STATEMENT IN SUPPORT OF THE APPEAL PROPOSALS FOR

THE CHANGE OF USE APPLICATIONS AT THE FORMER

MANSTON AIRPORT SITE, MANSTON, RAMSGATE, KENT
APP/Z2260/W/15/3140995 (LEAD CASE BUILDING 1/HANGAR 1, CT12 5BL)
APP/Z2260/W/15/3140992 (BUILDING 3 - CARGO CENTRE, CT12 5FF)
APP/Z2260/W/15/3140990 (BUILDING 870, CT12 5BL)
APP/2260/W/15/3140994 (BUILDING 4, CT12 5FF)

BACKGROUND
On 23rd May 2015, Thanet District Council received four Change Of Use applications
from the owners of the disused airport at Manston for buildings on their site. Three of
those applications have yet to be decided, some eight months after they were
submitted. One application, the application for APP/Z2260/W/15/3140990, known as
Building 870, was rejected on 21st October 2015.

THANET DISTRICT COUNCILS REJECTION OF CHANGE OF USE

APPLICATION NO. 3140990
On 21st October 2015, the Planning Committee of Thanet District Council (TDC)
went against the recommendation of the Councils officers and rejected the Change
Of Use application for Building 870 at Manston Airport. The reason given in the
Committees minutes was:
That Members refuse the application as it did not comply with Thanet Local
Plan Policy EC4 and CC1.1
The subsequent decision notice2 gives the reason for refusing the application as:
The proposed development, by virtue of the loss of a building for airport use,
would create the potential need for additional buildings within the countryside
and would not constitute essential airside development, contrary to Thanet
Local Plan polices CC1 and EC4 of the Thanet Local Plan and paragraphs 14
and 17 and guidance within the National Planning Policy framework.
This reason is nonsensical for a number of reasons. First and foremost, there is no
airport at Manston and there is no credible prospect of there being one in the
foreseeable future. This means that there is no need for buildings for airport use. The
only way that this need could come into being is if TDC were to be successful in
taking the site from its legal owners via a Compulsory Purchase Order and then to
hand the land to an operator to develop an airport on the site.
TDC does not have the capital to carry out a CPO by itself. TDC launched a soft
market-testing exercise in the summer of 2014 to find an indemnity partner to foot
the bill for a CPO. Despite two different political administrations pursuing this over
the last eighteen months, no indemnity partner has been found. This means that
TDC cannot CPO the site in order to develop an airport.
Even if an indemnity partner were available, TDC would not be able to demonstrate
a compelling case in the public interest for a CPO, given that the airport was a
consistent commercial failure during its fifteen years of commercial operation; that it
employed few people; and that it was a source of environmental nuisance and
pollution for residents in the area. In contrast, the sites current owners are
developing credible plans for a mixed use development which will support jobs,
houses, open space and community infrastructure, making their plan demonstrably

Item 3, http://democracy.thanet.gov.uk/mgAi.aspx?ID=25741

https://planning.thanet.gov.uk/onlineapplications/files/D05DF98CE21FFE89BDA7E1268A674609/pdf/F_TH_15_0457DECISION_NOTICE-357922.pdf

more in the public interest than the Councils dream of a developing a new cargo
airport next to one of its seaside towns. In short, there is no airport on this site now
and there is no prospect of the land being acquired so that a new airport can be
developed. It therefore is not a valid planning action to attempt to safeguard
buildings for airport use when there is no airport and no prospect of there being one.
There are also a number of planning policy reasons why the Council was wrong to
refuse permission for this Change Of Use application and, by inference, why it was
wrong simply to fail to decide the other three Change Of Use applications. We deal
with these reasons below.

POLICY EC4 AND CC1 ARE NOT PART OF A CURRENT LOCAL PLAN
Thanet does not have an up-to-date Local Plan. The two policies referred to in TDCs
21st October decision notice are saved policies from the 2006 Local Plan.3 When the
Council applied to the Secretary of State in June 2009 to save some policies from
the outgoing Local Plan, TDC was told that it should not assume that, just because it
had been allowed to save these policies, they would be accepted by the Secretary of
State as viable should they be presented to him/her at a later stage as part of a new
Plan. The Secretary of States letter at the time4 says:
Where policies were adopted some time ago, it is likely that material
considerations, in particular the emergence of new national and regional
policy and the emergence of new evidence, will be afforded considerable
weight in decisions.

POLICIES EC4 AND CC1 ON WHICH TDC IS RELYING TAKE NO

ACCOUNT OF NEW NATIONAL POLICY
It is now nearly seven years since TDC was given that guidance and almost ten
years since these policies were published in the 2006 Local Plan. Significant new
national planning policy in the shape of the NPPF was introduced after the
publication of TDCs 2006 Local Plan. The NPPF emphasises the need for Local
Planning Authorities (LPAs) to have up-to-date plans in place. Planning applications
which accord with an up-to-date development plan should be approved without
delay. Where the development plan is absent or silent, or where relevant policies are
out-of-date, LPAs should grant planning permission unless the adverse impacts of
doing so would significantly and demonstrably outweigh the benefits when assessed
against the policies in the NPPF. Policies EC4 and CC1 are out-of-date. TDC should
therefore have granted the Change Of use applications unless their adverse impacts
3

http://thanet.devplan.org.uk/document.aspx?document=15&display=contents

Letter from John Cheston, Senior Planning Officer, 2nd June 2009

would significantly and demonstrably outweigh their benefits when assessed against
the policies in the NPPF. However, TDCs Planning Committee did not make any
assessment of the proposals against the NPPF, let alone demonstrate that the
adverse impacts of granting permission for Change Of Use would outweigh the
benefits of doing so.
TDC now says5 that it took account of paragraphs 14 and 17 of the NPPF in taking
the decision to reject the Change Of Use application for Building 870 (3140990).
Video recordings of the Planning Committee meeting make it perfectly clear that the
NPPF was not a factor in Members thinking as they took the decision. Moreover, it is
hard to see how paragraphs 14 and 17 of the NPPF would have helped TDC to
decide that it should reject the applications. Paragraph 17 in particular presents a
number of challenges.
Paragraph 17 of the NPPF says that plans should:
be kept up-to-date, and be based on joint working and co-operation to
address larger than local issues.
The 2006 Local Plan is self-evidently not up-to-date. Nor has the former airports
planning status been a result of joint working with local residents. Formal planning
application was never submitted or approved for the use of the site as an airport. The
land was requisitioned in WWI when it did not need planning permission. In 1998,
the MoD announced its desire to dispose of the airfield. The then Local Plan had not
addressed the possibility of a civilian airport on the site. The Council therefore
produced a plan supplement - the Central Island Initiative - which was adopted in
August 1998. This supplement did not go out for full consultation in the way that the
Local Plan did, particularly not in Ramsgate, the town at the end of the runway where
residents were likely to be worst affected by the airports activities. So, when the
airport became a civilian airport, this outcome had not been properly consulted on as
part of the then Local Plan.
TDC could have insisted that the airport apply for proper planning permission, but it
chose not to do so. Instead, in 1998 and 1999, TDC issued a series of Certificates of
Lawful Use, on the grounds that civil aviation had been taking place on the airfield for
more than ten years alongside military use of the airfield. Residents challenged TDC
in the High Court and Appeal Court over the issue of these Certificates. The court
ruled that these Certificates simply allowed the airport to be transferred from military
to civilian ownership. Any future intensification of use would have to be dealt with via
the planning system. This has never happened.

https://planning.thanet.gov.uk/onlineapplications/files/D05DF98CE21FFE89BDA7E1268A674609/pdf/F_TH_15_0457DECISION_NOTICE-357922.pdf

A Certificate of Lawful Use is not planning permission. Government guidance says

that:
The certificate is not a planning permission. The planning merits of the use,
operation or activity in the application are not relevant.
Since these Certificates were issued, there have been a lot of changes on the former
airport site. Year by year piecemeal development has taken place that has required
a series of planning permissions to be given for specific buildings and structures. In
defiance of the legislation that says that this kind of cumulative, bit-by-bit
development should trigger a proper Environmental Impact Assessment (EIA),
TDCs own written summary demonstrates that it has allowed airport operators to
develop the site without carrying out a full EIA.6
In summary, TDCs refusal of the Change Of Use application is not supported by an
up-to-date Local Plan, nor is it supported by planning decisions that have been made
following joint working with the local community.
Paragraph 17 also says that planning should:
proactively drive and support sustainable economic development to deliver
the homes, business and industrial units, infrastructure and thriving local
places that the country needs. Every effort should be made objectively to
identify and then meet the housing, business and other development needs of
an area, and respond positively to wider opportunities for growth. Plans
should take account of market signals, such as land prices and housing
affordability, and set out a clear strategy for allocating sufficient land which is
suitable for development in their area, taking account of the needs of the
residential and business communities;
The report that officers put to the Planning Committee concluded that there was a
need for larger industrial units in the area. However, the Committee failed to respond
positively to this need. It has failed to respond to the needs of business and to wider
opportunities for growth. Moreover, TDC has ignored the biggest market signal of all
in relation to this site i.e. that the airport closed in May 2014 having made a loss of
around 100m7 in its 15 year commercial life. Preserving the site in case, in some
distant future, it becomes an airport again is not supporting sustainable economic
development.

Letter from Doug Brown, TDC, to Malcolm Kirkaldie, local resident, 2008

Manston Airport under private ownership: the story to date and the future prospects Position
statement by Kent County Council March 2015

Paragraph 17 also says that planning decisions should:

support the transition to a low carbon future in a changing climate, taking full
account of flood risk and coastal change, and encourage the reuse of existing
resources, including conversion of existing buildings, and encourage the use
of renewable resources (for example, by the development of renewable
energy);
The Change Of Use application is an application to make use of an existing building,
in line with the NPPF. The advanced manufacturing planned for that building is a far
lower carbon option than the cargo airport that TDC would like to see on the site at
some unknown future date.
Planning should:
contribute to conserving and enhancing the natural environment and
reducing pollution.
The former airport created noise and air pollution for the area. Despite the efforts of
the Environment Agency to get the previous owners of the airport to take its
environmental duties seriously, run-off from the airports runway also went untreated
into Pegwell Bay, a SSSI. Noise reports8 produced by experts for the Council
showed that the airport had a significant negative environmental impact on the town
of Ramsgate, situated at the eastern end of the runway. The Change Of Use
applications support a lower pollution use of the site in comparison to the Councils
desire for a cargo airport on the site.
Paragraph 17 also says that planning should:
encourage the effective use of land by reusing land that has been previously
developed (brownfield land), provided that it is not of high environmental
value;
The Government has stated that former airfields are brownfield land. TDC should
therefore support the owners desire to re-use it.
Paragraph 17 also says that planning should:
promote mixed use developments, and encourage multiple benefits from the
use of land in urban and rural areas, recognising that some open land can
perform many functions (such as for wildlife, recreation, flood risk mitigation,
carbon storage, or food production);

Thanet District Council Manston Airport night noise assessment review 4222827/R01 November
2010 Bureau Veritas

The owners plan for the site is for a mixed use development. TDC should be
promoting and encouraging this by supporting the Change Of Use applications.
Paragraph 17 also says that plans should:
take account of and support local strategies to improve health, social and
cultural wellbeing for all, and deliver sufficient community and cultural facilities
and services to meet local needs.
The broader plan for the site is for a mixed use development of employment,
residential, community and open space use. It would provide a considerable amount
of public open space as well as developing a heritage quarter. The Change Of Use
applications fit within this mixed use vision.
In summary, it would appear that the NPPF is more helpful to the owners of the site
and their application to re-use existing buildings for new employment opportunities
than it is to TDC who hope that the site will, at some unknown future stage and as a
result of finding an as yet elusive credible financial partner, be an airport again. At
the moment, the Council has no means of making that future happen. The NPPF
does not provide for land to be mothballed by LAs in support of unsubstantiated
land-use dreams that have little or no chance of ever being realised.

POLICIES EC4 AND CC1 TAKE NO ACCOUNT OF NEW MATERIAL

EVIDENCE
Clearly, the 2006 Local Plan was based on evidence captured before 2006. That
evidence is now demonstrably out of date. In fact, that evidence was already out of
date during the life of the old Plan. As part of its evidence base used for the 2006
Plan, TDC said that by 2011 it expected Manston airport to deliver as follows:
the Council takes the position that it should plan for 1 million passengers,
and 250,000 tonnes of freight per annum by the end of the Plan period.
In fact, the airport only ever managed a peak of about 20% of the Councils
aspiration for passenger numbers (just 206,875 passengers in 2005) and even less
than that in terms of its freight performance (a peak of 43,026 tonnes of freight in
2003). Levels of freight and number of passengers at the airport fell after the
introduction of the 2006 Plan, rather than increasing as the Council had envisaged.
By the final year of the airports operation in 2014, aviation business had fallen to
40,391 passengers and 29,306 tonnes of freight far, far below the level that the
Council had written into and planned for in its 2006 Local Plan. 9

http://data.parliament.uk/writtenevidence/committeeevidence.svc/evidencedocument/transportcommittee/smaller-airports/written/18016.html

As further evidence that saved policies EC4 and CC1 are no longer relevant, it must
be borne in mind that the airport closed nearly two years ago; it is no longer licensed
by the CAA and much of the necessary equipment for it to operate as an airport has
been sold. There is no airport.
It is clear from this that the saved policies from the 2006 Plan on which TDC is
relying as reasons for its rejection of the Change Of Use application, are based on
out-of-date evidence. Moreover, that evidence was out of date some years ago, and
the Council knows this. The new evidence of which the Council must take note in its
planning decisions is that there is no longer an operational airport at Manston and
also that, when it was operating, the airport was far less successful economically
than the Council had planned for. This new evidence is material and, taking
guidance form the NPPF, must be given considerable weight in the determination of
the Change Of Use applications.

POLICIES EC4 AND CC1 HAD BEEN CONSIDERED BY TDCS

OFFICERS IN THEIR RECOMMENDATIONS TO THE PLANNING
COMMITTEE AND DEEMED NOT TO BE CREDIBLE GROUNDS FOR
REJECTING THE CHANGE OF USE APPLICATION
The relevant policies saved from the 2006 Plan are:
POLICY EC4 - AIRSIDE DEVELOPMENT AREA
Land at the airport, as identified on the proposals map, is reserved for airside
development. Development proposals will require specific justification to
demonstrate that an airside location is essential to the development proposed.
Development will be required to retain sufficient land to permit access by
aircraft of up to 65m (217ft) wingspan to all parts of the site.
POLICY CC1 - DEVELOPMENT IN THE COUNTRYSIDE
The Thanet countryside is defined as those areas of the district outside
the identified urban and village confines.
Within the countryside, new development will not be permitted unless there is
a need for the development that overrides the need to protect the countryside.
With regards to saved policy EC4, TDCs officers advised Members that the
proposed Change Of Use for application 3140990/Building 87010:

would not affect the main runway

would not inhibit taxiway clearance

10

http://democracy.thanet.gov.uk/documents/s48299/Report.pdf

would not have a negative effect on the operation of the airports radar

was not seen by the Civil Aviation Authority as a potential inhibitor of any future
operation of the site as an airport.

Officers report to Planning Committee Members concluded on saved policy EC4:

In conclusion as a result of the additional information provided, and following
the comments of the CAA, it is considered that the proposed development
would not have a significant impact on the potential operation of the Airport.
With regards to saved policy CC1, the officers said:
the applicant has made a strong and clear argument for the need for a
building of this size to support a local business to expand, and as confirmed
by the Head of Economic Development there are no currently identified
alternative buildings available elsewhere in the District for a business of this
size to operate from. Although permission would run with the land and is not
linked to the business that may intend to use it, it is clear that a need has
been demonstrated for an industrial unit of that size, which does not appear to
be available elsewhere in the District.
The report to the Planning Committee therefore went on to recommend:
The recommendation of Officers to the Planning Committee is to approve the
application as an acceptable departure to Thanet Local Plan Policy EC4 and
CC1, given the specific demonstrable need for a building of this size for a
business within the district and the economic and employment benefits of the
proposal.
It is clear from the officers advice that they did not consider saved polices EC4 and
CC1 to be a barrier to TDC approving the Change Of Use application. However,
TDCs Members ignored this advice. The recording of the Committee meeting makes
it clear that Members rejected the Change Of Use application for reasons that are
not legitimate planning reasons. Members of the Planning Committee articulated
their reasons for rejecting the application as follows:

the airport is designated as an airport in the current Local Plan [in truth, there is
no current Plan, just some saved policies]

the proposed tenants were unsuitable [no evidence was given as to their
unsuitability. Planning permission, if given, would run with the land and not be
dependent on the tenant, making this concern irrelevant]

the Council was committed to a CPO of the site and so the applications should be
dismissed out of hand [in fact, the Council has twice decided that it cannot
pursue a CPO of the site; has no way of undertaking a CPO of the site; and, of
course, every planning application should be considered properly on its merits]

there was an agenda; Members did not know who was behind the application;
and the application was spurious [these vague concerns or allegations are not
valid reasons for refusing planning permission]

there were too many parking places [officers assured Members of the Committee
that Kent County Council had no issues with the suggested level of parking, but
this was ignored]

the officers did not have aviation expertise

despite the fact that there were, quote, no planning reasons for rejecting the
application, it was what people in the gallery wanted [this acceptance by at least
one Member that there were no planning reasons for rejecting the application
says it all].

Officers then advised that the meeting be adjourned and removed Members to
another room so that reasons for rejection could be crafted.

TDCS DECISION IS BASED ON A FLAWED UNDERSTANDING BY

MEMBERS OF THE CPO PROCESS
For all the reasons stated above, the chance of TDC ever acquiring the site by way
of a CPO to redevelop it as an airport is vanishingly small. However, in the unlikely
event that this were to happen, CPO legislation makes it clear that the Council would
acquire the site with vacant possession. Therefore it makes no sense to refuse the
Change of Use applications because there might possibly be a CPO and therefore a
future need for these buildings for aviation. Were a CPO to be granted, the tenants
would have to vacate the site anyway and the buildings could then be used for
aviation support purposes by the airports owners, just as they were before.
Finally, the site is large (around 720 acres) and has plenty of development space.
Were it ever to become an airport again, there is ample room to build new buildings
to support the needs of aviation on that site.

THE PLANNING CONTEXT THE NEW LOCAL PLAN

TDC is in the process of writing its new Local Plan. The draft Local Plan recognises
at paragraph 1.32 that:
The National Planning Policy Framework requires that we should avoid the
long term protection of allocated sites where there is no reasonable prospect
of them being used for that purpose.
And yet, in treating the Change Of Use applications as if they were happening on
site that is, or could be, an operational airport, this is exactly what TDCs Planning
Committee did.

10

The draft Local Plan entertains the possibility that, instead of being retained for
airport use, the site of the defunct airport should be recognised as an Opportunity
Area, subject to an Area Action Plan (AAP). That AAP will:
assess mixed-use development that will deliver significant new high
quality skilled and semi-skilled employment opportunities, residential
development, sustainable transport and community facilities.
TDC has therefore already accepted the possibility that the site will not be used as
an airport in the period of the next (and already overdue) Local Plan. The Change Of
Use applications are entirely consistent with the use of the site as a mixed-use
development.
Any Local Plan must be sound, justified and realistic. It must support sustainable
development which supports positive economic, social and environmental outcomes.
TDCs desire to support retention and expansion of aviation activity on this site an
option that is also considered in the draft Local Plan - is clearly flawed. It is neither
sound nor realistic. The site is not functioning as an airport and has not done so for
20 months. The sites owners have no plans to redevelop the site as a new airport.
TDC cannot afford to buy the site from the owners. TDC therefore needs a wealthy
and credible indemnity partner before it can even consider attempting to CPO the
site for use as an airport some years in the future. TDC has twice decided that it
does not have a suitable indemnity partner so it cannot start this process.
Even if a suitable partner could be found, the lack of economic viability of the airport
(evidenced by expert reports from Parsons Brinkerhoff11 and from Falcon
Consultancy12 as well as by 15 years of operational failure) means that there is not a
"compelling case in the public interest" to try to CPO the land to reopen an airport on
that site. Given this, TDC has no reasonable expectation of a CPO being awarded so
that an airport can be developed on this land. There is no economic, social or
environmental justification for attempting to safeguard this site for aviation use.
The airport has consistently failed to contribute positive economic, social and
environmental outcomes for the area. As an airport, the site produced 144 jobs at
peak. Many of these were part time. The average wage was lower than the average
wage in the rest of Thanet. The airport contributed negatively to the environment by
virtue of noise pollution, air pollution and water pollution (the runoff into Pegwell
Bay). The airport offered nothing in terms of the social or community fabric of the
area.

11

Validation report on documents submitted by Manston International Airport relating to a proposed

night-flying policy Parsons Brinkerhoff, January 2012, paras 2.1.1 and 2.1.2
12

Expert opinion on the prospects for the viable development of Manston Airport Falcon
Consultancy Ltd, July 2014

11

The draft Local Plan is also flawed in entertaining the idea that there could be an
airport on this site alongside other strategic aspirations for the area. It is inconsistent
to suggest, as the draft Plan does, that there could be a cargo airport at Manston at
the same time as developing Ramsgate as a centre for tourism, leisure, heritage and
nature conservation. Noise pollution, air pollution, and the need to introduce Public
Safety Zones would all produce significant constraints for Ramsgates development
as a tourism and cultural destination. TDC's draft Local Plan fails to recognise and
deal with the significant negative impact that a cargo airport at Manston would have
on Ramsgate's future.

THE CHANGE OF USE APPLICATIONS THEMSELVES

When the four Change Of Use applications were submitted, the owners set out
credible estimates that, if approved, the re-purposed buildings could support 320
jobs on the site. The estimates were credible because the owners were in discussion
with companies very keen to relocate to the site. 320 jobs is more than double the
number of jobs that the airport created in 15 years of civilian operation across its
entire site. At the time of application some jobs (those at Instro Precision) already
existed in the Thanet area. However, they were in danger of being lost to Thanet as
the company had outgrown its base and had found no suitable premises locally. In
fact, when TDC turned down the Change Of Use applications, the company started
actively looking at premises in another district, losing Thanet much-needed
employment.
Many of the other 220 jobs envisaged can be brought on site quickly either because
potential tenants are already in discussions with the sites owners about moving
existing jobs or because the companies involved have immediate expansion plans.
Thanet is an area of high unemployment and TDC has a responsibility to welcome
job creation and job retention.
The application for Hangar 1 (3140995) is for three years only. There is no case for
refusing this as there is no realistic chance of a successful CPO and a new airport
being developed on the site within that period. More importantly, were a CPO of the
site to be granted so that an indemnity partner could develop a new cargo airport on
the site, the CPO legislation allows for vacant possession of the site. Therefore any
Change Of Use between now and the unlikely event of a CPO being granted is
irrelevant from the point of view of the Councils decision to protect the site for
aviation purposes, as tenants would be forced to leave anyway were a CPO to be
awarded.
The traffic assessment submitted makes it clear that the traffic implications of these
Change Of Use applications are insignificant.
Three of the four Change Of Use applications are suggesting no change to the
outward appearance of the buildings and the changes envisaged in the fourth are

12

insignificant. The four buildings are in themselves of no architectural merit. There are
no adverse planning implications of the future use envisaged for these buildings.

13

IN SUMMARY:

The Council has failed to issue a decision on applications 3140992, 3140994 and
3140995

The Council rejected the Change Of Use application for 3140990 on the back of
saved policies from the 2006 Local Plan

Policies EC4 and CC1 on which TDC is relying take no account of new national
policy

Policies EC4 and CC1 on which TDC is relying take no account of new material
evidence

Policies EC4 and CC1 were considered by TDCs officers in their

recommendations to the Planning Committee meeting of October 2015 and were
deemed not to be credible grounds for rejecting the Change Of Use application

The National Planning Policy Framework requires that Councils should avoid the
long term protection of allocated sites where there is no reasonable prospect of
them being used for that purpose. There is no reasonable prospect of this site
being used as an airport

The draft Local Plan considers that the site of the former airport could be
recognised as an Opportunity Area, subject to an Area Action Plan (AAP) that will
assess mixed-use development that will deliver significant new high quality
skilled and semi-skilled employment opportunities, residential development,
sustainable transport and community facilities. This is in line with the owners
plans and with the Change Of Use applications

The Change Of Use applications are a bid to use brownfield land to support new
or additional jobs. Thanet is an area of high unemployment and TDC has a
responsibility to welcome job creation and job retention

There is no need to safeguard these buildings for aviation use. Aviation could
only return to that site if TDC were to find an indemnity partner and obtain a CPO.
Should this happen, the site would be handed to the Council with vacant
possession, freeing these four buildings for aviation use

The application for Hangar 1 (3140995) is for three years only. There is no case
for refusing this as there is no realistic chance of a successful CPO and a new
airport being developed on the site within that period

The traffic assessment submitted makes it clear that the traffic implications of
these Change Of Use applications are insignificant

Three of the four Change Of Use applications are suggesting no change to the
outward appearance of the buildings and the changes envisaged in the fourth are
insignificant. The four buildings are in themselves of no architectural merit. There

14

are no adverse planning implications of the future use envisaged for these
buildings

The appeals should be upheld and the applications should be

approved.

FOOTNOTE
We appreciate that the Planning Inspectorate will look at planning reasons when
assessing this appeal rather than following the lead of some TDC Councillors and
approving what the people want. However, we do want to make a point here about
local feeling about this site. In 2014, some people signed petitions to reopen
Manston as an airport because they fear that the site will be used solely for housing
if it is not returned to airport use. This is a fear that a local MP, Sir Roger Gale, has
actively encouraged in his regular column in the local Press. Many of these people
are not local residents. Some signed petitions more than once. We reproduce at
Appendix One a submission that we made on this subject to the Select Committee in
February 2015.
This save Manston campaign is now running out of steam with a couple of dozen
people turning out, at most, for every protest event that the coordinators, Save
Manston Airport, organise. Indeed, in last years parliamentary elections the only
candidate who stood purely on a save the airport ticket garnered just 191 votes
(0.4%). In the local by-elections in January 2016, the save Manston candidates
polled very few votes. Neither of the winning candidates stood on a save Manston
ticket.
By contrast, the owners of the old airport site have held a couple of informal
consultation events about their outline plans for the redevelopment of the site.
Attendance has reached more than a couple of hundred people at each event. More
than 80% of the feedback given to the owners about their proposals for the site has
been positive and supportive. People who actually live in the area want to see jobs,
decent housing, community services and a site that they can use. The owners
Change Of Use applications are in line with this new purpose for the site.

15

Appendix One
Local support13
163. 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 prayer
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

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Submission to the Select Committee on Manston Airport from No Night Flights, February 2015,
paras 163 - 174

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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 petitions
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.
173. The only properly managed public consultation about the airport was
TDCs 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.
174. 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.

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