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More from the EA
Subject: F/TH/08/0400 Date: 30/07/2008 16:57:02 GMT Standard Time From: Michael Child
I am highly concerned that the high environmental standards set for OLTH/95/0838 in 1995 do not appear to being adhered to for the CGP development F/TH/08/0400, there appears to be an assumption being made by the developer that discharge consent will be granted for hard standing runoff, via interceptors into soakaways.
Back in 2005 the only runoff allowed to go directly into soakaways was from the roofs, all other runoff from the site either had to go into mains sewerage or via interceptors into balancing ponds.
There are two important advantages with balancing ponds, one being their ability to deal with heavy rainfall, the other being that the health of the wildlife in them indicates the purity of the water.
I am also concerned that the most hazardous hard standing loading areas and lorry parks are far to close to Sparrow Castle Pumping Station, the opposite of the stipulations for OLTH/95/0838.
I have now received confirmation from the EA that the aquifer is indeed an important resource both for the water supply and agricultural boreholes.
Can you please clarify which parts of the site you will allow to discharge into soakaways?
Obviously without balancing ponds anything less than all the hard standing draining into mains sewage would be much more dangerous to the aquifer than the arrangements for the existing industrial development there.
Can you confirm that TDC signed a DEED in 1996 stating "not to occupy the 65 acres (Robertson's farmland) until requisition of a new sewer for the discharge of foul water between the land and Minster Wastewater Treatment Works”, and tell me if this will be conformed to?
I also noticed TDC Planning recommended to its Planning Committee as follows: "A CRUCIAL issue is the impact of the scheme upon the local and wider area in visual terms and therefore the quality of screening and landscaping of the site assumes considerable importance. I consider that the previously required 30m deep planting belt to the N and W boundaries of the original business park should be extended to the N, W and E boundaries of the business park extension." (i.e the exterior boundaries of the new 65 acres of agricultural land sold by the Robertsons.)
Will you be insisting on this level of screening?
In view of the EAs comments to me. “There is thought to be some control over the quality of water used for irrigation and crop washing, although this is not regulated by the Environment Agency.” It would appear that contaminated water could easily pass undetected into the food chain, not a happy thought.
I note from the letter 28/7/08 sent to you from Aaron Smith of PRC they still seem to expect all of the waste from the development to be processed on site and to go into soakaways, I feel it is very important that this issue is properly and satisfactorily resolved before it goes to planning committee.
Best regards Michael
Dear Mr. Child,
TOWN AND COUNTRY PLANNING ACT 1990
CONTAMINATION AND DRAINAGE ENQUIRY - REDEVELOPMENT OF LAND FOR B1C, B2 AND B8 (INDUSTRIAL AND WAREHOUSE USES) MIXED COMMERCIAL USE WITH ANCILLARY PARKING AND LANDSCAPING
Please find enclosed a copy of the letter from PRC to TDC in response to the questions/comments raised by Mr. Kirkaldie and referred to in your email. We trust this provides assurance that enquiries directed through the appropriate channels will be dealt with by those in the best position to do so.
With respect to the issues raised in your email, the Environment Agency is able to provide the following comments on those aspects within our remit.
Our Groundwater and Contaminated Land team are very aware of the risks to the groundwater environment from industrial sites and have had much experience in dealing with the drainage designs for similar sites. We are very concerned about the potential impact this proposed development may have on the groundwater in the underlying aquifer, and have therefore spent an extensive amount of time reviewing the proposals. We have also had many discussions with the developer's consultants to make them aware of our concerns, and to ensure our requirements are incorporated into the design.
Some private boreholes and wells are included on the Environment Agency's Groundwater Quality Monitoring Network and are sampled on a regular basis. If the quality of groundwater at a private abstraction has been impacted by contamination, the Environment Agency will be informed and the source of pollution will be investigated.
There is thought to be some control over the quality of water used for irrigation and crop washing, although this is not regulated by the Environment Agency.
As previously stated, we accept the findings of the flood risk assessment which concludes that the risk of flooding to and from the site is low.
Subject: China Gateway Date: 05/07/2008 12:34:21 GMT Standard Time From: Michael Child
Doug sorry this is a bit of a complex one with several difficult questions, it looks to me as though they have done their soakaway tests after running Micro Drainage, which can’t be right, so I am very confused and would appreciate it if you can put me right.
I have just received Malcolm’s correspondence with the EA, which combined with them telling me that they haven’t the resources to read the China Gateway environmental report properly, makes for a very worrying situation.
I can’t see how you can make a valid judgment on the pollution issue to put forward to the planning committee without answers to both my question about flood risk and answers to most of Malcolm’s questions.
Being familiar with what happens in reality on industrial estates and hence the very real chance of a serious accident, should the application be passed I will push hard for the closing of the aquifer.
This leads to a further question what is the situation with private wells and boreholes that presumably wouldn’t have much in the way of testing?
I ask this as if there is an accidental poison spillage into the aquifer and the poison gets to a private borehole used for agricultural purposes before it reaches the public water supply borehole, poison could enter the food chain without anyone being aware of it.
I have ploughed through most of the ENVIRONMENTAL STATEMENT CHAPTER 7 (ADDENDUM) – ECOLOGY added 01 Jul 2008 there also seem to be several new additions dated 20 Jun 2008 but actually added 01 Jul 2008 is this an error or am I mistaken?
I can’t see the difference between them and previously added documents except that they lack the council’s rubber stamp.
I am further concerned that the 13.6.08 revisions Utilities Report Appendices Utilities Appendix 7 Soakaway tests show the results for the tests but I cant find these tests interpreted anywhere.
So do you know what they mean in terms of flood risk?
Best regards Michael
----- Original Message -----
From: malcolm kirkaldie
Sent: Thursday, June 26, 2008 10:21 AM
Subject: CGP and water pollution
I am very concerned regarding TDC planning application F/TH/08/0400. There are a number of questions that I would like to raise.
1 No mention of Kent Highways, who do not have to obtain discharge consent for the drainage in this area and who are one of the prime polluters
2 No mention is made that Kent Highway has tapped into the drainage system in this area, that exits into a Ramsar site (Pegwell Bay)
3 No mention is made in the CGP reports that Thanet's underground water is poor.
4 No mention is made in the CGP report of the Ground Water Quality pollution besides the Nitrates why?
5 No mention is made of the Bulk Fuel Installation posing a significant risk which is very near the site .
6 No Mention is made of fuel pipes that may run under this land?
7 No mention is made of emergency shut off valves in the road drainage system entering and exiting both CGP and KIA Manston why?
8 No mention is made of the KIA Master plan why.
9 No mention of the ELD is made as well as the WDF.
10 How essential is the underground aquifers to maintain Thanet's water supplies now and in the future?
I would also ask what the exact status of the underground water aquifer is, other than poor i.e. is it the worst in England, the UK or Europe?
The reports submit to the EA are inadequate to say the least especially on safeguarding the aquifers, prevention of flooding and adhering to the polluter pays principle.
----- Original Message -----
From: Customer Contact, Kes
To: Malcolm Kirkaldie
Sent: Thursday, July 03, 2008 5:45 PM
Subject: id 627- China Gateway
Dear Mr Kirkaldie
Freedom of Information Request: China Gateway
I refer to your information request received in this office on 3rd July
Thank you for your enquiry, unfortunately question 1-9 do not fall within the jurisdiction of the Environment Agency you would need to address your concerns to Thanet District Council.
However we will respond to question 10, 11 please note this is chargeable.
The cost of providing your information is £100.00.
Due to various internal teams having to be consulted for your information, I am writing to inform you that the response for your request may take up to 10 working days from the receipt of your fee. If we cannot do this, we will let you know when you can expect to hear from us. We will aim to send you a full response within 20 working days as set out in the Freedom of Information Act. For requests under the Data Protection Act we will send a full response within 40 working days.
Please send a cheque payable to Environment Agency for the above amount to the address shown quoting the reference number CSC/2007/1402a.let. If you are paying by credit card, please phone Karen Rigg on 01732 22 3224. Once we have received payment and our searches are complete, I shall forward the results to you.
If you do not wish to receive the information requested or you wish to modify your request please contact this office as soon as possible.
If you require any further assistance please do not hesitate to contact me at the address shown.
External Relations Assistant
Direct dial:01732 223224
Orchard House, Endeavour Park
Addington, West Malling
Kent, ME19 5SH
Tel No 01732 223224
Rubbish, adhere to the EIR regulations. This information should be readily available as you have been consulted on this scheme, are you now saying that the EA have not taken this information that I have requested, into account, are you saying that questions 1-9 have also not been taken into account by the EA and TDC? My questions are not vexatious or vociferous so review please so I can escalate this to the ICO.
Mr M S Kirkaldie