Friday, 12 July 2013

Objection to Dover District Council (DDC) Core Strategy 2013

The following is my representation to the Dover District Council objecting to the DDC core strategy, which I sent on 6th February 2013.
This representation has been received and accepted by the Planning Office as relevant, therefore not rejected.

I object to the DDC core strategy plans to have around 10,000 new homes built in and around Dover (including Whitfield) in the period to 2026, as the number of proposed houses, if built, would generate at least 10,000 more vehicles moving constantly in and out of Dover, in particular Dover town.

Currently Dover suffers under the influence of heavy air pollution stemming from various sources, among which are:
1. The continuous stream of traffic along Barton Road leading into Dover, Frith Road, Maison Dieu Road, Pencester Road, part of Biggin Street in the town centre, Priory Street, London Road (town centre) and Folkestone Road. As well as along Tower Hamlets Road.
2. The port traffic transiting along Townwall Street and Snargate Street.
3. The constant pollution coming from ferries operating at Eastern Docks.
  1. Pollution coming across the Strait of Dover from Europe.
I am of the opinion that no consideration has been given to any proper air assessment in Dover, and that the 2008 DDC core strategy does not even take into account the existing levels of air pollution, let alone the inconvenience that would arise from the traffic ensuing from the building of around 10,000 more homes.
Many of Dover's schools, in fact even all of them, are situated in the immediate vicinity of roads with very high levels of chemical substances deriving from passing traffic.

Furthermore I am of the opinion that DDC has not properly and adequately informed Dover's residents of the very high risk to personal health caused by the high levels of chemical particles present in the air, and that, were the residents to be made aware of these unacceptable levels, the opposition to the core strategy would be far greater than it already has been.

In conclusion, I am of the opinion that DDC has downplayed the combined dangers to personal health caused by air pollution from local through-traffic, port activity and factory pollution from Europe, and that the building of almost 10,000 more homes in the Dover area would generate a significant increase in traffic heading in and out of Dover, which would bring on greater stress and a greater health risk to Dover's residents.

Therefore I ask Dover District Council to review the core strategy and implement a proper public consultation with due reference to health risks deriving both from existing levels of air pollution and from any future increase owing to more road traffic passing into Dover.

Adding to the present outlay of my representation, I further wish to point out that Dover Harbour Board has received permission from the Government to build a new ferry terminal at Western Docks, and that DHB's declared intentions are to build a terminal designed for road traffic, with an envisaged increase in car and lorry traffic of 70% passing through Dover over the coming 25 years.

Although in my representations to the Department for Transport (2010-2012) I have outlined the necessity for this new ferry terminal to be designed for rail traffic on account of Britain's carbon emission laws, there is as yet no indication from the DfT that my proposal has been accepted.

Following is some research data relevant to this representation:
From NHS Choices, April 23rd 2012:
Air pollution from exhaust fumes kills more than twice as many people as road accidents,” The Daily Telegraph has reported. The paper said that around 1,850 people die in traffic accidents annually, but that each year over 5,000 people will die as a result of heart attacks and lung cancer caused by vehicle exhaust fumes.
These estimates are based on a study that modeled the levels of pollution across the UK and predicted its impact on premature deaths. The study combined UK and EU emissions data with models of weather and the ways in which chemicals disperse. This allowed researchers to estimate the impact of pollution across the UK. According to the model, pollution from overall UK combustion emissions causes approximately 13,000 premature deaths a year, with road transport being the biggest source.
A further 6,000 deaths are estimated to be due to European Union emissions produced outside the UK.
The study was carried out by researchers from the Massachusetts Institute of Technology and was funded by the UK Engineering and Physical Sciences Research Council. The study was published in the journal Environmental Science and Technology.
The research was covered accurately in the newspapers.”

As can be seen from the data provided in the research and published on the NHS Choices website, air pollution in its various forms may account for 19,000 premature deaths every year in the United Kingdom.
As stated in the above points in my representation, Dover is massively exposed to all these factors: exhaust fumes from cars, from lorries and from ferries, and emissions from the European Union produced outside the UK.

Due to Dover's vicinity to the Continent, emissions from Europe are likely to affect Dover significantly more than other areas of Britain.
The building of around 10,000 new homes in the Dover area, or even just of several thousand new homes, combined with the prospect of a new ferry terminal designed to service an increase in road traffic from port activities, would drastically increase the health risk of Dover's residents to unsustainable levels.

Indeed we may assume that residents in Dover town already have a significantly lower life expectancy than residents in the nearby villages owing to our constant and daily exposure to road and port traffic.

In the sincere hope that Dover District Council will uphold my request that the core strategy be re-examined and presented to further Public Consultation on the basis of the points, considerations and research in my representation, I am keeping copy of this representation for any eventual use in future instances of Government involvement in the matter.
Yours sincerely,

D. Alexander

My representation is in response to the following public consultation made public in This Is Kent 02 January 2013:

The Land Allocations Pre-Submission Local Plan identifies and allocates sites suitable for employment, retail and housing. It follows on from the district's Core Strategy blueprint for development until 2026.

The blueprint outlines proposals to build 14,000 homes across the district, with the main concentration at Whitfield, and predictions of creating 6,500 jobs, a population growth of 15,500 and the occupation of 50,000sq m of shopping space.
It also includes proposals for regeneration of the Dover Waterfront, Terminal 2, mid-town, Priory station, Connaught Barracks, Coombe Valley and Aylesham.

Transport, environmental, educational and public utility proposals also form part of the document which was first submitted to the Government for approval in 2008.
The Land Allocations document puts forward some 120 sites in addition to those already earmarked in the Core Strategy.
Sites from Alkham and Capel to Sandwich have been identified as areas where building could take place in the next two decades.

Proposed sites include the Western Heights; Stanhope Road; land between St Richard's Road and Ellens Road in Deal and smaller developments in Staple, Goodnestone and Worth.

Public comments can be made until midnight on February 21. The council will then submit these to the Planning Inspector who will appoint an independent Inspector to oversee an Examination, anticipated to be during summer 2013. The Inspector will recommend changes to the Plan or will reject it. If it is agreed, the council can then adopt it.”

DDC core strategy 2008 and the financial crash:

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