6th April 2006

Submission to Stroud District Council. 

I am writing on behalf of the Stroud District Green party and would like to raise a number of very serious concerns regarding the EIA.

1. Transport

The Inspector to the SDC Local Plan advised that Aston Down was unsustainable in transport terms. We agree with the comments made by Cllr Martin Whiteside in his letter to SDC dated 17th March 2006 and enclosed below (see note i). The case outlined there is overwhelming and the omissions and inconsitancies that appear to have been made in the ES are very concerning.

Additional points:
- Nailsworth does not appear to have been addressed as part of the employee catchment area: if this is the case then analysis of employee figures will be based on incorrect data and result in an error.
- The ES fails to address whether the proposal is likely to have a significant affect on the livestock on the Commons and therefore the condition of the Commons.
- accident sites and public transport accessibility data are out of date and cannot be used to give an accurate picture of the proposals and their effect on the area.

2. Outside storage

There has been and still is a considerable amount of outside storage on the site. However, the outer sites storage on F and G Sites have been recently been removed.  The visual impact of outside storage including HGV and vehicle parking on the whole site has not been fully addressed within the ES.  The ES should also address this impact during the winter months when the trees are bare and the site exposed.

3. Contamination

This report is wholly insufficient regarding possible contamination. Further investigations are essential to determine the extent of the radioactive and other contamination: some of the figures we have seen are very worrying. Radium 226, for example, is present on the site above statutory contol levels. Furthermore there is a small possibility that plutonium maybe on the site: if this is the case it is extremely dangerous and hard to detect over large distances as the Alpha particles that are emitted can easily be shielded by its surroundings. Our understanding is that the equipment used in the surveys was not designed to detect the alpha radiation emitted by plutonium and depleted uranium.

Indeed the radiological report produced by the Rite Advice limits the report to the risks associated with radiological contamination of luminised aeronautical items buried on site.  This report therefore does not address the risks of any other radiological contamination which the LQAs advise that has existed at the site and potentially buried at depths on site.

The findings of the previous Land Quality Assessment survey, also only looked at evidence that considered contamination to a depth of 0.5m and was not a complete look at the site due to long grass and parked cars. We understand it also did not consider inside the buildings. The Phase II LQA Radiological Survey prepared by Enviros Aspinwall appears to have limited the radiological walkover of the whole site to 5%.

These reports are now over 5 years old and it is our understanding that the Defence Estates Policy Instruction Environment Management states that such surveys have a limited shelf life, that is "likely to be three years provided that there is no significant change in site activities". Infact, when these reports were written there was virtually no activity at the site, in recent years activity has increased very significantly, including trench digging, that may have led to the release of further contamination. The Land Quality Assessments conclude that only a 100% test of the whole site area could accurately define the true level of contamination. It is our concern that workers currently using the site are at risk of dangerous contamination. The Green party has written to the Health and Safety Executive regarding these concerns.

It is clear that the EIA does not assess fully the potential or existing effect on humans of the contamination on the site.

4. Integrity of buildings

The integrity of the buildings at Aston Down do not appear to have been assessed. This is of particular relevance as to whether the site should be re-used, or as to how much should be re-used - particularly when also considering the transport concerns. The evidence we have read makes clear that the WWII hangars were not designed for long term use or permanent structures. We have very considerable concerns about their inherent weaknesses (see note ii). Are these buildings to be demolished? And if they are, then surely their replacement with modern buildings should be addressed in terms of what impact this would have on the environment, in terms of size, shape, lighting, sustainability etc.

5. Planning concerns

The site is located within the open countryside and the Cotswold Area of Outstanding Natural Beauty (AONB), where strict development controls operate, particularly with regard to major development. It is not within an area of the District identified in the Structure or Local Plans for development - even in the latest version of the Stroud District Local Plan (May 2005). The Inspector previously concluded:

"… I consider this depot site and the sporadically located businesses nearby to be in open countryside. The sites have negligible public transport provision. There is limited opportunity for cycling to the sites and none for pedestrian access. The depot is vacant but it is understood that about 80 workers were employed on site. The depot is up for sale and is likely to be used for a B.8 use. I do not believe the depot or the other sites in the area would reasonably comply with criteria [in the Stroud District Local Plan] for a key employment site. In particular, the sites are not located within a reasonable distance of a settlement boundary and are not sustainable development in terms of public transport or cycling." (para. 4.6.25).

There are many other policy statements including those specific to AONB, that make this an unsuitable site for development. It is seems surprising therefore that the proposed uses on site include B.8. which the Structure Plan specifically argues needs to be served from wharves, harbours or railway sidings - none of which are at this site. It is also important to note that the site was abandonded when the military left and it is the view of many that the site is deemed to be 'nil use'.


6. Landscape, ecology and aquifer

The Landscape and Visual Assessment concludes that the existing ‘historic military airfield’ landscape should remain, yet does not give a satisfactory justification for this. There is indeed an opportunity to keep this site as a ‘historic military airfield’, yet the historical connections will only be obvious so long as the aircraft hangers and the gliding club remain. As noted in section 4 above, the integrity of many of the buildings mean that very significant work would be needed to restore them. In the light of the transport and other concerns it would also not seem appropriate to consider the whole site as suitable for such a significant development. Some very limited development, much less than is currently operating on the site, might be suitable but this option would need careful consideration. In any case this is an opportunity to develop the landscape into something more harmonious with the surrounding landscape.

The ES does not appear to have sufficiently considered and assessed the bat populations enough to be able to grant this planning application.

A significant proportion of the Aston Down site is situated over a designated sensitive Major Aquifer, within a 400 day Source Protection Zone. Many aspects relating to this aquifer do not appear to have been addressed (see note iii and concerns raised with the Environment Agency). The EIA also do not appear to distinquish between the minor aquifer below D site and the Major Aquifer over which the rest of the site lies. The assessment on the Aquifer is quite clearly insufficient.
 

Philip Booth, on behalf of Stroud District Green Party.

Notes:

(i) Letter from Cllr. Martin Whiteside re traffic concerns

Mr Darryl Rogers, Major Sites Officer,
Planning Department, Stroud District Council, Ebley Mill, Stroud. GL5 4UB

17 March 2006

Dear Darryl

Re – Aston Down Environmental Statement (ES)

I have read the traffic section of the Environmental Statement and find it seriously flawed on a number of counts.

There is no assessment of the impact of traffic generated along the A419 West down Cowcombe Hill, through residential areas of Chalford, past St Mary’s corner, through the residential areas of Brimscombe and Thrupp, through the residential/school areas of either Rodborough or Cainscross (including double roundabouts) to the M5.  I specifically asked in writing that this should be included as this is a  key issue. From the figures in the ES (table 8/T) it can be calculated that 82% of Aston Down inbound HGVs and 72% of outbound HGVs are likely to use the A419 west once the common HGV ban is in place – yet this has not even been assessed in this ES!1

The ES states (para 8.18) the A419 is generally good standard, is approximately 7.5 metres wide, while this may be true to the east, it is patently incorrect to the west where the carriageway narrows in at least four places to under 5.8m and one place to 5.38m, often without verges or pavements. This section of the A419 has been described as the only A road in England where two HGVs cannot pass each other.  It is already congested and is likely to have additional HGV movements once the HGV ban across Rodborough Common comes into force.  This road is subject to frequent maintenance with traffic lights due to the concentration of services along the road and the narrow verges due to the topography – encouraging drivers to use even less appropriate ‘rat-runs’ past the school on Thrupp Lane etc.  Any increase in traffic along this section of the A419 will therefore be a problem that will not be solved by junction improvements at the A419/Cirencester Rd and will have a high probability of resulting in fatalities.

The junction between the Cirencester Road and A419 is noted in the report as being already above capacity at peak AM.  It does not note however that this causes tail-backs towards a blind bend.  It does however claim that since the junction is already over capacity, and the additional load generated by Aston Down is likely to be a relatively small part of the total, it should not be considered significant.  Any addition to a junction already considered beyond capacity should be considered significant.  The report fails to note that the proportion of extra load generated by Aston Down at this junction will be increased once the HGV ban is in place across the common and the signage directing drivers from Aston Down to this junction are in place.

The report notes that Aston Down will contribute increased traffic at the accident black-spot of Tom Longs Post and generously offers to contribute money towards road improvements there.  This completely fails to recognise that the problem of additional traffic across the commons is not limited to accidents at Tom Long’s Post – but includes the loss of amenity to all common users, impact on the SSSIs and traffic through the Butts, Rodborough Hill and the many other pinch points leaving the commons.  None of this is analysed or even mentioned in this report.

The report notes that 100% of employees use private cars to access Aston Down and 0% use other forms of transport.  It then analyses typical Stroud and Minchinhampton residents journeys to work and concludes (in para 8.55) that ‘the level of car based travel to employment facilities within the local area is comparable with that currently experienced at Aston Down’.  However the figures actually show that 22% of Stroud employees travel to work not using a private car.  Since when has 0% been comparable to 22%?

The argument used in para 8.58 seems to defy logic!  It basically takes the average distance from home to work of the widely scattered current Aston Down workforce and compares the distance the same people would have to travel to work if they worked in Stroud - and uses this to conclude that Aston Down is a sustainable employment site.    However logic would suggest that if new employment opportunities were located in Stroud then the workforce would be more Stroud based (with less from Cirencester District, Tetbury etc.) than the current Aston Down workforce – and this would considerably reduce journey distances.  Therefore the conclusion of this section is patently incorrect and Aston Down is clearly shown to have low sustainability on journey to work criteria.

The report states that much of the cross-common traffic currently generated from use without planning permission at Aston Down comes from Serviceteam(Para 8.140), it then states that this is to service properties around the common and that therefore this would continue wherever Serviceteam were located. This seems unlikely, with the commons being the logical shortcut from Aston Down to the much higher population areas in the valley bottoms like Nailsworth, Rodborough, Cainbscross, Stonehouse etc.  Having the Serviceteam depot right on the boundary of the District, with the major access to the population they serve either across the commons or down a steep hill through Thrupp is highly inefficient in energy and CO2 terms as well as bad for the Commons and transport congestion through Thrupp.  This is not mentioned.

In summary it seems that this transport statement is full of errors and cannot be used to assess the impact of development at Aston Down.  The failure of the developers a second time to produce an adequate traffic assessment just emphasises the lack of sustainability of Aston Down for the type of uses being proposed.

Yours sincerely

Martin Whiteside
Thrupp District Councillor


(ii) Integrity of the hangars

The MOD/Defence Estates Technical Bulletins on World War II Hangars shows that these hangars have inherent weaknesses: 3 Bellman hangars collapsed in adverse weather conditions in Scotland. The Bulletins note that because of the Bellmans widespan design there are a number of health and safety risks. These include:

(a)  In gusts of 60mph the hangar doors must remain closed otherwise the hangar may have uplift and structural damage.
(b) In snowfall of between 2 to 4 inches, a view must be taken on the structure and whether the hangar must be evacuated by personnel or if the storage is valuable that it is removed.

The Mandatory MOD Technical Bulletin (2002) which covers Health and Safety at Work issues for all MOD World War II hangars sets down that all the hangars had to be appraised by a qualified chartered engineer with at least 6 years experience in steel structures, and must be undertaken every 5 years. The EIA does not appear to consider these factors.


(iii) Sections taken from an email by Stroud District Green party to the Environment Agency raising a number of concerns relating to the aquifer (31/03/06):

 - It is evident that until the sewer and drainage system is replaced, contaminants (including human waste) appear to be compromising the purity of the water.  What can be done to rectify this now?  Should those activities that are causing pollution or have the potentional to cause pollution be stopped until such time as the planning application is determined and conditions put in place prior to activities commencing? This is, of course, based on the application being approved, if it is refused then there would not be a problem.  What powers does the Environment Agency have?

- Radioactive contamination, heavy metals and hydrocarbons are present in the soil at levels considered dangerous. The report by Rite Advice limits the radiological risk assessment to only the radiological risks associated within the legacy of luminised aeronautical items buried on site. This should encompass all radiological risks and in particular those associated with the storage and possible burial of items brought back from western Australia contaminated from nuclear tests.  The current heavy use of the site which has included recycling activities, maintenance of vehicles, many vehicle movements, trench digging and storage is likely to be disturbing these contaminants and could lead to contamination of the environment including the aquifer. There is also the potential risk of the removal of spoils of earth containing contaminants off the site and being reused.

- Figures in the EIA are from a baseline in 2001. The MOD vacated the site on 31 March 2001.  Most activities during these last few months would have been wound down. Since the base was on the whole empty in 2001 this makes the statements in the EIA misleading and confusing?

- Aston Down Polo Grounds bore hole has been omitted from the ES.  This is the closest bore hole to the main site at Aston Down and most likely to be affected by any pollutants and should be included in the ES. I cannot see any reason why this should have been omitted?