Representation by Chris Lowe
- Date submitted
- 7 October 2018
- Submitted by
- Members of the public/businesses
List of the principal aspects and concerns; I wish to reserve the right to respond to issues raised by the Inspector, or to additional evidence supporting the Application.
SUMMARY
I question the Applicant's adequacy of evidence and consider they claim benefits far greater than could be achieved, seriously underplay the many adverse effects.
NEED AND ALTERNATIVES No need for proposal. Existing airports have capacity greatly in excess of Government Forecasts; Heathrow developments means less demand.
Alternative uses would create more benefits with less damage.
PLANNING AND LEGAL National and Local Policies and Plans do not propose new airports. Manston is not existing airport - Airport National Planning Statement provides no support for new airports, allows Heathrow developments, with increasing use of “Existing airports” only. Insufficient evidence for qualification as DCO or Compulsory Purchase processes. Revisions of National Planning Policy Framework emphasise housing not employment, with increased protection of natural features. UK Airspace Policy and airspace capacity militate against proposals.
LOCATION The north-east tip of Kent is wrong place for strong passenger or freight base. Few potential passengers nearby, on wrong side of London for freight distribution.
FORECASTS Freight movements decreasing since 2000, National forecasts for Air Transport and Freight Movements show no demand for proposals. Previous operators' forecasts never approached achievement, current forecasts not convincing.
VIABILITY Not viable now, nor in future, with no sources for regular freight or passengers.
FINANCE Competition with existing airports so extremely difficult for new startup. New airport and roads requires compensation for those affected.
ECONOMY, EMPLOYMENT Previous operators' employment projections and benefits were greatly overstated Applicant's forecasts similarly exaggerated, so no benefit for economy. If claims achieved, would adversely affect Kent by distorting local employment market, increasing housing and infrastructure needs and increasing costs for existing employers.
IMPACTS Consequential Impacts eg impacts of flights, consequences of claimed employment such as housing and infrastructure, inadequately assessed.
To establish Manston would have to accept flights unacceptable elsewhere, with greater impacts, such as night activity, with flights, road traffic and light pollution, and noisier planes.
Impacts occur both locally and over a very large area including Cross-boundary.
MAIN IMPACTS INCLUDE, BUT ARE NOT ONLY:
Inequality Greater effect on less well-off, wrong to aggravate deprived area of Kent.
Climate Change Aircraft emissions a major impact of airport, needs to include non-CO2 emissions as in Aviation Strategy. Government’s 'Growth Strategy' commits to reducing emissions in the aviation sector for UK legally binding targets, so need to constrain the number of flights. Faster action needed as Climate change is accelerating. Requires compliance with Committee on Climate Change Adaptation advice.
Pollution Serious impacts from Air, Fuel, Water, Noise, Light Pollution, and to associated resources.
Water Water resources, Water Framework Directive, Run-Off; Flooding, Hydrogeology
Noise, Tranquillity, Health, Welfare, Quality of Life, Accidents, Safety, Turbulence Damage
Ecology Bio-diversity, Habitats and Wild Life, Habitats Directive, Wild Birds Directive, Conservation of habitats and Species Regulations 2017
Land Landscape, Land Quality, Archaeology (such as Ramsgate Reculver, Richborough, CanterburyCathedral), Public Rights Of Way