Air Quality Action Plan Consultation (Four Elms Hill) response

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QUICK RESPONSE TO

AIR QUALITY ACTION PLAN (FOUR ELMS) CONSULTATION 

 “Save the Hoo Peninsula” has produced  template response for you to send to Medway.

Just fill in your details, alter the submission (if you wish) and click submit.

AQAP Response
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4 Replies to “Air Quality Action Plan Consultation (Four Elms Hill) response”

  1. Please no more in Hoo and surrounding areas, we do not have the infrastructure to cope with more housing and all that brings. Doctors, schools, roads and sewage are struggling to cope already. We are losing too many green spaces. Please find somewhere else and leave our countryside alone

  2. Dear Medway Council,

    This email serves as a representation, and should be recorded as such, concerning the Council’s Four Elms Hill draft Air Quality Action Plan (AQAP) consultation 2022. These comments cover the contents of the plan itself.The draft document is dated December 2021, yet it is only now that it is being consulted on and the Council intends to include it as part of it’s Local Plan evidence base. It’s very clear that the evidence base would not have been completed in time for meeting the Housing Infrastructure Fund (HIF) Project Grant Determination Agreement (GDA) milestone, with regards to the submission of the draft plan for Independent Examination – the Council has now defaulted on multiple milestones and the funding is now likely to be withdrawn (as there is a legal mechanism/basis to do so).The Air Quality Action Plan (AQAP) for Four Elms Hill will only cover a period of 5 years from 2022 to 2027, yet the Council’s Local Plan intends to cover a period of 15 years. Four Elms Hill was declared an Air Quality Management Area (AQMA) as far back as 2017. The Council intends to review action plans every 5 years at the latest, yet the AQAP (2015) for the other AQMAs in the Medway Towns has not been reviewed for 7 years. There’s no confidence that the Council is competent in it’s air quality responsibilities.The action plan mostly relies on two measures which have a high rating for “Target Pollution Reduction in the AQMA”. The first being supporting the implementation of zero-emmisions only Heavy Goods Vehicles (HGVs) and Light Goods Vehicles (LGVs) traveling on the Hoo Peninsula through the Four Elms Hill AQMA. The second being introducing/building a depot away from the Hoo Peninsula so that any HGVs and LGVs could drop off or collect goods there, zero-emmisions vehicles would then transport these goods on and off the Hoo Peninsula.
    Both of these measures are clearly ludicrous and show a complete lack of understanding with regards to the logistics industry – particularly time, fuel, human resources and efficency aspects. It would be surprising if any of the significant companies or organisations present at the two large industrial/commercial areas at Kingsnorth and Grain supported this. Indeed, these measures would make Kingsnorth and Grain less attractive logistically and commercially – this goes against the Council’s aspirations for these areas.The Council was very excited and dazzled when Amazon recently moved to Kingsnorth – not understanding that the increase in commercial growth will indeed reduce transport capacity and therefore capacity for housing development. The HIF Project only deals with potential residential growth. The Council can’t have it both ways – large scale commercial growth aspirations AND large scale housing development aspirations. The Council completely lost it’s senses with Amazon – so much so that they didn’t plan for the consequences felt by the local community, particularly lorry parking, road blockages (lack of signage, lorries getting lost), damage to roadsides and verges, litter and feaces.Being an international multi-billion pound company, with it’s own incredibly resourced ‘scouting’ of sites operation, the Council claims that it along with ‘Locate In Kent’ (both much smaller enties) wooed Amazon to Kingsnorth. It will be interesting to see companies and organisations such as Amazon responses to these proposed AQAP measures.The AQAP makes clear that a reduction in pollution to legal levels can only be achieved, taking into account the Council’s development aspirations for the Hoo Peninsula, by the use of zero-emmisions buses, LGVs and HGVs only passing through the Four Elms Hill AQMA. This is simply impossible and impractical, especially in the short and medium term. Even if the Council did try to argue that it is possible that all vehicles will eventually become zero-emmisions in the long-term, this can only be achieved very well beyond the AQAP’s and emerging Local Plan’s lifespan. For example, the phasing out of polluting HGVs won’t begin until 2040 with the ban on new polluting vehicles – there will still be a use of and used vehicle market for a number of years.The actual coverage area of the AQMA should be extended to cover from Four Elms Roundabout all the way to Ropers Lane Roundabout – there is evidence to support this extention due to the high levels of air pollution at various points along this route. The Council does recognise that buses and HGVs will not be permitted to use the so called new “relief road” – part of the HIF Project’s Road Scheme that only plans for and accomodates potential residential growth – therefore commercial and industrial expansion will need to be accomodated by the use of Four Elms Hill. The Council is already struggling to maximise as much housing development capacity from the Road Scheme and is particularly experiencing problems with the Main Road roundabout/new junction – a new pollution hot-spot in the making along with Four Elms Hill and the roundabout area.The Council’s preferred spatial strategy of concentrating housing development (up to 12,000 homes) on the Hoo Peninsula, particularly around Hoo and Chattenden, as well as large scale commercial/industrial development aspirations, is clearly not sustainable and this will be proven to be the case at the Independent Examination of the Local Plan. With the repeated lacking of genuine reasonable alternatives that have been properly explored before being discounted, the Council’s plan will again be found unsound for a third time – this was clear to see from the draft published in October 2021 and the failure to finish the evidence base.

  3. Considering we have been having issues with pollution for many years now, I cannot understand how it can be acceptable to propose another 12, 000 properties which in turn will create another 24,000 vehicles. Currently, due to the approval of an Amazon site and MORE houses the traffic has already increased since it was mentioned that the pollution level goes above the legally accepted level. How can it be justified approving 12, 000 more properties as well as expanding the Kingsnorth Industrial site which will equate to even more vehicles???
    Tell me how this can be legal and justified, has common sense completely been irradiated ???

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