Folkestone Ship Street Gasworks Housing Plan: “Health Impact” Tick-Box, Toxic Land Risks, and Equality Act Red Flags in a Deprived Coastal Ward

Folkestone & Hythe District Council’s proposal to transform the derelict former gasworks at Ship Street into 135 homes (planning ref: 25/1316/FH) is now out for public consultation. In this in-depth report, the Shepway Vox Team examines the scheme’s promises and pitfalls – the good, the bad, and the ugly – based solely on two key documents currently available for scrutiny: Arup’s Land Contamination Report (16 June 2025) and Arup’s Health Impact Assessment (HIA) (26 June 2025). Our analysis also draws on local deprivation data and wider public health context to see how the plan measures up.

Setting the Scene: A Derelict Gasworks in a Hard-Pressed Community

Overgrown and fenced-off for years, the old Folkestone Gasworks site on Ship Street is an infamous brownfield blot. Gas production ceased in 1956 and the gasholders were demolished by 2001. The District Council acquired the land in 2021, eyeing a regeneration opportunity: new housing to revive an “established community” and make productive use of a long-neglected plot. The scheme has outline planning for up to 135 homes (a mix of houses and flats) plus possible flexible retail space, aligning with local plan policies to deliver housing-led regeneration on this urban site. In principle, it sounds like a win-win: more homes in a sustainable location close to the town centre and Folkestone Central station, cleaning up contamination in the process, and even a government Brownfield Land Release Fund grant to help with site remediation.

But – and there’s a big “but” – this patch of land sits within one of the most deprived corners of Kent. According to official Indices of Multiple Deprivation data, the neighbourhood around Ship Street ranks among the worst-off nationally on several measures. (The 2019 statistics placed a nearby area in the bottom 10% most deprived in England, and the latest 2025 update is expected to show similarly grim standings.) Folkestone as a whole is classified as a “higher deprivation” coastal town, with premature death rates in many wards significantly worse than the Kent and England averages. These are not just abstract numbers – they reflect real challenges: low incomes, high unemployment, poor health, and fragile community wellbeing. Any development here must confront that context head-on. Building shiny new homes is one thing; ensuring they genuinely benefit and uplift the local community (rather than glossing over entrenched problems) is another. As England’s Chief Medical Officer warned in his 2021 report on coastal communities, places like Folkestone often have “some of the worst health outcomes in England, with low life expectancy and high rates of many major diseases”. The Kent Public Health Report 2021 similarly highlights Folkestone’s plight: it’s a “higher deprivation mixed coastal town” where overall health lags behind inland areas. This is the backdrop against which we evaluate the Ship Street plans.

In the sections that follow, we’ll break down the good, the bad, and the ugly in the proposal and its evidence base. Strap in – it’s a story of commendable intentions, concerning findings, and a few unpleasant truths buried (quite literally) in the soil.

The Good: Regeneration Promises and Potential Upsides

It’s only fair to start with the positives. There are several encouraging aspects about the Ship Street redevelopment:

• A New Lease on Life for a Derelict Site: The very fact that something is being done about this long-abandoned brownfield is good news. For decades the old gasworks has been an eyesore – a sunken, fenced wasteland with crumbling brick remnants of industry past. The outline plan envisions transforming it into a residential neighbourhood, which could replace blight with new life. Importantly, this includes dealing with the pollutants left by its former use. Large-scale remediation was already attempted in 2009–11, removing some 131 litres of oily tar and treating 3,070 m³ of contaminated groundwater. Even so, hazards remain (more on that later), and now additional cleanup is proposed. The scheme has attracted funding support: a Brownfield Land Release Fund grant specifically to help pay for the remediation needed before construction. In other words, public investment is being leveraged to make the site safe and usable – a positive step, since without cleanup the land would likely sit empty indefinitely. Better to spend money on bulldozers and cleanup crews than leave a toxic legacy leaking into the environment.

• Much-Needed Housing (Including Affordable Homes): With housing demand high, 135 new homes are not to be scoffed at. Folkestone & Hythe District Council is pushing this as a housing-led scheme, and the design aims to allow a mix of houses and apartments of “appropriate size and tenure mix”. While details are to be firmed up in later planning stages, the HIA notes that affordable housing should be prioritised – recommending that new affordable units be offered to the local population first. If the development delivers on affordable homes, it could help local families currently living in substandard or overcrowded conditions, thereby improving their health and quality of life. Even market-rate units can indirectly ease housing pressure by increasing supply. Either way, replacing a contaminated lot with modern, insulated homes (meeting today’s building standards) should bring health benefits – e.g. less exposure to damp and mould that plague many old rentals. Arup’s HIA emphasizes design features meant to promote healthy living: step-free pedestrian routes, cycle paths, and green links through the site to encourage walking and biking. The layout is intended to connect with surrounding streets, improving permeability. In essence, they don’t want this to become a gated enclave, but part of the community fabric.

• Built-in Healthy Design Principles: The scheme has been assessed against “Healthy Streets” criteria – and earns some positive marks. For example, the plan includes a landscaped “green link” and increased cycle parking, and it’s designed with slow-speed internal roads (likely 20mph or less) to be pedestrian-friendly. Arup’s HIA finds that the development would “address some of the Healthy Streets indicators” for wellbeing. There will be safe, accessible walking routes (step-free and gently sloping despite the site’s 12-metre west-to-east drop) and clear sightlines, which the HIA calls a positive feature for encouraging active travel. Secure cycle storage is planned for both houses and flats, to make cycling convenient. In a neighbourhood that currently might not be very pedestrian-friendly (the disused lot literally blocks some connections), this could stitch together streets and shorten walking distances. The site is also blessed with proximity to amenities: two small supermarkets within 200m, a primary school around the corner, the train station about 10 minutes’ walk, and the creative quarter and harbour not far beyond. So future residents would have plenty in walking range. The HIA notes that no new fast-food outlets will be included on site – a tongue-in-cheek plus for “healthy food access,” since it means the development “could limit” any further proliferation of takeaways in the area. (The area already has its fair share of kebab shops and chippies; at least this project won’t add to that waistline temptation.)

• Community and Environmental Benefits: The council and Arup have at least paid lip service to wider community benefits. They’ve engaged in pre-application discussions with the Local Planning Authority and some local community input to shape the scheme. While the cynic might say “consultation” often means showing neighbours some drawings after decisions are made, it’s better than nothing. The design also considers open space and play areas – a pocket park on Foord Road and green edges are mentioned. The HIA specifically recommends making those spaces child-friendly and ensuring they’re well-maintained long-term. Done right, even small green spaces can be a boon in a dense urban area, offering a place for kids to play and residents to get fresh air. There’s also talk of biodiversity net gain (likely turning portions of the scrubby lot into intentional habitat). And of course, cleaning up toxic soil and groundwater benefits not just the new residents but the whole area’s environment. Removing pollutants (or safely capping them) will reduce ongoing risk of contaminants leaching into the nearby stream or soil gas seeping into neighbouring buildings. In short, the idea of this project aligns well with what one would hope for in regenerating a deprived, inner-urban site: new homes, better environment, and attention to healthy urban design.

That’s the good news. However, as anyone who reads planning documents knows, the devil is in the details. The Ship Street proposal’s rosy prospects come with caveats – and some serious concerns start to emerge on close inspection of the reports.

The Bad: Questions, Omissions, and Contaminated Realities

Turning to the less rosy aspects, we find a number of issues in the application documents that raise eyebrows:

• A Heavily Contaminated Site (No Surprise, But Still Bad): It’s no shock that a former Victorian gasworks is polluted – but the extent and nature of contamination at Ship Street are frankly worrying. The Arup Land Contamination Report lays it out in black and white (and oily shades of hydrocarbon). Despite earlier remediation attempts, significant contamination remains in the soil and groundwater. For instance, one soil sample showed benzene at 8 mg/kg and other harmful hydrocarbons (like xylene and trimethylbenzene) far exceeding residential screening levels. Black tarry staining and strong hydrocarbon odors were noted in certain areas during site investigations. Beneath the surface, the groundwater of the Folkestone Formation (a principal aquifer) contains dissolved toxins at staggering concentrations – benzene at 7.7 mg/L and xylene at 2.2 mg/L in one well, “several orders of magnitude” above drinking water standards. Even free cyanide (a byproduct of gas purification) was found up to 1.17 mg/L, literally thousands of times above environmental safety limits. In plain English: nasty stuff is stewing down there. If that weren’t enough, the soil is laced with asbestos fragments from demolition debris – detected in about 40% of samples tested, including loose fibrous asbestos (chrysotile and even some crocidolite) at various depths. Arup calls the asbestos findings “relatively significant” even in the current surface capping layer. This cocktail of contaminants is not unusual for old gasworks sites, but it poses a real challenge: how to build homes here without putting people’s health at risk?

• Remediation: Necessary but Uncertain: The plan, of course, is to remediate the site – but the how is still being determined. Arup identifies several “data gaps” that need further investigation, meaning they don’t yet have the full picture of contamination in all corners. Notably, an unsaturated soil vapour assessment has not been done yet, even though initial evidence suggests a “potential vapour risk from groundwater” contamination. Translated: toxic volatile compounds like benzene could migrate as gas through the soil and potentially into buildings. Ground gas monitoring in 2022 was also limited (six rounds of tests) and may not have captured worst-case conditions. Arup explicitly states that the amount of gas/vapour monitoring so far “is not sufficient for a high-sensitivity development” (i.e. homes with families) on such a contaminated site. They strongly recommend additional rounds of monitoring and detailed risk assessment for vapour intrusion before design of foundations. This is not the kind of thing you want left unknown when planning residential construction. The remediation strategy will likely involve excavating some hotspots, installing thick clean soil caps in gardens (0.6–1.0 m of clean topsoil), and possibly deploying specialised systems like soil vapour extraction or gas ventilation membranes under buildings. All that is doable – but it’s complex and costly. The bad news is that until these measures are fully designed and funded, there’s an element of uncertainty. Will the eventual developer (if the council sells the land on) cut corners to save costs? Will the remediation be done comprehensively, or only to the minimum to get housing built? The documents can’t answer that, but the history of brownfield development offers cautionary tales.

• Health Impact Assessment (HIA) Gaps and Siloed Thinking: One would expect the HIA – a document specifically about health – to grapple deeply with the contamination issue. Surprisingly, it barely does. The HIA acknowledges in passing that the site’s history means “the existing ground is contaminated, and remediation is required”, noting that gardens will need clean soil before residents can safely grow food. However, beyond this note in a table about allotments, the HIA is oddly muted about contamination risks. Nowhere does it discuss the potential health implications of, say, vapour intrusion (indoor air pollution from soil contaminants) or the stress that construction dust could cause to existing neighbours worried about what’s being unearthed. Arup’s contamination report explicitly flags vapour and gas as a concern – “additional vapour monitoring…should be undertaken…to evaluate volatilisation and vapour intrusion into future buildings”, warning that without enough data, the risk assessment for a residential build is incomplete. Yet the HIA, perhaps operating in its own silo, doesn’t mention this at all. Instead, it gives the construction dust and noise impacts a relatively clean bill of health: dust impacts are assessed as “medium risk for dust soiling and low risk for human health” with mitigation, earning a Neutral/Negative rating in the HIA checklist. That feels optimistic, given that asbestos fibres are present on site – one would hope the risk is indeed low if proper controls are in place (water suppression, air monitoring), but the document’s bland treatment of it doesn’t inspire confidence. This disconnect – between the technical contamination report and the health assessment – is concerning. It suggests the HIA might be a tad superficial, focusing on easier wins like access to parks and shops, while giving less attention to “ugly” health risks that are harder to quantify or perhaps outside the assessors’ usual scope.

• Community Health and Deprivation – A Missed Connection: Another weak point is how the HIA handles (or doesn’t handle) the existing community’s vulnerabilities. Remember, this scheme sits in a highly deprived area. One might expect the HIA to really dig into what that means: e.g. higher baseline rates of chronic illness, mental health issues, and lower resilience to upheaval. The Chief Medical Officer’s 2021 report emphasised that coastal communities often have “concentrations of deprivation and ill health” hidden in plain sight – Folkestone is a textbook example. The Kent Public Health report notes Folkestone’s premature mortality and disease rates are markedly worse than average. Did the HIA reflect this? Only to a limited extent. It does include a baseline profile using local data – noting, for instance, that one of the local LSOAs (014B) is among the top 10% most deprived in England and that unemployment and child poverty are high. It even points out higher smoking rates among adults with long-term mental health conditions locally. Yet, when it comes to assessing impacts, the HIA doesn’t strongly link these factors to the development. For example, there’s little discussion on how construction might psychologically affect a community that has been “long overlooked” (to borrow the CMO’s phrase) or how the new housing could price out locals if not truly affordable. Mental health gets a brief analysis in the baseline (Folkestone has somewhat lower under-18 mental health admissions than national, but higher adult mental health need indicators). But the HIA doesn’t explicitly address how the development could impact community mental health – say, through changes in social cohesion, or simply the stress of living atop a remediated toxic site (which can be an anxiety factor in its own right). In a deprived area, residents may also be more vulnerable to construction nuisances (e.g. those with existing respiratory conditions could be more affected by dust). These nuances are absent. The HIA, by its own admission, was a “rapid desktop checklist” exercise, not an in-depth study, which might explain the tick-box nature of some sections.

• Strain on Services: The addition of 135 homes will inevitably put more demand on local services – GPs, schools, etc. The HIA does nod to this, suggesting that a review be done to see if health services can cope and that KCC (Kent County Council) be consulted about school capacity. It notes, for instance, that the nearest primary schools are already at or over capacity. These are modest mitigations (“consult and review”). It’s not a fatal flaw, but it’s something to keep an eye on: will developer contributions help expand a GP practice or fund school places? If not, new residents could find it harder to book a doctor’s appointment in an area that already struggles with GP recruitment (a common coastal town issue, as the CMO report highlighted about attracting healthcare staff to peripheral areas). Again, not unique to this project, but part of the “bad” that needs addressing.

In summary, “the bad” boils down to this: the project’s documentation acknowledges serious contamination and community challenges, but the strategies to deal with them feel under-baked at this stage. There are a lot of “to be investigated” and “should be done later” notes. That’s typical for an outline planning application – many details are deferred – but it means residents and planning committee members are being asked to support the scheme on trust that the ugly stuff will get fixed down the line. And speaking of ugly… let’s talk about that.

The Ugly: The Gritty Truth behind the Glamour

This is where the rubber (or perhaps the tar) meets the road. The “ugly” comprises the stark realities that no amount of PR spin can fully hide:

• Toxic Legacy Underfoot: No way around it – the site is a toxic minefield at present. The ugliest truth is spelled out plainly in Arup’s contamination report: “vapour monitoring of the unsaturated zone has not been completed to date… Additional monitoring is required”, and “the amount of gas monitoring and vapour monitoring is not sufficient for a high sensitivity development… Additional monitoring is required”. That is a sobering statement. It essentially means we don’t yet know exactly how dangerous the leftovers of the gasworks are to future residents. Given what’s already known – pockets of hydrocarbons, cyanide and who-knows-what in the ground – one doesn’t have to be a pessimist to imagine worst-case scenarios: vapours like benzene (a known carcinogen) seeping into homes if membranes fail; children digging up a shard of asbestos in the garden if any remediation is shoddy; or construction workers encountering unexpected hazardous hotspots. The report even notes that dense non-aqueous phase liquid (coal tar) was found as late as 2011 in wells over 2 meters thick – meaning there could still be blobs of pure tar lurking underground. It’s an ugly cocktail of contaminants that will require intensive efforts to remediate. Arup suggests multiple techniques (soil vapor extraction, continued groundwater pumping, etc.), but it’s not yet finalised. For local residents reading the planning file, this should set alarm bells ringing. Yes, it can be cleaned to a safe standard – brownfields get developed all the time – but if corners are cut, the consequences could quite literally poison the project. We trust that the council, as the applicant, will ensure a rigorous remediation plan (they surely don’t want a public health fiasco on their hands in a few years). But the history of such sites is checkered, and it will take sustained scrutiny to make sure promised measures (like full vapor barriers under buildings, permanent gas venting systems, and verification tests) are actually implemented and verified.

• A PR Paintjob vs. Reality: The glossy sales brochure by property agents Avison Young markets Ship Street as a prime “Freehold Development Opportunity” – complete with attractive aerial photos and upbeat bullet points. It boasts that the outline plan “addresses important environmental considerations such as flood risk, land contamination, and biodiversity net gain through comprehensive technical assessments”. That line is doing a lot of heavy lifting. The “comprehensive assessments” indeed exist (the reports we are reviewing), but reading them is enough to make one gulp. Nowhere in the brochure’s shiny pages does it mention the words “cyanide” or “asbestos” or “benzene in groundwater”; instead we get that a remediation grant is available and that the site is “vacant and ready” for a high-quality housing scheme. The ugly contrast between the public-facing narrative and the technical reality is striking. Of course, sales brochures are advertising, not academic honesty. But for The Shepway Vox Team, it’s hard not to smirk at lines like “the site presents a significant opportunity” – true, if your idea of opportunity includes the opportunity to don hazmat suits and remove tons of contaminated soil! The brochure emphasises the positive – proximity to the Creative Quarter, lovely views towards the harbour, the £2.2m government grant (reportedly) to fix the land – while downplaying the messier bits. It’s our job to highlight that mess. Lest anyone think the Shepway Vox Team is being alarmist, remember this is literally an old gas works. The ugly stuff is par for the course. What matters is total transparency and commitment to addressing it, not sweeping it under marketing euphemisms.

• Community Trust and Mental Wellbeing: Finally, an “ugly” factor that is harder to quantify but palpable: the potential impact on community trust and mental wellbeing if things aren’t handled right. Folkestone’s coastal community has, as the CMO put it, “been long neglected and overlooked”. Many residents in East Folkestone have lived with deprivation and health inequalities for years. A big regeneration project like this can be a ray of hope – or a source of anxiety. If locals feel the project is something done to them rather than with them, especially given the health hazards involved, it could exacerbate stress and skepticism. Consider the fear some may have about living next to a contaminated site: Will dust from construction harm my kids? Will the new homes be for outsiders or for us? The HIA, in its limited scope, didn’t really probe these community mental health angles. But they are very real. The Kent Public Health report on coastal towns notes a higher prevalence of mental health disorders in similar deprived coastal areas, and links issues like unemployment and poor housing to poor mental wellbeing. If the Ship Street development ends up feeling like a sanitised enclave that doesn’t integrate or address local needs (for jobs, truly affordable housing, safe environments), it might even heighten a sense of division. The best outcome would be if, after remediation, the site not only provides new homes but also maybe some community space or at least a safer streetscape that benefits everyone. The ugliest outcome would be if, years down the line, residents complain of strange odours in their new houses or illnesses that raise questions about whether the cleanup was thorough – a scenario we fervently hope never materialises. Trust is key: the community needs to trust that the Council (wearing its developer hat) isn’t cutting any corners, and that public health truly is front and centre.

Conclusion: Balancing Revitalization with Realism

In summary, the plan to redevelop Ship Street’s former gasworks has much to commend it – it aims to bring much-needed housing and environmental improvement to a long-blighted patch of Folkestone. The good includes thoughtful design elements for healthy living, investment to clean up industrial pollution, and alignment with the urgent need to uplift a deprived area. The bad encompasses the uncertainties and omissions in current plans: significant contamination yet to be fully assessed, and an HIA that, while highlighting some positives, glosses over critical health risks and local vulnerabilities. And the ugly is simply the gritty reality of what lies beneath the ground – a legacy of toxic substances that must be dealt with thoroughly and transparently to avoid future harm.

The Shepway Vox Team will continue to follow this application as it progresses. At this consultation stage, we have only the documents in front of us – and based on these, our commentary is one of cautious optimism tempered by serious concern. We urge the Council and any eventual development partners to heed the warnings in their own reports: do the extra investigations, communicate honestly with the public, and ensure robust health protections are non-negotiable. Folkestone’s people deserve nothing less. In an area with high deprivation and longstanding health inequalities, a project of this scale should set a positive precedent – showing that regeneration can be done without sacrificing safety or community trust. If the Ship Street redevelopment can turn a poisonous plot into a healthy, thriving neighbourhood, that would truly be a good news story for Folkestone. Until then, we’ll be watching – and sniffing the air – with a healthy dose of skepticism.

The Shepway Vox Team

Discernibly Different Dissent