Guidance for Commenting on the ES Addendum
The council are consulting on a final document for Princes Parade – an addendum to the Environment Statement:
The deadline for commenting is 22 June. This is a firm deadline – we are expecting the council to formally grant planning consent shortly after this date.
You can submit your comment on the council’s public access planning website https://searchplanapps.folkestone-hythe.gov.uk/online-appl…/ or by email email@example.com quoting ref Y17/1042/SH.
According to the site notice the council are trying to restrict comments to those covered by the addendum, giving the incorrect impression that everything else has already been determined by the planning committee and nothing else will be taken into account. We are challenging this because not everything that should have been considered had been revealed.
In the meantime this means that you can comment on the latest surface water drainage scheme and the addendum to the environment statement which covers the flood and ecology implications of the new scheme. If you feel that the revised scheme has any other implications please submit a comment explaining why.
The original drainage scheme proposed in the planning application drained water through outfalls into the sea. Not long before last summer’s planning committee they came up with an “indicative” scheme that included drainage into the canal as being “preferred”. It was later revealed this preference was because the Earl of Radnor owned the land below the high water line. The Environment Agency had always rejected the idea of drainage into the canal and prior to the meeting they formally objected. Nonetheless the planning committee resolved to grant planning permission in principle, subject to the EA withdrawing their objection. Later the EA did withdraw their objection but as you will see from this letter http://saveprincesparade.org/…/2019/01/Ea-Letter-17.1.19.pdf they were very reluctant to do so and described the scheme as “just-about viable” and that discharge into the canal should be seen as an emergency fall back option only.
Today the majority of surface water drains downwards through the permeable landfill which acts like a sponge – but it will no longer do so after development since they have to capture all water (including that from the road) and discharge it somewhere. The drainage problem is caused therefore by the development itself. Instead of the road water draining directly to the beach under the promenade as now, the relocated road will exacerbate the amount drained into the pond before controlled discharge into the canal.
The drainage scheme requires an array of attention ponds/tanks and mechanical controls to regulate the flow of water into the canal. Reliability and maintenance will be issues. Blockages, chemicals for cleaning, pollutant-capture – all are glossed over. The scheme does not decrease the overall amount of water that drains into the canal , as implied, it simply regulates the flow rate by means of a high risk mechanical system to protect a development that need not be placed on Princes Parade.
Addendum page 195 shows just how close the road will be placed to the canal, several metres above the path and what is left of the embankment. Both will sit permanently in its shadow for the whole of the east of Seaview bridge. Neither humans nor wildlife will be impressed by that!
Do you recall the only reasonably large area of open green space, with play area, that was promised at the western end? Well about 1¼ acres of that will now be replaced by an open attenuation pool (bog) with some form of undescribed pollutant trap. (Addendum p134)
Suggested Comments – please use your own words
• Point out the EA’s reluctance to accept the new scheme to drain the water into the canal quoting some of the phrases from their letter
• Emphasise the flood risk in the case of successive days of heavy rain particularly in the context of rising sea levels due to climate change. The Royal Military Canal is an important part of the flood defences for Romney Marsh so it makes no sense to be adding extra water to it.
• Point out that there is an alternative site for the leisure centre at Nickoll’s Quarry so there is no need to create this flood risk
• The new scheme is a complex arrangement that will require a high level of maintenance involving under-surface storage tanks and attenuation areas, numerous-flow rate and diversion controls, and pollutant capture facilities that have not been described in sufficient detail. If not properly maintained there is a serious risk of blockage and subsequent flooding.
• The scheme involves an attenuation pond that takes up a significant area of the western open space. Although this was the case with the scheme in under consideration when the planning application went to the planning committee this issue was not discussed.
• The new ecology report makes clear that at the leisure centre of the development the buffer between the canal and the diverted road will be very narrow – very much narrower than the 25m originally required by the EA. The report claims that quality of the buffer is more important than its size but it unlikely to be of high quality being so close to the road.
• The ecology report makes clear that there will be no measureable biodiversity gain. In practice it is hard to see how there can be anything other than a loss of biodiversity.
• The ecological report notes the presence of Cetti’s Warblers on the canal. These are a schedule 1 species and could be disturbed by the drainage works. As could the toad population.