Representation by CPRE Kent (CPRE Kent)
- Date submitted
- 8 October 2018
- Submitted by
- Members of the public/businesses
BELOW WE SUMMARISE THE PRINCIPAL AREAS OF CONCERN ON WHICH WE WILL WISH TO BASE SUBMISSIONS TO THE MAIN EXAMINATION. WE WISH TO RESERVE THE RIGHT TO RESPOND TO ANY ADDITIONAL ISSUES WHICH THE INSPECTOR HIGHLIGHTS, OR TO ADDITIONAL EVIDENCE PROVIDED IN SUPPORT OF THE APPLICATION.
POLLUTION: We question whether the impacts to human and environmental health from air, fuel, water, noise and light pollution can be adequately controlled as RSP claim, particularly with regard to noise and air pollution and the risk of uncontrolled spillages draining into internationally-designated Pegwell Bay.
CLIMATE CHANGE: The Government has legally binding targets to reduce greenhouse gas emissions and has committed to reduce all aviation sector emissions. We question whether the re-establishment of aviation operations at this site can remain compatible with policy on climate change, or indeed with the Airports NPS which offers support for increasing use of existing operational airports but not new airports.
ENVIRONMENTAL IMPACTS: We have significant concerns over the potential loss of biodiversity and habitats through breaches of the regulations on Conservation of Habitats and Species and Directives on Habitats and Wild Birds, particularly in the light of the recent ‘POW’ judgment on the Habitats Directive.
NEED AND ALTERNATIVES: We question whether the stated need for this facility has been accurately forecast. National forecasts for air transport and freight movements show no evidence for such need. The Masterplans of existing operational airports show available capacity greatly in excess of Government forecasts. If Heathrow were to expand it would provide additional bellyhold capacity, further increasing available capacity.
EMPLOYMENT FORECASTS: We have particular doubts about the employment forecasts projected by the applicants. Employment projections claimed by previous owners of Manston were all greatly overstated, and the current forecasts are not convincing. We recognise Thanet urgently needs to increase its employment offer but we query that the airport operations described by RSP can be the solution it claims to be, particularly in the light of the impacts on residents and tourism.
VIABILITY: We question the viability and funding case of the proposals. Manston’s location at the most north-easterly tip of Kent means that it is poorly located to serve the logistics hubs of the midlands which serve the wider UK, and also means that there are few local suppliers of significant amounts of outward-bound freight.
NIGHT FLIGHTS. We are concerned that cargo operations would require flights that would be unacceptable elsewhere (more night flights, with concomitant increases in road traffic and light pollution, and noisier planes, with impacts both locally and over a very wide area beyond Thanet).
OTHER IMPACTS: We have doubts over the control of risks to safety of people and property, over the risk of harm to heritage assets (Reculver, Richborough, Canterbury Cathedral, Ramsgate), and over the inequality of proposals which would have a disproportionately negative impact on the less mobile and less well-off, in an already very deprived area of Kent.