Representation by Dr. R. John Pritchard
- Date submitted
- 8 October 2018
- Submitted by
- Members of the public/businesses
I’ve lived and worked in Thanet since 1989 and have been active in the campaign to save, redevelop and re-open Manston after its closure in 2014, so I’m very familiar with Manston Airport’s importance to our community. As a experienced researcher, lecturer, writer, broadcaster and consultant, with academic degrees and other qualifications in history, economics and law, I’ve taken it upon myself to learn as much as I possibly could about CPO and DCO law and practice to consider the merits of the RiverOak team’s engagement with plans for the acquisition and redevelopment of Manston since 2014. In doing so, I’ve read as widely as possible, examined, spreadsheeted and analysed the handling and outcomes of every DCO Application that is to be found on the Planning Inspectorate website. All of that has only increased my admiration of RiverOak’s DCO Application from its inception to its final submission.
I strongly support RiverOak’s strategic vision. I understand how special purpose vehicles are created to fund business projects. I understand that it is regarded as unreasonable to expect any DCO Project to ringfence money amounting to the whole of the Project’s land acquisition and development costs at the point of applying for development consent. I also understand how scandalously inept and incomprehending our local Council have been in relations with RiverOak over the years. Thanet Council’s “due diligence protocol” is and was unfit for purpose. It was honed and put into place at the point when the senior management team sought to kill off the RiverOak team’s application to become an indemnity partner to pave the way for the compulsory acquisition and redevelopment of Manston Airport in the autumn of 2014.
Traditionally, Thanet District Council elected members have strongly supported the airport, and that importance has since 2009 been encapsulated in the Thanet Vision 2030 document that is still to be found on TDC’s website (in its most recent, weakened form see its opening sentence as at 8x2018: https://umbraco.thanet.gov.uk/about-us/thanet-vision-2030/: “Thanet’s economy has been renewed, driven by a busy airport at Manston with more passengers and freight coming into the area.”). Nearly all of Thanet’s district councillors were elected in 2015 with personal or manifesto commitments to fight for the re-opening of the airport. The Council’s Senior Management Team, however, has persuaded successive Leaders of the Council to undertake U-turns or run that policy (and their own personal reputations) into quicksand.
Even now, two-thirds of elected Members have supported the re-opening of the Airport and the preservation of Saved Elements of the 2006 Local Plan (SP05/EC4) which would ensure that as policy the airport would be reserved for aviation use only, no other uses permitted. However, the latest version of the Draft Local Plan abandoned that protection, all because of a misguided belief on the part of members of the Senior Management Team that the airport is not viable. They’ve done nothing less than “scope out” the Airport from the Draft Local Plan against the wishes of the two-thirds of TDC Councillors who still actively SUPPORT the Manston DCO! Again and again, TDC’s Senior Management Team has shown a remarkably poor grasp of CPO law & practice and of the Planning Act 2008 regime.
Thanet District Council’s Adequacy of Consultation Report that is included in the Applicant’s documentation is not fair, just or reasonable: its strictures should be rejected or accorded no weight. It reflects the bias and low calibre of Thanet District Council’s senior management team when it comes to engagement with developers of major infrastructure projects. It betrays that Council’s lack of engagement with neighbouring Councils about the airport and indeed housing. Since 2014, however, TDC’s SMT has been remarkably supportive of an alternative vision for what they call the “former” Manston Airport site (even after Inspector Nunn’s findings which were very much to point in his judgment rejecting the Stone Hill Park Appeals in July 2017). Manston is protected for aviation use under extant Policy EC4 (as SP05) until a contrary new plan is signed off by the Secretary of State, but that extant Policy is of great importance and should be given the weight it still deserves. TDC’s SMT are not doing that. I believe there is clear evidence that the bias in favour of “Stone Hill Park” has led TDC to wrongly put the Airport on the Brownfield Site Register despite the fact that under the Brownfield Site Regulations 2017, the Airport site does not qualify for inclusion on that list. Owing to a very narrow and defective understanding of the meaning of “evidence”, which puts an unrebuttable presumption of acceptance of any study (however inadequate or poorly funded) commissioned by the SMT against all contrary submissions and especially against the huge amount of research and documentation that RiverOak have undertaken and which is available to Thanet District Council. It is on that shaky basis that TDC’s Head of Planning and his SMT claim that there is no evidence that Manston can be brought back into use and made viable, that the policies backed by two-thirds of elected members should be ignored along with the wishes of 80-95% of our local residents and just about everyone on our chambers of commerce: you couldn’t make it up!
I’ve also closely studied the socio-economic case, statement of needs, environmental statement and other aspects of RiverOak’s application and watched how that has moved, grown ever stronger and more robust over time, from the time RiverOak’s first proposals were put to TDC in March/April 2014 to the roadblocks that they encountered finally gave them no other option but to embrace the PA 2008 regime for development consent of a larger still project.
Much depends on the case made out in the Azimuth Report. The Report offers the best and most through ‘health check’ into the socio-economic privations of Thanet that we’ve ever had: a story of high unemployment, high morbidity, poor health care, an aging population (which reduces need for housing growth out of kilter with population increases), lower educational attainments than elsewhere, declining or closing further & higher educational provisions compared with elsewhere, low aspirations, few career opportunities but rising crime rates. The airport can change all of that. The needs are established in NSIP terms, the employment opportunities are marked and quantified using standard metrics but also applying micro-economic as well as macro-economic analysis. All very robust, conservative in approach but with viability clearly established along with the scale of infrastructure required to deliver the goods, quite literally, that will make the airport and community thrive as never before. Why cargo? Because one ton of cargo provides the airport operator with the same profit as 100 passengers and thus a single cargo flight equates to a large number of passenger flights: does that make an impression on the anti-airport, anti-aviation cliques? No, but the viability of the cargo option is clear: the viability of decent passenger services and connectivity depends upon the cargo hub. I’ve watched the Azimuth study evolve, strengthen, take on new aspects, revisit and cross-check all assumptions and evidence. It is brilliant, peer-reviewed work, naturally attacked by the small bands of anti-aviation, anti-airport and anti-RiverOak protesters. For anyone deflected by thought, not prejudice or briefs, I believe it is clear that Dr. Dixon’s responses, however, have blown away those who took her on.
We’re left with health and environmental issues. There are critics who have made false claims about dirty noisy aircraft coming and going 24/7, spewing out filth and death. When stripped down, most of those critics are opposed to the Aviation NPS, emergent policies on the protection of airports especially throughout the Southeast, and indeed to NSIP Airport developments anywhere. We live on an island, surrounded by water on 70%, strong prevailing winds (hence the windfarms!) blow most pollution out to sea and the noise footprints are small in comparison with other airports. The documentation shown of consultations with the CAA suggests that the noise footprints may ultimately be deemed smaller still. Aircraft are quieter than before and will be even quieter as annual ATMs increase over the next twenty years. Such particulate and gaseous pollution that will act to our detriment is tiny compared to the benefits that accrue from much higher employment, tax revenue (hence better local public services), lower crime, less stress. I asked my GP which was worse: he scoffed at the pollution, said that would have barely perceptible impacts upon health compared to the huge benefits in mental and physical health from markedly greater prosperity and employment. That, indeed, has been the experience elsewhere, and is more likely than not the main factor for the fact that there’s a five year difference in morbidity between life expectancy in Thanet and higher life expectancy near major airports elsewhere in the Southeast of England.
I wholeheartedly support the Airport DCO. It is the first NSIP Airport Project, and it merits success. Indeed, were this DCO project to fail, it is doubtful that any other NSIP Airport Project would succeed under the PA 2008 regime during the next 10 years, a critical time post-Brexit and against the national interest. That might satisfy anti-aviation extremists who seek a return to a seaside oasis connected to the capital by slow-coach roads, paddle steamers, and steam railway engines but it would be contrary to Government policy and the requirements of the 21st Century.