Representation by mark de pulford
- Date submitted
- 6 October 2018
- Submitted by
- Members of the public/businesses
National policy context • No UK government policy for a new dedicated air cargo hub. • No official endorsement that Manston airfield could or should fulfil such a role. • No planning status as an existing airport in the South-east, thus no official support for expansion (even if balance of economic/environmental considerations were favourable, which it isn’t).
Economic considerations • Fundamental limitations of the peninsular location of Manston, plus the significantly lower cost of belly-hold freight operations. • Reliance of the applicant’s key claims upon market analyses and projections from a solitary and impugned source. • Adverse impacts on other businesses and on local visitor-led regeneration glossed over.
Environmental considerations
• RSP’s application is environmentally irresponsible to characterise Manston as a “Boris Island” site (too close to densely populated area, protected habitats and heritage assets).
• RSP is basing whole environmental assessment on assumptions about numbers and flight patterns that are demonstrably not “worst case”.
• RSP noise predictions are flawed and inconsistent with historical data.
• Commercial viability appears linked with environmentally repugnant elements e.g. a night flights regime permitting flights banned as too noisy elsewhere.
• Cumulative light pollution effects from night operations has still not been assessed.