APPENDIX II

FUTURE DEVELOPMENT OF AIR TRANSPORT IN THE UK -SOUTH EAST

1. Background situation in Thanet

1.1. Thanet, and East Kent, is one of the most economically and socially deprived areas in the whole of the South East region. Unemployment levels are currently at twice the regional level; benefit dependency levels are 65% higher than the Kent average and the area is identified as a Priority Area for Economic Regeneration (PAER), in the Regional Economic Strategy, including priority in terms of investment in transport infrastructure.

1.2. Clearly, of prime concern to the Council is the future development of Manston Airport, which potentially could be one of the major economic drivers towards sustained regeneration in this area of high unemployment and economic and social deprivation.

1.3. Thanet has some 300 acres of land adjacent (within one mile of the runway) to the airport which is allocated for employment purposes which is suitable for the relocation of companies who either need to be, or find advantage in being, located close to an airport.

1 4. Manston Airport has a single runway which is 2750 metres in length, making it the fifth longest runway in the UK. There is substantial land for development, both within the ownership of the Airport Operator and on surrounding land. Road access is considered good, with either motorway or dual carriageway standard from London to the airport boundary .

1.5. Rail access is currently inadequate, but is capable of cost effective improvement. Irrespective of airport development, East Kent is seeking the Strategic Rail Authority to upgrade the through services from East Kent to London via Ashford and the Channel Tunnel Rail Link. With the development of the airport the case for better quality and faster services to London is, in the Council's view, overwhelming. Relatively limited expenditure on rail infrastructure should make it possible to achieve journey times to the Airport from London of about 60 minutes. The Council's position in respect of the case to be made to the SRA on this issue is contained in the attached documents which were submitted to the SRA on the 2nd September 2002, and which should be considered in parallel with the consultation exercise on airport capacity.

1.6. In the Council's view, the connection between through fast rail services and the development of the airport for passenger services, is both logical and economically viable both in terms of the development of the airport itself and of the wider East Kent Region, which would benefit enormously from this twin track approach to developing the area and which would do so much for the economic and social regeneration of East Kent and of Thanet in particular.

1.7. Manston has immediate capacity to cater for up to half a million passengers per year without any investment whatever in additional off site infrastructure. Almost uniquely, the SERAS study, in referring to Manston describes it as "having a long runway and has a relatively supportive planning environment".

1.8. Uniquely, because with relatively few exceptions, the local community and the Local Planning Authorities, together with the Kent County Council, as Strategic Planning Authority, fully support the development of Manston. Both Thanet and Kent Councils see the potential of Manston at between 4-6 million passengers per annum by 2020, with potential to expand to 10 million by 2030, whereas the SERAS Study suggests an upper capability of just 3 million passengers per annum.

1.9. This is a position which the Council does not accept!

• Manston can be developed based on existing infrastructure, and the existing long runway, to produce an immediate effect upon available capacity within the South East Region;
• Unlike virtually every other airport, Manston has a very supportive local community, and local business community, who wish to see it developed;
• It is situated in an area much in need of regeneration where Government recognition of the development opportunities would be a major boost to employment, not just at the airport, but in the encouragement of new companies to invest and existing companies such as Pfizer, to continue to have confidence and to invest in the local community.
• The combination of available employment land, an existing airport and a willing workforce could be the economic catalyst that Thanet, or even the whole of East Kent, needs to achieve sustainable regeneration. The development of Manston to 4-6 million passengers can be achieved with relatively little in the way of off site infrastructure costs, when compared with other options.
• Road access is already to a high standard and only local road improvements would be required. Rail access is deficient, but at a relatively limited cost (certainly in relation to any other of the airport proposals put forward) rail access could be improved such as to make the journey time from central London to the airport approximately one hour.
• The consequential economic and social regeneration arising from investment in East Kent would reduce the benefit dependency of the local community, increase self confidence and increase tax generation levels to what one might term normal levels with consequent substantial economic benefit to the national economy.
• Development of Manston, unlike Cliffe, would not entail major disruption of UK Air Traffic Control capability.

2. Airfreight Development at Manston

2.1. The Consultation Document effectively makes no mention of the development of air freight services at Manston, although the document acknowledges that Manston is currently the 7'h largest airfreight operation in the UK. The length of runway and the recently completed programme of construction of new aprons and taxiways, and the proximity of 300 acres of development land for associated development in the Council's view, offers far more potential than the Consultation Document currently recognises. Particularly, as Alconbury the airport identified for freight development is no closer to London than Manston. The expectation is that by the end of the year 2002-03, Manston will handle 70,000, tonnes of freight and that over the next few years that will expand considerably. The Council expects, and is planning for, the airport to handle 250,000 tonnes of airfreight by 2010.

2.2. The Council fully supports the development of freight services at Manston, but not on an unrestricted 24 hour basis, as this would cause unnecessary disturbance and sleep deprivation to nearby residents. However, the availability of a long runway capable of handling long haul flights and available adjacent land for development offers opportunities in dedicated international freight handling rather than parcel/package delivery, where night time operation is less critical and in the Council's view should be developed and promoted within the Strategy to a position at least comparably with Alconbury.

3. The impact of constructing a new hub airport at Cliffe

3.1. One of the proposed options put forward in the Consultation Document is for the construction of a new hub airport completely from an undeveloped greenfield site, with four runways and 24 hour operation, at Cliffe (on the Hoo Peninsular in North Kent). The main advantage of the location relates to the availability of sufficient land, potentially good surface transport links with London and other areas (proximity to M25 -subject to substantial investment); the relatively low numbers of people affected by aircraft noise and the potential for a 24 hour operation. In addition, it is argued that the development of the airport would give support to the regeneration policies of the Thames Gateway.

3.2. The major disadvantages relate to the cost of construction (estimated at £11.5 billion); the high infrastructure costs associated with the development; the loss of existing property (1100 residential properties would be physically taken; 2000 hectares of agricultural land would be lost and a number of Grade I and Grade II listed buildings would be lost). The area is of high ecological value and has a number of international designations in nature conservation and any development is likely to infringe a wide range of legislation, both national and European, for the protection of wildlife. This in turn has mitigation measures which directly affect Thanet (see 'Implications of Mitigation' below).

3.3. Of concern to the whole of Kent is the likely impact on the economy of such a major investment. Employment levels, supply of services and investment opportunities will for a long time be disrupted to support such an enterprise such that the whole of the rest of Kent is likely to be disadvantaged. Of particular concern is the huge investment necessary to provide access to such a proposed airport. All available road and rail facilities will be vastly over subscribed by those travelling to and from the airport. Of particular concern for East Kent will be the effect on rail services, already over-stretched. Even the potential opportunities for domestic service on the CTRL to improve services to East Kent would be likely to be lost due to the overwhelming demand for airport services.

3.4. Of direct implication for Manston would be that if the development of Cliffe took place, it could severely disrupt the development of both Manston and Southend Airports, which would, at the very least, lose capability for instrument landing, which in the case of Manston would probably mean that international flights would be either severely disrupted or impossible to operate.

3.5. Cliffe, developed as a fourth London Airport, would have major implications for air traffic movements throughout the South East. Many of the planes that currently operate from Heathrow and Gatwick use the Thames Estuary as part of the pattern of approach and departure. The introduction of a new hub airport within the area would inevitably result in major disruption to all of the London Airports in terms of the ability to manage that number of air movements in such a contained air corridor.

3.6. There is little doubt that development at Cliffe, as a hub airport, would be an extremely expensive option in terms of the development of airport capacity for the South East, but would also likely to have major environmental consequences which, from an international and European perspective could be avoided, as there are clearly alternatives to the total destruction of this important environmental location. As such, this would be a very controversial option, if pursued in the White Paper, likely to result in potential legal action through the courts in both the UK and Europe.

4. The Implications of Mitigation Measures

4.1. As mentioned above, the development of the Cliffe site has implications in respect of international designations in terms of nature conservation. Any development is likely to infringe a wide range of legislation, both national and European, for the protection of wildlife. The "Habitats Directive" indicates that a plan or project can only go ahead where there is no alternative solution or in exceptional circumstances where compensatory measures necessary to ensure the protection of the overall situation are included within the development proposals.

4.2. In the case of the Cliffe site, the development would effectively eradicate the nature conservation interest and, therefore, in a supplementary document to the consultation documents a study was undertaken of the potential for alternative nature conservation sites to be created equivalent to, or larger than, the site to be lost at Cliffe. The consultants looked at a range of alternative sites in Essex, Kent, Sussex and as far away as the French, Belgium and Dutch coasts, which met a number of broad criteria in terms of size, proximity to other designated nature conservation sites and a desired relation with the 'flyways' of migratory birds that would use Cliffe at present. The result of that search has focused on the area between Reculver and Birchington and the Stour Valley is potentially the most attractive site for the provision of mitigation if the Cliffe proposal goes ahead.

4.3. In effect, the proposal would be to create a new managed nature conservation site extending from the coast between Reculver and Birchington through to the Stour Valley and effectively linking up with the areas already covered by coastal designation at Pegwell and the ~andwich Coast. As far as the consultants are concerned, this area fulfils the criteria as follows:

• most of the area has no national or international designation and, therefore, can be considered as an additional facility;
• it is an extremely large area (30-35 square km) (the approximate area that will be lost to Cliffe is 25 square km);
• it is comparatively close to the Cliffe area;
• it is low lying and susceptible to flooding and, therefore, could easily be turned into wetland;
• there is potential to create mudflats on its northern shoreline; .it would link in well with adjacent SPA's and wetlands.

4.4. A number of options were considered which have different cost implications although all of the six options considered also involve management to the benefit of nature conservation of the Stour Valley with the creation of changes to the drainage areas and the creation of wetlands and fresh water lagoons and pools within the existing river system. The five options are indicated in an extract from the document, with plans, as Appendix IV of this report. However, in brief they are:

• Scheme 1 -Managed retreat to the Heme Bay to Margate railway line -estimated cost £45 million (excluding land purchase).
• Scheme 2- Managed retreat to the A299 -cost £75 million (excluding land purchase).
• Scheme 3- Managed retreat to a relocated railway line -cost £57 million (excluding land purchase and railway relocation).
• Scheme 4- extension of the existing mudflats -cost £135 million-
• Scheme 5 -the creation of off shore mudflat creation -cost £200 million- .Scheme 6 -a combination of 4 and 1.

5. The implications for Thanet and Manston

5.1. It will not have escaped anyone's attention that there are a number of major infrastructure links within the area identified for creation of an intertidal habitat. The main Margate to Victoria, North Kent Rail Line, passes through the area and would potentially be threatened by inundation as a result of these proposals. Without substantial new coastal defence works to protect the line, rather than the current coastal protection, the rail line would be under considerable threat. Even if substantial coastal defence works were undertaken on the seaward side of the railway line, there is still a much greater potential for coastal erosion and inundation of the line making the provision of a guaranteed service more difficult and more likely to disruption. This line is not a branch line and provides the main line services between the Thanet towns and London and any potential disruption would simply be unacceptable and would, therefore, require substantial works to ensure a guaranteed service.

5.2. One of the other options is to develop the intertidal area up to the Thanet Way (A299). This, as everyone knows, is the main road link to Thanet from the rest of Kent and from London. The Road was not constructed to levels much above the surrounding reclaimed land and allowing the inundation of the sea right up to the line of the A299 would inevitably place the road under threat also. Almost inevitably at periods of high tides and storm conditions the road would be likely to be flooded (particularly in the area close to the existing Wantsum Channel). Given that these are the principal transport arteries between the rest of Kent and Thanet it would be totally unacceptable to have any scheme of managed retreat which put these two principal transport routes in jeopardy and should further work on this option be developed the Council would seek firm assurances that both routes were adequately protected and or raised sufficient to guarantee that their use would not be disrupted in abnormal weather conditions.

5.3. Furthermore, the Council would have to seek assurances that if such mitigation measures were being examined seriously, that none of these proposals would be considered acceptable without a thorough study of the implications for the existing marine processes which operate on the North Kent coastal area. Much of the current movement of sand along the North Thanet coast operates in a cyclic system moving along the coast from west to east. This cyclic system creates the movement of sand on the North Kent beaches of Minnis Bay, Westgate and Margate through to North Foreland. Any disruption of these process could, if not studied sufficiently prior to implementation, result in a disruption of the cyclic flow sufficient to denude the existing bays of their sand cover, or disrupt the movement sufficient to change the pattern of sand deposition and erosion. In economic terms for the Isle of Thanet this could be disastrous given the importance of tourism in the local economy.

5.4. Of critical importance, however, would be the result of the creation of such an extensive habitat area which would be likely to be the biggest new managed habitat anywhere in the country. Effectively creating a ring around the entire ThaneVurban area from Pegwell Bay to Reculver. There are obvious questions as to whether wildlife can be encouraged to make such a move, however; on the assumption that such an environment can be created then inevitably the area would be given protection under the various nature conservation national and international designations. In effect, this would create an environment in which Manston Airport simply could not exist. All potential development at the airport would be subject to the 'Habitats Directive' and to the other nature conservation legislation. In effect, this would inevitably give priority to the nature conservation interest over the commercial development of the airport and the airport as a commercial operation would effectively cease. Manston currently operates with approximately 70% of flights to the west. The Noise Abatement Routes take aircraft over the area to be created as a wetland habitat at between 2-4,000 feet. The potential disturbance and possibility of 'birdstrike' would, in the Council's view, totally curtail operations for heavy aircraft. The implication of that threat to the business development of the airport at some date in the future, would be to blight development opportunities and could result in substantially higher potential costs than envisaged in bringing about the mitigation measures, as a result of compensation payable to the owners of the airport for both their existing and potential business loss specifically brought about by this proposal.

6.1. It is clearly the Council's position that it is strongly opposed to the development of Cliffe, as the economic and environmental consequences for Kent as a whole and for Thanet in particular, and in respect of the proposed mitigation measures, would be totally unacceptable. Manston Airport is considered, not just by Thanet Council, but by East Kent in general, as a potential major generator of new employment opportunities in the East Kent area. The proposals for Cliffe and the mitigation measures associated with that proposal, would totally destroy the opportunity that the airport offers to East Kent area and to Thanet in particular, and no alternative package of economic measures, even if proposed, could come close to creating the conditions for employment generation that the airport and associated development would bring to the area. It is not, in the Council's view, acceptable to consider, as has been suggested elsewhere, that the trickle down economic effects of development of Cliffe would somehow improve the lot of the people of Thanet. Such a suggestion is unsustainable in terms of the local economy and of opportunities for a reasonable quality of life afforded to the people of Thanet. The job creation and other opportunities created at Cliffe would in the Council's view attract all potential labour and all investment opportunities to that area leaving Thanet with major economic and social deprivation for many years. Whilst the Council would never wish to see it happen, if Cliffe is chosen as the site for a hub airport, Thanet will require a package of economic mitigation measures to offset the devastating impact, and blight to the economy that will occur.

6.2. Rather it is the Council's view that the SERAS Consultation Document significantly underplays the contribution which Manston could make to the development of both passenger capacity in the South East and to airfreight development. There is strong local support for the development of the airport and sound economic reasons why investment should be encouraged in this area of high economic and social deprivation. The principal infrastructure problem appears to be the inadequacy of the existing rail services which as demonstrated above, can be overcome at relatively little direct cost but with substantial potential savings to the UK economy as a whole in terms of the regeneration of East Kent.

6.3. The Council, together with the owners of the airport, have worked successfully to develop a development framework, through a series. of Section 106 Agreements which have successfully balanced the economic development potential of the airport against the genuinely held environmental concerns of those living closest to the fJightpath. This close working relationship can be extended into the future with further development of the airport, particularly with the introduction of more modern quieter aeroplanes and continued good management. The planning and economic environment in Thanet, and in East Kent, is positive towards the further development of Manston and the Department of Transport should recognise this position.

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