Manston DCO issues: The question of need

The air cargo question Stock image by Tak via creativecommons

The Planning Inspectorate for the examination of a Development Consent Order application for the Manston airport site will be holding an issue specific hearing on the question of need this Thursday (March 21).

RiverOak Strategic Partners is applying for the DCO in order to purchase the land and create an air freight cargo hub and associated businesses.

However, the land is owned by Stone Hill Park which has submitted a planning application to create up to 3,700 homes, business and leisure and associated infrastructure.

The Planning Inspectorate hearings opened in January and are due to conclude in July.


RSP say the demand for dedicated freighter capacity is evidenced by the share of bellyhold and dedicated freighters outside the UK being balanced, whereas in the UK bellyhold dominates the market.

An RSP statement of need says the main airport to carry cargo is Heathrow, with around 95%  of that in the holds of passenger aircraft, restricting it to the destinations and timetables served by passenger flights. RSP say a focus at Manston on freight rather than passenger flights and significant airport capacity will provide a reliable and attractive service to freight companies.

They state Heathrow and Stansted are focusing on passenger expansion rather than freight with Heathrow expected to phase works over 10 years and add that East Midlands Airport serves a different function and is not in the south east.

The firm also says their case is strengthened by the fact goods are currently trucked through the Channel Tunnel to and from airports in mainland Europe to access dedicated freighter services not conveniently available in the South East.

‘Exploit opportunities’

In documents submitted to the examination RSP says: “As and when the UK leaves the European Union, the demand for both imports from and exports to countries further afield will become ever more urgent and for the UK to be best-placed to exploit such opportunities it should not be restricted to serving cities to which passengers fly or only to exporting and importing goods that can be contained in passenger aircraft.

“The trend towards low-cost carriers (both short-haul and increasingly long-haul) will further reduce the availability of bellyhold cargo as they do not carry it.

“Government policy is expressed as supportive of airports other than Heathrow making best use of their existing runways, indeed that is the title of the June 2018 policy paper on the future of UK aviation, which is what this proposal does. Given the extreme difficulty of bringing forward a new runway in the UK, very serious consideration should be given before this national asset is lost to aviation.”

RSP argue that Manston is ideally located with good road and rail links.

Capacity increase

Using a study by Azimuth RSP says capacity is forecast to increase by 17% to 2035 but leave a shortfall of around nine runways worth of capacity. According to that study, in the UK, non–EU trade accounts for just under half of all trade and 35% of the goods are air freighted . They say both figures could increase following the UK’s withdrawal from the EU.

The statement of need adds: “Forecasts show that by 2050, the value of air cargo lost to London due to capacity constraints would equate to £106 billion per annum with net national losses of around £3.9 billion per annum. The number of dedicated freighter movements that will be unmet by London airports is forecast to be 79,712 with no additional runways, amounting to some 2.1 million tonnes of freight, which would be diverted elsewhere, mainly to Northern European airports, putting huge additional pressure on the road network and Channel crossings

RSP say their proposed development, which would include 19 cargo stands, “would provide almost immediate relief to the pressing situation that is causing £2 billion in potential trade from being lost to the South East each year if it remains without additional runway capacity.”


Landowner Stone Hill Park says the Azimuth report used by RSP to support its case is flawed and the cargo forecasts are refuted.

An SHP submission says: “RSPs’ case for the DCO is fundamentally based upon the forecasts for the establishment and growth of cargo and passenger flights set out in the Azimuth reports. If the Azimuth reports do not withstand scrutiny, RSPs’ business case, its funding assumptions, its land requirements and the entirety of its DCO application cannot be sustained.

“The Azimuth forecasts are directly refuted on behalf of SHP by York Aviation and Altitude Aviation and (independently) in the reports prepared for Thanet District Council by AviaSolutions. The reports produced by those parties set out their extensive experience in the aviation industry, and the conclusions of each are based on a very detailed evidence base, which contrasts markedly with the limited experience of Azimuth and the unevidenced assertions and speculative arguments contained within the Azimuth report.”

‘No capacity shortage’

SHP say there is  no shortage in capacity for freighters, with planned expansions at existing airports comfortably providing sufficient capacity until 2040 and beyond. They point to the third runway and expansion plans at Heathrow and say Manston can only ever play a niche role in the market.

Their submission states: “Heathrow’s function as the primary freight airport was a significant consideration in the Government’s selection of Heathrow over Gatwick for an additional runway. In 2015 Heathrow published its blueprint for a £180 million overhaul of cargo facilities, together with a commitment to double freight capacity to 3.0 million tonnes with the advent of the third runway. Heathrow’s published proposals for its North West runway confirm its commitment to open the runway by 2026. The advent of this substantial uplift in freight capacity fundamentally transforms the market, renders out of date previous references to runway shortage and undermines the Azimuth forecasts.

“Based on the structure of the air freight market and Manston’s challenges – principally location, competitive forces and continuing trend to bellyhold – both York Aviation and Altitude Aviation are clear that a reopened Manston could only serve a niche role, similar to its historic level of operations.”


SHP say the number of dedicated freighter flights has been in consistent decline since at least 2000 limiting the pool of opportunities for Manston and the trend is a consistent growth in belly hold freight carried on passenger aircraft, a market where Heathrow is dominant. They also question the economic viability of dedicated freight transport, saying: “a tonne of cargo carried in a dedicated freighter aircraft is likely to cost around 4.5 times more per tonne to transport that the same tonne of cargo carried in the belly hold of a passenger aircraft.”

Bellyhold transport means passengers pay for the plane and freight fees only need to cover the additional cost of the extra fuel for the weight.

According to authors of York Aviation report the forecast used by RSP from the Azimuth document are of “ strained credibility.” The SHP statement adds: “Azimuth’s prediction that Manston would handle 5,252 freighter aircraft movements in its first year of operation represents almost 5 times the number ever achieved at the airport at its peak in 2003 and an instant 10 % share of the total freighter market.

“Against a background of decline or flat growth, this could only be achieved through displacement from other freighter airports i.e. East Midlands and Stansted. Both airports, however, are far better located to serve the freight market than Manston, with an established infrastructure of freight forwarders and better transport links.”

They question the level of landing charges that would have to be made to recoup the  £300 million RSP plan to invest and how these prices could be competitive compared to established airports.

SHP concludes the evidence used for the RSP case is not credible and say instances such as a stated airline used in the operation list not actually operating freight flights “raise serious doubts about the credibility of the Azimuth forecasts.”


The question of need for airport project at Manston will be scrutinised during the hearing which will be held at Discovery Park on Thursday (March 21) at 10am.


  1. 10. Lack of proper consideration in the proposal regarding impact on traffic and road network. RSP have shown little concern regarding the overall impact of the heavy goods and vehicles along the Thanet way, the single road access. RSP show no plans for a fuel pipeline servicing the freight hub which means the Avgas will have to be transported down the Thanet way and stored somewhere. Much of this route is just dual carriageway and already heavily used. Road Infrastructure Aircargo is used for serving markets that demand speed and reliability of transport of goods. It is unclear how the Applicant will meet these fundamental criteria as it is solely reliant on a poor road infrastructure with an HGV journey time of around two and half hours to London. The land at Manston airport can be reached by road only. All air-cargo will need to be ferried on Kent’s strategic corridors M2/A2 by HGV. Unlike most airports, there is no fuel pipeline at Manston airport9 and as such all fuel will also need to travel by road tankers. In 2012, Manchester airport had 160,473 ATMs a year10 and required three million litres of aviation fuel a day (equivalent to 79 road tankers’ worth of fuel a day)11. The Applicant has put in an application based on 83, 220 ATMs a year. It is unclear how, when and where it will stockpile a sufficient amount of fuel12. Further, it is unclear how many HGVs carrying air-cargo will be required to fulfill the capacity of 83, 220 ATMs, although as recently as 25 November 2018, the Applicant has publicly stated on video an estimate of around 400-500 HGVs per day based on 17,170 ATMs. No Railway Infrastructure There is no rail freight station. Further, neither Manston nor Thanet have been identified in Network Railway’s Strategic Freight Network “15-year Freight Plan13” and Network Railway’s most recent five-year plan until 31 March 2024, also has no mention of Manston nor Thanet14. There is no railway station in walking distance of Manston airport. It would take approximately 10-15 minutes by cab or about half an hour by bus to reach Manston airport from Ramsgate Station. Ramsgate station is a passenger station with very limited parking and narrow road access unsuited for HGVs. A return ticket during peak times to or from London to Ramsgate costs between £87 to £79 and takes between 2 hours and 17 minutes to one hour and 18 minutes15.

    • Good post and this is the reason manston isn’t a good place for a civilian airport. No way of getting fuel to it, every thing from fuel to goods has to go down the thanet way / M2, which are just two lane. Why would you fly your goods into the bottom right hand corner of England when you could go more central the Midlands, Manchester etc etc

  2. RSP are only interested in acquiring the land to build houses. They were offered a lease on the site at very advantageous terms but with the condition that use was aviation only. They turned it down. There is no commercial case for an airport, but as a housing development Manston is very valuable. Hence RSP’s desire to forcibly take it from its rightful owners.

  3. Yeah it is a slam dunk even Freudmann has said on the record he isn’t competing with Heathrow and 2/3rds of aircargo comes thru Heathrow currently. So Dr Sally says she is only after the other 1/3rd. I wonder what Stanstead, East Midlands, Manchester, and Southend will have to say. Oh and “a tonne of cargo carried in a dedicated freighter aircraft is likely to cost around 4.5 times more per tonne to transport that the same tonne of cargo carried in the belly hold of a passenger aircraft.”
    Bellyhold transport means passengers pay for the plane and freight fees only need to cover the additional cost of the extra fuel for the weight.” LOL

  4. There is no need for a dedicated freight hub.
    1) Almost all freight comes in the belly hold of passenger planes, and there is plenty of capacity there.
    2) Both Stansted and East Midlands have spare, and increasing, freight capacity.
    3) Even if neither of the above were true, Manston would not fill the gap, for the reasons David Green has spelled out. Manston is just too far away from the rest of the UK; there is no rail freight connection; there is no adjacent passenger station; there are no major logistics operations anywhere nearby.
    4) Of the handful of aviation companies mentioned by Azimuth as being interested in flying to/from Manston, one doesn’t fly to the UK at all, ane has mothballed its cargo fleet and another only flies pax aircraft.

  5. To reach the figures that RSP quote we will be plagued by noise 24/7 in our town life will be unbearable,what peaople do not realize is that there are dangerous particles called particulates,the larger ones lodge in the lungs and cause cancer, the smaller ones go straight into the blood stream and cause serious damage to our health,40,000 residents died from this problem in the UK last year and a good percentage came from aircraft. To open this freight hub is an outrage against residents and should not be allowed. there is concrete medical evidence on the web from hundreds of medical studies to back up what I have said check it for yourselves readers.

  6. Here we are a third of the way through the examination process and no credible and legitimate funding forthcoming from RSP. They have now missed THREE deadlines to provide PINS & the ExA with this information. I see yet again they are saying no night flights but are still applying for a very large QC quota that would allow them. Remember RSP said they only applied for night flights as planning inspectors said they had to and that was a lie, the planning inspectorate had said no such thing.

  7. The Manston cargo market is the London market. According to the CAA, in 2000, there were 27,294 dedicated cargo flights into all London airports. By 2018, this had shrunk year on year to 14,035. Would serious investors really be interested in investing in a business whose business plan is to capture 122% of a shrinking market. RSP’s investment vehicle MIO Investment is managed and administered by Helix Fiduciary which is mentioned in the Panama Papers.

  8. I’ve been listening to the Hearings over the past couple of days, where the Examining Authority (ie the Planing Inspectorate) has been looking in detail at RSP’s Application.
    I say ‘in detail ‘, but the reality is that there is no detail. Smoke, mirrors, obfuscation were the order of the day. Just the sort of thing you’d expect to hear from a snake oil salesman. Or the struck-off solicitor Tony Freudman.
    RSP’s ‘expert’ Dr Sally Dixon, author of the Azimuth Report on which RSP’s case is largely based was so flummoxed and flustered, floundering furiously, that she had to be rescued by other members of the team.

    • 14,000 houses is a ridiculous number Pippa, I agree. But its the Conservative Government policy, endorsed by our useless Council that they are coming anyway. At least SHP’s plan includes providing the supporting infrastructure.

    • It’s not the houses that I’m worried about, particularly. They won’t fly over me day and night, unlike cargo planes from a reopened Manston.
      Mr Broderick, One of the Planning Inspectors, commented yesterday having grilled Riveroak: “To sum up, there is no ban on night flights, is there?”

  9. The hearing title says it all. Need. It doesn’t matter which way you look at it, there is no NEED for Manston. The UK doesn’t need Manston to be a 24/7 cargo hub. There is no evidence of need in the RSP application and no evidence their nonsensical forecasts are viable.

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