Chief Planning Officer

Mr P W Mason

Chief Planning Officer

Council Offices

Tandridge District Council

8 Station Road

Oxted RH8 OBT

20th July 2016

Dear Mr Mason

COMMENTS ON PLANNING APPLICATION No 2016/1036 MOORHOUSE TILE WORKS

WESTERHAM KENT TN16 2ET

1.  Thank you for your letter of 1 July 2016. The revised planning application from Roxhill Developments for the above site does not resolve any of the objections raised in the comments submitted in my letter of 20 November 2015 to Ms Charlotte Parker with reference to the previous application (No2015/1217)

1.1 Accordingly I am re-submitting these comments and, additionally, I draw your attention to some of the more recent reports on the threat to health posed by air pollution caused by traffic. Professor Jonathan Grigg (with whom I have corresponded) stated, as co-author of the report (23 February 2016) for the Royal College of Physicians and the Royal College of Paediatrics that it was “essential that policy makers consider the effects of long term exposure on our children and the public purse”. In April, the House of Commons Environment Food and Rural Affairs Committee underlined the seriousness of “this public health emergency”

1.2 These reports were considered by our local NHS patient participation group. It became clear that, in the absence of a by-pass for Westerham, we cannot avoid the effects of the exceptionally high levels of pollution here (and eastwards on the A25) and that there should be no development that generates additional commercial traffic with a resulting increase in health risks that have fatal consequences.

1.3 It is to be hoped that our local Member of Parliament, The Right Honourable Michael Fallon has been notified

1.4 See additional Enclosures 12.16

2 Comments on Physical Environment Impact

2.1 Further traffic increases will increase risks of deterioration in the structure of Quebec House, a Grade 1 Listed Building on the junction of the A25 and B

2.2  During our 10 year tenancy, sections of the roadside wall had to be re-built as a result of HGV impacts

2.3  This (listed) wall had been re-pointed and restored before our arrival and needed re-pointing and remedial work on two further occasions. The specialist Historic Building Contractor (Colnets) put this down to not only pollution affecting the lime mortar and brickwork but also to the level of vehicle vibration on this busy road.

2.4  It was necessary to keep windows facing he road shut to avoid pollution penetration that would affect the contents (Doubtless the National Trust has provided a detailed conservation assessment for you).

2.5  Since moving to The Green, St Marys Church asked me to look into conservation issues relating to its Royal Coats of Arms in view of my museum experience. In securing support from the Society of Antiquaries, English Heritage and Church Care, among others, it was considered essential after expensive restoration to move them from vulnerable sites over doorways, (one exposed to the A25), which had affected their condition.

3  Comments on Human Impact

3.1 While the impact on Westerham’s historic heritage causes great concern, degrees of conservation and restoration can be achieved at a cost, but even more worrying is the continuing attack on the health of Westerham population, particularly the old and the young.

3.2  We were made aware of the full seriousness of this threat in 2013 during the Air Quality Management Area Consultation undertaken by the Environmental Health Partnership of Dartford and Sevenoaks through their Scientific Officer (Mr J Fox)

3.3  Following a report in The Times on 4th March 2015 concerning the risks to Eton school pupils from higher traffic pollution, a discussion with Mr Fox underlined the problem of Westerham’s Market Place being bordered by three storey buildings where the A25 forms a ‘T’ junction with London Road to the north, creating the excessively high level of nitrogen dioxide through traffic density

3.4  It was agreed that some improvement could be achieved by additional signposting to divert traffic from the north for Chartwell, Quebec House and the main town car park on to the by-pass of Beggars Lane. Any such improvement would be more than negated by the restoration of heavy commercial traffic based upon the Moorhouse site with, even apparently, over 150 distribution vans and HGV’s

3.5  The most pressing concern on unacceptable air quality is the effect on a significant number of schoolchildren who are obliged to travel westwards by bus from a bus stop located in Westerham’s Market Square as shown on the enclosed analysis and map. The location cannot be altered and suffers possibly the highest level of pollution in Kent with the current readings of 51.7ug/m3 of NO2 .

3.6  This figure (11.7ug/m3 in excess of the EU objective of 40ug/m3) compares with levels that caused alarm earlier in the year at Eton College from the adjoining M4 at a distance of about 1km (see enclosed map). By contrast the Westerham schoolchildren are directly exposed each school day, standing within feet of passing vehicles at peak traffic conditions over a period of 5 years or more at the Market Place bus stop waiting for the westbound service to Oxted School

Churchill Primary School has provided the information (attached) on which this analysis is based but figures were only available for three years, therefore representing only 60% of those travelling during five years of secondary school education

Nor does the above risk factor take into account the danger posed by the presence of fine particles less than 2,5mm diameter (PM 2,5) produced ‘primarily by cars, lorries and buses’ as referred to in ‘The Guardian’ Environmental Section on 11 April 2015 (copy attached) in a study of deaths caused by air pollution

3.7  On seeking advice from Great Ormond Street Children’s Hospital Trust, I was referred to one of their Environmental Consultants – Cool World Consulting – and received not only the Guardian article above but two other articles from the University of California Departments of Epidemiology and Environmental Sciences (UCLA) and the Canadian Association for Physicians of the Environment. These explain the vulnerability of children (until the age of 18) because of their lung/body ratio and provide the results of scientific studies that support the judgments on risks from air pollution. Key extracts are attached

3.8  From the House of Commons, I have also received the Proceedings of the Environmental Audit Committee for 27 October 2015 recording the Oral Evidence on diesel emissions and air quality from Ministers and Departmental Heads of the Department for Transport and Department for Environment, Food and Rural Affairs

3.9  While the questions were largely intended to explore the problems arising from the Volkswagen manipulation of nitrogen dioxide tests (certainly not irrelevant) I have focussed on Questions 150-157 which have a direct bearing on the air quality issues on the A25 and the unacceptability of the proposed Moorhouse site redevelopment which will worsen the situation. A full copy of the Oral Evidence covering these questions is attached. These seem to be the key points:

Q 150:- covers not only the possible liability of Local Authorities to pay part or all of any EU infraction fines for exceeding the 40mg/m3 of nitrogen dioxide but the DOE undertaking to achieve this level by measures ‘in cities outside London’ by 2020, observing the requirements of the Supreme Court in the United Kingdom (The Supreme Court has supplied a copy of this Judgment Summaries attached)

Q 155:- computes the number of deaths from pollutants related to diesel at 52,500 each year and records the DOE response that the EU’s target is to reduce premature deaths by half – but not before 2030

Q 156:- pursues further the question of bringing an action for corporate manslaughter against Volkswagen for the loss of life caused by the company’s actions and provides the information from the DOE that Kings College London/COMEAP is trying to produce a model of the impact

Q 157:- provides the response of the Department of Transport: ‘certainly if it could be proven that a case like that might be brought that could be open’

3.10  The questions did draw out the uncertainties arising from the need to calculate exact emissions to run them against health indicators, but in our local situation, this data is available together with the identity of the individuals who are being exposed to risk and the period of exposure

3.11  It is regrettable that Kent County Council does not seem to have liaised more fully on the complex cross border issues of the A25/M25 traffic, Perhaps the recent ITV/Meridian television coverage, with contributions from Professor Sir Malcolm Green and a European Member of Parliament, will create a better realisation of the problems

4  Conclusions

4.1  The risks outlined must not be increased and the redevelopment must be placed on an entirely different footing

4.2  On the contrary, there is a legal requirement (UK Supreme Court) to reduce levels of air pollution to the agreed safe air quality standards

Enclosures:

1.  Westerham Town Council Annual Report 2013

2.  Dartford and Sevenoaks Environmental Health Partnership Air Quality Management Area (21/1/2013

3.  Times Article (4/3/2013) and map : Eton pollution risk

4.  Proposals (20/4/2015) re: AQMA

5.  Analysis of Churchill Primary School leavers (2013 – 2015) Destination Schools

6.  Westerham School Bus Services

7.  Guardian Article (11/4/2015 Air Pollution Death Risks

8.  Canadian Association of Physicians for the Environment (2000) Introduction to Children’s Environmental Project

9.  UCLA Departments of Epidemiology and Environmental Science extract from article ’Impact of Air Pollution on Children’s Respiratory Health’

10.  House of Commons Environmental Audit Committee oral evidence : Diesel emission and air quality (27/10/2015)

11.  United Kingdom Supreme Court Judgement re: EU Air Quality Directive : Press Summaries (29 April and 1 May 2015)

Copies:

Westerham Town Council

Churchill Primary School

District Councillor Kevin Maskell

Rt. Hon Michael Fallon MP, Sevenoaks

Professor Jonathon Grigg

Cool World Consulting

Westerham & Sundridge Practice Patient Group

Westerham Society

Westerham Town Partnership

______

David M Boston OBE, MA (Cantab), FMA, FRAI, FRSA

14 The Green

Westerham

Kent TN16 1AS

20th July 2016

Additional Information (31 July 2016)

1.  A full set of enclosures 1-16 is deposited with the Westerham Town Clerk’s Office as well as Tandridge Council

2.  Pollution readings for Westerham High Street received subsequently from The Scientific Officer of Sevenoaks and Dartford show the average level reduced for 2015 but well above the legal limit of 40ug/m3 of N02. The improvement since the peak of 2012 appears to coincide with the reduction of commercial traffic from the Moorhouse site.

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