APPLICATION Ref: Y08/0124/SH.
Date: 3rd August 2008.
WATER ISSUES - THE FACTS.
My name is Leslie Barratt and have been working within the water industry as Engineering Technician for the past 37 years. I was first alerted to the water issues at the Otterpool site by Sellindge and District Residents Association in late February 2008.
My initial concerns over the application was the lack of information within the design statements produced by SLR consulting on behalf of the applicant: Countrystyle Recycling Ltd. Moreover, I was greatly surprised that an Environmental Impact Assessment was not provided nor insisted upon by Kent County Council.
ENVIRONMENTAL IMPACT ASSESSMENT.
Kent County Council has stated that an Environmental Impact Assessment would not be required back in October 2007. Having consulted with the Environment Agency and Natural England, their view then was that enough information was provided within the application and that the impact upon the surrounding area was such as not to warrant an EIA.
At the time of the application, the consultees were not in receipt of ALL the facts. The application was void of all drainage proposals. In an area where the nearest sewer was one kilometre away I consider this oversight to be a disgrace and put the blame squarely at the door of KCC.
It is a matter of record that European Law, directive EIA 85/337/EC states that given certain site criteria, an EIA is a requirement and must be carried out. My recent correspondence with KCC details all criteria and requirements and is available to any interested parties.
The South East is the driest area in the UK. In recent years we have experienced hose pipe bans with media headlines of low rainfall and barren reservoirs. I would expect to see some regard to water consumption at the site if only given as an estimated ‘Megalitres per year’ figure. There is no mention of water recycling (grey to black) or rainwater harvesting.
CONSENT TO DISCHARGE LICENSE.
As previously described, the site has no facility to discharge effluent to the Southern Water sewer. Previous owners of the site acquired a license to discharge to a local water course.
SLR’s design statement regularly mentions a consent to discharge and also states that sewage will be discharged via this license.
The license was issued to Redland Aggregates Ltd in 1989 and clearly states FOR SURFACE WATER ONLY.
GEOLOGY OF SITE.
The site overlies two important bed formations: Hythe and Folkestone.
The Hythe bed consists of sandy limestones: Rag stone and Hassock (hard sandstones). Mid Kent Water have modelled this strata and consider it to be a significant water resource. Local properties are believed to be served by this formation.
The Folkestone Beds consist of a series of sands including iron rich and clay bands.
Known as Lower Greensand, this formation is the second most important source of drinking water in Kent.
As the main consultees in the screening and scoping process, the EA have raised a number of points and concerns over the Otterpool site and Application specification.
Initially, an objection was raised by the EA in line with PPS23 by the Land Contamination Team on the EXISTING pollutants that may be present on site but later withdrew the objection after studies carried out by SLR Consulting Ltd.
The EA describe the site as vulnerable because of the very high water table and the permeability of the site.
The EA are surprised that full drainage proposals did not accompany the application and to date still do not have any drainage proposal from the applicant.
In any event, the EA has made it very clear to the applicant that NO SOAKAWAYS WILL BE ALLOWED TO BE INSTALLED AT THE SITE.
KENT COUNTY COUNCIL.
As a County council determining applications such as the Otterpool site, I am surprised that there seems to be no one at officer level that could screen applications, particularly on waste sites for environmental impact. I dread to think how far this application could have got if it wasn’t for the voices and expertise of local people.
The protection of our local water courses and Aquifers is of paramount importance and should be protected at all costs. There must be no trade off against employment or landfill costs whatsoever. We look to our District and County councils as guardians of our environment and expect nothing less.
One of the conditions of carrying out an Environmental Impact Assessment is that alternative sites must be considered. There has been very little consideration for this requirement from KCC and can only wonder at why, given the major concerns over water issues, other sites are not being considered. I also understand that the Otterpool site has never been ear marked as a waste site under the Kent Waste Strategy Plan.
As mentioned at the Development Control committee meeting, the old Richborough station site should be given consideration.
SHEPWAY DISTRICT COUNCIL REPORT. Terry Ellames.
I refer to paragraph 5.14.
As previously stated in this document, water issues have not been assessed to a satisfactory degree or conclusion. It is a fact that the Environment Agency still requires further information from the applicant.
Any concerns that Southern Water would have would only relate to drainage proposals. No mention has been made by SLR to connect to the sewer and to date there are no drainage proposals in existence.
EXISTING LOCAL SEWAGE PROBLEMS.
It is well noted in the area that during periods of high rainfall there are problems with the combined (rain and sewage) sewer system. It is a matter of record that during these periods, manhole lids are forced up by the surge of water, depositing human waste and such like over peoples properties and finding its way into the head of the river Stour (East Stour). Any attempt to connect to this system would only exacerbate an already unacceptable situation.
This document has been produced as a result of the Development Control Committee meeting at Shepway District Council on 29th July 2008. Although the member’s comments were most welcomed in condemning the application and site use, I was surprised that there were no officers in attendance that could advise members on technical matters such as water issues.
This is a brief and non technical summary of the complex issues surrounding water issues at the Otterpool site and has been produced for members of Shepway Development Control Committee.
I would be happy to provide further information should any member wish to pursue this matter further.
Leslie Barratt. Eng Tech MIPHE.