Representation by No Night Flights (No Night Flights)
- Date submitted
- 6 October 2018
- Submitted by
- Members of the public/businesses
The following shows key areas of concern where we plan to make submissions, reserving the right to respond to additional issues highlighted by the ExA or others:
General • Lack of evidence of UK government policy demand for a new dedicated air cargo hub, or any suggestion that Manston could or should fulfil such a role, were it to be needed. • Lack of evidence of market demand for a new dedicated freight airport • General unsuitability of the site for a major new international cargo hub in terms of its proximity to over 40,000 people, significant heritage assets and important protected natural habitats Noise and Night flights • Unsatisfactory “worst case” calculations and assumptions, underpinning all assessments. • Real aviation impact data from previous operations at Manston undermines applicant’s predictions • Multiple concerns about the collection, calculation and presentation of noise measurements and predictions (to include the host authority’s technical queries - see e.g. pages 326-352 of the Consultation Report, all dismissed by the applicant) • Likely ineffectiveness of the noise mitigation plan • Significance of night flights to the applicant’s business case. • Impact of night flights on health; educational attainment; quality of life and on the affected area’s tourism-dependent economy • Impact of noise on local heritage assets, and regeneration of the Heritage Action Zone. Economics • Lack of evidence how the Proposed Development would overcome the fundamental limitations of the peninsular location of Manston within the UK and the South-east, plus the significantly lower cost of belly-hold freight operations. • Critiques of the work submitted by Azimuth associates. • Unsoundness of applicant’s net employment creation projections • Assessment of adverse impacts on visitor-led regeneration plans (tourism, leisure, the arts, local attractions and visitor facilities)
Safety and Health
• Multiple safety issues including Public Safety Zones, risk contours, proximity of population densities over 40,000, number of schools under flight path, aircraft altitude over town, lack of proximate major A&E/trauma centre
• Multiple health and well-being issues, including evidence from research on the impact of heavy aviation on the health of proximate population densities (especially the young, sick and elderly), air quality, the absence of an emission mitigation plan, exclusion of road traffic pollution from key modelling, and water pollution issues
• Compatibility with UK and international climate change policies and targets
Funding
• Lack of evidence of secured funding for credible compensation and mitigation costs
• Need for transparent and robust financial projections for funding the Proposed Development, and a fully prepared investment appraisal
Traffic
• Multiple issues, including modelling of congestion and traffic emissions, the supply of aviation fuel (and alternatives to the Jentex site).
Habitats and biodiversity
• Multiple concerns regarding impact assessments relating to the eleven statutory designated sites located within 11 miles of the site, and the three Priority Habitats within 1 mile of the site, and concerning proposed mitigation measures.
Alternative Use of the Site
• The plans proposed by the owners of the site, offering local people homes and jobs and investment by regeneration specialists.
• Desirability of enabling the host authority to meet future housing needs with significantly less use of greenfield sites
• Lack of compelling case in the public interest to seize this land for RSP’s project