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Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008 Contents Executive Summary Page 1 1. Introduction Page 2 Summary of Review and Assessment Page 3 Scope and Methodology of Progress Report Page 4 2. New Monitoring Results Page 6 Continuous Monitoring Page 6 Passive Monitoring Data Page 10 Other Monitoring Page 18 3. New Local Developments Page 21 New Industrial Developments New Developments 4. Update on Policies to Improve Air Quality Page 22 Air Quality Action Plan Progress Update Page 23 Planning and Policies Page 30 Local Transport Plan and Strategies Page 31 5. Conclusions and Recommendations Page 32 6. Appendices Page 33

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Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

Contents

Executive Summary Page 1

1. Introduction Page 2 Summary of Review and Assessment Page 3 Scope and Methodology of Progress Report Page 4

2. New Monitoring Results Page 6 Continuous Monitoring Page 6 Passive Monitoring Data Page 10 Other Monitoring Page 18

3. New Local Developments Page 21 New Industrial DevelopmentsNew Developments

4. Update on Policies to Improve Air Quality Page 22 Air Quality Action Plan Progress Update Page 23 Planning and Policies Page 30 Local Transport Plan and Strategies Page 31

5. Conclusions and Recommendations Page 32

6. Appendices Page 33

Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

Executive Summary

The Annual Progress report is part of the ongoing review and assessment of air quality which is required under Part IV of the Environment Act 1995. This report follows on from the detailed assessment made in 2007.

The main aim of the Progress Report is to report progress on local air quality management within a local authority’s area and progress in achieving the Air Quality Objectives. Progress reports have been introduced to provide a more continuous approach to LAQM. Updating and Screening assessments are now required every three years with Annual Progress reports to be produced in the years between to supplement this.

Dartford Borough Council has continued to expand its network of air quality monitoring. The monitoring results are detailed in this report.

In general, results of NO2 and PM10 remain high as in previous years. Much of the monitoring is carried out within the existing AQMAs, Where results show that pollutant levels within these areas continue to be above the Air Quality Objectives (with one exception at Taunton Road where results are slightly below the objective level).

3 Mean levels of NO between 28.2 – 32.4 μg/m have been recorded in 2007

2 at four urban background sites. The levels of benzene, which are now monitored at only one site, have continued to fall.

The majority of monitoring carried out within the borough of Dartford is at locations classified as being roadside, and consideration should be given that these results do not indicate the levels of exposure at the nearest receptor to the pollution source.

1

Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

1. Introduction

The Environment Act 1995 introduced a system of local air quality management (LAQM), placing new legal duties on local authorities to assess the air quality in their area, and a requirement for the Government to publish a National Air Quality Strategy containing air quality targets which would protect people’s health.

The National Air Quality Strategy (NAQS)1 was published in 1997 and has since been revised in 2000. The Strategy contains standards and objectives for eight air pollutants; nitrogen dioxide (NO2), sulphur dioxide, carbon monoxide, fine particles (PM10), ozone, lead, 1,3-butadiene and benzene. Local authorities have a responsibility to assess levels of these pollutants, with the exception of ozone, and implement measures to reduce pollution where objectives are not met by the target deadlines which range from 2003 to 2010. Objectives included in the Air Quality Regulations 2000 and (Amendment) Regulations 2002 which will need to be assessed for the purpose of local air quality management are shown in Table 1.

Table1: Pollutant Objective Date to be achieved

byConcentration Measured as Benzene 5 ppb

1.5ppb Running annual mean Annual mean

31 December 2003 31 December 2010

1,3-butadiene 1 ppb Running annual mean

31 December 2003

Carbon monoxide

10mg/m3(8.6 ppm) Maximum daily running 8 hour mean

31 December 2003

Lead

0.5μg/m3

0.25μg/m3

Annual mean

Annual mean

31 December 2004

31 December 2008 Nitrogen dioxide*

200μg/m3 * not to be exceeded more than 18 times a year 40μg/m3*

1 hour mean

annual mean

31 December 2005

31 December 2005

Fine particles (PM10)

50μg/m3 not to be exceeded more than 35 times a year 40μg/m3

20μg/m3

24 hour mean

Annual mean Annual mean

31 December 2004

31 December 2004 31 December 2010

Sulphur dioxide

100 ppb not to be exceeded more than 35 times a year 47 ppb not to be exceeded more than 3 times a year 132 ppb not to be exceeded more than 24 times a year

15 minute mean

24 hour mean

1 hour mean

31 December 2005

31 December 2004

31 December 2004

ppb = parts per billion, ppm = parts per million, μg/m3 = micrograms per cubic metre. * These are provisional objectives. EU Limit values for nitrogen dioxide are to be met by 2010.

1 DoE (1997) The United Kingdom National Air Quality Strategy The Stationary Office

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Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

Local authorities must review and assess current and projected pollutant levels and where it appears the objectives will not be met by the designated time they must declare an Air Quality Management Area (AQMA) and draw up action plans to meet the Objectives.

1.1 Summary of Review and Assessment

Dartford Borough Council carried out its first round of review and assessment of air quality between 1998 and 2002. This was concluded in the requirement for the declaration of an Air Quality Management Area (AQMA) for nitrogen dioxide (NO2) and fine particles (PM10) along the A282 Tunnel Approach Road.

The Second Round commenced in 2003. The first phase of this was the Updating and Screening Assessment (USA). Dartford Borough Council completed this in May 2003, with the conclusion that a Detailed Assessment was required for nitrogen dioxide (NO2) and fine particulates (PM10).

This Detailed Assessment was completed in May 2004 and identified the need for further Air Quality Management Areas to be declared along London Road, the Town Centre and Bean Interchange.

An Updating and Screening Assessment was carried out in 2006. This identified several further areas requiring detailed assessment. In November 2006 a further three AQMAs were declared which encompassed the areas identified in the 2004 Detailed assessment and the 2006 Updating and screening assessment. A subsequent detailed assessment was carried out in 2007 which confirmed the requirement for the declaration.

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Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

1.2 Scope and Methodology of the Progress Report

Progress reports have been introduced into the LAQM

The main aim of the Progress Report is to report progress on local air quality management within a local authority’s area and progress in achieving the Air Quality Objectives. Progress reports have been introduced to provide a more continuous approach to LAQM. Updating and Screening assessments are now required every three years with Annual Progress reports to be produced in the years between to supplement this.

Progress reports are intended to assist local authorities by:

• Helping to retain a profile for LAQM within the authority, including the retention of staff with a knowledge of air quality issues

• Providing a means for communicating air quality information to members and the public

• Maximising the usefulness and interpretation of the monitoring effort being carried out by the local authority

• Maximising the value of the investment in monitoring equipment

• Making the next round of review and assessment that much easier, as there will be a readily available up to date source of information

• Helping local authorities respond to requests for up-to-date information on air Quality

• Providing information to assist in other policy areas, such as transport and land use planning

• Providing a ready source of information on air quality for developers carrying out environmental assessments for new schemes

• Demonstrating progress with implementation of air quality Action Plans and/or air quality strategies

• Providing a timely indication of the need for further measures to improve air quality, rather than delaying until the next full round of review and assessment.

4

Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

The Progress Report is structured as follows in accordance with the Checklist2 provided in Progress Report Guidance (LAQM. PRG (03)):

1. New Monitoring Results 2. New Local Developments 3. Action Plans (where appropriate) 4. Planning and Policies5. Local Transport Plan and Strategies

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Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

2. New Monitoring Results

2.1 Continuous Monitoring Data.

Dartford Borough Council has three roadside air quality monitoring stations within the Borough located at: the A226/B255 St Clement’s Way junction; Bean Interchange; and, Instone Road in Dartford Town Centre, which were installed in June 1999 to more accurately assess levels of NO and PM .

2 10The monitoring results for 2002 to 2007 for these sites are shown in Table 2 (the data capture for all sites is >95% during 2007). The stations are calibrated fortnightly in-house. Kent and Medway Air Quality Monitoring Network (KMAQMN) manages the data and AEA Technology, ratify it. The quality assurance/quality control (QA/QC) procedures for the KMAQMN are equivalent to the UK Automatic Urban and Rural Network (AURN) procedures. SupportingU service the station on a six monthly basis. The locations of these air quality stations can be seen on the map in appendix A2. The Bean roadside continuous nitrogen dioxide data has been used with the co-located diffusion tube data to estimate the bias adjustment factor for the diffusion tubes as shown in table 5. The results are presented in tables 2 and 3 and are displayed graphically in figure 1 and 2. Projected values have been calculated using the methodology given in LAQM. TG(03). This data has been fully ratified by AEA Technology. Stations which continuously monitor the air quality are located by roadsides and are in areas that have been identified in the Detailed Assessment Report as areas with predicted exceedences of air quality objectives and are now included in air quality management areas

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Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

Table 2: NO2 continuous analyser concentrations 2002 - 2007

Dartford 1 – St Clements Way Greenhithe Objective 2002

NO2

2003 NO2

2004 NO2

2005 NO2

2006 NO2

2007 NO2

*2010 NO2

Exceedences of 200 µg/m3

No more than 18

occurrences of hourly mean >200 µg/m3

27 36 37 29 62 75 -

Annual Mean Annual mean not exceeding

40ug/m3 60 66 60 59 64 58 51

Data Capture % 95 99 99 99 97 99 -

Dartford 2 - Town Centre Objective 2002

NO2

2003 NO2

2004 NO2

2005 NO2

2006 NO2

2007 NO2

*2010 NO2

Exceedences of 200 µg/m3

No more than 18

occurrences of hourly mean >200 µg/m3

0 2 0 0 1 7 -

Annual Mean Annual mean not exceeding

40ug/m3 48 56 56 51 52 54 48

Data Capture % 11 99 99 98 94 100 -

Dartford 3 - Bean Interchange Objective 2002

NO2

2003 NO2

2004 NO2

2005 NO2

2006 NO2

2007 NO2

*2010 NO2

Exceedences of 200 µg/m3

No more than 18

occurrences of hourly mean >200 µg/m3

0 1 1 11 1 16 -

Annual Mean Annual mean not exceeding

40ug/m3 50 60 62 61 58 55 49

Data Capture % 12 95 95 69 97 99 -

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Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

Table 3: PM10 continuous analyser concentrations 2002 – 2007

Dartford 1 – St Clements Way Greenhithe Objective 2002 2003 2004 2005 2006 2007 *2010

Exceedences of 50 µg/m3

No more than 35 days

where daily mean > 50

µg/m3

142 129 139 79 35 69

Annual Mean Annual Mean less than 40µg/m3

53 50 49 41 32 38 36

Data capture

86 98 97 95 96 99

Dartford 2- Town Centre Objective 2002 2003 2004 2005 2006 2007 *2010

Exceedences of 50 µg/m3

No more than 35 days

where daily mean > 50

µg/m3

12 90 84 54 22 30

Annual Mean Annual Mean less than 40µg/m3

38 43 41 37 31 31 29

Data capture

14 95 95 95 93 95

Dartford 3 - Bean Interchange Objective 2002 2003 2004 2005 2006 2007 *2010

Exceedences of 50 µg/m3

No more than 35 days

where daily mean > 50

µg/m3

4 74 72 6 23 25

Annual Mean Annual Mean less than 40µg/m3

30 39 39 30 32 29 27

Data capture

12 97 95 31 92 99

8

0

10

70

60

Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

Figure 1: Nitrogen Dioxide Annual mean in μg/m3 at Dartford Air Quality Stations.

50

60

40

30

20

Greenhithe Town Centre Bean

2002 2003 2004 2005 2006 2007 2008 2009 2010

Figure 2: PM10 Annual mean in μg/m3 at Dartford Air Quality Stations.

0

10

20

30

40

50

Greenhithe Town Centre Bean

2002 2003 2004 2005 2006 2007 2008 2009 2010

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Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

2.2 Passive Monitoring Data

Dartford Borough Council currently has a network of diffusion tubes across the borough consisting of 42 NO2 diffusion tubes. These tubes are supplied and analysed by Gradko and are prepared using the 20% Triethanolamine in water method.

Gradko International participates in the UK National Diffusion Tube Network and the Workplace Analysis Scheme for Efficiency (WASP). They currently hold UKAS accreditation for analysis of diffusion tubes and consistently achieve the highest performance level in annual field inter-laboratory performance comparisons.

These diffusion tubes have been co-located in triplicate with the continuous analyser at Bean Interchange. The co-location exercise has produced a bias factor which has been applied to the raw diffusion tube results. The results of this exercise can be seen in table 5.

The results of these can be seen in table 4 together with results from previous years. These results are also graphically displayed in figure 3. and figure 3.1 which shows the new monitoring sites since 2005.

There are two urban background diffusion tube sites that show (bias 3

corrected) annual mean levels of NO of 28.5 – 32.4 μg/m in 2007.2

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Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

Table 4:

Nitrogen Dioxide Diffusion Tube Data

Site ID

X Y Location Site Type

2000 Mean NO

2

μg/m3

2001 Mean NO

2

μg/m3

2002 Mean NO

2

μg/m3

2003 Mean NO

2 μg/m

3

(bias adjusted figure in brackets)

2004 Mean NO

2 μg/m

3

(bias adjusted figure in brackets)

2005 Mean NO

2

μg/m3

2006 Mean NO

2 μg/m

3

(bias adjusted figure in brackets)

2007 Mean NO

2 μg/m

3

(bias adjusted figure in brackets)

DA01 554187 173985 Lowfield Street AQMA 54 56 56 57.3 (58.5) 53.3 (58.1) 51.9 49.9 (48.8) 54.2 (49.3) DA05 558578 172821 Ightham Cottages AQMA 60 62 59.5 (60.7) 57 (62.1) 60..4 59.2 (57.9) 60.2 (55.2) DA07 550750 171918 Summerhouse Drive B 37.3 (38.1) 32.3 (35.3) 32.4 28.1 (27.5) 31.3 (28.5) DA10 559189 174872 London Road AQMA 47 50 55 53.4 (54.4) 47.6 (51.9) 49.3 46.4 (45.4) 55 (50) DA12 553282 175351 University Way AQMA 49 51 53 54.8 (55.9) 50.3 (54.8) 54.7 DA14 555484 174441 Bow Arrow Lane AQMA 66 73 67 68.9 (70.3) 72.1 (78.6) 74.7 69.8 (68.4) 74 (67.3) DA16 554108 173318 Princes Road (2) AQMA 53 58 62 58.2 (59.4) 49.9 (54.4) 52 47.5 (46.5) 54.5 (49.6) DA17 552732 173689 Shepherds Lane AQMA 53 56 54 51.2 (52.2) 46 (50.2) 51.3 49.9 (48.9) 53.5 (48.7) DA18 560298 174282 Alkerden Lane B 40.2 (41) 37.9 (41.4) 35.8 33.9 (33.2) 35.6 (32.4) DA20 555660 174863 Elliot Road AQMA 60 60 58.5 (59.7) 49.4 (53.8) 49.6 51.8 (50.7) 52 (47.3) DA21 555501 174005 Brentfield Road AQMA 53.3 (54.3) 44.7 (48.7) 45.5 42.6 (41.7) 49.7 (45.2) DA22 555600 174030 Brent Way AQMA 47 70 66 65.5 (66.8) 65.3 (71.2) 67 61.3 (60) 69.5 (63.2) DA23 555751 173900 The Brent AQMA 68 71 61.2 (62.4) 57.1 (62.3) 55.5 50.1 (49) 54.9 (50) DA24 555632 173558 Wayville Road AQMA 52.4 (53.5) 44.1 (48) 44.2 45.6 (44.6) 46.8 (42.6) DA25 555795 173210 Queens Gardens AQMA 53.9 (55) 48.9 (53.3) 52.5 46.5 (45.5) 50.2 (45.7) DA26 555880 173365 Princes Road (3) AQMA 62 57 55.1 (56.2) 48.8 (53.2) 61.8 DA27 555718 173805 Fairway Drive AQMA 53.8 (54.9) 51.4 (56) 53.9 DA28 558460 174671 Ivy Villas AQMA 58 62.1 (63.4) 54.4 (59.3) 56.9 61 (59.7) 61.7 (56.1) DA30 557887 175001 Charles Street R 44.9 (45.8) 35.6 (38.9) 36.6 DA31 561215 174898 London Road (2) AQMA 46.7 (47.6) 40.4 (44) 39.2 38.2 (37.4) 39 (35.5) DA34 555535 177375 The Brent II AQMA 48.8 51.5 (50.4) 56.7 (51.6)

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Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

Table 4:

Nitrogen Dioxide Diffusion Tube Data

Site ID

X Y Location Site Type

2000 Mean NO

2

μg/m3

2001 Mean NO

2

μg/m3

2002 Mean NO

2

μg/m3

2003 Mean NO

2 μg/m

3

(bias adjusted figure in brackets)

2004 Mean NO

2 μg/m

3

(bias adjusted figure in brackets)

2005 Mean NO

2

μg/m3

2006 Mean NO

2 μg/m

3

(bias adjusted figure in brackets)

2007 Mean NO

2 μg/m

3

(bias adjusted figure in brackets)

DA35 555383 177375 Highfield Road AQMA 60.2 54.2 (53) 58.6 (53.3) DA36 555325 177525 Burnham Road AQMA 46.5 38.8 (37.9) 44.4 (40.4) DA37 556567 173450 Watling Street AQMA 43.4 (42.5) 54.5 (49.6) DA38 558331 174596 London Road (3) AQMA 44.8 (43.9) 49.1 (44.7) DA39 555158 173825 Park Road AQMA 45.5 (44.6) 45.8 (41.7) DA40 553500 174238 West Hill AQMA 48 (47) 46.6 (42.4) DA41 554172 172812 Church Hill R 46.3 (45.3) 50.6 (46) DA43 554580 173992 Overy Liberty AQMA 64.2 (62.9) 70.3 (63.9) DA44 555656 174053 Brent Close AQMA 52.9 (51.7) 53.4 (48.6) DA45 555964 174098 Milestone Road B 40.4 (39.5) 42.7 (38.8) DA47 553938 174308 Westgate Road AQMA 37.8 (37) 42.6 (38.8) DA48 555297 171327 Hawley Road R 42.4 (41.5) 50.4 (45.9) DA49 554902 173893 St Albans Road AQMA 49.3 (44.9) DA50 553783 172319 A2 Bridge* R 49.8 (45.3) DA51 555068 175653 Cornwall Road* B 46 (41.9) DA52 555605 174358 Grange Crescent* B 50.5 (46) DA53 557693 174666 Park (Swallow Cl)* B 32.2 (29.3) DA54 553642 174616 King Edward Drive* B 30.8 (28) DA55 556012 174405 Littlebrook Hospital* B 50.7 (46.1)

Site names with an asterisk after them started in May 2007 & therefore haven’t a full year’s monitoring data

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Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

Figure 3:

80

70

60

50

40

30

20

10

0 DA01 DA05 DA10 DA12 DA14 DA16 DA17 DA20 DA21 DA22 DA23 DA24 DA25 DA26 DA27 DA28 DA18 DA07 DA31 DA30

NO2 Diffusion Tube Annual Mean 2000- 2007

2000 2001 2002 2003 2004 2005 2006 2007

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Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

Figure 3.1: NO2 Diffusion Tube Annual Mean 2000- 2007

80

70

60

50

40

30

20

10

0 DA43 DA34 DA35 DA36 DA37 DA38 DA39 DA40 DA41 DA44 DA45 DA48 DA49 DA50 DA51 DA52 DA55 DA47 DA53 DA54

2005 2006 2007

14

Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

Calculation of Bias and Period Mean Adjustment.

To take account of the bias in the diffusion tubes analysed by Gradko International Limited, an assessment has been made of data from the Bean Roadside site which has triplicate co-located diffusion tubes and >10 months of data capture. The methodology outlined in the Technical Guidance LAQM.TG (03) has been used in the calculation of the bias adjustment factor.

Table 5:

Bias Adjustment Factor 2003 Site ID

Location Annual mean NO2

(μg/m 3 ) continuous

analyser

Annual mean NO2

(μg/m 3 ) diffusion

tubes

Bias adjustment

factor

DA1 (ZR3)

Bean Interchange roadside 60.0 59.2 1.01

Bias Adjustment Factor 2004 Site ID

Location Annual mean NO2

(μg/m 3 ) continuous

analyser

Annual mean NO2

(μg/m 3 ) diffusion

tubes

Bias adjustment

factor

DA1 (ZR3)

Bean Interchange roadside 62.1 57 1.09

Bias Adjustment Factor 2005 Site ID

Location Annual mean NO2

(μg/m 3 ) continuous

analyser

Annual mean NO2

(μg/m 3 ) diffusion

tubes

Bias adjustment

factor

DA1 (ZR3)

Bean Interchange roadside 61* 60 1..00

*Data Capture < 75%

Bias Adjustment Factor 2006 Site ID

Location Annual mean NO2

(μg/m 3 ) continuous

analyser

Annual mean NO2

(μg/m 3 ) diffusion

tubes

Bias adjustment

factor

DA1 (ZR3)

Bean Interchange roadside 57 58.2 0.97

15

Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

Bias Adjustment Factor 2007 Site ID

Location Annual mean NO2

(μg/m 3 ) continuous

analyser

Annual mean NO2

(μg/m 3 ) diffusion

tubes

Bias adjustment

factor

DA1 (ZR3)

Bean Interchange roadside 55 60 0.91

Please Note: That for 2007 Dartford’s local bias adjustment factor differs from the factor derived from The University of the West of England’s study across those sites using 20% TEA in water (0.87) by 0.04, which if applied would reduce the Dartford’s figures fractionally.

In addition to the NO2 diffusion tubes Dartford Borough Council also operates one benzene diffusion tube. This is also supplied and analysed by Gradko. It consists of a steel/brass constructed tube that is designed to sample air diffusively at low speeds. The limit of detection for this tube is 0.2ppb and the precision is + 20%. The Benzene tubes are exposed for periods of 1 month but the exposure time is expressed in hours in order to calculate the benzene level for each tube. The table below also shows data for Lowfield Street which is no longer monitored.

Table 6:

Annual mean (ppb) DA01 Lowfield Street DA16 Princes Road

1998 3.19 2.96 1999 2.57 2.95 2000 1.59 1.70 2001 1.39 1.36 2002 1.22 1.17 2003 0.94 1.25 2004 0.82 0.95 2005 0.62 0.77 2006 0.67 2007 0.59

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Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

Figure 4:

Annual mean benzene concentrations in ppb: Dartford road sites

0.00

0.50

1.00

1.50

2.00

2.50

3.00

3.50

4.00

4.50

Annual mean (ppb) DA01 Lowfield Street Annual mean (ppb) DA16 Princes Road

Air Quality Standard: Annual mean of 1.5ppb by 2010

error bars show method uncertainty +/­21%

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007

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Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

2.3 Other Monitoring

Two portable particle monitors are also used in the borough of Dartford. These are Osiris monitors which are manufactured by Turnkey Instruments. The Osiris uses a light scattering technique to determine the concentration of fine particles passing through PM10 PM5 and PM2.5 impactors. The light scattered by the particles in the sample air is converted into an electrical pulse proportional to the size of the particle. Results are expressed in μg/m3 with a resolution down to 0.01. The Osiris is serviced and calibrated by the manufacturer and on going maintenance is carried out in house.

One Osiris monitor is co located alongside a continuous BAM analyser at Ivy Villas Greenhithe.

The second portable particle monitor has been located throughout 2007 in Bow Arrow Lane, within the existing Air Quality Management Area that exists along the A282 tunnel approach road. The results for 2007 can be seen graphically displayed in figure 6 which shows the 24 hour mean and a rolling annual mean. It can be seen from this that the levels of PM10 are consistently above the air quality objective at this location

18

01/01

/2007

15

/01/20

07

29/01

/2007

12

/02/20

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26/02

/2007

12

/03/20

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26/03

/2007

09

/04/20

07

23/04

/2007

07

/05/20

07

21/05

/2007

04

/06/20

07

18/06

/2007

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/07/20

07

16/07

/2007

30

/07/20

07

13/08

/2007

27

/08/20

07

10/09

/2007

24

/09/20

07

08/10

/2007

22

/10/20

07

05/11

/2007

19

/11/20

07

03/12

/2007

17

/12/20

07

31/12

/2007

Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

figure 5:

BAM vs Osiris co-location data for 2007

0

20

40

60

80

100

120

140

160

180

Ivy Villas Osiris

Ivy Villas Kent Ratified Data

19

01/01

/2007

15

/01/20

07

29/01

/2007

12

/02/20

07

26/02

/2007

12

/03/20

07

26/03

/2007

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23/04

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/05/20

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18/06

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05/11

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19

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03/12

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Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

figure 6:

Bow Arrow Lane Osiris adjusted data for 2007

0

20

40

60

80

100

120

140

24 hr adj us ted m ean Running Annual A v er age

air qu ality obj ec tiv e

20

Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

3. New Local Developments

3.1 New industrial developments

There have been no new part A industrial processes since the Updating and Screening Assessment was carried out in 2006. A map of Part A industrial processes is included in Appendix C2. There have been no new Part B industrial processes that are regulated by Dartford Borough Council since the updating and screening assessment was carried out in 2006. A full list of Part B industrial processes is included in Appendix C1

There are no new quarrying or landfill operations that have been granted planning permission since the Updating and Screening Assessment.

3.2 New Developments

There have been several new developments that have been granted planning permission since the Updating and Screening Assessment was carried out in 2006 that have the potential to impact on air quality. These are:

DA/06/00269/FUL The Wharf Station Road Greenhithe 194 Dwellings DA/05/00283/FUL Former West Hill Hospital Site Dartford Borough Council 239 Dwellings DA/07/00536/FUL Bellegrove Ceramics Salisbury Road Dartford 51 Dwellings

The most significant development to be granted planning permission is that of Eastern Quarry DA/03/01134/OUT

This application is for a mixed-use development comprising 6,250 dwellings and up to 231,000m 2 of built floorspace for business premises, education, community and social facilities; hotels; theatre; supporting retail and leisure facilities; and associated works to provide the development. Outline planning permission was issued in November 2007.

As part of this planning permission a section 106 agreement has been drawn up with requirements for air quality monitoring.

Part of the Borough of Dartford is in the Kent Thameside area which has the potential to see between 30,000 and 50,000 new homes being created over the next twenty years. Many of the new developments in Dartford are part of the Kent Thameside regeneration area. Air quality has been considered in these developments which use traffic assessments derived using the Kent Thameside Association’s Transport Model (KTS model).

One of the assumptions of this KTS model is a modal shift towards public transport. This modal shift relies in part on the development of a dedicated bus based transport system called Fastrack.

Fastrack began operation in 2006 and is planned to ultimately connect nearly all of the major existing and new developments in Dartford.

21

Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

Passenger surveys were carried out in October 2006 (six months after Fastrack Route B started) which showed that 19% of our passengers had previously used a car for the trip now being made on Fastrack. These surveys were repeated in 2007 and 17% said they would previously have used a car.

4. Update on Policies to improve Air Quality

4.1 Air Quality Action Plan Progress Update.

On the basis of findings of the stage 3 review and assessment an Air Quality Management area was declared along the A282 tunnel approach road. An action plan was drawn up and was approved for adoption by the General Assembly of the Council on 31/01/05. A second action plan for the three further AQMAs has been drawn up and is currently in draft format.

The progress made with the action plan for the A282 tunnel approach road is detailed in the following summary tables:

22

Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

DARTFORD BC ACTION PLAN PROGRESS REPORT 2007

SUMMARY OF EXISTING AND PROPOSED MEASURES: TABLE 1

Ranking 1 (Low) – 3 (High)

RES

PON

SIB

ILIT

Y

TAR

GET

DA

TE

(TIM

E SC

ALE

)

REL

ATI

VE A

IR

QU

ALI

TYIM

PRO

VEM

ENT PROGRESS

A282 Tunnel Approach Road measures: Lobbying Central Government for national actions a) to c) on the A282

DBC, KCC 2002 (short term)

Dependant on outcome

DBC – no lobbying undertaken. KCC – situation unknown other than Local Transport Plan submission.

a) Improved existing rail freight infrastructure

Central government

Yet to be agreed (long term)

Removal 50% HGVs – up to 27% NO2

No feedback to DBC

b) New rail freight infrastructure as above No feedback to DBC

c) New Lower Thames Crossing Removal 25% flow – up to 15% NO2

No feedback to DBC

Speed restriction and enforcement HA, Kent Police Yet to be agreed

(short/ medium

50mph – up to 14%NO2

Speed restrictions were brought in for northbound traffic approaching toll plaza in December 2005 – Monitoring is being carried out to see if predicted improvement occurs.

Use of variable message signs HA, Kent Police, KCC

term) 1 Discussed with HA but no action.

Assessment of the impact of the toll system

HA, DRC Dependant on outcome

No assessment of the impact of the tolls has been carried out. A public consultation has recently been carried out regarding proposed changes to the pricing policy.

23

Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

Improved screening HA Restricted benefits -up to 38% NO2

Following discussions with the Highways Agency they have indicated that having looked in to the possibility it was felt that it was not a possibility due to lack of available land.

The possibility of providing screening on DBC owned land was investigated; however there is no DBC owned land in this vicinity.

Discussions with the Highways Agency continuing.

Borough wide measures:

Planning policy: Local Plan Review adoption of policies on improving air quality

DBC 2004 (medium/longterm)

1 - 2 New policies within Local Plan Review but LP not adopted due to changes to Local Development Frameworks.

Transport Planning: Public transport infrastructure improvements: Fastrack

KCC, DBC 2004 (medium) £15 million (Phase1)

1 -2 The first phase of this commenced operation in March 2006

24

Green transport initiatives:

Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

SUMMARY OF EXISTING AND PROPOSED MEASURES : TABLE 2

Ranking 1 (Low) – 3 (High)

RES

PON

SIB

ILIT

Y

TAR

GET

DA

TE(T

IME

SCA

LE)

REL

ATI

VE A

IR

QU

ALI

TYIM

PRO

VEM

ENT

PROGRESS

Development and implementation of a Council Travel Plan

DBC 2002 draft (short -medium term)

1 A programme of staff travel surveys has been carried out and initiatives have been implemented to identify the travel habits of staff to form a database of potential car sharers. Dartford Borough Council is currently part of the Thames Gateway Car Share Scheme.

Ad hoc advice to businesses on travel plans

DBC 2002 -3 (short term)

1-2 No progress

Encourage KCC to develop and implement a Borough Transport Strategy

DBC 2002 draft (medium term)

1-2 School travel Dartford Borough Council is committed to a three year agreement with Kent and Medway Walking Bus Group. DBC pays a proportion of money for the group to visit schools and promote and encourage the school to develop a walking bus. Liaisons carried out with KCC School travel Planners who are working with a large proportion of Dartford Schools on school travel plans.

Encouraging cleaner vehicles and quality partnerships with operators

DBC 2002 (medium term)

2 Being carried out (e.g. cleaner fuel technology for Fast Track)

25

Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

Pollution controls for domestic emissions: Enforcement of statutory nuisance legislation

DBC Ongoing 1 Being carried out

Home energy efficiency measures DBC/KC C

Ongoing 1 The Sustainable Home Energy Strategy and Action Plan was finally agreed in June 2006. The Action Plan lists over 50 actions to be undertaken to reduce home energy usage measures include: • Home Energy Conservation Act survey. • Promotion of British Gas Tax rebate

scheme to encourage homeowners to install insulation.

• Promotion of Government Grant Warm Front.

• In August 2006 1000 homes were targeted with information about renewable energy.

• A successful application made to National Energy Action.

• Negotiations with British Gas relating to energy efficiency measures in Council Housing Stock.

Enforcement of Smoke Control Area DBC Ongoing 1 Being carried out Bonfire leaflets and advice DBC Ongoing 1 Being carried out Pollution controls for industrial emissions: Planning conditions and development controls

DBC Ongoing 2 Being carried out

Licensing and enforcement of IPC and DBC/EA Ongoing 2 Being carried out

26

Local Air Quality Management:

Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

LAQM (IPPC) regulated processes Enforcement of statutory nuisance legislation

DBC Ongoing 1 Being carried out

Review of air quality monitoring needs DBC Ongoing 1 Being carried out Commitment to future air quality monitoring

DBC 1 In place.

27

Local Air Quality Management:

Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

SUMMARY OF EXISTING AND PROPOSED MEASURES : TABLE 3

Ranking 1 (Low) – 3 (High)

RES

PON

SIB

ILIT

Y

TAR

GET

DA

TE(T

IME

SCA

LE)

REL

ATI

VE A

IR

QU

ALI

TYIM

PRO

VEM

ENT PROGRESS

Commitment to partnership working (action plan working group and KAQP)

DBC, KCC, HA, EA, LA’s

Ongoing 1 Being carried out. Development of Kent wide planning guidance for Air Quality currently being formulated. Membership of Air Quality Screening group for Authorities with AQMAs along the M25. Meetings held with representatives from Highways Agency and Defra.

Development and implementation of a local air quality strategy for Dartford

DBC 2002 draft (short term)

1-2 Not in place as yet progress has been made in the development of a strategy.

Potential for regulatory vehicle emissions testing investigated

DBC 2002 (short term)

1 Not practicable

Energy management:

Energy efficiency schemes domestic and commercial

DBC/KC C

Ongoing 1 Audits carried out of several council buildings with support from the Carbon Trust resulting in energy efficient measures being put in place in buildings with high energy use.

Energy awareness DBC/KC C

Ongoing 1 Ongoing

Building Control measures DBC Ongoing 1 Ongoing

28

Environmental promotion:

Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

Improved awareness and dissemination of air quality information, including development of the DBC web site

DBC 2002 -3 (short term)

1 In place, weekly updates. Kent Air Website provides information on Air Quality and Monitoring Data.

Ad hoc talks to schools on LA21 DBC Ongoing 1 Infrequent but happening. Dartford Borough Council is committed to a three year agreement with Kent and Medway Walking Bus Group. DBC pays a proportion of money for the group to visit schools and promote and encourage the school to develop a walking bus

Vehicle emissions testing- promotion of free testing locally.

DBC 2002 (short term)

1 No DBC vehicle emission testing but some prior promotion of vehicle testing.

Liaise with Health Authority on provision of information and advice on health effects

DBC, Health authority

2002 (short term)

1 Intended to do this via Kent & Medway Partnership but no progress.

DBC –Dartford Borough Council; KCC – Kent County Council; EA – Environment Agency; HA – Highways Agency; LA – local authorities; DRC – Dartford River Crossing Concessionaire

29

Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

4.2 Planning and Policies

The Local Development Framework is a series of documents, which when adopted will replace the adopted local plan.

It will contain development and landuse policies that will fulfill the Council's community, economic, environmental and social aims for the Borough in the future.

The LDF core strategy preferred approach document has been produced which includes a section on air quality, it states:

120. Local authorities have a duty to consider the air quality implications of proposed development and condition approvals or refuse applications accordingly. This is especially important within Air Quality Management Areas. One Air Quality Management Area has been declared in the Borough and it is possible that others may be declared in the future.

121. The air quality issue has an important part to play in the overall vision for the Borough. If the issue is viewed too narrowly, site specific considerations may work against wider actions to improve overall air quality. New development will inevitably generate transport demands for example but developers (particularly of large sites) will be required to demonstrate the long-term effects of their development on air quality and how this may be offset by the wider benefits of improvements to public transport, a greater mix of uses which potentially reduces the need for longer journeys and Green Grid enhancements.

Dartford Borough Council has also produced a Dartford Town Centre Area Action Plan Preferred Options Document for Consultation which includes a section on air quality that states.

8.7 Air pollution levels on the town centre ring road, East and West Hills, Lowfield Street and Hythe Street, exceed air quality standards. This area has been designated as an Air Quality Management Area. The Council is preparing an Action Plan to address the issue and to seek to reduce emissions to an acceptable standard.

8.8 Emerging actions to address the situation include a shift towards more sustainable forms of transport, and improved traffic management to minimise build-up of stationary traffic which are promoted through this Area Action Plan.

Preferred Approach 23: Air Quality

To investigate options and opportunities to help improve air quality, including measures such as improved junction management using Urban Traffic Management and Control.

To require new developments to make a contribution towards measures to offset any adverse air quality impacts of the development.

30

Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

4.3 Local Transport Plan and Strategies.

Kent County Council has produced a Provisional Local Transport Plan for Kent 2006- 2011. Air quality along with Accessibility Congestion and Road Safety are the four shared priorities of this plan. Policies have been drawn up to help deliver these shared priorities.

Policy ECH 1 for Air Quality states that 'KCC will work with partners to seek a reduction in pollution caused by traffic on the local road network'

The 2nd Local Transport Plan for Kent 2006-11 which was submitted in March 2006 aims to “stabilise and, where possible, reverse the adverse effect of transport and its infrastructure on the natural and built environment and on local communities”.

Specifically, the LTP contains an air quality policy “to seek a reduction in traffic pollution on the local road network”.

LTP8 Air Quality in Air Quality Management Areas (AQMAs) - To reduce the annual average level of NO2 missions at Kent's AQMAs to 40 µg/m3 by 2010/11. Based on 11 AQMA sites on Kent's local road network. Intermediate traffic flow monitoring will form annual trajectory for this particular indicator.

Dartford Borough Council has approved a proposal for securing a long-term programme of transport investment for Kent Thameside. This programme is needed both to mitigate the effects of development proposed in the South East Plan, and to manage growth in background traffic.

An interim policy was adopted as a material planning consideration for development control purposes in July 2007, requiring developers to contribute a tariff of £5,000 per home as a condition of the grant of planning permission. The policy has subsequently been reviewed and was considered by Cabinet and General Assembly of Council in January 2008. The policy has been extended to non residential applications and will now apply to residential applications proposing a net increase of two or more dwellings.

31

Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

5. Conclusions and recommendations.

At present, twenty-five (69%) of the thirty-six NO2 diffusion tubes are located within AQMAs. However twenty-seven tubes have continually shown levels above the Air Quality Objective. Tube DA31 situated in the London Road AQMA has shown a marginal drop in Nitrogen Dioxide and is now fractionally below the annual average objective level. However tubes DA41 and DA48 which are not in AQMAs have annual averages above the objective level.

At location DA1 Church Hill which is situated at a junction that becomes congested at peak times. In 2007 this showed a level of 46.1 ug/m3 in 2007. This location however does not represent exposure. It is proposed that this junction is considered further in the next updating and screening assessment.

DA48 This monitoring location is along Hawley road at a point where the M25 motorway passes directly above. Improvement works were carried out on this section of the M25 in 2007 and 2008, as part of these improvement works an environmental barrier has been constructed. It is proposed to continue monitoring at this location to see if this barrier helps to reduce pollution levels at this monitoring point.

Tubes situated within the original AQMA which are concerned with pollution from traffic using the A282 tunnel approach road show no improvement generally although sites east of the road tend to show higher levels than those to the west. This may be due to the prevailing wind or even screening which shields more sites to the west from the pollution source. Pollution levels where traffic is forced to queue, i.e. at junctions and traffic lights seem to be greater than levels on an open stretch of road where traffic moves freely, this, together with traffic travelling uphill, are likely contributors to particularly high levels recorded by tube DA43 at Overy Liberty.

It is recommended that further AQMA’s are to be declared where pollution levels continue to exceed the annual objective. Further studies should be made around the A282 in roads at varying distances from the source to ascertain the true distribution of pollutants. Consideration could be given to the effectiveness of a barrier as shielding in order to reduce the effect of pollution alongside the A282 at those sites with the highest recorded levels i.e. Bow Arrow Lane and Brent Way.

Despite benzene levels remaining within the objective levels one diffusion tube is proposed to remain at Princes Road.

The majority of monitoring carried out within the borough of Dartford is at locations classified as being roadside, and consideration should be given that these results do not indicate the levels of exposure at the nearest receptor to the pollution source.

.

32

Review and Assessment of Air Quality in the Borough of Dartford - Annual Progress Report 2008

6. Appendices

Appendix A1 Map showing location of continuous air quality monitoring

stations.

A2 Map showing location of continuous air quality monitoring stations.

B1 Map showing locations of the NO2diffusion tubes Around the A282 tunnel approach road.

B2 Map showing locations of the NO2diffusion tubes Around the town centre.

B3 Map showing locations of the NO2 diffusion tubes in Greenhithe and Swanscombe

B4 Map showing locations of other NO2 diffusion tubes. .

C1 Part B industrial processes regulated by Dartford Borough Council.

C2 Map showing the location of Part A industrial Processes in Dartford

33

Appendix A1

Continuous Monitor Locations

Ivy Villas St Clements Way

lghtham Cottages - Bean

------"--- - .. ..-.. .... c.... _____ ._,_ ·-°"""""'-===-~--.w-·..---::::::.....~-IO-

-.,.----..-_.? ... ..., --

lnstone Road - Town Centre

Appendix A2

Appendix B1

Appendix B2

Diffusion tube monitoring locations Swanscombe & Greenhithe

~ \ Sto ne \

~-

Appendix B3

Appendix B4

Appendix C1

Dry Cleaners Company Address Grid

Reference. Permit Reference Date of Issue Variation Notice

Date Enforcement Date &

Notice Swanscombe Dry cleaners 2 The Parade, High

Street Swanscombe DA10 0AJ

X – 560619 Y - 174529

P69 19/12/2007

Victoria Dry Cleaners 73, Hythe Street, Dartford DA1 1BG

X - 554144 Y - 174254

B/66/07/orig 24/09/2007

Evergreen Dry Cleaners 53, Hythe Street, Dartford DA1 1BG

X - 554140 Y - 174212

P/65

Capricorn Dry Cleaners 34, Station Road, Longfield DA3 7QD

X - 560070 Y -168986

P/63/08/rev1 16/04/2008 16/04/2008

The Iron Inn Dry Cleaners 33, Dartford Road, Dartford DA1 3EF

X – 553241 Y - 174244

B/62/07/orig 25/09/2007

Lords Dry Cleaning Service 21, The Brent, Dartford DA1 1YD

X - 555210, Y - 173784

P/61/07/orig

Greenhithe Dry Cleaners 48, London Road, Dartford DA2 6DJ

X - 555863 Y - 173916

P/60/07/orig

Dartford Dry Cleaners 81, Lowfield Street, Dartford DA1 1HP

X - 554075 Y - 173757

P/59/07/orig 24/10/2007

Drive In Dry Cleaners 5, Main Road, Sutton at Hone, Dartford DA4 9HG

X - 555511 Y - 170896

P/58/07/orig

Birchwood Dry Cleaners 1, Birchwood Parade, Woodside Drive, Wilmington DA2 7NJ

X – 551102 Y - 171624

P/57/07/orig

Vapour Recovery (Petrol Filling Stations)

Company Address Grid Reference.

Permit Reference Date of Issue Variation Notice Date

Enforcement Date & Notice

Joydens Wood Service Station

100, Summerhouse Drive, Bexley DA5 2ES

X - 550696 Y - 171787

P/40/05/orig 30/03/2005

Dartford Express 107-115, Dartford Road, Dartford DA1 3EN

X - 552964 Y - 174300

P/38/05/orig 10/03/2005

Longfield Service Station 1-3, Station Road, Longfield DA3 7QD

X - 560135 Y - 169134

P/37/07/orig 15/11/2007

Elms Service Station 453 Princes Road, Dartford DA1 1RB

X – 555397 Y - 173380

P/35/05/orig

Burnham Service Station Burnham Road Dartford, DA1 5BN

X – 553508 Y – 175159

P/34/05/orig 09/03/2005

Winston Service Station (ROC UK Ltd)

224 Princes Road Dartford, DA1 2PZ

X – 552761 Y – 173565

P/33/05/orig 22/12/2005

Vanguard Service Station London Road, Stone, Dartford

X – 559018 Y – 174877

P/31/00/orig 25/08/2005

Hawley Road Service Station (Shell UK)

Hawley Road Dartford, DA1 1PU

X – 554662 Y – 172354

P/30/07/orig

Dartford Service Station 474 Princes Road, Dartford

X – 555604 Y – 173333

P/28/05/orig 22/12/2005

Greenhithe Service Station London Road, Greenhithe, DA9 9ES

X – 559019 Y – 174813

P/27/05/orig

Asda Station Road, Greenhithe DA9 9BT

X – 558209 Y – 175048

P/54/05/orig 13/06/2005

Mobile Concrete Crusher Plant

Company Address Grid Reference.

Permit Reference Date of Issue Variation Notice Date

Enforcement Date & Notice

Lancebox Limited Office Block F, Manor Way Business Park, Swanscombe DA10 0PP

X – 560544 Y – 174963

EP/CC/002 19/09/2008

Pinden Limited Pinden Quarry, Green Street, Green Road, Longfield DA2 8EB

X – 559540 Y – 169589

EP/CC/001 17/10/2008

F.M. Conway Limited Conway House, Rochester Way, Dartford DA1 3QY

X – 551293 Y – 173758

P/50/05/orig 15/06/2005

Concrete & Batching Processes

Company Address Grid Reference.

Permit Reference Date of Issue Variation Notice Date

Enforcement Date & Notice

J. Clubb Limited Darenth Road, Dartford

X – 555113 Y – 172665

P70 28/11/2007 28/11/2007

F. M. Conway Conway House, Rochester Way, Dartford DA1 3QY

X – 551293 Y – 173758

P/55/05/rev1 15/06/2005

Lafarge Redland Readymix Limited

Johnsons Way, King Edward Road, Greenhithe

X – 558269 Y - 175163

P/10/06/orig 06/03/2006

Vehicle Re-sprayers

Company Address Grid Reference.

Permit Reference Date of Issue Variation Notice Date

Enforcement Date & Notice

Autotech Bodyshop Limited Dewland Industrial Estate, London Road, Stone, Dartford

X - 556074 Y – 173817

P/68/07/orig

A. Pile & Sons St Vincents Road Dartford DA1 1XA

X – 555107 Y – 174363

P/15/07/orig 09/05/2007

North Kent Commercials Unit A1, Northfleet Industrial Estate, Lower Road Northfleet, DA11 9SN

X – 561188 Y – 174963

P/24/07/orig 09/05/2007

Painting of Metal & Plastic

Company Address Grid Reference.

Permit Reference Date of Issue Variation Notice Date

Enforcement Date & Notice

Corus – Dartford Service Centre

Faningham Road Station, Station Road, South Darenth DA4 9LD

X – 555353 Y – 169281

B/16/05/orig 05/09/2005

Cray Metal Finishers Unit D1, Riverside Way, Dartford, DA1 5BS

X – 554251 Y – 174901

P/22/07/orig 09/05/2007

Printing

Company Address Grid Reference.

Permit Reference Date of Issue Variation Notice Date

Enforcement Date & Notice

Howard Hunt (City) Limited Masthead Close, Crossways, Dartford DA2 6QF

X – 556198 Y – 175157

P/54/05/orig 10/02/2005

Waste Oil Burners

Company Address Grid Reference.

Permit Reference Date of Issue Variation Notice Date

Enforcement Date & Notice

Bulldog Engineering Services Limited

Main Road, Longfield Hill, Longfield DA3 7AS

X – 562595 Y – 167917

P/67/06/orig 09/10/2006

MGS Auto Progress House, Powder Mill Lane, Dartford, DA1 1NT

X – 554685 Y – 173024

EP/WB/002

Appendix C2