Response from Walsham le Willows Parish Council
Re: WASTE CORE STRATEGY ISSUES AND OPTIONS (PART2) – STRATEGIC SITES
Summary
In
response to the Suffolk County Council Waste Core Strategy (Final Consultation)
July 2009 (WCS 07/09)
Walsham
le Willows Parish Council (WLW-PC) hereby lodges its VERY STRONG OBJECTION to
site 26 Shepherds Grove Industrial Estate being chosen as a potential Strategic
Site within the Suffolk County Council Waste Core Strategy (WCS).
The
WLW-PC rejects the suitability specifically of Site 26.
The
WLW-PC has a major concern in that it is being asked to make comment upon a
strategy document which gives little indication as to the potential final
development in terms of:
What
is it MBT OR EFW?
Size
100,000 tonnes - 350,000 tonnes?
With
this stated we have kept our objections to the specific site and its
characteristics as seen by the local Parish Councillors and the representations
of our Parishioners.
The
Parish Council specifically asks that both Suffolk County Council (SCC) Officers
and our Elected Councillors have full sight of this document.
The WLW-PC specifically rejects the suitability of Site 26
on the following grounds
1.
The negative
impact of additional traffic
1.1 Unsuitable
major road access
1.2 Unsuitable
minor road access via Local Villages
2. The Site and its Strategic position.
2.1 The
Site
2.2 Distances
from major centres
2.3 The site
and surrounding topography
2.4
Current site uses and problems
3.
The negative
impact on the environment
3.1 Visual
Impact
3.2 Light and
Noise pollution
3.3 Aquifer
4
Sustainable
development
4.1
Employment
4.2 Sources and types of waste material
4.3 Waste Reduction
4.4 Impact on our way of life
5
Health
concerns
Development of each of these
points is included in the subsequent submission
1. The negative
impact of additional traffic
1.1 Unsuitable major road access
WCS 07/09 6.2.28
states in conclusion that “the site is well related to the Strategic Lorry
Network” (SLN). Inclusion or exclusion of a road from the SLN is an absolute
statement. WLW-PC disputes the suitability of the A143 as part of the SLN and
its ability to cope with further substantive lorry movements. The A143 is a
single carriageway road and only part of the SLN as no other suitable East West
link road exists. The status of the A143 within the SLN should not be classed
as on a par with the A14, the two road capacities are totally different. A site
near a dual carriageway SLN is more suited to this type of development than one
adjacent to a single carriageway road; the WLW-PC do not agree with the
statement in 6.2.28.
The A143 runs through several villages from the A14 North
East to the site and from the A140 West to the site. These villages are already
highly congested and the subject of requests for a bypass, e.g. Great Barton.
As far as we know there are currently no road improvements planned for the A143
between Bury St Edmunds and Scole.
The A143 already has a high level of accidents and a poor
safety record at the current traffic levels. Additionally, there are no
suitable relief roads when congestion occurs due to road closure. The diversion
of traffic through small rural communities along C class roads or single track
ways causes damage to verges and hedges and endangers local road users and
pedestrians thus impacting adversely on rural amenity.
The current traffic position on the A143 is already
exacerbated by the seasonal impact of the Sugar beet Campaign and the
congestion problems at the St.Saviours Interchange on the A14 in Bury St.
Edmunds (British Sugar plc Plant roundabout).
To speculate on the numbers of additional lorries is
difficult, however within the WCS
07/09 5.18 300,000 to 350,000 tonnes is stated as a likely requirement for
Commercial and Industrial Waste. The lorry movements for this volume would be
totally inappropriate for the A143 and the local road network. The figure of
300-350kt has been used as it has been stated by SCC Officers that the Gt.
Blakenham site will handle the residential waste of 250,000 tonnes.
In the original Pick Everard Site Appraisal, site 26 was
ranked 7th and 8th for single and multi site disposal options,
in other words better options are available in terms of minimizing average km
travelled per tonne.
WCS 07/09 6.2.2
refers to the planning permission previously granted for the IKEA Distribution
Warehouse development. This should not be seen as a precedent in reference to
potential traffic impact. The WLW-PC makes the following observations to
support this view.
1. The
IKEA proposal occupied a significantly larger proportion of the area (32.78
hectares) when compared to the WCS proposal which is for only 5ha.
2. A
planning application was submitted in 2002 and planning consent for the IKEA development
was agreed in 2006. Over recent years we have seen significant increases in
traffic movements along the A143.
3. If
further development then occurs on the large area of land still available on
the rest of the site it would have an increasingly detrimental impact upon the
A143.
4. The
recent expansion of operations in particular on the
WLW-PC believes that the provision of a roundabout on the
A143 to link the industrial site to the main road is an insufficient response
to adequately upgrade this single carriageway road.
As only a small proportion of the total site (5ha) area
available at Site 26 would be required for either an
1.2 Unsuitable minor
road access and the impact upon Local Villages
However hard Suffolk County Council tries, WLW-PC does not
believe it will be able to prevent traffic accessing the site from the Elmswell
/ Badwell Ash direction using the C Class road over Golding’s Bridge on The Causeway
and then Summer Road. Golding’s Bridge was recently made into a single track
road and dates back several centuries. It has already been the subject of
monitoring for structural integrity and several cracks are evident underneath
the arch. These roads are simply not suitable for more HGV traffic. Witness the
verges around Walsham and Badwell Ash which are constantly churned up after two
lorries have met and cannot pass as the road is too narrow, and the increase in
black rubber skid marks at road junctions.
Use of Satellite Navigation systems will pinpoint the
shortest distance between two points rather than an SCC recommended route. This
could lead to bulk transfer vehicles, HGVs and refuse collection vehicles travelling
through the many rural settlements along routes more than the stated three
miles from roads included in the Suffolk Lorry Route Network (SLRN). The ‘rat
run’ from the A14 to the proposed site via Elmswell, Great Ashfield and Badwell
Ash, which cuts 13 miles travel each way off the A14/A143 recommended route,
would save both time and fuel for contractors and will continue to be used just
as it is now. These longstanding concerns have been the subject of two
officially supported traffic censuses in Walsham le Willows.
The community’s recent experience with the increased traffic
from the
Currently we are experiencing the
additional ongoing difficulty of the inappropriate overnight parking of HGVs in
the heart of the village and on the approach roads to the
2. The Site and its Strategic position
2.1 The Site
WCS 07/09 6.2.1 gives
an inaccurate description of the site, its previous and current use. The Site
Appraisal undertaken by consultants Pick Everard - Waste Facility Site
Appraisal 2008 assessed an area which does not include the old Mushroom farm
buildings. The site they appraised is north of the site described. The total
site area assessed in their report refers to 26 hectares and not the 66.32
hectares referred to in the consultation documents. The WCS 07/09 gives a false impression that the 26 hectare area
considered is already built upon - it is
not.
WCS 07/09 6.2.2 refers to the proposed IKEA development -
this again was on a different area to the original 26ha assessed by Pick Everard.
This leads us to conclude that the initial appraisal process is
fundamentally flawed in relation to the definition of this new site.
This explains the query which WLW-PC raised in its response
to Waste Core Strategy Issues & Options (Part 11) Strategic Sites (December
2008); in WCS 07/09 6.2.24 “The
designated development site is a huge area and the parish council feels that
any development should be restricted in its location to the Brown Field area to
the north of the site”.
The Mushroom farm is outside the area described and is
currently in part occupied by
The Final Consultation document does not make mention of the
ANTI-WASTE planning application (SE/01/2220/P) which was withdrawn following
it’s submission in June 2001 due to concerns over bio-aerosols affecting
residents and workers. This application proposed the construction of a
composting plant to handle 154,000 tonnes per year of green and sorted domestic
waste.
WCS 07/09 6.2.3
the site selection criteria ranked Site 26 as 7th of those available. This
ranking did not take into account the Aquifer locations. See separate note
under 3.4 Aquifer. Again the Pick Everard site appraisal is fundamentally
flawed in relation to this aspect.
Pick Everards site appraisal is further flawed in that it
states on the sixth page under Compatibility with Neighbouring Land Use; “No site designation, local plan or proposal
plan available for the site”. This statement is incorrect as the site falls
within a Local Rural Employment Area.
Site 26 is located within a designated low fly zone for
local military aircraft and the Statutory Bird Strike Zone surrounding RAF
Honington.
None of the other
sites have this combination of disadvantage.
2.2
Distances
from major centres
The choice of the site must be challenged on the grounds of
its distance from major urban centres. In fact Site 26 is 26 miles from
WCS 07/09 6.2.23 states “this site is well located to serve
the North and West areas of the county including Bury St Edmunds and
2.3
The site and
its surrounding topography
The site is a plateau approximately 60 metres above sea
level and is higher than the surrounding land to which it is adjacent.
2.4 Current adjacent site
uses and problems
The communities adjacent to the site have very real recent
experience of the mismanagement of waste facilities already in the area. These
are not being managed in accordance with the agreed licenses in place and when
this is pointed out to the Environment Agency, and the other relevant
authorities, they are powerless to do anything about it. This leads us to
question the ability of these self same agencies to effectively police and
enforce any further waste treatment licenses granted. These problems currently centre
on: traffic, parking, smells, fly infestations, vermin, noise and watercourse
contamination.
3. The negative impact on the environment
3.1
Visual
Impact
Site 26 has a rating of Severe for Visual Impact -
Comparative visual impact 9, as stated in Waste Core Strategy Issues and
Options (part 11). The site is elevated and surrounded by low lying ground with
no significant screening in any direction. The impact of a large industrial
facility would have a significant detrimental visual impact. ‘Around the site
are areas designated as Special Landscape Areas, County Wildlife Sites and Sites
of Special Scientific Interest.’ See Waste Core Strategy (Part II) Strategic
Sites.
Site 26 has the highest visual impact rating coupled with a
major underlying aquifer which, when combined together, significantly reduces
the design potential to “sink” any required buildings.
A structure of this potential size would be seen for miles
around. Significantly, reference points used by SCC are for heights of 90 and
45 metres. A site within an industrial area or obscured by natural or man-made
features would be less intrusive than in Stanton’s open aspect which is a
plateau site at approximately 60 metres, ideal for an airfield requiring
all-round visibility, but not for this proposal. “It would be difficult to
minimise adverse impacts on landscape quality” (SWLP 2.2.d13) … and all this
adjacent to our village which is known as a Conservation Village with a large number
of listed buildings of architectural and historical interest, the subject of a
year-long study by Architectural Historian, Leigh Alston, and, additionally,
the subject of a Tourist Trail book about the village.
Depending upon the precise nature of the development we
could be faced with an elevated 90 metre structure, festooned with red warning
lights at night, and visible from many miles around.
The siting of a facility of this nature should be in low
flood / low water table areas preferably Zone 1. Site 26 has an exceptionally
high water table classified as within Groundwater Source Protection Zone 3. The
constraints that the water table level would place on design options should be
considered. It would be more difficult and costly to partially dig in the
facility below ground level to reduce its visual impact and with the increased
risk of contaminating the water table. The Waste Core Strategy (Part II)
Strategic Sites itself recognizes that there could be potential for
contamination, (see Chapter 3/ Site 26 / Overview 1.6), as the site is close to
nearby groundwater abstractions and also located within a Nitrate Vulnerable
Zone.
3.2
Light and
Noise pollution
As the site sits upon a raised plateau, the impact of a
large facility of this nature will have detrimental Light and Noise pollution.
Outside lighting, to enable operation 24/7, would be visible within a
significant area, affecting a number of surrounding villages. Additionally, red
warning lights attached to the high structure would be visible for many miles
in any direction, just as the Mendlesham Mast is already highly visible. Noise
of vehicles involved in the delivery of waste and extraction of residual waste
would be significant during the day. Additionally, there would be the potential
for traffic movements, noise and vibration affecting nearby residential
properties as HGVs arrive ‘out of hours’ ready to offload early in the day.
These types of disturbance would be significant for the surrounding area and
are already happening at the
3.3
Aquifer
Site 26 overlies a major aquifer as identified in the Pick
Everard Appraisal although this was not considered within the Comparative
Criteria by Suffolk County Council. The site features, those of overlying a
major aquifer, being close to nearby groundwater abstractions and within
Groundwater Source Protection Zone 3:
4. Sustainable
development
4.1 Employment
In the WCS 07/09, page 41, it is stated that ‘the results
of the SA (Sustainability Appraisal) showed that this site scored very
positively against SA objective(s) 12 (To maximize opportunities for
new/additional employment) in the short term’. In Appendix 5, page 134, it states
that construction will create short term jobs. We question whether there will
be much job creation as major building contractors, who are likely to gain a
contract, are more likely to ship in their own existing workforce to work on
the plant. We also question how
this prospect relates to the St Edmundsbury District Plan that designates the
Shepherds Grove Industrial Estate as a ‘Rural Employment Zone? The WCS
07/09 does not recognise this
issue.
SCC makes much
of the fact that permission had already been given for a large facility on this
site, the IKEA Distribution Centre. However, this proposal was expected to
create around 300 new jobs which is far in excess of WCS projections for this
development.
This is
contrary to Policy E1 of the current St Edmundsbury Local Plan (SE1 - Existing
Employment Land and Premises).
The site is
designated as light industrial use. A waste facility, in whatever form it
takes, will not fall into this category.
Recent
evidence in relation to the problems on the
4.2 Sources and types of waste material
SCC will
potentially be allowing commercial waste operators to determine the type of,
and scale of, waste treatment technology for any given site. If the Industry
decide that we need an incinerator then we know that the plant will have to be
run at a certain level of ‘throughput’ to maintain efficiency and if the
throughput drops because the people of Suffolk reduce their waste output then
waste will have to be sourced from further afield. We have already seen
In order to
maintain the efficient running of the plant and the return on their investment the
operators may even resort to burning waste material which should sit further up
the waste hierarchy. This will be a commercial decision not one based on
environmental grounds.
In WCS
Chapter 8, 8.51, the statement is made that ‘there may be a need to collect, transfer, store, process and treat
hazardous waste in the County before being sent for final disposal or treatment’.
Policy WCS18 makes it clear that facilities for this transfer and storage
would be acceptable on existing waste management sites where hazardous waste
would only represent a small proportion of waste managed on site. Once again,
we are brought back to the fact that SCC is seeking approval for a scheme in
principle only, an umbrella application with no detail as to what may follow
from private contractors at a later date.
4.3 Waste Reduction
We believe
that SCC should be making plans to increase levels of recycling above 65%
before 2015 and that far greater effort should be put into increasing the current
recycling levels.
4.4 Impact on our way of life
St Edmundsbury’s Core Strategy Submission Document for the
LDF states, under Strategy for the Rural Areas 7.2 ‘
In 7.6 it states ‘Through the various stages of developing the
Core Strategy it is clear that residents value the history, visual quality and
unique character of the towns, villages and countryside in the Borough.
Retaining the local character and distinctiveness of the built environment will
be an important prerequisite of new development proposals.’ The Parish Council is well aware
that we are part of Mid Suffolk but are in a location closer to the proposed
site than many members of St Edmundsbury. We have the same rights and share the
same views as stated in the above document – we too enjoy the peace and beauty
of our countryside; we too value the history, visual quality and the unique
character of Walsham le Willows. We can foresee the local character of our area
being changed by traffic movements of large numbers of large vehicles and the
attendant wear and tear on parts of our village infrastructure; noise and light
pollution which will be exceedingly noticeable in a relatively quiet and dark area;
the potential for a decrease in air quality with the attendant possibility of
hazards to health; the visual impact of a development far removed from the
local character of our environment and the devaluation of land and properties
by close proximity to this proposed development.
Policy WCS21 declares that Waste Management Facilities will
be considered favourably where they incorporate safe and convenient access for
all potential users, and measures which will protect, preserve and where
practicable enhance the natural and built environment. We challenge the use of
this site when compared to these criteria.
5. Health concerns
As a Parish council we find it close to impossible to make
an informed comment on the Health risks associated with a waste site
development not least because we don’t know to what use the site may be put, Energy
From Waste or MBT, however it remains a major concern of our parishioners as
evidenced by their statements at our Open Meeting Consultation held on 16th
September 2009.
This concern is not alleviated by the comments in the WCS 07/09
WCS 07/09 6.2.7
“modeling carried out by the
consultants suggests that air quality could be
maintained above guidelines” and secondly;
WCS 07/09 6.2.11
“An additional requirement will be to carry out a Health Impact Assessment in
support of a planning application for a strategic Residual Waste Treatment
Facility at this site”.
These two comments give no confidence to local residents in
Suffolk County Council’s knowledge of either the subject area or long term
safety issues. The British
Society of Ecological Medicine (BSEM) has directly challenged the only report
to be produced in support of the incinerator solution but without any notable
response from the Health Protection Agency and the BSEM conclude that no more
incinerators should be built.
What we
have learnt about the ‘incinerator option’ is that it must be run at 90%
efficiency otherwise the likelihood of toxic emissions is greatly increased.
These include dioxins, PCB particles; ammonia, acid and fine dust which
represent very serious health risks.
Air quality would be monitored by the EA but monitoring does
not mean absolute 100% prevention of air pollution. This is demonstrated by
Allington Quarry Waste Management Facility Community Liaison Committee notes of
We have yet to learn what the long term health impact of
this development could be on local residents.
Conclusion
To summarise, in our view, whilst supporting the County’s
over-all strategy, we cannot see how the
The Environmental Protection section of the SWLP itself
states “Waste development will not be acceptable where impacts cannot be
satisfactorily controlled.” We seriously question whether SCC will be able to
control all these impacts once a developer has been found. By which time, when
further plans are unveiled, it will be too late to opt out, merely to challenge
minutiae rather than the ‘bigger picture’.