ttp://www.hardwickepc.co.uk/default.asp?pid=46
From County Councillor A.J.Blackburn
Gloucestershire CC Planning application 12/0008/STMAJW
Waste facility Javelin Park,Hardwicke
I refer to the above applicationwhich is to build a huge 48 m high incinerator at Javelin Park on the B4008 in my (North Stroud ) division and on behalf of a large number of local electorsin the Wards of Hardwicke Haresfield Standish andEastington whom I represent and on my own behalf wish to formally object and ask that planning permisson is refused. My reasons are set out i
Should the planning committee decide to grant planning consent then I request that theCommittee should impose planning conditions /obligations to protect and compensate the local communities in the area where the project is permitted as set out in the latter part of this objection
Except where indicated otherwise references are either to Balfour Beatty Gloucestershire Residual Waste Project Environmental Statement Vol 4 NonTechnical Summaryor the application document lodged with the GCC planning Dept where the paragraphing is 7.5.30 or similar .
1..Objections as to the need for the Scheme
(1)Objection as to the plant being at Javelin Park
The Gloucestershire County Council Core Waste strategy put forward only 4 sites for a County wide waste facility,two at Wingmoor Farm , one at Morton Valence (600 m away from Javelin Park) and Javelin Park. Because of objection in the consultation the Strategy was referred to an Inspector.He has not yet issued his report so this “strategy”allegedly grounding the need for the plant at Javelin Park is not yet formally approved . nor was it at the time the contract was signed with the applicant in December 2011. The application is therefore invalid. How can it be granted when the Core strategy is not officially approved?
As to the substance of the “ core strategy”, this proposes a single giant residual waste disposal plant for the whole County. My own and others’ submissions to the consultation( which I put forward as an objection to the current application) is that there should be 5 or 7 smaller plants at the source of the waste e.g Gloucester and where the heavy lorry journey to a central plant would itself be wasteful, polluting and carbon generating .e.g. 25/30 miles as South Forest of Dean ,Cirencester
I also query the figures as to the County’s residual waste disposal requirement. In submissions to theWaste Core strategy enquiry the estimate was 90,000/100,000 tonsand has been taken by the County for the contract to be 150,000 tons The facility is projected to take 190,000 tons. If it is run for this capacity it may discourage recycling and will have to seek waste from elsewhere thus negating the raison d’etre of the project indicating that smaller and more localised facilities would be preferable and more flexible( “flexibility” being a stated key object of the Core strategy)
(2)Objection as to the plant being an incinerator (“energy from waste”)
I object to this process being used under the application as opposed to mechanical biological or anaerobic digestion
(a) I adopt the objections of GlosVAin and others that the process generates pollution and deleterious emissions which have not been proved to be harmless to health to humans and animals in the vicinity There must be a specific Health Protection Agency check on the process used and the environment of this plant which confirms that the plant will be safe and will not adversely affect such health. The onus of proof should be on the applicant and only if discharged should consent be granted.
The new National Planning Policy Framework (March 2012)states in Para 38 that “The local planning authority should work withthe public health boards and health organisations to understand and account for health states and needsof the local population including expected future changes in improving heath and well being”..The threat of emissions pollution and noise from the plant to a local population which is set to expand by 3000 plus households (including young families)-see below- should be the subject of specific investigation and approval by local health bodies.
(b) The applicants suggest that the plant should be considered safe unless there are particular circumstances making it not so. I suggest that the lie of the land around the site with the Cotswold Edge 300 m high and only 3km away and the prevailing wind and topography of the Severn Vale here may cause the so called “safe” emissions from the plant’s chimney at 70 metres( not enough to clear Haresfield Beacon) to combine with emissions from the More ton Valence plant and the frequent hill top fog in failing to disperse and creating a potentially toxic mix to affect communities in the natural hollows to the East such as Harescombe and on the escarpment such as Edge.This micro –climate is entirely different from the climate in other more open Incinerator sites such as by the sea eg Cornwall,Hants,or more open plain e.g Cheshire,and the emissions are less likely to blow away in the wind
(c)The contract for the plant is for 25 years .There may be a safer process or more efficient checks developed during that period. If consent is granted it should be conditional on up to date processes/procedures being installed.
(d) The monitoring instruments all seem to be in the plant itself. What if theplant or such equipment explodes /collapses/fails ? Again consent if granted must be subject to a condition that monitors are placed and checked frequently at points outside the plant e.g on Haresfield Beacon. Placing monitors here could also verify my “ Fog hollow”point above Professor Harrison at his meeting with me in November 2011 confirmed that there was no reason why this should not happen.
(e) The applicants’ say that one of the benefits of the scheme is that it may be able to provide not only electricity but also heating by overland transfer to local residential or commercial premises in the vicinity but that it is not possible at this stage to ascertain how or where. Reference is made to a Balfour Beatty/Urbaser project in Peterborough where a planning condition as to endeavouring to prospect and connect up such an arrangement was agreed. If the Committee regard this aspect of the scheme as important and it appears one of its few bonuses then it should insist on a similar condition here.
2. Objections as to the shape and size of the building
The Core Waste Strategy in course of Inspector approval includes detailed provisions as to the Javelin Park site derived from requirements of Stroud DC .These include :
Core Waste Strategy Document: Appendix 5 Strategic Site Schedules Site No 3 Policy core policy S4 Javelin Park
“Landscape visual Impact”..
“ A waste facility could cause permanent alterationof the site in terms of scale,height and intensity of development resulting in a facility both taller and larger than thexisting surrounding units.This would lead to further encroachment of urban fringe lightindustrial /distribution style development in the surrounding agricultural landscape. However the extant outline permission for the currently undeveloped area permits a roof line of15.7 metres for the two units” and
“ The erection of an emissions stack(40-80m in height) would create a significant vertical landmark out of keeping the surrounding landscape character”
These planning restrictions inserted for good reason are effectively the “planning brief” for the site,and would be breached by the proposed building which is 48 metres high and has a 70m chimney thus being out of keeping with the rural character of the area .
The new Government Guidelines National Planning Policy Framework March 2012 says that planning committees are to “recognise the intrinsic value of the countryside(whether specifically designated or not)” (para s164-7) and the excessive size and prominent position of the proposed building disturbs the essential rural and pastoral character of this part of the Severn Vale.e
I maintain that the committee would be going against this general policy as well as the specific height and landscape polices by granting consent to this building.
If they reject the application the site could be used for a more modest smaller and more waste specific facility with a lower chimney respecting these important constraints.
Gloucestershire CC Planning application12/0008/STMAJW
Waste Facility Javelin Park
Objections (continued)
The Environmental Statement vol 4 Para 2.2.12 says that the final design option was selected (inter alia) because of“. reduced volume and height of the buildings”..and ..”low level buildings presented to views from the east and B4008” and .”.reducing visual impact of the building from elevated viewpoints e .g Haresfield Beacon and Cotswold AONB” .I dispute that this is so. Reduced from what ? The building is 48 metres high and the chimney 70m so it seems a monster from whatever angle it is viewed. Although there are photo montages of long distance views in the planning documents, it would appear that the developers only took 3 specimen viewpoints locally in Haresfield – surelyinadequate for a huge building which will dominate the Severn Vale from North Nibley to May Hill?
The architect’s “Design and Access Study-Jan 2012”states that...”There are no contextual references in proximity for a development of this scale in the countryside”... and ...”where appropriate the facility displays its inner functions and is uncompromising in scale.In other aspects the concept responds to the community and landscape” He is right about the excessive scale,but talking nonsense about the context and responding to the community. This site is in a continuation of the Cotswold AONB the boundary of which is only 1200 m away and is of rural farm and wood land set among listed buildings e.g Haresfield Church and Vicarage) in an attractive brick and thatch village vernacular.. The “context”is for a brick(or substitute) unobtrusive low profile building (like the wood cladded Complete Circle proposal)conforming to the stated planning brief in height and with a lower chimney
The design is ugly and does not fit in to the local community.It will be an overbearing presence in all local views like a giant toad squatting in the rich landscape of the Vale for ever
The NPPF para 120 allows planning authorities to refuse permission for a development of poor design that fails to takethe opportunity available for improving the characterof an area and the way it functions”...This is surely such a case.
The NPPF para34 also says that” the design should take into account the views of the community.” Having attended parish meetings at Haresfield and Hardwicke it seems to me that the community almost unamimously finds this design excessive and unpleasant
3 Objection as to increased traffic
The site does indeed adjoin Junction 12 of the M5 and the A38 and is on the B4008. These are all busy roads t aking traffic from a much larger area than the study area for the scheme- what Vol 4 calls “the key (traffic)assessment area “”confined “t o that around J12 The traffic problems of the wider area also deserve consideration of traffic accidents for a longer period than 5 years as contemplated by Vol4 and the planning documents . The B4008 is one of the most dangerous roads in Gloucestershire. Para 7.5.30 says that only a small section of it will be used but of course this section can have a “knock on “ affect on further down the B4008 and there may be heavy lorries waiting here –see para7.5.32 as to driver delay Even if heavy lorries are proscribed from theB4008 south of Javelin Park ,congestion at J12 and a general increase in traffic likely to occur will mean heavier use of this narrow key road with dangerous corners and other features. Even with a “travel plan” and assuming that there will be prescribed routes for the heavy lorries serving the plant with their average 104 trips a day I do not agree that the increase in traffic in the area of the plant is “likely to be limited” (para 7.5)
There are new housing developments not yet occupiedin the South of Gloucester and Hardwicke/Haresfield ( Kingsway 2500 houses ,Hunt’s Grove 1750 ,Sellar’s Farm200) all of which will generate car traffic to this junction in addition to lorry traffic from Downton and Attwool’s depots within 10 km and the commercial traffic which as the Summary says is already scheduled for the rest of Javelin Park which has a planning use of “Distribution centre”. For motorway use here and use of roads elsewhere in Gloucestershire note what I have said about waste lorries having to come from 25/30 miles distance to Javelin Park and back from outlying parts of the County such as South of the Forest of Deanand Cirencester which would not be necessary if consent is refused and a more sensible residual waste policy is adopted.
I submit that there will be a greatly increased traffic flow on all of the M5.A38 and B4008. It is stated that computer projections say not,but I would point out that the J12”recent improvements”mentioned in para 7.5.31 (costing £1.2m) had to happen because of a failure of SATURN computer modelling to predict the 2007/8 increase in traffic. If it failed then, why should we trust it now?
The statements that local distributor roads are predicted to operate free flowing etc ,that no local safety or capacity improvements are necessary, and that there will not be a material impact on the local highway network ( paras 4.2.5-4.3) are unfounded and have no basis except unreliable predictions.
Local knowledge leads me to believe that the Javelin Park plant WILL lead to increased traffic ,meaning more accidents,carbon emissions ,congestion etc I ask that consent is refused on this ground.
5 Objection Lack of Community Involvement
I also oppose the application because despite mention of consultation of the local community,neither the GCC nor the developers have properly engaged with the local communityThey should find out how local residents and farmers would be affected by the plant and what can be done to assuage their needs and fears about the project.
The idea that the two “pre planning” public exhibitions by the two competing bidders in July and November 2011 or that putting a”visitor centre” in the Incinerator building and inviting school parties is sufficient to ensure” public benefit” from the project is ludicrous.
Residents of the area and elsewhere have taken the opportunity to go to the exhibitions and ask questions but there was and is no obligation by the successful bidder( the applicant) to do anything about their concerns and what the local community e.g Haresfield residents want is not a token public access point in the building but for the persons in charge of the plant to COME OUT OF THE BUILDING( metaphorically and physically) and engage with them in what they-the Haresfield residents- want which may be such things as free medical checks,a new village hall ,grants towards sports activities, . and help over difficulties in getting mortgages or insurance . .That is “engagement”. The committee should realise that this has not happened and should refuse consent until it does. Alternatively please see my suggestions for conditions as to a local trust if consent is to be granted below
In conclusion of my objections,I refer to the last words o f Vol 4 para 4.15 that the assessments in the applicant’s evidence”have shown that the proposal would not result in a significant impact on local landscape character or unacceptable impacts on the Cotswolds AONB. No significant residual adverse environmental impacts have been identified”.
These statements seem to me to be most arrogant and presumptious assertions .As the submissions by the applicant and by the many objectors indicate , the proposal is founded on a false premise ( the unapproved and flawed Core Waste Strategy), unproven assumption as to health and safety ,lack of consideration for the environment and characterof the landscape, danger of potentially unsafe emissions, increased traffic and lack of regard for the local community.
Indeed on all counts there would be an ADVERSE impact on the landscape,the Cotswold AONB and on the local community The application should therefore be refused
Conditions/Obligations to protect /compensate the local community upon which t the Committee should insist if it is minded to grant consent
It is important to note that the 5.1 ha Site of the proposed development and access is OWNED by the Gloucestershire County Council This is relevant because the Planning authority can impose planning conditions and obligations on the landowner of a development site as well as on the developer. In this connection it should also be noted that GCC have expressly or impliedly hade a number of promises to the local Community about the project. Cllr Stan Waddington promised that the local community would be consulted.As mentioned above they have not been My questions in full Council on 7 09 2011 to Cllr Ray Theodolou ( Stan Waddington’s successor in charge of the Waste project) asking what reassurance I could give the residents farmers and businesses in Haresfield Standish and Hardwicke as to mitigating the impact of the facility and minimising traffic impact noise and light pollution met with the reply:
..”the issues you have raised are important ones and it is for this reason precisely that they are a fundamental part of the planning and permitting processes...” and
“ it is important to note that planning conditions have to be adhered to and therefore gives local people considerable additional enforceable protection”
So apparently it is left to YOU. the PlanningCommittee, to deal with the issues which I ask should be dealt with on behalf of the local community. You are the Community’s LAST AND ONLYCHANCE of being able to derive public benefit from The County’s “landmark” scheme ( in all senses!).
In particular The Lodge, home of Mr Rob Gaffney and his family 50 metres away from the entrance to the site is blighted by the GCC’s scheme and we owe it to him to pay him compensation Unless provision is made NOW in one of the planning documents he will be left without redress which would be disgraceful.
The committee should if minded to grant permission impose conditions or require a supplemental agreement with obligations on the develope rand on the County Council as landowner securing the position as to two aspects of the development first standard planning conditions as to construction and traffic- including those in 1 2 3 4 and 5 below and also and this is more urgent and important provision to protect and compensate persons adversely affected by the project as set out in 6 and 7 below
1.Confirmation from the Health Protection Agency as to plant being safe and free of pollution or deleterious affect on health of humans or animals
2. A condition that the operator of the plant will install the latest processing and safetyequipment that becomes available at any time during the period of the contract for operation of the plant
3. A condition that Monitoring devices are placed at suitable receptor points at suitable distances to be agreed with the GCC in each case outside the plant and that these are checked to ensure the that health Protection Agency standards as to non pollution or toxic emissions are complied with
4. A condition that all heavy lorry access to and from the plant shall be along prescribed routes as shown on maps to be agreed with the GCC only and by no other route and that a provision to this effect is included in all contracts with transport contractors and will be enforced
5 A condition such as at Peterborough that the developer shall endeavour to procure and will connect a heating from waste supply from the Plant to housing/commercial premises in the vicinity and enter into contract for supply on reasonable terms
6 That the developer/the GCC shall acquire the property known as “The Lodge” jJavelin Park from its owner Mr Rob Gaffney at market price and pay all legal costs and compensation in respect of his removal expenses and damages for inconvenience in respect of the construction of the facility
7... That the developer and the GCC shall set up a trust for the benefit of the residents or business owners in the parishes of Haresfield Hardwicke and Standish adversely affected by the Javelin Park Waste facility or traffic or activities arising from the same the trustees to include a representative of each of the developer,the County Council each Parish Council the objects of such trust also to include and any balance for the time being not applied as aforesaid to be applied to any charitable or public purpose for the benefit of the inhabitants of those parishes and to pay the cost of setting the same up and the initial contribution of ( £50,000) to the trustees
The NPPF allows such planning terms to be imposed provided they are they are fair and reasonably related to the kind of development and are(para 34) relevant to the planning application and the development,enforceable,precise and reasonable in all other respects,and I submit that all the above are within this description.
Of all the above comments I regard tothe GCC’s commitment to the local community as paramount and ask,if consent is to be granted, that the arrangements in Conditions 6 and7 are given priority.
END 1 04 2012
