SCRUTINY OF A.R. ENVIRONMENTAL STATEMENT – VOLUME 1

Table 1-1 Technical scope of EIA – Page 5:
Air Quality –  “The development is in a residential area with low levels of existing traffic and    consequently low levels of emissions. Increases in traffic generated by the proposed development will be relatively minor and are unlikely to impact on existing air quality.”
How can this be accurate with a four year building project of construction vehicles and workers travelling in and off the site.  When completed the expected vehicle level will be far higher on a 24/7 basis than with the existing college. The use of the word “unlikely” indicates the writer of this report is not sure if it will or will not have an impact.
Page 6: 
“ The operational development is likely to have only minor increases in traffic hence unlikely to impact the current baseline condition.”
Again the use of the word “unlikely” is used.  Therefore suggesting the writer does not really know what impacts could take place.
Water resources:
“The impact of flooding will need to be considered.”
Exactly when is this going to be considered
Regional context – Page13:
“ The plan (South East Plan – may 2009) states there are higher levels of multiple deprivation, lower levels of Gross Value Added, lower earnings and higher levels of unemployment compared with the South East.”
In view of this socio-economic statement who will buy? Where will they come from? Where will they obtain employment. 
“However, although recognised as an area of deprivation, Hastings supports a range of employment providers.”
How does this statement site with the previous and how can it be deprived then claim to have a range of work providers.
Residual effects – Page 48:
“The residual effects from the proposed development are predicted to be generally beneficial once any mitigation measures have been incorporated.”
Is prediction a way of covering yourself if it does not turn out to be beneficial.  What precisely does this statement suggest.
“The residual effect upon employment during construction as both direct and indirect employment opportunities is considered to be minor in benefit.”
Does this mean that most construction personnel will come from outside the Hastings area.
“The effect upon housing opportunities and affordable housing provision is considered to be a major beneficial effect.”
With approximately 800 properties empty in the Hastings Borough area how can this be beneficial.
Planning Policy Guidance: 13 Transport:
“The development site at Archery Road is ideally located as it is within an existing residential centre; public transport accessibility is good, with several bus stops nearby and both West St. Leonards and St. Leonards Warrior Square rail stations within walking distance from the site. The site therefore meets the criteria (referring to PPG13 on other modes of travel).”
Where are there several bus stops nearby?  One each side of the road on the A259 seafront and one at Boscobel Road.  Four buses – 98,99,23 and 26.  The last two do not run on Sunday’s and Bank Holidays.  Who is going to walk to these stops in rain, high winds, snow and cold weather – unless they have to.  Likewise with the two rail stations that are not an easy walk on the returning.
Temporal – Page 56:
“The proposed development replaces an existing college campus, which it is expected would generate a reasonably constant number of vehicle movements throughout the day.  It is expected that the proposed residential development would generate fewer daytime vehicle movements compared to the college campus.  Therefore it can be considered that the greatest traffic and environmental impact will be during the peak times.  This can be both a positive and negative impact.
For those who live in the immediate vicinity will know the volume of college traffic is far less than the proposed development, mainly due to the parking limitations. With the number of units proposed there will be a significant higher amount of vehicles accessing and leaving Archery Road.  It does not take into account service and delivery vehicles in and off site. The 24/7 movement will be total contrast to the current college vehicle activity.  How can it be described as a plus and minus impact. The sole vehicle population will escalate to around 250 conservatively.
“The Transport Assessment predicted that vehicle movements associated with residential development would peak at different times of the day than the existing movements associated with the college.”
Yes there will be a lot more traffic in and off site at earlier and later times according to peoples work patterns.  Including weekend workers and casual trips that does not exist within the college traffic movements.
“The college will be relocating to a new site, which is unknown at present, but assumed to be in the town centre.”
How can the writer of this report not know the new location of the college? This report is dated July 2009 and the new college is nearly completed.
“Pick up and drop off trips occur on roads adjacent to the college were not counted as college trips by the surveys.  It has not been possible, therefore, to accurately estimate the volume of college trips which would be needed to be removed.  Because of this inaccuracy it was considered more appropriate to include the existing college trips.”
It would appear the need to include the pickup and drop offs as an afterthought in order to increase the traffic figures in order to justify the claim of no increase in volume. What is never taken into account is college traffic is five days a week with breaks at holiday periods.
Determination of significance (traffic) – Page 58:
“An increase in traffic will have an adverse effect; however a reduction in traffic volume would have a beneficial impact.”
Why is the word “volume” only used once when this statement refers to the amount of traffic? But is this situation not obvious to all. 
Criteria for assessing impact magnitude – Page 59:
“Traffic surveys indicated that Quarry Hill Road and West Hill Road are relatively quiet streets.”
Considering the traffic survey was carried out at very tightly prescribed times and when the college was slowing down for summer recess.
“ The proposed development may have a reduction in vehicle reduction in vehicle traffic which is considered to be a beneficial effect.”
Another supposition based upon what?
“When considering the impact to pedestrians and cyclists it is unlikely that the development will generate a significant number of additional pedestrians or cyclists.”
This conflicts with the Traffic Report stating a major intention of the development is to encourage residents to use alternative means of transport.  Such as using buses and bicycles.  Does this mean the appointment of a Travel Plan Coordinator for five years on site is a waste. 
Page 62:
“No HGV’s were surveyed at the junction of West Hill Road and Quarry Hill Road, or accessing the site. “ 
One has to ask, was this survey carried out on a Sunday?  Had they carried out a traffic survey from The Highlands onto Archery Road there would have been several.  This route is frequently used by food service LGV’s & HGV’s on a daily basis.
Pedestrians and Cyclists – Page 62:
“There are footways on both sides of the carriageways adjacent to the site.”
This is totally incorrect.  There is no footpath on the inner course of Archery Road from Rosemount to the Eastern entrance of the college.  There is no footpath on the outer course of Archery Road between Crabtree House and 3 The Highlands.
“The local topography is hilly, which is unfavourable for cycling.”
Yet in the travel plan for alternative modes of transport they are going to encourage more residents to use such things as bicycles.
“Both these stations are roughly 800-900m (10minute) walk from the site.”
Unless one is fit and walks at a rapid pace Warrior Square might be feasible. If you are carry anything-doubtful.  On the return walk it is virtually all a uphill gradient.  Either way on foot in the rain or snow definitely not.
Pedestrian Amenity – Page66:
“There are, at present, no pedestrian routes through the college site.”
Incorrect. There is a pedestrian right of way through the college from Archery Road – east to west. Along the front of  The Terrace. 
“Residential development is more likely to be occupied in the evenings, compared to the existing college buildings.”
How can you argue with that expert observation.
Bats – page 111:
“An evening emergence survey was undertaken at the end of June 2007.  The activity surveys involved the walking of the transect route around the site; the direction walked was reversed during the second visit.  On 17 June 2009, the emergence and activity surveys were repeated. In addition all roof voids were inspected internally, trees were surveyed for their potential to support roosting bats, and a dawn survey was carried out. “
According to a local Bat surveyor based in Battle, it is not possible to carry out a Bat survey to access roosts in the summer months, such as done here in June.  Tree surveys can only be done effectively in the autumn /winter months when the canopy of leaves has dropped.  Given this expert opinion any suggestion of there being no Bat roosts in the wooded area is subject to accuracy. Here we have one cursory survey carried out on one day only.
“The majority of the site is considered to have little significance in terms of the urban habitat it provides; however the mature woodland on site is likely to provide a valuable pocket within the urban area.”
This obscure statement still fails to define the existence of Bat roosts.
Assessment of construction impacts page 124:
“The construction activities with the potential to have ecological impacts include:

• Habitat removal – vegetation clearance, building demolition, excavation.
• Disturbance – construction lighting and plant/vehicle noise, vibration, movement and general activity.”

However, in another section of these reports, it is planned to fence off established Badger Setts –work around them with sensitivity and use hand tools to minimise the disturbance.
“The partial loss of this locally important habitat would not be ecologically significant and would be a negligible to minor adverse impact.”
Part of this sentence implies these habitats are “important,” then states it really is not that important.
Badgers – page 126:
“The construction impacts associated with the proposed development will therefore be the following:

• Potential damage to or disturbance of the main sett (Sett 1) caused by tree felling and vegetation clearance near to the sett.
• Loss of one or two annexe setts (Sett 2 and potentially also sett 3)
• Disturbance caused by ground works/landscaping, noise and activity in the vicinity of an annexe sett (sett 3) .
• Increased area of foraging habitat.

Accidental damage or disturbance of the main sett would be likely to be ecologically significant as it is the badgers’ main residence and breeding place. In addition to being illegal, this impact would be of moderate adverse significance.”
Given a major four year building project with the entire land being redeveloped the safeguards planned for these animals will more than likely fail with all the above factors taken into account. The loss, should it happen is considered to be “moderate adverse.”  Not to be taken seriously then.
Cumulative Impact assessment – Page 131:
“ The cumulative effect of losing several trees with bat roosting potential is more significant that losing an individual tree. Although there is no evidence of bats roosting on the site, there is potential that they could in the future.”
How will Bats be able to roost in the trees in the future if virtually all of them are to be removed. Again the statement of no bats in the wooded area is not support by a proper Bat survey.
Ecological enhancement Page 133:
“ The trees with Bat roosting potential will be felled under supervision of an ecologist either in March-April or September-October, when the chance of accidently finding bats is at its least.”
We now go from there are no bats roosting in the wooded area to there might be some.  But the only way it is going to be discovered is when a tree is felled.
“If bats are discovered, work on site will stop immediately and Natural England will be contacted to discuss an appropriate course of action.”
The report has turned 180 degrees where the bats were only foraging and lived off site to they are still unsure as no comprehensive survey has been executed.
Page 134:
“ The only significant ecological impacts relating to the proposed development of the Archery Road site will be on badgers.”
Earlier in the report the loss of badgers was considered as “moderate” now it is “significant.”
Description of development-Page 162:
“The key components of the scheme are the retained woodland in the north.”
The development plan is to build the largest block of apartments in the northern sector of the site, where the wooded area is located. How can it be claimed this area is to be retained.
Throughout this vast report, much of it devoted to ecological issues, it is worth noting that nothing is mentioned about Foxes or Owls.  Of which all local residents know they are resident in the wooded area.  From the pages I have extracted  and made comments, mostly factual, some an opinion based upon my knowledge of the area.  As with other reports/surveys I have perused  yet again there is the issue of anomalies,  errors and validity. 

Richard heritage – November 2009