Written evidence from No Night Flights (SMA0092)

We would like to thank the Committee for granting us the opportunity to give written and oral evidence, and to submit this follow-up document.

During the hearing of 2nd February, a number of assertions were made regarding Manston Airport’s past performance, its national significance, and its past and future viability which we did not have the opportunity to comment on more fully at the time.

We believe that these assertions all bear on issues that must be material to the Committee’s consideration of the role of smaller airports, and we would like to present a fuller, more balanced and evidence-based view of the airport and its past and future viability.

Manston had fifteen years to make the transition from being a 20th Century RAF airfield to being a successful 21st Century commercial airport. It failed.

The airport:

• has never made a profit,
• has never delivered on its promises of jobs,
• consistently failed to meet its business forecasts,
• is not an important diversion airfield,
• has failed despite significant support from district and local government.

Furthermore, the “new” strategy suggested by RiverOak for a cargo airport at Manston is the same failed strategy pursued by past owners and ignores the view of independent experts as to the chances of developing a successful cargo airport on that site.

Each of these points is examined in more detail, with the supporting evidence, in the rest of this submission.

No Night Flights

Manston Airport has never made a profit

Losses incurred by Wiggins

Losses incurred by Infratil

Losses incurred by Manston Skyport

Manston Airport has never delivered on its promises of jobs

Manston Airport consistently failed to meet its own forecasts

Freight forecasts

Passenger forecasts

Manston is NOT an important diversion airfield

Manston has failed despite having significant support from local government

No planning permission to be an airport

A weak and unmanaged S106 Agreement

No Environmental Impact Assessment (EIA)

Permission for scheduled night flights

No Public Safety Zone

Public subsidies

RiverOak’s “new” plan for the airport is the same old failed plan

Local support

Ownership of the site

Manston Airport has never made a profit

Losses incurred by Wiggins

1. Our source for these bullet points is Wiggins’ company accounts unless indicated otherwise.
2. The Financial Reporting Review Panel investigated several years of Wiggins’ accounts. The Panel obliged Wiggins to restate five years of annual accounts to bring them into line with UK accounting standards. The restatement had a material impact on the results that Wiggins had claimed – for example, the £12.1m profit that Wiggins claimed for y/e 1999 became a £5.1m loss and the £25m reported profit for y/e 2000 became a loss of £9.9m. We have used the restated accounts in our summary:

Wiggins bought Manston in 1999 for £4.75 million. The airport was then 1,100 acres

In 1999-2000 Manston airport made an operating loss of £1.1m

In 2000-2001 Manston airport made an operating loss of £3.6m

In 2001-2002 Manston airport made an operating loss of £3.9m

The March 2002 report said that Manston would: “… double cargo traffic this year [from an actual of 36,000 tonnes] and to reach the profitable rate of 100,000 tonnes per annum within twelve months.” In the same year, Wiggins embarked on a cost reduction programme at Manston as it was losing money

In the period 2002-2004 Manston’s numbers were consolidated with those of other Wiggins airports and so we do not know how big Manston’s operating losses were. However, we do know that it made a loss. Manston’s most successful year delivered just 43,000 tonnes of cargo - it never reached the profitable level of 100,000 tonnes p.a.

In January 2004, Wiggins renamed itself Planestation

In March 2004 Planestation said that the airport would start to break even at 70,000 tonnes of cargo per annum. This was never achieved

In early 2004, Planestation bought 30% of EUJet

In summer 2004 Planestation’s overall losses were £73m and the company raised £46m at an interest rate of 28%

In August 2004 Manston’s main cargo customer, MK Airlines, left Manston for Europe

Planestation brought in a turnaround agent. He described the vision of the management team as “merely vapour” and said: “When I came here we were spending money to no particular end. Last year we spent £11 million maintaining dormant airports. The previous year £13.5 million.”[1]

In December 2004 Planestation bought the remaining 70% of EUJet

Mr Freudmann was “let go” by Wiggins in February 2005

In July 2005 Planestation collapsed when the banks refused to give more credit. While it is often assumed that EUJet sank Planestation, it is clear from the company’s accounts that it was just one of the factors that brought the company to collapse. Others were its high level of debt and its low level of revenue. Manston never made a profit, despite Wiggins selling almost 300 acres of the airport’s land in this period.

Losses incurred by Infratil

3. Our source for these bullet points is Infratil’s company accounts.

In August 2005 Infratil bought Manston from the Administrator for £17m

In the Infratil accounts, Manston’s results are consolidated with Prestwick’s and (between December 2006 and October 2009) Lubeck’s and so we do not have operating figures for Manston alone

In 2008 Infratil made £1m from its three airports by selling some airport land. This was the only year in which Infratil made any money from its European airports

In every other year, Infratil made a loss on its European airports. Losses ranged from £1million[2] to £9million[3]

In 2009-2010 Infratil undertook a radical cost-cutting programme at Manston

How do we know that Manston made a loss every year? Under Infratil’s ownership, Manston never achieved more than 31,000 tonnes of freight, falling well short of the break-even point of 70,000-100,000 tonnes p.a.

As losses continued, Infratil wrote down the value of Manston in 2010, 2011, 2012 and 2013

In January 2012 Infratil decided to sell Manston and asked PwC to handle an “extensive sale process”. Although this was a worldwide process, there were no takers until Mrs Gloag came forward at the end of 2013.

In its 2012 annual report Infratil said that it bought Manston because it was “at well below replacement cost”. At that time, Infratil thought that a decision about the next London runway was five years away and Manston was “in the running”. By 2012 Infratil said that it had decided to sell Manston as it would take too long for the airport to make a return on the company’s investment

In 2012-2013 Infratil wrote down the value of Manston for a fourth year saying that the “impairment reflects market feedback”

On 15th October 2013 Infratil announced the forthcoming sale of Manston for £1 plus the running costs from 15th October to 29th November

Infratil then wrote off the final £11 million of book value for Manston.

4. In evidence, Ms Bradley estimated that Infratil’s losses were around £55m. We think that this is realistic, given the purchase price, the annual losses and the capital expenditure we know Infratil to have made.

Losses incurred by Manston Skyport

5. With no company accounts available, we are reliant here on statements made by Ann Gloag and by Pauline Bradley. They report a daily loss of between £10,000 and 12,000 and an overall loss by the time of the airport’s closure in 2014 of £4.5million. This is in line with what we know to be the annual running costs under Infratil.

Manston Airport has never delivered on its promises of jobs

6. The table below illustrates the considerable gap between the job creation promises made by various owners of Manston and the reality. The forecasts are in thousands. The actuals never reach two hundred.
7. We have also included the predictions made by local politicians who believed what they were told by airport owners. From the table, you can see that in 2001 Tony Freudmann’s team at Wiggins promised that there would be 6,000 jobs at Manston by 2010. In 2001 Wiggins backtracked and said that this would not be achieved until 2017. In 2008 Infratil predicted 3,500 jobs by 2018 and 7,500 jobs by 2033. The following year this was hastily revised down to 2,800 jobs by 2018 and 6,000 by 2033. Records from monthly reports to the Kent International Airport Consultative Committee show that jobs numbers under Infratil ranged from 53 to 112 jobs. When the airport closed in 2014 there were reportedly 144 jobs, many of which were part time.

Manston Airport consistently failed to meet its own forecasts

Freight forecasts

8. In the 1999-2000 annual report, Wiggins forecast that the airport would reach 200,000 tonnes of cargo within two years.
9. In the September 2000 interim report, Wiggins said that cargo would reach 150,000 tonnes in 2001-2002
10. In the 2001-2002 annual report Wiggins forecast that the airport would be a “significant European cargo hub in the next few years” and that it would reach the profitable level of 100,000 tonnes in 2002-2003
11. In 2002 Wiggins also forecast 350,000 to 400,000 tonnes of cargo by 2020
12. In fact, in 2003 Manston reached its peak freight performance of 46,000 tonnes. This accounted for just 1.95% of the UK freight market[4]
13. In 2004 Wiggins lost its key freight customer and the volume of freight handled at Manston fell back down to 26,600 tonnes, or 1.1% of the UK market[5]
14. In 2005 Infratil forecast that Manston would handle 45,000 tonnes from 1st April 2009 and that the freight business would grow “steadily thereafter”[6]
15. Two months later, Infratil’s CEO made a statement in which he revised this down to say that freight would reach 34,000 in 2010
16. In fact, the most freight that Infratil handled was 31,000 tonnes in 2012[7].
17. In evidence, Dr Webber said that he disputed our figures because Infratil’s CEO had said that, under Infratil, Manston was the fifth largest freight airport in the UK. In fact, in its best year under Infratil, Manston was 7th in the UK freight league table. We do not seek to make a major point from this error, but wish to re-emphasise the point that we made at the Select Committee, which was that Manston always accounted for less than 2% of the UK’s annual freight total, and that it reached that peak in 2003 and dwindled thereafter. In the UK freight market, Manston was inconsequential.

Passenger forecasts

18. In April 2001 Wiggins published a report commissioned from Arthur D Little which predicted that Manston would handle 4 million passengers by 2010
19. In August 2002 Wiggins told the Press that passenger numbers could reach 3 million by 2007[8]
20. In November 2002 Wiggins told the Government that it expected to see 4 to 6 million passengers by 2012[9]
21. In fact, the most that Wiggins achieved was 206,875 passengers in 2005[10]. This represented 0.09% of UK total passengers[11]
22. In August 2005 Infratil predicted that passenger numbers would reach 700,000 from 1st April 2009[12]
23. In October 2005 Infratil predicted that passenger numbers could reach 2 to 2.5 million in 2007[13]
24. In 2008 Infratil predicted 1.2 million passengers by 2011 and, in the October Draft Master Plan, 6 million passengers by 2033[14]
25. In 2009 Infratil revised down its 2008 predictions, saying that there would be 100,000 passengers by 2011; 2.2 million passengers in 2018[15]; and 4.7 million by 2033
26. In February 2010 Infratil announced that there would be 500,000 passengers by 2014 on the back of Flybe’s new routes from Manston[16]
27. In fact, Infratil’s peak passenger year was 2011 when 48,450 passengers used the airport which represented 0.02% of the UK total[17]
28. In evidence, Sir Roger said that passenger numbers for the KLM flights were building nicely. The graph below covers the full twelve months of KLM’s operation at Manston[18]. It is clear that numbers were tailing off. Manston’s passenger numbers in 2013 accounted for just 0.02% of the UK total and were not growing.

Manston is NOT an important diversion airfield

29. For obvious reasons, Manston’s owners made no predictions about the number of diversions that it would handle. Pilots of commercial aircraft determine their preferred diversion airport for each flight before take-off. The UK AIP for Manston (a CAA document) makes it clear that, if a plane wanted to use Manston as a diversion airport, the crew would have to give prior notice. The airport would accept an emergency landing, but not a diversion unless this was planned in advance. It is incorrect therefore to picture Manston as ready to take last minute diversions from other airports. As an example, a BA plane diverted to Manston from LHRW in December 2013. After landing, passengers were kept on the aircraft for two hours. There was no food and no drink. When they finally disembarked, they were taken off the plane in batches of 20 and shown down to the tarmac by the captain by torchlight.[19]
30. In evidence to the Select Committee, Sir Roger, Dr Webber and Ms Sutton all sought to persuade the Committee that the airport had an important role in handling UK diversions.
31. On 19th January the Committee heard from Mr Osborne of the CAA that there had not been a single commercial emergency landing at Manston and that his records went back to 1976.
32. We produce below the CAA’s statistics about the number of diversions handled by Manston between 1990 and 2013. In that period Manston never accounted for more than 0.64% of the UK’s diverted commercial flights.

33. To put this chart into context, in 2013, there were 7 diversions to Manston out of a UK total of 1,099.
34. Ms Sutton gave evidence that “many years ago” she had dealt with 70 civilian diversions to Manston in one week. We do not doubt her word but are finding it hard to marry this statement up with her CV and the CAA data. We think that we may be talking about different periods of time. Ms Sutton’s LinkedIn profile suggests that the only period in which she might have handled diversions to Manston was either before 1995 or between 1995 and 2000 when she worked in Air Traffic Control for the RAF. After this she was either based in Scotland or not in Air Traffic Control. There is no reference to her having worked in NATS and therefore no evidence that she would have been involved in directing commercial flights to Manston. Our hypothesis is that when she was talking about diversions to Manston, she was referring to RAF diversions, and possibly diversions of small civilian aircraft, in the period before the airport became a commercial airport in 1999.
35. Of course, there are many airfields in the South East that can accept small civilian aircraft and so the loss of Manston in this regard can easily be managed.

Manston has failed despite having significant support from local government

No planning permission to be an airport

36. Manston has never had planning permission to be an airport. The airfield land was requisitioned in WWI and therefore it did not need planning permission. In 1998, the MoD announced its intent to dispose of the airfield. The local plan had no reference to development of the airport. The Council produced a plan supplement - the Central Island Initiative - which was adopted in August 1998. This supplement was not subject to the same consultation procedures as the local plan itself, particularly not in Ramsgate, the town where residents were likely to be worst affected by the airport’s activities.
37. TDC did not insist that the airport had planning permission. Instead it issued a series of Certificates of Proposed Use or Development, on the grounds that civil aviation had been taking place on the airfield for more than ten years. Residents challenged TDC in the High Court and Appeal Court over the issue of these Certificates. Their argument was that, in the absence of a planning application, some limits and controls ought to be included on the Certificates of Lawfulness. The court ruled that these Certificates were simple documents allowing the airport to be transferred from military to civilian ownership. Future intensification of use would have to be dealt with via the planning system. This has never happened.

A weak and unmanaged S106 Agreement

38. Without proper planning regulations, the airport was governed by a S106 Agreement drafted in 2000. The Council then ignored many of the commitments it made in that document. By 2014, had the Council taken its commitments in that Agreement seriously, the public should have benefitted from:

Four reviews of the S.106, making sure at each review that it captured best practice for an airport that is next to a heavily residential area

Best practice noise monitoring

A reduction in the noise footprint overall

Payment of a significant fine (or fines) by the Owner because of its failure to provide noise contour maps

An insulation scheme to protect local residents from aircraft noise

Proper noise abatement routes

New maximum noise levels per plane.

39. The Agreement was reviewed by the Council in April 2005, 2007 and 2008. It was found wanting in many ways, particularly in its allowance of unscheduled night flights by planes as loud as QC4. In its review of the S.106 in 2007 the Council’s Airport Working Party said:
40. “There was general consensus that, in terms of ad-hoc aircraft movement during the night-time hours (23.00 – 07.00), the existing Quota Count (QC) of four or less was now an inappropriate target. Aviation standards had improved, and it would definitely be appropriate to set, by Agreement, a lower QC.”
41. Despite this recognition that the S.106 was no longer appropriate, the Council did not engage Infratil in a review of the S.106 Agreement and none of the commitments outlined in the bullet points above were met.
42. The Council has accepted in writing that it failed to meet its obligations under the S.106 Agreement. It has also accepted in writing that it failed to ensure that the Owner met its obligations under the S.106 Agreement. Finally, the Council has accepted in writing that the S.106 Agreement lags far behind best practice for an airport close to a town.[20]
43. It is shameful of Sir Roger Gale to say that people should not live near an airport if they do not want to suffer from aircraft noise. The fact is that Manston became a commercial airport long after Ramsgate was developed. Sir Roger seeks to downplay the number of people affected by aircraft noise from Manston. He is wrong to do so. Bureau Veritas said in November 2010[21]:
44. “... departures to the east on runway 10 will affect the greatest number of people, i.e. those living in the densely populated areas of Ramsgate. 80 dB(A) SEL contours have not been calculated but the populations predicted to be within the 85 dB(A) contour by such departures ranges from 14,722 for MD11 departures, up to 30,903 for the Boeing 747-400. This is a significant number of people.”
45. The Council has failed to protect local residents from the negative impact of the airport. Yet, even though the Council has given the airport an extraordinarily benign planning environment in which to develop, the airport has still failed to succeed.

No Environmental Impact Assessment (EIA)

46. Manston has been allowed to operate without an Environmental Impact Assessment having been completed. The EIA regulations provide specific thresholds which determine when an EIA must be completed. For airfields, the threshold stipulated is extension of the runway or if the area of works exceeds 1 hectare. Any work which has been authorised since privatisation should have been subject to these regulations.
47. Since being privatised TDC has allowed the airfield to expand by granting a series of separate planning applications for development of the airfield. We have evidence of at least 15 separate planning applications up until 2007 and more development has taken place since then. The 15 developments include four separate applications which each exceeded the 1 hectare threshold and which should have triggered an EIA in its own right. In every case, TDC argued that an EIA was not required because the development was not likely to have a “significant” environmental impact.
48. TDC has granted a cumulative total of over 21.7 hectares of development at Manston. This far exceeds the 1 hectare threshold set out in the legislation. The government issued guidance to local planning authorities on the criteria which should be used in respect of this legislation[22]:
49. “However, in judging whether the effects of development are likely to be significant, local planning authorities should always have regard to the possible cumulative effects within any existing or approved development.” [Our bold]
50. This means that the Council should have obliged the airport to complete a full Environmental Impact Assessment given that the airport had had 21.7 hectares of cumulative development, way in excess of the one hectare trigger. The Council has accepted, in writing that it should have required the Owner to complete a full Environmental Impact Assessment, leading to a full Environmental Statement.
51. The Council has failed to protect the environment from the negative impact of the airport. Despite this unusual amount of environmental freedom, the airport did not succeed.

Permission for scheduled night flights

52. The Council has twice given permission for scheduled night flights to start. In 2004 Planestation asked for approval for EU Jet to have scheduled night flights. TDC granted permission for six months. At the end of the six months, the night flights continued.
53. In January 2009 Infratil asked for permission to introduce scheduled night flights in an attempt to persuade BAWC to use Manston. TDC gave approval for fully-laden cargo planes of QC4 to operate scheduled night flights in and out of the airport.

No Public Safety Zone

54. One of the starkest inaccuracies in the Why Not Manston submission to the Committee is the assertion that if a plane ran into trouble at Manston, it would be more likely to hit a sheep or a cow than anything else. Why Not Manston has evidently not noticed Ramsgate, a town of 40,000 people just 0.8 miles from the end of the runway and in the direct flight path of 70% of landings. Planes landing from the East line up at a height of just 289 metres over Ramsgate Harbour and then descend over the town as they approach the runway.
55. The Council has never insisted that a Public Safety Zone be implemented for Manston. Infratil’s 2009 Master Plan acknowledged that a Public Safety Zone (PSZ) should have been implemented in 2006. If it were, the 1 in 10,000 risk contour would include a number of residential streets (Kirkstone, Whinfell, Drybeck and Kentmere Avenues and part of Windermere Avenue). If a PSZ were introduced, these streets would need to be emptied.
56. “The Secretary of State wishes to see the emptying of all occupied residential properties, and of all commercial and industrial properties occupied as normal all­day workplaces, within the 1 in 10,000 individual risk contour.” [23]
57. The 1 in 100,000 risk contour would cover a substantial swathe of Ramsgate down to the Harbour and including part of the town centre. It would include three schools.
58. “…there is a general presumption against new or replacement development, or changes of use of existing buildings, within Public Safety Zones.” [24]
59. The planning blight for Ramsgate of a proper PSZ would be significant and could not be justified for the number of jobs that the airport created.

Public subsidies

60. In May 2004 KCC agreed to invest £100,000 in EUJet. KCC went on to invest £121,000.
61. In January 2006 KCC invested £50,000 in Mr Freudmann’s feasibility report recommending the start-up of a route between Manston and Norfolk, Virginia.
62. In July 2006 KCC invested £289,600 in the Manston-Virginia route. Sales were so poor that flights never started.
63. In June 2011 KCC and Infratil asked the Government for £600,000 to tempt KLM to use the airport (this bid was not successful) as well as millions to support a new station at Thanet Parkway.
64. In March 2013              KCC gave £100,000 to Visit Kent to market the new KLM route.
65. In addition, new roads have been developed around the airport.
66. The airport has benefitted significantly from public investment and subsidy. That money has been lost. It is hard to see what more TDC and KCC could have done to support the airport. It has benefitted from being at the heart of consecutive Local Plans and Visions. It has benefitted financially. In addition to this expenditure, the airport has cost local taxpayers significant sums in consultants’ reports (at least four) and legal advice commissioned by TDC. The Leader is on record as saying that she, and many senior officers, have been able to work on little else for months. Despite this solid support from local government, and during the biggest aviation boom the UK has ever known (2004-2008), Manston failed to become a successful commercial airport.

RiverOak’s “new” plan for the airport is the same old failed plan

67. We understand that it is not part of the Committee’s remit to give an opinion on the merits or otherwise of TDC attempting to obtain a CPO to take Manston from its owners, and that the Committee is not there to decide whether or not RiverOak is a suitable indemnity partner for a local authority. However, we were troubled by Sir Roger’s suggestion that the Committee should do just that. Given that, we feel that we must challenge the assertions made by Sir Roger and by RiverOak about their plans for a post CPO future for the former airport.
68. RiverOak says it can run Manston successfully because RiverOak has a new strategy. In evidence to the Committee, Mr Yerrall made it clear that RiverOak has no aviation experience and that it is reliant on the operational aviation expertise of Mr Freudmann. The outline plan that RiverOak has put forward as its “strategy” is the same plan that Mr Freudmann pursued between 1999 and 2005 when he ran Manston airport, and other former military airports, at a substantial loss.
69. Manston’s prime focus has always been freight, just as RiverOak suggests it would be if RiverOak were ever able to acquire the airport. Even before Wiggins acquired Manston airport, part of the airport was operated under lease by the freight haulier, Clive Bourne.
70. Mr Freudmann joined Wiggins in 1994 and says he was responsible for delivering Wiggins’ airport acquisition strategy.[25] Wiggins acquired Manston’s freehold in 1999 and Mr Freudmann was responsible for converting Manston into a commercial airport. Wiggins continued the focus on freight at Manston. EUJet did not start passenger flights from the airport until September 2004. Between 1999 and late 2004, Wiggins therefore pursued a strategy for Manston that was almost entirely focussed on developing freight business. As we have demonstrated above, it failed.
71. Under Mr Freudmann’s airport acquisition leadership, Wiggins (Planestation) also entered into agreements for the purchase or lease of a number of other former or existing military airports. All were targeted because of Wiggins’ belief that ideal airports were former military bases with ample surrounding land which could be developed using the real estate experience of Wiggins.[26] None of these contracts entered into under Mr Freudmann’s leadership produced a viable, commercially successful airport:

A joint venture with the local authority that owned Odense airport ended in arbitration after a breach of contract claim against Planestation

Pilsen, a former defence airport in Czechoslovakia, was unsuccessful; sold on to Babcock Brown; and then returned to the MoD after a breach of contract claim

Lahr airport failed

Planestation failed to pay the rent for Schwerin Parkim airport; the agreement was cancelled and a settlement of 3 million euros was paid

Planestation took a 43% stake in Cuneo airport and withdrew in 2004 having made heavy losses

An $800 million project to build an airport in Ajman was abandoned in 2003

Planestation had ambitious plans for Smyrna airport in 1999 and then withdrew in 2003.

72. Wiggin’s/Planestation’s strategy for Manston is summarised by Alan Stratford in his April 2005 report to Thanet District Council:
73. “KIA initially developed as a specialist freight airport, although the airport handled some specialist passenger charters, predominantly to the Former Yugoslavia during the 1960s and 1970s. Specialist dedicated freighter operations continue, although its main based airline, MK Airlines, moved to a new base at Ostend in Belgium in August 2004. There are still some ad-hoc freighter flights, mainly emergency relief and aircraft visiting the specialist maintenance centre, Jet Support. KIA’s owner, Planestation, have however, stated that they intend to find another home-based freighter operator to replace MK Airlines.
74. Although KIA have attempted to attract passenger flights over the past five years, until August 2004, this was mainly restricted to the occasional charter for cruise liners sailing from Dover. In August 2004, however, a new low-cost airline, EUJet, started operating from KIA to some 19 UK and European destinations using Fokker F100 aircraft.”[27]
75. In evidence, Mr Freudmann told the Committee that he was “long gone” by the time that Planestation went into administration. This is misleading. In fact, he was “let go” in February 2005.[28] Planestation collapsed in July 2005.
76. When Infratil bought Manston from the administrator in 2005, Steve Fitzgerald said that:
77. “The first services to be reinstated at KIA [Manston] will be freight operations. […] Recommencement of passenger operations will take somewhat longer…”[29]
78. “While the airport has, for a short time, been in administration following the failure of Planestation Plc, we believe that it has strong prospects as a freight airport servicing the south of England.”[30]
79. Mr Fitzgerald acknowledged that there were risks in this strategy as there was strong competition from Stansted, East Midlands, Manchester and Northern Europe. He accepted that a significant percentage of world freight travels in the belly hold of passenger flights and that Manston would not be in a position to benefit from the belly hold freight that comes in on long haul passenger flights.[31]
80. Despite Mr Freudmann’s public statements that it was a mistake for Planestation to try to attract passenger business to Manston, in 2007 it was he who provided consultancy services to Infratil and to KCC in an attempt to introduce passenger services between Manston and Norfolk, Virginia. KCC invested £50,000 in Mr Freudmann’s work and £289,600 in the venture. Advance ticket sales were so poor that the route was cancelled before any flights took place. KCC recouped nothing.
81. In 2009, Infratil reiterated that a key reason for buying Manston was that UK airport ownership was undergoing a major change with BAA being forced to sell Gatwick and a Scots airport, and that Kent was a candidate for the next new runway.
82. In January 2012, Parsons Brinkerhoff submitted an expert report to TDC about Manston. It said:
83. “We would agree that over the short to medium term, without significant capacity being built into the South East of England, freight volumes at Heathrow Airport are likely to fall as the airport allocates landing/take-off slots to higher yielding passenger aircraft (assuming no additional capacity is added). We would disagree, however, that MIA would likely benefit in any substantial way from these freight volume decreases. Stansted, and Gatwick to a lesser degree, have significant capacity to accept additional freight volumes and are strategically better located close to motorways and major conurbations. For this reason we would disagree with York’s contention that “It is for the relocation of these services that MIA is ideally geographically located”. MIA, whilst only 50 minutes from the M25 at Junction 2, is not strategically positioned for freight to be dispatched anywhere other than the far South East of England.”
84. “Given the geographic location of MSE it is unlikely that [passenger] carriers would show much interest for inbound traffic from key European city links – we would argue this would only be relevant if MIA was strategically placed near to a large city or a region with a large catchment area.”[32]
85. In July 2014 Falcon Consultancy submitted to TDC their expert opinion on the viability of Manston airport. Relevant extracts follow:[33]
86. Falcon’s assessment of the market:
87. “At the time of writing this introduction, fierce competition between all the airlines is redrawing the map once again and forcing the low cost airlines back towards the larger airports. Ever larger aircraft delivered to the major airlines offer many more seats to be filled from the major airports and the capacity and performance of these aircraft is so great that, for the moment at least, the growth is [sic] air cargo can be absorbed in the belly holds of passenger aircraft.” (page 3)
88. Falcon’s comments on Manston as a failed airport:
89. “The airport has never sustained growth. Now, the doubts surrounding Manston’s survival have become a self fulfilling prophesy.” (page 7)
90. “Manston Airport was up for sale for some time. That there was no interest reflects its poor business reputation, (it has never made a profit in all the years since the RAF moved out) and the general industry perception that it is not in an ideal location. It has failed to fulfil its perceived role as a regional airport.” (page 9)
91. The likelihood of developing a successful cargo business:
92. “Airlines are replacing their passenger aircraft with more fuel efficient aircraft at an increasing pace. Wide bodied twin aisle passenger aircraft deliveries are expected to grow by 19% this year which will effectively increase belly hold capacity worldwide by 8% allowing more and more cargo to be conveyed in the free under-belly cargo holds of passenger aircraft.” (page 21)
93. “Capacity is growing at a far faster pace than demand for airfreight and as sea freight yields are falling there is also a shift from airfreight to sea freight. The climate for cargo-only aircraft operations could not be much worse.” (page 21)
94. The likelihood of developing a successful passenger business:
95. “FCL agrees that as a regional airport, Manston has no natural sustainable passenger market. The practical experience of the airport’s operation demonstrates that its catchment area and its propensity to travel is insufficient to generate for the airlines enough traffic on one route to sustain a twice daily operation, the minimum required to risk launching a service.” (page 8)
96. “There is therefore a challenging period ahead where the issue of reduced journey time to the London area conurbation needs to be radically addressed. Even the proposed Thanet Parkway station would require some additional mode of transport to connect passengers from the terminal to the station. A solution is necessary that minimises journey time to the capital. This is a critical issue since there are so many alternative airport choices that the traveller to and from the London conurbation can decide upon.” (page 18)
97. The likelihood of developing a successful business reliant on general aviation:
98. “Overall revenue generated from GA is limited in scope and tends not to factor as a major contributor to airport economic activity. The range of competitor airports for Manston where serious high yielding corporate aviation activity takes place includes Lydd, Luton, Biggin Hill and Farnborough. In several instances there are significant investments by Fixed Based Operators present at these airports. On balance therefore the likelihood that the continuation of GA at Manston will be a reason to prompt the retention of the airport is slim.” (page 23)
99. Overall assessment of Manston’s viability:
100. “No business plan with a credible investment plan of less than 20 years is likely to define the commitment necessary to rebuild confidence. Phase 1 investment required could be in the order of £100m with no guarantees of success. Political support will be required to attract investors and PR work will be needed to convince the airlines.” (page 7)
101. In short, Mr Freudmann has already had over five years to pursue a “freight first” strategy at Manston, and he failed. For over five years, Mr Freudmann led an airport acquisition strategy for Wiggins/Planestation, focussed on former military airports. This strategy failed. Mr Freudmann tried to introduce passenger flights between Manston and Norfolk, Virginia. This venture failed.
102. RiverOak is relying on Mr Freudmann for its operational expertise. RiverOak is also relying on a strategy that independent experts have said is not viable. The majority of cargo travels in the belly hold of passenger planes.[34] Manston is not in a position to attract much passenger traffic and so cannot take advantage of this.[35] There is no compelling case in the public interest to acquire Manston via a CPO to develop it as a freight hub. There is no credible business plan on the table for Manston as a freight airport.
103. As a footnote, it has been suggested that, if Manston were to be redeveloped as a cargo hub, Bristows could move its search and rescue operation to Manston. Of course, if the current owners were agreeable, Bristows could operate just as easily from a site which is not dedicated to aviation. Helicopters do not need a runway.

Local support

104. The Committee asked for our view on the degree of local support for a CPO to re-open Manston as a cargo airport. FOIA requests have produced the following information from TDC and from central Government:

On 10th July 2014 an e-petition was submitted to TDC by a student living in Holland. It had 3,361 signatures. The petition prayer reads: “We the undersigned petition the council to make a compulsory purchase of Manston, Kent’s International Airport. We would also like Thanet District Council to look into the possibility of members of the public to buy bonds into this purchase.”

A paper petition was also presented of 4,330 signatures under the same petition prayer

TDC did not check whether the signatures were valid; whether people had signed more than once; or where the signatories lived

We know from the campaign group’s Facebook page that some people signed many times; that many people who signed live in other counties or countries; that the petition was widely publicised on airport and plane enthusiasts’ websites; and that campaigners against expansion at LGW, LHRW or against an Estuary Airport were encouraged to sign

On 21st July 2014 a paper petition was submitted to 10 Downing Street. The prayer was: “please keep our airport open. It is very important to our local economy.” We are told that this petition had “around 10,000 signatures”, but the Cabinet Office has only a sample, not the whole petition, and therefore cannot confirm what percentage of signatures are valid and what percentage are from local people

An e-petition was collected on 38 Degrees and copied to 10 Downing Street. We are told that it had “around 16,500 signatures”, but the Cabinet Office has only a sample, not the whole petition, and cannot confirm what percentage of signatures are valid and what percentage are from local people

In July 2014 a paper document was submitted to TDC. This notionally had 16,500 signatures, but TDC says that no signatures were actually attached. The prayer reads: "Dear Roger Gale, We do not want Manston Airport to close! There are many good points to this site. We have flights on our doorstep, it will create mor (sic). Why is this Important? Our Local airport here in Kent is under threat! Manston has been through so much since the RAF left in 1999. The airport is in the hea (sic)”. This was rejected as there were no valid signatories

We have found it impossible to glean which petitions were copies of other petitions

Think Support Save Manston also collected signatures for a petition. We have video footage of organisers exhorting people to sign the petition in order to: “Prevent a massive overspill housing estate from inner cities”. Organisers promised 3,000 (and sometimes 6,000) new jobs if the airport were to be reopened. They also talked about passenger flights. At no time were people told that RiverOak’s plan was for a cargo hub with minimal jobs.

105. The only properly managed public consultation about the airport was TDC’s consultation about night flights in early 2012. The Council received 2,275 responses between 3 February and 2 March 2012 – the biggest response that the Council had ever had to a consultation. Every signature was checked. Signatories had to be Thanet residents. Approximately 73% were opposed to regular night flights / implementation of the night flights policy.
106. Dr Webber says that he represents 8,500 people. We think that he might be talking about the Save Manston page on Facebook which recently had 8,876 members. We have sampled the membership list, taking a letter of the alphabet at a time. Our conclusion is that around 50% of the members live in the area covered by Thanet, Canterbury and Dover Councils. No Night Flights has yet to start any public campaign for local support via Facebook and so we cannot supply a comparison figure.
107. We were asked about night noise and whether, under the ownership of Wiggins and Infratil, unscheduled night flights really occurred. We refer the Committee to our original submission to the Committee as follows:

Figure 1 Locations of complaints about aircraft noise (blue line is flight path for arrivals from west)

108. The map above shows the location of a sample of residents who complained to us about noise from unscheduled night flights. It is clear from this map that the actual noise nuisance experienced covered Ramsgate (0.8m from the end of the runway), a number of nearby villages, and Herne Bay. Mobile noise monitors on Ramsgate roofs regularly recorded noise levels of Lmax (dB) 92.6, SEL (dB) 100 and Leq (dB) 86.0 timed in the small hours of the morning.
109. For the avoidance of doubt, in evidence Ms McIntyre said that the noise from night flights often reached SEL (dB) 1,000 over Ramsgate. This was an obvious slip of the tongue and, had it been challenged at the time she would have been happy to correct it. The correct figure is SEL (dB) 100.
110. Cllr Johnston has said on a number of occasions that if RiverOak were able to persuade TDC that it could be a suitable indemnity partner; and if TDC were able to obtain a CPO to acquire Manston; and if RiverOak were to develop a cargo airport on the site; then the flight paths would need to be repositioned. With the greatest respect for Cllr Johnston, this will have no effect on Ramsgate or on the nearby villages. Conversations with the CAA in July 2009 made it clear that:

Beneath flight level 65 Manston is class G airspace. It is unregulated. Pilots can fly where they like and ATC can send them where they like as long as they stick to the procedures in any local agreements

The airport’s AIPs carry weight and must be followed. Changes to an AIP must go through the CAA

For landings from the west approaching over Herne Bay towards RWY 10 in good weather it might be possible to persuade pilots to line up with the centreline 6 miles out, instead of ten miles out, thus reducing the amount of overflying of Herne Bay

However, Ramsgate is so close to the end of the runway that all landings from the east would need to approach directly over Ramsgate, as they did when the airport was operational.

111. Some people have signed a petition to reopen Manston as an airport because they fear that the site will be used solely for housing. This is a fear that Sir Roger is actively encouraging in his regular column in the local Press. This is puzzling given Mr Freudmann’s meetings with the Council in January and February 2014 about putting 1,000 homes on the Northern Grass which is part of the airport. As Annax Aviation, he commissioned Indigo Planning Limited to make a submission to TDC as part of the Local Plan process. In May 2014, when these meetings became public, the public was led to believe that this was Mrs Gloag’s initiative. In her interview in the Isle of Thanet Gazette on 8th August 2014, Mrs Gloag said:
112. “This representation was initiated, promoted and paid for by Tony Freudmann and Annax Aviation who had indicated they wanted to purchase the airport at that time and were keen for consideration to be given to alternative uses for the Northern Grass to be included in the Local Development Plan.”
113. This, and Mr Freudmann’s strategy at Wiggins of buying airports to use them for their development potential, strongly suggests that housing is part of the RiverOak plan for Manston.

Ownership of the site

114. We were surprised by the number of questions the Committee asked about changes to the ownership of the site after the airport was closed in May 2014. We are not sure how much value this debate will add to the Committee’s deliberations about the impact of regional airports on economic development and regeneration.
115. We understand that Sir Roger has a romantic attachment to the old airport and that he likes to describe it as a national asset. However, 16 years ago the Ministry of Defence determined that Manston airport was surplus to the nation’s requirements and the airport was sold into private hands. Since then it has been owned by a company that went into liquidation and another that could not attract a buyer for it until it had been on the global market for 22 months. It then sold for £1. The market has spoken clearly about the value of Manston airport as an airport.
116. We suggest that recent ownership changes and the structure of the financial vehicle(s) in which the airport is held have no bearing on its viability as a commercial airport. Until such time as constraints on future use are built into the sale of an airport into private hands, any change of use that Manston’s current owners might plan now that the airport is shut are a matter for the planning system.

February 2015

No Night Flights  Transport Select Committee              24