Ramsgate Town Council has formally submitted its response to the
Civil Aviation Authority (CAA) consultation on proposed changes to airspace and
flight procedures linked to the potential reopening of Manston Airport.
The Council’s response sets out strong objections to the proposals, citing
concerns over noise, public health, safety, environmental impact, and the
credibility of the project. The submission is supported by an independent
technical report commissioned by the Council, which has been submitted
alongside the response.
Residents are strongly encouraged to take part in the consultation and submit
their own views before the deadline of 22 June 2026.
The consultation can be accessed via the Civil Aviation
Authority’s Airspace Change Portal (https://consultations.airspacechange.co.uk/manston-airport/manston-airport-consultation/)
Residents may respond with any views they wish, including personal experience,
specific concerns, or general comments on the proposal.
Council’s Submitted Response
Ramsgate Town Council has commissioned an
independent technical review, “Review of Manston Airport Airspace Change
Proposal (ACP) – Options Appraisal” (ASA, May 2026), which is submitted
alongside this response as a supporting document. This report has informed the
Council’s position and should be read in conjunction with this submission.
(i) Overall Objection
to the Proposal
Ramsgate Town Council strongly objects to the proposed airspace
changes and Instrument Flight Procedures (IFPs) for Manston Airport due to
unacceptable noise and health impacts, serious safety concerns, environmental
harm, procedural inconsistencies, and fundamental credibility issues with the
proposal.
Under both Design Combinations A and B put forward by the
applicant, aircraft (primarily cargo freighters) would routinely overfly
densely populated areas of Ramsgate (population circa 42,000) at very low
altitudes of approximately 230–900 feet above ground level (AGL) during
departures from RWY10 and arrivals on RWY28.
This position is supported by the Council’s
commissioned consultant report, which confirms that departures and arrivals
would inevitably overfly Ramsgate, with aircraft potentially as low as
approximately 375 feet in some locations.
The applicant proposes increasing activity to 14,000 Air Traffic
Movements (ATMs) annually by 2038 (around 38 movements per day), between 2 and
4 per hour.
These flight paths and 3° approach and initial climb paths were
previously used by 747 400 freighters until the airport’s closure in 2014, when
operations were limited to around 1,000 ATMs per year (roughly one cargo flight
daily). Even at that much lower level of activity, they caused considerable
disturbance to residents’ sleep and enjoyment of their gardens and open spaces.
Lessons were disrupted in local schools, and services in churches.
Approval of these greatly increased plans would cause major
blight over residential, business and community facilities without the
applicant having secured funding, committed operators, or independently
verified demand.
The application for a Development Consent Order (DCO) led to
over one thousand local objections. Following a substantial hearing into the
applicant’s bid for a DCO, the Planning Inspectorate recommended refusal on the
grounds that the applicant had not demonstrated need for the proposal and that
there was potential for environmental harm. The DCO was subsequently allowed by
the then Secretary of State without addressing those concerns.
(ii) Public Health
Impacts of Noise
Based on the documentation provided in the Manston Airport
Airspace Change Proposal (ACP C3 2), it is possible to understand the impact of
noise from the proposed Freight Hub.
Table 6.1 of RSP’s report explicitly monetises the expected
increase in adverse health conditions resulting from the noise generated by the
airport’s operations, including dementia and strokes.
The UK Government, via Department for Transport TAG units, uses
established medical research to link environmental noise, specifically aircraft
noise, to physical health impacts.
Long term exposure to high noise levels, particularly at night,
triggers stress responses in the body such as increased cortisol levels and
raised blood pressure. Over time, this significantly increases the statistical
risk of strokes and Acute Myocardial Infarction (AMI / heart attacks).
More recent environmental studies show a correlation between
long term noise pollution and the acceleration of cognitive decline or the
onset of dementia.
The proposal also results in significant sleep disturbance and
loss of amenity, representing the economic cost of people losing sleep and the
loss of enjoyment of their homes and gardens.
The Council’s commissioned report further
confirms that chronic exposure to aircraft noise is associated with
cardiovascular impacts, sleep disturbance, cognitive effects, and wider public
health consequences, reinforcing the seriousness of these impacts for Ramsgate
residents.
RSP’s own report assigns the following monetised
health impacts attributable to noise (identical under both design options):
- Sleep disturbance: £355,157
- Loss of amenity: £14,539,029
- Acute myocardial infarction (AMI): £95,670
- Stroke: £2,333,407
- Dementia: £3,519,740
This equates to total health effects from noise of £20,843,003
over a ten year period.
The inclusion of these figures is an explicit admission by the
applicant that the reopening and operation of Manston Airport is projected to
have a quantifiable negative impact on public health. The report effectively
states that, over the ten year assessment period, the increased noise from the
airport will result in sufficient additional strokes and cases of dementia
alone to cost the health service and society over £5.8 million.
(iii) Requested
Conditions and Redesign Requirements
Ramsgate Town Council considers that the Civil Aviation
Authority should withhold approval of the proposed Instrument Flight Procedures
unless the applicant brings forward a fundamental redesign that:
- Achieves at least 1,500 feet AGL above populated areas.
- Provides an absolute preference for the use of non-seaward flight paths for both take-off and landing.
- Delivers meaningful seaward offsets, in accordance with the stated Design Principles, for any residual seaward flight paths used for departures or arrivals.
- Enforces strict night time restrictions, consistent with prior “no night flights” pledges.
- Is supported by robust, independently scrutinised evidence of demand, operational viability, safety, and secured funding.
These requirements are consistent with the findings of the Council’s independent review, which identifies limited viable options to reduce overflight of Ramsgate and highlights deficiencies in the assessment of alternative designs and operational assumptions.
(iv) Critique of the
Consultation Process
RSP has organised only two public facing consultation sessions,
only one of which is in Ramsgate, despite 40,000 residents potentially being
affected by the proposals. Previous public consultations organised by RSP have
resulted in residents being harassed by RSP personnel and airport supporters.
The online consultation process is also inadequate and open to
manipulation. The submission space is very limited, text only, and did not
allow PDF or Word documents, photographs, diagrams or plans to be submitted,
until Ramsgate Town Council made this request.
Individual submissions, whether online via Citizen Space or by
post, are not visible to respondents or the public during the consultation
period (open until 22 June 2026). The Citizen Space portal currently exists
solely for viewing the sponsor’s materials and submitting new responses. There
is no public responses section, browsable list, or real time feed. No
moderation or publication occurs during the open period; all submissions remain
private until closure.
Only after the consultation closes does RSP collate, review and
categorise responses, moderating content before uploading anonymised
submissions for public viewing. RSP then produces a Consultation Response
Document summarising themes and explaining how feedback influenced, or failed
to influence, the proposal.
This material is then submitted to the CAA as part of the
Consultation Gateway review, where the CAA assesses whether the consultation
was proportionate, fair and transparent, including sampling whether opposition
has been accurately categorised and not downplayed.
If an individual response does not appear, or appears
misrepresented, following publication after consultation closure, that is the
only point at which respondents can escalate concerns directly to the CAA, with
proof of submission.
While the process is ostensibly designed to prevent real time
influence campaigns during the consultation window, it places significant trust
in the sponsor and creates a clear asymmetry whereby respondents submit blind
and have no visibility or confidence in how their views are handled until after
the process concludes.
(v) Summary and
Conclusion
Ramsgate Town Council considers that the proposed airspace
changes and associated Instrument Flight Procedures for Manston Airport would
have a significant and adverse impact on the town and its residents. The
proposals would result in frequent, low level overflight of a densely populated
urban area, recreating historic flight paths that previously caused serious and
well documented disturbance, but at a scale many times greater than before.
The applicant’s own documentation acknowledges substantial
negative effects arising from aircraft noise, including sleep disturbance, loss
of amenity and increased risks of serious health outcomes such as
cardiovascular disease and dementia. These impacts are not abstract or
speculative; they are explicitly quantified within the proposal and amount to a
material public health burden over the assessment period.
The Council’s independent consultant report,
submitted alongside this response, provides further technical analysis
supporting these conclusions, including detailed assessment of airspace
options, noise impacts, and associated environmental and operational
considerations.
In addition to the environmental and health concerns, the Town
Council has significant reservations regarding the credibility of the project
as a whole, given the absence of secured funding, committed operators, or
independently verified demand, alongside the unresolved objections previously
raised during the Development Consent Order process. The consultation itself is
also considered inadequate in scale and accessibility for a proposal with such
far reaching consequences for Ramsgate’s community.
For these reasons, Ramsgate Town Council believes that approval
of the proposed airspace changes would be premature and unjustified. The
Council urges the Civil Aviation Authority to withhold approval unless and
until the applicant brings forward a fundamentally revised scheme that
demonstrably minimises overflight of populated areas, protects residents from
night time disturbance, aligns with stated design principles, and is supported
by robust, independently scrutinised evidence of need, viability, safety and
funding.
The full independent technical review report can be found here:
Review of Manston Airport Airspace Change Proposal (ACP) – Options Appraisal” (ASA, May 2026)