M20 Junction 10A

Representations received regarding M20 Junction 10A

The list below includes all those who registered to put their case on M20 Junction 10A and their relevant representations.

SourceRepresentation - click on an item to see more details
Members of the Public/Businesses
Elizabeth Kerr
"My concerns are regarding the configuration of traffic on the triangle of roads and roundabouts formed by the addition of 10a. I fear 1 minor accident will bring the whole thing to a stop and cause backlog on and off the motorway. I am concerned about the location, as it falls on a bend of the London bound carriageway, which has already seen several accidents at the point of the the new off ramp. I am concerned that the pollution from standing traffic will increase, in an area close to the local hospice and hospital."
Members of the Public/Businesses
Paul Bartlett
"Comments on J10A Environmental Scoping Report 1. The retention of the existing Highfield Lane bridge requires the southern crossing arm of the new junction to be moved east of its originally intended position and therefore closer to housing at the end of Kingsford Street (p12 refers). If the southern arm of the new junction is located where Highfield Lane currently crosses the M20, J10A will have less impact on the housing in Kingsford Street and may result in Lagonda Lodge being retained rather than falling within the scheme footprint. The loss of residential accommodation is a large adverse impact of the scheme (p113 refers) so the loss of Lagonda Lodge and Highfield, added to the loss of commercial property at Beauchamp Clerk Nurseries, Willesborough Garden Centre and Sweatman Mowers is to be avoided. It is noted that there are three garden related businesses operating on the footprint and the concentration of these three businesses in a single place is unique and advantageous to the community and would be impossible to replicate elsewhere. 2. There are a large number of properties affected by the loss of land from their properties. They are Ransley House (note this will doubtless have commercial effect on the kennels business located there as the land lost is integral to the business operations), Court Lodge Farm, The Hanchins and numbers 46, 86, 96 and 98 in Church Road. These are listed on p111. Ransley House and Court Lodge Farm are listed properties and the permanent land take from listed properties will be of regional significance (page 39 defines). 3. The list of roads affected by the Scheme are listed on p96 but this list should be expanded to take in the full effect of addition traffic flows into Ashford not just via Hythe Road (which is listed) but pas the Designer Outlet Village (which is already a congestion spot). The point is that we know the Scheme will result in building a further 12,989 houses and 19,756 jobs (these are listed on page 136) and this will have very significant traffic movements in and around Ashford. The Environmental Impact Report should carefully consider whether Ashford can cope, and not just look at roads 250m from the new Scheme. 4. In the number of jobs created by the Scheme, 2,500 jobs at Sevington Phase II are included. This land is outside the land allocated for development and including these jobs would lead residents to conclude that the development is given de facto support and will happen. Sevington Phase II is said to be part of a list of “proposed developments within Ashford Borough [that] have been identified”. This statement is incorrect as ABC has not identified Phase II Sevington so the the Environmental Impact Report should not consider unallocated developments sites in Ashford as it leads stakeholders to conclude that the required procedures to allocate sites for development are not being followed. 5. Developments and strategic planning decisions that have been taken in surrounding districts should be taken into account. A good example here is Lydd Airport. If this expands it will result in more traffic at the scheme and this will result in noise, air pollution, vibration, and driver stress. The report says at page 111 that “other planned developments in the study area have not yet been assessed”. It is essential that all schemes are assessed as to their impact on traffic flows. 6. The Development Consent Order for the SELEP scheme is on hold (p137 refers). For this reason the planning applications which are dependent of the SELEP scheme (i.e. the AXA scheme and Kent Wool Growers) should also be put on hold as it is impossible to determine these two planning applications until the outcome of the SELEP scheme is known. For that reason I would urge the Highways Authority to object to these two applications. 7. The scheme would result in the loss of 12ha of permanent agricultural land which is classified as Grade 2 and Grade 3a (page 112). Both of these grades are good quality land and are therefore the most productive and flexible. NPPF says “Planning authorities should take into account the economic and other benefits of the best and most versatile agricultural land. Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality” (this rule came out in 2012). Alternative arrangements must therefore be investigated again to the Scheme, such as expanding existing J10. The options considered in December 2005 should be reassessed in the light of the new planning guidance issued in 2012 for agricultural land and it is very likely that in the light of these new planning rules that Option 1 (from the original 2005 option assessments listed in page 11) would now be the preferred option. 8. There are significant access issues between Highfield Lane and Kingsford Street and the scheme will result in additional traffic flows through the centre of Mersham if this is not addressed. It is necessary to ensure that traffic cannot travel directly from Highfield Lane to Kingsford Street as this will increase traffic through the sensitive village centre. Unless a way can be found to address this the Scheme must not proceed. 9. Part of the Scheme lies in Flood Zone 3a – High Probability. This means that there is a greater than 1 in 100 probability of river flooding (page 121 refers). Clearly a lot more work is required here before the Scheme can proceed, not only is there a risk to flooding in the area but there is the added complication of runoff water from the scheme being contaminated with petrol, diesel and the like so that when there is a flooding event it will cause extreme damage to property if the water is mixed with fuel. Whilst the water quality in the Aylesford Stream is classed as High Quality we do know that water quality in the Great Stour and East Stour is of Medium Quality (page 124 refers). There may therefore be an effect of run off from the Scheme where water that flows into the Aylesford Stream is contaminated with petrol and diesel during operation and construction. This may ultimately affect the Great Stour quality. It is quite likely that properties near or on the floodplain (e.g. Bridgefield and Finberry) will be at risk of greater flooding due to the changes to the extent of the floodplain downstream from the scheme. 10. The scheme is near to and will be built partly on the old Ashford Corporation Tip in Mersham. Drilling through the old landfill site may release a number of contaminants as record keeping in the 60’s and 70’s was not as diligent as they are today. The risk is that once breached the landfill site will cause harmful substances to leach into the groundwater and such sites are best left free from development. 11. There was a significant pollution incident near to the site of the Scheme in 2003 (page 68 refers) and greater detail of what this was needs to be sourced so that the effect of construction in areas affected by the pollution incident can be assessed. We do know that the Scheme land has been contaminated by Mercury (page 68, presumably these two facts are linked) so there is a question whether the construction of the scheme will release this and other pollutants into the Aylesford stream or into the atmosphere during construction. 12. The views from the Wye and Crundale Downs site including the Devi’s Kneading Trough must be assessed. There is a terrific vista from these areas into Sevington and Mersham and the view from these important sites must be protected from development. 13. The loss of the footbridge over the A2070 (page 112) and replacement with two signalised crossings at the southern end of the link road would result in significant longer journey times for pedestrians who use the bridge. It will also impact cyclists who use the bridge. The journey to cross the A2017 from one part of Sevington to the other will be much more difficult than is currently the case and the footbridge must be retained. 14. There is great confusion over what is planned for the link road – page 112 refers to two signalised crossings and page 12 refers to a roundabout. Before an Environmental Impact report can be written the designers need to be clear. The impact of each will be different, particularly on the noise on the Highfield Estate and Sevington Church. Now the residents suffer from the noise of lorries moving slowly to the J10 in a low gear as J10 is at the top of an incline. Will this get netter of worse with the inclusion of either a roundabout or traffic lights at the southern end of the link road? There is also the very important question of the gradient of the link road along with at least one set of traffic lights on the link road – will residents on Kingsford Street be faced with the same noise pollution as the Highfield residents currently suffer? 15. Sevington Church is a delightful, well used Church. It is Grade I. One very pleasant aspect of the Church is the pealing of the bells (often change ringing) and there is fear that this unique attribute of the Kent Countryside will be lost from Sevington for good. This is because the southern end of the link road will be within about 70 yards of the Church. The southern end of the link road will have either a roundabout or signalised crossing which will cause additional noise of stop starting vehicles (especially air breaks from HGVs) which will drown out the pealing. It will also cause the loss of amenity land between the Church and Aylesford Stream. There is a popular and well used tract past the Church towards the stream which is popular with dog walkers and for general amenity use. 16. The junction of Barrey Road and the A2070 is badly in need of upgrading to traffic lights or a roundabout. There have been a good number of accidents where slow moving traffic joins fast moving traffic. This must be included as part of the Scheme if the Scheme is to proceed. 17. The access to the William Harvey Hospital from Mersham and Sellindge will be greatly hampered by the new road layout as car journeys will have to cross two big roundabouts at new J10A and old J10. This will add over 250m to journey lengths and will add significant stress to those seeking to get to the hospital. For similar reasons it is important that the access to the A2070 from London is maintained at J10 so traffic can more quickly access the hospital. Without it journey distances will increase by over 500m. Paul Bartlett Weald East Borough Councillor   "
Members of the Public/Businesses
Sharon Swandale
"I live next to the proposed site. I am particularly concerned about safety, pollution both noise and fumes and trying to minimise damage to our listed property. "
Members of the Public/Businesses
Geoffrey Fletcher
"1. I am deeply concerned that the application does not include the closure of Kingsford Street from Highfield Lane, and that this is left to other parties at some future stage. This application necessitates the closure of Highfield Lane to the A20, so there will be a rat run through the village 2 This application does not adequately deal with the access from Barrey Road to the A2070, especially in the light of the new developments in that industrial estate."
Members of the Public/Businesses
Miss Julia Miller
"As a homeowner who is going to be directly affected by the proposed plans. The whole scheme will result in me living right next door to a busy motorway with a slip road right outside my front door. There will be a lot of disruption during the build with potential damage to the foundations and structure of my house. The scheme will ultimately reduce the value of my property. There will be increased light, noise and air pollution with the dust and dirt during the construction which will continue once the works are complete with the volume of traffic that is expected to use the motorway and slip road. I will be faced with looking out onto a solid sound barrier. The design of the footpath and barriers alongside the solid sound barrier will destroy the whole rural character of this section of Kingsford Street; this will not enhance the environment. This section of Kingsford Street should not be lit overhead as the environmental analysis shows this road is a recognised flight path for Bats to local roosts and should be maintained in its present form. Destroying the roadside, wooded copse and replacing it with a wooden wall will not improve the environment. Currently Kingsford Street is a country lane and this will either change whereby it will become a rat run for Ashford traffic avoiding the roundabout or it will be closed at the Kingsford Street/Highfield Lane junction and would mean that I would have to travel an extra 2 miles plus each way in order to get into Ashford. The road plan currently proposed will result in a significant increase in the volume of traffic using Kingsford Street. Kingsford Street is very narrow, has poor horizontal alignment, poor junction visibility and does not have a proper drainage system. Deep flooding regularly occurs at three locations along the road. "
Members of the Public/Businesses
Linda Arthur
"I live in   and in the immediate vicinity of the proposed J10a. I am also involved with the J10a Coomunity Consultation and attend the meetings held by Ashford Borough Council and HE. I am concerned about: - The continued link of Highfield Lane and   Street. Because the design of J10a includes the closure of the connection from Highfield Lane to the A20, the continued link of Highfield Lane and   street will mean this will become a rat run. I am concerned because inevitable delays on the A20 during construction will mean traffic using these lanes to avoid congestion. These are narrow, single track lanes with blind bends, and no pavements and a children's play area, used by pedestrians, children, joggers, cyclists and horses riders. There is a potential for a serious accident. HE are ignoring this problem and not addressing it - it will arise as a direct result of their plans to close the Highfield Lane access to the A20. There are plans submitted by Friends Life to Ashford Borough Council 14/00906 to permanently close   Street from Highfield Lane which will prevent the the problem, but the timeline for this is unknown. HE need to acknowledge they will be responsible for any futurecongestion on Highfield Lane and   Street and include the closure as part of their plans for J10a. - I am concerned that the rural hedge at the end of   Street will be lost. The footpath could be put behind the hedge which could be retained and help protect residents opposite, who otherwise will be facing enormous sound panels. - only low level lighting should be used to light the path and footbridge. - low noise level road surface as far as possible to protect Mersham and Willesborough. - adequate landscaping for slip road."
Members of the Public/Businesses
The Village Alliance
"- does the construction of J10a represent good use of in excess of £85m, when in essence it is only providing an addional two slip roads, because of it's proximity to J10, the two east bound slip roads will be lost. - Traffic modelling - how accurate are future HGV movements which will be generated by the proposed warehouse development at U19 Sevington? Will the increased HGV traffic use all the addional capacity provided by J10a? - No significant improvement is proposed for the Barrey Road junction. A signalised junction has been requested, to allow right hand exit and for safety. There is serious concerns over safety for vehicles wishing to turn right out of Barrey Road and having to filter right to access the new roundabout on the link road. - A petition has been presented to KCC Joint Transportation Commiittee signed by 234 residents to close Highfield Lane to Kingsford Street and this had been passed to HE. The J10a scheme proposes closing the Highfield Lane and Kingsford Street access to the A20. This leaves the continued link of these two lanes open to "rat running" through the centre of Mersham from the A2070 and the A20. This happens at the slightest congestion. This scene will also leave Mersham with a connecting road to the proposed warehouse scheme. at U19 Sevngton. The closure of these two lanes must be considered as part of the J10a scheme, before construction starts. Any inevitable delays on the A20 will result in traffic from A20 and A2070 using this rat run. Highfield Lane and Kingsford Street are narrow, single track lanes, with blind bends, no pavement and a children's play park, used by pedestrians, joggers, children, cyclists and horse riders. Rat running through the centre of Mersham village would be extremely hazardous and must be prevented prior to commencement of scheme. - There is concern that ambulances travelling from the east (Folkestone) will have to negotiate J10a and J10, thus increasing journey time and putting lives at risk. - There is concern over increased traffic, particularly HGVs, using the section of the A20 between J10 and 10a. The road is not wide, has many entrances and exits and a roundabout and may become a potential bottleneck. - There is grave concern over air quality, both at the William Harvey Hospital and Pilgrims Hospice. - The country lane nature of Kingsford Street next to the new slip road should be protected by retaining the existing country hedge and constructing a footpath behind the hedge. If lighting is necessary on the footpath it should be low level and discrete. Lighting on the foot bridge should be the same. - Low noise surfaces should be used, extending as far as possible to protect Willesborough and Sevington residents."
Members of the Public/Businesses
NATS LTD
"NATS anticipates no impact from this proposal and has no objections to the development. "
Members of the Public/Businesses
David Hannigan
"I am an interested party due to being a local resident of Smeeth which is very close to the suggested site. I am against this due to the following reasons: Traffic congestion It will not fix Operation Stack, it will only bring MORE lorries into our area, affecting the local residents and businesses. This has a knock-on effect for the whole of Kent and further afield. Environment The proposed lorry park to take 3500 – 4000 HGVs will devour 150 acres of countryside and farmland in the ancient village of Stanford, adjoining Areas of Outstanding Natural Beauty, along with all the existing flora and fauna we enjoy in the Garden Of England. Air quality The increased emissions and particulates produced by so many lorries concentrated into one area could kill vulnerable people living nearby. Particulate 2.5 which are produced by diesel engines are so small that the human lung cannot filter them and thus they go straight into the blood stream. These particulates are directly linked to cancers, heart disease and lung disease, which all medical bodies accept cause premature death to thousands of people each year in the UK. There is no safe limit to these particulates entering the human body. Sound pollution The rumbling of Highways England’s expected 540 HGVs per hour will be heard for miles around and refrigerated units run through the night too. Light pollution The proposed full lorry park capacity will be lit up like a small town at night. No more starry skies to admire. Rubbish even though most lorry drivers are careful, we already know what sort of disgusting litter is left by a few unscrupulous truckers, including bottles of urine and bags of worse. Our environment could be littered even more with the increase in lorry traffic and time spent parked. Crime We have been given no assurance about how the potential increase in crime will be handled, since we do not even have enough police officers in Kent now. Emergency services No one has been able to explain to those concerned about an emergency on the proposed lorry park, where there would be an increased risk of fire, for example. This would be an added burden to the emergency services, which are already overloaded. It appears no one has thought about emergency access if the sliproad is blocked (presumably through the village?!) and no thought to what emergency response times would be. Terrorism Some worry that a single large site holding multi-nationals could be a target for terrorism. Flooding Of the two sites proposed, one is on a flood plain. 150 acres of tarmac will cause an immense run-off of polluted water which will need treating before it can be returned to the environment. The proposed pumping station associated with this is not reassuring. Quality of life Residents are understandably worried about the quality of life which they have worked so hard for will be destroyed, without so much as the courtesy of being consulted Smarter Options: Operation Stack is largely the result of man-made causes such as French industrial action and migrant incursion. These causes of the problem should be addressed before spending so much money on trying to fix the symptoms. Upgrade A2 / M2 infrastructure It makes no sense to have a single motorway to both the Channel Tunnel and the Port of Dover. The A2 needs urgently upgrading to be M2 all the way to Dover. This will mran that the bulk of Dover freight can then use the M2, thus distributing the flow of traffic. It will also offer a better alternative route to port, should one motorway be closed for any reason, causing less disruption. The French have far more major routes to their ports, which is why they never suffer as we do when they have industrial action. Projections for increased freight over the next few years suggest that more investment should be made into improving infrastructure to relieve the overburdened M20. Smaller lorry parks £250 million is a huge amount to spend on a facility to be used infrequently. There are plenty of applications for smaller new or extended lorry parking facilities in Kent, also adjacent to motorways. Far more suitable for larger numbers of HGV’s on the M20, less than an hour from the tunnel and Dover, is a recently available brownfield site at Aylesford. If regular overnight parking is the issue, then smaller lorry parks spread across the motorway network in the South would be far more effective when both major routes are completed. Smaller facilities will cause less detrimental impact to individual communities. Use of smart Technology Haulage companies and cross Channel operators could adopt smarter ways of working together by using the smart technology available today. This would mean that hauliers, cross-channel operators, highways and lorry parks can work effectively together to ensure smooth traffic flow to ports and lorry parks, more efficient booking and loading. eg instead of lorries gathering on local roads whilst playing off the ferry and tunnel operators for the last minute best deal, tickets should be purchased by app or on line before clogging local routes. Rail Freight by rail is a far more sustainable method of transporting freight. The UK needs far more investment into this opportunity as a long term measure."
Members of the Public/Businesses
Janet Oakley-Hills
"My concerns are as follows: 1. That the capacity of the A2070 has been underestimated, that there is a failure to consider the additional growth and developments that will feed onto this road. 2. That there is a failure to address the issue of the M20 London bound access from A2070 at existing J10. 3. The addition of traffic lights in such close proximity on A2070 will cause even more tail-backs around J10. 4. That there is total failure to assess the needs of residents of Church Rd/Cheesemans Green lane trying to access A2070. 5. That there is total failure to assess the needs of residents and customers of Barry Rd and Retail Park trying to access the A2070. 6. That the levels of light, noise, and air pollution during and after construction need to be fully addressed to the satisfaction of existing residents."
Members of the Public/Businesses
Sue Appleby
"as a resident of Hythe, I believe the plans for these changes are relevant to me"
Members of the Public/Businesses
Barry Kerr
"Kingsford street must be shut as part of the sievington and j10a development to protect the residents and local users of Kingsford street and mersham"
Members of the Public/Businesses
Georgina Mayes
"I really disagree in keeping Kingsford street open at the high field road and Kingsford street junction as it will be so dangerous and cause disruption. Kingsford street is a country lane and not design for a lot of traffic, which will happen being used as a rat run if there are delays on the A20. This road is a village lane with families with young children and animals ie dogs and horses/ponies. Buses currently come down here and should go on the main road out of Mersham to the A20 as their are no bus stop on Kingsford street and there is no need for them to go down Kingsford street which make it hard in a car to pass the buses as the road is not designed for them. Not closing Kingsford street is a disaster waiting to happen. "
Members of the Public/Businesses
John Eastwood
"1-The closure of Kingsford at the bottom end means the bus service which currently runs Through cannot continue. 2- Residents will no longer have access to it. 3- Kingsford Street traffic will have to exit into The Street Mersham which is a busy very narrow road. 4- The road junction where the Street Mersham meets the A20 (Hythe Road) will be even more congested with the extra traffic which is difficult to enter at present. (Will traffic lights be installed)"
Members of the Public/Businesses
Jonathan Mayes
"Hi, even though I don't agree with the whole scheme, I would like to express the need for Kingsford Street to be closed at the end with Highfield lane to prevent a rat run through Mersham. The road is not big enough to cope with it, as well as a danger to the current cyclists, horses and children that use the road. There was a serious incident this week with a turned over car which was going too fast."
Members of the Public/Businesses
Michael Cremonesi
"I live in   Mersham.I am concerned that proposed changes to local roads will result in traffic using Mersham village as a 'rat run' via Kingsford Street, in order to avoid Junction 10. In order to protect the village, It is imperitive that Kingsford Street is closed off at the junction with Highfield Lane."
Members of the Public/Businesses
George Koowaree
"I do welcome the Junction 10a on the M20. I would like to see Traffic Lights at the Junction of Barrey Road with the A2070. even if if will more than the planned junction before junction 10 this will not solve the risk of a serious accident at that junction specially now the Commercial Centre service by Barry Road has had more retail shops with an increase in footfold. The new signage will not solve the problem of joining the A2070 or entering the Centre. Please let have traffic lights"
Members of the Public/Businesses
Mrs Vivian Blaney
"I believe a simple solution to the problems arising trying to exit Ashford Business Park at Sevington is to add traffic lights. If traffic could be taken away from jct 10 if it didn't need to use it by adding the lights traffic would not build up plus when the M20 is closed during Operation Stack or after a serious accident, traffic would be able to find an alternative route by turning at the lights, either those coming up to jct10 from south of Ashford or off the Business Park. I suppose it requires fatalities to all of a sudden make it viable; the speed of traffic going past the entrance to the Business Park and not moving over to allow traffic to join means we may not be far from that! "
Members of the Public/Businesses
Mrs Heidi Milner
"I work on the Ashford Business Park and absolutely dread the drive to and from the estate five days a week. There is only the one road in and out of the estate and to say it is extremely dangerous and a major understatement. To enter the estate while travelling from the Junction 10 roundabout you need to 'play chicken' crossing two lanes of traffic which is travelling at 70mph !! To leave the estate you need to join the road, starting from zero mph trying to join a road where the traffic is speeding along at 70mph, so dangerous I cannot believe that nobody has yet been killed. Nearly everyone I have spoken to has had their car hit up the rear where they are leaving the estate realise there isn't time to join the traffic where it is speeding over the hill, put their brakes on and subsequently gets hit by the car behind. To add to the misery new shops have been added to the park making the traffic a nightmare. If leaving the estate at 17.00hrs it takes at least half an hour just to get onto the Bad Mustereifel Road. I cannot imagine what it is like for those poor people living in the village of Sevington having to cope with the situation seven days a week. A set of traffic lights would surely be the most sensible solution."
Members of the Public/Businesses
Rebecca Cowling
"I would like to request that during your M20 Junc 10A works you can please consider improvements to the Barrey Road Junction from Ashford Business Park - I notice in the plans the Bad Munstereifel Road / A2070 will be altered, it would be wonderful if a roundabout or traffic lights from Barrey Road onto the A2070 could be incorporated into the plans with an option for the traffic to go right and not only have the option to go left up to Junc 10 - this would elevate congestion at the junction of Barrey Road and reduce the amount of traffic going to Junction 10 inadvertently, just to come back on themselves and hopefully reduce the amount of accidents at this junction."
Members of the Public/Businesses
Peter Twaite
"To consider the possibility of traffic lights or a roundabout at the junction of Barrey Road and the A2070. This could be achieved by a slight re- routing of the proposed buildings access road."
Members of the Public/Businesses
David Lowe on behalf of The Executors of Marianne Clunies-Ross deceased plus 6 others
"As Freeholders of land (Plots 2/2/a. 2/2/b and 3/2/b on the Land Plans) directly affected my clients wish to confirm that they fully support the proposed scheme subject to the following: My clients are prepared to co-operate fully with all parties providing they achieve their primary objective. This is to ensure that the balance of their land to be returned to them on completion of the scheme will enjoy the benefit of direct access to and from the Link Road. This access must be suitable to serve any future commercial development of that land rather than the limited replacement agricultural access provided for. This same approach has been maintained from the outset of this scheme and has been registered with The Highways Agency, Highways England and the Developers of Stour Park at various times throughout the long history of the project. It is noted from Highways England's submission dated July 2016 that an alternative scheme is being considered. This involves the inclusion of a roundabout within the Link Road to provide access to the proposed Stour Park Development. My clients support this revision because it facilitates development of a valuable motorway related site for commercial development. However if adopted this revision will effectively determine the point at which any access to the Link road will be possible. My clients therefore wish to propose that if this roundabout junction is included provision should be incorporated for a fourth arm. This fourth arm should be on the North side of the roundabout to ensure that the potentially landlocked area between the Link Road and the M20 Motorway is accessible. Linked with this it is further suggested that Plot 3/16/c is acquired by Highways England and then transferred to my clients as part of the land purchase/exchange arrangement. In this regards my clients are prepared to deal with the Land Transfers by negotiation in advance of compulsory powers. I further maintain that the suggestions proposed in these representations provide a practical and logical basis for constructive and equitable forward planning. "
Members of the Public/Businesses
Miss Jennifer Mills
" A20 between J10A and Junction 10 Use of this piece of road will increase. Drivers coming from Ashford and Kennington wanting to use the J10A eastbound sliproad onto the M20 to go towards Folkestone/Dover and some of those drivers exiting the M20 on the J10A westbound sliproad to go into Ashford or Kennington will use this section of the A20 to avoid going via the link road, another roundabout and the A2070. This short stretch of road also has to cope with drivers going to and from Tesco via a small but busy roundabout. This will generate tailbacks at peak shopping times and add to the risk of gridlock. Highfield Lane and Kingsford Street, Mersham. In AXA/DMI's application 14/00906 it is proposed that Highfield Lane be kept more-or-less on its current alignment and not widened, and that access from Highfield Lane to Kingsford Street will be retained. The draft design for Junction 10A shows that Highfield Lane will not be connected to the A20 when Junction 10A is built so that any traffic using Highfield Lane to go to or from the A2070 and the A20, or will have to pass along Kingsford Street and The Street in Mersham. Although this route is less direct, drivers frustrated with the inevitable peak-hour congestion or gridlock on the J10/J10A/linkroad 'triangle' due to an accident, or simply wishing to avoid the roundabouts and traffic lights, will be tempted to rat-run to and from the A2070 and A20 via Church Road through the U19 site, Highfield Lane, Kingsford Street and The Street in Mersham as they do already. As there will be a link between Highfield Laneand the AXA/DMI site, drivers going to and from the businesses there may also be tempted to use this route as a 'back way' in and out of the development. Highfield Lane is very narrow in places, and in the past there have been jams caused by large vehicles trying to avoid Junction 10 approaching from opposite directions unable to pass each other. Kingsford Street is a narrow, winding lane, with blind bends and no pavements. However, there are many residential properties along it and pedestrians use it to walk to the village shop and school and to the playing field off Kingsford Street. If, as currently planned, a pedestrian/cycle bridge is built from Kingsford Street to the A20 as part of the Junction 10A scheme, this will also attract more pedestrian and cycle use from those who live in the western half of Kingsford Street wishing to reach the A20. Any intensification of traffic along this lane will be extremely dangerous to pedestrians and cyclists and there is the danger of vehicle collisions at the narrowest places in the road, especially at a blind bend near Ransley House. Many Mersham residents want Highfield Lane to be closed at its junction with Kingsford Street to prevent dangerous rat-running. A petition to this effect was presented to KCC in June 2014. Highways England should co-operate with Kent Highways to ensure that this closure is incorporated in the plans for Junction 10A or carried out by the developer of U19, or Kent Highways before the Highfield Lane/A20 junction is closed off. Safety and access at Barrey Road junction. The Barrey Road exit onto the A2070 is obstructed when traffic queues back from Junction 10. This is likely also to happen with the new link road/A2070 roundabout, which is even more likely to get snarled up by a tail-back as it is closer to J10. This will affect residents of Church Road whose only vehicular access to Ashford and elsewhere is via Barrey Road and the A2070, as the other end of Church Road is a cul-de-sac, and also the staff and customers of the many firms of the Ashford Business Park. Also very important to note is that when this road is blocked by a tail-back, access for emergency vehicles is also affected. "
Members of the Public/Businesses
Ian Scollick
"As a Sevington resident my property will be in the vicinity of the proposed road scheme and I will be directly affected by J10A which I expect to use on a daily basis. I would like to be able to make comment on the scheme, and on any proposed modifications to the Barrey Road/A2070 junction which provides the only access to the estate on which I live."
Members of the Public/Businesses
Kent Downs Area of Outstanding Natural Beauty (AONB) Unit (Kent Downs Area of Outstanding Natural Beauty (AONB) Unit)
"While the site of the proposed interchange is some distance from the boundary of the Kent Downs Area of Outstanding Natural Beauty (AONB), the nature of the AONB, which is based on the North Downs scarp, means that it is likely that views of the proposed works will be visible from the AONB. Areas of Outstanding Natural Beauty are a nationally important and protected landscape that have the same status in planning terms as National Parks. Section 85 of the Countryside and Rights of Way Act 2000 requires all public bodies and relevant authorities to have regard to the conservation and enhancement of AONBs in carrying out their duties. This duty of regard needs to be properly considered throughout the decision making process. It is important to note that the ‘Duty of Regard’ applies not just in respect of proposals within AONBs but also to public bodies in exercising their functions “so as to affect” land in an Area of Outstanding Natural Beauty. In view of the potential for the scheme to impact on the setting of the Kent Downs AONB, it is important that that suitable mitigation is incorporated. The Kent Downs AONB Unit would like to ensure that the scheme incorporates appropriate landscaping. In respect of consideration of the cumulative impact of the proposed works, in terms of potential impact on the AONB it is considered that proposed developments at Sevington need to be carefully considered and mitigation planting considered in the context of screening this development too. It is noted that new lighting is proposed both on the gyratory and for all new junctions in the scheme. In order to assist in maintaining dark skies at night, the AONB Unit would also like to see careful design and the use of new technologies to minimise light pollution. "
Members of the Public/Businesses
Mrs Gillian Miller
"The effect of disruption during building process. And then the increase lighting, and noise ruining our quiet country life the additional dust and dirt from lorries and cars being so close to our property, The damage to the house foundations with drilling and building the new slip road and later the noise of Lorries as they change down coming up the slope to the new junction 10a Kingsford street is at present a country lane this will either change, either it will become a rat run for ashford traffic avoiding the round about, or it will be closed off and mean we would have an extra 2 mile plus run each way in order to get into Ashford and we would not have acts to Highfield Lane."
Members of the Public/Businesses
Bellamy Roberts on behalf of Church Commissioners for England
"1. The Church Commissioners for England (The Commissioners) are long term landowners in Kent with significant land holdings in excess of 3,500 acres to the south of Ashford. Part of that land holding at Cheeseman’s Green has an extant planning permission for 1100 dwellings and 8,500m2 of employment floor space. Implementation of that permission has commenced and is continuing apace. The final 400 dwellings are subject to a Planning Condition which restricts their development prior to completion of M20 Junction 10A. 2. The Commissioners are fully supportive of the proposals for a new motorway junction in this location. This will not only unlock the final part of their existing planning permission but it will also facilitate development on parts of their remaining land holdings in South Ashford (south of Cheeseman’s Green). It is recognised by all parties that the Junction 10A scheme is a key transport requirement which is essential to the future development of South Ashford and will unlock development potential in that area. 3. However, The Commissioners are concerned that the traffic modelling work described in the DCO Application does not properly reflect the Approved Development Plan and, therefore, does not fully take account of the development potential for land in South Ashford. 4. The March 2015 Scoping Opinion from the Planning Inspectorate explains that “Ashford has been identified as a major growth area in Kent with 31,000 additional homes and 28,000 new jobs anticipated in the area by 2031”. That is repeated at Paragraph 1.2.2 of Document 7.2, the Submitted Transport Assessment Report. Paragraph 2.5.1 of that Transport Assessment Report records the current Development Plan as comprising the LDF Core Strategy 2008, Borough Local Plan 2000 Saved Policies, and the Urban Sites and Infrastructure Development Plan Document 2012. 5. The Core Strategy 2008 established the appropriateness of the South Ashford location and the principle of development, identifying the potential of the Cheeseman’s Green and Waterbrook area to accommodate about 4,300 dwellings up to 2021 and a further 2,200 dwellings beyond that period. The DCO Application for Junction 10A should accord with the Development Plan and, therefore, should reflect that development potential in the Cheeseman’s Green and Waterbrook area. 6. It is difficult to be certain from the submitted documents with the DCO Application but from the Transport Assessment Report (Table 3-9) it appears that the traffic modelling has been constrained to local traffic growth forecasts based upon a total of some 10,589 dwellings and 5,617 jobs. Those figures are clearly a long way short of the figures set out in the Development Plan Core Strategy 2008. The list of included developments in the Transport Assessment Report makes no allowance for any development at Cheeseman’s Green and Waterbrook over and above existing planning permissions. 7. The Commissioners are concerned that if the traffic modelling has indeed been constrained in this manner, even the new Junction 10A design will present a highway capacity constraint on future development of their land holdings and others in South Ashford, which are a significant resource for economic growth in Ashford. "
Members of the Public/Businesses
Campaign for Better Transport
"Campaign for Better Transport objects to the quality of the accompanying pedestrian and cycle infrastructure that forms part of this application. It appears to be of a standard that does not fit with Highways England's requirements and aspirations as contained within its own Cycling and Access Strategies. It is unclear how the proposed infrastructure provides as good, or better connectivity for pedestrians and cyclists to what they currently enjoy. If anything, there are substantial elements that appear to be a backward step and therefore likely to make it harder for the Government to implement its Cycling and Walking Investment Strategy (CWIS), which relies in part on Highways England delivering improved infrastructure for these modes."
Members of the Public/Businesses
response has attachments
Environment Agency
"We have provided a detailed representation in a letter attached to our email sent to [email protected] at 16.12, on 29 /09/2016. In summary more information is required to demonstrate that flood risk will not be increased by this proposal. Our representation also covers other matters such as land contamination and access to the Aylesford Stream. Please do not hesitate to contact me if you have any questions regarding our representation. "
Members of the Public/Businesses
Lee Evans Planning on behalf of Broad Oak Motor Group Limited
"RESPONSE TO CONSULTATION IN RESPECT OF M20 - JUNCTION 10A We are writing on behalf of Broad Oak Motor Group Limited to support the long awaited scheme to provide the new Junction 10A on the M20. Broad Oak Motor Group Limited wish to establish a further motor dealership on Orbital Park, Ashford - the town’s principal Business Park. Orbital Park was established as a key element in the growth of Ashford and has been developed over the last 20 years. However, a number of plots remain undeveloped due to the stance taken by Ashford Borough Council and the then Highways Agency that no further development at Orbital Park could take place until capacity at M20, Junction 10 was increased. We submitted a planning application to Ashford Borough Council in 2008 for the motor dealership. The application remained undetermined for many years whilst the issues relating to capacity at Junction 10 were considered. The planning application is only now moving forward following an assessment of the additional capacity created by the Junction 10 interim works. It is clear that this situation has delayed construction and economic growth at Ashford - this is clearly not in accordance with Planning Policy and particularly the NPPF and the Government’s emphasis on economic growth. We, therefore, fully support the proposal to increase capacity through the construction of the New Junction 10A - the first objective of the scheme. We welcome the acknowledgement of the importance of this key scheme which is designed to accommodate traffic generated by the future growth of Ashford - a major growth area in the South East. We do not have any comments on the design of the new M20 junction itself but would stress the importance of proceeding through the planning process and construction as quickly as possible, to ensure that Ashford can continue to grow through the delivery of employment development and residential development within the Ashford area. We do support the proposal to provide direct access to the new Stour Park development site from the new A2070 link-road (the alternative scheme) as this will assist economic growth. "
Members of the Public/Businesses
Pilgrims Hospices
"The Ashford Hospice is situated on the Hythe road and is a peaceful sanctuary for dying and very ill people. We manage the end of life for over 2,500 local people in any one year. The proposal to build a motorway fly off in front of our building will have severe implications on the peace and tranquillity that is integral to the last weeks of our patients’ lives. Our gardens are currently an oasis, vital for the wellbeing of the patients and the visitors and residents. These gardens face directly onto the Hythe road. Clearly having motorway traffic coming past in the numbers proposed will decimate these peaceful settings, and severely disrupt the end of life experience of thousands of local residents, not to mention the impact it will have on the relatives who need to be able to rest in a peaceful environment and come to term with the reality of the situation they are experiencing. It is also important to understand the layout of the wards, our bedrooms are on the first floor facing the gardens , looking out to the right they can see the Hythe road (therefore it is not possible to shield the bedrooms from the road with bushes or fences). The additional noise, congestion and fumes, will mean that it will be almost impossible to open the doors onto the bedroom balconies, as you can imagine this will have the effect of incarcerating dying patients in their rooms making access to meaningful nature impossible. I am sure nobody would wish this on our patients. The gardens cannot be moved, and to add insult to injury, we now hear that a large part of our car park and our only entrance is going to be compulsory purchased austensively for a builder’s complex. I am sure you can imagine the noise that will emanate from that use, heavy Lorries, early starts, possible 24 hour working, shouting builders, hot tarmac, etc, etc. Apart from this noise the loss of the car park will severely restrict access for visitors, relatives and staff, the hospice is not well served by public transport and it will be especially difficult for our elderly volunteers to get to the Hospice. Without these volunteers we will have no choice but to shut the site for the duration of the build. If we were to shut the site the consequences for the NHS would be dire as they would have to deal with all the patients that we could no longer house, over 2,500 more NHS beds would be needed. The local people would rightly be up in arms if we had to shut the hospice due to this scheme and I think the public outcry would be massive. On a personal note having used the roundabout where the alleged congestion is, for almost 2 years, I would also like to question the rationale of spending money on a scheme to alleviate only a minute or two of queuing at worst, when there are far more needy schemes crying out for money and investment. The most relevant being the Wincheap works to move traffic away from the wincheap train bridge, congestion there means that cars are stuck in traffic for at least half an hour EVERY DAY. Surely we want to put our precious money into relevant schemes that help many instead of pointless schemes that help a few. I look forward to a more in-depth review of this scheme that will not affect the last few weeks of life of thousands of Ashford residents, and will put the money into other schemes where it will really make a difference. Kind regards Cate Russell CEO Pilgrims Hospices "
Members of the Public/Businesses
Julia Spooner
"Request to extend the low noise surface being used at junction 10a to the surface between junction 10 and 9. Improvement to the junction of Barrey Road and the A2070"
Members of the Public/Businesses
North Willesborough Community Forum
"North Willesborough Community Forum made many comments during the Highways England consultation phase expressing our concerns and objections. These may be summarised as follows: • There is no provision for public transport. • The A2070/Barrey Road junction should be an all-direction signalised junction for safety reasons. • The A2070/Church Road junction should be an all-direction signalised junction for safety reasons. • The A2070 “Y” junction should be redesigned to: 1 Encourage London Bound traffic to use Junction 10a rather than Junction 10. 2 Have a filter lane for traffic travelling from J10 to J10a. • There should be provision for A20 traffic to by-pass J10a in both directions (especially as much of this is local traffic seeking only to use the Tesco store). • The “redundant” J10 sliproads should be “recycled” to provide a connection between J10 and J10a. We also found inconsistencies in the traffic modelling figures, for which we received no conclusive response - we are therefore unconvinced that the modelling technique and data forms a valid basis for the Scheme design. Finally, we believe that the scheme has been designed to benefit national traffic to the detriment of local residents and that a few minor modifications would rectify this. Ian Stevenson "
Members of the Public/Businesses
PSPconsulting on behalf of Taylor Wimpey
"We have reviewed the DCO Application and in particular the Scoping Opinion and the AECOM Transport Assessment (TA). We are concerned that ‘Commitments’ to establish the correct baseline may have been understated and that ‘Planned Development’ for future year testing may not have been properly considered. Thus the TA does not appear to be consistent with ‘The Development Plan’ as set out in the Planning Inspectorate’s Scoping Opinion. We can see from TA paragraph 3.1.3 that the AECOM updated traffic model “has its origins based upon the M20 J10a 2010 Transport demand Model, which was an updated version of one used for the Ashford 10a Highway Traffic Study (AHTS) founded on data collected in 2003” and at paragraph 3.1.4 “as part of the latest revision, the model has been further updated to a 2014 base year and develops it sufficiently to enable testing for planned development and consideration of the wider assessment needs that arise within the M20 corridor”. Under ‘Local Growth Forecasts’ at TA paragraph 3.4.10 “the traffic modelling process requires the production of a ‘Core’ Scenario. The ‘Core’ Scenario is founded on the most unbiased and realistic set of assumptions that form the central case for the Main and Alternative Scheme. This includes assumptions on local uncertainty in terms of delivery, which is typically dependent on whether developments or other planned transport schemes go ahead in the vicinity of the scheme “. We consider this approach to be inconsistent with the analysis undertaken by the Highways Agency in the preparation of AHTS which set out detailed assessments of commitments and then modelled the full Core Strategy development. The March 2015 Scoping Opinion from the Planning Inspectorate explains at paragraph 2.4 “Ashford has been identified as a major growth area in Kent with 31,000 additional homes and 28,000 new jobs anticipated in the area by 2031”. And at paragraph 3.73 “The assessment of cumulative and combined effects is particularly important for a number of environmental topic areas, as noted above, and the ES should address each topic area fully”. Ashford Borough Council’s 18TH February 2015 response to the HA’s Scoping Report advised that “The Development Plan comprises the saved policies in the adopted Ashford Borough Local Plan 2000, the adopted LDF Core Strategy 2008, the adopted Ashford Town Centre Area Action Plan 2010, the Tenterden and Rural Sites DPD 2010, the Urban Sites and Infrastructure DPD 2012, the Chilmington Green AAP 2013.” In our opinion, the AECOM TA does not provide an assessment of cumulative and combined effects consistent with the Development Plan and the ‘realistic’ assessment described in the AECOM TA appears to be a ‘sensitivity test’. Given that M20 J10a is necessary to unlock development to 2031, we believe that the Development Plan position has been understated in the DCO documentation. We wish to present our views at the Examination. Patrick Gurner BSc CEng MICE Director PSPconsulting On behalf of Taylor Wimpey and Persimmon Homes The developers of Park Farm, Ashford "
Local Authorities
response has attachments
Ashford Bororugh Council - Local Authority
"Ashford Borough Council's relevant representation comments are below. 1. Overview 1.1 Ashford Borough Council considers there is a compelling need in principle for a new Junction 10a and A2070 link road to provide further capacity to facilitate residential and employment development within the Ashford growth area identified in its existing development plan documents. 1.2 Ashford Borough Council also expects the scheme to avoid and mitigate, environmental and social impacts in line with the principles set out in the NPPF and government planning guidance. Good design should be an integral consideration of the proposals and it must be as aesthetically sensitive as possible. 1.3 The need for additional motorway junction capacity to the south-east of Ashford has been recognised since at least the turn of the century. The South of Ashford Transport Study (1999) highlighted that the limited available capacity at the existing Junction10 would mean that some development proposals in the then emerging Borough Local Plan 2000 would be unable to be fully built out unless a new ‘Junction 10a’ could be provided. 1.4 Since then, the council has adopted the Core Strategy (2008) which remains the principal Development Plan Document for the borough and the subsequent Urban Sites & Infrastructure DPD (2012). Both Documents place significant weight on the need for Junction 10a to be delivered in order for allocated sites to be built out. The council has also granted planning permission for several developments which rely to some degree on Junction 10a coming forward. 1.5 On 9 June 2016 the Council approved a consultation version of the emerging Local Plan to 2030. The relies on the delivery of Junction 10a to an even greater degree as it will be fundamental to the council’s ability to demonstrate the deliverability of key proposed site allocations for housing and employment development. Without this ability, the new Local Plan would be expected to be found unsound, or otherwise far less suitable sites elsewhere in the borough would be required to be allocated instead. 1.6 Ashford Borough Council has constructively worked with Highways England and our partners at Kent County Council from the pre-application stage. This has included meetings with Highways England and setting up a Junction 10a community group where Ashford Borough Council, Kent County Council and Highways England meet with local residents, parish councils and local members to discuss issues. This is expected to continue during the examination stage. 1.7 Whilst Ashford Borough Council supports the principle of the proposals it has set out detailed issues where there are still objections or concerns and where further changes need to be considered. In additional further information and plans are required in certain areas to fully understand the impacts of the proposals. Some of these were raised at the pre-application consultation stage. 1.8 Ashford Borough Council has the following comments on specific issues: 2. Impact on public open space area in connection with works to Church Lane footbridge 2.1 Ashford Borough Council objects to the proposals in their current form as it impacts on existing public open space and play area and at present acceptable mitigation measures have not been provided. 2.2 The works at present are showing permanent and temporary acquisition of land forming part the Church Road Public Open Space area. This land also forms part of the Ashford Green Corridor and is dedicated as a LNR. 2.3 Highways England and Ashford Borough Council have been in discussion on this matter but this only came to light after the formal pre-application consultation. At present there is no formal statement of common ground between the two parties. Ashford Borough Council’s current position is outlined below. 2.4 In response to the Statement of Reasons Vol.4 (i) Ashford Borough Council agrees as shown on drawing number HA514442-MMGJV-Gen-SMW-DE-Z-2204A with the measurements for plot 3/14b and 3/14a that 3/14b needs to be permanently acquired. (ii) Ashford Borough Council considers that plot 3/14a should also be permanently acquired as the necessary changes in level will permanently affect the accessibility of this land for members of the public and maintenance operations making it unsuitable for use as public open space. Further the necessity of building up levels to ensure a stable raised ramp will also entail the use of fill which will hinder the establishment, survival and appearance of amenity planting and will significantly and permanently change the character of much of this land. (iii) Ashford Borough Council objects to the proposed replacement land being given in exchange for the following reasons: • It is visually and physically severed from the remaining useable open space and has extremely low amenity potential being a linear strip beside the highway. • Access to the replacement land from the existing open space via a ramp going up and then down some stairs, which are not DDA compliant and is likely to adversely affect local people with mobility issues. • The existing land is within the Ashford Green Corridors and is a LNR but the proposed replacement land is not of sufficient wildlife potential to warrant it being part of the Ashford Green Corridor or LNR designation. 2.5 Ashford Borough Council does not therefore accept that it is suitable for replacement land. Other possible replacement land may be available which is more suitable for replacement land in that it is suitable for inclusion in the LNR and of visual amenity value and accessibility at least equivalent to the land acquired. This land has been identified to Highways England by Ashford Borough Council but there is no agreement at present with Highways England. 2.6 Part of the acquired land will be re-profiled in a way (Section A-A on drawing HA514442-MMGJV-GEN-00039-rev B) that effects and prohibits access by members of the public to the public opens space area from Church Road as well as by maintenance vehicles. It is also not clear if the fenced off play area is directly affected. The main lighting scheme (figure 2.5d drawing number HA514442-MMGJV-GEN-SMV-DE-Z-602106 rev A) also indicates a mini pillar to serve the bridge lighting is within the play area. Confirmation of the overall impact on the POS/play area will be needed. A new access point is also likely to be needed and agreed and created at no cost to Ashford Borough Council. 3. Stour Park scheme and relationship with alternative scheme 3.1 The council has resolved to grant outline planning permission for the Stour Park development subject to a section 106 planning obligation agreement at the Planning Committee meeting 18 May 2016. 3.2. The illustrative master plan showing the proposed building footprint of the Stour Park development includes the principal access to the site from the access roundabout shown on the A2070 link as the alternative scheme proposals. The council has no objection to this access arrangement. 3.3 The indicative master plan of the Stour park development identifies that the northern boundary to the site would have a screen planting belt fronting towards the Junction 10a A2070 link road. 3.4 The planting for the Stour Park development would be supplemented by tree planting through the Junction 10a scheme. If the quantum of land needed by Highways England for the link road corridor is reduced by adjustments to its boundary with Stour Park northwards then the space available for tree landscaping entirely within Stour Park would be enhanced as a consequence. 3.5 Overall in view of the substantial scale of the Stour Park development the council requests a strong boundary of woodland scale tree planting of maximum depth possible on the southern side of the A2070 and that this supplements similar planting provided with the Stour Park development. 3.6 The Stour Park development identifies the importance of having a sensitive lighting scheme in terms of impact on ecological receptors (bats) and visual & historic receptors (St. Mary’s Church and adjoining properties). The proposal is for limiting light spillage in certain areas marked purple as shown on the image attached as Annex 1. 3.7 In terms of ecological receptors, the recommendations of the bat conservation trust would be incorporated to ensure that the development mitigates impacts on wildlife. A bat activity map was provided and this highlights in purple ecologically desirable ‘dark’ areas of the site and in green conflict zones where street lighting has potential to cause fragmentation of habitat areas thus lessening the value to bats. The Stour Park applicant acknowledges that this would dictate as sensitive approach as possible in the conflict zones. The approach that would be taken in the areas marked purple would be to provide level (e.g. bollard) or directional lighting in order to limit excessive light spill into these areas with design to limit light spill being the subject of computer simulation with lux levels to be less than 1. The junction10a scheme involves new lighting being provided along the A2070 link road in close proximity to this area. The impact of this on ecological receptors in this area also needed to be considered as it has been for the Stour Park development. 4. Impact on grade 1 listed St Mary’s Church and adjoining listed Court lodge complex 4.1 The setting of the grade 1 and adjoining grade 2 Court lodge complex is important. The comments from Heritage England need to be considered and whether improvements can be provided such as less highway paraphernalia and more space for landscaping to the noise barrier to the north. There are no details of the new footbridge so this impact on the setting of these buildings cannot be fully assessed. 5. Air quality 5.1 The context of the Environmental Statement is noted. Further clarification/information is required on the following matters outlined in Chapter 5 of the Environmental Statement. 5.2 Further information as to whether there is the potential for DMRB criteria for further assessment to be triggered for the construction phase, specifically (i) Whether changes in speed (either peak-hour or average) at the approaches to 50mph speed limits on the M20 could trigger DMRB criteria; (ii) Whether temporary changes associated with traffic lights on the A20 or changes in speed on the M20 would be likely to be significant. 5.3 Further information regarding modelled versus observed speeds that led to derivation of traffic speed data in Appendix 5.3. 5.4 Clarification as to the apparent minor discrepancy between 5.8.12, Table 5.13 and Appendix 5.4 (specifically with respect to receptor 1469). Confirmation that all receptors were fully considered in the ‘Main Scheme – Operation’ and ‘Alternative Scheme – Operation’ sections and whether any amendments to the section are necessary. 6. Noise and vibration 6.1 The context of the ES is noted. Further clarification/information is required on the following matters outlined in Chapter 9 of the Environmental Statement: (i) Section 9.2 – there is no reference to any local planning policy in respect of noise and vibration as the NPPF would require. (ii) One of the aims of the proposed scheme is to relieve current and ameliorate anticipated future traffic congestion. However, the ES is not clear how the assessment has addressed the way in which congestion in future “Do–minimum” scenarios will influence the speed of traffic on the roads evaluated. This is potentially important as congestion often results in a drop in traffic speed and can cause the associated noise level to fall, if not over the whole of a 16 or 18 hour day to be reduced for substantial periods during that time. Consequently, it is not clear if the calculated difference between “Do– minimum” and “Do-Something” noise levels appropriately reflects the likely difference between the “Do–minimum” scenarios with congestion and the DS scenarios without, or at least with less, congestion. Clarification of if and how traffic congestion in the opening and design year “Do–minimum” scenarios and whether the assumed future “Do–minimum” noise predictions allow for reduced speed and therefore lower noise levels associated with congestion, is therefore recommended. 6.2 It should be explored whether the use low surface noise surfacing throughout the scheme add any material benefits in terms of noise and vibration. 7. Effects on All Travellers 7.1 The context of the ES is noted. Further clarification/information is required on the following matters outlined in Chapter 12 of the Environmental Statement: (i) The chapter refers to traffic models, but is not specific as to which have been used. It seems likely that appropriate models have been employed (e.g. an area-wide model such as SATURN, and/or specific junction models such as ARCADY or PICADY. (ii) Clarification sought over whether the traffic data has been predicted for the construction period 8. Landscape and visual 8.1 The areas likely to experience the greatest landscape effects are those adopted Landscape Character Areas physically affected by the proposed scheme and those which lie immediately adjacent to the proposals e.g. Mersham Farmland and Brabourne Lees Mixed Farmland. It is considered that the significance of landscape effects on these two landscapes in Year 1 and Year 15 have been underestimated. 8.2 In relation to visual receptors it is considered that the visual effects of the scheme have in a number of cases been underestimated either because they were not assessed, because the additional effects of the alternative proposal were not properly articulated or because ancillary aspects of the proposals were not sufficiently taken into account. 8.3 It is also considered that some of the mitigation planting proposals are inadequate and / or are uncharacteristic and have missed opportunities in relation to improving landscape legibility and place making. In addition, opportunities to improve access and connectivity between the urban areas of Ashford and the wider countryside do not appear to have been adequately considered. There is considerable scope to improve the landscape proposals within the Aylesford Stream valley in particular 8.4 A significant amount of existing established landscaping will be removed. It is important that substantial replacement and new planting is provided in particular the following locations. (i) The approaches along M20 corridor which currently are characterised by dense tree-lined landscaping. The planting proposals should look to continue and retain this characteristic. (ii) Along Kingsford Street which currently has a narrow rural lane tree- lined character. The planting should look to continue this characteristic. (iii) The A2070 link road should have substantial landscaping provided along the southern end in particular and this integrates with landscaping provided for the substantial Stour Park development. The landscaping providing should include woodland scale planting. (iv) The northern end of the A20 where existing boundary landscaping along the highway is lost through the realignment of the road. Replacement boundary planting along the A20 with suitable trees will need to be provided. (v) The area around the new Church Road footbridge. The replanting on the western side and screening lost located close to the nearest dwellings along Nightingale Close is likely to result in overlooking from the footbridge. On the eastern side screening to St Mary’s Church and the Court Lodge complex, more initial substantive planting is likely to be needed in these areas 8.5 Appendix 2.2 provides the indicative planting schedule. The final detail planting will need to be clear 8.6 Further clarification/information is requited on the following matters outlined in Chapter 7of the Environmental Statement: (i) It would be helpful to have an aerial photograph with the proposed scheme overlaid so that the features associated with the scheme could be readily placed in the existing landscape patterns and topography (ii) It would be useful if the environmental masterplan proposals included all aspects of the scheme which can have a visual cumulative effect including barriers, signage and lighting (iii) It is unclear why only three of the key viewpoints have been made into montages and not others. (iv) St Mary's Church is not shown on Figure 7.9b although it is expected that the removal of vegetation along the M20 will open up views to the church in Year 1. (v) The main LVIA document does not set out all volumes relevant to the chapter at the start of the chapter which would aid navigation and cross referencing. (vi) There is no reference to the Ashford Green and Blue Grid prepared by Shields Flynn (2008) (vii) No reference is made to landscape impacts and in particular physical and perceptual impacts (viii) Not all important visual receptors appear to have been picked up during the assessment. For example it is considered that key visual receptors also exist on the Public Right of Way which heads north from adjacent to St Mary's Church. (ix) The assessment of the alternative scheme is unclear and appears to just repeat the text for the main scheme. A more appropriate description would be to focus on the additional effect of the third roundabout in terms of potential intensification of effects overall (x) The 3 m environmental barrier proposed along Highfield Lane to reduce acoustic impacts would appear out of character and visually intrusive when travelling along the lane. It could be concealed with foreground planting and the lane itself fringed with a dense hedgerow in order to retain its typical rural character as it connects to Kingsford Street (xi) No information is provided on the physical loss of trees, vegetation, grassland and arable land as a result of the proposed development, although it is noted that the plans in Appendix 7.1 Volume 3.2 show trees and hedgerows for removal (xii) It is unclear why the alternative proposal is not also assessed separately for Visual Receptors 1 and 2 both of which would afford views cross the Aylesford Stream to the rising land beyond. 9. Arboricultural Survey Report Appendix 7.1 9.1 TPO trees at Pilgrims Hospice boundary with A20 Hythe Road. The arboricultural survey report appendix 7.1 indicates no TPO trees are affected which is incorrect. The belt woodland trees on the southern boundary of the Pilgrims Hospice is protected by Tree Preservation Order No.22, 1998. The TPO has not been picked up in the survey which states that no TPO trees will be affected. The trees are included within the wider area of W1 of the survey and are mentioned as being implicated in the Arboricultural implications assessment. 9.2 The belt of woodland trees is an important visual feature and provides screening to the hospice from the busy A20 road. This will be of increasing importance with the construction of the Junction 10a link road. The loss of these trees is unacceptable on the grounds of visual amenity and needs to be addressed at this early stage 9.3 Page 8, paragraph 6 of the Executive Summary states that there are 36 tree groups in the survey, however the Schedule of Trees as well as page 14 paragraph 2.1.9 specifies that there are 35 groups which have been surveyed. An error in counting group G30 twice in the Schedule of Trees has resulted in inconsistency in the report. 9.4 Page 10, paragraph 1.5.1 states that the survey was undertaken by a qualified Arboriculturalist, please can the level of qualification for example ‘level 3’ qualification be specified. While this may not be a statutory requirement clarification concerning the competency of the surveyor would be required in line with best practice. 9.5 Page 13, paragraph 2.1.2 to 2.1.4 discusses ‘grouping’ of trees in the survey. In the absence of clarification it is assumed that the groups were selected in accordance 4.2.4 (B) of BS 5837:2012 9.6 Page 13, paragraph 2.1.4 discusses hybrid black poplar trees. Was a check made to establish if these were hybrid or native black poplar trees, as native black poplar are nationally important and may require special consideration or upgrading of their category status. 9.7 Page 24, Appendix B. Species list cross referencing common names with scientific/botanical names is missing from the report.(paragraph 1.5.6) 10. Arboricultural Implications Report Appendix 7.3 10.1 Page 8, paragraph 2 of the Executive Summary states that the Arboricultural Implications Report should be read in conjunction with M20 Junction 10a Arboricultural Survey Report (June 2016) document reference 341755-09-300-RE-02-A, however the Survey Report we have reviewed is reference July (2016) reference HA514442-MMGJV-GEN-SMW-RE-Z-630701, and therefore does not correspond. 10.2 Page 8, paragraph 2 of the Executive Summary states that 36 groups of trees were surveyed, however this does not correspond with the Schedule of Trees in the Arboricultural Survey Report which states 35 groups. 10.3 Page 11 paragraph 1.4.1 states that due to minor changes in the scope of works, a revised Arboricultral Survey report was issued. Clarification is required to whether the latest report corresponds to report reference July (2016) reference HA514442-MMGJV-GEN-SMW-RE-Z-630701. 10.4 In Section 3 there is no reference to root incursion analysis of root protection areas of impacted trees or specific construction mitigation recommendations. While it is not a requirement of BS 5837, it is established industry practice to undertake an assessment of root protection area incursions. 11. Visual impact of 3m Noise barrier along Kingsford Street and A2070 11.1. The 3 m acoustic barrier will be a visually prominent feature in places. Although it is recognised that mitigation for noise is crucial it is important that the barrier is visually screened and properly integrated into the existing landscaping scheme in the best way possible. 11.2 There are certain locations the barrier may be particularly intrusive and changes to the siting/landscaping should be considered if these still provide the required noise mitigation. 11.3. The start of the Kingsford Street footbridge on the Kingsford Street side, the barrier is located right up to the footpath from Kingsford Street with no planting/ screening in between. This may look oppressive when walking along the footway. Consideration should be given to setting the barrier further back into the native shrub and tree planting area. There are also two listed buildings located close-by - Ransley Cottage and Redburr and their setting would potentially be enhanced with better screening. 11.4. The barrier along the corner of Highfield Lane by the Junction 10a roundabout is exposed without any screening landscaping. 11.5. The initial barrier along the southern side of the A2070 near the Junction 10a interchange is right up against the footway/cycleway without any screening landscaping. 11.6. The barrier on the southern side of the A2070 roundabout has little or no landscaping screen and is partly sited on a noise bund. A cross section needs to be provided through this. 11.7. There needs to be confirmation that there is no problem with planting in particular larger specimen trees being planted close to barriers or highway hard surface areas in terms of impact on roots. 12. Flooding and drainage 12.1 The report refers to Ashford Borough Council as the Lead Local Flood Authority when it is actually Kent County Council. 12.2 With regards to the technical details then there are no objections to the runoff rate and methodologies being proposed. As discussed with Highways England throughout the process the design has focussed on ensuring Ashford Borough Councils local Sustainable Drainage SPD by seeking to limit runoff rates to those identified within the aforementioned document. Due to the betterments that achieving these rates can provide it is considered positive that HE are seeking to generally achieve these rates across the proposed scheme. 12.3 Pond 3 of the development a runoff rate of 4l/s/ha has been opted for rather than the 2l/s/ha (As stated in the Sustainable Drainage SPD) for the area north of the M20, however it is likely that ground conditions here will be similar to the rest of the development, with the underlying geology being of Hythe formation and therefore of low permeability. Furthermore, as identified within the available documentation, due to the area being drained to pond 3 being just over 1Ha the control rate would be limited to just above 2l/s, whilst small orifice controls can achieve the lower discharge rate, and with regular maintenance can continue to ensure the risk of blockages is very low, as this scheme involves national critical infrastructure the discharge rate of just over 5l/s from pond 3 is deemed acceptable 12.4 Appropriate levels of treatment are considered to be in place before the water finally discharges into the Aylesford stream. The use of ponds, when used in conjunction with appropriate vegetation, can enhance treatment process and biodiversity. However, appropriate maintenance will be required and consideration given in the final design to ensure that sufficient capacity is provided within the ponds, even during periods when these may be heavily vegetated 13. Funding statement 13.1 Paragraph 3.1.9 states the following: “The contribution from local developer is reliant on a grant funding agreement between the Homes and Communities Agency (HCA) and Ashford Borough Council…”. This needs amending as the contribution from local developer is reliant on a loan or grant funding agreement, between the Homes and Communities Agency HCA and Ashford Borough Council 14. Highfield lane 14.1 It should be explored if a closure of the vehicular link between Kingsford Street and Highfield Lane needs to be provided as part of these proposals for Junction10a to prevent unreasonable levels of rat-running through Mersham village. 15. Barrey Road 15.1 The council had previously requested that there is a right hand signalised turn-out from Barrey Road onto the A2070. It is regretted that a right hand turn from the Barrey Road junction is not included as part the proposals. 16 Pilgrims Hospice 16.1 The Pilgrims Hospice is a particularly sensitive site where the peace and tranquillity of residents is of great importance. There is concern about the impact of works at the front of the site on this environment including the use of compounds nearby whose position needs to be clarified. 17 Highways 17.1 Ashford Borough Council will rely on comments made by Kent County Council on this matter. 18. Draft Development Consent Order 18.1 Part 2 section 8 - Limits of deviation. The full implications of this need to be considered and are these limits of deviation covered in the current environmental statement. It is not clear what is a materially new or material worse environmental effect from those reported in the Environmental statement. 18.2 Given the short time period for considering the application documents the Council has not fully assessed the wording of the draft development consent order. The Council may wish to submit written comments on the draft development consent order. 19. Further details required : 19.1 The two footway and cycleway bridges. 19.2 The retaining walls/structures and extent of them shown along M20 corridors and A2070 which should be aesthetically finished 19.3 The precise area and working of the compounds as they are shown indicatively 19.4 More user friendly sections through the development showing existing and proposed changes. The engineering sections provided are not user friendly to a lay person and it is not clear what the proposed changes in levels are. 20. Conclusion 20.1 The Council is supportive of the proposed new junction and the positive contribution towards the growth agenda of the borough. ABC will continue to work with Highways England and Kent County Council on this application to deal with the issues identified and welcomes the opportunity to comment in more detail at a later stage. "
Members of the Public/Businesses
Ashford Borough Council - Affected Person
"M20 Junction 10a Planning Inspectorate Reference TR010006 Representations by Ashford Borough Council on behalf of Head of Cultural, as landowner of Plot 3/14/a and Plot3/14/b and the proposed replacement land. The Borough Council recognises the importance and relevance of the proposed new junction. However, as owner of the land identified above, it is important that the scheme works for the local community and the Borough Council. Ashford Borough Council owns plots 3/14/a and 3/14/b. These plots form part of the public open space land at Church Road which is used for the purposes of public recreation and enjoyment. This land is also designated as a local nature reserve and forms part of the Ashford Green Corridor. The land at Church Road combines complementary wildlife habitats, such as dense scrub, trees and semi-natural grass areas; children’s play space, including the opportunity for informal pay in a safe and attractive space; visual quality to the immediate residential area, introducing a green element to the residential street environment; forming part of the Public Right Of Way and well used pedestrian route from South Willesborough to Sevington; providing a quiet and relaxing green space where people enjoy informal sport and contact with nature and fresh air. Land to be Permanently Acquired from Ashford Borough Council Plot3/14/b In part 3 of the Statement of Reasons the description of the land being acquired concentrates on the vegetation cover and little else, without acknowledging the role this land plays in the ecological, social and the visual quality of the whole space of which it forms. Clarification is required over the extent of the permanent land being acquired; it is not clear from the plans and drawings. The acquisition of this plot and proposed profiling will obstruct the Borough Council’s maintenance access to the Recreation Ground at Church Lane, Sevington. This will be due to the introduction of a steep cutting along the access route and because the access route will permanently be removed from the Ashford Borough Council’s ownership. An alternative entrance will need to be constructed to enable Ashford Borough Council to access from Church Road to carry out maintenance of the retained public open space. There is no proposed clear demarcation between land being retained by Ashford Borough Council and the land being acquired by Highways England. Land to be Temporarily Acquired from Ashford Borough Council Plot 3/14/a This small area should be permanently acquired by Highways England as it will be completely surrounded by HE land in future and cut off from the remaining public open space with no access for the Borough Council over its own land and no clear boundary demarcation. The steepness of proposed re-profiling of this plot will render it of little use to the public and difficult to maintain and less likely to sustain stable tree planting. It is unclear who will be responsible for maintaining the banked land. A substantial area of the land in question currently receives minimal maintenance in keeping with its designation as Local Nature Reserve and Green Corridor to encourage wildlife. It is unclear if the proposed changes in the profiling of the land will necessitate a higher standard of maintenance or of it will still be in keeping with Local Nature Reserve and Green Corridor status. Proposed Replacement Land to be given to Ashford Borough Council by Highways England Plots 3/1b, 3/1/c and 3/1/d Clarification is sought over the extent of the proposed replacement land. The replacement land forms part of the highway verge and is not of equal size to the land being acquired. The available maps differ as to whether the cycleway is included in the replacement land or not. The borough council is not responsible for the maintenance of highways and does not adopt highways standard cycleways , highway verge or associated infrastructure because they are subject to highway rights and obligations which are normally maintained by the County Council. There is a lack of proposed demarcation (which is likely to cause maintenance and liability issues), the land is surrounded by HE land and it is not easily identifiable as public open space by the public and not easily accessible by Ashford Borough Council for maintenance purposes. The transfer of this land to the Borough Council will reduce the efficiency with which it can be maintained and increase costs to the public without bringing any additional public value. It is not appropriate for this replacement land to be subject to the same rights, trusts and incidents as the Public Open Space being permanently acquired. The replacement land is not a like for like replacement in terms of public amenity, landscape value or suitability as public open space or for inclusion in the existing Local Nature Reserve, which currently includes plots 3/14/a and 3/14/b. The replacement land will be less advantageous to persons entitled to use the land given that it is highway verge and it is visually and physically severed from the exiting open space. Access to the replacement land from the existing open space is via a ramp going up and then down some stairs, which are not DDA compliant and is likely to adversely affect local people with mobility issues. The replacement land is not suitable alternative land in exchange for the POS. In addition the replacement land does not meet the criteria for the inclusion in the Green Corridor due to its location and topography. It would be more appropriate for Highways England to retain this piece of land together with the rest of the highway land which surrounds it. There is reference to a new mini lighting column within the proposed land swap. It is not clear if this is to be maintained by Highways England, Ashford Borough Council or Kent County Council Highways who normally maintain public street lighting. The Council has requested that Highways England look at alternative options such as other replacement land or the procedures under s131 (4A) PA 2008. The Council wishes to reserve its right to make further representations on these issues, given that negotiations are ongoing. "
Members of the Public/Businesses
BDB DESIGN LLP on behalf of Brett Aggregates Limited
"M20 Junction 10A Planning Inspectorate Reference: TR010006 Representations submitted by BDB Design LLP on behalf of Brett Aggregates Limited Land and Development at Conningbrook Lakes, Willesborough Road, Ashford Summary 1. We represent Brett Aggregates Ltd in connection with development and redevelopment proposals including up 600 homes at Conningbrook Lakes, Willesborough Road, Ashford. 2. This objection relates to the inadequacies of the primary highway network including M20 Junction 10 to serve not only this development, but also many other development proposals within the Ashford Area. 3. The lengthy delays associated with the provision of a new Junction M20/10A continue to frustrate investment and the provision of much-needed homes and employment within the Ashford area. Ojection 4. Our objection is primarily about the protracted time-scale involved in securing all necessary consents, commissioning, building and completing the proposed junction. We strongly urge a speedy resolution to the Inquiry procedure and delivery of this essential infrastructure without further delay. 5. The delivery of large numbers of much needed new homes at Ashford is the long-held primary aim of the Borough Council. This has been made clear through successive policy reviews and now accentuated recently by an under-delivery of homes to meet Objectively Assessed Need. The planning strategy steered by thorough analysis of constraints and opportunities, as well as National Planning Policy Guidance dictates that the bulk of new development for jobs and homes should be located at Ashford. 6. For many decades and in support of Ashford’s growth-point status, landowners including the Brett Group and developers, have been encouraged to invest significant resources into securing planning permission for development or redevelopment of sites within and at Ashford’s periphery. To a greater or lesser extent, these sites rely on access to and from the M20 motorway. However, in order to manage under-capacity at junction 10, planning applications generating additional capacity are either being refused as premature, or made the subject of ‘Grampian’ conditions withholding commencement until Motorway access capacities can be increased. These proposals offer this in the form of a new Junction at known as 10A. 7. As a first phase, planning permission has been granted for 300 homes at Conningbrook Lakes, together with the formation of a Country Park including a range of associated leisure and sporting activities. However, development proposals for further phases of mixed-uses with up to 300 further homes, cannot progress until such time as the additional M20 Junction has been completed and open for use. 8. Interim solutions to enhance the capacity at junction 10 have been prepared and agreed, but any extra capacity will already be absorbed by approved development schemes to the south and east of Ashford. This leaves no prospect for the timely delivery of further phases at Conningbrook Lakes and many other sites allocated for development in adopted and emerging planning policy, which suffer from the same embargo. Conclusion: 9. The failure to provide essential transport infrastructure to help realise Ashford’s growth-point status and long-held policy objectives, continues to stifle investment in jobs and housing. 10. The proposed Junction M20/10A has been a preferred solution for a very long time. We object to the protracted programme for completion. The scheme should be approved, commissioned, built and opened for use without delay and afforded the highest priority. Recommendation 11. We Support the provision of a new M20/J10A as proposed in the planning application and associated documents. However, WE OBJECT in the strongest terms to the inordinate delays to completing the approvals and the delivery process. "
Members of the Public/Businesses
Gowling WLG LLP on behalf of Friends Life Limited/Aviva Investors
"Friends Life Limited and Aviva Investors (the "Interested Party") owns and controls the land known as Sevington, north of Highfield Lane. Sevington is allocated in local planning policy for major employment development. Friends Life submitted an outline planning application to Ashford Borough Council (the “Council”) for such a development on part of this land, known as “Stour Park” (the “Development”). The Development is referred to in section 2 of the Statement of Reasons. The Council resolved to grant planning permission for the Development, a section 106 agreement is near to being finalised and outline planning permission will be granted shortly. The Interested Party supports the Scheme in principle. However, it objects to the proposed compulsory acquisition of its land on the grounds that it is both unnecessary and would significantly prejudice the Interested Party’s ability to deliver the Development. The Interested Party objects to all of its land being included in the compulsory acquisition, in particular the following plots: • 3/16/a It is not necessary for the Applicant to acquire the entirety of this plot for the stated purpose - a section of the plot would be sufficient. The Interested Party has included part of this plot abutting Church Road for a future development of the adjacent Batts Farm yard. • 3/16/b It is not necessary for the Applicant to acquire this plot for the stated purpose of creating a balancing pond. The Interested Party intends to construct a balancing pond in this location pursuant to the planning permission for the Development and has offered to the Applicant that it will create a sufficiently large pond that can be serve both the Development and the Scheme. This would create a significant saving to the public purse. If this plot is taken and the Applicant build a pond for its sole use, the Interested Party will need to have to divert all surface water to the south of the Stour Park site, creating an environmental impact which has not been tested in the Applicant’s Environmental Statement. • 3/16/cde It is not necessary for the Applicant to acquire these plots for the stated purposes. 3/16/c is land which the Interested Party has planted with wild flora to provide ecological mitigation in relation to the Development. The Applicant’s compound could be easily located on the neighbouring open land to the north west of this plot. • 4/16/ab Acquisition of these plots is unnecessary. More comprehensive environmental mitigation is proposed by the Interested Party as part of the Development; acquisition of this land would prejudice the future development of Sevington (East) envisaged in the local plan. • 4/16/c This plot is the land upon which the Interested Party is required under its section 106 agreement to provide a turning circle to enable vehicles to exit Highfield Lane. This is a legal obligation on the Interested Party which it would not be able to comply with if this plot were taken. • 4/16/d It is not necessary for the Applicant to acquire these plots. More comprehensive environmental mitigation is proposed by the Interested Party and compulsory acquisition of this land would be contrary to best use of this land as promoted through the local plan process. • 4/16/efg It is not necessary for the Applicant to acquire these plots for the stated purpose. The creation of balancing ponds within the Scheme and elsewhere within the Development provide excellent habitat. Acquisition of this plot and its use for habitat would prejudice the future development of Sevington (East) envisaged in the local plan. The Interested Party has throughout provided the Applicant with all information necessary to avoid or minimise the above issues. However the Applicant has not taken this into consideration and as such has not fully complied with its statutory to consult. Neither has the Applicant made a proper attempt to acquire land by agreement. The Applicant has failed to demonstrate a compelling case that the acquisition of the Interested Party’s land is necessary and that there is a compelling case for it. "
Members of the Public/Businesses
DHA Planning on behalf of GSE Group
"Land at Waterbrook, including land owned by GSE, is identified in Policy CS5 of the adopted Core Strategy for 15ha of employment land as part of a mixed use development. It is also proposed to be allocated in the emerging Ashford Local Plan (Regulation 19 Draft) under Policy S16 for a mix of uses including a relocated 600 space lorry park, residential and employment uses. The delivery of the full Waterbrook development is reliant on the new motorway junction M20J10a and GSE wish to present their views to the Inspector at the Examination. GSE have reviewed the DCO Application including the AECOM Transport Assessment (TA) and the PINS Scoping Opinion. We are concerned that the normal approach to the preparation of transport assessments has not been followed and that all commitments necessary to establish the baseline have not been included and that future development has been understated. The TA is thus considered to be inconsistent with the Development Plan as detailed in the PINS Scoping Opinion. The TA states that the updated traffic model has its origins based upon the M20 J10a 2010 Transport demand Model, which was an updated version of one used for the Ashford 10a Highway Traffic Study (AHTS). The TA then explains that the model has been further updated sufficiently to enable testing for planned development. The local growth forecasts in the TA refer to a ‘Core’ Scenario’ “founded on the most unbiased and realistic set of assumptions that form the central case for the Main and Alternative Scheme. This includes assumptions on local uncertainty in terms of delivery, which is typically dependent on whether developments or other planned transport schemes go ahead in the vicinity of the scheme“. GSE do not accept that the full Core Strategy development has been taken into account in the TA, as it was under AHTS, nor that the correct assessment of commitments has been carried out. PINS Scoping Opinion explains that Ashford has been identified as a major growth area in Kent with 31,000 additional homes and 28,000 new jobs anticipated in the area by 2031. PINS go on to state that “The assessment of cumulative and combined effects is particularly important for a number of environmental topic areas, as noted above, and the ES should address each topic area fully”. Ashford Borough Council, in response to the HA’s Scoping Report, advised that the Development Plan comprises the saved policies in the adopted Ashford Borough Local Plan 2000, the adopted LDF Core Strategy 2008, the adopted Ashford Town Centre Area Action Plan 2010, the Tenterden and Rural Sites DPD 2010, the Urban Sites and Infrastructure DPD 2012, the Chilmington Green AAP 2013. GSE do not accept that the AECOM TA provides the correct assessment of cumulative and combined effects consistent with the PINS Scoping Opinion. The DCO documentation understates the Development Plan position for this critical element of strategic highway infrastructure, which is necessary to deliver full adopted Core Strategy development to 2031. "
Members of the Public/Businesses
response has attachments
Historic England
"Please see PDF letter submitted by email on 3 October 2016 to [email protected]"
Members of the Public/Businesses
response has attachments
Kent County Council
"Mr. Richard Price National Infrastructure Case Manager The Planning Inspectorate 3/18 Eagle Wing Temple Quay House 2 The Square Bristol BS1 6PN BY EMAIL ONLY Environment, Planning and Enforcement Invicta House County Hall Kent County Council Maidstone ME14 1XX Phone: 03000 418827 Ask for: Katie Stewart Email: [email protected] 3 October 2016 Dear Mr. Price, Re: Application by Highways England for an Order granting development consent for the proposed M20 Junction 10a – Relevant Representation submission Following the Planning Inspectorate’s notification of decision to accept an application for examination for an order granting development consent (dated 11 August 2016), Kent County Council (KCC) requests that this letter be considered as a Relevant Representation and to be registered as an Interested Party for this application. KCC fully supports the proposal for the construction of the M20 J10a. In the Ashford Borough Council - Kent County District Delivery Deal (2015), the new junction is listed as one of the ‘Big 8’ strategic projects that have been identified as having the greatest collective ability to unlock thousands of jobs and homes in the Ashford Borough. KCC has set out its full commitment to work closely with Ashford Borough Council (ABC) in delivering the ‘Big 8’ strategic projects and in supporting the delivery of the Borough Council’s growth agenda, which is set out in the emerging Local Plan 2030. The submission of this application for a Development Consent Order by Highways England (HE) is welcomed, particularly as there is compelling need in principle for a new Junction 10a and link road to provide further capacity to facilitate residential and employment development in the Ashford growth area, as identified in Ashford’s existing development plan documents. KCC will continue the constructive dialogue with ABC and Highways England throughout the process to address outstanding matters. KCC has noted the letter sent from the Planning Inspectorate to HE on 21 September 2016, which identifies areas in which additional information is required during the pre-examination stage, including updated Works Plans and Book of Reference. In addition, KCC, in collaboration with ABC, has commissioned an Independent Review of the Environmental Statement (ES) (APP-029- APP-208 in the Examination Library, covering air quality, noise and vibration, effects on all travelers and landscape and visual impacts), with the objective to ensure that the ES is compliant with the EC Directive 2011/92/EU on the assessment of the effects of certain public and private projects on the environment. This may result in a recommendation for further areas of work, and KCC will welcome the opportunity to comment on matters of detail at future stages of the NSIP process. This letter sets out a summary of the main aspects of the application with which KCC agrees and/or disagrees, together with an appropriate explanation, in accordance with the Planning Inspectorate’s Advice Note 8.3. In summary, an outline of the principal submissions that KCC intends to make in relation to the application will concern: - All matters concerning KCC as Local Highway Authority; - Asset management/ maintenance; - Public Rights of Way impacts; - Cultural heritage impacts; - Biodiversity impacts; - All surface water management aspects of the scheme covered by KCC as the Lead Local Flood Authority; and - Minerals and waste. Local Highway Authority The Local Highway Authority has made comments in respect of the status of the A20 Hythe Road in the context of M20 J10A. The A20 Hythe Road currently forms part of the local road network. However, the closure of the east-facing slips as part of the proposal for M20 J10A would result in a greater volume of coast-bound traffic using the A20 Hythe Road. Accordingly, it is necessary for the Local Highway Authority to raise this as a matter requiring further discussion with HE. The Local Highway Authority considers that a suitable way forward would be for HE to take on maintenance responsibility for the section of A20 Hythe Road between the extent of HE’s asset at M20 J10 and the proposed connection of M20 J10A with the A20 Hythe Road. It makes operational and strategic sense that this short section of road is picked up by HE, as it directly links the two junctions. This request will not have implications on the cost of constructing the M20 J10A scheme, as maintenance is an on-going requirement post-scheme implementation. It is commonplace for such discussions to take place in respect of long-term asset status, and the Local Highway Authority is mindful that the matter should be resolved as soon as practicable. It is understood that the Project Sponsor is checking this proposal with their legal team as this area sits outside of the “red line” for the scheme, but that should not discount the requirement, especially as HE was made aware of the request some 18 months ago. The draft DCO at section 12(4) (APP-018) also suggests that the Local Highway Authority may be liable for the maintenance of the surface over the two new footbridges. KCC requests confirmation that HE will be responsible for the structures in their entirety. In addition, KCC proposes that HE should be the operators and maintainers of the adjacent sections of the A20, including the Swatfield Bridge, that it will strengthen as part of this proposal. The increase in traffic here will be very significant and is appropriate that HE takes responsibility for such infrastructure. It is understood that the new A2070 link from 10a down towards Church Road will be part of the strategic trunk road network and therefore, for HE to manage. KCC is aware that there have been a large number of complaints about potential HGV movements along Highfield Lane. It has been stated before that this lane should be closed and a turning area provided, but HE has not acknowledged this as being part of their responsibility. KCC’s view is that this is not a local road network issue, and rather that residents/parish concerns should be addressed by HE and that HE should provide both the closure and turning area as part of the scheme. In respect of street lighting, clear ownership will need to be identified. Issues around ownership, access and shared networks need to be established with HE in order to prevent future maintenance problems. KCC would seek confirmation from HE that lighting will be under the ownership of HE so that there will be no impact on KCC street lighting and maintenance issues. The DCO draft (APP-018) at Part 2, Section 8, gives a 1m limit of deviation, the consequences of which will need to be considered and clarification is sought as to whether these limits have been covered in the Environmental Statement. Further discussions between KCC Asset Managers and HE will be required to resolve these outstanding matters. Public Rights of Way The General Arrangement Plans still refer to the Kingsford Street Bridge (APP-010, sheet 2 of 4) as a footbridge (without an equestrian access), so KCC would like to see evidence of how this has been arrived at through the design stage process. The proposed drawings for Public Rights of Way (PRoW) extinguishments are as expected and requested. The only other concern is in relation to the retained PRoW connections to the south side of the new A2070 access road, shown on the Rights of Way and Access Plans 03 and 04 (APP-008). There appear to be level changes and drainage channels that would prevent access to the new footway/cycleway. Access points and suitable ramps and access will be required to connect the retained Footpaths AE337A and AE338. Cultural Heritage In summary, the assessment of Cultural Heritage issues is reasonable. In addition to the points raised below, further detailed comments are provided in Appendix A. There is potential for the scheme to impact on prehistoric, Roman, Early Medieval and Medieval remains which may be considered of greater importance than “low local value” only. The evaluation work so far is too limited to suggest there are no significant remains within the scheme area. The designated milestone (HA no: 1276471) (Table 6.5, p 16 and p18, APP-034) should not be excluded from mitigation solely on the basis only of a site visit made in 13 October 2014 (para. 6.7.15, APP-034). Archaeological mitigation needs to be integrated into all aspects of the scheme, including the initial enabling works, ecological and drainage works. Assessment of St Mary’s Church should reflect the complexity of its significance and be more detailed. Historic England has noted that there is likely to be considerable harm from the proposed Stour Park scheme but that suitable mitigation measures for both schemes could reduce the level of harm (APP-199 and APP-043, page 13, 14/00906/AS). Mitigation for St Mary’s Church needs to be agreed with Historic England. HE needs to put forward a meaningful construction programme with mechanisms in place to ensure archaeological mitigation is suitably dealt with, including County Archaeologist sign off of detailed mitigation and agreement of post-excavation works. Biodiversity KCC is satisfied that HE’s ecologists have a sound understanding of what species and habitats are present and what mitigation is required. However, there is a need to ensure that the time to create/enhance the habitat for the required mitigation is factored in to the development timetable. This will ensure that development works are not delayed waiting for habitat to establish before the mitigation is implemented, nor that substandard mitigation is carried out at the risk of the mitigation being unsuccessful (e.g. species dying as there is not sufficient food to support them). Habitat enhancements should be carried out as soon as possible to give them sufficient time to establish. For instance, it is noted that the dormouse mitigation is proposing to create a dormouse feeding station; this can only be a short-term mitigation measure, and long-term habitats must be created that provide suitable foraging habitat for dormouse. Measures must be in place to ensure the feeding station is stocked up for as long as required. To address this and wider concerns about the timetable for such works, it is suggested that a timetable is produced, clearly setting out the programme for the proposed habitat enhancements/creation and species/habitat mitigation. This will ensure the development timetable can be designed accordingly. In respect of long-term management, there is a need to ensure that the created/enhanced management is managed long-term to ensure that the mitigation will be successful. This means either changing long-term management plans for HE land or ensuring landowners (where enhancements will be carried out) can, and are willing to, manage the habitat appropriately. For example, the receptor site for reptiles is proposed to be located on the London Bound M20 Highways verge which is currently unsuitable for reptiles (as it is regularly cut), so there is a need to ensure that the maintenance team understands that the management of this area has changed. It is also worth noting that there are other developments being delivered or proposed within this area. The ecologists for the M20 J10A application should ensure they are aware of any developments within the surrounding area to confirm the mitigation proposed remains suitable; there may be a need to tweak / change the mitigation due to other works being carried out within the immediate area. Lead Local Flood Authority KCC has reviewed the flood risk assessments and drainage strategy information and is generally satisfied with the proposals for the management of surface water generated by the scheme. ________________________________________ KCC is supportive of the proposed new junction and the positive contribution that it will make towards the growth agenda of the Borough Council. KCC looks forward to working with ABC and HE as the project process progresses and will welcome the opportunity to comment on matters of detail in the Examination. Should you require any additional information or clarification, please do not hesitate to contact me. Yours sincerely, Katie Stewart Director - Environment, Planning and Enforcement ? Appendix A In relation to cultural heritage, set out below are more detailed comments on specific sections of the application details: 1. 6.7.8 – milestone (MM43) – a Listed Grade II milestone not identified on site. May be buried and needs to be looked for more robustly. It was observed and listed in 1989 so there needs to be assessment as to what might have happened to it. 6.7.17 suggests that as the milestone was not observed during a site walkover it must have been removed or misallocated. However, October would still be a time of high vegetation cover and a small object could easily be buried. It should not be assumed that it is no longer present. Suggestion that it is premature to state in Table 6.8 and paragraph 6.11.3 that this asset is missing and therefore does not require any mitigation. Recommendation that this designated asset is still subject to mitigation until it is definitively clarified whether it survives on site or not. 2. 6.7.12 – need to check the visible impact on Lacton Green Conservation Area, 150m north of scheme boundary. Robust consideration is needed in view of scale and height of new roundabout and possible increased traffic flows. 3. 6.7.13 – Hatton Park should be Hatch Park. 4. 6.7.13 – a designated heritage asset is generally considered to be of national importance. Disagrees with the Cultural Heritage assessment which suggests that some designated heritage assets, such as Hatch Park parkland, can be of “High regional value”. 5. 6.7.30 should highlight that the scheme area has only been partially evaluated. Many of the trenches were not excavated, partly due to ecological constraints. As such, there are areas north of St Mary’s Church, which will be impacted by both the scheme and by the proposed site compound, which have not been reasonably evaluated. Further archaeological evaluation of this area ahead of initial scheme works is essential. 6. 6.8.6 – the prehistoric background data is fine but there have been some more recent findings from Ashford Orbital Park including 3 Iron Age funerary enclosures (Oxford Archaeology East 2015). 7. 6.8.13 and 6.8.14 – there is no mention of a Lime kiln and its associated quarry which are identifiable on the 1st Ed OS map immediately north of the new motorway roundabout. It is not clear whether this post medieval structure is within the scheme or not but recommendation that some assessment of this feature is required to ensure suitable assessment and mitigation if necessary. 8. 6.8.19 – assessment of importance level of Palaeolithic remains is debateable. Palaeolithic remains are so rare that they are generally considered to be of importance, subject to their context. It should also be noted that river valleys, including the Aylesford Stream one, were favourable areas for prehistoric activity. This valley could also have high potential for palaeo-environmental evidence which could provide valuable information on the development of the stream in relation to the River Stour and the local environment during the Prehistoric and later periods. Palaeo-environmental evaluation and assessment would need to be fully integrated into the formal programme of archaeological works. 9. 6.8.20 – Disagree with the assessment that the scheme is likely to only contain prehistoric or Roman features of “Low local value”. The archaeological fieldwork so far has been minimal and there was evidence of prehistoric activity. There is potential for this scheme to have an impact on archaeology of greater significance than “low local value”. 10. 6.8.21 – Disagree with the assessment that the scheme is likely to contain early medieval or medieval remains of “low local value”. Early medieval remains are not common and in view of the proximity of St Marys Church Sevington and Court Lodge, suggestion that there is reasonable potential for remains which may be of greater significance than “low local value”. 11. 6.8.19 The Archaeological Potential and Value Assessment does not provide reasonable statement of significance for St Mary’s Church Sevington. St Mary’s Church is a significant and complex archaeological and historic site and there is potential for the scheme to impact on remains directly associated with this asset as well as on its setting and character. As such, there needs to be a robust assessment of this designated heritage asset dealing with all areas of significance and value. Mitigation needs to be clearly informed and evidence-based. 12. 6.8.19 and vol 6.3 App 15.1 - The comments from Historic England submitted with the application details are noted, although it is focused on the proposed industrial development off Highfield Lane. HE’s comments repeat the concerns over the level of harm to St Mary’s Church and consider it is “substantial” but that mitigation could effectively reduce the level of harm. In view of this, there is a need for this Highways England scheme to also ensure that mitigation measures for St Mary’s church are robust and agreed with Historic England. 13. 6.9 Mitigation and Compensation Measures need to be more robust. Mitigation for heritage needs to be scheduled well in advance of construction work and integrated into every aspect of the scheme, including site compound set up, landscaping, drainage schemes etc. If there are intentions to undertake geotechnical work, especially along the Aylesford Stream area, it would be advantageous to include archaeological palaeo-environmental work. 14. Fig. 6.2 (volume 6.2) Non Designated Assets drawing does not indicate the presence of known archaeological remains within the scheme area or within the study area, as suggested by the Archaeological Evaluation of Land West of Highfield Lane and by the Geophysical Survey. 15. Cannot not find any appendices for heritage assessment including copies of the evaluation report and the geophysical survey report. These reports need to be consulted as part of this scheme and should be available. 16. There seemed to be only two figures showing heritage assets and areas. This is a bit limited and it would be helpful to have more detailed Cultural Heritage figures, especially ones showing areas of impact on known heritage assets. "
Members of the Public/Businesses
Public Health England
" 1) PHE notes that the applicant has provided a health impact assessment navigation document (Appendix 4.3 Volume 6.3) within the Environmental Statement (ES). We consider that the public health impacts likely to arise from the development on air, land and water have been adequately considered in the related sections of the submission. We note that the scheme crosses or passes close to several sites which may be contaminated by historical activities. Whilst the main risk is posed to workers on-site, we expect that any works on areas of potentially contaminated land should be with the agreement of the Local Authority and Environment Agency such that it will not lead to off-site impacts on receptors. The proposer’s air quality assessment is dependent on a number of assumptions, for example related to traffic flows and traffic emissions, and our review is based on the assumption that the traffic modelling undertaken is both robust and validated. The proposer’s air quality assessment indicates that concentrations of nitrogen dioxide (NO2) are predicted to exceed air quality standards with or without the Scheme at some locations in the study area. However, the proposer states that no exceedances are predicted to be caused by the Scheme and any changes in NO2 concentrations are predicted to be imperceptible. It is unclear if the proposer intends to undertake air quality monitoring once operational to verify the assessments. 2) The majority of the potential impacts on public health during the construction phase will be controlled by the implementation of a suitable and sufficient Construction and Environmental Management Plan (CEMP). PHE requests that, prior to the issuing of a Development Consent Order (DCO), the Planning Inspector confirms that both the Environment Agency and Local Authority are satisfied with the proposals for control, mitigation and monitoring contained within the CEMP or equivalent document. 3) On the basis of the submitted documentation PHE does not envisage any significant further involvement in the development consent process but requests that we be notified and consulted should there be any significant changes to the currently submitted proposals or should any public health concerns be raised by a third party. 4) PHE reserves the right to make additional comments or observations at a future date. "
Members of the Public/Businesses
Southern Gas Networks PLC
"Southern Gas Networks PLC (“SGN”) is a statutory undertaker, responsible for the management of a network of gas apparatus that is used to distribute gas to 5.8 million homes and businesses across Scotland and the south of England. SGN is responsible for the safe and reliable operation of the said network and as such must ensure that the said network is not adversely impacted by Highways England’s construction project known as M20 Junction 10a (“the Project”). SGN is prepared to discuss the terms of the Project with Highways England with a view to ensuring its successful delivery. However, SGN wishes to make it clear that its agreement, to the terms of the Project, can only be granted on the condition that Highways England provides SGN with an assurance that the safety and integrity of the network, operated by SGN, will not be adversely affected by the Project. In particular SGN wishes to make it known to Highways England that the Project encroaches into land under which a Major Accident Hazard Pipeline (“the Existing Utility”) is situated and that as a result SGN expects Highways England to take all necessary measures to ensure that the Existing Utility is properly protected prior to the implementation of any works associated with the Project. Please note that ‘all necessary measures’ extends to SGN being provided, by Highway England and at Highway England’s sole cost, with all the necessary land, and ancillary rights, that SGN might reasonably require in order that they might divert the Existing Utility to an area unaffected by the Project. "
Members of the Public/Businesses
Stuart John Ramsay
"In respect of this planning my issues surrounding the building of Jct10a are not limited to but include the following. My property is both residential and a working kennel and cattery business which has served the local community for well over 35 years of which the last 10 years has been in my hands. Any land to be compulsory purchased from me could mean the end of my business in its current form as I may not be able to operate to a level required in todays world as my storage facilities, exercise areas to name just two things could be reduced to a level rendering me unable to operate. The road lay out also causes issues and customers would then have to drive through Mersham and onto Kingsford Street from the far end causing an increase in traffic through the village which in the height of my busy period could cause more issues. The related noise, dust and overall up disruption will also deter people from bringing their animals to me for boarding as the building work is literally a stones throw away. My property is also Grade II listed, dates back to the 1600's and is well known and documented as a part of local smugglers gang the "Ransley's". The property has remained largely undeveloped and therefore to build this so close to cause blight and reduce its appeal should be avoided at all costs. I hope these points will be taken into consideration on examination. "
Members of the Public/Businesses
Savills on behalf of Wyevale Garden Centres Limited
"WYEVALE GARDEN CENTRE, HYTHE ROAD, WILLESBOROUGH, ASHFORD, KENT, TN24 0NE PROPOSED M20 JUNCTION 10 IMPROVEMENT On behalf of our client Wyevale Garden Centres Holdings Limited (Wyevale), Savills wish to make a representation to the proposed M20 Junction 10a improvement consultation. Wyevale own the freehold title in Wyevale Garden Centre, Hythe Road, Willesborough, Ashford, Kent, TN24 0NE (the Property). The Property is situated on Hythe Road, located between the M20 and A20 approximately 750m from Junction 10 of the M20. The Wyevale Garden Centre has been operating a successful and profitable business at the Property since 1952 trading gardening and household goods to the local community and beyond. Wyevale enjoys the loyalty of many returning customers along with passing trade due to its prime location as a result of its proximity to Ashford, the M20 and the A20. The Garden Centre also provides employment for thirteen people within the area, jobs which may be lost if the Garden Centre is forced to close as a result of the road proposals. The Garden Centre is very conveniently located along the A20 and is highly accessible for customers from a wide area. The creation of an enjoyable shopping experience with a wide range of products for both the garden and in the house, in a well laid out centre is an important element in the attraction of the site. The preferred option application for a DCO has been submitted and accepted by the Planning inspectorate. This scheme proposes to construct a new, partially signalised junction 10a with two 3 lane bridges on the M20 and link road to the A2070 at Ashford as well as connections to A20 Hythe Road. This option will result in the proposed new junction being located directly where the Property is situated currently. It will not be possible for Wyevale to continue their operation on the site. Objection Our clients oppose the current application on the following grounds: 1. The application, if approved, will result in the removal of our Client’s business at the Property and the loss of this valuable trading site. 2. It will also result in the loss of a number of other businesses on the site. 3. A consequence of this may be significant loss of employment in the area. 4. The closure of the Garden Centre is likely to reduce shopping capacity in the locale. 5. The number of shoppers and visitors to the area may decline. 6. Whilst or clients have responded to the formal consultations produced by Highways England, there has been no dialog with Highways England, as they have not responded to our consultation responses. Thus the “consultation” has been somewhat one sided. 7. If the DCO is confirmed, it is not certain, from the plans submitted that Highways England intend to take the whole of our client’s site permanently. Certainly, parts of property in our client’s ownership are scheduled to be acquired temporarily. As it will not be possible to continue trading from the site after the works, we will be seeking to ensure that all of our client’s land holding at this location is acquired permanently. 8. It is not clear whether the approach of providing a multiple option application for a DCO was envisaged under the Planning Act 2008, nor whether this is therefore a lawful application by Highways England. We therefore reserve the right to challenge this approach to the application and the Planning Inspectorate’s acceptance of the application in the future. Our client’s therefore intend to oppose the daft Development Consent Order which seeks to confer compulsory purchase powers and rights to acquire an interest in our Client’s Property as set out above. We reserve the right to alter, enlarge, modify or withdraw this submission in the future and at any hearing in relation to the Development Consent Order. R W Asher Director Savills 33 Margaret Street, London, W1G 0DJ On behalf of Wyevale Garden Centres Ltd "