Response 649010440

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Seeking your views

4. Please provide your comments on the environmental permit application received from East Kent Recycling Limited

Please provide your comments on the environmental permit application received from East Kent Recycling Limited (Required)
In their submission on behalf of East Kent Recycling with specific regard to Air Quality within the AQMA at Ospringe on the A2 Waterman conclude with the sentence: ‘In all cases the “with development” proposition identifies a reduction in potential harm, and therefore an environmental benefit.’ Implicit in those words is the knowledge and acceptance that harmful pollution exists at the designated AQMA at Ospringe as a result of the excessive quantity of vehicles using the A2 and the low lying canyon nature of the road there, closely bounded by many important historical properties. Also in that submission Table 3 gives incorrect, limited and misleading listed numbers for NO2 measures at locations along the AQMA, implying that these levels are close to the acceptable legal limits when in fact they are not and have not been throughout the recording made by Swale Borough Council between 2005 and 2017. The proposal from East Kent Recycling is just one of many ongoing and cumulative developments in the town that inevitably will impact on traffic numbers on the A2, of which Heavy Goods Vehicles have always been and will be in the future a very significant contributing factor to poor Air Quality at Ospringe (because of the narrowing and restricted carriageway there), and undoubtedly at other locations along the A2 at times of heavy congestion on the road. It is grossly misleading then to speak of ‘environmental benefit’, in this specific context, when an estimated 226 residents living at Ospringe are subjected daily, and have been for continuously for many years, to damaging traffic pollution which can only be ameliorated tangibly and effectively by reduced traffic numbers per se. Given the present situation of road infrastructure in the town any proposals that will add to traffic numbers and emissions on the A2 will be damaging to Air Quality and the presentment for the Local Authority must be to restrict any application that will have this effect in the absence first of clear and measurable reductions in traffic numbers and types that will legally satisfy the Air Quality Directive at Ospringe, according to the judgement made by Mr Justice Garnham (https://www.documents.clientearth.org/wp-content/uploads/library/2018-02-21-high-court-ruling-on-remedies-clientearth-no3-vs-ssefra-liberty-to-apply-and-air-pollution-plans-ext-en.pdf), and confirmed with direct relevance in local context for the AQMA on the A2 at Newington (which is precisely comparable with the situation at Ospringe on the A2) by Mr Justice Slipperstone (http://www.bailii.org/ew/cases/EWHC/Admin/2017/2768.html).