Parish News
06/10/2008 - Your Parish Council response to the additional information submitted by Veolia regards Rock Common Quarry Landfill
Mr M. Elkington
Head of Planning Services
Environment & Development
The Grange
Tower Street
Chichester
West Sussex
PO19 1RH
5th October 2008
Dear Mr Elkington
Rock Common Quarry, The Hollow, Washington – Landfill Application Regulation 19 response Documents
The Parish Council has considered the additional response and we continue to maintain our STRONG OBJECTION. We have the following comments to make:
We are deeply concerned that Veolia Environmental Services (VES) has stated, within their preamble on Page 2 that they only respond to additional comments raised where it is considered that further clarification is required. If there were to be true consultation on this application, then surely they should respond to all public concerns.
We are further deeply concerned, that this document contains a complete re-routing strategy that places all of the traffic connected with this proposed development on one of the most dangerous roads in West Sussex, the A283 Steyning Road. This road was the subject of a comprehensive Road Safety scheme, which has reduced accidents by 25% in the last 3 years. The effect of 500 + HGV’s turning on to or off that road, at a point that was highlighted as dangerous within this safety scheme, is unimaginable.
We below, consider the response document. The statements within the Regulation 19 response by VES are in italics. Our own comments are in normal font. (Where VES comments are contained within the Regulation 19 response document, and not within an additional report, the relevant page number prefixes their italicised comments).
WSCC Minerals and Waste Development Plan.
P16: Veolia continue to maintain that there is insufficient capacity within West Sussex for Landfill.
They note Brookhurst Wood (approved) and a capacity there for 1.4 mt (although WSCC say 1.8mt), but VES say there are technical issues there that may significantly reduce this; we are not appraised of this particular problem.
They also mention Freshfield Lane, which was refused on appeal. What they do not say is that WSCC did not support this application, this site was not a preferred site within WSCC’s MWDF, and a press-released comment from WSCC was that they were very pleased that it was refused by the Inspectorate. Included in the reasons for refusal were the identified need for landfill in West Sussex, and this proposal impacted significantly on the AONB.
VES further omit to mention the other two preferred sites, Laybrook Brickworks (2.4mt) and Langhurst Wood (1.2mt), and the proposed Material Recycling Facilities (MRF), at Ford and the Mechanical Biological Treatment (MBT) at Langhurst Wood. The former will be operational by February 2009, and the latter by 2011.
WSCC’s stated policy is that they are continuing to move away from the need for Landfill, and are striving towards putting alternatives in place, as has been recently demonstrated by the signing of the contract for the MBT at Langhurst Wood.
P26: Horsham District Council’s new LDF - they say that there are no policy based comments on this application from any statutory consultees that relate to any new policies contained within the new LDF.
Waste policy is a matter for WSCC to decide. It is not within the remit of Horsham District Council (HDC).
Groundwater Control.
P13: Groundwater pumping-they refer to the existing pumping system that demonstrates that groundwater can be adequately managed.
We are not sure how this conclusion can be reached, when the current pumping system actually relates to existing use at Rock Common Quarry.
P37: Regards integrity effect on adjacent landfill sites. De-watering-at this stage it is difficult to predict precisely how BIFFA intend to manage & maintain groundwater levels beneath the Windmill Landfill following recovery of groundwater levels round Rock Common.
P38: it is not considered necessary to develop a specific monitoring strategy beyond monitoring the de-watering applications themselves. It is considered that ground watering at this site should be by the holder of the Waste Management Licence for the Windmill Site.
We are extremely concerned that VES are proposing that this is the responsibility of the holder of the Waste Management Licence for The Windmill Site (currently Biffa). Has WSCC ascertained BIFFA’s own response to this?
Membrane Integrity:
P11: the lining system will provide an environment within which effective landfill management systems can be implemented.
Also, they state that non-hazardous waste will be considerably more stable than the untreated wastes that were previously landfilled within “Rock”, “Windmill”, and
“The Rough”
We continue, strongly, to maintain that the integrity and stability of the proposed lining system cannot be relied on. This is not only because it can never be 100% guaranteed in its own right but that extraneous factors can never be discounted. We can not accept that a fire within the landfill, such as occurred at Warnham in July that affected over 300 square meters of the site, will not happen at this proposed site and destroy a large area of liner.
Additionally they refer to what was previously landfilled in The Windmill and The Rough. Those permissions were granted many years ago and legislation has, quite rightly, evolved since that time and continues to evolve in order to protect the environment from the irretrievable damage that might be caused by speculative, inappropriate use of resource. The nature of waste has, too, changed over the years and we do not believe a true comparison can be made.
P40: sub-water table - VES say that aftercare for 60m (re new site datum height) need not apply as the type of waste is ‘source-separated’ not municipal solid waste, so its biodegradability does not necessitate long term aftercare for 60 years as is required under RGN3.
This is a continuing, very important statement. In isolation, we believe that this should be a matter of legal challenge.
VES list 6 sites that operate sub-water table. Research shows that 4 of these sites are definitely clay-based. The source of both Pwllfawawatkin and New Albion cannot be found but permission was granted in the mid-1970’s and 1999 respectively. Legislation and guidance has changed since these dates -might these also be clay-based containment barriers? The question should be “How many landfill sites founded on a permeable sand layer with an aquifer beneath do VES actually operate?”
Also, CLAG had highlighted the environmental disaster at Houghton Le Spring. VES say that it had a different containment layer. However, this containment layer was modelled and proposed as being adequate and effective. It wasn’t, so why should the containment layer proposed for Rock Common Quarry succeed where Houghton Le Spring’s failed?
P44: Landsim is not capable of modelling effectively when the proposed landfill site is below the water table, or has multiple aquifers.
VES say it is to be continually de-watered, and therefore is not below the water table as such. We wish to ask WSCC whether this is a valid statement.
Noise and air quality:
A very full and technically concise report on the effects of noise and air quality has been submitted to WSCC by Rob Golds of Rock House Nurseries in his letter dated 4th September 2008. We do not seek to replicate his information, but support his findings such as mis-calculation and mis-statement, and fully endorse his claim under The Human Rights Act 1998:
Article 8 -The Right to Respect for Private and Family Life:
Everyone has the right to respect for his private and family life, his home and his correspondence.
Article 1 of the first protocol - Every natural or legal person is entitled to the peaceful enjoyment of his possessions except in the public interest.
The effect on human rights and enjoyment of the countryside apply equally to all residents in Washington Village and the surrounding areas.
P107: VES say that they only determined the impact on those receptors within the closest proximity
and in
Air Impact assessment-additional report
Page 1: VES state that the site is located approximately 200m from Washington Village. What they fail to say (as CLAG has demonstrated) is that there are 80 residential properties and 18 businesses within 250m. VES themselves, in their ES Volume2 s 13.2.2, state that the most significant impact from nuisances are likely to occur within 250m of such facilities. Additionally, there are a significant number of houses and businesses that are less than 150m from the site. Significantly the Conservation Area of Washington Village also comes to within 200m.
It is fundamentally remiss of VES not to address the impact of noise and air quality on those significantly affected.
A statement: that the nearest school is Rydon Community College situated 2.7km to the West.
This statement is fundamentally wrong and grossly misleading.
St Mary’s CE Primary School and their 90 pupils aged 4-10 years is within the Village, and within 350 m of the proposed site.
Windlesham School (with an estimated 200 pupils), and Garden Cottage Nursery (within Windlesham) that has approximately 40 children aged 2-5 years is far closer than Rydon Community College.
Additionally, there is the Lorica Trust Site under development at East Clayton Farm, within 400m of Rock Common. When fully operational this will house profoundly disabled young people in flats, on their own working farm.
It is fundamentally remiss of VES not to address the effects of noise and air quality on these educational establishments, and also on the development at East Clayton Farm. The proposed development at Rock Common will adversely affect quality of life and safety throughout the working day and beyond, with additional traffic hazards on the “School Run” and resultant air quality concerns for these children and young adults.
P90: In response to the fact that VES had assumed free-flowing traffic at the site-entrance, VES counters with ‘as the most sensitive receptor is significantly below nationally statutory air-quality objectives there is significant ‘head-room’ for any slight understatement for non-free flowing traffic.
We do not accept that ‘significant head-room’ is an adequate replacement for proper information.
P92: Concern raised that 20% of traffic associated with the development will pass through Storrington and this will have significant impact on an area already a concern.
VES responded with ‘Golder will continue to liaise with the Council as necessary, with respect to any potential air-quality impacts due to the development proposal.
The question which was raised by the EHO at HDC remains unanswered. This is totally unacceptable.
P100: The receptor to the West, the camping and caravan site, with their minimal resistance to noise intrusion given the lightweight structures there, were not considered necessary to address because the noise-level criteria are designed to protect residential amenity in external spaces and as Landfill will operate in the daytime.
VES also did not consider necessary the need to consider ‘transient receptors’. These, being mainly walkers on the many footpaths on the site boundaries, will suffer high levels of exposure.
We suggest that each of these groups of receptors, given their relative proximities to the proposed site, should be judged to have the same exposure to noise and air-quality nuisance as Rock House Nurseries.
P101: The suggestion that the noise levels quoted in their submission exceed the existing background noise is dismissed as the noise-levels of landfill will be less than those of the existing quarry operations due to the legislation then applying, when mineral extraction was approved.
How might this be the case? The application is for a huge intensification of use. Noise is audible in the Downs area with the present landfill, and as the site will be operating in darkness, during the winter months, there is a significant probability of light pollution.
P7: VES indicates quarrying will cease in 2011
We have asked WSCC for further information regarding this date, as our belief was that quarrying was to cease in 2009 although existing permission does run to 2020. Sand is an important resource, and we would ask that Tarmac confirm that 2011 is the finite date.
Road Traffic Impact
P78: 6m width at the site entrance, and The Hollow from the site entrance down to the A283.
We do not consider that this is adequate. There would be no margin of road for horse-riders, pedestrians, or cyclists, should two lorries pass each other.
P80: latest available accident data 2004 to present indicates that the site does not suffer any major safety related issues as a result of HGV movement.
P81: 3 year Personal Injury Accident data (PIA)
The exemplary safety record at the Hollow/A24/A283 junctions would be unlikely to change following the implementation of the development proposal. The accident record at Washington Roundabout was found to be reasonably high, but this can be attributed to driver behaviour rather than junction/road layout.
Here we have two comments based on existing road usage. We cannot accept that this will not change.
Additionally, the statement on P80 that they are using data “to the present” is not correct. They later say on Page 8 of the Supplementary Transport Paper that this is to November 2007. The PC is mindful of a number of fatalities, on the A24, and a number of serious accidents on the A283 since that time.
Supplementary transport Paper-additional report
P6 shows the impact of development traffic at AM peak hours on the A283 Storrington Rd and the A24 London Rd would increase queues at the roundabout by 20 and 18 in the hour.
P7: The proposed new road layout changes will reduce the AM queues A283 Storrington Rd from (now) 159.5 to 89.3.
To increase the number of lanes from 2 to 3 on A24 London Road, Horsham Road and A283 Storrington Road approach arms.
They consider the proposed improvements would adequately mitigate the impact of the development
What is not addressed by VES is the effect of increasing speed onto the Roundabout by creating a ‘clear’ centre lane. This will have a significant effect on accidents at the roundabout, especially with their predicted increase in traffic movements of over 500 slow-moving HGV’s per day.
The addition of a further lane on the A283 Storrington Road utilises the parking area in front of Washington Cottages. That will leave these residents with nowhere to park their vehicles, for which VES has made no provision.
The A283 Storrington Road pedestrian crossing point consists of a place of safety at the best visibility splay, crossing two lanes, then two lanes. It is situated almost on the Roundabout. The present speed of vehicles makes it very difficult especially for the elderly, and mothers with pushchairs. This is well used by residents of Montpellier Gardens, Spring Gardens and Washington Cottages to catch the bus into Storrington. The crossing point would not be feasible over three lanes, and it would have to be moved further west with the result that the visibility splay is lost. Traffic speeds will increase, and it will become even more dangerous.
Bridleway 2697 crosses the A283 Storrington Road, to join bridleway 2623 at a point by East Clayton Farm. The current crossing can take up to 10 minutes. Increased traffic speeds will make this a more dangerous manoeuvre.
The crossing point of the A283 at “The Pike” (by the Allotments) is well used on a regular basis by many people including parishioners and children walking to St Mary’s School. Visitors to the Recreation Ground, The Village Hall, and the Frankland Arms and families walking to an from the highly popular Washington Caravan and Camping Site also utilise this crossing especially during the holiday season. There is a narrow footpath running from Sandhill Lane to this crossing point. The impact over 250 HGV’s passing this narrow footpath, heading east, and then returning west, will be very significant.
Thus we have three pedestrian crossing points that would be even more exposed to traffic accidents and VES are not proposing any mitigating works.
Nothing has been proposed to mitigate the increase of traffic through our current ‘rat-runs’-Rock Road, The Pike/Old London Road, and Water Lane, into Ashington-indeed also The Hollow that will result from the routing of traffic to and from the proposed site.
P8: Safety audit at The Hollow said it looked at most recent accident data available they conclude that there were no conflicts involving HGV’s and therefore this junction operates efficiently. They are not proposing to increase the entry radius as this might lead to faster entry speeds, which may exacerbate the likelihood of conflict They suggest trimming trees/shrubs to form a low hedge to give the left-turner some forward vision, together with an anti-skid surfacing.
We mentioned earlier our deep concern about the proposed re-routing of traffic. We cannot believe that VES is relying on the current use of the junction to justify doing very little in terms of road safety improvements here.
In reality, what will happen is that an HGV turning left into The Hollow will stop to let an exiting HGV out. If he is turning right, towards the roundabout, no one will want to let this slow-moving vehicle go in front of them. The result will be a tailback behind the stopped vehicle that is attempting to turn left and will increase the risk of accidents on these notorious bends.
Landscape/Conservation
P72: Regards the proposed visual impact from Chanctonbury Ring.
VES say it is over 1.5 km away, and the impact is assessed to be moderate to minor, as the site would form a small part of a much wider vista.
However, VES fails to comment on the impact from Chanctonbury ridge this is more easily accessible for those less able visitors. It extends very much closer to the proposed site, and is extremely popular. The proposed site (as we know from experience with earlier landfills) would be well within earshot, and would be the most prominent foreground object in this scenic and highly-regarded view over The Weald.
It is a fact that the proposed restoration levels rise to a significant height, and combined with the plant on top of it, it will be highly intrusive site particularly from the West. VES has completely failed to address the landscape impact, both on the historic core of Washington Village, and its impact within the AONB and the proposed South Downs National Park, that adjoins the proposed site.
P76: listed buildings.
Veolia stop at 28 within 500 meters and they will have a negligible effect on their setting since they are located some distance from the site.
There are at least 10 buildings within 250 metres, 3 in extremely close proximity, and Green Farm House (which Veolia states is their closest receptor), is a listed building, as is Green Farm Barn. Account should be taken of these historic properties.
In conclusion, there are a number of points as yet unanswered in our previous letter of objection, and we would ask that those remain on file to be considered with this amended application.
Our very strong objection is maintained.
There is nothing within this further and additional information that successfully addresses our main points of objection, which are:
1. The site is on permeable sand, on a major aquifer, and there is no proven way of preventing the pollution of groundwater.
2. The integrity of the proposed liner/barrier is unproven, with catastrophic consequences should it fail.
3. This site is not needed by WSCC, and is not within their preferred options, contained within their MWDF.
4. There is an approved restoration plan, in place, for when sand-winning ceases. This has been stated, by VES, as 2011, (although we have asked WSCC for confirmation from Tarmac on this revised date).
5. The site is classed as a Site of Regional Geological Importance
6. The effect on the amenity of households, and businesses is totally unacceptable, and fails to be addressed. We have been able to comment further on the amenity effect of households, but there is no further addressing, by VES, on the effect on businesses within close proximity to the proposed site. These include Castle Kitchens, a notable food-producer, and a number of soft fruit and arable farms, and other food producing businesses within 250m.
7. The proposal that all traffic be routed via the A283 is totally unacceptable and would only increase the danger to motorists, pedestrians, and equestrians.
8. The proposal has an extremely significant visual and auditory impact on one of the most famous, protected, landscapes within Southern England.
9. VES does not address the recently ratified European Landscape Convention aimed at preventing unnecessary development on the periphery of protected landscapes.
Yours sincerely
Lesley C. Britt
Chairman
