The contamination study included in the intial Princes Parade report is almost entirely based on a study carried out by Ground Solutions Group Ltd in 2002 which URS admits is out of date. Shepway did not pass on the whole GSG report to URS – the appendices and figures were missing.
Eventually Shepway commissioned a new contamination report which you can read here.
This study comprised of a phase 1 (non intrusive investigation) and a phase 2a ( preliminary exploratory investigation). The report acknowledges that intrusive locations were limited because of ecological considerations and dense vegetation. Hazardous gas testing was carried out in just 4 locations.
Table 9 summarises the possible pollutant linkage.
It identifies a low risk to the health of current users from heavy metal and hydrocarbon contaminants but one of the claimed mitigating factors is that the site is fenced. It isn’t and won’t be if and when it is developed.
It identifies a low to moderate risk from the same contaminants for future residents and construction workers. The mitigating factor here is that the proposed scenarios suggest predominantly hard landscaping and limited landscaping. Given that one of the supposed aims was to enhance the open space this was never going to be true. There are several references elsewhere in the report to the fact that the houses won’t have private gardens. Really?
As regards protection of construction workers para 7.8.1 recommends that dust levels are kept within statutory limits but the site is often very windy and this does not seem to have been taken into consideration. And what about local residents and pupils at the primary school who could be affected by polluted dust during the development works?
A moderate risk of groundwater contamination from vertical migration is identified from all forms of contamination. The report proposes further monitoring. Has this been done?
A moderate risk was identified of hydrocarbons being able to permeate polymeric pipes which could have serious implication for drinking water supplies.
A low to moderate risk of elevated carbon dioxide has been identified and further monitoring recommended. Has this been done?
In the archives in Folkestone library there is a very interesting account of the landfill site written by a local resident in 1968. She said that the dust carts had a regular dumping schedule but that local traders were also allowed to dump rubbish there too. Given that the site was open, does anyone really know what was dumped there?
Here is a reply from David Monk about how the contamination risk will be dealt with:
“Thank you for your query. I can confirm that that the issue of contamination will be addressed in detail in the Environmental Statement (ES) accompanying the, soon to be submitted, planning application within a chapter covering geo-environment , land contamination and ground conditions. This document will include a number of suggested remediation measures..
The information within the ES will be reviewed by the Environment Agency, as part of the statutory consultation process, and it is anticipated that they will suggest that a number of planning conditions be included as part of any planning permission. It is anticipated that such conditions will require further investigative work prior to the commencement of the development in order that the necessary remediation measures may be agreed and finalised. Such conditions are likely to require further survey work to be undertaken to establish, in more detail, the extent, scale and nature of the contamination as well as providing a further assessment of the risks to the following :-
Property (existing or proposed) including buildings, crops, livestock, pets,
woodland and service lines and pipes,
Ground waters and surface waters,
Archaeological sites and ancient monuments.
Once this assessment has been undertaken it will be is necessary to a submit, to the Local Planning Authority for their approval, a detailed remediation scheme to bring the site to a condition suitable for the intended use by removing unacceptable risks to human health, buildings and other property and the natural and historical environment. Such a scheme will need to include details of all works to be undertaken, proposed remediation objectives and remediation criteria, a timetable of works, site management procedures and a verification plan.
Following the implementation of the remediation scheme, and prior to commencement of the main development, a verification report demonstrating completion of the works and the effectiveness of the remediation will need to be submitted to and approved in writing by the Local Planning Authority. The report will need to include the results of any sampling and monitoring carried out in accordance with the approved verification plan to demonstrate that the site remediation criteria have been met. It will also need to include details of longer-term monitoring of pollutant linkages and maintenance and arrangements for contingency action, as identified in the verification plan, and the mechanism for reporting of this to the Local Planning Authority.
I trust that information is of assistance and reassures you that there are sufficient checks and balances in place to ensure that the scheme will not pose a risk to the health and safety of local residents and visitors to the area.”
According to the initial consultants’ report the Environment Agency classified the site as Flood Risk 3.
This is an extract from the consultants’ environmental report :
The location of the site within Flood Zone 3 means there would be a presumption against development for more vulnerable types of development (e.g. housing, schools) in favour of developing sites within the Shepway administrative area at lower risk of flooding.
Where SDC can demonstrate through application of the ‘sequential test’ and ‘exception test'(detailed in the National Planning Policy Framework (NPPF) that there are no other alternative or more suitable sites for development within the borough, then it would be possible to develop the site. Part of the evidence that would be used to inform the exception test would be data on the hazard to the site.
Should development of the site proceed based on the current SFRA Flood Zone 1 hazard classification of the site, data on the hazard should also be used to ensure the most vulnerable types of development are guided to the areas of lowest hazard within the site. Hazard mapping should be used to assist the siting of development types across the site, this would categorise the flood hazards present on the site arising from a flood (i.e breach of local coastal defences) enabling Master Planners to site vulnerable development types (e.g. housing) in those areas of the site with the lowest hazards, whilst areas of relatively greater hazard could be used for other low risk land uses such as car parks, leisure facilities or public open space.
The latest (July 2015) flood risk assessment for Shepway still shows the site in flood zone 3:
and the flood map:
and the flood hazard map: