Manston Airport
A Nationally insignificant Infrastructure
Project
Barry James | NSIP | 23/1/2019
Foreword
As we wrote this and read all the reports
that dealt with Aviation connected with Manston is became apparent that
“experts” had a different way of interpreting the many statistics involved. It
also became clear that even the same statistics had different interpretations
dependent on whether the information was being used to defend or attack
aviation use at Manston. It is hoped that we have tried to remain neutral in
our report.
Even when the same report was used to back
the claim that Manston was viable important statistics have been selectively
interpreted to benefit that viability. As an example Boeing wrote a report
stated worldwide aviation would (in their opinion) grow by 6%. What was ignored
was this applies to passenger growth and the Manston DCO is for a Cargo Hub
using cargo freighters and not passenger planes with bellyhold cargo.
Executive Summary
To be a Nationally Significant
Infrastructure Project (NSIP) Riveroak Strategic Partners (RSP) have to show
that the UK would benefit from the reinstatement of Manston Airport and that
taking the land from the legal owners would benefit the greater need of the
population at large. The case for this they have failed to do simply because
that need (for a cargo hub handling air freighters only) is simply not required
in the United Kingdom and that current capacity restraints will not be reached
until 2050 at the earliest if at all. *2
− • There is no overall shortage of freight capacity in the UK or
South East specifically. While Heathrow is constrained, there is significant
spare freight capacity at the established dedicated freighter hubs at Stansted
and East Midlands.*1 Exec summary
− • Cargo activity in the UK has become much consolidated on the 3
cargo hubs (Heathrow, Stansted and East Midlands). All three of these airports
have plans to significantly expand cargo capacity, and they forecast strong
growth in cargo tonnage. Furthermore, other established passenger airports have
the capability of handling much higher cargo volumes if demand existed. *1
exec summary
− • There has been a strong trend towards bellyhold freight, with the
role of dedicated freighters diminishing. The most recent (2017) Department for
Transport (“DfT”) forecasts to 2050 assume the number of freighter flights in
the UK will remain flat at 2016 levels.*1 exec summary
−
• Trucking is a highly
integrated component of the air freight business model, and not merely a
substitute for air freighter flights when airport capacity is constrained. The
increasing use of truck feeder services is due to cost efficiencies and is not
restricted to the UK. *1 exec summary
− • Manston is in a poor location to serve the wider South East or UK
market. Other structural disadvantages include lack of critical mass, lack of a
passenger hub, and night flight restrictions. These factors have limited
Manston’s role to that of a niche freight airport. *1 exec summary
This is analysed
under the heading freight market
− Further there are the following reasons to worry about the
submission as follows
− 2. Why would the
Planning Inspectorate grant a DCO to a UK shell Company with control hidden behind
an offshore corporate veil in a Belizean Tax Haven, and especially one that is
depending on raising the finance AFTER the DCO is granted? (RSP seem not to
have any income unlike many infrastructure companies)
− 3. Without a cap on ATMs why
hasn’t RSP considered a Public Safety Zone (PSZ) at each end of the runway?
− 4. It seems from the
submission that the Northern Grass zone isn’t needed as it isn’t fundamental to
the operation of a cargo hub so why is it included in the CPO powers asked for?
− 5. Why are the (only) two
noise monitors positioned 6.5km from the runway (placing the Ramsgate one in
the sea) when Central Ramsgate is 3.2KM from the runway?
− 6. Why have RSP reversed the
conventional wisdom of landing and taking off INTO the wind? 20 years of commercial
aircraft flying dictates the predominant wind is from the South West over the
UK which would mean that 70% of cargo flights would overfly Ramsgate on landing
and take-off over Herne Bay.
7. How have RSP
come to the conclusion that the Manston site is worth £7.5M when “In Spring
2006 Kent County Council acquired the undeveloped area of Manston Business
Park, amounting to some 40 acres of developable land, from the Administrator of
Planestation plc for £5.35 million”? (*5 KCC-Position-Statement-on-Manston-Airport
page 7)
8.
Justification for NSIP, We would like the Tribunal to ask RSP why they haven’t
considered any of the surplus airfields in the middle of the country. For
instance both Mildenhall and Lakenheath are looking for buyers and have far
better motorway connections without a town of 40000 inhabitants at the end of
the runway.
9. Environment
RSP confirm within their documents that the effect of
noise and pollution would have an adverse effect on the residents of Thanet
“12.7.72 Considering the impact is permanent and a large number of
dwellings…………….significant adverse effects…….Ramsgate, Manston, Wade and West
Stourmouth” One has to consider that the
possible benefit to the Community at large is outweighed by the detrimental
effect on the Residents in the above towns. (Our emphasis) Further there is
another potential environmental risk being glossed over, that is, the volume of
heavy goods and fuel bowser vehicles proposed along the Thanet Way daily.
1. FREIGHT MARKET
Overview of the UK Freight Market
In 2016 the total freight market in the UK
amounted to 484 million tonnes which includes shipping, road haulage and air
freight. The airfreight proportion of this market has averaged 2.3 million
tonnes which equates to ½ of one percent. This is hardly surprising considering
the relative cost of each element with shipping being the most cost effective
followed by road haulage and airfreight being up to 4x the cost of shipping by
sea.
What has also been a trend since 2004 is
freight sharing with passenger flights. This is called bellyhold freight and
significantly reduces the overall cost due to cross subsidies and makes up 95% of
all freight tonnage at Heathrow the UK’s biggest freight airport.
Both these trends count against Manston
because passenger numbers are constrained by the catchment area and the
determination of RSP to state their preferred route is freighter only.
From 2006 to 2016 the study of the individual
freight airports show that bellyhold freight has been increasing to the
detriment of air cargo freighters. E.g. Heathrow has increased its total amount
of freight handled by 17.5%. From 2006 to 2016 the total freight handled in the
UK has increased by a paltry 2.58% (2.31 Million tonnes to 2.38 million tonnes
over the same period). East Midlands increased by 9% and Stansted by 9.5%.
Obviously with these taking more of a share other airports have gone backwards,
Gatwick for instance has lost 50% of its airfreight business in the last 10
years.
However a cargo NSIP only has to prove that
they will achieve 10000 ATM’s and not the freight tonnage which in theory could
mean 5000 aircraft landing and taking off empty which would be hardly
sustainable considering the capital expenditure needed to open the airport.
Overall, 29.7% of UK air freight in 2016
was carried on cargo only aircraft, with 70.3% carried in the bellyhold of
passenger aircraft.
The Department of Transport (DfT) recently
released a report “Moving Britain Forward” *2
The following is from the freight element
of the report and clearly shows that the DfT believes that freighter only ATM’s
are in decline and with the choosing of a 3rd runway at Heathrow
this trend will almost certainly continue. With both Stansted and East Midlands
both expanding capacity the chance of there being a market for Manston is
receding every month it remains closed. Further recent (2016 and 2017) freight
tonnage into and out of Gatwick show above average increases due to their
management making increasing use of long haul bellyhold freight. They are still
only 50% of the 2006 (CAA figures) so can still mop up any constraints found at
Heathrow.
Manston Airport history
Manston has had a civilian conclave since
1959 but since 1989 after it changed the name to Kent International Airport it
became dependent on passenger charters and freight however no matter what it
renames itself it is only likely to be involved in a niche market because of
its geographical position. At its closest it is an hour from the A2/M25
junction adding considerably to the costs of any freight forwarder.
Taking the Civil Aviation Authority (CAA)
figures from 1990 to 2014 it is apparent that cargo has only ever been marginal
compared to the rest of the freight airports such as Heathrow, East Midlands
and Stansted however what it does show is that the average load per ATM during
the 24 years of operation was 44 tonnes and this is not reflected in the forecasting
by Dr. Dixon.
Several reports have stated the reasons why
Manston would not succeed and these include the following points:-
“Note that at no time in the period since
1990 has Manston played a significant part in the UK air freight market. Its
share peaked at 2.0% in 2003, and in the 5 full years prior to its closure in
2014 (2009-13), it had an average share of 1.3%. The number of cargo ATMs only
exceeded 1,000/year on a single occasion since 2000 (1,081 in 2003), averaging
462/year in the 2009-13 period”
“Although there are no local airspace
restrictions, Manston lies beneath some of the busiest cross channel airways
giving access to Europe and so movements would need to share airspace capacity
with heavy traffic flows to and from the main London airports.”
“Rapid turnaround times that Manston has
achieved when handling one or two planes a week. There is no evidence that this
could be maintained at higher volumes – in fact, the longer turnaround times at
other, busier, airports suggests that it cannot”
“With enough stands, and warehousing and
terminal space, Manston could handle a lot of traffic, but that doesn’t mean
that it will. In fact if it were this simple why didn’t Wiggins/Planestation
and Infratil not build more stands instead of asking for night flights”
Even under previous configurations of the
airport they should have been able to handle 21000 cargo ATM’s however because
of the geography of the site few Cargo freight forwarders considered it a
viable option. In point of fact Gatwick is considered too far south and since
2006 they have lost 50% of their freight tonnage.
Azimuth Associates
Dr. Dixon has written a report (https://infrastructure.planninginspectorate.gov.uk/wp-content/ipc/uploads/projects/TR020002/TR020002-002459-7.4%20-%20Azimuth%20Report.pdf
to explain just why RSP believe Manston is an NSIP, however many more experts
have repudiated all of her forecasts (this includes the figures in York
Aviation’s reports that she quotes in her forecasts). It does seem rather
strange that the only report in support of a Cargo Hub at Manston (and there
have been a few) is the one written by Dr. Dixon.
Azimuth Associates (Dr. Dixon) has produced
a series of forecasts with the intent of “proving” RSP’s contention that
reopening Manston would be an NSIP (an NSIP in cargo aviation terms is 10000
air traffic movements (ATM’s)) however it is particularly noticeable that she
has worked backwards to achieve this aim instead of looking at Manston’s past
performance and working forward. Several reports have clearly stated that her
forecasts are simply unrealistic. (Altitude Aviation and York Aviation’s (*3)
reports)
We are, however, more concerned about the
fundamentals of the way in which she approaches her forecasts. The NSIP
requirement is for 10000 ATMs which historically Manston has never achieved. In
fact from 1990 until 2012 (22 years) Manston failed to achieve 10000 ATMs at
all and yet according to Dr. Dixon RSP will achieve that magic figure inside 7
years simply by increasing the number of aircraft stands from 2 to 19.
Something is simply wrong.
From Dr. Dixon *4
With reference to the previous history of
Manston, compiled over a 24 year period, it shows that every ATM averaged 44
tonnes of cargo which is an historical fact and should have been the basis for
the forecast. Notwithstanding RSP have failed to produce a meaningful business
plan breakdown it makes sense to look at where Manston’s niche market lay.
Using this as a basis and comparing it to
the figures produced by Azimuth it becomes apparent Dr. Dixon has chosen to
reduce the tonnage per ATM simply to ensure the 10000 ATM’s are reached.
|
Year
|
Azimuth ATM
|
Azimuth Tonnage
|
Average per ATM
|
Historical ATM
|
Tonnage
|
Average per ATM
|
|
2
|
5252
|
96553
|
18.38
|
2194
|
96553
|
44
|
|
5
|
9936
|
173741
|
17.48
|
3948
|
173741
|
44
|
|
10
|
11600
|
212351
|
18.30
|
4826
|
212351
|
44
|
|
15
|
14113
|
270579
|
19.17
|
6149
|
270579
|
44
|
Extrapolated from the CAA and Dr. Dixon’s report
Using the appropriate, more cost effective
cargo tonnage it does show that even after 20 years the figure of 10000 will
not be reached. It may be that RSP wants to attract far smaller freight planes
however even then freight planes would on average carry far bigger loads than Dr.
Dixon utilises.
Notwithstanding the above it is still our
contention that even these figures will not be reached due to the previous
reasons quoted.
2. FUNDING
On the acceptance of the DCO the Planning
Inspectorate wrote to RSP to advise them on the terms of them being accepted
for Examination. This letter dated 14th August 2018 made it clear
there were several areas that needed immediate work BEFORE examination. The
Funding Statement (document 3.2) was clearly singled out as being subject to
revision “As reflected in Box 30 of the Checklist, the Inspectorate considers
that the Funding Statement poses substantial risk to the examination of the
application.” We couldn’t agree more. Further it clearly want more information
on the following:
·
In the generality, further evidence that adequate funds will be
available to enable the Compulsory Acquisition of land and rights within the
relevant time period.
·
Further information in respect of Riveroak Strategic Partner’s (RSP)
accounts, shareholders, investors and proof of assets.
·
Further clarification in respect of the term “completion of the DCO”
(Funding Statement para 12, 13, 27).
·
Further details of RSP’s Directors, staff, auditors etc.
·
Further details of the funders who have already expressed interest
and others that are likely to come forward (Funding Statement, para 23).
·
Further justification as to why Article 9 of the draft DCO is
appropriate and provides sufficient security for individuals in consideration
of the provisions of the Human Rights Act 1998.
·
Further information on the sources and availability of funding for
the Noise Mitigation Plan.
·
Further information on the joint venture agreement (Funding
Statement, para 19 etc.).
·
Further details of how the costs set out in the Funding Statement at
paragraph 15 have been estimated.
·
Further evidence to support various statements such as:
·
“The investors are willing to underwrite the cost of any blight
claims or eventual claims in compensation […]” (Funding Statement, para 10).
·
“Riveroak anticipates that it will raise further equity and debt
finance following the making of the DCO in order to develop the authorised
development to completion” (Funding Statement, para 11).
·
“[Riveroak] have drawn down £500,000 from their investors” (Funding
Statement, para 20).
Point 1 is the compensation to the owners
in the event the DCO (and CPO) is granted and is based on a valuation by CBRE
of £7.5M for the 720-800 acres. This valuation can only be derisory as based on
previous valuations and purchases, notably the purchase in 2005 by KCC “In
Spring 2006 Kent County Council acquired the undeveloped area of Manston
Business Park, amounting to some 40 acres of developable land, from the
Administrator of Planestation plc for £5.35 million” (*5 KCC-Position-Statement-on-Manston-Airport
page 7)
Further in 2005 Infratil purchased the
airport from the administrators of the defunct Planestation for a figure of
£17M
From KCC report (*5 KCC-Position-Statement-on-Manston-Airport
)
From the 1st example and without
inflation the developable land should be worth around £100M and from the second
at least £25M (with inflation).
The whole structure has been designed to
obfuscate the real ownership of RSP and to hide the source of funds and who
controls the entity.
RSP is a series of shell companies
registered in the UK but controlled by an entity, MIO Investments Limited,
which is based in Belize. These UK registered companies include the following
entities
It is understandable just why the Planning
Inspectorate is concerned about “Further information in respect of Riveroak
Strategic Partner’s (RSP) accounts, shareholders, investors and proof of
assets.” As the ultimate control is masked within M.I.O. Investments Limited
based in Belize.
Further RSP confirm that they do not have
the funds to complete the DCO process only that they say “Riveroak anticipates that it will raise further equity and debt finance
following the making of the DCO in order to develop the authorised development
to completion” (Funding Statement, para 11).
The final point that the PI identify “[Riveroak] have drawn down £500,000 from
their investors” (Funding Statement, para 20) is an oddity in itself seeing
that this £½ million seems to have been placed in a separate legal entity
“Freudmann Tipple International Limited (05429140)”
3. PUBLIC SAFETY ZONE
Our submission notwithstanding that 10000
ATM’s are unachievable RSP should have considered whether Manston Airport needs
a PSZ because they state that the potential number of ATM’s is 83220 and they
also state they will not cap the number of flights. The logic says that both
83220 and PSZ’s are potentially capable they should be considered together (worst
case scenario)
The area of a Public Safety Zone
corresponds to the 1 in 100,000 individual risk contour for an airport. These
tend to be two triangular shapes extending out for 3-4 kilometers from either
end of the runway. Whilst aircraft follow a number of routes surrounding an
airport, 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 triangle.
The last Masterplan done for Manston in
2010 (*6 page 22) acknowledged that its PSZ should have been done in 2006. It
was not. But by looking at other airports and knowing the pattern of aircraft
take off and landings at Manston it is possible to gauge the likely shape of
the PSZ that would affect Ramsgate.
The number of variables to be taken into
consideration when determining the risk contours are:
• Annual
traffic movements
• Maximum
Take-off Weight Authorised (MTWA)
• The
crash consequence model includes population density
• The
number of crashes per million movements done by using crash rates for each
aircraft class
• The
crash location model for large and light aircraft
(2009-11-KIA-Master-Plan-Final-Infratil)
Aircraft landing at Manston used to line up
at 300 metres above the harbour and descended across the most densely populated
area of Ramsgate to the runway at the edge of town.
The 1 in 10,000 contour would most likely
be a triangle extending a 1-1.5 km beyond the end of the runway. The 1 in
100,000 contour, and thus the PSZ, would extend approximately 3.5-4km from the
end of the runway. It would cover a substantial area of Ramsgate right down to
the harbour and including part of the town Centre. Three schools, Clarendon House
Grammar School, Christ Church Primary School and Ellington Infant School, are
within the 1 in 100,000 risk contour.
The 1 in 10,000 risk contour would include
a number of residential streets on the Nethercourt Estate, It also includes
the, as yet unbuilt, estate to be named Manston
Green. This new estate of some 785 dwellings, given planning permission
prior to the consultations, isn’t even mentioned in the 10500 pages of the DCO
submission and has not even been considered for compensation purposes but lies
well within the PSZ for a busy airport. These residents would need to be moved
and in the case of Manston Green the developer would need to be compensated for
the loss of their development.
Position of Manston Green development.
4. NORTHERN GRASS
Without going into a great deal of detail
it is apparent that much of the land north of the B2050 isn’t required by RSP
in their pursuit of achieving 17000 ATM’s. To make it clear from section 3 we
do not believe this number of ATM’s is achievable either however in the
interest of fairness we will assess their needs notwithstanding.
There are other Aviation experts who will
deal with the detail however just to be clear we reproduce a map of the area we
believe isn’t required to run a cargo hub.
Reproduced from a report dated November
2017 York Aviation *7 SHP-York-Aviation-Summary-Report-Final pg 57
From the same report they believe that a
cargo hub could be run perfectly well, notwithstanding the ATM’s aren’t
possible, and they believe the surplus land would be used to cross subsidise a
loss making cargo hub.
“4.19
No other justification is given for the extent of the commercial development
shown on the ‘Northern Grassland’ part of the site. In our view, it is
certainly not ‘associated development ‘required to support the operational
airport, other than in terms of providing a financial cross subsidy from rental
income for general commercial buildings.” And further
“4.24
We can see no justification for the inclusion of the ‘Northern Grasslands’
within the DCO as associated development as there will be little requirement
for the relocation of freight forwarding activity from adjacent to the UK’s
main cargo hub at Heathrow to Manston and any requirement could be accommodated
south of the B2050. The development on the Northern Grasslands site appears to
be speculative commercial development which, based on the precedent at East
Midlands Airport – the UK’s principal airport for pure freighter operations –
would be expected to be largely for non-aviation related uses.”
*7 SHP-York-Aviation-Summary-Report-Final
pg 58
5. NOISE MONITORING
The DCO clearly states that they will be
monitoring the noise from aircraft landing and taking off by positioning 2
noise monitors 6.5km from the runway. This, however, isn’t possible at the
Ramsgate end of the runway. Ramsgate at its closest is 1.2KM and at the harbour
is 4km and even allowing for where the aircraft starts rolling 6.5KM will
terminate in the main shipping channel. Whoever wrote that statement obviously
has no idea how close a town of 40000 people is from the end of the runway?
6. LANDING AND TAKE-OFF
20 years of commercial aircraft flying
dictates the predominant wind is from the South West over the UK which would
mean that 70% of cargo flights would overfly Ramsgate on landing and take-off
over Herne Bay. Within the Environmental statements RSP seem to imply that this
20 years of practice will be changed to the complete opposite which is rather
odd seeing as aircraft land into the wind for stability and also take-off into
the wind to facilitate a smoother lift.
70% of all landings are over Ramsgate
because of the wind and only 30% of take-offs are over Ramsgate. Clearly this
will have to be examined but using conventional wisdom 7000 landings a year
will be from the harbour to Manston and 3000 take-offs will be over Ramsgate
generating the following noise contours.
Landings from the East Boeing 747
Take off to the East Boeing 747 noise contours
at 85, 90, and 95 Db
7. VALUATION
See section 2
8. Justification for NSIP
We would like the Tribunal to ask RSP why
they haven’t considered any of the surplus airfields in the middle of the
country. For instance both Mildenhall and Lakenheath are looking for buyers and
have far better motorway connections without a town of 40000 inhabitants at the
end of the runway.
Nowhere in the document “TR020002-002382-2.3
- NSIP Justification” does it mention whether other surplus airfields have been
assessed.
In the document “TR020002-002386-3.1 -
Statement of Reasons” there is the following
“4.10
A cargo-focused airport at Manston Airport would meet that need as it has
several advantages:
4.10.1
A long runway that can accommodate all types of aircraft;
4.10.2
Close to London but outside congested London airspace;
4.10.3
A focus on freight rather than passenger flights and significant airport
capacity will provide a reliable and thus attractive service to freight
companies; and
4.10.4
Dual carriageway or better access to the M25, London and the Channel.”
Nowhere however have RSP considered that
Mildenhall or Lakenheath, both surplus and operational, could meet the needs of
their cargo hub without the need for a DCO and CPO powers. Both airfields are
more central, would meet the needs of a hub and are closer to the market. Being
as they are both close to the A14 (access to the midlands and the seaport of
Felixstowe) and M11 (access to the M25)
There, of course, maybe other surplus
airfields as both the USAF and RAF continually review their requirements.
9. Environment
Within their documentation RSP state that
there would be adverse effects on the Ramsgate population but they think that
their uncosted (as in derisory payments without sufficient monies to pay for
it) is sufficient to justify the 7000 landings and 3000 take-offs a year
(notwithstanding our belief this is unachievable). In the last 20 years of
Manston’s life they failed to achieve 10000 ATM’s so there is no one alive
today living in Ramsgate that has lived through the number of ATM’s RSP propose
and further this excessive disruption cannot be justified as RSP have yet to
prove that a Cargo Hub is viable.
CONCLUSION
Finally it must be proven to the
satisfaction of the Examiner that various criteria have been met. It is in our
contention this is a resounding NO. The Planning Act 2008 makes things clear
and it is also apparent that PINS isn’t convinced.
“Further
justification as to why Article 9 of the draft DCO is appropriate and provides
sufficient security for individuals in consideration of the provisions of the
Human Rights Act 1998.”
Further consideration should be examined
carefully:-
Guidance
Related to Procedures for Compulsory Acquisition (DCLG February 2010) (issued
under section 124 Planning Act 2008) sets out general considerations which are
to be applied when considering whether compulsory acquisition is justified. The
following guidance is given (at paragraph 24):
“The
first criterion is that the land is required for the development to which the
development consent relates. For this to be met, the promoter should be able to
demonstrate to the satisfaction of the decision-maker that the land in question
is needed for the development for which consent is sought. The decision-maker
should be satisfied, in this regard, that the land to be acquired is no more than is reasonably required for the
purposes of the development” (our emphasis)
Further
“In
practice it is necessary, when considering confirmation of any CPO, to address
the question of whether there is a compelling
case in the public interest (our emphasis), in order to address the policy in the
Circular and in order to address considerations arising when Article 1 Protocol
1 and Article 8 (European Convention on Human Rights (“ECHR”)) rights are
engaged. As a result the addition of a statutory test is unlikely to change the
way in which confirmation of CPO’s (or in the case of DCO, inclusion of powers
of compulsory acquisition) is likely to be approached.”
And
“The
overarching public interest test is whether there is a compelling case in the public interest (our emphasis). As the Circular advises (17), an authority should be sure that the
purposes for which it is making the CPO sufficiently
justify interfering with the human rights of those with an interest in the land
affected.” (Our emphasis)
And
Before
proceeding to any CPO the Examining Authority should seek further information
on their plans for the site from the new owners. The Examining Authority must
be in a position to assess the degree of
interference with the landowner’s human rights, and also, if appropriate,
to consider the benefits of their
alternative proposals for the site to strike the public interest balance. (Our emphasis)
In
seeking to justify any CPO the Examining Authority would have to show that the
benefits of what it proposed would be so extensive that (notwithstanding the
merits of the new owners’ proposals) the
public interest v human rights balance would still be in favour of the CPO. (f)
It
should be remembered that a CPO is a last resort, Counsel would not advise
against attempting to negotiate. Indeed, in order to strike the balancing
exercise properly (and safely) it is in the Examining Authorities interest to
understand the new owner’s position, and their intentions for the land. *Guy
Williams, Landmark Chambers
What is clear is that nowhere in the DCO
application is a comparison made with the existing owners plans either
financially or which would benefit the wider (Thanet) community better. It
should be part and parcel of the examining authority to look at both schemes
and to assess whether there is a compelling case in the public interest. As the
Circular advises (17), an authority should be sure that the purposes for which
it is making the CPO sufficiently justify interfering with the human rights of
those with an interest in the land affected.
References
*1
Altitude Aviation Report Web reference for original report. Attached as
appendix 1
*2 (DfT “Moving Britain
Ahead”) Web reference for original report. Attached as appendix 2
*3 York Aviation “Key
Findings of York Aviation Report” Web reference for original report. Attached
as appendix 3
http://www.stonehillpark.co.uk/images/uploads/documents/SHP-York-Aviation-Summary-Report-Final.pdf
*4 RSP Transport
Assessment. Available on PINS
*5
KCC-Position-Statement-on-Manston-Airport. Attached as appendix 4
*6 2009-11-KIA-Master-Plan-Final-Infratil.
Attached as appendix 5
*7 SHP-York-Aviation-Summary-Report-Final.
Attached as appendix 6
You have put a lot of time and work into that piece Barry I hope they sit up and take notice thanks for standing bye us.
ReplyDelete