Those who haven’t been following comments added by readers in relation to the proposed asphalt plant at Medina Wharf may have missed one posted by Harvey yesterday to our article published before Christmas.
As Harvey’s comment was fairly lengthy and raised a subject not previously discussed here in connection with the asphalt plant, flooding, we felt it would be worthwhile republishing his comment. In his own words. Ed
Once again the Medina Wharf asphalt plant applicant is to be given unlimited time to enhance their case (note the process has now being ongoing since April 2012) whereas the public on the other hand are being denied any further consultation period.
I have therefore written to the LPA, objecting on the grounds that the proposed development is on the flood plain of the river Medina and that despite this, no provision has been made for this aspect in the application, either in the preliminary design statement or the design itself.
Not acknowledged by applicant
In fact the applicant does not even recognise that the site is located on the River Medina flood plain as stated in their application (Risk Assessment page 3 Paragraph 2.4).
Although the site is locally elevated, due to the amount of uncontrolled and contaminated wasted dumped since 1913 this statement is clearly incorrect as the site is directly adjacent to the river and therefore exposed to tidal surges and flash floods.
Importantly when the applicant’s claims of site levels are checked against the Ordnance Survey map, the latter shows the five metre contour line going through the middle of the site giving a height of five metres above mean sea level i.e. SEVERAL METRES LOWER than the spot (aOD) levels specifically referenced in para 2.1 of the Risk Assessment (Environmental Setting) claimed by the applicant.
Risk from flooding is self evident
Taking the applicant’s stated intention of lowering the site by two metres and with recorded high tides in excess of four metres, the risk from flooding is self evident.
I note that this is not apparent from the maps submitted with the application because these show either contours marked at ten metre intervals or do not include the five metre contour marked as such within the area depicted.
Questionable information provided
An earlier letter of objection to the LPA from another resident dated 04/10/2012 independently confirms these points with regard to tidal records.
It also refers to other cases where information provided by this applicant cannot be taken at face value or relied on – a point which I have also made separately to the LPA in relation to the soils investigations (over 60% of the original soils samples could not receive accreditation because they were either incorrectly collected or suffered interference).
Planning experts vocal over building on flood plains
Building on flood plains is a very topical subject at the present time as a result of the devastation caused by changing weather patterns and subsequent flooding up and down the country causing misery, pollution, health hazards, damage to homes/businesses and the economy.
Various planning experts interviewed by the BBC in relation to the recent floods were asked to explain why developments are still being allowed to take place on flood plains.
Strict controls in place
Generally they denied that such developments were being allowed to take place unless strict controls were agreed to be put in place prior to approval being considered/recommended in line with Government Policy on building on flood plains.
The site includes the following statement :
”Between May and June 2007, extreme rainfall led to widespread flooding in England and Wales. It was arguably the largest peacetime emergency since World War II, causing 13 deaths and £3.2 billion in damage. The Government commissioned Sir Michael Pitt to undertake an independent review of the floods, which concluded that “urgent and fundamental” changes were needed to reduce flood risk. It called for a range of actions, including:
• Clearer roles and responsibilities for flood risk management
• A continued presumption against development in flood-prone areas, barring exceptional circumstances
• Flood-proofing of buildings in flood-prone areas
The Government accepted all 92 recommendations and the Flood and Water Management Act 2010 implemented those that required legislation ”
No alternative sites?
The following statements in bold summarise what the experts said:
1) Before any development is considered on a flood plain the applicant must prove to the LPA that there is/are no alternative site/sites
We know the applicant has spoken about three sites, but all are in the same location. These therefore cannot be reasonably described as alternative sites as they are in the same location and within the flood plain of the Medina and therefore all give rise to similar concerns/problems. The question therefore is “has the applicant investigated genuine alternative sites and actually demonstrated this to the LPA?”
St George’s Down Quarry site
We also know that there is at least one genuine alternative site on the Island (St George’s Down Quarry). This may not be the applicant’s preferred commercial choice. However, it is undoubtedly an alternative site which has operated without complaint or enforcement for approximately 25 years.
The siteowner/operator has a current planning application pending to upgrade their asphalt plant. This application has received public support and unlike the Medina Wharf site is not in a controversial location and is serviced/accessed by much better roads.
Comparing the sites
Compare the Medina Wharf site with St George’s Down Quarry : apart from the former’s controversial location (close to thousands of homes and sited on contaminated land), the road access is very congested and suffers frequent holdups. For example the Cowes/Newport Road becomes blocked whenever buses or refuse trucks stop en route and also when large trucks turn into Arctic Road.
Regarding Arctic Road despite this road being in a densely populated area there are no traffic lights to regulate heavy traffic turning, safe pedestrian crossing provision or indeed even a pavement on one side of the road.
At certain times of the day the Cowes/Newport Road cannot cope with present levels of traffic and as indicated becomes jammed. It is surprising that the highways department have not commented publicly on its inadequacy to support additional traffic, general safety and lack of pedestrian safety in relation to the Medina Wharf planning application.
Delays to alternative asphalt plant
It is noted that the planning application to upgrade the asphalt plant for St George’s Down Quarry is still outstanding. Much has been made by the LPA of the requirement to cooperate with planning applicants.
The public perception is that while the applicant for Medina Wharf has been given several opportunities and unlimited time to enhance their case, i.e. maximum cooperation, the St George’s Down application is unaccountably being held up by IWC, thus placing more pressure on planners to recommend approval for the Medina Wharf site on the pretext there is no alternative viable option.
The question has to be asked, why is the St George’s Down application taking so long to process? If the delays are due to other IWC departments dragging their feet, are the reasons for this valid, and if so, what are they? Have these considerations been applied equally in the case of the Medina Wharf application?
2) Before any development is considered on a flood plain the applicant must prove to the LPA that the design for the site can cope with flooding and not cause pollution. i.e. flood defenses must be part of the planning application BEFORE recommendation/approval can be considered.
Where are the applicant’s proposals for flood defence measures? Does their absence imply that we are to see yet another opportunity and more unlimited time being given to the applicant to produce a response?
We know that the applicant has not considered this issue. In fact they have made it more likely that the site will be vulnerable to tidal surges/flooding by planning to lower the site level by two metres.
Not only will the site be at greater risk of tidal surge/flooding etc as a result of the lowered level but also in the event of surge tides/flooding everything (waste oil, toxic crushed road planings and the like) will be washed into the river.
It is worth noting that historical records (County Press) indicate that in Carisbrooke when the roads were first tarmaced, all the water that drained from these new roads after the first rains into the ford and watercourses killed all the fish. The same material that killed those fish will be present on this site because there are no plans to put the mobile crusher, which will deal with the toxic road planings, into a secure pit/flood-proof building.
3) Before any development is considered on a flood plain the applicant must prove to the LPA that the design for the buildings/equipment themselves must be able to cope with/prevent internal flooding and pollution.
What has the applicant proposed in this case?
We know very little about the applicant’s design other than it is to be clad in steel sheeting or similar and painted dark green to blend in with the surrounding dense foliage (which of course isn’t currently there because it’s winter and the trees haven’t even been planted yet and if as planned the trees are planted on bunds of contaminated land removed from the surface of the landfill, they will probably never grow at all).
In no way can this be described as effective provision against tidal surge/flood risk, the incidence of both of which is becoming increasingly more common due to extreme weather patterns.
Urged refusal of application
To conclude I have urged the LPA to refuse this planning application for the above reasons and because it is poorly conceived and in an entirely inappropriate location. Because of the importance of these issues I have copied these objections to our Island MP who at least has represented the views and interests of his constituents in an exemplary manner.