Open letter to local KCC Councillor about likely problems with access to Woodcut Farm warehouse development site.

Hollingbourne Parish Council and other local Parish Councils plus local elected representatives have fought development over the last 25 years at Woodcut Farm in Hollingbourne at Junction 8 of the M20. Some £3 million of public  money has been spent by Kent County Council and Maidstone Borough Council over the years fighting development but on 30th November 2017 Maidstone Borough Council granted planning permission to Roxhill PLC to build a 500,000 square foot development. This was reported at the time at  http://www.hollingbournepc.kentparishes.gov.uk/maidstone-approves-planning-application-for-development-at-woodcut-farm/

An unsuccessful legal challenge was mounted earlier this year by CPRE with support from Hollingbourne Parish Council. Other opponents have included Leeds Castle, Natural England, and local organisations representing thousands of local residents.

Now members of the Bearsted and Thurnham Society are asking local KCC Councillor Shellina Prendergast to pursue the matter of the access to the site from the A20 which may not meet the statutory minimum requirements. It is also suggested that Kent County Council Highways may not have validated the access and traffic impact correctly.

Earlier this week KCC Leader Paul Carter identified the area between Maidstone and Dover as being at risk from major traffic jams after Brexit if the EU leaves the Customs Union and Single Market because of Customs delays at Dover and Eurotunnel. Junction 8 is already frequently congested and the Roxhill warehousing development is expected to make the situation worse especially plus the fact that Junction 8 is at one end of the Operation Brock post Brexit lorry storage area on the coastbound side of the M20 as far as Ashford.

The website of Roxhill PLC is  http://www.roxhill.co.uk/ and they are contributing £10,000 for local tree planting as part of their S.106 contribution to the community (page 19). More details are at  Junction-8-17_502331_OUT-S106_Agreement-4346089.pdf (25 downloads) . “Private Eye” last year reported that Roxhill is under some control of a company in the tax haven of the Cayman Islands. Please see http://www.hollingbournepc.kentparishes.gov.uk/private-eye-report-denied-by-roxhill-developments-limited/

 

The open letter from Robert Sinclair of the Bearsted and Thurnham Society appears below.

Dear Shellina,

As you know, I am very concerned that, in my opinion, KCC has not considered the full implications of the Woodcut development on the A20 and additionally on the surrounding road network, particularly leading to a detrimental effect on Junction 8. It appears that it has simply accepted the applicant’s proposals without really testing them. So, I (along with the rest of the local community) need to be convinced that KCC has done everything correctly and that we are not going to be faced with yet another location experiencing frequent traffic jams in the Maidstone area.

As a local resident it concerns me that KCC only seem to be motivated into action when accidents and congestion occur. I can assure you that Leeds Castle management is worried that future business is likely to be lost if potential problems are not anticipated and dealt with before they arise. It is vital to ensure that there is full transparency as to what the S278 agreement is designed to achieve, and therefore how it is worded. Without this transparency, local residents will inevitably conclude that KCC has not done its job properly. This will result in widespread public dissatisfaction increasing pressure on KCC to correct fundamental mistakes arising out of a flawed S278 agreement, for which KCC (ie. Kent council tax payers) will have to pay!! Surely it must be in everyone’s interests that KCC ensures that the proposals work from the beginning, are safe and are future proofed?

MBC did not bother to challenge the consultation response to ensure that KCC had done its job properly. As far as MBC is concerned, it is KCC’s responsibility. And have passed the buck to KCC to address this aspect of the planning application without any further responsibility?

I respectfully suggest that it would be in everyone’s interests to arrange a meeting with KCC to enable this matter to be discussed openly, and in this regard would like to include Malcolm Kersey who can discuss the technical niceties which are above our pay grade. Residents need to know that KCC has completed its role relating to A20 correctly. If it has not, then now is the time to get it right.

We want to make sure that the mitigation works set out in the Local Plan (referred to below) are written into the S278 agreement. We need to ensure that these works are carried out at the start of the development rather than leave them for later, leaving KCC to finance remedial works at a later stage simply because provision was not made in the design stage.

“4.234 Vehicular access to the site will be taken from the A20 Ashford Road and a Transport Assessment will identify improvements required to the junctions (and associated approaches) at:

• The M20 Junction 8(including the west bound on-slip and merge);
• The A20 Ashford Rd/M20 link road roundabout;
• The A20 Ashford Rd / Penfold Hill Junction;
• The A20 Ashford Rd/ Eyhorne Street/Great Danes Hotel access; and the Willington Street/A20 Ashford Road Junction.”

We anticipate that these road works could take two years. So, addressing the mitigation works at the same time is important. The community is concerned that the mitigation works will be diluted with the net result that the two years of disruption will be extended, resulting in further congestion and disruption, as well as extra cost to Kent tax payers. Junction 7 works are likely to overlap, and therefore this additional stress needs to be considered also.

The comments that I have received focus on whether KCC should obtain a second opinion from an independent expert to ensure that the safety issues have been fully considered. The site entrance will be near to the brow of a hill. As the extracts from Google Street view shows, (in the discussion document attached) visibility is restricted to such an extent that solid white lines are installed to prevent overtaking in this area. If is it not safe to overtake, is it really safe to place a junction in this location, or an uncontrolled pedestrian crossing on the other side of the hill?

It appears that KCC has relied upon the applicant’s expert. This approach will not relieve KCC of the ultimate responsibility if at a later date an Inquiry / Court decides that the margin of error was too narrow. The conclusion may well be that perhaps KCC should not have relaxed the standards. Grenfell Tower was re-clad with materials that complied with out of date building regulations. The current standards are being reviewed because “professionals” see the need. Does KCC have an opinion regarding these standards which might perhaps made them anxious?

In any event, since the use (or uses) of the site are as yet unknown, it makes sense to future proof the access by anticipating a variety of traffic flows in and out of the site. The scheme could extend to 45,295 sq m of accommodation. This is a huge amount of development. An assessment needs to consider the types and quantum of traffic that could be generated from this size of development. This assessment needs to be make certain that potential modifications can be made at the S278 stage to ensure that finance is obtained from the developer, avoiding the risk of having to call upon the public purse, which may or may not have sufficient funding available at a later date when required to implement additional mitigation works.

The improvements to the A20 Ashford Road/Willington Street junction have been removed from an earlier draft S106 agreement, so I am assuming that cost saving for the developer can be utilised to consider in greater detail the junction access. For your information their experts have reported this sum “to be around £60,000.00 for the mitigation works shown on Drawing 15136-01RevA (Appendix K of the Transport Assessment) plus £50,000.00 for the associated retaining wall (based on reinforced masonry with steel fence).”

I understand that KCC was not included as a party to S106 agreement and had no involvement in the negotiations on its content? It is unclear to me why KCC did not insist on being included since it bears ultimate responsibility for highways’ issues. For the record , as a resident, it is very important for us to know that there are no gaps in ensuring that the implementation of this planning approval is progressed correctly. We actually believe that the S278 agreement should be discussed with MBC and they should be able to ensure that it covers matters that as the local planning authority should form part of the application process. We actually consider that MBC and KCC are on the same side and have a statutory responsibility to protect us.

We now have a situation where KCC simply comments on planning applications and even if MBC has an issue MBC appears to take no action or even discuss with KCC, particularly if the KCC comment simply supports a planning decision. The Woodcut Farm application is dependent on the best advice to ensure the detail can be worked up to produce an access solution that is safe and future proof and will have regard to the impact on the existing community. At the moment, we only have the applicant’s design simply approved by KCC. In other words, KCC appears to be underwriting the design, and with that comes all the risk and burden that there is a KCC guarantee and seal of approval?

You should be aware that the community is confused after the Sutton Road discussions as to who is running the roads. Following the adoption of MBC’s Local Plan the general consensus is that MBC does have a responsibility. There needs to be a clear message being sent out to the community. In this instance, my information, as can be seen from the attached discussion document, leads me to the conclusion that more work needs to be carried out to improve the design to underwrite the objective of avoiding more accidents, and therefore traffic jams, at this point on the A20.

I look forward to your response and sincerely hope that you will consider my comments positively hopefully set up a meeting as soon as possible simply to confirm that KCC has all these matters in hand.

It may be that the outcome of a meeting will be to agree that everything has been considered to ensure that this development will be made safe. However, to reinforce this message to the community the appointment of an independent traffic expert to audit and recommend the design would go a long way to addressing our concerns. If KCC does take up this suggestion positively, then this will reinforce the clear message that KCC is perceived to be doing everything to protect the community.

I believe it is in all parties’ interests that this matter is progressed openly and in a constructive manner to achieve the best result in terms of infrastructure improvements that are required as a direct result of this development.

Kind regards

Robert Sinclair

Brogden Barn
Forge Lane
Leeds, Kent ME17 1RT

rob@robertneil.co.uk

A discussion document illustrating the issues relating to site access and likely traffic problems can be downloaded at  Discussion-document-to-be-attached-to-email-to-KCC-11-Oct-2018.docx (9 downloads)

Pictured below is local KCC Councillor Shellina Prendergast.

Maidstone Rural East County Councillor Shellina Prendergast.