Representation by The Ramsgate Society (The Ramsgate Society)
- Date submitted
- 7 October 2018
- Submitted by
- Members of the public/businesses
The Ramsgate Society, with over 700 members, asks the Examiners to consider the following points : 1. The application claims ‘national significance’ yet it is not underpinned by any objective strategic study of air cargo capacity and needs in the UK or the Region. Neither is it backed by the latest National Policy Statement on Airports nor by any objective and reliable evidence of market demand. It is an opportunistic, speculative, commercial proposition which does not embody “overwhelming public interest”. 2. Manston airport was unprofitable throughout the last 15 years of operation, losing over £100 million. 3. The forecasts of overall air cargo growth and market share are generated ‘in-house’ and are without a credible evidence base. They are consistently contradicted by several independent, leading aviation experts. 4. A re-opened Manston would face severe market competition. Stansted and East Midlands airports have the capacity to expand dedicated cargo flight operations if warranted by future demand. 5. The proposals come at a heavy economic and environmental cost to Thanet District Council’s future supply of housing sites as evidenced by its revised Local Plan. 6. The overall impact of the proposals on Ramsgate is understated by the applicant. The town with a population of 42,000 lies at its western edge less than 1.5 kilometres from the airport perimeter. Aircraft landing from the east would traverse the Royal Harbour at an altitude of about 300 metres and descend at an angle of 3 degrees for 2.7km down to 80 metres over the residential, urban area before reaching the runway. 7. The official data from Manston's most recent operational period establish that most of the town of Ramsgate is likely to experience sound levels in excess of 60dB SEL. Maximum sound impacts from aviation in Ramsgate were regularly recorded at over 100dB. 8. The aircraft noise modelling undertaken by the Applicant underestimates the noise levels likely to be experienced. Despite this the Applicant admits that '… significant adverse effects are likely in the communities of Ramsgate and nearby settlements to the point where there would be a perceived change in quality of life for occupants of buildings in these communities' (Para 4.1.46/47 5.1 Non-Technical Summary TR020002/ APP/ 5.1) 9. The Applicant fails to acknowledge that Ramsgate’s heritage assets are of national significance. In 2017, Historic England designated Ramsgate as one of only eight Heritage Action Zones (HAZ). The 5-year HAZ programme aims to harness the heritage assets to leverage sustainable economic growth. 10. The way in which the heritage assessment modelling methodology is applied and interpreted understates the impact of aircraft noise on the heritage assets of Ramsgate with its 450 listed buildings and 4 conservation areas.( Paragraph 9.6.21 – 23 of Volume 5.2 – 1 Environmental Statement Volume 1 TR020002/APP/5.2.1) Aircraft noise and vibration constitute a major disruptive factor for the residential occupiers of Ramsgate’s listed buildings, particularly given their age, construction and the limitations of acceptable sound proofing and insulation measures. 11. The close proximity to the airport, its location directly under the flight path, and the intensity of its 24-hour operation, would put the HAZ Programme, historic Ramsgate, its buildings and residents at serious risk from the effects of noise, vibration, pollution and visual disturbance. It would undermine the tourism and leisure economy, and jeopardise much needed investment and regeneration.