning Kent County Council’s and not RSP’s. ? Why the cargo ATM forecast increases at a steady 4 per cent a year when the
UK cargo market has been flat since 2000 and when the DfT is forecasting an
increase of just 0.4% a year. To put the DfT’s forecast in context, there were
52,598 cargo ATMs in the UK in 2016. The DfT’s latest forecast is that there will
be 60,000 cargo ATMs p.a. by 2050 – an increase of just 7,400 ATMs (14%)
spread over 33 years. Given this forecast and the availability of significant ATM
capacity at Stansted and East Midlands, it is clear that there is no need for a new
national cargo airport anywhere in the UK, let alone one in the very toe of Kent. RSP’s air freight forecasts simply bear no relation to reality “The Rochdale Envelope” There is a suggestion that, in failing to provide so much of the information critical to helping
the public to understand the implications of this scheme, the developer is relying on the
‘Rochdale’ approach. In answer to a query to the Planning Inspectorate (PINS) about the
inadequacy of RSP’s consultation, PINS replied:
Applicants can assess the likely significant impacts of a proposed development using
the ‘Rochdale Envelope’ (RE) approach; this is used to assess a likely or reasonable
‘worst case scenario’. This approach is consistent with the objective of the EIA
Directive, and the Planning Inspectorate acknowledges the Rochdale approach is a
way of dealing with an application comprising EIA development where details of a
project have not been resolved at the time when an application is submitted. PINS then refers to Advice Note 9 which says: …Taken with those defined parameters of the project, the level of detail of the
proposals must be such as to enable a proper assessment of the likely environmental
effects, and necessary mitigation – if necessary considering a range of possibilities: …The level of information required is: “sufficient information to enable ‘the main’, or
the ‘likely significant’ effects on the environment to be assessed… and the mitigation
measures to be described…” (Para.104 of the Judgement) …The ‘flexibility’ referred to is not to be abused: “This does not give developers an
excuse to provide inadequate descriptions of their projects.”
RSP SCC ? NNF Response Page 25 of 49
Care will be needed by the developer to ensure that the project description is clear so
that the developer can demonstrate that the statutory requirements regarding
consultation have been met. Pre-application consultation forms an important element of the 2008 Act regime. Developers must be able to demonstrate, among other things, that they have
complied with their duties under sections 42 and 47 of the 2008 Act. Under the 2008
Act it is important to consult comprehensively on the project and to report fully on that
consultation. The process should be clear and thorough.
It is clear that The Rochdale Envelope does not give developers carte blanche to carry out
pre-application consultation that is lacking in the key information required to enable the
public to assess the potential impact of the developer’s proposed scheme. We are not sure
to what extent RSP is intending to rely on The Rochdale Envelope to explain the lack of
critical information available to local residents as part of its statutory consultation. More
importantly, we are unconvinced that The Rochdale Envelope is even relevant here. The Rochdale Envelope is designed to help developers to cope with a situation in which their
proposal is a new undertaking and little is known about the potential environmental impacts
of the scheme. That is not the case with RSP’s application for a DCO to enable RSP to
reopen Manston. The project is described as:
The upgrade and reopening of Manston Airport primarily as a cargo airport, with some
passenger services, with a capacity of at least 12,000 air cargo movements per year. Manston was recently an airport. There was a commercial airport at Manston from 1999 to
2014. Its primary focus was cargo, with some passenger services. It had a CAA licence
which set out agreed flight paths. Noise levels were monitored and reported. Residents’ complaints were collated. Unscheduled night flights were recorded. The airport was the
subject of a number of different consultants’ reports while it was still operational. Some of
those reports assessed the noise impact of current and proposed operations on the local
population. The airport had a Master Plan which set out a range of traffic aspirations and
potential operational scenarios. It was an airport for many years and many of the
environmental impacts are well known. Previous plans for the old airport’s expansion included projections based on low, medium
and high usage. There is absolutely no reason why this information could not have been
used as a starting point for the statutory consultation. RSP could have taken the data that
described the impact of an airport with 500 cargo flights, and used that to help paint a picture
of an airport with 10,000 to 17,000 cargo flights. It is astonishing that RSP has provided so
little information to the public about the likely impact on residents of its proposals, when
there is so much past data to call upon. We can see no justification for RSP having done
such a poor job for local people in this statutory consultation and no justification for any claim
that the developer will not have access to this information until much later in the DCO
process. The following extract from a letter to TDC sets this out clearly: “I lived in the centre of Ramsgate from 1992-2015 and I represented a community
group on the Manston Airport Consultative Committee from 2003-2009. During this
time the airport was owned and run by the Wiggins Group. As a community group we
were primarily concerned with the noise and pollution generated by the airport.
In order to monitor the levels of noise and pollution to which local people were being
exposed, permanent noise monitors were installed on Clarendon School in Ramsgate
and also next to the roundabout at the Eastern end of the Thanet Way. The latter
noise monitor had been intended to monitor noise in the village of St. Nicholas but the
airport operator deliberately installed it in a location where the noise readings would
be minimised so that it would not reflect the real levels of noise being experienced by
RSP SCC ? NNF Response Page 26 of 49
people in the village. A temporary noise monitor was made available so that it could
be situated in locations where noise complaints were being made. Pollution monitors were installed on the Nethercourt Estate near the Western end of
Windermere Avenue. These monitors recorded the levels of various pollutants,
including particulates, NOx and Benzene. Data from the monitoring was reported back to the Consultative Committee for its
quarterly meetings and was also reported to Thanet District Council's environmental
monitoring team. My complaint about RSP's consultation is that they have deliberately ignored all of the
available evidence from the monitoring activities which took place between 2000 and
2014 when the airport closed. There is a wealth of evidence showing who was being
affected by noise, what noise levels were being generated, the types of aircraft
making the noise, the levels of air pollution and much more besides. None of this
information has even been referred to in the company's documentation. In fact, the
company's documentation fails to make any meaningful predictions about the levels
of noise and air-pollution which would be experienced by local residents and does not
identify the areas which would be worst affected, although these are well-known.
It is not meaningful to conduct a consultation in which key information is withheld from
the people who are likely to be affected by a development. It would be
understandable if RSP were proposing a new development which did not resemble a
previous one. But this is not the case. RSP are proposing to reopen the airport for
freight flights and this is exactly what Wiggins were doing when they ran the airport. It
can't even be argued that RSP were unaware of the previous data because Tony
Freudmann who is one of their key executives, was Managing Director of the airport
when it was owned by Wiggins. He used to attend all meetings of the Consultative
Committee and used to present the results of the monitoring. RSP is attempting to present a business case for reopening the airport which revolves
around a figure of 10,000 flights per year. This is the minimum level of activity which
would be needed to allow the project to qualify for a Development Consent Order. Consequently, it wouldn't be correct to claim that we do not know what levels of
activity will be conducted at the airport. They will be aiming for a minimum of 10,000
flights per year. The company is targetting the freight market and so they know
perfectly well that they will require 24/7 operations. In their business plan they clearly
state that the airport will be staffed 24/7. If they know what levels of activity there will
be, what types of activity there will be and where the flight paths will be, there can be
no excuse for failing to use established computer modelling software to predict noise
and pollution for people living in the surrounding areas. Previous plans to expand the
airport included projections for levels and patterns of noise pollution for low, medium
and high levels of activity. Again, RSP cannot claim to be unaware of this
methodology because Wiggins commissioned plans to expand the airport when Tony
Freudmann was the Managing Director.
In conclusion, my complaint is that RSP has provided hopelessly inadequate
information to local residents about the levels of noise and air pollution which would
be generated by their freight depot. Not only are computer models available to do this,
there is also a wealth of information available from the Consultative Committee, all of
which has been ignored. You cannot claim to have consulted people properly about
your proposal if you have not provided them with the information they would need to
assess the impact on their lives.”
In short, there is a wealth of historical information to help RSP to assess the likely impact of
its proposals. There is no excuse for RSP to hold a statutory consultation about the re- opening of an airport and yet not to be clear to residents about the likely flight paths; the
RSP SCC ? NNF Response Page 27 of 49
hours of operation; the likely aircraft to be flown; and the resulting noise and air pollution that
residents can expect to experience. RSP is abusing the process by offering such an
inadequate description of their proposal. This renders the statutory consultation pointless.
RSP SCC ? NNF Response Page 28 of 49
RSP’s statutory consultation fails to meet the required standard because RSP has not:
? Consulted all those who might be affected
? Provided clarity as to what it is that RSP is consulting on
? Carried out a consultation that is appropriate to the scale and nature of its
proposed project
? Carried out a consultation that is appropriate to the places in which the effects of
the project will be experienced
? Provided accurate information
? Provided consistent information
? Provided local people with the information that they need to develop an informed
view of RSP’s proposals
? Taken the earliest opportunity to correct a significantly inaccurate statement of
the benefits that it claims the project will deliver
? Held a consultation that makes information accessible and that helps people to
engage with the process.
RSP SCC ? NNF Response Page 29 of 49
PART TWO – the substance of RSP’s proposals
Opaque and unrealistic business case
Between 1999 and 2014 three separate owners of Manston airport each tried to develop the
former military airfield as a commercial cargo airport. Local residents were promised that the
airport would handle hundreds of thousands of tonnes of cargo. They were told that it would
be a nationally significant airport for cargo. They were promised thousands of jobs. The
promises made in this DCO proposal by RSP are not new, just more extreme. We have
been here before.
In fact, in every year between 1999 and 2014 the airport accounted for no more than 1% to
2% of the UK’s air freight. It lost millions of pounds every year. It closed in 2014 because it
could not attract cargo airlines to use it. The airport lost around £100m during its fifteen year
commercial life. The UK air cargo market has not grown since 2000. The sector of the air cargo market that RSP is pursuing – cargo that is moved in dedicated
freighters – is getting smaller. According to the PINS website, RSP must demonstrate that a
cargo airport at Manston would handle 12,000 freighter flights a year. However, the entire
UK market for freighters only handles 52,600 freighter flights a year. In a falling market, RSP
would need to tempt 12,000 freighter flights away from successful and established cargo
airports. When operational, Manston handled around 500 freighter flights a year. It is unlikely ever to
handle more. In the South East, cargo operators say that Gatwick is too far away to be
viable as a cargo airport – they want to be at Heathrow or Stansted. Failing that, they want to
be at East Midlands. Even when Heathrow was closed to freighters during the London
Olympics, not a single extra cargo flight came to Manston. There is plenty of spare capacity for cargo at East Midlands airport. There is plenty of spare
capacity for cargo at Stansted. There is even spare capacity for cargo at Heathrow. The
combination of spare capacity and falling demand means that the UK does not need a new
nationally significant cargo airport. The Department for Transport forecasts that demand for
UK air dedicated air cargo will increase by just 7,400 freighter flights a year by 2050. This
forecast increase in freighter flights is insignificant given the spare capacity at East Midlands
and Stansted for tens of thousands more cargo flights. One expert report after another has concluded that a cargo airport at Manston will not be
viable. Quite simply, the very south-eastern tip of the UK is the wrong place for a cargo
In a market awash with spare capacity, there is no need for a new cargo airport that can
handle an additional 12,000 freighter flights a year. Even if there were, an airport at the very
edge of the UK would not be the answer. The Ministry of Defence owns surplus airfields that
are far better located than Ramsgate for air cargo. If the Government thinks that a new UK
cargo airport is essential, then it has the solution in its own hands. Instead, the Government
is selling these airfields for housing, demonstrating neatly that, in the eyes of the
Government, an additional UK cargo airport is not needed. At the consultation events, RSP said that it was not going to try to take dedicated air cargo
business from other UK airports. The plan is apparently to attract air cargo that is currently
being flown into European airports and then trucked to the UK. This justification barely
features as part of the case in the Azimuth Report, Volume III.There is no substance in the
RSP documentation to support this as a credible plan. No cargo customer has signed up
to use the airport. No data is offered that demonstrates that it would be preferable to cargo
customers currently flying cargo into European airports for forwarding to the UK by truck for
them to fly their cargo to Manston instead, thence to be trucked the length and breadth of the
RSP SCC ? NNF Response Page 30 of 49
UK. There is no fact-based business case underpinning the idea that 2m tonnes of air cargo
are being trucked into the UK from European airports and that its owners would far prefer to
fly it into Manston and then truck it from there. RSP is apparently relying on Dr Dixon’s rendition of TfL’s secret papers as the basis for this
plan for mopping up air cargo customers from European airports. This is not a sound enough
business case to warrant taking land from its rightful owners by a CPO on the basis that a
new cargo airport – the UK’s second biggest dedicated cargo airport – can successfully be
developed on that land. The public has a right to know the underlying business fundamentals. Without them, residents cannot assess the likelihood of success of this ‘plan’ and whether its
notional benefits will ever be achieved. Without a proper business case that gives the public
access to the market demand data behind it, RSP is asking residents to trust implicitly that
one secret set of documents will guarantee enough business to justify the UK’s second
biggest dedicated cargo airport being built in their neighbourhood. This is unreasonable and
falls far short of the developer’s obligation to put the public in a position in which it can
“engage” with the developer’s proposals.
In its entirety, RSP’s written plan is dependent on two forecasts, one for freight traffic and the
other for passenger traffic. Both forecasts are from Dr Sally Dixon and the results presented
in the four volumes of the Azimuth reports. The actual forecasts are shown in Volume III – The Forecast. These forecasts are based on dubious assumptions, speculative guesswork and have zero
backup evidence. Sadly, all other RSP plans depend on the validity of these forecasts – the
predicted flight levels, the justification for NSIP status, the jobs forecast, the business case,
the case for financial viability, the delivery plan (wherever these latter may be). The Northpoint Report is entirely based on finger-in-the-air guesswork. The author of this
report, Chris Cain, arrives at a freight forecast of 660,000 tonnes per annum at Manston for
2050, subsequently revising this to 470,000 tonnes for year 2040. Both guestimates are
between 1.5 and 2 times the freight levels currently handled by the UK’s principle dedicated
freight airport at East Midlands.
It is entirely unclear how the figure of 5,250 freight movements in Year 2 is derived
. This
appears to be simple conjecture, derived from various speculative interviews with airport and
charter operators, freight associations and freight handlers, and a helicopter business. From Year 11, a subsequent year-on-year growth of 4% has been used, reportedly based on
forecasts from Boeing and Airbus. Boeing and Airbus are airframe manufacturers who have
a vested interest in making optimistic forecasts of their customers’ business growth. Their
forecasts bear no relation to forecasts made by the DfT. Discussions with RSP representatives at the consultation events suggest strongly that the
DCO application notionally to develop a nationally significant cargo airport is a stalking horse
for something else. We were told emphatically that the proposed teardown business is the
“jewel in the crown” and that that is “where the money really is” and “the only financially
viable bit of the airport”. In addition, RSP plans to charge a chunky fuel premium as its
second main source of revenue. Thirdly, the industrial estate that RSP plans to develop on
the Northern Grass needs no airside access because tenants there will not be using the
airport. The only part of the Northern Grass that is needed for airport operations is a small
area for the radar installation. This suggests strongly that the Northern Grass is not an
essential part of a nationally significant cargo airport on the site. RSP is trying to CPO it
simply to develop an industrial estate on that land, income from which will prop up the loss- making airport. This is not an acceptable use of compulsory purchase powers. There is no airport at Manston and there has not been one for over three years. If successful, RSP’s proposal would introduce to thousands of residents a blight that they do not currently
13 Azimuth vol III Table 2, p. 10
RSP SCC ? NNF Response Page 31 of 49
live with. This is important. We are not talking here about a DCO that would expand or
increase an otherwise negative impact on a community. We are talking about a significant
blight that would be inflicted on a community from scratch. The base figure of 4,932 passenger movements in Year 3
is based on highly speculative
guesswork that scheduled, LCC, charter and cruise ship flights will want to use Manston. There is absolutely no evidence for this. None of these operators has come anywhere near
making a commitment to use Manston. Previous passenger operations at Manston failed, and LCC airlines have rejected Manston several times as being in the wrong place. Again, a
speculative 4% annual growth rate has been used from Year 11 to Year 20. RSP forecasts 965,295 passengers in the fourth year of passenger operations and more
than 1.4 million by year twenty. The population of Kent is about 1.6million. About half of them
fly. These people have access to a multitude of flight destinations at Gatwick, Heathrow and
London City. The core catchment area of East Kent obviously comprises even fewer people
than Kent as a whole and has a less wealthy population than that of West Kent. RSP’s
passenger projections are extraordinarily optimistic and rely, even in the early years, on a
hope that most people in East Kent who take flights would take two flights a year each from
Manston. RSP gives a partial quote
from the Airports Commission, suggesting that the Airports
Commission is supportive of the concept of reliever airports (which is what RSP sometimes
suggests that Manston could become). Infratil suggested this possibility to the Airports
Commission as a short to medium term proposal. However, Manston was not mentioned in
the Commission’s Final Report in July 2015, nor was it mentioned in the Interim Report of
Dec 2013. Manston does not in any way figure as part of the solution in the Airports
Commission’s recommendations for addressing the capacity of the South East’s airport
system. Manston airport was mentioned in the Appendix to the Commission’s Interim Report, which was a specific assessment of all the short and medium term options submitted by the
UK’s airport owners. The Commission looked at whether it would make sense to redistribute
some flights away from Heathrow so as to ease congestion. It looked at Infratil’ s ideas for
changing the slot allocation regime and forbidding some types of flight, like cargo flights,
from using Heathrow at all, but concluded: “none was assessed as being a viable or effective
It is very difficult to offer precise feedback on RSP’s proposals because what is being
proposed is so unclear. Our comments below are therefore more generic and highlight the
areas in which RSP’s proposals threaten local residents with significant new blight. The impact of noise on human health
Aircraft noise is a serious problem around all airports and under flight paths. Noise levels are
typically measured using the Decibel 'A' Scale, usually expressed as dB(A). A limit of
55dB(A) was for a long time regarded as one which should not be exceeded to allow
undisturbed sleep. Sound levels above 70dB(A) make normal speech communication
impossible. The Government’s overall policy on aviation noise is to limit and, where possible, reduce the
number of people in the UK significantly affected by aircraft noise.16 Counter to this, RSP’s
proposals will of course inflict a brand new source of significant aviation noise on a
population that currently is not affected by aviation noise. It is surprising to see a proposal
that runs so clearly counter to Government policy. Measuring the levels of noise pollution from aircraft is a controversial area. 14 Azimuth vol III, Table 5, p 10
15 PEIR volume I 4.3.12
16 Aviation Policy Framework 2013
RSP SCC ? NNF Response Page 32 of 49
The two most commonly used techniques for measuring noise levels are Leq and Lmax. Leq is
favoured by the aviation industry. It measures the average level of sound intensity over a
period of time. However, as NNF often points out, it is not the average noise of one’s alarm
clock over an eight hour period that wakes one up – it’s the loudness of the alarm clock at
the precise moment at which it goes off. Lmax is a more useful measure for those who have to live with the debilitating effect of noise
pollution. It measures the maximum sound pressure level occurring during a certain period of
time or during a single noise event. Lmax can identify serious noise problems arising from
short-lived single noise events, which are not picked up by Leq. This is important. A Leq
measurement can suggest that there is a tolerable level of noise when the experience on the
ground is very different. After all, noise that is loud enough to (say) stop conversation is
noise that is having an impact on the people living through it. Averaging out the noise of 17,000 cargo flights a year will produce a relatively low Leq
number. However, this will in no way reflect the impact of each of those separate flights on
someone under the flight path who is overflown dozens of times in a day. As an example, if
Concorde were still in service, one Concorde flight going over every four hours is the Leq
equivalent of four hours’ of non-stop noise from Boeing 757s flying overhead at a rate of one
every two minutes. It is not sustainable for RSP to attempt to rely on Leq as a sole measure
of the noise nuisance that its proposals will inflict on local residents. The UK’s Aviation Policy Framework explicitly recognises that LAeq alone is an inadequate
measure of the noise nuisance that people suffer from airports and aviation: “The Airports Commission has also recognised that there is no firm consensus on the
way to measure the noise impacts of aviation and has stated that this is an issue on
which it will carry out further detailed work and public engagement. We will keep our
policy under review in the light of any new emerging evidence.” 17
“However, the Government recognises that people do not experience noise in an
averaged manner and that the value of the LAeq indicator does not necessarily reflect
all aspects of the perception of aircraft noise. For this reason we recommend that
average noise contours should not be the only measure used when airports seek to
explain how locations under flight paths are affected by aircraft noise. Instead the
Government encourages airport operators to use alternative measures which better
reflect how aircraft noise is experienced in different localities, developing these
measures in consultation with their consultative committee and local communities.” 18
“As a minimum, the Government would expect airport operators to offer financial
assistance towards acoustic insulation to residential properties which experience an
increase in noise of 3dB or more which leaves them exposed to levels of noise of 63
dB LAeq,16h or more. Any potential proposals for new nationally significant airport
development projects following any Government decision on future
recommendation(s) from the Airports Commission would need to consider tailored
compensation schemes where appropriate, which would be subject to separate
consultation.” 19
In March 2016 the Civil Aviation Authority published CAP 1278. That report says: “With regard to night noise and sleep disturbance, there is growing recognition that
average indicators such as Lnight are insufficient to fully predict sleep disturbance and
sleep quality and that use of number of noise events (LAmax) will serve to help
understanding of noise-induced sleep disturbance.” 17
RSP SCC ? NNF Response Page 33 of 49
RSP’s noise assessment methodology is out of date and will significantly under- assess the noise impact of its proposals on local residents. RSP needs to stop trying to hide behind average measures of noise and deal with the reality
of how noise is actually experienced on the ground. We need to see more honest measures
such as SEL, Lden, LMax and N70. RSP likes to suggest that, if its DCO were successful, it
would develop a modern airport. If that is the case, then RSP needs to start using modern
measurements of noise. A report prepared for the Airports Commission in 2015 collated some of the research around
noise and human health. Among other remarks that report said: “Over the past 10 years, evidence that aircraft noise exposure leads to increased risk
for poorer cardiovascular health has increased considerably. A recent review, suggested that risk for cardiovascular outcomes such as high blood pressure
(hypertension), heart attack, and stroke, increases by 7 to 17% for a 10dB increase in
aircraft or road traffic noise exposure (Basner et al., 2014). A review of the evidence
for children concluded that there were associations between aircraft noise and high
blood pressure (Paunovic et al., 2011), which may have implications for adult health
(Stansfeld & Clark, 2015).”
“[…] a 10dB increase in aircraft noise at night (Lnight) was associated with a 14%
increase in odds for high blood pressure”
“[…] a 10dB increase in night-time aircraft noise was associated with a 34% increase
in the use of medication for high blood pressure”
“[…] those exposed to aircraft noise levels over 63dB in the day-time had a 24%
higher chance of a hospital admission for stroke; a 21% higher chance of a hospital
admission for coronary heart disease; and a 14% higher chance of a hospital
admission for cardiovascular disease.”
“The WHO Europe Night Noise Guidelines state that the target for nocturnal noise
exposure should be 40 dB Lnight, outside, which should protect the public as well as
vulnerable groups such as the elderly, children, and the chronically ill from the effects
of nocturnal noise exposure on health. The Night Noise Guidelines also recommend
the level of 55 dB Lnight, outside, as an interim target for countries wishing to adopt a
step-wise approach to the guidelines”
“Annoyance is the most prevalent community response in a population exposed to
environmental noise. The term annoyance is used to describe negative reactions to
noise such as disturbance, irritation, dissatisfaction and nuisance (Guski, 1999). Annoyance can also be accompanied by stress-related symptoms, leading to
changes in heart rate and blood pressure,”
“ […] in recent years, several studies have suggested that aircraft noise annoyance
around major airports in Europe has increased (Babisch et al., 2009; Janssen et al., 2011; Schreckenberg et al., 2010),” A meta-analysis of research based on one hundred published reports from fundamental
studies, experimental studies and epidemiological studies into “noise annoyance” found that
a high level of aircraft noise is related to an increased chance of death from heart attacks, high blood pressure and strokes with a 10 decibel average increase in aircraft noise
exposure resulting in increasing these incidents by between 7% and 17%. The World Health Organisation (WHO) recommends an 8 hour night flight curfew so as to
ensure most people get the sleep they need. WHO’s view is that above 55 dB Lnight noise is
a significant concern to public health. As a result it has set an interim target of 55 dB
Lnight,outside. For the longer term it recommends that night noise exposure should be
RSP SCC ? NNF Response Page 34 of 49
reduced below 40 dB Lnight,outside. WHO says that the interim target is only recommended
in the situations where the achievement of the 40 dB Lnight,outside target is not feasible in the
short-term. A major study by Warwick Medical School concluded that chronic lack of sleep produces
hormones and chemicals in the body which increase the risk of developing heart disease, strokes and other conditions such as high blood pressure and cholesterol, diabetes and
obesity. That study said: “If you sleep less than six hours per night and have disturbed sleep you stand a 48%
greater chance of developing or dying from heart disease and a 15% greater chance
of developing or dying from a stroke." A UK study in 2013 published in the British Medical Journal, found evidence that people
living in areas with high levels of noise pollution from passing aeroplanes had a higher risk of
heart disease and stroke. The report compared Civil Aviation Authority data on aircraft sound
levels with hospital admissions and mortality rates for 3.6 million people living near Heathrow
Airport, in areas where aircraft noise exceeded 50 decibels – the level of normal
conversation in a quiet room. Researchers from Imperial College London and King’s College London found that the risks
of cardiovascular disease were greater for those living in neighbourhoods with the highest
noise levels and closest to the airport, such as Slough and Hounslow. Around 72,000 people
living in the noisiest areas had a 10 to 20 per cent greater risk than people living in the
quietest areas, researchers estimated.
In an editorial for the BMJ, Stephen Stansfeld, professor of psychiatry at Barts and London
School of Medicine, said that the results
“imply that the siting of airports and consequent exposure to aircraft noise may have
direct effects on the health of the surrounding population. Planners need to take this
into account when expanding airports in heavily populated areas or planning new
airports.” Some local residents believe that aircraft noise at night “doesn’t bother them” because it
does not actually wake them. The research says otherwise. Even if people don’t wake up as
a result of noise from aircraft, the World Health Organisation says that there is “sufficient
evidence” to show that the noise increases the heart-rate. In other words people’s health can
be affected by the noise of aircraft at night even if they do not wake up. TDC has already commissioned expert studies that concluded that there is no social, economic and environmental case for night flights. The damage that they would entail far
outweighs the benefits. Given that, and the evidence quoted above, we emphatically oppose
any suggestion that a new cargo airport at Manston should or would have scheduled night
flights. For clarity, there must be an eight-hour curfew on scheduled flights between 2300 and 0700.
In addition, there must be heavy penalties for any unscheduled flights. We have learnt from
experience that unscheduled flights tend to creep in with surprising regularity with the airport
operator allowing this to happen. Our stance is clear – there is no case for introducing
scheduled night flights. Thanet residents on average already suffer from worse health than the majority of the rest of
the UK, and the poorest physical and mental health statistics in Kent with the average life
expectancy in Cliftonville West being 69 years, 18 years lower than the best in the county. We do not need the damaging effect on people of aircraft noise day and night to lead to
even poorer health outcomes for local residents.
RSP SCC ? NNF Response Page 35 of 49
RSP does not intend to complete a Health Impact Assessment as part of its DCO application. This is completely unacceptable. RSP says
This PEIR does not have a chapter entitled ‘Public health impacts’ as there is no
requirement under the 2011 EIA Regulations (Schedule 4) to include a health based
assessment. We make the point above that the EU intended European countries to be protected under
the new Directive from May 2017. RSP’s proposal would not produce an operational airport
until 2021 at the earliest, four years after the deadline for using the new Directive. If RSP
persists in trying to develop an airport that it knows will fall well short of modern
environmental standards, we expect this point to be argued at a Judicial Review. Finally, the UK Government has said that it wants to bear down on the noise associated with
aviation. It has also long been a Government objective to bear down on night noise.21
2.21 It is proposed that our achievements against delivering this objective would be
measured by: The area of and number of people in the 48dB LAeq 6.5hr night contour. This is a different measure to that used for the current regime, but reflects increased
evidence about the impacts of lower noise levels on sleep disturbance and health. 2.28 The second pillar of the Balanced Approach is land-use planning. Primarily this
aims to ensure that new airport developments are located away from noise-sensitive
areas and that only compatible land-use development takes place in areas affected
by aircraft noise. RSP’s proposal would introduce an entirely new source of noise and night noise to local
residents. RSP’s proposal will have a debilitating effect on the health of residents who are
exposed to this new source of aviation noise. RSP’s statutory consultation has failed to take
into account current thinking about the appropriate measurement of aviation noise. RSP
needs to provide the public with a proper assessment of the noise nuisance that its
proposals will inflict on us. The introduction of a brand new source of aviation noise to this
district is unacceptable. The impact of noise on the education of children
There is a growing body of evidence to demonstrate that exposure to aircraft noise is
harmful for children, their health and their ability to learn. Studies into the effects of chronic
exposure to aircraft noise on children have found:
? consistent evidence that noise exposure harms cognitive performance;
? consistent association with impaired well-being and motivation to a slightly more
limited extent;
? moderate evidence of effects on blood pressure and catecholamine hormone
In its summary of some of this evidence, the Airports Commission report said: “Many studies have found effects of aircraft noise exposure at school or at home on
children’s reading comprehension or memory skills (Evans & Hygge, 2007). The
RANCH study (Road traffic and Aircraft Noise and children’s Cognition & Health) of
2844 9-10 year old children from 89 schools around London Heathrow, Amsterdam
Schiphol, and Madrid Barajas airports found that aircraft noise was associated with
20 PEIR volume I 5.8.4
21 Night flight restrictions at Heathrow, Gatwick and Stansted. Consultation document. DfT, Jan 2017
RSP SCC ? NNF Response Page 36 of 49
poorer reading comprehension and poorer recognition memory, after taking social
position and road traffic noise, into account (Stansfeld et al., 2005).”
“In the UK, reading age was delayed by up to 2 months for a 5dB increase in aircraft
noise exposure (Clark et al., 2006). The UK primary schools in the RANCH study
ranged in aircraft noise exposure from 34dB LAeq 16 hour to 68 dB LAeq 16 hour. If
we take a 20dB difference in aircraft noise exposure between schools, the study
would estimate an 8-month difference in reading age.” Teachers in Ramsgate have spoken publicly of the impact of cargo flights into and out of
Manston previously, saying that lessons used to come to a standstill until the plane had gone
over, simply because the teacher could not make him/herself heard. Each interruption lasted
longer than the time it took for the plane to go over, as children then had to settle down and
refocus attention on whatever they had been working on previously. In addition, night flights
disturb the sleep of children and impair their subsequent performance at school. Thanet children on average already perform less well educationally than the vast majority of
children in Kent, and indeed in the rest of the UK. Thanet District’s secondary school
performance ranks it in the poorest performing 0.5% of all local authorities when looking at
attainment of 5 GCSEs at A* to C. We do not need the damaging effect on people of aircraft
noise day and night to lead to even poorer education outcomes for our children. Environmental Issues: Air
RSP says:
Of the potential impacts on human health, the most likely to constrain the
acceptability of the Proposed Development is annual mean nitrogen dioxide (NO2). Given that the airport will operate at a steady level over time (except for
daytime/night-time differences), it is much less likely that short-term (i.e. hourly
mean) NO2 concentrations will be constraining. Similarly, concentrations of other
pollutants such as PM10 or PM2.5 are unlikely to be the most constraining criteria. However, they will be included in the assessment to provide confidence in this
Air pollution is a major issue for those who live in the vicinity of large airports. Emissions
from aircraft, airside support vehicles and airport-related traffic all contribute to a build-up of
potentially harmful gases such as oxides of nitrogen, carbon monoxide, VOCs (volatile
organic compounds) and ozone. They also produce small particulates. The most important
pollutants are usually nitrogen dioxide (NO2) and small particulates (PM10, PM2.5). These
often breach standards set by the UK government and the EU to protect human health. Air pollution is a significant threat to human health and the environment, especially in areas
close to airports. NO2 exerts most of its effects on the human body locally, in the airways
and lungs. High NO2 levels cause breathlessness and coughing, and long term exposure
results in chronic coughs and infections such as bronchitis. Ozone (O3) is an important
secondary pollutant that is formed out of NO2. With regards to particulate matter, overwhelming evidence has been compiled in recent years, demonstrating its mortality and
morbidity impacts.23
As the Environment Agency reports: “Of all the pollutants, particulates are worst for human health. They are responsible
for up to 10,000 premature deaths through respiratory problems in the UK each year.” 22 PEIR volume I 6.4.17
23 Health Aspects of Air Pollution with Particulate Matter, Ozone and Nitrogen Dioxide. WHO 2003, and Systematic Review of Health Aspects of Air Pollution in Europe. WHO 2004
RSP SCC ? NNF Response Page 37 of 49
A study by the Massachusetts Institute of Technology has estimated that long term exposure
to aviation related ozone and fine particulates (specifically PM2.5, the smallest particles)
contributes to 16,000 premature deaths a year worldwide, costing an estimated $21 billion a
year.24 The study considered the health impact of near airport, regional and global emissions, estimating that “cruise altitude” emissions were the most significant contributor to health
impacts world-wide. However, emissions from landings and take-offs were found to have
significant pollution-related health impacts for communities living close to airports, contributing to 49% of the premature deaths associated with aircraft emissions in Europe. The study considered that the costs of the pollutants studied were of a similar magnitude to
the costs associated with CO2 emissions. Surprising as it might be, aircraft emissions are not the major contributor to air quality
problems around airports. The sources of pollution in order of significance appear to be:
? road traffic at and around airports. It appears as if RSP has chosen not to include
this data in its PEIR Volume I. ? aircraft exhaust fumes (10% of air pollution around Amsterdam Airport Schiphol
(urban region) (Noord-Holland, 2001), 20% east of Roissy Charles de Gaule
(rural region), (Airparif, 2004)
? emissions from ground service equipment and auxiliary power units.
It is fair to say that RSP’s consultation materials on the topic of air pollution are a serious
challenge for the lay reader. This diminishes the value of the consultation and makes it
extraordinarily difficult for ordinary residents to understand the implications of this project
and what it might mean for them and their health. What is clear, though, is that some important information is missing. At 6.10.2 of PEIR Volume I, RSP reveals that it has not yet completed its traffic assessment
and therefore it has not calculated the full air pollution impact of its proposal. This is a huge
gap in the information. As we have said above, road traffic associated with airports is the
biggest source of air pollution. This is particular concern given that, following the East
Midlands Airport model, there are likely to be more than 150,000 HGV movements
associated with the level of operation that RSP aspires to develop. We cannot see how RSP
can suggest that it is consulting the public when such a major piece of information about the
impact of its proposals on the public is missing. The UK is already struggling with air pollution. There is no clear government plan to keep
aviation emissions to a level consistent with the Climate Change Act (despite the fact that in
the 2011 ruling on Heathrow expansion, the judge declared the Government’s claim that
aviation policy was divorced from the requirements of the Climate Act to be “untenable in law
or common sense”). We can find nothing in the RSP consultation materials that deals with
climate change and how this proposal will add to the UK’s emissions. It is extremely
unhelpful that RSP has not made available to the public as part of this statutory consultation
a full assessment of the likely air pollution impacts of its proposals. This is a significant flaw
in the consultation. Finally, we know from past experience that residents in Ramsgate and in those villages
close to the airport often experienced droplets of fuel falling on their house and garden. This
pollution has not been addressed. In addition, residents near each end of the runway have
long complained about the smell coming from airport operations and particularly from aircraft
with their engines idling. RSP has mentioned this as an issue but we can find no information
that the issue has been addressed any further than that. 24 Global, regional and local health impacts of civil aviation emissions – Steve H L Yim, Gideon L
Lee, In Hwan Lee, Florian Allroggen, Akshay Ashok, Fabio Caiazzo, Sebastian D Eastham, Robert
Malina and Steven R H Barrett. 2015
RSP SCC ? NNF Response Page 38 of 49
We strongly object to the inevitable decrease in local air quality for residents that will result
from a cargo airport at Manston. We do not support the decrease in the health of local
residents that will inevitably result from airport operations. Environmental Issues: Water Pollution
A persistent and recurring concern regarding any kind of development in central Thanet is
the potential impact on the Island’s aquifer which lies in part under the Manston site as well
as the impact on the coastal SSSIs such as Pegwell Bay. Given that RSP’s proposal envisages a very high level of air and road traffic, and given that
RSP plans to build up to a dozen new stands, allowing planes to be parked near the runway,
the ‘worst case scenario’ that must be adequately addressed in RSP’s proposals is
managing a catastrophic spillage involving multiple planes. Similarly, the risks associated
with having significant fuel storage on-site must be explicitly addressed. RSP has not done
this. Environmental Issues: Water – impact on aquifer recharge
There is no consideration given to the potential impact on aquifer recharge caused by the
creation of an additional 400 acres of hard-standing at the airport, which is located
immediately over a drinking water aquifer. Assuming a typical annual water use for a 3 bedroom house of 130m3, and an assumed
rainfall of 650mm annually with a 60% infiltration, this equates to the loss of recharge to the
aquifer of enough water to service just under 5,000 homes. This is a significant impact on a
site which is not suitable for SUDS which could mitigate this reduction. RSP has not tackled
this issue as part of the consultation. Increased building on greenfield land
The draft Local Plan allocates 2,500 homes to be built on the site that RSP wishes to acquire
for a cargo airport. If the DCO were to be successful, those 2,500 homes would have to be
built on green field land as the Plan has already taken account of all the suitable brownfield
sites available when arriving at the Council’s Housing Supply total. Even with 2,500 homes
allocated to the old airport site TDC is already making provision in the draft Local Plan to
build on green field land. If this housing site of 2,500 homes is used instead for an airport, an
additional 2,500 homes on green field land would have a significant impact on agriculture, on
green space, and on the local environment. We object to this strongly, as does the CPRE, (Campaign for the Protection of Rural England). Tourism
Tourism is a vital, and growing, part of the local Thanet economy. Thanet’s visitor economy
grew 19% in 2015, making it the biggest district tourism success in Kent and, arguably,in the
whole of the UK. The total value of Thanet’s visitor economy reached £293m with the district
welcoming nearly 4 million visitors. Research by Visit Kent shows that there has been a rise of 23.3% in the total number of jobs
in the area supported by tourism, with the total in 2015 being 7,312 jobs. This number is
expected to continue to grow. This growing tourism economy would be threatened by the introduction of a huge cargo
airport with 24/7 operations and 17,000 noisy cargo flights a year. People do not travel to
take holidays under the final approach of a 24/7 cargo airport. Many of our beaches, cafés, hotels and visitor attractions would become intolerable and unattractive to visitors due to
levels of noise, roads clogged with haulage vehicles and significantly worsened air pollution.
RSP SCC ? NNF Response Page 39 of 49
We would lose tourist visitors to the district and the tourism spend that they bring and the
tourism industry jobs that they support. We object to this strongly. Traffic
The traffic assessment has not been completed. This means that residents have not had
access to the information that they need to assess the traffic impact of RSP’s proposals. Again, it is hard to see why RSP has come to this statutory consultation when so much of
the critical information is not yet ready. RSP suggests that there will be 65,000 HGV movements by year twenty. This appears to be
no more than a finger in the wind estimate that it takes about four HGVs to unload a cargo
plane. We can find no recognition in the information given that there will be an additional
need for thousands of fuel tankers every year as well as the need for extra HGVs to
transport everything needed on a daily basis for RSP’s claimed numbers of passengers. East Midlands Airport’s Sustainable Development Plan (2014) talks of 500 HGV a day, with
most of them at night, providing a more realistic benchmark of the impact of traffic due to an
airport with significant freight operations. To clarify: 500 HGV movements a day is 182,500
movements a year, almost three times the level of RSP’s estimate.
In the absence of any robust data on traffic numbers by type of vehicle, and any meaningful
assessment of any potential requirement to upgrade local and county-wide road
infrastructure, it is not possible for any potentially affected parties to understand the potential
impact of the proposed development. We object strongly to the addition of what we estimate to be substantially more than 65,000
extra HGV vehicles on local roads and the congestion, road wear, and additional pollution
that they will inevitably bring. Dubious Job Forecasts
The employment and economic benefits of the airport have always been greatly exaggerated, and have never materialised. Historically, Manston’s owners have always promised big
numbers but delivered small numbers. After 15 years operating as an airport in private
hands, this 720 acre site peaked at just 144 mostly part-time jobs. The graph illustrates the eternal gap between the job creation promises made by various
owners of Manston and the reality. The forecasts have been in the thousands, and are now
in the tens of thousands. The actuals never reach two hundred.
In 2001 Tony Freudmann’s team at Wiggins promised that there would be 6,000 jobs at
Manston by 2010. In 2001 Wiggins backtracked and said that this would not be achieved
until 2017. In 2008 Infratil predicted 3,500 jobs by 2018 and 7,500 jobs by 2033. The
following year this was revised down to 2,800 jobs by 2018 and 6,000 by 2033. In 2015, Sir
Roger Gale stated there would be 2,000 jobs in two years. Dr Dixon’s forecasts dwarf all
previous over-estimates. Records from monthly reports to the Kent International Airport Consultative Committee show
that actual jobs numbers under Infratil from 2005 to 2013 ranged from 53 to 112 jobs. When
the airport closed in 2014 there were reportedly “144 mostly part-time jobs”. Dr Dixon’s approach to job forecasting starts by assuming that a given amount of business
(one million passengers or 100,000 tonnes of freight) generates a certain number of direct
jobs – this we call the Direct Jobs Multiplier (DJM). She then applies some other multipliers
from disparate research sources to predict increasingly remote categories of jobs. This is like
playing Chinese whispers in an echo chamber – errors multiply.
RSP SCC ? NNF Response Page 40 of 49
Dr Dixon’s first error is to misuse the freight-to-passengers equivalence. The idea that 100,000 tonnes of cargo is equivalent to one million passengers is only true in
terms of weight. It assumes that a passenger (with luggage) weighs about 100kg, so ten
passengers weigh about 1,000kg, which is one tonne. Sure enough, 1,000,000 passengers
would weigh about 100,000 tonnes. This is an aviation rule of thumb that is used for assessing how much “stuff” is being
transported, simply in terms of weight – useful when looking at fuel requirements, or wear
and tear on landing gear and runways, or anything else weight-related. It is a mistake to use
it for anything that is not purely or primarily about weight. One million passengers (or 100,000 tonnes of passengers, to put it another way) and
100,000 tonnes of freight do not have the same requirements for heating, cooling, lighting, pressurisation, feeding, cleaning, security, customs, quarantine, customer service, or
staffing levels, and can’t be regarded as equivalent for any of them. For example, if Airport
A needed 500 staff to handle 100,000 tonnes of passengers, it doesn’t necessarily follow
that Airport B would need 500 staff to handle 100,000 tonnes of freight. Because the DJMs
for pure passenger and pure freight business are so different, it would make sense to use a
“freight-only” DJM for jobs forecasting, up to the point that the project breaks even and RSP
starts operating passenger flights as well as freight flights. Dr Dixon provides no figures from
freight-only airports. Dr Dixon’s second error is to over-estimate the Direct Jobs Multiplier – the number of
direct jobs generated by a unit of work (passenger or freight) at the airport. All of the studies that Dr Dixon refers to in section 4.1 (ACI Europe, 2015; Intervistas, 2015;
Steer Davis Gleave, 2015) are described by Dr Dixon as passenger focussed, and
unsurprisingly this is reflected in the high DJM numbers she quotes. A tonne of passengers
needs more human attention than a tonne of freight, so we would expect the actual DJM
value for a cargo airport at Manston to be lower than any of the figures she quotes, as it
will be purely freight, at least initially.
RSP SCC ? NNF Response Page 41 of 49
East Midlands Airport (EMA) is a busy cargo airport, and it is also a busy passenger airport, comparable to London City in scale. Thus the DJM value at EMA is boosted by the more
labour-intensive passenger operation which handles 4.5m passenger p.a., and cannot
meaningfully be applied to Manston from Year 1. Looking at actual DJM values from across the UK over the last 20 years or so:
? In 1998, Stansted airport operated at 1,173 jobs per million passengers. This fell
to 480 in 2015. ? In 2003, Gatwick operated at 821 jobs per million passengers. This fell to 683 in
2015. ? In 2005, Southampton airport operated at 652 jobs per million passengers. This
fell to 505 in 2015. ? In 2005, Bournemouth airport operated at 408 jobs per million passengers. This
fell to 247 in 2015. ? In 2007, Glasgow’s Prestwick airport operated at 248 jobs per million passengers. ? In 2011 Infratil (then owners of Manston) and KCC applied to the Government for
£600k from the Regional Growth Fund. The owners stated in their bid to the
Department of Business Innovation and Skills that the airport could handle
55,000 tonnes of freight and 787,000 passengers p.a. with just 167 staff. This
would have equated to a DJM value of about 125 per million.
This brief review of the facts makes two things abundantly clear. 1. The overall trend for actual DJM values is steadily falling – airports are becoming less
labour-intensive. 2. RSP’s chosen DJM value is not a typical value, it is an outlier. It is higher than most of
the historical values, and is going against the trend. Despite being referred to in the industry as ‘self-loading cargo’, passengers and cargo have
very different handling requirements and place different demands on the airport operator. Put simply, a tonne of boxes needs a lot less human attention than a tonne of people. Less
RSP SCC ? NNF Response Page 42 of 49
human attention means fewer jobs. This is why freight business is always much less labourintensive
than passenger business. All of the figures quoted so far have referred to airports
with a sizeable passenger component to their business. The proposed Manston site will be
purely freight, at least initially.
It is clear that the “887 per million” DJM that RSP’s Dr Dixon cherry-picked from East
Midlands Airport and applied to this cargo hub proposal is far too high. When questioned
about this at a consultation event, she described her calculation as a “mash-up” of the EMA
figures and previous staffing levels at Manston. We need a much better explanation than
that to account for this brand new cargo hub being one of the most labour-intensive (or
should that be labour-inefficient?) airports in the country. A further technical factor to consider is that the new-build operation proposed by RSP offers
every opportunity to automate wherever possible, to ‘engineer out’ expensive labour costs, making it more ‘robot-intensive’ than existing cargo hubs. This will further lower the actual
DJM number for an operational cargo hub at Manston. Dr Dixon’s third error is to forecast something unknowable and uncheckable. This proposal’s key selling point for the community is jobs, so it is important that the job
forecasts are scrutinised carefully. The first tier of jobs that Dr Dixon describes is the so- called “direct jobs”. Dr Dixon tells us that direct jobs include: aircraft maintenance; airlines; airport and air
traffic control; airport security and passenger screening; employment by the airport operator;
food and beverage; general aviation; ground handling and ground transport; handling agents;
immigration, customs and government jobs; maintenance repair and overhaul (MRO); retail,
food and other in-terminal services; and ‘other’. This is what most people think of as ‘airport jobs’ – jobs at the airport, jobs that rely on the
airport. In fact, there should be no need to forecast most of these numbers – they should
emerge automatically from any comprehensive business plan. Obviously, direct jobs are
easy to count, and easy to compare with the forecasts.
In contrast, attempting to forecast and then count the numbers of ‘indirect’, ‘induced’ and
‘catalytic’ jobs is a fool’s errand. Each successive category definition (Azimuth vol IV section
3.1.2 to 3.1.5) becomes broader, vaguer and more all-inclusive. ? An ‘indirect’ job in the supply chain could be a cooper in the Scottish distillery that
makes the whisky sold in the airport shop, or a machine operator in the factory
that makes the braid on the airport security guards’ uniforms. ? An ‘induced’ job seems to include jobs affected by how people in the direct and
indirect jobs spend each and every penny of their income. ? ‘Catalytic’ jobs could be just about anything, the definition is so sweeping –
“facilitates employment and economic development in the national economy
through a number of mechanisms”. There are simply too many tiny details, too many impacts to be considered, too many
threads to be followed, to allow any meaningful level of accuracy – we’re in the realms of
‘best guess’, anybody’s guess. Once again, Dr Dixon has chosen some high guesses for the multipliers she uses – 2.1 for
indirect and induced jobs, and an additional 4.0 for catalytic jobs. Dr Dixon is telling the world
that every job created in this proposed cargo hub will, in its turn, create 6.1 further jobs. This goes beyond ‘optimistic’, ‘bullish’ or ‘toppy’ – this is fantasy, and it guarantees that any
and all errors made in estimating the DJM value will be magnified and multiplied. A fundamental flaw with counting anything other than direct jobs is that every job in every
industry creates other jobs around the world. However, if every employer were to pad his or
her business case this way, the inevitable double- and triple-counting would lead to a
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situation where there are more ‘jobs created’ than people. This is clearly absurd and is a
misleading ‘statistic’ to put before the public. Of course, counting the actual numbers of ‘indirect’, ‘induced’ and ‘catalytic’ jobs is
impossible – they are statistical projections, not individual, identified jobs and people. This
has two consequences. Firstly, it means that there is no evidence base of actual values for
multipliers that can be used to validate RSP’s assumptions. Secondly, it also means that in
the fullness of time, it won’t even be possible to tell whether RSP’s promise was kept, whether the proposal actually delivered the indirect, induced and catalytic jobs that were
promised.This makes it all the more absurd that Dr Dixon’s report should present these tens
of thousands of jobs as if they were factual or inevitable. RSP should set out a clear and evidence-based business plan with a carefully calculated
estimate (not a “mash-up”) of the number of direct jobs that this plan could create. To
suggest that every job at a new cargo airport would create more than 6 additional jobs is to
deliberately mislead the public. To be able to “engage” with RSP’s proposal and to take an
“informed view” of it, we need real data.
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Appendix One
RSP’s intended area for direct communication about the public consultation
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Appendix Two
No Night Flights data – map showing a sample of residents who have complained about aviation noise associated with the operation of the
former Manston Airport. The noise complaints clearly extend far beyond RSP’s chosen area of direct communication about the statutory
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Appendix Three
The ‘noise contour’ maps are taken from the Bickerdike Allen Partners report of August 2010. We have shown only those maps that show the
impact to the east of the airport. The area affected by noise levels of up to 95dBA clearly extends far beyond the area covered by RSP’s direct communication about its
statutory consultation.
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