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Lodge Hill – Parish Council Response

High Halstow Parish Council
c/o 53 Capelands
New Ash Green

Further response to Medway Council
Re Lodge Hill development MC/11/2516


We are objecting to the proposals for the development at Lodge Hill and are dismayed to read some of the submissions and comment to the outline planning application MC/11/2516 for around 5000 homes (estimated 12500 people) at Lodge Hill

You will appreciate that as ordinary people we are in no way experts in planning matters, let alone qualified to understand what is required to set up a completely new town. We therefore approach our reaction to the application with common sense and some degree of negative skepticism.

In the entire time since 1947 that the Peninsula has been under the spot light as a potential site for an airport for London, Governments and developers have paid little attention to true environmental importance of the Area or its position in, and value to biodiversity in the wider North Kent Marshes and global bird migratory routes. In 1972 Eldon Griffiths MP (Con, Bury St Edmunds), Parliamentary Under-Secretary of State at the Department of the Environment, referred to the Maplin Sands scheme as the “world’s first environmental airport”.
In 2008, Mayor Boris Johnson said that it was “ever more urgent that we investigate the possibility of a long-term solution, in the form of a new and more eco-friendly international airport at a site in the Thames estuary”. The 2009 Oakervee report referred to a ‘green airport’ in the estuary.

It is unsurprising therefore that we read from KCC that Land Securities have paid scant attention to the value of biodiversity present at Lodge Hill in relation to items listed below.

1. Areas they recommend for retention for True fox sedge not being on the plans.
2. In adequate information given for the protection of Chattenden Woods SSSI.
3. Given the variety of habitats available on the site, it is likely that there are areas of the site that would fall into BAP habitat and it is not clear whether the potential importance of theses areas has been recognised and adequately assessed.
4. Only Three site surveys were undertaken. The Natural England Research Report (NERR005) advises that “ a reasonably thorough survey of a terrestrial habitats can be made through seven visits at monthly intervals from April to October” For a site the size of Lodge hill we would consider three visits inadequate.
5. Given the size of the site with some thirty four ponds we doubt that all great crested newts are part of the same metapopulation.
6. In their Masterplan for Amphibians the proposal will result in the loss of nine great crested newt and common toad breeding ponds and eight additional ponds 49.8 hectares of terrestrial habitat with 250m of existing great crested newt ponds will be lost. which are protected under the Conservation of Species and habitats regulations 2010.
7. Mitigation and compensation are proposed but the detail is inadequate.
8. The reptile surveys have not been carried out using best practice guidelines and there is insufficient information available to assess the impact on reptile populations.
9. The survey has indicated a large number of wintering bird using the site. There is currently insufficient consideration on the increase in the numbers of people will have on the numbers of wintering birds using the site.
10. Insufficient information has been provided to adequately assess the potential impact on breeding birds using the site
11. Insufficient number of Nightingale territories have been recorded within the site.
12. Insufficient information has been provided to adequately assess the potential impact on Bat populations within the site.
13. Insufficient information has been provided to adequately assess the potential impact on dormice populations within the site.

Read submission letter 143 at http://planning.medway.gov.uk/dconline/AcolNetCGI.gov?ACTION=UNWRAP&RIPNAME=Root.PgeDocs&TheSystemkey=124463

You will appreciate that the A228 is the main and only major access road for the peninsula’s entire population, International container port, 4 or 5 power stations, major LNG facility, and many other road dependent businesses. A new town housing an extra 12,500 people at its mouth, with no provision for separate access to the M2 / A2 or Medway towns renders it critical in terms of traffic flow.

The Highways Agency note :-

The transport assessment indicates that the A2/M2 will suffer a material impact from the proposed development.

1. Due to errors within the capacity assessments presented of A2 / M2 junction 1, these are not able to be acceptable. These should be reviewed, corrected and revised assessments presented to the Highways Agency.

2. The assessments currently presented do however indicate that element of the A2 / M2 junction 1, interchange will be overloaded. The transport Assessment has suggested that potentially a ramp metering scheme could be introduced for the A289 approach. A potential layout and assessment of this scheme has not however been presented. If the applicants wish to take forward this option, further details and evidence supporting such a response will need to be provided.

3. The Transport assessment suggests that the operation of the Junction 1, westbound diverge will be monitored to see whether upgrade is required. It is not clear how the upgrade will be monitored and funded. Therefore further information should be provided.

4. We also consider that the developer should provide details of the additional trips that are predicted to be generated by the proposed development at M2 junctions 2 and 3, both on the mainline carriageways, the slip roads and turning movements at the junctions. If the development traffic flows at these junctions exceeds 30 two way vehicle trips in an hour, junction and merge / diverge capacity assessments should be undertaken. The requirements is in accordance with the Highways Agency Protocol for dealing with Planning applications.

(read submission letter 115 at http://planning.medway.gov.uk/dconline/AcolNetCGI.gov?ACTION=UNWRAP&RIPNAME=Root.PgeDocs&TheSystemkey=124463
Further The Design and Access or other statements do not fully demonstrate how crime prevention measures have been considered.

If the submission is successful we would welcome an assurance from Medway council that the infrastructure indicated in the proposal is delivered in a timely manner so as not to cause disruption to the infrastructure already in place in nearby villages. That road access to the site is up and running before building begins.

It is not clear what the impact is on the A228 should there be an incident which causes partial or total closure of this road. What is the contingency plan being put into place should an incident occur? Please note we have been asking for this information now prior to any development at Lodge Hill and want to know what are the contingency plans irrespective of any development.

The extension to the consultation period has allowed further objects to be raised we note however that Land Securities appear not to have used this time to disseminate information about the proposed development. The general feeling of this council is that they have failed to consult positively to sufficient members of the communities on the peninsula.

No consideration has been identified for any S106 issues and would want to know how this would be addressed in relation to our Parish

Yours faithfully
For and on behalf of High Halstow Council

George Crozer

cc Mark Reckless MP

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