Representation by Susan Kennedy
- Date submitted
- 7 October 2018
- Submitted by
- Members of the public/businesses
Below represents the main areas I wish to comment on during the examination period but would ask to reserve the right to add to these areas. NSIP: • The proposal contradicts national aviation policy. Manston was sifted out by the Airport Commission at an early stage. The Airports National Policy Statement (June 2018) confirms their recommendation and presents no case for a new dedicated freight hub in the south-east. • The DfT evidences a declining freight market which, combined with spare capacity for dedicated freight ATMs at existing airports, makes clear there is no requirement for this proposal. • The applicant’s proposal relies on the work of [Redacted] whose independence and expertise have been called into question and whose conclusions are disputed by 4 reports from aviation experts. • Independent reports by York Aviation, Altitude, Falcon Consultants and AviaSolutions have all concluded that Manston is not viable. Their conclusions would dispute any possibility of this proposal meeting NSIP criteria. Noise and night flights: • The noise projections, assumptions, worst case scenarios, noise modelling and mitigation plans need thorough interrogation.
o The proposal is contradictory in that it proposes no ATM cap, projects 17,000-83,000 freight ATMs with potentially additional passenger ATMs but then bases its noise assessment and noise mitigation plans on substantially less.
o There is no cap on night flights. Certainly, the QC applied for would allow QC4 planes meaning local residents would be subjected to a worse night flight regime than is allowed at Heathrow. Past experience of planes overhead at night, regularly in the range of 80-100dB, mean that as residents we are well aware of the impact of these levels of noise at night.
o There needs to be a thorough examination of the impact of noise events as opposed to average noise levels. The proposal’s noise mitigation statements are meaningless at present.
Funding: The financial credibility of the proposal and the inexperience, lack of expertise and dubious record of the applicants must be interrogated.
Health: Insufficient assessment, evaluation and mitigation work has been presented with regard to the negative impact on people’s health and wellbeing which, given the proximity to and low height over major residential areas, would undoubtedly be severe. These negative impacts are well recognised and the Secretary of State, in determining any application for development consent with regard to an airport, must, with any applicant and Examining Authority, not only thoroughly examine those impacts but must also consider ‘the cumulative impact on health’ as insisted on in the 2018 Airports NPS.
Public safety: The application does not provide sufficient reassurances and mitigation plans to address concerns around public safety.
Heritage and tourism: Robust and expert interrogation of the negative impact on Ramsgate’s heritage assets, its standing as a Heritage Action Zone an on Ramsgate’s flourishing and growing visitor economy is required.
Traffic: The insufficient traffic modelling and impact of the proposal with regard to road congestion, fuel supply and pollution must be properly investigated.
Biodiversity/environment:The impact on the unique biodiversity of the area plus more general environmental concerns, including pollution and climate change, must be more thoroughly examined and evaluated.
Alternatives: The owners of the site, Stone Hill Park, have credible plans and have experience and a sound track record. The proposal must be rigorously examined against such plans which promise much needed mixed-use development to include jobs and homes.