With over 300 documents on the planning site, it would take even the most dedicated of locals to read them all. We have been through quite a few and have selected some highlights that may be of interest.
The comments are selective and try to reflect a wide variety of thoughts and ideas. Many people wrote in outlining the objections that were on the leaflet and reproduced elsewhere on this site.
We start with comments supporting the proposal
And now those who are against….
COMMENTS HIGHLIGHTS
Dogs dinner
The flaws in this proposal were very obvious from the beginning and the City Council has had four years to sort out and seek a sufficiently competent and informed masterplan. I would like to know why the Council appears to have stuck its head in the sand all this time and done nothing to sort it out so we are faced with this dogs dinner coming back to Planning Committee. (AD, Public Comment)
A 2013 Plan for a 2021 reality?
In the current pandemic the whole question of the need for a Sturry Relief Road and its supporting development is an interesting one.
Looking to the future:
- Commuting will be less common with more people working from home.
- Home deliveries of everything will continue.
- Traffic volume and journey patterns will be different.
- The High Street experience will not be the same with many retail jobs lost.
- CCC’s car parking charges will continue to rise making a visit to town even less attractive.
- International visitors (tourists and students) will not be as numerous, particularly when Brexit is added into the equation.
- The National Economy will be vulnerable for decades due to recent spending to mitigate the effects of Covid 19.
- Budgets will be constrained for the City, the County, companies and individuals.
- Measures to combat climate change will become even more significant.
- A perceived need for a new road in 2013 to take even more traffic was one thing. The idea of funding it through a housing development, which would also have to find various 106 Contributions, as well as raise a level of profit acceptable to developers, looked a simple answer to a lack of public money for road construction.
In the intervening years it has became apparent that linking the major infrastructure with development on this site is not an easy proposition.
The flaws in this 2021 proposal of compromise would result in long term and unacceptable issues for the community.
As it stands, despite its best efforts, this application should be refused. (JG, Public Comment)
LINK/RELIEF ROAD
The reason for this rushed reworking of the application is that CCC is in a desperate rush to obtain the funding that would be contributed by the SELEP (South East Local Enterprise Partnership) fund to the tune of £5.5million as a recent extension to the period allowed for consideration of this grant will expire in March 2021. This is not a reason to rush through this flawed application, creating a badly designed environment for new residents with insufficient open space and a divided, much worsened village for existing inhabitants of Sturry.
Not only does the promotion of the variously named “relief road”, ” distributor road” and “link road” ( indicative of the confused nature of this major ‘A’ road being run through a new estate) put car use above any other mode of transport, it even makes reference to how difficult it will be to cross this road. The most recent information makes reference to 22,00 vehicular movements over the rail crossing, the intention being to divert all this traffic through the new estate. In addition, extra traffic now expected to emanate from the new developments at Herne, Hersden, Hillsborough and other small sites in the area will add up to many more vehicles than this passing through a residential area, contrary to all current advice with regard to roads and proximity to housing. (RA, Public Comment)
Two plans, no governance?
Refusal Reason 2
LOCAL PLAN Policies cited. DBE 3 especially (e) (h) (j) (k) DBE4 ,DBE8 especially (b) (c) , T1 especially (a), T2.
REL 1 The two parts of the Sturry Relief Road are co-dependent and yet they are the subject of two applications, the first which is a hybrid application for the housing in outline and the major part of the Relief Road in detail. The second, submitted by the KCC, which seems to have been temporarily postponed, was for the viaduct and approach roads at the western end, together with the intended changes to the area of the A28 & A291 at the eastern end.
As the application puts it, the relief road is “fully designed” and the Head of Planning, Simon Thomas, reminded members at the Planning Committee in November, for Application CA/17/01383, that although the housing layout on the “Masterplan” is only indicative, every aspect of the relief road layout is fixed.
We suggest that to ask for two separate consents was irrational, as each is not deliverable or meaningful without the other.
Objections to the current application, numbered CA/20/02826 which rely on observations on the KCC one, could be held to be not appropriate. However, we believe that as the CA/20/0286 application if approved, would somehow presume approval of the second, that comments on it are highly relevant. It is a problem for local people to understand that two responsible local authorities could have generated such a confused submission, after ten years of preparation. Objections were and are, being made to the former relying on aspects on the latter .Indeed, to make it worse, they have had about five years longer than was planned because of delays that have occurred subsequently. (Council For Protection of Rural England)
300% More Traffic and a threat to the Co-op
REL6 In the case of Sturry, the need to link up Island Road ( A 28) to any relief road, has been proposed by turning the A 28 at the level crossing location, up the existing hill of the A291 and thence by roads on the allocated site to an onward new relief road provision. This, on the admission of the application, increases the traffic volume on this southern section of Sturry Hill by “200 to 300%”. It is a residential road and about 25 homes on the west side will suffer a great loss of amenity. This number includes Sturry Court which is sheltered accommodation for older people, mainly well over 80 years of age who, we feel would be most severely affected by increased traffic and poor air quality.
This section of the road, as has been pointed out by many local people, has no footway on its east side and has a width not commensurate with the increased traffic levels. The 12 houses on the east side have drives from which users reverse out leading to greater danger of accidents and will also suffer loss of amenity as well .The abrupt turn at the bottom, with all the inherent traffic movements and the uphill gradient which exceeds the standard 1: 12.5 used for the new parts of the relief road, will confuse and slow traffic, causing additional noise and pollution.
Just to the east of the southern end of Sturry Hill is the Co-operitive Stores which serves the village and passing traffic. Access and egress from this valuable village resource would be worsened by the altered junction and the lack of ability to leave the store and travel through Sturry village. If it suffered loss of trade, it could face the threat of closure, which would be a great loss to the village.
…The number of houses in Sturry Village which would benefit from the Relief Road by losing the negative impacts of heavy traffic is 62. This must be the only by- pass where the result of building it is that 149 more properties suffer detrimental effects than is currently the case… (CPRE)
Lead Pollution
Various reports have been submitted dating from 2017 – 2019. Each report details heavy lead contamination plus some other heavy metal contamination which will need to be remediated to a level which will not have an effect on the end users of the site.
The outline remediation strategy submitted in 2017 recommends the requirement for additional site investigations and the submission of a detailed remediation strategy for the site to enable all of the contamination on site to be dealt with in line the requirements of the Contaminated Land (England) (Amendment) Regulations 2012. (Env Health)
Closing a footpath
Network Rail also welcome the stopping up of PRoW CB60 & CB61 which will allow for the closure of Milner Court footpath level crossing.
Strain on Broad Oak road crossing
Network Rail would like to take this opportunity to highlight that the Broad Oak AHB (Automatic Half Barrier) Level Crossing is at full capacity in terms of the amount of vehicular crossings. Network Rail are keen to work with Canterbury City Council to explore funding options to upgrade the Broad Oak level crossing to a Manually Controlled type crossing to mitigate the additional risk posed by the cumulative impact of new developments across the area. (Network Rail)
Air pollution
Canterbury City Council Air Quality Action Plan states the following policy;
Because of their potential impacts on human health, welfare and the natural environment, ambient concentrations for a number of these pollutants are measured continuously at a wide range of rural and urban locations throughout the UK.
What Canterbury City Council has done in response to Air Quality monitoring and reducing traffic in the surrounding area. NOTHING
CCC 2018 air quality response excluded the measurement of PM2.5 which is the particles that penetrate the brain, and will cause babies to be born with unformed lungs. This means the data the developers have submitted as part of their mitigation is not viable.
The application refers to Air Quality 2007 rather than 2008/50/EC policy made law in 2010
….
On a local level Green Party member Henry Stanton said: “This plan is simply not fit for purpose as the council deliberately chooses not to monitor the deadliest form of air pollution, PM 2.5 particulate matter – simply because it’s not required to. This suggests the council doesn’t even understand the nature of the problem.
He said: “The council has ducked this issue for too long- granting planning permission after planning permission that adds traffic to local roads and even pushing for a multi- storey car park that will attract cars into one of the most polluted areas of the city.”
He said: “It’s great that primary schools have been involved in this plan, but citing their exhibition in the Beaney as an example of how the council is dealing with an air pollution problem that takes 750 years of life from our residents every year illustrates the paucity of imagination and complete lack of interest in taking this problem seriously.”
(PB, Public Comment)
Giving proper weight to Green House Gas emissions
The Appeal Court decision about considering climate change in making planning decisions, means that proper weight must be given to Green House Gas emissions (GHG).
(SEE: https://www.bailii.org/ew/cases/EWCA/Civ/2021/43 .html)
For this Application, the highly significant generation of GHG from the proposals both from its construction and from the subsequent use and maintenance of the site, as well as from occupants and users of this site, means that the present Application cannot be approved, because the Applicant has not designed it to minimise GHG emissions.
So approval, without stringent Conditions to actually minimise GHG emissions, such as by specifying fully Certified Passive House construction, would be a ground for legal challenge. (CL, Public Comment)
Safe community
…..why nobody take in consideration the police review regarding this new building idea? Where there the report is saying black on white that the development/ construction is not supporting the community on the contrary will increase the theft, robbery and other crimes. That from my point of citizen this needs to be an alarm for the council. We don’t have enough Sturry Road, and everything what is happening there? We need to increase the risk? (DA, Public Comment)
Suds and floods
Reading through the proposed surface water management strategy it is understood that a SUDs scheme comprising mainly of ponds, with surface water discharge rates mimicking predeveloped ‘greenfield’ rates. However it is noted that only a 20% increase of peak rainfall intensity due to climate change has been used, rather that the 40% value that is more commonly adopted in accordance with current guidance. Is it not also common for climate change factors to be applied to the 1 in 1 and 1 in 30year events? It is also queried, without infiltration on site due to the unsuitable underling ground conditions, how is it proposed to control the run-off volume? It is noted that the report states that there is sufficient space in the development for the storage of surface water runoff, however using the ‘Upper End’ climate change allowance additional storage area will be necessary. Furthermore, it appears that some SUDs ponds have been included within or at least very near to the ancient woodland buffer zone which goes against government guidelines. I assume KCC as the LLFA will be reviewing in detail?
It is also understood that the revised scheme has diverted some catchments away from the existing ditches adjacent to the railway which are habitat to the Desmoulins wharf snail. It is unclear what the revised proposals consist of but it is considered to be unrealistic that ‘No other roads within the Proposed Development will be subject to winter maintenance programmes involving road salt’, when it is readily available to any member of the public to buy and spread during the winter season. (CH, Public Comment)
Noise and pollution
The proposal does not comply with the Canterbury Local Plan (2017), and ignores government guidelines
Policy DBE3 Principles of Design
The distinctive character, diversity and quality of the Canterbury District will be promoted, protected and enhanced through high quality, sustainable inclusive design, which reinforces and positively contributes to its local context creating attractive, inspiring and safe places.
Proposals for the development, which are of a high quality design, will be granted planning permission having regard to other plan policies and the following considerations:
i. The impact of polluting elements, such as noise, dust, odour, light, vibration and air pollution from the development or neighbouring uses;
Policy QL12 (noise and pollution policy)
Policy QL11
10.16 The visual impact of built development or uses and any associated noise and light pollution can have a significant impact on the enjoyment of the tranquillity of our countryside, as well as its character. Policy LB4 includes tranquillity as one of the aspects of the landscapes in the District that should be protected and enhanced.
Currently the proposed site offers an area of tranquillity between the main built up area of Canterbury and the traditional village settlements of Sturry and nearby Broad Oak.
…
- Planning controls
- 6.8 Consideration should be given to managing noise through the operation of the national and local transport and land use planning systems. Techniques used include traffic management schemes, such as the re-routing of traffic away from sensitive receptors, restrictions on the type of traffic (e.g. heavy vehicles) that can use certain roads at certain times of day, the design and building of new roads to provide an alternative route away from noise sensitive premises, and the introduction of speed restrictions directly or as a consequence of congestion management schemes. There may also be opportunities to reduce road noise using Local Transport Plans.
It appears that in this instance the developers have totally ignored these government guideline and have positioned housing directly around the traffic, thus ensuring that sensitive receptors of noise will be greatly affected, rather than protected from noise.
(DW, public comment)
Inadequate Buffer for the protection of the woodland
The applicants for both sites plan to use a 15metre buffer, this is inadequate for the Ancient Woodland. It is the minimum width advised by Natural England.
Standing Advice from Natural England relating to an Ancient Woodland:
‘Buffer zones should be at least 15 metres’.
‘When assessment shows other impacts are likely to extend beyond this distance you’re likely to need a larger buffer zone for example: The effect of air pollution from development that results in a significant increase in traffic’.
The 15metre buffer used by the applicants is to be one of three materials; Thorny (native) shrubs, logpiles and dead hedge.
Apart from the inadequate width of the 15metre buffer a question arises: How are the inpenetrable thorny shrubs going to be maintained and managed and cleared of litter if their role is to prevent access?
The 6metre X 1.5metre high log piles mentioned in the Environmental Statement would make ideal play structures for those children who have not been provided with sufficient play areas within this application. Logs rolling off of the pile could cause injury.
The use of dead hedge as a buffer material in a residential setting is a major fire hazard. Although dead hedging is used in rural settings it would not be suitable here.
The close proximity of the Ancient Woodland 15metre buffer to built development could result in the buffer also being used for residents to dump garden rubbish and fly tipping.
Advice from the Woodland Trust for application CA/17/01383 (document 8th May 2019) pointed out that a more substantial width of buffer was needed. I would like their advice to be noted since it is still appropriate to this application since so little has changed.
‘For the scale of development proposed as part of this application, the Trust would recommend a buffer zone of at least 50metres to avoid root damage and to allow for the effect of pollution from the development’.
Destruction of woodland
The Environmental Statement states;
7.130. During construction there will be permanent irreversible adverse impacts on Ancient Woodland.
7.131. 2.5ha of the approx 5.5ha non ancient woodland will be removed this equates to 47% of the non ancient woodland. This direct loss is predicted to result in permanent adverse impacts.
7.128. 0.01ha/0.06% of the Ancient Woodland will be removed to enable two local incursions into the Ancient Woodland to accommodate a proposed footpath/cycle link connecting adjacent land.
The non ancient woodland provides connectivity for the species living in the area and Kemberland Wood to the NE, this is a very large amount, almost half, which will be removed. The Ancient Woodland is a priority habitat and removal and loss of almost half of the adjacent non ancient woodland will have a detrimental impact. (HS, Public comment)
Wild life
A short walk undertaken beyond the target field will reveal as many as 30 species of birds, many all ready threatened with extinction, competing for nesting sites. Large numbers of hawks and vicious predators are gleaning the rewards of the species compression further endangering loss.
This area is a migratory gathering point for Swallows, House Martins, Swifts, Fieldfares, Skylarks and Redwings. An increase of human occupation will have a devastating impact on these annual events. Already there is a decline in Yellowhammers, Grasshopper Warblers, Tree Pippets, Barn Owls and Wrynecks.
There are many arterial reasons why development should stop which must include the demand for the supply of fresh water. (PM, Public Comment)
Flood Plain
…..One of the other main concerns is the wildlife and the local environment. The ancient woodlands should remain just that, ancient, for future generations. Open woodland space is known to benefit people’s health and well-being as well as being a home for wildlife which is being destroyed. The woods on Broad Oak hill are now a race track for motor cross bikes, so no animals can live there. Trees take hundreds of years to grow and taken down in a matter of minutes, we should be planting them not cutting them down. Destroying wildlfe habitat is so wrong, it’s not our right to destroy it just because we can.
With increasingly wet winters Broad Oak Hill is running with streams of water after it has rained and the same amount must also run down from the woods to the bottom of the hill where the proposed site is. At the moment this is absorbed by the fields, but dread to think what it would be like if it was all concrete. There are many underground springs that run down from the top of the hill to the flood plain area at the bottom, as is the case at the present time with the field just past the Broad Oak crossing being flooded, which is what it is for.
All in all, the plan is wrong on every level and I object to it in the strongest possible terms. (JT, Public Comment)
Noise
I support all the objections that have been raised, but would like to highlight the plight of residents in 37 properties at Sturry Court Mews, a retirement complex , who if the planning application was approved would endure years of noise and disruption. (SB, Public Comment)
Sturry Hill
The Sturry Link Road and routing of traffic from Thanet along the A28 up Sturry Hill will add to the congestion, air and noise pollution on Sturry Hill. The Environmental Statement Land at Sturry Volume 3 Appendices shows predicted traffic flows for the local road network and on Sturry Hill for 2031. With the development and Sturry Link Road 31,737 vehicle movements are forecast and without the development and Sturry Link Road 9,705 vehicle movements are forecast, representing an increase of 227%. (NF, Public Comment)
People with mobility problems…
… However, in the latest submission ES 13.1 at 4.3.81 vi, it is stated by the applicant that “Pedestrian groups such as those with mobility impairment, the elderly or the young may have difficulty crossing the (Relief) road given the amount of traffic expected.” They then claim that the one “signal controlled (Puffin) crossing has therefore been proposed, staggered to two stages” . This will result in those groups who make up about 30% of the population having to walk up to 600 metres on the west side and 300 metres on the north east to access this crossing. If they wish to return to their starting point those distances would be 1.2KM and 600 metres respectively. The applicant is assuming that only the “safe “ categories of pedestrian not in those categories will be able to use the nearer, but less safe,” uncontrolled crossings”. In practice all pedestrians, irrespective of age or mobility will be tempted to use the uncontrolled crossings. It is noted that there are bus stops away from the Puffin crossing which will emphasise this problem. The risk to safety thus arising has not been identified. (CPRE)
Traffic Congestion
This is already a serious issue in Sturry and already has a detrimental effect on air quality due to the amount of exhaust fumes emitted from standing traffic, particular at the level crossing. The increased traffic during construction and later caused by the increased population would only exacerbate this problem with potential damage to health, cf the recent court case in London regarding the death of a 9 year old girl.
Flooding
The Environment Agency should be consulted and their findings taken into consideration regarding the potential runoff from the buildings and the increase in waste water would have in exacerbating the potential for serious flooding in Sturry village and Fordwich. Only in recent days has there been a flood alert along the river Stour with gardens in Fordwich Road being under water. The area around the barn at Junior Kings School frequently floods and could pose a danger to the children who are as young as 3. The development would only make matters worse. (RR, Public Comment)
As before…
I am objecting to the current plan for ALL the reasons the previous plan was rejected earlier at 10 votes to 3 .
As government funding and other funding will be less feasible this expense would be even more problematic. I am aware that this proposed project would provide no affordable housing, which is required of new developments. (SF, Public Comment)
Unsustainable
The number of houses does not give an adequate reflection of the number of vehicles being introduced to the area, as each home could have multiple vehicles. This area is already a funnel for drivers approaching Canterbury from outlying areas, so increasing the amount of road users would be entirely unsustainable. Adding in access over a flood plain solves nothing, as we see from the land that is currently underwater in Fordwich.
Any additional building in this area, whether Sturry, Broadoak or Fordwich would also be disastrous for the sewage system, local amenities, healthcare and open spaces for exercise and recreation. The number of houses planned would benefit no one but the builders, due to the density and number of the houses planned. It would be a claustrophobic site and who would want to buy a house with a sewage tank nearby that is emptied by road? I also question what access for the emergency services would be like, if they needed to bring multiple vehicles into the area – ambulances and fire engines are huge and would not be able to negotiate narrow road systems quickly when there was an emergency.
We have already seen these areas pushed to their limits with additional people coming to walk here during lockdown. It is entirely unfeasible to reduce the green spaces and put more pressure on a small area. The cycle path in Fordwich has already been damaged by increased use during lockdown – if other green areas are built on, that will increase the use even more on paths that are being eroded. It is also detrimental to the environment at a time when this should be a priority to the council. (AW-S, Public Comment)
Foul water
As someone with asthma and a condition which affects my breathing, I am also concerned about the rise in pollution that this proposal will entail. Building on the green field site will damage the environment and increase run-off in heavy rain into drains and onto the flood meadows increasing the risk of flooding of foul water in the development and low-lying parts of Sturry and Fordwich. (KW-S, Public Comment)
Indefensible…
The failure to provide any affordable housing whatsoever in a dense development of 630 dwellings is contrary to government guidelines. The Local Plan requires there to be 30% affordable housing. To grant planning permission for a development with zero affordable homes would be indefensible and totally inappropriate. (MT, Public Comment)
Ella’s Law
….4) Simply changing the last proposal by reducing the total number of houses by 20 and adding a *tiny* bit more green space shows how little the developers care and will continue to do the bare minimum.
5) Water pressure in the area is very weak and by adding this many houses it simply will not cope. Even with the plans they put in place it will not be enough as the area simply cannot handle it.
6) Many of the proposed houses will be built on flood land – every year we see flooding in the winter of houses build on low laying land.
7) The pollution levels will be too high and therefore Ella’s law will be broken. Enough said.
8) There is no mention of a doctor surgery being built to support all the new people moving to the area.
This makes their plan contrary to policy QL8 of the Canterbury District Local Plan 2017.
9) The plan is far too dense. It is contrary to policy DBE3 of the Canterbury City Council Local Plan 2017.
10) Kent Police have commented stating that they “Cannot recommend approval for this application (Illustrative Master Plan 22600A-150M) as shown on the planning portal at 12.01.2021. We have some significant concerns…”
11) The developer’s proposal is to put a huge sewage tank in to serve the new housing – this will be emptied by road and at the owner’s expense – this shows the developer is seriously clutching at straws to meet the ‘requirements’. Disgusting.
12) WE DON’T WANT THIS! (KM, Public Comment)
Gridlock
Currently the surrounding roads are very busy at peak times. Allowing this development would increase the traffic and cause grid lock. You only have to see what happens every time you have road works on Island Road, Herne Bay Road or Shalloak Road. The three road that access the City turn to grid lock. Sturry Train station/Co Op road junction can’t handle increased traffic currently especially when the level crossing is down. ….The local water pressure is already low and would not cope with another 600 odd dwellings …(LLW, Public Comment)
Misleading
Dengrove Wood is an ancient woodland and as such an irreplaceable habitat. Ancient woodland is protected not only by NPPF but also Canterbury’s own Local Plan, the Preliminary Arboricultural Impact Assessment (3841_RP_002_Rev E) highlights a total loss of approx. 4.57ha of tree/woodland and hedge loss including recognised ancient woodland parcels. The Ecological effects on ancient woodland have been assessed to be likely significant and slight adverse.
Current government guidance states that ‘For ancient woodlands, you should have a buffer zone of at least 15 metres to avoid root damage. Where assessment shows other impacts are likely to extend beyond this distance, you’re likely to need a larger buffer zone. For example, the effect of air pollution from development that results in a significant increase in traffic.’ The introduction of a link road into an area of woodland and agriculture would results in a significant increase in traffic… not only from the through traffic but the likely 1000+ cars from a 630 unit housing scheme, which would further increase if further development occurs at Broad Oak.
Please note that it also appears that footpaths are included in the buffer zone, which should not be allowed if the habitat is harmed by trampling, if this development Is permitted this woodland would go from infrequently light usage through PROWs to daily use by hundreds of residents.
What is also misleading is the blatant unenforceable landscape design shown. Planting in rear gardens should not be illustrated and allowed to appear as a cohesive connected landscape as this type of planting is entirely unenforceable and could all be replaced with AstroTurf, decking and non-native shrubs and trees, which in such close proximity to an Ancient Woodland would be detrimental over time.
Alluring depictions of tree lined streets, in my experience as landscape architect disappear with drainage, lighting and service runs. Such tightly restricted street layouts and housing densities limit opportunity for tree growth resulting in frontages with little or no substantial tree cover.
Visual
I would also draw attention to the repetitive nature of the ‘adverse’ effects assessed in the landscape and visual impact assessment, which will most assuredly would be noted from the PROW CB64, which is classified as the highest form of receptor along with residents. Please note the belief that by year 15 tree cover will make this view slightly beneficial to what it is now, is completely misguided. The topography of the site rises to the north, the majority of the ‘tree cover’ they argue will grow to 10m tall is again shown in peoples curtilage and as such cannot be factored into mitigation.
The reality appears that walkers will now walk alongside a sewage treatment plant, go under a highway bridge walk alongside basins which will be seasonally dry / wet, have views of close board fences roof pitches before arriving alongside a station car park.
Urban grain
The actual residential development style is in complete contrast with the rest of Sturry which is predominately semi-detached plots with garden and parking to the front. Please note this has been the year where England fell back in love with their gardens, so why are permitting houses to be built with so little space for their residents to benefit from.
However we should not also underestimate the impact that COVID has placed on the working lives of millions. Flexible home working is now a reality for so many and as such will reduce the levels of day to day traffic. Companies across the country have permanently closed offices in favour of staff working from home, this work life balance for thousands will continue long after COVID.
I do ask what are the cumulative effects of the housing that has been approved in and around Canterbury, and why are we building homes that are not good for the resident, the landscape and the community as a whole? (LW, Public Comment)
Flawed data
This application is being pushed through because funding towards the new relief road is dependent on it being agreed, none of it will benefit the exciting or proposed new residents, but ultimately cause misery & years distribution. Much of the application is based on flawed and inaccurate data, as already highlighted by others. For example air pollution, the application refers to Air Quality 2007, not 2008/50/EC policy made law in 2010.
Traffic will be greatly increased on the main roads into Canterbury. The data on traffic projections for road traffic provided in Appendix 9.2: Predicted Traffic Flows for the Local Road Network, clearly shows there is an expected increase on Island Road by 31% with the development & link road. The A28 East traffic is predicted to decrease by 53%, in reality the traffic problems would be pushed onto the new road. No reassurances or clear studies have been put into the affects on the residential roads within Sturry and Broadoak. The current Link Road, into Meadow Road, through to Homewood Road is already used as short cut to bypass traffic at the bottom of Sturry Hill when train crossing is down. This route passes by Sturry School, Sturry Pre School & the community park. Clearly any increase in this traffic would raise safety concerns for the children moving around in this area, more so than it does now. Also referring back to my earlier point, what is the effect on air pollution. …without adequate site investigation, this is contrary to policy DBE3 and QL12 of the Local Plan. The area should remain protected to avoid harm to the ancient woodland and wildlife in the area. The planning committee has already stated the development would result in deterioration of the woodlands, contrary to policies LB8 and LB10 of the Local Plan
The development is purely about maximum profit, with blatant unforgivable disregard to the health and well-being of the residents of Sturry, Broadoak and surrounding areas
(RC-H, Public Comment)
Increased risk of foul flooding from sewers
It appears that the applicant is proposing to abandon/divert a public sewer. Any public sewer diversion proposals shall be approved by Southern Water under Section 185 of the Water Industry Act. An application should be made using Southern Water’s Developer Portal at: southernwater.co.uk/developing
Southern Water has undertaken a desktop study of the impact that the additional foul sewerage flows from the proposed development will have on the existing public sewer network. This initial study indicates that these additional flows may lead to an increased risk of foul flooding from the sewer network. Any network reinforcement that is deemed necessary to mitigate this will be provided by Southern Water.
Southern Water and the Developer will need to work together in order to review if the delivery of our network reinforcement aligns with the proposed occupation of the development, as it will take time to design and deliver any such reinforcement. (Southern Water, Consultee Comment)
Misleading Description:
To keep this objection to planning application CA/ 20/02826, a selection of some the many reasons to disallow this application for planning permission are set out below.
This application is a resubmission of a previous application to build 650 houses which was rejected on the grounds of amongst others, being to many for such a small area. The new proposal has reduced the number of houses by 3% which is a mockery of the application process itself. The current application sets out the planned building of 630 houses very well but other associated considerations have not received as much attention. The planning application is peppered with vague positive sounding comments and misrepresentations designed to make the application more appealing than it is. For example, in the section entitled “Site Context and Analysis”, the plan states that there are “a variety of shops in the Sturry High Street” and refers to a Pharmacy, restaurants, a town hall and a Post office. This list includes all of the shops; hardly a variety. In addition, the Post Office is a 2 birth counter within the Pharmacy which is not available every day of the week. The planning proposal’s description of available amenities is disingenuous, designed to mislead and to make it appear more appealing to decision-makers than it really is.
….The plans refer to flood areas alongside the railway line which is regularly saturated or flooded by rain water. These contain a reed bed which is frequented by wild fauna such as rabbits, song birds, slow worms, grass snakes, amphibians, bats and even foxes, not to mention insects such as moths and butterflies. The proposal mentions the installation of “mammal tunnels” to facilitate movement of species from one area to another. However, these are prone to blockage with rubbish, leaves and soil yet no provision has been made to ensure they are kept open for the foreseeable future…..
…the proposal plans to install a massive sewage tank alongside the 630 houses to contain polluted water. This is an unnatural and not sustainable without maintenance incurring on-going costs. In addition, at times of high rainfall it may contribute to the smell from the nearby sewage works to which local residents are already subject to. The application state that foundation piles may interfere with the ground water table. This proposal will reduce ground water replenishment and will not contribute in any way to the amelioration of drought conditions regularly experienced in the summer by local residents. Furthermore, Canterbury will be deprived of yet more cultivated soil; an issue of high sensitivity. Loss of agricultural land is also of national importance.
…Remedial Strategies awaiting Future Surveys:
There is too much reliance on “future (targeted etc.) additional surveys and site investigations to inform remedial strategies”. Supporting documentation states that the Geology and Soils investigation into the Geology was preliminary in some aspects. To remedy this, further investigation will be carried out after planning permission is granted. This is unsatisfactory.
Mineral Resource Lock-up:
An estimated 584,000 tons of brick-earth, a mineral of economic interest will be exempted by the CCC, from obligatory removal. Instead it will be made inaccessible for potential use in perpetuity after building has been completed.
Contamination:
The supporting documentation contains contradictions in that it states that lead, other heavy metals, copper, zinc and a variety of chemicals have been detected in the soil, often at concentrations above acceptable levels and that ”transmission of contaminants through the soil is a strong possibility”. However the application downplays these findings and regards them of minimal concern. In addition, this application does not apply with paragraph 170 of the NPPF.
Supporting documents state that the top soil has been found to be contaminated with various chemicals (eg: polycyclic aromatic hydrocarbons, benzopyrenes and anthracenes). However, the application states, these investigations were preliminary and that further adequate investigation will be carried out after the development plan has been approved. It is likely that many of these undertakings will be abandoned once planning permission has been granted. There is no mechanism to guarantee and ensure that these “promises” or any others will be fulfilled,
New Employment, Economic Benefits, Health and Traffic Reduction:
The proposal claims that the project will promote new jobs, new community facilities, economic and social benefits for the town but it does not explain how this will be done. Similarly, it claims to promote priority of walking and cycling over that of cars while the plans show a significant number of roads. The proposal does not provide even a brief explanation of how this will be achieved. References are vague and not as clearly defined as the building plans. The addition of 630 new houses will inevitably lead to increased traffic with an accompanying reduction in local air quality. The health of elderly residents of a retirement centre adjacent to the planned development will be adversely affected. In addition, reduced air quality will contribute to the development of chronic respiratory conditions, such as asthma, amongst local residents…..Insufficient open space for use by the residents of the housing development, thereby ignoring policy OS11 of the 2017 local plan. (MG, Public Comment)
Groundwater protection
CONTAMINATED LAND
Condition
No development approved by this planning permission shall take place until a remediation strategy that includes the following components to deal with the risks associated with contamination of the site shall each be submitted to and approved, in writing, by the local planning authority:
1. A preliminary risk assessment which has identified:
- · all previous uses
- · potential contaminants associated with those uses
- · a conceptual model of the site indicating sources, pathways and receptors
- · potentially unacceptable risks arising from contamination at the site.
- A site investigation scheme, based on (1) to provide information for a detailed assessment of the risk to all receptors that may be affected, including those off site.
- The results of the site investigation and the detailed risk assessment referred to in (2) and, based on these, an options appraisal and remediation strategy giving full details of the remediation measures required and how they are to be undertaken.
- A verification plan providing details of the data that will be collected in order to demonstrate that the works set out in the remediation strategy in (3) are complete and identifying any requirements for longer-term monitoring of pollutant linkages, maintenance and arrangements for contingency act
DRAINAGE
The application proposes to discharge surface water to the nearby stream. As no discharge to ground is indicated we have no comments on surface water drainage at this time. If there is a change of design at a later stage to incorporate infiltration drainage systems the Environment Agency will need to be reconsulted.
It is understood that foul water is to be discharged to mains drainage and that prior to leaving the site, the water will be treated within a Package Treatment Plant.
However, we note that the current drainage system is inadequate to accommodate the proposed discharge volumes. We are aware that to overcome this, the drainage systems are to be upgraded. This improvement works must be completed prior to occupancy of the development as we will not agree to any foul water discharges to the ground in this area.
Condition
The development hereby permitted shall not be commenced until such time as a scheme to connect the property to foul and or surface water drainage system has been submitted to, and approved in writing by, the local planning authority. The scheme shall be implemented as approved.
Condition
Whilst the principles and installation of sustainable drainage schemes are to be encouraged, no infiltration of surface water drainage into the ground is permitted other than with the express written consent of the local planning authority, which may be given for those parts of the site where it has been demonstrated that there is no resultant unacceptable risk to controlled waters. The development shall be carried out in accordance with the approval details.
Reasons
To ensure that the development does not contribute to, or is not put at unacceptable risk from, or adversely affected by, unacceptable levels of water pollution caused by remobilised contaminants present in shallow soils/made ground in line with paragraph 170 of the National Planning Policy Framework.
(Extracts from Environment Agency, Statutory Consultee)
Stick to their guns
The local amenities in the parish struggle at present with water pressure often being very low and burst pipes a regular occurrence proving the infrastructure is too delicate to cope, adding extra houses will make this situation untenable. Given the fact that the plan already includes a cess pit proves it is realised the sewage system could not cope but living close to the proposed site means my neighbours and myself will have to suffer the smell, pollution and health hazards of this pit being regularly emptied and lorries full of the resulting effluent being driven close to our properties. In conclusion, this ill thought out and totally unsuitable application should be as soundly rejected as it’s predecessor was and I urge the Planning Committee to stick to their guns no matter what pressure they are under from whatever source. (DS, Public Comment)
Get Sturry Right
This application shows only minor changes from application CA/17/01383 which was refused by CCC.It does little ,if anything, to address the reasons given for the rejection by the Plannig Committee.
This current application should also be refused.
The hasty presentation of the current virtually unchanged application might suggest an attempt to ‘Get-Sturry-Done’ rather than to Get-Sturry-Right.
As has been pointed out, the price paid for this land, the burden of payment towards the Relief Road, the extra costs of providing onsite sewage processing pits and so on all mitigate against the provision of high quality development in line with CCC’s aspirations to provide communities based on Garden City principles.
This application is inadequate
It should be refused. (GK, Public Comment)
