Thursday, August 11, 2016

Kent CPRE Response on Richborough Masts development

We thought the CPRE's response to the planning application was worth publishing - Please see their website at for further details:

The local campaign against the Masts can be found at here

The company site can found here

CPRE Kent believes that the applicant has not demonstrated that other technologies are not available to meet communications needs.  Establishing the need for the mast will be important during evaluation of the planning balance when determining the application. An identified harm would be more difficult to justify if there are different ways of meeting the same communications objective.  A mast of the size should not be permitted anywhere is East Kent unless it is demonstrably in the public interest, and the least harmful site has been identified.  The case has not been made.

There are clear planning objections to this particular site (see landscape, heritage and ecology impacts below).  It is therefore relevant and necessary to consider whether there are more appropriate sites elsewhere.  Although the Planning Statement and the Technical Operation Report mention consideration of alternatives, it is not clear which alternatives were considered and why they were discarded.  This is necessarily relevant to the decision.  Indeed the similar and current application at Richborough Power Station is necessarily relevant to the decision. 

It has not therefore not been demonstrated that the proposal, by necessity, should be sited in the location proposed.   It is essential that a scheme of this size should make every effort to minimise its impact and site choice must of course be relevant. 

The Planning Statement sets out search parameters at paragraph 3.9.  It is of particular note that the search parameters did not include avoiding landscapes of historical, cultural or archaeological importance.  Furthermore,
avoiding impacts on habitats and species of principal importance, and designated habitats, should also be relevant to the choice of site.

The consideration of alternatives is critical in this case and a key element of justifying harm.  Weighing public benefits against that substantial harm (in the planning balance) would be inappropriate if that harm can be reduced on an alternative site.  Of course this would need to have regard to site availability and deliverability.

Mast Sharing

The statements associated with the application do not indicate whether they have discussed mast sharing with other operators, with a view to reducing the numbers of masts proposed in this area.  They commit to accommodating other users where possible, but do not appear to have communicated with a prospective alternative provider (such as Vigilant Global) also seeking a similar mast.  In view of the scale of the proposal this would not be an unreasonable expectation.  Questions should be asked such as: Is New Line Learning Networks prepared to share the mast with competitors?   What structural changes, or changes to mast height, would be required if additional dish antennae were to be accommodated?

This point is key.  It has not been demonstrated that there is a need for two masts of this scale.  The proliferation of masts of this size should clearly be avoided where possible and that is in the public interest.

CPRE notes that The Planning Statement explains that it will use mast ‘sharing’ to improve local infrastructure (local telecommunications).  CPRE disagrees with the justification set out at paragraph 7.56.  A mast of this height and in this location is not necessary to sustain the rural economy, nor meet the needs of the community.   This would be a negligible benefit in the overall planning balance.

Landscape and visual impact

The Ash Level Landscape Character Assessment makes the following notable statement:  ‘There is little built development, creating a predominantly horizontal landscape with little to interrupt the view or focus the eye’.   The proposed mast would clearly not protect or enhance the local and wider landscape character of this open and horizontal landscape.   CPRE is of the view that it will have far-reaching and significant detrimental impact.

CPRE believes that this harm to the character and appearance of the landscape is a significant impact, reinforced by its relevance to nearby nationally important heritage assets, and Richborough Fort (and associated features) in particular.  Indeed the Wantsum Channel itself is a landscape of historic, cultural and archaeological importance in its own right and it is inappropriate to assume that the harm to this landscape area is only relevant insofar as it relates to the cultural contribution of the landscape to the understanding of nearby heritage assets. 

Impact on the views from Richborough Castle are also harmful and significant.  CPRE disagrees with the following conclusion (para D8.7) in the Environmental Statement:

“These effects are not considered to be significant due to the visibility of other large scale buildings and infrastructure, the limited physical effects and the reversible nature of the effects on aesthetic and perceptual aspects.  In relation to Richborough Castle, the slender nature of the mast means that whilst visible the proposed development would not affect visitors’ ability to interpret the historic landform and strategic siting of the fort”.   

The proposed mast would clearly disrupt important views across this heritage landscape.  The open nature of the landscape is important and the development would represent a substantial and unpleasant feature.  The visibility of other buildings and infrastructure does not limit the significance of the harm to the setting of the Fort, since it will be nearer than other development, and of course, much taller.     It is the view of CPRE that the mast, by virtue of its height and location, would have significant and harmful landscape impact over a wide area.  Further, it is unlikely that ‘using subtle and slimline materials and colour’ will significantly mitigate impacts on landscape character.

As such, the proposal fails to satisfy Policy DM 16 (Landscape Character) of the Core Strategy, which states:  

“Development that would harm the character of the landscape, as identified through the process of landscape character assessment will only be permitted if:  
i. It is in accordance with allocations made in Development Plan Documents and incorporates any necessary avoidance and mitigation measures; or  ii. It can be sited to avoid or reduce the harm and/or incorporate design measures to mitigate the impacts to an acceptable level”.

This case cannot be made for this proposal.  The impact is unacceptably harmful and it has not been justified.  Other proposed vertical features, such as the Richborough Connection, would further compound this impact.  Indeed the information submitted with the proposal does not seek to properly understand the visibility over long distances.

Heritage assets 

The proposed development is likely to have a significant effect on the setting of the Roman site at Richborough.   The site is designated as a Scheduled Ancient Monument and includes the Grade 1 listed Richborough Castle.    

There are, of course, other historic landscape features in the locality, most notably the former Wantsum Channel which forms part of the setting of Richborough Fort.  Views of this channel are prominent from the castle and are important in the understanding of the strategic siting of the castle.  Correspondingly the mast will be visible from the Scheduled Monument and the listed Richborough Castle and would be clearly detrimental to the experience of visitors to the site and the interpretation of the landscape setting in particular.  The harm to the setting of the fort, and the ability to appreciate it would be significant. 

Furthermore, it is the view of CPRE that the Wantsum Channel is a heritage asset of value.  It forms part of a historic and cultural landscape that makes a significant contribution to the understanding of the pattern of development in East Kent.  The impact of the scheme on the landscape character of this area, which forms part of the setting of numerous heritage assets, would be substantial and harmful to its evidential, historic and aesthetic value and thereby its significance.

Ecological assets

The site is designated as a Local Wildlife Site with notable bird, invertebrate, mammal and reptile species.  Golden Plover (an SPA species) is relevant, but there are numerous other Species of Principal Importance or otherwise notable.   The risk of bird impacts is a significant concern of CPRE and this issue should be discussed in detail with Natural England, Kent Wildlife Trust and RSPB.  An alternative site might lower this risk and this should be relevant to the alternative site assessment.  Of course the lack of experience of this height of mast must make the impact on birds uncertain, and this is an important concern due the valuable migratory species overwintering in East Kent.

CPRE Kent must object to this application and submit that it is essential that the need for the mast is established, that the alternative site assessment is made available, that the two applications should not be considered in isolation, and that significant weight be given to the heritage, landscape and ecological harm likely to result from the  development

Thursday, July 28, 2016

Victoria's Green Matters - 28th July 2016

Deal With IT's Secretary Victoria Nicholls writes a regular column in the East Kent Mercury:

It is a long time ago – thirty years, in fact – since we first heard about the hole in the ozone layer above Antarctica. This was followed by serious fears that ozone depletion could cause harm to health and to the environment through ultraviolet light reaching the surface of the earth.
There was an unparalleled global reaction to these findings and in 1987, the Montreal Protocol, an international treaty, was ratified by all United Nations’ members to eradicate the use of chlorofluorocarbons or CFCs in products. These chemicals, once commonly used in aerosols and refrigeration, can remain in the atmosphere for more than 50 years. The phasing out of CFCs means that the ozone layer is slowly recovering and by September of last year there was a consistent shrinking of the size of the hole.
Britain has around 5% less ozone than it did thirty years ago but it would have been twice as bad by now if CFCs hadn’t been phased out. There would be damage to skin and eyes and also to crops. It has been estimated by the UN that 2 million cases of skin cancer per year have been avoided through this action.
This is a fine example of worldwide co-operation dealing with a worldwide problem in which we are all involved. It would be wonderful to think that global climate change could be tackled with the same enthusiasm throughout the world. The economics are certainly different because the fossil fuel industry involves billions of dollars.

Thursday, July 21, 2016

Victoria's Green Matters - 21st July 2016

Deal With IT's Secretary Victoria Nicholls writes a regular column in the East Kent Mercury:

The year 2016 is on course to be the hottest year on record. There has been an amazing acceleration in global temperature rises, far in excess of that which scientists expected. These temperature rises show that climate change is no longer a threat for the future, it is here and now. Climate change deniers, please take note!

Each of the past 13 months has been the hottest globally on record for that month and the maximum extent of Arctic sea ice set a record low and the extent in May was the lowest for that month ever. India recorded its hottest day ever with the mercury reaching 51°C in Phalodi, Rajasthan and the temperature in Australia was 1.86°C above the average, beating the previous above average temperature of 1.64°C. The Great Barrier Reef suffered its worst coral bleaching, leaving only 7% untouched by devastating algal loss.

There has been an increase in carbon dioxide levels in the atmosphere in 2016 and this is expected to reach 3.1 parts per million. This is much more than the annual average increase of 2.1parts per million and leaves the total figure of 400 parts per million now probably unattainable.

Carbon dioxide levels are almost entirely responsible for the record temperature increase but El NiƱo, a natural climate phenomenon, must take some blame as it causes stored heat to be released into the oceans, affecting the whole world.

These figures surely make the connection between cutting emissions and the impacts of global warming. 

Sunday, July 10, 2016

Sandown Beach Clean 10th July

Thank you to our 12 volunteers on today's Deal Beach Clean at the Sandown Castle end of the beach - we collected over 60kgs of rubbish is just over an hour

Our next Beach Clean will be on Sunday September 18th at 9:30am as part of the Marine Conservation Society's Great British Beach Clean - A  national survey of rubbish on our beaches

Thursday, July 7, 2016

Victoria's Green Matters - 7th July 2016

Deal With IT's Secretary Victoria Nicholls writes a regular column in the East Kent Mercury:

We have heard a lot about poor air quality recently concerning our own cities, most notably London but these problems are nothing compared with Rajshahi in Bangladesh. Rajshahi has had the unfortunate accolade of being one of the world’s most polluted cities. This has been caused by dust blowing up from fields, roads and dry riverbeds combining with choking smog from brick kilns on the edge of the town and transport emissions.

A campaign to make the city greener began 15 years ago with a tree planting drive and now includes everything from rubbish collection to transport. Changing transport for greener options began in 2004 by altering the petrol/diesel powered rickshaws, which are the main form of public transport, for battery operated versions and by banning large lorries from the city centre during the day.  

A campaign to clean up the brick kilns by changing the chimneys and fuel has reduced the pollution from them dramatically as has a project to make the city centre greener by reducing the amount of dust thrown up by people and vehicles. To ensure that dust is removed from the roads, pavements have been installed and surfaces have been grassed or planted. The city’s chief engineer who is responsible for all this improvement was inspired by visits to London and other cities around the world where people walk around the city instead of looking for transport.
His next project is to encourage cycling by installing cycle lanes to encourage a healthier lifestyle.

Tuesday, June 28, 2016

Next Deal Beach Clean is on Sunday 10th July

The next Deal Beach Clean will be on Sunday 10th July starting at 10am - please meet at the Sandown Castle end of the Beach.

Pickers, Bags and Gloves - Beach cleans last for about 1-1.5hr

Monday, June 27, 2016

Pocket Poppy Meadow - West St Deal

Our pocket poppy meadow on the waste land in front of Deal Telephone Exchange is awesome at the moment. 
Get down and have a look.

One of our guerilla gardening projects to brighten up the unloved bits of our town

Sunday, June 26, 2016

Deal Beach Clean 26th June

Thank you to our 15 volunteers on today's Deal Beach Clean - about 42kgs of rubbish collected despite the sudden monsoon just as we started!

Our next Beach Clean will be on the Sunday 10th July at 10am starting at Sandown Castle end of the beach

Thursday, June 23, 2016

Victoria's Green Matters - 23rd June 2016

Deal With IT's Secretary Victoria Nicholls writes a regular column in the East Kent Mercury:

Climate change caused by human behaviour not only affects humans but has caused the first recorded extinction of a mammal anywhere in the world. This animal is a small rodent called the Bramble Cay melomys, also called the mosaic-tailed rat, which lived on the tiny island of Bramble Cay, off the north coast of Queensland, Australia.

The island, only 3 metres above sea level at most, has regularly been covered by rising seas, destroying the animals’ habitat and killing them. The area of land above the high tide level is estimated to have decreased from about 10 acres in 1998 to 6 acres in 2014: 97% of the habitat has been lost in just 10 years.

Around the world, average sea level has risen by almost 8 inches between 1901 and 2010. This is an unequalled rate in any period in the past 6,000 years but around Bramble Cay in the Torres Strait, sea level seems to have risen at almost twice the global average between 1993 and 2014. This tiny island is also the most important breeding ground for green turtles and some sea birds.

Scientists say that other species that are constrained to small, low lying islands or those with very tight environmental needs will probably be the first to go. A report in 2015 found that one sixth of the world’s species faced extinction as a result of climate change and scientists believe that the world is on the verge of the sixth mass extinction.