Representation by R McIntyre
- Date submitted
- 6 October 2018
- Submitted by
- Members of the public/businesses
Key areas of concern:
June 2018’s Airports NPS identifies no need for a new airport for dedicated freight in the South East. RSP’s proposal is not in line with national aviation policy.
RPS’s proposal rests solely on [Redacted] work. [Redacted]is not expert in this field. She ignores: • the DfT’s assessment that demand for dedicated freight ATMs will remain at the present level until 2050 • considerable spare capacity for dedicated freight ATMs at better located airports like East Midlands and Stansted • freight expansion plans at Heathrow, East Midlands, Stansted and others.
[Redacted] work lacks rigour and credibility (see critiques by established aviation experts York Aviation and Altitude). York Aviation, Altitude, Falcon Consultants and AviaSolutions all conclude that a dedicated freight airport at Manston will attract no more ATMs than it did previously - .1,081 at its 15 year operational peak. This does not meet NSIP criteria.
RSP’s principals have never developed and/or run a successful airport. [Redacted] oversaw years of financial loss at Manston (when the number of UK dedicated freight ATMs was twice today’s level), despite the airport being capable of handling 200,000 to 250,000 tonnes of freight. Dr Dixon advised Manston’s owner on the acquisition of other airports to develop as dedicated freight airports. Every airport acquisition/joint venture failed.
RSP has repeatedly failed to produce evidence of funding. This makes RSP’s application a gamble with the potential to be a significant blight and drag on the local economy for years to come.
RSP’s noise assessment requires interrogation. RSP suggests no ATM cap and quotes a capacity of 83,000 freight ATMs (plus any additional passenger and GA ATMs). The potential “worst case” ATM total is much worse than the “worst case” used in RSP’s noise assessment.
RSP sets no cap on night ATMs. RSP will welcome QC4 craft at night. This would inflict on tens of thousands of local residents a night flight regime that the Government would deem unacceptable at Heathrow. The previous S.106 agreement with TDC is deeply inadequate. It was written 20 years ago by a Council naïve about the impact of airport operations. TDC has previously accepted that the old S.106 needed substantial revision and that it does not reflect modern thinking about the effect of noise on people. If a DCO is granted, residents need to be protected by a complete ban on night flights – scheduled and chartered.
RSP has not considered an alternative way of delivering additional (unneeded) dedicated freight capacity by acquiring a better placed airfield. RSP is focussed only on the Manston site.
RSP’s proposal comes with heavy cost to local residents’ health; quality of life; and educational achievement. It would damage irreparably the tourism industry on which two seaside towns depend. It would force the development of thousands of houses on green field land, against Government preference for brownfield development.
RSP’s proposal would deny the local area the benefits of the owners’ plans for their site – provision for jobs in advanced manufacturing; houses in a well-planned site; supporting services like schools and GP services; substantial amount of new open space; and a nationally important leisure attraction.
Whether assessed on its own, or whether assessed against the owners’ plans, there is not a compelling case in the public interest in favour of RSP’s proposal.