Representation by Adem Mehmet
- Date submitted
- 2 October 2018
- Submitted by
- Members of the public/businesses
Below is a summary of representations regarding the RSP DCO application. A larger document that references specific chapters within the application and verified evidence available in the public domain can be supplied if required.
Funding RSP twice attempted, with support from Labour-led and UKIP-led councils to become a CPO indemnity partner but basic requirements concerning funding were not met. Plans were for a very small operation until this failure, when they constructed a business plan designed to qualify as a NSIP. This DCO is completely fictitious, RSP have no intention of building a NSIP qualifying airport. RSP directors have previously sought to build housing on airport land including at Manston. The inspector should prohibit the building of houses by RSP on the site within the DCO.
RSP’s private investors previously had £15m to pay items estimated at £13.6m. RSP recently purchased the Jentex site which has depleted these funds. The inspector should stress the cost assumptions when assessing whether RSP have the required funding in place. How have CBRE concluded on the £7.5m? Have CBRE provided a range the payment could fall within or specified a best, worst and average value? The inspector should question the figure for blight claims as the noise contours drawn are questionable and the number of people affected underestimated. The documents are mute as to whether Part 1 claims apply in relation to aircraft noise; Part 1 claims are applicable in the case of Stansted and Southend. Have RSP assumed the CAA will place an Order exempting them from these in their budget estimates?
The project cost estimate is £300m. Where is the funding? The DCO process is not meant to support speculative commercial activity where a sponsor applies for a DCO and once approved seeks to secure funding as RSP propose. RSP have no balance sheet, no assets, no experience of raising funds or operating an airport successfully. DCOs are generally from entities like the Highways Agency who demonstrate the ability to finance and deliver projects on a regular basis.
RSP cite funding provisions from other DCOs. However, these companies have long-term operational experience. Covanta and Able have experience of raising funding and delivering projects of national importance; the degree of scrutiny and requirement in their funding statement is rightly less than we must expect for RSP. Why do RSP need a financing vehicle based in Belize? Is it to avoid investor disclosure, to avoid money laundering regulations or to strip profit from the U.K. operating company to avoid corporation tax being paid? If any of these reasons are remotely suspected, compulsory purchase powers should not be awarded.
Noise Monitoring, Noise Mitigation and Blight RSP indicate noise levels of 54db over Ramsgate, inconsistent with evidence from TDC’s website of levels recorded during previous operation of the airport and with evidence from CAA measurements for Boeing 787 and other planes operating at Heathrow. There are no recordings for any plane below 90.0db monitored in the CAA study at 3.8km so the noise over St Lawrence (1.6km) and central Ramsgate (3.2km) would be higher. Results from the CAA are consistent with monitoring at Manston.
The inspector should investigate the basis for derivation of noise contours and the assumptions behind them.
Night Flights
Quota level for night-time flights is 3028, quota 8 and 16 are banned at night. Heathrow’s quota count is reducing from 9180 to 5150 and quota 4 is banned at night. RSP’s proposals are disproportionately high given the relative number of movements of the two airports. RSP could be more ambitious in mitigating the impacts of this development and compensating residents.
The inspector question the science behind assumptions on awakenings; what's being said doesn't make sense.
All interested parties whether for or against the airport, SMA, SMAA, SUMA, NNF, [Redacted] and [Redacted] have all stated they are against night flights with both [Redacted] and [Redacted] (in recent letters to his constituents), confirming that RSP do not require night flights. Given this wholesale objection, that national policy is considering banning night flights (as they will be at Heathrow), the inspector should ban them as a condition of the DCO.
RSP plans I have not commented on the business case but know others will. Suffice to say the case is not made. RSP rely on their own assessment of the aviation market which has been refuted by many; in particular York Aviation whose data they have misused. There is significant independent evidence showing aviation is not viable at Manston. RSP make unverified statements regarding the shortcomings of Stansted, Heathrow, Gatwick, Luton and Southend. These are at odds with public statements made by these airports regarding their future plans. The inspector should hear directly from each of these operators concerning the assertions made by RSP. RSP focuses only on the South East but there are successful freight airports elsewhere like East Midlands. Have RSP properly considered other airports that are currently for sale like Mildenhall and Lakenheath?