Response to Night Flights Proposal

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    Manston Airport

    Proposed Night-time Flying Policy

    and Noise Assessment Report

    Response from

    No Night Flights

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    CONTENTS

    Introduction ............................................................................. 3

    Infratil's proposed night-time flying policy ................................. 4

    Background ........................................................................... 4Master Plan ........................................................................... 4Market and Business Requirements ...................................... 6

    Proposed Night-time Flying Policy ......................................... 8Impact assessment ............................................................. 13

    Bickerdike Allen Partners noise assessment report ............... 15

    1.0 Introduction ................................................................... 152.0 Site description .............................................................. 173.0 Aircraft movements at night ........................................... 17

    4.0 Night noise assessment criteria ..................................... 195.0 Noise contour and assessment methodology ................ 226.0 Impact of night-time airborne aircraft noise .................... 23

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    INFRATIL'S PROPOSED NIGHT-TIME FLYING POLICY

    BACKGROUND

    2. [.]Equally importantly, the operation and development of an airport mustbe acceptable to the resident and business communities within which it islocated.

    No. The operation and development of an airport must be acceptable to the residentand business communities on which it has an effect.

    3. Clearly the issue of night time noise is significant for residents in closeproximity to the airport. []

    No. The issue of night time noise is significant for every resident affected by the night

    time noise.

    MASTER PLAN

    The Master Plan states that "as the airport grows, the essential requirement toaccommodate delayed aircraft will remain" and the airport owners "will propose asystem of controls ... including a Quota Count System, restrictions on noisy aircraftand the adoption of a night time flying policy." There is no mention of schedulednight-time flying.

    4. National Aviation Policy is set out in the Future of Air Transport WhitePaper (FATWP) in 2003. []Therefore the expected growth in the air market

    for both passenger and freight traffic will need to be accommodated within theexisting runway capacity. This national policy position further increases theprospects for future demand at Manston.

    The 2003 FATWP and its projections for growth in the air traffic market arerecognised to be out of date. Moreover, the High Court judge who presided over thehearing into Heathrows application for a third runway, Lord Justice Carnwath, saidthat the Government's attempt to rely on the 2003 White Paper in its planning forairport capacity was "untenable". He said:

    "Common sense demanded that a policy established in 2003, before the

    important developments in climate change policy ... should be subject toreview in the light of those developments..

    It is clear from this that airports should not rely on the 2003 White Paper as arationale for pursuing growth. Growth estimates in the FATWP are nowhere nearborne out by current actual trends. Air passenger numbers have been below thelowest of the FATWP forecasts since 2008. UK air freight has been static for tenyears and has all the signs of being a mature, i.e. a non-growing, market. Therefore,there can be no rational expectation that there will be increases in the prospects forfuture demand at Manston. New custom for Manston will need to be won from other,more established, and better located, airports. So far, Manston has been unable to

    do this.

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    9. ln particular, the Master Plan forecasts that direct employment at the airportwill rise to 500 by 2018, and further to 1,000 by 2033, with total employmentgenerated by the airport (including direct, indirect, induced and catalytic)reaching 2,800 by 2018 and 6,150 by 2033.

    Councillors need to be clear that this employment forecast relies on everything in theMaster Plan coming to fruition. It is not a forecast for an increase in jobs as a resultpurely of the night flights proposal. The airport needs to produce an estimate of thejobs it can demonstrate will be created purely as a result of the night flight proposal,so that the costs and benefits of this proposal can be assessed on their own merits.

    10. The airport currently employs 111 staff, with a similar number directlyemployed on the site through other organisations. Of MSEs own employeesthe significant majority (61%] live within Thanet.

    The airport has been in private hands for 11 years through the biggest aviation boomthe world has ever seen and has produced only 111 jobs, roughly 10 a year. This

    figure of 111 jobs has been pretty stable over the last few years. The airport claims itwill have 611 jobs in 2018, i.e. that it will create 500 new jobs in 8 years, or 63 ayear. As well as the direct jobs the airport claims it will also produce 2,189 additionalindirect and induced jobs. These jobs can be located anywhere in the world certainly not just in Thanet. For example, an indirect job could be a job in a firm inthe Midlands or in Poland which supplies goods to the airport. The most importantthing to grasp here is that the airport is producing a nice, eye-catching, positivegraph that does not in any way represent the number of jobs created by thisapplication for night flights. This graph is the airports estimate of the jobs it mightcreate (and this in itself is flawed) if everything envisaged in the Master Plan for 2018comes to fruition exactly as planned.

    On its own numbers, we can see that Manston thinks it can create 3.6 additional jobs(2189 611) for every person on its own payroll. That is an estimate, and estimatesof potential jobs created in the aviation industry are notoriously exaggerated.Stansted has already delivered jobs for its community and says that it has createdjust 0.3 additional jobs for every existing real job. Manstons job creation claims are amassive overestimate.

    Our research using Stansteds data is reinforced by a recent study by Omega (TheEconomic Benefits of Aviation Technical Report, January 2009). This reportexamines the multipliers arrived at in a variety of studies into indirect and induced

    employment at airports. The Omega study reports a range in multipliers of between0.3 and 1.16 used to calculate indirect employment generated by airports. This is afraction of the multiplier of 3.6 that Manston is suggesting that it can achieve.

    The aviation industry itself recognises that increasing the number of flights does nothave a significant impact on the number of new jobs created. The Airport OperatorsAssociation has forecast that by 2030 an increase of 104% in the number ofpassengers passing through UK airports will produce only a 21% increase in jobs atairports.

    When Charles Buchanan was part of the management team at London City airport,the airport promised that in return for permission to increase flights by 50% (thats36,000 flights), 3,135 new jobs would be created. The airport got their flights and by2008 had created only 726 jobs a fraction of what was promised. Of these, only

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    30% were filled by local people. So, 36,000 extra flights delivered only 218 local jobs(726 jobs x 30% = 218). Manston wants just 8% of the flights London City requested(7.7 flights per night x 365 days = 2,810 flights p.a. and 2,810 36,000 x 100 = 8%).So, if we work with the track record that Charles Buchanan has of translatingpromises into jobs and apply it to the level of flights that Manston is requesting, we

    arrive at a maximum of 17 to 18 local jobs for this night flight application (218 localjobs actually delivered at London City for 36,000 flights x 8% for the number of flightswanted at Manston = 17.4 local jobs). More jobs than this will easily be lost if just afew local businesses - hotels and restaurants - close as a result of night flights.

    Weve spoken to workers at the airport who tell us there is plenty of capacityavailable at the airport to absorb the extra flights anticipated by changing shiftpatterns and using overtime. Their assessment is that no new jobs will be created asa result of the night flight application.

    In their response to Manstons Master Plan the Campaign to Protect Rural Englandprovided figures that show that the average wage at Manston is lower than theaverage wage in Thanet. This suggests that a successful night flight application willproduce at most a few low-paid jobs at the airport, whilst risking the loss of manymore jobs in the local tourist industry.

    In short, the airports job creation estimates are wildly over-optimistic and relate tothe entire Master Plan, not just the night flight application. They must be disregarded.

    More generally, Infratil's forecasts are of questionable worth:

    October 2008 Draft Master Plan: "Our forecasts envisage that there will be apassenger throughput of 1.2 mppa (million passengers per annum) by 2011."

    November 2009 Master Plan: "Our forecasts envisage that there will be apassenger throughput of 100,000 passengers per annum by 2011."

    MARKET AND BUSINESS REQUIREMENTS

    15. De