GRAVENEY WITH GOODNESTONE PARISH COUNCIL COMMENTS
APPLICATION REF : 22/503259/SUB
PROPOSAL : SUBMISSION OF DETAILS TO DISCHARGE REQUIREMENT 12 OF THE CLEVE HILL SOLAR PARK ORDER 2020 -CONSTRUCTION TRAFFIC MANAGEMENT PLAN
Graveney with Goodnestone Parish Council would make the following comments and observations in respect of the Cleve Hill Solar Park - Construction Traffic Management Plan.
We would question the validity of some of the information provided in the Plan as this is based upon details submitted in connection with the London Array sub station which was constructed at the Cleve Hill site some 12 years ago. Since that time the number of vehicles , walkers and cyclists using the local road network has increased significantly. The last traffic survey undertaken by the developers was published back in 2019 at the time of the Planning Inquiry.
Since then there has been a continued upsurge in tourist traffic to Faversham and Whitstable and as a result there has been a proportionate increase in the use of the coastal route through Graveney and Goodnestone. Additionally, in the last few years circa 1,000 new homes have been built in and around Faversham and there is a further circa 3,500 homes shown on housing allocation sites in the Local Plan review. This has, and will continue to substantially increase vehicles using the route through Graveney and Goodnestone. This includes those vehicles looking to avoid the Thanet Way due to congestion at Estuary View and also when there are accidents or other incidents along the Thanet Way;Seasalter Road and Head Hill Road then serve as a diversion route causing extreme congestion in the villages.
There is clearly the need for an up-to-date traffic survey to give a realistic view of the current vehicle movements which in turn will provide clearer evidence of the impact which the proposed construction traffic will have on the local road network. This should reasonably include business user data which has so far been largely ignored.
The major impact which the Solar Park development will have on the villages has not been fully recognized or respected in the Plan. There is also great concern over the impact of dust, noise, pollution and structural damage which have not been addressed.
In 1.3.2 and throughout the Plan the names of certain stakeholders needs to be amended.
Graveney with Goodnestone Parish Council
Graveney Rural Environment Action Team (GREAT)
In 2.2.3 it now indicates that the development will be built in 4 phases. The original plan provided for 2 phases with an indicative timescale. We find it unacceptable that the current development plan provides no clear indication for local residents as to how long the disruption to their daily lives will last.
In 2.6.1 and 2.6.7 it states that 6 abnormal indivisible loads will be required and these will move through the villages during off peak periods,typically at night. However, there is no evidence in the Plan as to the trailer configuration and Network Rail’s requirement for structural surveys of Graveney Bridge at the pre and post works stages. It is also unclear as to who the ‘stakeholders‘ are and whether this group will include the Parish Council.
2.7.1 suggests that the daily peak traffic volumes quoted in the Outline Plan will not be exceeded. However, the peak durations have been deleted and no indication of these has been provided. This is similarly the case for daily peak HGV movements. We have also calculated that some 500 bulk carrier HGVs will be required to bring materials for the construction of the new internal access roads serving the transformers ( as detailed in the Requirement 2 submission ) and this would represent a significant increase in HGV traffic movements over the period required to create these roads. We strongly challenge the developer’s claims that this falls within the contingency allowance and would like to see the basis of this calculation.
In 3.2.1 the distance of the route from Whitstable Road to the site is 3.4 kms,not 1 km as stated.
3.2.8 suggests that the widths of Head Hill Road and Seasalter Road are between 4.5 m and 7.5 m. These measurements were previously challenged and check measurements taken at the time ranged between 4.2 m and 6.1 m. The developer should be required to provide specific locations where the 7.5 m width was recorded so that these can be validated.
4.2.2 suggests that,based on OS mapping , there are only 4 places along Head Hill Road and Seasalter Road where a large HGV and large car may experience difficulty in passing each other and a further location where this would apply to two large HGVs. Our local knowledge and experience enables us to identify other areas where similar width restrictions would apply. These include the entire section of Head Hill Road from the Whitstable Road junction to the bend at Poplar Hall; the section opposite Baron’s and Hobbit’s Oasts along Head Hill Road,and the section from Church Lane,Goodnestone to the Langdon Manor Farm entrance. We would also maintain that no account has been taken of further limitations on effective road widths and usage due to overgrown verges and hedges encroaching upon the highway,the presence of cyclists and pedestrians, cautious drivers requiring more space to pass,in addition to the planned and emergency maintenance of the highway and utility services. We would maintain that at all stated locations,including those which we have identified,it is not possible for an HGV and large car to pass.
We would also wish to see more extensive restrictions and monitoring in critical areas such as Graveney Bridge,Graveney Primary School,and Head Hill Road between the Whitstable Road junction and Poplar Hall. Furthermore,the developer should undertake revised and current measurements to ensure accurate details are recorded,the Plan updated accordingly and their implications properly considered.
4.2.3 suggests there is good forward visibility in all places where ‘two vehicles may struggle to pass’. This is clearly not the case and we would use the bend by Poplar Hall as a prime example. Once again these conclusions need to be reassessed accurately and expediently , the Plan updated accordingly and the revised implications properly considered. We would also make the point that an HGV will have better forward visibility due to the cab height which a car driver would not have the benefit of thereby putting the drivers at much greater risk.
4.2.12 suggests that in all places identified as not being sufficiently wide for two vehicles to pass safely that there are suitable places along the public highway for vehicles to give way. No specific details have been provided as to the exact locations of these places,but this assumption is completely inaccurate. Apart from road junctions there are no such public areas for vehicles to pull over along the entire route through the villages to the development site. The only ‘available’ places are private laybys or driveways. The developer should therefore be required to detail the areas which they have identified so that these can be properly validated and that the developer provides full assurance that any use of private property has not been inappropriately assumed.
In 5.1 and Appendix D ‘No access to construction traffic‘ signage should be erected at the Seasalter Road junction with Cleve Hill and at the junction of Homestall Lane with the Brenley Corner roundabout. As the road through the villages is an important cycling route with a section of Seasalter Road being designated as a National Cycling Route additional signage should be positioned to alert construction traffic to the use of the village roads by cyclists in order to help safeguard them.
In 5.3 core working hours should be tightly controlled and limited to the hours specified in 5.3.1 without the extra hour provision. We would oppose any variation due to ‘exceptional circumstances’ as this potentially affords the developer too much latitude without any proper checks being implemented.
In 6.4 the HGV movement restrictions stated in 6.4.4 should apply to all vehicles associated with the development to safeguard Graveney Primary school.
In 6.5 HGV omissions are stated as being compliant with Euro Standard IV class. No emission standards are prescribed for other construction vehicles. We would argue that higher emission standards should apply to all construction vehicles in accordance with Euro 6 which was introduced in 2015.
We should also be given information as to the air quality impacts for Graveney Primary School ,the elderly ,and those with respiratory problems. Accordingly ,an air quality impact assessment should be required for monitoring purposes for all vehicles using the development site. Indeed ,having regard to the nature of this development, we would ask why is there no undertaking from the developers to use a meaningful proportion of electrically powered construction vehicles.
6.6.9 suggests the use of laybys on the Thanet Way for HGVs to wait prior to being called forward to approach the site. However, this is a somewhat optimistic proposal as these laybys are frequently closed by the Highway Authorities and even when they are open, many foreign and UK drivers use them for their rest periods. We would like to understand the plans for the marshalling of HGVs when the laybys are not open and for effective traffic management and communication with the drivers.
6.7.1 suggests that the call forward layby positions have been identified and agreed. However as already stated in 4.2.12 we do not believe there are any such places. We would request that the developer confirms the respective locations so these can be properly validated.
In 6.9.1 a maximum speed limit of 20 mph for all construction traffic should apply to the entire route along Head Hill Road and Seasalter Road as the majority of this route has no public footpath and additionally reasonable adjustments are needed for children as well as elderly residents and those with disabilities.
6.10 We consider the Incident Management Plan to be inadequate. It does not provide any detail as to how incidents which may occur on the site (such as battery fires or other accidents) would be handled. We would also maintain that the installation is a potential target for theft or even terrorism given its strategic significance ,size and accessibility. There is no detail as to how incidents or traffic would be managed with Kent Police ,the Ambulance Service and Kent Fire & Rescue.
We understand that Kent Fire & Rescue will be consulted and are required to approve the design of the battery storage area. However,we believe it is essential for Kent Police to be consulted on security and evacuation arrangements for the villages in the event of a major incident occurring.
In 7.2 there has been no consultations to date with local groups despite the Plan stating categorically that a Traffic Management Group would be established prior to any construction work commencing. This is of concern to us bearing in mind how advanced the project is and our observation that previous calls from local groups for a meeting with the developers have been ignored.
7.2.3 suggests that Traffic Management Group meetings would be scheduled twice a year. This is wholly inadequate for such a large scheme, particularly given the estimated volume of construction traffic. We believe meetings should initially be held at least on a fortnightly basis so that the impact of the scheme can be closely monitored and appropriate adjustments made quickly and effectively. We note that the London Array project commenced initially with weekly meetings and these were very effective and enabled emerging issues to be dealt with rapidly.
7.4.2 and 7.6.1 There have been no consultations to date with local groups despite the Plan stating that a complaints management procedure needs to be in place prior to the start of construction. Local groups also need to be consulted on the penalties and enforcement procedures relating to infringements by construction traffic.This is crucially important and must be agreed at the earliest opportunity.
Thanet Way junction with Whitstable Road
The accident rate at this junction is particularly high, given the short slip road and the configuration of the bend. We believe that for safety reasons this should be urgently redesigned to ensure the safety of road users both entering and exiting Whitstable Road. There is every likelihood that HGV drivers who are unfamiliar with this junction coming into conflict with oncoming traffic and the sheer volume of HGV construction traffic will increase the risks significantly. We would ask that the relevant Highway Authority be asked to comment on this specifically.
We would ask that a detailed noise impact assessment be undertaken to cover all planned construction vehicle traffic using the local road network for monitoring purposes.
We have experience of structural damage being caused to properties along the construction traffic route when the London Array development was underway. To safeguard these properties and the interests of their owners there needs to be a comprehensive condition survey of all properties in close proximity to the route before construction commences so that this can be properly monitored and appropriate remedial action taken by the developers at their expense. These properties need to be identified as a matter of priority and their owners contacted.
We feel very strongly that there should be temporary provision put in place during the construction phases for pedestrians and cyclists to be able to pass freely and safely through the villages. This could be achieved by creating dedicated footpaths and cycle routes ,some of which could then become permanent and be seen as a lasting legacy for the community. One initiative which has already been put forward is the Faversham Community Corridor and Solar Cycleway. The Parish Council and other local groups are ready and willing to engage with the developers to establish the appropriate mitigation schemes.