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					998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge



          Report presenting detailed OBJECTIONS
          by
          Sellindge and District Resident's Association
          to the Proposal submitted by
          Countrystyle Recycling Ltd
          for the
          Construction and Operation of a
          Materials Recycling Facility and
          Anaerobic Digestion Plant
          at
          Otterpool Quarry, Sellindge, Kent.




Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 1 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge



  A - INTRODUCTION & OVERVIEW

         1.     On every occasion that the application documents are inspected with any
               degree of close attention more errors and inconsistencies come to light.
               There are multiple instances of contradictory designs given for the same
               element; for example there are notable inconsistencies in the illustration of
               the site access and egress arrangements.

         2.    The single consistent conclusion that has been drawn is that the
               application itself is poorly presented and ill-thought out. The application
               documents are fundamentally flawed and deficient to a level that would
               commonly render a full application being designated invalid.

         3.     The design and layout of the proposed development verges on the
               incomprehensible. The inaccuracies within even the very limited
               information submitted for the physical manifestation of the proposed use
               shows a disregard by the applicant and their agents for the specific
               character and qualities of the environment they intrude upon.

         4.    The image shown above right is from a public demonstration and march
               against the proposed development. The villages have no doubt about the
               deleterious impact this development would have on our community and the
               existing rural landscape.

         5.     Throughout the Application documents and the Environmental Statement,
               there are further distinct inaccuracies.

         6.    One example of this is found in SLR’s Ecological Report, ECOL P 16.
               which describes how surface water with the potential to cause pollution
               during the construction phase ‘is likely to be intercepted by the drainage
               system for the A20 to the North of the site where it would be discharged to
               storm drains and treated before being released into natural water courses’ .
               Our own knowledge of the locality is that ‘run off’ from the highway
               drainage system situated at the junction of Otterpool Lane and Ashford
               Road discharges into the property known as Barrow Hill Farm Cottages.
               Needless to say, it is untreated.



Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 2 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge

        7.     It is the inconsistencies in the submission that exemplify our doubts over
               the thoroughness of the Applicant and their Consultants, SLR, to present
               robust and comprehensive information as part of their application to Kent
               County Council, particularly in such complex areas of concern as
               Hydrogeology and Groundwater protection.

        8.     It is quite obvious from many areas of the submission that there is an
               unusual absence of awareness of the physical characteristics of the site,
               and the environmental issues that surround it. The application documents
               are separated into specialised sections but there is no point at which the
               various elements are satisfactorily co-ordinated and in many instances the
               documents are inconsistent and contradictory.

        9.     It is usually the case that development information is consolidated into a
               Design and Access statement supporting adequately detailed drawings
               and other information. The Design and Access statement provides no
               relevant information at all and the drawn project information is almost
               entirely absent compared to what would be reasonably expected to
               comprise a Full Planning application for a major development.              Kent
               County Council publishes very clear requirements of the type and level of
               information and detail required as part of any planning application. This
               application contains very little to satisfy these, and little that can be relied
               upon.

        10. The most fundamental obligation that an applicant must fulfil when making
            a planning application is to provide a clear, accurate description of the
            proposed development in all respects: this particularly includes use,
            layout, impacts and appearance. This is the basis on which the merits or
            otherwise of an application can be properly considered and determined by
            a Planning Authority. If the information provided is incomplete, inaccurate
            or contradictory it would be unsafe for consent to be granted.

        11. Our fear is that, whilst it should be possible to trust applicants and their
            consultants to be accurate when supplying development proposals and
            assessments, in the absence of necessary basic information we are left
            having to guess at their intentions, risking critical areas slipping through
            with inadequate consideration, at the expense of the environment.



Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 3 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge

        12. We conclude that :-

               ●    the development proposal for the former Otterpool Quarry site is badly conceived.

               ●    the application is incomplete, inaccurate and contradictory.

               ●    the use of the site for Anaerobic Digestion and Mixed Waste Recycling Facilities is inappropriate.

               ●    the bulk and massing of the proposed buildings would be harmful to the visual environment.

               ●    the development would endanger water quality, public and environmental health and well-being.

               ●    for these reasons the application should be refused planning consent.

               We have now identified seven key areas of objection.

               These are detailed in the following pages as Core Objections 1 to 7.




Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                                page 4 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge


  B - CORE OBJECTION 1.

          There are serious discrepancies between the drawn plans, and there are
          further inconsistencies with written descriptions and illustrations. Examples of
          the contradictions, inconsistencies and ambiguities include :-

   1.     The means of access to and from the site is ambiguous, showing differing
          arrangements on different drawings.
            (a) The use of the existing quarry access point is recognised as
                appropriate. The submitted drawings OP/4, OP/10, OP/11 and OP/12
                all show identical bi-directional access and egress arrangement
                connecting to the A20.

             (b)    This arrangement totally contradicts the proposed access
                    improvements and detail design shown on drawings numbered 2 and
                    HD1 within the Traffic and Transport assessment at Chapter 4 of the
                    Environmental Statement. Drawing HD1 is explicit and is a design
                    which will only permit vehicles to enter the site from the east, and to
                    leave in an eastwards direction.

             (c)    The text of the Traffic and Transport assessment contains many
                    references that only the “...vast majority of vehicles would approach the
                    site from the east and therefore right turn movements into the site
                    would be minimal...” whereas the detail design should make any
                    access from the west wholly impossible.              The assessment is
                    ambiguous in this respect and requires clarification.

             (d)    Since the Traffic and Transport assessment was submitted, planning
                    consent has been granted for a B1 commercial development to the
                    rear of the Airport Cafe. This will alter the traffic flow characteristics in
                    the immediate vicinity of the new site entrance.           The assessment
                    should be updated to take account of this.

             (e)    It is surprising that the site access arrangements continue to ignore
                    and contradict the proposed access improvements and detail design
                    shown on drawings numbered 2 and HD1 within Chapter 4 of the
                    Traffic and Transport assessment. These drawings are dated April and
                    May 2008 respectively.


Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 5 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge

   2.     The office block is alternately shown as single storey, flat roofed (Application Drawing
          OP/9) and then as two storeys with pitched roof.

             (a)    The most recent part of the submission provided by the applicant is the
                    document entitled Visual Appraisal, dated November 2009. The document
                    includes a series of before and after photomontage views of the site from varying
                    distances. The document also includes a brief written description of the
                    buildings that in total comprise the built form of the proposed development.

             (b)    At paragraph 1.3 it states that the development would “...comprise of a Materials
                    Recycling/Transfer Station..., an Anaerobic Digestion Facility...., as well as office
                    facilities (a two storey brick built building with fibre cement roof, approximately
                    6m to the eaves).....”. The application submitted to KCC in December 2007
                    included drawing OP/9, proposed office elevations, which shows a single storey
                    portakabin type of building, entirely different to the two storey brick building that
                    the applicant seemingly now proposes.

             (c)    This two storey brick building and the MRF building dominate and overwhelm the
                    landscape as shown in Viewpoint 3, even after the supposed ten year
                    landscaping establishment.




Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 6 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge




   3.     The drawings inaccurately show the extent of the site and the scope of
          existing landscape features.


             (a)    The Visual Appraisal also includes an amended landscaping plan, drawing
                    OP11/A dated November 2009, which replaces a preceding version dated May
                    2008. The latest amendments on this drawing include the addition of Betula
                    Pendula Standard trees to the area immediately adjacent to the A20 junction with
                    Otterpool Lane.

             (b)    This area has been substantially changed by junction alterations completed in
                    mid-2009. It is extraordinary that these changes have not been acknowledged in
                    the revised drawing.




Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 7 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge



   4.     There are discrepancies concerning layout, function and size of buildings.

             (a)    The submitted site layout plan for the MRF shows the building oriented
                    with the belt screeners equipment shown at the southern end of the
                    building the plans and elevations for the building show the
                    arrangement handed completely opposite.

             (b)    The contradiction heralds implications for traffic movements around the
                    site.

             (c)    This unnecessary ambiguity shows a lack of care or concern in the
                    assembly of the design at the most basic of levels and throws doubt on
                    the reliability of any other information provided as part of the
                    application.




Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 8 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge

   5.     The submitted site layout plan shows the finished product building as an
          enclosed structure with specific vehicle entry/exit points.

              (a)    Eight lorry parking bays are shown arranged across the northern
                     boundary of the site. Vehicle tracking diagrams are included on the
                     site plan showing how this layout and vehicle manoeuvring operates.

              (b)    The detailed plan for this building shows an open sided structure with
                     entry/exit along the full frontage. This is inconsistent with the parking
                     layout shown.




              (c)    There is a lack of information and clarity about exactly how operational
                     vehicle movements within the site will be managed and undertaken
                     safely or with due regard to wider environmental considerations.

Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 9 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge



   6.     Some buildings are not described at all.

              (a)    The Design and Access Statement mentions 'weighbridge facilities'.
                     Inspection of drawing OP/4 (dated December 2008) shows a structure
                     in plan only.

              (b)    None of the application documents provide any further information
                     concerning the appearance, height or materials of this facility.

              (c)    A further structure seems to be indicated behind the weighbridge, with
                     some form of connection to the foul drainage system.

              (d)    Apart from the rectangular shape shown on the plan no information is
                     given for this at all.

              (e)    The written descriptions, including basic dimensions where actually
                     given, of the proposed Materials Recycling Facility, Finished Product
                     or External Maturation Pad, and Anaerobic Digestion Plant buildings
                     are inconsistent with those given on the drawings. For the office and
                     mess room building no height is given at all, either in the document or
                     on the drawings.




Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 10 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge



   7.     Landscaping proposals described in the documents make several references
          to the retention of existing trees and landscape features on the boundaries of
          the site and their use to visually screen the development. These either do not
          exist, or would be severely compromised by the implementation of the
          development.

              (a)    Reference is made to a new “....4m high bund along side the western
                     boundary where the maturation pad is located.” The maturation pad
                     (or finished product building) is located alongside the eastern
                     boundary of the site. There are no 4m high bunds shown on any of
                     the application drawings in any location.

              (b)    The Visual Appraisal dated November 2009 describes the existing site
                     as surrounded by a belt of trees on its northern, southern and eastern
                     sides providing a valuable visual screen of the site. It confirms that
                     these will be retained, supplemented by new planting aimed at
                     providing additional screening and landscape enhancement. The
                     proposed planting would also rely on existing and new bunding within
                     and outside the application boundary. No arboricultural report has
                     been carried out, nor has a survey of existing trees on and about the
                     site been undertaken to confirm size, species and location to enable a
                     full assessment in the context of the proposed development works and
                     alterations to levels.

              (c)    Along the eastern boundary existing trees and planting that forms the
                     screening belt sit on raised ground that extends some distance into
                     the site. Overlaying the proposed site plan onto an aerial photograph
                     shows that much of this area would have to be be excavated and
                     levels altered to accommodate the Finished Product Building and an
                     attenuation pond. As a result the raised ground would be removed,
                     the effectiveness of existing screening almost completely eradicated
                     and the proposed buildings completely exposed to view from the east.

              (d)    Similar conclusions are made concerning the existing screening along
                     the southern and northern boundaries, especially either side of the site
                     access where mandatory highways sight lines will raise additional
                     concerns.


Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 11 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge

   8.     The visual impact of the proposed development has
          not been fully explored and is based on flawed
          assumptions.

              (a)    The Visual Appraisal only presents
                     conclusions    from    two    viewpoints,
                     numbered 2 and 3. Both of these are from
                     the north-west and are on almost identical
                     alignments.

              (b)    No visual assessment has been made for
                     views along the A20 looking west towards
                     the site, and none from Otterpool Lane
                     looking northwards.

              (c)    The visual assessment has failed to fully
                     identify the potential for significant adverse
                     visual effects.

              (d)    The Visual Appraisal is devalued by being
                     based on inaccurate assumptions, taking
                     no account of existing landscape feature
                     losses, and by ignoring key public
                     viewpoints from the south and east making
                     allowance for the loss of existing
                     screening.




Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 12 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge



   9.     No detail is given showing how the operational site will be secured and made
          safe during and outside the specified working hours.

              (a)    There is no detail of the location or type of entrance gates proposed,
                     and no detail of perimeter fencing.

              (b)    As the activities to be undertaken on the site hold undeniable dangers
                     to the public this is a matter of significant local concern. Has the
                     applicant carried out or provided a Risk Assessment for the proposed
                     development when operational?




Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 13 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge


  C - CORE OBJECTION 2.

          The proposal does not adequately describe the situation regarding the use,
          disposal and pollution of water.

   1.     Our concerns centre on the importance of maintaining and protecting an
          extremely precious resource. Principally these relate to the potential for
          irreparable pollution of groundwater, the primary source for water supply in
          this area.

              (a)    In March 2006, Folkestone and Dover Water Services (now Veolia
                     Water) applied to Central Government for, and received, the
                     designation ‘Water Scarcity Status’. This indicates the degree of
                     water deficit experienced in East Kent. No other Water Company has
                     received such status and this clearly shows that this is the driest area
                     in the UK.

              (b)    Most of our drinking water comes from aquifers in this area and at
                     present needs little treatment.

              (c)    The Otterpool area contributes to the recharging of the aquifers and
                     we must ensure that precious water supplies are kept potable and not
                     put at unnecessary risk.

              (d)    Water management is critical in this area if we are to cope with the
                     expanding population in the south east. In parallel domestic use
                     initiatives such as metering, commercial calls on the water supply
                     must also be considered.

              (e)    The application does not provide any information on projected water
                     consumption at the site, nor does it demonstrate any proposals for
                     water saving initiatives.




Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 14 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge

   2.     Geologically, the site lies on the Hythe Formation.

               (a) This is classified by the Environment Agency as a Major Aquifer in
                   terms of the Policy and Practice for the Protection of Groundwater.
                   The Hythe Formation is also described by Mid Kent Water as a
                   Significant Water Resource.

               (b) The site of the former quarry is made up of Ragstone and Hassock
                   overlying Lower Greensand. The Lower Greensand is significant for
                   its importance as a major source of drinking water for this part of the
                   South East. Areas of the Folkestone Formation are also relatively
                   close; these are also regarded as a significant water resource.

               (c) The site itself is very permeable and usually copes quite well with
                   short, heavy downpours. Water drains towards a small pond at the
                   north east corner of the site and from there it leads into a water
                   course, flows east for a short distance and then north, eventually
                   finding its way to The Stour.

               (d) During prolonged periods of wet weather the site tends to become
                   waterlogged. During heavy downfalls In these periods, rainwater runs
                   over the surface of the site (from the south to the north) and ‘sheets’
                   across the A20 towards the Airport café.

               (e) As a cautionary note, Lower Greensand is more susceptible to
                   groundwater pollution than any other formation due to its extensive
                   outcrop area.




Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 15 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge

   3.     Negligible information has been submitted concerning existing and proposed
          ground levels. No correlation has been made by the applicant between these
          and the local water table levels:-

              (a) Examination of levels stated on the drawings shows that the applicant
                  proposes to reduce existing ground levels by as much as 5 metres,
                  and an average approaching 4 metres. We have analysed the limited
                  site levels information provided and from this have calculated that a
                  minimum of 50,000 cubic metres of material will need to be excavated
                  and transported away from the site. Some of this material is known to
                  be contaminated. The application gives no details of how this volume
                  of material will be dealt with.

              (b) The size of the individual building footprints and the disposition of
                  entrances and exits means that there would have to be extensive
                  excavation below the current reduced land levels.

              (c) The volume of site waste materials proposed to be handled generates
                  a very high number of daily HGV journeys; this would have a highly
                  significant detrimental effect on the amenity of the surrounding area,
                  particularly that of Newingreen and other homes alongside the A20.

              (d) We have been repeatedly assured by KCC that the applicant is to
                  provide fully detailed sections and levels across the site to properly
                  identify the relationship of the buildings to the site, its immediate
                  surroundings, and the landscape in general. Without this information
                  it is impossible to fully assess the impact of the proposed
                  development on the immediate and surrounding environment or
                  landscape. It is impossible to verify the degree of intrusion into the
                  water table. This information is still awaited.

              (e) The ground water levels data given by SLR has been extremely
                  selective, initially referencing only to a single dry summer period from
                  2008, and latterly from a drought winter period in 2005. This
                  misrepresents the true situation, is misleading, and entirely unreliable.
                  The Environment Agency has noted the deficiency in information and
                  has asked for wider annual information which as yet has not been
                  provided.


Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 16 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge



              (f)    The Association has recorded the water levels on the site at various
                     ‘on site’ boreholes on at least three occasions. We have found the
                     water level in the most southerly borehole to be between only 0.35
                     metres and 1.85 metres below surface level during the winter months.
                     We have also noted that these levels dropped away during long dry
                     summer periods with the same borehole registering a depth of 3.3
                     Metres. This indicates a fast flowing groundwater regime travelling
                     from the SSSI escarpment directly to the south of the site, and a
                     highly variable water table level.

              (g) Rainfall statistics have been recorded in the village for many years.
                  They show that at least once in each decade from the past 50 years
                  more than 5 inches of rain has fallen within a single 24 hour period.
                  Flooding is not an uncommon event in Sellindge.




Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 17 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge

              (h) Even using the limited water table figures given by the applicant and
                  comparing these with existing site survey levels, careful examination
                  of the plans shows that both of the proposed surface water
                  attenuation ponds lie below the water table. The attenuation ponds
                  are shown linked and the smaller pond will be constantly draining into
                  the second. They will therefore be permanently full of water and
                  incapable of attenuating the rate of surface water discharge from the
                  site.




Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 18 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge



   4.     There are no mains sewers serving the site location. We have major
          concerns about the disposal of foul and polluted water from the site. The
          application contains insufficient information concerning the detail design of
          foul and surface water drainage installations.

              (a) No mains sewers, foul or surface water, serve the quarry site. The
                  application shows that foul and noxious wastewater will be collected
                  on site in a holding tank, and then be pumped out into tankers and
                  removed from site. No information is given concerning size, depth,
                  capacity, or bunding of storage tanks to deal with either normal or
                  abnormal spillage conditions and no information on how many vehicle
                  movements are required daily to dispose of this waste.

              (b) There is a direct relationship between the volumes of water used or
                  produced as part of material processing and the volume of polluted
                  water that must be exported from site, by tanker in the absence of foul
                  sewers. The volume to be exported will be further added to by
                  surface water from vehicle area hardstanding areas which will also
                  contain pollutants. These factors in turn define the size of foul
                  drainage holding tank that would be required, the position of this in
                  relation to the water table, and in turn the number of regular vehicle
                  movements required to carry liquids away. None of the information
                  required has been included in the submission documents.

              (c) The Environment Agency expressly demands that no part of the foul
                  water storage facility must ever be below the water table.

              (d) The Environment Agency has expressly stated that planning
                  permission can not be granted unless a fully detailed drainage and
                  infrastructure plan for surface and foul water drainage has been
                  submitted and agreed by them.




Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 19 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge

              (e) The application explains that the site currently benefits from a
                  Consented surface water discharge, ref: P.2136/11/89, although it has
                  not been in current use for several years. The correct reference is
                  P.2136/K/89 and is dated 16th January 1989. The schedule for this
                  consent clearly states that ‘The effluent discharged shall consist only
                  of surface water from the land and premises to which the application
                  relates’, and that the effluent discharged shall not contain any visible
                  traces of oil or grease. The application only related to the site, plant
                  and equipment in use at that time and has no relation to the
                  operations now proposed. ‘To which the application relates’ does not
                  include a Materials Recycling Facility or an Anaerobic Digestion plant.

              (f)    The applicant states that surface water ‘run off’ shed from site would
                     pass through an oil interceptor to arrest oil and grease. This has been
                     common practice in arresting petrol and oils for many years. It is also
                     now commonly recognised that under peak conditions the
                     effectiveness of petrol interceptors is compromised by high volumes
                     of water passing through in short periods of time.

              (g) As submitted the design proposes that this discharge would comprise
                  rainwater from roof structures and the external hardstanding areas,
                  which would be impervious. There is a high probability that the
                  external hard surfaced areas of the site will be contaminated by
                  material distributed on vehicle wheels through traffic movements on
                  the site. Petrol and Oil interceptors do not arrest microbial or
                  bacteriological contaminants and these would therefore be passed
                  through to local watercourses and groundwater via the attenuation
                  ponds. This would be an entirely unacceptable situation placing
                  natural waters at serious risk of contamination.

              (h) Only rainwater shed from roof areas can be considered safe for direct
                  disposal to watercourses.        All surface water drainage from
                  hardstanding areas must be drained away through foul water
                  systems. In the absence of foul water mains sewers serving the site,
                  this would mean via the foul drainage sealed holding tank.




Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 20 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge

              (i)    The capacity of the foul drainage sealed holding tank would need to
                     be increased in size to handle 1 in 100 year + 20% climate change
                     potential site runoff, in addition to any volumes originating within the
                     buildings and from the anaerobic digestion processing. According to
                     the Hydrology and Flood Risk Assessment the attenuation ponds
                     have been sized at 2250 cubic metres to deal with building roofs and
                     hardstanding drainage. As the hardstanding areas account for
                     approximately 55% of the surface water runoff source area it would
                     appear that the relevant additional volume should be in the order of at
                     least 1200 cubic metres.

              (j)    To reiterate, no part of the foul water storage facility must ever be
                     below the water table.




   5.     There is a perceivable likelihood of an increased risk of flooding of adjacent
          properties as a direct result of the proposed development.

              (a) The site is elevated above the carriageway of the A20 and surface
                  water run-off is frequently observed escaping from the site area,
                  crossing the road and flowing onto the land around the Airport Cafe.
                  From there it finds its way either into groundwaters or via ditches into
                  the Stour.

              (b) The existing site area comprises virtually fully permeable surfaces.
                  The proposed development converts a large proportion of this to
                  impermeable surfaces and in doing so creates the potential for
                  heightened surface water runoff to flow from the site and have impact
                  on the surrounding locality, particularly the Airport Cafe.            In
                  considering annual probability rainfall events the documents identify
                  that at present the 2-year current rate of runoff for the catchment area
                  is 4.7 litres/second. This rate of runoff has been adopted as the
                  design standard for maximum outflow from this development, although
                  developments are usually required to achieve a reduction from, rather
                  than just equalling an existing situation. After development this would
                  rise in the worst case scenario to a 100-year + 20% climate change


Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 21 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge

                    runoff rate of 38.8 litres/second. In calculating the storage capacity
                    required to achieve the intended result it is necessary to use the
                    difference in runoff rate before and after development of 34.1
                    litres/second, and not the much smaller volume used by the applicant.

              (c) The Environment Agency has vetoed the use of soakaways at this site
                  to protect the water resources below from contamination risk. In
                  response to this the applicant's design method to reduce the rate of
                  runoff from the site is to construct attenuation ponds within the site to
                  temporarily store storm water, and to release it beyond the site
                  boundary over a longer period of time at a slower rate than the ponds
                  fill up. However as we have identified that these ponds will be within
                  the water table, and therefore be permanently filled, we believe that
                  this method will prove ineffective. Heightened volumes of water will
                  pass from the site across the roadway and cause significant problems
                  for the neighbouring land and properties.

              (d) Groundwater levels fluctuate by some 2.75 metres and is fast flowing
                  indicating a steep hydraulic gradient from the South to North. We are
                  concerned that development on the site will alter the flow regime in
                  such a way to cause flooding (by creating in effect a dam) to the south
                  from the SSSI escarpment and to the West and East. We have
                  already witnessed alterations at the newly formed Otterpool Lane
                  junction simply because rainwater would not drain away as originally
                  designed. We are observing a situation where groundwater from the
                  site area is seeping from the base of the newly formed landscaped
                  grass bank, draining continually into the highway drainage system at
                  the junction. This is evidenced by algae growth on the concrete
                  components bordering the bank. This demonstrates what will ensue if
                  developers do not understand or do not acknowledge the complex
                  hydrogeology of the locality of this site.




Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 22 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge


  D - CORE OBJECTION 3.

          The proposal is out of scale with the surrounding landscape. The industrial
          sheds proposed will be highly visible intrusions into the local landscape and
          will have serious visual and ecological impact on the wider locality. The
          Design and Access Statement procaims that the site is a 'brownfield, industrial
          type location'. This proposition can not be supported by any reasonable
          interpretation of the facts.

     1. Inspection of historic mapping and aerial photography (including information
        from the Kent Landscape Information Service) shows that the development of
        the site had little previously built form, and nothing constituting the industrial
        character falsely proclaimed on the applicants submission documents.

              (a) The applicant's Preliminary Contamination Assessment, dated April
                  2008, accurately described the site as “...located within a predominantly
                  agricultural area.”

              (b) The application documents disingenuously suggest that the site has a
                  history of industrial usage. Original activity at this location was small
                  scale quarrying developed over a period of many years, starting close
                  to Otterpool Lane and moving across the site to its current location.
                  Most recently the site was used for roadstone preparation and supply,
                  presumably an attractive operation in the context of the construction of
                  the M20 and the CTRL works.

              (c) OS mapping for this site illustrates the history since about 1870 to the
                  present day. A succession of Ordnance Survey mapping was helpfully
                  included as part of the original application documents in Appendix B.
                  This documentation would seem to have been removed from the
                  current document set. No evidence has been provided about what any
                  preceding buildings looked like, what size they were or indeed where
                  they were. Reference to Ordnance Survey mapping suggests they
                  were small in size and clustered in the centre of the site. There is no
                  similarity between that and the proposed development. There is no
                  evidence of any large structures ever having existed on the site.




Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 23 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge

              (d) The applicants have provided no evidence of any significant structures
                  having ever existed at this location, yet repeatedly rely on bald
                  assertions that there were. This is arrant fabrication flying in the face of
                  plain fact. The owner of Upper Otterpool has lived adjacent to the site
                  for over twenty years and has explicitly confirmed at public meetings
                  that the scale and scope of any previous buildings on the site was really
                  quite small.


     2. The proposed development displays no sensitivity to its location and has no
        design or architectural merit.

              (a) The proposed main buildings are plain industrial sheds of great size and
                  height, compounded by the appearance, height and materials of the
                  exposed AD plant equipment. The proposed buildings have no design
                  or architectural merit.

              (b) The Design and Access Statement claims that the site is a 'brownfield,
                  industrial type location'. Although the definition as brownfield is
                  acknowledged, based on the original quarrying activity and the brief
                  period when the site was used for a small scale roadstone production
                  facility (a related deviation from the original usage), the designation
                  industrial is absolutely refuted. Apart from the issues of noise, traffic
                  and air pollution the physical size of that development had little impact
                  on the immediate environs. The site is clearly not an 'industrial type
                  location' suited to the scale of building and nature of operation that is
                  proposed by this application. It is located in open countryside. The
                  introduction of very large industrial sheds would be destructive, whilst
                  the smaller scale and quality design of the recently approved Airport
                  Cafe B1 development will be easily integrated into the environment and
                  village structure, to the benefit of the village and the area as a whole.
                  Otterpool Quarry is not an industrial location and never has been.




Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 24 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge

              (c) The sheer scale of the buildings will dominate the landscape. Local
                  facilities include important Kent tourist attractions such as Folkestone
                  Racecourse and Westenhanger Castle, which English Heritage have
                  supported with grant-aided investment of £4m; these will be severely
                  affected.

              (d) Westenhanger Castle is a Scheduled Ancient Monument with a Grade 1
                  listed house.




              (e) In addition to this there are two Grade 2 listed buildings within the
                  immediate locality of the site. These are Otterpool Manor to the west,
                  and Upper Otterpool to the south-east. The proposed development will
                  affect the setting of both of these, and in particular that of Otterpool
                  Manor which has direct outlook over the proposed development.




Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 25 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge

              (f) The applicant has provided photomontage views of the site from two
                  similar locations. Examined carefully these eminently illustrate the
                  visual impact and sheer enormity of the 93metre long and 12.5metre
                  high Materials Recycling shed.




Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 26 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge



     3. The development will disrupt protected species habitats on site and endanger
        downstream habitats.

              (a) The old quarry site is an important local habitat for badgers.

              (b) In their submission Countrystyle reported a relatively small sett
                  comprising seven entrance holes of which four were designated active.

              (c) Since then the Association has identified an much larger community
                  with twenty four (24) entrance holes of which seventeen (17) were
                  active.

              (d) The physical area occupied is considerably larger than that implied by
                  Countrystyle and would be significantly affected by the proposed
                  configuration of buildings and associated engineering works.

              (e) The design proposed takes insufficient account of the presence of
                  statutorily protected species.




Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 27 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge



  E - CORE OBJECTION 4.

          The application ignores the presence of habitation and businesses in close
          proximity and the impact of the proposed plant on those.

     1. The Office of the Deputy Prime Minister has issued a document “Planning for
        Waste Management Facilities : A Research Study” containing very clear
        guidelines.

              (a) The document was prepared by Enviros Consulting and published in
                  August 2004.

              (b) The document states that “where possible, (anaerobic digestion)
                  facilities should be located at least 250 metres from sensitive
                  properties.”

              (c) The definition of sensitive properties includes both domestic and
                  business premises. In total, twenty-one dwellings and businesses
                  would fall within the 250 metre zone.

              (d) A different study, also published in 2004, conducted by Kansas State
                  university concluded that:-

                      ●     There are several environmental advantages to anaerobic digestion.

                      ●     The process reduces greenhouse gas problems, decreases the
                            consumption of fuel, and transforms waste into fertilizer.

                      ●     The consumption of water is a problem in dry areas; however, water
                            from the process can be used for irrigation.

                      ●     From a public relations perspective, people generally accept
                            biodigesters.

                      ●     However, they should still be constructed far from residential areas
                            for reasons of biosecurity and to minimize odour problems.




Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 28 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge

     2. The Environment Agency has since published and consulted on a series of
        Standard Rules for the operation of waste handling installations, including
        Anaerobic Digestion Facilities and the use of the resultant biogas.

             (a) The consultation process finally concluded in August 2009 and the rules
                 became fully operative from April 2010.

             (b) The Standard rules have been developed on the basis that an activity
                 can be undertaken under the rules that have been put in place at a
                 particular location without causing pollution or nuisance. This means
                 that under the standard rules activities can only be carried out in areas
                 away from sensitive receptors such as habitats or groundwater. This is
                 because if they are near these sensitive places additional controls might
                 be needed that are not standard.

             (c) For each type of waste facility the rules list a set of prescriptive
                 requirements for any operational location that if met would allow the
                 issue of a licence under the Environmental Permitting Regulations 2010.
                 Standard Rules SR2010No15 deals with Anaerobic Digestion Facilities
                 and the use of the resultant biogas and for these sets out the following
                 parameters....
                   ●  “The permitted activities must not be carried out within
                   ●  500 metres of a European Site, Ramsar site or a Site of Special
                      Scientific Interest (SSSI) (excluding any SSSI designated solely for
                      geological features).
                   ●  The permitted activities must not be carried out within
                   ●  250 metres of any off-site building used by the public, including
                      dwelling houses or within a specified Air Quality Management Area
                      (AQMA)3.
                   ●  The activities must be outside groundwater Source Protection
                      Zone 1.
                   ●  All storage and treatment of waste solids, liquids and sludges shall
                      also not be within:
                   ●  10 metres of any watercourse,
                   ●  50 metres from any spring or well, or from any borehole not used
                      to supply water for domestic or food production purposes, and
                   ●  250 metres from any water abstraction point or borehole used to
                      supply water for domestic or food production purposes.


Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 29 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge



             (d) The rules do not allow any emission into surface waters or groundwater
                 except clean water from roofs and parts of the site not used for the
                 waste activity including storage of wastes.        However, under the
                 emissions of substances not controlled by emission limits rule, biogas
                 condensate, treated digestate and waste waters may be discharged to a
                 sewer subject to a consent issued by the local water company.”

             (e) Other relevant Standard Rules sets dealing with Materials Recycling
                 Facilities set out identical constraints on proximity and emissions into
                 surface waters or groundwater.


     3. The nearest property to the site, The Airport Café, is just 50 metres from the
        site entrance and only 100 metres from the Anaerobic Digester Plant building.
        The Airport Cafe is used intensively by the general public and has residential
        accommodation on the first floor.        In total, twenty-one dwellings and
        businesses would fall within the 250 metre zone.

     4. The Standard Rules set out clearly preferred standards and characteristics
        governing the location of waste plant installations. They focus on the primary
        risks to environment and local populations arising from waste management
        facilities.

             (a) The Otterpool Quarry site does not satisfy the parameters of the
                 Standard Rules, particularly in terms of proximity to sensitive receptors,
                 and the absence of sewerage infrastructure. Were the proposed
                 development to proceed the standard of protection required would be
                 considerably higher. The application documents give no information that
                 suggests the applicant has taken any measures at all to address these
                 issues.

             (b) If a site does not meet the stated parameters an operator must submit a
                 detailed Risk Assessment and apply for a site specific Bespoke Licence.
                 The detailed risk assessment collates data and information identifying
                 risk sources, records judgements of the level of risk, and sets out actions
                 taken to void or mitigate the risk. If the operators assessment is not
                 agreed by the Environment Agency a permit would not be issued.


Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 30 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge



             (c) The Resident's Association believes that all of these matters must be
                 fully explored and determined before any construction work commences.

             (d) The Association perceives a risk that buildings and plant could be
                 erected on the site, with all of the damage and disruptions that would
                 ensue, and the operator only then fail to properly satisfy the
                 requirements of the permitting regime. In these circumstances the site
                 would be scarred by immediately obsolete buildings.

             (e) The Residents Association asks that if the County Council should be
                 minded to grant permission for the application that any decision notice
                 includes a clear condition requiring that all matters pertaining to the
                 issue of an Environmental Permit be fully resolved before development
                 commences.

     5. The Airport Café has traded continuously for seventy five years. It serves over
        50,000 meals per year and its reputation is well known across the South-East
        region.

             (a) This business has invested heavily in improvements over recent years
                 and has planning permission for further development.

             (b) Planning permission has been granted to build an environmentally
                 sensitive development of workshops and craft units to the rear of the
                 Airport Café on the area currently used for car breaking.

             (c) The utilisation of the Airport Cafe site will benefit the social and economic
                 structure of this rural area, introducing small workshop businesses in a
                 modern development that is of a high design standard sensitive to the
                 character of the area.

             (d) Work has already commenced clearing the site of the former scrapyard
                 activities.

             (e) The success of this development will be very badly affected by the scale
                 and character of the proposed waste plant.



Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 31 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge

     6. The proposal is in conflict with Shepway District Council’s emerging plans to
        develop the locality for housing at Folkestone Racecourse, Lympne and
        Sellindge.

             (a) The emerging plans project approximately 1400 new homes in the
                 vicinity of the application site.




Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 32 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge


  F - CORE OBJECTION 5.

          The proposal offends the local community by considerable increasing traffic flows.

     1. Traffic flows through Newingreen, Sellindge and Lympne on the A20 are
        already subject to considerable congestion especially at the Newingreen
        Junction with the Hythe Road and at the traffic lights by the M20 bridge in
        Sellindge. Emerging plans for new houses in this area will bring substantial
        amounts of additional domestic and commercial traffic onto the A 20. The
        applicant's assessments make no provisions here.

     2. The A20 route to Junction 11 on the M20 is not suitable for carrying
        significantly increased volumes of HGV traffic. Although the recorded accident
        data shows only a small number of serious personal injury accidents, the same
        data shows a great number of minor incidents. These incidents will inevitably
        rise in direct proportion to the increase in HGV movements. This is a factor
        that should not, and must not be underestimated, all the more so considering
        the quixotic junction arrangement that exists at Newingreen.




Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 33 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge



     3. Vehicles emerging from the proposed site will be required to cross vehicles
        travelling at speed along the A20 carriageway. This would be compounded by
        being directly opposite the entrances and exits to the Airport Cafe sites.

     4. The Traffic and Transport Assessment assumes a regularly timed spread of
        vehicle movements to and from the site during the specified operating hours.
        Outside of these operating hours the site must be closed and secured.

             (a) Observation of driver behaviour at similar sites tells us that prior to site
                 opening times queuing of vehicles takes place, with each driver keen to
                 be first in line to enter, and first to leave so that driver working time is
                 maximised.

             (b) The Resident's Association estimates that only the first vehicle would be
                 able to pull up off-road, the remainder would stack along the
                 carriageway. It is hard to imagine a situation more likely to lead to
                 accidents during the peak flow hours for this section of road.

     5. The Traffic and Transport Assessment submitted as part of the application
        documents states at paragraph 4.2.5 that during the implementation of
        Operation Stack the M20 always remains open between junctions 10 and 11.
        Frequently this is not in fact the case and this factor in assessing traffic access
        is not reliable.




Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 34 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge



G - CORE OBJECTION 6.

          The applicant provides no site
          specific justification for locating the
          proposed        facility   onto     this
          unallocated site.

     1. Government planning guidance
        and County Policy give specific
        criteria to be satisfied in the event
        of an unallocated site being
        considered as a windfall proposal.

     2. The proposal does not comply with
        the locational guidance set out in
        policies W3, W9 and W10 of the
        Kent Waste local Plan that seeks
        to locate such uses in existing
        industrial areas. The location is
        not a of an industrial type.

     3. Reference to available data or
        commentary from any Internet
        search      of    Waste     Sorting
        Operations       and     Anaerobic
        Digestion plants, demonstrates
        concerns and anxieties regarding
        air pollution, dust, noise, odours,
        flies, rats and airborne diseases
        and aerosol emissions.

     4. There is no justification for siting
        industrial processing of this type
        and scale in a rural setting
        adjacent to village communities,
        thriving businesses, schools and
        tourist attractions.


Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 35 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge


  H - CORE OBJECTION 7.

          The proposal gives no detail of the operational processes or site management
          procedures that will be adopted on the development should it become
          operational.

     1. The Resident's Association is extremely concerned that the application
        documents provide no detailed technical explanation of the sequences of
        operations to be carried out in the proposed development, or any process
        engineering information that explains the precise nature of the technology to be
        employed, the management and movement of materials and vehicles on site,
        and arrangements that would be in place to handle system failures or
        accidents.

     2. Our concerns are that the processes involved hold inherent dangers for our
        environment. These can result from simple routine operational procedures
        which allow accidental spillages and contamination entering surface and
        groundwater systems. In the worst cases they would manifest from escapes of
        noxious gases, contaminant dusts, pathogens and microbiological emissions to
        the atmosphere.




Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 36 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge



     3. What we have been able to discern is that materials are imported onto site to
        be dealt with in one of two ways. Some material enters the anaerobic digestion
        stream and the remainder enters the dry waste recycling stream.

            (a) The recycling stream is generally simpler to infer in that it is presented as
                being dealt with entirely within a closed building environment. However
                even here there is a shortfall in information. Amongst what is not clear is
                where materials are stored after sorting, what arrangements are made for
                loading on to vehicles for transporting away from site, what happens to
                rejected material and so forth. The Resident's Association fears that the
                extent of hard surfaced areas around the buildings would become used
                as external storage areas as baled material or within roll-on roll-off
                containers. We note that were this to be the case all surface water
                drainage would have to be treated as foul water. As there is no available
                foul sewer this would increase the volume of foul water to be tankered
                away from the site, with a related increase in the storage capacity of
                underground tanks.




Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 37 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge



            (b) The handling of material in the anaerobic digestion stream is far from
                clear. The applicant has indicated that this would be unloaded from
                incoming vehicles within the AD plant building. It appears that this
                material would then be moved around on a flat surface using conventional
                mechanical shovels. There is no information provided that explains how
                the spread of this material would be controlled, or how the transfer of this
                to areas outside the building on vehicle wheels would be prevented.




Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 38 of 39
998 - May 2010            Detailed Report Objecting to Waste Development Proposals at Otterpool Quarry, Sellindge

     4. From inspection of the sparse amount of information provided of the individual
        buildings it appears that the proposed structures are no more than ordinary
        commercial sheds, with large opening doors to allow vehicle entry and exit.

            (a) This unsophisticated form of building proposed has no special
                characteristics consistent with maintaining a specialised negatively
                pressurised internal environment that would be required and that the
                applicant seems to infer. No detailed information is given concerning
                ventilation or extraction systems proposed. This is core to the safety of
                the operation and any prospect of controlling or curtailing release to
                atmosphere of extremely noxious and poisonous emissions.

          We consider Waste Treatment, including Anaerobic Digestion, to be important
          contributors to a properly established comprehensive Waste Management
          Strategy. To site such processes unnecessarily close to human habitation and
          places of work, using unsuitable roads and endangering source waters and
          fresh air close to villages, disfiguring rural settings, can only alienate local
          populations.




Sellindge & District Resident's Association   998 OQ DETAIL REPORT 100531                                           page 39 of 39

				
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Description: Sellindge Residents Association Detailed Response