Page 15 Agenda Item 5a
8 week date Application No. Date of meeting Report No.
09.03.2010 GR/2010/0020 14 April 2010
Land at Springhead, Ebbsfleet, between A2 and Springhead Park, Northfleet, Kent.
Construction of a landmark sculpture in the form of a White Horse.
Ebbsfleet Landmark Project Ltd & Ebbsfleet Investment (GP) Ltd
Recommendation:
Permission be granted subject to conditions
1. Description of the Site and Surroundings
The Ebbsfleet Site
The original Ebbsfleet outline planning application which straddles the boundary of both Gravesham and Dartford Boroughs extends to some 152 hectares (375 acres) and is centred around the new International and Domestic Passenger Station at Ebbsfleet, from which Eurostar currently operates a high speed passenger train service linking the UK with Paris, Lille and Brussels. It is a key site in the strategic development and regeneration of the Kent Thames Gateway.
The Ebbsfleet site in broad terms is bounded by the A2 in the south, the North Kent railway line to the north, Southfleet Road and Swanscombe to the west and Springhead Road to the east. The site has been planned on the basis of four quarters – Springhead ( Springhead Park ) and Northfleet Rise ( Portland ) which are within Gravesham and Station Quarter South ( Cressfield ) and Station Quarter North ( Ebbsfleet ) in Dartford Borough.
The development is closely linked with the planned development of the area of land to the west of the Ebbsfleet station and to the east of the Bluewater shopping centre formerly known as Eastern Quarry. This is a clay and chalk quarry operated by Lafarge Cement Company which has now been exhausted and for which outline planning permission was granted in November 2007 by Dartford Borough Council (reference DA/03/01134) for 6,250 dwellings and an additional 231,000m² of mixed use floorspace including business premises, community, leisure and retail uses and where there has been subsequent approval for a site wide master plan and an area master plan for one of the five “villages”.
Central to the development will be a dedicated bus route ( Fastrack ), reducing reliance on the private car, which will provide a fast and convenient public transport link between Dartford and Gravesend town centres. In December 2009 domestic train services began operating between Ebbsfleet station and St Pancras London with a journey time of 17 minutes. Page 16
The Ebbsfleet site and Eastern Quarry together are known as the Ebbsfleet Valley. Overall the Ebbsfleet Valley will deliver 1,659,550m² (17.8m sq ft ) of development with 10,000 new homes, 6m sq ft of commercial development, 3m sq ft of retail, leisure and community uses on 420 hectares (1035 acres) of land, 40 per cent of which will be open spaces and parkland (158 hectares).
Land Securities who own the Ebbsfleet Valley site in conjunction with Lafarge propose to build out the whole development over a 25 year time span on a phased basis with joint venture partners.
Springhead Quarter
The Springhead Quarter comprises an area of 27.5 hectares.
It lies immediately west of Springhead Road, Northfleet and is bounded by the Ebbsfleet stream and Channel Tunnel Rail Link (High Speed 1) to the west, the Northfleet sewage works and Springhead Enterprise Park to the north and the former line of the now disused Gravesend West railway line (but actually within the site of the Springhead Quarter) and the Sainsbury’s Pepper Hill store to the south.
The majority of the land was fairly level agricultural land farmland although the north- west part of the site falls down from the Springhead Enterprise Park and the former allotments site towards the Ebbsfleet stream and the west boundary also has a steep slope towards the Ebbsfleet stream now further accentuated by the cutting as a result of the CTRL. The former Gravesend West railway line is also for the most part in a deep cutting. The Springhead Quarter also included the site of the former Meadow Road prefabricated dwellings long since demolished off Springhead Road.
The Springhead Quarter is crossed by public footpaths and there are existing National Grid high voltage power lines crossing the site in the south west corner of the site and lower voltage lines in the north-west. A further set of reserve power lines running north-south have been removed. Existing two storey dwellings in Springhead Road adjoin the site to the east.
Construction has commenced on the first phase of residential development on an area of 7.2 hectares and which forms a gateway into the Quarter. The development under construction in Phase 1 is for 388 residential units and associated car parking spaces together with a number of small open spaces as well as a local park (referred to as Central Park and now known as Penn Green Park) of one hectare in area. Currently there are 120 residential units that are occupied and approx. a further 90 units completed or under construction.
No detailed planning permission has been applied for the later phases of the development at Springhead but the outline planning permission and subsequent master planning allows for up to 600 residential units to be built on the Springhead Quarter at Ebbsfleet as well as commercial development (32,000m²) and community facilities including a school, health facility, place of worship, leisure centre and community centre. The master plan also indicates the provision of a linear park and potential allotments on the western side of the Quarter. No work has yet commenced on the provision of the linear park which could take 5-7 years to complete. Page 17
The Specific Application Site
This specific application site relates to an area of approx 0.36 hectares of undeveloped land on elevated ground being part of the prominent escarpment in the southern and western edges of the Springhead Quarter of the Ebbsfleet development overlooking the A2 trunk road and close to the National Grid overhead electricity line that runs through the southern part of the Quarter.
The site would sit within the proposed linear park for the Springhead Quarter of the Ebbsfleet development and is on a plateau area 31 metres above ordnance datum.
The profile of the Ebbsfleet river valley in this location comprises a steep cliff and plateau and the natural topography has been significantly changed due to farming activity but more recently by the Channel Tunnel Rail Link engineering works.
An electricity pylon within the specific application site was relocated due to the CTRL works some 60 metres to the north west and the site was used as a construction site for spoil storage during the building of the railway line.
The application site is about 60 metres from the Northfleet East National Grid sub station site that adjoins Springhead to the south east. It is approx. 90 metres from the line of the High Speed 1 railway (CTRL) which, at this point, is within a cutting before it enters a tunnel to go under the A2 trunk road.
The A2 trunk road is about 160 metres to the south of the application site and is about 20 metres lower than the application site at its nearest point. The nearest dwelling is at Springhead Nurseries (Springhead House) which is about 160 metres from the application site and in a significantly lower position. Proposed dwellings on phase 2 of Springhead Park would be about 80 metres from the application site. The nearest dwellings in both Springhead Road and the Pepper Hill estate (Fleet Road) are about 350 metres from the application site.
A public footpath (NU 16) runs through the application site.
2. Planning History of the Site and Surroundings
The Outline Planning Application
The Ebbsfleet planning application was originally submitted by Blue Circle Properties Ltd in January 1996 to both this Council and Dartford Borough Council (GBC reference GR/96/35 and Dartford reference DA/96/47).
That application was for outline planning permission on the 152 hectare site with all matters reserved for detailed planning approval and proposed a development for a maximum of 789,550m 2 (approx. 8.5 million square feet) of mixed use development with quantities for the land uses expressed in the following ranges:
Page 18
• up to approx. 493,700m 2 of employment uses (use Class B1 – offices, research and development and light industrial)
• up to approx. 310,420m 2 of residential development (3,200 dwellings - subsequently increased to 3,384 by reason of higher quantities agreed within the Dartford Quarters)
• up to approx. 310,420m 2 of supporting uses (including schools, community facilities, local shops) and
• up to 163,740m 2 of core space development (including hotels, leisure, entertainment and supporting retail)
The key elements of the development are:
• creation of a new centre of development of a ‘critical mass’ around a new transport focus i.e. Channel Tunnel Rail Link and Ebbsfleet Station
• mixed use
• higher density than surrounding development
• linkage of existing communities
• encouragement of public transport and reducing reliance on the private motor car
• sustainable form of development
The development is planned for a 20-25 year time span. The application indicated that for the Springhead Quarter (27.5 hectares) the development would be for predominantly residential with a neighbourhood centre and shops and some employment use, with development more akin to suburban areas of Gravesend.
The application was supported initially by a number of documents and statements including Environmental, Urban Design Transport and Community Development statements. Further documents were subsequently submitted including environmental strategies, illustrative master plan, retail and travel impact assessments, and illustrative floorspace scenarios.
Gravesham Councillors received a number of initial reports and participated in seminars and a study tour of the Ebbsfleet site before receiving a full first report at a special meeting of the Environmental Services Committee on 16 December 1997 which drew together all the issues and analysed and evaluated the proposals.
Following resolution of many of the issues and concerns identified a further report was submitted to a special meeting of the Environmental Services Committee on 4 March 1998. The Borough Council resolved to grant planning permission subject to 91 planning conditions and also subject to withdrawal of a holding direction by the Highways Agency, to the Secretary of State not calling the application in for the determination as a departure from the development plan, and to the applicant entering into a legal agreement under Page 19
section 106 of the Town and Country Planning Act 1990 to provide amongst other things education contributions and affordable housing.
Following the withdrawal of the Highway’s Agency’s holding direction and notification from the Secretary of State that the authorities could determine the application themselves work proceeded from the beginning of 1999 on the refinement of the heads of terms of the legal agreement and the drafting of the agreement itself. Negotiations on the agreement were long, protracted and very difficult.
The legal agreement was however finally concluded on 21 November 2002 and the outline planning permission issued concurrently.
The legal agreement contains provisions for the management and maintenance of open land, a financial contribution to environmental liaison, a financial contribution to heritage/interpretation facilities, the setting up of an architectural consultative group, obligations for transfer of primary school provision, a financial contribution to secondary education, and obligations for the delivery of affordable housing.
The outline planning consent, through the planning conditions, imposed not just an overall limit on the total amount of development proposed and on the maximum quantities of each land use types but also placed a ceiling on the total floorspace for each of the four quarters but with some flexibility to move within the ranges. In respect of the two Dartford Quarters the total amount of development permissible was 339,000m 2 for Station Quarter North and 250,500m 2 for Station Quarter South.
For the Gravesham Quarters the following quantities were permitted:
Springhead Quarter (Springhead Park)
The outline consent (condition C7) allows a total amount of development within the Springhead Quarter of up to but not exceeding 100,000m 2 comprising within a range of 50,000m 2 of employment (B1), 60,000m 2 (600 dwellings) of residential use, 10,000m 2 of residential supporting uses and 1,500m 2 of core space including hotels, leisure and entertainment. There would be six hectares of open space.
Northfleet Rise Quarter (Portland)
The outline consent (condition C9) allows a total amount of development within the Northfleet Rise Quarter of up to but not exceeding 167,000m 2 comprising within a range of 75,000m 2 of employment (B1), 45,000m 2 (464 dwellings) of residential use, 7,000m 2 of residential supporting uses and 30,500m 2 of core space. There would be 3.75 hectares of open space.
The total permissible employment floorspace for Ebbsfleet is 455,000m 2 which would provide 20,000 jobs. The traditional (B1 office) employment plus that generated at shops, schools and leisure uses would equate to 59 per cent of the total floorspace with 41 per cent of the total floorspace allowed being residential.
There would be 73.25 hectares of open space within the whole of Ebbsfleet.
Page 20
Social and Community Provision
The outline planning conditions provide for the delivery of a range of social and community facilities to be provided at certain thresholds of development across the four quarters including pre-school nurseries, primary schools, health care, family centre, a range of open space including a multi purpose sports centre, library, community centre, adult education, waste recycling and a place of worship.
The location of the various elements of social and community provision would be determined through the quarter master planning.
Affordable Housing
25 per cent of all the dwelling units within the two Gravesham Quarters must be affordable housing (20 per cent in Dartford) and a proportion of both the affordable housing and the market housing are required to meet lifetime homes standard. Quantities of affordable housing must be delivered at certain thresholds of market (private) residential dwellings. The terms for the delivery of affordable housing are set out in the section 106 agreement which includes obligations relating to the location, tenure, size and standard of affordable housing and the organisations to provide or manage affordable housing.
Quarter Master Planning
The outline planning conditions (conditions C4, C5 and C6) required the submission and approval of quarter master plans (QMP’s) and various planning and environmental strategies before any detailed (reserved matter) planning approval could be given to built development commencing on the site.
Springhead Quarter Master Plan (GR/2003/0016)
The original QMP for the Springhead Quarter was submitted in January 2003. The Springhead Quarter comprises an area of 27.5 hectares. The majority of the land was farmland apart from the site of former Meadow Road prefabricated dwellings long since demolished off Springhead Road.
The master plan indicated the disposition and quantum of uses and the footprint or zones of built development but the location of individual buildings was for illustrative purposes and their shape and layout would be determined at the reserved matter planning stage. The composite Master Plan indicated a number of community uses centrally located including the location of a primary school, a health facility, place of worship, leisure centre, nursery, family and community centre and recycling centre.
In terms of roads the plans showed a main spine road running through the site connecting to the A2/STDR 4 Ebbsfleet station road in the north west and Springhead Road, close to the junction with Haldane Gardens to the east. There was no road connection to Wingfield Bank and the Springhead Road/Hall Road roundabout but the potential to link was indicated.
The employment areas were shown located in the north west part of the site.
Page 21
There were six hectares of open space identified including allotments and a playing field in the south west corner of the site.
The average density of the residential development was stated to be 51 dwellings per hectare. The QMP indicated that in some locations close to the proposed Fastrack route through the site some buildings would be four storeys in height.
The original (2003) QMP proposed the following quantity of land uses:
Employment 50,000m 2 Residential 46,860m 2 (approx. 480 dwellings) Retail 500m 2 Community (residential supporting uses) 2,040m 2 Core 600m 2
Total 100,000m 2
The Springhead QMP was approved on 8 October 2003 subject to a number of informatives concerning, amongst other things, footpath provision, appropriate archaeological evaluation, details of the procurement of community infrastructure, location of affordable housing, and review of the QMP consequent to approval of the transport and other strategies. A visual impact assessment (VIA) for the Springhead Quarter was also approved.
Approval was granted under the same application to vary condition C3 of the outline planning permission to allow the footprint of the development to extend outside that set in the Ebbsfleet Development and Environment Framework and the Springhead Development Brief. Additionally approval was given to vary condition H10 of the outline planning permission to allow the building height at Springhead to exceed three storeys but subject to a condition that no building shall exceed four storeys and that any such four storey buildings are confined to the commercial area and selective locations along the main road frontages.
Revisions were made to the Springhead QMP in 2006 to reflect the submission of detailed planning applications which were submitted for the first phase of residential development, particularly in relation to the position of the spine road, although those revisions were not formally submitted for approval as they were of a minor nature.
2008 Revision to the Springhead Quarter Master Plan (GR/2008/0843)
In September 2008 an application was submitted for approval of a revised Quarter Master Plan (QMP) for the Springhead Quarter of the Ebbsfleet development and including a review of Visual Impact Assessment.
The QMP had been updated to reflect the detailed design work that had been undertaken by the applicants in relation to the provision of community facilities and the northern part of the Springhead Spine Road which links to the proposed bridge over the river Ebbsfleet.
The revised QMP included changes to the quantity of land uses to be provided within the Springhead Quarter.
Page 22
The revised (2008) QMP proposed the following floorspace:
Employment 32,000m 2 Residential 60,000m 2 (approx. 600 dwellings) Retail 500m 2 Community (residential supporting uses)* 5,000m 2 Core~ 2,500m 2
Total 100,000m 2
* Residential supporting uses means retail, class D1 uses (non-residential institutions) such as medical and health centres, day nurseries, places of worship and class D2 uses (assembly and leisure) including sports halls, dance halls and gymnasiums.
~ Core uses as defined in the original outline planning permission would include similar use classes as the residential supporting uses (retail, non- residential institutions and assembly and leisure but would also include hotels and A2-financial and professional-offices) although the applicants suggested that in the context of Springhead this would be principally sports centre floorspace.
The applicants pointed out that the community and core uses were greater than the approved QMP but they did not see this as a fundamental change. Although the outline planning permission allowed for up to 10,000m 2 of residential supporting uses in the 2003 QMP this was indicated as just over 2,000m 2. In the revised QMP some 5,000m 2 of residential supporting uses were now proposed.
The changes apparently reflected the emerging sizes of the community centre/place of worship, health centre and leisure centre. Subject to detailed design the various residential supporting uses were, according to the applicants, likely to be in the region of 2,000m 2 for the health centre, 1,540m 2 for the place of worship/community centre and 1,401m 2 for the primary school (if required).
Individual sizes for the various community facilities were not specifically indicated in the outline planning permission – they were expressed only as minimum sizes required at certain thresholds of development. The place of worship was indicated as being at least 250m 2 at the 350 dwelling unit threshold with a second place of worship of 150m 2 at 1000 units and across the Ebbsfleet development site as a whole rather than just in the Springhead Quarter. The requirements for a community centre were 190m 2 at the 200 unit threshold and a second community centre of 190m 2 at the 1,700 unit threshold. Thus a combined facility (church/community centre) should at least be 780m 2 for the development as a whole.
The revised QMP indicated a four fold increase in the quantum of core uses (to 2,500 m2) from that indicated in the approved QMP, this core floorspace being a sports centre. The applicants advised that they were seeking greater flexibility than was set out in the outline planning conditions (the maximum size leisure floorspace in condition C7 for Springhead was 500m 2 and the requirement for a multipurpose sports centre across the whole site in condition G10was at least 600 m2 on a one hectare site).
Page 23
The employment provision in the revised QMP, on the other hand, was significantly less than as approved, a reduction of 18,000m 2, while the residential numbers conversely were to be increased (from 480 to 600 units).
Other significant changes to the QMP were:
• the re-alignment of the northern section of the Springhead Spine Road
• the provision of a bus gate.
• the provision of an enlarged public Square.
• co-location of the community centre and the place of worship
• a stand alone Health Facility.
• changes to the shape of the Linear Park.
To the east of the public square on the eastern side of the Spine Road a one hectare site was still reserved as a 1FE Primary School although this does not accord with Kent County Councils preference which is for a 2FE school located within Station Quarter South.
In addition to revisions to the QMP a separate planning application had also been submitted (GR/2008/0842) for variation of condition D11 of outline planning permission GR/96/35, relating to the maximum number of dwellings that can be occupied until a certain quantum of employment floorspace has been completed within the Springhead Quarter.
The applicants requested that the condition be varied to delay the provision of employment floorspace in order to provide an initial focus of employment around Ebbsfleet International Station. They considered it would be unviable to provide commercial floorspace at Springhead at this time.
The revised QMP and condition D11 variation were considered by the Council’s Regulatory Board in November 2008 but a decision at that meeting was deferred and also at a further meeting in December pending the submission of additional information. The Borough Council did have some concerns at the delay in the provision of employment and the reduction of employment floorspace at Springhead since it was being reduced from 50,000m 2 in the approved QMP to 32,000m 2. However the employment floorspace would still provide 1,500-2,000 jobs at Springhead. In addition there were employment opportunities arising from the various community facilities.
The revised QMP and the variation to condition D11 were approved on 14 January 2009.
Station Quarter South Quarter Master Plan (DA/06/1045)
Dartford Borough Council approved the QMP for Station Quarter South on 12 October 2007.
Page 24
Station Quarter South is located in the south west corner of the Ebbsfleet development and comprises an area of 35 hectares. It is bounded along its eastern edge by the River Ebbsfleet, to the south by the A2 and to the west by Southfleet Road connecting to Swanscombe. It was formerly used for mineral extraction and deposition and has been subject to considerable land alteration. The site is divided into two parts by the Station access road across the Ebbsfleet Valley. The northern part is land remodelled under the CTRL works and is used for station surface car parking. The southern part has been returned to grassland.
The QMP indicates the northern part being a business district with commercial uses and retail development but with some residential development. The southern part is termed the southern neighbourhood and would comprise principally residential uses but with some commercial including hotels and a primary school. A large park area of 7.1 hectares including playing pitches and a multiuse games area would also be located in the southern part of the quarter (South Park). There would also be a civic square, market square and neighbourhood gardens.
Development would be principally medium to high density, generally 4-5 storeys with taller building along road frontages and some high landmark buildings of 10 storeys or more.
The Station Quarter South QMP proposed the following floorspace:
Employment 93,000m 2 Residential 135,000m 2 (approx. 1390 dwellings) Community (residential supporting uses) 2,500m 2 Core 19,500m 2
Total 250,000m 2
The employment floorspace was reduced by 37,000m 2 from what was approved in the outline planning consent.
The approval was subject to caveats on road junction design, the final design of area D and archaeological investigation and to informatives indicating that local archaeology should be used as a reference to the design of the southern park, that in the detailed design there should be integration and consistency with transport ad infrastructure issues and that biodiversity is incorporated into detailed submissions for open spaces and landscaping.
Station Quarter North Quarter Master Plan (DA/08/00577)
An application was made to Dartford in April 2008 for approval of the Station Quarter North QMP.
The Quarter is located around the Ebbsfleet Station itself where much of the area is currently used for station car parking which will be relocated to decked car parking or additional surface parking. It is bounded along its eastern edge by the River Ebbsfleet, to the north by rail tracks and to the west by Southfleet Road. The southern boundary falls broadly through the middle of the station car park area. The western half of the site is dominated by a restored landfill area.
Page 25
The Station Quarter North Quarter extends to 70.65 hectares.
The QMP indicated this Quarter as being a principally commercial district in a number of distinct centres including Fleet Place, the heart of Ebbsfleet, a central urban space and commercial district with buildings on average 8 storeys high; Blue Lake Promenade lined with tall buildings including retail at ground floor running from the station; Station Square West a smaller development around the station providing commercial, retail, hotel and residential space and Western Quarter, a mixed use area with development up to four storeys but with some taller buildings.
The Station Quarter North QMP proposed the following floorspace:
Employment 200,000m 2 Residential 83,000m 2 (approx. 930 dwellings) Community (residential supporting uses) 2,500m 2 Core 53,500m 2
Total 339,000m 2
The QMP indicated the provision of 40.5 hectares of open space and comprising two sports pitches, five combined local play areas, four additional hard landscaped open spaces and three additional soft landscaped open spaces, the major open space being located to the north west of the station (North Park).
Dartford Borough Council approved the QMP for Station Quarter North on 29 May 2008. It was approved subject to informatives advising that the canalisation of the River Ebbsfleet beyond that already existing would not be acceptable and also pointing out that there were concerns about the structure of the blocks to the south and north and future reserved matters will be expected to ensure that buildings address the street scene to provide activity and vitality and that the spaces are of a scale and character which create a pedestrian friendly environment.
Northfleet Rise Quarter Master Plan (GR/2008/327)
An application was made to Gravesham in April 2008 for approval of the Northfleet Rise QMP.
The Northfleet Rise Quarter extends to some 17.2 hectares.
It is bounded along its western edge by the River Ebbsfleet, to the north by railway tracks of the Kent Railway Line and to the south east by Blue Lake. It is largely unused land, partly overgrown and partly enclosed by fencing. It comprises areas of grassland, some woodland and some marsh. The land rises to the north where it includes former railway sidings. There is an overhead electricity line that crosses through the site. It used to be the Ebbsfleet pleasure ground adjoining the former Blue Circle Sports Ground. To the south is the Northfleet sewage treatment works.
The Ebbsfleet River within the Quarter is little more than a stream but it does have valuable reed beds and associated wetland habitats and is currently maintained artificially by pumping.
Page 26
The Northfleet Rise Quarter is truncated by the embankment carrying the North Kent railway link running between the North Kent railway line and the CTRL domestic platforms.
The quarter is also dissected by the route of Thames Way (STDR4) which is a strategic highway route connecting Springhead Road with Stonebridge Road but with links across the Ebbsfleet Valley to the station and the A2. It is a two way single carriageway with a footway/cycleway on one side of the road (north) but with the potential to be dualled. There is a roundabout connection into the Lafarge Cement Works and the route of STDR4 west of Springhead Road used to be the Blue Circle private access road to the cement works.
The application for the Northfleet Rise QMP also included a Visual Impact Assessment (VIA) and a Landscape Strategy Framework.
The Northfleet Rise QMP proposed the following floorspace:
Employment 75,000m 2 Residential 45,000m 2 (approx. 464 dwellings) Community (residential supporting uses) 7,500m 2 Core 34,900m 2
Total 162,400m 2
The outline consent allowed up to 167,000m 2 in total and with quantums of types of floorspace up to 75,000m 2 of employment (B1), 45,000m 2 (464 dwellings) of residential use, 7,000m 2 of residential supporting uses and 30,500m 2 of core space, although these maximums would have totalled only 157,500m 2. Although the overall total in the QMP was shown as reduced from the outline consent it was still greater than the specific floorspace maximums when cumulatively added and there was an increase of 500 m2 of residential supporting uses and 4,400 m2 of core space.
The QMP proposed 3.75 hectares of open space.
In terms of implementation the proposals indicated that the development would be on a phased basis with Northfleet Rise being one of the second phases of development following the first phase focused around the CTRL Station. No specific interim uses were proposed.
In terms of dwelling density an average gross density was indicated as 35 dwellings per hectare but that density would not be uniform across the quarter. The net residential density allowed in the outline planning conditions (condition H10) would allow 60 dwellings per hectare.
Employment would be focused in the south west area of the quarter creating a commercial hub linked with the core area with the Station Quarter North.
In respect of building heights these were indicated as principally 5-10 storeys for built development either side of STDR4 but with some lower buildings of 1-4 storeys. A development of 1-4 storeys was shown in the south west corner near to Blue Lake but with a potential landmark building (possible hotel) of over 10 storeys. The maximum height permitted in the outline consent (condition H10) is 6 storeys.
Page 27
A key element in the master plan layout linking the Northfleet Rise QMP with that of Station Quarter North was what the architects termed Blue Lake Promenade, a thoroughfare linking Blue Lake with Ebbsfleet Station.
In respect of car parking the QMP indicated that an allowance of up to 1.5 spaces per residential dwelling would be permitted as an average across the site. However some elements of parking may be charged for on a leased basis. Much of this parking would be undercroft parking.
The road layout proposed a grid system with a strong emphasis on non- highway based transport measures. The current roundabout on Thames Way that provides a link to the Northfleet cement works was shown as a cross roads in the master plan probably traffic light controlled.
In terms of open space it was indicated that play facilities and open space would comprise two combined local play areas, one additional open space (hard landscape), two additional open spaces (soft landscape). A river park (or pocket park) focused on the river Ebbsfleet was shown to be located within the centre of the site and open space was proposed in the southern area next to Blue Lake. The river was proposed to be widened to provide storm water storage capacity but also as a recreational and ecological feature.
The Northfleet Rise QMP, Visual Impact Assessment and Landscape Strategy Framework were approved on 25 June 2008.
Planning and Environmental Strategies
The outline planning conditions also required the submission and approval of various planning and environmental strategies before any detailed (reserved matter) planning approval could be given to built development commencing on the site.
An application for approval of the Transport Strategies (GR/03/441) for both the Springhead Quarter and for Ebbsfleet as a whole (Ebbsfleet wide) pursuant to conditions F1 (a-d) and F1 (c) respectively of the outline planning permission was submitted in May 2003. Following a series of amendments revised transport strategies were finally approved on 13 May 2005.
A range of other environmental and planning strategies (application reference GR/03/660), addressing such matters as air quality, noise, water management, archaeology, leisure, public art, landscape, utilities, contaminated land and construction code relating to the Springhead Quarter specifically or on an Ebbsfleet wide basis were also submitted pursuant to the outline planning conditions in July 2003.
These strategies establish the principles to be applied to the various environmental factors and provide guidance and a checklist to designers to take into account in the detailed development proposals.
Modelled Air Quality baseline data for Springhead Quarter submitted pursuant to condition E12 (a) was approved on 8 October 2003.
The Construction Code of Conduct submitted pursuant to condition E11 of the outline planning permission was approved on 31 December 2004.
Page 28
The Utilities Strategy submitted pursuant to condition H3 of the outline planning permission was approved on 31 December 2004 subject to informatives.
The Springhead Quarter Landscape Strategy submitted pursuant to condition E7 of the outline planning permission was approved on 31 December 2004.
The Public Arts Strategy for Ebbsfleet was approved on 21 December 2004.
The Ebbsfleet-wide Leisure Strategy submitted pursuant to condition H2 of the outline planning permission was approved on 20 January 2005.
The Springhead Archaeological Framework and Ebbsfleet Updated Archaeological Strategy were both approved on 10 May 2005. An Archaeological Written Scheme of Investigation for Springhead Quarter Phase 1 was approved on 1 June 2005.
The Ebbsfleet-wide Structural Landscape Strategy was approved pursuant to condition E6 of the outline planning permission on 10 May 2005.
The Ebbsfleet-wide Environmental Management System submitted pursuant to condition E1 of the outline planning permission was approved on 10 May 2005.
The Springhead Quarter Water Management Strategy and the Ebbsfleet-wide Water Management Strategy were approved on 2 June 2005.
An Indicative Phasing Plan submitted pursuant to condition A5 of the outline planning permission was approved on 6 June 2005.
A separate application (GR/2008/414) for approval of a combined transport strategy for the Northfleet Rise and Station Quarter North quarters submitted in May 2008 and was finally approved on 5 November 2009 following amendments made in March 2009 as required by the Highway Authorities. The approval was subject to informatives.
A number of strategies for the Northfleet Rise Quarter were also submitted and approved in 2008 – Water Management Strategy (GR/2008/0464), Contaminated Land Strategy and Air Quality Baseline Data (GR/2008/0440) and Archaeological Mitigation (GR/2008/0394).
A community development strategy (condition G18) and some environmental strategies for the remaining quarters are still to be submitted.
An application (GR/2009/0399) for approval of condition F1 d (xi) of outline planning permission reference number GR/96/0035 relating to the framework travel plan was approved on 30 October 2009. The Framework Travel Plan was submitted to provide a framework and toolkit to assist future developers prepare their own individual travel plans. The approval was subject to the informatives.
An application for a Joint Monitoring Strategy (JMS) submitted pursuant to condition H1 (Planning Application GR/2009/0166) was approved, following revisions to the document, on 10 November 2009 subject to informatives.
Page 29
Detailed Planning Approvals
Detailed planning approval was given for the new road junction on to Springhead Road to serve the Springhead Quarter (GR/2005/0126) on 1 August 2005 providing a traffic signal junction with bus priority and pedestrian and cycle provision, and for the initial part of the spine road serving the Springhead Quarter (GR/2006/604) on 11 September 2006.
Reserved matter planning approval was given for the first phase of residential development for 388 residential units at Springhead Park with associated car parking and open space (GR/2006/454) on an area of 7.2 hectares, also on 11 September 2006 following a report to the Regulatory Board on 6 September 2006. The approval was subject a number of additional conditions.
About 65 per cent of the phase 1 development will be one and two bedroom apartments and 35 per cent two, three and four bed houses. There will be 94 affordable units provided by Amicus/Horizon, London and Quadrant (formerly Tower) and Hyde Housing including social rented, intermediate rented and shared ownership units, with a similar split as the overall mix between houses and apartments.
The net density is 62.5 dwellings per hectare and there will be 558 car parking spaces for the 388 units. The parking provision comprises 465 allocated spaces, 59 occasional visitor spaces and 34 management company leased spaces.
Countryside Properties are developing the first phase of development on behalf of Land Securities.
About 120 units (including affordable units) have been completed and are occupied on a leasehold basis and a further 90 units have been either completed or are under construction. The current build programme is around 50 units per annum.
The first phase of development at Springhead Park also includes a one hectare local park (Central Park) which is now open and is known as Penn Green Park.
Consent has been given for a temporary marketing suite (GR/2006/0483) and for the use of Wingfield Bank Bridge as a means of construction access to the site, including bridge strengthening works (applications GR/2006/1100 and GR/2006/0980 respectively).
Planning permission was also granted for an application (GR/2006/0907) for the re-routing of a public footpath (NU19) around the perimeter of the development.
Planning permission has been granted for an application (GR/2009/0709) for the variation of condition 3 of planning permission reference number 20060454 for residential development to allow the erection of a conservatory on 25 of the units, being plots 245-251, 345-358 and 297-300.
Page 30
Other Applications
In November 2007 retrospective planning permission (GR/2007/0865) was granted for the retention of engineering works associated with a series of ponds and culverts required as part of a surface water drainage system for the Springhead Quarter. The system involves discharge into the River Ebbsfleet via a stepped cascade with reed bed planting to provide cleansing prior to discharge. The culvert and associated ponds are located in the northern part of the Springhead Quarter.
In December 2008 planning permission was granted (GR/2008/0885) for the installation of a temporary underground 11kV cable between Springhead and Eastern Quarry for a temporary period of five years.
Spine Road Phase II and Ebbsfleet Bridge
Applications were submitted at the end of January 2009 for Phase II of the Springhead Spine Road (GR/2009/0058) and the Springhead Bridge Link (GR/2009/0057).
The Phase II Springhead Spine Road will extend the current built spine road within the Springhead Quarter north westwards through the part of the site shown in the QMP for employment, providing a two way carriageway width of 6.75m and with a separate public transport only bus gate. The area of the application which includes as well as the roads, points of access for future developments, creation of a car park, a permissive way pending the diversion/stopping up of public footpath NU20, a public square, landscaping and an attenuation pond, extends to 4.6 hectares.
The Springhead Bridge Link will take the Spine Road over the River Ebbsfleet to join with the Station Link Road which takes traffic between STDR4 (Thames Way) and the A2 across the Ebbsfleet Valley and to the Ebbsfleet Station. The bridge is a composite structure formed of steel beams, concrete deck and concrete abutments. The supporting embankments are formed with reinforced earthworks. The development will require the removal of reed bed habitat with associated ecological impacts. The area of the application is 2.2 hectares and the application was also submitted to Dartford Borough Council as part of the bridge is within Dartford.
These applications were considered by the Council’s Regulatory Board on 15 April 2009 and were granted permission subject to conditions.
3. The Proposal
Background to the Ebbsfleet Landmark Project
In May 2007 Land Securities in conjunction with London and Continental Railways (LCR) and Eurostar announced that they proposed to commission the building of a major public artwork for Ebbsfleet Valley, a £2m project known as the Ebbsfleet Landmark Project, and which would occupy a prominent site in the south east corner of the Springhead Quarter.
The aim was to create a high profile marker for the Ebbsfleet Valley as well as for the Ebbsfleet International railway station. Page 31
They put together a panel comprising representatives from the companies involved and art experts to oversee the selection of a design for the landmark.
Five internationally acclaimed artists were invited to take part in the project and their artworks were the subject of an exhibition at Bluewater shopping centre in 2008.
Three of the submissions – Daniel Buren’s ‘Signal’, Richard Deacon’s ‘Nest Sculpture’ and Mark Wallinger’s ‘White Horse’ were selected towards the end of 2008 to go forward for further refinement; the two schemes not selected were Christopher Le Brun’s ‘Wing and Disc’ and Rachel Whiteread’s ‘Recycled Mountain’.
The selection panel announced on 10 February 2009 that Mark Wallinger’s ‘White Horse’, a figurative sculpture of a 50m high white horse, had been chosen as the winning entry.
The White Horse Design Philosophy
The design philosophy behind the sculpture is described in the ‘Ebbsfleet Landmark: Unveiling the Shortlisted Proposals’ (7th May 2008). The document reports that:
“The ancient route Watling Street – now the A2 – runs adjacent to the site and as the main route into England from mainland Europe would have seen countless thousands of horses transporting man and his possessions over the centuries. The Thoroughbred was first developed during the 17th and 18th centuries in England, when native mares were crossbred with imported Arabian stallions. Every racehorse in the world is descended from these animals and the White Horse wears a bridle to signify that it has been domesticated and bred by man.
Wallinger has, for many years, explored the history of the horse and its link to man. The horse in Anglo-Saxon mythology is an extremely significant symbol. ‘Horsa’ – from which we derive the word ‘horse’ – was the semi-mythological leader of the Anglo-Saxons who landed near Ebbsfleet, on the Isle of Thanet in the 6th century and so the white horse became the symbol of Kent. In ancient times these figures would be made by revealing the underlying chalk and the sculpture connects visually to the more recent chalk quarry faces that define Ebbsfleet Valley.
Wallinger’s work examines identity, nationality, and the politics of representation. Horses have featured extensively in his work and he sees the racehorse as symbolic of colonial and post-colonial history.”
The artist, Mark Wallinger, has indicated that,
“As a sculpture the aesthetic work has been done. The horse is the work of continuous collaboration between man and nature. It is beautiful. And if the scale makes it uncanny, perhaps this is because it is also something quite plain and simple – a horse in a field.”
He has also described the sculpture as a recognisable, entire and organic feature in a scarred landscape. It is modelled on a racehorse which he is the part owner of, 'Riviera Red'. Page 32
The Chair of the Selection Panel for the competition, Victoria Pomery, explained that,
“The selection panel arrived at their decision on the basis of artistic merit and it was felt that Mark Wallinger has made an outstanding response to the brief. I am confident that it is the right one. Mark is a superb artist of world renown and his sculpture will become a real landmark for Ebbsfleet Valley and the whole region.”
About the Artist
British artist Mark Wallinger was born in Chigwell, Essex in 1959. He studied at the Chelsea School of Art and Goldsmiths College where he also later taught. He also briefly studied architecture at the University of Sheffield.
He exhibited throughout the 1980s and in 1983 was included in the Young British Artists II exhibition at the Saatchi Gallery. He was also one of the artists featured in the iconic Sensation exhibition at the Royal Academy of Arts in 1997. In 1998 he was awarded the Henry Moore Fellowship at the British School in Rome and in 2000 a retrospective of his work, Credo , was exhibited at Tate Liverpool.
Mark Wallinger works in many different media, including performance, video and photography as well as painting and sculpture. From his early paintings onwards, his art has often been concerned with social issues, and sometimes with a preoccupation with death, belief and myth. One of his earliest successes was a series of paintings of race horses, Race Class Sex . In 1993 he bought an actual racehorse in syndicate which he named A Real Work of Art and was nominated for the Turner Prize. His sculpture Ecce Homo (1999) was the first to occupy the empty 4th plinth in Trafalgar Square. In 2007, the Turner Prize was awarded to him for the work for which he became best known: the re-creation in the Duveen Galleries at Tate Britain of Brian Haw’s protest display outside Parliament at Westminster.
He was more recently the curator of The Russian Linesman exhibition at the Hayward Gallery in 2009.
The Planning Application
Scale
This planning application seeks planning permission for the construction of the Ebbsfleet Landmark Project, which is entirely funded by the private sector. The artwork or sculpture is in the form of an accurate representation of a thoroughbred white race horse with a bridle in a field. It will be 33 times life size.
It will be known as the ‘White Horse at Ebbsfleet’.
The main body of the sculpture is 40 metres high with the head of the sculpture up to 50 metres tall. The sculpture is a maximum 56.9 metres wide and a minimum of 35 metres wide at ground level (front to rear legs).
Page 33
Location
The sculpture is to be located on what is currently open land on an escarpment that overlooks the Ebbsfleet river valley and takes in an area of approximately 0.36 hectares. It is an elevated position at 30m above ordnance datum and about 20 metres higher than the A2 trunk road to the south.
The applicants advise that the site was selected following an assessment of sites within the locality and also within the control of the Ebbsfleet Landmark Project patrons and was chosen because the surrounding topography allows for the artwork to be seen by a significant number of people on a daily basis whether from the A2 or from Ebbsfleet International Station.
The sculpture will be seen on the escarpment against an urban backdrop immediately adjacent to overhead pylons and electricity lines. It is approximately 10 metres below the maximum height of the adjacent National Grid electricity pylons. Ultimately it will be seen against a background of the emerging Springhead Park residential development with Phase 2 of the development being nearest to the site, and the nearest buildings are likely to be in the region of 80 metres away although at this stage it is not known what their relative heights will be.
This part of the Springhead Quarter will be used as parkland as a linear park and which will include some wooded areas and potential allotments. Work will commence on the linear park as the new development at Springhead Park progresses.
There is a public footpath that runs through the site, NU16, which will require a temporary diversion for construction purposes.
Construction
The sculpture will be assembled on site and will be constructed using a primary and secondary steel frame with a sprayed concrete finish. It will be supported on concrete piled foundations approx 25m deep with interlinking ground beams.
Pre bent mesh reinforcement, produced using computer modelling to replicate the contours of the horse, will be imported to site and prefabricated in 2m x 2m panels incorporating secondary backing mesh, which will be craned into place and tack welded onto the secondary steel. The initial scratch coat (cement) will be sprayed onto the mesh from the bottom of the horse up. The final sculpting coat (cement) will be applied from the top of the body down.
The finished surface will be a mixture of cement plaster and colour pigments.
No major earthworks are proposed or changes in levels beyond a surface strip of 300mm and excavation for the pile caps.
Construction access will be via the existing Wingfield Bank Bridge which is currently used by Countryside as their construction access to Springhead Park to develop the phase 1 residential scheme.
Site hoarding will be erected around the construction site and compound. A crawler crane and tower crane will be required on the site during the construction Page 34
phase. Access walkways or access scaffolds will be erected to gain access to the face of the horse. The scaffolding will be covered in sheeting to protect the concreting operation from rainfall.
The construction programme is likely to run for about 18 months although if permission is granted it is not known whether it would be completed in time for the London 2012 Olympics.
Anticipated numbers of management and operatives will vary throughout the project, commencing at 5-20 staff, increasing to 20-30 generally and reaching a peak on site of circa 100 operatives.
Illumination and Landscaping
It is not intended to illuminate the sculpture at night.
There are no landscape proposals by way of mitigation, as the proposed landmark feature is designed to be visible although some landscaping will be necessary by way of reinstatement of the land with grass seeding and a pathway.
The area under the body of the horse would feature grasscrete mono-blocks or similar for maintenance access and water drain off.
Access and Parking
It is not intended for the sculpture to be a formal visitor attraction due to its high visibility from the A2, adjoining roads across the valley, High Speed 1 and the Ebbsfleet International Station, but any visits by the public are suggested as likely to be only of a short duration. The applicants advise that the development is not intended to be a commercial development and no income will be derived from it. Therefore it is not intended that vehicular access should be provided direct to the site as a matter of course.
Upon completion the landmark will be accessed from the A2 at the Pepper Hill junction with tourist signs directing visitors to the A2260 (Springhead Road) and A226 (Thames Way) and with access also from the spine road through Springhead Park linking with the Ebbsfleet Station link road via a new bridge across the river Ebbsfleet due for completion in 2012.
The applicants suggest that they consider visitor numbers will be relatively low. They indicate that car parking provision is expected to be in the region of 24 spaces which is considered appropriate for any demand that may arise. The exact location is still being considered and will be either a communal area serving a range of uses or at Station Quarter South near to the station. The number of spaces is based on comparable landmarks such as the Angel of the North at Gateshead where there are 30 spaces and two coach spaces and the Dream Sculpture at St Helens where there are 20 spaces.
There will be a number of pedestrian routes to the site from Wingfield Bank next to the Sainsbury retail store, from the new footpath around the eastern and southern edges of Springhead Park, from the Springhead Park residential development and from the Ebbsfleet linear park.
Page 35
There will be public transport services close by in Springhead Road but also from within Springhead Park by existing bus services and from a future Fastrack service.
Delivery and Maintenance
The project has been commissioned by three patrons, Eurostar, Land Securities and London and Continental Railways (LCR). Together the three companies have formed a new not for profit company, Ebbsfleet Landmark Project Limited. The company administers the project fund and will safeguard the ongoing legacy of the artwork once it has been completed and installed. There is no local authority funding for the project.
It is intended that the project will be delivered, subject to detailed funding arrangements, by Ebbsfleet Landmark Project Limited which will also be responsible for the ongoing maintenance requirements of the artwork.
The intended life span is suggested as at least 60 years.
Maintenance is dependent on a variety of factors. The applicants indicate that the materials and processes recommended are based on the highest performance and durability especially in wind, salt air, high humidity and broad temperature range. Finish sealers are intended to maximize the resistance to natural shedding of dust, soot and airborne debris particularly during rain.
Maintenance treatment would consist of a low intensity pressure wash and is considered by the applicants to be sufficient to remove accumulations of dirt or grime.
Supporting steels will be stainless or galvanised to avoid corrosion due to exposure and possible condensation.
Lightning protection will be incorporated into the structure.
The Reasons for the Proposal
The benefits of the sculpture are stated by the applicants to be wide ranging and are as follows:
• It will provide a high profile marker for Ebbsfleet Valley, the communities of Gravesham and Dartford and the wider area;
• It will engender a sense of local pride, community ownership and excitement;
• It will help identify Ebbsfleet Valley and Ebbsfleet International Station and ‘help put Ebbsfleet on the map’ through a work that impresses visitors including inbound continental visitors and potential investors in the area.
• It will be an icon for Ebbsfleet in a gateway location.
• Over 40 million motorists will view the artwork every year, as well as a significant number of rail passengers at Ebbsfleet International Station. Page 36
• It will be a local place of interest adding to the growing cultural identity of the region.
• It will create interest for walkers and users of the linear park at Ebbsfleet
• It is seen as one of a number of catalysts for the continued regeneration of Kent Thameside.
• It will bring the name and work of Mark Wallinger, a critically acclaimed artist, to Kent who has the necessary profile to aid the delivery of an internationally significant cultural project.
• There are very few comparable precedents in the United Kingdom - ‘The Angel of the North’, Gateshead and ‘Dream’ at St Helens are the only similar structures.
• It will act as an educational resource by involving local schools.
• The project has already attracted considerable media attention both locally, regionally and nationally and has helped to establish the location for new development.
The Submitted Documents
The application is supported by a series of documents and technical reports as follows:
• Planning Statement
• Planning Application Summary
• Drawings and Images
• Design and Access Statement
• Transport Statement
• Ecology Statement
• Landscape and Visual Impact Statement
• Archaeology Statement
• Construction Methodology Statement.
The following is a summary of the technical issues in the main supporting documents.
Page 37
Transport
The transport statement has been prepared by traffic consultants Peter Brett Associates.
The key issues in respect of highways identified in the supporting statement are:
• Safety Issues – driver distraction and potential for crashes and distraction from lighting.
• Operational Issues as a visitor attraction and parking provision and signing strategy.
• Construction Issues in terms of transport and materials travelling to the site.
Driver Distraction
The applicants indicate that due to the size of the proposed landmark it will be visible from a significant distance and therefore be a passive landmark as opposed to a more sudden and smaller scale distraction to drivers. There is no evidence from studies of the Angel of the North to suggest that this has resulted in driver distraction. Accident data has been analysed for both the A2 and in relation to the Angel of the North on the A1. In respect of the latter only 1 per cent of accidents were the result of distraction and none were reported to be as a result of the Angel of the North.
Trip Generation
In respect of trip generation the applicants indicate that there is no database information available for a site such as this and their approach is based on assessing the impact of two other notable landmark in the country, the Dream Sculpture at St Helens Liverpool and the Angel of the North at Gateshead. The former also did not have any data to assess visitor attraction and car park provision and visitor demand was based on the information available from the Angel of the North.
The initial estimate of visitor trip generation at the Angel of the North was fairly low such that only a small lay-by for parking was provided but subsequently upgraded to 30 spaces and two coach spaces. Surveys were undertaken by Gateshead Council between 1998 and 2001 that showed on average up to 3000 visitors went to the site on a typical bank holiday weekend. The most visitors was up to 6150 at the four day Easter bank holiday weekend in 2000.
Based on a worst case scenario this could if the same at the White Horse result in 2050 car trips on an Easter weekend or 64 vehicles per hour.
The applicants consider that this would not cause a significant impact on the local highway network.
However traffic flows on the A2 at Pepper Hill are greater in a 24 hour period (45000-75,000) than the flows on the A1 around the Angel of the North.
Page 38
Parking
The statement indicates that peak parking demands are anticipated to be during weekends when uses of other on site facilities will be limited and that parking demands of other facilities and the landmark are likely to be complimentary.
It suggests that by limiting car parking and making it distant will be a deterrent to large numbers of visitors.
Construction Traffic
The applicants advise that there will be between one and 20 construction vehicles on site on an average day during the first 20 weeks and between 10 and 100 construction vehicles on site for the remainder of the construction process. This includes site worker car movements.
The construction access will be from the A2260 and across the single lane road bridge from Wingfield Bank.
Landscape and Visual Impact Assessment
The Landscape and Visual Impact statement has been prepared by RPS Planning and Development. The statement,
• describes and evaluates the existing landscape likely to be affected by the scheme during construction and operational phases
• identifies visual receptors with views of the development
• appraises the significance of the effects on landscape character and visual resources.
It looks at both character changes and visual effects both during construction and operation.
The applicants make it clear that the landmark feature is designed to be seen and as such no landscape mitigation is proposed as part of the project.
The statement indicates that in the Landscape Assessment of Kent (October 2004) the application site is located within the Dartford and Gravesend fringes where the landscape is identified as ‘very poor’ and sensitivity as ‘low’.
It does however note that in the Local Plan it is within the Ebbsfleet Valley Area of Local Landscape Importance.
In summary in relation to the construction effects the assessment considers that,
• the Dartford and Gravesend Fringes Landscape is the only character area which would be directly affected by the construction activities
• the overall effect on landscape character during construction would be minor adverse Page 39
• the visual receptors that would experience the most significant change in view would be those closest to the site and users of the footpath
• the overall effect on visual receptors would be minor adverse.
In summary in relation to the operational effects (i.e. the visual impact once the landmark is built) the assessment considers that the Dartford and Gravesend Fringes is the only character area which would be directly affected by the development proposals and that,
• the overall effect on landscape character during the operational phase would be moderate
• there is potentially a large number of visual receptors that would experience a change in view. The visual receptors that would experience the most significant change in view would be those close residential receptors and users of the public rights of way that pass directly by the proposed landmark feature. The close proximity of these views to the White Horse would result in a moderate/major effect on views.
• the overall effect on all visual receptors during operation would be moderate/minor.
Ecology
Middlemarch Environmental Limited has undertaken Extended Phase 1 Habitat Surveys and targeted species surveys at the Ebbsfleet Development site, which includes the site of the landmark. The habitats identified within the vicinity of the landmark location include: semi natural broadleaved woodland; broadleaved plantation woodland; and semi improved neutral grassland.
Given the low moderate level of existing ecology and the predicted impacts of the construction and long term operation of the White Horse, the applicant’s consultants conclude that the adverse effect on ecology by the development would be of minor significance without mitigation.
Archaeology
An archaeological desk based assessment has been undertaken by CgMs consultants. The site has been previously evaluated (by desk study, field walking and trail trenching) ahead of the construction of the Channel Tunnel Rail Link (CTRL). There has also been an Ebbsfleet Archaeological Framework Plan (2006) that identified areas of archaeological potential in the Ebbsfleet development and which was a requirement of the conditions in the Ebbsfleet outline planning permission.
The current CgMs review concludes that from available archaeological and historical sources the site would have had a moderate potential for prehistoric, Roman, Anglo Saxon and Medieval and Post Medieval periods.
However, it suggests that from recent impacts from the construction of the High Speed railway line, and the relocation of an electricity pylon and use of the site Page 40
for spoil storage for the construction works these are likely to have significantly reduced the archaeological potential of the study site.
The applicant’s consultants conclude that the proposed development of this site is unlikely to have a significant archaeological impact due to the extent of impacts from past developments.
The applicant’s consultants suggest that any requirement for further archaeological work could follow planning permission, and is likely to comprise a two phase investigation, with an initial phase of trial trenching followed, if the results justify, by an archaeological investigation. They suggest that a condition could be imposed as follows:-
No development shall take place until the applicant has secured the implementation of a programme of archaeological work in accordance with a written scheme of investigation which has been submitted by the applicant and approved by the planning authority.
4. Development Plan and Planning Policies
The Development Plan comprises:-
• The Regional Spatial Strategy, South East Plan (2009)
• The Gravesham Local Plan First Review (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.
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
Page 41
• 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, 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
Page 42
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.
There are a number of other general policies in the South East Plan that are of relevance including:
Policy SP2: Regional Hubs Policy CC1: Sustainable Development Policy C4: Landscape and Countryside Management Policy C5: Managing the Rural-Urban Fringe Policy BE6: Management of the Historic Environment Policy TSR4: Tourism Attractions Policy TSR6: Visitor Management Policy KTG7: Green Initiatives
Local Planning Guidance
Gravesham Local Plan First Review
The First Review of the Local Plan was adopted in November 1994. The Plan predates identification of the station – related development potential at Ebbsfleet in the sub-regional guidance (RPG9a) and the Kent and Medway Structure Plan.
In the First Review the Ebbsfleet site, referred to a Land West of Springhead Road, Northfleet, is the subject of Area Policy AP14 and is considered as two distinct areas – the northern part (Ebbsfleet) and the southern part (Springhead). For the southern part (Springhead) the policy states that the Borough Council wishes to see the existing open character retained but in the longer term recognises that the area has potential for built development including residential, commercial and recreational uses.
The Ebbsfleet Valley including the escarpment at Springhead (and which includes the application site) is shown in the Local Plan Proposals Map to be within an Area of Local Landscape Significance and subject to Policy C5. This indicates that development that adversely affects the landscape quality of the area will be resisted unless it can be demonstrated that there are no other suitable locations. However it should be noted that this is not a saved policy.
There are other general policies of some relevance to this application notably TC1 (Design of New Development) and T14 (Channel Tunnel Rail Link Safeguarding) as well as the general transport and parking policies. General Leisure Policy LT1 supports the provision of suitable facilities for formal and informal recreation at appropriate locations in the urban area.
Gravesham Local Plan Second Review Draft Deposit Version 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, and the decision by the Borough Council Page 43
to replace the Local Plan with the Local Development Framework it is not being progressed any further.
The policies in the plan are therefore of only limited weight but 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 South East Plan.
In the Gravesham Local Plan Second Review the Ebbsfleet Valley including the Springhead Quarter is shown as a major development site and is subject to Policy MDS1 as follows:-
Policy MDS1 Ebbsfleet Valley
Land is safeguarded in the Ebbsfleet Valley for a new mixed use development, comprising employment, residential, hotel and leisure uses, with supporting retail and community facilities. Development proposals will only be permitted where the following criteria are met:- i. a mix, distribution and density of development which discourages the need to travel by private car and encourages travel by more sustainable means; ii. with regard to the Springhead Quarter, an appropriate mix between the principal land uses of residential and employment, where neither use predominates (see paragraph 3.3.10); iii. with regard to the Northfleet Rise Quarter, an appropriate mix between the principal land uses of employment and residential, with employment use predominating (see paragraph 3.3.10); iv. the phasing in of necessary social and community infrastructure, to ensure that adequate facilities are available at all stages of the development to meet the needs of new residents; v. a high quality of urban design; vi. a high degree of public access throughout the site; vii. a hierarchy of extensive green spaces and water spaces; viii. a close integration with the Channel Tunnel Rail Link (CTRL) and the Ebbsfleet International and Domestic Station (see Policy T5); ix. close integration with existing communities through the provision of road, pedestrian, cycle and public transport links, including a dedicated corridor for Fastrack ; and x. the concentration of development at nodal points and along public transport corridors.
All proposals will be subject to Policies T1 (Location of Development), H9 (Affordable Housing), LT3 (Green Grid) and SC1 (Social and Community Infrastructure).
The Ebbsfleet Development and Environment Framework and the Development Brief for the Land West of Springhead Road, Northfleet will remain important material considerations in determining any future planning applications within the Ebbsfleet Valley which are related to the Page 44
CTRL and the Ebbsfleet International and Domestic Station. In the event of Phase 2 of CTRL not proceeding, fresh proposals for development in the Ebbsfleet Valley would need to be subject to a new development brief.
Springhead is also shown as an area for new employment under policy E4, for new housing under policy H1 and for development of green grid sites under policy LT3.
The Ebbsfleet valley including the ridge of land on which the application site is located is shown as an Area of Local Landscape Significance under policy NE3 which allows development only where local character and the landscape function of the area are respected and any development should minimise impacts on the landscape.
There are number of other general policies of relevance in the Second Review including those relating to transport and parking.
Local Development Framework
The Council has been in the process of preparing a Local Development Framework (LDF) for the Borough since 2005. 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.
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.
A number of public consultation exercises have been carried out to identify the key issues and priorities for consideration in the Core Strategy.
A draft Core Strategy and Development Management Policies Development Plan Document (Regulation 25 document – Issues and Options) was considered by the Council’s Cabinet in December 2009 who approved the document for the purposes of public consultation. A six week consultation period was undertaken between 28 January and 11 March 2010 to enable residents, local businesses and stakeholders to have their say in the future planning for the borough.
It is anticipated that this will be examined by an independent Inspector appointed by the Planning Inspectorate in March 2011 for adoption in August 2011.
Draft Core Strategy and Development Management Policies Development Plan Document, January 2010
In the Core Strategy Key Diagram Ebbsfleet is identified as a regional hub.
Ebbsfleet is also identified as a strategic site under Core Strategy Policy 16 . The objectives for the site are stated to be as a major driver of economic regeneration within Kent Thames Gateway and Gravesend, and deliver sustainable neighbourhoods which relate to and reinforce existing Page 45
neighbourhoods around the western edge of Northfleet ensuring that they are well served by local provision of services and facilities such as a network of open spaces, green walking and cycling routes, community hub etc.
A number of site specific requirements are identified including open space, provision of and improvements to walking, cycling and the public realm and the provision of public art.
Core Strategy Policy 12: Culture, Tourism and Leisure indicates that,
In order to realise the significant cultural and tourism potential of the area, to improve the quality of life of existing and future residents, promote healthier lifestyles and a participative and inclusive community, the Council and its partners will:
1. Maximise the opportunities for expansion in the visitor economy derived from regeneration and growth in the area, including greater use of the River, high speed train services, London 2012, Ebbsfleet and Bluewater;
2. Encourage provision of a diverse range of cultural facilities, including leisure and art, especially within town centres;
3. Support and encourage tourism-related development, including green tourism initiatives and re-investment in existing facilities;
4. Improve the quality and quantity of visitor accommodation in the Borough;
5. Make the most of opportunities to provide appropriate leisure and cultural facilities as part of new development in accordance with PPS6 and the sequential test
6. Encourage cultural facilities as part of mixed use development schemes, including other uses such as retail (within designated centres), community facilities and housing;
7. Safeguard existing cultural and sport facilities that are viable, and seek to extend and supplement these with new facilities where appropriate to meet a broader range of needs;
8. Encourage participation in the arts throughout the Borough, taking advantage of new opportunities to make links between arts and cultural businesses and local schools and communities;
9. Promote existing tourist attractions in Gravesham, such as Milton Chantry and New Tavern Fort, Cobham Park, Jeskyns, and the opportunities offered by the Borough’s industrial and maritime heritage;
10. Encourage additional tourist attractions in Gravesend town centre and other areas with high public transport accessibility levels, as well as appropriate tourist infrastructure, such as signposting and information centres;
11. Encourage sensitive proposals for ‘green tourism’ in the rural areas.
Page 46
There are a number of general Development Management policies of some relevance including Policy 3: Protecting Amenity, Policy 4: Design, Policy 9: Landscape, Policy 13: Heritage and the Historic Environment and Policy 30: Assessment Criteria for Transport Proposals
Ebbsfleet Development and Environment Framework
Recognising the changing context in the Ebbsfleet Valley arising from the RPG9a and the CTRL proposals, and the Government’s decision that there should be an international and domestic railway station at Ebbsfleet, Gravesham Borough Council, Dartford Borough Council and Kent County Council decided to prepare the Ebbsfleet Development and Environment Framework.
This was adopted by Gravesham Borough Council as supplementary planning guidance in June 1996 following public consultation. It has been adopted by the other two Councils. The document sets out a number of principles and includes an indicative plan showing the local authorities’ expectations regarding the extent and nature of future land uses, and identifying transport corridors and a network of green space.
Key relevant principles are P3 (Regeneration), P6 (Scale of Development), P7 (New Development and Environment Standard), P19 (Height and Mass of Development), P42 (Tourism).
Land West of Springhead Road Development Brief
The Land West of Springhead Road Development Brief was adopted by the Borough Council in January 1997 and has the status as supplementary planning guidance.
The development brief identified Springhead as suitable for,
• High quality business use • A mix and balance of house types • Education and other community support uses including open space • Small scale retailing justified by the development • Possible visitor attractions including a heritage/CTRL visitor centre
In the preferred land use pattern plan the application site is shown as being within the Ebbsfleet stream corridor as an area of greenspace.
Planning Policy Guidance and Statements
The following Government planning advice documents are also material considerations:-
Planning Policy Statement No. 1: Delivering Sustainable Development (PPS1) Planning Policy Statement No. 4: Planning for Sustainable Economic Growth Planning Policy Statement No. 5: Planning for the Historic Environment Planning Policy Guidance No. 13: Transport Page 47
Planning Policy Guidance No. 17: Planning for Open Space Sport and Recreation
5. Reason for Report
Development of major public interest
6. Consultations and Publicity
Consultations
Kent County Council Planning
No comments received
Dartford Borough Council
The application was considered by Dartford Borough Council’s Development Control Board on 4 March 2010.
The Board members supported the proposal in principle, subject to Gravesham Borough Council being satisfied regarding the traffic impact from distraction to drivers on the A2. Members were concerned at the lack of detailed analysis on this topic and suggested that a further report from the applicants would be advisable.
Some Members also raised concern about
- the visual impact of the proposal in such a prominent location
- the absence of any strong link with the history and sense of place of the area and Kent in general
- and the lost opportunity for tourism and education.
Medway Unitary
No objection
Thurrock Unitary
No comments received.
Kent Highways
There is some debate as to whether or not advertising and certain types of structures can be a distraction to drivers. Some research has been carried out on this matter however this was several decades ago. However there is some concern that the proposal could increase the risk of road accidents in the area, this is more to do with location than the form of the structure. The studies suggest that distractions (adverts) close to busy interchanges or bends are Page 48
more liable to contribute to accidents than similar objects on long straight sections of highway.
This proposal being close to Bean junction for Bluewater and Ebbsfleet for Ebbsfleet International must be considered to be close to a busy junction, which will have a mix of frequent, infrequent and first time users. The matter is further complicated by the lane gain at Bean and a slip at Ebbsfleet for east bound traffic, which all adds to the complication of the junction. Whilst this matter is an issue for the Highway Agency to comment on in greater detail, any event on the A2 which results in queues forming inevitably results in traffic diverting on to the local road network, adding to any congestion.
With regards to accidents, the information submitted by the applicant shows that there has been a slight increase in recorded accidents on the trunk road (no information on local roads) after the Angel of the North was constructed. It is not possible to say whether this was in anyway attributable to the structure.
On the basis of the information that has been provided it is not possible to judge how visible the horse will be from the local highway network, and whether or not a glimpse of part of the structure over a roof or between buildings, may draw a driver’s eye from the highway. It is suggested that some form of temporary structure be installed so the impact can be assessed. This would involve video monitoring from the roads in the local area, both on the trunk and local network. Alternatively it is recommended that the applicants be requested to undertake some alternative means of simulating the visual impact.
With regards to the matter of signing, for an attraction to be signed in general a minimum number of visitors is required to be reached. It is suggested that the applicants needs to consider this matter further to see if tourist signing could indeed be justified (particularly in relation to the Trunk Road), given the low number of visitors they consider will visit the site. Any signed route will need to be carefully considered to minimise its impact on the existing road network.
It is considered that further consideration needs to be given to two aspects of the parking provision. The first is the long view, where people wish to take the art form in its landscape setting and perhaps photograph it, hopefully with the least distracting background possible, which may involve a walk to find the best position. This car park would need to be close to the Ebbsfleet junction with appropriate footway/footpaths to ensure the Art can be viewed from several directions.
The second matter with car parking is for those that actually wish to get close to the structure. Usually one car park would suffice with a footway providing the necessary links. But here because of the high speed rail cutting, this is not possible, so a second car park needs to be provided. The size of this car park needs to be determined by visitor numbers and the anticipated length of stay, so if 60 visitors arrived per hour and the average length of stay was 30 minutes the car park would need to accommodate 30 vehicles in addition to any other parking requirement for other uses.
Page 49
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 A2 trunk road at Gravesend. 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).
A Transport Statement (TS) dated December 2009 was prepared by Peter Brett Associates (PBA) on behalf of Land Securities and was submitted alongside the planning application. The TS has been reviewed by our transport consultants, AECOM.
(Note: Their technical note is appended to this report)
The HA are consequently directing conditions to be attached to any grant of planning permission relating to the requirement of a signage strategy and a construction management plan to be produced and agreed prior to the commencement of any part of the development.
The Highways Agency directs conditions to be attached to any planning permission which may be granted.
Conditions to be attached to any grant of planning permission:
1. Before the development hereby permitted is commenced, a proposed signage strategy shall be submitted to and approved by the Local Planning Authority.
2. Before the development hereby permitted is commenced, a Construction Management Plan shall be submitted to and approved by the Local Planning Authority and shall be fully implemented as approved prior to the commencement of any construction activities in association with the development hereby permitted.
Reasons
1. To ensure that the A2 trunk road continues to be an effective part of the national system of routes for through traffic in accordance with section 10 of the Highways Act 1980 and to satisfy the reasonable requirements of road safety.
2. To ensure that the A2 trunk road continues to be an effective part of the national system of routes for through traffic in accordance with section 10 of the Highways Act 1980 and to satisfy the reasonable requirements of road safety.
Kent County Council Archaeology
The site of the application lies within an area which contains extremely important and sensitive early prehistoric, Roman and early medieval remains. Archaeological investigations, especially those associated with the CTRL and Page 50
Springhead Quarter Ebbsfleet, have highlighted the potential depth and quality of archaeology within this area.
Submitted with this detailed application is an Archaeological Deskbased Assessment by CgMs which does provide a reasonable description of the archaeological resource of the area. There are a few specific comments on the desktop assessment:
• It would have been useful if the deskbased assessment had focused a little more on the application site itself and highlighted specifically the most relevant discoveries located closest to the application site. • Figure 2b is a little confusing and it would be helpful if a clearer plan could be composed showing the most recent findings from the Wessex 2004 evaluation work on Springhead Quarter and showing the relevant archaeology in relation to the application site. • It would also be useful to have a previous ground disturbance plan, showing the extent and depth of previous disturbances which have “significantly reduced the archaeological potential of the study site”. It is suggested that this statement needs more supporting data.
The Deskbased Assesment does not cover the entire area of potential impact of this development, notably the area of the site compound. It seems the proposed site compound may extend over an area where archaeology has been located (Wessex Springhead Quarter evaluation 2004). The archaeological implications of the site compound need to be assessed fully.
The Deskbased Assessment suggests archaeology surviving within the study area has been significantly disturbed. However, some of the archaeological potential relates to more deeply buried Palaeolithic remains and in view of the proposal for piling to a depth of c.25m, there needs to be assessment of the archaeology at depth. Further details of the location of the twenty 600mm diameter, 25m deep piles and the pile caps also needs to be considered once a clearer understanding of the actual archaeology present is established. In addition, it is noted the construction methodology includes the use of a substantial crane. The transportation, setting up and fixing this crane may include significant ground disturbance and this should be included within consideration of archaeological implications.
In conclusion, this landmark sculpture site lies within an area which contains significant archaeology and there is potential for similar archaeology to survive within the application site. It is important that appropriate archaeological mitigation is agreed and that a phased programme of archaeological work is well integrated into this scheme. The Deskbased Archaeological Assessment by CgMs provides reasonable information although some additional plans and data would be useful to ensure informed decisions are made. Of particular importance is the need to establish the potential for Palaeolithic remains and the need to clarify the extent of previous ground disturbance. It would be preferable if this additional information was submitted prior to determination of this application in the form of an amended deskbased assessment. The additional information should include results from some test pitting or targeted trial trenching on the site of the sculpture and on the site compound too.
If it is considered appropriate to determine this application at this stage, the following conditions are recommended: Page 51
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.
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.
Kent Police Architectural Liaison Officer
No comments received
Kent Fire Brigade
Means of access is considered satisfactory.
Kent County Council Footpaths Officer
Wishes to place a holding objection until such time further details are forthcoming and can be discussed in relation to Public Rights of Way (PRoW) both within and immediately surrounding the site.
The plans submitted which show PRoW in places are inaccurate and/or may show indicative lines of routes yet to be implemented. Detail of proposed works in terms of surface, structures, signage etc is also lacking.
I think it is probably best that a meeting is arranged with the landowner, developer etc and Gravesham to discuss not only proposals for this application but also the other PRoW in the vicinity so there is clarity as to the network now, the network to be in the future, standards required and the steps that will be necessary to achieve that.
Ramblers Association
"Putting Ebbsfleet on the map."
I presume this means letting the world know where Ebbsfleet is and has been likened to "The Angel of the North" and Gateshead. If you were to survey the people of the UK let alone the world asking where the "Angel of the North' is situated and its nearest town, probably less than 1 per cent would probably get it right. It is so far removed from iconic functional structures like The Eiffel Tower, The Sydney Opera House, The Empire State Building, Royal Albert Hall, Festival Hall and many more. A 50 metre high White Horse is for those egotists who believe it does something for Ebbsfleet. All really iconic structures are those that Page 52
are functional and offer something to and for the public in the areas they are located.
People do not say, "Oh! Lets go to Gateshead to see the Angel of the North", or will not say "Let's have a ride out to Ebbsfleet to see the White Horse". Why would they? People only see these so called "art structures" because they are driving on motorways and are just points of interest that you pass as would be a giant advertising bill-board. They do not associate them with a wonderful place to visit. So what value are they and how does it put places on the map? Art does have its place in society, but an edifice of a giant white horse is just not what is needed in the countryside.
The impact of such a structure affects people living for miles around and is a further blot on the landscape. People, like Mark Wallinger and his supporters, who revel in the idea of looking out of their back window or sitting in their garden and purring over a structure of a white horse should have one in their back garden so they can see it whenever they please without it intruding on the neighbouring properties.
In their ecology statement they admit that there would be permanent habitat losses if this application were to succeed, i.e., birds, bats, lizards, broad leaved woodland, grass land. But then they state that this is of course "best described as adverse and of a minor significance". Hasn't enough land already been taken in Ebbsfleet reducing these habitats? Is it not time, with £2m at their disposal, that they cannot put anything back to benefit our ecology? Would not Eurostar, London & Continental Railways and Land Securities be better remembered for being champions of nature? And would not Gravesham Council be at one with its residents and neighbours by refusing this application?
An exhibition was held at Bluewater to ascertain what people think of a giant white horse, but how many of those who attended the exhibition were from surrounding neighbourhoods? Less than 0.1 per cent, I would hazard a guess, which is not a true representation of local opinion. How many of those were told that the structure would result in a loss of landscape and habitat? Would this question cause a change opinion? When considering this application perhaps an exhibition in every parish within a radius of 20 miles should be undertaken which would give a much better consensus of opinion and I would be confident it would be given the "thumbs down".
I am therefore objecting to the proposed development for the following reasons:
It is aesthetically, visually intrusive and an imposition in the countryside. It further destroys the ecology of the area proper representation to obtain the views of Gravesham residents and residents of neighbouring districts has not been undertaken.
GBC (Sports & Recreation Manager)
No comments from a leisure perspective
GBC (Arts and Heritage Manager)
No comments received
Page 53
GBC (Planning Policy Manager)
Under the terms of section 38(6) of the Planning and Compulsory Purchase Act 2004, the application stands to be determined in accordance with policy as set out in the development plan unless material considerations indicate otherwise.
In this instance, the development plan comprises the Gravesham Local Plan First Review (1994) and the South East Plan (2009), with the latter taking precedence where there is conflict between the two documents because it is the most recently adopted.
Policies contained in the Gravesham Local Plan Second Review Deposit Version (May 2000) are capable of being a material consideration but the weight which may be accorded them is limited as it did not proceed to adoption. For this reason, specific reference has not been made to them in the text that follows.
The Gravesham Local Development Framework has only progressed to the Regulation 25 consultation stage to date so the weight that may be accorded policies therein is also limited.
Both the Ebbsfleet Development and Environment Framework (June 1996) and the Land West of Springhead Road, Northfleet Development Brief (1997) comprise adopted Supplementary Planning Guidance (SPG) and are also material planning considerations.
Statements of Government planning policy are also material planning considerations - particularly those relating to the need to achieve high quality design and develop sense of place based on local distinctiveness set out in PPS1 and associated documents.
Relevant adopted development plan policies include:-
South East Plan (2009)
SP3 – Urban Focus and Urban Renaissance [requires well-designed development]
CC6 – Sustainable Communities and Character of the Environment [Requires high quality built environment that promotes sense of place]
C4 – Landscape and Countryside Management [Relates to the need for positive and high quality management of countryside and landscapes outside nationally designated areas, protecting and enhancing local landscape distinctiveness based on assessments of landscape character and the use of criteria based policies].
C5 – Managing the Rural-Urban Fringe [Requires that the rural-urban fringe be subject to positive management based on multi-functionality. Functions include areas acting as a bridge to the country and gateway to towns, providing a powerful first impression to visitors and possible investors].
Page 54
BE1 – Management for an Urban Renaissance [Promotes and supports design solutions relevant to context and which build upon local character and distinctiveness and sense of place]
TSR4 – Tourism attractions [General support given to the provision and enhancement of tourist attractions, particularly where they assist in regeneration and reinforce the distinctiveness of a locality. Kent Thames Gateway specifically identified as a suitable location for regionally significant attractions].
KTG1 – Kent Thames Gateway Core Policy [Requires high standards for the sustainability and design of new communities and for improvement of existing area, reflecting the riverside and historic character of the area]
Gravesham Local Plan First Review (1994)
TC1 – Design of new developments [Scale and massing of buildings should normally be in keeping with their surroundings; accord with principles set out in Kent Design; with materials used of good quality and sympathetic to area concerned]
AP14(b) – Area policy on Ebbsfleet [Relates specifically to Springhead Quarter but pre-dates Channel Tunnel Rail Link and RPG9a on Thames Gateway. States that particular importance will be attached to protecting landscape of Ebbsfleet Valley].
C5 – Areas of Local Landscape Significance [Identifies the scarp slope of the valley as an important landscape feature and states that development adversely affecting this will be resisted].
T14 – Channel Tunnel Rail Link Safeguarding [Policy identifying area safeguarded under the Channel Tunnel Rail Link Act 1996].
It should be noted that Policy C5 above is affected by policy guidance set out at paragraphs 24 – 25 of PPS7 on Sustainable Development in Rural Areas (2004). This advises that it is preferable for criteria based policies to be used to protect locally valued landscape features and that local designations should only be retained where such policies cannot provide the necessary protection. Local Planning Authorities are advised therefore to consider the need for such blanket policies when the development plan is being reviewed.
Background documents include The Landscape Assessment of Kent (Kent County Council, 2004). This shows the site as lying within an area defined as the ‘Dartford and Gravesend Fringes’ where the character of landscape is fragmented, largely of poor quality and of low sensitivity. The recommendation in the document is that a new landscape framework should be created which serves in part to enhance underlying landform whilst embracing the urban nature of much of the area.
Whilst a separate landscape assessment has been undertaken to support the emerging Gravesham Local Development Framework, this does not extend to the south of the A2 at the Ebbsfleet Valley because that part of the ‘Dartford and Gravesham Fringes’ within the borough is almost exclusively comprised in the Springhead Quarter development area.
Page 55
However, the importance of the scarp slope ridge as an important landscape feature within Springhead Quarter is set out (along with other policy guidance) in the documents that follow.
Ebbsfleet Development and Environment Framework SPG (June 1996)
Policy P7 – at page 16 requires the creation of a high quality environment and development of sense of place.
Policy P19 – at page 18 on height and massing of development requires that all non-CTRL development should be sensitive to context with tall buildings confined to the northern part of the Ebbsfleet and located on the valley floor rather than its flanks. Tall and massive buildings deemed inappropriate in the southern part of the valley and on the Springhead Plateau area, with height of development needing to be sensitive to proximity to the rural area in the south and views from the A2.
Figure 7 (page 42) and paragraph 2.4.4.4 identify the scarp slope forming part of the current application site as the most prominent natural landscape feature in the Ebbsfleet valley and notes the designation as an Area of Local Landscape Significance.
Land West of Springhead Road, Northfleet Development Brief (1997)
Paragraph 6.13 notes significance of landscape and designation via the adopted Local Plan of the western slope of Springhead Quarter as an Area of Local Landscape Significance.
Figure 8 and paragraphs 8.13 – 8.19 address landscape issues and impact of development on key features.
Paragraphs 10.17 – 10.22 refer specifically to development on and affecting the Springhead plateau and scarp crest area. In particular, 10.21 states:-
10.21 Overall, development of the highest environmental quality will be expected. Heights of development on the plateau area should respect views of the site from the west and south where appropriate. Consequently, development should be drawn back away from the crest of the western slope of the site and proposals must demonstrate that noise attenuation measures and re-profiling of the CTRL cutting and planting of the slope have been fully addressed.
Paragraphs 10.36 – 10.40 address the scale and form of residential development but remain relevant in terms of approach to sensitivity of views and landscape impact :-
10.40 Height and mass of development on the site should be sensitive to the proximity of the rural area to the south, views from the A2 (T) and the wider area (see paragraph 10.19). Three storey development is considered to be the maximum within the site unless additional storeys are justified by more intensive development in the vicinity of public transport nodes and facilities.
Additional planning considerations where more generic policies will apply include those relating to visual impact; affect on amenity of occupiers of Page 56
adjoining properties; and affect on highway safety due to the potential of such a structure to distract drivers on the A2 and surrounding road network.
Discussion on merits of the application
It is not the purpose of the planning system to make judgement on what constitutes art , even less so good art .
From a policy viewpoint, the inclusion of public art to secure high quality urban design and sense of place is well established – albeit this does not preclude the requirement that designs should be developed in context and reinforce local distinctiveness.
Clearly, there are also elements of adopted South East Plan policy that lend proposals such as this support. These include support for tourist attractions that assist regeneration and the role the rural-urban fringe can play in acting as a gateway to towns whilst providing a powerful first impression for visitors and investors.
However, the proposal here has few precedents given its scale and prominence, as it will be amongst the largest animal sculptures in the world. It is important therefore to consider whether it is appropriate through the application of basic planning principles.
In looking at the application papers, the following points are therefore raised:-
Design and Access Statement:
It is noted that the Design and Access Statement contains a number of factual errors but, as these are largely immaterial to the consideration of the application itself, it is not intended to correct them here.
However, it is of some concern that the artist’s brief set out at 3.1 fails to incorporate a requirement that the design should relate to context given that Policy KTG1 of the adopted South East Plan clearly states that the design of new development should reflect the riverside and historic character of the area.
Whilst the artist’s admiration for the equine form at 4.4 is understandable, it still needs to be explained why such a statue is appropriate in this particular location.
On this the logic set out in the application would appear to be as follows:-
• The site stands next to Watling Street and thousands of horses would have passed by over the centuries;
• Horsa (from which name the word horse is derived) landed at Ebbsfleet, near Ramsgate and the white horse subsequently became the symbol of Kent; and
• Ancient tribes carved white horses out of chalk hillsides and this therefore connects visually with the chalk scars caused by cement manufacture locally.
However, this rationale is questionable for a number of reasons:- Page 57
• The original Watling Street largely went out of use as a major thoroughfare in the post-medieval period – plans from the 19 th century show little more than a country lane in the vicinity of the site and it disappeared altogether to the west of Park Corner, Swanscombe where only a footpath is shown. What we see today is a modern road constructed on a similar alignment from the 1930s onwards to service the needs of the car and not the horse. What therefore is the particular relevance of this site and what makes it special compared to any other road that might have been used in the past by horses?
• The proposed sculpture is of a modern thoroughbred horse, developed as a result of selective breeding following the introduction of Arab stock in the late 17 th – early 18 th centuries. It is likely therefore that the original Watling Street had gone out of use as a main thoroughfare before such horses were being bred in this country, so the horse depicted in the statue would be an anachronism and not representative of those that used it historically.
• If Horsa (a Jutish mercenary and not a Saxon) landed at another Ebbsfleet some 60 miles to the east, how can this be a justification for erecting a statue of a horse here? Would it not be more logical to erect such a statue there or perhaps at Aylesford, where Horsa was supposed to have died in battle in about 455AD?
• Whilst there is a tradition of carving white horses on chalk hillsides, where is the evidence to suggest that this was done in the area that was to become Kent? If not, what is the relevance in this context?
Landscape and Visual Impact Statement
The proposed statue is large (50m high) and similar in height to Nelson’s Column (52m) and higher than the Statue of Liberty (47m). It would be bigger than the proposed Kelpie Heads (35m) at Falkirk/Grangemouth (http://www.falkirkhelix.co.uk/latest/worlds-largest-horse-sculpture- planned.html ) currently being promoted as the world’s largest equestrian statue or even the mounted statue of Genghis Khan (40m) at Tsonjin Boldog, Mongolia ( http://www.nytimes.com/2009/08/03/world/asia/03genghis.html ).
Such a structure will therefore have a considerable visual impact and will be seen from vantage points both close to and far away from the actual site.
It is unfortunate then that the visual representations provided are selective, largely showing only what the structure would look like from the A2 and a number of points to the south. It would be useful if there were also representations showing what the structure would look like from the urban area to the east and from Hall Road etc.
Would it not also be a good idea to show what the structure would look like from the development adjoining when built out?
Whilst the Design and Access Statement contends at 4.4 that the sculpture is ‘something quite plain and simple – a horse in a field’, it is noted that this particular field is affected by the presence of pylons and overhead power cables. As the application has no reference to their removal, it is assumed Page 58
that they will stay. This will affect the setting of the sculpture and add to the sense of visual clutter on the hillside.
It is also noted that the importance of the scarp slope in the local landscape is identified through existing policy and the SPG for this particular site, whilst developers are advised that new buildings should be kept back from the crest and be no more than three storeys in height unless justified by their location close to transport nodes.
A judgement will need to be made therefore as to whether the proposed structure is acceptable in this context.
Transport Assessment
Whist it is noted that transport issues fall primarily within the remit of KCC Highways to comment, it is noted that the Transport Assessment covers issues relating to the sculpture acting as a visitor attraction together with potential impact on highway safety due to distraction caused to drivers.
On the former, comparisons are drawn with Dream (St Helens) and the Angel of the North (Gateshead). Whilst these may both be attractions in their own right, it is noted that they are smaller than the proposed horse sculpture – 20 metres high compared to 50 metres high. As this will make the horse one of the largest animal sculptures in the world, is there not the potential that it could be a bigger attraction?
On distraction caused to drivers, it is assumed that KCC Highways will make a judgement on whether the comparison with the impact of the Angel of the North on the A1 is valid – albeit it is noted that the A2 and the Ebbsfleet junction at this point is likely to experience considerable increases in traffic flows due to Thames Gateway related development in the area.
However, it is somewhat surprising that the issue of potential driver distraction for cars travelling along Hall Road and approaching the Springhead Road roundabout does not appear to have been addressed. Presumably the sculpture will be prominent when viewed from these points also.
GBC (Regulatory Services – Environmental Health)
The structure lies within a declared air quality management area (AQMA) for Nitrogen dioxide due to traffic from the A2 trunk road. It is considered the extra traffic generated by the sculpture will not have a significant impact on the area and there is therefore no comment to make on this issue.
Whilst it is accepted that this structure has by and large contoured edges there is no comment as to possible noise effect caused by the wind blowing onto the structure.
The applicant needs to provide some comment on this possible impact.
Page 59
Kent Wildlife Trust
The Ecology Statement provided with this application is rather vague in its assessment of the presence of biodiversity interest, particularly with regard to protected species. Also, no provision is made for mitigation or biodiversity enhancements.
The list of species provided from the data search is now out of date, and Common lizard, a protected species known to be present on the site, is now a Biodiversity Action Plan Priority Species, as is Skylark, a species that is also present in the grassland to the east of the CTRL.
However, owing to the relatively small area involved, and the small area of permanent habitat loss, these concerns can be dealt with by Condition.
Therefore we request that the following conditions (or similar) be attached to any approval:
1. A Construction Environment Management Plan to be approved in writing by the planning authority before development commences.
Grounds: to safeguard protected species and comply with the Wildlife and Countryside Act
2. A plan for habitat enhancement and/or creation to be approved in writing by the planning authority.
Grounds: to mitigate the loss of 0.4ha of neutral grassland and enhance biodiversity in line with Planning Policy Statement 9.
Subject to conditions covering these concerns being imposed upon any approval we would have no objection.
RSPB
No comments received.
Natural England
Natural England has no comments to make on this planning proposal. However we would like to stress that the absence of comments or direct involvement on individual plans or proposals is simply an expression of our priorities. It should not be taken as implying a lack of interest or indicating either support for, or objection to, any proposal.
However, we would expect the Local Planning Authority to assess and consider the possible impacts resulting from this proposal on the following when determining this application:
Local wildlife sites
If the proposal site is on or adjacent to local wildlife site, e.g. Site of Nature Conservation Importance (SNCI) or Local Nature Reserve (LNR) the county ecologist and/or local Wildlife Trust should be contacted. Page 60
Protected species
If representations from other parties highlight the possible presence, or the Council is aware of a protected or Biodiversity Action Plan (BAP) species on the site, the Council should request survey information from the applicant before determining the application. Paragraph 98 and 99 of ODPM Circular 06/2005 and Paragraph 16 of Planning Policy Statement 9 (1 Government Circular: Biodiversity and Geological Conservation – Statutory obligations and their impact within the planning system ODPM Circular 06/2005/Defra Circular 01/2005) provide information on BAP and protected species and their consideration in the planning system.
We would draw the Council’s attention to our protected species standing advice, which provides guidance on when protected species may be impacted by a proposal. The advice can be found at: http://www.naturalengland.org.uk/regions/south_east/ourwork/standingadvice/def ault.aspx
Biodiversity enhancements
This application may provide opportunities to incorporate features into the design which are beneficial to wildlife, such as the incorporation of roosting opportunities for bats or the installation of bird nest boxes. The Council should consider securing measures to enhance the biodiversity of the site from the applicant, if it is minded to grant permission for this application. This is in accordance with Paragraph 14 of PPS9. Additionally, we would draw your attention to Section 40 of the Natural Environment and Rural Communities Act (2006) which states that ‘Every public authority must, in exercising its functions, have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity ’. Section 40(3) of the same Act also states that ‘ conserving biodiversity includes, in relation to a living organism or type of habitat, restoring or enhancing a population or habita t’.
Southfleet Parish Council
When looking at your photographs Members noticed that from some angles the sculpture appears to be tangled up with the surrounding pylons, presenting a potentially odd visual impact which might attract adverse public comment. Whatever the sculpture is going to be, its actual siting needs to be reconsidered.
The Parish Council repeats the opinion previously given to others about this particular sculpture: the horse appears completely static and life-less. We feel this is such an important item of landmark art, which surely should suggest movement, speed, a sense of going forward, dynamism. The Bluewater “horse emerging from water” symbol suggests some of these aspects: in our opinion the subject sculpture does not. Think “Sea the Stars” winning the 2009 Derby by a short head = ambition, energy, life. When Members were considering the proposals, we had with us a book “The Horse in Art”; and, compared the sculpture with a rock painting of horses circa Page 61
17,000 BC, and Stubbs’ “Whistlejacket” of 1762: against these depictions of horse power in our opinion what is proposed is not enough for this prime site.
The Parish Council trusts there is time for there to be a rethink.
Swanscombe and Greenhithe Town Council
The whole set of documents have been carefully searched and scrutinised and comments made section by section. Comments have been made where appropriate and are in connection with the effect of this major development on the Town Council area as well as the Boroughs of Gravesend and Dartford, including other local village Parish’s. This is followed by a conclusion and recommendation by the Swanscombe and Greenhithe Town Council for the planning authority to take into consideration.
Archaeology Statement
As expected this statement confirms the richness of the area’s history from prehistoric times through to roman/Anglo Saxon times and industrial remains. It does not mention the closeness of the SSSI site (Swanscombe Skull Site) adjacent to Eastern Quarry. It also makes no mention of the Invicta Monument site which used to be on Park Corner adjacent to the proposed site. This is now placed by St Peter and St Paul Church in Swanscombe. The monument commemorates the meeting place of the “Men of Kent” and “Kentish Men” which resulted in Kent not being conquered by the invading Normans. It is also noted that policy BE6 states that
“Local authorities will adopt policies and support proposals which protect, conserve and where appropriate, enhance the historic environment and the contribution it makes to local and regional distinctiveness and sense of place.”
Design and Access Statement
In this statement it mentions boats travelling on the river Fleet and the roman settlements. Regarding access and public transport it mentions public footpath NU16 linking Sainsbury’s at Northfleet and bus routes 497, 498 and 499. It also mentions Fastrack but it lacks to say that these are all to the east of the site with no connections to the west (Swanscombe and Greenhithe), or that Fastrack only passes on the edge of Swanscombe, not through it.
Regarding the monument design, it states that five artists (selected by the developer) submitted designs involving public consultation and local schools with 40,000 public responses. What it does not show however, is that there was no avenue for locally submitted designs. This meant that the public and school involvement was only based on designs that the local population had no input to. Also, since the consultation was conducted at Bluewater Shopping Centre (the largest shopping centre in Europe and one visited by many, many people who do not live in Kent) it does not state how many responses were from the local Boroughs of Gravesend and Dartford. It should be noted that the populations of these Boroughs are vastly greater than the responses which indicates that the designs offered did not greatly inspire local residents.
Drawings and Images Page 62
No comment since these basically just illustrates how the monument will be seen from various positions.
Ecology Statement
No basic comment except it does not emphasis the importance of the water cress beds that used to be in this area in the past, or the fact that it is close to Swanscombe Gorge, where plants and insects have been found that are considered very rare and in some cases have never been found anywhere else in Kent. In one case an insect was found that was previously thought to be extinct.
Transport Statement
The comments are the same as those mentioned under the ‘Design and Access Statement’ in that access and transport is all concentrated to the east of the site. It seems to ignore any population living to the west, presumably because the application is produced to suit Gravesend’s Planning Committee. Whilst the site is only yards away from the border of both Dartford Borough Council and Swanscombe and Greenhithe Town Council.
Planning Application Summary
This repeats much of the previous statements so all the previous comments apply. It does state that the monument signifies the heart of the development as being Ebbsfleet Station and 10,000 properties. It should be noted that Ebbsfleet Station and the bulk of the housing proposed are situated within the area of Dartford and Swanscombe and Greenhithe Town Council.
Conclusions
Landmark: The principle of a landmark to signify the International Train Station and the surrounding major redevelopment (including Eastern Quarry) is accepted.
Design: The method of selecting a design was found to be flawed. Although local historian Mr Christoph Bull was consulted, his suggestions seem to have been ignored and there was no local input. The developers proposed design also conflicts with policy BE6 as it does not reflect ‘the historic content of the area or sense of place’ . The design being proposed is “out of character” with the area, considering historical aspects and its significance to the immediate area. Since the design is to reflect the location of the Ebbsfleet valley then the Town Council would have expected that it would have reflected a nautical flavour, because the name Ebbsfleet refers to the area where the river Fleet enters into the river Thames.
Consultation : Once again this was found to be both flawed and inadequate. The consultation only involved the designs put forward by the developer and excluded any local designs. Also responses would have been expected to have been much higher if local opinion was inspired. Documentation did not show how many of the responses favoured the design being proposed. It is also noticed that letters to the local press are against the proposed design with virtually no responses in favour.
Page 63
Tourism: There is no element supporting tourism to the Boroughs of Gravesend and Dartford only in the main for passing vehicles. The Town Council believes that this is an important opportunity that is being overlooked.
Employment: There is no mention of employment after construction and we believe that this is due to the lack of tourism to the site. More details of local labour employment during construction are also required. This is to take into account the fact that Swanscombe and Northfleet are both listed as in the most deprived areas of the UK.
Education : There is no element of education included with the propose design and the Town Council feel that this is an ideal opportunity to ensure an interactive element is included in this, or a more suitable design.
Access and Public Transport: There is no inclusion in the documentation for footpaths and cycle-ways to the west of the site. This needs to comply with the needs of the area and be approved by both the Town Council and Kent County Council Public Rights of Ways officer. With regard to public transport; there is nothing included to imply connections to the west. Once again this needs to be included, not only to new developments but to existing population areas. This needs to be approved by the Town Council, public transport providers and developers.
Sustainability: This is only slightly mentioned, more detail is needed. If a tourism element was included this could have helped to the long life sustainability.
Recommendations
The Town Council strongly objects to the proposed landmark project and recommends that the planning authority refuses the application on the grounds of being out of character with the area. Refusal is also recommended as the application does not meet the priorities of policy BE6 and is also lacking in addressing the Archaeological, Design and Access, Public Transport, Tourism, Education, Employment needs of such a development (all as mentioned in our deliberations above).
Note
Should the planning authority be minded to approve the application then the Town Council recommends that this be granted in principle only and should include the following conditions:
1. That further investigations are made to find other more suitable designs and consultations be made with the public, to include the immediate surrounding population, to identify one that meets majority approval. These to satisfy policy BE6. This to be submitted for further planning approval.
2. That Tourism, Education and Employment should form a basis for future designs and be approved by al Authorities before proceeding.
3. That Public Transport, footpaths and cycle-ways to the west of the site be approved by al Authorities before processing.
Page 64
Longfield and New Barn Parish Council
No comments received
Northfleet Action Group (NAG)
No comments received
National Grid
There is a High Voltage Overhead Lines which runs through this land parcel, COBHAM JUNCTION - NORTHFLEET - Span YN071 - YN070. Please consult the Technical Specification EN-43-8 for "Overhead Line Clearances" Issue 3 (2004); you need to be sure that any existing clearances are not infringed. The construction can not be closer than 5.3m to the nearest (lowest) conductor. National Grid will also need to be ensured that their tower access is maintained during and after construction. There is a High Voltage Underground Cable which runs through this land parcel, NORTHFLEET EAST -NORTHFLEET POWER STATION - GBS 97. Please consult the Technical Specification HS(G)47 "Avoiding Danger from Underground Services", National Grid will also need to be ensured that their cable access is maintained during and after construction.
National Grid wish to submit a holding objection on the grounds stated below:
Safety concerns regarding the application for the steel sculpture with reference to:
• Proximity of sculpture to the power lines. The height of the horse is 52 metres and the distance to the nearest conductor is shown to be 40 metres. There is insufficient clearance to the route if it falls towards the line. The impact of such an event would be catastrophic.
• Rise of earth potential. The high voltage powerline operates at 400,000 volts and due to the proximity of the sculpture there is a high risk of ‘rise of earth potential’. In other words, the sculpture will have a dangerous electric current flowing around it and without adequate earthing there is a risk of electric shock to the public.
• Construction phase: How will the sculpture be earthed / bonded during and after construction phase? There may not be adequate space for use of a crane which will need to be earthed.
• Ground excavations will need to be carefully considered due to high voltage under ground cables.
• Proximity to Northfleet East substation. Clearances will need to be confirmed
• Proximity of public to the power lines and sculpture
• Earthing plans for sculpture Page 65
• Maintenance. Will the sculpture be cleaned? If so, are there method statements and risk assessments available?
EDF Energy
No objections
Transco
Advises on low/medium/intermediate pressure gas mains in proximity to the site and safety advice.
Environment Agency
We have no objection to this proposal, provided the conditions in this letter are imposed on any permission granted. Without these conditions, the proposed development on this site poses an unacceptable risk to the environment and we would wish to object to the application:
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
The site is underlain by the Thanet Sands and Upper Chalk formations, classified as a secondary aquifer overlying a principal aquifer in accordance with the Groundwater Protection Policy (GP3). The site is also located on the boundary of Source Protection Zone I and II for a number of groundwater abstractions, and is considered to be a vulnerable groundwater protection area. A piling risk assessment is therefore required to ensure controlled water resources are protected from potential contamination.
The risk assessment should be undertaken 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.
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 LPA) shall be carried out until the developer has submitted, and obtained written approval from the LPA, details of how this unsuspected contamination shall be dealt with.
Reason
Page 66
This condition is requested because the development is located within a vulnerable groundwater protection area. This is because it is underlain by the Thanet Sands and Upper Chalk formations, classified as a secondary aquifer overlying a principal aquifer in accordance with the Groundwater Protection Policy (GP3). The site is also located on the boundary of Source Protection Zone I and II for a number of groundwater abstractions. All precautions must therefore be taken to protect controlled water resources from potential contamination.
As stated above, the site is located on the boundary of Source Protection Zone (SPZ) I and II. In accordance with our Groundwater Protection Policy, there must be no fuel storage/refuelling/maintenance of vehicles or machinery undertaken in SPZ I.
Southern Water
No objections
CABE
As the SE Regional Design Panel is already involved in the planning application it is standard practice not to offer a further review.
University for the Creative Arts
No comments received
Kent Architecture Centre (SE England Design Review Panel
Comments will be set out in a supplementary report
Turner Contemporary
The Turner Contemporary was involved in the process to select the artist and was delighted when Mark was awarded the commission. Mark is an extremely high profile artist with an international track record and has produced some seminal pieces of work during the past twenty years.
Having reviewed the documents, the Turner Contemporary remain convinced that this piece of work will be an amazing addition to the landscape and this it will bring significant regeneration impacts. Furthermore, it is believed that the work will help re- position the area and will support the wider transformation of its immediate surroundings as well as changing perceptions of Kent. This is a challenging site on which to locate a piece of art and Mark’s work considers the themes of history, identity and place, all of which are very pertinent.
It is very much hoped that this piece of work will be realised.
Christoph Bull, District Manager, Gravesend Library
No views received
GOSE Page 67
Unless we receive any requests for the Secretary of State to call in the application GOSE will not need to become involved.
Network Rail
In principle there is no objection to the proposed development. As the proposal will border High Speed One, Network Rail requests the following informatives are taken into consideration during the decision making process.
Development
Prior to the commencement of any works on site, developers must contact Network Rail to inform them of their intention to commence works. This must be undertaken a minimum of six weeks prior to the proposed date of commencement.
Construction
Any scaffold which is to be constructed within 10 metres of the railway boundary fence must be erected in such a manner that at no time will any poles over-sail the railway and protective netting around such scaffold must be installed.
Lighting
Any lighting associated with the development (including vehicle lights) must not interfere with the sighting of signalling apparatus and/or train drivers vision on approaching trains. The location and colour of lights must not give rise to the potential for confusion with the signalling arrangements on the railway. The developers should obtain Network Rail’s approval of their detailed proposals regarding lighting
Union Rail
No views received
Eurostar
No views received
Arriva
No views received
Sport England
No views received
Page 68
Ministry of Defence Estate Organisation
Thank you for consulting Defence Estates Safeguarding on the above proposed development. This application relates to a site outside of Ministry of Defence safeguarding areas. We can therefore confirm that the Ministry of Defence has no safeguarding objections to this proposal.
Whilst we have no safeguarding objections to this application, the height of the development will necessitate that our aeronautical charts and mapping records are amended. Defence Estates Safeguarding therefore requests that, as a condition of any planning permission granted, the developer must notify Tony Ruff at the Defence Geographical and Imagery Agency with the following information prior to development commencing:
• Precise location of development.
• Date of commencement of construction.
• Date of completion of construction.
• The height above ground level of the tallest structure.
• The maximum extension height of any construction equipment.
• If the site will be lit.
Civil Aviation Authority
The sculpture would not constitute an aviation en-route obstruction. There is a need to check any aerodrome specific safeguarding issues. The question of military aircraft safety should be brought to the attention of the Ministry of Defence. Due to the unique nature of associated operations in respect of operating altitudes and potentially unusual landing sites it would also be sensible to establish the related viewpoint of local emergency services air support units.
Ofcom
No views received
J Sainsbury Head Office
No views received
Publicity
The proposal has been advertised on site and in a local newspaper under Article 8 and as development affecting a public right of way although it falls outside the categories of development as a major development proposal.
Individual notification was also sent to 600 properties in the locality.
Page 69
Objections
There have been 19 individual letters of objection to the proposal.
The reasons for objection are as follows:
• It will be an eyesore and monstrosity • It should be a prancing horse or Invicta horse from the Kent heraldry • It will serve no practical purpose • It will deteriorate through lack of maintenance • It is an advertising hoarding to sell houses • It is not reflective of the local communities or the local area • It is a waste of money. The money (albeit not public money) would be better spent on more viable and worthwhile projects such as community projects or footpaths • The public exhibition (at Bluewater) was not supported by public opinion and was in any case not representative of the local opinion but voted on by shoppers • The horse is not inspiring and not reflective of the history, architecture, cultural, diversity or ethnicity of the local area. • It will be a target for anti social behaviour – graffiti and vandalism • The orientation is unsatisfactory for residents of Gravesham • The bulk/size is disproportionate to the surrounding area • It will result in hazards to road safety and be a distraction to drivers • It will result in additional traffic to this area • The development will be a visitor attraction which is contrary to what the applicants suggest based on the experience of the Angel of the North • No resident would be allowed to construct a tall structure on their own land • The landmark structure should be related to the River Thames • Big is not always beautiful • Archaeology is ignored • Flowers or trees should be planted there instead or have real horses grazing there • The relative popularity of the horse compared to the other entries does not justify a visually intrusive structure • It will be seen against a backdrop of hideous pylons which already spoil the countryside • If the horse is to be accepted it should be smaller • It should be located in the car park next to Ebbsfleet Station or in the quarries • It should include a restaurant or viewing platform • If intended to put Ebbsfleet on the map the International Station already does that; if intended to put Kent on the map the white cliffs of Dover would be a better location.
Objections at the Pre-Application Submission stage
Around 20 letters or more were also received by this Council and Kent County Council objecting to the proposal at the time when the White Horse was announced as being the winning entry. Page 70
The reasons for the objections were diverse including its lack of association with Kent, structural stability, distraction to drivers, its location against the power lines, the waste of money that could be put to other uses, its lack of artistic value, its visual impact, the sheer size of the horse and the amount of traffic generation by visitors.
Letters of Support
There is one letter of support from the Swan Valley Community School on the basis that their Year 7 group worked with Creative Partnerships when the Horse was one of the short listed candidates and the school was the location for the announcement of the competition winner.
Screening Opinion
In August 2009 the applicants submitted to the Borough Council a screening opinion under Regulation 5 of the Town and Country Planning (Environmental Impact Assessment) Regulations 1999, as amended, as to whether an Environmental Impact Assessment was required.
It was determined on 14 September 2009 that a formal EIA was not required under the Regulations based on the scale and type of proposal but the application would need to consider and address a number of important environmental issues.
7. Service Manager (Development Control) comments
Introduction
This application represents a unique and almost unprecedented proposal. There are very few artistic landmarks in this country of a similar nature or scale.
The nearest comparisons are The Angel of the North, a 20m (66ft) high sculpture with wings 54m (178ft) across, designed by artist Anthony Gormley, commissioned by Gateshead Council and supported by £0.8m from the national lottery, which was unveiled in June 1998; and Jaume Plensa’s ‘Dream’ sculpture, a more recent project, built on the apex of a spoil heap of a former colliery in 2009 at St Helens and chosen as one of seven national sites filmed for the Channel 4 ‘Big Art’ series and consisting of a large head structure, sitting on a circular concrete base plinth. The Dream sculpture is 20m high and is 100m above sea level and cost almost £2m funded by the Arts Council, Development Agencies and Regeneration funding but not by local tax payers’ money.
The Angel of the North is now considered as one of the most recognisable landmarks in the UK and is seen by up to 90,000 people each day as they pass it by car on the A1 or by train on the East Coast mainline; around 400,000 people per year visit the site itself.
Page 71
The proposed White Horse is a significantly tall structure at 50m high. By way of comparison it is similar in scale to Nelson’s column in London which is 51.5m high and the Leaning Tower of Pisa in Florence Italy which is 55m high. Blackpool Tower is 158m high. The two recently demolished chimneys at the Northfleet Cement works site were 173m tall and the Bevan’s chimney also recently demolished was 108m tall.
The B of the Bang , which was at one time Britain’s tallest sculpture at 56m high located outside the City of Manchester Stadium (the name inspired by Olympic Gold Medal winning sprinter Linford Christie, who said that he started his race on the B of the Bang) and designed by Thomas Heatherwick was dismantled in 2009 due to structural problems.
The tallest sculpture currently in Britain is the 60m high Aspire , a tapered steel sculpture painted in a variety of reds and located at Nottingham University campus designed by Make, the architectural practice founded by Ken Shuttleworth.
However even this will be surpassed as it has just been announced that a 115 metre high tower known as Orbit and described as “a looping lattice of tubular steel” is to be built in the Olympic Park for the 2012 Olympic Games. It is designed by Anish Kapoor and will allow visitors to climb its structure.
The Ebbsfleet landmark sculpture was first proposed in May 2007 and the Council received a presentation from Land Securities in October 2007 outlining the purpose behind the project.
The project has attracted huge media attention both nationally and locally at all stages since its inception and the applicants have engaged with the public and widely publicised the proposals including a major public exhibition at the Bluewater shopping centre in 2008 when over 40,000 responses were received to all five of the original landmark designs.
Despite the significant public interest there has been very limited response from local residents to the publicity given to the planning application. There have been less than 20 objections despite some 600 properties in the locality having been notified in addition to the notices on site and in the local newspaper.
There are nevertheless some strong feelings against the project from those residents that have responded and also from other local interest groups and organisations such as Swanscombe and Greenhithe Town Council and Southfleet Parish Council.
The Key Issues
The proposed Ebbsfleet landmark raises a number of key planning and highway issues that need to be fully explored and considered. These are set out below.
• The Overall Concept and its justification.
• Whether the location for the landmark is appropriate having regard to the context and background. Page 72
• The Visual Impact of the structure in the Landscape and its scale and impact on the surroundings.
• The Traffic Impact in relation to moving traffic and road safety, and potential to be a visitor attraction.
• The environmental impacts of the structure.
• Management and Maintenance Issues.
The Overall Concept and its justification.
Substantial mixed use development at Ebbsfleet centred around the Ebbsfleet International and Domestic Stations on the western edge of the Borough and running through the wider Ebbsfleet Valley into Eastern Quarry at a significant and almost city scale over a 25 year time span is now firmly established through the granting of outline planning permission by both this Borough and Dartford Borough and by the subsequent detailed planning permissions coming forward.
Whilst the progress in bringing forward the development has been slower than anticipated, to a large extent due to the slowness of the economy, and as a result due to the rethink and review of timing, scale, mix and location of development within the Ebbsfleet Valley as a whole nevertheless there is still a strong commitment by Land Securities to realise the development potential of the Valley and the station in regenerating this part of North Kent and realising the vision in creating a regional hub and a major growth point in the South East.
Firmly rooted in that vision and concept is the desire by the promoters to create a development that inspires, is cutting edge and is unique. The provision of public art and the delivery of a strong public realm is an important element of that vision. Public art is already displayed at one of the roundabouts within Ebbsfleet Valley.
A public arts strategy for Ebbsfleet has been approved by both authorities as a requirement of the planning conditions of the Ebbsfleet outline planning permission.
The strategy defines public art as encompassing,
“a wide variety of media such as murals, sculptures, paving, bespoke street furniture, photography and digital displays, architectural ornamentations, temporary events and permanent installations and performance art. At its best, public art can delight, provoke, engage and inspire”.
Public art is seen as an integral part of the master planning of Ebbsfleet to aid legibility, way finding and civic pride.
The approved strategy suggests key locations for public art within Ebbsfleet can be at gateway locations, focal points and at civic buildings.
Page 73
Whilst the Ebbsfleet landmark project may be on an entirely different scale to what may have been intended by the strategy it is suggested that the White Horse accords with general concept of the public art strategy for Ebbsfleet.
Without question public art displays are now common place in the general street scene, civic plazas, auto-routes and roadside roundabouts on the continent.
It is not the role of the Board in determining this current planning application to consider or debate the artistic merits of the chosen sculpture or to consider alternative proposals either for a different style of horse or more radically an alternative landmark sculpture which might have a theme which some consider ought to relate more to the local area.
The intention in commissioning the work was not to deliver either an abstract artwork that the public could not relate to or a brand or symbol for Kent but to create a high profile marker for the Ebbsfleet Valley or Kent Thameside.
The fact remains that the proposed landmark chosen would be a very high quality representation, would be simplistic and understandable, and is the work of a critically acclaimed artist.
Whether the location for the landmark is appropriate having regard to the context and background.
The proposed landmark is intended to be a gateway feature and is on the edge of the Ebbsfleet development. The artist’s intention was for the sculpture to be seen as a horse in a field although it could be argued that this concept will be less so with the future development that is planned to take place in this part of the Springhead Quarter (Springhead Park Phase 2) when the landmark will be seen against a background of residential development.
It is suggested in some consultation responses that the landmark would be better located in the proposed commercial areas of the emerging Ebbsfleet development or more related to the international station or station development. However, arguably the concept of a horse in a field would be further diluted in more built up locations.
Other sites were considered and evaluated by the applicants as a location for the landmark but were not considered as suitable or appropriate as the site at Springhead. These included roundabouts within the Ebbsfleet Valley or within the central area of the Valley. The former were discounted as too constrained and the latter because of lack of prominence and visibility.
The visual impact of the structure in the landscape and its scale and impact on the surroundings.
The proposed landmark sculpture is located on a hill and is clearly intended to be prominent in the landscape. There are overhead lines and a pylon immediately to the north of where the sculpture will be sited. However it is considered that these are visually permeable and would not detract from or necessarily compete with the landmark.
Page 74
The White Horse will be a significant vertical element in the landscape in the same way that the electricity pylons are or perhaps the cement works chimneys have been over the years.
It is to a large extent a matter of personal response to the proposed landmark feature whether the White Horse will be a beneficial or adverse addition to either the landscape character of the area or the views of the landscape.
The applicants supporting visual analysis suggests that the landscape quality is poor and of low sensitivity.
It could reasonable be argued that there may be some visual harm just by the sheer size of the structure and there is some merit in questioning whether the scale is appropriate in its context.
However the applicants have demonstrated that there will be no material impact on the nearest dwellings, yet to be approved and built, to the north within the phase 2 residential development for Springhead Park. Residents in the new properties within Springhead will have views of the sculpture on the skyline and in silhouette. Although the horse may create an unusual view for some residents and future employees within Ebbsfleet Valley it is not considered that this will have a detrimental impact on amenity as it is not close enough to cause a direct adverse impact.
The shadowing impact has in any case been investigated by the applicants by way of a ‘solar shading swept path analysis’ which demonstrates that there would be no impact in the summer months and only a short term impact in December.
The landmark would be visually imposing when viewed from the open countryside to the south of the A2 but it will be at the forefront of an area that will be substantially developed in the next 20 or so years and which will radically change in character.
It is not considered that the landmark would be a precedent for large or dominating development anywhere else as it can be considered as very much a one off and unique structure.
The scale and impact of the landmark have been considered by the South East England Design Review Panel and their formal response will be set out in a supplementary report. However the discussions that took place at the review panel were extremely positive towards the landmark sculpture.
The Traffic Impact in relation to moving traffic and the potential of the landmark sculpture to be a visitor attraction.
A key consideration of the proposed landmark is the impact that it will have on the adjoining highways particularly on the A2 trunk road as a potential distraction to motorists and also whether the landmark will generate a significant increase in traffic in the area leading to congestion. In addition an issue to consider will be its potential to become a visitor attraction and what provision should be made for parking for people to view the sculpture.
Page 75
The applicants submitted transport statement, which includes a comparison of similar sites such as the “Angel of the North” Gateshead and “Dream”, St Helens and a study of accident data on the A2, concludes that the White Horse is not expected to cause a significant increase in trip generation or lead to an increase in accidents along the A2 as a result of the distraction by the artwork.
Kent Highways Services who are responsible for local roads and the Highways Agency who maintain the trunk road system have critically assessed the potential for distraction of drivers by the White Horse which could consequently lead to accidents on the A2. The proposal is very close to a busy major junction, which will have a mix of frequent and infrequent users.
Kent Highway Services do not consider that the information submitted is sufficient to make a judgement and suggest that an experiment is carried out in terms of having some form of temporary structure installed at the site so the impact can be assessed and that this could involve video monitoring from the roads in the local area, both on the trunk and local network. Alternatively they recommend that the applicants be requested to undertake some alternative means of simulating the visual impact.
However it is considered that any further detailed investigation would be difficult to carry out before the landmark sculpture is in place and a pragmatic view should be taken.
Photomontages submitted with the application show clearly the impact of the White Horse on views when driving in both an easterly and westerly direction. When driving eastwards on the A2 from Swanscombe cutting, the horse will appear as a small object on the skyline but in the centre of drivers view and should therefore form no distraction. It is only when passing the Ebbsfleet junction that the sculpture will appear to the drivers left which might cause some people to turn their heads to look at it. At this point the road has flattened out and is straight. There is an Ebbsfleet on-slip but as this is also to the left of the driver they would be looking in this direction in any case.
Drivers on the A2 approaching from the east towards Pepper Hill will not see the landmark sculpture until their vehicle has passed under Hall Road and passed beyond the Pepper Hill junction slip at Southfleet. As any vehicle drives on, the sculpture would be quickly behind drivers, and certainly before the next off-slip to Ebbsfleet.
The Board will note that the Highways Agency is not objecting to the application and the HA’s technical consultants do not consider that it will cause a distraction to drivers. They direct however that conditions are imposed on a signage strategy and construction management strategy. Their consultants conclude on the issue of distraction that,
“Research would suggest that there is no link between driver distraction as a result of wind farms/ landmark sculptures. However, it is also suggested that such features are not provided at or close to interchanges or usual road layouts where drivers will be concentrating. The proposals are located adjacent to two A2(T) junctions. It is unclear if there is an existing accident problem at these junctions which may be exacerbated by the proposals. However, given that the ‘White Horse’ will be visible from some distance on the approaches to the junction, it Page 76
could be argued that drivers will have grown accustomed to the landmark and it will not pose a distraction at the junctions”.
The applicants propose to create a car park to serve visitors to the landmark, which is likely to be located at Springhead Park to enable footpath access and shared use with the community facilities proposed there. However, they have requested that this be dealt with by condition so that an appropriate location can be considered properly at the time. Similarly they have suggested that signage to the landmark also be dealt with by condition, so that account can be taken of the location of the car park and also in order to assess the situation first with regard to the number of visitors so that the need for signing can be established in order to avoid creating unnecessary signage clutter in the area.
The Highways Agency consider that the proposed parking provision is thought adequate to cope with demand and is a broadly sensible provision when compared to similar sites, although they recognise that this may need to be monitored and funding allocated to increase the size of the car park if necessary. They also consider that given the close proximity of the site to the Sainsbury’s Store there is a risk that the Sainsbury car park could be used by visitors to the site. However they suggest that the number of visitors is likely to be low.
The environmental impacts of the structure.
The environmental impacts have been fully considered and explored by the applicants in terms of ecological, archaeological impacts and construction impacts in the various technical reports that accompany the planning application.
There are currently ongoing discussions between the applicants and National Grid in relation to safety issues relating to the proximity to the adjacent overhead electricity lines and pylons.
It is considered that more information on the potential effects on environmental matters can be addressed through planning conditions.
Management and Maintenance Issues.
If permission is granted to the proposed landmark sculpture a key issue will be its longevity. Its intended lifespan is at least 60 years and to achieve this will require ongoing management and maintenance.
The applicants advise that the company administering the project will clearly want to safeguard the ongoing legacy of the artwork once it has been completed and installed and to have in place a full maintenance and management regime.
The applicants indicate that the materials and processes recommended are based on the highest performance and durability.
It is considered that these matters could also be addressed through planning conditions.
Page 77
There has been some concern expressed over the strength of the structure. The applicants have therefore clarified that the White Horse structure design has been tested and validated by a Design Engineer and also a third party expert. It will also have further detailed reviews of all the forces that might affect it, such as wind, rain, temperature change and construction loadings.
Issues relating to potential vandalism and security will also need to properly considered and addressed in response to planning conditions.
Conclusions
In conclusion it is considered that the proposed landmark sculpture will meet the intended objectives of the applicants in providing an iconic feature at the gateway to the Ebbsfleet Valley and could assist in the re-generation of this key strategic location within the Thames Gateway, and at no cost to the public purse.
There are some concerns as to whether the scale of the sculpture is appropriate in its emerging context and setting and whether it could give rise to traffic congestion as a result of its visitor attraction in the future.
However it is considered that there are no compelling planning policy or other planning reasons to reject the proposals, and such issues as the artistic merits or its cost are not relevant to the planning considerations.
It is considered that the proposed landmark in the form of a White Horse is innovative, inspirational and will create a lasting legacy for the Ebbsfleet development and the local area.
Having therefore weighed all the issues and considered all the relevant planning responses from the various consultees and taken into account the objections received in response to the very wide publicity given to the application, it is recommended that PLANNING PERMISSION be granted subject to conditions.
Page 78
Consultation expiry date: 31.03.10
Recommendation
PERMISSION subject to conditions.
The recommended planning conditions will be set out in a supplementary report.