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EA letter to KIA 18.12.08
© Environment Agency
Mr. Matt Clarke - Chief Executive Officer Our ref: KT120081107364101-L01
Kent International Airport Your ref: OCT 2008 DRAFT
PG Box 500
Manston Date: 18 December2008
Dear Mr. Clarke
KENT INTERNATIONAL AIRPORT DRAFT MASTER PLAN OCTOBER 2008
We would like to thank you for consulting us on your draft master plan. We welcome the opportunity to provide some advice at this stage and outline our comments below:
Groundwater and Contaminated Land
We are pleased that the master plan makes reference to the vulnerability of the groundwater in the underlying aquifer. The abstraction point for the Lord of the Manor public water supply lies very close to the airport and is an important source of drinking water for the Thanet area. This makes the airport and the surrounding area extremely vulnerable to development in the long and short term.
One of the major risks to groundwater from this site will be the bulk fuel storage installation. The two proposed locations are noted from the master plan, however, they are both very close to the public water supply abstraction point. This installation should be located as far away from the abstraction as is practicable in order to minimise the risk to potable water. The location and detailed design details will need to be agreed with the Environment Agency to ensure the groundwater will be adequately protected.
Page 109 of the master plan states that a land quality survey has been undertaken. We look forward to receiving more detailed information regarding this.
Orchard House (Endeavour Park) London Road, Addington, West Mailing, ME19 5SH. customer services line: 08708 506 506
Planning Policy Statement 23: Planning and Pollution Control states that:
`In considering individual planning applications, the potential for contamination to be present must be considered in relation to the existing use and circumstances of the land, the proposed new use and the possibility of encountering contamination during development. The EPA should satisfy itself that the potential for contamination and any risks arising are properly assessed and that the development incorporates any necessary remediation and subsequent management measures to deal with unacceptable risks, including those covered by Part llA of the EPA 1990.'
Full details of this survey should be forward to the Environment Agency to ensure all risks to controlled waters (this includes groundwater) have been adequately assessed. We have serious concerns regarding the existing (used and unused) fuel storage installations. If there are any fuel storage tanks that are no longer in use, these should be decommissioned and the ground beneath and surrounding them should be thoroughly investigated to determine if any contamination of the ground and/or groundwater has occurred.
Any existing fuel storage that is to be continually used should be fully assessed to determine that there are no leaks and that adequate pollution prevention infrastructure is in place and in good condition.
With the expected increase in passenger numbers and new buildings that are planned there will be a large increase in the amount of sewage generated by the airport. A review of the current sewage infrastructure that serves the airport should be undertaken as it is our understanding that it is currently near capacity. Any discharges of sewage to ground would likely be refused due to the large pollution potential that such a discharge would pose. Therefore an appropriate connection to the public sewerage system would be required. Early consultation with Southern Water Services Eimited would be recommended.
Surface Water Drainage
In accordance with Planning Policy Statement 25 (PPS25), the Government's guidance on Development and Flood Risk, a Flood Risk Assessment/Drainage Strategy (FRA)should accompany any application for development which is more than I ha in area. Whilst this site is classified as lying within Flood Zone I (low risk), an assessment should be carried out with respect to the proposed drainage of the site to ensure that the site will not be subject to fluvial flooding and that the risk of flooding off-site is not increased. Whilst we acknowledge that the future surface water drainage has been considered in the master plan, we would like to take this opportunity to offer the following guidance with respect to the drainage of the site.
The risk from flooding should not be increased elsewhere, and as such, runoff rates should be attenuated to that of the Greenfield runoff rate. In this area, this is typically 7 litres per second per hectare, but the Eocal Authority should be consulted on this figure. The opportunity should be taken to utilise Sustainable Drainage Systems (SuDS) in order to achieve this and to minimise the impacts on the quantity and quality of the runoff whilst maximising amenity and biodiversity opportunities.
We recommend that the 100-year 30% rainfall event is taken into account when designing the drainage system (unless the applicant is able to demonstrate that another return period is a more critical event). This reflects the guidance of Table B2 `Recommended national precautionary sensitivity ranges for peak rainfall intensities'
We will be in a position to provide more feedback on receipt of a Flood Risk Assessment/Drainage Strategy. Any such document should be submitted with full supporting calculations and drawings.
Sustainable Drainage Systems
The publication of Planning Policy Statement No. 1 :Delivering Sustainable Development (PPS1) in February 2005, gives weight to the installation of both Sustainable Drainage Systems and grey water recycling systems for new developments. In particular, paragraph 22 of PPS1 states `local authorities should promote the sustainable use of water resources and the use of sustainable drainage systems in the management of runoff'
The master plan states that SuDs will be used for discharging surface water drainage. Due to the vulnerability of the groundwater in the underlying aquifer, it is important that all areas that may contain potentially polluting run off (for example refuelling areas), do not discharge to ground. The risk to the groundwater should be taken into account when designing surface water drainage systems.
We encourage the use of rainwater harvesting facilities where possible; although the benefits of such systems can be small regarding reduced stormwater storage and discharge from the developments, there is the additional benefit of reduced consumption of domestic potable water.
We have no comments to make regarding biodiversity at this point, however we would like to highlight that all development must comply with PPS9 and aim for a positive! neutral impact on biodiversity.
Water Management, Water Quality and Waste Management
We are pleased with the comments relating to water management, waste management, and water quality and at this time would only urge the airport managers to ensure these good intentions are carried through to the design stage, so as not to miss opportunities for innovative design and environmental management.
Mr N jail Connolly
Planning Liaison Officer
cc Thanet District Council