Friday, April 13, 2007


Mrs Debbie Smith
The Planning Inspectorate
Room 4/04
Temple Quay House
2 The Square
Temple Quay

Dear Mrs Smith,


1. I am one of the two Tonbridge and Malling Borough Council ward members for Burham, Eccles and Wouldham. I am also a well qualified Civil Engineer (Chartered Engineer , Fellow of the Institution of Civil Engineers). I am not a practicing UK road engineer and though I have experience of road design and construction, I am not fully conversant with current UK standards. However there are general highway engineering points that I wish to draw to your attention.

2. KCC refused this planning application for two sound planning reasons TP15 & QL11 of the Kent and Medway Structure Plan July 2006. You will be familiar with the wording of those two policies but please forgive me for restating them:

Policy TP15: Development Traffic & Heavy Goods Vehicles

Development which generates significant increases in traffic, especially heavy goods vehicles, will not be permitted if it is not well related to the primary and secondary road network, or it would result in a significant increased risk of crashes or traffic delays unless appropriate measures to mitigate the effect of the development have been secured.

Kent County Council and Medway Council will:

· Identify and signpost lorry routes so as to direct heavy goods vehicles away from rural and residential areas:
· Work with others to achieve distribution of goods by sustainable means in the urban areas in Kent.

Policy QL11: The Protection and Enhancement of Existing Community Services

Existing community services* and recreation facilities will be protected as long as there is a demonstrable need for them. Provision will be made for the development and improvement of local services in existing residential areas and in town and district centres, particularly where services are deficient. Flexibility in the use of buildings for mixed community uses and the concentration of sports facilities at schools will be encouraged.

‘community services’ includes schools and other education provision, social services, adult education, libraries, youth and community services, police and emergency services, health, culture, places of worship, recreation and amenity space, sport, local shopping, public utilities and transport.

3. Though TP 15 and QL 11 are separate reasons for refusal the two policies are linked together because it is the presence of HGV traffic that causes the degradation of quality of life. In this letter I want to amplify the reasons why these policies are critical to the well being of not only the village of Eccles but also of Burham and Wouldham. Collectively there are just over 2000 households in these villages. In the next 10 years the new village of Peters Village will be constructed adding a further 1000 houses with little upgrading of the road network. It is however the village of Eccles that is most affected by this application.

4. I have six general points that should be noted:

a. You will be aware that a number of planning applications have been refused by KCC and Tonbridge and Malling Borough Council where there is an increase of HGV movement through Eccles.

b. Traffic counts by local people indicate that at present there are about 60 to 70 HGVs passing through Eccles each weekday.

c. That Southern Water has openly declared their wish to pass 128 HGVs through the village of Eccles each day effectively trebling the HGV movements to 200 movements each day.

d. That in the small print of the application Southern Water reserves the right to pass unlimited HGVs through Eccles in the event of one of their other plants breaking down.

e. I understand that the Kent Police have never been consulted on this planning application and have road safety reservations about it.

f. I believe alternative sites or alternative routes to this site could be found by Southern Water. They might not be as attractive commercially or sit as comfortably with their strategic plans but if this appeal is rejected they will still be able to meet their statutory obligations.

5. My principle concern in this appeal is that Kent Highway Services, the local roads authority, did not raise any major objections to the original planning application. This has been met with incredulity by the villages of Burham, Eccles and Wouldham. I ask you to examine this concern in detail in your inquiry and if necessary seek a second opinion on Kent Highways Services advice which the local villagers feel is so flawed. I set the case out below by presenting the following information: the lack of proximity to the primary and secondary road network, the poor parking in Eccles, the narrow road width, the road accidents figures, road wear, noise, vibration and smells. These are the main issues that affect TP 15 and hence QL 11.

6. Proximity to the primary and secondary road network. The rural road system that serves Burham, Eccles and Wouldham starts at the junction of Rochester Road and Pilgrims way at Grid Reference 745606. From there going towards the villages there is 700 metres of single lane dual carriageway road. The lanes are narrow with limited passing places and any blockage here seals the southern access and exits to the villages. From the end of the dual carriageway to the junction of Bull Lane and Pilgrims Way is a further 600 metres of two lane single carriageway road. I would particularly like you to note the bend at Hale Farm, at Grid Reference 735610. This bend is deceptive and is taken at speed by rural traffic. HGVs going east gravitate to the centre of the road into the path of oncoming traffic where the road is not wide enough for evasive action. There has been at least one fatality and a number of serious injuries well within living memory at this bend. From the Bull Lane, Pilgrims Way junction to the Southern Water’s access road to their plant at Grid Reference 725592 is another 2.2 kilometres part of it through the village of Eccles. The only other public access is via the historic part of Aylesford village which is out of bounds to HGVs and cannot be used hence the only route on the public highways is through Eccles. There other routes on private land not owned by Southern Water.

7. Parking in Eccles. The old part of Eccles was established before the car was invented to house local workers. No provision was made for parking. Subsequent development has not been generous with parking places. The public transport system is poor and therefore car ownership in the village is high. The problem is made worse by the number of trade vans that are parked by working people who live in the village. All the land to the to the west of Eccles where parking could be developed is owned by Trenport who are reluctant to sell the land. The result is that Eccles has a high rate of car ownership in a village that has not been planned to accommodate it and little prospect of improving the availability of parking spaces. Inevitably overspill parking occurs onto Bull Lane adding to the restrictions on road width and a further traffic hazard. Parking in the village in general and along Bull Lane is not good now but is going to get worse in the foreseeable future.

8. Road width. On the afternoon of 17th March, I conducted a carriage way width survey from just to the west of the dual carriage way on Pilgrims Way at Grid Reference 738609 via the junction of Pilgrims Way and Bull Lane at Grid Reference 733612 to the junction of Southern Water’s exit on to Bull Lane to the south of Eccles at Grid Reference 725592. This was done using an engineering surveying global positioning system (GPS). The results are at Annex A to this letter. Outside the Eccles 30 mph limit readings were taken were possible at about 100 metre centres and inside the 30 mph limit at about 50 metre intervals. The GPS results record the grid reference of the point being surveyed and these are at Annex A. This means that the results can be reproduced by any competent engineering surveyor. The results are at Annex A and show that the maximum roadway width is 6.48 metres and a minimum of 4.68 metres with an average width of 5.67 metres. These roads are too narrow for HGVs and the result is that many times a day on our roads there are hold-ups when two oncoming HGVs, buses or coaches try to pass one another.

9. Road Accidents. In my submission to KCC, I compared traffic accidents on a 6 kilometre stretch of the A228 with the same length of typical rural lanes in my ward. I reproduce those results at Annex B. From the results it can be seen that both roads have a similar number of accidents. However when traffic numbers are taken into account the rural roads are much more dangerous. I also make the point that there are a host of minor accidents on the rural roads, such as wing mirrors being hit and scratches, which are not reported. These do not occur on the wider secondary or trunk roads. These road accidents are aggravated by speed and the sub contactors and private hire companies running HGVs into the Southern Water facilities have a bad reputation for speeding through Eccles and for travelling at unsafe speeds on the rural roads where the maximum speed limit is 60 mph but the safe speed for a laden HGV is often less than half that speed. Many of the residents of my 3 villages feel that these drivers are on piece work rates of pay and that their vehicles are big and powerful and if somebody gets in the way their attitude is that it is just bad luck.

10. Road wear. Basic engineering road theory attributes most road pavement deterioration to successive loadings by vehicles. Each loading does a minute amount of damage which builds up over the design life of a road pavement; a phenomenon known as fatigue. It takes millions of axle loads before failure occurs. However different vehicles weights have different damaging power depending in large part on their weight. The damaging power of vehicle weight is not linear ie double the weight causes double the damage. It is in fact a function of the fourth power of the weight thus a 10 tonne vehicle does 10,000 times the damage of a one tonne vehicle (ie 104). Further rural roads are not designed to take the same number of vehicle loadings as secondary or trunk roads. Passing more HGVs down country lanes will cause those roads to fail more often requiring more frequent repairs with attendant congestion and delays for the villagers.

11. Noise, Vibration and Smells. In addition to the hazards above the HGVs are noisy with sound emanating from their tyres, engines and the metal body work. The weight and the speed they travel at through Eccles causes vibration in nearby buildings. Some Southern Water vehicles emit very unpleasant odours as they pass through the village. It is difficult for the environmental health officer to record this as it is a transient nuisance but never the less a very real one.

12. Discussion.

a. Please note that Southern Water are asking you to increase the number of road HGV movements from about 60 or 70 vehicles to about 200. This application “generates significant increases in traffic, especially heavy goods vehicles” contrary to TP 15.

b. In the evidence I have set out above it can be seen that the sewage works is not “well related to the primary and secondary road network” because HGVs must pass down 3.5 kilometres of narrow rural road and through a village where this road is degraded further by parked vehicles. This is contrary to TP15.

c. Because we are on a rural road system where I have shown the differences in accident rates from trunk roads to rural roads the application will “result in a significant increased risk of crashes” contrary to TP15.

d. The narrow width of the road where there is not sufficient room for large vehicles to pass each other does already cause traffic delays. As a result of this proposal there is “a significant increased risk of ……. or traffic delays” contrary to TP15.

e. All of the factors above plus the effects of noise, vibrations and the objectionable smells will detract from the quality of life in Eccles which is a residential village with houses on the main road. Transport will be disrupted; parents will be even more reluctant to let their child go across Bull Lane to get to the recreation ground which is one of the few facilities in Eccles. All of this detracts from the quality of life in Eccles and as such is contrary to QL 11.

13. Questions. If I can help more by answering any questions you have or providing more information I will be delighted to help.

14. Speaking at Inquiry. I would be grateful if you could note my wish to speak at any inquiry you hold.

15. Conclusions. This letter expresses the reservations the people of Burham Wouldham and Eccles have about the advice of Kent Highway Services to KCC’s Planning Committee. The Planning Committee turned the application down for sound reasons that were contrary to the TP 15 & QL 11 policies of the Kent and Medway Structure Plan July 2006. I ask you to investigate very fully the suitability of the rural road system that Southern Water wish to subject to a three fold increase in HGV traffic. I ask you to note that I believe that the Kent Police Road Safety Team have reservations about this application but have not been consulted on it.

16. Conclusion I ask you to reject this appeal on the grounds that TP 15 and QL 11 of the Kent and Medway Structure Plan of July 2006 were valid grounds for turning down the original application and to do this in the knowledge that other options are open to Southern Water albeit they are not as commercially attractive.

Yours sincerely

Cllr Dave Davis
Printed and promoted by A Kennedy on behalf of Burham, Eccles and Wouldham Conservatives, all at 200 Canterbury Street, Gillingham, Kent.