Representation by Commuters Against The Cargo Hub Facebook Group
- Date submitted
- 8 October 2018
- Submitted by
- Members of the public/businesses
I write representing the Facebook group Commuters Against The Cargo Hub.
The 2018 Airport National Policy Statement states that the DCO applicant should demonstrate: ““that its scheme is cost-efficient and sustainable, and seeks to minimise costs to airlines, passengers and freight owners over its lifetime.” (1)
The 2018 National Planning Policy Framework (Promoting Sustainable Transport ) also states: “Transport issues should be considered from the earliest stages of plan-making and development proposals, so that:…. d) the environmental impacts of traffic and transport infrastructure can be identified, assessed and taken into account;….” (2)
We believe that RiverOak Strategic Partners’ DCO for Manston Airport has demonstrated none of the above. We also believe the airport proposal is not the kind of development that satisfies the needs of the present without adversely affecting the future.
The DCO should be declined for the following reasons.
1/ HEATHROW’S THIRD RUNWAY HAS ADDRESSED THE NEED FOR EXTRA CARGO CAPACITY IN THE SOUTH EAST.
• Manston never accounted for as much as 0.5% of the UK’s passenger or air traffic movements. Manston represented about 1% to 1.5% of the UK’s freight operation. (3) Further expansion would occur at East Midlands, Stansted and Gatwick ahead of Manston.
• Parsons Brinkoff report (2012) said of Manston Airport: “Whilst only 50 mins from the M25 at Junction 2 it is not strategically positioned for freight to be dispatched anywhere other than the far South East of England.” (4)
2/ RSP’s BUSINESS CARGO-FIRST MODEL IS BASED ON A DEMAND WHICH DOESN’T EXIST The 2017 Aviation Forecasts by Dept For Transport (Moving Britain Ahead) predicts negligible growth in dedicated cargo flights for the next 24 years. (5)
• Dedicated freight flights are the most expensive and environmentally unfriendly way to fly cargo.(6) Global preference is for more cost-effective bellyhold cargo.
3/ THE AIRPORT PROPOSAL IS NOT ENVIRONMENTALLY SUSTAINABLE • Dedicated freight companies prefer to convert old passenger planes which are noisier and less fuel efficient. (7) This will negatively impact on a) locals living under the flight path and b) the environment due to higher emission levels. • Manston's physical position is at the edge of the UK markets. The airport’s added delivery mileage will put extra strain on roads and be detrimental to the environment
4/ NIGHT FLIGHTS APPLIED FOR BY RSP ARE A THREAT TO THE LOCAL COMMUNITY, ENVIRONMENT AND ECONOMY, NOT A BENEFIT • Night flights will disturb sleep which will lead to health problems. • No meaningful investigation has gone into the negative impacts on the local residents or economies under the night time flightpaths. (8) • Commuters, who bring money into the area, will move or be deterred from moving into the area . • Tourists will be deterred from visiting and staying in the areas under the flightpath. • Manston Airport should abide by guidelines of the World Health Organisation which recommended no night flights between the hours of 11.30 and 6am. (9)
5/ THE LOCATION OF MANSTON AIRPORT IS NOT GEOGRAPHICALLY SUITABLE OR SUSTAINABLE
• The National Planning Policy Framework 2018 states. “Significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes.” (10)
• Road infrastructure is inadequate. Thanet District Council Transport Strategy report (2015-2031) states that “local road structure lacks resilience to cope with future growth. “(12)
• Brexit may increase the need Operation Stack (13) Road traffic from Manston Airport will prejudice Operation Stack which will see traffic diverted from the M20 over to the M2, A2 and A299.
• Manston Airport has no freight handling rail facility. The nearest is Ebbsfleet International, 54 miles away by road. (14)
CONCLUSION RSP’s proposal is not a viable or sustainable business plan. It is an inefficient use of land and would be more sustainably used for a new settlement, employment floorspace and a parkway station. That would address the needs of the south east better than low density development for air freight use. As Thanet’s largest brownfield site (15) it would also relieve pressure on local Greenbelt development.
Note: (Figures in brackets denote the info sources. For brevity these have not been included but I am willing to supply .)