Application Number: 22/503259/SUB
Address: Cleve Hill Solar Park Cleve Hill Graveney Kent ME13 9EE
Proposal: Submission of Details to Discharge Requirement 12 of The Cleve Hill Solar Park Order
2020 - Construction Traffic Management Plan
Case Officer: Terry Hardwick
Faversham Society Comments
We have multiple objections
We strongly support Graveney Rural Environment Action Team’s (GREAT) objections
“The negative impact the construction of this development will have on local villagers is not recognised or respected in the Plan. There is great concern, anxiety and resentment about the impact of the amount of traffic, dust, dirt, noise, pollution and potential structural damage as these have been largely ignored in the Plan.”
We support all the points made in GREAT’s submission. The developers should be required to:
The submission made by Mrs King on behalf of GREAT points out that the “Plan is based on assumptions and inaccurate data which calls into question its validity.”
We share the concerns expressed in detail in Mr Wilcox’s objection to the way in which the original submitted CTMP has been amended. This “appears to be cost-cutting, which is of benefit to the applicant, without any benefits to the community. The result is a plan that is substantially different from that provided for the DCO and therefore is not in accord with that plan.”
Monday to Friday 06:00 to 20:00 Saturday 06:00 to 14:00 including contractor requirement of “a period of up to one hour before and up to one hour after core working hours for start-up and closedown of activities (5.3.2). This is confirmed in para 6.6.1.
Access by sea
We note that 2.6.3 “abnormal loads will be transported to the UK by sea and transported to the site by road”
2.6.7 refers to abnormal loads being moved at night and that “agreement with relevant stakeholders will be sought prior to any abnormal load movement being undertaken.”
Compliance and Complaints
There is no detail on non-compliance guidance and complaints procedure in 6.16. This should be required to ensure enforcement. See below.
6.4.4 “It is proposed that CHSP will not accept HGV deliveries to site or let HGVs leave the site between the hours of 08.30 to 09.30 and 15.00 to 16.00 to avoid Graveney Primary School start/finish times. CHSP will ensure this is added to the contracts with its contractors.”
HGVs will disrupt lessons and playtime and pose a hazard for children and parents crossing the road. Why cannot HGVs and traffic arrive at the site via Monkshill Rd and Brook Bridge?
Figure 14.1 show a construction route east of the site past the Sportsman towards Seasalter.
6.5.1 All vehicles used in the construction of the solar park will be to Euro standard IV class.
Volume of Movements
2.7.2 “up to 80 two-way HGV movements (40 vehicles) will be required per day.
As is pointed out in 4.2.17 the roads are already used by large vehicles accessing farms and there is a removal business with large vehicles located on the access road network. The Construction Traffic Management Plan glosses over the issues: “4.2.17 Vehicles will be required to give way to each other in these locations as currently occurs.”
There is reference in Table 4.1 to “Contractor briefing, speed restrictions and signage.”
There is a reference in “6.8.2 Staff will be trained to conduct this monitoring process, collect and collate data and present the data for the Transport Co-ordinator (TCO) and Traffic Management Group (TMG).”
In 7.4.2 “CHSP will agree with appropriate stakeholders to ensure that a complaints management procedure is in place prior to the start of construction.”
Public Rights of Way
It is not clear that the changes in the “Hierarchy of Road Users” in the revised Highway Code have been taken into account in the CTMP.
3.1.2 proposes managed and full closures of PRoWs.
Solar Cycle Way
Given the extent of residential development currently in the pipeline, the likely rate of traffic growth in Faversham will not be sustainable. The Town faces worsening congestion, visual intrusion, loss of heritage townscape, pollution, noise, dirt, and accident risk. At present, the Town is hoping to tackle the problem via three major schemes all of which attempt, among other things, to re-distribute travel demand away from the private car in favour of ‘active travel’ (cycling and walking) together with public transport:
(i) the ‘20’s Plenty’ area-wide speed limit,
(ii) the Local Cycling and Walking Infrastructure Plan (LCWIP), and
(iii) the emerging Neighbourhood Plan.
The proposed Solar Cycleway through the Cleve Hill Solar power station would contribute positively to all three. As it happens, the SUSTRANS National Cycling Route 1 passes through the area, and while a significant part of the route eastbound towards Whitstable lies off-road along the Creek and through Sandbanks, it re-joins the Seasalter Road at Graveney. Conditions for walking and cycling from that point on to Whitstable are less than ideal and will be considerably worse once the construction of the power station begins.
The Faversham Society strongly opposes the power station project itself but recognises, should it go ahead, that there are potential advantages to incorporating a well-designed walking route and cycleway into the scheme. The key benefits are:
- promotion of public health,
- supporting action to combat climate change,
- Increasing public awareness that travel choice needs to shift away from the private car,
- improvement to an existing national cycle route,
- reducing pedestrian and cycle casualties,
- adding to the attractiveness of Faversham as a destination for walkers and cyclists,
- raising awareness of the natural environment in the Graveney area.
The Society disagrees, however, with the proposal to run the cycleway through land that is designated in the Cleve Hill scheme for wildlife conservation rather than solar power station infrastructure. The cycleway would bring with it increased pedestrian traffic, including dog walkers, whose passage would have an inevitable negative impact on wildlife, especially ground-nesting birds. As a result, we welcome the proposal on the condition that the cycleway is routed through land that is designated for solar power station infrastructure in CHSP plans, not for wildlife conservation. It is unlikely to progress without a feasibility study, and a successful initiative should involve multiple stakeholders including Sustrans, local authorities, and Kent Wildlife Trust as well as the developer of the power station.