29 November 2002

Our Ref: PT/cg26

The Future Development of Air Transport in the UK (South East)
Chelmsford data Centre
Caxton House
Freepost KE4466
Chelmsford
CM1 1ZZ

Dear Sir

THE FUTURE DEVELOPMENT OF AIR TRANSPORT IN THE UNITED KINGDOM: SOUTH EAST

In response to the Department for Transport’s Consultation Document I attach the formal response from the Wiggins Group as the owners and operators of London Manston Airport.

The response is in two parts; first, our response to the ‘Questions for Consultees’, and secondly a summary statement of the capacity and capabilities of London Manston Airport.

It is our contention that the Government and its consultants have failed to appreciate the true potential of London Manston Airport. It is the considered opinion of consultant’s Arthur D Little (ADL) that Manston has the potential to grow into a sizeable airport, even if London’s five main airports had unlimited capacity and grew traffic at the Government’s middle rates projection. Independent of developments at other London airports, Manston expects to see passenger traffic of between 4-6 million passengers over the next 10 years. If the acknowledged shortfall in capacity persists until 2020, Manston has the potential to attract between 10 and 15 million passengers by 2020. Copies of ADL’s report and copies of the Strategic Master Plan based on ADL’s major piece of research were published in April 2001 and made available to the then DETR. Notwithstanding formal discussions with the then DETR on the content of the ADL report it can only be assumed that the publication of a major and detailed study of Manston’s potential was too late to influence work on SERAS and so be incorporated into the Government’s Consultation Document.

In parallel with forecast growth in passenger traffic, Manston has, since acquiring its CAA licence in September 1999, continued its successful efforts to attract cargo traffic. At present, the Airport manages an annual throughput of about 40,000 tonnes. Within the freight market the Airport has established a reputation for unparalleled efficiency in the handling of perishable cargo. The completion of a new taxiway and aprons, officially opened in August by David Jamieson MP, provides the Airport a capacity to accept tonnage in excess of 200,000 tonnes, a throughput that will be achieved over the next 2-3 years with the availability of additional warehousing and cold storage facilities and the creation of a Border Inspection Post. With the considerable interest being shown in Manston by established international cargo operators, Manston is confident of realizing the potential for 350,000 to 400,000 tonnes by 2020. Indeed, the local planning authority (Thanet District Council) in its formal response to the Government’s Consultation Document has stated that it ‘expects, and is planning for, the Airport to handle 250,000 tonnes of airfreight by 2010’.

Notwithstanding any views collected by the Department’s consultants when they visited Manston in 1999, the reality is that in the intervening period the Airport has worked closely with the local and regional authorities to ensure that future development respects the principles of sustainable development and that an appropriate balance is struck between maximising the significant social and economic benefits of airport expansion whilst minimising the environmental impacts. The result of that on-going work is reflected in the unanimous support given to the Airport by the local villages, parish and town councils, district and county authorities and the East Kent Triangle Area Strategic Partnership.

To argue that Manston is somehow too remote to be able to attract sizeable volumes of traffic is to ignore the very real prospect of CTRL Domestic Services operating from 2007 fast through services from London to East Kent and offering an overall journey time of just under the hour. It also betrays an apparent ignorance of the relatively low cost of the necessary rail upgrades and improvements. In addition to improvements to the existing rail infrastructure, Manston is already well served by fast motorway and dual carriageway which runs to the perimeter of the Airport, and has quick and efficient road access to the Ports of Ramsgate and Dover, and to the Cross Channel Tunnel thus reinforcing the Airport’s attractiveness as a gateway to Europe.

Lastly, it has been argued that one of the key constraints on Manston’s development is the noise impact over the nearby town of Ramsgate. That this is a key constraint is not accepted. That aircraft noise is and will remain an important issue for any airport’s operation is a reality that has somehow to be managed to the point that it is acceptable in relation to the wider benefits that an airport brings to the local and regional economies. At Manston, the Airport and its Consultative Committee continues to work closely in identifying new noise management techniques (for example, noise abatement routes) that minimise the impact of aircraft noise over nearby villages and towns, including Ramsgate. A Sound Insulation Grant Scheme is being introduced to help mitigate the impact of aircraft noise to those living within the 63dBLAeq noise contour of the Airport. Projections of future noise contours based on forecasts of growth and aircraft fleet mix are regularly reviewed with the aim of helping to identify further noise mitigation measures that might be introduced consistent with the introduction of newer and quieter aircraft and improved operating procedures. An example is the attached projected noise contour based on an assumed annual throughput of 1.5 million passengers and 200,000 tonnes of freight. In addition, careful consideration is currently being given to extending the length of Manston’s 2,752 metre long runway to further minimise the noise impact and to contain a 57 dBLAeq noise contour as close to the Airport’s eastern boundary as possible.

These significant developments and those that are planned and represented in the Strategic Master Plan for the Airport demonstrate clearly that events have moved on from the days in 1999 when the Airport was in its infancy and having to manage on the basis of an outdated airport infrastructure that whilst meeting the needs of the RAF was wholly inappropriate for a modern and efficient airport operation. Whilst the potential that Manston currently has could not offer the solution to the capacity crisis in the South East, it is the case that the Airport already has the ability to make a major contribution to easing congestion at the main South East airports and to supporting the growth of both passenger and importantly air cargo traffic.

Yours faithfully

 

 

P H TIPPLE
Head of Strategy and Development

 ANNEX A

QUESTIONS FOR CONSULTEES – RESPONSE BY THE WIGGINS GROUP

SECTION 1 – HOW MUCH CAPACITY SHOULD BE PROVIDED?

Q1 Should new airport capacity be provided in the South East over the next 30 years and, if so, how much? What are the main reasons for your answer and how does it measure against the environmental, economic and social objectives of the Government’s strategy for sustainable development?

A1 The starting point here must be an assessment of future demand and importantly the likely nature of that demand. It is difficult to take issue over the forecasts for 2030 (500 mppa for the UK and 300 mppa for the South East). Given the inherent problems of forecasting over such a long period, we believe that the figures are in the right ballpark, accepting that they provide the best available forecast of unconstrained demand and should be subject to regular review and update. But the figures alone conceal the considerable uncertainties felt throughout the aviation industry as to what the future actually holds. Will there, for example, be further consolidation of capacity and routes on the part of the major international airline operators? What will be the impact of the advent of larger, wider-bodied passenger and freight aircraft on airport capabilities and capacities, and how will this relate to the continued forecast growth in point to point air travel undertaken by the low cost carriers and now by established major airlines seeking to challenge the supremacy of the low cost carriers but still on the basis of operating point to point routes? The second main area of concern is the extent to which airline operations will be allowed to grow in an unconstrained environment without the imposition of environmental control measures and accompanying fiscal regimes, the effect of which might well be to constrain growth. Lastly, there is the concern about the ability of national air space management policies and actual control regimes to be able to continue to support growth in airline operations until such time as new technologies are available to open air space to greater more flexible use.

Against that background the Government should, within the strategic framework provided by its long-term growth forecasts for both passengers and freight, introduce a 15-year rolling programme for airport/runway development that is reviewed and updated every 5 years. This would afford the opportunity to introduce a demand managed strategy for increased runway capacity that would have at its heart the need for specific proposals for airport expansion to be judged against the criteria of national/strategic needs, technological advances, commercial imperatives, environmental impacts and sustainable development.

Within the next 15 years it is reasonable to plan on the basis of the Government’s mid-point forecast of unconstrained demand of around 200 million passengers in the South East. By maximising the existing runway capacity of each of the main sites at Heathrow, Gatwick, Stansted and Luton, it would be possible to meet a forecast traffic figure of about 154 million passengers. Assuming that no constraints were applied to growth at identified first tier and selected second tier airports in the South East, there should be every confidence in minimising ‘shortfalls’ or ‘traffic lost to the UK system’ to some 30 million. On that premise it is possible to construct a robust case for at least one new runway in the South East and to select the appropriate existing airport location. The need for subsequent additional runway capacity in the South East can then be reviewed over the following 7-10 years in the light of actual growth and the emerging pattern of airline operations.

This approach implies a clear commitment to maximising the position of Heathrow and Gatwick together as providing the necessary hub capability in the South East and so meeting the key strategic economic imperative whilst minimising the environmental impacts. The development of capacity at the other main South East airports to support the growing demand for point to point air travel and to accept traffic that is not essential to the operation of Heathrow and Gatwick as the South East hub offers the real prospect of making the most efficient and effective use of existing airport resources in a manner that exploits the existing and planned surface access arrangements, that enhances economic regeneration in those areas where airport growth will create badly needed employment and foster improved social cohesion, and importantly that serves also to attract inbound tourism to the regions.

Q2 Should the Government aim to maintain at least one large hub airport in the South East? Is a second hub plausible, and if so, should Government seek to promote one, and what would it need to do to achieve this?

A2 We see no case for a new purpose built hub airport in the South East. The notion of airports operating a hub and spoke system is essentially an outdated American concept that has been proved not to work in competitive situations (e.g. Mirabel Airport in Montreal, Canada). In North America it effectively defeated the liberalising measures brought in 20 years ago and has been responsible for killing competition and for driving domestic fares to unacceptable levels. Indeed, the hub and spoke system was largely responsible for passenger satisfaction levels standing at an all-time low prior to September 11. It is considered to be a wholly inappropriate concept to introduce to a European environment yet alone to the geography of the UK.

Heathrow and Gatwick already function as partial hubs, and the complex of the main South East airports already provides in overall terms an effective hub network. The development of a hub airport at an established site such as Stansted would undoubtedly have the effect of downgrading the position of Heathrow and Gatwick, a situation that would be exacerbated by any thought of creating a new unnecessary, unsuitable and unsustainable airport complex at Cliffe. The emphasis should therefore be on maximising the existing capacity of both Heathrow and Gatwick (with direct rail links) to meet the demands for hub traffic, and on redistributing the growth in point-to-point travel, charter and domestic traffic across other existing airports in the South East that have the infrastructure to support such operations.

Q3 Are there any benefits of aviation to passengers, the aviation industry or the wider economy that the Government should aim in particular to secure through its airports policy? Are there any drawbacks it should aim to avoid?

A3 It is undoubtedly the case that aviation contributes significantly to the UK economy. It is also the case that people in the UK fly a lot, a fact that should not be too surprising given our island heritage and the obvious constraints that attach to travel by other means of transport. But the expansion of airports has to be scrutinised in the context of the Government’s stated policy that airports, particularly in the South East should aim to maximise the significant social and economic benefits that growth in aviation would bring whilst trying to minimise the environmental impacts. In addition the Government’s policy should aim to provide a framework that gives the aviation industry confidence in its ability to grow and provides investors the stability needed to attract long-term investment in improved infrastructure. In parallel with determining the strategy and policies that will guide the development of the aviation industry, the Government should be looking to develop, with the industry ways in which the needs of the travelling public are better provided for. For most passengers (international and domestic) the experience of flying through the main UK airports is stressful and often unpleasant. For airport expansion to attract a greater measure of public support there needs to be an acceptance of the need for airport facilities to provide improved check-in arrangements (with enhanced security), improved waiting times, improved access to public transport services and more comfortable terminal arrangements. Lastly, the Government’s policy should address in significantly more depth the enormous opportunities for the UK to establish itself in trading terms as an ‘air cargo friendly’ destination, with specialist facilities to support the demands of the growing niche sectors of perishables and inventory management..

Q4 Should the Government seek to ensure that the potential employment benefits of aviation growth are spread to those people and localities which are most in need of such benefits? If so, what should it do to achieve this?

A4 The Government should ensure that the potential employment benefits of aviation growth are spread to as large a number of people and communities as is possible. There are many areas of the United Kingdom that are in need of economic development and regeneration. Government policy should be to develop a balance between the need for airports with hub capabilities, growth in regional airports and making the most of existing capacity. Putting to one side the particular arguments that militate against a new hub airport in the South East, one of the Government’s policy objectives for aviation ought to be to help focus development in areas where airport expansion will serve to promote badly needed economic regeneration and give impetus to existing fledgling programmes for improved surface access (both road and rail) and the creation of new employment opportunities, consistent with the principles of sustainable development. In a similar vein, regional airport development also offers the opportunity to promote inbound tourism and so strengthen local economies.

This argues against an excessive concentration of resources to any one particular site, since to do so runs real risks of overheating the local economy and of so unbalancing investment across a region that it leads in the long term to unsustainable growth. Rather, the emphasis should be on maximising the potential both of the existing main South East airports and the first and second tier airports, particularly where, as in the case of Gatwick and Manston, existing catchments and recruiting areas contain high levels of unemployment. In a similar vein the potential of other regional airports across the country should be maximised, particularly in regions where the economic and social impact will be felt most keenly and be of tangible advantage to the residents most affected by airport development.

 

SECTION 2 – WHERE TO PROVIDE ANY NEW AIRPORT CAPACITY?

Q5 To which criteria should the Government attach the most and the least weight in reaching decisions about the location of any new capacity, and why?

In addressing the need for and location of any new runway capacity, there is first and foremost a need for the Government to articulate clearly its view on the future of Heathrow, not only in terms of it function (nationally as well as within the South East) but also of its capacity. All the available evidence suggests that there is a strong business case for further expansion at Heathrow, but the environmental and social implications of this are real and serious. Clearly there is a question as to how long Heathrow (without further expansion) will be able to maintain its pre-eminence in the regime of UK airports. But as referred to earlier (Response to Q2) it ought to be possible to maximise Heathrow’s hub capabilities in parallel with those of Gatwick to enable London to remain the focus of hub operations, and so begin a much needed process of persuading those airlines not dependent on access to an international hub airport to adjust their patterns of operation to embrace other airport locations in the South East. On balance, a strategy that allows for a more efficient hub operation at Heathrow but does not extend basic runway capacity is probably the most pragmatic if not the most convenient solution. The implication of this approach is that every effort has to be made to maximise existing runway capacity at other airports in the South East, particularly where they are able to support point-to-point, charter and UK domestic passenger traffic by drawing from a strong regional catchment and, by virtue of improved rail access, able to extend that catchment as well as provide attractive destinations for inbound passenger and cargo traffic. This will require that airline operators, particularly the low cost airline operators, adapt their operations to reflect better the wish of passengers to be able to embark from airports within a reasonable distance of their homes, thus minimising the impact on the road network. The second key implication of this approach is that additional runway capacity should be phased and concentrated at Gatwick (post 2020) and Stansted. A failure to recognise Gatwick’s potentially major contribution to maintaining a strong hub capability in the South East runs a very real risk of undermining its current role and stifling the prospect of sensibly structured investment in the long-term. We suggest that the least weight should be attached to surface access issues where a solution involves no more than an upgrade to existing infrastructure.

 

Q6 What are the relative merits of these alternative combinations of possible airport development as set out in Chapter 14?

A6 On the premise that there is no case for a new hub airport at Cliffe, and as argued for above, the most attractive combination for the development of airports and runway capacity in the South East is to make the maximum use of all existing runways in the South East – including first and second tier airports - whilst at the same time developing Heathrow (and Gatwick) to the level of their combined capacity for hub operations. Additional runway capacity to support an expansion of hub operations would best be provided at Gatwick with Stansted attracting additional runway capacity to support demand. This combination provides the optimum balance between economic improvements to the UK economy whilst limiting the environmental impacts of increasing airport capacity in the South East.

Q7 Giving reasons for your answer, which combinations do you prefer and which do you not favour?

A7 Not surprisingly in view of earlier responses, we favour an approach that maximises identified capacity of the main South East airports, supplemented by allowing each of the identified first tier airports and the second tier airports of Manston and Southend to meet as much of the demand as they can attract. The actual siting of additional runway capacity should be determined essentially by the nature of the then forecast demand. That suggests a combination of maximum use across the South East and a second runway at Stansted (supporting a forecast traffic figure of an additional 48 mppa) provided that such a solution would not undermine the position of Heathrow and Gatwick as primarily international hub airports. Such an approach would help ensure a fair and equitable distribution of economic growth and prosperity across the South East whilst minimising the environmental impact and presenting valuable opportunities for promoting economic regeneration and improved public transport services. Stansted has the potential to grow substantially without affecting either a large population or an internationally important environmentally sensitive area and, in combination with allowing and encouraging existing airports to expand to their potential (given any environmental concerns) would provide the most acceptable combination.

Q8 If you think either Cliffe or Stansted should be developed as a hub airport, should the Government take action to ensure such development can be financed and subsequently fully utilised and if so what form should any action take?

A8 It is our view that Stansted should not be developed as a hub airport. Furthermore, we see no evidence in support of a new hub airport at Cliffe.

Other South East airports (Chapter 12)

Q9 Should the Government encourage the development of smaller airports to meet as much of the demand as they can attract?

A9 Yes, without any doubt. Within the South East the identified first tier airports and the second tier airports of Manston and Southend should most certainly be allowed to develop as quickly and as fully as possible, the more so given their ability to contribute to easing slot pressures and to absorb overspill from the London hub airports. As important is the ability of such airports to accept growth on point-to-point traffic and to configure their ground handling operations to become ‘cargo-friendly’ airports. Many of these airports (particularly Southampton and Manston) are located in areas of relative economic and social deprivation and would benefit considerably from Government encouragement to develop business opportunities.

Q10 Should support be given for a specialised low cost/freight and maintenance facility at Alconbury?

A10 The case for a new airport at Alconbury concentrating on low cost/freight traffic and serving the interests of the South East has not been demonstrated. Alconbury is distant from the core commercial activities of the South East, particularly London and the area to the south and east, and is arguably better placed to serve the commercial needs of the Midlands assuming of course that existing airports in that region cannot support forecast demand. Interestingly, Alconbury and Manston are equidistant from London with the latter already able to handle at least 200,000 tonnes of freight carried by large, wide-bodied freighter aircraft, and capable of significant expansion as a cargo friendly airport. In terms of allowing the diversion of dedicated airfreight away from Stansted, Gatwick and other sites, Manston already provides the range of facilities to accept cargo and access markets in London and its environs. It is difficult to see therefore a justification for creating a new airport at Alconbury. It may be that Alconbury has a role as a 24 hour operation specialising in express freight, and if that were the case one would want to see evidence of the inability of airports such as East Midlands (and others) to continue handling such traffic and meet the forecast demand in that niche market. More generally, there appears to be no overt local or regional support for the development of Alconbury on the scale suggested in the Consultation Document, other than for the possible provision of a maintenance and aviation facility on the site.

Q11 If so, what conditions, in broad terms, should be attached to this support?

A11 (Not applicable)

Q12 What views do you have about the six sites identified in the SERAS study as having the potential to cater for the demand for Business and other General Aviation?

A12 It is clear that as capacity constraints at the main South East airports start to bite, business and general aviation will need to migrate to other airports. Farnborough and Northolt would appear particularly well placed to accept overspill, particularly from Heathrow. Poor surface access to Biggin Hill might place a natural limit on attracting additional traffic but in principle there is every reason to support carefully controlled growth there. Southend falls within the category of a second tier airport that should be allowed to attract as much traffic as its infrastructure will support. More generally, we support the use of sites capable of accepting business and general aviation provided that their operations are compatible with airspace management strictures and in that context do not hinder the operation of larger established airports.

Freight (Chapter 13)

Q13 How far should the Government make specific provision for the air freight sector in its decisions about future airport capacity in the South East? What might this involve in practice?

A13 Global trends in the airfreight sector offer significant opportunities for the UK to enhance its strategic position as a major international trading country. The Government’s Consultation Document already acknowledges the potential growth in the sector over the next 30 years but fails to address the underlying trends that will characterise requirements on the ground for fast turnarounds and swift onward distribution of cargo. Attention should be given to the implications for cargo traffic of the fact that growth in the low cost passenger sector will not provide a belly cargo carrying capability. In order to make the most of the available capacity, as much airfreight cargo as is possible should be diverted from the main South East airports. A key factor in the development of airfreight is the availability of business parks/industrial land in the immediate vicinity of the airport and in that respect Manston offers a substantial opportunity, particularly in relation to freight operations in the South East.

SECTION 3 - MANAGING THE IMPACTS OF AIRPORT GROWTH

Q14 Are there any specific conditions that you feel should be attached to any or all of the airport options described in Chapters 7-11?

A14 As in the development of all airports a balance has to be struck between the commercial imperatives of growing the business that is an airport, the importance of an airport’s development for the economic regeneration of an area or region, and the environmental concerns of those living close to or affected by the operation. This is a matter that ultimately should be resolved locally through negotiations between the surrounding local authorities and the airport owners and developed through best management practice. But it would be invidious if one airport were to find itself disadvantaged by the actions of another, either at home or abroad. It is therefore imperative that local negotiations take place within an overall international and EU framework, and that regional and local authorities be given latitude to reach solutions appropriate to local circumstances.

Of most concern to those living close to an airport are issues related to aircraft noise and the potential for disturbance, particularly during night flying operations, if they exist. The Government should take a position in relation to all airports, above a reasonable size, in respect of night-time flying operations, even if this does mean an increase in costs for airport operators and airlines.

Q15 Are there any impacts reported in the chapters on individual airport options that you consider unacceptable?

A15 The environmental impact of a development at Cliffe is of such a scale that it sits apart from any consideration of the environmental impact of providing additional capacity at existing airports. The Cliffe proposal is not practical, viable or environmentally acceptable, the more so given the disastrous consequences such a development would have on east Kent and its plans for economic regeneration. .

Q16 How can local noise and air quality impacts in particular, best be reduced, controlled and mitigated?

A16 Again, these matters are best dealt with locally in relation to legally enforceable planning agreements, such as the use of Section 106 Agreements on a planning permission, at which time the local authority and the airport operator can negotiate the appropriate balance between economic development and environmental concern. Equally, however, solutions need to be found that are compatible with an overall policy framework reflecting international and EU agreements and undertakings to which the UK is a party.

Noise controls (Chapter 16)

Q17 What are your views on the following points on the control of noise impacts:

  • Do you think that caps on the size of noise contours are the best way to determine a noise limit for an airport? If not, what other limits might you suggest?
  • If you agree with the concept of contour caps, what size of noise contours might be desirable and feasible for each option?
  • How do you think a contour cap might be regulated and enforced?

A17 Over time, improvements in the design of aircraft and their engines/airframes have diminished the volume and longevity of noise created by individual aircraft movements. Although it is anticipated that these improvements and their associated trends will continue into the future, rapid growth at individual airports is likely to increase the overall frequency of disturbances experienced by those living close to or nearby airports. Against the backdrop of an agreed EU policy framework, it therefore behoves each airport to have a noise management strategy, rooted in an Environmental Statement, identifying and assessing the relationship between growth in ATMs and aircraft noise, and then identifying, designing and implementing appropriate control measures. The noise management strategy should promote a balanced approach to noise management that identifies a comprehensive programme of noise control measures designed to ameliorate the effects of growth. The programme should aim to ensure that future growth is structured so as to expand in a responsible manner with as little detriment to the local noise climate as is possible. Within that programme there will many generic mechanisms (e.g. reducing noise at source, noise abatement routes, land use planning and operating restrictions) for managing the noise impact of growth, not all of which will be applicable to all airports, and some of which would have to be progressively introduced as an airport expands. Noise contours are one such mechanism for establishing upper limits on the impact of aircraft noise on the local community. They can be used to establish a base contour for an airport against which each year’s actual performance is mapped and any increase in the area of the contour requires some form of compensation by the airport authority. To avoid a static picture, there is the opportunity to negotiate with the local planning authority realistic targets for percentage reductions over time in the base contour, supported by a penalty regime in circumstances where the airport operator has failed to meet the targets. But it does need to be recognised that noise contours form only a part of managing noise, and that there are other measures that an airport can aspire to, the effect of which is to maintain an acceptable balance between the commercial needs of the airport and the wider interests of the community. In that respect, every airport is different and will operate under a set of different circumstances. It follows that the detailed application of some or all of the potential mechanisms for managing the impact of aircraft noise is a matter for local negotiation and regulation, the outcome of which should normally be reflected in Section 106 Agreements.

Noise mitigation and compensation (Chapter 16)

Q18 What views do you have on the following possible measures:

  • Should any residential property which suffers an increase in noise of 3dBA or more as a result of any of these options, and which would be exposed to a noise level of 63dBA daytime or more, be eligible for acoustic insulation?
  • Should acoustic insulation for households be extended to other noise-sensitive buildings not normally eligible, such as schools and hospitals, depending on detailed circumstances?
  • Should those eligible for insulation be given the choice of either having the insulation work done or accepting a cash payment of an equivalent amount?
  • Should assistance with relocation expenses be offered to households subject to very high levels of noise (such as 69dBA or more)?
  • Should offers be made to purchase those properties which would be subject to both a very high level of noise and a large increase in noise?
  • Should cash compensation be offered to those households suffering a significant increase in noise to a level greater than 57dBA but less than 63dBA – and therefore not qualifying for insulation?

A18 All residential properties which fall within the 63dBA contour for any airport ought to be eligible for assistance under the terms of a sound insulation grant scheme, which itself should be generous and fair and seen to be such. Sympathetic consideration should be given to making special provision for noise sensitive buildings, such as schools and hospitals, which are unduly affected by aircraft noise, and where noise insulation would actually have some tangible effect. This could include buildings within a 57dBa noise contour. We reject the suggestion of providing cash payments in lieu of acoustic insulation; the single purpose of sound insulation grant schemes is to help provide the physical insulation necessary to minimise a proportion of noise associated with aviation. The notion of an occupier accepting a cash payment without making the necessary improvements to insulate the property is unacceptable. At a purely practical level, cash compensation would create difficulties of its own when a property changed ownership. The key point must surely be that a house that has sound insulation will always remain insulated, whereas an owner who receives cash can move, leaving the new owner with unsolved noise problems for which no further assistance would be forthcoming.

It is not unreasonable for existing households suffering extremely high levels of noise (69dBa and above) to be offered the option of relocation expenses, or indeed for offers of house purchase to be made. Again, however, care should taken to avoid legislating for these possibilities recognising that the issue is one best left for local negotiation, and that the instances of acquisition or relocation ought to be relatively rare.

Cash compensation should not be offered to households in the 57-63dBa range. If they do not quality for insulation there can be no justification in cash compensation.

Night noise (Chapter 16)

Q19 Do you think that a five-yearly review cycle for the night restrictions regime for Heathrow, Gatwick and Stansted is appropriate or should some other review cycle be considered and, if so, what would you suggest? Are specific night noise restrictions needed at any other airport, and if so how should these be determined?

A19 Night noise is the single most quoted objection to the development of airports. We agree that for the foreseeable future the five yearly review cycle remains the most appropriate mechanism by which to review night restrictions regime. Other than at locations where 24 hour operations have little or no impact on communities by virtue of their geographic isolation, airport authorities should be expected to adopt a sensitive stance on night flying outside of established and publicly accepted operating hours. Experience suggests that communities take a very reasonable view in respect of the acceptability of night noise generated by emergency and aid relief flights. Equally, they show some latitude where for commercial or unavoidable operating reasons airline operators need occasionally to access an airport outside of normal operating hours but not normally after midnight. In such circumstances, however, the expectation is that the airline operator incurs a financial penalty which contributes directly to a local Community Fund the proceeds of which go towards funding local community projects. The introduction and management of such schemes should be left to local Airport Consultative Committees to initiate and police. Any more regular a pattern of night flying should properly be the subject of night noise regime negotiated with all interested parties.

 

Access to airports by rail and road (Chapter 17)

Q20 Are there specific surface access improvements that should be made a condition of any airport option and any that should not be included?

A20 The development of good quality surface access to an airport is important both from an operational and financial perspective, and is vital to its long-term success. Without it airports will not achieve their identified growth potential, nor will they be able to attract the continuing support of the local communities. Airports need to be in a position to promote the development of green transport solutions and to exercise a positive influence on people’s propensity to travel by means other than the motor car, and so ensure a sustainable modal split for surface access as an airport develops. That ability depends on having in place plans for airport development that demonstrate clearly the likely impact of airport growth on the local road and rail network, and propose solutions for adequately addressing traffic flows and for encouraging maximum use of public transport. To the maximum extent possible Airport Surface Access Strategies should reflect the role of airports as key interchanges within an integrated transport strategy, and form an essential part of a strategic planning authority’s holistic approach to the formulation of Local Transport Plans. In this context, Airport Transport Forums have a particularly important role to play. Also, where the activities of an airport involve the regular movement of trucks and commercial vehicles, airport authorities should take the lead in developing with the local councils and all users of the airport’s facilities, a freight quality partnership that has as one of its aims the mitigation of the potential impact that such movements could have on local communities, particularly at night.

Q21 How should any surface access schemes that are required for a particular airport development option be funded?

A21 Although surface access is fundamental to airport expansion, it would be wrong to assume that airports need consider only their own particular requirements and that Government has no role in funding. Surface route planning must be conducted at least at sub-regional level to reflect the broader needs of the community, the requirement for phased development over the long-term and to optimise the return on investment in what is part of the national infrastructure. The case for dedicated transport links carrying only airport traffic should be made on the basis of private sector funding. In principle, the potential for joint ventures between the private and public sector should be developed where the surface access infrastructure has a wider contribution to a national or regional interest, such as the regeneration of a particular area, such that an appropriate proportion of the infrastructure costs are shared between the private sector operators and the public purse.

ANNEX B

FUTURE DEVELOPMENT OF AIR TRANSPORT IN THE UK - SOUTH EAST

THE CAPACITY AND CAPABILITIES OF LONDON MANSTON AIRPORT

Introduction

The Consultation Document makes only a fleeting reference to Manston Airport. It consigns it to the status of a Second tier airport alongside Cambridge, Lydd and Shoreham airports despite the fact that in the year ending December 2000 Manston’s throughput of air cargo expressed in work load unit terms equated to the annual passenger throughput of the First tier airport of Norwich. The Document assumes an upper limit of 3 million passengers per annum for Manston notwithstanding it has a long runway and a ‘relatively supportive planning environment’. Finally, it identifies geographic position and aircraft noise over the town of Ramsgate as the two key constraints on expansion.

It is understood that in preparing this position statement, officials (and their consultants) from the then DETR visited Manston some three years ago. This was prior to the major piece of research undertaken by Arthur D Little published in April 2001 to determine Manston’s long-term potential, subsequent environmental and noise studies addressing in a formal Environmental Statement the potential impact of the airport’s growth and identifying appropriate mitigating measures and, most importantly, the significant investment that has been made in new taxiways and aprons. It is important and timely therefore yet again to explain the basis on which Manston now lays claim to be able to make a meaningful contribution to easing congestion at the main South East airports and to attracting an important share of the Government’s projected demand in passenger and cargo traffic over the 30 year planning period.

Geography

London Manston Airport is located on a chalk plateau in the central part of the Isle of Thanet in East Kent. It is approximately two miles from the port of Ramsgate and some 12 miles from the Port of Dover. Manston is no further distant from central London than Southampton or Alconbury. It is 17 miles from Canterbury, 28 miles from Ashford and the Channel Tunnel and only 48 miles from the major development areas of the Thames Gateway and the planned development of Kent Thameside.

Current Capacity

Manston provides the fifth longest runway in the UK. With a length of 2,752 metres and a width of 61 metres it is already capable of handling all types of aircraft, including the new A-380-800F. Importantly, plans exist to extend the runway to at least an overall length of 3,250 metres. Prior to August 2002 all of the airport’s taxiway and apron arrangements dated from the days when Manston was an RAF base and when the requirements for dispersed operations dictated the spread and location of aprons and connecting taxiways. Those arrangements are totally inappropriate to today’s commercial aviation requirements where the demands of safety, efficiency and effectiveness call for concentrations of apron space. The construction of a new taxiway and aprons in 2002, envisaged in the Airport’s Strategic Master Plan, now provides a capacity on the ground equivalent to an annual throughput of at least 200,000 tons of cargo.

Surface Access

Road access to Manston Airport is excellent. From London, road access is via the M25, along the M2 and then the dual carriageway of the Thanet Way (A299) to the western perimeter of the Airport. Current access points to the Airport are (for cargo) within ½ mile and (for passengers) one mile of the dual carriageway. In addition the Airport is served by direct road links connecting to Canterbury, Margate and Ramsgate, and to Dover and Folkestone. There are two scheduled changes to the existing road network in north east Kent and Thanet that will have a significant impact on any predictions of future growth and capacity of roads in the region. The first involves improving the strategic transport links between East Kent and both the rest of the country and Europe. Essentially this will provide dual carriageway roads connecting north Thanet to Dover via Ramsgate and Sandwich. The second involves improvements to the Thanet Way the effect of which will be to improve significantly journey times from Manston Airport to Dover and to Folkestone.

Two routes from London currently provide rail access to Thanet. The first is the North Kent Line running from central London via the Medway towns and along the north Kent coast via Margate to Ramsgate. The second is the East Kent Line from central London via Ashford and Canterbury to Ramsgate, which at its closest point runs to within half a mile of the Airport’s southern boundary.

Current overall journey times from London to Thanet will improve dramatically with investment in the provision of CTRL domestic services. It is expected that from 2007 overall journey times from London will have reduced considerably bringing Ramsgate and Dover to within one hour of London, and Canterbury to within 50 minutes of London. Plans supported by the local and county authorities for the introduction of a new railway station close to the Airport will bring access by rail from London to the Airport down to between 55-58 minutes. These rail improvements will serve not only to dispel notions that Manston is too remote but will importantly assist in extending Manston’s catchment area to embrace the large and expanding towns and communities of Kent and south east London.

Managing the Impacts of Airport Growth

The publication of the Airport’s Strategic Master Plan served to confirm the basis on which future expansion and development would take place. It made clear that whilst the Airport clearly has the potential to become one of the largest single generators of economic activity within the region, with an influence that spread far beyond the creation of direct on-site job opportunities, the actual development and expansion of the Airport had to be consistent with the principles of sustainable development. In that regard, the Strategic Master Plan addressed the process of identifying and assessing the environmental effects of developing the airport, and the attention that would be given to noise, ecological and habitat conservation and water and air quality.

From that basis, the Airport has worked closely with the local and regional authorities to ensure a consistent and sustainable approach to development. The Airport voluntarily entered into a Section 106 Agreement with the local planning authority. That agreement established obligations on both parties in respect of the key issues of night-time flying noise policy, general noise limitations, sound insulation grant schemes, noise abatement, noise and air monitoring, aircraft testing, strategic master planning, green travel strategies and plans, the production of an Environmental Statement and the creation of an Airport Consultative Committee funded by the Airport. The Agreement spans an initial period of three years. It is the intention of both parties to put in place a new Agreement of the same or similar nature to address changing circumstances and plans for development at the Airport.

Summary

In summary, London Manston Airport is a responsible airport operator that takes a strategic view of its development. The targets for passenger and cargo traffic reflect a rigorous analysis of demand growth, on-going national and regional airport planning, and trends in aviation. The growth and development of the Airport is seen as an increasingly important factor in the health of the local and regional economy. The targets that the Airport is working toward in respect of both passenger and cargo traffic suggests that over the next 10 to 15 years some 6000 new jobs could be created. At all times, it works closely with the local and regional authorities and government bodies to ensure that sustainable development principles underpin the approach to development. Development of the Airport features as one of the key priorities in the new Area Investment framework for east Kent, and as a result of a continuous process of public consultation the planned development commands widespread support from local residents.

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