To Red Wood...

Phesants...

Track through Clarkes Wood

Track through Clarkes Wood

Ruined beech, Clarkes Wood...

Parish boundary marker tree, Clarkes Wood...

Track from Clarkes Wood into Red Wood...

Old shepherds hut, Red Wood...

Ancient beech and one-time bat roost, Red Wood

View towards Cuxton from edge of Red Wood...

Warren House from edge of Red Wood...

Cuxton from Peckway...

Back towards Red Wood, looking east from Great Peckham Field..

 

Reasons To be Objectionable (Part 3)

What Vineyard Farm's new restaurant complex may look like at night...

In previous posts I have described how the Vineyard Farms planning proposals for a new country club and restaurant in Bush Valley are primarily based on sophistry and inadequate and distorted data. The Ecological Impact assessment doesn’t quite fall into either of those categories, but, rather like the traffic survey, it looks to be limited in scope and with serious omissions. It seems that the assessment refers only to the impact on the immediate area of the site, as if somehow the site exists in complete isolation from the habitat around it. Both the Environment Agency and Natural England have nodded the assessment through, but only on face value as they rely solely on the assessors to flag up any issues.

The site itself is historically arable farmland, and so it would not be expected to harbour permanent populations of wildlife. Similarly, the band of scrubby woodland to the north of the site scheduled for hacking back is only around 40 years old and (from my own walk-around in it) I would agree with the survey when it says that it is nothing special.  (Update: as an antidote to my lamentable ignorance about the value of this "plantation" woodland, please see p.20 of the "Community Insight" document. It is far more valuable than I thought...)

The winery development site is in close proximity to SSSI sites to the south and west, however. Whilst these are acknowledged by the assessment as existing, the long-term effects of the construction and operation of the restaurant and entertainment venue upon the adjacent wildlife is only mentioned in passing.

Hypercallia Citrinallis

The extensive Halling and Trottiscliffe escarpment received its SSSI designation because of the presence of rare insects and orchids. The survey does not consider the impact that Vineyards Farm’s new country club could have on the nearby SSSI woodlands and its wildlife.  It mentions in passing the rare moth Hypercallia citrinallis (found nowhere else in the UK) and yet the assessment made no attempt to see if it was present, even in transit, on the site. A simple night-time moth trap could have been used.

Both the lighting assessment and Foster & Partners Design and Access statement show that the restaurant building will be lit up throughout the night.  At the moment this is quite a dark site, largely sheltered from the lights of Cuxton and further afield by woods and hills. Given the elevated position of the Vineyard Farms’ new country club on the top of Barrow Hill, however, it is going to act like a giant insect trap in Bush Valley when lit up at night.  The adverse affects of artificial lights upon wildlife are well known yet the assessment fails to mention it.  I wonder why?

Red Wood, looking south from fields above Warren Road...

I was also very surprised by the bat survey results. Back in 2017 I witnessed dozens of noctule bats (Britain’s largest bat) flying around Bush Valley, and yet the survey in 2021 found not much bat activity (though there were apparently some “big” bats around that the survey couldn’t name!).  It seemed that they suffered from mysterious technical failures of their recorders and no attempt was made to repeat the work due to the rushed nature of the assessment.

This lack of bats led me to go looking for the noctule bat roost that I had been shown at the northern end of Red Wood. Historical records of bat surveys in the area showed no evidence of the roost I saw, but then I certainly never brought widespread attention to it (I don’t count this blog as nobody reads it) and neither would my bat-hunting companion have done (and indeed, we have seen what happens when you advertise the presence of our wildlife to the wider “community”…).

Unfortunately, I found that that area of Red Wood has recently been coppiced (long overdue, to be fair). I certainly couldn’t find any evidence of the rotten old chestnut trees that were the roosting trees, but to be fair I am not 100% certain they were in the area where the coppicing has taken place. It is illegal to disturb bat roosts, but Tilhill (the woodland contractors for Vineyard Farms) are a highly professional crew and I have no doubt they would have spotted the roost if it was there.

Northern part of Red Wood, recently coppiced...

It seems likely that the coppicing activity would have disturbed any nearby bats though, who would have just flown off elsewhere.

If you want to make an objection to the council about Vineyard Farm’s proposal, then you are running out of time (closing date September 22nd.) 

As an aside, I have been rather surprised to see the degree of on-line hostility directed towards those of us who have taken the considerable trouble to read through the hundreds of pages of planning application documents and analyse them in detail. I came into this with an open mind, hoping to see a sound justification for the project. I really, really like Lord Foster’s design. Instead, the submission has been shown to be a rather disappointing collection of half-truths and distortions, some of which could have a significant negative impact upon the village of Cuxton. I thought local folk would be grateful for our efforts in calling all this out.

Instead, we have been decried as NIMBYS, whingers and (my favourite) “fluffy hand wringers”. I’m not going to respond to that. After all we live in a democracy, where one person’s angry, self-centred ignorance is equivalent to another’s knowledgeable attempts to educate and inform.

I look forward to seeing a reasoned, well-argued case in favour of Vineyard Farms’ plans. It isn’t in their planning application as yet. And it certainly won’t be put together by some of the Facetube/Twitbook brigade, who prefer lazy insults to the hard work of actual research and careful, documented argument…

Reasons To Be Objectionable, Part 2...

Chicane on Bush Road, bottom of Wood Street...

In my last post I explained how the Vineyard Farm planning application to build a country club-style winery in Bush Valley is effectively based on smoke and mirrors.

My objection on that point is really one of principle: plonking new buildings in green belt land is simply not permitted under existing planning regulations.

It looks like most people in the area don’t really care about that, however. Most local people don’t take walks in our wonderful countryside in Bush Valley, it seems. Vineyard Farm’s plans for Upper Bush don’t directly affect them, so they’re not bothered. Oh, it might even be a nice place to go for a meal, they’re thinking. It will even create jobs (how many local, I wonder? Enough to offset the local job losses that occurred when Vineyard Farms bought out Court and Brookers Farm and then Bush Farm?).  

But this post is going to concentrate on how the winery development will directly and adversely affect all residents of Cuxton.

Everyone who lives in the village knows how congested Bush Road can get, especially at school run time. It is effectively a single track road, with three chicanes and lots of on-road parking that makes HGV and delivery driver’s lives pretty difficult – especially at school run time when Cuxton Primary empties out.

Parking on the main road by the Co-Op.  Note the bus stop parking - so much for public transport...

The proposals put in by Vineyard Farms (see the Framework Travel Plan on the council’s planning web page) freely admit that around 70,000 visitors a year will be going to the winery. The site will also employ around 150 winery and estate workers.

We all know how poor public transport to and from Cuxton is. We all know most of these visitors and staff will be driving to the winery.

The Outline Deliveries and Servicing Management Plan tells us that around 850 HGVs a year will be going to and from the site. There will also be waste collections and deliveries of goods via non-HGV vehicles.

It all adds up. It’s all additional traffic trying to negotiate the three chicanes (where the road has been narrowed at the bottom of Wood Street, by the social club, and just up from the bottom of Charles Drive) and the resident’s cars parked by the shops and further along the road.  And that's without the cars parked up during school run time.

Bush Road is already heavily congested. Anyone who walks along it, pretty much any time, can see that.

Parking outside school, non-peak...

And yet the Transport Assessment concludes in Section 2.23 that “that traffic flows on Bush Road are low”…

This defies all common sense and even the most casual of observations. How on earth does it come to that conclusion? 

Simple…

Section 2.21.states that vehicle count data was gathered from an area adjacent to the Dean Farm access road. This is a completely inappropriate place to conduct a traffic survey if the true extent of congestion in Bush Road is to be assessed. Congestion in Bush Road occurs primarily between the school and the A228 junction and this is where interactions of new facility traffic with existing traffic are likely to occur.  The data in the survey is skewed because it effectively excludes much of the existing traffic.

Section 2.22:  Peak times for traffic are given as 8-9 a.m and 5-6 p.m. This is also wrong, as the traffic congestion in Bush Road is primarily driven by the “school run” times, which are 8.15-9.15 a.m. and 2.30 – 5.00 p.m.

The conclusion in 2.23 that “that traffic flows on Bush Road are low” is therefore based on completely unrepresentative data.   

2.24. Given the above poor choice of the traffic survey data collection point, HGV movements have also been severely underestimated as many HGVs are deliveries to Cuxton village that will run up James Road, or to the Co-Op, well before the data collection point.

Given that the traffic survey data is derived from the wrong place and the wrong times, any conclusions drawn are effectively meaningless. This survey has to be repeated in a proper manner before any compliance with consent conditions can be assessed.

Social club chicane...

There is another omission in Meyer Brown’s Transport Assessment.

Section 4 of the Transport Document attempts to justify the development in terms of manufacturing process logistics. It claims that the grape processing, fermentation and bottling process has to be conducted local to the vineyard for quality considerations, and that therefore the wine factory has to be built at Upper Bush.

It ignores the obvious logistical solution. Crushing the grapes on site (to reduce possible bruising and oxidation damage to the fruit if otherwise transported) could take place in very modest facilities, possibly even existing ones at Court and Brookers Farm in Luddesdown. Based on 900 acres with a 3 ton per acre yield, it would subsequently need only approximately 90 tanker movements to transport an entire annual juice harvest to a local business park that had a fermentation and bottling plant built there, with access that allows easy delivery of bottles and process consumables, and distribution of finished product.

As stated earlier, the Meyer Brown documents suggest 850 HGV movements a year in the proposed facility. The alternative, completely unaddressed by any of the submission documents, reduces this enormously.

It must be emphasised that were this activity to be primarily focussed upon the production of bottled wine, the fermentation and bottling operations would take place at a facility with better transport access than that offered by Upper Bush – and one that would not cost £30m.

This option has not been discussed at all in the proposal.

Charles Road chicane...

And so it goes on…

In terms of access to the proposed development site post-construction, it is worth noting that section 3.25 of the Mayer Brown Transport Assessment admits that the site accessibility index is zero, due to its rural location away from major roads and its poor access to public transport.

The document then attempts to describe Cuxton’s accessibility by means other than a car as meeting national and local planning criteria for accessibility. This is not supportable. Bus and train services do not directly connect with any major transport hub, with drop-off points located well away from the proposed facility.

The Outline Delivery and Services Management plan is also flawed.  It states (1.11) that 3 HGV deliveries will be made per day for import and export.  This does not allow for the seasonal nature of the business.  If we assume this means “3 per working day” then this means approximately 750 HGV vehicles to site per annum (or 1500 HGV transits), with the majority arriving in 3 months over harvest time.  If we assume that 75% of HGV deliveries are seasonal, this means that around 10 HGVs per day will be arrived at peak season.

HGV deliveries will supposedly be restricted to 6-7 pm and 4-5pm. The latter times clearly clash with school run times. This also indicates that morning deliveries will be made at anti-social times (defined as operation outside of normal business hours by both trade unions and mental health professionals).

Sections 1.15-1.21 rely entirely on the goodwill of delivery drivers to minimise site nuisance noise arising from deliveries and do not say what action will taken to enforce compliance.

So, villagers of Cuxton, if you ignore this one, then you really can’t complain in the event that the tourist and vineyard maintenance traffic clogs Bush Road and turns any journey to or from your home into a logistical nightmare.

You were warned.

Reasons To Be Objectionable (Part 1...)

 

The plans for the Vineyard Farms winery for Upper Bush in Cuxton have now finally been put up on Medway Council’s planning portal. Just put the word “winery” into the search panel and you will have access to the thousand or so pages of assessments, planning statements and (of course) all of the glossy brochures provided by Foster and partners for the breath-taking flying saucer they want to crash in one of Medway’s last bits of green belt land.

The response deadline is next Wednesday September 22nd so you haven't got much time to comment on it.

I’ve had a good read of most of it, though.

All I can say is that in a fair and just world, this planning application should have been laughed out of the planning office during the pre-application stage. (But of course, it’s Medway Council we are dealing with here, with their vainglorious dreams of city status…)

The absolute, unavoidable reason why this application should have been kicked straight out by Medway Council is that building new buildings on green belt land is still pretty much forbidden.  End of.  No argument.  

The National Planning Policy Framework 2021 sets out what the Government’s planning policies are for England and how they should be applied. Section 13 details protections for Green Belt land (in which the proposed development lies) and paragraph 149 is unequivocal:

149. A local planning authority should regard the construction of new buildings as inappropriate in the Green Belt.

It is noticeable that the Shrimplin-authored Planning Document refers to many sections of the NPPF and other planning guidelines, yet funnily enough, it fails to mention this one.  The biggie.  The "er, we're not really allowed to do this, are we...?" one.

In desperation, the Vineyard Farm application to build on Green Belt land relies on claiming that the winery building is an “agricultural” development and is therefore exempt from Green Belt/ANOB planning restrictions.

This is complete and utter rubbish; indeed, the Planning Statement tries to pass off Lord Foster's spectacular £30m design as some sort of farm shop! The proposed winery building is, first and foremost, a sophisticated entertainment venue with a “visitor’s centre” comprising of a large restaurant, bar and café.  It will be used primarily by visitors and restaurant customers – how can they claim it is an agricultural building? 

Foster & Partners own series of beautiful, highly impressive but desperately superficial “Design and Access Statements” (and in particular, Volumes 3, 4 and 5) show the emphasis that is being placed upon the visitor reception, restaurant, café, retail and wine-tasting areas. It is absolutely clear that the basement production facility, although large, is very much secondary to all of this.

How many farm buildings have a 31,000 litre ornamental lake as a fixture, I wonder?  (As an aside, I’ve wondered about that lake. It seems quite fashionable for billionaires to want to fly rockets these days. Maybe the owner of Vineyard Farms, Mark Dixon, has similar aspirations…?)

Anyway...

The staffing level for the whole building is stated to be around 50 FTEs and although the planning document is careful not to mention it, the transport documentation tells us that the staffing of the production area is 10 FTEs. This alone gives the lie to the argument that the hospitality operation is “ancillary” to production. If your staffing levels are 4 hospitality guys to every one production worker, where does that show your emphasis to be?

To try and prop up this paper-thin case for exemption to Green Belt planning rules, Shrimplin also cites a legal precedent where planning permission for a wine plant was given in a green belt area (Millington v. Secretary of State for the Environment). The similarity of that development to this one being put forward by Lord Foster is pretty much zero and, I think, would be laughed out of court were it used to try and overturn what should, in a just world, be a straightforward rejection of these plans by Medway Council.

This single factor should be enough to kill this planning application stone dead.  Foster’s Flying Saucer is not an “agricultural building”. It is not a farm shop.  It is a vainglorious visitor’s reception/wine bar/restaurant/café-style country club that just happens to have a wine plant in the basement.

It must also be emphasised that were this activity to be primarily focussed upon the production of bottled wine, the fermentation and bottling operations would take place at a facility with better transport access than that offered by Upper Bush – and one that would not cost £30m. Crushing the grapes on site (to reduce possible bruising and oxidation damage to the fruit) could take place in very modest facilities, possibly even existing ones at Court and Brookers Farm in Luddesdown. Based on 900 acres with a 3 ton per acre yield, it would subsequently need only approximately 90 tanker movements to transport an entire annual juice harvest to a separate fermentation and bottling plant built elsewhere, maybe on a local business park with access that allows easy delivery of bottles and process consumables, and distribution of finished product. This would eliminate at least half of the HGV movements in Cuxton that would otherwise result from the existing proposals.

This option has not been discussed at all in the proposal, because it would negate the need to build the large facility they want on green belt land in Upper Bush.

If the spurious nature of the claim that the development is primarily an “agricultural development” is recognised, then the submission meets none of the other criteria cited for permitted development within green belt land/AONB. Assertions of conformance made within the Planning Statement are completely and demonstrably baseless.

And, villagers of fair Cuxton, Luddesdown and Halling, you need to be shouting about this outrage from the rooftops. You must not be seduced by Lord Foster’s glossy brochures, or the promise of a swanky restaurant on your doorstep, or even a bit of local discount on the wine they are planning to make.

These plans are a stalking horse.

In Section 2 of their Design and Access Statement, they boast that:

“The planning application for the Kentish Wine Vault forms the first project of an estate-wide strategy for Vineyard Farms Ltd that will evolve in subsequent years across it’s (sic) Luddesdown and Upper Bush estate”...

If they get planning permission to build in the green belt, it will open the floodgates not just for development in Bush and Luddesdown Valley, but in every bit of green belt land in the country. 

It’s a test case, being closely watched by Boris’s building chums everywhere, who are licking their chops and rubbing their wallets in anticipation of developing the UK’s green belt for cash.  If Vineyard Farms get their way, it will set a national precedent. This would be just the start. 

"Oh, we've bought a wine kit from Boots and we'll put it in the cellar of our proposed shopping centre, because that makes it an agricultural building" will be the next stretch of the argument. Maybe followed by "little Johnny might grow some mustard and cress on a bit of damp kitchen towel in his bedroom, so can we call this housing estate an agricultural development, please...?"  There's just too much money in development land these days to rule out any argument in favour of building stuff as fatuous. Big companies can pay clever lawyers fortunes to argue that black is white. Killing folk on zebra crossings doesn't matter to them.

So, Cuxton/Halling/Luddesdown villagers, you have to speak up, not just for yourselves, but for everyone. Get engaged. You owe it to yourselves, your kids and your grandkids. We can’t let Foster and Partners build on our green belt land. We simply can’t. Please, please, go on to the Council planning web page, find the application (MC/21/2328, or type in "winery" as described above), click on "comment" open an account and register your objection to this scheme. Yes, it's a faff but you have to do it.  Or just write a letter to them.

This has to happen by September 22nd.  

Tell them that the Vineyard Farms proposal must be rejected because it is inappropriate for Green Belt land, as spelt out unequivocally in paragraph 149 of the National Planning Policy Framework 2021.

Tell them that the case made for an exemption to Green Belt planning restrictions, based on the assertion that the winery building is primarily an agricultural building, is clearly unsupportable. Say that the Foster and Partner Design and Access statements clearly show that the prime function of the proposed facility is that of a hospitality venue (of a nature of which Kent is already well-served by) and not a wine manufacturing plant. 

Tell them that no consideration has been given to a proper agricultural business-based process flow assessment (which would logically conclude that the fermentation and bottling operations should be conducted elsewhere due to access and transport issues) solely because that would undermine the case for the proposed scale and design of the visitor’s centre in green belt land.

Tell them that Vineyard Farms shouldn’t be allowed to fly Thunderbird One out from under that lake (no, don’t tell them that, I made that up. Mind you, it’s no more ridiculous than a lot of the stuff in the Vineyard Farm proposals).

If you love Cuxton, Halling and Luddesdown, its beauty, its peaceful woods and farmland, its wildlife and its scenery, you have to oppose this planning application. You have to make your voice heard.

If you don’t, our children and grandchildren will look back at pictures of how it all used to be and will never forgive us.  "Grandad, what's a tree...?"

Please watch this space. I have more to say about the traffic and the environmental assessments in my next posts.

The End Of History...

The future...?

It seems that the pleasant little village of Cuxton is under attack like never before. Earlier this year, we learned that an overseas tax exile wants to plonk a vainglorious restaurant and visitor’s centre on top of Barrow Hill in Upper Bush, an act of green belt vandalism that has been met by a tidal wave of complete apathy by most Cuxton residents.

Now it seems that Cuxton Church (along with all little parish churches right across the country) is under threat of closure and sell-off by the Church of England. 

So how is this happening? To summarise:

The Mission and Pastoral Measure (MPM) 2011 is a piece of legislation that sets out the legal procedure for Church of England parish reorganisation and for closing consecrated church buildings and settling their future. 

Recently, the Church Commissioners (the body which administers the property assets of the Church of England) conducted a review of MPM 2011 and published a proposal (known as GS2222) for “simplifying” it. 

In summary, these proposals (discussions of which will close on September 30th this year), would empower dioceses (the offices of the regional al bishops and archbishops) to take an axe to the present local parish system. They would effectively short-circuit the current review and consultation processes related to church closures and remove any input or objection to a church closure from the local parish clergy, the parishioners and the community at large. 

Essentially under these proposals, a diocese could unilaterally decide to close any local parish church and dispose of it and its assets, and there would be very little the local community could do about it. 

This is an outrage. Most people in Cuxton may not be regular churchgoers, but many of them care deeply about Cuxton Church, its history and its role in the village of Cuxton. It was built on the remains of a Roman villa and has been a place of worship for at least a thousand years. The church is, however, much more than just a place of worship. Its endurance gives a sense of place and continuity to the local community of Cuxton: a village without a church is a village without a heart. 

St. Michaels and All Angels Church is loved and cherished by Cuxton village, and many of its residents invest their own time and money in its upkeep without being regular church-goers. For example, the eighteenth-century church organ had recently fallen into disrepair and required an extensive re-build, with an estimated cost of £50,000. Whilst the diocese contributed some funding, the bulk of the money had to be secured elsewhere and indeed, was subsequently raised within a few months thanks to the hard work of volunteers. 

The bell-tower is similarly maintained and operated by volunteers. When bell-ringing practice recommenced in July after 18 months upon relaxation of Covid restrictions, the outpouring of appreciation and support from the local community that the sound of the bells drew was overwhelming. 

The local community is fully invested in Cuxton Church. It is completely unjust that it could be closed and taken from that community, and on the mere whim of the Bishop and their staff, depending on their latest “mission” or a perceived need to fund a fashionable project elsewhere.  

The joyous sounds of the church organ and the church bells must not fall silent for such reasons. 

If the Church of England were impoverished, the desire to close churches for cost-control reasons would be reasonable. But it is not. Since 1993, the value of the assets managed by the Church Commissioners has grown from £2.4 billion to £9.2 billion.  In 2020 alone (a year blighted by the pandemic) they grew by £500 million. Indeed, the post of Personal Assistant to the Archbishop of York (a lay position) was recently advertised at a salary of £90,000 a year! 

Instead, these reforms are being pushed through by the Church of England’s dioceses for their own convenience. They are being made without proper and timely advance consultation with clergy, parishioners, or groups who use church buildings. 

So what can you do about it?  Not much, but if you care, you can at least make your voice heard.  You have to do this by the end of this month. 

You can write to the Church Commissioners review body at mpm2011review@churchofengland.org , (clicking on the link should open your e-mail with the address already put in, but you can otherwise just copy the e-mail address and then paste it into the address box of your e-mail) perhaps citing some of the above arguments, and ask for the Church’s legislative proposal GS2222 to be dropped immediately. 

You can also write to your local MP (in Cuxton and Halling’s case, Kelly Tolhurst, at kelly.tolhurst.mp@parliament.uk), again citing the arguments above and asking her to support her constituents in Cuxton and in Halling, by writing to the Second Estates Commissioner, Andrew Selous MP, asking for the Church’s legislative proposal GS2222 to be dropped. 

Don’t forget to put your name and postal address in the e-mail somewhere: that makes sure the recipients know you are genuine, and are compelled to respond. 

Please e-mail the church and our MP about this.  We have to try and save our churches.  Or a thousand years of history could get sold off…