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.
Objection:
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.
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:
