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CPREKent2

Council for the Protection of Rural England objection

Mr D Brown

Development Services

Thanet District Council

PO Box 9

Cecil Street

Margate, Kent

CT9 1XZ

27th June 2008

Dear Mr Brown,

Planning Application F/TH/08/0400 – Redevelopment of land for B1c, B2 and B8 (industrial and warehouse uses) mixed commercial use with ancillary parking and landscaping on land at Manston Business Park, Manston Road, Manston, Ramsgate – Amended Plans

Thank you for your letter of 17th June 2008 inviting comments on the amended plans in relation to the above-mentioned planning application.

I should start by saying that CPRE Kent maintains its strong objection to the application for the reasons given in my letter of 9th May 2008.

The potential impact of the development on the local highway network and on the Source Protection Zone (SPZ) are major issues, and the fact that additional consultation on these issues has been necessary is a clear indication that the applicant is still grappling with them. This is both extremely unsatisfactory and worrying. These matters should have been thoroughly investigated and discussed with the relevant agencies before the application was submitted. As a consequence, residents and interested parties find themselves in a situation of having to consider another tranche of documentation, but with less than two weeks in which to do so and respond.

We cannot help but conclude that these amendments are a product of the very high degree of uncertainty surrounding the development, and a failure by the applicant to robustly undertake all the necessary supporting work. Consequently, we re-emphasise our view that the whole development must be a matter for the development plan process which will enable decisions to be made based on a robust evidence base which will be subjected to an independent examination.

We remain firmly of the view that, given the way the application is presented, it is impossible for the Council to consider phase 1 as a stand alone development as proposed in the Local Plan, and that it is inevitable that Members of the Council will have the larger scheme in their minds in considering the application, and will potentially be swayed by this. The amended plans do

nothing to address this issue, and we have seen nothing in the vast volume of supporting documentation that demonstrates that phase 1 could, and would, be delivered in accordance with the Local Plan.

The potential impact on the SPZ, as you are well aware, has raised serious concerns amongst local residents who are fearful of potential pollution of Thanet’s water supply. We share their concerns, and consider that the uncertainties surrounding the development, and the on-going deliberations as to how drainage and foul water disposal should be managed, make the threat to the SPZ very high risk. I appreciate that the Environment Agency (EA) is the appropriate body to advise you on this matter, but we consider that where such uncertainty exists the precautionary principle must be applied. The EA has already advised that groundwater quality in Thanet has been classified as poor status[1], and it is the EA’s responsibility to ensure that groundwater is protected and managed for future generations.

The EA’s literature on Groundwater, for example “Underground, Under Threat – the state of groundwater in England and Wales” published in 2006, clearly highlights that groundwater is vulnerable to contamination, and identifies large building developments as causing a variety of problems for groundwater, including pollution. These problems they see as only getting worse in the future[2]. Once polluted, groundwater becomes very difficult, even impossible, to clean. Specifically, the EA highlight underground storage as being a particular risk to groundwater pollution because of the difficulty of detecting and dealing with leaks, and as a consequence it is “inherently more risky than above ground” storage[3]. The applicants, though, have opted for this inherently more risky approach.

Given a) the serious implications for groundwater pollution arising from the development, and the associated risk to a water supply that is already classified as poor, and b) the applicants larger scale proposals and the uncertain nature of the composition of the development, we strongly consider that a precautionary approach must be taken. The potential serious impact on groundwater is a matter that must be subject to rigorous and independent examination where all the technical information can be assessed before a decision is made – not presented in the ad hoc fashion that it has been. Such rigorous examination can only be done through the development plan process.

On other matters, we note that the applicants have now produced a further ‘final’ travel plan. Worryingly, the section proposing a shuttle bus has been removed from the plan, which is a detrimental step (though it is still obliquely referred to in paragraphs 12.7 and 12.9). The firm commitment to the provision of a shuttle bus must be reinstated if the plan has any chance of achieving the ambitious 20% modal transfer target.

Also with regard to the revised travel plan, paragraph 5.9 indicates that a total of 1,920 cycle parking spaces will be provided – 907 just in phase 1. Such a high level of provision is to be applauded, but with just 150 (5%) of the indicated 3,000 workforce being targeted to travel to work by bicycle this provision does seem to be unnecessary high. If all of these spaces are used, that would mean that 64% of the indicated workforce would have to cycle to work! Could there possibly be a mistake in the figures here?

I am also a little confused as to the total number of people that will be employed on the site. As mentioned above, the travel plan refers to 3,000, whilst other documents refer to 2,000 to 3,000 employees. However, when discussing water supply in the Water and Sewage Strategy (section 4.2) it is assumed that there will be 1 worker per 50 sq.m of floorspace. With a total proposed floorspace of 325,000 sq.m, this equates to some 6,500 employees in total. What is the correct figure?

These last two points might seem trivial and a little flippant, but they suggest a lack of thoroughness in putting together the supporting documentation. Such inconsistencies do nothing to give confidence to residents and interested parties in the robustness of the information presented, particularly when the scheme already has so many unknowns and uncertainties. This underlines the need for independent and detailed examination.

Yours sincerely

Brian Lloyd

Senior Planner

CPRE Kent

[1] Letter from Kathy Aucott to Thanet District Council dated 19th March 2008.

[2] See page 5 of “Underground, Under Threat”.

[3] See pages 4 and 9 of the EA’s publication “Groundwater Protection: Policies and Practice – Part 4: Legislation and policies, public consultation 2007”


	Thanet Ground Water Quality \| home Return to post and other links \| Thanet Ground Water Quality \| Thanet Ground Water Quality table \| Manston map \| Benzine \| From the China Gateway environmental report \| Xblocks \| Phases \| Source Protection Zones \| EA \| Environment Agency's Response \| My response to the Environment Agency \| My initial objection to the development \| Executive Director of East Kent Opportunities LLP \| Title 15 \| Title 16 \| CPRE Kent \| CPREKent2 \| Title 19 \| Title 20 \| Title 21 \| Environment Agency being difficult \| Information Request \| Letter to Doug 5.7.8 \| Natural England's comments \| complaint ref 1342 \| Title 33 \| power of the sea \| BRIEFING DOCUMENT FOR THANET DISTRICT COUNCILLORS \| More from the EA \| Southern Water discharge consent letter. \| INFRATIL LETTER \| Recommendation to the planning committee to approve \| Explosive \| Developers clarification of points raised at the planning meeting \| Doug Emails \| CUMMINS POWER GENERATION LTD. \| Title 47 \| voting \| Sericol Investigations \| Title 50 \| the history at Thor \| EA letter to KIA 19.12.08 \| EA letter to KIA 18.12.08 CPREKent2 Council for the Protection of Rural England objection Mr D Brown Development Services Thanet District Council PO Box 9 Cecil Street Margate, Kent CT9 1XZ 27th June 2008 Dear Mr Brown, Planning Application F/TH/08/0400 – Redevelopment of land for B1c, B2 and B8 (industrial and warehouse uses) mixed commercial use with ancillary parking and landscaping on land at Manston Business Park, Manston Road, Manston, Ramsgate – Amended Plans Thank you for your letter of 17th June 2008 inviting comments on the amended plans in relation to the above-mentioned planning application. I should start by saying that CPRE Kent maintains its strong objection to the application for the reasons given in my letter of 9th May 2008. The potential impact of the development on the local highway network and on the Source Protection Zone (SPZ) are major issues, and the fact that additional consultation on these issues has been necessary is a clear indication that the applicant is still grappling with them. This is both extremely unsatisfactory and worrying. These matters should have been thoroughly investigated and discussed with the relevant agencies before the application was submitted. As a consequence, residents and interested parties find themselves in a situation of having to consider another tranche of documentation, but with less than two weeks in which to do so and respond. We cannot help but conclude that these amendments are a product of the very high degree of uncertainty surrounding the development, and a failure by the applicant to robustly undertake all the necessary supporting work. Consequently, we re-emphasise our view that the whole development must be a matter for the development plan process which will enable decisions to be made based on a robust evidence base which will be subjected to an independent examination. We remain firmly of the view that, given the way the application is presented, it is impossible for the Council to consider phase 1 as a stand alone development as proposed in the Local Plan, and that it is inevitable that Members of the Council will have the larger scheme in their minds in considering the application, and will potentially be swayed by this. The amended plans do nothing to address this issue, and we have seen nothing in the vast volume of supporting documentation that demonstrates that phase 1 could, and would, be delivered in accordance with the Local Plan. The potential impact on the SPZ, as you are well aware, has raised serious concerns amongst local residents who are fearful of potential pollution of Thanet’s water supply. We share their concerns, and consider that the uncertainties surrounding the development, and the on-going deliberations as to how drainage and foul water disposal should be managed, make the threat to the SPZ very high risk. I appreciate that the Environment Agency (EA) is the appropriate body to advise you on this matter, but we consider that where such uncertainty exists the precautionary principle must be applied. The EA has already advised that groundwater quality in Thanet has been classified as poor status[1], and it is the EA’s responsibility to ensure that groundwater is protected and managed for future generations. The EA’s literature on Groundwater, for example “Underground, Under Threat – the state of groundwater in England and Wales” published in 2006, clearly highlights that groundwater is vulnerable to contamination, and identifies large building developments as causing a variety of problems for groundwater, including pollution. These problems they see as only getting worse in the future[2]. Once polluted, groundwater becomes very difficult, even impossible, to clean. Specifically, the EA highlight underground storage as being a particular risk to groundwater pollution because of the difficulty of detecting and dealing with leaks, and as a consequence it is “inherently more risky than above ground” storage[3]. The applicants, though, have opted for this inherently more risky approach. Given a) the serious implications for groundwater pollution arising from the development, and the associated risk to a water supply that is already classified as poor, and b) the applicants larger scale proposals and the uncertain nature of the composition of the development, we strongly consider that a precautionary approach must be taken. The potential serious impact on groundwater is a matter that must be subject to rigorous and independent examination where all the technical information can be assessed before a decision is made – not presented in the ad hoc fashion that it has been. Such rigorous examination can only be done through the development plan process. On other matters, we note that the applicants have now produced a further ‘final’ travel plan. Worryingly, the section proposing a shuttle bus has been removed from the plan, which is a detrimental step (though it is still obliquely referred to in paragraphs 12.7 and 12.9). The firm commitment to the provision of a shuttle bus must be reinstated if the plan has any chance of achieving the ambitious 20% modal transfer target. Also with regard to the revised travel plan, paragraph 5.9 indicates that a total of 1,920 cycle parking spaces will be provided – 907 just in phase 1. Such a high level of provision is to be applauded, but with just 150 (5%) of the indicated 3,000 workforce being targeted to travel to work by bicycle this provision does seem to be unnecessary high. If all of these spaces are used, that would mean that 64% of the indicated workforce would have to cycle to work! Could there possibly be a mistake in the figures here? I am also a little confused as to the total number of people that will be employed on the site. As mentioned above, the travel plan refers to 3,000, whilst other documents refer to 2,000 to 3,000 employees. However, when discussing water supply in the Water and Sewage Strategy (section 4.2) it is assumed that there will be 1 worker per 50 sq.m of floorspace. With a total proposed floorspace of 325,000 sq.m, this equates to some 6,500 employees in total. What is the correct figure? These last two points might seem trivial and a little flippant, but they suggest a lack of thoroughness in putting together the supporting documentation. Such inconsistencies do nothing to give confidence to residents and interested parties in the robustness of the information presented, particularly when the scheme already has so many unknowns and uncertainties. This underlines the need for independent and detailed examination. Yours sincerely Brian Lloyd Senior Planner CPRE Kent [1] Letter from Kathy Aucott to Thanet District Council dated 19th March 2008. [2] See page 5 of “Underground, Under Threat”. [3] See pages 4 and 9 of the EA’s publication “Groundwater Protection: Policies and Practice – Part 4: Legislation and policies, public consultation 2007”