Representation by Jason Jones-Hall
- Date submitted
- 22 September 2018
- Submitted by
- Members of the public/businesses
I am submitting this response as both a private individual and business owner in Ramsgate. A major part of my business is focused on placemaking, including economic regeneration based on the built environment and unique features of local heritage, culture and architecture.
As an international expert in culture-led economic regeneration, I have more than 15 years experience in assessing applications for funding and investment involving both private and public finance.
I would like to formally raise objections and concerns with regards to the significant environmental and health impacts, safety concerns and issues with regards to veracity, misrepresentation and conduct of RSP during the consultation period. For the purposes of this initial submission I would also like to focus concerns on the following:
- RSP, its team and funders lack any credibility to develop or operate a Nationally Significant Infrastructure Project, (NSIP), failing to meet the most basic requirements of due diligence for a project even 1/1000th of its size
- RSP’s business case is poorly researched, inadequate and unrealistic
- Failure to deliver on the proposed plan and/or projections - which seems inevitable - will result in failure to meet the minimum requirements of a NSIP. Further, there will be a significant opportunity cost with regards to alternative development proposals and the region’s resurgent heritage and tourism sectors
- The proposal is not consistent with Thanet District Council (TDC) Draft Local Plan - 2031, specifically in relation to housing requirements and vision for Ramsgate ‘to maximise its maritime heritage, Royal Harbour, marina, beach and attractive waterfront, and provide economic base of its vibrant mix of town centre uses, visitor economy and café culture”. (Sections 2.34 - 2.44)
There are significant issues in basic due diligence which lead to the inevitable conclusion, shared by TDC’s independent consultants, Avia Solutions, that Manston Airport is not viable. These include but are not limited to:
Neither RSP nor its parent companies have any track record in owning or operating an airport or any other NSIP The split from RiverOak Corporation - the original applicants - means RSP is essentially a start-up business with no major corporate backers, limited assets and finance, no registered Persons with Significant Control and a corporate structure that lacks transparency Principal RSP Directors have no track record in this sector, with the exception of [Redacted], and no experience in a NSIP [Redacted] own track record is one of failure, serial insolvency and being struck off the Solicitors’ Roll for 27 counts of misappropriation of client’s funds Helix Fiduciary - the only funder for which RSP has provided any evidence of support - has no track record of investing in airports or any other NSIP or of raising the levels of finance required to do so [Redacted] , author of the “Azimuth” report which forms the foundation of RSP’s proposal and business case, continues to illegally and fraudulently present herself as “Azimuth Associates Ltd” on her own website. In fact, she has no connection with this company - a mobile foot clinic in Cheltenham [Redacted] is an independent researcher with limited experience in aviation research, no experience in the economics of airport operations or formal training or experience in economics at all, having achieved her PhD in 2014, shortly before the start of this process. The only evidence of any research experience in this field is her PhD thesis on the master planning process for airport managers. This is a completely different field of research, requiring a different understanding and skill-set, than is needed to develop a business case for a NSIP
The Azimuth Report is neither independent nor authoritative, filled with exaggerated claims of benefits and wilful avoidance of any downsides. Serious omissions include, but are by no means limited to:
Lack of any credible competitor analysis, specifically with regards to recent developments at East Midlands, Stansted and Southend Airports Inadequate identification of risks and risk mitigation, including a naive dismissal of the implications of Brexit on the international freight market Inaccurate and outdated freight market analysis, with International Air Transport Association (IATA) reporting as recently as August 2018 that “air cargo continues to be a difficult business with downside risks mounting” Under-estimation of costs, over-estimation of potential addressable market and Air Traffic Movements (ATMs) and an inconsistent and unfocussed business model No evidence of support from any potential clients and unrealistic expectation to win major business already committed elsewhere in the UK and internationally - notably Amazon Unrealistic comparisons with other national and international cargo hubs given major geographical and infrastructure limitations to the Manston site
RSP’s Funding Statement is totally inadequate. Specifically:
Helix Fiduciary’s letter of 12/7/18 confirms only that “up to a total of £15m” is available “should the DCO application be accepted and ultimately approved by the Government”. This offers no guarantees that any sums are available now or to provide RSP with the funds required to complete the DCO process RSP claims to have already drawn down £500,000 and expended £9m - before the recently-reported purchase of the Jentex fuel site. Evidence of these sums - or of their source - has not been presented. Further, it is unclear whether the £9m+ already committed is included in Helix Fiduciary’s commitment of up to £15m and - if so - whether there will be enough funds remaining to complete the compulsory acquisition, valued optimistically by RSP at £7.5m, or the Noise Mitigation and Blight claims, also optimistically valued at £5.6m. RSP has provided no evidence whatsoever that it has access to the significant finance required to fund any construction costs or implementation if the DCO is successful. Given the inadequacies of the Business Case and Azimuth Report, significant rival developments at East Midlands Airport, Stansted and Southend and lack of experience of RSP and its principal directors, it is naive in the extreme to suggest that RSP will be able to merely “select one or more funders from amongst those who have already expressed interest and others that are likely to come forward” to finance the project capital costs, estimated by RSP on the low side at £300m. Yet again, RSP has presented no evidence whatsoever to support this bizarre claim.
Opportunity Cost
I am deeply concerned by what in RSP’s own words will result in “significant adverse effects” in Ramsgate, Manston, Wade, West Stourmouth and Pegwell Bay “... to the point where there would be a perceived change in quality of life for occupants of buildings in these communities”.
I also note RSP’s use of the phrase “occupants of buildings” as opposed to “people”, “families” or “businesses”. Quite apart from the dehumanising intentions behind this phrase, it fails to adequately convey the wider impact on the town and its current resurgence, with its unique heritage and architecture at the heart of this.
In recent years - and since the closure of the previous failed attempts to operate the airport - the resurgence and regeneration of Ramsgate has included:
Total of almost £10m investment in heritage-based regeneration projects in Ramsgate from private investors and public funders including Heritage Lottery Fund (HLF), Historic England, (HE), Arts Council England (ACE) and European Union (EU) Around 450 listed buildings in Ramsgate and recent designation of one of Historic England’s (HE) 18 Heritage Action Zones, opening the door to further funding via HE’s Repair Grants and Capacity Building Grants Increase into tourism in Thanet since the closure of the airport, with a 21% increase in overseas visits and 23% increase in tourism-related employment in the year immediately after closure
Since RSP’s proposal fails to identify or recognise any of the above, it also fails to take into account and wilfully misrepresents the full impact on Ramsgate, the national significance of the town and its heritage and inconsistencies with development plans as set out in TDC’s Local Plan - 2031.
This is due in part to RSP’s misleading assessment that Ramsgate is 4km from the runway, (in fact, the built-up area begins 1.3km from the runway and directly under the flightpath), and an environmental impact assessment that does not extend beyond 1km from the airport. Consequently, RSP’s estimates for costs of noise mitigation, compensation and blight claims are unrealistic and inadequate.