Comments on KCC/SW/0247/2017
Redevelopment of an existing waste management facility and inclusion of additional land into waste management use.
It is noted that this proposal seeks to increase the intensity of the existing waste transfer facility which was established in 1992 on the Faversham side of Oare Creek. This is in connection with the intended closure of an existing waste transfer station at Aylesham and consolidation onto a single site. The proposal involves the replacement of the existing buildings with taller and more extensive buildings, additional equipment including a crusher, conveyor, metal containers and stacked materials, extended storage area, night watchmen, weighbridges and more parking together with extended hours and a doubling of the number of lorries servicing the site. The planning application is supported by site plans, elevations of the buildings and equipment individually but not in context and reports on traffic generation, noise, a visual appraisal and studies on wintering birds and on the impact on the adjacent RAMSAR site.
The noise appraisal seeks to demonstrate that there is no harmful or even significant increase in noise levels emanating from the site as a result of the new buildings and greater area over which waste is treated. This is because some of the noisy machinery is enclosed in buildings and the site would be enclosed to the south by noise absorbent bunds. However, the noisiest item, the crusher, is at the unenclosed area of the site and is expected to run for periods of two weeks out of every six weeks. The site is already relatively close to residential areas in Oare to the south of Pheasant Barn which is identified as the nearest residential property and the measuring point for noise. The new residential development at Oare Lakes starts at 250m from the site which is substantially closer than the houses in Oare. This is also used as a measuring point for noise impact. At present the hours of operation are 0700-1800 on Mondays to Fridays and from 0700-1300 on Saturdays. This represents a 13-hour day on weekdays. The proposal includes the prospect, with the approval of KCC, of working on Sundays after Bank Holidays, Bank Holidays and Boxing Day working. These are all days when residents and potential residents would normally expect the site to be quiet and as such, this element of the proposal represents a substantial intrusion into residential amenity and the relative quiet of the area for walkers and other users. Further, it is proposed that the hours of operation for the lorries would be extended to run from 0500-2000 daily and 0500-1500 on Saturdays and to include Bank Holidays. These extra hours and days are also periods when it is usually expected to be much quieter than business hours and would intrude on the amenity of the area both for residents and outdoor users.
The existing facility with the exception of some partly used buildings is relatively low in height. It has been used since 1992 for waste transfer and previously there were other industrial uses around Oare Creek including loading cargoes and the explosives industry. The areas around Oare and Ham Marshes have been used for gravel working but are expected to be restored and new housing added on the Oare Lakes site. The footpaths, marshes and lagoons form part of a countryside buffer zone between Oare and Faversham. Close by and directly adjacent to the roadway serving East Kent Recycling are areas protected for wildlife comprising the SPA which is also a RAMSAR site. The erection of three large-footprint buildings at 20, 25 and 30m long with two over 7.5m high and one at 12m high represent a much more visible and extensive built development which would be more prominent in views from Oare village including from the footpaths near the playing field, from Church Road across the creek, from Ham Marshes and across Oare Creek on the Saxon Shore Way as well as from the footpath across the lagoons adjacent to the site. The footpath adjacent to the site which runs along the service road is already at least a moderately sensitive use but would become a highly sensitive use when it becomes part of the England Coast Path. It is considered that for these reasons, the erection of more extensive and high buildings on this site would be an unwelcome development and would contravene the aims of the Swale Landscape Character and Biodiversity Appraisal.
Dust and other air pollution issues
In addition to the dust and diesel particulates associated with the increased traffic flows there are likely to be dust and other air pollution issues arising from the increased scale of operations. The marsh is a windy area and dust, and other airborne pollutants are likely to spread over a considerable distance on the wind. The prevailing winds are onshore and will carry airborne pollution to residential areas. An air quality monitoring system should be put in place to ensure that there is objective evidence on the emissions.
Conflict between traffic and the footpath
It is proposed to increase the number of vehicles from the present 80 per day (40 in and 40 out) to 160 per day (80 in and 80 out) In peak hours this would amount to 16 vehicles per hour. The hours would be extended in the mornings to 0500 from 0700 but also in the evening from 1800 to 2000 and from 1300-1500 on Saturday afternoons. In addition, Bank Holiday working including potentially on Boxing Day and some Sunday afternoons would be introduced. This means that not only would there be more vehicles at all the times the plant has been working up to now, but the road will be used for much more of the time when the public would want to use it as a footpath. The Traffic Appraisal refers to employees being able to access the works on foot or by cycle although there is no pavement but takes no account of the use of this roadway as a public footpath. Throughout the documents it is assumed that the footpath runs on another parallel line and not on the road but the map extract that they provide shows that this line runs through the water of the lagoon. The roadway is enclosed on the lagoon side by barbed wire fencing with very narrow grass strips in places. There are only three lorry passing places and these are more likely to be needed by passing lorries if there are 16 per hour. The creekside is open with no fencing and a drop onto either mud or water depending on the state of the tide with only approximately 450mm of bank which is sometimes muddy in winter. This means that a substantial increase in vehicles would make a walk along the footpath unpleasant and potentially dangerous. Most vehicles would be skip lorries or rigid vehicles and these tend to have come from sites elsewhere so throw up dust. The trees along this road are already covered in dust and water sprayers also pass up and down to suppress dust on the road but make passage less pleasant for walkers. It is considered that the increase in the intensity of the waste transfer use on the site is not compatible with use of the roadway as a nationally designated public footpath such as the England Coast Path and this is the only route from the Oare Stray stretch of the footpath to the head of Oare Creek.
While the proposal would comply with KCC policies CSW2 (enhances the county’s ability to process waste) and CSW16 (is an extension of an existing waste transfer site) of the Kent Minerals and Waste Local Plan, with regard to policy CSW8, any extra vehicles have to pass through a road which is in an Air Quality Monitoring Area, so the site would not be particularly well-located with regard to sourcing and sending out materials. The advantages of extending the site to take in the activities from Aylesham are outweighed by environmental costs which demonstrate why this would not be a suitable site to extend.
The Society is concerned that this development reverses the whole thrust of planning policy for this area over the last twenty years which has been toward conservation and leisure use. This sets a dangerous precedent for industrial development whilst creating very few new jobs and jeopardising residential quality. We are concerned that there is already some evidence that vehicle movement numbers have been exceeded and obviously all vehicle movements must affect either Ospringe or Teynham and the village of Oare.
Bess Browning of Kent Messenger reported that the referendum on the Faversham Creek Neighbourhood Plan had approved it,
“88% vote in favour of the Faversham Creek Neighbourhood Plan. 5,418 votes cast for yes with just 706 for no.”
Faversham Creek Neighbourhood Plan 42.28%
Faversham Local Elections 42.94%
The Society will remain vigilant and continue to scrutinise planning applications.
Letter sent to
Transport Strategy Team,
Planning and Environment Division,
Kent County Council,
Kent ME14 1XX
We are responding to your invitation to comment on the draft Freight Action Plan. What we want to say doesn’t fit into the questionnaire format so would you please accept this letter as our response.
It is not easy for Counties to control lorry movements using the limited powers available to them within the existing legal framework. The KCC Freight Action Plan makes a fair stab at the problem, drawing together a number of measures that have already been implemented and suggesting a couple of new proposals. But they are not very specific: the document is vague on the details and gives no timescales for implementation. I suggest we confine our response to asking questions rather than questioning the aims or the policy as such.
The Society strongly supports the efforts of the KCC to control undesirable lorry movements together with inappropriate overnight lorry parking. The draft Freight Action Plan mentions several measures that are already in place. However, we would like the draft to be clearer on the new ones so we can comment sensibly on what is being proposed. Our main queries are as follows:
1. What is the total capacity of the proposed new network of lorry parks and how does it measure up against existing facilities? Could the Plan say where they are to be located, and what is the timescale for implementation?
2. The Freight Journey Planner will be useful for operators who don’t know the local road network, especially those based overseas. Could the Freight Action Plan please explain whether there is a strategy for promoting its use among operators and how it will work?
3. The Plan refers to a proposed connected/autonomous vehicle control corridor on the A2/M2 corridor. Could the Report please make clear who is implementing the plan and what is the timescale?
4. Could the Plan prioritise new areas for implementing Lorrywatch schemes?
5. Could the Plan please specify what options are available for Faversham, whose core network of medieval streets is particularly vulnerable to the environmental impact of heavy goods traffic?
We look forward to your reply….
The KCC Freight Action Plan Consultation Draft can be downloaded from the KCC web site at kent.gov.uk/freightactionplan. The Plan aims to reduce the impact of growing road freight traffic on local communities. It has been prepared by KCC staff under the direction of the Cabinet Member for Environment and Transport Matthew Balfour. The deadline for responses is 12 March 2017.
What the Plan proposes
There are five main actions, most of which are already taking place. Paraphrased, they are:
1. Tackling the problem of overnight lorry parking
2. Finding a long-term solution to Operation Stack
3. Confining HGV routeing where possible to the strategic road network
4. Protecting local communities by restricting access
5. Planning and development control of potentially harmful freight-generating land uses.
Overnight lorry parking
A survey in September 2016 showed that around 700 lorries are illegally parked overnight on principal roads in Kent. The greatest concentration occurs in Swale around the Port of Sheerness. Ashford Borough Council already issues warning notices and penalty charges for illegal lorry parking, and may clamp frequent offenders. Highways England is proposing an overnight lorry park with 500 spaces at its Operation Stack site.
The Action Plan says the KCC ‘is developing a strategy’ for a network of small lorry parks with suitable facilities for overnight stops. They will be priced so as not to compete unfairly with existing commercial sites. No numbers are quoted, there are no indications of where the sites might be, and there is no indication of the timescale for completion.
Highways England has created the Operation Stack facility at Stanford West off the M20. It has 3600 spaces. Under extreme conditions this will not be enough and the police will still need to store another 3600 vehicles on the east-bound carriageway of the M20, but the west-bound carriageway will remain clear. In 2015 Dover introduced a smaller scheme on the A20 to protect the Town centre.
The KCC Action Plan supports these initiatives but seems not to propose any further action.
The Department for Transport is promoting the use of new technology that connects vehicles electronically and allows autonomous (‘hands-off’) control.
The KCC Plan says that a scheme for the A2/M2 corridor is being developed, but does not make clear by whom, or by when.
But the KCC has adopted and developed a Freight Journey Planner on-line mapping tool that can be downloaded from freightgateway.co.uk/kent. It is said to feed into lorry satnavs. The map can be configured to show local height, width and weight restrictions, but not parking controls.
In general, there are four ways of deterring lorries from entering sensitive areas unsuitable for heavy vehicles:
– width and height restrictions (on environmental grounds)
– height and weight restrictions (to protect bridges)
– advisory signs (flagging roads that are unsuitable for heavy vehicles – not legally enforceable)
– direction signs (encouraging lorries to use a particular route).
In 2012, KCC launched in collaboration with the police and local communities a Lorrywatch scheme in selected areas. Examples are Smarden, Sandwich and Westerham. Local residents are asked to report instances where lorries violate restrictions to the County’s Freight Officer. Repeated violations can lead to prosecution for UK-based vehicles but not those based overseas. Recently schemes have been added in which the Freight Officer contacts firms whose vehicles have been observed flouting the restrictions, but has no legal powers to enforce them. There is no mention of any scheme, mandatory or otherwise, in Swale.
The Freight Action Plan does not appear to recommend any new schemes under this heading.
A developer can be required by the KCC to produce a Transport Assessment that identifies potentially adverse impacts of freight movements associated with the scheme together with mitigation measures. KCC monitors applications for HGV operator licences and can object.
The Freight Action Plan does not propose any extension to these measures.
The Faversham Society does not support the development of a restaurant in Building 1 of Standard Quay. The Society is disappointed that there is to be further gentrification at Standard Quay and that this important quayside townscape is being developed in the way that it is, the extent of car parking and retail in the areas around these iconic buildings detracts from them. The development of the restaurant will further detract from the conservation area and an important part of Faversham’s maritime heritage is being lost as the quayside becomes a shopping and café/restaurant area. There are also legitimate concerns about the increasing flow of traffic in Abbey Street and a significant flood risk.
The best use for a conserved building is one as close as possible to its original use. A restaurant is far from that. Both the Society’s Planning Committee and the Board have spent time carefully examining the proposal. We have published the outcome of discussions in the Planning Committee (see below). The Board considered the Planning Committee’s analysis and with regret decided not to object to the planning application. Whilst we see no grounds for rejecting the planning application on planning grounds, and do not wish to see the Council required to pay further compensation to the developer, this does not mean that we support the application.
The Planning Inspector’s Decision in January 2014 rejected Swale’s case except on heritage conservation grounds. He pointed out that the “workmanship and utilitarian nature of the building envelope exemplified by the rough and ready quality of its finishes and internal spaces, all contribute to its special architectural interest and to its historic character as part of the wharf.” The Inspector further pointed to the importance of the building’s “form and finishes …which evokes the long history of the quay..”
The Inspector expressed concern that in order to turn the building into a restaurant, the overall nature of the building would change and that “the overall nature of the building and of the conservation area would be significantly damaged.” The Swale Conservation Officer has secured detailed specifications, in the Heritage Statement, on the internal form and finishing and the Board consequently saw no grounds for rejecting the application. The focus now shifts to compliance with the conditions placed on the planning permission.
The Society has invited Swale Planners and Enforcement Officers to a members’ evening in the Fleur Hall on February 16th at 19:30. We shall be discussing the Council’s approach to planning compliance and enforcement and we shall be pressing the Council to ensure that all the details so carefully defined in the application will be enforced. In our view conditions should be attached to the decision – if the decision is to allow the application – and those conditions should be detailed, robust and enforced.
The Society will object where we can identify planning grounds, once the planning permission passes the issue is compliance. This may be an example where planning has secured good design – the proof will be in the degree of compliance. If the restaurant were to fail there may well be an application for change of use or further gentrification. The Society will remain vigilant.
The Planning Committee’s report accepted by the Board can be found here
 Para 8
 Para 10
Two matters are central to our response:
First, the implications of new housing allocations on matters that were already of concern to the Society when we responded previously in August 2016; those concerns are further exacerbated by the new allocations.
Second, the pace of recent and current change in Faversham, which means that new information is now available to augment the Faversham Society’s previous submission. For example, the decision of Swale BC’s Joint Transportation Board to implement innovative measures in the form of a 20mph default speed limit across Faversham and the wider Borough is, we believe, highly relevant. In a similar vein, the Faversham Society’s proposal for a Faversham Neighbourhood Plan, with associated transport strategy and conservation area appraisals, is an example of robust and locally meaningful infrastructure planning that the modified Plan is currently missing.
You can read our full response here
The Board has discussed in detail the latest version of Swale Borough Council’s Development Plan. The Society has expressed it concern about the impact of the increased housing allocations on traffic and the historic fabric of Faversham.
The Society’s submission is available here Faversham Society Evidence on Bearing Fruits
We believe that the two buildings are late 19th century and have in the past been used as shelter for bridge workers and users, storing tools, etc. They do not include any operating machinery. We understand there is no intention to demolish the larger white rendered building on the NE side of the road, which houses the control mechanism.
Although the bridge structure and associated buildings can be considered to make a positive contribution to the conservation area, it is inevitable that there will have to be changes to accommodate a new bridge, and these two buildings are not major features. They are not listed, nor are they mentioned in the Faversham Conservation Area Character Appraisal (2004) or in the Undesignated Heritage Assets paper (co-authored by Anne Salmon) which was submitted as part of the evidence base for the Faversham Creek Neighbourhood Plan. They are not mentioned by Arthur Percival in his History of Faversham Creek. While they have some intrinsic value for their historical and architectural relationship with the bridge, their loss would, in our view, cause less than substantial harm and this would be outweighed by the very significant public benefit of a new bridge.
The Faversham Society therefore considers that, on the basis of the evidence available, there are no compelling reasons to object on conservation grounds to the removal of these two buildings, provided that a full record of their ‘standing archaeology’ is made before and during demolition, and this record is made publicly available.
We look forward to seeing the proposed bridge design, and may have further comments at that stage.