Page 15 Agenda Item 5b
8 week date Application No. Date of meeting Report No.
24.06.09 GR/2009/0238 29.07.09
The Former Northfleet Cement Works, The Shore, Northfleet, Kent
Outline application for a mixed development and comprising up to 510 homes, up to 46,000 sq m employment floorspace (B1/B2/B8), mixed use neighbourhood centre comprising up to 850 sq m of retail/cafe/takeaway (A1/A2/A3/A5) and D1 community centre, up to 500 sq m A3/A4 food and drink uses, public open space, fastrack link, street and footpath network, access improvements to Grove Road/The Creek and The Shore/Crete Hall Road, supporting services and infrastructure, ground re-grading, other minor works and development ancillary to main proposals together with associated car parking and landscaping for the development.
Lafarge Cement UK
Recommendation:
This is an interim report for information of the Board and not for decision at this stage.
The Board are asked to consider and endorse the key issues that are identified in the report and to suggest any other issues that they consider should be appraised by the applicants.
1. Site Description
The application site covers an area of 30.97ha.
The application site is located on land within the former Northfleet Cement Works in the west section of what is known as Northfleet Embankment.
The site is bounded by the River Thames to the north, dissected by the B2175 Northfleet High Street and bordered by the North Kent Railway Line to the south. To the east lies Kimberly Clarke tissue paper mill and the west are Robin’s Creek and existing industrial areas.
The whole of the Cement Works site is around 42.2 ha in size including land in Vineyard Pit and Church Path Pit.
Northfleet is the home of Portland Cement and bulk powders have been manufactured, imported, exported and packaged at Northfleet Works site for the last 150 years. Over the years the extraction of chalk and the resultant level changes has created a fragmented landscape with varying levels.
The works site can be split into four distinct areas:
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• Church Path Pit – a former quarry lying between the B2175 and the North Kent Line accessed by tunnel from the main works site, the western branch of this quarry is known as St Botolph’s Pit;
• Northfleet Works – the current site of the cement works laid out on a level quarry floor between the B2175 and 42 Wharf on the River Thames;
• The former Bevan’s Works Site – the area to the west of Lawn Road including the main site access and land rising up from the river front towards the existing residential community of Northfleet; formerly the site of Bevans Cement Works; and
• Vineyard Pit – a small quarry on what is the main road access into the works lying between the B2175 Northfleet High Street and the North Kent Railway Line.
Bevan’s works dates from 1926 with significant upgrades in 1958 but itself was a wholesale replacement of the Knight, Bevan and Sturge works originally dating from the 1850’s but reconfigured in 1905.
Church Path Pit and Vineyard Pit are 19 th Century chalk quarries. Vineyard Pit until 2008 contained 2 large fuel oil tanks and an associated pump house which have now been removed as part of the decommissioning works. There is an electricity distribution area to the east of Church Path Pit but this is not within the application site. The southernmost part of Church Path Pit contains railway infrastructure associated with the Ebbsfleet International and domestic railway stations which are situated further to the south. Church Path Pit used to contain part of the ‘merry go round’ rail system from the Cement Works to Northfleet Station and Northfleet sidings.
There are two wharfs to the river frontage of the cement works - Bevans Wharf, a wooden structure located within the river, which in more recent years has been used only for the occasional import and export of bulk powders; and 42 Wharf, a working wharf, so named because of its 42 feet depth, which has been used for the import and export of cement bulk powder/cement clinker and the import of fuel, and is one of the best deep water wharfs in the South East Region with the potential for reinstated rail links.
The waterfront to the River Thames is formed of man-made flood protection walls. Between 42 Wharf and the Shore, at the east end of the site, there is a small inlet which forms a beach at low water. Currently public access to the riverside is restricted with some limited public access available at the Shore adjacent to the east entrance to the Cement Works.
The Cement Works is characterised by industrial utilitarian buildings of varying scales and heights with conveyors and silos. They are mostly steel structures clad in mineral compound sheeting. Some areas are devoid of buildings such as south of Bevans works site where much of the land is derelict apart from the existence of the Bevans chimney which dates from 1958. There is an existing seven storey office building on the site which is located next to The Shore and alongside 42 Wharf. It was built in the Brutalist architectural style. The office building currently accommodates the Port of London Authority (PLA) radar equipment.
In April 2008 the cement kilns ceased to operate, since then there has been on-going grinding of clinker; the cement works ceased operations in December 2008 and, is in the process of demolition on a staged basis. The demolition works will include the removal
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of the industrial buildings, the office building, the chimneys and Bevans wharf. The wharf is to be demolished as it is according to the applicants reaching a point where significant repair and upgrading would be required.
An element of cement based activity is still continuing in the form of the import and distribution of bulk powders via 42 Wharf following a planning permission granted in 2005.
The wider Northfleet Embankment is traditionally an area of heavy industry and employment including manufacturing, a tissue paper mill, aggregates import, a builder’s yard and vacant plots. The settlement of Northfleet lies to the south of the site. Land use here is predominately residential, with some commercial use comprising shops and services at The Hive. Lawn Road School is located immediately to the south of the main cement works site.
The main road access into the Northfleet Cement Works is privately owned and runs from a roundabout junction on A2260 Thames Way (also known as STDR 4) underneath the North Kent Railway Line and through Vineyard Pit before entering the site via a tunnel under Northfleet High Street. Other road linkages exist from Grove Road to the west and The Shore/Crete Hall Road to the east.
There are a number of public footpaths that are located within and adjoining the application site - NU42 runs from High Street Northfleet along the length of Lawn Road in a northerly direction and into the works site before turning eastwards along the Shore to Granby Road; NU3 that runs in a northerly direction from Hive Lane towards the old Bevans Works and NU6 that runs from the Bevans Works to join Grove Road. Public Footpaths NU7 and NU8 cross at a high level over Church Path Pit but are not within the works site and NU4 adjoins the eastern side of the Cement Works site along Granby Road. Footpath NU7a on the other hand does run alongside part of the road access from Thames Way into Vineyard Pit and across towards Blue Lake where it links with footpath NU14 as well as running north to High Street Northfleet.
The application site for the mixed use development comprises the western section of the Northfleet Cement Works site. It includes Grove Road at the western end of the Cement Works. It excludes Robins Creek also at the western end of the Cement Works where the Ebbsfleet River enters the River Thames. The outlet at Robins Creek is controlled via a sluice and vegetation has colonised the area around the creek. Robins Creek is principally in the ownership of the Environment Agency. It performs a floodwater storage function for the Ebbsfleet River where tide lock prevents discharge to the River Thames and comprises some mud flats and pioneer vegetation.
2. Planning History
The Northfleet Works including the application site has a long history of industrial use. Cement manufacturing on the site of the present day Northfleet Works began in the 1850s with the construction of Bevans Works. This was reconstructed twice before elements of it were incorporated within the new Northfleet Works, constructed between 1969 and1970. Served by road, rail and water, Northfleet Works on its opening was the largest cement works of its kind in the world. As built, rail traffic was intended to be 21 coal trains per week, bringing in 1 Mt/a of coal and 9 trains of gypsum inwards per week (250,000 t/a required). Cement production totalled 3.8 Mt/a of which 1.3 Mt/a cement was despatched by rail (about 18 trains per week) and the remainder by water for export and by road for UK consumption.
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The closure of Northfleet Cement Works, due to the exhaustion of its main permitted raw material (chalk from Eastern Quarry) has been in the public domain for many years prior to occurring in April 2008. Planning policy dating back to 1994 has identified opportunities for elements of the Northfleet Works site to be redeveloped for other uses. Planning applications for Medway cement works at Holborough, as a replacement for Northfleet, were approved in 2001 following two public inquiries.
A Section 106 agreement required Lafarge, amongst other things, to cease activities at Northfleet and to work with the County and Borough Councils to formulate proposals for the redevelopment and use of the site by participating in Local Plan reviews and, specifically, by preparing Master Plans for the redevelopment of Northfleet Works.
The principle of closing and redeveloping Northfleet Cement Works has, therefore, been a fundamental plank in local and strategic land use planning for a decade and was specifically endorsed by the Government by allowing development of Green Belt land for Medway Cement Works in order, in part, to release Northfleet Works for redevelopment as soon as possible, and by planning for that redevelopment through a legal obligation upon Lafarge.
The first element of this redevelopment was permitted in 2005 when planning permission was granted by the Borough Council for the construction of a Bulk Powders Import Terminal handling up to 1 million tonnes of bulk powders per annum with material imported across 42 Wharf. The Bulk Powder Import Terminal has been completed and is now operational. It lies at the east end of the works site adjacent to the application site.
In terms of specific historic features, within the site adjacent to the main office building on the waterfront is the Bevans war memorial. This commemorates those killed in World War I. The memorial is Grade II listed and is an important historic feature which is proposed to be relocated as part of the redevelopment to a more sensitive and appropriate setting. Separate detailed proposals for the relocation of the war memorial will be made as part of a separate planning and listed building consent application to be made to the Borough Council.
The other Grade II listed building within the wider Northfleet Works site is the Port of London Authority owned Northfleet Lower Lighthouse located at the eastern end of 42 Wharf. This will remain in its present position and will retain its industrial setting.
Outside of the application site, but forming part of the overall context, lies a Conservation Area at The Hill, forming the historic core of Northfleet. Six listed buildings are located within the Conservation Area. These include the Grade I listed Parish Church of St Botolph, which is just to the east of Church Path Pit. The church dates from the 14th century and forms a focal point for a triangular open space at the historic core of the village which lies in an elevated position above the site. A further prominent listed building and local landmark is Sir Giles Gilbert Scott’s Roman Catholic Church of Our Lady of the Assumption .
Aspdin’s Kiln, to the south of Robin’s Creek, is a Scheduled Ancient Monument and the oldest surviving cement kiln in the world. The kiln is currently surrounded by employment development and is not visible from public vantage points.
A full description of the historic context of the site is set out in the Cultural Heritage chapter of the Environmental Statement.
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3. Proposal
The application is an outline planning application with all matters reserved for detailed planning consideration. It is submitted by David Lock Associates as planning agents for Lafarge Cement UK.
A sister application (reference GR/2009/0286) for full planning permission for a Bulk Aggregates Import terminal has been submitted to Kent County Council as Minerals Planning Authority in association with the continuing use of 42 Wharf.
The outline application to this Council seeks to develop the Northfleet Works site as a mixed used development comprising the following land uses:
• Up to 510 homes, related car parking and landscaping (C3);
• Up to 46,000 sq m employment floor-space, related car parking, servicing and landscaping (B1/B2/B8);
• Mixed Use Neighbourhood Centre comprising up to 850 sq m of retail/café/takeaway floor space (A1/A2/A3/A5), community centre (D1) and related car parking and landscaping;
• Riverside Food and Drink Uses comprising up to 500 sq m of pub or food and drink uses (A3/A4)
• Public Open Space including riverside promenade, public park with equipped play areas, playing field with shared public/school use and wildlife corridors;
• Fastrack link to provide a segregated link across the site along with Fastrack stops;
• Street and Footpath Network to provide access to development and maintain and enhance existing public rights of way, including a bridge link between Hive Lane and Factory Road;
• Access Improvements to Grove Road/the Creek and the Shore/Crete Hall Road and other associated highway improvements;
• Supporting Services and Infrastructure including new utilities, enhanced flood defences and providing for access to cliffs and tunnels ;
• Ground re-grading to create efficient development and open space platforms and to raise land to address flood risk;
• Other minor works and development ancillary to the main proposals including the principle of relocating the Scout Hut within the site.
The application is accompanied by the following supporting documentation:
Application Drawings and Parameter Plans:
• Mixed Use Planning Application Boundary • Existing Ground Levels
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• Proposed Ground Levels • Existing/Proposed Ground Sections • Proposed Building Heights Plan • Proposed Site Access Plan • Indicative Cut and Fill Analysis • Demolition Plan • Proposed Green Space Plan • Proposed Access Parameters Plan • Proposed Land Use Plan • Development Framework Plan • Indicative Phasing Plan Phase 1-2009 to 2011 • Indicative Phasing Plan Phase 2-2012 to 2014 • Indicative Phasing Plan Phase 3-2014 to 2020 • Indicative Phasing Plan Phase 4-2020 to 2022
Planning Statement
Design and Access Statement
Environmental Statement covering the following topics:
• Transportation and Access • Air Quality • Noise and Vibration • Hydrology and Flood Risk • Socio- Economic and Community • Landscape and Visual Impact • Sunlight and Daylight Analysis • Geotechnics and Soil Contamination • Waste • Cultural Heritage • Ecology and Nature Conservation
Environmental Statement: Non-technical Summary
Transport Assessment
Flood Risk Assessment (including Drainage Strategy)
Sustainability Strategy and Appraisal
Phasing and Implementation Strategy
Land Stability Statement
Extent of the Site
The mixed use planning application comprises 30.97 ha of the overall works area.
The application boundary includes the development area and land required to provide the required access including tunnels underneath the B2175 Northfleet High Street and the North Kent Railway Line. Within Church Path Pit land required for the
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reinstatement of the rail link to Northfleet Works is excluded from the application boundary except for where a private level crossing is proposed. The reinstatement of the rail link is addressed in the Bulk Aggregates application.
The application boundary includes land running to the south of 42 Wharf that is proposed to form an east-west Fastrack and pedestrian/cycle link to The Shore. This land is included such that permission can be obtained for the Fastrack Link. This land also forms part of the application area for the proposed Bulk Aggregates Import Terminal such that permission might be obtained to the principle of reserving the land for a Fastrack Link and for conveyors etc. crossing over the Fastrack Link connecting 42 Wharf and the proposed Bulk Aggregates Import Terminal.
The application site includes Chimney View Park, a community park located to the north of The Hive and in the same area a Scout Hut used by the 5 th Northfleet Scouts.
The Plans
The development framework plan submitted with the application sets out the disposition of land uses. This is supplemented by an Illustrative Master Plan which indicates how the development could be laid out and shows a network of open spaces.
The proposals include groundworks to raise the waterfront residential element out of the flood risk area and to rationalise the slope of the land down Hive Lane to the riverside. Plans show existing ground levels and indicative proposed ground levels and sections although it is intended that the detailed ground levels are the subject of a later approval as a result of a planning condition. It is suggested in the application that all lowering or raising of ground levels can be undertaken without importing/exporting of fill materials.
Residential
The application proposes up to 510 dwelling units on the western half of the site, 30 per cent of which would be affordable dwellings.
A mix of house types are proposed but it is suggested that family housing would predominate with apartments employed extensively on the river frontage.
There is no indication given of the specific mix house types or balance between houses and apartments and there are no illustrative drawings. Average densities are however indicated as ranging from 61 to 132 dwellings per hectare.
Employment
Employment floorspace is indicated as being up to 46,000m 2 located on the eastern half of the site and in Vineyard Pit and Church Path Pit.
The main vehicular access will be via the main works access through Vineyard Pit and which will be retained as access to the existing Bulk Powders Import Terminal and the proposed Bulk Aggregates Import Terminal.
It is stated that there would be a broad range of employment – B1 (Offices/Light Industry), B2 (General Industrial) and B8 (Storage and Distribution).
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The application does not indicate the precise amount and distribution but an indicative split is assumed for the purpose of the Environmental Statement and Transport Statement.
Retail
The application proposes a neighbourhood centre (up to 850m 2) comprising small scale retail units adjacent to Hive Lane. This would include a convenience store as an anchor unit and other units within classes A1 (shops), A2 (Financial and Professional Services), A3 (restaurants/cafes), A4 (Drinking Establishments) and A5 (Hot Food Take-away).
No indication is given however as to how the floorspace and retail need has been derived.
It is indicated that there would be apartments over the shops.
An additional 500m 2 of A3 (Restaurants), and A4 (Drinking Establishments) are proposed on the river front mixed with apartment blocks.
Community Uses
A community hall is proposed perhaps as a ground floor unit within the local centre.
No additional schools are proposed as it is envisaged that any additional provision would take place with the expansion of Lawn Road School. A new playing field for the school shared with public use is proposed to the north of the existing school.
No additional health provision is proposed.
It is proposed the existing Scout Hut on the site would be relocated elsewhere but the precise site would emerge through detailed master planning work.
Open Space/Sports Provision
The application proposes a network of open spaces in line with Green Grid principles.
A junior playing field for shared school/public use is proposed to the north of Lawn Road School to address the need for additional Play space at the school. A combined Locally Equipped Area for Play (LEAP) and Neighbourhood Equipped Area for Play (NEAP) within the residential area are proposed as a replacement for Chimney View Park.
Scale of Development
The precise scale of each proposed building is not defined at this stage in the application which according to the applicants is in order to retain an appropriate and necessary degree of flexibility for the detailed design of proposals in the future. Parameters have been set for the upper and lower limits of the height, width and length of each building proposed.
The building heights plan indicates the maximum height of each development block, thereby setting the parameters for development within a built envelope. Residential
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development will vary from 2 to 3 storeys to up to 7 storeys at the riverfront. Employment buildings are proposed to be up to 12m in height.
The building heights plan identifies areas within the master plan where landmark buildings are suggested as being suitable. In these locations building heights may increase by up to 2 storeys over and above the general height identified. Building heights may also increase by one storey at corners and junctions over and above the general building height identified as a design response to create a suitable urban form.
The full building parameters and their tolerances suggested are as follows:-
Land Use Building Building Building Depth Frontage Height Range Range Range Residential 5m-20m 4.5m-110m 6m-27m Mixed Use including retail, 5m-50m 5m-100m 5m-21m food and drink and community uses Employment 8m-110m 5m-350m 6m-27m
Vehicular and Pedestrian Access
Vineyard Pit will remain the main HGV and vehicular access point into the proposed development, and will also be the main point of vehicular access for the sister Bulk Aggregates Import Terminal proposal. Footpath NU7A will be improved in this area and where it passes through the south of the two tunnels. While appropriate pedestrian access will be provided to serve new employment uses within Vineyard Pit, it is proposed that no cycle or pedestrian access is provided through the northern tunnel under Northfleet High Street.
College Road will provide some local vehicular access to new dwellings fronting onto it. Otherwise, all new connections made to College Road will involve pedestrian and cycle links only.
Grove Road/the Creek will provide a second main access point into the development. As well as providing for vehicular access to the site, this will also provide Fastrack access into the site. While comprehensive segregated Fastrack proposals are made within the site, the applicant advises that they unable to propose these improvements between the site and the Stonebridge Road roundabout. They advise that this is primarily due to lack of land control, and also a reflection that regeneration proposals for the area along this part of Grove Road have not yet sufficiently matured for detailed proposals to yet be made.
Interim measures for the improvement of Grove Road to accommodate development traffic are included within the Transport Assessment. These set out interim improvements that can be delivered by the applicant within highway boundaries and within land under its control and which will not in any way prejudice opportunities to secure further improvements in due course.
Hive Lane will be extended and realigned to form a new vehicular, cycle and pedestrian access to the residential part of the proposals. The route has been realigned to create glimpses toward the river and Hive Lane will form a key link between the existing
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community and the river. A new footpath link is proposed linking Hive Lane to Factory Road/Lawn Road to provide an alternative school route to new residents.
Lawn Road footpath will retain a role in providing pedestrian and cycle access to the site. The Design and Access Statement sets out detailed proposals for the Lawn Road headland and how the path will provide access to a viewing point, to the proposed school/public playing field and to the employment elements of the development and riverside.
Access to the Shore and Crete Hall Road is proposed for Fastrack vehicles as part of a wider proposed Fastrack link across Northfleet Embankment. Pedestrian and cycle linkages east-west across the rear of 42 Wharf to this area are also proposed to retain the right of way that currently exists as footpath NU42 and to form part of the wider Thames Path initiative. Pedestrian and cycle links in this area will continue to link with Granby Road.
Under the sister Bulk Aggregates Import Terminal application HGV access is retained to the Shore/Crete Hall Road for Lafarge vehicles only, in effect maintaining the existing access arrangements associated with Northfleet Works.
Access to Church Path Pit is via the westerly of the two former rail tunnels under Northfleet High Street. This will be improved to provide access to all travel modes. Within Church Path Pit a private level crossing will provide access across the reinstated rail link proposed as part of the sister Bulk Aggregates Import Terminal planning application. Emergency access to Church Path Pit will also be provided from an access road linking under the North Kent Line from Blue Lake to the south of the site.
Phasing and Delivery
The indicative phasing plans submitted with the application indicate the applicant’s intention to develop the site in a phased manner. It is suggested that the development will be undertaken in four principal phases which allow demolition, land raising, provision of access and construction to come forward in a timely manner. The indicative timescales for the four phases are set out below and for completeness this includes the sister proposals for the Bulk Aggregates Import Terminal and its associated rail works. Works that do not require the benefit of planning permission such as demolition are also included.
Phase 1 2009-2011 Phase 2 2012-2014 Phase 3 2014-2020 Phase 4 2020-2022
Phase 1
• protection of war memorial; • demolition of Northfleet works; • removal of HV cable and pipe from Vineyard Pit; • translocation of protected species to Church Path Pit.
Phase 2
• land raising and re-grading of residential parcels, Church Path Pit and
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Vineyard Pit; • retention/creation of primary HGV access; • relocation of war memorial; • creation of rail facilities; • construction of Bulk Aggregates Import Terminal; • removal of Bevans Wharf; • construction of mixed use centre.
Phase 3
• off-site access improvements to Grove Road and the Shore; • construction of employment areas in part of Church Path Pit, Vineyard Pit and east of Lawn Road; • construction of residential units; • creation of formal open space, equipped play areas and footbridge; • commencement of riverside promenade; • construction of mixed use area adjacent to the Thames; • creation of Hive Lane; • construction of Fastrack corridor.
Phase 4
• construction of final element of Church Path Pit employment; • construction of riverside apartments; • completion of riverside promenade.
Conditions and Heads of Terms
The application planning statement includes suggested planning conditions to control the level of development, the submission of reserved matters, design codes, external materials, drainage, archaeology, ecology, children’s play, cliff stabilisation and a travel plan.
The applicants also indicate a willingness to enter into a legal agreement under section 106 of the 1990 Act with suggested covenants to the Borough Council for funding for community facilities, provision of affordable housing, a local centre brief, management of public areas, and covenants with Kent County Council for funding contributions towards new highway works or improvements to public highways, a contribution to the provision of new public transport services, and land and provision of a junior playing field for shared school and public use.
4. Development Plan
The Development Plan comprises the Regional Spatial Strategy and the Development Plan Documents (taken as a whole) which have been adopted or approved in relation to the area. These include:-
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The South East Plan (adopted 6 May 2009) which has recently replaced Regional Planning Guidance for the South East RPG9 (2001) as the Regional Spatial Strategy (RSS)
The Gravesham Local Plan First Review (adopted November 1994);
There are a number of other un-adopted planning documents (e.g. The Gravesham Local Plan Second Review) which are of some relevance to the consideration of this planning application and which are also referred to in this section together with national planning advice and guidance.
(It should be noted that in respect of strategic planning guidance the Kent and Medway Structure Plan ceased to have effect as a development plan document after 6 July 2009 and the relevant policies are only referred to here on the basis that the application was submitted while the KMSP was still in force and because the application documents refer to the KMSP policies as giving support to the proposals).
Regional Planning Guidance
South East Plan
The Regional Spatial Strategy (RSS) for the South East of England (known as the South East Plan) sets out the long term spatial planning framework for the region over the years 2006-2026. The Plan is a key tool to help achieve more sustainable development, protect the environment and combat climate change. It provides a spatial context within which Local Development Frameworks and Local Transport Plans need to be prepared, as well as other regional and sub-regional strategies and programmes that have a bearing on land use activities. These include the regional economic and housing strategies as well as strategies and programmes that address air quality, biodiversity, climate change, education, energy, community safety, environment, health and sustainable development.
The Plan includes spatial policies for:
• the scale and distribution of new housing • priorities for new infrastructure and economic development • the strategy for protecting countryside, biodiversity and the built and historic environment • tackling climate change and safeguarding natural resources, for example water and minerals
In the South East Plan Kent Thames-side Core strategy policy is as follows:-
POLICY KTG1: CORE STRATEGY
Local and central government, and all parties concerned with service provision and infrastructure, will co-ordinate their policies and programmes to:
i. as a first priority, make full use of previously developed land before greenfield sites, except where there are clear planning advantages from the development of an urban extension that improves the form,
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functioning and environment of existing settlements or a new community
ii. locate major development in order to exploit the potential of the regional hubs at Ebbsfleet and the Medway Towns and locations served by the Channel Tunnel Rail Link, and locate housing, employment and community services where they are accessible by a choice of transport
iii. ensure that the benefits of new services and employment are available to existing communities, and that new development is carefully integrated with them
iv. raise the standards of education and skills in the workforce, including support for higher and further education, and achieve economic development and inward investment at an accelerated pace
v. greatly increase the supply of new housing, and affordable housing in particular
vi. set high standards for the design and sustainability of new communities, and for improvement of the existing urban areas, reflecting the riverside and historic character of the area
vii. create higher density development in the main urban areas, linked by public transport to one another and to London
viii. review local planning and transport policies to manage the forecast growth in car traffic related in particular to employment in the area and encourage greater use of sustainable modes
ix. make progress in the transfer of freight from road to rail and by water, by improving the links between international gateways and the regions, including freight routes around London
x. protect from development the Metropolitan Green Belt, the Area of Outstanding Natural Beauty and avoid coalescence with adjoining settlements to the south, east and west of the Medway urban area and to the west of Sittingbourne.
Other relevant policies in the South East Plan are:
Area Policies
KTG2: Economic growth and Employment KTG3: Employment Locations KTG4: Amount and Distribution of Housing Development KTG6: Flood Risk KTG7: Green Initiatives
Spatial Strategy Policies
SP3: Urban Focus and Urban Renaissance SP4: Regeneration and Social Inclusion
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Cross Cutting Policies
CC1: Sustainable Development CC2: Climate Change CC4: Sustainable Design and Construction CC6: Sustainable Communities and Character of the Environment CC7: Infrastructure and Implementation CC8: Green Infrastructure
Sustainable Economic Development Policies
RE3: Employment and Land Provision
Housing Policies
H1: Regional Housing Provision 2006-2026 H2: Managing the Delivery of the Regional Housing Provision H3: Affordable Housing H4: Type and Size of New Housing H5: Housing Design and Density
Transport Policies
T1: Manage and Invest T2: Mobility Management T4: Parking T5: Travel Plans and Advice
Natural Resource Management Policies
NRM1: Sustainable Water Resources and Groundwater Quality NRM2: Water Quality NRM4: Sustainable Flood Risk Management NRM5: Conservation and Improvement of Biodiversity NRM9: Air Quality NRM10: Noise NRM11: Development Design for Energy Efficiency and Renewable Energy
Waste Management Policies
W6: Recycling and Composting
Countryside and Landscape Policies
C7: The River Thames Corridor
Management of the Built Environment Policies
BE1: Management for an Urban Renaissance BE6: Management of the Historic Environment
Social and Community Infrastructure Policies
S1: Supporting Healthy Communities
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S2: Promoting Sustainable Health Services S3: Education and Skills S5: Cultural and Sporting Activity S6: Community Infrastructure
Note: There are a number of other regional planning documents that have been referred to in the planning application by the applicants as providing policy support to the proposals including Regional Planning Guidance for the South East (RPG - 2001), The Thames Gateway Planning Framework (RPG9a – 1995), Strategic Planning Guidance for the River Thames (RPG3B/9B – 1997), Thames Gateway Interim Plan: Policy Framework (November 2006 ), Sustainable Communities: Building for the Future (February 2003) and Creating Sustainable Communties: Making it Happen: Thames Gateway and the Growth Areas (July2003). However many of these have now been superseded by the South East Plan.
Strategic Planning Guidance
Kent and Medway Structure Plan 2006
The Kent and Medway Structure Plan was approved on 6 July 2006 and provided strategic planning guidance in Kent for the period 2001 to 2021. The structure plan however ceased to have effect as a development plan after 6 July 2009.
The following strategic policies of the Kent and Medway Structure Plan were relevant considerations when the application was originally submitted:
Policy DG1: Dartford and Gravesham Policy EP2: Employment Land Provision Policy QL1: Quality of Development and Design Policy QL5 : Mix of Uses on Sites Policy TP3: Transport and the Location of Development Policy TP12: Development and Access to the Primary/Secondary Road Network Policy TP15: Development Traffic & Heavy Goods Vehicles Policy TP19: Vehicle Parking Standards Policy NR10: Development and Flood Risk Policy NR7: Air Quality Management Areas
Local Planning Guidance
Gravesham Local Plan First Review 1994
The Local Plan is still the current adopted plan. A substantial number of policies of the Gravesham Local Plan First Review have been saved by a Direction dated 25 September 2007 of the Secretary of State under paragraph 1 (3) of Schedule 8 to the Planning and Compulsory Purchase Act 2004.
In the Local Plan Proposals Map part of the mixed application site, mainly the site of the old Bevans cement works, is shown as being within an existing industrial area and subject to policy E1. This states:-
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Policy E1: Existing Industrial Areas
In the existing industrial areas shown on the Proposals Map, the Borough Council will give priority to the need for employment. In these areas, proposals which will generate additional employment of all types, whether industrial or not, will normally be permitted except where such proposals would be in conflict with Policy S1. All proposals will be expected to take into account the requirements relating to design, environmental protection and parking set out elsewhere in this Written Statement.
The western area of the mixed use site is shown as being subject to Area Policy AP13. This states:-
Policy AP13:
In the area shown on the Proposals Map, the Borough Council will not oppose in principle partial redevelopment for a commercial or mixed development, provided this is consistent with the amenity of adjacent residential properties and results in a substantial improvement in the environment of the area. The Borough Council will seek the preparation of a planning brief.
The area immediately north of The Hive between College Road and Hive Lane is shown as being subject to policies PLT1 and M1, being a site for additional open space and for restoration of derelict land. These policies are as follows:-
Proposal PLT1: Additional Open Space including Public Open Space and/or Playing Fields
The following additional areas of land are identified on the Proposals Map for open space purposes, including public open space and/or playing fields:-
(i) Land north of Thames Way, Northfleet 9.2 ha (ii) South of Riverview Park 0.5 ha (iii) Third Avenue, Northfleet (part)* min. 0.40 ha (iv) College Road, Northfleet 1.9 ha (v) Waterton Avenue, Gravesend 1.3 ha (vi) Wombwell Hall (Phase 1), Northfleet* 0.4 ha (vii) Campbell Road Chalk Pit, Gravesend (after restoration) 1.48 ha (viii) Dover Road Pit, Northfleet (after restoration) 0.78 ha (ix) Bat and Ball Ground, Trafalgar Road, Gravesend 2.4 ha (x) Ordnance Road, Gravesend 0.76 ha
and as part of the development of major sites at:-
(xi) West of Wrotham Road, Gravesend* 9.2 ha (xii) North East Gravesend* Undetermined
Policy M1: Restoration of Derelict Land
In seeking derelict land grants, the Borough Council will concentrate its efforts (where necessary in conjunction with other agencies or private developers) on schemes which will reclaim and bring into use sites within the Borough, particularly where this would increase employment and on schemes which would result in significant environmental improvements. In considering
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proposals the Borough Council will have regard to the protection of the wildlife value of derelict sites.
The following sites, as indicated on the Proposals Map, are considered to be the priorities for concerted action to create employment or recreational facilities, using derelict land grants as necessary:-
(i) Land at College Road, Northfleet (ii) Land at Grove Road, Northfleet (iii) Thames and Medway Canal (See Proposal PLT3) (iv) The former Gravesend West Railway Line (See Proposal PLT2) (v) Pit south of Dover Road, Northfleet (vi) Campbell Road Pit, Northfleet
The area of the Northfleet Cement Works on the east side of the site including the land within the sister application for aggregates is shown in the Local Plan as an existing industrial area (policy E1) and also subject to Channel Tunnel Safeguarding under policy T14.
The following Local Plan First Review policies are relevant considerations to this application.
Policy R1: Commercial River Frontage Policy
In the commercial riverside, as shown on the Proposals Map, the Borough Council will have a preference for development adjacent to the river which requires a riverside location and makes use of the river as a means of transport. Any new buildings will need to be set back sufficiently from the water's edge, to enable access to be achieved to the river for wharfage purposes. Where appropriate and consistent with safety, a public riverside walkway or riverside access will be expected.
Other general policies relevant to the development are:
Policy H2: Residential Layout Guidelines Policy H6: Provision to Meet Special Housing Needs Policy S2: Change of Use to Shopping Policy S6: Local Centres Policy TC1: Design of New Developments Policy TC10: Landscapes Policy LT1: General Leisure Provision Policy LT5: Additional Open Space and Playing Fields Policy LT6: Additional Open Space in Housing Developments Policy T1: Impact of Development on the Highway Network Policy T2: Channelling Traffic onto the Primary and District Distributor Network Policy T3: Development not well related to the Primary and District Distributor Network Policy T5: New Accesses onto Highway Network Policy P3: Vehicle Parking Standards
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Gravesham Local Plan Second Review 2000
The Draft Gravesham Local Plan Second Review Deposit Version 2000 (Draft Local Plan Second Review) has been adopted by the Borough Council for development control purposes but in view of the provisions of the Planning and Compulsory Purchase Act 2004, it is not being progressed any further. Nevertheless, it remains a material consideration. It is acknowledged that the policies are of limited weight but that the weight which can be attached to its policies is greater where the policies are consistent with Government guidance and with policies of the adopted Local Plan First Review and the adopted Kent and Medway Structure Plan.
The following Local Plan Second Review policies are particularly relevant to this application.
Policy MDS3 Northfleet Cement Works/Land East of Grove Road
In the event of the Northfleet Cement Works becoming available for redevelopment, the Borough Council will support proposals for a mixed use scheme, to include Land East of Grove Road, which comprises some or all of the following elements:-
i. a range of employment uses, including port-related, manufacturing and distribution; ii. residential development; and iii. a major sports facility.
A planning brief should precede any planning application(s), such proposals to be accompanied by a comprehensive Master Plan for the area. The following issues would need to be addressed:-
iv. nature, location and mix of land uses;
v. height, layout, density and tenure of residential development;
vi. land contamination – remediation measures;
vii. possible rail connection to North Kent Line via Church Path Pit/St. Botolph’s Pit;
viii. highway links and traffic generation, including any off-site highway improvements;
ix. need for and potential to provide major sports facility;
x. provision of open space and landscaping;
xi. access to riverside; and
xii. links to surrounding community.
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All proposals will be subject to Policies T1 (Location of Development), H9 (Affordable Housing), LT3 (Green Grid) and SC1 (Social and Community Infrastructure).
Other relevant policies in the Gravesham Local Plan Second Review are; Policy E4: New Employment Areas, Policy TR3: Public Access to the Riverside, Policy BE12: Design of New Development, Extensions and Alterations, Policy T1: Location of Development, Policy T12: New Accesses on Highway and Public Transport Network, Policy T14: Freight, Policy T16: Car Parking Standards, Policy NE15, Policy NE23: Tidal Flood Risk Area, Policy LT3: Development of Green Grid Sites, Policy LT8:Open Space in New Residential Developments, Policy RS1: General Policy on Retail and Service Proposals, Policy RS7: Local Centres, Policy NE15: Contaminated Land and Landfill Sites, Policy NE16: Air Quality, Policy SC1: Social and Community Infrastructure, Policy H3: Design of New Housing Developments, Policy H9: Affordable Housing.
Local Development Framework
The Council is in the process of preparing a Local Development Framework (LDF) for the Borough. Progress to date on this document has focussed on the Statement of Community Involvement (SCI), which was adopted in March 2007 and the Core Strategy. Three public consultation exercises have been carried out to identify the key issues and priorities for consideration in the Core Strategy. The last consultation was in October/November 2007 on the Core Strategy Key Issues and Options Report. Work is currently progressing on the Core Strategy Preferred Options Report. The Local Development Scheme (LDS), which sets out the programme for taking forward the LDF, was reviewed in order to address deficiencies in the evidence base and the changes introduced by PPS12 and the Town and Country Planning (Local Development) (England) (Amendment) Regulations 2008. The revised LDS was approved by GOSE on 16 January 2009.
Extracts from Core Strategy Key Issues and Options Consultation Document, October 2007 :
Delivering the Major Development sites – the main focus of sustainable development in Gravesham.
In the Core Strategy Key Issues and Options Consultation Document it is stated that leaving aside Gravesend Town Centre, which will in itself be a focus of regeneration activity, the main mixed use sites are Ebbsfleet, Northfleet Embankment (east and west) and Canal Basin/North East Gravesend.
The emerging South East Plan designates Kent Thameside as a major growth area, thereby taking forward strategic planning policy already established in Regional Guidance (RPG9 and 9a) and the Kent and Medway Structure Plan. The challenge is therefore is to deliver that growth in a way that is sustainable and responds to local context.
Of particular concern are identifying those major sites which can accommodate the proposed level of development set out in the emerging South East Plan; ensuring that existing neighbourhoods are made more sustainable; and that new and existing areas
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are knitted together to create a new structure for the Borough that works and meets the needs of the local community.
Beyond this, the growth planned for Kent Thameside set out in the emerging South East Plan is based upon Ebbsfleet performing an important role as an international and domestic transport node on the new Channel Tunnel Rail Link and as a new commercial centre with employment opportunities driving forward the economic regeneration of the sub-region.
Constraints on development limit choices for accommodating the major new development. Beyond this, higher level policy documents already identify the broad areas deemed appropriate for regeneration whilst others already benefit from planning permission. As such, many of the major development sites are largely ‘givens’ and include:-
Ebbsfleet (station and development).
Northfleet Embankment east and west (major opportunities for mixed housing, employment, retail, leisure and other uses together with enhanced transport facilities).
Canal Basin/North East Gravesend (major development under way and fresh opportunities being explored).
Christianfields/Southfields (separate redevelopment schemes in south Gravesend). Swanscombe Peninsula (area where the potential has yet to be fully explored).
However, whilst the broad development areas have already been defined, the character, mix and distribution of development on individual sites have still to be decided. This will be influenced by a range of factors, including physical constraints, the status of the land (i.e. whether it is brownfield or greenfield land), flood risk, water capacity and transport infrastructure.
In addition, there are a number of significant development projects that are already underway. These include:-
• Completion of Channel Tunnel Rail Link Phase 2 – Autumn 2007.
• Ebbsfleet International and Domestic Station – opening 2007 with domestic services from 2009, including trains from Gravesend.
• Ebbsfleet Development, as set out in the outline planning consent.
• A2 widening
The primary objective of the LDF is to deliver a sustainable pattern, mix and form of development within the Borough of Gravesham which meets the needs of the local community through to 2026 but does not compromise the ability of future generations to meet their own needs. The major development sites are largely “givens” and the main issues are therefore about the way in which these sites are developed and how they are integrated into the wider urban fabric.
With regard to Northfleet Embankment , this is an extensive area (87 hectares, extending 2.5 kilometres) on Thames Waterfront, close to Ebbsfleet International Station. SEEDA, with the assistance of with funding from the Department of Communities and
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Local Government, has assembled key parcels of land for redevelopment and a range of new, mixed uses are proposed, including office, residential and leisure development, as well as new public open space and a riverside walk/cycle way. It is also proposed that FASTRACK will run through the area.
There are three key areas: Northfleet Embankment East, West and Industrial Core.
Northfleet Embankment East contains the SEEDA land ownerships and will be progressed most rapidly. A planning application is suspected in the Autumn, which will include, amongst other elements, up to 1,800 dwellings in a range of types, sizes, densities and tenures, up to 25,000 square metres of employment uses a mixed use centre and a new primary school.
Northfleet Embankment West is predominantly in the ownership of Lafarge Cement UK. The opportunity to redevelop the site will occur following the closure of the existing Northfleet Cement Works in 2008, although Lafarge are proposing to retain land to include an aggregates terminal based around 42 Wharf and rail access alongside the new cement import terminal. A Master plan for this area is in the course of preparation by David Lock Associates.
The Industrial Core comprises the new cement facility and the existing and newly rebuilt Kimberly-Clark facility. The reinstatement of rail freight is actively being pursued for this area. Apart from the housing mix and employment land uses, the key issues are what social, community and leisure/open space facilities are to be provided and where these are best located, height of buildings, highway access and pedestrian links to the existing surrounding communities and the riverside.
In the responses to the Key Issues Leaflet (March 2005) the Core Strategy Key Issues and Options Consultation Document indicates that in respect of Northfleet Embankment there was widespread support for regenerating the area for mixed use development (housing, employment, leisure and open space), whilst making the riverside more accessible and securing environmental improvements. There were varying degrees of support for particular types of development, especially industry and employment, whilst safeguarding existing uses and leisure, recreation and tourism, including river-related uses. A significant but lesser number of responses also advocated a wider range of housing, including affordable and key worker accommodation and a combination of housing and employment uses.
A number of people also saw the possibility of improving the road network and links to the Town Centre and A2 and also expressed support for Fastrack.
In Responses to the Future of Gravesham Leaflet and Exhibition (March 2006) the Core Strategy Key Issues and Options Consultation Document indicates that in respect of Northfleet Embankment in response to the questions posed, there was a large majority favouring residential-led mixed use development and in agreement with the retention of existing employment and the proposed location of housing. There was strong support for confining leisure provision to housing areas and for improved access to the riverside. A number of people also wanted new indoor leisure facilities to be provided.
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Planning Policy Guidance and Statements
The following Government planning advice documents are also material considerations:-
Planning Policy Statement 1: Delivering Sustainable Development
Planning Policy Statement: Planning and Climate Change - Supplement to Planning Policy Statement 1
Planning Policy Statement 3: Housing
Planning Policy Guidance 4: Industrial, Commercial Development and Small Firms
Planning Policy Statement 6: Planning for Town Centres
Planning Policy Guidance 8: Telecommunications
Planning Policy Statement 9: Biodiversity and Geological Conservation
Planning Policy Statement 10: Planning for Sustainable Waste Management
Planning Policy Statement 11: Regional Spatial Strategies
Planning Policy Statement 12: Local Spatial Planning
Planning Policy Guidance 13: Transport
Planning Policy Guidance 14: Development on Unstable Land
Planning Policy Guidance 15: Planning and the Historic Environment
Planning Policy Guidance 16: Archaeology and Planning
Planning Policy Guidance 17: Planning for Open Space, Sport and Recreation
Planning Policy Statement 22: Renewable Energy
Planning Policy Statement 23: Planning and Pollution Control
Planning Policy Guidance 24: Planning and Noise
Planning Policy Statement 25: Development and Flood Risk
5. Reason for Report
Major development proposal
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6. Consultations and Publicity
Consultations
Planning Policy Manager
The redevelopment of the Lafarge site brings with it a major opportunity to begin the regeneration of an important part of the borough that has been environmentally degraded as a result of 200 years of industrial development and the poor post-war planning of the area.
Section 38(6) of the Planning and Compulsory Purchase Act 2004 states that, where regard is to be had to the development plan for the purpose of any determination to be made under the planning Acts, the determination must be made in accordance with the plan unless material considerations indicate otherwise.
It is noted that Kent County Council, as Mineral Planning Authority, are currently dealing with an application for a major aggregates import facility on land adjoining and it is assumed that the implications of this will also inform the determination of this application.
Development plan and other material considerations
In this instance, the development plan comprises the South East Plan (2009) and saved policies from the adopted Gravesham Local Plan First Review (1994). 1
In general terms, the proposal has a good fit with policy contained in the South East Plan. In particular, Kent Thames Gateway Policy KTG1 refers to prioritising the use of previously developed land to accommodate development, especially where this can exploit the potential of the Ebbsfleet regional hub and where housing, employment and community services are accessible by a choice of transport.
Paragraph 19.5 of the South East Plan also states that the effect of Policy KTG1 will be the concentration of new dwellings, employment and services at the major regeneration locations, including the Thames riverside, with a particular concentration near the transport hub at Ebbsfleet.
Policy AP13 of the adopted Gravesham Local Plan First Review covers the application site, together with land to the east around Robin’s Creek. This states:-
Policy AP13
In the area shown on the Proposals Map, the Borough Council will not oppose in principle partial redevelopment for a commercial or mixed development, provided this is consistent with the amenity of adjacent residential properties and results in a substantial improvement in the environment of the area. The Borough Council will seek the preparation of a planning brief.
1 Policies contained in the Kent and Medway Structure Plan have been omitted from these comments as the application is unlikely to be determined in advance of the expiry of the policies in this document on the 6 th July 2009.
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Whilst it did not proceed to adoption, the Gravesham Local Plan Second Review Deposit Version (May 2000) is also capable of being a material planning consideration in the determination of the application – albeit the weight which may be accorded it is very limited.
Policy MDS3 of this document covers the cement works site, the pits south of the B2175 Northfleet High Street, and the land north of Wallis Park as far as Robin’s Creek. This also supports the concept of a mixed-use redevelopment of the area subject to the preparation of a planning brief and comprehensive Master Plan dealing with a range of key issues.
The principle of the mixed-use development of this area is therefore well established within planning policy.
However, Policy KTG1 of the South East Plan also states that we should set high standards for the design and sustainability of new communities, and for improvement of the existing urban areas, reflecting the riverside and historic character of the area.
This emphasis on high quality and the promotion of local distinctiveness is also reflected in Policy CC6 of the South East Plan, which states:-
POLICY CC6: SUSTAINABLE COMMUNITIES AND CHARACTER OF THE ENVIRONMENT
Actions and decisions associated with the development and use of land will actively promote the creation of sustainable and distinctive communities. This will be achieved by developing and implementing a local shared vision which:
i. respects, and where appropriate enhances, the character and distinctiveness of settlements and landscapes throughout the region ii. uses innovative design processes to create a high quality built environment which promotes a sense of place. This will include consideration of accessibility, social inclusion, the need for environmentally sensitive development and crime reduction
As such, there are clear links to Planning Policy Statement 1 on Delivering Sustainable Development (2005). This sets out a number of key principles to be taken into consideration in the formulation of policy and the determination of planning applications. Amongst these is the need to promote high quality inclusive design in the layout of new developments and individual buildings in terms of function and impact, not just for the short term but over the lifetime of the development. Design which fails to take the opportunities available for improving the character or quality of an area should not be accepted.
Whilst Local Planning Authorities are advised not to be unnecessarily prescriptive in terms of design detail, it is legitimate to attempt to reinforce local distinctiveness and urban design solutions should be developed in context to develop a sense of place.
This approach is also clearly articulated in the DCLG publication By Design – Urban design in the planning system: toward better practice (2000) whereby a clear understanding of context is central to the creation of places with a distinctive character and identity.
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Paragraph 37 to Planning Policy Statement 1 states that Local Planning Authorities should have regard to best practice set out in this (and a number of other guidance documents) in planning for the achievement of high quality inclusive design. This document is therefore a material planning consideration in the determination of the application.
A question which must therefore be asked is whether the proposals take full advantage of the site’s context, so as to help create a sustainable and well-integrated riverside community with a distinctive identity and a strong sense of place.
Effectively, our objective here should be to create somewhere and not just anywhere .
Consideration of the proposals and their context
Essentially, the application is for a mixed-use development comprising up to 510 dwellings; up to 46,000 sq.m of employment floorspace; a range of other uses, including retail and other commercial uses adjacent to The Hive local centre; relocation of the Scouts Hut; provision of open space; and other infrastructure.
Residential uses would be accommodated on a re-profiled area of higher ground to the north of The Hive and on the riverside; employment uses would be located to the east to form a buffer to the proposed aggregates import facility; and open space would be provided as a replacement for Chimney Green within the residential area and in the form of a playing field and informal open space at a lower level to the north of Lawn Road. The playing field would be used by Lawn Road Primary School but also be available for public use. A riverside walkway/promenade would also be provided at the north of the site, within the residential area.
The main highway access to the residential area from the B2175 Northfleet High Street would be primarily from an upgraded Hive Lane, which would be re-aligned and extended down to the River Thames to also provide a vista. Grove Road would be improved within highway limits and on land within the applicant’s control, so as to provide a widened carriageway and adjoining footway/cycleway. However, a pinch point would remain at the end of College Road, where land is in Environment Agency ownership, that would require traffic lights and one-way working.
To the east of College Road, the existing road would be realigned and improved to incorporate a segregated Fastrack route. This would continue through the aggregates and cement import facilities, to link with Granby Road/Crete Hall Road thus providing part of an east-west route to support the future regeneration of the remainder of Northfleet Embankment.
The main road access to the commercial area would be via Thames Way and the existing cement work access. This would also serve the aggregates and cement import facility. Access to commercial units in Church Path Pit would be via the factory site.
The proposals include a variety of pedestrian and cycle link upgrades which are also of importance, including the provision of a bridge between the residential proposals around Hive Lane and Factory Road. This would significantly improve access to Lawn Road Primary School and the proposed open space to the north of Lawn Road. In addition, a new footpath/cycleway would be provided adjacent to the Fastrack route through the factory site to Granby Road.
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Both this and public access to the riverside at Bevan’s Wharf would be an important contribution toward the creation of the Green Grid/ Thames Path in this area.
The Planning Statement accompanying the application includes a vision for the site at paragraph 3.3. This states:-
The vision for the redevelopment of Northfleet Works is of a development which reconnects the existing community of Northfleet with the riverside, which revitalises employment opportunities in the area and which regenerates formerly derelict land to the benefit of new and existing communities.
The Design and Access Statement at paragraph 2.3 goes further by adding:-
Development will embrace good design and sustainable development techniques, together with the provision of affordable and market housing, employment, community and open space uses.
Whilst the applicant has had clear regard to the cultural context of the existing settlement in developing the preferred design solution, the analysis contained within the submission and accompanying Environmental Statement focus primarily on archaeology and impact on surviving built elements relating to cement heritage.
However, there does not appear to be any reference in the document to the Kent Historic Town Survey for Northfleet, which gives more information on the historic context of the area and is a resource to which the applicant should have regard (see http://ads.ahds.ac.uk/catalogue/projArch/EUS/kent_eus_2006/downloads.cfm?area=2 8&CFID=2534609&CFTOKEN=89045387 ) .
Notwithstanding this, the site and its environs is far richer and a better understanding of this context might allow the development of a more robust vision and development rationale for the area that could better assist in the creation of a more distinctive sense of place. Following research, the planning policy section is in possession of a range of materials that could assist in this process and these can be made available on request.
In particular, it is considered regard should be had to:-
• The development of the area around Robin’s Creek, given this was probably the site of a major medieval watermill once owned by Canterbury Cathedral and later the Crown, before eventually being incorporated into Parker and Wyatt’s (later Aspdin’s and then Robin’s) cement works.
• The development, layout and form of the Hive House and Orme House estates which previously stood on the site. These were purchased by the Crown in 1808 to enable the development of a new Royal Naval Dockyard on the adjoining marshes. Following the abandonment of the scheme in 1812, the land was sold by the Crown in 1831. The Hive House Estate was sold again in 1842, when it came into the possession of Thomas Sturge, a founding partner of Knight, Bevan and Sturge.
• The importance of the River Thames at this point as a main anchorage for the East India Company during the late 18th/early 19 th centuries. Their ships moored here to be supplied before sailing and for cargoes to be taken off on their return. Their
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officers actually lodged at the India Arms PH, the location of which forms part of the application site at the northern end of the Lawn Road footpath.
Overall, the impression made by the proposals is that, although they are good in parts, there is significant room for improvement. It is considered therefore that they would benefit from review to achieve a higher quality of design that is based on local distinctiveness and a stronger sense of place.
Situating the proposals within the context of an indicative Master Plan for the wider area would also be useful in this respect, to show how the sum of the parts can be unified to create an integrated and sustainable community to the north of the railway.
In terms of detail contained within the application, the following comments are provided:-
Segregated Fastrack route
The Design and Access Statement (at paragraphs 6.1 and 6.13) make it clear that a key determining element in the layout has been the need to incorporate a segregated Fastrack route running east-west through the site. This is unfortunate as the layout is thereby dictated by a 24 metre wide dual carriageway that divides the riverside part of the development from the community to the south.
This also prevents the road from taking its original historic route, which formed the boundary between the Hive House Estate and Orme House – part of the cultural context of the development.
It also seems to be intended that the Fastrack route should continue westward, round Grove Road to the Stonebridge Road roundabout. However, no schematic is provided to show how this might affect the future development of the remainder of the area around Robin’s Creek; the setting of the Aspdin’s Kiln SAM (SAM); or any other items of heritage significance. This could be significant if it is also intended to be a segregated route.
Looking at the AM + PM Scenario C Actual Flows for 2025 (Transport Assessment Figure A7.4.2 and Figure A8.4.2) it is noted that predicted flows either in or out of Grove Road at the roundabout do not exceed 252 PCUs for the peak hour - i.e an average of 4.2 PCUs per minute.
Grove Road: Scenario combined development impact, actual peak hour flows (PCUs) at roundabout 2025 Grove Road Grove Road Total two- northbound southbound way flow AM Peak 214 175 389 PM Peak 214 252 466
Whilst the flows shown on the diagrams for the east-west link through the site to the east of College Road are higher, this is due to the model used as it appears to assume trips to and from the development go via College Road rather than Hive Lane. The applicant is actually assuming that 95 per cent of trips to the B2175 Northfleet High Street would be via Hive Lane, so what is shown is misleading.
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A consideration of Table 7.10 of the Transport Assessment also shows that delays for vehicles and queue lengths for vehicles coming out of Grove Road are minimal in 2025.
Arm 2025 AM Peak (8.00 - 9.00) PM Peak (17.00 - 18.00) M Max Delay Max Max Delay ax Que (Min/V RFC Queu (Min/V R ue eh) e eh) F C Grove Road 0. 0.3 0.08 0.448 0.8 0.12 24 4 Stonebridge 0. 9.7 0.28 0.506 1.0 0.09 Road (East) 94 4 Thames Way 0. 0.4 0.06 0.637 1.7 0.09 29 1 Stonebridge 0. 2.4 0.11 0.924 8.5 0.23 Road (West) 71 4
Whilst the above doesn't include traffic arising from new development on land west of Grove Road (which will replace existing traffic generation to some extent - albeit the flow direction may be different AM + PM), it does appear to show that there is unlikely to be an intrinsic problem with Grove Road itself. If there is an issue here, it may be with the Stonebridge Road roundabout itself, with the east leg in the AM peak and west leg in the PM peak approaching capacity.
It is recommended therefore that the issue of putting a segregated Fastrack route through this part of Northfleet Embankment West be revisited and the alternative options properly considered.
In any event, a very strong case could be made for taking the Fastrack route here southwards through the Vineyard Pit tunnels to Thames Way and Ebbsfleet. This would provide a direct public transport connection between the office and other business uses on this site and other development on the wider Northfleet Embankment.
Contemporary design approach and use of materials
Whilst the Design and Access Statement provides information on the future form and character of the residential areas to the north of The Hive and on the riverside, there is very little reasoned justification for why a contemporary rather than a more traditionally inspired approach (perhaps with some contemporary highlights and other elements such as green and brown roofs) has been adopted.
There is a concern here that the development may replicate the approach to urban design and architecture adopted at sites such as Ebbsfleet and Eastern Quarry, when there is the potential to do something that gives the area its own identity and distinguishes it from what is being brought forward elsewhere.
Because of topography and the distribution of uses, this part of Northfleet has the potential to be different and it should be possible to bring forward a development that sets a very high standard for the future.
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However, figures 7.6 ( Northfleet Works: Indicative residential built form ) and 7.8 (Northfleet Works: Materials palette ) are disappointing in this respect because they are so eclectic it is difficult to get a clear feel for what type of place the applicant is trying to create.
A particularly disturbing aspect of the proposals set out in the Design and Access Statement (at 7.71; 7.78; 7.79; 8.43; and 8.76) is the notion that concrete should be a dominant architectural element, just because cement was made here.
The fact that the original Victorian industrial settlement of Northfleet around the High Street was largely built of brick and that brick was also made here in considerable quantities seems to have been overlooked.
Notwithstanding the use of concrete in parts of The Hive development in the 1960s – 70s, which would be inappropriate to use as a design reference in connection with the new proposals, a visit to the site indicates that a variety of facing materials are used – including a high proportion of brick and painted render + brick and flint to the boundary walls in College Road and Hive Lane.
A question that must be asked therefore is whether the proposed use of concrete set out in the Design and Access Statement is the right approach for this site to reinforce and achieve a distinctive sense of place.
Open space provision
The applicant states that the proposals have been devised to accord with Policy LT6 of the Gravesham Local Plan First Review (1994) and guidance at paragraph 10.20 of that document that open space levels should be provided to the then National Playing Fields standard of 2.43 hectares/1,000 population.
However, Policy PLT1 already identified this area as being deficient in open space and identified 1.9 hectares at College Road, north of The Hive, as potential open space - part of this area comprises the existing Chimney Green Open Space.
In the absence of an up-to-date PPG17 open space assessment or an adopted local open space standard through the emerging Local Development Framework, it is necessary to consider the application on its own merits, in the light of saved policy LT6.
As a matter of principle, it would not be appropriate to require the proposed development to make up an existing shortfall in open space, although the existing local population should have the opportunity to make use of and benefit from any new open spaces created.
For information, some work on the delivery of Green Grid has been undertaken by the Borough Council in this area and this can be made available to the applicant, if it has not already been taken into consideration in the development of the layout and design.
This having been said, there are a number of concerns regarding the proposals:-
• The main open spaces within the residential areas are at the riverside and the replacement play area for the Chimney Green Open Space. Whilst the latter will
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be of higher quality than the existing open space, affording better opportunities for play in a better environment, this will be under considerable pressure from existing children living in and around The Hive and from those living in family housing within the new development.
Consideration therefore needs to be given as to whether this area is big enough and has sufficient carrying capacity to meet levels of demand, both to ensure adequacy of play space and to protect the residential environment of people adjoining. As it may be possible to remove the segregated Fastrack route through the site, an opportunity may exist to revise the layout to include a more generous greenspace allocation within the main residential area.
• The proposals include the provision of a remote playing field to serve Lawn Road Primary School and other open space to the south of Lawn Road connected by a footbridge to the main residential area. These spaces appear to be at a lower level and there is a degree of concern that this would suffer from lack of natural surveillance and be remote from the intended users.
On this, it is noted that the Design and Access Statement at paragraph 3.20 states that the isolation and lack of surveillance of the existing Chimney Green limits its potential as a well used public open space – is there not a danger that the same could apply to this part of the proposals?
• On the joint use of the proposed remote playing field for Lawn Road Primary School, is it intended that this would be fenced and what would be the access arrangements for general members of the public?
If satisfactory joint-use arrangements cannot be put in place, made binding by a legal agreement, then this area should not be considered part of the public open space supply serving the development.
In any event, an alternative approach might be a land swap with KCC, releasing some of the existing playing field site west of College Road as a community resource in place of a new playing field to the north of the school.
How joint use of the playing field might be facilitated also links to any issues relating to expansion of the school itself to meet the needs of the expanding local community. Further points will be made in relation to this in the section below on local services.
Provision of the footbridge to Factory Road would need to be secured via a Grampian style condition or s.106 agreement.
• On the layout of the open space to the south of Lawn Road, it is noted that the existing footpath between Lawn Road and The Shore appears to be lost. It is unclear whether this is the intent and clarification on this point is required. This is an important link that used to run from the main road down to the site of the India Arms PH and associated wharf. Because of its utility in linking the existing residential area to the waterfront/proposed employment uses and its historical connections, this link should be retained.
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Robin’s Creek and Grove Road
Whilst there is no built development proposed on land owned by the applicant to the north of Grove Road and around Robin’s Creek, it is noted that significant highway works are proposed, including the creation of a new 2.5m wide footway/cycleway and a widened carriageway.
These are shown on Figure 5.1 of the Transport Assessment as requiring the demolition of an old industrial building that may have been part of Robin’s cement works and the original brick boundary walls and entrance gates along the western and northern side of Grove Road. Part of the alignment may also encroach on the area once occupied by the medieval watermill, later used by the cement works.
There are a number of issues here to be addressed regarding the heritage interest of these items, their recording, and whether a more detailed assessment is required before works are permitted. Given the degree of uncertainty here, this may include some intrusive investigations to evaluate whether the assumptions made above are correct and whether there are archaeological remains of any significance. Further discussions on this issue should be had with KCC Archaeology.
Irrespective of this, a sensitive approach is required to replacement boundary treatments, surfacing materials and street furniture along Grove Road, reflecting the industrial heritage of the area and the setting of the Aspdin’s Kiln SAM. Whilst the latter is currently surrounded by utilitarian industrial buildings (some of which include original boundary walls) and not visible from the highway, Robins Creek and Grove Road will form an integral part of its setting in the future so getting this right is important.
Further, whilst Robin’s Creek itself is in the ownership of the Environment Agency, it is noted that basically all the land surrounding it is controlled by the applicant. So, if we don’t address problems in this area now, as part of this application, what opportunity will we get to do it later?
The issues surrounding Robin’s Creek are extremely complex, because it is impounded by the flood defences. This situation is unlikely to change because removal of the defences would lead to widespread flooding both around the Creek and up the Ebbsfleet valley, even under short return period surge tide events.
Indeed, without the flood defences, it is possible that much of the area to the west and south would flood even under ordinary tidal conditions given some of it sits at marginally over three metres AOD and the current level of the highest Spring tides (March & October) is about 3.68m AOD – a situation which would worsen due to the effects of climate change and rising sea levels.
Robin’s Creek is also important because it forms a containment pond to accommodate surface water and other drainage from the Ebbsfleet Valley and land adjoining. Water is only allowed to discharge at low water, hence tide lock and the ability of the Creek to store water during extreme rainfall events is therefore an issue.
An inspection of Robin’s Creek itself shows the area to be largely overgrown and in poor condition. Visually, the dockside walls that once served the cement works also appear to be in poor condition and potentially warrant examination and repair.
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Because Robin’s Creek forms part of the setting for and will be overlooked by development on the riverfront, as well as being on the main approach to the development site along Grove Road, it is suggested that this area be looked at once again to see if a programme of improvement could be put in place.
The Environment Agency should also be involved in any discussions because of their ownership of Robin’s Creek. Some form of trade-off here might also facilitate the removal of the pinch point at the end of College Road to allow the road to be properly upgraded. This could include the removal of some of the quayside walls to the west of Grove Road and re-grading/landscaping to create a more naturalistic riverine environment, further open space, and increased water storage capacity in the Creek.
The above points in relation to the improvement of Robin’s Creek and its environs would also have a good fit with the Environment Agency’s commitment toward the Ebbsfleet under the EC Water Framework Directive and through the draft Thames River Basin Management Plan. The potential to develop a joint project with the Environment Agency or to draw down grant aid funding should therefore be investigated.
Access from River Thames
It is noted that the proposals include the total removal of Bevan’s Wharf as a redundant structure. However, access to and from the River Thames in this location might be useful because of its strategic location relative to Ebbsfleet and the potential to make a public transport connection via Fastrack .
Whilst access to and from the river by small leisure craft is unlikely to be acceptable here due to conflict with large vessel movements approaching and leaving adjoining jetties and the main Tilbury Dock lock, there may be potential for a future river bus service linking key riverside destinations on the Kent Thameside and Thurrock shores.
As this could also add to the vitality and viability of the development, it would be useful to consider therefore whether an all tide landing stage would be both practical and feasible at this location. It is suggested that discussions be held with the applicant and the PLA on this point.
Housing
In general terms, the quantity of housing proposed in acceptable, albeit this may have to be adjusted to allow additional open space to be provided should access to the new open space north of Lawn Road be overly restrictive. The aim here should be to deliver an integrated sustainable community and not simply to deliver housing numbers. The offer to include up to 30 per cent affordable dwellings is acceptable and in line with adopted policy.
However, it will be necessary to agree the most appropriate mix of affordable tenures, given the close proximity to Wallis Park and the amount of existing social rented properties in the area.
It is also noted that the development will incorporate a mix of unit types, including apartments, town houses and houses, within a range of unit sizes. Whilst the emphasis on family housing within the development is welcomed, it would be useful if
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agreement could be reached on the parameters for this mix to ensure what is ultimately delivered accords with the intent of any outline permission.
Any comments from GBC’s Housing Strategy Manager will also need to be taken into consideration in the determination of the application.
Employment
The Borough Council has recently been engaged in a review of employment land supply as part of the development of its evidence base to support the emerging Local Development Framework.
Whilst this report has yet to be finalised, the methodology used sought to identify what floorspace will be needed in the different ‘B’ use-classes through to 2026, depending on how quickly the Regional Economic Hub at Ebbsfleet develops. Northfleet Cement Works is identified within the study as a potential site for the delivery of some of this floorspace, it being assumed that around 12.5 hectares of employment land could come forward. This is a good fit with what is shown in the application.
However, it is difficult to make a judgement on the application in terms of the acceptability or otherwise of the type of jobs that may be delivered because the mix of ‘B Class’ employment floorspace is not defined – the outline application is simply for up to 46,000 sq.m in any of the B1/B2/B8 use classes.
Because the application is subject to an Environmental Impact Assessment and Transport Assessment that are based on assumptions about floorspace mix, a decision will need to be made as to whether this is acceptable – the implication being that the conclusions of either document may not hold true if the mix is varied and the documents become invalidated.
In addition, paragraph 1.8 of PPS 6 on Planning for Town Centres (2005) identifies commercial offices and those of public bodies as main town centre uses to which the policies in the statement apply. This prioritises town centre sites for such uses, unless there is an alternative policy justification or the sequential approach set out in the PPS is followed.
Clearly, the current application site could be construed as an outlier of the Ebbsfleet development and Policy KTG2 of the adopted South East Plan also refers to major sites in Thameside with access to the M25 motorway and the national rail network continuing to develop a mix of employment uses, including offices, regional distribution, and manufacturing.
It would be useful though if the rationale for the scale and location of the proposed office uses could be made more explicit within the application, as they have the potential to compete directly with sites that might come forward in the Town Centre.
Notwithstanding the above, it is also important that what comes forward not only contributes toward the achievement of regional economic objectives but also meets the needs of the local community.
Given levels of deprivation in the area and the long-term decline in traditional industrial employment, it would clearly be a lost opportunity not to use the
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regeneration of the Lafarge site as a major opportunity to secure improved access to training and jobs for the local community.
It would be useful therefore if we could agree to work pro-actively with the applicant to establish a strategy that sets out a clear approach toward development of the employment areas to achieve that end.
It is also important that in developing this site we achieve an appropriate balance between the delivery of homes and jobs. The approach adopted in Ebbsfleet was that there should be a link between the delivery of homes and jobs through the use of Grampian style conditions. This approach should also be considered here.
Existing industrial/commercial properties to northern end of College Road
It is extremely disappointing that the applicant has chosen to restrict the red-line boundary of the application to exclude the industrial/commercial properties in third party ownership to the north-eastern corner of College Road. There is a clear opportunity here to relocate these businesses to other land within the applicant’s ownership and College Road would make a more logical site boundary. This would also assist in overcoming any environmental constraints that might arise as a result of these businesses remaining in-situ, as well as allowing for a cohesive approach to the design and build out of the wider area.
It would be useful if this could be revisited and the application amended accordingly.
Local Centre
The proposal involves the creation of additional retail space on a site to the east of Hive Lane, to supplement the existing local centre. This approach appears to have been adopted because the applicant would be able to deliver it on land within his control.
However, it is clear from a visit to the site that the existing local centre is not performing particularly well. Several units are closed and others only open for a few hours per day. The following table sets out the situation at 12.00 noon on the 27 May 2009.
Unit Use Comment 1 Newsagent Open on visit 2 GBC Housing Office Closed until 1 st June then only open Mon – Sat 2.00 to 4.30 pm 3 Butcher/Fishmonger Selling African/Afro-Caribbean foods but no activity during site visit. 4 Excel Launderette Open but nobody using during visit. 5 Frozen Foods Shutters down on visit – appears to be closed as no opening times shown. 6 Charity shop Linked to unit 7 below but did not appear to be open. 7 KASBAH charity Open on visit – Kent Association for Spina office Bifida and Hydrocephalus. 8 Sally’s Fish Bar Open on visit. 9 Happy Shopper Open on visit 10 - Library Opening hours: 9 -12.30 Mon – Fri; Closed 11 Weds; 2.00 – 5.00 Thurs – Friday; 10.00 – 2.00 Sat.
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12 Empty unit Closed 13 Direct Services Closed on visit and may not be trading. South East – employment agency/security etc. 14 Surestart Community programme aimed at families + children aged 0 – 4 year old in the area. 20 Empty unit Former Barclay’s Bank unit – appears to be empty and/or unused when viewed from outside.
Whilst any investment in the local centre at The Hive is to be welcomed, there is a danger that the proposals set out in the application may compete with the existing centre rather than complement it. This is because the existing local centre turns its back on Hive Lane, with the only link between existing and proposed retail areas being the footway under the arch by Sally’s Fish Bar.
It is likely therefore that the old and new will operate as two separate local centres rather than a combined entity. This is likely to be detrimental to the existing centre, potentially undermining its viability.
It is suggested therefore that this aspect be revisited to see if there is a way in which the Borough Council and the applicant can bring forward an improved scheme that reinforces the existing centre; encourages passing trade from the B2175 Northfleet High Street; and introduces an improved retail offer and other services that address the needs of the combined local community.
If this isn’t dealt with as part of the current application, the opportunity to re-invent Northfleet High Street/The Hive as a vital and vibrant centre at the heart of a sustainable community is likely to be lost. It is important therefore that GBC looks at this corporately and is proactive on this issue.
Once again, the outcome of any discussions on the local centre and the improvement of facilities may require an alteration of the red-line application boundary.
Community uses
In terms of community uses, the Planning Statement says (at 3.20 – 3.23) that an element of D1 uses is proposed in association with the local retail centre. It is envisaged this will consist in part of community hall, perhaps using a ground floor unit within the centre itself.
The statement says that education provision will be met by an expansion of Lawn Road School, facilitated in part by the provision of the new playing field with shared public/school use.
It is envisaged that health provision will be met by existing surgeries.
It is proposed that the existing Scout Hut on site will be relocated.
On the basis that the Scouts wish to remain in the immediate area a number of potential locations within the site are identified where detailed master planning work might bring forward alternative provision.
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These include alongside a site on the proposed playing field, at the north end of Factory Road or the joint use of the proposed community facility, within the mixed use centre.
It is proposed that the principle of relocation be established at the outline planning stage.
The following comments are made as a result of work that the Planning Policy section has been undertaking in relation to social infrastructure:-
• Health
Whilst there is a Doctor’s Surgery located approximately 500 metres to the east on The Hill at Granby Place, it is understood that no new patients are being accepted. Further, the opening hours here were reduced in January this year. These hours are now 8.00 – 12.30 am Monday – Friday with only one afternoon opening on Monday between 14.00 – 18.30 pm. Apart from this, the next nearest GP surgeries within Gravesham are a significant distance away as follows:
- A single handed GP surgery at Beaumont Drive is accepting new patients - Deneholm Surgery at Hunt Road is accepting new patients - The Shrubbery at Perry Street is accepting new patients - Forge Surgery at Coldharbour Road is accepting new patients
West Kent NHS PCT has indicated that they would run the HUDU model on this application, when received and this should be followed up.
In addition, it should be noted that accessibility is likely to be an issue in relation to medical provision in this part of Northfleet because the main bus routes all run toward Gravesend Town Centre and not southwards toward Thames Way, Perry Street or Coldharbour Road.
Depending on future plans for the Granby Place surgery, a case might be made for a new surgery at The Hive, as either a stand-alone or satellite unit, to serve existing and new residents within the immediate area. This could also assist in reinforcing the local centre here, whilst making extended opening hours more viable.
It is suggested therefore that the PCT be approached to see what their intentions are in this area.
• Schools
Lawn Road Primary School currently only has a Pupil Admission Number capacity of 120. It is unclear therefore whether an extension to the primary school will provide sufficient capacity for the numbers of pupils generated by the development. KCC currently have no specific proposals for this school though it might benefit from the primary capital programme in the longer term.
It is suggested that this be followed up with Kent County Council as Education Authority to ensure sufficient educational provision can be made in the area to support the creation of a sustainable community.
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• Libraries
The site is close to Hive House library. Whilst there are no specific plans for this library, KCC libraries service is keen to develop partnership working with ad hoc use by other services and increase community use out of hours at this and other smaller libraries.
• Kent Adult Social Services
KCC have indicated that there will be short term break/training for life flats at Northfleet Embankment which would deliver short term respite care and independent living skills for people with a learning and/or physical disability. They have also indicated that a community hub will be provided here. Community hubs are shared by a variety of agencies and provide a fully accessible social community facility with services such as dementia care and day activities for people with a learning and/or physical disability. KCC might be approached to see if such facilities can be accommodated within the development.
• Post Offices
The nearest post office is at the Nisa Store in Rosherville, some distance away. Given the expansion in population here, the potential to reintroduce a Post Office should be explored as part of the regeneration of the local centre.
• Pharmacies
There is a pharmacy at The Hill – would the expansion in population as a result of the development (and the rest of Northfleet Embankment West) support an additional facility at The Hive? This should also be checked with the PCT.
Public realm, lighting and art
As a matter of course, it is required that the proposal should deliver a high quality public realm as part of the development. This should extend not only to materials, detailing, and street furniture but also to street planning to green the development and lighting – something that is particularly important given topography and the fact that the proposal will occupy a prominent riverfront location.
The use of flint in some of the key boundary walls along the original network of roads and paths would be a useful way of linking to the heritage of the site. It should also be remembered that Hive Lane was the main entrance to the mansion house that once stood on the site, so an appropriate design reflecting the original high status of this road would also be worthy of consideration.
Given the very distinctive character of the mid to northern part of College Road, with its uninterrupted brick and flint boundary walls, consideration should be given to revising the layout so the existing flint wall is retained in-situ. Whilst this would mean the development turning its back on College Road at this point, the effect would be to maintain the very strong sense of place already generated by this location – its something worth keeping + protecting by condition.
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Public art should be included in the development to enliven the area and add interest – perhaps with an emphasis on local maritime connections and the development of the cement industry.
A heritage interpretation strategy would be useful in this respect and it is suggested that this is done so that it could be rolled-out to provide a unified approach on the remainder of Northfleet Embankment West around Grove Road/Robin’s Creek.
In addition to the heritage connections set out in the comments above, attention is also drawn to the controversy that surrounded the early development of the cement industry and its impact on the environment from the early 1870’s onwards. This eventually led to several court cases; a formal investigation by the Royal Commission on Noxious Vapours in 1878; and the introduction of statutory controls under the Alkali (etc), Works Regulation Act in 1881.
Of particular interest in respect of the application site is an incident which occurred at a new works being erected by J.C. Gostling on the 2 October 1873 – this would have been somewhere on the site of the current works. Following complaints by the Frederick Southgate, the Vicar of Northfleet, the cement manufacturer had built a chimney some 220 feet high to avoid paying compensation. On completion, it was intended to undertake a topping-out ceremony and it was during preparations for this that the top 80 feet of the chimney collapsed, leading to the death of six workmen.
Details of all the above can be supplied to the applicant on request.
Flood Risk
The site is a previously developed one within Thames Gateway, identified in several key planning documents as a regeneration opportunity. As such, there should be no need to apply the PPS25 Sequential Test, given a general dispensation has been issued by the Environment Agency. The applicant has also provided a site specific Flood Risk Assessment detailing levels of risk from a range of sources. It is assumed that the Environment Agency will provide an assessment of the submission in due course and no further comment on this issue is made here.
Water use and carbon reduction
It is noted at 7.95 of the Design and Access Statement that is intended to meet Code Level 4 under the Code for Sustainable Homes and the relevant standard for non- domestic properties. It is also noted that it is intended to ensure that 10 per cent of energy used on site derives from renewable or low-energy sources, in line with South East Plan policy NRM 11. Consideration should also be given to the use of CHP and district heating systems within the development, together with the use of bio-mass fuels as per South East Plan Policy NRM 12 – subject to impact on air quality. It is advised that any agreed standards be incorporated within conditions or the s.106 agreement so that they are enforceable at the detailed stage. However, they should be set as minima to be achieved given that some elements are likely to be surpassed through the progressive introduction of more stringent national legislation.
It is also noted that as part of the work on the forthcoming Kent Thameside Water Cycle Strategy, Southern Water Services indicated the need for a new or reinforced main from Singlewell Reservoir to supply development on Northfleet embankment.
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Has this been taken into account in the application and is it intended that mechanisms will be put in place to secure the delivery of this infrastructure?
Nature Conservation and biodiversity
Paragraph 14 of PPS9 states that development proposals should provide opportunities for building-in beneficial biodiversity features as part of good design. When considering proposals, local planning authorities are required to maximise such opportunities in and around developments, using planning obligations where appropriate.
As a matter of principle, nature conservation and the enhancement of biodiversity should be integral to design through the use of SUDS, planting, creation of wildlife corridors linking to Ebbsfleet Valley, and use of green and brown roofs etc. It should not be an afterthought or bolt-on, utilizing the space left after planning other land uses.
It is advised therefore that the expert advice of Natural England and Kent Wildlife Trust be sought on the adequacy of the proposals. Both of the above organizations should also be involved in any discussions regarding works to Robin’s Creek if it is decided to follow up the points made above.
On specifics, it is noted that the site plan includes wildlife translocation areas in Figure 2.6. Paragraph 16.6.39 of the Environmental Statement concerns itself with reptile mitigation, compensation and enhancement during demolition and construction. This explains that there will be two stages to the reptile mitigation strategy. For the first stage, reptiles will be translocated from the development area (consumables storage area, grassland around Bevans chimney, grassland south of the Scouts Hut and Vineyard Pit) to Church Path Pit. The second stage will involve the translocation of reptiles from Church Path Pit to an off-site receptor site within the local area”.
Recent discussions with KCC and KWT have highlighted translocation as an issue. Whilst the Kent and Medway Structure Plan is due to be superseded para 4.13 of SPG2 ( http://www.kmsp.org.uk/pdfs/kmsp-spg2-pre-print.pdf ) attached to that document advises:
4.13 Translocation of habitats or species should not normally be considered as a form of mitigation or compensation for the purposes of planning. The general difficulty and unproven efficacy of translocation means that nature conservation agencies do not accept it as a valid nature conservation method. Translocation should only be used in two situations:
• Where the translocation is used only as a temporary stop-gap, for example, where reptiles are moved from a site during works but allowed back after the works are completed; or
• Where the development is to proceed notwithstanding any impact upon a protected species and where translocation is the only method to avoid direct killing or injury of individual animals or plants.
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It is assumed therefore that the phase 1 temporary translocation would be acceptable but not phase 2. Alternatively, if an off-site receptor is the best long-term option, it may be better as just a one-phase move.
The problems associated with a double translocation is recognised in para 16.6.40 – 16.6.43 of the Environmental Statement but it is not made clear why the 2 nd phase of translocation is required. Whilst it is understood that during phase 4 the applicant intends to build employment on this area (fig 2.8) no reason is given in the planning statement as to why this area cannot be left as greenspace.
Natural England has produced guidance for the following protected animal species commonly encountered by developers incl. reptiles http://naturalengland.etraderstores.com/NaturalEnglandShop/Product.aspx?ProductI D=93dcf938-5c8f-4d6c-aed1-626b3e2dfaf3 and this shows translocation as the least desirable option.
Aside from any other impact on nature conservation interest, it is noted that the ecological survey work set out in the Environmental Statement details the presence of up to three breeding pairs of Black Redstarts on site. This is a Schedule 1 species under the Wildlife and Countryside Act 1981 (as amended) and a UK BAP target species. The numbers of breeding pairs on site is significant at the national level, representing around 3 – 4 per cent of the entire national breeding population.
Whilst the Environmental Statement sets out mitigation measures during demolition and construction, to ensure that the birds are not disturbed and sufficient foraging habitat is maintained to support them, care will need to be taken to ensure that the phased implementation of any approved scheme reflects this and that the final design also includes sufficient environmental features to maintain and enhance nature conservation interest.
PPS9 on Biodiversity and Geological Conservation (2005) is also of relevance here in that Key Principle (ii) states that in making planning decisions, the aim should be to maintain, enhance, restore and add to biodiversity interests and that the appropriate weight should be attached to protected species and to biodiversity within the wider environment.
Transport Assessment
Issues related to impact on the highway network fall primarily within the remit of Kent County Council and the Highways Agency.
However, it is thought appropriate to flag up the following transport related issues that need to be addressed (please note that more detailed comments may follow in due course):-
• Fastrack routing through the site – dealt with in the comments above.
• Hive Lane – the highway impact of the development on this junction does not appear to have been modelled nor is there a layout given of any improvements to be made.
• Grove Road pinch point - Consideration should be given to dealing with this issue now, to provide good highway access from Stonebridge Road to the highest density part of the development at the river front. Encouraging vehicles
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to use this route would also take pressure off the B2175 Northfleet High Street and the College Road/Hive Lane junctions.
It is also noted that the proposal is based on it being a sustainable development, within easy walking distance of Northfleet Station and the Ebbsfleet development. As access to Ebbsfleet is largely predicated on an improved linkage over or under the railway at Northfleet Station, it is important that the phasing of the link and delivery of this development are well related. It would be useful if clarification on this could be sought.
It is suggested that the development might make contributions towards the following transport related items under s.106, subject to a consideration of the tests set out in Circular 05/2005:-
• Traffic calming/streetscape enhancement in the High Street • Enhanced access to Northfleet Station to connect through to Ebbsfleet • Contribution towards the Ebbsfleet - Northfleet link • upgrading of off site walking and cycling links as well as the on site • upgrade to the footbridge across St Botolph's Pit (Church Path Pit)
The need for proportionate contributions toward strategic transport infrastructure will also need to be assessed, taking into account the actual impact of the site set out in the Transport Assessment.
Kent Wildlife Trust
The application site supports UK and Kent Biodiversity Action Plan habitats and species, many of which are also NERC Section 41 habitats/species, and some of which are also protected under the Wildlife and Countryside Act.
It is clear that without extensive mitigation, this development will have a major adverse impact on biodiversity in the Borough, with a national impact for Black Redstarts in particular. There is a need to deliver the mitigation in a coordinated way across the application site and the adjacent site, as it would appear that it is the variety of habitats, the extent of the site, and the site’s location that contribute to its value for biodiversity. The continuity of these habitats through mitigation during the long development period will also be important. These considerations will help to ensure that the development fulfils national planning policy such as PPS9 and policies NE11 and NE12 of the Gravesham Local Plan 2nd Review (Deposit Version).
The type of mitigation proposed is appropriate. However, as an outline application the extent and detail of this mitigation is lacking. Therefore we have no objection subject to conditions imposed on any permission that would ensure adequate mitigation and compensation is delivered.
Habitat Management Plan/Biodiversity Action Plan.
The ES recognises the need for a habitat management strategy to deliver mitigation and enhancement. This should be appropriate for the habitats and species of concern. A steering group of relevant organisations should be in place during the construction period, with opportunities to review the plan if necessary. The plan should allow for habitat management for a minimum of five years after completion of the final phase of
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development. Opportunities for using all non-builtspace, such as road verges, should be maximised.
Brown Roofs
Aggregate-based, biodiverse roofs are mentioned as mitigation for bats, breeding birds, black redstarts, invertebrates and bare ground mosaic. Given the loss of habitat to the development that brown roofs would potentially partially replace (3.9ha open mosaic habitat, 2.7ha unimproved neutral and calcareous grassland), it would appear that the entire potential three hectares of brown roof are being relied upon in the assessment of residual effects. Owing to the application being outline only, the actual extent of brown roof is not given, and the ‘up to 3ha’ stated allows for a lot of variation. Three hectares of brown roof should be a minimum required to mitigate the habitat losses, any shortfall in this will need to be made up in the form of open species rich grassland/mosaic habitat off site. A correct specification is vital to the success of brown roofs for biodiversity, and while the recycling of aggregate from the site is possible, it may not be appropriate depending upon the type of material available. Further guidance from a specialist, such as Dusty Gedge of livingroofs.org, should be sought on this matter. Specification for the brown roofs should be approved through condition attached to outline permission. I suspect that the area and specification of brown roofs in this development will be the difference between its success or failure as a sustainable development, owing to the potential losses versus potential mitigation plus the dearth of other on-site mitigation areas identified.
Black Redstarts
Apart from the brown roof mitigation mentioned above, other safeguards will be necessary to ensure continued presence of Black Redstart in this part of Kent. Continuity of foraging habitat during demolition will be vital, as will monitoring during demolition and construction to avoid breaches of the wildlife and Countryside Act. A Black Redstart conservation management plan should deal with these issues, and be made a condition of outline permission. This should compliment the other mitigation plans, and pay particular attention to the phasing of demolition and loss/replacement of forage, whilst allowing for the extra detail that is needed to deal with the issues surrounding this species. It should be noted that the nesting opportunities suggested are inappropriate, as Black Redstarts forage on, but do not nest on, brown roofs. Siting nesting opportunities on escape routes and in utility buildings is also inappropriate owing to potential disturbance from human activity.
Breeding Birds
A need for compensation for birds breeding in the extensive scrub areas to be lost has been identified. In order to ensure continuity of habitat in this area, the site should be identified and management (or creation) put in place before this habitat is lost to the development. The applicant will need to allow for the management of this site for a minimum of five years after completion of the development.
Reptiles
A reptile mitigation strategy is necessary for this application. This should compliment the habitat management strategy with regard to onsite provision of habitat, but will also need to deal with the translocation of reptiles within the site, and from the on-site translocation area to the compensation area, which should be identified and appropriate management put in place before permission for the phase in question is granted. The applicant should
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allow for management of the site for a minimum of five years after completion of the development.
Additional Response on Green Roofs
“Green roofs [brown roofs - are green roofs that are substrate based and planted with a range of herbs] are known to support foraging black redstarts. A seminal study of roofs in Switzerland in 2000 showed that black redstarts were one of the three commonest birds found on green roofs in the City of Basel.
Brenneisen, S. (2003). Ökologisches Ausgleichspotenzial von extensiven Dachbegrünungen — Bedeutung für den Arten- und Naturschutz und die Stadtentwicklungsplanung. Doctoral dissertation, Institute of Geography, University of Basel, Switzerland.
In the UK we have evidence of a family party using a green roof at Canary Wharf as forage. This roof was not the standard sedum roofs commonly found on the estate but a specific field station that used commercial brick based substrates seeded with the London living roofs mixed. This was witnessed in 2006 2007 and 2008. One of the commonest two plants on this roof are birds foot trefoil and Kidney Vetch important forage plants for rare bees.
Visual observation of black redstarts have not been noted whilst on the roofs but there are several roofs in the London area where black redstarts have been observed singing from.
I would also like to highlight I am one of the originators of the 'brown' roof idea and now recognised as one of the leading authorities on green roofs and biodiversity in the UK. In the early days we were seeking a mix of crushed brick and concrete and for roofs to self colonise. This is been refined as at the time commercial brick based substrates were not widely available in the UK. To balance the growing acceptance that green roofs are a good source control mechanism in the SUDS train and the fact that the EA are allowing on a case by case base run-off rates from green roofs it is important to use substrates which have known run off co-efficients. These should be then planted with a range of wild flowers associated with brown field habitat and known to be of high value to rare invertebrates. The use of crushed concrete is not advisable for a number of reasons - low porosity, lack of understanding of the quality (I have heard of stories (real) of recycled local aggregate being used that was found to be polluted with asbestos) and poor growth rates of plants.
I would recommend referencing the EA green roof toolkit which provides the most detailed approach to green roofs and biodiversity currently in the UK, which I wrote last year. www.environment-agency.gov.uk/business/sectors/91967.aspx
It has now been shown in a mirror of an identical study in Switzerland that such green roofs do support rare invertebrates. This PhD was undertaken by Dr. G. Kadas in London between 2004 -2007 and the results are reviewed in peer reviewed article that Dr. Kadas and I wrote for the Institute of Biology www.iob.org/userfiles/File/biologist_archive/Biol_52_3_Kadas.pdf
As an insectivore good populations of invertebrates are an important factor for black redstarts.
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In terms of habitat area at roof level, this is difficult to pin down. However the average territory for black redstarts is between 3 - 7 HAs. My advice has always been that for every pair that needs to be mitigated for at least 3HAs of habitat should be set aside. In Urban development this should mean at least 2HAs of roof space if amenity landscape is to be used at ground level. The other ha can be considered non green elements of buildings, industrial plant areas. Black redstarts do use these.
In terms of continuity during construction and demolition black redstarts are perhaps unique as demolition can make a site more favourable for black redstarts (not surprising as they are associated with alpine scree slopes). I would recommend an annual monitoring programme as they have been known to nest in shown strange places. One of my favourite stories is the pair that nested on the axle of freight container in Bremenhaven and proceeded to accompany the nest and container when loaded onto a freight liner bound for Tilbury!!! Everyone survived apparently the truckers and crew feed the adults during the crossing and the nest was moved to a local wildlife sanctuary!!! Chicks survived and flourished!
I have been involved with a long term monitoring during the construction of the East London Line at Bishopsgate in the City for four years. This should not be a panic for the developer as black redstarts are relatively tolerant of people. It is just good to know where the nests are to assess what should be done. In most cases this should not affect any work programmes.”
As mentioned in my previous correspondence I would be keen to see a recognised expert like Mr Gedge brought in to oversee the issues raised above.
Natural England
The information supplied as part of the application includes details of the location and populations of the following protected species, together with an assessment of the likely impacts.
Species Protection legislation Bats The Conservation (Natural Habitats &c.) Regulations 1994 (as amended) The Wildlife and Countryside Act 1981 (as amended) Widespread The Wildlife and Countryside Act 1981 (as amended) reptiles Breeding Birds The Wildlife and Countryside Act 1981 (as amended)
Paragraph 98 of ODPM Circular 06/2005 2 states that ‘The presence of a protected species is a material consideration when a planning authority is considering a development proposal that, if carried out, would be likely to result in harm to the species or its habitat.’ Paragraph 99 also states that ‘It is essential that the presence or otherwise of protected species and the extent that they may be affected by the proposed development, is established before the planning permission is granted otherwise all relevant material considerations may not have been addressed in making the decision.’
Relevant legislation
2 Office of the Deputy Prime Minister Circular 06/2005 Government circular: Biodiversity and geological conservation- statutory obligations and their impact with the planning system.
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Details of the legislation relevant to this application are included in Annex One appended to this letter. Natural England’s comments relating to each species are provided in the following sections.
Bats
The survey information provided by the applicants indicates that species of bat are present within the application site. The indicative proposals set out in the application, however, appear sufficient to mitigate any potential impacts on bat populations. Therefore, subject to the condition listed below, Natural England is satisfied that these proposals should not be detrimental to the maintenance of the population of the species concerned at a favourable conservation status in their natural range (as defined in Regulation 44 of the Habitat Regulations).
The following condition is required to ensure that development does not breach English or European legislation.
• Prior to the commencement of any works which may affect bats or their breeding sites or resting places, a detailed mitigation strategy shall be submitted to, and approved in writing by the Local Planning Authority. All works shall then proceed in accordance with the approved strategy with any amendments agreed in writing.
Where a development affects bats or their places used for shelter or protection, work may need to be conducted under a Regulation 44(2)(e) 3 overriding public interest licence. These licences are administered by the Wildlife Management and Licensing Unit of Natural England who can be contacted on 0845 601 4523 for further information on the licensing process.
Widespread Reptiles
The survey information provided by the applicants indicates that species of reptile are present within the application site. The proposals set out in the application, however, appear sufficient to mitigate any potential impacts on local reptile populations. Therefore, Natural England is satisfied that these proposals will not be detrimental to the population of reptile, subject to the condition listed below.
• Prior to the commencement of any works which may affect reptiles or their habitat, a detailed mitigation strategy shall be submitted to, and approved in writing by the Local Planning Authority. All works shall then proceed in accordance with the approved strategy with any amendments agreed in writing.
Breeding birds
The survey information reveals that a number of bird species utilise the application site for breeding. However, the proposals to conduct any site clearance works outside of the breeding bird season and provide replacement nesting opportunities through the landscaping strategy (full details to be submitted at the detailed application stage), therefore Natural England is satisfied that this proposal should not be detrimental to local breeding bird populations.
Thames Gateway Green Grid
3 Of The Conservation (Natural Habitats &c.) Regulations 1994 (as amended)
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Thames Gateway North Kent is a place of great opportunity and challenge and the Green Grid Programmes for Kent Thameside, Medway and Swale are a co-ordinated response to seize the opportunities and meet the challenges presented. The Thames Gateway Green Grids set out how strategic partners can transform the environment of Thames Gateway north Kent into an attractive and distinctive place in which to live, work and invest. They are environmental enhancement programmes for Thames Gateway North Kent, which provide a framework within which partners can demonstrate effective project delivery, creating an environment of the highest quality with a distinctive identity.
Natural England is a key Green Grid partner and expects all Thames Gateway North Kent development proposals to include an outline of how natural greenspace and water courses within a new development would link into the Green Grids for North Kent. In this case the application site falls within the Ebbsfleet Valley and A2 Corridor Green Cluster study 4. The proposed green space proposed by the development is welcome and provides valuable wildlife corridors linking green infrastructure to the south to the Thames.
In addition we welcome the provision of pedestrian access to the Thames at Bevans Wharf. It should be noted that there are proposals for a City to the Sea path that will link the Thames path at Greenwich to the Saxon Shore Way at Gravesend. It is envisaged that this will be a multi-user path and where possible a minimum of 4m wide. It is therefore important when looking at this application at the detailed planning stage that consideration of this proposed long distance path is taken into consideration.
Landscape Assessment
We welcome the inclusion of a landscape assessment for this application. We would agree with the findings that the proposed development will improve the visual aspect of the area and provide a stronger link between the town and river. There will be a loss of the chimneys that provide a distinct landmark on the skyline but this is more than outweighed by the benefits of the scheme i.e. open space and linking the town to the river.
Biodiversity Enhancements
This application has indicated a number of opportunities to incorporate features into the design which are beneficial to wildlife such as the incorporation of roosting opportunities for bats, the installation of bird nest boxes or the use of native species in the landscape planting, for example. As such we would recommend that should the Council be minded to grant permission for this application, measures to enhance the biodiversity of the site are secured from the applicant by way of a condition.
Additionally, the application refers to the use of brown and green roofs to a number of the buildings that would not only benefit a range of wildlife but can also reduce a building’s carbon footprint and reduce/slow water run-off. These are to be encouraged and should be secured at the detailed planning stage.
Summary and conclusions
4 Produced by Greening the Gateway Kent and Medway www.gtgkm.org.uk of which Natural England is a partner
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Based on the information provided, Natural England has no comments to make at present regarding protected species subject to the conditions described above.
It should be noted that the protection afforded to species under UK and EU legislation is irrespective of the planning system and the applicant should ensure that any activity they undertake on the application site (regardless of the need for planning consent) must comply with the appropriate wildlife legislation. Failure to do so may result in fines and potentially, a custodial sentence.
Natural England would be grateful if the Council were to inform us as to how our advice has been incorporated into the decision made when determining this application.
Southern Water
Following initial investigations, there is currently inadequate capacity in the local network to provide foul sewage disposal to service the proposed development. The proposed development would increase flows to the public sewerage system, and existing properties and land may be subject to a greater risk of flooding as a result.
The public sewer is a combined system, receiving both foul and surface water flows, and no flows greater than currently received can be accommodated in this system. However, it is possible that by removing some of the existing surface water entering the sewer, additional foul flows could be accommodated, i.e. no net increase in flows.
If the applicant wishes to investigate this option, the applicant will be required to provide Southern Water with a topographical site survey and/or a CCTV survey. The survey should show the existing roof, drive and highway areas draining to the sewer and their connection points, pipe sizes, gradients and calculations confirming the proposed flows will be no greater than the existing flows received by the sewer.
As an alternative to the above, additional off-site sewers, or improvements to existing sewers can be provided to service the development. Section 98 of the Water Industry Act 1991 provides a legal mechanism through which the appropriate infrastructure can be requested (by the developer) and provided a specific location.
Southern Water requires a formal application for a connection to the public sewer. The applicant is advised to contact Atkins Ltd, Anglo St James House, 39A Southgate Street, Winchester, SO23 9EH (tel 01962 858688), or www.southernwater.co.uk
This initial assessment does not prejudice any future assessment or commit to any adoption agreements under Section 104 of the Water Industry Act 1991.
The Council’s building Control officers or technical staff should be asked to comment on the adequacy of soakaways to dispose of surface water from the proposed development.
The application details for this development indicate that the proposed means of surface water drainage for the site is via a watercourse. The Council’s technical staff and the relevant authority for land drainage consent should comment on the adequacy of the proposals to discharge water to the local watercourse.
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The planning application form makes reference to drainage using Sustainable Urban Drainage Systems (SUDS).
Under current legislation and guidance SUDS rely upon facilities which are not adoptable by sewerage undertakers. Therefore, the applicant will need to ensure that arrangements exist for the long term maintenance of the SUDS facilities. It is critical that the effectiveness of these systems is maintained in perpetuity. Good management will avoid flooding from the proposed surface water system, which may result in the inundation of the foul sewerage system. Thus, where a SUDS scheme is to be implemented, the drainage details submitted to the Local Planning Authority should:
Specify the responsibilities of each party for the implementation of the SUDS scheme
Specify a timetable for implementation
Provide a management and maintenance plan for the lifetime of the development. This should include the arrangements for adoption by any public authority or statutory undertaker and any other arrangements to secure the operation of the scheme throughout its lifetime.
We request that should this application receive planning approval, the following condition is attached to the consent: “Construction of the development shall not commence until details of the proposed means of foul and surface water sewerage disposal have been submitted to, and approved in writing by, the Local Planning authority in consultation with Southern Water”.
I enclose a plan showing the existing sewers and water mains which will be affected by the proposal. The developer must respect the easements in place for protection of the apparatus or fund any necessary diversions. No new buildings, tree planting or soakaways should be located close to the apparatus. Easements vary depending upon the depth and size of plant affected. The developer should discuss the protection of apparatus at the earliest opportunity.
In order to protect drainage apparatus, Southern Water requests that if consent is granted, a condition is attached to the planning permission. For example “The developer must advise the local authority (in consultation with Southern Water) of the measures which will be undertaken to protect/divert the public sewers and public water mains, prior to the commencement of the development”.
Environment Agency
The Environment Agency has no objection to the proposal provided that the condition/s within this letter are imposed on any planning permission granted:
Issue: Contamination
We are aware of the historical investigations undertaken at this site and in the immediate area, and note that there are areas of the development site which are yet to be investigated. The following conditions are therefore requested to ensure that all aspects of potential contamination are dealt with at this site, so that no Part 2A liabilities remain following development:
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Condition:
Prior to the commencement of development approved by this planning permission (or such other date or stage in development as may be agreed in writing with the Local Planning Authority), the following components of a scheme to deal with the risks associated with contamination of the site shall each be submitted to and approved, in writing, by the local planning authority:
1) A preliminary risk assessment which has identified: - all previous uses - potential contaminants associated with those uses - a conceptual model of the site indicating sources, pathways and receptors - potentially unacceptable risks arising from contamination at the site.
2) A site investigation scheme, based on (1) to provide information for a detailed assessment of the risk to all receptors that may be affected, including those off site.
3) The site investigation results and the detailed risk assessment (2) and, based on these, an options appraisal and remediation strategy giving full details of the remediation measures required and how they are to be undertaken.
4) A verification plan providing details of the data that will be collected in order to demonstrate that the works set out in (3) are complete and identifying any requirements for longer-term monitoring of pollutant linkages, maintenance and arrangements for contingency action.
Any changes to these components require the express consent of the local planning authority. The scheme shall be implemented as approved.
Reasons:
The site is underlain by upper chalk principal aquifer and is located within Source Protection Zone II for a number of groundwater abstractions.
Condition:
If, during development, contamination not previously identified is found to be present at the site then no further development (unless otherwise agreed in writing with the Local Planning Authority) shall be carried out until the developer has submitted, and obtained written approval from the Local Planning Authority for, an amendment to the remediation strategy detailing how this unsuspected contamination shall be dealt with.
Reasons:
The site is underlain by upper chalk principal aquifer and is located within Source Protection Zone II for a number of groundwater abstractions.
These conditions have been recommended as the Environment Agency is satisfied that there are generic remedial options available to deal with the risks to controlled waters posed by contamination at this site. However, further details will be required in order to ensure that risks are appropriately addressed prior to development commencing.
In line with the advice given in PPS23, we understand that the Authority must decide
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whether to obtain such information prior to determining the application or as a condition of the permission. Should the Local Planning Authority decide to obtain the necessary information under condition we would request that this condition is applied.
Issue: Piling
Condition:
Piling or any other foundation designs using penetrative methods shall not be permitted other than with the express written consent of the Local Planning Authority, which may be given for those parts of the site where it has been demonstrated that there is no resultant unacceptable risk to groundwater. The development shall be carried out in accordance with the approved details.
Reasons:
To protect the groundwater environment within the underlying chalk principal aquifer.
This should be constructed in accordance with Environment Agency guidance; Piling and Penetrative Ground Improvement Methods on Land Affected by Contamination: Guidance on Pollution Prevention and Piling into contaminated Sites. The guidance is available on the Environment Agency website, under publications.
Model Procedures and Good Practice
Informative/ advice to applicant:
The Environment Agency recommends that developers should:
1. Follow the risk management framework provided in CLR11, Model Procedures for the Management of Land Contamination, when dealing with land affected by contamination.
2. Refer to the Environment Agency Guidance on Requirements for Land Contamination Reports for the type of information that we require in order to assess risks to controlled waters from the site. The Local Authority can advise on risk to other receptors, such as human health.
3. Refer to our website at www.environment-agency.gov.uk for more information.
Clean, uncontaminated, naturally occurring, non-putrescible material only shall be permitted as infill material.
Any remediation must be carried in a strictly controlled manner to ensure that contaminants are not exposed and releases allowed to air, land or controlled waters, which could cause pollution, harm or nuisance. Clearing areas, particularly removing hardcover, must be done in a manner not likely to expose contaminants to flushing by incipient rainfall or surface water run-off on the site. Temporary surface water controls and management of any materials movement on site is critical to ensure protection of controlled waters near the site.
Informative/ advice to applicant:
The recovery, treatment and disposal of contaminated soils and groundwater is
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regulated by waste legislation and requires an Environmental Permit (2007) .
Treatment of contaminated soil by mobile plant requires a mobile treatment licence. Soil may be re-used on-site as part of a soil recovery operation by registering a waste management licence exemption with the Environment Agency or by obtaining a Waste Management Licence.
Developers should ensure that all contaminated materials are adequately characterised both chemically and physically, and that the permitting status of any proposed on site operations are clear. If in doubt, the Environment Agency should be contacted for advice at an early stage to avoid any delays.
It is recommended that developers should refer to the Environment Agency’s:
- remediation position statements outlining its regulatory position on remediation processes - guidance on the Definition of Waste: developing greenfield and brownfield sites for assisting those involved with construction work in deciding whether or not they are handling waste. - website at www.environment-agency.gov.uk for further guidance.
Informative/ advice to applicant:
Contaminated soil that is excavated, recovered or disposed of, is controlled waste. Therefore, its handling, transport, treatment and disposal is subject to waste management legislation, which includes:
- Duty of Care Regulations 1991 - Hazardous Waste (England and Wales) Regulations 2005 - Waste Management Licensing Regulations 1994 (as amended) - Pollution Prevention and Control Regulations (England and Wales) 2000 - Landfill (England and Wales) Regulations 2002
Developers should ensure that all contaminated materials are adequately characterised both chemically and physically, and that the permitting status of any proposed off site operations is clear. If in doubt, the Environment Agency should be contacted for advice at an early stage to avoid any delays.
Treatment is defined using a three part test. Must:
• be a physical, thermal, chemical or biological process, includes sorting • change the characteristics of the waste • do so in order to: • reduce its volume or • reduce its hazardous nature or • facilitate its handling or • enhance recovery
It does not include compaction.
Producers of waste can treat themselves or pass to someone else to treat, but need written declaration of pre treatment having taken place, prior to sending to landfill.
Issue: Flood Risk
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The proposed development will only be acceptable if the following measures as detailed in the Flood Risk Assessment submitted with this application are implemented and secured by way of a planning condition on any planning permission.
Condition:
The development permitted by this planning permission shall only be carried out in accordance with the approved Flood Risk Assessment (FRA) by Peter Brett Associates incorporated in the submitted environmental statement, and the following mitigation measures detailed within the FRA:
1. Finished residential floor levels will be set no lower than 7.2m above Ordnance Datum (AOD) (section 9.6.2).
2. A 15m margin, measured from the landward toe of the flood defence, will be free from obstruction (section 9.6.7).
3. Identification and provision will be made for safe a route into and out of the site to an appropriate safe haven (section 9.6.4)
Reason:
1. To reduce the risk of flooding to the proposed development and future occupants.
2. To ensure the structural integrity of flood defences and the availability of maintenance access to the same.
3. To ensure safe access and egress from and to the site.
The site will discharge to the tidal river Thames and the volume and rate of runoff is therefore of less important than achieving improvements in water quality through the use of appropriate SUDs techniques. As the drainage strategy has not been finalised, we additionally request the following condition:
Condition:
Development shall not begin until a surface water drainage scheme for the site, based on sustainable drainage principles and an assessment of the hydrological and hydro geological context of the development, has been submitted to and approved in writing by the local planning authority. The scheme shall subsequently be implemented in accordance with the approved details before the development is completed.
Reason:
To prevent the increased risk of flooding, to improve and protect water quality, improve habitat and amenity, and ensure future maintenance.
For information, in addition to any planning permission, the prior written consent of the Environment Agency is required under the Water Resources Act 1991, and the Southern Region Land Drainage and Sea Defence Byelaws, for any proposed works or structures, in, under, over or within 15 metres of the top of the bank of the River Thames, or within
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15 metres of the landward toe of any flood defence, where one exists.
Issue: Biodiversity The proposed development will only be acceptable if a planning condition is imposed requiring a method statement to be agreed to ensure that the invasive weed species Japanese Knotweed present on site is prevented from spreading and/or eradicated.
Condition:
Prior to the commencement of development, a detailed method statement for the removal or long-term management /eradication of Japanese Knotweed on the site shall be submitted to and approved in writing by the local planning authority. The method statement shall include proposed measures to prevent the spread of Japanese Knotweed during any operations such as mowing, strimming or soil movement. It shall also contain measures to ensure that any soils brought to the site are free of the seeds/root/stem of any invasive plant covered under the Wildlife and Countryside Act 1981. Development shall proceed in accordance with the approved method statement.
Reason:
Japanese Knotweed is an invasive plant, the spread of which is prohibited under the Wildlife and Countryside Act 1981. Without measures to prevent its spread as a result of the development there would be the risk of an offence being committed and avoidable harm to the environment occurring.
Condition:
No development shall commence until a Code of Construction Practice has been submitted to and approved in writing by the Local Authority.
This CoCP shall include:
- Methods statements detailing how environmental impacts will be prevented during construction (e.g. erection of temporary fences)
- Measures to protect the mudflats to the east of the development
Thereafter the development shall be carried out in accordance with the approved plans.
Reason:
The production and implementation of the Code of Construction Practice is essential in ensuring that all potential environmental impacts of construction will be prevented or minimised.
Although not designated BAP habitat the mudflat to the east of the development site is likely to still be an important habitat for several species and should not be adversely impacted.
For information:
Fuel/Chemical Storage
Where it is proposed to store more than 200 litres (45 gallon drum = 205litres) of any type of oil on site it must be stored in accordance with the Control of Pollution (Oil Storage) (England) Regulations 2001. Drums and barrels can be kept in drip trays if the drip tray is capable of retaining 25 per cent of the total capacity of all oil stored.
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Care should be taken during and after construction to ensure that all fuels, oils and any other potentially contaminating materials should be stored (for example in bunded areas secured from public access) so as to prevent accidental/ unauthorised discharge to ground. The areas for storage should not drain to any surface water system.
Port of London Authority
Principle of the Development
The PLA has no principle objection to the re-development of this site for a mixed use development. The PLA is also supportive of the sister application which has been submitted to KCC for a bulk aggregates terminal. A copy of the PLA’s comments to KCC on the bulk aggregates application will be forwarded to Gravesham Council for information once they are available.
The PLA would not which to see the loss of the existing facilities which are currently located on the proposed mixed use development site unless the bulk aggregates import terminal is provided. It is noted that should planning consent be granted for both schemes that the construction of the bulk aggregates import terminal would occur during phase 2. The PLA would wish to see a suitably worded clause in a Section 106 agreement linking the two applications, ensuring that the mixed development can only go ahead should consent be granted for the aggregates import terminal. Furthermore, it should ensure that the aggregates import terminal is provided during phase 2 of the overall development.
Design of the Development
It needs to be ensured that the scheme is designed in such a way that the occupiers of the mixed use development will not be detrimentally affected by the operation of the bulk aggregates import terminal. In particular the Council needs to be satisfied that occupiers of the mixed use development will not experience unacceptable noise, dust and lighting levels from the aggregates terminal.
It is stated in the planning statement that “the physical separation between the aggregate import terminal and existing and proposed residential uses and the intervening employment uses mitigate any adverse impacts from the Bulk Aggregate Import Terminal.” This general approach of using land uses as buffering is welcomed and is reflected in the application through employment uses being located at the points to the aggregates terminal. Cliffs and formal open space then provide a further buffer with residential development being located alongside the riverside at the points furthest from the proposed aggregates terminal. The Council needs to satisfy itself at this outline stage that this approach is sufficient and that adequate consideration has been given in the Environmental Statement to air quality, noise and lighting impacts. This is necessary to ensure that any mitigation measures which are proposed at the detailed design stage are sufficient.
Air Quality
The air quality chapter of the Environmental Statement states that “the operation of the import terminal is unlikely to effect the proposed residential development because it is too far away.” Any impacts appear to be attributed to traffic. However, the Environmental Statement for the Aggregates Import Terminal states that the closest
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proposed dwellings are approximately 320m to the west of the open storage area. Whilst it is stated that at this distance there should be little dust deposition or elevated PM10 concentrations, the ES goes on to state that use of open stockpiles is proposed on occasions and therefore the mitigation measures set out in the ES should be used. The Council needs to satisfy itself that it agrees with the air quality assessment and it needs to ensure that the mitigation measures that the applicant is proposing in connection with the aggregates import terminal will be implemented.
Noise
At paragraph 8.8.9 of the ES it is stated that it is anticipated that industrial noise arising from the bulk aggregates import terminal will have an impact upon noise sensitive receptors, as a basis for detailed design. It is also anticipated that the rating noise level from the industrial activities of the bulk aggregates import terminal will not exceed +3dB above background noise levels.
When the PLA was consulted on the screening and scoping opinion it recommended that the potential noise impacts that were considered included vessels berthing, aggregates discharge, cargo handling on the site more generally, and the subsequent re-loading to barges from the wharf. The Council should satisfy itself that the noise monitoring which has been undertaken and the assumptions which have been made are appropriate and that the operation of an aggregates import terminal would not significantly affect the occupiers of the proposed mixed use development. This is particularly important as the aggregates terminal would work 24 hours a day.
Lighting
When the PLA was consulted on the screening and scoping request for the mixed use development it recommended that, on the basis that the aggregates terminal will potentially operate throughout the 24 hour day, the impacts of necessary on-site lighting should be assessed. I can find no reference in the documentation to consideration of the impacts of any lighting from the aggregates terminal and the potential impacts that this could have on the mixed use development.
Consideration also needs to be given to any lighting that is proposed alongside the River. This should be designed to minimise light spill towards the river, it should be white with no decorative coloured lights and it should be positioned such that it does not impede the navigation of vessels on the River Thames. It is suggested that a condition requires details of all lighting that is proposed on the site to be submitted to and approved by the Local Planning Authority.
PLA Navigational Equipment
As noted in the application, Northfleet works accommodates navigational equipment including that of the Port of London Authority. This navigational equipment includes radar, CCTV, Lighting and a Microwave Dish. The office block upon which the PLA’s navigational equipment is currently located would be removed as a result of the re- development of the Northfleet Works site.
The PLA and Lafarge have been working for some time now to find an alternative site for the navigational equipment and it is believed that in principle such a site has now been found. However, consent still needs to be obtained from Gravesham Planning Department for the alternative site and detailed discussions with Lafarge need to be held about specific aspects of the proposal. Additionally, once consent has been
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obtained, the radar tower needs to be built and the navigational equipment located on the radar tower. All this needs to occur prior to the demolition of the office block.
Whilst the office block and the location for the replacement tower are not located within the red line planning application boundary for the mixed use development, it is essential for the safety of navigation on the Thames that the replacement tower and its associated equipment is provided prior to the demolition of the office block.
Whilst a previous planning permission (reference GR/2005/0561) required through condition (19) that “before the development commences, the applicants, or their successors in title, shall in consultation with the Port of London Authority, provide details of how existing radar navigation coverage is to be maintained including details of the location of a replacement radar mast” this condition does not appear to have been complied with or enforced. It is therefore imperative that this matter is dealt with through the current planning applications for the re-development of the Northfleet Works site. The PLA would suggest that a suitably worded clause in a section 106 agreement requires the applicant to provide a replacement location for the PLA’s navigational equipment on a favourable basis. It should also require the PLA’s navigational equipment to have been satisfactorily relocated to the replacement location prior to the demolition of the office block.
The PLA would welcome further discussions with the applicant and the Council about this matter and the wording for the Section 106 agreement.
Use of the River for the Transport of Material
It is noted that the Environmental Statement makes reference to consideration being given to the use of the River Thames in removing certain heavier waste streams and to exploring opportunities to transport material to and from the site by sustainable modes including by barge from 42 Wharf. These references are welcomed. A condition or a clause in a section 106 agreement should secure this.
Sustainability Strategy and Appraisal
It is noted in the Sustainability Strategy and Appraisal that biomass has been discounted. One of the reasons for this appears to be the transport of material. Was any consideration given to the use of the River for the transport of biomass material to the site?
River Works Licence
It would appear from the plans that none of the works would extend over Mean High Water. It is also noted that Bevans Wharf which is outside of the application boundary is to be removed during phase 2 (2012-2014) and that this does not require planning permission. The applicant is advised to contact the PLA’a River Works Licensing Officer, Pauline Redwood on 01474 562 267 to discuss this matter further.
English Heritage South East Region
We do not wish to comment in detail, but offer the following general observations.
English Heritage Advice
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The planning application referred to English Heritage relates only to the part of the site of the Lafarge cement works at Northfleet that is intended to be redeveloped for use as a bulk aggregates import terminal. We note that there is a "sister" application for a mixed use development on the remainder of the cement works which is alluded to in the aggregates site application. We have, of course, not commented on this but I would suggest that the points below apply in general terms to that application also.
The application is referred to English Heritage on grounds of the affects on the setting of a scheduled ancient monument and because it is development affecting a conservation area where the application site is greater than 1000 sq.m. In the case of the former, the relevant monument is the Aspdin's Kiln to the west of but outside the application site boundary. The Kiln's immediate context is formed of industrial units that almost entirely enclose it. It is not visible from any nearby public areas and is not directly connected to the application site, which is itself a site of heavy industrial character. Consequently, I can see no affect on the setting of the monument arising from the proposed aggregates depot.
The site's location adjacent to The Hill Conservation Area is unlikely to result in any harmful impact on the character or appearance of the area. The conservation area is positioned on a cliff above the works site; if there will be any affect on the appearance of the area it will result form the demolition of the two tall chimney stacks that are a major feature of the townscape of Northfleet. However, this change may be neutral rather than negative in terms of the appearance of the conservation area. The character of the area will itself not be affected by the change in industrial processes on the neighbouring Lafarge site.
The site contains two listed buildings, the war memorial and lighthouse, both listed at Grade II, that are affected by the proposals. We are not asked to comment on the potential impact on either of these, but we note the intention to relocate the war memorial within the site. While acknowledging that the memorial has been repositioned in the past and is therefore not on its original site, its proposed removal will require a separate listed building consent application which, I understand, has not been submitted. This should be requested immediately and should be determined in parallel with the planning application. The lighthouse is to be retained in its present position on the wharf side. The Council should include a condition on any permission requiring the protection of these structures during the demolition and redevelopment process.
Archaeology is a matter for the Council taking advice from its archaeology adviser at Kent County Council. We note and welcome the fact that the applicant has provided for a full record of the present structures on the site to be made and that the Environmental Statement reflects this. We suggest that there may be salvageable structures relating to the industrial heritage of the site that could be re-used within the redevelopment or housed in a local museum or archive, and the Council may like to impose an appropriate condition to that effect. The County Archaeologist will want to advise on the appropriate form of a condition in respect of the evaluation and recording of any archaeology on the site through trial excavation or watching brief.
Recommendation
We would urge you to address the above issues, and recommend that the application should be determined in accordance with national and local policy guidance, and on the basis of your specialist conservation advice. It is not necessary for us to be consulted again. However, if you would like further advice, please contact us to explain your request.
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Kent County Council, Archaeologist
Thank you for consulting us on the outline application for mixed development at the above site. The application is accompanied by an Environmental Statement and cultural heritage issues are addressed mainly in Chapter 15 with several specialist appendices on built environment, archaeology and palaeolithic assessment.
I would like to provide some general comments on the heritage issues for this development and the cultural heritage assessment by the applicant. In addition, there are three more significant issues I wish to raise, firstly the consideration of the chimneys and secondly the character of the new development and thirdly the location of the memorial.
When considering cultural heritage there are three aspects to consider: archaeology, historic buildings and historic landscapes. For some reason, the cultural heritage assessment in Chapter 15 of the ES does not consider historic landscapes although there is mention of it in the Regional Planning Policy section, ES, 15.2.10. I would like to encourage CgMs to ensure consideration of cultural heritage is complete and that they include historic landscape assessment. For this particular application, the historic landscape is very much an industrial one. There should be consideration of the historic features such as the slurry backs, the chimneys, the tunnels and the quarry faces and then refer to the proposed open spaces. I understand the tunnels and quarry faces will probably remain and as such there is an issue about how the new development would impact on them. The tunnels, quarry faces and slurry backs all relate to each other forming key parts of the industrial cement works. How will these historic elements sit within the development and how will their historic context and integrity be protected and preserved? I understand the comments in the Built Heritage Baseline Assessment (paragraph 4.4.31) on the complexity of the nature of these remains but this stresses the need to retain the full structures themselves wherever possible, decide how they are going to appear in the new development and provide interpretation, so the knowledge of these structures, their function and construction, is not lost.
It would be preferable for one or more of the chimneys to be preserved. These are important historic industrial structures and could be considered as iconic structures within the wider landscape of North Kent. They are clear reminders that Northfleet was the original home of Portland Cement, a nationally important innovation in the world of construction. The popularity, success and development of Portland Cement was a crucial part of Northfleet and Kent’s past economy and community. The chimneys are also striking historic landscape features and can be seen for miles, including at the gateway into Kent across the Queen Elisabeth II Bridge. They are symbols of the success of the North Kent industrial commerce and of Kent’s historic relationship with the river. I do appreciate that the applicants have undertaken assessment of this issue. There do seem to be substantial long term financial, safety and management issues but these have surely been addressed for other tall structures within England. Preservation by record of these large structures will not be able to reflect their shear size and mass when standing next to them and their towering nature rising well above the surrounding buildings. The scale of these chimneys gives an impression of the enormous size of cement industrial structures. They would not necessarily be completely isolated industrial historic structures as the
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tunnels and quarry faces will be visible too. As with Ingress Park, Greenhithe heritage attributes of a site can be retained and form a positive part of a development.
I welcome the proposal to retain some of the smaller structures and fixtures currently surviving within the cement works (15.6.6). Would it also be possible to retain the tram lines in situ or reposition them within the new development roads? There are elements within this cement factory which can be used to reflect the history of activity and past communities and give the new residents of the proposed development a “sense of place”. The character of the industrial activity could be visibly reflected in the new street furniture and especially in the design of the open spaces, including perhaps any playgrounds, benches, landscaping etc. The historic character of this site should be seen as a positive asset to the new development, providing a sound base for a distinctive character and innovative design of buildings and streets. I recommend that the historic environment here, particularly the cement works, is used to inform and guide the layout and design of the new development.
I welcome the proposal to retain the memorial and relocate to a more sympathetic location. However, I query whether relocating to another active industrial site is the best option. The memorial is certainly related directly to the Northfleet Works here and the association is important but the memorial is to the people who died in the war and who lived and worked here. I suggest other locations for this memorial should be considered, such as in an open space within the new development. This would provide a clear symbol to remember local people lost in the war and the close tie between the cement works and the people of Northfleet. The memorial would also then be far more accessible and visible to existing residents, future residents and visitors.
The proposal to fully record the buildings on the entire site at this stage, supplemented by oral evidence, is very welcome. I have not been consulted on this in detail recently and certainly have not been given any recent updates on the progress of work.
The assessment of the archaeology and the palaeolithic element is fine. Reasonable fieldwork assessment has been done to clarify the palaeolithic potential and clearly some further work would be appropriate. Generally the mitigation proposed for archaeology and the palaeolithic is acceptable in content but I do not agree with the wording of the condition. The condition should cover the whole site not just a targeted area.
In summary, I set out the following comments:
• Historic landscapes form part of the historic environment and should be considered alongside historic buildings and archaeology. The historic landscape of this application site is the industrial features, structures and character and this includes the tunnels, quarry faces, chimneys and smaller fixtures, such as tramlines and bollards. I would welcome further consideration of these and consideration of how they can provide a positive contribution to the character and layout of the new development;
• It would be preferable for the chimneys to be retained as structural reminders of the importance and origins of the Portland Cement Industry and of the shear scale, mass and extent of the engineering associated with this industry. They are also iconic historic landmarks for North Kent. I would welcome further
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consideration of how they could be retained, what are the issues to be addressed and how these are addressed for other tall structures in the country.
• I welcome the assessment of the potential for retention or preservation of undesignated features (4.4 of Built Heritage Baseline Assessment). The retention of the tunnels, quarry faces and smaller fixtures can be a positive contribution to the character and quality of the new development. I encourage complete retention of the slurry backs and emphasize the positive benefits to providing interpretation to enable understanding, education and enjoyment of the remnants of a significant Kentish activity within this large development.
• I welcome retention of the memorial but suggest that other options for a new site should be considered further. Accessibility to the local people should be a high priority plus the long term setting should also be considered. Placing this memorial within the heart of the new development, forming part of an open space, could address these issues well. Connections with Northfleet Cement Works is important and should not be lost but this could be addressed by ensuring areas of the new development also reflect the industrial past.
• The assessment of archaeology and the palaeolithic potential is reasonable and supported by agreed specialist fieldwork.
The mitigation proposed for archaeology is generally fine although it should cover the entire site. Mitigation for other aspects, such as the chimneys, slurry backs etc still need resolving. I therefore do not agree with the single proposed condition. I would prefer a few issues set out above to be resolved more fully but if it is decided to determine this application at this stage, I recommend the following conditions are placed on any forthcoming consent:
AR1 No development shall take place until the applicant, or their agents or successors in title, has secured the implementation of a programme of archaeological work in accordance with a written specification and timetable which has been submitted to and approved by the Local Planning Authority.
Reason: To ensure that features of archaeological interest are properly examined and recorded.
and
AR2 No development shall take place until details of foundations designs and any other proposals involving below ground excavation have been submitted to and approved by the Local Planning Authority. Development shall be carried out in accordance with the approved details.
Reason: To ensure that due regard is had to the preservation in situ of important archaeological remains. and
AR7 No development shall take place until the applicant, or their agents or successors in title, has secured the implementation of a programme of building recording in accordance with a written specification and timetable which has been submitted to and approved by the Local Planning Authority.
Reason: To ensure that historic building features are properly examined and recorded.
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And
No development shall take place until the applicant, or their agents or successors in title, has secured the implementation of a programme of historic landscape recording work in accordance with a written specification and timetable which has been submitted to and approved by the Local Planning Authority.
Reason: To ensure that historic landscape features being retained are properly examined and recorded.
and
On completion of the project the Developer, or their agents or successors in title, will arrange for the development archaeological archive to be deposited in a suitable museum or similar repository to be agreed with Kent County Council and the District/Borough Council. Deposition of the archive will include a one-off payment by the Developer at the standard museum archive storage rate per box at the time of deposition.
Reason: To ensure suitable provision for the long term storage of the archive
And
No development shall be carried out until a long term heritage management plan (including interpretation facilities and a heritage trail) of archaeological finds and heritage elements of the site have been submitted to and approved by the Local Planning Authority. Upon approval, the works shall be implemented as approved plan.
Reason: To facilitate awareness and enjoyment of the heritage of the site through interpretation and selective preservation
Conservation Officer, Gravesham Borough Council
Subject to suitable context/location for the war memorial there are no comments to make.
Kent Highways (KHS)
No formal comments have been received at this stage as discussions are ongoing between KHS, the Highways Agency and the applicants. The following questions and comments were submitted to the applicants by KHS in June 2009.
Questions and requests for which KHS are currently awaiting information from applicant (as at 5 th June 2009):-
1. Assessment of impact on junction of Thames Way and Ebbsfleet Gateway (requested June 2008 in KHS response to the scoping report and October 2008);
2. Assessment of impact on junction of A226 London Rd and B255 St Clements Way (requested June 2008 in KHS response to the scoping report and October 2008);
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3. Independent safety audit of proposal to open the two roads through the tunnels for public traffic (requested 13 th May 2009);
4. Feasibility Report about proposal to open the tunnels to public traffic, including information about drainage and road gradients, and investigating the works necessary to upgrade to standards suitable for public use (lighting, ventilation, fire tolerance, structural condition etc). We would need to be confident of the tunnels’ structural integrity for the next 120 years. (requested 13 th May 2009);
5. Origin-Destination matrices used to model journeys to and from the Mixed Use Development (requested 14 th May 2009);
6. No response yet on request to visit the sites of the proposed developments.
Further questions and requests we would like to discuss with the applicant:
1. We would like our request for an independent safety audit to extend to all accesses to the proposed development, including the proposed emergency access route around the Blue Lake. (Is the route via the Blue Lake sufficient to cope with requirements even if there is a crash or fire in the main road tunnel into Church Path pit?).
2. In view of the high level of traffic flows indicated on critical links and junctions we would like to reiterate our request of October 2008 that the applicant models the network using an extended version of the Eastern Quarry / Ebbsfleet paramics model. Among the advantages would be a more accurate representation of the road network around Ebbsfleet station and the priority-give-way traffic-calming which will reduce the capacity of Springhead Road.
3. In paragraph 5.5.2 there is reference to Figure 5.1 which is not included. We would like to see a plan (drawing) of the proposals for Grove Road.
4. Paragraph 5.5.5 refers to the Hive Lane access being 5.6m wide, but paragraph 5.5.14 says a cycle path would be provided “integrated within the carriageway”. Clarification is required. If cyclists are to cycle on the carriageway, is this “cycle path” actually a cycle lane and is it included within the 5.6 metres? The information in paragraph 5.5.5 of the TA does not agree with the drawing of Hive Lane in Figure 8.4 of the Design and Access Statement.
5. Figures 7.1 and 7.2 show significant increases in traffic on Springhead Road and Dover Rd. Bearing in mind that both of these have single-track sections (one due to traffic calming, the other due to parked cars) – would these links still be within capacity?
Other comments on Transport Assessment and Design and Access Statement:
1. KHS is concerned about the long-term maintenance of the tunnels and cliff faces. Appropriate measures need to be set up for monitoring the structural condition of the tunnels and cliffs and for their maintenance in perpetuity before any parts of the development are occupied.
2. It is likely we would want the proposed “pinch point” removed from Grove Road, which would need the cooperation of the Environment Agency.
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3. With regard to the comments about the access tunnels (paragraph 5.5.3), KHS would not accept responsibility for the tunnels or the roads through them or the proposed footbridge over the entrance road (paragraph 5.5.18).
4. It is noted that 5.5.5 says around 95% of traffic between the development and B2175 would use Hive Lane. The modelling seems to use College Road to represent the Hive Lane, and Table 7.12 shows significant queuing for westbound traffic in the morning at this junction. It appears that a right-turn queuing lane would be beneficial, which in turn would be likely to require substantial changes to the mouth of the junction. Similarly it is likely that the London Road junctions with Hive Lane and College Road would need to be signalised with pedestrian phases replacing the existing adjacent pelican crossings. The presence of signalised junctions would help lower the number of vehicles using London Road in preference to Thames Way.
5. Paragraph 5.5.16 states that pedestrians and cyclists were not to use the Vineyard Pit tunnel. However, due to lack of acceptable alternative route, it is likely that pedestrians and cyclists would persist in using this tunnel. A single track road through the tunnel under signal control might be preferable, leaving space for a path for pedestrians and cyclists so long as this does breach any regulations.
6. Paragraph 5.5.16 also states that the public right of way under the railway line (path NU7A) will be retained and enhanced. However, this path is narrow (1.8m under railway bridge and narrower in other places) and steep (up to 1-in-7 gradient). Although any upgrade would certainly be welcomed, it should be noted that the path has limited capacity and does not meet standards for disabled users or cyclists.
7. Table 6.5 contains errors in the “All vehicles” column; see for example the line for B8 category development.
8. Is there any reason why the comments in paragraph 7.2.7 disregard higher increases in traffic which can be found in Figures 7.5 and 7.6? These are found on Overcliffe, namely 13% eastbound AM and 12% westbound AM.
9. Paragraph 7.3.6 shows that one arm of the Thames Way / Stonebridge Road roundabout is estimated to be with 95% of capacity in the AM peak by 2025, even without the development. The fact that this figure seems to reduce when the development is modelled we believe is due to congestion up-stream at the junction with Hive Lane. Nevertheless, the figures are of concern because the model only shows the average 3-hour peak traffic flows, not the peak of the peak traffic.
10. Paragraph 8.1.1 mentions improvements to the tunnel entering the southern part of Vineyard Pit; could these be clarified please.
11. Figures 8.3 and 8.7 of the Design and Access Statement appear to show that public footpath NU42/2 north of Lawn Road has been closed. Figures 3.4 and 3.5 of the Design and Access Statement appear to show that the land under footpath NU42/2 has been excavated to accommodate the new road to the industrial area. Please confirm that this is the plan.
12. The Design and Access Statement makes no reference to cycle parking for the proposed houses and apartments. This needs to be as specified in the Supplementary Planning Guidance 4 of the Kent and Medway Structure Plan.
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13. The Design and Access Statement figures show the proposed pedestrian / cycle routes. It is important to be able to understand where the proposed cycle network is planned, so please could these routes be specified?
14. In view of the aspiration to build a “Thames Path” along the banks of the Thames within Kent Thameside, this needs to be incorporated into the design. The Thames Path footpath / cyclepath needs to extend across the entire river frontage of the development (with the exception of the industrial wharves) and should include Robins Creek barrier.
15. Section 4 of the TA, “Future Transport Networks” refers to the delivery of the final two phases of Fastrack by 2018. It should be noted that Fastrack route D would only be able to go through the site if the developer builds the route. The reference to Crossrail services to Ebbsfleet (should be Northfleet?) by 2017 is extremely optimistic.
Highways Agency
The Highways Agency’s interest relates to the Strategic Road Network (SRN) that we manage on the Secretary of State’s behalf. In this case, it relates to the M25 (A282) at junction 1b and the A2 trunk road. In spatial planning and development control terms, we have a duty to safeguard the operation and safety of the trunk roads in accordance with the Government’s policy as laid down in DfT Circular 02/2007 ‘Planning and the Strategic Road Network’ (and PPG13). The Transport Assessment (TA) must be constructed with due regard to Circular 02/2007 and DfT/DCLG ‘Guidance on Transport Assessment’ (March 2007).
A TA has been prepared by Peter Brett Associates (on behalf of Lafarge Cement UK), dated February 2009 in order to predict the traffic impacts associated with the proposed development. AECOM Transportation have reviewed the TA and have advised us on the adequacy of the TA (see accompanying Technical Note).
One deficiency that was identified was that the TA did not consider the impact of the proposed development upon the Strategic Road Network (SRN). Consequently, we are unable to fully understand the traffic implications of this development which allow the Secretary of State to come to a view. We are therefore issuing an Article 14 ‘Holding Direction’ to allow additional assessment work to be undertaken. The Holding Direction shall remain in place for six months.
Technical Note
The technical note accompanying the HA’s comments has been prepared by AECOM Transportation (formerly Faber Maunsell AECOM). The conclusions and recommendations of the technical note are as follows:-
This Technical Note has been prepared in response to a planning application for a mixed use development at Northfleet Works comprising of around 510 residential dwellings, 46,000sqm of employment and restaurants/take-away outlets.
The planning application is being put forward by land owners Lafarge in parallel with a planning application for a Bulk Aggregates Import Terminal on an adjacent site.
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This Technical Note has considered the Transport Assessment and the Draft Framework Travel Plan submitted as part of the planning application. The focus of this note has been to determine the potential impact of the proposed development upon the strategic road network, in this case the A2 and M25.
The TA has considered the impact of the proposed development utilising the KTS Model. Unique KTS Model scenarios have been developed which test the impact of the proposed development and neighbouring Bulk Aggregates Import Terminal. The impact of the proposed mixed use site only upon the strategic road network junctions in Kent Thameside has not been presented. AECOM has undertaken its own assessment utilising information provided in the TA and the original (version 4) KTS Model to determine the potential impact of mixed use site development flows at the three strategic junctions which are expected to be most affected by the development – M25 Junction 1a, A2 Ebbsfleet Interchange and A2 Pepperhill Interchange.
AECOM’s assessment has determined that the mixed use site could have a material impact on these junctions including the slip roads and associated junctions and local road arms.
The TA has not provided junction capacity assessments nor proposes any mitigation measures at these junctions.
The TA does not clearly indicate whether the developer intends to contribute to the Strategic Transport Investment Programme. Based on a residential tariff of £5,000 per dwelling, the development could generate a contribution in excess of £2.5million. Without a contribution to the STIP, a more traditional approach could be required to securing monies from the developer to fund highway improvement schemes which are specifically aimed at mitigating the impact of the proposed mixed use site. Without sufficient funding to the STIP, a number of the proposed schemes, some of which could be of benefit to the proposed development, may not be delivered.
In its current form, the Draft Framework Travel Plan does not sufficiently detail the proposed approach to encouraging more sustainable travel choices and mitigating the impact of the proposed development on the surrounding road network by implementing measures to discourage car travel.
Based on its review of the submitted Transport Assessment and Draft Framework Travel Plan, AECOM make the following recommendations:-
• It is recommended that confirmation is given as to whether the developer intends to make the required contribution to the Strategic Transport Investment Programme.
• It is recommended that junction capacity assessments are carried out for M25 Junction 1a, A2 Ebbsfleet Interchange and A2 Pepperhill Interchange for with and without development scenarios to accurately determine the impact of the proposed development.
• It is recommended that an assessment of slip road capacity and mainline weaving is carried out, making reference to DMRB TD 22/06, for Ebbsfleet and Pepperhill Interchanges.
• It is recommended that a condition is attached to any planning permission that may be given for the proposed development which stipulates that a Travel Plan should be
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submitted which is to the satisfaction of Gravesham Borough Council, Kent County Council and the Highways Agency
• It is recommended that the Travel Plan is secured through a Section 106 agreement. Included within the Travel Plan should be clearly defined targets for reducing car travel, a methodology for monitoring travel behaviour and a management approach to responding to exceedance of targets.
Arriva
Arriva support the provision of a Fastrack route through the site and would add that other bus services will continue to use the High Street and The Hill where adequate good quality pedestrian access should be provided between the development and the bus stops on that route.
Crossrail Ltd
Crossrail is a proposed new railway that will link Heathrow and Maidenhead in the west to Shenfield and Abbey Wood in the east using existing Network Rail tracks and new tunnels under Central London.
The Crossrail Bill which was introduced into Parliament by the Secretary of State for Transport in February 2005 was enacted as the Crossrail Act on the 22nd July 2008. The first stage of Crossrail preparatory construction works began early in 2009. Main construction works are scheduled to begin in 2010 with completion of the project expected in 2017/18.
Crossrail Limited administers a Direction issued by the Department for Transport on 24 January 2008 for the safeguarding of the proposed alignment of Crossrail.
The site of this planning application is identified outside the limits of land subject to consultation under the Safeguarding Direction.
The implications of the Crossrail proposals for the application have been considered and Crossrail Limited does not wish to make any comments on this application as submitted.
You may inspect and/or purchase copies of Plans, Sections, Environmental Statements, Explanatory Notes and Non-Technical Summaries pertaining to the Crossrail proposals at specified Libraries, Local Authority Offices or directly from Crossrail Limited at “28th Floor, 25 Canada Square, Canary Wharf, London E14 5LQ”. These documents may also be viewed or downloaded at http://billdocuments.crossrail.co.uk on the Crossrail website www.crossrail.co.uk.
Network Rail
Network Rail has no comment to make.
David Young, Sustrans
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Asks whether the western tunnel under the High Street can be used for pedestrian/cycle access to Ebbsfleet station. The plan says that this is not panned but it would be useful to know why – is it no sufficiently wide.
The tunnel under the railway is proposed for pedestrian/cycle access so why not the western tunnel under the High Street.
SEEDA
SEEDA supports the application to deliver a mixed use development at The Shore, Northfleet. The application is in general well aligned to the Regional Economic Strategy (RES), we specifically welcome references to:
• The development of modern housing (up to 30 per cent affordable) and office space. This complements Target 9 of the RES which seek to ‘ ensure sufficient and affordable housing and employment space of the right quality, type and size to meet the needs of the region and support its competitiveness’.
• Delivering sustainable commercial buildings that achieve an ‘Excellent’ BREAAM rating and residential units achieving at least Level 4 of the Code for Sustainable Homes. This complements the headline target of the RES which seeks to ‘reduce the rate of increase in the region’s ecological footprint’
• Safeguarding a Fastrack route through the development to enable the development to be connected by public transport to key destinations within Kent Thameside and the provision of improved infrastructure for pedestrians and cyclists. This complements Target 8 of the RES which seeks to ‘reduce road congestion and pollution levels by improving travel choice, promoting public transport, managing demand and facilitating modal shifts’
The RES identifies Kent Thames Gateway as a Diamond for Investment and Growth where the concentration of people, employment, built assets, networking and creativity give the potential to be economic catalysts for the region. We therefore welcome the proposed development creating approximately 1650 permanent jobs in addition to those generated during the construction phase.
In addition, we consider the application complements the Policy MDS3 of the Local Plan and the SEEDA Northfleet Embankment Masterplan.
Regulatory Services, Gravesham Borough Council
Comments relating to section 8 (Noise and Vibration) of Environmental Statement prepared by Peter Brett associates.
The contents and methodology of the noise and vibration assessment are generally accepted.
It is expected and accepted at paragraph 8.6.5 in the report that a construction assessment will be undertaken when detailed information is available which will then feed into a comprehensive Code of Construction Practice to include the control of noise,
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vibration, dust etc. It is therefore considered that this undertaking be conditioned as follows:
The commencement of the development shall not take place until a comprehensive Code of Construction Practice is provided by the applicant and submitted for approval to the LPA. No building works shall commence until approval of this report has been given by the LPA
Paragraph 8.3.15 – This confirms that the bulk powders import terminal is now operational and the noise impacts from these premises is considered as part of the baseline noise survey. The main noise from this operation is the emptying of the ships using two different methods. As this will be an ongoing regular operation which appears to be tonal in nature and occurs during the day and night, it is important that these two methods of work are carefully assessed using the methodology contained within BS4142 to ensure they do not exceed the existing background noise level by more than 3 dB at existing and proposed noise sensitive premises. This issue needs to be resolved before we can progress with this application.
Paragraph 8.3.17 It is noted and welcomed that the proposed new dwellings aim to obtain a design range of ‘good’ indoor ambient noise levels, as described in BS8233.
Paragraph 8.5.10 It is predicted that almost all the new build houses will fall within Noise Exposure Category (NEC) A. The report identifies 15-20 proposed new properties overlooking College Road will be in NEC B.
The point made in paragraph 8.6.12 that, other than for these small number of properties, no special work will be required to bring the new build properties into the ‘good’ indoor ambient noise standards as described in BS 8233 is accepted. The paragraph also advises that a more detailed sound insulation assessment may be required at the detailed design stage. This is accepted and this point needs to be conditioned such that the details of noise insulation work are provided to this Service at that time.
Paragraph 8.6.11 recommends limiting the Sound Power Levels (LWA dB) for buildings in parcel MU1, E3, E9 and E12 and provides a table 8.7 with these figures. This is accepted and should be conditioned. The question is asked however why the other employment area land parcels MU2, E5, E4, E10, E11, E1 and E2 do not have noise limits? The applicant will need to advise on this before this matter can be resolved.
Section 8.7 of the report then looks at the effects this development is predicted to have on existing receptors. There appears to be a typing error at Paragraph 8.7.7 which advises certain properties in Wallis Park, Huntley Avenue, North Kent Avenue, West Kent Avenue, East Kent Avenue and Rose Street will experience a change in noise levels due to transportation noise of between -1dB and +1dB describing this effect as adverse- minor. A change of between -1dB and +1dB is defined as not significant. Figure 8.6 and 8.7 actually show these properties to be affected by a change of +1dB and +3dB which is an adverse – minor effect.
Paragraph 8.7.8 advises that some existing properties in Hive lane will experience a change in noise of between +3dB and +5dB an adverse - moderate effect. Figure 8.6 and 8.7 also show that some properties within the block 1-16 Ford Road and some localised properties in East Kent Avenue, Springhead Road and Vicarage Drive are predicted to be affected by a change of +5dB and +15dB which is an adverse – major effect. This is not acknowledged in the report and before this matter can be progressed,
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further discussion is required to ascertain what action can be taken to protect these properties affected by more than a +3dB increase.
Section 8.8 looks at the cumulative effect of the proposed development and the bulk aggregate import terminal. The report advises that the majority of the off-site noise sensitive receptors will experience a change in noise levels from the proposed mixed use development and the bulk aggregates and import terminal of between 0dB and +1dB. The significance of this impact is not significant. This conclusion is accepted. The report identifies that certain properties in Wallis Park, Huntley Avenue, North Kent Avenue, West Kent Avenue, East Kent Avenue and Rose Street will experience a change in noise levels due to transportation noise of between of +1dB and +3dB which is an adverse – minor effect. It also advises that some existing properties in Hive lane will experience a change in noise of between +3dB and +5dB an adverse - moderate effect. Figure 8.8 and 8.9 also show that some properties within the block 1-16 Ford Road and some localised properties in East Kent Avenue and Vicarage Road are predicted to be affected by a change of +5dB and +15dB which is an adverse – major effect. This is not acknowledged in the report and before this matter can be progressed, further discussion is required to ascertain what action can be taken to protect these properties affected by more than a +3dB increase.
The biggest change to the noise modelling which includes the bulk aggregate import terminal is the increase in noise caused by the re use of the railway sidings linking the terminal to the existing North Kent line through Church Path Pit. Whilst this does not show any significant increase in noise levels to properties overlooking Church Path Pit, the robustness of the noise prediction model needs to be tested through the current planning application relating to the bulk aggregate import terminal and this Service’s consultation response to KCC stresses this.
Paragraph 8.8.9 advises it is anticipated that industrial noise arising from the bulk aggregate import terminal will have an impact upon noise sensitive receptors but that this will not exceed +3dB above background and based upon this paragraph 8.8.10 advises that as a worst case the cumulative effect will not exceed +6dB above background when measured as a BS4142 assessment. This is unfortunate as these two developments when take separately do not cause a significant increase but when added together they cause the overall ambient background noise to increase. The application does not provide any detail as to how their conclusion was reached. Before we can move forward on this issue, the applicant will need to provide a more detailed report showing which properties (if any) are predicted to be affected in this way and whether there is anything that can be reasonably done to reduce this effect such that the cumulative noise effects of these developments do not exceed the existing background noise level by more than 3 dB at any noise sensitive properties.
The permission also needs to be conditioned as follows:
A noise report showing that the rating level of the noise emitted from the non residential units in this development (other than noise from the exit or entry of road vehicles), shall not exceed the existing background noise level by more than 3 dB shall be submitted for approval to the Local Planning Authority. The noise levels shall be determined at the points nearest to adjacent existing and proposed residential premises. The measurements and assessments shall be made according to BS4142:1997. No building works shall commence until approval of this report has been given by the Local Planning Authority.
Lighting
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The mitigation of this issue is covered in section 11.6. It is accepted that the impact of lighting will be improved naturally by the removal of the existing installations and that the new development will minimise the impact of lighting by the use of low level lighting wherever possible, horizontal cut off designs and matt surfaces on large buildings. It is considered however that the following condition is necessary to ensure that undue loss of amenity is not caused:
A suitable written report shall be submitted to Planning and Regeneration Services providing sufficient information as to what extent surrounding existing and approved light sensitive properties are to be affected by the lighting of non residential units in this development, demonstrating best practice and detailing what works are to be carried out to minimise light disturbance. The non residential units shall not be lit until approval of the report is received from Planning and Regeneration Services and all measures included in the approved plan have been put into place.
Commercial Refuse Arrangements
Storage facilities provided shall be of sufficient capacity having regard to the quantity of waste produced and the frequency of waste collection. All waste shall be removed from site on a regular basis by a licensed waste carrier and disposed of at a licensed waste disposal site.
Commercial Refuse Arrangements - Advisory Notes
Compliance with the Environmental Protection Act 1990 "Duty of Care" is essential. Advice on Solid Waste Management can be obtained from Waste Services on [01474] 337533.
Domestic Refuse Arrangements - Single Dwellings
The dwelling should have sufficient storage capacity to cope with the waste generated in between collections (1 week).
Domestic Refuse Arrangements - Advisory Notes
Plastic sacks are issued for solid waste storage and collection will be from the front entrance to the property adjacent to the road or footpath.
Comments relating to section 7 (Air Quality) of Environmental Statement prepared by Peter Brett Associates.
The mixed use development site lies within the Northfleet Industrial Air Quality Management Area declared for industrial sources of fine airborne particles referred to as PM10. It is agreed that whilst the cement works is the major source of particulate matter (PM10) in the area it is not the only industrial source. Though it closed at the end of 2008 the demolition and construction phase of the Northfleet Works site have the potential for significant environmental impacts on the locality and must therefore be managed and mitigated carefully. I therefore support my colleague, Allan Glasson’s request for a condition for an agreed Code of Construction Practice as follows:
“The commencement of the development shall not take place until a comprehensive Code of Construction Practice is provided by the applicant and submitted for approval
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to the LPA. No building works shall commence until approval of this report has been given by the LPA
It should be noted that the section of the air quality assessment relating to the traffic impact is only as good as the traffic data input. Therefore these comments are reliant on the acceptance of the Transport Assessment by Kent County Highways Unit and should any amendment be necessary to that report it should be amended in the air quality impact assessment as appropriate.
Whilst the report suggests that the residual impact of the demolition and construction phase is likely to be not significant because of the nature of the operations close to the receptors, the height of the cliffs and the fact that the area has historically been exposed to dust/PM10 a comprehensive raft of mitigation measures must still be implemented to minimise the impact on the local air quality through all phases. The impacts are very dependent on the application of dust suppression measures and the assessment assumes that good mitigation is appropriately used during construction. It is therefore requested that the list of mitigation measures in section 7.6 be conditioned with the added general requirement for all necessary mitigation to be implemented in case any necessary mitigation measures have been omitted from the list.
The report states that on its own the mixed use development will not be significant as no change in concentrations is predicted at most receptors as a result of the emissions from the proposed development’s traffic. However it does state that the combined impact of the proposed aggregates terminal and mixed use development will be a small increase in annual nitrogen dioxide and PM10 concentrations at a few receptors as a result of the development traffic. This impact therefore needs to be mitigated either directly or indirectly i.e. by traffic management measures along the B2175 through Northfleet, including junction improvements if necessary, otherwise the future declaration of an Air Quality Management Area due to traffic sources cannot be ruled out.
Vermin Control - informative
This site has a significant potential for rat infestation due to its location adjacent the river, cliff and railway. The demolition and construction phases will cause rats to be displaced. The applicant is therefore advised to implement a strict baiting regime during all phases from demolition to occupation and to consider the landscaping carefully to avoid providing the ideal habitat for rats.
Housing Services, Gravesham Borough Council
No comments
Housing Strategy and Development Manager, Gravesham Borough Council
As this is an outline application there are no details of the split in terms of house types and tenure. However, it is good to see that it is intended that the residential element of the scheme will incorporate a mix of unit types and sizes, to include apartments and town houses and that it is envisaged that the emphasis will be on the provision of family housing.
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It may be helpful for me to take this opportunity to confirm what has been approved by Cabinet in relation to the negotiation of affordable housing:-
• That 30 per cent affordable housing be sought on sites with 15 or more units (or 1 hectare in urban areas) and 15 or more units (or 0.5 hectare in rural areas);
• That the tenure split sought should be 50 per cent Social Rented Housing and 50 per cent Intermediate Housing;
• That variations in affordable housing delivery be considered on a site by site basis in line with current housing need and priorities and agreed with the Lead Member for Housing and, where appropriate, reported to Regulatory Board;
• That proposals by applicants and/or officers that are not in accordance with adopted Planning Policy will be agreed with the Lead Member for Housing and, where appropriate, reported to Regulatory Board;
• Where it is deemed inappropriate to provide 30 per cent affordable housing on-site e.g. if a proposed scheme is made up of 1 and 2-bed apartments, consideration may be given to an alternative delivery option in order to achieve family sized homes elsewhere in the borough.
In these circumstances, consideration will be given, following consultation with the Lead Member and, where appropriate, reported to Regulatory Board, to alternative delivery options such as:-
• Full provision on an alternative site • Part on-site provision plus a payment in lieu of affordable housing (commuted sum) • Payment in lieu of affordable housing (commuted sum)
Leisure Services, Gravesham Borough Council
This department acknowledges the principles by the applicant for the inclusion of a community hall, the possible relocation of the current Scout Hut within the development, opportunities for a network of open space including a waterfront promenade, a junior playing field for shared school/public use and a combined Locally Equipped Area for Play (LEAP) and Neighborhood Equipped Area for Play (NEAP) within the residential area.
At the outline stage it is unclear whether the open space provision and facilities provided will be adequate for this development, as no assessment has been made of the level and form of demand. Due to there presently being no formal plan or assessment of need in place from the Council, this will therefore need to be clearly demonstrated by the applicant at some stage. The inclusion of a formal recreation area for pitches that can be shared between the school and the community would appear to make sense, but again at this time I am unsure whether this will be adequate bearing in mind the size of the development from a residential point of view. The need for this type of facility for new and existing communities is highly important, especially within this area of the Borough. The current playing pitch assessment provided by Strategic Leisure in 2002 (and updated in 2006 using the same raw data) suggested a standard of playing pitch provision of 1.16 hectares per 1,000 population. However, as you may be aware there is a need for these documents to be updated for future use, but this figure can be used as a current guide to applicants.
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Another issue that needs to be addressed at some point in the future, is the potential need for a contribution towards indoor leisure provision, such as main hall provision or swimming pools, using the Sports Facility Calculator, as provided by Sports England.
National Grid Transmission Asset Protection Team
We have now carried out a detailed assessment with respect to our operational electricity transmission and national gas transmission networks.
Based on the information you have provided and the proximity and sensitivity of these networks to your proposals we have concluded that the risk is NEGLIGIBLE .
The Risk Tables used in the assessment of your enquiry can be found by following this link:
http://www.nationalgrid.com/uk/LandandDevelopment/DDC/electricitytransmission/risk table.htm
You will find useful information including maps with our transmission routes marked on them which can be downloaded into a compatible mapping system:
http://www.nationalgrid.com/uk/LandandDevelopment/DDC/GasElectricNW/
● Important Note : This response is for the national transmission gas and electricity networks only . You must also obtain information for local gas and electricity distribution networks . Please refer to the "Work Safely in the Vicinity…" site at:
http://www.nationalgrid.com/NR/rdonlyres/06655048-D0D9-4C28-9B63- 6FBE96BC1C40/24106/Contactmap.pdf
● If the nature, location or extent of your work changes please submit a new enquiry .
EDF Energy Networks
No objections
Kent Fire and Rescue Service
The submitted plans do not show sufficient detail of the access to the site for fire and rescue service as required by section 53 of the legislation.
W F Ripper Local Footpath Officer for the Ramblers’ Association
It was unclear exactly what is proposed for the existing Public Rights of Way and Urban Alleyways other than being improved. We feel that any improvements should incorporate making the footpaths greener and wider (five metres) and linked into the Green Grid.
A riverside path is essential to link into the already existing Thames Path and Saxon Shore Way.
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Whilst the application did not deal specifically with Ebbsfleet FC, I understand from recent newspaper reports that they are seeking to establish a new stadium on green belt land and we felt that perhaps this application would be an ideal opportunity to include it.
Dartford Borough Council
The Borough Council has no observations to make on the proposals.
Informative:
For information the Council has some concerns about the Bulk Aggregates Import Terminal and the impact of the heavy goods traffic generated on surrounding roads and the environment and the impact on residents and occupiers of areas along the key transport routes.
Swanscombe and Greenhithe Town Council
That due to the closeness to the Council’s boundary this application should be viewed with regards to a section 106 Agreement including a financial contribution to the Town Council, as indicated within the Town Council’s LDF, to compensate for the effects that will be had on the community facilities.
The Town Council have concerns that the density of housing seems excessive and that the height of the proposed buildings also seems excessive.
The Town Council would like to request assurances that waste will not be transported to or from the site using the A226, London Road.
(Note: There are still a number of organisations that have not responded to date to the planning consultation. These include the Primary Care Trust-although they have recently visited the site with planning officers, Kent County Council Planning, Thurrock Borough Council, Ancient Monuments Society, Kent Police, Kent County Council Footpaths, Land Securities, Kent Thameside Group, Union Railways, Northfleet Action Group, 1st Northfleet and 5th Northfleet Scouts Group.
Publicity
The owners/occupiers of 1265 dwellings/premises have been notified of the application and the application has also been advertised as major development, development affecting a public right of way, development affecting a statutory listed building and development not in accordance with the development plan.
7 individual representations have been received as follows:-
Mr H J Luff, 49 Factory Road, Northfleet, Kent
The proposals are a long time coming. Since moving to the area in 2000 the pollution has decreased while the noise has increased. The area is generally run down with severe crime issues in the area. The proportion of police to head of population is staggeringly small and with a new development I fear the local police services will be
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stretched beyond their limit. Burglaries, car crime and such like are already reported over the telephone, so if police services only respond to the most urgent calls what is the point of having a bigger population to feed an already burgeoning need to justify the Ebbsfleet rail development?
On the positive side, property prices are likely to stabilise or increase with any development of the cement works which will be a boost to the local economy.
Will local services be improved (without increased budget, just become more efficient?) to cope with a higher demand without an increase in the Council Tax bills?
The Borough's budget is already huge and I am sure certain localised budgets could be more efficiently managed to provide householders with the services they so desperately need - to maintain the current community without seeing it slip even further beyond that which should be expected in a First World Country and in the 'affluent South East'!
Gillian Bull and Pete Bailey 8 Vicarage Drive, Northfleet.
We realise that this development will go ahead regardless of any inconvenience to the local community, as did the construction of the Channel Tunnel Rail Link (CTRL), the plans suggest that there will be large scale levelling of the site, to make this construction possible, meaning 24 house, even day a week working of the site, as with the CTRL which caused extra Heavy Goods Vehicle (HGV) traffic and the filth of their loads and road use made, not to mention the noise which was constant, mainly form their reversing warning sounds which during the CTRL site construction lasted continually for about tow years, night an day.
It is good to see that provision for wildlife is being made but as with CTRL this will take many tens of years to recover. The local wild life has suffered tremendously with the CTRL, A” road changes and Thamesway Fast track construction, this development will be yet another major set back.
Our concerns are with “Church Path Pit” the closest to our property, the plans suggest that the old railway tunnel will become HGV access to that part of the development and tries to say that this is also an emergency exit from the whole site but there is no way out of this part of the development other than returning through the tunnel, if they have not thought this through then what else is wrong?. We are concerned too that there is intention to reopen the other part of the rail link to the site, though this is subject to another planning application letter to us being handled at Maidstone (Planning application GR/09/286 which we will be replying to direct to Kent County Council). The noise from the original rail operation was excessive; see attached letters sent to you personally and a colleague, one of which was never acknowledged.
As already stated there is no point in objecting to this planning submission as it is part of Government policy on development of the Thames Gateway but we would ask that it is better “policed” than the CTRL one was, especially for noise in unsocial hours, disruption to road communications and that if any changes are made to the plans we are consulted with more understandable submissions.
Mrs F.Gill-Hall, 4 Vicarage Drive
I am writing regarding the above application to record my worries over the proposal use of the ‘Church Path Pit’. Over the past years we have constantly been forced to endure not only the vibrations, which were very severe from the ‘Lafarge’ site, but also
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the noise from the Euro line. My worry is that lorries will be disrupting the quiet we now have. Also I hope that the line that runs at the bottom of the pit will not be brought back to life.
We first had the notice that ‘Lafarge’ wanted to retain the unit as a distribution centre, which I did object to at the time. I know that all my neighbours are worried abut excessive noise levels.
S L Deakin, Strutt and Parker on behalf of Trustees of Huggens College
Does not object in principle but has concerns on
• impact of necessary improvements to Grove Road and the affect on the existing industrial operations on their clients land, • the possible closure of College Road and impact on their clients land, • the absence of any education provision within the application site and the proposal/suggestion by the applicant that such could be located on their clients land.
Whilst acknowledges that detailed applications will follow considers it essential that incorrect parameters are not set. Surprised that there has been no previous dialogue with their clients since they are a stakeholder.
B E Driscoll, 6 Davis Avenue
Gravesham Friends of the Earth object to the application. It is a development not in accordance with the Development Plan and affecting a Public Right of Way. It is a dangerous, unbalanced and unsustainable proposal, contrary to Government Policy on Climate Change, and reducing co 2 emissions because it will cause people to travel long distances for employment. The site is also liable to flooding unless the flood defences are improved, some of the site is already lower than very high tides.
Gain from ‘Green Energy’ will be outstripped by the growth in co 2 caused by housing and travel which is forecast to increase by 37 per cent by 2020, and, Global Warming beyond the very dangerous level.
The whole site area is designated as an ‘Air Quality Management Area’ and some of the worst pollutants such as Dioxins contaminate the site. At least three inches of cement dust and pollution from tall factory chimneys including acidic and particulates from a Power Station have fallen on the site, over the years the cement factory and Power Station were open.
This development is completely contrary to Government Policy and what is required, employment locally in this part of Thames Gateway, so, should be refused and strict orders placed on developers to clean up all the contamination.
Building houses on contaminated land, flood plains, marshes and other low-lying areas is not sustainable. It is passing trouble onto future generations.
Penny J Richards, 1 Hamerton Road
Concerns and objections are:-
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• Specific concerns concerning road access to the area in particular the need for Grove Road access to be made dual carriageway. • If the “Fast Track” lane is dedicated to Fast Track buses then further carriageways need to be provided for vehicle access to the site. • Parking does not appear to be sufficient. Further visitor parking needs to be provided. • Whilst not a Gravesham responsibility, consideration needs to be given to improvements to Galley Hill Road and traffic lights/junctions adjacent to Phoenix Park to aid traffic flow. • With a proposed additional 510 homes, what consideration has been given to additional schooling and medical facilities?
In conclusion, objection would stand unless further improvements to traffic flow, entry/access roads and additional parking spaces supplemented with parking restrictions.
Mr and Mrs G D Jewiss, 12 Central Avenue, Gravesend
Considers that the proposals are a definite improvement to the area but makes the following points,
1. Dwellings in the main will be flats with no gardens and there will be insufficient parking for visitors.
2. Leisure areas are not as good as the county parks provided by the Council.
3. The soccer pitch if shared between the school and general public use would become overused.
4. There has been a significant loss of sports pitches in the area in recent years.
5. The bridge from Hive Lane to the old ambulance station will be unique, presumably with a roof over to stop ‘bombing’.
6. The sight viewing area and promenade areas are a step forward.
7. More thought is required to improve other aspects.
Note: Copies of all the consultation and publicity responses have been provided to the applicants planning consultants and they have commented on all the responses and are reviewing the proposals in the light of all relevant comments received.
7. Service Manager (Development Control) Comments
Principle of the Development
The potential for redevelopment of the Northfleet Cement Works has been a realisation for some years and this was recognised in the Draft Second Review of the Local Plan (2000) which identified the site as a Major Development Site (Policy MDS3), and even earlier in area policy AP13 of the Gravesham Local Plan First Review (1994) in relation to the western part of the Cement Works. Early work on the Local Development Framework in 2007 in the Core Strategy Issues and Options
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consultation confirmed Northfleet Embankment (of which the Cement Works lies within the western part) as a Major Development Site within the Borough proposed for comprehensive regeneration.
Equally for some years at both a strategic level and regional level through the Kent and Medway Structure 2006 (now expired) and regional planning documents – The Thames Gateway Planning Framework (RPG9a - 1995), Regional Planning Guidance for the South East (RPG9 - 2001), Thames Gateway Interim Planning Framework and Prospectus (2006) and more recently the now adopted South East Plan (2009), have identified the site as part of a wider area for Gravesend Waterfront and Northfleet Embankment within Kent Thameside (as a part of Thames Gateway) for regeneration and growth following the principles of sustainable development. There have been numerous other regional and strategic policy documents including the Kent Thameside “Looking to the Future” 1995, creating Sustainable Communities: Making it Happen: Thames Gateway and the Growth Areas (July 2003), Growth and Regeneration in the Gateway (2004), the draft Thames Strategy East (February 2005) and Thames Gateway Parklands Vision (2008) which also promote the vision of this area for major redevelopment.
The redevelopment of this site for a mixed use therefore has a sound planning policy footing and the principle of redevelopment is well established.
David Lock Associates on behalf of SEEDA published a master planning strategy for Northfleet Embankment early in 2006 covering both Northfleet Embankment East (Kimberley Clark’s paper mills, former Northfleet Power Station and AEI/GEC/Henley) and Northfleet Embankment West (Northfleet Cement and land west of Grove Road including Robins Creek).
The Borough Council has received presentations on the emerging master planning for both the Northfleet Cement Works and the more SEEDA led regeneration proposals for Northfleet Embankment East.
The planning proposals for mixed use development of the Cement Works were the subject of a screening and scoping opinion under the Environmental Impact Assessment Regulations 1999 in April 2008 when it was determined that there was a requirement to submit a formal Environmental Impact assessment (EIA).
Lafarge and its planning consultants (David Lock Associates) carried out its own pre- application consultations on the proposals with local residents in the locality at a number of local venues.
It is intended that Board Members will have the opportunity to view the application site and discuss any issues arising from observations at the site visit with the applicants on Wednesday 16 September.
It is therefore not proposed in this report to set out in any great detail a full analysis of the proposals at this stage pending the site visit.
Section 3 (Proposal) of this report does however provide Board Members with a fairly comprehensive summary of what is proposed for the mixed use development of this site (which is for outline planning permission).
Section 6 (Consultations and Publicity) will also provide Board Members with a reasonable idea of what issues and concerns have emerged from the various
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consultation responses and they will note that there are still some consultees who have still to respond.
Summary of the Main Issues
The key issues for the Board to consider are suggested as follows:
Scale, Density and Mix of Development
• Whether the scale and mix of development is appropriate
• Whether the location of the various land uses is satisfactory
• The mix of housing types
• The density of the development
• The quantum of affordable housing
• The mix of employment provision
• Whether the scale and location of the proposals for retail and community provision can be justified
• How the development can link with existing and potential development sites.
• The scope for including adjoining areas within the development site such as the College Road industrial units and Robins Creek
• Whether the commercial uses proposed are satisfactory and make the best use of the existing deep water wharfage facilities.
Open Space and Green Links
• Whether the proposals provide for sufficient open space provision to meet the needs of the local community.
• Whether shared use of the school playing field is appropriate.
• Whether other contributions to leisure facilities are necessary.
• Whether the site offers the opportunity for a new (indoor) leisure facility
Transportation and Access
• The impact of the development on the local road network.
• The impact of the development on the wider network including the A2 trunk road.
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• Whether the proposals make adequate provision for access to the site for private motor cars, public transport and commercial traffic.
• Whether there is sufficient pedestrian and cycle access to the development and satisfactory linkages with the adjoining community.
• The capacity/capability for re-establishing rail links to the site to serve any commercial development.
• Whether the proposals make sufficient provision for public access to the riverside.
• The appropriate route for Fastrack within the proposals.
Environmental Impacts
• Whether there is sufficient separation between proposed industrial uses including both the proposed aggregates depot and the approved cement import terminal and the new and existing residential communities; and how noise issues will be addressed.
• The air quality impacts from the development.
• The impact of lighting of the commercial development on the residential areas.
Ecology and Biodiversity
• Whether the proposals make adequate provision for mitigation and translocation of nature conservation interests.
• Continuity of habitats.
• The incorporation of brown and green roofs.
Cultural Heritage
• The possible omission of existing features identified in the heritage assessment.
• Whether it is appropriate to ‘erase’ all the industrial history of the site or whether a few structures should be integrated as reminders of the past cement industry.
• The scope/need for a heritage interpretation centre
(In respect of heritage matters the Board is advised that a meeting was held with the applicants on 15 July which was attended by a number of interested parties following concerns that demolition works were proceeding rapidly and that any potential industrial or archaeological heritage could potentially be lost).
Design, Scale and Sustainability
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• Whether the scale of development/storey heights are appropriate to their local context
• The potential for improvements to the public realm and incorporating public art into the development.
• The justification for a contemporary design approach.
• How local distinctiveness and a sense of place can be achieved.
• Whether the development sufficiently incorporates proposals for carbon reduction and renewable energy.
• The impact of land raising and remodelling in visual terms.
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Consultation expiry date: 2009
Recommendation
This is an interim report for information of the Board and not for decision at this stage.
The Board are asked to consider and endorse the key issues that are identified in the report and to suggest any other issues that they consider should be appraised by the applicants.
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