This will
be my 4th submission to the consultation and will concentrate on
NEED and need alone. Notwithstanding the pandemic Cargo air transport movements
(CATM) has hardly changed in nature for nigh on 20 years. It is a niche market
in the market that moves goods from point A to point B simply because of the
cost.
In the
original examination report from 2019 (before the pandemic struck) the ExA
concluded:
“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.” (E.R 5.7.28)
Very little
has changed and what has changed is debated within the Ove Arup’s report which
concludes:
Overall, the
Independent Assessor concludes that there have not been any significant or
material changes to policy or the quantitative need case for the Proposed
Development since July 2019 that would lead to different conclusions being
reached (compared with the previous ExA conclusions) with respect to the need for the Manston
development. In particular:
1.
The changes to policy, notably the
withdrawal and reinstatement of the ANPS and adoption of the Thanet Local Plan,
do not significantly change the policy context that was in place at the time of
the Examination;
2.
The recent growth in e-commerce
sales is not driving a demand for additional runway capacity for dedicated air
freighters in the South East;
3.
Although there have been short term
changes in the balance between bellyhold freight and dedicated freighter
activity during the Covid-19 pandemic, these changes are not expected to be
permanent, notwithstanding growth in ecommerce and changes to the UK’s trading
patterns post-Brexit;
4.
There is unlikely to be a
significant reduction in bellyhold freight capacity (once the passenger market
recovers) due to the introduction of narrow-bodied twin-engine aircraft;
5.
Despite the uncertainty concerning
the timescale for the Heathrow Airport Third Runway, changes since July 2019 as
described do not lead the Independent Assessor to reach a different conclusion
on the need case for Manston Airport. East Midlands Airport has sufficient
capacity to handle additional dedicated freighter services should the market
demand them, while the planning determination at Stansted confirms that
significant freight capacity remains available; and
6. There is no new evidence to suggest a different conclusion should be drawn
in respect of the locational performance of Manston compared to East Midlands
Airport, and to a lesser extent Stansted, to that of the ExA Report.
What the
applicant forgets (sic) is that there is a marked difference between worldwide
projections for CATM and those that are UK specific and conflating the two is
disingenuous and naïve.
Using
forecasts is akin to crystal ball gazing and this seems to be the favourite
behaviour of the applicant. To ignore prior statistics in favour of cherry
picking forecasts that are not UK specific can lead to erroneous conclusions.
Take the
case of a recent report in the Telegraph:
Rocketing shipping costs force businesses to
avoid container ships and head to the skies in efforts to avoid freight delays
By Louis
Ashworth (Telegraph) 20 November 2021
The headline is misleading because although
worldwide shipping costs have “rocketed” in 2020 the volume of CATM in the UK
reduced by 21%, a
fact that was overlooked in the report that followed.
There were
some gems included within the report however:
“However, it comes with a price tag. Estimates
by the World Bank suggest air freight is usually four to five times more
expensive than road transport, and up to 16 times more than sea. This has
typically meant only some products earn a plane ticket: certain fresh foods,
time-sensitive documents, pharmaceuticals and cut flowers, for example.”
““There's not a one-size-fits-all response to
the current climate,” says Niall van der Wouw, managing director of Clive, an
Amsterdam-based air freight data provider. It’s been a boom period for air
freight, but sky-high pricing and favourable comparisons with nautical
alternatives may not last forever.
“I think there is quite a risk that this big
surge in demand that we've seen over the past year could just disappear as
quickly as it started,” says James Hookham from the Global Shippers’ Forum, a
trade association for cargo owners.
Industry insiders accept that what goes up must
come down, although fate may briefly be in the freight firms’ favour. As air
passenger levels begin to normalize, cargo space will shrivel.”
What is
true is that airfreight is a small niche market which according to Ove Arup has
hardly changed in the last 10 years
“Combining these airfreight volumes with data
from DfT Port Statistics for unit load cargo passing via sea ports in the same
years (cargo in maritime containers, accompanied Heavy Goods Vehicle (HGVs) and
unaccompanied trailers) shows that air
freight’s market share has effectively remained unchanged over the period 2009
to 2019, at around 1.5%. As illustrated by table 2 below. Overall, sea
freight is by far the dominant mode. These modes of shipping are effectively
air freight’s ‘competitor’ in the movement of finished consumer cargoes.” (Page 19 OVE Arup)
The essential
reason for this is cost airfreight being 16X more expensive that goods shipped
by sea. The Steer report clearly understood these facts in their 2018 report as
they graphed volume growth which clearly showed a flat line for Freighter only
carriage and only a slight rise in bellyhold cargo. Most of the bellyhold is
carried in and out of Heathrow which up to the end of 2019 carried 2/3rds of
all UK airfreight.
During 2020
with the onset of Covid and the decimation of passenger flights airfreight
reduced by 1/5th and with most freight being carried on pure
freighters however it is clear from the events in 2021 and the reopening of
passenger flights in the UK and worldwide in July that CATM’s are reverting
back to their previous pre 2020 configurations.
The 3 main
airports for freight in the UK are Heathrow, East Midlands and Stanstead and
the respective volumes are in the 2nd pie chart below
So looking at the post Covid figures from the 3 main cargo airports it is clear that from July 2021 the market is reverting back to pre-covid volumes perhaps quicker than even Ove Arup believed in their report
Although
Heathrow is still running 6% behind 2019 it is clear that bellyhold is now well
ahead of pure freighters with the clear winners being East Midlands and
Stanstead with growth of 27% and 22% respectively.
Clearly the
number of CATM’s has only markedly changed at Heathrow with pure freighters
rising with the fall in bellyhold however 2021 will show that change moving
back to a more normal configuration. It is also clear that the applicant hasn’t
understood the volume of airfreight has actually reduced by 21% in 2020 despite
the growth in E-Commerce. Their assumption is an increase in E-Commerce will lead
to an increase in airfreight. Ove Arup’s report states
“Contrary to the propositions above, York
Aviation on behalf of Jennifer Dawes seeks to cast doubt on the link between
e-commerce and air freight:
“Increases in e-commerce activity, however, do
not necessarily lead to an increase in the volumes of air freight carried to or
from UK airports. Consumers have long purchased goods made in China for
example, which are transported to the UK by both air and surface modes. Even if
some goods that were previously bought in physical stores are now bought
online, these goods generally share the same journey from China to the UK, but
rather than being shipped directly to the retailer’s distribution centre for
onward travel to the physical store, they are being shipped to an online
retailer’s distribution centre for last-mile dispatch direct to consumers.
Therefore, whilst increased e-commerce activity has resulted in an increase in
demand for last-mile logistics between distribution centres and consumers, there
has so far been a negligible net impact in the volumes of air freight carried
to and from UK airports." (paragraph 4.36)
And
When airfreight volumes are compared to the increase in e-commerce there does not appear to be any correlation. Figure 1 below illustrates the percentage change in internet retail sales (£ millions, all sectors) between 2009 and 2020, alongside the percentage change in air freight volumes (total tonnes from all reporting UK airports) over the same time period (page 19 Ove Arup report)
Also within
the applicants submission is the rather naïve belief that much of the
airfreight is lost to HGVs which take goods to and from airports abroad, this
was highlighted in the Steer report as follows
In fact
during the period back to 2009-2014 Manston was trading as a Cargo airport yet
despite the assertion that London Centric airports were at capacity Manston
never grew as a cargo airport. You have to wonder where this naïve belief has
come from. In fact most of this trucked cargo could have gone to East Midlands
which would have been a quicker and more convenient airport but that never
happened either.
East
Midlands, Stanstead and Heathrow have combined achieved between 80-90% of all
aircargo during the last 10 or so years yet growth has been slow as the graph
below shows
Between
2010 and 2019 growth was just 9% with belly hold growing by 17% and pure
freighters just 7% and that only with a very big increase in 2017.
Where the
applicant finds their figures from isn’t hard to find as they spurn actual
figures and would prefer people to view their crystal ball forecasts through
rose tinted spectacles.
It is clear
from Ove Arup’s report they aren’t convinced the applicant knows what they are
talking about however the pro-airport supporters want aviation back at Manston.
Many of these supporters will not be affected by the low flying aircraft. They
are confused however between the words “Want” and “Need”.
I’d like to
quote from the esteemed Ramsgate Society which is made up of people that only
wish the best for Ramsgate and the wider East Kent area. They said:
“There is a world of
difference between “want” and “need”. Want is about desire and aspiration, Need
is something required, where a deficiency causes a clear adverse outcome. There
are those in Thanet and beyond, including politicians, whether consciously or
otherwise, are content to conflate the two. A “wish” is based on feeling and
emotion, “need” is tangible, measureable and evidence based.
The key factor in this
(debate) is “Need”
If the DCO is approved
and the development goes ahead it will inevitably be a business failure because
fundamentally there is no market need, however much sections of the population
may wish for airport jobs and cheap convenient continental air travel that will
not trump stark commercial realities. The project is being touted on a false
prospectus”
There are plenty of White Elephant Airports in
Europe, China, and Africa that were built on “Want”.