Our concerns about air quality

We have submitted our concerns about air quality in the consultation “Improving air quality: national plan for tackling nitrogen dioxide in our towns and cities”.

We are very dissatisfied with DEFRA’s (Department of the Environment, Farming and Rural Affairs) proposed measures to address the problem:

• We do not accept that devolution of responsibility for air quality to local planning authorities is an appropriate way forward. Local authorities lack the resources, capacity and expertise to shoulder the responsibility.
• We are concerned that each local planning authority will act in isolation with regard to air quality. The government is committed to delivering 1 million new homes by 2020, and it is clear that the adverse air quality impacts of increased traffic, increased congestion and air pollution in pinch-points, will be experienced across more than one planning authority area and we are aware of no overarching strategy that can address this.
• Within Kent, we are particularly concerned at the conflict between the requirement for air quality improvement and policies and decisions on transport. Kent’s channel corridors provide for the movement of some 60% of freight between the UK and mainland Europe. Kent County Council’s Freight Action Plan seeks to facilitate increased traffic, rather than engage in sustainable freight movement strategies which reduce the nation’s reliance on this route. The Port of Dover’s expansion plans will have concomitant impact on the highways network further afield, not least at the existing Dartford Crossings. It is because of the congestion, delays and exceedance of air quality limit values that already exist at Dartford that DfT recently announced a third Thames Crossing to be sited east of Gravesend. However, Highways England have acknowledged that the construction of this crossing would be expected to divert only 14% of the traffic using Dartford to the new crossing at Gravesend; it will not resolve the existing problems at Dartford, but it will create new problems at Gravesend.

CPRE Kent Director Hilary Newport said: “For all of these reasons, and many more, we find it implausible that a national air quality strategy which focuses on simply forcing responsibility, but not capability, to deliver air quality improvements can possibly achieve the outcomes required by the Supreme Court.”

To read the full submission click here.

Meanwhile our Canterbury committee has also responded to the consultation raising issues specific to the city.

Barrie Gore said: “Canterbury basically sits in a bowl on the floodplain of the River Stour with higher land around, so that when cloud cover is low, or during conditions of extreme heat, traffic fumes are unable to dissipate and the City suffers from even worse pollution than usual. Geological situations should always be taken into account where they worsen existing bad pollution. Such areas will often have medieval street plans, like Canterbury, which trap fumes more than modern, wider, roads, which also may adversely affect the fabric of historic buildings and World Heritage Sites.”

He also referred to the Canterbury Local Plan and the huge level of development planned which will make things much worse with 25000 (twenty-five thousand) vehicle movements in the city on a daily basis. and which would increase Canterbury’s population by at least 25%.

To read the Canterbury submission click here.

June 14th 2017, updated June 19th.

• A number of important documents have yet to emerge. For example, a rigorous transport plan and a finalised air-quality assessment. The latter is critical given that allocations at Teynham will feed extra traffic into AQMAs.
• There seems to be no coherent plan for infrastructure delivery – a key component of the plan given the allocations being proposed near the already crowded Junction 7.
• There seems to have been little or no cooperation with neighbouring boroughs or even parish councils within Swale itself.

The removal of a second consultation might have been understandable if this final version of the plan were similar to that being talked about at the beginning of the consultation process. It is, however, radically different in the following ways:

• There has been a major shift in the balance of housing allocations, away from the west of the borough over to the east, especially around the historic town of Faversham. This is a move that raises many concerns.
• A new large allocation, with accompanying A2 bypass, has appeared around Teynham and Lynsted, to which we are objecting.
• Housing allocations in the AONB around Neames Forstal that were judged “unsuitable” by the council’s own officers have now appeared as part of the housing numbers.
• Most of the housing allocations being proposed are on greenfield sites, many of them on Grade 1 agricultural land – a point to which we are strongly objecting.

Concerns about the rush to submit the plan

The haste with which the plan is being prepared is especially worrying given the concentration of housing in Faversham. If the town is to take a large amount of new housing, it is imperative that the policies concerning the area are carefully worked out to preserve, as far as possible, the unique nature of the town. The rush to submit the plan is likely to prove detrimental.

As Swale does not have a five-year land housing supply, it is open to speculative development proposals, many of which would run counter to the ideas contained in the current plan. Some are already appearing. This is a common situation, and one that, doubtless, is a reason behind Swale’s haste.

Our overriding fear, however, is that this emphasis on haste is ultimately going to prove counterproductive. This is because it is our view that the plan, in its current form, is unlikely to pass independent examination. We are urging Swale to listen to and act upon the comments being made about the plan and to return the plan to the council with appropriate modifications before submitting it to the Secretary of State.

Essentially, this means treating the current consultation not as the final one but as the ‘lost’ second consultation.

The consultation ends on Friday 30 April and we strongly urge residents to make their opinions known if they have not already done so.

Further information

• Read more on the Swale Local Plan
• Read CPRE Kent’s detailed comments on the plan
• View the council’s consultation document