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Ramsgate Soc.
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MANSTON AIRPORT 2017 CONSULTATION
Response to consultation by The Ramsgate Society and the Ramsgate Heritage and Design
Forum to RiverOak Strategic Partners proposals to re-open and redevelop the Manston
site as an international airport cargo hub
1 INTRODUCTION
This is the combined response of The Ramsgate Society and the recently formed Ramsgate Heritage
and Design Forum to the RiverOak Strategic Partners (RSP) consultation exercise. Both bodies are
charged with the role of safeguarding and promoting the rich and varied heritage of the town of
Ramsgate a responsibility that The Ramsgate Society has successfully carried out for more than 50
years with a current membership of around 700.
All major planning proposals affecting the town, either within or outside the urban confines, are
scrutinised by the two organisations and commented upon to the planning authority. In this case our
response goes to the Planning Inspectorate and Thanet District Council as well as to RiverOak
Strategic Partners given the adoption of the Development Consent Order procedure by RSP.
Our response takes the following form :
? contextual information relevant to our consideration of theproposals
? an examination of the business case for the re-opening of theairport
? a review of the environmental impacts of the proposed airport
? overall conclusions.
2 CONTEXT
2.1 Ramsgate
Ramsgate is a coastal town within Thanet district which has a total population of 138,000 comprising
Ramsgate (population 42,00), Margate (56,000), Broadstairs (24,000) and the outlying Villages
(16,000).
The main industry in Ramsgate is tourism. It has a 700 berth marina, one of the largest on the South
Coast. The marina lies within the historic and only “Royal” Harbour in the UK , so designated by
George IV.
The town has a very rich historic past represented in large part by many splendid Regency and
Victorian buildings and important Georgian squares. In all there are over 900 listed buildings in the
town of which over 200 are in the vicinity of the Harbour. Historic England cites 445 listings, many
relate to more than one structure.
Ramsgate has four Conservation Areas, namely Ramsgate (encompassing much of the centre of the
town), Ramsgate – Royal Esplanade, Ramsgate – Montefiore, and Pegwell. (See Map Page 2)
2.2 Heritage Action Zone
In March 2017 the national importance of Ramsgate heritage was recognised when Historic England
chose the town as one of only ten ‘Heritage Action Zones’, in a new nationwide scheme. The aim is
for the Heritage Action Zone five year programme to grow Ramsgate into a prosperous maritime
town where outstanding heritage and architecture coupled with new investment and development
strengthens the economy for the benefit of the local community.
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At the launch of the Ramsgate HAZ in March, Andy Brown, the Planning Director for Historic England
in the South East said:
Ramsgate is one of the great English coastal towns with a fascinating maritime history. As well as
Britain’s only Royal Harbour, the town is blessed with a wonderful variety of historic sites including
buildings by the architect Augustus Pugin, who is famous for designing the interiors of the Palace of
Westminster, including his own house and the neighbouring church. But this barely scratches the
surface of what Ramsgate has to offer as a historic town. The Heritage Action Zone partnership
brings together the national skills and local passion which will make use of its amazing heritage
stories and places to reinvigorate Ramsgate, helping to grow the local economy, boosting tourism and
business investment as well as encouraging the local community to reconnect with its heritage with a
renewed sense of pride.”
At that same event Cllr Lin Fairbrass, Deputy Leader of Thanet District Council commented:
“Ramsgate combines outstanding heritage and architecture with a beautiful marine landscape and
engaging history. Being chosen as one of the country’s first ten Heritage Action Zone will not only
raise awareness of our town as a heritage destination to attract visitors and investors but will also
reinforce our sense of identity and pride. The partnership will act as a catalyst for regeneration and we
look forward to Ramsgate being better understood, enjoyed, valued and protected.”
2.3 Natural Environment
Pegwell Bay which adjoins Ramsgate to the south, It is formally designated as a natural
environment and habitat of national and international importance. It lies to the south of the built up
area and forms part of the Sandwich and Pegwell Bay National Nature Reserve. The Nature
Reserve is a Ramsar Site of International Importance. It is rich in flora, fauna and especially bird life,
with many rare species. It is a highly valuable outdoor leisure asset. (See Map page 4 Natural
Environment Designations).
2.4 The Manston Site
The Manston former airport is west of Ramsgate. The site covers 700 acres (283ha). It has a single
runway 9029 feet (2750m) in length orientated approximately east-west. It is 1.6 km from the nearest
point on the coastline and at an elevation of 178 feet (54m). Parts of Cliffsend village adjoin the
southern boundary of the site and are 100 metres from the eastern end of the runway. Ramsgate is
directly on the flight path. Nethercourt, a densely residential area, is the nearest part of Ramsgate to
the site. It is 400metres from the site perimeter and 1300 metres from the eastern end of the runway.
2.5 Previous airport operations
Brief commercial history
From 1989 RAF Manston ceased to be a military airbase and became Kent International Airport. The
site was bought by Wiggins Group. Following multi-million pound loss-making passenger and freight
operations the site was sold to Infratil in 2005. In 2009, Infratil, the then owners of Kent International
Airport (Manston) published a Master Plan for the airport. In 2009 the actual was cargo carried was
30,038 tonnes. The key forecasts for cargo tonnage by year were 2015 138,000 tonnes, 2033
401,200 tonnes.
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They were massively higher than the ‘actuals’ at the time and it soon became evident that they were
totally unrealistic. The airport closed in 2014 with freight at no time comprising more than around
30,000 tonnes per annum.
Again after heavy financial losses the airport was sold to Manston Skyport Ltd in November 2013. The
airport was closed on 15th May 2014. The site was sold to developers who submitted an application
for a mixed residential, business, leisure scheme known as Stone HillPark.in June 2016.
Aviation statistics
The Civil Aviation Authority (CAA) compiles month-by-month and annual statistics on the operation of
airports in the UK (see www.caa.co.uk/data-and-analysis). They offer a revealing backdrop to, and
benchmark for, the present RSP proposals. The final full year of Kent International operation was
2013 and figures are available for that and the preceding decade. The levels of activity in 2013 are
similar to those of previous years. Passenger and freight traffic is distinguished. After an overview of
all commercial activity, we focus on freight movements in the light of the RSP proposal for a airfreight
hub at Manston. There are three key measures of activity: passengers, tonnage of cargo (metric
tonnes), and commercial Air Transport Movements (ATMs) (an ATM is a take-off or a landing).
Summary of Activity
Traffic type ATMs Passengers Freight (tonnes)
Scheduled 1,086 36,474 0
Charter* 554 3,669 29,306
Totals 1,640 40,143 29,306
*excludes air taxis
Table 1: Manston Summary of Activity 2013
Source: CAA Table 2-2 (2013)
The CAA statistics show that passenger flights accounted for all scheduled ATMs plus a small
proportion of charter ATMs. All freight was carried by charter flights. Scheduled passenger services
were withdrawn prior to closure in 2014.
Tonnage of Air Freight
Figures from the CAA show actual air freight tonnage by year in the UK and at Manston.
2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
UK total ‘000 tonnes 2205 2368 2360 2314 2325 2282 2047 2324 2297 2302 2262
Manston ‘000 tonnes 43 26 7 20 28 25 30 28 27 31 29
Table 2: UK airports total air freight tonnage and the Manston contribution by year 2003 – 2013
Source: CAA. Freight 2003-2013 Table 13-2
In 2003, the Department for Transport forecast that freight growth would ‘grow even more rapidly over
the next decade’. In reality, UK air freight has stabilised since then hovering in the region of 2.2 m-
2.4m tonnes. The divergence between forecast and actual air freight volumes widened over ensuing
years. The Department for Transport’s growth projections may have caused many Airport Master
Plans to have seriously overestimated the growth of freight.
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This table reveals that the UK demand for all air freight remained flat from 2003 to 2013, furthermore,
the UK totals for 2015 (2,299,000 tonnes) and 2016 (2,385,000 tonnes) confirm that pattern has been
maintained over at least the last 13 years. The contribution by Manston showed no growth and
hovered between 1.2% and 1.5% of all airfreight. It was a minor player in the freight market
throughout its operation.
Freight import and export
UK Other EU Other
overseas
Set-down Pick-up Set-down Pick-up Set-down Pick-up
Tonnes 4 2 13,156 96 13,973 2,076
% share - - 44% - 48% 7%
Table 3: Manston Freight by type and nationality of operator 2013
Source: CAA, Table 13-1 (2013)
CAA statistics show the split between the quantity by weight of incoming (known as ‘set-down’) and
outgoing (‘pick-up’) cargo. The table above shows there was a highly skewed imbalance in favour of
import over export tonnage.
? 99% of freight was carried by non-UKoperators.
? 92% of freight was set-down
? 7% was pick-up
This imbalance would have severely affected the efficiency and profitability of carriers. This picture
suggests that there was a lack of UK market demand to ‘export’ freight by air from Manston or that
other operational factors were having an impact.
In 2013 the airfreight handled at Manston was 29,306 tonnes. Analysis of CAA statistics shows this
was carried via 511 dedicated freight aircraft ATMs. On average therefore each ATM accounted for
57.4 tonnes of cargo. On the assumption that there are equal numbers of inbound and outbound
ATMs it is possible to derive the average payload of each given the recorded set-down and pick-up
tonnages. On this basis the average ‘set-down’ payload was 106.4 tonnes; and the average pick-up
payload was a mere 8.5 tonnes. In other words set-down aircraft were arriving heavily laden but, in
many cases, departing empty.
2.6 Freight aircraft
Air freight falls into two distinct categories. There is the freight which uses the ‘bellyhold’ capacity of
scheduled passenger flights and there is freight which comes in dedicated freighters. CAA statistics
reveal that 70% of UK air freight tonnage is carried as ‘bellyhold’, the balance of 30% is carried by
dedicated freighters and amounted to approximately 715,000 tonnes in 2016.
The characteristics of the freighter aircraft fleet is significant in the context of the past and possible
future of Manston airport.
The dedicated freight carrier sector of aviation is dominated by variants of the Boeing 747. This has
been the case since the 1970s and seems destined to be so for decades to come given that freighter
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variants are still in production. The type was originally designed to be adaptable to dedicated freight
as well as passenger use. There are three main freight variants as follows:
Variant Period of manufacture Typical Maximum
revenue payload
(tonnes)
Boeing 747-200F 1971-1991 105
Boeing 747-400F 1989-2009 124
Boeing 747-8F 2011-2021 140
Table 4: The main Boeing 747 freight variants
Source: Boeing 747, Wikipedia.
The freight ‘workhorse’ Boeing 747-400F requires a take-off field length ranging from 9,250 feet to
10,950 feet (depending on range, payload and overall weight). This poses a serious problem for the
future of Manston with its runway at 9029 feet in length. While it may be sufficient to land fully laden
aircraft it is not capable of handling this market leading freight aircraft at maximum take-off weight.
This puts Manston at a considerable commercial disadvantage compared to its competitor airports in
the UK. Manston ranks only 11th in terms of the length of runway in the UK, and behind leading
dedicated freighter traffic rivals East Midlands and Stansted. It makes it unattractive to air freight
operators. The relatively short runway explains why, historically, there has been very little pick-up
tonnage over previous years of operation undermining efficiency and contributing to a lack of any
profitability.
3 THE BUSINESS CASE EXAMINED
3.1 Commercial background
The former airport lost £100m in the previous 15 years for various owners and operators. Over that
period it operated as a mainly freight hub. Plans are on the table for it to become a freight hub yet
again, despite a catalogue of failures over the years. There has been extensive work over decades
analysing possible futures for the site and the clear conclusion from past history, independent studies,
industry experts, and numerous commercial failures is that an airport is not commercially viable.
Nevertheless, the RSP proposal demands to be judged on its merits for it may be that the proposition
convincingly defies earlier history and opinion.
3.2 Site and Location
There is very little, if any, of the previous airport infrastructure and facilities remaining or that could be
used in any future airport operation. Apart from the runway itself this is a blank canvas. In the overall
scheme of things the siting of a new airport should not be predicated on the existence of this runway.
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While at first that may seem a major asset the runway, as has been shown is too short to cater for the
take-off of fully laden air freighters.
There is fundamental problem with the location at the eastern-most corner of Kent. A circle
circumscribed at a radius of 50 miles from the site reveals that 320 degrees of that circle covers only
sea. The very location limits the catchment at that range to only 12% of that available to a more
central location. Furthermore, the area is more sparsely populated than the rest of the Region, thus
limiting the potential customer base. Greater London is further afield and accessible via the road
network, however, there are well established cargo airports competing for that business. Road
accessibility to Manston from other regions is poor and competitor airports then come into the frame.
3.3 Features of the RSP proposal
Main features of the RSP proposal for a new Manston Airport are:
? Focus on the dedicated freighter market.
? Develop an air freight hub
? Year 1 of operation 2020 of air freight services generating 5,000 air freight movements
? Year 6: 10,000 annual air freight movements
? Year 20: 341,000 tonnes of cargo
? Year 21: 17,000 annual air freight movements “equating to 350,000 tons of air freight”.
? 10,000 passenger ATMs by 2041
? 64,906 HGV movements per year in Year 20
3.4 Competitive position
A new Manston cargo hub would be entering a market that has flat-lined for years. No growth in the
market means that Manston, starting from scratch, and in order to succeed commercially, would have
to take substantial market share from established operators who will inevitably compete strongly to
keep their business and customer base. The RSP documentation includes a forecast 341,000 tonnes
of cargo in 2040, an 11-fold increase over anything that was achieved up to 2013.
Based on CAA figures, in the UK the cargo carried by dedicated freighters amounted to 30% of the
overall freight market, that is approximately 715,000 tonnes in 2016.
The leading UK airports (based on tonnage) for dedicated freighters are: London (Heathrow,
Stansted, Gatwick together account for) 43%; East Midlands 40%, Manchester 3%, Belfast 3%.
Heathrow handles over 50 per cent of UK cargo, of which only 6% is carried by dedicated freighter.
East Midlands airport is the largest ‘pure freight’ airport in the UK, which means almost all dedicated
freighter aircraft. Over 90 per cent of Stansted cargo is in dedicated freighters. Unlike those of its
main competitors, Manston runway is too short to allow the take-off of fully laden air freighters such as
the Boeing 747-400F. There is no mention by RSP of this critical commercial disadvantage, nor of
any proposal significantly to lengthen the runway, indeed that may not even befeasible.
In terms of dedicated air freight business the leading competitors for Manston would be East Midlands
(300,000 tonnes in 2016) and Stansted (223,000 tonnes in 2016). Both have successful track records,
substantial freighter market share, spare capacity and well developed plans for expansion in order to
respond to market opportunities.
3.5 Air Transport Movements and Payloads
The RSP forecast is for 5,000 ATMs in Year 1(2020), 10,000 in Year 6 (2026) and 17,000 in Year 21
(2041). In Year 21 this is forecast to account for 350,000 tons of cargo. RSP does not refer to the
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average payload per ATM, however, arithmetic tells us this is 20.59 tonnes. This is a suspiciously low
figure when one considers that the typical maximum revenue payload for Boeing 747 freighter
variants is 105 to 140 tonnes. We also know that the average weight of set-down cargo at Manston
was 106.4 tonnes in 2013.
We question why the RSP average payload is so low. In order to do so we examine the relationship
between RSP forecasts of ATMs, air freighter payloads, the proportional split between ‘set-down’ and
‘pick-up’ cargo, and the overall freight tonnage carried. We go on to consider the implications of these
findings.
There are several forecasts, values and realistic assumptions that feed into this appraisal, as follows:
? The total annual UK weight of cargo carried by dedicated air freighters 715,000 tonnes (at
2016 levels source CAA);
? The mean set-down weight of cargo per incoming ATM 106.4 tonnes (assume Manston 2013
level, source CAA);
? RSP forecast freight ATMs at Manston:
o Year 1 2020 5,000 ATMs
o Year 5 2026 10,000 ATMs
o Year 21 2041 17,000 ATMs
? RSP’s own forecast split between set-down and pick-up cargo byweight
o Set-down 80%
o Pick-up 20%
? The overall size of the UK airfreight market (ie bellyhold plus dedicated freightlinermode)
continues to flat-line as from 2003 – 2016.
On this basis we calculate the tonnages of cargo for each of the RSP ATM forecasts in the three
years quoted (see table below).
Share Quantity ATMs
per annum
Payload per
ATM
Freight
Tonnes per
annum
Share of
annual UK
Market
YEAR 1 2020
Set -Down 80% 2500 106.4 255,000
Pick-Up 20% 2500 26.6 66,500
Totals 100% 5,000 - 332,500 46.5%
YEAR 6 2026
Set -Down 80% 5,000 106.4 532,000
Pick-Up 20% 5,000 26.6 133,000
Totals 100% 10,000 - 665,000 93.0%
YEAR 21 2041
Set -Down 80% 8,500 106.4 904,400
Pick-Up 20% 8,500 26.6 226,100
Totals 100% 17,000 - 1,130,500 158.1%
Table 5: The tonnages of cargo for each of the RSP ATM forecasts in the three years quoted
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For reference, there were 511 air freight ATMs at Manston in 2013, accounting for 29,306 tonnes of
freight. The Table reveals that in Year 1 the volume of cargo ATMs will be nearly ten times that
achieved in 2013, or equivalent to all the ATMs for the last decade of operation added together.
On the basis of wholly realistic assumptions and hard CAA statistics then the RSP forecast of ATMs
in Year 1 of operation (2020) would account for 46% of the whole UK dedicated freight market.
This is a ridiculous claim. The Table shows a 93% market share in 2006 and 158.1% in 2041. Thisis
against a background of no overall growth in the market, and where rivals such as East Midlands, and
Stansted have plenty of surplus capacity. There is no unfulfilled demand.
We have used the approach to calculate the number of ATMs needed to account for particular
tonnages of air freight, as shown in the Table below.
Tonnage of
dedicated freight per
annum
Set-down tonnage @
106.4 tonnes per ATM
(80%)
Pick-up tonnage @
26.6 tonnes per ATM
(20%)
Number of dedicated
ATMs per annum
needed
50,000 40,000 10,000 752
100,000 80,000 20,000 1,504
200,000 160,000 40,000 3,008
350,000 280,000 70,000 5,262
Table 6: The number of ATMs needed to transport specified tonnages of dedicated air freight
This demonstrates that the RSP proposal grossly exaggerates the number of ATMs needed to
transport any given tonnage. This has far greater significance and ramifications for the validity of the
RSP proposal. RSP claims it needs 17,000 ATMs to transport 350,000 tonnes of freight, whereas, we
here demonstrate convincingly that only around 5,262 ATMs would be needed. The previous table
demonstrates that 10,000 ATMs would equate to 93% of the whole UK market for dedicated freight,
which RSP claims would be achieved in Year 6.
We conclude that either RSP is claiming that in Year 1 it will have 46% of the whole UK dedicated air
freight market, or that it will never have the requisite ATMs to meet the 10,000 ATMs criterion to
qualify for an airport as a Nationally Significant Infrastructure Project (NSIP) in which case a
Development Consent Order (DCO) is irrelevant and cannot be pursued.
The RSP proposal does not, and cannot, meet the criteria to qualify as an NSIP and the DCO
process should be terminated.
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3.6 Conclusions on the Business Plan
We conclude as follows:
? The airfreight market has remained stable over the last 15 years and shows no indications of
growth and within it the dedicated freight market accounts for around 30% by tonnage;
? RSP has produced no evidence of a lack of dedicated airfreight capacity;
? There are well established potential competitors airports that have plenty of capacity to
expand if warranted by the market
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? there are no compelling reasons why a freight forwarder or carrier would favour Manston over
other airports;
? Manston is in an unfavourable geographic location,
? the runway is too short for fully laden air freighter take-off,
? By implication RSP makes wholly implausible and exaggerated claims of marketshare when
in operation
? RSP has presented forecasts deliberately designed to mislead in an attempt to meet the
NSIP criteria.
? The RSP proposal does not, and cannot, meet the criteria to qualify as an NSIP and theDCO
process should be terminated.
4 ENVIRONMENTAL IMPACT ASSESSMENT
4.1 Introduction
A Preliminary Environmental Assessment Report (PEIR) forms part of RSP’s evidence. This will need
to be developed into a fuller and detailed Environmental Impact Assessment (EIA) when and if an
application is submitted to the Planning Inspectorate for a Development Consent Order. The EIA will
need to cover the likely significant environmental effects of the project as well as a review of
alternative options for fulfilling the project objectives.
Following the structure of the Consultation Overview Report our comments are as follows.
4.2 Alternative Options
RSP claim to have considered alternative locations for increasing air freight capacity in the South East
including existing airports and concluded that neither the required infrastructure nor capability exists
to match that of Manston. As we have commented earlier there are established and well equipped air
cargo operations at each of the London airports and indeed plenty of spare capacity at Stanstead for
expansion should the air cargo business increase. Moreover, East Midlands airport which lies just
outside the South East, having far improved road and rail links to the rest of the country, is the natural
location for achieving a major increase in cargo handling business.
4.3 Air quality
RSP’s preliminary assessment acknowledges that their plans for Manston will involve a significant
increase in air pollution from both increased road traffic and more importantly landing and taking off
aircraft. Without any hard evidence the PEIR predicts that even at the maximum level of airport
operation the levels of pollutant will not exceed national air quality objectives for the protection of
human health.
Our assessment is not so sanguine.
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While it is the case that the proportion of goods air freighted is small compared to other modes, of
transport the environmental impacts are disproportionate. Air freight has far higher negative
environmental impacts, including greenhouse gas emissions, than other modes of transport. Air
freight produces immensely more CO2 equivalent emissions per tonne kilometre than transport by rail
or by sea.
DEFRA has calculated the impact of dedicated freighters emissions per tonne kilometre as up to
ten times those of road transport, and up to 43 times those of rail transport. Guidelines from DEFRA/
DECC include the conversion factors used to estimate carbon emissions from various forms of
transport, including dedicated air freight. The figures include not only CO2 but also Ch4 (methane)
and NOx. Adding all these together gives the total grand total GHG in kg CO2-equivalents per tonne
kilometre. The application of this is shown in the Table below:
Trip Length
Mode 1000km 5000km
Air freighter 4,532 kg 7,924 kg
Diesel train 10 kg -
Ship 30 kg 150 kg
Table 7: Weight of Carbon emissions from transport of 2 tonnes of freight by mode of transport
(Calculations based on 2011 Guidelines to Defra / DECC’s GHG Conversion
Factors for Company Reporting)
Emissions from aircraft, air-side support vehicles and airport related traffic all contribute to a build up
of potentially harmful gases such as oxides of nitrogen, carbon monoxide, VOCs (volatile organic
compounds) and ozone. They also produce small particulates. The most important pollutants are
usually nitrogen dioxide (NO2) and small particulates (PM10, PM2.5). These often breach standards
set by the UK government and the EU to protect human health.
Air pollution continues to be a significant threat to human health and the environment in the UK,
especially in airport adjacent regions, from both aircraft and local surface transport. The largest study
of health impacts at airports was carried out for the Dutch government and published in 1999. It is
called “Public health impact of large airports”. It looked at the range of health impacts, including noise
and air pollution. More specifically on airports and health it concludes that: “…there is sufficient
evidence that episodes of air pollution with levels observed within an airport operations system cause
short-term effects like an increased mortality rate and an increased frequency of hospital admissions
due to acute respiratory and cardiovascular morbidity. A decrease in pulmonary function is also one of
the acute effects for which the committee considers there to be sufficient evidence. “
The study summarises the health effects and assesses the strength of evidence and severity of
impact on aspects of health. To a greater or lesser extent it has an evidence-based impact on:
? Premature death
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? Aggravation of respiratory and cardiovascular disorders (resulting in hospital admissions):
? Decreased lung function
? Increase in chronic respiratory conditions
? Aggravation of asthma
?
Given the proximity of Manston to significant residential settlements, in particular Ramsgate, all of
these adverse impacts potentially arise from RSP’s proposals.
Air pollution is also a significant factor in relation to the well-being of sensitive ecological sites. The
proximity of Pegwell Bay and Sandwiich Nature reserve, a Ramsar Site of International Importance, is
an important factor here. It is our submission that the scale of RSP’s forecast air freight movements
is very likely to be adversely affecting this major ecological site.
4.4 Biodiversity and Wildlife
RSP acknowledges that Manston is within 10 kilometres of 8 internationally designated nature
conservation sites and 6 nationally designated conservation sites. The closest is Sandwich Bay to
Hackling Marshes SSSI and Pegwell Bay and Sandwich Bay nature reserve. The PEIR records that
work is needed to assess the airport use on legally protected species on or adjacent to the nature
reserves. We believe this is vitally important given the proximity of Pegwell Bay and Sandwich Bay
sites to the airport.
Airports can impact biodiversity in a number of ways, including loss or degradation of habitats and
through impacts on wildlife of air and noise pollution. Bird populations can both harm and be harmed
by aircraft, and large flocking birds, particularly geese, are seen as a threat by airports regulator the
CAA. The CAA advises that steps should be considered to minimise bird populations as far as ten
miles away from airports. Reducing the attractiveness of surrounding areas to large birds – for
example by removing nesting habitat, can in turn impinge on other wildlife populations.
We expect Natural England and Kent Wildlife Trust to comment in depth on these matters.and in
particular on the threat to rare and endangered species currently present on the nearby internationally
recognised Pegwell Bay and Sandwich Nature reserve
4.5 Freshwater Environment
The PEIR recognises the need for the proposal to be assessed in relation to its impact on the Chalk
Aquifer which underlays the site and provides a high level of water storage which contributes
significantly to the public water supply to Ramsgate and Thanet generally. We believe this is
important and particularly have concerns about the danger of full spills from the proposed fuel farm
given there is no fuel pipeline supply to the site.
4.6 Historic Environment
The PEIR draws a very tight circumference around the site in assessing the airport’s impact on the
historic environment. Within a 1 kilometre band RSP record only 2 scheduled monuments and 24
listed buildings and no conservation areas. The significance of archaeological features both within
and adjacent to the site are recognised however and a commitment to carry out a full-scale desk
review is given
What is not mentioned is the effect that the proposal has on nearby Ramsgate, a densely built-up
area, with a population of 42,000. Lying directly on the prospective flight path and wholly contained
within a zone between 1.2km and 4.15km distant from the runway. (see Map p15 ), Ramsgate has a
rich and varied townscape with its many regency and Georgian listed buildings and extensive 4
conservation areas.
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The main concerns are :
Safety
While aviation prides itself on its safety record, the risk of an accident must not be overlooked. It is
important to undertake accurate risk assessment and consideration of opportunity costs in the context
of any airport development plans. Cargo flights, undertaken by older aircraft and operated from
countries which pay less attention to safety, are regrettably more liable to accidents. There are more
accidents and crashes to air cargo aircraft than to passenger aircraft and of these around 80 per cent
occur during take-off and landing. This is particularly relevant when considering the RSP proposal in
relation to its effect on the built and residential environment of Ramsgate.
Damage to buildings
There have been a considerable number of incidents where properties have been damaged
by vortices caused by low flying aircraft. The reason is well understood. Aircraft cause turbulence in
the air which can continue for some time and descend to ground level.. On take-off and landing
aircraft travel much slower than at altitude and the atmosphere is much thicker, so the vortices that
are generated are less powerful and dissipate quicker. The most critical period is when a large aircraft
is coming into land, when it is common for the aircraft wake vortex to reach ground level, potentially
causing tiles or slates to be sucked off roofs of buildings close to the flight path.
In Ramsgate the flightpath approach is from the east over the Channel. Any vortex will be most
damaging as it makes landfall over the centre of the town, including the conservation area and most
of its listed buildings. These buildings, mainly Regency and Georgian, are vulnerable as the roofs are
predominately period slate or tile and non-compliant with the standard recommended to resist aircraft
vortices. Given the large number of listed properties and the extent of Conservation Areas, places
much of the built heritage under significant threat.
(See Map page 15 Zone of potential vortex damage)
(The PEIR sets out steps to assess the impact of the airport use on land quality and the environment.
We have no comments to make at this preliminary stage)
4.8 Landscape and Visual
RSP acknowledge that the site lies within an area of significant landscape character being within the
North Kent Palin and Thanet Landscape Character Area. It also lies within 5 kilometres of 5 other
character areas including the adjacent Pegwell Bay Landscape Character Area. It reports that a full
assessment of the proposed airport development will be included within the EIA when submitted.
At this stage our main concern is the disturbance to peace and tranquillity within the Pegwell Bay
Landscape Character Area caused by aircraft movements. There is substantial public access to the
area in the form of footpaths and cycle routes, providing a much cherished amenity by both local
residents and visitors. The same concern arises in relation to the public enjoyment of the beaches of
Ramsgate and surrounding seaside settlements which contribute significantly to the tourist business
of South East Kent.
(See Map page 16 The Manston flight path in relation to Ramsgate and the Conservation Areas).
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4.9 Noise and Vibration
The PEIR sets out measures to assess the impact of noise and vibrations from the development and
operational phases of the planned development. While disturbance within the development phase will
impact on properties in the immediate vicinity of the site, the operational phase is of much greater
significance for both adjacent and neighbouring areas including Ramsgate. Surprisingly the work to
assess this impact on residential areas is not intended to extend as far as the town. We wonder why?
Aircraft noise is a significant political issue and remains the most important environmental concern for
our members and residents and businesses in the town. Noise can impact children’s learning,
interrupt conversations, disturb sleep, and cause serious long term health problems. The European
Environment Agency considers environmental noise, of which aircraft noise is a significant part, to be
more damaging to health than passive smoking.
Because aviation is exempt from noise nuisance claims, there is very little legal protection for people
affected by aircraft noise even if an increase in airport activity or a change in flight paths causes a
significant noise increase. Yet the UK Government has always avoided setting maximum noise
exposure thresholds for airports, instead having adopted policy simply to “limit and where possible
reduce” aviation noise impacts.
Noise is the major problem for most communities living around airports and under flight paths,
especially at night. The Government claims that “the onset of significant community annoyance” starts
when the noise from aircraft averages out at 57 decibels, known as 57dB(A) LAeq.
The World Health Organisation (WHO) puts the figure between 50 and 55 decibels
(and about 10 decibels lower at night). On this basis, it recommends maximum noise
exposure levels of 55 dBA Leq to avoid the risk of people being significantly annoyed. There is little
prospect of significantly quieter aircraft being introduced over the next 20 years. The International
Civil Aviation Organisation (ICAO) has set a tougher standard for new aircraft noise that came into
force in January 2006. However, the standard is already met by 98% of aircraft currently inproduction.
ICAO also agreed that there should be no global phase-out of existing “Chapter 3” aircraft
(such as early versions of the Boeing 747 very widely used as dedicated freight aircraft) to speed up
the transition to quieter aircraft.
The only way to avoid an increase in noise problems would be to reduce the number of aircraft
movements, or to see a step-change in the noise of individual aircraft. Neither is on the cards. The
Government’s approach has been tacitly to accept that the noise climate will get worse and try to
lessen the blow for those worst affected through the compensation and mitigation measures that
airports are expected to provide. But these schemes are far from generous and are not on offer to the
vast majority of people affected by aircraft noise.
Disturbance from aircraft noise can be greater in areas with low background noise than in urban
areas. For example, a 2014 trial of new flight paths at Gatwick led to the creation of five new anti –
noise groups and a huge wave of complaints from surrounding villages.
Night noise from aircraft increases the risk of heart attacks, strokes and dementia. The World Health
Organisation has recommended that night noise should not exceed 45 dB Leq. In 2009 WHO
Europe updated this guidance to recommend a maximum level of just 40 dB Leq at night. Noise levels
around major airports far exceed these recommended levels and, in the UK, night noise is not even
recorded down to 40 dB Leq.
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Aircraft types have become quieter over time, but average noise levels mask the impact of the
increase in the number of individual noise events. The number of noise events is an important factor
in disturbance, and so a reduction in noise contours may not be matched by any reduction in
annoyance if combined with an increase in aircraft numbers.
Government policy is that aircraft should fly in a way that minimises the number of people significantly
affected by aircraft noise. The trend towards more concentrated flight paths, being pursued as part of
a Europe-wide reform of air traffic management, appears to support this, since fewer people are
overflown than when flight paths are dispersed. Given the importance of the number of noise events
as a trigger for annoyance, however, an increase in concentration may increase significant
annoyance for those still under the flight path.
Noise not only causes irritation to people exposed to it, but increasingly it is recognized that it can
also have adverse impacts on health. That is particularly the case when the planes are heard very
frequently, and at night when they can disturb sleep. Aircraft noise is especially annoying and
stressful, as individuals feel they have little control over the situation, and are powerless to get any
improvements. That is invariably the case for those living under flight paths. Aircraft noise is excluded
from the usual safeguards and remedies there would be for other, terrestrial, sources of noise.
Aircraft noise has an impact on health, well being and brings economic consequences.
The annoyance caused by noise can lead to stress which in turn can lead to cardiovascular problems
as well as psychological problems. It can even sometimes affect ability to function effectively at work,
especially if sleep has been disturbed. Research has shown that even if people are unaware of a
noise at night, while asleep, their bodies still sense it and react. This may be the mechanism by which
noise has cardiovascular effects. The impacts of noise are worse if people feel they have no control
over the situation, and are unable to influence it. The monetary costs of transport noise are enormous,
and though hard to accurately quantify, arise from the cost of sleep disturbance, stress, and the cost
of medical treatment for cardiovascular conditions, includingstrokes.
Noise generation is a particular problem in relation to dedicated freight aircraft. These are
predominantly converted early variants of the Boeing 747 that are noisier and less fuel efficient and
more polluting than later generation aircraft types. However, the sheer number of this type on the
market, its operational longevity, its load capacity and low cost of acquisition means that it is likely to
dominate cargo fleets for many more years to come.
The Environmental Research and Consultancy Department (ERCD) of the Civil Aviation Authority
(CAA) has developed a computer model, ANCON, that calculates the emission and propagation of
noise from departing and arriving air traffic. It uses data relating to specific aircraft types and variants
(eg Boeing 747-200). Noise exposure is depicted in the form of noise contours on an OS base map.
Following the government Aviation Policy Framework (2013) DfT has commissioned ECRD to
produce noise contours for a number of airports on an annual basis. A variation of this approach could
be used to forecast the noise contours generated by a new Manston airport based on traffic volumes,
flightpaths, aircraft types. This is commended in order to appreciate the extent of noise nuisance that
the airport would potentially inflict on Ramsgate and surrounding areas both day and night.
.
4.10 Socio – Economics
The PEIR sets out to establish the main characteristics of Thanet and surrounding areas and the key
economic impact of the airport development. It notes the high level of unemployment compared to
remaining parts of Kent and the importance of tourism to the local economy. It then sets out a very
tenuous and inflated assessment of the economic benefits arising from direct and indirect
employment once the airport becomes operational.
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Our concern is that these are overstated whilst the negative effects are downplayed.
The negative environmental impacts of air freight are supposedly compensated for by economic
benefits, but air freight’s reputation as a driver for economic growth warrants critical examination.
Proponents of expansion of air freight argue that it is a crucial driver of economic growth but there is a
lack of in-depth analysis of the economic impacts. As UK air freight has flat lined since 2000, the case
for a causal relationship, or even a correlation, between air freight growth and GDP growth appears to
be weak.
Airports, when they expand create fewer jobs than they used to because of the increased reliance on
technology, particularly since the advent of low-cost airlines. As the process of replacing staff with
technology at airports continues the generation of job opportunities will decline even further.
Recently opened logistics facilities at airports tend to be highly mechanised, creating fewer jobs in
relation to the scale of the developments than might have been anticipated. The evidence base that
businesses consider air freight to be of crucial importance to growth and investment is inadequate,
and there are indications that the security and reliability of air freight, rather than speed, are deciding
factors for this choice of mode of transport. The fallibility of the forecasts for and purported benefits of,
future air freight suggest it is time to reassess the future size and contribution of the industry.
The fallibility of air freight forecasts, and uncertainly about its purported economic benefits suggests it
is time to reassess the claimed and anticipated growth of air freight. This brings into question the RSP
employment forecasts, particularly in relation to airport operation.
In terms of the negative impacts, the scale of forecast operation, with night and day flights, would
blight the burgeoning tourist business. This in the post industrial world we now live in is the main
driver of economic regeneration in Thanet and its decline would impact severely on the socioeconomics
of the sub region.
4.11 Traffic and Transport
The PEIR set out an assessment of the existing traffic and transport system and initial assessment of
the impact of the operational use of the site as a cargo hub. It notes the site its well served by the
nearby presence of the A299 with connecting links to the M2 and via the East Kent Access road to
Dover.
Our main concern is about the increased volume of heavy goods traffic to and from the site. In
particular at the safety considerations arising from the need to bring by road aircraft fuel given no fuel
pipeline to the site.
4.12 Conclusions on Environmental Impact
In summary :
Contrary to RSP’s claims alternative options do exist to meet any increase in air freight business at
either or both Stansted and East Midlands airports.
The environmental impact of Manston re-opening and operating as a major air freight hub is neither
adequately assessed nor addressed in the PEIR. The negative impacts arising are understated, the
most serious of which are as follows:
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? To air quality, A serious degradation in air quality for residents and visitors to Ramsgateand
surrounding settlements is threatened by the landing and taking off of air cargo carrying
aircraft and vastly increased heavy goods traffic from and to the site.
? To biodiversity. The proximity of Manston to the internationallyrecognised Nature reserve at
Pegwell Bay and Sandwich poses a major threat to endangered and rare species currently
found within the reserve.
? To the historic environment With over 900 listed buildings, many of considerable antiquity
and national importance, and four conservation areas, Ramsgate faces significant risk of
damage to its older and more fragile buildings given the nature and scale of the proposed
airport operation. The disturbance from air traffic would so reduce the desirability of the town
that the refurbishment and repair of historic buildings would become a far less attractive
proposition and the urban fabric would deteriorate.
? To noise and vibration, With a population of over 40,000 and with a significant visitor
population in the summer months Ramsgate faces major noise and disturbance from 24/7
airport operation with significant health and well-beingconsequences.
? To socio-economics Ramsgate, along with the rest of Thanet, depends critically on tourism as
a major growth industry, the future prosperity and expansion of which is seriously placed at
risk by the air freight business proposed.
5 OVERALL CONCLUSIONS
In summary these are :
? The airfreight market has remained stable over the last 15 years and shows no
indications of growth.
? RSP has produced no evidence of a lack of dedicated airfreight capacity.
? There are well established competitors airports that have plenty of capacity to
expand if warranted by the market.
? Manston is in an unfavourable geographic location.
? The runway is too short for fully laden air freightertake-off.
? Past operators and owners have lost over £100m. in the past 15 years.
? RSP makes wholly implausible and exaggerated claims of marketshare.
? The RSP proposal does not, and cannot, meet the criteria to qualify as an NSIP.
? Proposal would have serious health and well-being consequences for Ramsgate
residents and visitors as result of air quality and noise effects.
? It would impact adversely on both the historic and natural environment of
Ramsgate and adjoining internationally recognized Nature reserve.
? It would blight the growing and successful tourism business depressing the fragile
economy of Thanet.
? It would choke off the healthy growth in investment now in evidence and effectively kill
off the tourist industry.
? It would blight the residential and commercial property market.
As a result the Ramsgate Society and Ramsgate Heritage and Design Forum strongly oppose
the DCO application and urge its rejection
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Annex The overall purpose of the Ramsgate Society and the Ramsgate Heritage and
Design Forum
The Ramsgate Society mission is :to encourage high standards of architecture and town planning; to
stimulate public interest in, and to care for, the beauty, history and character of the Town and its
surroundings; to encourage the preservation and improvement of features of public amenity or historic
interest in Ramsgate. It is a registered charity and has a membership of around 700
The Ramsgate Heritage and Design Forum purpose is to promote high standards of architecture
and urban design in the built environment of Ramsgate and to support the conservation and
improvement of the town’s rich heritage, both within and without its conservation areas.
Its current members are :
John Walker (Chair, Ramsgate Society)
David Gullick (Chair, RHDF)
Nigel Phethean
Amanda Newbury
Sue White
Anna McFarland
Brian Daubney
Ivan Del Renzio
Mark Samuels
Penny Perrot
Russell White
Irene Seijo
Richard Oades