Representation by David Green
- Date submitted
- 1 October 2018
- Submitted by
- Members of the public/businesses
I oppose granting a DCO 24/7 Freight Hub at Manston and ask that the appointed Examining Authority thoroughly interrogate the following areas: 1. Qualifications and experience of the applicant. RSP have no experience of running a freight hub of the scale proposed. The history of the individuals involved in the bid shows inconsistency in twice responding to a search for a CPO partner by Thanet District Council as Riveroak Inc. a USA finance company, for an entirely different business model. It would seem their motivation is to acquire the site rather than create a freight hub. 2. Financial credibility of the applicant. RSP have repeated failed to declare the source of their finances. This was one reason for the collapse of the two CPO bids. PINS have indicated that this needs to be addressed early in the examination. 3. Due diligence on the applicant. Granting a DCO to a company based off shore with no track record, to the detriment of a British company with a good track record in redevelopment would be unprecedented. I would ask PINS if there is any precedent. 4. Fundamental flaws in the proposal and the methodology underpinning the business plan. RSP has provided no detailed long term business plan, just a list of aspirations. Repeated Independent , professional reports question whether RSP’s speculative plans are viable.
Flawed assessment of the UK’s freight market. RSP have provided little evidence of demand from existing logistics companies. RSP have provided little evidence of how they will compete with existing freight hubs at Heathrow, Gatwick, Stansted or East Midlands. Does Manston have a 24 hour operation like EMA? NO because they say they don't need Night Flights. Does Manston have a central UK location with fast motorway access to all parts of the UK? Er No it's stuck in NE Kent with an hour to get to the M25. Does it have frequent flights to other UK airfields to avoid the road network? Well no and it has never been suggested. Can it build an extensive network of Freight forwarding companies? Doubtful In fact most cargo travels in the belly of passenger planes and would prefer their planes not returning empty something that didn't happen at Manston.
Case for “of National Significance”. Claims that any operation of this type located in the extreme south east of the country could be of national significance are unrealistic. Manston has never been more than a minor regional airport, and has now been closed for four years with no appreciable loss, nationally, regionally or locally.
Viable and credible alternatives. RSP have not provided evidence that they have seriously examined other possible locations. Both Mildenhall and Lakenheath are looking for buyers and have far better motorway connections without a town of 40,000 inhabitants at the end of the runway.
Manston’s past failures. Manston has failed as a commercial airport under 3 different owners. Each tried to develop it as a Cargo hub. Between 1999 and 2014 the airport accounted for no more than 2% of U’s air freight. It closed in 2014 having losses of around £100m during its 15 year commercial life. A number of independent studies have concluded that without massive government support any operation will fail. The government’s study of future airport capacity in the south of England dismissed Manston.
Geography. Almost any other location than a remote coastal peninsular would provide better logistics than RSP’s proposal. The location’s distance from any possible freight market means the operation would be particularly environmentally unfriendly.
Lack of proper consideration in the proposal regarding impact on traffic and road network. RSP have shown little concern regarding the overall impact of the heavy goods and vehicles along the Thanet way, the single road access. RSP show no plans for a fuel pipeline servicing the freight hub which means the Avgas will have to be transported down the Thanet way and stored somewhere. Much of this route is just dual carriageway and already heavily used.
Underestimation of impact on local economy. The impact on Ramsgate will be severe as Ramsgate is increasing reliant on its vibrant tourist trade economically. Ramsgate has the largest conservation area of Regency and Victorian houses in the country particularly difficult to insulate and susceptible to vibration.
I have already made a submission stating the deficiencies in RSP’s DCO application, being: • Lack of any experience in running a major freight installation • Lack of sufficient identifiable finance • Failure to establish market need • Choice is a poor geographic location for a NISP • Proximity of major settlement in flight path near end of runway.
However I understand there may be political pressure for the SoS to approve the application. I am concerned that there is not a s106 agreement included in RSP’s application for development consent.
“The NPPF has only brief but references to the section 106 agreement process (with nothing on timescales for their completion): “203. Local planning authorities should consider whether otherwise unacceptable development could be made acceptable through the use of conditions or planning obligations. Planning obligations should only be used where it is not possible to address unacceptable impacts through a planning condition. 204. Planning obligations should only be sought where they meet all of the following tests: • necessary to make the development acceptable in planning terms; • directly related to the development; and • fairly and reasonably related in scale and kind to the development.."
It would seem that you could recommend a 106 or its equivalent meaning that RSP cannot operate without any restrictions at all. Our experience during past operation of Manston has demonstrated that conditions of operation need to be clear and enforceable.
We would like to see: Restricted night time hours, with no flights 09:00pm to 09:00 am with escalating fines for breaches Restricted QC count aircraft, certainly QC2 and lower Well defined flight paths with escalating fines for breaches A ban on any training flights Restrictions on vehicles servicing the site to day time, outside of peak traffic hours. Detailed monitoring of noise, noise peaks and pollutants with escalating fines for breaches.
Included in a 106 or equivalent. Reading through the many pages of RSP documentation it would seem that much of this would be acceptable to them. I cannot emphasise enough though that it needs to be strictly enforced.