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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 Airports 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 Committees 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 .......................................................................... 3

Losses incurred by Wiggins ............................................................................................... 3
Losses incurred by Infratil .................................................................................................. 4
Losses incurred by Manston Skyport ................................................................................. 5
Manston Airport has never delivered on its promises of jobs ......................................... 6
Manston Airport consistently failed to meet its own forecasts ....................................... 7
Freight forecasts ................................................................................................................ 7
Passenger forecasts .......................................................................................................... 8
Manston is NOT an important diversion airfield ............................................................. 10
Manston has failed despite having significant support from local government .......... 12
No planning permission to be an airport .......................................................................... 12
A weak and unmanaged S106 Agreement ...................................................................... 12
No Environmental Impact Assessment (EIA) ................................................................... 13
Permission for scheduled night flights.............................................................................. 14
No Public Safety Zone ..................................................................................................... 14
Public subsidies............................................................................................................... 15
RiverOaks new plan for the airport is the same old failed plan................................. 16
Local support .................................................................................................................... 21
Ownership of the site ........................................................................................................ 24

No Night Flights Transport Select Committee


Manston Airport has never made a profit


Losses incurred by Wiggins


Our source for these bullet points is Wiggins company accounts unless indicated


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


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

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

11. In January 2004, Wiggins renamed itself Planestation

12. 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

13. In early 2004, Planestation bought 30% of EUJet

14. In summer 2004 Planestations overall losses were 73m and the company
raised 46m at an interest rate of 28%

15. In August 2004 Manstons main cargo customer, MK Airlines, left Manston for

16. 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

17. In December 2004 Planestation bought the remaining 70% of EUJet

18. Mr Freudmann was let go by Wiggins in February 2005


Planestation: turnaround from hell, www.growthbusiness.co.uk 1 September 2004

No Night Flights Transport Select Committee

19. 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
companys 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
airports land in this period.


Losses incurred by Infratil


Our source for these bullet points is Infratils company accounts.

22. In August 2005 Infratil bought Manston from the Administrator for 17m
23. In the Infratil accounts, Manstons results are consolidated with Prestwicks and
(between December 2006 and October 2009) Lubecks and so we do not have
operating figures for Manston alone

24. 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

25. In every other year, Infratil made a loss on its European airports. Losses ranged
from 1million2 to 9million3

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

27. How do we know that Manston made a loss every year? Under Infratils
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.

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

29. 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.

30. 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 companys investment

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

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

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


In evidence, Ms Bradley estimated that Infratils 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.

Converted from NZ$


No Night Flights Transport Select Committee


Losses incurred by Manston Skyport


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 airports closure in 2014 of 4.5million.
This is in line with what we know to be the annual running costs under Infratil.

No Night Flights Transport Select Committee


Manston Airport has never delivered on its promises

of jobs


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.


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
Freudmanns 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

No Night Flights Transport Select Committee


Manston Airport consistently failed to meet its own



Freight forecasts


In the 1999-2000 annual report, Wiggins forecast that the airport would reach
200,000 tonnes of cargo within two years.


In the September 2000 interim report, Wiggins said that cargo would reach 150,000
tonnes in 2001-2002


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


In 2002 Wiggins also forecast 350,000 to 400,000 tonnes of cargo by 2020


In fact, in 2003 Manston reached its peak freight performance of 46,000 tonnes. This
accounted for just 1.95% of the UK freight market4


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 market5


CAA statistics

No Night Flights Transport Select Committee


In 2005 Infratil forecast that Manston would handle 45,000 tonnes from 1st April 2009
and that the freight business would grow steadily thereafter6


Two months later, Infratils CEO made a statement in which he revised this down to
say that freight would reach 34,000 in 2010


In fact, the most freight that Infratil handled was 31,000 tonnes in 20127.


In evidence, Dr Webber said that he disputed our figures because Infratils 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 UKs annual freight total, and that it reached that peak in 2003
and dwindled thereafter. In the UK freight market, Manston was inconsequential.


Passenger forecasts


In April 2001 Wiggins published a report commissioned from Arthur D Little which
predicted that Manston would handle 4 million passengers by 2010


In August 2002 Wiggins told the Press that passenger numbers could reach 3 million
by 20078

Infratil presentation to analysts August 2005

CAA statistics
Kent Online 1 August 2002

No Night Flights Transport Select Committee


In November 2002 Wiggins told the Government that it expected to see 4 to 6 million
passengers by 20129


In fact, the most that Wiggins achieved was 206,875 passengers in 200510. This
represented 0.09% of UK total passengers 11


In August 2005 Infratil predicted that passenger numbers would reach 700,000 from
1st April 200912


In October 2005 Infratil predicted that passenger numbers could reach 2 to 2.5 million
in 200713


In 2008 Infratil predicted 1.2 million passengers by 2011 and, in the October Draft
Master Plan, 6 million passengers by 203314


In 2009 Infratil revised down its 2008 predictions, saying that there would be 100,000
passengers by 2011; 2.2 million passengers in 201815; and 4.7 million by 2033


In February 2010 Infratil announced that there would be 500,000 passengers by 2014
on the back of Flybes new routes from Manston16


In fact, Infratils peak passenger year was 2011 when 48,450 passengers used the
airport which represented 0.02% of the UK total17


In evidence, Sir Roger said that passenger numbers for the KLM flights were building
nicely. The graph below covers the full twelve months of KLMs operation at
Manston18. It is clear that numbers were tailing off. Manstons passenger numbers in
2013 accounted for just 0.02% of the UK total and were not growing.

Response to the DoTs consultation The future development of air transport in the United Kingdom South East 29
November 2002
CAA statistics
Infratil presentation to analysts August 2005
Press statement by Steve Fitzgerald
Infratil Draft Master Plan 2008
Infratil Master Plan 2009
Press statement
CAA statistics
Data taken from CAA statistics

No Night Flights Transport Select Committee



Manston is NOT an important diversion airfield


For obvious reasons, Manstons 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


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


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.


We produce below the CAAs 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 UKs diverted commercial flights.



No Night Flights Transport Select Committee



To put this chart into context, in 2013, there were 7 diversions to Manston out of a UK
total of 1,099.


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 Suttons 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.


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.

No Night Flights Transport Select Committee



Manston has failed despite having significant support

from local government


No planning permission to be an airport


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 airports


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


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:

78. 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

79. Best practice noise monitoring

80. A reduction in the noise footprint overall
81. Payment of a significant fine (or fines) by the Owner because of its failure to
provide noise contour maps

82. An insulation scheme to protect local residents from aircraft noise

83. Proper noise abatement routes
84. New maximum noise levels per plane.


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 Councils Airport
Working Party said:

No Night Flights Transport Select Committee



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.


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.


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


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 201021:


... 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.


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)


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


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.


TDC reply to August 2010 FOIA request

Manston Airport Night Noise Assessment review Bureau Veritas November 2010

No Night Flights Transport Select Committee



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 legislation22:


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]


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.


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


Permission for scheduled night flights


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


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


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.


The Council has never insisted that a Public Safety Zone be implemented for
Manston. Infratils 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.


DETR Circular 2/99

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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


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.
there is a general presumption against new or replacement development, or
changes of use of existing buildings, within Public Safety Zones. 24


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


In May 2004 KCC agreed to invest 100,000 in EUJet. KCC went on to invest


In January 2006 KCC invested 50,000 in Mr Freudmanns feasibility report

recommending the start-up of a route between Manston and Norfolk, Virginia.


In July 2006 KCC invested 289,600 in the Manston-Virginia route. Sales were so
poor that flights never started.


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.


In March 2013 KCC gave 100,000 to Visit Kent to market the new KLM route.


In addition, new roads have been developed around the airport.


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


DfT Circular 1/2010


No Night Flights Transport Select Committee



RiverOaks new plan for the airport is the same old

failed plan


We understand that it is not part of the Committees 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
Rogers 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.


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.


Manstons 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.


Mr Freudmann joined Wiggins in 1994 and says he was responsible for delivering
Wiggins airport acquisition strategy.25 Wiggins acquired Manstons 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.


Under Mr Freudmanns 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 Freudmanns leadership produced a viable, commercially
successful airport:

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

124. 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

125. Lahr airport failed


Mr Freudmanns LinkedIn profile

Wiggins company reports

No Night Flights Transport Select Committee


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

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

128. An $800 million project to build an airport in Ajman was abandoned in 2003
129. Planestation had ambitious plans for Smyrna airport in 1999 and then withdrew in


Wiggins/Planestations strategy for Manston is summarised by Alan Stratford in his

April 2005 report to Thanet District Council:


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. KIAs owner, Planestation, have however, stated that they intend to find
another home-based freighter operator to replace MK Airlines.


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


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.


When Infratil bought Manston from the administrator in 2005, Steve Fitzgerald said


The first services to be reinstated at KIA [Manston] will be freight operations. []

Recommencement of passenger operations will take somewhat longer29


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


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


Kent International Airport review of S106 Agreement April 2005 Alan Stratford & Associates
Tony Freudmann email to Support Manston, published 13 November 2014
Press statement 25 August 2005

No Night Flights Transport Select Committee


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


Despite Mr Freudmanns 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
Freudmanns 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.


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.


In January 2012, Parsons Brinkerhoff submitted an expert report to TDC about

Manston. It said:


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 Yorks 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.


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


In July 2014 Falcon Consultancy submitted to TDC their expert opinion on the
viability of Manston airport. Relevant extracts follow: 33


Falcons assessment of the market:


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


Presentation to analysts August 2005

Validation report on documents submitted by Manston International Airport related to a proposed night-flying
policy Parsons Brinkerhoff January 2012
Expert opinion on the prospects for the viable development of Manston Airport Falcon Consultancy Ltd July

No Night Flights Transport Select Committee


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)


Falcons comments on Manston as a failed airport:


The airport has never sustained growth. Now, the doubts surrounding Manstons
survival have become a self fulfilling prophesy. (page 7)


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


The likelihood of developing a successful cargo business:


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)


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)


The likelihood of developing a successful passenger business:


FCL agrees that as a regional airport, Manston has no natural sustainable

passenger market. The practical experience of the airports 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)


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)


The likelihood of developing a successful business reliant on general aviation:

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

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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)


Overall assessment of Manstons viability:


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)


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.


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


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.


CAA statistics
See the various expert reports quoted above.

No Night Flights Transport Select Committee



Local support


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

164. 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, Kents
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.

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

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

167. We know from the campaign groups 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

168. 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

169. 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

170. 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

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

172. 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 RiverOaks plan was for a cargo hub with minimal jobs.


The only properly managed public consultation about the airport was TDCs
consultation about night flights in early 2012. The Council received 2,275 responses

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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.


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.


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)


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.


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.


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:

No Night Flights Transport Select Committee


179. 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

180. The airports AIPs carry weight and must be followed. Changes to an AIP must
go through the CAA

181. 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

182. 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.


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 Freudmanns 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 Gloags initiative. In her interview in
the Isle of Thanet Gazette on 8th August 2014, Mrs Gloag said:


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.


This, and Mr Freudmanns strategy at Wiggins of buying airports to use them for their
development potential, strongly suggests that housing is part of the RiverOak plan for

No Night Flights Transport Select Committee



Ownership of the site


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 Committees deliberations about the
impact of regional airports on economic development and regeneration.


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 nations 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.


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 Manstons current owners might plan now
that the airport is shut are a matter for the planning system.

No Night Flights Transport Select Committee