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In Part One of this response by No Night Flights (NNF), we comment on the inadequacy of

In Part Two of our response we comment on the substance of RSP’s proposals in so far as

PART ONE – the consultation process..................................................................................... 3

The applicant’s obligation.................................................................................................... 3

Manston would find out about the proposals....................................................................4

will be affected by the proposal can engage with the consultation............................... 9

EU Directive 2014/52/EU...................................................................................................10

Failure to treat residents’ concerns with respect and residents’ data with care....... 11

Misleading information....................................................................................................... 12

Lack of critical information to enable the public to assess RSP’s proposals............ 13

the likely impact of the proposal on their lives........................................................14

Flight paths...................................................................................................................15

Night flights.................................................................................................................. 16

Noise.............................................................................................................................19

Pollution........................................................................................................................20

Public Safety Zones....................................................................................................21

Other planning blight.................................................................................................. 23

Other operational impacts......................................................................................... 24

“The Rochdale Envelope”..........................................................................................24

Summary..............................................................................................................................28

PART TWO – the substance of RSP’s proposals..................................................................29

Opaque and unrealistic business case............................................................................29

The impact of noise on human health............................................................................. 31

The impact of noise on the education of children..........................................................35

Environmental Issues: Air..................................................................................................36

Environmental Issues: Water Pollution............................................................................38

Environmental Issues: Water – impact on aquifer recharge........................................38

Increased building on greenfield land..............................................................................38

Tourism.................................................................................................................................38

Traffic.................................................................................................................................... 39

Dubious Job Forecasts...................................................................................................... 39

Appendix One..............................................................................................................................44

Appendix Two..............................................................................................................................45

Appendix Three...........................................................................................................................46

The Department for Communities and Local Government’s Planning Act 2008: Guidance on

consultation by developers, as part of their preparation before submitting an application for a

Development Consent Order (DCO). Paragraph 20 of the Guidance says: “Experience suggests that, to be of most value, consultation should be:

? shared at an early enough stage so that the proposal can still be influenced, while

views.” Paragraph 24: “The aim should be to ensure that consultation is appropriate to the scale and nature

of the project and where its impacts will be experienced.” The developer is obliged to seek the views of the relevant local authority or authorities on the

developer’s suggested approach to its statutory consultation duties. The guidance says:

Paragraph 38: “The local authority’s aim in such discussions should be to ensure that the people

consultation exercise about the proposed project.” Paragraph 42: “Provided that applicants can satisfy themselves that they have made reasonable

endeavours to consult with all those who might have a legitimate interest or might be

affected by a proposed development, it would be unlikely that their application would

be rejected on grounds of inadequate public consultation.” Paragraph 49: “Applicants will also need to identify and consult people who own, occupy or have

another interest in the land in question, or who could be affected by a project in such

a way that they may be able to make a claim for compensation.” Paragraph 53: “Local people have a vital role to play at the pre application stage. People should

proposals at an early stage.” Paragraph 55: “Applicants must set out clearly what is being consulted on.”

Paragraph 93: “For the pre-application consultation process, applicants are advised to include

provide clarity to all consultees.” The local authorities in this instance are Thanet District Council (TDC) and Canterbury City

Council (CCC). The site in question is in Thanet’s area and the former official flight path

number of concerns about the developer’s proposed Statement of Community Consultation.

timing of flights and physical development of the site. ? There was no delivery strategy for the project, no business plan and no

information about financial viability or evidence of investment. ? Given the scale of the project and its impacts, consultation should be extended to

eight weeks. RSP chose to ignore the Council’s advice on this point. ? The extent of postal consultation was inadequate. All residences and businesses

within 3km of the development should be included in the postal consultation and, given the lack of information about flight paths, a consultation leaflet should be

the Council’s advice on this point. ? Newspaper advertisements should be taken out in Thanet, Herne Bay and

Sandwich. ? Given the extent of the population in Ramsgate that would be affected by the

proposed development, there should be two consultation events in Ramsgate. RSP chose to ignore the Council’s advice on this point and only held one, and it

was shorter than most at 4 hours. ? RSP should make sure that it informed “hard to reach” parts of the community. When asked at one consultation event what had been done to reach people

paper, an RSP representative replied: “You can tell them.” ? There should be a consultation event in Minster or Birchington. RSP chose to

would be a meeting at Birchington that night and one at Chislet on 6th July. Residents in Birchington and Chislet were also informed in writing about these

presentations. These were not formal consultation events. Failure to take reasonable care that those affected by a new cargo

The population of Thanet District is around 140,000. The population of Ramsgate (directly

under the flight path and part of Thanet) is nearly 40,000 and the population of Herne Bay

(directly under the flight path and part of Canterbury district) is similar. RSP took out an

Express (2015 readership 5,798) setting out the details of the forthcoming consultation. Dover is not under the flightpath.

collected from various shops and locations around the centre of town. The advert appeared

on the very day of the Herne Bay consultation event. When asked why RSP had not made a

better job of advertising the consultation to Herne Bay’s 40,000 residents, we discovered

that RSP believed Herne Bay was in Thanet. It is not. RSP says that it sent a consultation leaflet to all residential and business addresses within

2km of the airport, extended in some places to logical boundaries such as main roads. Despite being advised by the Local Authority to do so, it did not directly contact the tens of

thousands more people who live under the former airport’s official flight path. Having

leafleted this swathe of residents ourselves, NNF knows that this can be done for a total cost

of less than £2,500. Given the scale of RSP’s proposals and the often quoted budget for the

project of £300m, it is entirely reasonable to expect the developer to spend £2,000 to £3,000

on informing the people who will be significantly affected if RSP’s Development Consent

Order application were to be successful. This is clear evidence that RSP did not make reasonable endeavours to bring to the

attention of those who would be affected by RSP’s development either the fact of the

proposed development, or the impact that this development would have on these residents

and their daily lives and on local businesses, or the fact that RSP was carrying out public

In contrast, RSP wrote to residents in Birchington, miles from the flight path, to invite them to

affected by its cargo airport proposals whilst at the same time reaching out to those who will

inconsistent about which residents it chooses to communicate with directly and has made a

deliberate choice not to communicate directly with the tens of thousands of people who will

be most affected by their plans. The map showing the extent of the direct communication that RSP intended to carry out is

shown in Appendix One. When questioned at consultation events as to why a 2km limit had been chosen for the

direct communication exercise, RSP said variously that “that’s what is normal for a DCO”, or, “it is only these people who would be affected”, or that “RSP wanted originally only to contact

those within 1km of the runway. TDC wanted RSP to contact those within 3km of the runway

and so RSP compromised on 2km which was enough”. RSP’s George Yerrall also said he

looked at TDC’s advice to leaflet residents under the flight path with details of the

consultation, but that it “wasn’t a command” to him and that he decided: “I didn’t need to do

It is patently unsatisfactory to say that a 2km communication zone is normal for all DCOs. The RSP DCO application is the UK’s first aviation DCO project. The nature of aviation is

that its noise impact is not restricted to a development site, in this case the airport and its

immediate surrounds, but that it extends for some miles beyond this along the flight path. This is self-evidently true. Indeed, deep within RSP’s PEIR is the statement that: “aircraft air

noise could extend up to 14 km along the westerly runway centreline (i.e. to Herne Bay

coastline) and 3.5 km along the easterly centreline (i.e. to Ramsgate coastline)”.1 Given this,

it is telling that RSP chose not to contact the tens of thousands of people who live either side

of this 17.5km centreline. It should be remembered that a flight path is a mile wide, so

aircraft noise will be experienced for some distance either side of the centreline as well. The RSP suggestion that only the few residents within 2km of the airport boundary would be

affected by noise pollution is, of course, entirely contrary to the actual experience of local 1 PEIR 12.7.42

residents during the years in which the airport was open. Ramsgate residents (and others)

created by the airport’s activities. Residents spoke of their anger and desperation at the

effect aviation had on their quality of life. It is important to note that this reaction was

provoked by an annual average of just 500 freight arrivals and departures at the old airport, compared to the 10,000-17,000 freight flights now being projected by RSP. RSP’s suggestion that few residents will be affected by noise is also in contradiction to the

wealth of factual material available which sets out the real noise nuisance impact on local

would be affected by noise if scheduled night flights were to be introduced, make it clear that

noise nuisance is not confined to a small area within 2km of the airport. Indeed, Bureau

Veritas predicted that the population within the 85 dB(A) SEL contour affected by a flight

departure to the east over the centre of residential Ramsgate would be ‘up to 30,903 [people]

for the Boeing 747-400’. RSP has not let these people know that a much, much bigger cargo

airport is now being proposed in their neighbourhood. A series of noise contour maps produced by experts and easily available in the public

them. RSP is also ignoring the noise nuisance map produced by No Night Flights which shows

clearly that actual noise nuisance from planes using the old airport spreads all the way from

the coast at Ramsgate in the east, through Herne Bay town to the coast at Hampton in the

It would be disingenuous of RSP to claim that it did not know that the noise and pollution

impacts of an airport at Manston would affect far more people than RSP chose to inform

directly about its consultation. Mr Freudmann was MD at Wiggins/Planestation (the first

commercial owner of the airport) for many years. He represented the airport operator at the

regular meetings of its Consultative Committee. The committee was given regular reports of

complaints made by the public. Most complaints came from Ramsgate and Herne Bay. Those complaints were about noise, pollution, low-flying planes and repeated approaches. On occasion, Ramsgate residents also reported damage to residential roofs caused by the

wind vortices created by low-flying planes. Mr Freudmann, and therefore RSP, knows full

proposals. RSP’s consultation has fallen far short of a reasonable endeavour to inform

people who might be affected by the development and operation of a cargo airport on the old

Manston site. RSP’s statutory consultation is fatally flawed and should be treated as

such. Similarly, it is surprising that the RSP Scoping Report ignores the actual decibel levels

recorded by various noise monitors while the airport was open. Again, these were reported

to the regular meetings of the Manston Airport Consultative Committee (MACC) and to its

later incarnation, the Kent International Consultative Committee (KIACC). Mr Freudmann, RSP principal, was a regular attendee at Consultative Committee meetings. Despite the

rather patchy coverage of the physical noise monitors, noise levels of 80 to 85 average

noise levels of over 100 dB. Chapel Place is comfortably outside the boundary within which

RSP informed people of the consultation. RSP’s Mr Freudmann is fully aware of this. We can see that RSP deliberately limited the number of people to which it reached out

directly in its statutory consultation. This is not what RSP should have been doing. The

RSP failed to cover areas in which the impact of its proposals will be experienced. This fundamentally undermines the purpose of the public consultation part of the DCO

process, which is to consult with people who will be impacted by the DCO should it be

awarded. RSP should have followed TDC’s advice and extended its consultation activities so that it

communicated directly with all those living, working and studying under and either side of the

flight path, and with those in all areas from which there have been complaints about past

noise levels. This is especially important as RSP is now proposing a 24/7 operation. The

official flight path is a mile wide. It allows for a 10 mile approach to the airport in either

direction (we do appreciate that part of this approach for arrivals from and departures to the

east is over sea). This means that, at a minimum, RSP should have written to all households

within half a mile of the centreline for the flight path, for up to 10 miles to the west and to the

coastline in the east. As part of this communication, RSP should have set out clearly how

many flights it intends to handle a year; what kind of planes it will be using; and what hour of

day or night it envisages planes taking off and landing. The Planning Inspectorate has

already confirmed in an email to No Night Flights that this would count as “preliminary

environmental information” and that it would be reasonable to expect this information to be

made available to the public as part of this statutory consultation exercise. We note that RSP informed its support group, Save Manston Airport Association (SMAa), of

the public consultation events long before they were advertised elsewhere. We note that

them would have to travel from outside the area) and to submit positive feedback. RSP did

not reach out similarly to community groups who have grave concerns about RSP’s plans, such as No Night Flights, until the first consultation events were already over. They also

failed to contact all of the organisations set out in Appendix 1 of their SoCC, as they have

not, to date, made contact with the group ‘No DCO for Manston’ despite this group having a

presence on Facebook and therefore being very easy to contact. All this would, of course, serve to skew the balance of attendees at the consultation events and the feedback

submitted to the consultation. Contrary to TDC’s advice, RSP held just one consultation event in Ramsgate. This event

was on a Saturday and lasted just four hours. This was the only consultation event for

Ramsgate’s 40,000 residents and it was a shorter consultation event than those held in other

areas. Ramsgate will be the area worst affected by a new cargo airport at Manston because

it is on the final approach to the runway that is used 70 per cent of the time. The final

approach takes planes the full width of Ramsgate from the sea to the runway. As planes fly

over the outer harbour, they are at a height of 289m. As they fly over the last houses in

Ramsgate before the airport, they are clearly lower than that as they descend towards the

runway. Tens of thousands of people (as evidenced by previous expert reports by qualified

noise consultants) live under this part of the flight path. RSP did not contact people in

Ramsgate directly to let them know about their proposals and about the consultation process. When questioned as to why only one, four-hour consultation event had been organised for

the tens of thousands of Ramsgate residents who will be affected by a new cargo airport if a

DCO is awarded, RSP said that it could “only get the venue for that amount of time”. This is

responsibilities seriously. Another resident was told that the Ramsgate consultation event

was shorter because it was a Saturday and “more people can get there on a Saturday”. Again, this is a patently unsatisfactory response given that there is evidence in the public

domain that over 30,000 Ramsgate residents will be affected by a 747-400 flying over their

In 2016 NNF reported residents’ concerns about RiverOak Investment Corp.’s Non-Statutory

The first five [consultation] events were held on a weekday between 1400 and 2000. No provision was made for people who work away from their home town and who

Saturday. The choice of locations means that over half of the events were held in towns that are

was at a location (Canterbury) that was very minimally overflown during the airport’s

commercial existence. The two towns that experience what it is like to live under the

flight path – Ramsgate and Herne Bay – had just one consultation event each. No provision was made for the villages that are close to the airport to have a

It is disappointing that RSP has not attempted in any way to address those legitimate

concerns in this statutory consultation, but has chosen to repeat its previous choice of

In contrast, RSP took pains to write to people in Birchington, a town miles away from the

flight path, to invite them to a presentation. We are told constantly that 98% of Thanet wants to see an airport at Manston (what kind of

airport these people apparently want is never specified). However, in a recent poll being

approximately 214 are from Thanet, cared enough to offer their views to SMAa about RSP’s

consultation. It took SMAa more than ten days to gather up this level of interest and support. This demonstrates that nowhere near 98% of Thanet supports RSP’s plans for a cargo

airport at Manston. Having seen this poll, on Friday 21 July NNF launched its own poll about the RSP

consultation. We let the poll run for a little under 48 hours. An on-line survey was advertised

to members of the NNF closed Facebook group and members on the NNF subscription list. 318 people had responded within two days. 89 per cent of respondents live under the flight path of the old Manston airport and would be

directly impacted by RSP’s proposals. A resounding majority, 89%, had not been directly

In the absence of the developer publicising its consultation, NNF tried to step into the breach

by distributing leaflets across the flight path. We were only able to do this after the

consultation events had taken place. This meant that the majority of people were unaware

of the consultation events and so did not attend. Of our 318 respondents, 206 had not been able to attend a consultation event. It should be

noted that our respondents were drawn from a pool of established NNF supporters who were

consultation events. This is a disgrace and demonstrates how partial RSP has been in its

promotion of this consultation. 98% of our participants felt that the consultation was not of

sufficient length given the scale and nature of the proposed project. Of those that did manage to attend an event: ? 87% felt the event was disappointing in terms of the information available

? 86% felt the event did not provide everything they needed to be sufficiently informed

about the proposal ? 82% felt the responses from staff at the event were unhelpful, lacking in detail and/or

? Only 4% felt the event provided sufficient information on which to form a judgement

regarding the proposal ? Only 4% felt the event was well-staffed by informed representatives. Survey respondents struggled to find and/or access critical consultation documentation. Some unable to do so. Even those who did manage to access the documentation struggled

to make sense of it. Only 29 of our 318 respondents found RSP’s documentation accessible

to read in language and length. Only 13 found it sufficiently informative. Just 2 of our

respondents said that they found RSP’s documentation sufficiently referenced through

demonstrates that RSP has not met the bar for an engaging and accessible consultation. Regarding the business case and proposal itself, our survey highlighted real deficiencies. Only 258 respondents had been able to access and read the information/documentation. They described their experience as follows:

impacted. ? 88% felt there was insufficient information on hours of airport operation

? 4% were satisfied that sufficient information was provided on all/most of the areas. The NNF survey is clear evidence that the statutory consultation failed to reach the vast

majority of people who will be most affected by RSP’s proposals. In addition, our survey

reports serious failings with regard to the consultation events, the staff available to the public

at those events, the information available, the business case and the proposal itself. The

extremely unhappy with the way they have been treated by RSP and with proposals that lack

any real information or detail on which to form a judgement. Ramsgate Town Council also commissioned an on-line survey to help in the development of

a Neighbourhood Plan. Responses are still being analysed. However, it is notable that four

of the top ten most agreed with comments were about the Manston site. All were strongly

against plans to re-open the airport. Overall there were three times as many comments

against opening an airport on that site as there were in favour. Comments in favour of the

airport attracted at most three agreements while four comments opposed to RSP's plans

attracted over twenty agreements with many of the others scoring double figures. Failure to provide clear, thorough and accessible information, such

A full suite of documents – over 2,200 pages – was released on-line on the day that the

consultation period started, Monday 12 June. Consultation events took place on 14, 15, 16, 17, 20, 22 and 24 June. This meant that

which comprise unfamiliar and highly technical information, before forming their questions to

take to a consultation event in search of answers. This is inadequate and is particularly

challenging for those residents who either work full time or who do not have access to the

Internet. We understand that when challenged on this, Tony Freudmann insisted repeatedly that if

any consultee had questions or concerns after the consultation events that he or she should

just put it in writing. When it was pointed out that RSP’s lack of response to concerns which

Freudmann confirmed that RSP would not necessarily respond directly to the consultee prior

to the consultation period ending, but insisted that the only option open to consultees was to

“put their concerns in writing”. RSP did not staff the consultation events consistently. At some events there was nobody to

whom the public could address environmental issues. At others there was nobody to whom

residents could direct questions about flight paths. For example, at more than one event

residents found that the environmental representative was too busy with other residents to

deal with questions. People who attended more than one meeting noted that not all RSP

representatives attended all the consultation events. The on-line documents appear to be documents prepared for print and then loaded onto the

website. They are extraordinarily difficult to navigate and look at off-line. It is also impossible

to search each document for key words. The only feasible way of coping with them is to

download each one and to look at them on a personal computer. This really does limit the

accessibility of the consultation material to residents who have computers at home, fast

broadband access, and room for soft copy storage. People with limited or no access to online

took many hours to print. Printing a version of one’s own proved prohibitive for many in

see The Infrastructure Planning (Environmental Impact Assessment) Regulations 2017. This

improved the breadth and depth of public consultations on environmental impact and closed

In the 2016 Scoping Opinion given to ROIC (the original DCO applicant), the Secretary of

advised to consider the effect of the implementation of the revised Directive in terms

of the production and content of the ES. We note that RSP (the current DCO applicant) has taken no notice of this advice.

In its consultation around the new Directive, the European Commission referred to the need

to strengthen the protection of the environment and the quality of life for those affected by

major development. The deadline for introducing new standards was May 2017. Examples of

environmental effects of its operation. We appreciate that there are transitional arrangements. We appreciate too that RSP feels

Opinion before the Directive came into force this year. However, we note that, by RSP’s own

timeline, the very earliest that it would expect an airport to be operational on Stone Hill Park

is 2021. Given this, we think that the Secretary of State’s advice to RSP as quoted above

was sound – RSP should pay attention to the new Directive. RSP’s position seems to be that it has crept in under the line and that it can carry out a lower

standard of environmental assessment for a development that will go live in 2021 or later. This would be four years after the EU’s deadline for all countries to have brought the new

standards into play. If RSP persists with this strategy of relying on out-of-date environmental

regulations and treating local residents to an outdated and inferior standard of environmental

appropriate time by a Judicial Review. Failure to treat residents’ concerns with respect and residents’ data

In 2016, ROIC held a series of non-statutory public consultation events. Despite telling the

public that these events were “a progress report only” and that they were not going to be a

part of the DCO process, they appear to have been reported to PINS as if they were actually

a first formal round of consultation. We reported at the time the concerns of a significant number of residents that, during the

2016 events, ROIC had allowed airport supporters to handle residents’ personal data;

steward the events; prevent residents from asking questions of ROIC’s representatives; and

that the atmosphere was unwelcoming and intimidating for those residents who expressed

concerns or challenges. TDC was so concerned about this that, in its response to RSP’s Draft Statement of Statutory

Community Consultation, it said: “There should be no intimidation or disregard of attendees

at consultation events and all those present on behalf of RiverOak should be from RiverOak

itself or consultants employed by it.” RSP responded by saying: “RiverOak confirms that

there has never been any intimidation or disregard of attendees at consultation events and

It is appreciated that RSP did not use airport supporters as informal members of the RSP

team in the 2017 consultation events. However, RSP’s assurance that there had never been

any intimidation or disregard of attendees at the 2016 events, and that there would not be

any at the 2017 events, ignores the facts of the 2016 events and was not borne out by the

? “I don’t give a shit about night flights” ? “I don’t give a fuck about night flights” ? “Here you go again, just like last year”. Residents reported that RSP representatives referred to Thanet residents as “knuckleheads” and “a bunch of commies” and to TDC councillors and officers as “muppets” and “fuckwits”. Some residents reported RSP representatives standing around them when residents were

trying to ask questions. One said: “As I tried to put my questions or share my evidence, it

became clear that the job of the others was to laugh and to say that I was wrong.” Others

? “I felt intimidated by the circling heavies as I tried to put my questions” ? “It’s undermining to be openly scoffed at when you’re trying to raise concerns” ? “I told them I had spoken to Stansted and that I was told that there was plenty of

spare capacity for cargo there. They just laughed at me and said ‘You’re wrong’ and ‘of course that’s what they would tell you’. I can stand up for myself, but it’s

inappropriate to behave in this way in what should be a public consultation event” ? “Again and again I found myself asking someone questions only to be told, ‘I

speak to. I came away with my questions unanswered.” A prominent SMAa campaigner and new Kent County Councillor, Paul Messenger, was seen

questionnaires. We have grave concerns about the data protection issues implicit in this. We

also note that, as part of the 2016 informal consultation, ROIC had to accept that some

consultation forms that had been handled by airport supporters had been ‘lost’ and that it

never received them. RSP has laid itself open to the same challenge this year by allowing a

member of the public and a well-known and active airport supporter to remove forms from

At the consultation events, RSP produced a large display panel. The first paragraph of the

panel ended with the claim that RSP’s proposal would create almost 30,000 jobs “in East

Kent”. This claim was spotted during the first hour of the first consultation event in Herne Bay

on 14 June 2017. It was brought to the attention of Dr Sally Dixon, the RSP team member

responsible for producing the freight and jobs forecasts. She accepted immediately that this

was not correct. Her claim is that RSP’s proposal will create almost 30,000 jobs somewhere

in the world. She said that she was embarrassed to be so misreported; that she understood

that it was misleading; and that she would get it altered. The panel was not altered during

the Herne Bay consultation event. On 15 June, in Broadstairs, the panel was there again, including the knowingly inaccurate

claim of creating 30,000 jobs in East Kent. Dr Sally Dixon was challenged on this again and

said “I feel like taking the Tippex to that myself”. The resident who raised this with her replied: “but you haven’t, have you?” pointing out the fact that the RSP knew about this important

error but had chosen to leave it uncorrected. On 16 June, in Cliffsend, the panel was there again, including the knowingly inaccurate claim

of creating 30,000 jobs in East Kent. George Yerrall confirmed that Dr Dixon had brought the

error to his attention “straight away” during the Herne Bay event. Mr Yerrall was invited, on

the record, to explain why he had allowed information that he knew to be inaccurate and

misleading to continue to be put before the public. He said: “I’m not going to jump through

Kent by the airport’s 20th year of operation.” The end of this sentence should read: “creating almost 30,000 jobs within East Kent

and the wider economy by the airport’s 20th year of operation’. Please note, the correct phraseology was used on pages 8 and 42 of the report. The omission has now been corrected on the downloadable version of the document

acknowledge or make it clear that it is an updated version. This is not transparent. At the Chislet presentation on 29 June, Sir Roger Gale talked about 30,000 jobs that the

RSP would bring to the local area. He did not clarify that this optimistic estimate refers to

30,000 jobs across the entire globe. Thanet is an area that suffers from high unemployment

and his assertion was met with vigorous applause. Many, many local people think that this

statements and beliefs to go uncorrected. This is extremely disturbing behaviour by RSP. At around 3pm on 14 June RSP knew that its

Overview Report and its biggest display panel were promising the creation of almost 30,000

jobs in East Kent. RSP accepts that, even by its own optimistic numbers, the East Kent jobs

that it actually forecasts that it could create are a fraction of that number. RSP chose to do

nothing to correct this until George Yerrall was challenged to explain on record why he had

chosen not to issue the correct information. Everyone who downloaded a copy or picked up

a copy of the Overview Report and all those people who attended the events in Herne Bay, Broadstairs, and Cliffsend will have seen the inaccurate information. RSP continued with the

inaccurate information long after it had accepted that to do so would be to mislead the public. This is deceitful. Lack of critical information to enable the public to assess RSP’s

RSP has provided very little information on how it arrived at its very optimistic freight

forecasts. Challenged as to which UK airport a new airport at Manston would be winning

business from, RSP responded in various ways: “We will attract business from Stansted. Stansted has no cargo capacity and they

“We won’t be trying to take business from UK airports. 2m tonnes of air freight is

no capacity at Heathrow, Stansted or East Midlands.” RSP’s claim about the lack of capacity at Stansted does not match reality. NNF has been in

touch with the operator at Stansted. Stansted’s position is that it has capacity for more

freight flights; that it is investing in its cargo-handling operation and that it expects to expand

the amount of freight that it handles. Likewise, East Midlands Airport currently handles

around 300,000 tonnes of freight a year and says that it can handle an additional 900,000

tonnes with the existing runway. Heathrow, whose freight is mainly bellyhold freight, is

embarking on an £180m expansion plan for its cargo handling operation. RSP’s sweeping

claims of no air cargo capacity in the UK are not evidenced and simply do not add up.

At the consultation events, RSP’s Dr Dixon explained that her freight forecasts relied heavily

on a series of unpublished papers by Transport for London (TfL). It was put to her that this

informed view about RSP’s freight forecast. Similarly, a document produced for Kent County

Council by Dr Fragkiskos Fillipiaos is referred to in the documentation but is unavailable to

the public. Although in the narrative, Dr Fillipiaos’ work is referred to as a paper, in the

reference section it is referred instead to as a “lecture”. In discussion with residents, Sally

Dixon found it “curious” that the paper wasn’t available. Both examples given mean that the

consultation is neither “engaging” nor “accessible” for local residents. This suite of TfL

documents is apparently central to the calculation of RSP’s forecasts and is therefore critical

to its DCO proposal. By relying on secret documents, RSP has prevented the public from being able to

interrogate the underlying data. Dr Dixon agreed that the situation was “Not ideal, no” but

assistance as to how residents might be able to access them. The public must have access

to the core information underpinning the business case if it is to be able to develop an

“informed view” as to the credibility or otherwise of what is being proposed. This is a recurring theme with this DCO application. In its non-statutory consultation last year, RiverOak Investment Corp. LLC also relied on papers not available to the public. We said

this in our response to the ROIC non-statutory consultation in 2016: “I spoke to Toby Gibb, RiverOak’s environmental representative. I asked him about

impact of night flights on residents would only be significant if there were 18 or more

night anyway. I’ve since identified that study (it’s German and refers to Leipzig airport)

but cannot get hold of a copy. I’ve asked him for one and have heard nothing back. Residents should be able to access information this critical to their future life under

the flight path, or how can we possibly give informed answers to the consultation?” We also said a year ago that “Any supporting studies or documents [must be] made

available to the public before the consultation begins.” Members of the public spent some

months trying to get a copy of the study referred to above, but were not able to do so. Amec

Foster Wheeler, ROIC’s and then RSP’s environmental adviser, refused to release it. This is

unacceptable. Failure to provide the necessary information to enable local residents to

Under the Environmental Impact Assessment (EIA) regulations, Preliminary Environmental

Information means information referred to in Schedule 4, Part 1, which has been compiled

by the applicant and is reasonably required to assess the environmental effects of the

development and any associated development. The Planning Inspectorate (PINS) confirmed

to No Night Flights that it would be reasonable to expect that RSP would make clear to the

public the likely impact of its operations. The public could reasonably expect to be told

whether their home/business/place of work/school would be affected by the developer’s

? pollution implications. RSP has failed spectacularly to provide this information as part of its pre-application

It is of critical importance that RSP sets out clearly what it is consulting the public about. RSP must provide sufficient preliminary environmental information to enable consultees to

arrive at an informed view as to what the proposals are; what impact they will have; and

where and on whom that impact will be felt. RSP has failed spectacularly to do this. At the

consultation events RSP gave inconsistent answers to questions from the public about flight

? RSP could only show potential ‘flight swathes’ ? The flight paths for a fully-loaded cargo plane would be as they were before, i.e. a

always were – namely over Ramsgate and Herne Bay. People at the Ramsgate consultation were told that the flight paths were going to be altered

so that almost all of them were over Herne Bay. People at the Herne Bay consultation were

told that the flights would be altered so that they would be over the land between Herne Bay

and Ramsgate. Others were told the flight paths would be altered so that they would be over

Wingham and Preston. It really does appear as if RSP is seeking to conceal from the public

the unpalatable truth about the flight path. This in no way gives the public the information we need to be able to understand the impact

that a cargo airport at Manston would have on our lives. It is particularly troubling to see at

over Reculver, was being sold as the flight path for arrivals from and departures to the west. Residents have reported back to us that they heard other members of the public saying: “Oh,

if that’s the case, I’ll be happy with that, that’s not over me” and had to intercede, pointing

out that this flight path had only ever been for departures, not arrivals, and that a fully-laden

cargo plane would not, according to both the Civil Aviation Authority and RSP’s own

airspace expert, be able to use that path for arrivals from the west. It transpired that the RSP

team members pushing this flight path had no idea that this path was unidirectional when it

was previously in use by the old airport. It also transpired that members of the RSP team

thought that this flight path was the sole flight path and had no idea that planes approached

the runway from different directions. This is unacceptable. It means that members of the

public have been misled into thinking that there will be new flight paths that will not overfly

their home. This is all the more troubling when, buried at the back of volume IV of RSP’s PEIR there are

four flight paths shown. These are the flight paths that existed before (minus the path that

came north from the Dover beacon and then turned over Canterbury). These flight paths

should have been put front and centre of all RSP’s documentation and consultation events. 2 RSP’s PEIR volume 4, 3.32 d

Too many people have left various events and presentations believing that RSP’s a cargo

It is a fatal flaw of this public consultation not to be able to spell out clearly to people whether

or not they would be under a flight path. Aircraft noise is widely accepted, including by the

UK Government, to be the negative impact associated with aviation and with airports. RSP

has failed to tell people transparently whether or not they would experience aircraft noise as

a result of the operation of a new cargo airport at Manston. This renders the public consultation useless and therefore void. Night flights

RSP gave inconsistent answers to questions from the public about night flights, saying

? The estimate of eight flights per night given by RSP in its consultation material is

? “PINS made us put in a number for night flights” ? “The CAA made us put in a number for night flights” ? “It’s a guess to keep the Planning Inspectorate happy because they’re using us

night flights.” This, of course, is entirely inaccurate as it was RiverOak Investment

? RSP does not “give a shit” about night flights and RSP does not “give a f***” about night flights

? There will, of course, be night flights as planes will start leaving from 06:00, but

? The cargo will be perishables and so the planes will be “in and out quickly with no

need for night flights” ? The cargo will be coming in from areas of Africa in the same time zone so night

? RSP has “assessed the potential for night flights”, but it depends on what freight

companies want to fly from Manston as to what times of day or night they will fly. When asked if RSP had any freight companies lined up, RSP replied “No”. The

more expensive. ? Dr Sally Dixon said to one questioner, “There will be no night flights. Flights will

schedules.” ? Repeatedly, to various participants, RSP representatives said that night flights

social media as ‘evidence’ that there will be no night flights. RSP representatives

did not tell residents that, at Frankfurt, scheduled flights start at 0500 – just six

hours into what should be an eight hour night curfew. RSP has been wholly inconsistent in its handling of this critical issue for those tens of

thousands of people who live under the flight path. It is clear that RSP is intending to have

As part of the development of the project, RiverOak have been exploring the potential

impacts and benefits of limited night flights at Manston Airport. Night flights will make

Manston Airport even more attractive for air freight and will allow us to explore more

opportunities for benefits in the region but come with additional impacts. RSP’s suggested staff shift system allows for 24-hour operation, which suggests that there

will be night operations. RSP says in its consultation documents that flights will be

“predominantly” during the day, which can only mean that the rest of the flights will be at

night. It also says that there will be “a small number of night-time flights, the details of which

will be determined as part of the ongoing project design”. This simply is not good enough. RSP needs to spell out to the public what this might actually mean for us, now, as part of the

statutory consultation. On 13th June 2017 George Yerrall told Kent News: “RiverOak will seek to minimise night flights and incentivise airlines to fly during the

day by levying additional charges and requirements on any night movements. However, we recognise that night flights might be unavoidable in certain operating

circumstances. Therefore, whilst our proposals work on the basis that air freight operations would be

number of night flights.” However, RSP is not assessing the possible impact of night flights as part of its statutory

consultation, because it is not giving the public the information we need as to how many

night flights there might be; at what time of the night they might happen; and how loud they

might be. RSP is quite obviously ignoring the facts about the air cargo market when some of its team

whatsoever. The cargo operation was a night operation. ? The second airport operator, Infratil, then applied twice more for scheduled night

cent of cargo flights at East Midlands, the UK’s biggest dedicated cargo airport, 3 Dependent on the Dark: Cargo and other night flights in European airspace, Eurocontrol 2009

? The Government recognises that air freight operators require night flights: “Stansted is also a hub for several large freight and express companies, which

require the flexibility to fly throughout the night in order to ensure timely next day

RSP claims that night flights were only needed in the past because Manston had just two

cargo stands and so was constrained by how many cargo flights it could handle in a day. This argument does not hold water. In its last full year of operation Manston had 511 cargo

flights. This means that the airport only ever handled on average one to two cargo flights in

any 16-hour day. RSP, along with Wiggins/Planestation and Infratil, has always claimed that

Manston was extremely efficient and fast in its handling of air freight. However, if we are to

believe RSP’s new claim that Manston failed in the past to attract cargo customers because

it had only two aprons, and therefore could only handle one cargo plane at a time, the

implication is that the former airport operator took between half a day and one full day to

deal with each cargo plane and that is why it could not cope with more than one or two cargo

planes in a 16-hour day. This is not credible. We accept that having two aprons imposed a limit on throughput, but we know from former

airport staff that that limit was rarely met or exceeded. There were never traffic jams at

have been five times the traffic Manston actually handled. It is laughable to suggest that

Manston was doomed by an ‘apron bottleneck’ – the problem was never too many planes, but too few. The idea of an ‘apron bottleneck’ as the key constraint is made all the more unlikely when

one appreciates that, on many days of the week, the airport handled no cargo planes at all. It

would have had 16 hours clear capacity on those days – and still it failed to attract dedicated

cargo business. The more likely explanation for the old airport’s repeated failure is that it

failed to attract cargo business because of its location and because it could not offer

It is a fatal flaw in RSP’s consultation that it has not set out a clear and credible picture of the

likely number of scheduled cargo night flights needed if its proposed cargo airport is to

succeed. In the consultation events, RSP representatives confessed that the company has

no firm business commitment from any air freight operator beyond a “we would consider

Manston” email from Atlas Air. Logically, therefore, RSP has no idea whether or not any

future potential customers will require night flights. Given that, RSP cannot say with any

certainty that there will be no night flights. What RSP should therefore have done as part of

its statutory consultation is to set out for the public a possible ‘worst case’ for night flights. The relevant evidence that RSP should have taken into account when putting together a

? 32 per cent of cargo flights at Stansted are night flights. This understates the real

position as Stansted is using a 23:30 to 06:00 definition of ‘night’ ? Every previous operator of the old airport at Manston cited the need for

5 10,475 night flights at Stansted of which 35% were cargo flights, making 3,666 cargo night flights out

“Night flight restrictions at Heathrow, Gatwick and Stansted – Consultation document” – DfT Jan

dedicated cargo flights at a reopened Manston would be night flights, i.e. 12 to 20 flights on

average every night if Manston were to achieve its stated aim of 10,000 to 17,000 cargo

flights a year. This should have been put to the public as a possible scenario. RSP has failed

to set out for the people who would be affected by a new cargo airport what the likely impact

would be on them. This is unacceptable and another fatal flaw in RSP’s consultation process. As a footnote on night flights, it must be noted that the MP for Thanet North, Sir Roger Gale,

Freudmann brings to the table in a bid develop a cargo airport at Manston. Sir Roger says

regularly in the local Press, in interviews, and at presentations to local residents that the

suggestion that there will be night flights is inaccurate and mischievous. Many residents

assume that their MP is telling them the truth. Given this constant stream of communication

from the local MP claiming that there will not be night flights, it is even more important that

RSP should come clean in this statutory consultation about the fact that there will inevitably

be night flights. Many local people who support the airport genuinely believe that they are

supporting a proposal for a little passenger airport with cheap flights to sunshine destinations

and no night flights. At the consultation events, RSP representatives have done little, and

sometimes nothing, to dissuade residents of this rose-tinted picture of what is being

RSP produced only very limited information about which areas of the district would be

affected by the noise created by the proposed nationally significant cargo airport. Chapter 12

of the PEIR, which deals with noise impact, is a highly technical document which is largely

clarifying what that impact will be. To clarify, pages 12-1 to 12-8 (48 pages) document the

technical assessment process, with only pages 12-49 to 12-51 (3 pages) documenting the

calculated or estimated impact. Additionally, there are no plans or maps showing the affected areas, despite them being

listed in paras 12.11.20, 12.11.21 and 12.11.22. When asked why a diagram had not been

included, RSP’s consultant said that this was because the impact assessments were only

preliminary. When it was pointed out that a diagram showing flight paths had been included, even though these were also preliminary, the consultant claimed these were somehow

different, but when further pressed could not provide an explanation. Furthermore, Chapter 12 of the PEIR is so full of acronyms that it is virtually impossible for a

lay person to read. Failure to provide clear and unambiguous information on the impact of noise, which is

arguably the most significant potential impact from the proposed development, is a major

failure. RSP also gave inconsistent answers at consultation events to questions from the public

the consultation was “only about the infrastructure” ? It was not possible to say at this stage which residents would suffer a “significant

because of the new cargo airport would be compensated” ? When challenged by residents sharing their past experience of the many noise

be well over 80dB, RSP told residents that these were “isolated incidents”, which

? RSP had not appreciated that there are around 440 listed buildings in Ramsgate. Some of these listings represent a whole terrace of 15 or more separate

of double or triple-glazing were therefore unlikely to constitute a workable solution.

It is self-evident that the developer needs to set out which residents will be affected by the

developer’s proposals; how those proposals will affect residents; and the extent of that

impact. RSP has completely failed in this statutory consultation to set out for residents what

the noise impact on them would be of a new cargo airport at Manston. RSP has in no way

equipped residents to understand what RSP’s proposals may mean for them and their daily

lives. This renders the consultation void. As a footnote, Table 12.8 of RSP’s PEIR volume III mentions an historical log of ATMs given

to the consultants by RSP. It says that the log covered April 2012 to September 2014. This is

troubling as the airport closed in May 2014. RSP suggests a “zone of influence” of 5km for noise

cargo airport. This is inaccurate and RSP knows this. The noise contour maps produced by

previous noise experts, and the noise nuisance map produced by No Night Flights, make it

clear that noise resulting from the operation of an airport on that site constitutes a nuisance

far beyond 5km from the runway. RSP also admits this in its PEIR vol I section 12.7.42. Pollution

As we mention above, there was no information available about noise pollution and the area

that might be affected. RSP admitted that it has not yet started the assessment into the possible impact of run-off

into the nearby Site of Special Scientific Interest (SSSI) at Pegwell Bay and so it had no

surface water run-off treatment and discharge system, but conflicting information about its

design was provided by two separate RSP consultants. One claimed that the system had not

yet been designed. The other claimed that the design was completed – if that was indeed

Given the extreme sensitivity of the receiving water, Pegwell Bay, this is a considerable

weakness in the PEIR. Pegwell Bay is designated as a RAMSAR site, a Special Protection

Area, a Special Area of Conservation, a shellfish fishery and a Site of Special Scientific

Interest. It is an area in which there is significant local interest. No specific information regarding the impact of noise on the designated features of Pegwell

Bay has been provided. This is surprising, given the very clear link between aviation noise

and breeding and overwintering success in sea birds. Pegwell Bay is already under pressure

due to the influence of other factors such as human disturbance, and so the additional

impact from RSP’s proposed development clearly needs to be properly quantified. Likewise, there is no information on the potential impact of sediment or other pollutants

which may be present in surface water run off which is to be discharged into Pegwell Bay. This will have a potential, but entirely non-quantified, environmental impact on the marine

algae species which are part of the designation for the receptor. One resident in particular had tried hard at the non-statutory consultation in 2016 to get

some answers on the topic of potential pollution and had followed up by email. Following

RSP’s statutory consultation in 2017, this resident reports on his blog that RSP seems to

Consent Order… the representatives I spoke to just didn’t seem to have a good grasp

of the environmental impact of an airfreight hub. He goes on to talk about: … a recent change of attitude towards diesel road vehicles due to the discovery that

the tiny particles that come out of their exhaust pipes are killing people. […] It is

living upwind of major road junctions where as much as 10 tons of diesel is burn in a

year. RSP has not provided a full calculation of the number of HGVs implicit in its proposal, and

nor has it spelled out to the public the potential for diesel pollution on the roads near the

It is unacceptable that RSP should hold a statutory consultation about a potential new

cargo airport if it has inadequate information to give the public about noise and air

No Public Safety Zone (PSZ) has ever been implemented for Manston. The area of a Public

Safety Zone corresponds to the 1 in 100,000 individual risk contour for an airport. The PSZ

tends to be two triangular shapes extending out for 3 to 4 kilometres from either end of the

runway. It is statistically more likely for an airport-related aircraft incident to occur on landing

rather than on take-off so the landing PSZ tends to be a longer triangle than the take-off

Infratil’s 2009 Master Plan acknowledged that a PSZ should have been implemented. However, no PSZ was ever implemented. By looking at other airports and knowing the

pattern of aircraft take-offs and landings at Manston it is possible to gauge the likely shape of

the PSZ that would affect Ramsgate. The prevailing wind direction means that 70% of the

landings are made over Ramsgate. Aircraft landing at Manston used to line up at just 289

Ramsgate to the runway at the edge of town. Depending on the exact trajectory, they would

overfly one of three schools. The 1 in 100,000 contour would extend approximately 3.5km to 4km from the end of the

runway. It would cover a substantial area of Ramsgate right down to the harbour. Three

Infant School, are within the 1 in 100,000 risk contour. The 1 in 10,000 contour is estimated to be a triangle extending 1km to 1.5 km beyond the

end of the runway. If a PSZ were implemented now, we calculate that the 1 in 10,000 risk

contour would include a number of residential streets in Ramsgate (Kirkstone, Whinfell,

Drybeck and Kentmere Avenues and part of Windermere Avenue). If a PSZ were introduced,

the homes on these streets would need to be emptied: “The Secretary of State wishes to see the emptying of all occupied residential

RSP’s responsibility as part of its statutory consultation is to make clear to a number of

residents that a successful DCO and airport at Manston could cost them their home. RSP

has failed to do this. The planning blight for Ramsgate of a proper PSZ would be significant. The implications of

the introduction of a PSZ have not been spelled out to local residents. “…there is a general presumption against new or replacement development, or

This would substantially hamper much-needed regeneration of the town. RSP has failed to

warn residents about this. The Minister for Aviation’s letter of 28th October 2010 made it clear that proper PSZs for

Manston should be implemented. The letter stated that the threshold for PSZs is usually

1500 flights per month. In its Master Plan of November 2009 Infratil predicted that it would

cross this threshold in 2010. RSP’s plans are for 10,000 to 17,000 cargo flights; 10,000

passenger flights; and an unknown number of other flights. Even at the lower number of

freight flights, RSP’s business plan will take it comfortably over the threshold for a PSZ. However, residents who will be affected by new PSZs have not had this brought to their

attention. As of May 2014, Manston is no longer an airport. A new airport developed on that site would

need to be brought properly within the planning regulations. The old airport avoided this by

relying on its previous status as a mixed military and civilian airport before the military

withdrew and it transitioned to being a commercial airport. The necessary PSZ could have

financial implications:. “The refusal of planning permission on Public Safety Zone policy grounds does not

compensation under a purchase notice if a site or property is incapable of being put to

any alternative beneficial use as a result of it being within a Public Safety Zone.” 11

Ramsgate residents have seen a rise in the value of their property since the closure of the

airport. It is estimated that roughly 4,500 households comprising nearly 10,000 people live

within the 1 in 100,000 contour. These people may well have a claim for compensation too. The number of flights is not the only risk factor that needs to be taken into consideration

12 Proposals to Revise the Public Safety Zones at Bournemouth Airport, Annex C, CAA, August 2010, pops 7-8.

people on the ground being killed.” As the aircraft are at a height of only 289 metres above sea level when they line up over

It is the safety concern which is paramount. At least two houses in Southwood Gardens have

lost large areas of roof tiles as a result of ‘wing-tip vortices’ caused by an Ethiopian airliner

coming in to land. In one incident, a large section of roof narrowly missed one of the

residents sunbathing in her back garden. Five of the cargo airlines which flew into Manston

in the last few years of its operation were either banned from European air space or fined

In August 2010, Ramsgate had a near miss with a heavily overloaded Kam Air flight which

demonstrates that the creation of PSZs is no empty exercise. As it tried to lift off, the Kam Air

plane struck its tail 35m before the end of the runway, continued onto soft ground and ran

lucky to avoid a major disaster. Previous airport customers such as Meridian and Airlift International were banned from EU

air space and Egypt Air received a warning from the EU. MK was another regular customer

at Manston – an airline that attracted attention because of crashes in 1992, 1996, 2001 and

customer, Atlas Air was fined $500,000 by the US Federal Aviation Authority for improper

maintenance practices. (It is unclear if this is the same Atlas Air that has expressed an

RSP has not brought to the attention of affected residents in Ramsgate the substantial

negative impact on their homes and their freedom to develop those homes as and when a

proper PSZ is implemented. This is irresponsible and a fatal flaw in RSP’s consultation

RSP has not set out the extent to which a successful airport on that site might prevent other

Statement for England say that exposure to noise at the “significant observed adverse effect

level” should be avoided. This is the level of noise exposure above which significant adverse

effects on health and quality of life occur. The NPSE has the following to say about this level: “Increasing noise exposure will at some point cause the significant observed adverse

certain activities during periods when the noise is present. If the exposure is above

this level the planning process should be used to avoid this effect occurring, by use of

appropriate mitigation such as by altering the design and layout. Such decisions must

be made taking account of the economic and social benefit of the activity causing the

noise, but it is undesirable for such exposure to be caused.” This means that large areas of Ramsgate could start to experience planning blight. TDC will

have to take planning decisions that take account of the need to avoid new development

near the airport if that development could put people into the position in which they would

suffer a significant observed adverse affect (SOAA) because the new development would

expose them to noise from airport operations. RSP should have set out for residents the

areas of the district in which future planning decisions might be constrained because of the

need to protect people from experiencing a SOAA as a result of airport noise. RSP has failed

problem’, meaning Kent County Council’s and not RSP’s. ? Why the cargo ATM forecast increases at a steady 4 per cent a year when the

national cargo airport anywhere in the UK, let alone one in the very toe of Kent. RSP’s air freight forecasts simply bear no relation to reality “The Rochdale Envelope” There is a suggestion that, in failing to provide so much of the information critical to helping

the public to understand the implications of this scheme, the developer is relying on the

‘Rochdale’ approach. In answer to a query to the Planning Inspectorate (PINS) about the

the ‘Rochdale Envelope’ (RE) approach; this is used to assess a likely or reasonable

project have not been resolved at the time when an application is submitted. PINS then refers to Advice Note 9 which says: …Taken with those defined parameters of the project, the level of detail of the

effects, and necessary mitigation – if necessary considering a range of possibilities: …The level of information required is: “sufficient information to enable ‘the main’, or

the ‘likely significant’ effects on the environment to be assessed… and the mitigation

measures to be described…” (Para.104 of the Judgement) …The ‘flexibility’ referred to is not to be abused: “This does not give developers an

Care will be needed by the developer to ensure that the project description is clear so

consultation have been met. Pre-application consultation forms an important element of the 2008 Act regime. Developers must be able to demonstrate, among other things, that they have

Act it is important to consult comprehensively on the project and to report fully on that

It is clear that The Rochdale Envelope does not give developers carte blanche to carry out

pre-application consultation that is lacking in the key information required to enable the

public to assess the potential impact of the developer’s proposed scheme. We are not sure

to what extent RSP is intending to rely on The Rochdale Envelope to explain the lack of

critical information available to local residents as part of its statutory consultation. More

importantly, we are unconvinced that The Rochdale Envelope is even relevant here. The Rochdale Envelope is designed to help developers to cope with a situation in which their

proposal is a new undertaking and little is known about the potential environmental impacts

of the scheme. That is not the case with RSP’s application for a DCO to enable RSP to

passenger services, with a capacity of at least 12,000 air cargo movements per year. Manston was recently an airport. There was a commercial airport at Manston from 1999 to

2014. Its primary focus was cargo, with some passenger services. It had a CAA licence

which set out agreed flight paths. Noise levels were monitored and reported. Residents’ complaints were collated. Unscheduled night flights were recorded. The airport was the

subject of a number of different consultants’ reports while it was still operational. Some of

those reports assessed the noise impact of current and proposed operations on the local

population. The airport had a Master Plan which set out a range of traffic aspirations and

environmental impacts are well known. Previous plans for the old airport’s expansion included projections based on low, medium

and high usage. There is absolutely no reason why this information could not have been

used as a starting point for the statutory consultation. RSP could have taken the data that

described the impact of an airport with 500 cargo flights, and used that to help paint a picture

of an airport with 10,000 to 17,000 cargo flights. It is astonishing that RSP has provided so

little information to the public about the likely impact on residents of its proposals, when

there is so much past data to call upon. We can see no justification for RSP having done

such a poor job for local people in this statutory consultation and no justification for any claim

that the developer will not have access to this information until much later in the DCO

process. The following extract from a letter to TDC sets this out clearly: “I lived in the centre of Ramsgate from 1992-2015 and I represented a community

In order to monitor the levels of noise and pollution to which local people were being

noise monitor had been intended to monitor noise in the village of St. Nicholas but the

airport operator deliberately installed it in a location where the noise readings would

be minimised so that it would not reflect the real levels of noise being experienced by

be situated in locations where noise complaints were being made. Pollution monitors were installed on the Nethercourt Estate near the Western end of

including particulates, NOx and Benzene. Data from the monitoring was reported back to the Consultative Committee for its

monitoring team. My complaint about RSP's consultation is that they have deliberately ignored all of the

of noise and air-pollution which would be experienced by local residents and does not

It is not meaningful to conduct a consultation in which key information is withheld from

freight flights and this is exactly what Wiggins were doing when they ran the airport. It

Committee and used to present the results of the monitoring. RSP is attempting to present a business case for reopening the airport which revolves

around a figure of 10,000 flights per year. This is the minimum level of activity which

would be needed to allow the project to qualify for a Development Consent Order. Consequently, it wouldn't be correct to claim that we do not know what levels of

activity will be conducted at the airport. They will be aiming for a minimum of 10,000

perfectly well that they will require 24/7 operations. In their business plan they clearly

state that the airport will be staffed 24/7. If they know what levels of activity there will

be, what types of activity there will be and where the flight paths will be, there can be

no excuse for failing to use established computer modelling software to predict noise

and pollution for people living in the surrounding areas. Previous plans to expand the

airport included projections for levels and patterns of noise pollution for low, medium

information to local residents about the levels of noise and air pollution which would

be generated by their freight depot. Not only are computer models available to do this,

there is also a wealth of information available from the Consultative Committee, all of

In short, there is a wealth of historical information to help RSP to assess the likely impact of

its proposals. There is no excuse for RSP to hold a statutory consultation about the re- opening of an airport and yet not to be clear to residents about the likely flight paths; the

hours of operation; the likely aircraft to be flown; and the resulting noise and air pollution that

inadequate description of their proposal. This renders the statutory consultation pointless.

RSP’s statutory consultation fails to meet the required standard because RSP has not:

? Carried out a consultation that is appropriate to the places in which the effects of

Between 1999 and 2014 three separate owners of Manston airport each tried to develop the

former military airfield as a commercial cargo airport. Local residents were promised that the

airport would handle hundreds of thousands of tonnes of cargo. They were told that it would

be a nationally significant airport for cargo. They were promised thousands of jobs. The

In fact, in every year between 1999 and 2014 the airport accounted for no more than 1% to

2% of the UK’s air freight. It lost millions of pounds every year. It closed in 2014 because it

could not attract cargo airlines to use it. The airport lost around £100m during its fifteen year

commercial life. The UK air cargo market has not grown since 2000. The sector of the air cargo market that RSP is pursuing – cargo that is moved in dedicated

freighters – is getting smaller. According to the PINS website, RSP must demonstrate that a

cargo airport at Manston would handle 12,000 freighter flights a year. However, the entire

UK market for freighters only handles 52,600 freighter flights a year. In a falling market, RSP

would need to tempt 12,000 freighter flights away from successful and established cargo

airports. When operational, Manston handled around 500 freighter flights a year. It is unlikely ever to

handle more. In the South East, cargo operators say that Gatwick is too far away to be

viable as a cargo airport – they want to be at Heathrow or Stansted. Failing that, they want to

Olympics, not a single extra cargo flight came to Manston. There is plenty of spare capacity for cargo at East Midlands airport. There is plenty of spare

capacity for cargo at Stansted. There is even spare capacity for cargo at Heathrow. The

combination of spare capacity and falling demand means that the UK does not need a new

nationally significant cargo airport. The Department for Transport forecasts that demand for

UK air dedicated air cargo will increase by just 7,400 freighter flights a year by 2050. This

forecast increase in freighter flights is insignificant given the spare capacity at East Midlands

and Stansted for tens of thousands more cargo flights. One expert report after another has concluded that a cargo airport at Manston will not be

viable. Quite simply, the very south-eastern tip of the UK is the wrong place for a cargo

In a market awash with spare capacity, there is no need for a new cargo airport that can

handle an additional 12,000 freighter flights a year. Even if there were, an airport at the very

edge of the UK would not be the answer. The Ministry of Defence owns surplus airfields that

are far better located than Ramsgate for air cargo. If the Government thinks that a new UK

cargo airport is essential, then it has the solution in its own hands. Instead, the Government

is selling these airfields for housing, demonstrating neatly that, in the eyes of the

Government, an additional UK cargo airport is not needed. At the consultation events, RSP said that it was not going to try to take dedicated air cargo

business from other UK airports. The plan is apparently to attract air cargo that is currently

being flown into European airports and then trucked to the UK. This justification barely

features as part of the case in the Azimuth Report, Volume III.There is no substance in the

RSP documentation to support this as a credible plan. No cargo customer has signed up

to use the airport. No data is offered that demonstrates that it would be preferable to cargo

customers currently flying cargo into European airports for forwarding to the UK by truck for

them to fly their cargo to Manston instead, thence to be trucked the length and breadth of the

UK. There is no fact-based business case underpinning the idea that 2m tonnes of air cargo

are being trucked into the UK from European airports and that its owners would far prefer to

fly it into Manston and then truck it from there. RSP is apparently relying on Dr Dixon’s rendition of TfL’s secret papers as the basis for this

plan for mopping up air cargo customers from European airports. This is not a sound enough

business case to warrant taking land from its rightful owners by a CPO on the basis that a

new cargo airport – the UK’s second biggest dedicated cargo airport – can successfully be

developed on that land. The public has a right to know the underlying business fundamentals. Without them, residents cannot assess the likelihood of success of this ‘plan’ and whether its

notional benefits will ever be achieved. Without a proper business case that gives the public

access to the market demand data behind it, RSP is asking residents to trust implicitly that

one secret set of documents will guarantee enough business to justify the UK’s second

biggest dedicated cargo airport being built in their neighbourhood. This is unreasonable and

falls far short of the developer’s obligation to put the public in a position in which it can

In its entirety, RSP’s written plan is dependent on two forecasts, one for freight traffic and the

other for passenger traffic. Both forecasts are from Dr Sally Dixon and the results presented

in the four volumes of the Azimuth reports. The actual forecasts are shown in Volume III – The Forecast. These forecasts are based on dubious assumptions, speculative guesswork and have zero

backup evidence. Sadly, all other RSP plans depend on the validity of these forecasts – the

predicted flight levels, the justification for NSIP status, the jobs forecast, the business case,

the case for financial viability, the delivery plan (wherever these latter may be). The Northpoint Report is entirely based on finger-in-the-air guesswork. The author of this

report, Chris Cain, arrives at a freight forecast of 660,000 tonnes per annum at Manston for

2050, subsequently revising this to 470,000 tonnes for year 2040. Both guestimates are

between 1.5 and 2 times the freight levels currently handled by the UK’s principle dedicated

It is entirely unclear how the figure of 5,250 freight movements in Year 2 is derived

appears to be simple conjecture, derived from various speculative interviews with airport and

charter operators, freight associations and freight handlers, and a helicopter business. From Year 11, a subsequent year-on-year growth of 4% has been used, reportedly based on

forecasts from Boeing and Airbus. Boeing and Airbus are airframe manufacturers who have

a vested interest in making optimistic forecasts of their customers’ business growth. Their

forecasts bear no relation to forecasts made by the DfT. Discussions with RSP representatives at the consultation events suggest strongly that the

DCO application notionally to develop a nationally significant cargo airport is a stalking horse

for something else. We were told emphatically that the proposed teardown business is the

“jewel in the crown” and that that is “where the money really is” and “the only financially

viable bit of the airport”. In addition, RSP plans to charge a chunky fuel premium as its

second main source of revenue. Thirdly, the industrial estate that RSP plans to develop on

the Northern Grass needs no airside access because tenants there will not be using the

airport. The only part of the Northern Grass that is needed for airport operations is a small

area for the radar installation. This suggests strongly that the Northern Grass is not an

essential part of a nationally significant cargo airport on the site. RSP is trying to CPO it

simply to develop an industrial estate on that land, income from which will prop up the loss- making airport. This is not an acceptable use of compulsory purchase powers. There is no airport at Manston and there has not been one for over three years. If successful, RSP’s proposal would introduce to thousands of residents a blight that they do not currently

live with. This is important. We are not talking here about a DCO that would expand or

increase an otherwise negative impact on a community. We are talking about a significant

blight that would be inflicted on a community from scratch. The base figure of 4,932 passenger movements in Year 3

guesswork that scheduled, LCC, charter and cruise ship flights will want to use Manston. There is absolutely no evidence for this. None of these operators has come anywhere near

making a commitment to use Manston. Previous passenger operations at Manston failed, and LCC airlines have rejected Manston several times as being in the wrong place. Again, a

speculative 4% annual growth rate has been used from Year 11 to Year 20. RSP forecasts 965,295 passengers in the fourth year of passenger operations and more

than 1.4 million by year twenty. The population of Kent is about 1.6million. About half of them

fly. These people have access to a multitude of flight destinations at Gatwick, Heathrow and

London City. The core catchment area of East Kent obviously comprises even fewer people

than Kent as a whole and has a less wealthy population than that of West Kent. RSP’s

passenger projections are extraordinarily optimistic and rely, even in the early years, on a

hope that most people in East Kent who take flights would take two flights a year each from

Commission is supportive of the concept of reliever airports (which is what RSP sometimes

suggests that Manston could become). Infratil suggested this possibility to the Airports

the Commission’s Final Report in July 2015, nor was it mentioned in the Interim Report of

Commission’s recommendations for addressing the capacity of the South East’s airport

system. Manston airport was mentioned in the Appendix to the Commission’s Interim Report, which was a specific assessment of all the short and medium term options submitted by the

UK’s airport owners. The Commission looked at whether it would make sense to redistribute

some flights away from Heathrow so as to ease congestion. It looked at Infratil’ s ideas for

changing the slot allocation regime and forbidding some types of flight, like cargo flights,

from using Heathrow at all, but concluded: “none was assessed as being a viable or effective

It is very difficult to offer precise feedback on RSP’s proposals because what is being

proposed is so unclear. Our comments below are therefore more generic and highlight the

areas in which RSP’s proposals threaten local residents with significant new blight. The impact of noise on human health

Aircraft noise is a serious problem around all airports and under flight paths. Noise levels are

typically measured using the Decibel 'A' Scale, usually expressed as dB(A). A limit of

impossible. The Government’s overall policy on aviation noise is to limit and, where possible, reduce the

number of people in the UK significantly affected by aircraft noise.16 Counter to this, RSP’s

proposals will of course inflict a brand new source of significant aviation noise on a

population that currently is not affected by aviation noise. It is surprising to see a proposal

that runs so clearly counter to Government policy. Measuring the levels of noise pollution from aircraft is a controversial area. 14 Azimuth vol III, Table 5, p 10

The two most commonly used techniques for measuring noise levels are Leq and Lmax. Leq is

favoured by the aviation industry. It measures the average level of sound intensity over a

period of time. However, as NNF often points out, it is not the average noise of one’s alarm

clock over an eight hour period that wakes one up – it’s the loudness of the alarm clock at

the precise moment at which it goes off. Lmax is a more useful measure for those who have to live with the debilitating effect of noise

pollution. It measures the maximum sound pressure level occurring during a certain period of

time or during a single noise event. Lmax can identify serious noise problems arising from

short-lived single noise events, which are not picked up by Leq. This is important. A Leq

measurement can suggest that there is a tolerable level of noise when the experience on the

ground is very different. After all, noise that is loud enough to (say) stop conversation is

noise that is having an impact on the people living through it. Averaging out the noise of 17,000 cargo flights a year will produce a relatively low Leq

number. However, this will in no way reflect the impact of each of those separate flights on

someone under the flight path who is overflown dozens of times in a day. As an example, if

Concorde were still in service, one Concorde flight going over every four hours is the Leq

equivalent of four hours’ of non-stop noise from Boeing 757s flying overhead at a rate of one

every two minutes. It is not sustainable for RSP to attempt to rely on Leq as a sole measure

of the noise nuisance that its proposals will inflict on local residents. The UK’s Aviation Policy Framework explicitly recognises that LAeq alone is an inadequate

measure of the noise nuisance that people suffer from airports and aviation: “The Airports Commission has also recognised that there is no firm consensus on the

which it will carry out further detailed work and public engagement. We will keep our

averaged manner and that the value of the LAeq indicator does not necessarily reflect

measures in consultation with their consultative committee and local communities.” 18

In March 2016 the Civil Aviation Authority published CAP 1278. That report says: “With regard to night noise and sleep disturbance, there is growing recognition that

average indicators such as Lnight are insufficient to fully predict sleep disturbance and

RSP’s noise assessment methodology is out of date and will significantly under- assess the noise impact of its proposals on local residents. RSP needs to stop trying to hide behind average measures of noise and deal with the reality

of how noise is actually experienced on the ground. We need to see more honest measures

such as SEL, Lden, LMax and N70. RSP likes to suggest that, if its DCO were successful, it

would develop a modern airport. If that is the case, then RSP needs to start using modern

measurements of noise. A report prepared for the Airports Commission in 2015 collated some of the research around

noise and human health. Among other remarks that report said: “Over the past 10 years, evidence that aircraft noise exposure leads to increased risk

for poorer cardiovascular health has increased considerably. A recent review, suggested that risk for cardiovascular outcomes such as high blood pressure

(hypertension), heart attack, and stroke, increases by 7 to 17% for a 10dB increase in

aircraft or road traffic noise exposure (Basner et al., 2014). A review of the evidence

“[…] a 10dB increase in aircraft noise at night (Lnight) was associated with a 14%

“[…] a 10dB increase in night-time aircraft noise was associated with a 34% increase

vulnerable groups such as the elderly, children, and the chronically ill from the effects

the level of 55 dB Lnight, outside, as an interim target for countries wishing to adopt a

noise such as disturbance, irritation, dissatisfaction and nuisance (Guski, 1999). Annoyance can also be accompanied by stress-related symptoms, leading to

“ […] in recent years, several studies have suggested that aircraft noise annoyance

around major airports in Europe has increased (Babisch et al., 2009; Janssen et al., 2011; Schreckenberg et al., 2010),” A meta-analysis of research based on one hundred published reports from fundamental

studies, experimental studies and epidemiological studies into “noise annoyance” found that

a high level of aircraft noise is related to an increased chance of death from heart attacks, high blood pressure and strokes with a 10 decibel average increase in aircraft noise

exposure resulting in increasing these incidents by between 7% and 17%. The World Health Organisation (WHO) recommends an 8 hour night flight curfew so as to

ensure most people get the sleep they need. WHO’s view is that above 55 dB Lnight noise is

a significant concern to public health. As a result it has set an interim target of 55 dB

Lnight,outside. For the longer term it recommends that night noise exposure should be

reduced below 40 dB Lnight,outside. WHO says that the interim target is only recommended

in the situations where the achievement of the 40 dB Lnight,outside target is not feasible in the

short-term. A major study by Warwick Medical School concluded that chronic lack of sleep produces

hormones and chemicals in the body which increase the risk of developing heart disease, strokes and other conditions such as high blood pressure and cholesterol, diabetes and

obesity. That study said: “If you sleep less than six hours per night and have disturbed sleep you stand a 48%

of developing or dying from a stroke." A UK study in 2013 published in the British Medical Journal, found evidence that people

living in areas with high levels of noise pollution from passing aeroplanes had a higher risk of

heart disease and stroke. The report compared Civil Aviation Authority data on aircraft sound

levels with hospital admissions and mortality rates for 3.6 million people living near Heathrow

conversation in a quiet room. Researchers from Imperial College London and King’s College London found that the risks

of cardiovascular disease were greater for those living in neighbourhoods with the highest

noise levels and closest to the airport, such as Slough and Hounslow. Around 72,000 people

living in the noisiest areas had a 10 to 20 per cent greater risk than people living in the

In an editorial for the BMJ, Stephen Stansfeld, professor of psychiatry at Barts and London

“imply that the siting of airports and consequent exposure to aircraft noise may have

direct effects on the health of the surrounding population. Planners need to take this

airports.” Some local residents believe that aircraft noise at night “doesn’t bother them” because it

does not actually wake them. The research says otherwise. Even if people don’t wake up as

a result of noise from aircraft, the World Health Organisation says that there is “sufficient

evidence” to show that the noise increases the heart-rate. In other words people’s health can

be affected by the noise of aircraft at night even if they do not wake up. TDC has already commissioned expert studies that concluded that there is no social, economic and environmental case for night flights. The damage that they would entail far

outweighs the benefits. Given that, and the evidence quoted above, we emphatically oppose

any suggestion that a new cargo airport at Manston should or would have scheduled night

flights. For clarity, there must be an eight-hour curfew on scheduled flights between 2300 and 0700.

In addition, there must be heavy penalties for any unscheduled flights. We have learnt from

experience that unscheduled flights tend to creep in with surprising regularity with the airport

operator allowing this to happen. Our stance is clear – there is no case for introducing

scheduled night flights. Thanet residents on average already suffer from worse health than the majority of the rest of

the UK, and the poorest physical and mental health statistics in Kent with the average life

expectancy in Cliftonville West being 69 years, 18 years lower than the best in the county. We do not need the damaging effect on people of aircraft noise day and night to lead to

RSP does not intend to complete a Health Impact Assessment as part of its DCO application. This is completely unacceptable. RSP says

This PEIR does not have a chapter entitled ‘Public health impacts’ as there is no

assessment. We make the point above that the EU intended European countries to be protected under

the new Directive from May 2017. RSP’s proposal would not produce an operational airport

until 2021 at the earliest, four years after the deadline for using the new Directive. If RSP

persists in trying to develop an airport that it knows will fall well short of modern

environmental standards, we expect this point to be argued at a Judicial Review. Finally, the UK Government has said that it wants to bear down on the noise associated with

aviation. It has also long been a Government objective to bear down on night noise.21

measured by: The area of and number of people in the 48dB LAeq 6.5hr night contour. This is a different measure to that used for the current regime, but reflects increased

evidence about the impacts of lower noise levels on sleep disturbance and health. 2.28 The second pillar of the Balanced Approach is land-use planning. Primarily this

by aircraft noise. RSP’s proposal would introduce an entirely new source of noise and night noise to local

residents. RSP’s proposal will have a debilitating effect on the health of residents who are

exposed to this new source of aviation noise. RSP’s statutory consultation has failed to take

into account current thinking about the appropriate measurement of aviation noise. RSP

proposals will inflict on us. The introduction of a brand new source of aviation noise to this

There is a growing body of evidence to demonstrate that exposure to aircraft noise is

harmful for children, their health and their ability to learn. Studies into the effects of chronic

In its summary of some of this evidence, the Airports Commission report said: “Many studies have found effects of aircraft noise exposure at school or at home on

21 Night flight restrictions at Heathrow, Gatwick and Stansted. Consultation document. DfT, Jan 2017

“In the UK, reading age was delayed by up to 2 months for a 5dB increase in aircraft

would estimate an 8-month difference in reading age.” Teachers in Ramsgate have spoken publicly of the impact of cargo flights into and out of

Manston previously, saying that lessons used to come to a standstill until the plane had gone

over, simply because the teacher could not make him/herself heard. Each interruption lasted

longer than the time it took for the plane to go over, as children then had to settle down and

refocus attention on whatever they had been working on previously. In addition, night flights

disturb the sleep of children and impair their subsequent performance at school. Thanet children on average already perform less well educationally than the vast majority of

children in Kent, and indeed in the rest of the UK. Thanet District’s secondary school

performance ranks it in the poorest performing 0.5% of all local authorities when looking at

attainment of 5 GCSEs at A* to C. We do not need the damaging effect on people of aircraft

noise day and night to lead to even poorer education outcomes for our children. Environmental Issues: Air

acceptability of the Proposed Development is annual mean nitrogen dioxide (NO2). Given that the airport will operate at a steady level over time (except for

pollutants such as PM10 or PM2.5 are unlikely to be the most constraining criteria. However, they will be included in the assessment to provide confidence in this

Air pollution is a major issue for those who live in the vicinity of large airports. Emissions

from aircraft, airside 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 is a significant threat to human health and the environment, especially in areas

close to airports. NO2 exerts most of its effects on the human body locally, in the airways

results in chronic coughs and infections such as bronchitis. Ozone (O3) is an important

secondary pollutant that is formed out of NO2. With regards to particulate matter, overwhelming evidence has been compiled in recent years, demonstrating its mortality and

As the Environment Agency reports: “Of all the pollutants, particulates are worst for human health. They are responsible

for up to 10,000 premature deaths through respiratory problems in the UK each year.” 22 PEIR volume I 6.4.17

23 Health Aspects of Air Pollution with Particulate Matter, Ozone and Nitrogen Dioxide. WHO 2003, and Systematic Review of Health Aspects of Air Pollution in Europe. WHO 2004

A study by the Massachusetts Institute of Technology has estimated that long term exposure

to aviation related ozone and fine particulates (specifically PM2.5, the smallest particles)

contributes to 16,000 premature deaths a year worldwide, costing an estimated $21 billion a

year.24 The study considered the health impact of near airport, regional and global emissions, estimating that “cruise altitude” emissions were the most significant contributor to health

impacts world-wide. However, emissions from landings and take-offs were found to have

significant pollution-related health impacts for communities living close to airports, contributing to 49% of the premature deaths associated with aircraft emissions in Europe. The study considered that the costs of the pollutants studied were of a similar magnitude to

the costs associated with CO2 emissions. Surprising as it might be, aircraft emissions are not the major contributor to air quality

problems around airports. The sources of pollution in order of significance appear to be:

? road traffic at and around airports. It appears as if RSP has chosen not to include

this data in its PEIR Volume I. ? aircraft exhaust fumes (10% of air pollution around Amsterdam Airport Schiphol

It is fair to say that RSP’s consultation materials on the topic of air pollution are a serious

challenge for the lay reader. This diminishes the value of the consultation and makes it

extraordinarily difficult for ordinary residents to understand the implications of this project

and what it might mean for them and their health. What is clear, though, is that some important information is missing. At 6.10.2 of PEIR Volume I, RSP reveals that it has not yet completed its traffic assessment

and therefore it has not calculated the full air pollution impact of its proposal. This is a huge

gap in the information. As we have said above, road traffic associated with airports is the

biggest source of air pollution. This is particular concern given that, following the East

associated with the level of operation that RSP aspires to develop. We cannot see how RSP

can suggest that it is consulting the public when such a major piece of information about the

impact of its proposals on the public is missing. The UK is already struggling with air pollution. There is no clear government plan to keep

aviation emissions to a level consistent with the Climate Change Act (despite the fact that in

the 2011 ruling on Heathrow expansion, the judge declared the Government’s claim that

aviation policy was divorced from the requirements of the Climate Act to be “untenable in law

or common sense”). We can find nothing in the RSP consultation materials that deals with

climate change and how this proposal will add to the UK’s emissions. It is extremely

unhelpful that RSP has not made available to the public as part of this statutory consultation

a full assessment of the likely air pollution impacts of its proposals. This is a significant flaw

in the consultation. Finally, we know from past experience that residents in Ramsgate and in those villages

close to the airport often experienced droplets of fuel falling on their house and garden. This

pollution has not been addressed. In addition, residents near each end of the runway have

long complained about the smell coming from airport operations and particularly from aircraft

with their engines idling. RSP has mentioned this as an issue but we can find no information

that the issue has been addressed any further than that. 24 Global, regional and local health impacts of civil aviation emissions – Steve H L Yim, Gideon L

Lee, In Hwan Lee, Florian Allroggen, Akshay Ashok, Fabio Caiazzo, Sebastian D Eastham, Robert

We strongly object to the inevitable decrease in local air quality for residents that will result

from a cargo airport at Manston. We do not support the decrease in the health of local

residents that will inevitably result from airport operations. Environmental Issues: Water Pollution

A persistent and recurring concern regarding any kind of development in central Thanet is

the potential impact on the Island’s aquifer which lies in part under the Manston site as well

as the impact on the coastal SSSIs such as Pegwell Bay. Given that RSP’s proposal envisages a very high level of air and road traffic, and given that

RSP plans to build up to a dozen new stands, allowing planes to be parked near the runway,

the ‘worst case scenario’ that must be adequately addressed in RSP’s proposals is

managing a catastrophic spillage involving multiple planes. Similarly, the risks associated

with having significant fuel storage on-site must be explicitly addressed. RSP has not done

There is no consideration given to the potential impact on aquifer recharge caused by the

creation of an additional 400 acres of hard-standing at the airport, which is located

immediately over a drinking water aquifer. Assuming a typical annual water use for a 3 bedroom house of 130m3, and an assumed

rainfall of 650mm annually with a 60% infiltration, this equates to the loss of recharge to the

aquifer of enough water to service just under 5,000 homes. This is a significant impact on a

site which is not suitable for SUDS which could mitigate this reduction. RSP has not tackled

The draft Local Plan allocates 2,500 homes to be built on the site that RSP wishes to acquire

for a cargo airport. If the DCO were to be successful, those 2,500 homes would have to be

built on green field land as the Plan has already taken account of all the suitable brownfield

sites available when arriving at the Council’s Housing Supply total. Even with 2,500 homes

allocated to the old airport site TDC is already making provision in the draft Local Plan to

build on green field land. If this housing site of 2,500 homes is used instead for an airport, an

additional 2,500 homes on green field land would have a significant impact on agriculture, on

green space, and on the local environment. We object to this strongly, as does the CPRE, (Campaign for the Protection of Rural England). Tourism

Tourism is a vital, and growing, part of the local Thanet economy. Thanet’s visitor economy

grew 19% in 2015, making it the biggest district tourism success in Kent and, arguably,in the

whole of the UK. The total value of Thanet’s visitor economy reached £293m with the district

welcoming nearly 4 million visitors. Research by Visit Kent shows that there has been a rise of 23.3% in the total number of jobs

in the area supported by tourism, with the total in 2015 being 7,312 jobs. This number is

expected to continue to grow. This growing tourism economy would be threatened by the introduction of a huge cargo

airport with 24/7 operations and 17,000 noisy cargo flights a year. People do not travel to

take holidays under the final approach of a 24/7 cargo airport. Many of our beaches, cafés, hotels and visitor attractions would become intolerable and unattractive to visitors due to

levels of noise, roads clogged with haulage vehicles and significantly worsened air pollution.

We would lose tourist visitors to the district and the tourism spend that they bring and the

The traffic assessment has not been completed. This means that residents have not had

access to the information that they need to assess the traffic impact of RSP’s proposals. Again, it is hard to see why RSP has come to this statutory consultation when so much of

the critical information is not yet ready. RSP suggests that there will be 65,000 HGV movements by year twenty. This appears to be

no more than a finger in the wind estimate that it takes about four HGVs to unload a cargo

plane. We can find no recognition in the information given that there will be an additional

transport everything needed on a daily basis for RSP’s claimed numbers of passengers. East Midlands Airport’s Sustainable Development Plan (2014) talks of 500 HGV a day, with

most of them at night, providing a more realistic benchmark of the impact of traffic due to an

airport with significant freight operations. To clarify: 500 HGV movements a day is 182,500

In the absence of any robust data on traffic numbers by type of vehicle, and any meaningful

infrastructure, it is not possible for any potentially affected parties to understand the potential

impact of the proposed development. We object strongly to the addition of what we estimate to be substantially more than 65,000

extra HGV vehicles on local roads and the congestion, road wear, and additional pollution

The employment and economic benefits of the airport have always been greatly exaggerated, and have never materialised. Historically, Manston’s owners have always promised big

numbers but delivered small numbers. After 15 years operating as an airport in private

hands, this 720 acre site peaked at just 144 mostly part-time jobs. The graph illustrates the eternal gap between the job creation promises made by various

owners of Manston and the reality. The forecasts have been in the thousands, and are now

In 2001 Tony Freudmann’s team at Wiggins promised that there would be 6,000 jobs at

Manston by 2010. In 2001 Wiggins backtracked and said that this would not be achieved

until 2017. In 2008 Infratil predicted 3,500 jobs by 2018 and 7,500 jobs by 2033. The

following year this was revised down to 2,800 jobs by 2018 and 6,000 by 2033. In 2015, Sir

Roger Gale stated there would be 2,000 jobs in two years. Dr Dixon’s forecasts dwarf all

previous over-estimates. Records from monthly reports to the Kent International Airport Consultative Committee show

that actual jobs numbers under Infratil from 2005 to 2013 ranged from 53 to 112 jobs. When

the airport closed in 2014 there were reportedly “144 mostly part-time jobs”. Dr Dixon’s approach to job forecasting starts by assuming that a given amount of business

(one million passengers or 100,000 tonnes of freight) generates a certain number of direct

jobs – this we call the Direct Jobs Multiplier (DJM). She then applies some other multipliers

from disparate research sources to predict increasingly remote categories of jobs. This is like

Dr Dixon’s first error is to misuse the freight-to-passengers equivalence. The idea that 100,000 tonnes of cargo is equivalent to one million passengers is only true in

terms of weight. It assumes that a passenger (with luggage) weighs about 100kg, so ten

passengers weigh about 1,000kg, which is one tonne. Sure enough, 1,000,000 passengers

would weigh about 100,000 tonnes. This is an aviation rule of thumb that is used for assessing how much “stuff” is being

transported, simply in terms of weight – useful when looking at fuel requirements, or wear

and tear on landing gear and runways, or anything else weight-related. It is a mistake to use

it for anything that is not purely or primarily about weight. One million passengers (or 100,000 tonnes of passengers, to put it another way) and

100,000 tonnes of freight do not have the same requirements for heating, cooling, lighting, pressurisation, feeding, cleaning, security, customs, quarantine, customer service, or

staffing levels, and can’t be regarded as equivalent for any of them. For example, if Airport

A needed 500 staff to handle 100,000 tonnes of passengers, it doesn’t necessarily follow

that Airport B would need 500 staff to handle 100,000 tonnes of freight. Because the DJMs

for pure passenger and pure freight business are so different, it would make sense to use a

“freight-only” DJM for jobs forecasting, up to the point that the project breaks even and RSP

starts operating passenger flights as well as freight flights. Dr Dixon provides no figures from

freight-only airports. Dr Dixon’s second error is to over-estimate the Direct Jobs Multiplier – the number of

direct jobs generated by a unit of work (passenger or freight) at the airport. All of the studies that Dr Dixon refers to in section 4.1 (ACI Europe, 2015; Intervistas, 2015;

unsurprisingly this is reflected in the high DJM numbers she quotes. A tonne of passengers

needs more human attention than a tonne of freight, so we would expect the actual DJM

value for a cargo airport at Manston to be lower than any of the figures she quotes, as it

East Midlands Airport (EMA) is a busy cargo airport, and it is also a busy passenger airport, comparable to London City in scale. Thus the DJM value at EMA is boosted by the more

meaningfully be applied to Manston from Year 1. Looking at actual DJM values from across the UK over the last 20 years or so:

to 480 in 2015. ? In 2003, Gatwick operated at 821 jobs per million passengers. This fell to 683 in

2015. ? In 2005, Southampton airport operated at 652 jobs per million passengers. This

fell to 505 in 2015. ? In 2005, Bournemouth airport operated at 408 jobs per million passengers. This

fell to 247 in 2015. ? In 2007, Glasgow’s Prestwick airport operated at 248 jobs per million passengers. ? In 2011 Infratil (then owners of Manston) and KCC applied to the Government for

This brief review of the facts makes two things abundantly clear. 1. The overall trend for actual DJM values is steadily falling – airports are becoming less

labour-intensive. 2. RSP’s chosen DJM value is not a typical value, it is an outlier. It is higher than most of

the historical values, and is going against the trend. Despite being referred to in the industry as ‘self-loading cargo’, passengers and cargo have

very different handling requirements and place different demands on the airport operator. Put simply, a tonne of boxes needs a lot less human attention than a tonne of people. Less

human attention means fewer jobs. This is why freight business is always much less labourintensive

with a sizeable passenger component to their business. The proposed Manston site will be

It is clear that the “887 per million” DJM that RSP’s Dr Dixon cherry-picked from East

Midlands Airport and applied to this cargo hub proposal is far too high. When questioned

about this at a consultation event, she described her calculation as a “mash-up” of the EMA

figures and previous staffing levels at Manston. We need a much better explanation than

that to account for this brand new cargo hub being one of the most labour-intensive (or

should that be labour-inefficient?) airports in the country. A further technical factor to consider is that the new-build operation proposed by RSP offers

every opportunity to automate wherever possible, to ‘engineer out’ expensive labour costs, making it more ‘robot-intensive’ than existing cargo hubs. This will further lower the actual

DJM number for an operational cargo hub at Manston. Dr Dixon’s third error is to forecast something unknowable and uncheckable. This proposal’s key selling point for the community is jobs, so it is important that the job

forecasts are scrutinised carefully. The first tier of jobs that Dr Dixon describes is the so- called “direct jobs”. Dr Dixon tells us that direct jobs include: aircraft maintenance; airlines; airport and air

traffic control; airport security and passenger screening; employment by the airport operator;

food and beverage; general aviation; ground handling and ground transport; handling agents;

immigration, customs and government jobs; maintenance repair and overhaul (MRO); retail,

food and other in-terminal services; and ‘other’. This is what most people think of as ‘airport jobs’ – jobs at the airport, jobs that rely on the

airport. In fact, there should be no need to forecast most of these numbers – they should

emerge automatically from any comprehensive business plan. Obviously, direct jobs are

In contrast, attempting to forecast and then count the numbers of ‘indirect’, ‘induced’ and

‘catalytic’ jobs is a fool’s errand. Each successive category definition (Azimuth vol IV section

3.1.2 to 3.1.5) becomes broader, vaguer and more all-inclusive. ? An ‘indirect’ job in the supply chain could be a cooper in the Scottish distillery that

that makes the braid on the airport security guards’ uniforms. ? An ‘induced’ job seems to include jobs affected by how people in the direct and

indirect jobs spend each and every penny of their income. ? ‘Catalytic’ jobs could be just about anything, the definition is so sweeping –

through a number of mechanisms”. There are simply too many tiny details, too many impacts to be considered, too many

threads to be followed, to allow any meaningful level of accuracy – we’re in the realms of

‘best guess’, anybody’s guess. Once again, Dr Dixon has chosen some high guesses for the multipliers she uses – 2.1 for

indirect and induced jobs, and an additional 4.0 for catalytic jobs. Dr Dixon is telling the world

that every job created in this proposed cargo hub will, in its turn, create 6.1 further jobs. This goes beyond ‘optimistic’, ‘bullish’ or ‘toppy’ – this is fantasy, and it guarantees that any

and all errors made in estimating the DJM value will be magnified and multiplied. A fundamental flaw with counting anything other than direct jobs is that every job in every

industry creates other jobs around the world. However, if every employer were to pad his or

her business case this way, the inevitable double- and triple-counting would lead to a

situation where there are more ‘jobs created’ than people. This is clearly absurd and is a

misleading ‘statistic’ to put before the public. Of course, counting the actual numbers of ‘indirect’, ‘induced’ and ‘catalytic’ jobs is

impossible – they are statistical projections, not individual, identified jobs and people. This

has two consequences. Firstly, it means that there is no evidence base of actual values for

multipliers that can be used to validate RSP’s assumptions. Secondly, it also means that in

the fullness of time, it won’t even be possible to tell whether RSP’s promise was kept, whether the proposal actually delivered the indirect, induced and catalytic jobs that were

promised.This makes it all the more absurd that Dr Dixon’s report should present these tens

of thousands of jobs as if they were factual or inevitable. RSP should set out a clear and evidence-based business plan with a carefully calculated

estimate (not a “mash-up”) of the number of direct jobs that this plan could create. To

suggest that every job at a new cargo airport would create more than 6 additional jobs is to

deliberately mislead the public. To be able to “engage” with RSP’s proposal and to take an

No Night Flights data – map showing a sample of residents who have complained about aviation noise associated with the operation of the

former Manston Airport. The noise complaints clearly extend far beyond RSP’s chosen area of direct communication about the statutory

The ‘noise contour’ maps are taken from the Bickerdike Allen Partners report of August 2010. We have shown only those maps that show the

impact to the east of the airport. The area affected by noise levels of up to 95dBA clearly extends far beyond the area covered by RSP’s direct communication about its