CDGPs Keith Bothwell submits response to CCC's consultation on PSPO Public Spaces Protection Order review, regarding the protection of Long Rock SSSI in Swalecliffe.
The full response can be read here:
Canterbury District Green Party submission to the Planning Inspectorate with regard to proposed closure of Glebe Way pedestrian crossing, Whitstable - July 2020
We would like to see the crossing remain open with improved safety measures.
While we understand the sensitivity of the reasons for proposing the closure we disagree with the proposal. The crossing is part of a well-established public right of way (CW80) which is a vital walking route to and from the beach and town, used by lots of people.
We are concerned that many residents have said they would use their cars more often instead of walking if this crossing was closed, and that this will contribute to unhealthy air quality in our town. Canterbury City Council's routine air quality monitoring indicates that levels of nitrogen dioxide in Whitstable are already dangerously high. As the council does not monitor levels of particulate matter, we carried out our own monitoring in 2019 and found that the level of PM₂.₅, the smallest and most toxic form of particulate pollution, is also dangerously high. The annualised rate exceeded the World Health Organisation’s guidance for health of 10 micrograms per cubic metre. PM₂.₅ pollution aggravates children’s breathing problems, allergies and asthma, and has also been associated with lung cancer. A primary source of PM₂.₅ pollution is emissions from cars and other vehicles.
People who still choose to walk would have to take a much longer route, probably via the Canterbury Road, which is a busy main road, where as well as the noise and pollution, there have been several accidents in recent years.
At a time of global concern about climate change, air pollution, public health and obesity, where people are being encouraged out of their cars for short journeys, and walking and cycling encouraged, we believe that closure of this well used crossing would be the wrong decision.
St George's Street Improvements
Canterbury District Green Party submission to the consultation February 2020
There are some aspects of the proposed redevelopment of St George’s Street that are to be welcomed. Repaving to increase the pedestrian space and the provision of extra seating will improve the community feel of the area. Creating a shared-space surface with a wider pedestrian area may also lead to cars driving more slowly along Canterbury Lane and giving way to pedestrians which is currently not the case. Hopefully, the numerous bollards that clutter the area around the Clock Tower, will be removed as they needlessly limit the pavement space for the many people who walk there.
However, plans for the removal of the existing trees are both short-sighted and unwarranted. These mature trees, which have recently been pruned, create an attractive natural feature along this stretch of St. George’s Street. Mature trees are a haven for birds and insects, and help create a calming atmosphere and natural backdrop to the urban landscape. Aesthetically, they look beautiful in all seasons and give the city a green feel which many people value.
It is well known that mature trees have other benefits too, including helping to ameliorate air pollution1. With its grid-locked roads and worsening traffic congestion, air pollution is a real problem in Canterbury and is set to worsen if the massive housing developments around the city are given the go-ahead. The St George’s roundabout is frequently at a standstill with exhaust fumes hanging over the area. Anything that helps to mitigate the effects of this pollution is to be welcomed and mature trees do this – so please let’s keep them.
There is a large body of research that supports the retention of established trees in urban environments. Guidelines from numerous bodies including town planning organisations, local government, environmental, scientific, health, tree and forestry groups repeatedly emphasize the importance of retaining mature trees. Many local authorities have heeded this advice and incorporated it into their own policy documents. This is because of the evidence showing that mature trees not only help absorb pollution but also provide valuable shade and drought resistance. Yet Canterbury City Council claim the trees need to go because they have “overbearing canopies” and would be better replaced with “manageable” new ones. It is simply wrong to state that the trees in St George’s Street cast “deep shade” on the surrounding area. In the summer, the dappled shade they offer is beneficial and any cooling effect is to be welcomed. According to the Trees & Design Action Group “Climate change and increasingly erratic weather patterns including heatwaves and extreme localised rainfall also put new pressures on the infrastructure of our towns and cities. Urban trees have a lot to offer towards urban cooling and surface water management”2.
By removing mature trees and replacing them with “manageable” ones, Canterbury City Council is acting against recommended best practice. Newly planted trees require a constant cycle of maintenance in order to stand a chance of surviving in an urban setting. With frequent dry spells in the south-east in particular, regular rainfall cannot be guaranteed and it will be costly in time and resources to ensure adequate watering of newly planted trees. Actually, many new tree plantings do not survive as they are vulnerable to drought, vandalism, disease and irregular maintenance. Far better, to concentrate on preserving the trees that already exist.
According to the Forestry Commission “Big is better……. larger trees in developments bring proportionately greater benefits. Shade, shelter, water attenuation, improved air quality, biodiversity and aesthetic values are all increased.”3 This is confirmed by many leading organisations and in an award-winning report by the Trees & Design Action Group, it is emphasized that “…most environmental benefits associated with trees in hard landscapes can only be realised if the trees reach and live through their mature stage. Efforts to retain existing large growing trees should be made a priority consideration, particularly when such trees are found in dense built-up setting where opportunities are limited and needs high”2. In the light of so much irrefutable evidence, it would be advisable for Canterbury City Council to think again.
This would be a good opportunity to review the plans to ensure that the existing trees are incorporated in any re-development of St. George’s Street. Let’s hope that an imaginative design that is both environmentally sound and people-friendly can be agreed with new planting to complement the existing trees and plenty of additional public seating to encourage people to enjoy the atmosphere of this beautiful city. Other suggestions include:
The provision of bicycle racks to encourage people to cycle into town
Replacing existing bins with simple recycling ones (such as those at the University of Kent) with a section for plastic waste so that some of the thousands of plastic bottles can be recycled and kept out of landfill4. With so many visitors, it would be a great initiative.
More space where people can walk freely and are not corralled into a narrow section near the Clock Tower by bollards and fast-food signs (the Kentucky Fried Chicken sign impedes pavement access).
There are some other issues in the proposed plans that are also of concern. Let us hope the distinctive, somewhat higgledy-piggledy character of this medieval city will be retained. Canterbury City Council claim that “adhoc market stalls on non-market days add to the general random, disorganised appearance of the street.” It is not clear how the redevelopment will affect the market stall-holders - it is important that they will not be disadvantaged as these traders add to the character and vibrancy of the city. Plans for a “central spine” with space for “electronic information, signposting and advertising boards” while removing the existing trees raises concerns about whether it will be in keeping with the character of the area. While the switch to LED lighting is a good initiative as it is more energy efficient and cheaper to run, this is only the case if lighting levels are kept roughly the same as they are at present. Hopefully, the area will not be over-illuminated as the plans suggest increased lighting “to illuminate trees and spaces”. These trees will presumably be the small replacements for the existing ones whose maturity is at odds with the “manageable” uniform look planned for the area.
Owing to increased awareness of the benefits of mature trees, there is growing consensus that felling such trees is a last resort only if the tree is diseased. Sheffield has been criticised recently for taking a gung-ho approach to removing mature trees leading to community groups and residents having to “fight” their council to try to stop needless tree-felling on their streets. It would be unwise to do the same here in Canterbury. One tree felled for spurious reasons because it does not fit into a particular design is one tree too many. It is the design that needs re-working not the tree that needs removing. It is hoped that those responsible for approving these plans are familiar with the report of the Working Group commissioned by DEFRA to examine the barriers to both planting and retaining urban trees5. This report suggests solutions to perceived problems of mature trees in urban settings and challenges some of the barriers put up by authorities when it comes to tree provision and retention.
In the Canterbury District Local Plan (2014 draft)6, the Council states it aims to “develop, protect and enhance Green infrastructure.” The mature trees in St George’s Street are part of this infrastructure and their protection should be a priority and the social, environmental and health benefits of these trees recognised as an amenity which benefits the city. The positive aspects of trees on air pollution, their cooling effects in city centres and the contribution they make to the well-being of local people should not be under-estimated.
Hopefully, plans to remove these well-established trees will be looked at again as their loss will be considerable.
Planting Healthy Air. A global analysis of the role of urban trees in addressing particulate matter pollution and extreme heat. Rob McDonald et al. The Nature Conservancy, 2016.
Trees in Hard Landscapes: a guide for delivery. Trees & Design Action Group, 2014.
The case for trees in development and the urban environment. The Forestry Commission July 2010
Just a third of plastic is recycled, survey shows. The Guardian Newspaper, 22nd November 2016.
The Barriers and Drivers to Planting and Retaining Urban Trees. Working Draft for Discussion. Working Group, 2013.
(As part of supporting The Big Tree Plant Defra tasked the Forestry Commission to set up a Working Group of partners to highlight the main barriers and drivers to both planting new trees and retaining existing ones within urban areas. This recently released report highlights potential solutions through recommendations from the Working Group and is intended to provide a platform for discussion with the relevant sectors that are perceived to be contributing to the barriers listed. It is hoped that the report will encourage constructive dialogue and assist in challenging some of the more entrenched issues around the provision of trees in urban areas).
Canterbury District Local Plan. CDLP Publication Draft. Canterbury City Council June 2014
Redevelopment of Wincheap Park&Ride Proposals
Canterbury District Green Party submission to the consultation February 2019
Canterbury District Green Party welcomes the addition of a much larger number of electric vehicle charging points in the proposed new Wincheap Park&Ride site and approves the substantial increase in the number of parking spaces overall, although the increase should probably be at least double the number envisaged. With the inevitably sharp rise in vehicle numbers heading into Canterbury along Wincheap from the new planned slip road off the A2, it will be of paramount importance to strongly encourage drivers to use the Park&Ride facilities.
Nevertheless, the current plan of extending the site down to the river bank is completely unacceptable for a variety of reasons:
The Canterbury District Local Plan designates the valley of the River Stour around Canterbury as an Area of High Landscape Value in which development is only allowed if it has “no significant impact upon … nature conservation interests”. Furthermore, Canterbury District’s Green Infrastructure Strategy 2018-2031 states the Council’s longer-term aspiration to “ensure wildlife and access corridor links into the urban area from the countryside are maintained and enhanced”. It is clear that extending the Park&Ride site down to the river bank would conflict with the Council’s stated aims and protections for this part of the Stour Valley.
127 trees are to be removed with only 35 retained whole or in part. Hambrook Marshes, which border the river at this site, are part of the flood plain and trees form an important barrier against flooding – they absorb 67 times the amount of water as compared to grassland. They also provide shade and cooler water for fish, a vital consideration when our climate is heating up.
The development entails the loss of allotments, a highly valued local amenity.
Inevitably, pollutants from vehicles parked on the site would flow directly into the river whenever it rains.
Yet more wildlife habitat would be lost, resulting in a further reduction in the number of species. 60% of species have become extinct over the last 35 years owing to human development.
The visual impact of this site for walkers and cyclists on the Great Stour Way would be extremely unwelcome and intrusive. They use this wonderful local amenity to “get away from it all” and feel they can escape to the countryside a short distance from the city.
Air pollution from vehicle exhaust fumes in the car park could easily spread to the other side of the river where the path runs. We know that this pollution is detrimental to health, especially for children and the elderly, leading to all kinds of respiratory problems, reduction in brain growth and dementia, among other things.
Access for pedestrians and cyclists to the Great Stour Way from Wincheap would be complex and potentially unsafe.
The best solution to satisfying the requirements of increasing parking space and yet maintaining distance between the river and the car park, and not cutting down trees, is to build a multi-storey car park on the site. This would need to be done sensitively, ensuring the building is shielded from view along the Great Stour Way by trees.
 Policy LB2 p. 248
 p. 17
Canterbury City Council Consultation: Station Road West Multi-Storey Car Park
Response from Canterbury District Green Party: 3 July 2017
Canterbury City Council claim that due to increasing numbers of people using rail services “there is a definite need to increase parking capacity”. The success of high speed services to London, rising numbers of students and visitors to the city and largescale residential developments will inevitably lead to much higher use of rail services. However, this does not automatically mean that there should be a three-fold increase in parking with a large multi storey car park being the only solution.
When approving numerous large developments, the city council argued that there would be little overall increase in traffic because there will be a “modal shift” in the way people travel. Much was made of this concept and reassurances given that all will be done to facilitate such a shift in line with the council’s own transport plans. Indeed, sensitive to criticism that air pollution in Canterbury will rise as a consequence of increased traffic generated by these developments, this argument was used as justification for granting planning approval. Now, there seems to be a change of direction and plans are afoot to build a 380-space car park to encourage rail users, visitors and locals to drive to the station. By providing so many additional spaces, the council is creating “induced demand” and when these spaces fill up (as is inevitable), it will be seen as justification for this £5 million project.
Currently there are approx. 129 spaces in the public car park in Station Road West in addition to a smaller station car park. There is also a temporary car park of 111 spaces. It is claimed that these car parks are almost always full. However, this is not the case as several visits at various times of the day have confirmed. Even at rush hour, there are empty spaces. Increased use of rail services (which is to be welcomed) does not require trebling the parking allocation, particularly in light of the council’s promise to encourage modal shift in the way people travel. There is no evidence to suggest that more car parking is needed “in order to maximise the opportunities for rail travel” and so the rationale for this project is flawed. The proposed multi storey car park will attract drivers into an already congested city, may discourage people from using other forms of transport to and from the station and negatively affect the character of the existing streetscape within a conservation area.
Canterbury West station is grade II listed and sited within the conservation area. It is the gateway into Canterbury – a World Heritage city. Within this context, it is vital that any proposed development is designed to create the least intrusive impact and not dominate or overpower the surrounding buildings. More importantly, it needs to be recognised that rail service users are not just car drivers. Indeed, most people will arrive at the station by bus, foot, cycle, taxi or be dropped-off and their needs should be factored into the proposed plans.
The design of the car park is out of scale for the area – it is too big and overpowering and will impact negatively on the surrounding conservation area. In their document Canterbury Parking Strategy 2006-2016, the council outline proposals to increase parking at Station Road West by approx. 140 spaces by adding an extra deck. Why has there been a change of policy regarding the size of the car park?
Aesthetically, it looks ugly, bulky and overshadows the adjacent buildings. The “wood-effect cladding” is monotonous and out of keeping with the materials used in surrounding buildings. Using vegetation to soften the effect of large block structures is an option and is often seen in European cities. Vertical wires for climbers to grow up would add interest and greenery. However, it is questionable whether there is a need for such a huge car park given the consequent detrimental effects it would have so comments on the intricacies of the design are in some ways, beside the point.
The proposed retail units are out of character and their design is corporate, dull and unimaginative. The idea that these should be appended to the front of the car park to “maximise the economic opportunities presented by the high-speed rail services” demonstrates that sustainability and visual appearance have not been properly considered. The council claim that they want to “make the pedestrian route ……as attractive as possible” and that these retail units will add to the vibrancy of the area. However, there is no proven demand for these shops which may take business away from the long-established independent shops in St Dunstans and result in more chain outlets, litter, light pollution, noise and street clutter.
Building these units requires provision of a loading bay for goods vehicles which will increase traffic movements in the area, including heavy goods commercial vehicles. These vehicles are mostly diesel – the most polluting kind which will impact on the large numbers of pedestrians walking by. The retail block will also necessitate the removal of eight mature horse chestnut trees. How will this improve the pedestrian experience? The value of mature street trees is well known - they help to ameliorate air pollution, provide valuable shade, improve the appearance of the streetscape and contribute to people’s wellbeing. The replacement of these trees by a few smaller ones planted close to the wall will not provide the same benefits and will not have the beneficial effect on air quality stated in the council’s plans but may actually make it worse by impeding air flow in the area. Recent guidance by NICE supports the retention of mature trees, stating that “Use of trees to encourage deposition of air pollutants, to reduce heat stress, provide shade and create a more attractive environment – all of which benefit health without inadvertently creating areas of poor air pollution”. NICE Guidance(p26).
Pedestrians and cyclists
There is little consideration given to pedestrians, cyclists and bus users. The current plan for a multi-storey carpark is to accommodate as many cars as possible (as confirmed at a recent consultation event). Provision for other forms of travel to and from the station has not been considered, as evidenced by the council’s statement that “cycle racks and seating would also be provided where space is available”. This is unacceptable and needs to be challenged because it undermines the whole premise of the council’s objective of supporting modal shift and ensuring that priority is given to pedestrians, cyclists, bus and taxi users. There are no actual plans to improve cycle access to the station or for bicycles to be safely stored. Cyclists should not have to enter the car park building to secure their bikes in whatever space is left – the air quality in this building will be heavily polluted and there will vehicles moving around at most times. Priority must be given for a separate cycle storage area with dedicated access.
The design of the access areas of the car park will make it difficult for pedestrians to cross safely. It is a wide area and there appears to be no crossing so the large numbers of people walking here will be subject to cars driving out at them. There should, at the very least, be a raised surface to indicate to car drivers that people have priority when crossing.
In a report by Smarter Cambridge Transport presented to the Parliamentary Transport Committee’s Urban Congestion enquiry (December 2016), the following suggestions are made with reference to the issue of parking at stations:
§ In most cities, train stations are at the centre of a highly congested road network. It therefore makes sense to gradually reduce the number of car parking spaces provided, reducing congestion.
§ Providing high quality, secure cycle parking and short-term bike hire services at stations reduces the need for car parking and the volume of private and hire car traffic accessing the station.
§ A large car park would be neither desirable nor necessary at most such hubs [transport hubs such as stations]: many busy train stations have little parking provision, with most people walking, cycling or being dropped off.
The proposed plans will have an environmental impact that needs to be fully evaluated. The main impact arises from the generation of more traffic leading to increased levels of air pollution and congestion in an already congested area. St. Dunstans has high levels of car traffic and is a pollution hot-spot due to the level-crossing and the build-up of exhaust fumes in the area. Air pollution must be taken more seriously and needs to be factored into every new development as the health consequences of ignoring this will be felt by all the people in Canterbury. There is strong evidence showing that the only way to tackle air pollution is to take positive steps to change the culture that puts cars at the forefront and ensure that all local planning decisions are taken within the context of supporting modal shift and minimising the impacts on people’s health and wellbeing that over- development and increased traffic cause.
The height of the proposed car park and its proximity to the road will create a “canyon effect” which traps air pollution and prevents dispersal. There is no doubt that the expanded car park will attract more traffic into the area resulting in higher levels of air pollution and the design itself adds to this effect. NICE have recently issued guidance that echoes other research, calling for planning decisions to ensure that every possible measure is taken to reduce air pollution. The latest guidance issued on 30 June 2017 states that councils should consider the following points:
Siting and designing new buildings, facilities and estates to reduce the need for motorised travel
Minimising the exposure of vulnerable groups to air pollution by not siting buildings in areas where pollution levels will be high
Siting living accommodation away from roadsides
Avoiding the creation of street and building configurations (such as deep street canyons) that encourage pollution to build up where people spend time
Including landscape features such as trees and vegetation in open spaces or as 'green' walls or roofs where this does not restrict ventilation
Including information in the plan about how structures such as buildings and other physical barriers will affect the distribution of air pollutants
It seems that Canterbury City Council has changed its policy of sustainable travel as in one of their own policy documents Canterbury Parking Strategy 2006-2016, the following statement is made: “The strategy aims to reduce the need for drivers to travel to and from the city centre reflecting concerns about the impact of traffic congestion on the environment and historic fabric of the city, while providing parking provisions that meet a sustainable demand.”
It is the view of Canterbury District Green Party that the proposed expansion of parking at Canterbury West is unnecessary and is contrary to the council’s own policy of promoting non-car modes of travel in the city.
It is not simply a matter of the building design but the concept of increasing by three-fold the parking in an already heavily congested area. As the research evidence shows, this leads to “induced demand” meaning that the car park will act as a magnet and attract more vehicles into the St Dunstans area. This will lead to worse air quality, a reduced area for pedestrians (the most frequent users of rail services) and degradation of the local environment. Investing so much in this car park will inevitably lead to a lack of money and support for the development of essential sustainable forms of transport that are so desperately needed in this city.
Canterbury District Green Party support the approach to sustainable transport advocated by Smarter Cambridge Transport who argue that:
“To achieve modal shift in towns and cities we need to invest in improving sustainable transport modes and, at the same time, reduce capacity, access and convenience of urban road networks for motor vehicles. This requires a revolution in transport planning: no longer can the motor vehicle be king of the city. We must design urban roads and streets to be attractive and convenient places to walk, cycle and use public transport”.
Building this huge ugly car park together with the retail and office units and justifying such an over-development as an economic opportunity is inappropriate. The impact of this proposed development will detrimentally affect the appearance of the conservation area, air quality, pedestrian experience, local residents’ quality of life and increase traffic to unacceptable levels. The council has a duty of responsibility to the people of Canterbury to adopt the best practice recommendations of a number of key advisory agencies and also its own sustainable transport policy and abandon plans for such a large-scale development.
The council must publish all responses to this consultation in whichever format they are submitted so that there is full community engagement and a process that is open to wider public scrutiny of such an important proposal with far reaching consequences for Canterbury.
Smarter Cambridge Transport submission to Urban Congestion Inquiry Parliamentary Transport Committee: 12 December 2016
NICE guideline Published: 30 June 2017, nice.org.uk/guidance/ng70
Nine Reasons to Vote Yes to Europe
1 Fighting Climate Change
It’s only through concerted international efforts that we have a chance of solving the climate crisis. The UK’s membership of the EU is a crucial part of that fight.
2 Our Rights at work
Our rights at work - from paid holidays, to maternity pay and the right to strike - are protected by EU rules.
3 Controlling Corporate Power
With corporations operating across borders - and attempting to drive down wages and environmental protections in the process - it’s clear that we need international rules to keep them in check, and cross-border action to tackle tax-dodging.
4 Protecting our Environment
Our beaches are cleaner, our air less polluted, and our wildlife is far safer because of EU protections. We benefit from over 100 European laws protecting people and our environment.
5 Tackling Poverty
EU funds help some of the most deprived communities in Europe - including many places in the UK. Working closely with other EU countries allows us to begin tackling the huge inequalities across our continent.
6 Creating Decent Jobs EU membership gives us a better chance of getting a decent job. 3-4 million jobs are linked directly and indirectly to our trade with other EU countries according to a range of studies by independent experts as well as the UK Government.
7 Freedom of Movement All EU citizens have the right to freedom of movement. Whether that means travelling across Europe, studying abroad, retiring to Spain or moving to Britain to work - it enriches our lives and culture.
8 Peace and Security The EU has been crucial to lasting peace in Europe after the bloodshed of the Second World War. No matter how slow some of the discussions can be in Europe it’s infinitely better to be sitting around a table discussing issues rather than resorting to bullets and bombs.
9 Because we can achieve so much more together
The EU isn’t perfect, but to change Europe, we’ve got to keep our seat at the table. Greens are fighting for a more democratic EU – where citizens have more of a say. By working together with people across Europe, we can ensure the EU goes further in protecting our environment, lifting people out of poverty, and challenging the power of corporations.
Greens were active in the strong campaigns by East Kent Against Fracking and Keep Shepherdswell Well in 2013 and 2014 to fight applications for coal bed methane exploration at four sites in East Kent, which could eventually have led to fracking. The campaign groups raised public awareness about the damage which could be done to the environment by drilling exploratory boreholes in the region, particularly highlighting the risk of contamination to the chalk aquifer, which supplies more than 70% of Kent with its drinking water supplies. Three applications were withdrawn after the Environment Agency required detailed explanations on how the company concerned (Coastal Oil and Gas Ltd) would protect the aquifer.
The 14th round of government Petroleum Exploration and Development Licences (PEDLs) in 2015 saw Kent free of licences, Coastal Oil and Gas Ltd having relinquished those it held in the county.
An estimated 81 people die each year in Canterbury District as a result of air pollution from traffic.
Green MEP Keith Taylor joins Green Party members in Canterbury on 30th April 2013. They are canvassing for the KCC Election and pausing to draw attention to the vital importance of good air quality.
See Keith's publication 'Air Pollution - The Invisible Killer' for more information about the issue
Public transport should be owned by the public and for the benefit of the public, not shareholders.
We are campaigning for the renationalisation of our railways and for proper investment in this clean, green form of transport.
We continue to campaign for 20mph roads where people live. Research has shown that accidents are significantly reduced while traffic is not unduly delayed.