You say that the onus is on applicants to get their applications right before they are submitted. How are they supposed to do this if the feedback they need is not given until later? For example, the local council will not be asked to provide their opinion on the adequacy of consultation until after the application has been submitted. Until the council is asked to comment you cannot know the full horror of what was done (or not done) and just how many people knew nothing about the proposal. Surely, the applicants need to know that their consultation has not been good enough if they are to design a better one? The points I have made in previous correspondence stand. RSP have not provided people who would be badly affected by noise from their proposed development, with adequate information about the likely impacts.
This proposed development is somewhat different from others, in that the applicants are seeking to use the DCO process to reopen something which previously existed. Quite how there can be a national need for a new freight airport, when the old one went bust because it wasn't viable, is something which needs to be explained. Three separate aviation consultants' reports have now concluded that an airport at Manston is not viable. These include York Aviation, whose claim that RSP have cherry-picked and misrepresented their findings. We know that it will generate unacceptable levels of noise because that's what it did when it was open previously. It is not acceptable for the applicants to make a unilateral decision not to advertise their consultation to large numbers of people who were previously affected by severe noise.
It would make a great deal of sense to separate the decision on whether a project is a Nationally Significant Infrastructure Project from the rest of the application process. In many cases it will be obvious that a proposal is of national significance but, in this case, the rationale for needing a new freight depot really should have been established before the applicants were allowed to embark on this ridiculous exercise. When the vast bulk of freight is carried in the belly-hold compartments of passenger aircraft, it makes no sense whatsoever to be trying to create a facility which is dedicated to freight planes so far from the major passenger hubs. I have been in touch with the Infrastructure Planning Commission and they have confirmed that this project is not something which they have either considered or backed.
I would like to see this application put on hold pending a decision on whether it is or is not a Nationally Significant Infrastructure Project. The ongoing uncertainty is causing a great deal of damage in Thanet, and the repeated delays just prolong the misery. I don't believe the DCO process was ever intended to be used in this way and it is incumbent on those in positions of authority not to allow it to be drawn out indefinitely.
I am only able to reiterate that the Secretary of State cannot test the project against the provisions in section 23 of the Planning Act 2008 (PA2008) until an application is submitted to the Planning Inspectorate. The Applicant has however stated that the consultation documents for its 2018 exercise will set out its position on the baseline assumed in terms of flight numbers for the purposes of the capability test set out in the PA2008: attachment 1