Otterpool Waste - locl roads + Traffic Assessment

Reply from Sharon Thompson, KCC, 19th April 2011, to Dave Motley (local resident) questions raised regarding the impact on the local roads, including both the A20  and the local infrastructure. 

The points in her reply that seem worth particular attention are highlighted in red below.....

The A20 will be an absolute nightmare but the computer (stats/highways agency) says no!! See attached Assessment – email and Assessment going on our website, obviously

Any suggestions as to how to get them to use some common sense? 

Not all 'A' roads are dual carriageways, or the same width, with junctions, or a thriving business directly opposite, or Newingreen 4 entry/exit corner. 

From: sharon.thompson@kent.gov.uk [mailto:sharon.thompson@kent.gov.uk] 

Sent: 19 April 2011 17:55
To: dave@davemotley.co.uk
Cc: Susan.Carey@kent.gov.uk; Richard.King@kent.gov.uk; Linda.Songhurst@kent.gov.uk; Mike.Clifton@kent.gov.uk; Angela.Watts@kent.gov.uk
Subject: RE: Otterpool Waste Treatment

Dear Mr Motley

Thank you for your further email seeking further clarification on the highway considerations raised by the planning application.   I have discussed further with the Divisional Transport Manager who has provided the following response to your 2 points.  

1. On a second particular point, I have real problems with understanding how the local road infrastructure can cope with the current increasing volume of traffic, let alone with this massive increase. My concern is other roads not necessarily directly used by Countrystyle vehicles will suffer greatly – i.e. the A20 through Sellindge and Swan Lane!! Is there a report of the review that took place and by who? I would like a copy please?    

The A20 is a principle route which in accordance with the guidance documents issued by the Department for Transport is capable of carrying approximately 23,000 vehicles per day before the performance of the route begins to break down. The actual traffic counts in this location, carried out as part of the Transport Assessment submitted with the application, are approximately 6650 vehicles per day.  By 2018 with the additional development proposed for the District and natural traffic growth this figure is forecast to be about 8000 vehicles per day.  The A20 therefore has more than sufficient spare capacity currently to absorb additional traffic.

The proposed use of the site is likely to generate approximately 152 lorry movements per weekday, broken down this equates to approximately 8 HGV loads in and then out of the access per hour plus approximately 40 car trips per day associated with visitors and staff to the site.

Improvements to the site access will make it easy for exiting lorries to turn towards Junction 11 of the M20 but impossible for them to turn towards Sellindge.  The accident data contained within the Transport Assessment showed that no crashes occurred at the site access location or at the accesses to the Airport Cafe.  Of the accident data received for the nearby area none of the accidents were attributed to slow moving lorry movement.  There is no reason to anticipate that, given the improvements made to the Quarry site access, there will be an increase in crashes due to the proposed site operations.

2. I live in the village of Sellindge, in Swan Lane, not very far at all from the proposed site (1 mile). “Did the Highway Assessment cover all or only some of the

    following in their assessment before apparently deciding that development was acceptable?” :

a)      just the site itself

b)      the A20 to the M20

c)      Newingreen junction

d)      the A20 outside the Airport café

e)      the junction with Otterpool Lane

f)        the A20 through Sellindge Village including

a.       Grove bridge

b.      Swan Lane junction

c.       Swan Lane/blind house lane (traffic will increase due to knock on affects

d.      The school crossing and school children

e.       The doctors and Village hall crossing                       

g)      Extra housing at Lympne (400?) – increased use of Otterpool Lane

h)      Extra housing at the Racecourse (800?)

i)        Extra housing in Sellindge (300?) including possible new road close to Grove Bride

j)        Operation Stack

k)      The Wind farm

l)        Increase in Otterpool Lane traffic

m)    And any other associated aspects

a)    The site access has been significantly improved to prevent lorries turning towards Sellindge and better assisting lorry turning movements back towards junction 11.  There is adequate turning and parking provision within the site.  The gates are set back 15m from the highway and will be open from 07:00 hrs.  It is unlikely that vehicles would be queuing prior to this time.   Approximately 8 incoming HGV’s are anticipated in an hour which can be adequately accommodated by the access arrangements with no queuing back onto the A20 expected.

b)    The A20 between J11 of the M20 and the application site is part of a signed advisory lorry route for vehicles accessing Lympne Industrial Estate.  There is no crash data to suggest that problems have occurred in the past with lorries using this stretch of road.

c)   The Newingreen junction is recognised as needing mitigation works by the Shepway Transport Strategy and will be addressed by the Core Strategy in the LDF process.  The traffic impact on the Newingreen junction by this development is not of a significant nature to request a contribution towards improvement works.  The Transport Strategy has however considered the cumulative effect on the junction if all of the strategic sites within the LDF come forward and suggested a mitigation strategy which will be developer funded.

d)     The junction has been modelled to take account of the access points of the Airport Cafe opposite and any associated turning movements.  The testing carried out was very robust and the analysis demonstrated that the junction would operate adequately in the future without queuing or driver delay expected.

e)    The junction with Otterpool Lane has recently been improved to accommodate large HGV movement, however the junction configuration for the access road to the application site prevents lorries from turning towards this junction. 

The submitted transport assessment does not directly identify physical measures that can be taken at J10 to prevent freight traffic using the the A20 as this may discriminate against existing businesses served via this route by HGV vehicles.  It does however refer to the section on Freight within the LTP stating:

"The Council will work with partners to ensure that road freight operations are undertaken with minimal social and environmental impact.

Where practical, the Council will:

·        identify and signpost heavy transport and HGV routes to direct road haulage vehicles away from rural, residential and environmentally sensitive areas;

·        discourage through traffic, particularly goods vehicles, from travelling on minor roads by use of the traffic management and regulatory measures and the control of development and freight quality partnerships; and

·        promote a web-based Kent Lorry Route Map as a definitive guide to road based freight routes in the County and ensure that the map is revised accordingly to include up to date highway and land use developments."

KHS Network Performance team are working on this strategy.

f) Already addressed above and with site access improvements.

g, h, i) These issues will be addressed by the Transport Strategy within the LDF process and is not a consideration for the Otterpool Quarry application which cannot consider sites unless planning consent has already been granted. 

j)   Traffic flows on the A20 are increased during Operation Stack.  However, the M20 between J10 and J11 remains open during the operation and therefore the corresponding section of the A20 is relatively unaffected.  A moderate increase in traffic flows can be expected from vehicles avoiding the motorway route altogether, although the significant reserve capacity available determines that the link would continue to operate effectively.  Development traffic would have an insignificant impact on highway capacity during periods when Operation Stack is enforced.

k) Not a consideration for this application.

l)  The only likely impact will be car based from staff and visitors to the site.  It has been confirmed that the majority of staff would arrive and leave the site outside of peak hours.  With an estimated total of 40 trips per day the impact on Otterpool Lane is likely to be negligible.

m)    None to my knowledge.

As requested I  attach a copy of the traffic assessment.

I trust that the above is helpful

Kind regards

Sharon  

Sharon Thompson

Head of Planning Applications 

Planning and Environment,

Enterprise and Environment

Kent County Council  Invicta House, County Hall, Maidstone, Kent ME14 1XX

Internal: x6052

External: 01622 696052

www.kent.gov.uk/planning

 Please consider the environment before printing this email

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From: Dave Motley [mailto:dave@davemotley.co.uk]
Sent: 19 April 2011 13:42
To: Thompson, Sharon - EE PE
Cc: Carey, Susan - MEM; King, Richard - MEM
Subject: RE: Otterpool Waste Treatment - conditions
Importance: High

Dear Sharon

Thank you for your reply.

Can you please reply specifically to the following point :regarding the local road infrastructure which I raised in my email to you:

On a second particular point, I have real problems with understanding how the local road infrastructure can cope with the current increasing volume of traffic, let alone with this massive increase. My concern is other roads not necessarily directly used by Countrystyle vehicles will suffer greatly – i.e. the A20 through Sellindge and Swan Lane!! Is there a report of the review that took place and by who? I would like a copy please?    

When considering your reply please take into account the following:

I live in the village of Sellindge, in Swan Lane, not very far at all from the proposed site (1 mile). “Did the Highway Assessment cover all or only some of the following in their assessment before apparently deciding that development was acceptable?” :

a)      just the site itself

b)      the A20 to the M20

c)      Newingreen junction

d)      the A20 outside the Airport café

e)      the junction with Otterpool Lane

f)        the A20 through Sellindge Village including

a.       Grove bridge

b.      Swan Lane junction

c.       Swan Lane/blind house lane (traffic will increase due to knock on affects

d.      The school crossing and school children

e.       The doctors and Village hall crossing                       

g)      Extra housing at Lympne (400?) – increased use of Otterpool Lane

h)      Extra housing at the Racecourse (800?)

i)        Extra housing in Sellindge (300?) including possible new road close to Grove Bride

j)        Operation Stack

k)      The Wind farm

l)        Increase in Otterpool Lane traffic

m)    And any other associated aspects

An increase required for the application of 168 heavy lorry movements a day is massive. How will the roads cope? Is it not almost a certainty that more accidents will happen on that stretch of the A20 – Have you really reviewed this 100% so you can sleep at night?

Now is the time to reconsider before it is too late!! We all will agree that Recycling is good and necessary but not in a Village, without the infrastructure to cope with it. Put it in the right place.

I look forward to receiving a quick reply including a copy of the Assessment and the answers to my email.

Regards

Dave Motley    

From: sharon.thompson@kent.gov.uk [mailto:sharon.thompson@kent.gov.uk]
Sent: 19 April 2011 13:00
To: dave@davemotley.co.uk
Cc: Mike.Clifton@kent.gov.uk; Angela.Watts@kent.gov.uk; Linda.Songhurst@kent.gov.uk
Subject: RE: Otterpool Waste Treatment - conditions

Dear Mr Motley,

Thank you for your e mail dated 4th April 2011. I apologise for not having written to you earlier.

Whilst I understand from your e mail that you are disappointed with the outcome of the Planning Applications Committee's decision, I assure you that the application was considered in accordance with planning policy and that Members of the Planning Applications Committee considered all the planning arguments before taking a decision. As you are aware there was a very detailed officer report that set out the relevant issues including the impact upon the highway and traffic, landscape, local amenity and impact upon the nearest properties and pollution considerations. The Committee members were fully aware of the strong local objections to the development but had to consider the application against all relevant government guidance and planning policy which weighed heavily in favour of the proposal at the Otterpool site.

Planning applications for waste management development is always controversial but is a necessary infrastructure to meet community needs. To aid planning authorities, the Government has prepared planning policy and guidance advising where such development are most appropriately located together with what are the acceptable amenity impacts.  In this case, I am advised that the Otterpool Quarry site was firmly in accordance with that Government advice and planning policy, and in the light of no technical objections from statutory consultees such as the Environment Agency (E.A.) and Kent Highway Services there were no grounds upon which in refusing the application this could have been sustained and defended at Public Inquiry. 

In order for the site to operate, the applicant will also require an Environmental Permit from the E.A.. This is a separate regulatory process which sets the operational parameters of the plant in order to control risks from pollution. As explained in the officer report which I re-emphasised at the committee,  local planning authorities are required to work on the assumption that the regulatory control regime will be properly applied and enforced.

Turning to traffic impacts, Kent Highway Services raised no objection to the application. In reaching this view they undertook a comparison of the level of traffic proposed at the Otterpool site with the existing levels of traffic on the local road network along with the previous use of the site and concluded that the impacts would be negligible. The site access itself has been specifically designed so as to preclude vehicles entering and leaving the site in the direction of Sellindge Village and will therefore direct vehicles along the most suitable route towards junction 11 of the M20.

Finally, regarding the conditions which have been imposed on the planning permission, I recently wrote to Bob Edden from the residents association who had previously provided me with a copy of what he considered should be covered by condition in the event that permission were granted. As you point out reference was made to his conditions at committee which are reflected in the minutes of the meeting. At the meeting whilst I indicated that with the exception of one condition the rest would be covered,  it was made clear that this would not necessarily include his specific wording for the purposes of enforceability. You may find it helpful if I set out below my response to specific points he asked for clarification on in the context of the list of conditions he had provided:

     

'Whilst you are concerned that the conditions do not in your opinion cover the issues raised by the SDRA, I would wish to assure you that very careful consideration was given to ensure your concerns along with those matters raised by consultees were incorporated, albeit as I stated at the meeting of the Planning Applications Committee last month when the application was determined, their specific wording would need to ensure their enforceability amongst other matters.

As requested I would make the following comments as to how and where your schedule of conditions are covered in the formal decision notice referring firstly to your numbering;

2.     Conditions (3) and (12) address the issue of surface and foul water drainage with condition (12) in particular reflecting the specific     

        wording recommended by the  Environment Agency (E.A.). Whilst condition (12) only refers to surface water drainage, condition (3) is

        also relevant reflecting a standard approach to ensure developments are carried out strictly in accordance with the submitted documents.

        This includes not only the original application documents but also any subsequent supplementary supporting information as reflected in    

        the schedule attached to the planning permission. In this respect the SLR Document entitled ' Groundwater Addendum Report' dated

        October 2010 is particularly relevant. With regard to the underground foul water storage tank the E.A. were satisfied that given the    

        additional groundwater monitoring data demonstrated to their satisfaction that the base of the tank would sit over 1m above the highest    

        recorded groundwater levels they raised no objection to this particular element of the drainage scheme.  

3.      Conditions (3) and (8) deal specifically with site layout and boundary treatment.

4.      Condition (3) and (34) deal with site layout and hard surface landscaping.

5.     Condition (34) deals with landscaping including the identification of existing trees along with additional planting. The ecological

        assessment undertaken by  the applicant did not reveal the presence of bats on site and was not raised as an issue by either Natural

        England or the County Council's Ecologist. However bats are still nevertheless protected under the Wildlife and Countryside Act ( 1981 )

        and the Conservation of Habitats and Species Regulations ( 2010 ).

6/7.  Conditions (3), (4) and (19) deal with odour/bio aerosol releases, matters which are specifically addressed in the Air Quality

        Assessment and Bio aerosol Risk Assessments including mitigation measures.

8/9. Condition (4) of the permission refers specifically to a number of drawings which were submitted as part of the planning application ( i.e.

        drawing numbers OP/5, OP/6, OP/8 and OP/9 ). These drawings show the elevational details of the individual buildings proposed to    

        be erected on site and include their individual heights, none of which exceed 12.5 metres above the finish floor levels ( FFL ). Drawing

        number OP/7 shows the FFL as being 79.0m GL along the southern boundary of the site reducing on an even gradient to 77.0m            

        GL  along the northern boundary.

        Condition (4) of the permission requires that the buildings permitted are erected in accordance with the above mentioned drawings    

        which make specific reference to their heights in relation to the FFL. The wording used in the condition which seeks to control    

        maximum building heights in order to minimise their visual impacts, reflects a standard approach which has been successfully used to    

        control building heights on proposals of a similar nature and is therefore confident that should it be found necessary could be        

        satisfactorily enforced.

        In addition, an informative has been included which advises of member's request that the finished floor levels (FFL) of the        

        proposed buildings be as low as possible in order to reduce the visual impact of the development, albeit this will largely be dictated by    

        the requirement that the FFL,s are above the highest recorded groundwater levels as shown on supplementary information submitted as

        part of the planning application.

10.  Conditions (3) and (34) address this issue.

11.  Condition (9) requires details of external lighting to be submitted and approved by the Waste Planning Authority

12.  Condition (1) removes Permitted Development Rights such that before the introduction of any additional fixed plant, machinery, buildings 

       or structures and erections their details require the prior approval of the Waste Planning Authority.  

I remain confident therefore that the issues the SDRA wanted to see covered as previously provided by you, have been reflected in the formal decision notice and accordingly the concerns of local residents along with those others raised by consultees have all been addressed to the extent that they secure proper control over the development.'

Kind regards

Sharon  

Sharon Thompson

Head of Planning Applications 

Planning and Environment,

Enterprise and Environment

Kent County Council  Invicta House, County Hall, Maidstone, Kent ME14 1XX

Internal: x6052

External: 01622 696052

www.kent.gov.uk/planning

 Please consider the environment before printing this email

---

From: Dave Motley [mailto:dave@davemotley.co.uk]
Sent: 04 April 2011 17:16
To: Thompson, Sharon - EE PE; King, Richard - MEM
Cc: Carey, Susan - MEM
Subject: Otterpool Waste Treatment - conditions
Importance: High

Dear Sharon

I am a long standing resident in the Village of Sellindge for over 27 years. It will not surprise you that I am absolutely appalled at the decision of KCC to approve Countrystyle’ Planning Application. I find this absolutely irresponsible – how can a waste plant be put in a Village, massive impact on local roads, noise, dust and water pollution and local residents and the long standing Airport Café?

I do not know how such a site can be approved to exist and operate in the COUNTRYSIDE – that is what it is here – it is not an industrial site!! We are real people, with kids and grandkids – how can you sleep at night and live with yourself?

I totally agree with ‘Recycling’ but clearly any responsible councillor would put this in the correct location. You know all this as I know many many people have told you already but somehow you do not ‘hear’ the obvious?

What will it take for you to listen? Is it too late for the matter to be reconsidered and put in an appropriate location?

On a second particular point, I have real problems with understanding how the local road infrastructure can cope with the current increasing volume of traffic, let alone with this massive increase. My concern is other roads not necessarily directly used by Countrystyle vehicles will suffer greatly – i.e. the A20 through Sellindge and Swan Lane!! Is there a report of the review that took place and by who? I would like a copy please?    

On a third point, the minutes clearly show the conditions (except the first) suggested by Sellindge & District Residents’ Association (of which I am a member) would all be covered in a manner so they could be enforced. BUT I don’t see where our conditions have been clearly included (no appendix or similar?), and that being the case I can’t understand why they have not been? The planning approval document as issued does not conform to the requirements of the motion to approve the ‘agreed conditions’ that was voted on by the Committee. Can you please explain how the correct conditions are to be inserted – this is crucial!!  

I look forward to your complete response by reply.

Regards

Dave Motley