Updated (Oct 22) with RSP and No Night Flights responses
An independent assessor’s report commissioned by the Secretary of State has concluded the case of need for a freight hub at the Manston airport site is not proven.
The draft report, drawn up by Ove Arup & Partners Ltd, was commissioned as part of the process of re-determination after approval for the airport project was given but then quashed by a High Court order.
The Development Consent Order granting approval for RSP’s air freight hub at Manston airport last July was quashed in February this year with a new decision now needing to be issued after a re-examination of the Planning Inspectorate evidence.
The action came as the result of a Judicial Review challenge to the decision, launched by Ramsgate resident Jenny Dawes. A substantive hearing was due to look at whether the Government followed correct procedure in reaching the decision to approve the DCO for airport landowners RiverOak Strategic Partners despite the Examining Authority conclusion which followed a lengthy process of public hearings in 2019.
Last December the Department of Transport acknowledged that the decision approval letter issued from the Minister of State did not contain enough detail about why approval was given against the advice of the Planning Inspectorate and said the Judicial Review would not be contested.
In June the Secretary of State appointed an independent aviation assessor to advise him on matters relating to the need for the development and to draft a report summarising those findings.
This report has been published today (October 21) and looks at various arguments for and against need of the airport.
Areas in the report
Amongst the areas looked at are any changes in demand for air freight, including as a result of Brexit and/or Covid 19.
The report examines the impact of e-commerce and air freight, including recent changes resulting from the Covid-19 pandemic; the impact of the Covid-19 pandemic on bellyhold capacity and the increased use of freighters; a shift to narrow bodies aircraft; the situation for post Brexit trade; longer-term impacts of Gross Domestic Product (GDP) on freight demand; and also changes in capacity at other airports which include a delay to expansion of Heathrow Airport; the Stansted Airport planning inquiry; and developments at East Midlands Airport.
RSP states that the current growth in online retail sales has ‘helped create a shift in transportation modes to favour air cargo’ and that the Covid-19 pandemic has driven and will continue to drive a sustained increase in online shopping. But York Aviation on behalf of Jennifer Dawes say: “Increases in e-commerce activity 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 on line, 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.”
The assessor says: “There is no clear evidence that the recent growth in e-commerce sales has created ‘a shift in transportation modes to favour air cargo’. Consequently, the Independent Assessor does not agree with the Applicant’s position that growing e-commerce sales are driving a demand for additional runway capacity (for dedicated freighters in the South East).”
In terms of belly-hold capacity – where freight travels below passengers in the same aircraft – the assessor said: “passenger demand and therefore belly-hold capacity is likely to recover as restrictions on international travel are lifted, restoring at least some of this capacity before Manston could be operational again.” The report said this would likely negate need for more dedicated freighter crafts.
The assessor also concluded they had not seen any evidence – one way or the other – on how changed trading arrangements post-Brexit will affect long distance trade or air freight demand.
The report quotes a submission from Cllr Rev Stuart Piper saying “Covid and Brexit have highlighted the potential problem of a temporary closure to the Port of Dover and the potential for future blockades. This is a major problem for perishable goods (…) Dedicated Freighters would alleviate this problem.”
The assessor agreed that “the provision of increased freight airport capacity can provide resilience against unforeseen events,” but said such events has ‘low probability’ of occurring.
Looking at freight capacity at Heathrow, Stanstead and the Midlands, the report acknowledges “A delay until at least 2030 on the opening of a third runway at Heathrow is, in the view of the Independent Assessors, likely,” saying this would” improve the need case for the Proposed Development.” But it then adds that there is freight capacity at Stanstead and East Midlands.
Also considered were the Government’s Net Zero climate strategy and The Transport Decarbonisation Plan.
The original recommendation from the examining panel said: “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.”
The new report from Ove Arup & Partners Ltd concludes there have been no significant changes since that recommendation in 2019 that “would lead to different conclusions being reached with respect to the need for the Manston development.”
Secretary of State Grant Shapps has today written to RSP and Interested Parties, inviting comments on the report by November 19 before making his decision.
As well as inviting comments on the draft report, the Secretary of State has requested several submissions from RSP and is also inviting comments from interested parties on “Decarbonising transport: a better, greener Britain” and the “Jet Zero consultation.”
(Update) RSP has issued a scathing response to the report, saying: “Having read the Assessor’s report – which didn’t take long – it is clear that it is an amateur and poorly constructed report. Setting aside the numerous grammatical errors and typos – not to mention the reference at para 1.3 to a section on the sixth Carbon Budget that the author has then apparently forgotten to even write – the content of this report does not address the broader strategic need case set out in the Secretary of State’s original decision letter and is little more than a by-the-numbers review of the Examining Authority’s previous report, and series of opaque assertions using pre-2019 data, with little or no detailed analysis or reasoning behind any of the conclusions drawn.
“To be honest, we have come to the conclusion that someone has accidentally sent an unfinished draft to the Department of Transport.
“For a report designed to inform the Government’s decision making on the nation’s long term global airfreight capacity needs, the thinking behind it appears firmly stuck in a pre-COVID past. It takes no account of the need for greater resilience in our logistics infrastructure the pandemic has highlighted, the permanent disruption to the traditional ‘just-in-time’ business model that has occurred – and the requirement for enhanced cross border trading infrastructure required to address this – nor even the constraints at existing airports pre-COVID that will re-appear as the industry recovers and will only get worse in the medium to longer term. The report therefore neither defines or deals with the need for Manston and pays absolutely no attention to the big picture strategic requirements of the UK in a post-pandemic, post-Brexit global market.
“As aviation propositions go, Manston is unique – because it will be built to be Carbon Net Zero from scratch, providing a model for future airport planning. It represents a perfect opportunity for the UK Government to demonstrate how it can deliver on its commitment to grow the aviation sector, whilst still meeting its decarbonisation targets, a model approach which UK expertise can then export around the world. It also provides the prospect of becoming a flagship levelling-up project, by providing much needed economic and employment stimulus to one of the UK’s most deprived areas – yet none of these considerations even feature in the report. Lower GDP will lower air freight demand? How about trying to increase GDP by increasing trading opportunities?
“Effectively, this report concludes that the Secretary of State should look in the rear view mirror to try and plan the future. How embarrassing. We need to be looking forward to a new, decarbonised aviation industry, serving the UK’s global trading and levelling up ambitions. We will be responding in depth, in due course.”
Ramsgate resident, and the person behind launching the JR bid, Jenny Dawes, said: “I am cautiously pleased by the findings of the Independent Assessor’s report and am now preparing a detailed response to the Secretary of State.”
A spokesperson for Ms Dawes’ team said: “In a letter published yesterday (21 October 2021) on the Planning Inspectorate website, alongside the report of the Government’s appointed Independent Assessor, Ove Arup & Partners Ltd, questions are raised about the commitment of RiverOak Strategic Partners (RSP) to the Development Consent Order (DCO) process.
“The Secretary of State for Transport has had to ask once again for information initially requested in June 2021 in relation to RSP’s Application, which he has yet to receive.
“RSP are required to provide details of their progress in negotiation with:
– local landowners regarding compulsory purchase of land
– the Ministry of Defence in relation to their High Resolution Direction Finder (currently located within the Manston boundaries)
– Network Rail.
“ In addition, Secretary of State Grant Shapps again requests updates to RSP’s environmental and historic environment impact reports.
“The Secretary of State also requests feedback from RSP regarding the impact on their Application of the Net Zero and decarbonisation papers.
“In addition to the paucity of information reaching the Secretary of State from the Applicant, the Civil Aviation Authority has twice refused RSP’s Change Process application to proceed to the next stage, for failing to fulfil the necessary criteria.
“It is worthy of note that, whilst the Department of Transport has paid their portion of the costs of the Judicial Review, as ordered by the Court, RSP continues to delay their payment.”
Save Manston Airport association
“It seems to us that much of the aviation data is pre the Secretary of State’s letter (9 July 2019). Such data should not be there at all according to the DfT guidelines. It should be replaced by the plentiful much more up-to-date information that is now available, showing a strong up-turn in aviation cargo.
“Regarding need for Manston Airport, that the report only has three references to jobs (At Heathrow, in Kent, and a dubious figure for Manston) and no references to changes in Thanet / East Kent deprivation, in the relevant timescale of the report, is shocking.
“At this stage SMAa will say little more than agree with RSP that the reportis “amateur and poorly constructed.” SMAa would be mortified if we had produced as poorly evidenced document as this draft Arup Report.
“RSP conclude : “We will be responding in depth, in due course.” As will SMAa, in the hope of informing the next version of the Arup Report with a more forward-looking reality and relevance.”
Cllr Karen Constantine
Ramsgate county councillor Karen Constantine said: “Whilst some people will feel disappointed, and I can appreciate it’s difficult when long held dreams fail, a great many more people, including myself will breathe a sigh of relief at the commonsense contained in the ARUP report.
“I believe it’s now time to look afresh at the future of the Manston site. Given our dreadful housing shortages and how local people are suffering by not being able to either rent or buy homes, and the urgent need to reduce our carbon emissions isn’t it time to build green homes? Both creating much needed homes and jobs.
“The community needs to come together over what has been a very divisive issue. Both of our MPs now need to step up and work harder to bring economic opportunity to Isle and not just rely on the Manston air cargo hub.
“One question remains intriguingly outstanding, now Manston is no longer a ‘flyer’ will Sir Roger Gale be true to his word and resign?
“He told the inquiry: “Manston airport site is of national strategic importance, very important locally and to Kent….. He said if the DCO or subsequent plans to reopen the airport were rejected he ‘would retire as MP.'”
North Thanet MP Sir Roger Gale
“I regard the draft “Manston Airport Assessors Report” as deeply flawed. That is not surprising as it contains numerous errors and no original material but is instead based upon one-sided extracts drawn from the original Inspectors` report which itself was flawed. For example, the report`s authors (led by Arup) appear to have made no effort to make contact with locally elected representatives to seek their views and have not addressed the reasons given for the Secretary of State`s original and correct decision.
!I shall submit a detailed critique in due course but in the meantime believe that this piece of work, which has so far cost the taxpayer £150,000 and has taken six months to prepare forty-one pages that could have been written over a weekend, deserves no credibility whatsoever. I shall be submitting a full critique to the Department For Transport.”
- 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;
- The recent growth in e-commerce sales is not driving a demand for additional runway capacity for dedicated air freighters in the South East;
- 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;
- 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;
- 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
- 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.