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Representation by Samara Jones-Hall

Date submitted
23 September 2018
Submitted by
Members of the public/businesses

I am a resident of Ramsgate and Ramsgate-based business owner. I hold a solicitor’s practicing certificate and am on the Rolls but do not currently practice law. I, also, do some work for the Bar Standards Board. Before moving to Ramsgate I worked as a lawyer in the offshore trusts and funds industry in all three of the Crown dependencies including at a senior level for the Jersey Financial Services Commission.

The Applicant claims to have run a wide social media campaign. Since 2016, I have run the twitter account @LOVE_RAMSGATE which has 1000+ followers with a reach of 3,689 and impressions of 44,207 compared to the Applicant’s number of followers of 700+ with impressions of 30,700 of which my twitter feed accounts for 1/3 of their total impressions. The only engagement by the Applicant with any other user on twitter since June 2017 was to ‘like’ an image of a UFO with the narrative “I Want to Believe”.

To the best of my knowledge, I did not receive a postcard or receive any other communications from the Applicant before or during any of the Consultation periods. I am happy to provide an affidavit stating such.

To date the Applicant has not shown a respect for or understanding of fiduciary, statutory and regulatory obligations at the most basic level. One of the Applicants was struck off the Solicitors’ Roll for 27 counts of Misappropriation of Client Funds. As of 12/9/18 the Applicant and their professional advisors (Synapse.It, Copper Consultancy and Bircham Dyson and Bell) have been notified that they are in breach of GDPR or DPA 2018 personal data breach and that the Information Commissioner’s Office will be notified after the required 28 days. As of 13/9/18 Companies House has been notified that Applicant’s website and email communications are in breach of the Companies (Trading Disclosure) Regulations 2008 and Section 82 of the Companies Act 2006.

This is all before the Applicant has even begun trading.

I very strongly object to the Applicant’s proposal on the following grounds: Significant and/or severe negative impacts on Community, Quality of Life, Economy, Noise, Biodiversity, Soil, Water, Air Quality, Carbon (Climatic Factors), Resources and Waste (Material Assets), Tranquility, Landscape and Historic Environment (Cultural Heritage) coupled with insubstantial and inaccurate Noise data and Noise Mitigation Plan, an inadequate Consultation and a derisory Funding Statement, an investment structure which looks designed for aggressive tax avoidance and an insufficient and flawed business plan produced by a connected person to the Applicant who has no background in economics or in the air-cargo freight industry.

Further to date, the Applicant has shown no demonstrable commitment or connection to the air-cargo freight industry or any demonstrable commitment or connection to employment in Thanet through direct employment despite expenditure of GBP 9m to date.

1A. Community - Housing: a) Applicant Proposal directly prevents the lawful owner’s development of some 25% of Thanet’s Local Plan housing requirements as well as GPs, schools, business space and recreational facilities on the site b) Applicant Proposal has directly caused the draft Local Plan (endorsed by Thanet District Council but opposed by its officers) to push 2500+ houses to be built on Greenfield sites and in areas with little or no additional infrastructure (if Applicant is successful at achieving a DCO). c) Applicant Proposal uses brownfield land, which could be used to meet a significant proportion of district’s housing needs. d) Applicant Proposal directly impacts around 900 listed buildings of which five are Grade I and eleven are Grade II (and therefore cannot have double glazing) and around 400 of which are residential. e) Applicant Proposal potentially impacts the Manston Green proposal, which has outline permission for 785 homes, a primary school, shop, community hall and public open space and has received GBP 2.5m SELEP funding directly under the proposed flight path.

1B. Community - Regeneration: a) Applicant Proposal is not consistent with and will blight significant heritage projects in Ramsgate, which have received circa GBP 10m in private and public regeneration funding since the closure of the previously failed airport.
b) Many of these sites have opened only in the last year and their contributions to tourism have not been quantified. c) For example St Augustine’s visitor centre (GBP 1.2m) which had 10,000 plus visitors last year and the Royal Victorian Pavilion Wetherspoons (GBP 4.5m) which has a capacity of 1,400 and is Britain’s largest Wetherspoons and received significant national press. d) Applicant Proposal is not consistent with the Lords Select Committee Regenerating Seaside Towns. e) Applicant Proposal is not consistent with the draft Local Plan.

1C. Community – Recreational Spaces: a) Applicant Proposal significantly impacts the use of recreational spaces. b) Please note that the DCO application omits a significant number of recreational spaces for example: St Luke Football ground, Ramsgate Football ground, Boundary Park, Winterstoke gardens, Victoria Gardens, Ramsgate Bandstand (surrounding which is the only open-air polished dance floor that you will find on a cliff top anywhere in the world), Arklow Square, Vale Square Gardens, Ramsgate Skatepark, Newington Park, Royal Harbour Marina (a Four Gold Anchor Award complex) which holds the very popular nationally and internationally Ramsgate Week as well as offering 700 finger moorings throughout the year and Ramsgate croquet lawns (four excellent full-sized lawns and a clubhouse). c) People have been escaping to Ramsgate for more than 200 years, for the laidback seaside vibe, the breathtaking sandy beaches and fresh sea air, discovering a natural, relaxed and friendly place. d) Since the closure of the previously failed airport Ramsgate has hosted British Kitesurfing championships 2018, is part of the 28-mile circular Viking Coastal Trail (one of the most attractive leisure cycle routes in Kent) which links up with Regional Route 15 of the National Cycle Network, has 2 canoe trails, seal and bird watching walks and our walk from Ramsgate's Royal Harbour to Margate Walk was voted in the Top 100 Walks in Britain (the only walk on the list from Kent). e) Natural England has found that for every £1 spent on establishing healthy walking schemes, the NHS could save £7.18 in the cost of treating conditions such as heart disease, stroke and diabetes. Applicant Proposal will blight this NHS health saving to the people of Ramsgate, Thanet, Kent and UK.

1D. Community – Churches, places of Worship and/or Remembrance: a) Applicant Proposal significantly impacts the use of churches and places of worship and/or Remembrance. b) Please note that the DCO application omits a number of working churches and places of worship and/or Remembrance. c) For example: Montefiore Synagogue & Mausoleum (1833+), Ramsgate Jewish Cemetery (since 1872), St Augustine’s Shrine (Pilgrims are welcome each day at the Shrine Mass), St George’s Church (consecrated in 1827), St Ethelbert’s RC Church (1902), St Luke’s Church (1876), Christ Church (1847), St Laurence-In-Thanet Church (St Laurence-In-Thanet Church)(1062), Hadres Street United Church, Kent Thanet Amman Temple and Holy Trinity Ramsgate (1845).

1E. Community – Schools: a) Applicant Proposal significantly impacts our schools from those rated as outstanding to poor.

1F. Community – Social Cohesion: a) Support for Applicant Proposal is largely from the community directly impacted by its closure and cultivated by positioning itself - directly and/or indirectly - as “the planes will stop the houses" and "people from London overspill” and miscommunication/misrepresentation about night flights and number/location/type of jobs. b) This has had a divisive effect on the community and its social cohesion. Many against the Applicant’s proposal have received threats and have experienced bullying.

1G. Community – Road Infrastructure: a) Kent County Council Local Transport Plan 4: Delivering Growth without Gridlock 2016-2031 there is no support for or inclusion Applicant Proposal until at least 2031. b) Kent County Council Local Transport Plan 4: Delivering Growth without Gridlock 2016-2031 has not been referenced within the Applicant Proposal. c) Kent County Council’s Freight Action Plan for Kent: currently sea-freight vehicles already account for up to 41% of all vehicles on the country’s strategic road network via M2/A2 and M20/A20.
d) Applicant Proposal will add a significant volume of road vehicles and HGVs used to transport air-cargo, workers, passengers and fuel, on Kent's overburdened strategic road network via M2/A2 and M20/A20. This has not been addressed. e) Road Haulage Association has publicly stated that this road network is not geared up for HGVs at a current level let alone even more. f) Applicant Proposal and its reliance on a poor road infrastructure for air-cargo, workers, passengers and fuel have not been subject to an Equalities Impact Assessment for Thanet and Kent.

  1. Noise: a) Applicant has inaccurately stated that Ramsgate is some 4km from the closed airport. It is around 1km away. Further, Applicant has determined future noise monitoring when operational will take place at 6.5km from the now closed airport (ie in the sea). This is unacceptable. b) Applicant’s Table 12.3 is inaccurate by their own figures noise goes down to 5 dBL and averages at 28 dBL not 54 dBL as stated at OBS 12. c) At OBS 12 Ramsgate Royal Harbour there is not usually “intermittent aircraft noise audible” in Ramsgate nor are there any trees at OBS 12 for the dominant source of sound to be “wind rustling through the trees”. Applicant needs to provide accurate and verifiable statistical raw data. d) Applicant’s Chapter 12.4.16 there is no reference to the duration of the study period or any dates as to when the study actually took place re the 14 locations on Applicant’s Figure 12.2. e) It is unclear where the figures referenced at Chapter 12.7.49 come from. f) Applicant’s Figure 12.5 does not seem to follow pattern at Figure 12.4 or Figure 12.8. Applicant’s Figures are not in a format that a layperson can understand and navigate. g) Applicant’s Figure’s 12.1 and 12.2 is missing St Laurence-In-Thanet Church and its three and a half acre churchyard in addition to other places of worship and recreation. h) Independent Transport Commission The sustainability of UK Aviation: Trends in the mitigation of noise and emissions (2016) states that in relation to air-cargo "aircraft are usually either conversions of older passenger aircraft or the last aircraft from a given aircraft production line. This means that the rates of technology implementation for dedicated freighter airlines are among the lowest in the industry. Popular aircraft types for these airlines continue to include the McDonnell Douglas DC-10 (first flight 1970) and Airbus A300 (1974)”. i) Applicant has not set a maximum departure noise limit; therefore aircraft are certified to comply with the agreed international noise standard in force at the time it was manufactured. Applicant has not accounted for this in the Noise assessment or Noise Mitigation Plan or blight compensation. j) So older aircraft comply with less stringent standards than aircraft manufactured today. It is reasonably likely that the Applicant or its agents will use conversions of older passenger aircraft or the last aircraft from a given aircraft production line as stated by the Independent Transport Commission (2016). Applicant has not accounted for this in the Noise assessment or Noise Mitigation Plan or blight compensation. k) Further actual limit values are reference to weight so heavier aircraft can make proportionally more noise under the same standard. Applicant has not accounted for this in the Noise assessment or Noise Mitigation Plan or blight compensation. l) Applicant has not identified the percentage mix of aircraft types and makes unsupported statements such as at Chapter 12.7.55 “the reduction from Year 2 is due to the forecast phase out of the Boeing 767-300 and Boeing 767-400” with no supporting evidence or rationale. This statement indicates that the Applicant is using best-case scenario accounting rather than worst realistic case scenario. m) Further, Applicant has not factored in perceived noise and the fact that noise travels over water. n) Applicant has not factored in transport noise (from road vehicle and HGVs used to transport air-cargo, workers, passengers and fuel), in Manston, Ramsgate, Thanet and Kent.

  2. Noise Mitigation Assessment: a) For the reasons outlined above Applicant has not presented an accurate picture of Noise (current and projected), worst realistic case or reliable evidence. b) Applicant’s Noise Mitigation Plan is unreliable and therefor the blight compensation sums identified by and stated in the Funding Statement are Applicant inadequate. c) The statements at 2.4, 2.5, 3 and 4 of the Noise Mitigation Plan cannot be quantified or relied upon for the Funding Statement d) Third party independent monitoring of noise levels is required particularly in view of the large number of schools, residents and community facilities under the flight path. Many of which are listed buildings. e) There have been reports of damage to residential roofs in Ramsgate caused by wind vortices by low flying planes. Applicant has not considered or factored this into Environmental Statement or blight assessment. f) The Community Trust Fund has not been quantified. As this is part of the Noise Mitigation Plan this should not be omitted and needs to be quantified and addressed as part of the Funding Statement.

  3. Quality of Life (Population, Human Health) a) Applicant’s Proposal has blank paragraphs in Chapter 15 of the Environmental Statement. b) Applicant’s proposal will directly adversely and significantly affect the residents of Ramsgate whom already have a high incidence of poor health and average life expectancy significantly lower than the figures for Kent as a whole. c) The Health Assessment is inadequate particularly as Ramsgate already has high levels of Multiple Deprivation within 4 of its 7 wards each containing LSOAs within the bottom percentile. Ramsgate has a large number of SEN children and older people and associated increased health risks. Applicant Proposal will significantly increase health risks particularly with regard to air pollution. d) The impact of and congestion on road vehicles and HGVs used to transport air-cargo, workers, passengers and fuel travelling to and from the proposed airport on Kent’s road transport infrastructure and the associated carbon, nitrogen oxides and particulate matter emissions, noise and air pollution - on Thanet’s and Kent’s villages, towns and businesses has not been addressed by the Applicant or been subject to a Health Impact Assessment; and - on travel times for all East Kent stroke victims to reach stroke unit in time as the nearest stroke unit is likely to be moved to William Harvey Hospital in Ashford has not been addressed. e) I cannot locate the Health Impact Assessment.

5A. Economy - Tourism and Film (Economic and Opportunity Loss) a) Applicant’s Proposal will negatively impact proven economic benefits and opportunity loss in the Tourism and Film market. b) In 2014, the previously failed airport closed. One year later tourism had shot up. Research by Visit Kent published at the end of 2016 shows that in that one year after the airport closure (ie for 2015) £293 million was spent in Thanet as a result of tourism and 7312 jobs supported, 6403 tourism jobs, 909 non-tourism jobs. These numbers are based across all of Thanet. Applicant Proposal has not taken into account these factors. c) Currently much of Thanet’s tourism is day-trip based. d) To mitigate the costs of day-trips to each of Thanet’s towns and to reap the economic and financial benefits of overnight trips (weekend and week-stays) Thanet needs to continue to provide and build upon an offer to tourists across all of Thanet. This is even more relevant with BREXIT and the rise of the stay-cation. e) This is in line with Thanet’s and Kent’s marketing campaign Visit Thanet, Active Ramsgate and Explore Kent. Applicant Proposal will blight this proven revenue stream with economic and financial benefits and there is an opportunity loss for Thanet as well as Ramsgate. f) The Visit Kent Summer campaign research shows the most 'likes', 'reactions', 'shares' and 'comments' on social media were Viking Bay, Hever Castle and Ramsgate. g) Ramsgate was named amongst Canterbury and Sandwich in a top ten of the most beautiful towns and cities of England in 2018. h) Since the closure of the previously failed airport many tourist attractions have opened/ reopened and visitor figures have not been fully appreciated and quantified. i) For example: the Arches at the Royal Harbour (opened 2013/2014), the Ramsgate Tunnels (re-opened May 2014), Ramsgate Music Hall (voted best small venue by NME in 2015), Royal Victorian Pavilion (re-opened August 2017 with a 1400 capacity), and St Augustine’s Visitor’s centre (opened 2017). Applicant Proposal has not taken into account these factors at all. j) Since the closure of the previously failed airport many boutique 4/5 star hotels have opened. For example: Albion House built in 1791 voted The Telegraph's "The 50 Most Romantic Hotels in Europe" - in at number 15 (March 2017), The Times "20 Great hotels for a Weekend away" in at Number 10 (March 2017), The Times "Best Places by the Sea" (Number 26) (May 2016). The Falstaff built in 1801 within the West Cliff conservation area as well as three seaside vacation apartments. In addition to the Landmark Trust’s Grade I listed the Grange (1844) holiday home. Applicant Proposal will blight this revenue stream and positive growth. k) Most of our hotels and a great number of the self-accommodation apartments are within listed buildings (Grade I and II) which cannot have double-glazing. l) As well as its sandy beaches and rich designated historical and heritage, Ramsgate’s main attraction is its coastline, which led to the creation of one of the largest marinas on the English south coast. m) The unprecedented night flights and sheer number of daytime flights would severely impact this part of the Tourist market, as few visitors would want to stay in accommodation, walk on a coast and visit our heritage and historical sites with such significant noise and visual detriment day and night. Applicant Proposal will blight this revenue stream and there is an opportunity loss for Thanet as well as Ramsgate. n) Since the closure of the previously failed airport many exceptional restaurants, café, bars, have opened which have garnered national press coverage, 4/5 star ratings on TripAdvisor, 4 in Hardens all adding to the food scene and café culture at the harbor side. Applicant Proposal will blight this revenue stream and provider of jobs. o) Since the closure of the previously failed airport Ramsgate has been a location for film and TV. Applicant Proposal will blight this revenue stream. p) Since the closure of the airport Ramsgate has hosted British Kitesurfing championships 2018, is part of the 28-mile circular Viking Coastal Trail (one of the most attractive leisure cycle routes in Kent) which links up with Regional Route 15 of the National Cycle Network, has 2 canoe trails, seal and bird watching walks and our walk from the Royal Harbour to Margate Walk was voted in the list of the Top 100 Walks in Britain in 2018. q) Applicant Proposal will blight enjoyment and impact on this revenue stream of active, cultural, historical and heritage holidays. Business will suffer. Job market will contract. Applicant has not identified and quantified economic loss and opportunity loss for Ramsgate and Thanet in the event that the airport is re-opened. Past performance strongly indicates that the day flights will slow or reverse Tourism growth in Ramsgate and it will limit the Visit Thanet tourist offer significantly. Presumably night flights will do so even more.

5B. Economy – Growth in Employment a) Applicant will not contribute to a sustainable growth in employment, as it is not feasible or viable. b) Applicant Proposal will result mostly in a redistribution of jobs rather than new jobs. c) Applicant has made clear that it would highly mechanize the cargo freight operation. This would reduce the number of and attractiveness of jobs. d) Further, freight-handling jobs typically do not allow for progression or advancement. e) Applicant has misrepresented and/or not factored in the size of the air cargo market, the fierce and stiff competition for air cargo business, the developments already underway (East Midland Gateway, Lydd and Stansted) and the growth and positioning of the Manchester Airport Groups (“MAG”) and nor has it factored in the costs of and inherent risks, weaknesses and threats to its proposed business. f) Applicant does not have a stall at the Thanet Jobs, Skills and Apprenticeships Fair 2018 (55 organisations as of 19 September have confirmed attendance). g) Applicant Proposal does not identify key employers in Thanet for example FUJIFilm.

5C. Economy – Business Plan (Air Cargo) a) The most recent (2017) Department for Transport forecasts to 2050 the number of air cargo/freight flights will remain flat at 2016 levels. b) IATA (2018) reports that there has been a slow down in air cargo growth that began earlier in 2018 with downside risks mounting and that supply growth has now outstripped demand growth. c) Average hourly pay in freight air transport services fell by 12% between 2011 and 2016 suggesting that freight air transport has not been performing strongly. d) Independent Transport Commission November 2017 states that the Aviation sector has low returns on capital. It is unclear which investors will invest and continue to invest in this type of market. e) Independent Transport Commission November 2017 states that there are air connectivity concerns, “particularly around the air freight regime and perceptions of the UK’s air transport sector”. Again, it is unclear which investors will invest and continue to invest in this type of market particularly in light of the factors highlighted above and below.

5D. Economy – Business Plan (Competition) a) MAG own and operate three out of the top four cargo airports in the UK; East Midlands, Stansted and Manchester. It can offer customers several cargo gateways across England linking up air-sea-rail-road. b) Applicant does not take into consideration the unused cargo capacity and spare runway at MAG airports (East Midlands, Stansted) and Gatwick. c) MAG’s Stansted serves nearly the same market identified by the Applicant. Stansted is ideally geographically located, has good access to good rail and road infrastructure, has spare runway capacity and a current planning application (tbd mid-October 2018) to increase capacity both passenger and cargo. d) MAG’s East Midlands Gateway is located next to the M1 and East Midland Airport has planning consent for up to six million sq ft of logistics space and 50-acre strategic rail freight interchange which will be operational in 2019. e) Lydd Airport in Kent (Ashford) has the go-ahead for a new passenger terminal and longer runway. f) Independent Transport Commission report: The sustainability of UK Aviation: Trends in the mitigation of noise and emissions states that “Sustainability for air freight is most likely to be achieved through the use of existing passenger airline hub networks supplemented by large-scale freight aggregators with dedicated aircraft fleets linking logistics hubs. This will minimise the need for extra flights, ensure economies of scale from larger aircraft, and utilise the most modern and efficient technologies available”. g) Applicant Proposal does not meet this standard whereas its competitors do.

5E. Economy – Business Plan (Surface Access Connectivity) a) Speed and reliability benefits airfreight offers that require time-sensitive and high-value commodities. b) Applicant has misrepresented and/or not factored in the negative impact of Manston’s limited geographical location and its reliance solely on a poor road infrastructure for air-cargo, workers, passengers and fuel. c) Applicant's reliance solely on a poor road infrastructure with a single motorway connection does not provide any resilience or alternative routes. d) M2 is the only “M” road in England that does not meet any other motorway at a junction. In 2017, there have been a number of severe and fatal incidents on the A299 and M2. e) Applicant has incorrectly placed dependency on the Lower Thames Crossing to demonstrate surface access connectivity. Private finance necessary to support development of the Lower Thames Crossing is not yet in place and the Crossing is not scheduled to open until 2027 at the very earliest. f) Applicant has incorrectly placed dependency on the Thanet Parkway railway as an alternative transport route to demonstrate surface access connectivity. Thanet Parkway Railway station is a passenger railway and not scheduled to open until 2021 at the very earliest. A funding shortfall of GBP 8.75m still exists. g) Applicant has overstated access to high quality public transport. The high speed train (HS1) does not start until Ashford (about 60 minutes away by road and train from airport). The passenger train stops running to Ashford at 23:05 and starts again at 04:51am. h) Applicant has poor/average surface access connectivity whereas its competitors have good/excellent surface access connectivity.

5F. Economy – Business Plan (Weaknesses and Threats and Risks) a) Applicant has not done a SWOT analysis and has accounted only for strengths and opportunities in its Forecasts. The impact of weakness and threats to its Forecasts are missing, as are the risks to the Applicant. b) For example: the Applicant does not negatively factor in reliance on a poor road infrastructure; long journey times; terrorism; rising fuel costs; the weak economics of most carriers (Monarch Airways, Alitalia, Air Berlin and VLM Airlines have all collapsed in 2017/2018); security compliance to multiple regulations; increased regulatory oversight; impact of BREXIT; unregulated supply chain participants; ground waiting times (clearance); in-flight fires; handling of and regulatory cost of Dangerous Goods (Yemen Incidents in 2010); inadequate security and safety etc. c) Further, Independent Transport Commission states that to be an efficient dedicated freighter requires high loads for both outbound and return legs. Independent Transport Commission states that demand for freighters can often be mono-directional. d) The weaknesses, threats and risks to the Applicant must be factored into the Forecast not only strengths and opportunities. e) The strengths and opportunities identified by the Applicant are not unique strengths and opportunities to the Applicant.

5G. Economy – Business Plan (Amazon and Ryanair) a) Applicant has over exaggerated/misrepresented Amazon’s and Ryanair’s commitment. Ireland-based ASL Aviation Group is already providing Amazon with airlift. b) Amazon has recently negotiated a 500,000 sq ft warehouse at SEGRO Logistics Park East Midland's Gateway. c) Ryanair has now committed to a new base at London Southend from April 2019 as well as Stansted.

5H. Economy – Business Plan (Loss Growth and Productivity of the UK Economy) a) Additional capacity being provided in the wrong location will not yield the optimal result for the UK’s connectivity requirements. b) Applicant Proposal relies on a redistribution and cannibalisation of the total air—cargo freight market in the UK rather than demand for a new market and generating new business. c) Discovery Park located in Sandwich just south of Ramsgate still has a large Pfizer workforce (this is inaccurate in the DCO application). d) Lawful owner's development would provide suitable space for expansion out of Discovery Park. e) Since the previously failed airport’s closure (after a number of previous failed attempts) there has been a significant influx of ‘Down From London’ commuters and homeworkers and small businesses. This trend is likely to slow or reverse if DCO is granted. f) Since the previously failed airport’s closure the number of restaurant, café culture, independent shops, use of tradesmen and services have increased. This trend is likely to slow or reverse if DCO is granted. g) Since the previously failed airport’s closure Tourism has significantly risen. This trend is likely to slow or reverse to Ramsgate and Thanet if DCO is granted.

5I. Economy – Business Plan (Opportunity Loss and Economic Loss) a) Since the previously failed airport closed the Royal Victorian Pavilion has been redeveloped as the largest Wetherspoons in Britain, which employs 140 people and has a capacity for 1,400 people. It is located on the Ramsgate main sands and has a large terrace with views over the beach and marina. Applicant proposal would put a flight path directly overhead and noise day and night. b) Many hotels, restaurants, bars, cafes and shops have opened since the previously failed airport closed. c) Ramsgate Week, a very popular Sailing Regatta with national and international entrants, would be significantly impacted by the Applicant Proposal of an unprecedented number of flights in the flight path directly overhead and noise day and night. d) Applicant Proposal directly prevents the lawful owner’s development of some 25% of our Local Plan housing requirements as well as GPs, schools, business space and recreational facilities on the site. e) Houses bring people and revenue streams – council taxes, shopping (food and retail), eating out, use of cabs and railways, use of tradespeople and visiting arts and leisure complexes etc. People having moved to or back to the area may move their businesses as well for example Rare Microsoft, SAGA etc.

  1. Air Quality: a) Applicant does not take into account the Committee on the Medical Effects of Air Pollutants recent report (2018). b) Increase in emissions (nitrogen oxides and particulate matter), particularly from aviation and surface transport emissions (from road vehicle and HGVs used to transport air-cargo, workers, passengers and fuel), which will affect Ramsgate, Thanet and Kent have not been addressed by Applicant. c) Applicant Proposal will impact children’s attainment levels (air pollution, sleep deprivation, noise during daytime). d) Applicant Proposal will impact the Indoor Air Quality as well as Outdoor Air Quality. e) There is a proven correlation between inadequate ventilation and poor Indoor Air Quality in schools and poor pupil performance. This has not been addressed at all by the Applicant. f) Worse case scenarios for Ramsgate, Thanet and Kent have not been factored in to Applicant Proposal.

  2. Biodiversity, Soil, Water, Carbon (Climatic Factors) and Climate Change: a) Applicant Proposal and its reliance on a poor road infrastructure for air-cargo, workers, passengers and fuel has not been subject to a Strategic Environmental Assessment. b) Worst realistic case scenarios for Ramsgate, Thanet, Kent, and UK have not been factored in to Applicant Proposal. c) Applicant’s Proposal is contrary to Objective 2 of the Department for Environment: Food and Rural Affairs single developmental plan updated 23 May 2018. In particular objectives: 2.1, 2.2, 2.3, 2.4, 2.5, 2.6, 2.7, 2.8, 2.9, 2.10. d) In 2017, European Commission sent final warnings to Germany, France, Spain, Italy and the United Kingdom for failing to address repeated breaches of air pollution limits for nitrogen dioxide (NO2). NO2 pollution is a serious health risk. Most emissions result from road traffic. e) Applicant Proposal relies heavily on poor road infrastructure for air-cargo, workers, passengers and fuel. f) Worst realistic case scenarios have not been factored in re financial and environmental costs of decommissioning and/or environmental and/or human disaster and/or vehicle disaster and/or cost of weather on business (increase congestion roads, increase in accidents etc).

  3. Resources and Waste (Aircraft Recycling): a) Worst realistic case scenarios have not been factored in to Applicant Proposal particularly in light of the age of aircraft and proximity to groundwater.

  4. Historic Environment (Cultural Heritage): a) Applicant Proposal omits loss or harm to the significance of designated and non-designated heritage assets and their settings, from physical works or indirectly, e.g. through surface transport or over-head flights. b) These include but are not limited to:

    • Ramsgate has the only Royal Harbour in the UK (1821);
    • Ramsgate has its own Meridian Mean Time is 5 minutes 41 seconds ahead of Greenwich Mean Time;
    • Ramsgate Maritime Museum is in the Clock House on the quayside in Royal Harbour, where the Ramsgate Meridian is situated;
    • Four Gold Anchor Award complex marina is situated in the Royal Harbour;
    • Shrine of St Augustine;
    • Ramsgate Montefiore Synagogue & Mausoleum are designated by Jewish Heritage UK as one of the Top Ten Synagogues of Britain;
    • Royal Temple Yacht Club (1857) and the title Royal was confirmed in 1897;
    • Sailors’ Church and Harbour Mission (1878);
    • Royal Victorian Pavilion;
    • Around 900 listed buildings of which five are Grade I and eleven are Grade II and 400 are residential;
    • Ramsgate is second only to London for its Georgian and Victorian buildings and only to Bath for its Regency architecture;
    • Home to the Grange the first so-called 'modern' house, built by architect Augustus Pugin, who designed the interiors of the House of Parliament;
    • Ramsgate Tunnels (the UK’s largest network of Civilian Wartime tunnels);
    • Ramsgate’s Royal Esplanade is a conservation zone and the buildings, including the croquet clubhouse, are Grade II listed;
    • Wellington Crescent Lift is Edwardian and over 100 years old and currently a working cliff lift in Ramsgate;
    • Awarded the first Heritage Action Zone in 2017 by Historic England; l - Ramsgate’s history can be traced back to 449 AD and includes landings by Anglo-Saxons, Romans and Saints;
    • Ramsgate has a rich history of Literary, Architecture and Art heroes. c) St Augustine (the first Archbishop of Canterbury) landed nearby to bring Christianity to England. St Laurence-In-Thanet Church (St Laurence-In-Thanet Church) churchyard extends to three and a half acres and contains over 1400 graves dating back as far as 1656. Ramsgate was an important garrison town in the Napoleonic Wars and in 1821 around 40,000 men were landed here. Ramsgate rallied behind the war effort when it became a main point of departure for the “Little Ships” that crossed to Dunkirk to rescue Allied troops. d) Samuel Taylor Coleridge, Arthur Ransome, Wilkie Collins, Vincent Van Gogh, Sir Francis Cowley Burnand, James Tissot, Stanislawa de Karlowska, Anthony Buckeridge, Elizabeth Fry, Hans Christian Anderson, Daniel Defoe and Jane Austen, whose brother lived in the town. Charles Dickens also performed on stage in the Town. Karl Marx and his daughter lived here. Charles Darwin stayed here, and the World's Greatest Showmen, Buffalo Bill and PT Barnum, both brought their circus shows to town. The latter also brought General Tom Thumb. James Tissott painted 15 paintings of Ramsgate. Joseph Mallord Turner painted Ramsgate’s Royal Harbour. Vincent Van Gough inked a View of Royal Road Ramsgate whilst working as an assistant schoolmaster here in Ramsgate. Augustus Pugin is regarded as being one of Britain’s most influential architects and designers designed many of the buildings around Ramsgate. e) William Powell Frith’s ‘Ramsgate Sands’ proved a great success with the public. Its reception at the Royal Academy in 1854 was so enthusiastic that a guard-rail was installed to protect it from the crowds keen to examine the details at close hand. Queen Victoria expressed an interest in buying it. Queen Victoria had visited Ramsgate several times with her mother between 1825 and 1836 and had stayed in Albion House (now a successful boutique hotel since the airport has closed), visible in Frith’s composition as the highest building overlooking the beach. Many of Ramsgate seafront remains the same and is visible in Frith’s painting.

  5. Landscape and Tranquility: a) Ramsgate’s historic landscapes would be directly affected by the start of over-flight (day and night) and more indirectly by increased road traffic. b) Noise from aircraft and air pollution would be intrusive and have a detrimental impact on the appreciation, understanding and enjoyment on the extensive designated and undesignated historic and heritage sites. c) Historic landscapes – The Royal Harbour, Ramsgate Conservation areas and all areas mentioned above – are a key part of the historic character and heritage of Ramsgate and the tranquility of the historic areas (the Royal Harbour and Conservation Areas) are valued by residents and visitors. d) There will be a detrimental visual impact on the views from and towards the historic Royal Harbor, which since the closure of the previously failed airport has a steadily growing café culture and independent shops around the Royal Harbour and inside the refurbished Military Road Arches. e) Applicant’s Proposal not only threatens the character of these historical places but the literary, artistic and architectural settings of our heritage which will diminish enjoyment and understanding as well as slow or reverse visitor numbers and tourism spend in the coastal economy in Ramsgate and Thanet. f) Preserving the tranquility of all these areas including the Ramsgate main sands is not only important for the people that live in these coastal communities but it is also important for the tourism economy and is part of our national heritage and integral to our history.

  6. Environmental Statement: a) Does not following European and UK procedure regarding airfield noise management. b) Is inadequate for the reasons outlined throughout. c) Cannot find Environmental Impact Assessment.

  7. Permanent Airspace Change - CAA a) Elements of the DCO Consultation feedback cannot be used to support the ACP consultation submission. b) It has not been made clear to the public that we are also contributing to the ACP and the process has not been explained. c) Applicant in Document Number TR020002/SC2018/01 (An Introduction to the Consultation 2018) clearly states that “Having taken all such factors into account, the subsequent proposals for flightpaths and airspace will be subject to a separate round of consultation once the DCO application has been made”.
    d) This has not happened. e) As of 13 September 2018 the CAA website does not show Applicant’s formal airspace change proposal as received by the CAA.

  8. Inadequate Consultation: a) Lacked transparency about aircraft moves, numbers of flights and altitude data and aircraft types. b) Information not in accessible form, which a layperson can easily understand. c) The applicant has withheld/ misrepresented/ changed information. d) The applicant has confirmed in writing that the application documents are different from the 2018 consultation documents. e) Despite confirming to Thanet District Council in the DCO Consultation documentation HTML and PDF versions would be provided they were not provided to the public. f) This is important as Government Digital Service states that HTML is preferable as it is more accessible, searchable and user friendly. This is of particular importance in a socially deprived area with a digital divide and poor academics across the district. g) Lacked overall reach and engagement. h) Consultation times prevented attendance from commuters or workers. i) Flight path information has been buried. The Applicant put hurdles in the way to access information for example: to find the flight paths: Hurdle 1) flight paths are contained in the document entitled “Figures”. Hurdle 2) to purchase this document it costs £500. Hurdle 3) I need to know that flight paths will be in a Figure and in a Figure about Aircraft Noise. j) Non-technical summary does not include flight paths. It is a misleading title as it implies it has all information in laypersons terms. It does not.