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:

1. Carry out a detailed traffic modelling exercise using industry-standard simulation software such as SATURN to enable a realistic impact of the development traffic to be made. The business user data which is significant has so far been ignored and should be included.
2. Carry out a road safety audit of all key sites where the increase in HGV construction traffic is likely to alter the risk to existing users of the local road network, especially pedestrians and cyclists.
3. Reduce the speed along the whole of the route to 20 miles per hour, in line with the London Array arrangements.
4. Schedule the meetings of the Travel Management Group on a fortnightly basis rather than twice a year.
5. Introduce further restrictions and monitoring in critical areas such as the railway bridge.
6. Have regular meetings with businesses, The Parish Council, residents or GREAT. This is a requirement of the new Energy Strategy for developers and this has as yet not happened with the new developers.
7. Recognize the negative impacts of the development and the Solar Farm itself by providing yearly grants for the duration of the life of the Solar Park to enable the Graveney and Goodnestone communities to invest in their villages.
8. Fund the wider community need for the Faversham Community Corridor.
9. Develop an emergency evacuation plan detailing the involvement of Kent Police, the Ambulance Service and Kent Fire & Rescue. Kent Police should also be consulted on crime and security arrangements.
10. Make arrangements for suitable public highway passing places and HGV waiting areas. Provide more information on the duration of the development - is this for 2 or 3 years?
11. The Plan states that the daily peak traffic volumes quoted in the original submission will not be exceeded but the peak durations have been deleted. These need to be made transparent. This should also include the shift patterns.
12. The developers need to show how air quality will be affected by the development itself as well as the construction and personnel transport. A detailed air quality impact assessment is needed so that residents are able to judge whether thresholds for air quality are exceeded and take the appropriate action.
13. The developers need to show how much noise is generated by the development itself and the construction and personnel transport. A detailed noise impact assessment is needed so that residents are able to judge whether thresholds for noise are exceeded and take the appropriate action.
14. The new developers claim that their prime concern is the environment - therefore the use of a minimum of 30 % of electric vehicles should be included in the Plan.

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.”

Working Hours
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.

• This amounts to an excessive 144 hours per week of disturbance from traffic movements.

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”

• The abnormal loads, solar panels and construction materials should arrive by sea at the site to reduce traffic to acceptable levels.

Abnormal Loads

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.”

• The “relevant stakeholders” and process need to be defined.
• There are too many get-out clauses in 6.77 “where possible” and “where applicable” – these should be removed.

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.

Graveney School

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.”

• How will this restriction be enforced? Cameras to monitor numbers, time of day and speed are essential.

Construction Routes

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.

• There should be no consent for construction traffic to go further east beyond the entrance to the site, .

HGV Emissions

6.5.1 All vehicles used in the construction of the solar park will be to Euro standard IV class.

• How will this be enforced with independent oversight?

Volume of Movements
2.7.2 “up to 80 two-way HGV movements (40 vehicles) will be required per day.

• There are to be up to 400 construction staff based on site.  How many vehicle movements will this generate and at what times?

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.”

• To whom will complaints of non-compliance and excessive speed be made and enforcement action taken? Where will it be possible to appeal if the site management does not take action?

Enforcement

• How will monitoring and enforcement be applied? In our view, Swale/KCC should install cameras to monitor vehicle movements (night & day) and enforce any planning consent granted.

There is reference in Table 4.1 to “Contractor briefing, speed restrictions and signage.”

• How is this to be enforced?
• Speed cameras should monitor driver behaviour and speed on the access road network day and night.
• Has consideration been given to enforcing speed limits on the access roads?

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).”

• But no provision for independent oversight on behalf of the community.
• Similarly, there should be independent oversight of the Delivery Management Systems (DMS) (6.15.1)
• We note with concern that there is no independent oversight of the Management Structure described in 7. In 7.4.1 there is a reference to Actions but they are not defined.

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.” 

• Appropriate stakeholders are not defined and there is no provision for effective independent oversight of CHSP.
• In 7.6, relevant stakeholders are identified as KCC & NH – there is no reference to Swale or Graveney councils.

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.

• Full closure of these popular PRoWs is unacceptable.
• PRoW ZR 692 needs to be maintained and upgraded to provide a safe walking route east from Faversham.
• There should be no interference with the England Coastal Path.

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.