Representation by Simon Crow
- Date submitted
- 1 October 2018
- Submitted by
- Members of the public/businesses
Sirs I am opposed to this application. Accordingly, I wish to make a representation at the examination stage of the DCO. The main grounds for this are as follows. However, please note i) this is not an exhaustive list and there may be further matters that I would like to raise during the examination stage and ii) I may wish to engage relevant expert witnesses to support my representation at examination. 1. Economic Viability • No financial business case has been presented anywhere in the DCO submission documents. • The forecasts, on which rests all of RSP’s case, are highly suspect. The four Azimuth Reports are based on one person’s ([Redacted]) personal assessment of the air cargo market. There is no independent corroboration of those forecasts. Indeed, there have been four independent reports each of which conclude that Manston as a cargo airport cannot be viable. Altitude Aviation Advisory concluded: “We consider the (Azimuth) forecasts to be extremely optimistic, not credible or likely, with negligible supporting evidence.” • Furthermore, the No Night Flights Group has produced critiques of each of the Azimuth Reports demonstrating those reports to be not credible. 2. Funding • As you, the Planning Inspectorate, have already indicated, there are many questions about the project’s funding that remain to be answered. • There is much uncertainty and a high degree of risk around the project. • There is sparse evidence of the source and availability of funding in RSP’s submission. • On two occasions the local authority, TDC, has rejected previous applications by RiverOak, primarily for lack of evidence of funding. • The RSP directors have no track record in this sector, except for failure, serial insolvency and other issues. • The funding source appears to be based on a shadowy, offshore investment fund in the tax haven of Belize. 3. Noise and Night Flights • RSP’s submission documents appear to significantly downplay the impact of noise for people under the flightpath. • For example, i) RSP uses noise levels which measure average noise over a period of time, but the true annoyance occurs from the extremely high and short-term noise levels from aircraft passing overhead; ii) RSP claims just 225 residential dwellings will be exposed to significant annoyance and disturbance from noise, but this is just not credible given the population of approaching 80,000 people under the flightpath and known previous recorded aircraft noise levels in the area. • Throughout, over the last 3/4 years, RSP has been extremely evasive about the need for night flights, repeatedly telling locals that RSP do not need night flights. However, it is clear from the submission that night flights are indeed planned, although, even here, the true level is not specified. Is it eight flights per night? Or 18 flights per night? Or is it based on the quota system, which potentially could be many more flights during the night? RSP’s submission is entirely elusive and vague on this key issue for local residents. • Should RSP go ahead with its plans for a 24/7/365 cargo airport, Ramsgate would become the noisiest and most air-polluted urban centre anywhere in the UK.