Representation by Richard Oades
- Date submitted
- 7 October 2018
- Submitted by
- Members of the public/businesses
I am a planner with many years experience in research and consultancy. I approached the proposal to reopen Manston airport with an open mind. My permanent home is in Ramsgate. 1. Assertions tested a. The Application is founded on five key ‘assertions’, explicit, implicit or assumed. If any one of these ‘assertions’ is demonstrably ‘untrue’, based on the best evidence, then there is no case to progress the Application beyond that point in the process. b. The 'assertions' in logical sequence are as follows: i. There is a current and long term need for greatly increased air cargo capacity within the South-East (and in the UK as a whole); YES/NO ii. That the specific need is best met by a new dedicated air cargo hub (as opposed to other means); YES/NO iii. That Manston is the best site and location in the UK for that air cargo hub; YES/NO iv. That RSP has means, and a robust, sustainable 'stress tested' business plan that demonstrates that the airport would have short, medium, and long-term commercial viability; YES/NO v. That the adverse impacts and damage to population health, well-being, educational attainment, natural environment, built environment, heritage assets, culture and economy through noise, air pollution, safety risks and congestion proposal are demonstrably outweighed by local, regional and national benefits. YES/NO c. The evidence is clear that the first ‘assertion’ is not valid, and indeed neither is any of the others.
- Risk and Uncertainty a. The vast majority of DCOs applications are made by public sector agencies or utilities and relate to tangible engineering works and structures that are an upgrade or an integral addition to existing physical infrastructure. In stark contrast the RSP proposal is a standalone, speculative, wholly commercial venture that carries an inherent high level of financial risk and commercial failure.. Furthermore, it does not embody ‘overwhelming public interest’.. b. Those risks and uncertainties are summarised as follows: i. The commercial operation is highly sensitive to, and predicated on universally disputed forecasts of dedicated air cargo demand and market share. ii. There is no business plan by which to gauge the strength of the commercial operation; iii. There are efficient , well established, expandable air cargo competitor airports; iv. Manston would have stiff competition for market share, including from East Midlands (scoped out by RSP) and Stansted; v. Very high start-up costs coupled with the prospect of any financial returns being at best very long term; vi. Uncertainties about scale, origin, reliability and sustainability of funding sources over the short, medium and long term especially given the high level risk that potential investors would perceive; vii. Past record of serial failure of Manston as a commercial airport to an extent due to inherent unattractiveness of the location to serve markets across the UK.