WHY DOES AQMA5 MATTER? WHY IS SBC REVOKING IT??
In Planning Guidance, if you have an AQMA nearby its existence supports arguements against over-development that worsens the situation.
BUT, "nearby" means really close. So, AQMA5 protects us in a way that pointing to either Ospringe or Sittingbourne AQMAs simply wont!
In much the same way, the AQMA6 at Ospringe has a weaker influence as you move east towards the A251 and Brenley Corner.
What is missing is a Planning Authority that takes seriously the legal requirement to protect communities with AQMAs against ANY development that adds "cumulatively" the pollution levels created even at a distance. In other words, if a community is trapped along a piece of straight road (as it is between Faversham and Sittingbourne, ALL new housing of any size MUST add to the cumulative harm calculation and development applications should be rejected.
In short, we cannot avoid (mitigate) pollution created by developments between the A251 and A249. So, NO MORE development this side of the two towns should even be contemplated.
On 20th September 2023 (Sittingbourne News), Rich Lehmann (Green Party) is reported patted himself on the back for an Air Quality Action Plan that includes revoking the protection of AQMA5 as SBC Official Policy. SBC is doing this because, it says, five years of data shows AQMAs in Teynham and East Street, Sittingbourne, are "compliant". Central Government policy advice says that Local Authorities have to be confident that their five-year data is consistent and that future conditions will not get worse.
- On the first point - That five years straddles Covid years, with all the uncertainties that brings. SBC only measure NO2. SBC only use the least accurate and reliable technology (single passive Dispersion Tubes in Teynham/A2 - that have been reduced in numbers over recent years and often missing); SBC has spent years avoiding measuring Particulate Matter (PM2.5) on a real-time basis.
- On the second point - Defra/LAQM advise Local Authorities that even if an AQMA is "compliant", it should NOT be revoked if future conditions might get worse. Their specific example is ... new house-building! I leave you to work out what SBC apparently cannot! More housing leads to more pollution in congestion spots (built-up areas like Teynham/Lynsted on the A2) and Government targets include PM2.5, which SBC is down-playing.
We are being treated as second-class citizens - again.
10th October 2023 - Greenhouse gas emissions - 2022 provisional estimates.
Transport is still the rogue-player (but not the only one) when it comes to how we are damaging our health and the planet. I share this provisional report from the Office of National Statistics as yet more data showing that SBC should adopt a more precautionary approach to abandoning residents as SBC works towards revoking AQMA5.
Main points
- UK greenhouse gas (GHG) emissions on a residence basis increased by 2% between 2021 and 2022 (provisional), having increased 3% in 2021 following the coronavirus (COVID-19) pandemic which particularly affected 2020.
- UK emissions stood at 512 million tonnes of carbon dioxide equivalent (Mt CO2e) in 2022, 7% below the pre-coronavirus pandemic level of 550 Mt CO2e in 2019.
- The sector with the largest increase in UK emissions was transport, up 34% in 2022 compared with 2021, following a fall of 28% in 2020 during the coronavirus pandemic and a 9% decrease in 2021.
- Consumer expenditure remains the largest single contributor to UK emissions, at 25% of total UK GHG emissions in 2022, followed by the energy sector at 16%.
- In 2022, 190 tonnes of Co2e were emitted per million pounds of UK economic activity (gross value added on a residence basis); this is down 67% since 1990.
- The sector with the highest increase in emissions intensity in 2022 was transport, up 20% from 2021.
We refer to residence-based emissions in this release. This is one of three official measures of UK greenhouse gas emissions. Territorial emissions, published by the Department for Energy Security and Net Zero (DESNZ), is the measure used for greenhouse gas emissions targets. Footprint emissions, published by the Department for Environment, Food and Rural Affairs (DEFRA), account for emissions from trade.
We are being treated as second-class citizens - again.
A2 POLLUTION SOURCES INCREASING
15,691 Vehicles per day (July 2022) - up from 14,001 (2019)
Department of Transport (DoT) manual vehicle count on A2 through Teynham/Lynsted
2019 = 14,001 each day (pre-COVID).
24-Hour video was used to update that manual traffic count
between 7.00am, 21st July and 06.59am, 22nd July 2022.
15,691 Vehicles counted manually over 24 hours. [PDF]
DoT Guidance: manual counts should be recorded on video and take place
on weekdays, avoiding public holidays and school holidays.
If you want to do your own 24-hour manual counts of traffic
along Station Road and Lower Road here are some ideas on how to manage it
(PDF)
Professor Whitty - Chief Medical Officer
published his Annual Report on Air Pollution
(8th December 2022).
There really cannot be any doubt that the A2 between Sittingbourne and Ospringe/Faversham should NOT have any further burdens from estate building.
I have linked to the Press Release, the Executive Summary, and the Full Report.
The Lynsted with Kingsdown Parish Council Response can be downloaded with this link
Teynham Area of Opportunity Website, Regulation 18 Update
This excellent resource will provide the starting point whenever SBC kicks us again.
Summary Submission to REG18 - The 2021 Battle with Swale Borough Council's madcap schemes.
In case this submission from Nigel Heriz-Smith helps understand the structure of the Reg18 and the key Questions relevant to Swale Borough Council's determination to force Teynham
Area of Opportunity on our communities. SBC's fall-back position in Reg18 is simply to allocate housing on the same plots with the same destructive impact on us. SBC has simply ignored 30% of all comments in Reg19 - disgustingly self-serving and unaccountable.
WHAT IS SWALE BOROUGH COUNCIL (SBC) DOING TO US?
- Devious Swale Borough Council has to be 'called out'.
- Early in 2021, Swale Borough Council (SBC) tried to sneak their Reg19 Local Plan past us all by launching a very short-consultation period for the Reg19 rush to Publication of their shoddy Draft Local Plan.
- On 27th November, SBC has done exactly the same thing, but this time only giving us four weeks to respond to an entirely new Regulation 18 consultation on "Issues and Preferred Options".
In both cases, SBC has deliberately fired the starting gun without advertising the fact and without any support across the whole Borough! They have no shame and we have every reason to be outraged at the level of contempt being show for Swale residents and businesses.
Here is a link to the Consultation Portal - if you are not already signed up to SBC Portal, it is very easy to do before you can comment. - Here is a link to the excellent Lynsted with Kingsdown Parish Council detailed response to help you understand aspects of the WHOLE consultation. Definitely worth dipping into for good ideas and 'planning relevant' language.
- Lynsted with Kingdown Parish Council Newsletter to every home in the Parish - download a copy.
- The Action Group website has been updated- it contains clear key arguments intended to help us all to focus on which of the 42 Questions are most important in our defence against our hostile Borough Council dumping housing around us. Those were Question 25, 24. 10, and 6. Do visit the website.
- Early in 2021, Swale Borough Council (SBC) tried to sneak their Reg19 Local Plan past us all by launching a very short-consultation period for the Reg19 rush to Publication of their shoddy Draft Local Plan.
- The Importance of Working Together.
- Early in 2021, it took a huge effort from Residents to win the argument against the Regulation 19 Draft Local Plan.
- Very nearly 30% of all the comments made across the whole Reg19 Consultation opposed the Teynham Area of Opportunity (TAO). That is 750 public statements made against TAO and yet SBC's Rebooted Regulation 18 (Reg18) peddled the same idea as part of their "preferred option (Option 3)". Deaf or stupid - I leave you to decide?
So, what can we do in case the 'zombie' proposals hit us again?
- Dust off your objections to TAO under the Reg19 consultation that we managed to overturn. Nearly 240 of you objected to the Teynham Area of Opportunity (TAO) in the "Reg19" consultation and all of you can just dust off those comments, tidy up any old cross-references in Reg19 (2021) and Reg18 (2022). Simples!.
- It really is that straightforward if you are short of time - we all are! But as soon as we hear the Starting Pistol, we will kick into gear to alert as many households as possible across the whole Ward.
- Of course, you can add further comments if you have time. A very good place to start is the detailed Response from Lynsted with Kingsdown Parish Council (11th November 2021) - whether you agree or disagree with the points.
No doubt each Parish Council will engage as they have done already.
- SBC Smokescreen and attempt to force TAO on us, even after we saw them off the first time. SBC have no conscience.
- SBC clings to the belief that their Reg19 Local Plan (2021) was "sound" - they argue that SBC had to reboot the Local Plan Review because of a technical change in the National Planning Policy Framework (NPPF) about "large developments" and a vague reference to the impacts of COVID (no-one knows how that will play out and it is NOT a planning policy issue!)
If NPPF was really the reason for jumping ship, SBC should have drafted what is known as a "Major Modification". But that is not what happened. So, NPPF changes is a busted flush of an argument. - It was residents' actions that blocked a terrible and damaging plan for an Area of Opportunity around Teynham and Lynsted that had no justification. Today, we know what SBC are up to:
- A bypass paid for by huge housing plans in the worst possible place.
- A place that is the furthest from the motorway and trunk road systems.
- A place that has experienced a steady decline in services and resources so that we have to use cars to meet our daily needs. May 2022 saw the public announcement that we will lose our last GP practice - the NHS only permits new GP surgeries in towns. So, the definition of "Teynham" as a service centre has just failed.
- A place that would lose safe and quiet cul-de-sacs.
- A place that is already suffering from harmful pollution that drags us down every day whether you live on the A2 or within one kilometre north or south. Spare a thought for Ospringe and Bapchild too - we share their pain.
- SBC clings to the belief that their Reg19 Local Plan (2021) was "sound" - they argue that SBC had to reboot the Local Plan Review because of a technical change in the National Planning Policy Framework (NPPF) about "large developments" and a vague reference to the impacts of COVID (no-one knows how that will play out and it is NOT a planning policy issue!)
- SBC's "Race to the bottom". Instead of accepting responsibility for their own poor decisions, SBC uses another smokescreen - "The Local Plan process was worse under the terrible Conservative Administration"!
- What if that accusation is true? That has nothing to do with the poor quality of decisions being made TODAY in our name by the Local Plan Panel and most of the Cabinet Councillors who want to bury Teynham and Lynsted.
When SBC Councillors argue that "if you think ours is bad, take a look at the previous Administration" - SBC Councillors are in a race to the bottom of levels of care and responsibility for our communities. SBC are trying an old conjurer's trick - look at my left hand while I pick your pocket with my right hand. - We are facing the decisions of our elected representatives TODAY. SBC would rather we ignored THEIR responsibility for their own actions.
- Just for the sake of balance - I believe the Conservative's "vanity project" of promoting a northern and southern relief road around Sittingbourne was totally bonkers and I opposed it under Bearing Fruits. Why are we surprised that developers (like Quinn Estates) have taken encouragement from the mishandling by SBC?
- Frankly, the performance of SBC Councillors has been woefully inadequate and recent shuffling of deck-chairs under their "committee-based" re-organisation shows nothing has changed - nothing that matters in any case.
- What if that accusation is true? That has nothing to do with the poor quality of decisions being made TODAY in our name by the Local Plan Panel and most of the Cabinet Councillors who want to bury Teynham and Lynsted.
HAS SBC LEARNT ANYTHING FROM REG19, OR THE LATEST REG 18?
- Inadequate consultation - there has been no public engagement announcements or supporting public exhibitions to to help us all to get to grips with their arguments in favour of Option 3 (and the TAO that is part of their thinking);
- Late Press Notice misses publication dates. On 3rd November2021, SBC issued a Press Notice that carefully avoided mentioning that the Cabinet decision on 27th October marked the beginning of the Rebooted Reg18 consultation period that ran until 29th November.
Four weeks and counting. - Lack of consistent messaging across the whole Borough through SBC events/exhibitions (again) - rather than rely on local interpretation by Ward and Parish Councillors;
- Policy of Consultation by "discovery" rather than "active engagement" (again). If you don't know to look at SBC's website regularly, you miss your democratic right to respond;
- Exclusion of most Residents from Commenting (again)! You did get a letter (hopefully) from SBC but only if you commented on Reg19 earlier this year. That leaves all other households across Swale finding out by other means... after the Consultation has begun!
The Local Government Association and Planning Advisory Service sets out the 'best practice' standards for all local authorities. Swale Borough Council ignored best practice, no doubt in the hope that we won't notice when they rushed the Reg18 (Issues and Preferred Options) without any regard for national standards of behaviour of local authorities. SBC appears not to understand how to do a good job, so we have to remind them...
Remember, SBC pushed on with the Reg18 Stage earlier in 2022 without having in place key evidence to explain their prejudiced position of "Option 3". There was no traffic modelling, the pollution analysis was out of date, much of their other 'evidence base' was already three years out of date. We were told that we don't need to know the evidence that SBC relies on....
Reg19 'Zombie' Local Plan in 'Autumn' 2022 we must repeat our arguments so we can get them in front of the Government Planning Inspectors, who will understand just how badly residents have been abused since the Spring of 2021.
OTHER THREATS and where to find them...
- Question 10. [LINK] based on paragraphs 5.1.16 to 5.1.25. Proposes "small scale development" in what SBC call "thriving villages" - neither of these terms is defined. So, potentially, 1,400 homes around Teynham and Lynsted parishes could still be permitted - even without a "masterplan" proposed for TAO. Residents demonstrated in the Reg19 exercise earlier this year that Teynham/Greenstreet has been steadily losing businesses and services - many commercial units have been converted to residential or knocked down to make way for housing. Adding significant numbers of homes will not reverse that downward trend as we have become increasingly dependent on cars/vans to meet our 'real world' daily needs and busy lives.
On the evidence of the Reg19 exercise, I don't trust SBC not to sneak their ideas for Teynham as a dumping ground through this ambiguous text and Question 10.
Government statistics confirm that rural communities have higher car and van ownership than anywhere else. Building homes between Faversham and Sittingbourne is guaranteed to be "Building for Cars". The "real world" needs of modern families cannot be met by SBC declarations of 'optimism'. SBC's attempt at 'social engineering' based on the idea of "thriving villages" is a false argument that is fatally flawed - just sugar-coated - Question 24. [LINK] based on paragraphs 5.1.87 to 5.1.96. This is where you can let SBC know what you think of their preferred Option 3.
- Apart from the fact that Option 3 includes TAO, it also argues for a "balanced" or 'fair' approach to sharing the pain. This is emotional and superficial. SBC would rather avoid a strategic analysis of how the whole Swale Borough might be best served in terms of existing utilities infrastructure, centres of employment, access to transport infrastructure (road and rail). Sittingbourne is a natural economic and service hub for all residents of Swale.
- Question 6. [LINK] based on paragraphs 5.1.1 to 5.1.11. You are asked if SBC "should attempt to justify not complying with the Government’s Standard Method for calculating the borough’s housing need figure. As the Chairman of Lynsted with Kingsdown Parish Council reminds us (Facebook - "Stop the Destruction of Kent") - "The Office for National Statistics (ONS) forecasts that the population in Swale will increase by 19,282 people by 2038. The ‘housing requirement’ to 2038 in the Swale Reg 18 document is 16,768 new dwellings. That's an occupancy level per dwelling of 1.15 people. According to ONS, the average household size in England in 2038 is forecast to be 2.28 people – almost exactly double. A population growth of 19,282 would therefore require 8,457 new dwellings. So 16,768 new homes is DOUBLE the number needed to accommodate local population growth. Who exactly is going to occupy half of these new homes? WE MUST CHALLENGE THE TARGETS…!"
If you want the full statistical tables, I can provide them!
Innovation around Facebook. I am instinctively suspicious of Facebook but I have decided to try a Facebook Page in support of this website - https://www.facebook.com/Aqma5a2. My intention (so far) is to share ideas about vocabulary used in planning and pollution. Perhaps also pick on interesting ideas from the news or policy-makers. For those of you who don't 'do' Facebook, I have added a page to this site in which Facebook posts will appear from time to time. Go to my web-page for non-Facebook peeps.
| Contact: nigel@aqma5.co.uk |
