C.P.R.E
These are the submissions of CPRE to date regarding China Gateway. Updates will be posted as time goes on.
CPRE Kent
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
9th May 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
On behalf of CPRE Kent I write to register objection to the above-mentioned
planning application.
CPRE Kent acknowledges that the application is for land allocated for employment
development in the adopted 2006 Thanet Local Plan under Policy EC1, and we
acknowledge the importance of the site for employment development in the District.
However, the application is being promoted as phase 1 of a significantly larger
development that has no status in the development plan, and we consider that
an approval of the application on this basis would pre-empt the proper consideration
of the additional land proposed through the statutory development plan process.
Chapter 4 (Planning Policy Context) of the Environmental Statement seeks to
make the case for providing additional employment land in Thanet. This though
is first and foremost an argument that must be made through the Local Development
Framework (LDF) process rather than through a planning application. It is
entirely inappropriate for the Council to support phases 2 and 3 of this development
on the back of this application. It should also not be overlooked that Thanet
already has a generous existing employment land supply of 288,766 sq.m, which
more than adequately covers the Local Plan period to 2011. Indeed, it meets
95% of the Kent and Medway Structure Plan requirement to 2021. The need to
identify further employment land, therefore, is a matter for the review of
the Local Plan through the LDF process, which the Council is already progressing
and will be consulting on shortly. This process should not be pre-empted now
by approving this application, as it will be necessary for the Council to
consider all appropriate options for accommodating future employment needs,
and to consult on them.
All the supporting information is presented in the context of the much larger
scheme, with Chapter 11 of the Design and Access Statement (DAS) clearly stating
that development will be delivered in 3 phases. As a consequence it is extremely
unclear as to whether the phase 1 land, comprising the allocated land, could
viably be developed as a standalone development as proposed in the Local Plan,
which is the proposition that the Council must consider.
Whilst Chapter 11 of the DAS states that funding is in place for immediate
commencement of phase 1 once permission is granted, there is no suggestion
in the supporting information that this would be the case without phases 2
and 3. The applicant is clearly looking to the Council to consider this application
in the context of the larger scheme, and it is on this basis that the commitment
to implementation and delivery must be seen. Approval of the application as
presented, therefore, would inevitably mean the Council would be giving at
least implicit support for phases 2 and 3. This, in our view, would be totally
unacceptable and undermine the forthcoming consultations on the Council's
LDF documents. In effect, the Council would be going into the LDF process
with a closed mind contrary to at least the spirit, if not the legal requirements,
of the statutory development plan process.
Furthermore, because the supporting information is presented for the larger
site, we have found it impossible to disentangle relevant information to enable
the phase 1 land to be considered independently to the larger site. We consider
that the Council will similarly be unable to assess what the impacts of phase
1 alone would be if it were permitted to proceed on its own in accordance
with the Local Plan. Consequently, we consider that the Council is not in
a position to approve the application in the context of the Local Plan allocation,
i.e. as a standalone and self contained development.
The inclusion of phases 2 and 3, in addition to the allocated site, makes
the proposition entirely different to that currently proposed in the Local
Plan. It raises some very serious planning issues of principle that demand
proper justification and examination through the development plan process.
We would, therefore, strongly urge the Council to refuse planning permission
for phase 1 as proposed, and if the Council considers that a larger scheme
is necessary to deliver its economic objectives this should be pursued as
a single proposition through the LDF process. This would avoid the piecemeal
and backdoor approach currently being advocated and give third parties the
proper opportunity to comment on the scheme as a whole. The Council and the
developer might see this as delaying the delivery of much needed new employment,
but there is no indication that the developer will proceed on the basis of
permission for phase 1 alone without a commitment from the Council to phases
2 and 3. This commitment can only be properly given through the development
plan process, so it is unlikely that development will proceed before the LDF
is progressed in any event.
In addition, we would raise the following concerns with the application and
the proposals for phase 1:
The application describes the proposal as the “redevelopment of land”,
whilst some of the supporting documentation refers to the phase 1 land as
brownfield (for example see para. 3.1 of Chapter 3 of the Environmental Statement).
This is clearly a misleading and wrong description of the land involved, as
it is obviously largely, if not entirely, greenfield land. Notwithstanding
the fact that it is allocated for development in the Local Plan, this greenfield
status must be properly acknowledged. Phases 2 and 3 will similarly involve
greenfield land, very likely high grade agricultural land, and the future
loss of this land is an important implication if phase 1 is approved.
The Local Plan indicates that the outstanding commitment at Manston Park is
for 121,789 sq.m of employment land. The application for phase 1, however,
is for 137,664 sq.m, though it does not include all the land remaining available
within the allocated area. This suggests that the proposal for phase 1 is
at a higher density than envisaged by the Council. This higher density, we
believe, is an over development of the site with the consequence being some
very large buildings, which will be very visible in the landscape. This is
a point that I return to later.
It is clear from the Local Plan that it is the Council's objective to diversify
the local economy, and PRC's covering letter to the planning application seems
to respond to this objective by explaining that the site will be developed
for “high-tech manufacturing purposes”. It is clear, though, from
the application form and the supporting information that the precise uses
for the site are far from certain. This is particularly clear from Chapter
12 of the Environmental Statement, which deals with transport issues. Such
is the uncertainty as to what the specific mix of uses will be that the transport
assessment is forced to consider two vastly different development scenarios,
within which completely different patterns, types and distributions of traffic
are considered.
This uncertainty is worrying given that the applicant states that this is
not a speculative development (para. 4.126 of Chapter 4 of the Environmental
Statement). If the development is not speculative, the developer must know
what the development will comprise and who the users will be. However, this
does not seem to be the case and as a consequence there is considerable doubt
over the mix of uses, and the emphasis of the development. Therefore there
can be no certainty that it will deliver the Council's objective of diversifying
the local economy. There would seem to be a very real danger that the focus
will be on storage and distribution uses rather than the high-tech manufacturing
promised by the applicant. It is our view that the Council must be assured
by the applicant that the site will deliver in accordance with the Council's
economic objectives, but the supporting information does not give this assurance.
Given the very great uncertainty about the uses that are likely to be accommodated,
we consider that the transport impacts of the development on the local roads
are far from clear. Two development scenarios are presented and assessed,
but in reality this is just two of an infinite number of scenarios.
In particular we question the reliance placed on the travel plan as the solution
to potential problems that are predicted to arise at certain junctions. Whilst
we fully support travel plans and the encouragement of non-car modes of transport,
the isolated location of this site inevitably means that it will be entirely
dependent upon car based journeys. A travel plan that seeks to achieve a 20%
modal shift to non-car modes plus 20% car sharing is extremely ambitious.
Such reliance on an ambitious travel plan as the solution to predicted traffic
problems caused by the development must be seen as being of great concern
and a significant risk.
Within the development proposal a range of buildings are proposed, which are
described as being single or two storey. Some of the buildings, though, are
very tall and bulky. For example in phase 1 the units marked `A' will be upto
16.975m high whilst those marked `X' will be upto 12.775m high. Additionally,
the landmark `Gateway' building is 14.5 m high. These are all very imposing
buildings, and will be clearly visible in the landscape from a distance.
The site falls within the Central Chalk Plateau Landscape Character Area as
defined in the Local Plan. Policy CC2 of the Local Plan, which relates to
this area, specifically states that “particular care should be taken
to avoid skyline intrusion and the loss or interruption of long views of the
coast and the sea”. We note that the applicant proposes that landscaping
in the form of bunds, native hedgerow, trees and low lying grass will be provided
to soften the bulk and the mass of the buildings. However, we consider that
it will be impossible to avoid the skyline intrusion that is the concern of
Policy CC2 given the bulk and the height of the buildings proposed. This is
clearly evidenced in the computer generated views of the site provided by
the applicant. These clearly show that the landscaping, even when mature,
will not hide the bulk of the buildings, and demonstrate in particular that
the Gateway building will be very prominent on the skyline.
Paragraph 5.20 of Chapter 5 (Landscape and Visual Impact) of the Environmental
Statement explains that “a sensitive approach to the scheme design needs
to be taken into consideration due to the surrounding land designations”
(i.e. the Landscape Character Area). However, we are told in Chapter 3 (Proposed
Development and Alternatives) of the Environmental Statement that the Gateway
building will be a principal feature of the development, and that it is “a
standard inclusion within future Chinamex developments worldwide” (para.
3.4). This standard inclusion is hardly sensitive to the particular surrounding
circumstances here. Furthermore, paragraph 3.6 of Chapter 3 explains that
the industrial units “will all be standard rectangular shape units varying
in size and height”. Again, this is hardly sensitive to the site's location
on a plateau that commands long views. We would submit that the standard design
approach proposed fails to respond to the sensitivity of the site in the surrounding
landscape, and will make it particularly visible in long distance views. This
we feel makes the proposal contrary to policies CC2 and D1 of the Local Plan.
Finally, we would raise issues with regard to hydrology, and the site's location
within a groundwater protection zone. Chapter 10 (Hydrology) of the Environmental
Statement clearly acknowledges that the development has the potential to impact
on the water resource features within the area (para. 10.5). Mitigation measure
are proposed, and we leave it to others more qualified than ourselves to comment
on the technical aspects of this, but it is difficult to distinguish from
the assessment what specifically is proposed to mitigate phase 1 as opposed
to the larger development proposals. The situation is complicated further
by the fact that the mix of development, and therefore the potential impact
on water resources, is unknown. Again we consider that the Council is not
in a position to judge what the potential impacts of phase 1 on this crucially
important resource will be, as distinct from the larger scheme.
It is clear from the submitted Environmental Statement that the development
will have impacts for both phase 1 and the subsequent phases. It is openly
acknowledged by the applicant that there will be impacts on ecology, archaeology,
ground water, ground soil conditions and the highway network, and that there
will be implications for noise, lighting, drainage, air quality and vibration
(paras 3.30, 3.31, 3.35, 3.36, 3.40 & 3.41 of Chapter 3 of the Environmental
Statement). These are serious admissions. Although the developer submits that
these inevitable impacts and implications are minimal or can be mitigated,
it is difficult to draw firm conclusions on the impacts for the allocated
site, the subject of the planning application, as distinct from the larger
site. The impacts will inevitably be different, as will the mitigation required.
Crucially, is the provision of the mitigation measures necessary for the allocated
site dependent upon phases 2 and 3?
The difficulty for the Council is that it must determine the application in
accordance with the prevailing statutory development plan, and this does not
propose the larger scheme. The Council, therefore, needs to satisfy itself
that the allocated site can be delivered, with appropriate mitigation, as
proposed in the Local Plan. We do not consider that the Council has the appropriate
information provided by the applicant to reach a positive conclusion in this
regard. The applicant is proposing the site as a first phase of a larger development.
If it is this larger site that makes the development viable then, in our view,
the Council has no choice but to refuse planning permission. Any commitment
to a larger development site must be a matter for the LDF, not by sanctioning
phase 1 of a scheme that has not been independently assessed and examined
and subject to the proper consultation and considerations that would be expected
for such a major development.
We would strongly urge the Council, therefore, to refuse planning permission.
Yours sincerely
Brian Lloyd
Senior Planner
CPRE Kent
CPRE Kent
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
WHY THIS ENVIRONMENTAL CHARITY NEEDS YOU
The CPRE is anxious to recruit more members. Kent needs the Campaign to Protect Rural England (CPRE), and CPRE Kent needs YOU. With representation from district to national level, we promote sustainable development and preservation of our natural environment. CPRE Kent, with more than 3000 members and supporters, is England's strongest branch of the charity. By becoming an active member of CPRE Kent, you can help to limit the damage of the tidal wave of development which threatens Kent.
FOR MORE INFORMATION: call 01303 815180, e-mail ....
info@cprekent.org.uk or visit www.cprekent.org.uk.