Manston DCO News

Wednesday, 27 September 2023

The Role of Thanet Council planning during the Manston DCO

What is a DCO requirement?
A Development Consent Order (DCO) is the means of obtaining permission for developments categorised as Nationally Significant Infrastructure Projects (NSIP). This includes energy, transport, water and waste projects.

Introduction

1. A Local Authority’s Role

1.1 Host and neighbouring local authorities have an important role in the PA 2008 process. Participation is not obligatory but is strongly advised. Whilst it is appreciated that local authority resources are limited, relevant authorities are strongly encouraged to discuss and work through the issues raised by NSIP proposals. A local authority will provide an important local perspective at the pre-application stage, in addition to the views expressed directly to the developer by local residents, groups and businesses. Local authorities are likely to become responsible for discharging many of the requirements (akin to planning conditions) associated with an NSIP in their area if development consent is granted. Local authorities are also likely to have a role in monitoring and enforcing many of the Development Consent Order (DCO) provisions and requirements.

30. Roles and responsibilities

30.1 A local authority’s role does not usually end once a decision is made by the SoS to grant development consent. As with any planning permission a local authority will have responsibilities to discharge requirements (as discussed earlier) and also to enforce the terms of a DCO. Sections 160 to 173 of the PA2008 set out local authorities’ powers to enforce a breach of the terms of an order granting development consent.

Sunday, 30 April 2023

Timeline 2005-2015

A History of Manston Airport from July 2005 to 2015

2005

Mr. Tony Freudmann had overseen Manston’s transfer from an RAF base to a commercial operation. He was Senior Vice President of Wiggins Group between 1994 and 2005. He was ‘let go’ by Wiggins in February 2005. He is now the spokesman for the RiverOak consortium*1

*1 “KCC-Position-Statement-on-Manston-Airport”

2006

The airport was sold to Infratil for a sum reputed to be around £17M and separately Kent International Business Park (70 acres hived off to raise £4M for investing in further airports) was sold to Kent County Council (KCC) for £5.35M *1. During Wiggin’s tenure the area of Manston reduced from 1100 acres to 720 acres.

Anthony Freudmann (who resigned from Wiggins/Planestation in Feb 2005) approaches KCC with a view to building a Manston to Virginia US holiday route using his “experience”. His initial report costing £50K was followed by further invoices totaling £176K then in early 2007 KCC invested a further £289K in the venture. There were no ticket sales and the project was abandoned by KCC

2007-2009

Infratil invests heavily in Manston

“Infratil Limited is a successful company listed on the New Zealand stock exchange with the primary purpose of investing in electricity distribution, public transport and ports. The company was established in 1994 with NZ$50m of capital. At the time it acquired Manston and Prestwick airports it controlled assets worldwide in excess of NZ$ 4.4 billion. Following Wiggins’ demise, Infratil Limited bought Manston Airport from the Administrator for £17 million in August 2005.

In addition to Manston, Infratil also owned Prestwick, Flughafen Lubeck, Wellington and Auckland Airports. Its master plan for Manston (published in November 2009) envisaged building a new passenger terminal to accommodate up to 3 million passengers per annum. It also envisaged building a parallel taxi way to the runway and an increase in the freight and passenger aprons. At the time of publishing its plan the airport was handling 32,000 tonnes of freight per annum. The master plan envisaged freight growth of between 4% and 6% per annum to equate to approximately 167,000 tonnes of freight per annum by 2018. It also planned on developing corporate jet facilities with an executive terminal.” *1

In 2009 the airport was handling fewer than 50,000 passengers per annum, the airport employed approximately 100 people, some full time and some part time and cargo was just 30038 tonnes.

2010 -2011

Infratil approached Thanet District Council (TDC) with a view to altering the current flying agreement (S106) to allow cargo flights between 11pm and 7am. At the time of requesting this approximately 50% of cargo flights (20% overall) were arriving during the night anyway. A series of reports were commissioned to support this request.

2010-10-BAP-report-Night-Noise-Assessment

2011-08-Economic-IMPACT-of-Night-Flying-Policy-York-Aviation

2011-10-BAP-Noise

TDC’s response was to debate the request in chambers and then to ask MORI to run a poll in Ramsgate to determine the response from the electorate. This Poll was overwhelmingly against Infratil’s request. TDC then told them NO. In response Infratil put the airport up for sale with Price Waterhouse Cooper. It was to remain unsold for nearly two years.

Anthony Freudmann 2006-2011

On leaving Planestation, Anthony Freudmann became involved in the travel industry. His parents had established a travel business in the 1960's and his brother, Steven, took the helm of the family firm, Majestic Travel and rose to the top of the industry. He was a director of ABTA for 18 years and it’s President during 1997-2000. The complexities of Anthony Freudmann’s relatively brief involvement in the travel industry precludes a detailed analysis. There were a number of acquisitions. Some of these acquisitions would seem to have been direct whilst others were made through Alpha Consolidations Ltd and Alpha Prospects PLC, companies founded with his brother Steven.

Anthony's travel companies included Carefree Travel acquired on 22/3/07, Radiant Travel 22/3/07 Travel Club of Upminster, (founded in 1936), Upminster Travel, Austria Travel all acquired on the 19/1/09. Majestic Travel, the old family firm was purchased from his brother Steven on 6/2/09. Seligo Holidays 23/2/2009 A useful summary from Travel Trade Gazette of the state of play on 19th March 2009 goes some way to unravel the complexities. “Steven Freudmann is a director of Alpha Prospects, a plc listed on the Junior Plus stock market and set up in 2008 to invest in travel companies. His brother Tony Freudmann was a director of Unpackaged Holidays Ltd of which Seligo was a trading name. Tony Freudmann is also a director of The Travel Club, the company which bought the assets of Unpackaged Holidays. Tony Freudmann is also a director of Unpackaged’s parent company, UHN Ltd, of which Alpha Prospects has an option to acquire. Tony Freudmann is also a director of Seligo Holidays Ltd, which was set up in February and could now become the trade arm of The Travel Club. Alpha Prospects also has an option to acquire Alpha Consolidations Ltd, which owns The Travel Club Ltd.”

It was not very long before all of these companies, with the exception of Anthony and Steven's Alpha Prospects, bit the dust. Steven resigned his Directorship of ABTA after calls to do so from creditors of Seligo / Unpackaged and at a time when he was due to face questions from the board regarding the collapse of and involvement in, the Unpackaged Group run by Tony and Alpha Prospects.

2011-2013

During this time when Manston was being touted for sale by PWC attention was also focused on Lahr in the German Black Forest by Tony where Messrs. Joshi and Soards were being fronted by Anthony Freudmann in the acquisition of that airport using a company called INTEGERAL LIMITED (06602485) which was ordered to be wound up on the 28/2/2013.

“In June 2012 Anthony Freudmann returned to Lahr. Equipped with a business plan that might sound very familiar. The focus would be on freight, aircraft stripdown and recycling, a new West African Airway would establish a base, there would be aviation related industry and parking and leasing of aircraft.

In fact, nothing happened. In October 2012 an article in Stadtanzieger commented on the workers at the airport not having been paid but stated that the Mayor had been reassured by Mr. Freudmann that the payments had been initiated. Two weeks later on the 14th November when the wages were still not paid, the same paper quoted Mr. Freudmann as saying that he had no comment to make as it was a “private matter”.

By January 30th 2013 there was considerable speculation as to what was going on and the local press stated that the editorial team had not seen Anthony Freudmann at Lahr since the 5th October 2012. However the 30th January 2013 was a significant day for Integeral Investments for reasons other than the speculation at Lahr, for they were in the High Court in London for the final hearing of a contested winding up petition and a counter application for the company to be placed into administration. Whilst Mr. Freudmann was representing Integeral on the ground at Lahr, a winding up petition in respect of the company had been presented to the High Court on the 25th July 2012.

However, what is perhaps more striking is that the court heard evidence to the effect that in fact, Integeral was insolvent “from (at least) late 2011". The significance of this of course is that it would seem that Integeral was insolvent before they even got involved in the Black Forest Airport. Now of course it could be that Anthony Freudmann was completely oblivious to this state of affairs in which case one would have to question the absence of his making his own enquiries as to the status of the company he was representing. The judgement does however have a mention in passing in that is with regard to this project that Integeral owed a Mr. Douglas John Maggs the sum of £460,000, thus revealing Maggs (through a company) as an investor in the Lahr project. DJM lived at 11 Grosvenor Hill, London W1K 3QA, an address that becomes important later in 2013.

Back to Manston

A number of previously unpublicised facts emerged from the evidence presented to the Select Committee, ‘Small Airports’ inquiry, among which, was that it was Anthony Freudmann that introduced Anne Gloag to Prestwick and Manston Airports as potential business ventures. Both airports being owned at that time by New Zealand company Infratil. Anne Gloag’s company purchased the latter only, with an announcement to that effect being made on the 29th November 2013.

We now know that just two months after the deal that he brokered goes through, Mr. Freudmann decided that he wished to purchase the airport himself. This first came to light in an interview Anne Gloag gave to the Kent Messenger on the 8th August 2014. In relation to a question asked about enquiries being made as to the potential of house building on a part of the airport lands known locally as the Northern Grass, she had this to say. "This representation was initiated, promoted and paid for by Tony Freudmann and Annax Aviation who had indicated they wanted to purchase the airport at that time and were keen for consideration to be given to alternative uses for the Northern Grass to be included in the Local Development Plan. The representation was not made by us. We did attend one meeting with the council, Mr. Freudmann and his planning advisor, when we were made aware it was happening, as we had concerns and felt, as the landowner, we should be represented"

Check the address where Annax was registered.

Anthony had approached a businessman with a view to buying Manston for £8M with £2M of working capital. Annax Aviation Ltd (08576648), now dissolved, was incorporated on 20 Jun 2013 and Freudmann had been in the process of approaching Thanet Planning department with a proposal to build 1000 houses on the Northern grass. When that collapsed through failure to acquire the funding, Freudmann approached Ann Gloag. Her evidence to the select committee on airports said:

“This submission is provided on behalf of Manston Skyport Limited, following a written invitation from Mr. Nick Beech on November 6th 2014 to submit written evidence to assist the Select Committee in its review of the viability of regional airports in the UK.”

“The opportunity to acquire Manston Airport was introduced to us by a consortium including a former executive of the airport prior to its insolvency in 2005 (Anthony Freudmann, Douglas Maggs et al). At that time it was part of a larger transaction involving Prestwick Airport, in Scotland.”

“The sale consisted of two businesses, Infratil Kent Airport ltd and Infratil Kent facilities Ltd (being the operating company and the property owning company which made up the airport business).”

In fact by November 2013 Ann Gloag had purchased the airport and debts and then set out to see if it could be viable

2014-2015

In Gloag’s words to the select committee:

“Two key executives were brought in to the business to conduct a thorough review of the business and to report to shareholders on options for the future. One of these executives was a highly regarded Chartered Accountant who had worked on numerous turnaround strategies on behalf of funders and investors; the other was an industry professional with extensive aviation experience, and who crucially had led a team that had successfully turned around a UK Regional Airport.

The remit given to the turnaround team was to put in place strong cash management procedures as this had been a key concern of our advisors during the due diligence period; and secondly to consider how income generation at the airport could be enhanced.

At the time of purchase, a number of possible upsides had been identified. The key three ones were:

3.2.1. That the Davies Commission would support making best use of existing runway capacity and not support a further runway in the SE.

3.2.2. The British Airways cargo operations at Stansted could be migrated to Manston.

3.2.3. That Ryanair would set up a major new base at Manston.

Whilst all of these options had been considered and assessed, by Christmas 2013 it became clear that Ryanair, after two profits warnings was undertaking a major strategic review and announced it was moving from a policy of remote airports to more central ones. The Davies commission had published its options assessment, which did not favour Manston, but further capacity at either Heathrow or Gatwick (or, at that stage, possibly the Thames Estuary). In addition, shortly thereafter, British Airways announced they were terminating their cargo operations at Stansted- and not migrating them elsewhere.

At the same time it became clear that the airport’s finances were in a worse state than had been understood during purchase negotiations, with losses significantly higher than expected including a large number of outstanding commitments that had been omitted from the sale information. For example, a radar, which had been installed some years ago, had outstanding payments due within a year of purchase of around £420,000.

In addition, during the review of the business, the consortium (Freudmann, Maggs et al) who had originally introduced the opportunity to Manston Skyport continued to negotiate with the new owners to purchase the airport. However despite many deadlines coming and going, this consortium consistently failed to demonstrate proof of funds and failed to complete on any of the dates they had promised. (Where have we heard that before?)

The business review concluded that losses would continue into the future and that cash of over £10m would be required to maintain airport operations over the following three years. Even if all of the possible changes were delivered and if no existing business departed, resulting cash requirements over the three-year period would be over £7m. Critically, at the end of the three-year horizon, there was no prospect of the business becoming profitable. The Directors of Manston Skyport very carefully considered the situation. They were not in a position to continue to fund the business’ losses indefinitely and with no credible buyer available, they resolved to inform the Directors of the airport that, as shareholders, they could not continue to fund the business, in the absence of a realistic expectation of future returns.

Around 25 staff had chosen voluntary redundancy prior to the date of closure and a further 15 were retained to support the closure activities. Around 100 staff were made redundant on the date of closure, 15 May 2014.”

After it became clear the Anne Gloag had taken the decision to close the airport and it would seem that Tony Freudmann then went in search of financial backers to purchase the airport.

A businessman, resident in the Columbian city of Bogota, expressed an interest in investing in the airport to Sir Roger Gale who immediately referred him to Tony Freudmann. Doubts grow as to whether the ING bearer bonds that he presented as evidence of capital were in fact genuine.

RiverOak Investment Corps of Connecticut are then named as the new investors. It was said that Tony was at a conference in Canary Wharf where he met the MD Steve DeNardo and the rest as we know is history.

RiverOak

“Following the failure of negotiations between Anne Gloag and RiverOak the suggestion was made that the Airport should be made the subject of a Compulsory Purchase Order and whilst it is not entirely clear from whom this idea emanated, it was taken up with gusto by the Member of Parliament for North Thanet with the orchestrated backing of the various groups wishing to see Manston returned to its former usage. That the use of such a draconian measure to deprive one set of people of their land in favour of another group, one might suppose would sit quite uncomfortably with a Conservative politician. Apparently not, as despite the bullish approach of the US Company, with their schoolboy gibes of “my lawyers better than your lawyer” he has not only continued his support for a Compulsory Purchase Order, he has accused Anne Gloag (under the protection of Parliamentary Privilege) of being a liar. What is surprising is that when it became apparent that, in whatever capacity, the two former directors of Integeral were involved with Riveroak, that anyone seriously considered that Thanet District Council would even entertain further dealings with the company. Given the Council’s troubles in the past with outside companies it might be hoped, that they would have by now developed an ultra-cautious approach to such dealings. In any event, despite various extensions TDC determined that RiverOak had not met its criteria. That should perhaps have been the end of the story.

However Sir Roger has continued in his quest to have the airport lands delivered to the US Corporation and has raised questions as to whether the purchase of 80% of the controlling company by the developers of Wynyard and Discovery Parks was indeed a ‘real’ sale back in September. Supporters of the airport have become obsessed with the ‘real’ ownership of the land and spent hours trying to prove that in fact, Anne Gloag was the ‘real’ owner. Sir Roger even managed to divert the Transport Select Committee from its brief of looking at the role of smaller airports into an inquisition into who owns land.

When RiverOak made Anthony Freudmann a Partner and Managing Director of RiverOak, it was clear that he was to represent their’ hands on experience of aviation and airports’. Given what might be considered by some, a less than impressive track record in keeping companies afloat and given that none has seemingly thrived under his management, why would anyone think that he was the right man for the job of getting Manston flying again. The suspicion must remain that Douglas Maggs has involvement with the Manston project Has he and Messrs. Soards and Joshi be hiding in the wings? Some, including the writer believed so and to get an answer one way or the other, wrote to Mr. DeNardo asking this question on the 12th December 2014 but still await a reply. The same question was put to Sir Roger Gale by e-mail on 3rd February 2015, he was good enough to respond very quickly but did not answer the two questions posed, i.e. why he had such confidence that Anthony Freudmann was the right man to turn the airport around and as to whether Joshi, Soards or Maggs had any involvement in any capacity in Riveroak’s’ Manston ‘venture’. In a second e-mail the writer elaborated on Tony Freudmann’s career and gave further information regarding the ‘Lahr’ project, again, asking the question as to whether the three men were involved. The reply, suggested that the information (all garnered from the public domain) might be libelous to Tony Freudmann. Again the question remained unanswered. This might suggest that not only are these three men involved but that Sir Roger Gale is fully aware of their involvement.

It would have course been very easy for Sir Roger to simply state “to the best of my knowledge and belief none of the named parties are involved in any capacity in the RiverOak Manston project” that he did not, might perhaps suggest that they are and that he was unwilling to confirm this fact. Confirmation of Mr. Maggs involvement has been provided in the form of correspondence submitted into the evidence of the Select Committee on 23rd February 2015.”

“Re: Letter dated 2lst November 2014. On a more general note you (Roger Gale) continue to champion the cause of Riveroak who we have tried to contact and who seem reluctant to talk to us (Mssrs Cartner & Musgrave). We have recently been approached, via a third party, by Mr. Maggs, who claims to be working with them (Riveroak) and who asked for our contact details, which we gave. He has an interesting history (he was made bankrupt in 2016) of failed property ventures and controversial housing scheme proposals attached to his name and we weren’t aware until recently of his involvement.”

“This correspondence dated 25th November 2014 was submitted in rebuttal of Sir Roger Gale’s evidence to the committee that Messrs Musgrave and Cartner had not responded to his enquiries in respect of the ownership of the Manston site. This letter suggests that Mr. Maggs represented himself as “working with RiverOak”

Local reporter Tom Barnes approached DeNardo in respect of Maggs involvement and he (unlike me) was given the courtesy of a response. The response however raises more questions than it answers. “RiverOak has never worked with, employed or indeed had any formal involvement with Douglas Maggs. Mr. Maggs at one time offered to approach a Discovery Park investor to see if a meeting between RiverOak and the owners of Discovery Park could be arranged. It went no further than that”

Douglas Maggs according to Company Check has been the former director of 37 Companies. As alluded to in the correspondence cited, he is a property investor with a certain reputation. According to Company Check, in addition to his previous Directorships, he currently holds 28 Directorships, these companies having an asset value of £69 million. Under another registration number he is the director of Rosslyn Film Partnerships, with assets of just under £8 million. In addition he is reputed to have considerable offshore interests.

So this very busy multi-millionaire just strolled along to RiverOak, a company he has no connection with and offered to pay a visit to another company, where he was not known, just to do RiverOak a favour. Such altruism may damage his reputation. RiverOak and indeed Sir Roger Gale have consistently relied on what they perceive to be the gullibility of local people and the unwillingness of the press to look closely at who these people really are. It is perhaps notable that the ‘denial’ of Maggs involvement does not preclude him being a ‘potential investor’.

What perhaps is remarkable is that the situation ever got to the stage whereby anyone would seriously entertain doing business with RiverOak. The involvement of Anthony Freudmann with a string of business failures, including of the course at the very same airport, should have been sufficient to raise the alarm. One might have hoped that the sniff of the rest of the Integeral team’s involvement would have been sufficient for the drawbridge to be hoisted up back in May 2014. Even when it was revealed that RiverOak had chosen to incorporate a new company in Delaware to be the indemnity vehicle, the process continued. (Delaware, whilst hosting legitimate businesses, is also the favoured state of ‘less legitimate entities’ who appreciate the anonymity given to investors)

It would seem likely that the momentum for this folly has come from a very intelligent orchestration of the supporters groups, perhaps manipulation would be a more suitable term, in a process given an air of respectability and credibility, by the vehement endorsement of Sir Roger Gale. Like the people of Lahr, Thanet residents are also being kept in the dark as to the true cost of this fated enterprise, although it has been remarked by one councillor that the officers of the council have spent almost all of their time on this project, no ‘formal’ record has been kept according to Freedom of Information requests.

Many questions remain unanswered although of course we could all speculate. Why is RiverOak, a real estate investment company, so keen to obtain an airport that has never been commercially successful? Do they think that Anthony Freudmann’s revived Wiggins / Planestation and Integeral business plan will succeed for them, when it has failed for others or do they in fact have their eyes on the future potential of 720 acres of land for other purposes, after all it was their Tony who went to the trouble of obtaining the services of planning professionals back in January 2014? Why in the summer did Anthony Freudmann incorporate Aviation companies in Ireland?

I suspect that we may never get the whole story. Anyone who has had an even cursory perusal of the law relating to Compulsory Purchase will be confident that an opposed CPO would be bound to fail. Even if a new council were comprised of sufficiently irrational beings as to ignore officer advice, the CPO will not happen. Whilst I am keen that this matter is now disposed of with all due expedition, it is my hope that whichever organisation is given the task of reviewing TDC’s decision making process, that they spare a few minutes to take a closer look at the persons and entities backed so keenly by Sir Roger Gale and if appropriate, refer the whole sorry saga to any appropriate authorities.” *2

*2 submitted to the NSIP DCO

In the end the CPO failed due to Riveroak being unable to complete “Due Diligence”. In other words they could not provide proof they had sufficient monies to indemnify Thanet Council.

Tuesday, 21 February 2023

aircargo and the consequences for Manston

Aircargo is the transportation of goods to and from the United Kingdom and is measured by tonnage transported and the number of air transport movements (ATMs) to carry said goods. Because of the cost of air transport compared to ships or HGVs it is normally reserved for valuable or time constrained goods. It can be 4-8X the cost of HGV or cargo ship transportation.

Also because of the much higher cost aircargo has been normally limited to a 1/2 of 1% of all other goods tonnage (figures from the Department of Transport DfT)

Between 2015 and 2018 the tonnage carried had been steadily increasing however most of of this increase was being carried in the hold of passenger planes and being landed at Heathrow which incidentally carries 2/3rds of all airfreight in the UK.

Year Passenger plane Freighter Total % of 2018

2015 1611432 687511 2299343

2016 1676594 707813 2384407

2017 1861759 760737 2622496

2018 1859178 772005 2631183

2019 1763776 771646 2535422 -3.64%

2020 766149 1236037 2002186 -23.91%

2021 820041 1447771 2297812 -12.67%

2022 1230059 939408 2169467 -17.55%

2023 projected 2108293 -19.87%

2019 the overall tonnage dropped, which was possibly caused by the Brexit affect, however a far bigger collapse occurred in 2020 and 2021 with covid lockdowns reducing passenger air transport and the massive reduction in bellyhold carriage and the slack being taken up by an increase in pure freighter ATMs. These pure freighter increases benefitted both East Midlands and Stanstead who both still have spare capacity for freighters. The issue however was overall aircargo reduces by 21% on 2019 figures but even more compared to 2018. (23.91%)

The other way to measure is ATMs and in comparison with the DfT forecasting currently up to 2019 Cargo ATMs were on target (60000 atms by 2030) and then came Covid and a massive drop in Bellyhold cargo with an increase in cargo freighters however far less tonnage was carried overall as seen above.

Table 06 Air Transport Movements

2015 56550

2016 51863

2017 52330

2018 54061

2019 57561

2020 83225

2021 92997

2022 66027

2023 projected 56757

As the figures show at the end of 2022 the pure freighter ATMs had started to revert back to 2019 levels however still not yet back on the path the DfT forecast back in 2017.

DfT forecast

Riveroak Strategic Partners have based their forecasting on Cargo only freighters which the DfT have forecasted to achieve around 60000 ATMs by 2030 currently the last "normal" year was 2019 which is slowly reverting back to the DfT forecast however, as can be seen by the tonnage figures is a declining method of transporting goods to and from the UK.

It is extremely unlikely that either UK freighter airport, Stanstead and East Midlands, will run out of capacity and currently Heathrow is still the largest cargo airport still with capacity it is difficult to see Manston taking much of the market share especially as all the other 3 have infrastructure to cope with cargo which Manston doesn't have.

This is Dr. Dixon's forecast from her original report

Clearly after just 7 years Dr. Dixon has forecast nearly 11000 ATMs that is 20% of the whole UK Cargo ATMs from a standing start without any current infrastructure in place. Most normal people might believe this is somewhat farfetched

Tuesday, 24 January 2023

Riveroak statement after Appeal was refused

RSP's statement is in black

Editor's comments in red

Steer report "Steer Assessment-of-the-value-of-air-freight-services-to-the-UK-economy-Final-Report-v22-Oct-2018-b-STEER can be downloaded from here

Manston: an airfreight hub for London & the Southeast

Manston Airport is a unique and important transport infrastructure asset. An illustrious history as a Battle of Britain airfield and an exciting future as a vibrant hub for international airfreight, delivering economic prosperity and employment across Kent and protecting a strategic aviation resource for the nation.

RSP’s proposals for the redevelopment of Manston Airport as a dedicated airfreight hub have now been approved by the UK Government as a Nationally Significant Infrastructure Project.

Once reopened, Manston will help the UK trade across the globe, importing vital and time-sensitive goods, including fresh fruit and medical supplies, providing air freight operators with a realistic alternative to the overcrowded London airports, easing the considerable road congestion caused by lorries carrying freight through the channel tunnel to European airports and improving resilience and boost economic growth and jobs in Kent.

Ignoring the very real increase in HGV movements along the Thanet Way onto an already overcrowded A2/M2 corridor and the QE2 Bridge across the Thames. As Manston isn’t connected to the fuel pipeline Aviation fuel will have to be trucked from the refinery at Canvey yet again adding to the congestion at the Dartford river crossing

Manston Airport is also unique in that it is deliverable; it will be ready to open its initial phase in less than three years.

Not a spadeful can be turned until the DCO conditions are complied with including the moving of the HRDF. There are a number of conditions that need meeting before development starts. Please read the DCO document pages 35-44. In all 24 conditions MUST be met.

Upon opening it will:

Immediately absorb the increased demand for air cargo post COVID and Brexit and relieving capacity pressure on key London airports as they focus on passenger markets.

Provide an operating base for UK traffic currently lost to EU airports and create future capacity to meet global freight growth, adapting to changing market requirements using the latest technology.

When fully built, Manston will be able to handle in excess of a million tonnes of freight a year.

Very careful wording here, “will be able to handle” is light years away from “will achieve” in fact the Total tonnage of airfreight in the UK in 2019 (before Brexit and Covid) was 2535422 tonnes and 2020 and 2021 were 21% and 9.38% below that level.

The Development Consent Order – granted August 2022

The Government has granted the Development Consent Order because our plans for Manston are consistent with all relevant Government policies, including the Airports National Policy Statement, the Aviation Policy Framework, General Aviation strategy and Transport Decarbonisation Plan, and recognising the contribution Manston will make to resilience in UK’s under-pressure freight transport sector.

In addition, Manston will make a significant contribution to the decarbonisation of aviation and so is aligned with the Government’s 2022 Jet Zero consultation outcomes.

The Government-approved Development Consent Order provides consent for:

19 widebody parking stands

4 narrow body passenger stands 65,000m2 (750,000ft2) of cargo terminal

100 ha of non-aircraft pavement (247 acres)

57 ha (140 acres) of aircraft pavement 105,000m2

(1.1m ft2) of landside development

8 business aviation hangers

3 recycling hangars and aprons

Securing flight procedures for Manston

Before Manston can reopen, new air routes must be approved through an airspace change process set out in the Civil Aviation Publication (CAP) 1616. The process consists of seven stages and the Manston Airport proposal has already reached Stage 3.

But only after 3 years of work. Doesn’t bode well for the next 4 stages

RSP has developed a number of options for the flight procedures that will be required when the airport re-opens. These options will be subject to a full public consultation, which is currently programmed for early 2023.

Following this consultation, we will be able to submit our proposal to the CAA for consideration, with a decision expected during the course of 2024.

Why Manston?

1. The global air cargo market is growing

Ecommerce giants are transforming the air freight market, with their share of total sales reaching 25% very soon.

This is inspiring the growth of specialist freighter hubs. By way of an example, Amazon now has 85 aircraft with a further five on order and are expected to have 200 by 2028. In Europe alone, Amazon is making 38 daily flights serving eight cities.

But have recently withdrawn their aircraft from their hub at Southend and have stated they will truck goods in instead as cheaper

2. The UK is reliant on air cargo for economic growth and resilience

No it isn’t airfreight only accounts for ½ of 1% of all shipped tonnage with less than 1% annual growth over the last 20 years. In fact pure freighters atms have dropped by 50% in the last 20 years with the growth of bellyhold mainly at Heathrow.

Maximising international import/export, post-Brexit and post-COVID, is critical to the UK economy and the UK economy is increasingly reliant on airfreight to achieve this. Air cargo provides the immediacy that the UK relies upon for perishables, medicines and other time-sensitive goods

Dedicated freighters carry over 50% of the world’s air cargo. Airframe manufacturer Boeing forecasts global freighter fleet to grow more than 60% to 3,260 over the next two decades.

Boeing certainly do but their forecast for the UK market is less rosy.

Prior to COVID, more than £2 billion was lost to the London and Southeast England economy each year due to air freight diverted to Europe due to lack of capacity. Dedicated freighters could not find suitable slots anywhere in London and the Southeast – leading to 70% of freight flying belly hold in passenger aircraft.

This statement shows a complete lack of understanding how aircargo is managed. Also it should be apparent that during operations Manston would have been a closer airport than Liege (European aircargo hub) but nothing came to Manston despite its inactivity.

COVID has reinforced the cargo sector – and created a cultural shift that underpins the Manston strategy. One key observation from the COVID-19 crisis has been the importance of main deck freighters in airplane fleets and the global air transportation system. Freight use of passenger slots is unsustainable and inefficient, and many passenger airports lack air freight facilities.

Again a lie. Heathrow was the Premier airfreight hub (2/3rds of aircargo came through Heathrow in the belly of PAX) however with lockdown and the grounding of PAX much freight was directed on to pure freighters. Total aircargo dropped by 21% in 2020 due to this lack of capacity. However 2021 showed a partial recovery (only down 9.38% on 2019 levels) as PAX resumed.

In terms of the security of the UK economy, it is clear that cargo hubs can increase our resilience as an island nation: COVID-19 showed increasing critical importance of dedicated air cargo in protecting supply chain dependability.

3. Manston has capacity for growth

Manston has a strategically useful location by road, rail freight, air – and water. It has a full length, existing runway 2,748m (9,016 feet), capable of handling all widebody freighters and with a phased construction plan already developed it can be ready to open in under three years.

Manston has had these advantages ever since the War Department built the concrete runway 1945/46. I wonder why no hard headed business people have taken advantage?

In addition, it benefits from proximity to (but remains just outside of) London and Southeast airspace.

So is Southend where Amazon has just walked away from

The airspace over London and the Southeast is among the busiest and most congested in Europe – with the exception of the airspace over Manston. The London Terminal Manoeuvring Area (LTMA), west of Manston, handles aircraft using Heathrow, Gatwick, Stansted, Luton, Southend and London City airports – plus Biggin Hill and Farnborough airfields.

And Manston will add to if it ever they get granted a licence.

The airspace above Manston is much less congested, with aircraft at a much higher altitude. It also has capacity for significant future growth.

Airfreight – unable to access slots within the LTMA – is regularly trucked through the Channel Tunnel or via ferry to airports in mainland Europe to fly long-haul.

All 3 main airports for freight are well able to give slots to freight aircargo. That is Heathrow (Bellyhold is nearly back to pre-pandemic levels), East Midlands and Stanstead have space available.

The challenges of Brexit have motivated UK importers and exporters look for alternatives to the practice of trucking through the Channel crossings to and from airports in Northern Europe.

Airfreight is still depressed, 2020 was down 20% on 2019 levels and 2021 down 9.29% on 2019. Trucking is still 4-5X cheaper than airfreight.

From 2025 they will instead be able to direct their business to Manston as the only airport offering substantial numbers of slots and capacity.

See above. This statement is wishful thinking

4. Other London and Southeast airports cannot handle the increased demand for dedicated freighters

Both EMA and Stanstead have stated they have capacity both now and into the future

Boeing categorises congestion in London airports as serious. The existing London airport runways will soon be back at capacity, and they are prioritising passenger traffic over freight movements.

Heathrow’s third runway was first proposed in 2006 but will take at least another decade to deliver

Stansted Airport has been granted consent to reduce cargo movements in favour of increased pax movements

Again this is a deliberate misuse of Stanstead’s reduction in aircargo ATMs. What they asked for is permission to change cargo for PAX as aircargo had failed to grow at the forecasted rate and had never reached 2/3rds of the allocated ATMs

Passenger traffic growth will absorb almost all UK runway capacity

Again this is a lie as 4 airports are currently unviable. That is Cardiff, Southend, Doncaster/Sheffield and Prestwick and have struggled to find new owners

Current closest alternative cargo airport with realistic capacity is three hours’ drive from the London M25 orbital motorway

Which is irrelevant as the main central warehousing for freight is centred on the “Golden Triangle” in the Midlands. Manston is 3 further hours away from this “Golden Triangle”.

In addition, there are extreme difficulties in obtaining planning consents for new airports in the UK. So the solution to the capacity crisis can only realistically come from an airport adjacent to, but outside of the London Airport system that is already built and can be ready to go quickly.

Like Southend

5. Manston will be built to be Carbon Net Zero

Aviation, and in particular the cargo sector, is not a luxury that the UK economy can live without and so it is incumbent on airlines, airport operators and governments to work together to protect its vital role in the economy, whilst simultaneously striving towards sustainability.

The Government has made it clear that it requires ‘high innovation’ of aviation to meet carbon reduction targets – something which we have willingly committed to delivering within the terms of the DCO, based upon the significant levels of investment, innovation and testing on alternative aviation fuels and technologies underway in the global aviation community.

The facilities at Manston will be built to make an active contribution to Government carbon reduction targets, with the aim that airport operations are Carbon Net Zero operation by 2035 through the use of smart and energy efficient buildings, the use of electric apron vehicles and autonomous vehicle technology to drive efficiency, the lack of airspace congestion above Manston and much more.

In addition, we are also exploring how we can best utilise the airport’s river connections into central London, the use of bio/synthetic fuel, hydrogen and charging for electric aircraft and whether we would be able to provide any renewable energy surplus to the local community.

Building a strong economic future for Kent

Manston will deliver sustainable economic growth and opportunity in a UK gateway region, supporting regional regeneration, inward investment and employment targets. By Year 5 we forecast 2,150 jobs on the airport site and 13,100 indirect/catalytic jobs.

RSP is meeting with a wide range of other potential partners and stakeholders across Thanet and East Kent to explore opportunities and develop partnerships that will bring additional benefits to local people from our commitment to reopening the airport.

The airport will provide focused training and career development for students and adult learners through progressive education and business partnerships, building on the work established by the Manston Skills and Employment Board (MSE-B) to ensure people from East Kent have the right skills to take the wide range of jobs that will be created by the reopening of Manston.

The MSE-Board considers the future employment and skills needs of the airport following DCO approval, from planning and construction through to operation.

The aim of the MSE-B is to ensure that Manston and associated businesses will have access to well-trained and experienced potential employees across a diverse range of skillsets. The MSE-B will do this by ensuring a comprehensive range of services are available to young people, job seekers and employers in the area around the airport.

In addition to RSP, the MSE-B membership currently includes representatives from:

Thanet District Council

Dover District Council

Canterbury City Council

Kent County Council

EKC Group

Canterbury Christ Church University/EDGE Hub

Kent and Medway Skills Commission

The Education People

Jobcentre Plus

Discovery Park

Thanet and East Kent Chamber of Commerce

Board representation is available to unrepresented local councils and business sectors.

Manston is the right solution, in the right location, at the right time

Appendix 1

Steer report 2017

“Market Analysis

Bellyhold cargo at Heathrow accounted for over 60% of total UK air freight volume in 2017, with forwarders and shippers utilising its extensive intercontinental passenger network. Over 30% of total air freight was shipped on US routes and most of the remainder on Asian routes. Freighter and integrator cargo is concentrated at East Midlands and Stansted, which, in 2017, together accounted for over 20% of all UK freight and the majority of freighter (60%) and integrator (79%) activity. Integrators accounted for over 90% of freight at East Midlands. At Stansted, integrators FedEx and UPS were the largest cargo airlines, although intercontinental freighters such as Qatar Airways, Cargolux and China Southern also accounted for a large share of volume.

In the last 15 years, aside from the decline in 2009 due to the fallout from the financial crisis, total volumes have remained relatively flat, growing with a compound average growth rate (CAGR) of +1.2% over the 15-year period with volumes only surpassing the pre-crisis peak in 2016.

North America was the largest destination market (accounting for 32% of volume), followed by Europe (25%, 18% of which was to the EU) and, South and East Asia (19%). Heathrow, and to a lesser extent Gatwick, handled predominately North American and Asian freight, benefitting from extensive passenger networks. The large European share of volume at East Midlands reflects the airport’s role within its integrators’ networks. Similarly, at Stansted, much of the freight volume is on European and North American routes.”

Trucked freight

2.24 Alongside the business models described above, a significant amount of air freight is transported in customs-bonded trucks between the UK and continental Europe and is classified as air freight with an assigned flight number. Freight is often flown to continental Europe, particularly from Asia, as there is often more available air freight capacity than to UK airports, partly due to lack of available slots for freighter aircraft at Heathrow. The freight is trucked as bonded freight to avoid having to undergo local customs procedures so that importers only need to deal with the UK customs authorities rather than investing in systems to deal with multiple customs authorities. This represents an inefficiency from the perspective of the UK economy as whole. See also the Case Study on consumer electronics imports at the end of this chapter.

2.25 In contrast to goods from Asia, Heathrow stated that goods destined for North America are also often trucked to the UK, in particular Heathrow, from continental Europe in order to take advantage of cheaper rates from the UK on North American routes. As Heathrow is the primary European hub for North American passenger connections, there is a significant level of bellyhold capacity available, which means air freight rates are cheaper compared to other European airports.

2.27 One notable feature of the UK air freight market is the huge importance of Heathrow and its surrounding freight facilities, with most forwarders having major consolidation centres in the vicinity of the airport, as noted in paragraph 2.19 above. Very significant volumes of air freight are trucked to such facilities near Heathrow, processed and then trucked to another airport, either in the UK or in continental Europe, without ever flying in or out of Heathrow itself.

2.28 Another common model is freight arriving from long haul origins (such as China or the US) flown into Heathrow and then being trucked to other airports (e.g. East Midlands) to be flown to continental airports overnight, leading to a symbiotic relationship between the different airports.

2.29 Both of these models mean that the resilience of the road network to and from airports is an important factor in reliability of service. To a large extent, they reflect the constraints on the UK air freight industry"