Representation by Steven Nixon
- Date submitted
- 28 September 2018
- Submitted by
- Members of the public/businesses
Dear sirs, I aim to make a representation as an individual and wish to cover the following points in my argument against the proposed development/reopening of Manston Airport.
1- Primarily the applicant Riveroak has not presented a robust enough business case to validate the requirement for reopening Manston airport as a cargo hub. Multiple independent studies have decreed that River Oaks business case argument is deeply flawed, and does not represent current market realities, with anticipated freight operator tonnage which is critical to the cargo hubs success likely to be considerably lower than Riveroaks own projection to the point where (York aviation study’s) findings found that Riveroaks (Azimuth) study was more a work of assertion than systematic analysis and had in fact misrepresented it’s own data and findings. Under private ownership, Manston has previously failed in the capacity of a commercial cargo hub due to mismanagement and the lack of freight business being attracted to the airport (the freight market has since halved in the UK slumping from 108,000 movements in 2000 to just 52,000 in 2016 and the Department of Transport forecasts until 2050 that the UK figures will stay around this 2016 figure.) There is no evidence that the air freight business will either grow again, or that Indeed Manston is needed as a matter of National importance to serve as an additional cargo hub). The commercial driver for the airport simply does not exist and future business use projections are wholly unrealistic.
2 - Thanet is primarily a seaside tourism based economy. The reinstatement of a cargo hub would destroy the potential for Thanet (and Ramsgate in particular) to continue to thrive through the introduction of oppressive noise pollution and the associated health risks and environmental damage which is well associated with residential areas found in the vicinity of busy cargo airports. River Oak have not suggested any cap on air traffic movements under their business case and the proposed cargo hub could potentially be handling approximately 83,000 of these movements per annum. No cap has also been stated in relation to night flights and speaking from personal exposure to these nocturnal movements when the airport used to operate, the after effects are horrible with huge disruption of sleep for the affected local population. This is further compounded by the fact that the applicant also include the option to accommodate Excessively noisy QC4 aircraft as a part of proposed night time activity - these aircraft are currently banned from flying into London airports due to excessive noise pollution but Riveroak would welcome them at Manston as a means to secure freight operator’s business at the expense of local residents. 3 - Nowhere in the Application does the Applicant prove that it has the funding for the hundreds of millions necessary to fully realise it’s intentions. Prima facie it would seem that the Applicant does not currently own any of the land in question and it would seem to be utilising the means of the DCO process to acquire said land. The Planning Inspectorate itself has already confirmed that the Applicants funding statement is non-compliant and must be rectified very early in the Examination in order to satisfy regulations. To this end, the Examination should not be allowed to proceed unless the Applivant proves that they have access to sufficient funding to substantiate its claim. In addition to this, the directors of Riveroak (the applicant)have been seeking the same compulsory purchase order since early 2014, having twice been rejected by a Labour and once by a UKIP administration at the local Thanet District Council on the basis of becoming a potential indemnity partner due to it’s consistent failure to demonstrate the necessary financial credibility and provode evidence of the necessary funds. Put simply, the aforementioned firectors have no background or track record in the air freight sector, but instead have a history of insolvency and failure. The Applicant must provide sufficient evidence that it can finance the application appropriately by furnishing full details of investors and finance planning. So far it has failed to provide this information and as such, the Applicatikn should be suspended or rejected until it does.