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(Prepared by Save Thanet's Water -Stop China Gateway Group - July 2008)

Dear Councillor,

We appreciate that our Councillors are very busy people working on Thanet's behalf and that sometimes it is very difficult to find the time to address all the issues brought to your attention.
We believe that the application to construct a `China Gateway' (F/TH/08/0400) at Manston is the most important planning issue to come before TDC for many years and are concerned that the democratic process is being rushed and even impeded in order to push this application along too quickly. Our members attended a Planning Committee Site Meeting where views from interested parties were not allowed( under TDC rules adopted as recently as April 2008) and where, in our opinion, important information was not given clearly or fully to Councillors who attended and that many aspects that are highly relevant were not considered. It did not help that half of The Planning Members did not attend.

We hope you will read this briefing document carefully and consider the points made. Our Group consists of ordinary Thanet people from all political groupings and we are a non-political group. We rely, as an electorate on our Councillors to make wise and balanced decisions on our behalf and in this instance, with this application, for our children and grand-children.

We have already invited our MPs to do a `tour' of the site and its surroundings as it is the only way to understand the serious implications involved in this application by developers Commercial Group Properties (CGP) and one `tour' has already been carried out. We cordially invite you, if you would like a detailed examination of the implications of this scheme `on the ground', to contact me, Amy Murray, on 01843- 825041 or by e-mail at . It will only take 1 hour to walk the important locations and visit areas outside the site to `look-in' on the problems and difficulties that need to be addressed. Please contact me.

Yours sincerely,
Amy Murray

Sparrow Castle Pumping Station, Manston Road.

Manston Business Park, prior to 1995, was Kent International Business Park and was a residue of wartime expansion around `the Loop'. It was considered too small to be viably developed and in 1995 an application (OL/TH/95/0838) was made to expand the site from its 110 acres by a further 65 acres from Alland Grange Farm, which consisted of Grade 2 & 3a agricultural land. The expanded site was incorporated into The Thanet Plan. There were two main concerns expressed by Government agencies who had to be consulted; these were MAFF (now DEFRA) and National Rivers Authority, NRA (now incorporated in EA). The NRA were particularly concerned with the underground water aquifer and its protection and MAFF was concerned that development would lead to further expansion and further loss of high quality land.
These concerns were so serious that they were taken on by TDC in its conditions for the development of this site. They were:


Only roof water to be taken to soakaways
The most hazardous uses of the site to be sited furthest from Source Protection Zone 1 of the aquifer i.e, closest to the Airport, on the south of the site.
Mains foul sewerage
Construction of lagoons (balancing ponds)
No discharge of foul or contaminated water directly or via soakaway
Hydro-carbon interceptors for all hard-standing rainfall outflows and 3 interceptors for HGV areas.


Grade 1, 2 &3a agricultural land is the `best and most versatile land' and `is a national resource for the future and considerable weight should be given to its protection because of its special importance'.
MAFF agreed to the 65 acre expansion and dropped its original objection because of `particular regard to the advice and assurances' given by TDC `that the land we now have will be sufficient to provide for economic regeneration of the area'.
The open nature of the site

So serious were these points that TDC incorporated the strict water conditions into its planning consent; incorporated 30m deep planting belts (to screen the site) to the North, West and East boundaries of the business park extension and even signed a Deed of Planning Obligation  with KIBP Ltd and H, R & Struan Robertson of Alland Grange that the additional 65 acres would not be occupied `until the requisition of a new sewer for the discharge of foul water between the land and Minster Waterwaste Treatment Works'.

The requirements for these conditions to protect the aquifer and screen the site were maintained by Cummins Ltd in their application of 1996 (F/TH/96/0810) and more recently in 2005 (F/TH/05/1410). The results are excellent and there are native fish and moorhens in the balancing ponds on the site and a successfully developing woodland belt screening Cummins to the west. So far development has been carried out to the highest standards as required by TDC in its original conditions for the site and has been a credit to all concerned.


It is a `creeping' application onto prime agricultural land that MAFF was concerned about in 1995 and TDC said would not happen. Whilst presenting Phase 1 on land earmarked for development almost all the plans are clearly of a 3 Phase Scheme.
The landscaping plans on the most sensitive boundary do not meet the previous high standards demanded of 30m wide planting belts.
CGP continues to present plans for foul sewage treatment that fail to meet the EA requirement of foul mains sewerage.
CGP fails to address protection of the aquifer as required by TDC and NRA in 1995 in respect of water flow off hard-standing areas by not presenting a plan incorporating interceptors and balancing ponds. (On May 28th 2008, during a 30 minute storm over Thanet, 10 million litres falling on this site would have overwhelmed CGP's inadequate water plans and would have flowed downhill into SPZ 1)

The map above shows the water collection and protection zones for Thanet's main aquifer. Source Protection Zone (SPZ) 3 is in blue; SPZ 2 is green and SPZ 1 is in red. SPZ 1is the most sensitive as any contamination only takes 50 days to enter the water supply.

CGP insists on siting its most hazardous activity, redistribution warehouses (X types) on the NW corner closest to the SPZ of the Sparrow Castle Pumping Station contrary to NRA's advice in 1995. These warehouses are the hub of the import/sort/redistribute operation involving HGVs parking up, unloading and re-loading etc that will occur 24hrs a day, 7 days a week all year round.
The huge `X' sheds stand in the final Source Protection Zone of the water aquifer and in addition are the closest, noisiest, most disruptive operation on site and are on the CLOSEST part of the proposed development to the community of Acol!
How serious the water issue is given by consultants in CGP's own submission to TDC in its Planning application:
    "There is potential for significant pollution of the aquifer to occur".
    "Should chemicals leach into the groundwater underlying the site the
      impact would be LONGTERM and in some cases UN-RECOVERABLE"
The proposal and its intensity of buildings on site is an attempt to cram as much as possible into a small space without mains sewerage; without hardstanding water catchment in balancing ponds and with inadequate space allocated on the most visually sensitive boundaries for 30m wide planting belts.
It does not take into account spare KCC land on the site and Theatrical Pyrotechnics located on the site with a lease until 2013.
The `creation' of jobs in Phase 1 is a very `grey' area. If the hub of the initial application is `redistribution', this in modern operations, requires few but highly skilled operatives. The `myth' that thousands of jobs are possible is just that at this stage. Councillors are asked to decide on THIS APPLICATION, not on what might be, could be, might never be.

This diagram shows CGP proposals for Phase 1 (blue) with existing buildings and sites (black) with open space at the S end of the site (top) owned by KCC.  The Chinamex `Gateway' Building is actually proposed on KCC Land that has not been sold. The main point of note is the sheer intensity in the CGP plans and lack of space for `lagoons and adequate 30m wide planting belts on the most visible aspects of the site on the N, W & E boundaries.

Councillors are being asked by CGP to approve an application in 2008 that falls far below the standards demanded by this Council 13 years ago and more recently in 1996 and 2006 when Cummins were developing. It has been described by some planners as inadequate; others would describe it as a squeeze `em  in, stack'em high, cheap and tawdry plan that fails to take into account the very sensitive nature of this site.

As the diagram above, clearly shows, there has been high quality development on this site since 1998 with the construction of the first Cummins Building with mains foul sewerage, interceptors and `lagoons' for surface water run-off and an excellent 30m wide screening planting belt. Such is this quality that a wetland habitat has been created in the middle of Thanet's chalk plateau and is extraordinary. The claim by CGP's consultants that `balancing ponds'/ lagoons for surface water run off  are not acceptable to the site because of the proximity of the air-port and potential for bird strike, is not backed up with advice from CAA or Infratil.  We already have `ponds' on the site and moorhens do not cause a problem!  The major bird problem to Cummins is sea-gulls nesting on roofs! Not having balancing ponds is however, LESS COSTLY and releases more `shed' space.

CGP was formed only 2 years ago, shortly after KCC purchased land at Manston Business Park from administrators of Wiggins/Planestation.  It has yet to develop a major site. It does not appear to have the experience, structure or resources that ING, working with Schipol Airport on a major `Gateway' project, has. It has the website; the glossy presentations and computer graphics but no track record yet of successful development.
Its `key' director is Mr Seymour-Prosser.  CGP say this about him:
          “Mr Seymour-Prosser's expertise is in gaining planning consents to turn them       
            quickly into a return for share holders.”

Company Eye Website reports that in addition to the land earmarked for development on The Manston Site, CGP purchased a further 73 acres of agricultural land in March 2007 (presumably for Phases 2 and 3). In addition, “it is intended to endeavour to secure options to acquire additional (agricultural) land adjacent to the business park that can only be accessed via land held by the company”.
CGP has borrowed heavily to finance the acquisition of sites and land from the Israel Discount Bank (IDB) and figures shown indicate a sum of £23,525,564 is the size of its loan/debt. As is normal, IDB has reserved the right to demand repayment of all loans at any time.
Elevations of the huge X-Type warehouses which are at the heart of the redistribution centre and placed in the most vulnerable spot on the site and closest to the people of Acol with constant 24hr operating all the year round. The buildings will be THE ONLY building other than The pumping Station in SPZ1!

CGP's shares began at 350p, fell to 200p by Jan 2008 and are currently at a low of 75p having lost 40p in value this month alone. It posted `maiden'/first results news of a £1.53 million loss on 30th Nov 2007.
Clearly a China Gateway project (looking at similar projects around the world) is a huge development that normally includes `cultural' exhibitions, leisure facilities and retail outlets. It is interesting that CGP states it is looking at further land adjacent to its present holdings.

The decisions facing our Councillors are difficult ones.
This application is clearly just the first of a bigger project. Should this Application be referred back so that the whole project be examined as a whole rather than as a `creeping' step by step process?
The density of development is excessive on this application.
The high standards insisted on in 1995 must be insisted on 13 years later when protection of water resources and agricultural land is at an even greater premium in a world, including this country, facing water and food shortages.
What is the price future Thanet resident's will pay for decisions taken in 2008?

We urge our Councillors to;
Make it quite clear that only appropriate development of a high standard (already achieved on Manston Business Park) is acceptable and that Phases 2 and 3 will  not have their support and nor will further expansion. (Policy CC9)
Insist on mains sewerage for foul waste. (Policy EP13)
Insist that all hard-standing areas be drained to interceptors and then balancing ponds/lagoons. (Policy EP13)
Insist that the X-Type warehouses and the highly disruptive and noisy redistribution operation be sited elsewhere further S on the site away from SPZ 1 and Acol residents. (Policy EP13)
Insist on the same standard of 30m planted screening as in 1995. ( Policy CC2)
Refer this application to Full Council so that all Councillors can be consulted in the democratic process concerning this major development.

This picture is a sobering vision of how China Gateway might look in a few years time when CGP, Chinamex and TDC have moved on elsewhere! It is a picture of what happens to Industrial estates in decline and was taken earlier this month at Sandwhich Industrial Estate. Rusting drums of chemicals together with waste of all descriptions litter this once 1960's icon of job creation and employment. Will this be worth polluting our water supply and losing highly productive farmland for?