As you may well be aware, Maidstone Borough Council has issued its draft Core Strategy Strategic Site Allocations and draft Integrated Transport Strategy for public consultation.  These are important documents which will determine the development and growth of the Borough up to 2026.

The Maidstone district committee of CPRE Protect Kent has grave concerns over the suggestions put forward in these proposals, which do not support the regeneration of Maidstone’s town centre that is so desperately needed.  We will be making our thoughts known to the MBC in no uncertain terms.

As a valued supporter of CPRE Protect Kent in Maidstone Borough, you may also wish to respond to these public consultations, and we would urge you to do so.

Our concerns can be summarised as follows:

• The Council is proposing that 10,080 new houses are built in this period. This represents an additional population of about 25,000 at current house occupancy rates, which is nearly a 20% increase on the current population. No particular new services are included to meet this increase other than some minor transport ideas.
• The housing sites proposed are: one along London Road; two of the large fields near the hospital either side of Hermitage Lane; and very large areas either side of Sutton Road in Park Wood, as well as just over 1000 new houses in the major villages.
• In addition there are proposals for major industrial or commercial development at two sites at M20 motorway junctions. At J7, retail and possibly medical services will be allowed around and beyond the Notcutts area.  At J8, industrial and commercial development is proposed on sites which include land where the Kent International Gateway was recently so strongly opposed.
• Industrial and commercial development at these sites will have a major adverse effect on Maidstone’s town centre and the town’s setting in open countryside.

Details can be found on the Maidstone Borough Council website:  http://www.maidstone.gov.uk

The full documents can be viewed, and responses made, online or at the Council’s offices.  Replies to the consultation are required by 1 October 2012.

Your Views Matter

The regeneration potential of the Thames Gateway is undoubted, and we welcome the intent to finally unlock the opportunities to deliver housing at Eastern Quarry. However CPRE Protect Kent remains cautious about the potential erosion of the developer contributions that were agreed as part of the original planning permission for the site.

The developer contributions are intended to provide the necessary infrastructure that makes and enables a new community to come to life. This ‘section 106’ agreement will help to provide the transport links, the education, healthcare and all the other essential facilities that will be required. These developer contributions are absolutely critical, without which other nearby communities services may be overwhelmed by the influx of new residents. Therefore, CPRE Protect Kent believes it will be absolutely crucial to Ebbsfleet’s regeneration that the developers are required to provide sufficient money for the infrastructure.

CPRE Protect Kent also have concerns, after our recent drought, about the strain that a new mass of houses might put on an already stressed water system. We would urge developers to take the opportunity to deliver houses which meet the 21st century’s needs for water and energy efficiency, and not to lower standards in the rush to provide quantity over quality.  The watchword for this development must be ‘sustainability’, both in terms of developer contributions, as well as both water and energy efficiency. Without these conditions being met, we feel that Ebbsfleet may well be a poisoned chalice for the government.

SOUTHERN WATER

APPLICATION FOR DROUGHT PERMIT BEWL WATER RESERVOIR

CPRE STATEMENT.

1.        The Kent Branch (“Protect Kent”) of the Campaign to Protect Rural England exists to promote the beauty, tranquillity and diversity of rural England by encouraging the sustainable use of land and other natural resources in town and country. Our comments on the Drought Permit application relate to the implications for the sustainable management of Kent’s water resources.

2.         Southern Water has made its case to the Environment Agency for a Drought Permit on the grounds that storage in Bewl Water reservoir is now substantially lower than normal for the time of year (approx 41%) and groundwater reserves, which provide 70% of the supplies to Kent’s households are also severely depleted. Bewl Water constitutes the storage element of the Medway Scheme (Licence No 02/114) by which the Company is authorised to pump up to 250 Ml/d to the reservoir from the Medway at Yalding and up to 136 Ml/d into supply from the river at Springfield near Maidstone; subject to a Minimum Residual Flow (MRF) of 275 Ml/d as measured at Teston Weir. This is essentially a “hands – off” flow to protect the biological and chemical quality of the river and the interests of other lawful abstractions. The Medway flow is already below the MRF and SW are seeking authorisation to continue pumping to storage by reference to a reduced rate of 100 Ml/d. The permit, ifgranted will expire on 31^st March.

3.         CPRE recognises the urgent need for the Company to improve the reservoir stock, but it should be noted that the permit is being sought under conditions similar to those which obtained in 2005/06 when we made known our concerns with respect to the lack of investment by the industry in new sources of supply on a scale sufficient to meet the anticipated increase in demand arising from climate change and population growth in the SE. Kent has been officially identified us “Water Scarce” and the situation faced by SW should not therefore come as a surprise. Unfortunately Ofwat, in line with its objective of minimising increases in charges to customers, has actively discouraged water companies from making investment in large scale water resource development schemes. We now see the effect of this short term thinking in the threatened failure of Bewl Water which has a current rated output lower than when first commissioned more than 40 years ago. And with the additions of supply areas in Ashford and Hastings, it is expected to serve a significantly larger population, making it even more drought-sensitive.

4.         Our conclusion is that the Bewl/Medway system can no longer guarantee security of supply without frequent recourse to emergency measures such as those defined in the Permit, and which should in practice only be invoked under exceptionally severe drought conditions. If the Permit is granted, it will have been the second occasion in approx 6 years when SW have been obliged to resort to such measures; and this tells us something about the Company’s capacity to deal with conditions which, although severe, cannot be rated as extreme events.

5.         Defra’s new water white paper “Water for Life”, released in December last year, sets out Governments’ vision of a new coherent strategy for the management of water resources; aiming at a draft Bill later this year. It recognises that resources are already under pressure and that the supply deficit will continue to increase, threatening the environmental quality of our rivers and wetlands. The paper goes so far as to propose a pause on housing development for any given area until a water supply (and sewerage) infrastructure of adequate capacity is put in place. Paragraphs 6.45 – 6.49 of the paper also draw on the findings of a review of Ofwat’s role in determining whether their regulatory approach was “fit for purpose”. A number of areas for improvement were identified, including (Para 6.47), incentivising a more sustainable approach to the use of water resources; looking to keeping bills low in the short term but having a longer perspective on the impact that its decisions are likely to have on affordability and future resilience. It was also acknowledged (6.49) that Government could provide a stronger steer to Ofwat on how it should interpret its sustainable duty. This is to be welcomed as a move toward more balanced assessments of the economic, social and environmental components of resource management strategies.

6.         CPRE, having consistently campaigned for the identification of new sources of supply (e.g. recycled waste water and bulk transfers from other regions with more abundant resources), looks to the Environment Agency to treat this application as another reality check and an opportunity to send the message back to Government that if we fail to invest in a more robust and flexible water resource development strategy, we will have to be resigned to the prospect of drought restrictions becoming a permanent feature of water supply management in Kent.

Night flights at Manston have been an extremely contentious issue for many Thanet residents. Some believe that allowing the flights will bring economic prosperity to the area, with much needed local employment opportunities. Others believe that it is unlikely that many jobs will be created. We took the stance some time ago that we did not believe allowing night flights would bring any real economic benefit to the residents of Thanet, and may in fact bring real harm to the area due to the impacts of noise and air pollution.

We are glad to see that we have been justified in this view by a recently published report authored on behalf of Thanet District Council by Parsons Brinkerhoff, a leading transport consultancy.

This report, which is based on an examination of the documents submitted by Infratil, clearly brings into doubt many of their claims.  Parsons Brinkerhoff indicates that Infratil’s views of the economic benefits are wildly over-optimistic, while the impacts of noise – the major concern of residents in the area – have been seriously understated. These two points alone vindicate the local opposition groups, whose concerns have been regarded by some as backward-looking and ‘nimby-ism’.

The fact that Flybe are pulling out in March because they cannot fill planes is damning proof of the lack of demand for flights out of Manston. We simply cannot see how allowing night flights will help Manston grow as a passenger airport, and therefore generate both jobs and economic sustainability for the area.

In light of this recent report, CPRE Protect Kent would ask that there be a full and unrestricted public consultation before any night flights are allowed. This should be open and transparent, with all the facts available. This will enable the people of East Kent to weigh up the benefits and disadvantages of night flights and lobby Thanet District Council accordingly. It is only right they be given this opportunity, as it is their communities and environment that will be significantly affected by the implementation of night flights.

The county-based campaigning organisation Protect Kent have welcomed David Cameron’s announcement of a public consultation into the proposal for airports in the Thames Estuary.  The two main options currently on the table are the Grain Airport, to be sited on the Hoo Peninsula; and “Boris Island”, which is to be constructed on reclaimed land within the estuary itself.

Andrew Ogden, Campaigns Manager for Protect Kent said:  “While our views on this consultation may appear to contradict our normal stance, we anticipate that this opportunity to share all of the facts and figures behind these proposals will expose them as the futile schemes they are.  Over the past 60 years there have been many ventures to build airports in and around the Thames Estuary, but none have ever passed the planning stage.”

Andrew continued: “Together with other campaigning and environmental groups, we will be presenting our case against these airports in response to the consultation. We will also be calling for a referendum to be held amongst all residents likely to be impacted by these proposals, both sides of the estuary.”

Protect Kent claims there are a multitude of reasons for these airports not to go ahead, some of the main arguments being:

• The disastrous impact on large areas of land both north and south of the Thames, due not only to the airport but also from the necessary supporting infrastructure;
• The impact on local people and communities, not least from the continuous take-offs and landings, day and night;
• The environmental implications of an airport with multiple runways, particularly on air quality and tranquillity;
• The ecological importance of international significance of the chosen sites and the surrounding region;
• The negative financial viability: for a giant airport to be created off the Kent coast all three main airports around London would need to close, and the land sold off for development.
• The weakness of the business case, given the current decline in air travel and the rise of more appropriate alternatives such as high speed trains.
• The misleading messages about employment. We would not see the creation of new jobs, but the movement of employment from Heathrow, Gatwick and Stansted, as airlines and businesses move their operations.

Protect Kent have expressed concern that Kent County Council are doggedly pursuing “Growth without gridlock”, their transport strategy for Kent for the next 20 years, despite the flaws it contains and the widespread opposition to some of the schemes from the people of Kent.

Earlier today, at KCC’s “Policy Overview and Scrutiny Committee” meeting for environment, highways and waste, an update on Growth without gridlock was delivered, covering the major proposals for a third Thames Crossing, a solution to Operation Stack, dualling of the A21 between Tonbridge and Pembury, and rail improvements for East Kent.  It also covered the thorny issue of funding for these schemes, seeking to avoid direct contribution from the public purse.

Almost no alternatives remain on the table.  There will be a Third Thames Crossing, despite the fact that removing the existing tolls at Dartford would solve the congestion problems at the crossing “at a stroke”.  An enormous lorry park will be built at Aldington, near Sellindge, despite other options including parking at the Port of Dover.  And the Thanet Parkway Rail Station is still being promoted as essential to the development of Manston airport, even though Flybe (the only scheduled flight operator at Manston) have announced their intention to withdraw their operations in March.

Possibly the only scheme that is sensible and receives widespread support is the improvement and dualling to the A21 between Tonbridge and Hastings.  This is long overdue, and would do much to improve safety and air quality in the area, as well as remove congestion and hence relieve some of the stress for motorists.

Andrew Ogden, Campaigns Manager at Protect Kent said:  “KCC appear to be pursuing all of the schemes within their transport strategy with blatant single-mindedness, as though sheer determination will make them acceptable in the eyes of the public.  There certainly does not appear to be room for open debate on all possible options to solve our transport problems.  In fact, it appears that KCC have decided there is but one solution – theirs, which must be the right one – and nothing else will be entertained”.

Andrew continued:  “However, as everything is still at the planning stage, it is not yet too late for KCC to open-up a consultation on their proposals.  This will ensure we arrive at the best possible transport solutions for Kent, its people and communities.  We encourage KCC to take up the challenge of a public debate.”

No, Protect Kent are not stating that there will be a drought next year – but that is only because there has not been any formal declaration made to that effect! However, based on the current water resources situation, the risk of parts of Britain, especially the South East, enduring drought measures next summer is becoming very likely.

Autumn has come and gone, but the usual weather patterns and rainfall were noticeably absent.  November continued a pattern set in the preceding months of Autumn, receiving under 60% of the rainfall that is considered ‘normal’ for this month. Reports from the Environment Agency show that “the last three months have been the fifth driest September – November period since 1910” and “2011 has experienced the fourth driest January to November period”.
However, should our weather ‘return to normal service’ over December and the following months, and we receive rainfall commensurate with this time of year, drought measures can be avoided.  This will in part be due to appropriate measures incorporated within water companies’ Water Resource Management Plans – something Protect Kent have encouraged in the past.
So what does next year have in store for us ‘water-wise’?
Well, the first Drought Order in the South East is likely to be in operation in early January.  South East Water have applied to Defra for a specific Order, to enable them to replenish stocks in Ardingly Reservoir (serving 72,000 homes across East and West Sussex) over the winter period.  This will happen irrespective of future rainfall, as the amount of “usable” water currently available in the reservoir is only about 12%.
Should a formal drought be declared, then we must expect to see a number of other applications for Drought Orders being issued by water companies.  In Kent, our major surface water source is Bewl Water, near Lamberhurst, which was approaching minimum levels at the end of November.  But at the moment Southern Water are just keeping a watchful eye on the situation. Thankfully, in Kent, around 70% of our potable water is supplied from groundwater sources, which at present are generally healthy.
Protect Kent will also be keeping a watchful eye on the situation … and you can expect to read more about this serious issue, should the situation worsen.