Thursday 30 July 2020

Five Big Ones

Tony Freudmann's latest foray into the land of propaganda seems to have been prompted by adverse comments because more than just the faithful have now been shown the extent of the noise and disruption coming their way.
He has published on RSP's website the following page. View it here

I have published the web page which is viewable at the bottom of the blog however what follows is a detailed investigation of the statements

The art of misdirection is strong in this one so lets take it as it is stated. 
"Even when it is operating at its peak (circa twenty years after reopening)"
Well that's ok then except Tony has no idea when or even if the fixed capacity as laid down in the DCO (17170 cargo ATMs + 9298 passenger ATMs + 38000 General Aviation ATMs = 64468 ATMs which is one aircraft movement every 6 minutes assuming the airport is even successful which isn't guaranteed.

However what is clear from the statement is Tony is prepared to inflict future noise and disturbance on Thanet children simply because he doesn't care one bit.

"Manston Airport will average no more than five large aircraft movements per hour"
So that's all right then? What Ramsgate residents have been used to since 1990, when Manston became Kent International Airport is in the chart below.
Clearly this shows that Manston very seldom had more than 1 flight a DAY now Tony want to inflict 5 movements an hour for 17 hours a day every day 365 days a year.
As an aside all other airports treat night time as 11PM to 7AM but not Tony.

"and will not operate any scheduled services overnight"
The reader will note the use of the word "scheduled" in use here however in the world of Cargo flights the word scheduled is seldom used as the vast majority of cargo flights are not scheduled like most passenger flights. Rather cargo flights into the UK are either belly hold passenger flights (95% of long haul passenger flights have belly hold cargo travelling into Heathrow which by volume is the largest cargo airport with 67% of all cargo into the UK) or they are chartered (non-scheduled) cargo flights arranged on an ad hoc basis when the aircraft can travel full.

An example of this in Manston's history is the African harvest where the customer determines the times the cargo is ready to be flown and the airport grants a slot based on take off and flight time. An example would be cash crops from Africa centrally collected and loaded into an aircraft chartered to fly to the destination when fully loaded
Even Sir Roger Gale understands this when he wrote in 2001 when his buddy ran Manston.

The DCO sets out the maximum capacity for aircraft movements however what the DCO doesn't do is set out the punishments for any abuses such as Night Flights which are monitored by the airport itself.
Careful to tug the heartstrings people ought to remember the British airways training flights which would also come under GA but were large aircraft going round and round for hours.
Clearly 64458 ATMs is one movement every 6 minutes

"minimal impact" what an aircraft movement every 6 minutes including  large cargo and passenger aircraft movements every 12 minutes (5 movements an hour 17 hours a day 365 days a week)
"The numbers are very small" yeah right compared to what? Heathrow, Gatwick, or New York.

Again to repeat the comment above Cargo seldom is scheduled. Most Cargo is chartered and will not fall foul of the restrictions laid out by the DCO, in fact there could be unlimited Night flights.
Interesting that Tony creates a FAQ confirming that they will be so inefficient in unloading an aircraft will take all day to get unloaded. An aircraft doesn't make any money when sitting on the ground, its money is made when it is carrying cargo.
However the DCO places no restrictions on chartered cargo flights both day and night
A nicely swerved answer however most airports impose fines on aircraft that breach the rules especially when it comes to noise and night time disturbance. The Manston DCO is remiss in that it imposes no fines at all.

Finally a word on how Manston will be operated and these are from the RSP application itself . Clearly if Tony was serious about no flights after 11pm then he would arrange for any "late" running flights to be diverted to an airport that had 24 hour operations however that has never been his intention. The 4 main airport operations needed for landing and take off are Air Traffic control, Fire and Rescue,  Airport security, and Operations



I'm sure the reader can clearly see Tony intends an airport that operated on a 24 hour basis


This is the recent page posted on the 29th July 2020




Wednesday 29 July 2020

Memory and noise

Memory and Noise

"Manston Airport has been there for over 100 years"
"I remember the United States Airforce and their noise never bothered me"
"Its always been there and it didn't bother me"
"it only takes 30 seconds to fly over, never bothered me"

We have heard these and more for 6 years from the pro lobby however none can actually say just why it never bothered them, yet those that live under the Heathrow flightpath have complained for years about the noise and pollution from planes flying into Heathrow.
Even Sir Roger Gale spoke in the House of Commons about the effect on his own daughter who lives in Chiswick (a distance from the runway):-

 “I am not remotely unsympathetic to the concerns expressed by colleagues representing seats in west and south London. My daughter has a home in Chiswick under the flightpath to Heathrow. I am a sufficiently infrequent overnight stayer not to have become acclimatised to the air traffic, so I understand what it means, and I also have considerable concern for the quality of the air that my six-year-old grandson, Soren, will breathe during the course of his young life.
HOC link: dated 7/6/2018 

Airports National Policy Statement


So why is it the pro lobby have such fond memories of events that either occurred 60 to 70 years ago (The USAF were at Manston between 1950 and 1958. They actually left because of noise over Ramsgate) or more recently when Manston became an airport in 1989 when it became Kent International Airport (KIA).

As to the 1st it is extremely unlikely that noise events have been remembered properly, especially by such young individuals, what is remembered is perhaps an echo of what the actual event was and that it is fondly remembered is most likely because it was exciting for such a young mind. The fact is after 8 years of noise a deputation from local people, with the Ramsgate Mayor, went up to London to present a petition asking for the USAF to be removed because of the many noise complaints and I seriously doubt anyone is alive today that remembers that event because children didn't take part.

As to recent events, when folks say it never bothers them, the amount of air transport  movements bar 2004 and 2005 (which drove Planestation into receivership) has been so low as to be single events in themselves.
In fact if you look at the actual data from the Civil Aviation Authority for the last 30 years (fig 1) it is obvious just why it never bothered people, only two periods have produced more than 1 landing a day (2003 - 2005 and 2010-2011 with 2013 being an outrider as KLM started a twice daily Passenger route to Schiphol)
fig 1

 It is also clear that if RSP hit their DCO Capacity ceiling the level of noise and pollution will be nothing like Ramsgate has endured in the last 30 years.

If the same regime and disregard for rules as Infratil succeeds then the 20% of Cargo flights that arrived during the night then life in Ramsgate will be unbearable. The pro lobby will point to the DCO which clearly shows night flights aren't allowed however they were banned under Infratil as well yet they still happened.

Even Roger Gale, speaking in September 2001 (when his mate Tony Freudmann ran Manston), said the only way was Night Flights for cargo.

Saturday 18 July 2020

Need


In the advice to the Secretary of State " SoS" (document TR020002-005347-TR020002 Final Recommendation Report to DfT) the examiners:

Examining Authority
Kelvin MacDonald BSc(Hons) FAcSS FRTPI CIHCM FRSA – Lead Member
Martin Broderick BSc MPhil FIEMA – Panel Member
Jonathan Hockley BA(Hons) DipTP MRTPI – Panel Member
Jonathan Manning BSc(Hons) MA MRTPI – Panel Member

set out a complete chapter (Chapter 5) where they discussed "Need" (pages 54-103).
Their conclusion on page 103 stated:

Given all the above evidence, the ExA concludes that the levels of freight that the Proposed Development could expect to handle are modest and could be catered for at existing airports (Heathrow, Stansted, EMA, and others if the demand existed). The ExA considers that Manston appears to offer no obvious advantages to outweigh the strong competition that such airports offer. The ExA therefore concludes that the Applicant has failed to demonstrate sufficient need for the Proposed Development, additional to (or different from) the need which is met by the provision of existing airports.

This report was written in the 3 months after the examination concluded in July 2019 and passed to the SoS for the Department of Transport "DoT" to make their decision. In January 2020 the DoT delayed the decision and then further delayed this to the 10th July. The decision was announced on the 9th July and was a Yes against the advice given by the four experts noted above.

What the Examiners would have been unable to forecast was the Coronavirus Pandemic which has decimated the aviation industry.
This collapse of short and long haul flights has has two consequences:
1. The airport which handles most air freight is Heathrow. 67% of all air freight is carried in the belly of long haul passenger planes and this has dropped by 90% and according to most experts will not recover for 3-4 years.
2. This has meant air freight will need freighter only aircraft to carry freight for the next 3-4 years providing a boost to this niche market.

The problem for freight managers is consumer confidence is still low so the demand has also dropped and most of the World will enter a recession and currently no expert can predict when this will recover.
If freighters are to be used the upside is there is plenty of slots at all the airports to cater for this usage, certainly enough to not need a new airport in the South East for the foreseeable future.

To get back to the report I will not seek to post all 50 pages but will concentrate on the conclusions, the viewer can read the full report by clicking in the link above.


5.7. CONCLUSIONS (page 98)
5.7.1. The ExA is mindful that the ANPS does not have effect in relation to an application for development consent for an airport development not comprised in an application relating to the Northwest Runway at Heathrow and associated proposals for new and reconfigured terminal capacity and, therefore, the application is examined under s105 of the PA2008.
5.7.2. Nevertheless, the ANPS remains an important and relevant consideration in the determination of such an application, particularly where it relates to London or the South East of England.
5.7.3. Government policy states that the Government is minded to be supportive of all airports which wish to make best use of their existing runways, including those in the South East (ANPS paragraph 1.39).
5.7.4. The ExA considers that the Applicant’s forecasts, when seen in the light of the historical performance of the airport seem ambitious. Previously the airport did not go above around 50,000 tonnes of cargo and 200,000 passengers a year, compared to the 340,000 tonnes and 1.4mppa forecast now.
5.7.5. The ExA accepts in this context that the investment levels proposed for the airport are at a different level to that previously spent on the site and notes anecdotal evidence that British Airways was previously in discussion with Infratil but pulled out due to a lack of investment and failure of the operator to provide a state-of-the-art facility. However, conversely SHP make reference to Wiggins Group investing £6 to 7m on new aprons and taxiways to increase freight capacity to 200,000 tonnes per annum [REP5-028].
5.7.6. Although to a certain extent it may be a cause and effect situation, it is also reasonable to suggest that the previous operators of the airport, either Wiggins Group (of which one member of the Applicant’s team was also involved) or Infratil, an experienced airport operator, would have invested more heavily had there been a reasonable prospect of this investment being repaid through increased traffic levels. While at this time the new integrators were not around, Heathrow and Gatwick were at similar levels of constraint.

Capacity
5.7.7. The third runway would clearly add to capacity substantially at London Heathrow. The ANPS states that the Government estimates that a new runway at Heathrow would result in an additional 43,000 long haul flights. This would provide more space for cargo, a greater frequency of services, and boost trade and GDP. It appears to the ExA that Heathrow would be able to accommodate the projected 3m tonnes of air freight per annum in due course and that more markets would likely be served by routes from the Northwest Runway at Heathrow, should demand exist. Heathrow is the dominant airport in the UK for air freight, and the proposed third runway would build upon this, providing significant new opportunities for bellyhold freight via new long-haul routes. While the 3m tonnes of freight would not be achieved overnight it would be a substantial uplift from the almost 1.7m tonnes carried in 2017 and supply could rise roughly with demand.
5.7.8. London Stansted has reached agreement, subject to the signing of a Section 106 Agreement with Uttlesford DC, to increase caps on the airport from 35mppa and 274,000 air movements including 20,500 air cargo movements, to 44.5mppa and 285,000 movements respectively. While a substantial part of the business at Stansted is passenger focused, the Airport clearly provides an important base for freight, with capacity for both integrator traffic (Fed-Ex) and general freight. The Applicant’s view is that Stansted airport has made a strategic choice to prioritise passengers over freight but this is not objectively supported by the evidence.
5.7.9. Stansted is clearly a busy airport and becoming busier. However, from the evidence provided there appears to be a degree of capacity left at the airport, including for freight movements with the airport forecasting a growth to some 376,000 tonnes per year by 2028 from a level of 236,892 tonnes in 2017, involving 16,000 cargo movements a year (from 10,126 in 2017) and an increasing amount of bellyhold cargo alongside the predicted growth in passenger numbers.
5.7.10. EMA is a major integrator hub with significant growth potential. Given levels of passenger throughput at the airport, it is unlikely that there will be significant strategic conflicts between passenger and cargo traffic. The ExA does not consider that there is ‘substantial circumstantial evidence’ that there is likely to be little if any scope for general cargo operators to stay overnight at EMA and it appears that the airport seeks to attract both integrator and general freight traffic. Evidence is also noted of germinative Amazon Air operations at the airport (via DHL), and the substantial new warehouse and sorting centre adjacent to the airport [REP05-029].
https://www.nwleics.gov.uk/pages/east_midlands_gateway DCO granted

Demand and forecasts
5.7.11. The ExA does not agree that zero growth forecast by the DfT is a pragmatic view due to lack of capacity; the Department does not claim to model freight in detail and have labelled it as an assumption. From the evidence provided there is no clear view of the levels that demand for air freight may grow, but levels of growth that do occur are likely to be accommodated by the proposed new runway at Heathrow, should this occur.
5.7.12. Should this not occur, there may be more demand available elsewhere, although given the preponderance of facilities in northern Europe it may be that this increases trucking levels rather than leading to a substantial growth in levels of freight being handled at other UK airports. Furthermore, growth in bellyhold at Gatwick and at other airports outside the South East may occur.
5.7.13. The Applicant’s Azimuth Report [APP-085] is a comprehensive document but the weight that the ExA can place on its forecasts is reduced by the lack of interview transcripts available, and of the size and sample frame of many of the interviewees, when considering the size of the forecasts that are generated and there is little evidence that academic and industry experts have validated the approach of the Azimuth Report. Furthermore, there is little evidence that capacity available elsewhere such as at EMA, or the impact of the proposed Northwest Runway at Heathrow have been taken into account in the production of the forecasts.
5.7.14. The Northpoint Report [REP4-031] provides a valuable alternative source to ‘back up’ the Azimuth Report. However, the limitations identified within its model, particularly those considering the scope for migrating between types of carrier and the impact of price (particularly when considering differences between bellyhold and pure freight, and trucking) appear to the ExA to be substantial limitations in the case of the Proposed Development and a more detailed model assessing such variables was not available to the ExA.
5.7.15. The forecasts of Boeing and Airbus are useful in terms of noting overall levels of global air cargo growth and provide support for the Northpoint analysis. The ExA do note however the previous considerable overestimation of the number of freighters by these aircraft manufactures.
5.7.16. The Avia Solutions Report forecast [REP3-276 report available in Library] provides a comprehensive view of the viable potential of Manston Airport. The ExA note that this report is independent; the brief from TDC did not indicate any desired outcome and required an independent assessment advising whether or not it is possible to run a viable and economically sustainable free-standing airport operation from Manston. While the report was written in 2016 this remains relatively recent and it concludes that, even with a generous assumption over air freight captured from trucking, airport operations at Manston are very unlikely to be financially viable in the longer term, and almost certainly not possible in the period to 2031.
5.7.17. While the Avia Solutions Report’s conclusions were based on viability, this arises in the report from the authors’ assessment of potential and forecasts for the airport – in other words, the need for the development. Also of note is that the report considered capacity squeezes and a major retail group, akin to Amazon basing themselves at the airport; neither possibility led to a different conclusion. Due to the independence and depth of this report, the ExA place significant weight on its findings.
5.7.18. On the basis of the evidence provided, the ExA considers that the predominance of bellyhold freight in the UK market as opposed to pure freight is to a large extent a by-product of the dominance of Heathrow in the UK aviation market. The effect of the size of Heathrow, and the vast range of destinations that are available from this hub airport have led to the strength of bellyhold freight for UK purposes, particularly when coupled with the relative ease of access to the large hub airports and pure freight airports in northern Europe. Trucking is a necessary mechanism to complete this overall market pattern and allows access to the population and manufacturing capacity of northern Europe. In the ExA’s view air freight would still primarily be attracted to the airports with the widest possible global networks for reasons of economies of scale.
5.7.19. It also appears logical to the ExA that bellyhold freight would be significantly cheaper than pure freight and that this in itself also helps to explain the dominance of bellyhold over pure freight, with much pure freight dedicated to express integrators who can charge more for express delivery times.
5.7.20. The Applicant considers that Manston could act in a complementary role to bellyhold freight at Heathrow and integrator freight at EMA.
5.7.21. However, the ExA’s analysis of the predominance of bellyhold freight in the UK (above) suggests that there is little complementary role to be had – while some oversized freight items may be too large or bulky for bellyhold travel, the vast majority of general freight can be carried in bellyholds.
5.7.22. A useful point is made by the Applicant noting that the cargo industry is fundamentally changing, and that this change needs an innovative response which cannot be provided at constrained South East airports. However, the change proposed by the Applicant appears to be largely based on new integrators who would offer similar comprehensive delivery patterns and structures to established integrators but with less strict time restrictions. In the view of the ExA then the likely locations for such integrators are likely to be closer to the centre of the country than Manston. While Manston can clearly offer good quick access to London and much of the South East*, a more central positions within the UK offers more potential customers than just London and the South East can provide; within a three hour drive from Manston only the South East and parts of the East of England can be reached, whereas most of England and Wales is within three hours of EMA.
* Editor's note: The conclusion (tempered by the second sentence is slightly odd considering Heathrow is served by the M4 and M25, Gatwick by the M23 (with the M25 20 minutes away), and the East Midlands by the 8 lane M1. Manston is dual carriageway until the Hoath Way junction on the M2 some 35 miles away with a further 10 miles to the M25 and Dartford river crossing which for those in the area hold ups are a regular occurrence especially at the river crossing.

Summary
5.7.23. The ExA is not convinced that there is a substantial gap between capacity and demand for general air freight within the South East at present. Capacity is available or could be available at other airports within the South East or at other airports within reach of the South East should the demand exist, and such capacity could largely be achieved relatively simply through permitted development rights or existing facilities.
5.7.24. The ExA is of the opinion that general air freight would continue to be well served in the UK with spare capacity at Stansted in the short term (to 2030) and the proposed Northwest Runway at Heathrow in the longer term, and that new integrators are more likely to wish to be sited in a more central location. If constructed and operated then the Proposed Development could carry out a role within the market focused on perishables and oversized niche freight as previously but it seems unlikely that tonnage achieved will be significantly more than previously handled. Without the proposed Northwest Runway at Heathrow more demand may be available but the ExA’s conclusions relating to new integrators, that is that they would be more likely to base themselves in a more central location to their other logistical operations, remain valid.
5.7.25. The Applicant argues that price is not the only determinant in where freight business may go – factors such as facilities, speed, handling efficiency and location all count too. While the ExA agree with this view, it seems logical to assume that price is the main component in any decision made and that bellyhold freight will generally be cheaper. If demand were present, then facilities could be constructed at other airports where speed and handling efficient could be largely matched to the Applicant’s plan and the ExA is not convinced that the location of the Proposed Development is entirely favourable.
5.7.26. In terms of passenger traffic, the full extent of the Azimuth Report forecasts [APP-085] may be difficult to reach. However, the ExA considers that there would be a market for passenger traffic from the airport although the extent to which such traffic would be viable for the airport operators has not been assessed in depth.
5.7.27. GA was not examined in depth in the Examination, and the Azimuth Report [APP-085] does not cover the subject in detail. Nevertheless, the ExA notes the support for GA facilities in the APF and the NPPF (paragraph 104) and the representations received on this matter.
5.7.28. Appendix 1 of the Applicant’s Overall Summary of Need Case [APP11-013] states that little weight should be afforded to the submissions of SHP given the withdrawal of this company’s objection to the Proposed Development *. In this context however the ExA note the comments of York Aviation, which states that they strongly refute criticism of their work by the Applicant in its written answers and consider that they have “provided substantial and well evidenced responses throughout the process” [REP11-070].
* Editor's note The request by SHP to withdraw its representations was made less than five hours before the Examination closed at 23:59 on 9 July 2019. On that basis, the ExA determined that it was received too late in the Examination for the ExA to properly consider the request or the implications for other Interested Parties. SHP’s representations therefore remain part of the Examination Library. This determination has been communicated to IPs via the s51 advice pages on the National Infrastructure Planning website.
 
Given all the above evidence, the ExA concludes that the levels of freight that the Proposed Development could expect to handle are modest and could be catered for at existing airports (Heathrow, Stansted, EMA, and others if the demand existed). The ExA considers that Manston appears to offer no obvious advantages to outweigh the strong competition that such airports offer. The ExA therefore concludes that the Applicant has failed to demonstrate sufficient need for the Proposed Development, additional to (or different from) the need which is met by the provision of existing airports.


Friday 10 July 2020

Perverse

Having waited through delay and further delay finally the Minister has made a decision over the Manston site. Far more than the decision it was important to finally get to see how all the evidence had been received by the Examiners, the report can be viewed here

Taking the decision first:
The decision deadline was delayed twice and the inspectors recommended refusal but on 9 July 2020, one day before the latest deadline, the Secretary of State for Transport (in fact, Minister of State Andrew Stephenson, because Grant Shapps had previously expressed support for the project), granted consent for the Manston Airport Development Consent Order.

Now a look at the ExA (Examining Authority) itself:

  • Project: a primarily cargo airport near Ramsgate in east Kent;
  • Promoter: RiverOak Strategic Partners Ltd;
  • Application made: 17 July 2018;
  • Four inspectors, Kelvin MacDonald (his sixth), Martin Broderick (his sixth), Jon Hockley (his first), Jonathan Manning (his first);
  • 2074 relevant representations, very high;
  • 198 written representations, very high;
  • 551 questions in the first round, high;
  • two compulsory acquisition hearings, eight issue specific hearings and four open floor hearings – high;
  • four Local Impact Reports, from Kent, Thanet, Dover and Canterbury;
  • examination exactly six months, recommendation nine days over three months, decision nearly nine months, ie nearly six months late;
  • 723 days from application to decision, just under two years, the third longest to get consent; and
  • 2,005 documents on the Planning Inspectorate web page on the date of the decision (not including the relevant representations), very high.
Now a look at the report:
Written by Four inspectors, Kelvin MacDonald (his sixth), Martin Broderick (his sixth), Jon Hockley (his first), Jonathan Manning (his first)

Their conclusions

In conclusion
So it seems that a Minister who says:

Whilst noting the ExA’s consideration of need [ER 5] and conclusion that the Applicant’s failure to demonstrate sufficient need weighs substantially against the case for development consent being given [ER 8.2.25 - 8.2.26], the Secretary of State disagrees and concludes that there is a clear case of need for the Development which existing airports (Heathrow, Stansted, EMA and others able to handle freight) would not bring about to the same extent or at all.

The Secretary of State’s conclusions on the need for the Development are set out above in paragraphs 20 and 21 and, whilst noting the ExA’s view that the jobs created would not be to the same extent as forecast by the Applicant [ER 8.2.183], he concludes that significant economic and socio-economic benefits would flow from the Development to Thanet and East Kent as well as more widely including employment creation, benefits to general aviation and regeneration benefits. In reaching that view, the Secretary of State notes the ExA’s view that the Development may adversely affect the tourism industry in Ramsgate. Whilst he is sympathetic to any residents and business holders that may be affected, he also notes the ExA’s overall view that it would increase the attraction of tourists to other parts of Thanet and the wider East Kent area 

You can read the full justification in the decision letter

One might ask how 4 experienced Examiners could be so wrong. 
You might ask just what relevant experience  Andrew Stephenson brought to the decision making process. 
One might ask why two Conservative MP's have been so vocal in their support for an entity controlled in Panama, and why a Conservative Minister can overturn the conclusion of said experienced Examiners.

This decision feels so irrational that it should be assessed in the Courts at a Judicial Review

The courts may intervene to quash a decision where they consider it to be so demonstrably unreasonable as to be “irrational” or “perverse”. The test is whether a decision “is so unreasonable that no reasonable authority could ever have come to it”. In practice this is very difficult to show, and it is usually argued alongside other grounds.