Text Box: St Dennis Parish Council Response 
To Planning Application 
No. 08/00203/WAS
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 


FOR THE ATTENTION OF RESTORMEL BOROUGH COUNCIL PLANNING DEPARTMENT

AND

CORNWALL COUNTY COUNCIL PLANNING DEPARTMENT

 

 

 

 

 

 

 Submission supporting the St Dennis Parish Council Objection to Application:

08/00203/WAS.

 is sent to Restormel Borough Council Planning Department as Consultees.

 

 

 

Submission supporting the St Dennis Parish Council Objection to Application:

08/00203/WAS.

 Is also sent to Cornwall County Council Council Planning Department as the Determining Authority.


ST DENNIS PARISH COUNCIL

 

 

 

 

 

 

RESPONSE TO PLANNING APPLICATION:

 

 

SITA (UK)  Cornwall.    Planning Application No. 08/00203/WAS

 

 

 

 

 

 

Proposal Address

 

Land at Rostowrack 

St Dennis

St Austell

Cornwall

PL26 8DX

 

Applicant:

 

Sita Cornwall Ltd.

Waste Management contractor to Cornwall County Council

 

Proposal:

 

Construct and Manage a 240,000 tpa. Incinerator.

To burn predominately Municipal Solid Waste (MSW) and Commercial and Industrial (C&I).

 

 

 

 

 

 

 

 

 

 

 

 

 

The St Dennis Parish Council request that you consider the following points made in objection to the Cornwall Energy Recovery Centre Planning Application.


 

 

 

Summary of St Dennis Parish Council submission to Restormel Borough Council Planning Department and Cornwall County Council Planning Department.

 

 

 

 

The St Dennis Parish Council Object to this Application for the following reasons:

(Supported by accompanying text).

 

 

1.      Overwhelming opposition from the public as evidenced from public meetings held in the locality.

 

2.      Green field site with only partial permission for plant construction allied to the China Clay industry.

 

3.      Site is too close to Treviscoe and St Dennis

 

4.      Irreparable visual, noise and smell intrusion into two villages and numerous hamlets.

 

5.      All Emission figures are modelled and assumed.

 

6.      Waste hierarchy not complied with.

 

7.      Proximity principle not complied with.

 

8.      Minimum road miles policy not complied with.

 

9.      National Policy, W L P and W D F criteria not complied with.

 

10.   Close proximity to SSSI and S A C sites and the river Fal.

 

11.   No suitable access road to proposed site without construction of 3.4km. of new            

             haul road.

 

12.   No back up systems identified in documentation if major breakdown occurs.

 

13.   More than one Residual Waste Disposal Plant essential in the County.

 

14.   Duty of care to residents from the Cornwall County Council.


 

 

 

The St Dennis Parish Council request that you consider the following points made in objection to the Cornwall Energy Recovery Centre Planning Application.

 

 

 

 

 

 

 

 

General Observation

 

 

Point 1.5 in the Environmental Statement states that the Cornwall County Council are the Waste Disposal Authority.

 

 

The Cornwall County Council (C C C) has awarded a Waste Contract to Sita Cornwall Ltd. for the disposal of the Counties waste.

Now C C C are being asked to consider a Planning Application for the Waste Management Incinerator.

 

The Waste Management Incinerator is part of the Contract awarded by CCC.

 

The question arises, how can CCC decide a planning application on a proposed Incinerator, when C C C were instrumental in awarding the contract to Sita Cornwall Ltd. in the first instance?

 

As all Members of the Cornwall County Council had the opportunity to vote on the Award of Contract, how can the C C C Planning Committee that is made up of from those same Members be unbiased in their views?

 

 

 

Question:

 

Does this constitute a prejudicial interest for Members of the County Council Planning Committee ?

 

 

 

 

 

 

The St Dennis Parish Council request that you consider the following points made in objection to the Cornwall Energy Recovery Centre Planning Application.

 

 

 

 

The St Dennis Parish Council submit the following documentation to underline their Objection to this Application.

The Parish Council state that they object in the strongest terms to this application for the construction of a C E R C.

This view has been reached after meetings with the general public and scrutiny of the application documents.

 

The following points are made with reference to the Environmental Statement that is part of this Application.

 

 

 

Quote from Environmental Statement:

 

‘‘Transport

1.32 The number of miles each day trucks travel carrying waste associated with each

scenario was taken as a good proxy for transport amenity impacts, reflecting the

fact that these impacts are likely to be proportional to the amount of traffic

involved in each of the scenarios. The results show that increasing the number

of plants generally decreases the overall transport mileage, because the average

distance to the nearest facility is reduced.

1.33 The relative differences between the scenarios are not consistent, in that moving

from one to two plants delivers an 11.3% decrease in daily mileage…………………’’

 

Response

 

Clauses 1.32 and 1.33 indicates that there is a saving in road miles using two incinerators.

This 11.3% saving is environmentally a very important consideration.

 

 

Quote from Environmental Statement:

 

 

‘’Cost

1.35 SITA provided ERM with estimates of capital and operating costs (excluding

depreciation) and revenues for the three scenarios. With regard to capital costs,

there are considerable economies of scale associated with the construction of a

single, large facility (£117M), in comparison with two smaller or, in particular, five

much smaller facilities (£135M and £223M, respectively). Operating costs per

plant are markedly higher for a 240,000 tpa facility in comparison to the

120,000 tpa or 48,000 tpa plants. However, when the operating costs for all the

plants in each scenario are summed, the single plant is the least expensive.’’

 

 

Response

 

Clause 1.3 gives the increase in cost for two incinerators over the cost of one plant rising from £117M to £135M.

This represents a 15.38% one off rise in capital cost at the outset.

However the 11.3% decrease in road miles would be accumulative year upon year for the duration of the contract.

Given the spiralling cost of DERV it would seem that the argument for a saving in capital cost is somewhat circumspect.

 

Clause 1.41 discusses weighting of transport impact criteria and concludes this is not a logical approach.

Whilst this may be true in monetary terms we must argue that the Environmental benefits over the 30 years of the contract will far outweigh any short term monetary gain.

It is our opinion that the extra initial capital outlay to build two incinerators would be the best solution for the County and its inhabitants.

 

Proximity Principle and Minimum Road Miles

 

The two incinerator site approach will also better fulfil the ‘Proximity Principle’ and also

the ‘Minimum Road Miles’ criteria both of which are part of current Policy documents that form part of the Planning Guidance for this type of application.

 

 

 

CHAPTER TWO

 

Alternative sites – planning policy background

 

Quote from Environmental Statement

 

National policy

 

2.5   PPS10 sets outs relevant national policies for waste management facilities,

including location criteria to inform local planning policy and planning decisions.

In searching for sites suitable for new waste management facilities, PPS10

recommends that a broad range of locations, including industrial sites, are

suitable, giving priority to the re-use of previously developed land.

2.6   In deciding which sites and areas to identify, PPS10 sets out criteria against

which the suitability of sites should be assessed. These are as follows:

• The extent to which they support the policies in the PPS

• The physical and environmental constraints on development, including

existing and proposed neighbouring land uses.

 

 

Cornwall’s WLP

 

2.7 The WLP was adopted in December 2002 and the majority of its policies are

saved to October 2010. On the basis of the BPEO study that informed the WLP,

the WPA identified an area of search located in the centre of Cornwall, within

which a single EfW plant should be located. The suitability of sites identified

within this area of search will be assessed against a range of criteria listed in

Policy L6 of the WLP, although it is acknowledged that a site need not achieve

them all. The equally weighted criteria are:

• Demonstrate reasonable proximity and accessibility to the Primary Route

Network

• The plant is to be served by rail

• Demonstrate reasonable proximity and a good quality connection to the main

electricity grids

• Will produce both electricity and heat for off-site consumption

• Will have sufficient on-site capacity to provide for residue processing facilities

• Can demonstrate that any adjacent ancillary development will be in

accordance with the spatial strategy contained in the relevant development plan

• Does not adversely affect the integrity of a Special Area of Conservation

• The plant has a gross maximum annual capacity of no more than 200,000

tonnes.

 

Emerging WDF

 

2.10 The sites identified in the emerging WDF were derived from a search undertaken

by the WPA to identify those sites that were considered to be most appropriate ‘in

principle’ for use as waste management facilities, not specifically EfW. Sites with

the following attributes were identified as being potentially suitable:

Vacant and undeveloped sites larger than 0.5 ha

Land allocated for employment and industrial uses in adopted / draft local

plans

Unallocated sites with existing industrial uses

Existing minerals and waste management sites

Areas of contaminated, derelict or previously developed land.

 

 

 

Response

 

National policy, the Cornwall Waste Local and the Waste Development Framework all suggest criteria for sites that are clearly not met.

 

 

Clear points of conflict are:

 

National Policy

 

·          2.6  The cumulative effects on the well being of the local community, including any adverse impacts on environmental quality.

·         The capacity of existing and potential transport infrastructure to support the

           sustainable movement of waste and products arising from resource recovery,

           seeking when practicable and beneficial to use modes other than road

           transport.

          

 

NOT MET

 

 

 

Reasons:

 

B. P. 1   The well being of local residents will be adversely affected by the implementation of this Application. Noise, Smell, Dust, Chimney Stack Emissions and Loss of Green Field Site.

 

B. P. 2   The existing road infrastructure will not support the increase in traffic generated to and from the proposed site.

Modes of transport other than road clearly not considered in this application.

 

 

 

 

Cornwall’s WLP

 

2.7 The WLP was adopted in December 2002 and the majority of its policies are

saved to October 2010. On the basis of the BPEO study that informed the WLP,

the WPA identified an area of search located in the centre of Cornwall, within

which a single EfW plant should be located. The suitability of sites identified

within this area of search will be assessed against a range of criteria listed in

Policy L6 of the WLP, although it is acknowledged that a site need not achieve

them all. The equally weighted criteria are:

 

1.    Demonstrate reasonable proximity and accessibility to the Primary Route

Network

2.    The plant is to be served by rail

3.    Demonstrate reasonable proximity and a good quality connection to the main

electricity grids

4.    Will produce both electricity and heat for off-site consumption

5.    Will have sufficient on-site capacity to provide for residue processing facilities

6.    Can demonstrate that any adjacent ancillary development will be in

accordance with the spatial strategy contained in the relevant development

plan

7.    Does not adversely affect the integrity of a Special Area of Conservation

8.    The plant has a gross maximum annual capacity of no more than 200,000

tonnes.

 

 FIVE POINTS NOT MET.  (1,2,6, point 7 arguable AND 8)

 

 

 

Emerging WDF

 

 

2.9   Following a second round of public

consultation, these four sites were reduced to two in the submission stage of the

WDF, which, although not formally submitted to the Secretary of State, was

agreed by CCC’s Executive in November 2006.

 

2.10   The sites identified in the emerging WDF were derived from a search undertaken

by the WPA to identify those sites that were considered to be most appropriate ‘in

principle’ for use as waste management facilities, not specifically EfW. Sites with

the following attributes were identified as being potentially suitable:

·       Vacant and undeveloped sites larger than 0.5 ha

·       Land allocated for employment and industrial uses in adopted / draft local

           plans

·         Unallocated sites with existing industrial uses

·         Existing minerals and waste management sites

·         Areas of contaminated, derelict or previously developed land.

 

 

BULLET POINTS IN 2.10 ARE NOT MET

 

CHAPTER THREE

 

The Site

 

Response

 

Clause 3.8 states that a 15km radius area was considered when visual impact was considered.

St Dennis and Treviscoe villages and several hamlets are well within 1km of the proposed site.

 

Clause 3.9 states that: The CERC and its access road will be constructed on an area of previously undeveloped Grade 3 classified agricultural farmland. A portion of this land has been identified for china clay industry related development in the MLP.

 

This is clearly in conflict with clauses quoted above ( NP.  PPS 10, WLP. 2.7 and WDF 2.10.

 

Clause 3.12 deals with the haul road.

 

The St Dennis Parish Council feel that a major opportunity has been lost in the design of this road.

If this road is built to adoptable standards then it would serve as a vehicular link to Nanpean and beyond, if, in the future the road could be continued through to the existing unclassified road that connects St Stephen and Roche.

 

The Parish Council have made representations to the County Council outlining their proposals but were not successful in their efforts to make the road a County Highway.

 

 

General Observations   The Site

 

It is our view that the site does not meet  the criteria cited above.

 

 

We believe the site selection to be flawed in the extreme.

 

 

It has been freely admitted, in the Planning Application documentation, that mitigation can not be achieved to alleviate known problems as described in the Environment Statement.

 

 

CHAPTER FOUR

 

The Proposals

 

Quote from E S Statement:

 

4.8 The building housing the plant process equipment will be approximately 145.5m

long, between 37.7m and 58.2m wide and between 7.5m to 45.0m in height,

relative to the ground level, at the apex of the roof (162.5-190.0m AOD).

Elevations of this building are shown in figures 4.4 to 4.7 and a longitudinal

section in figure 4.8.

 

Response

 

The building is huge in proportion to even the largest china clay plant buildings on the adjacent site.

When compared to the domestic scale of St Dennis and Treviscoe it is totally disproportionate to any building in the area.

As stated previously no mitigation or landscaping will overcome such a building mass only a distance of 400 metres from residents in both St Dennis and Treviscoe.

 

 

 

 

4.12   A 120.0m (265.0m AOD) chimney stack will be situated at the northern end of the

site between the main CERC building and the bottom ash recovery facility. It will

comprise two flues, one for each line, each having an outside diameter of 3.4m.

The height is subject to final agreement with the Environment Agency through the

PPC application process; hence it could be subject to change, possibly resulting

in the need to amend relevant sections of this ES.

 

Response

 

This clause shows clearly the dimensions of the modified chimney stack.

Whilst trying to mitigate the effects on the local immediate environment there has been no consideration given to the local residents and the blot on their views across existing green fields, indeed farmland.

 

4.13  The proposed height has been determined through extensive computer

dispersion modelling of emissions and evaluation of the resulting dispersion

plumes. This height meets the PPC requirement to utilise best available

techniques (BAT) to minimise pollution and will ensure that ground level

concentrations of key pollutants are kept within acceptable levels under all

operating conditions, including emergency shutdowns.

Cornwall Energy Recovery Centre SITA Cornwall Limited

Planning Application

ES Chapter 4: Proposals

Terence O'Rourke March 2008

4.14   The stacks have been structurally designed to meet all predicted climatic

conditions. Each stack has lightning protection, sampling points for manual

measurement and connections for continuous emissions monitoring equipment.

 

 

Response

 

The data used in the design of the 120mtr. Chimney stack is stated to be computer generated.

Why has there been no assessment of the existing chimney emission direction and effect on the locality?

What effects will the mixing of various chimney stack emissions in the vicinity have on the local air quality?

 

 

DESIGN AND MATERIALS

 

Design

 

The design of the building element is very limited in that the building has to cloak a massive incinerator.

The building is too large for this particular site being adjacent to two villages and dwarfing already large china clay industrial buildings.

 

Materials

 

Materials for this type of building are limited in variety and therefore no comment is made.

 

 

ACCESS AND SITE ACCESS ROAD

 

 

The Environmental Statement variously describes the haul road as ‘mainly on Imerys land’, ‘constructed across farmland’.

3.4 km. of road that need not have to be built if the proposed site fulfilled the criteria previously set out above in National Policy, WLP and WDF.

 

 

 

 

 

 

 

LANDSCAPE STRATEGY

 

 

Response

 

 

CERC SITE AND HAUL ROAD

 

Clauses 4.49 to 4.62 deal with  landscaping issues when taken in context of the massing of the building and the ancillary works.

 

NO AMOUNT OF LANDSCAPING WILL MITIGATE THE EFFECTS OF THIS MASSIVE BUILDING.

 

The E S Non Technical Summary seems to be in conflict with the Environmental

Statement where it says: (reference the buildings)

 

‘This larger scale can be accommodated in the landscape’

 

This is in conflict with the E S where it says the buildings are of high impact on receptors (residents)  from most of the viewing points mentioned in the report. (9.96 to 9.132).

 

Mitigation measures are stated in the E S Non Tech Summary as being ‘incorporated in the building design’.

The E S states that mitigation is not possible due to the massing of the buildings.

 

 

 

PROCESS EFFICIENCY, RECOVERY VERSUS DISPOSAL

 

 

Response

 

 

Clauses 4.73 to 4.78 refer to the efficiency or more properly described the inefficiency of energy recovery, marginally above the required efficiency factor of 0.65 from December 2008.

 

Estimated efficiency factor for the Incinerator energy production and the heat recovery methods to be employed is 0.66.

 

If any part of the process fails to deliver the optimum amount of energy recovery the whole process will become a disposal operation and not a Combined Heat and Power Plant. (CHP).

 

 

 

 

 

 

WASTE INPUTS, TIPPING HALL, ODOUR AND DUST SUPPRESSION, LIQUID RUN OFF, FURNACE AND FLUE GAS TREATMENTS

 

 

 

Response

 

Clauses 4.79 to 4.101 set out the optimum methods for dealing with the topics addressed therein.

4.79 to4.81    NO COMMENT

 

4.82 TO 4.88  DEALS WITH A CRITICAL PART OF THE PROCESS

 

The delivery and tipping of waste products are believed by the Parish Council to be a source of air pollution by dust, noise and odours.

 

It has been personally evidenced that vehicles delivering and returning from the plant do create noise, dust and odour problems. Southhampton (Marchwood) and I of M.

 

It has also been personally evidenced that in the event of a catastrophic breakdown the management  of the systems do not work as described in 4.83 to 4.98.

When a serious breakdown occurred at Kirklees the system management failed to stop further operation of the plant.

The plant was somehow started by the operative with no water in the combustion chamber jacket causing a catastrophic breakdown.

 

These points may not seem to be Environmental issues but will become so if pollutants are allowed to escape into free air.

 

 

The areas of most environmental concern would be possible leaching from the Refuse Bunker; failure of the Air Fans; variation from recommended,  regulated temperatures in the Super heater, Gas Scrubbers and Boiler; spillage or failure in the Filters and chemical formation in the flue gasses as they escape the plant via the stack.  The "clean flue gas" is anything but clean, and therefore is part of the waste stream.

 

 

MONITORING

 

Response

 

The monitoring of the flue gasses are of great concern to the Parish Council as there are exceedances evidenced from plant data in several locations both in UK and Europe.

 

 

 

 

 

 

 

 

ABNORMAL OPERATING CONDITIONS

 

Response

 

Clauses 4.133 to 4.141 deal with the most contentious areas from an Environmental point of view.

The start up and shut down phases of operation give cause for serious questioning with regard to the robustness of the systems employed to monitor the two phases of operation.

It has been show at other Incinerator operation sites that these two phases of operation are the most problematic to control effectively giving rise to exceedances and complaints from the public.

 

 

CHAPTER 5

 

Defining the Issues

 

 

Cumulative impacts

 

Quote from E S Statement:

 

 

5.27   Where there is the potential for the CERC to give rise to cumulative impacts with

other proposed, permitted (but not implemented) developments or developments

for which land is allocated, these will be assessed using all available relevant

information/data. However, no such significant developments are known off within

the vicinity of the CERC. All existing developments will be incorporated into the

determination of the baseline environment.

 

 

Response

 

Taking into account the various emission points around the proposed site is a reasonable valuation to take for reference purposes.

However the issue of most concern is the mixing of the various emissions when they are emitted to free air.

What cocktails of mixed chemicals will this produce?

 

 

 

 

 

 

 

 

 

 

 

CHAPTER 6

 

Transport and traffic

 

Response

 

 

Considering Transport and Traffic issues from an Environmental perspective, the points already made with regard to noise, dust and smell emanating from vehicles using the site road and the haul road must be re-emphasized.

 

It is felt that this element of the whole strategy being put forward for the management of pollutants is the most difficult to control.

The age of contractors vehicles, the condition of containers carrying refuse etc.

 

CHAPTER 7

 

Air quality and climate

 

 Response to E S Non Tech Summary (page 20) where it states:

‘the chimney height of 120 mtrs is high enough to ensure adequate dispersal of pollutants and avoid any adverse effects on the integrity of the adjacent S A C (Special Area of Conservation).

The E S (chapter 7) clearly says ‘pollutants are not expected to cause any significant impact on human health’

 

Comment:

 

This whole Waste burning process is not an Environmentally clean method of dealing with residual waste.

 

 

Quote from E S Statement:

 

7.3 This section details the legislation and policy covering the emissions to air from

the chimney of the proposed CERC. The human health, vegetation and

ecosystems air quality assessment criteria used in this assessment are also

provided.

 

Table 7.3: Air emissions characteristics modelled for the proposed CERC

Variable Value

Equivalent chimney diameter (m) 2.192

Chimney location (National Grid Reference) 194441,057132

Chimney height (m) 120

Exit temperature (°C) 132

Exit velocity (m/s) 18.4

Normalised volumetric flow rate (N/m3/s) 38.8

Actual volumetric flow rate (A/m3/s) 69.5

Pollutant emission rates (g/s) (b)

Particulates (PM) 0.388

Volatile organic compounds (VOC) 0.388

HCl 0.388

HF 0.039

SO2 0.78

Oxides of nitrogen (NOx) 5.81

Ammonia 0.19

Group 1 metals 0.00194

Group 2 metals 0.00194

Group 3 metals 0.0194

Dioxins and furans 3.88 x 10-9

CO 1.94

 

 

Notes

a) All of the modelling undertaken during this assessment, unless stated otherwise, assumed continuous operation as a worst case (i.e. 8,760 hours per year).

b) Assuming emission concentration based on the air emission limit values specified in the WID (mg

N/m3 (11% O2 (dry), 273 K). Emissions of metals are taken as an equal proportion of their respective limit value, for instance the lead emission is taken as an equal proportion (one ninth) of the total group 3 metals limit value.

c) Emissions are as provided to ERM by SITA Cornwall Ltd, based on the contractor’s design. Note that there are two chimneys, separated by a small distance. The emissions are modelled as one ‘effective’ source, with the flow rate (and associated calculations) based on the total flow through the two

chimneys and total mass release rates for each pollutant.

 

 

Response

 

The figures given in the table are admitted to be ‘assumed and modelled’. What confidence does this give to residents who live in close proximity to the chimney stack?

 

The model goes on to state that the two chimneys are modelled as ‘one effective source’.

How can this assumption be made when it is clear that any one of the two combustion chambers may be working in isolation?

 

It is generally recognised that the start up procedure and shutting down procedure are the two most polluting parts of the process together with any exceedence periods.

There are no explanatory clauses in the text to suggest how these difficult stages of operation will be controlled or monitored.

 

 

Quote from E S Statement:

 

 

Table 7.4: AQS objectives for the key pollutants for the protection of human health

Pollutant Concentration…………………………….

 

Measured as                                                                         

 

PM10                    

NO2                                                                 

SO2

 

Other pollutants

HCl

HF

Cadmium

Thallium

Mercury

Antimony

Arsenic

Chromium

Cobalt

Copper

Manganese

Nickel

Vanadium

Dioxins and furans

 

 

Response

 

There is no measurement of PM2.5’s at all.

It is the opinion of nationally recognised experts that PM2.5’s are very harmful to human health.

 

Clause 7.7, table gives a list of pollutants that will be emitted from the chimney stack.

15 different pollutants to be precise.

 

The most disturbing point to note is that furans and dioxins will be the least monitored of all.

 

 

CHAPTER 8

 

Noise

 

 

Introduction

 

 

Quote from E S Statement:

 

 

8.1 This chapter considers the potential effects of the CERC proposals on existing

and future noise levels in the vicinity of St Dennis, Cornwall. The EIA scoping

exercise highlighted noise effects as a primary issue due to the scale of the

development and its 24-hour operation.

 

 

Response

 

It is appreciated that the evaluation processes employed to ascertain noise levels and their effect on the human ear are of a highly technical nature.

Therefore the following points of concern are made in generalised terms.

 

The residents living in St Dennis and Treviscoe already have problems from time to time with mechanically produced noises emanating from the Goonvean and Imerys China Clay Works.

It is therefore inevitable, at some stage, that noise created from the procedures carried out in the plant operations will disturb members of the public in the two villages mentioned above.

 

Vehicle movements are of concern to residents when considered as a source of noise pollution.

It has been established by the Cornwall Air Quality Forum that 1 Heavy Goods Vehicle (HGV) equates to 22 private cars in terms of polluting the atmosphere.

It is therefore reasonable to assume from data provided in this submission Table 6.8)(below) that  a total of 350 vehicle movements will take place daily minus 122 staff movements leaving 228 movements of HGV type vehicles.

 

Simple mathematics will show that 228 multiplied by 22 as the private car equivalent gives a figure of 5016 plus the 122 staff movements.

 

This equates to 5138 private car movements per day.

How can this amount of traffic increase be dismissed as having no effect on St Dennis and Treviscoe?

 

It is not reasonable to come to the conclusion that this increase in traffic volume when will have no adverse impact when considering Environmental implications on the immediate area.

 

 

Quote from E S Statement:

 

 

Table 6.8

Predicted daily vehicle movements

Trip type                                           Arrivals                            Departures                 Total

Service deliveries                                    5                                        5                             10

Staff                                                        61                                       61                            122

Visitor coach (per week)                         1                                        1                               2

Waste vehicle (import)                           72                                       72                            144

Waste vehicle (export)                           20                                       20                            40

On-site recycling (import)                      14                                       14                             28

On-site recycling (export)                       2                                        2                               4

Total                                                       175                                   175                            350

 

 

 

CHAPTER 9

 

Landscape and Visual effects

 

Quote from E S Statement:

 

 

Landscape related planning designations

9.3  The following paragraphs describe areas with landscape or related environmental

or cultural designations that might either be directly affected by the development,

or indirectly affected because they lie within the 15km projected visual influence

of the proposals.

 

Response

 

NO AMOUNT OF LANDSCAPING WILL MITIGATE THE EFFECTS OF THIS MASSIVE BUILDING.

 

The E S Non Technical Summary seems to be in conflict with the Environmental

Statement where it says: (reference the buildings)

 

‘This larger scale can be accommodated in the landscape’

This is in conflict with the E S where it says the buildings are of high impact on receptors (residents)  from most of the viewing points mentioned in the report. (9.96 to 9.132).

 

Mitigation measures are stated in the E S Non Tech Summary as being ‘incorporated in the building design’.

The E S states that mitigation is not possible due to the massing of the buildings.

 

Clauses 9.4 to 9.14 set out areas of special interest that will be affected by this application.

They are:

 

Quote from E S Statement:

 

County wildlife sites

9.14 There Special areas of conservation

 

9.4 The Goss Moor SAC is centred in the main area of Goss Moor 2km north of the

site, but the boundary of the SAC extends along the River Fal tributary streams,

one of which extends up to within 100m of the site of the main building. The SAC

also extends adjacent to the haul road access to Stamps Hill.

National designations

 

Area of outstanding natural beauty (AONB)

9.5 There are two AONBs within the outer margins of the 15km projected zone of

visual influence (ZVI) of the proposals. These are Trevose Head to Stepper Point

on the north coast and South coast central. As national landscape designations

they are important factors in determining the significance of effects on

surrounding landscape resources.

Heritage coast

9.6 There is one area of heritage coast within the outer area of the 15km projected

ZVI of the proposals. The area affected is 14-15km south of the site, immediately

to the west of Caerhays and within the AONB. As national landscape

designations they are important factors in determining the significance of effects

on surrounding landscape resources.

Scheduled monuments

The ancient woodlands of main concern are those for which a wider landscape

setting is an important part of their appreciation by people visiting the site. ES

chapter 10: natural heritage describes the sites in more detail.

 

Registered historic parks and gardens

9.11 No registered historic parks and gardens are directly affected by the proposals.

Within the projected ZVI there are five, Trewithen, 9km south of the site, Lost

Gardens of Heligan 13km to the south east, Trewarthenick 13km to the south,

Caerhays Castle 15km to the south (a small part marginally within ZVI) and

Chyverton House 14km to the south west. As landscape and cultural features

they are important factors in determining the significance of effects on

surrounding landscape resources.

 

Listed buildings

9.12 The proposals could potentially affect the settings of listed buildings in the

surrounding area. Consideration of this is included in the evaluation of the effects

on landscape resources.

 

 

Local designations

 

Area of great landscape value (AGLV)

9.13 There are six AGLVs within the projected ZVI, the closest two are 4.5km to the

south and 4.5km to the south west. The others are in the area north of Truro, to

the north east and south west of Newquay and the area extending east and south

of Bodmin.

are several county wildlife sites within the projected ZVI.

Response

 

 

The expressed view on these categories, all of which are of nationally recognised importance, is that a Waste Treatment Plant of such magnitude must have an effect on the surrounding countryside and the hinterland.

 

It is freely admitted, in the application documents,(Landscape 9.3)  that an area of 15km radius will be affected by this application in one way or another.

 

It is also freely admitted, in the application documents, that no amount of mitigation can overcome the visual impact on the surrounding area.

 

When considering the Methodology, Definition and Classification of significance of effect on visual amenity, Land Use and Development Patterns, Land Resource, Landscape Character, assessments contained in clauses 9.15 to 9.89 ,it is largely accepted that the facts given are reasonable.

 

In clauses9.93 to 9.138 the visual impact of the proposal is dealt with, the following responses are made:

 

View from La Mount is categorised as having a medium effect impact on the residents.

We wish to challenge this assessment.

The building and chimney stack will have a huge detrimental effect on these residents as stated for the residents of Treviscoe.

 

 

Response

 

From the evidence highlighted above in clauses 9.93 to 9.138 it is clear that in most cases the impact on residents is in the high category.

 

Why is it necessary or even reasonable to subject so many residents to the high degree of visual intrusion as referred to in this application?

 

Surely a more appropriate site could and should have been located by the Cornwall County Council who did name this site, as the model, for all Contract Applicants when the first round of Applicants were considered.

 

 

 

 

Quote from E S Statement:

 

 

Stack and plume

 

9.138 The stack comprises two 3.4m diameter flues 120m high set apart from the main

CERC building. The first 35m of chimney will be clad in a non-reflective steel

similar to the CERC cladding and its base long axis will be 12m and the short

axis 7m. It is demonstrably the most widely visible element due to its height and

will be finished in a light matt grey in order to minimise its degree of visibility. The

plume is predicted to be visible for 47% of the daylight hours of the year. The

maximum plume length predicted is 221m but it is estimated that there will only

be two hours per year where the plume length is over 200m long. Average plume

length is predicted to be 45m. Visible plumes can occur at any time but would

predominantly occur during the night because of cooler temperatures and higher

relative humidity. The plume is mainly composed of water vapour and therefore

will appear white or light grey in daylight, possibly darker grey when viewed

backlit by the sun, for instance in views from northerly directions.

 

 

Response

 

This plume can only be described as totally unacceptable and constitutes yet more visual intrusion.

 

The chimney stack is huge in proportion to many chimney stacks viewed at other Incinerator operation sites visited in the U K.

One can only assume from the height of stack required to dissipate the emissions that the choice of site is flawed and totally unsuitable in Environmental terms.

 

 

CERC facility

 

 

Quote from E S Statement:

 

 

9.139 The CERC building is 145.5m long, varying from 37.7m to 58.2m wide and up to

45m high at the apex of the roof.

 

Response

 

This building is massive by any standards and is totally unacceptable in this prominent position that can be viewed from so many points as previously evidenced.

 

The remainder of Chapter 9 gives values for intrusion of a visual nature both now and after a 10 year maturity of the site.

It is unfortunate and unacceptable that the majority of views will be unaffected by any mitigating measures that will be employed.

The massing of the building and the prominent position of the site are the two main causes for concern and objection and contribute to the impossibility of trying to screen the site from view.

 

The Environment that local residents currently enjoy will be seriously affected visually and most likely be affected by noise pollution.

It is therefore considered that the Plant buildings and ancillary equipment proposed can only be detrimental to the general environmental climate that the surrounding residents enjoy.

 

 

CHAPTER 13

 

 Water environment

 

 

Quote from E S Statement:

 

 

13.1  This chapter considers the potential effects of the development proposal on the

surface water environment at the site.

 

 

Response

 

·         The containment of water on site is a major concern to residents in the immediate area of the Waste complex.

 

·         In the event of a fire in the area of the refuse reception hall, how will the water used to extinguish a fire be dealt with?

 

·         How will the water needed in the process be provided?

 

·         It is of the greatest importance that the river Fal is protected from any run off from the site

 

 

 

 

 

Pedestrians and Footpaths

 

There is a passing almost dismissive reference to the loss of ancient footpaths that have been used for centuries by residents walking between the villages of St Dennis and Treviscoe.

The E S Non Tech Report states that the average vehicle movements at peak times will be 1 per minute and will have no adverse effect on pedestrians.

 

 

 

Response

 

This amount of vehicles will certainly affect pedestrians especially as they can now enjoy the countryside that is quiet and vehicle free.

 

It should also be made clear that the vehicle movements will also have a detrimental effect on the two houses at La Mount near Treviscoe where the new site access road will join the C 184.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Summary of St Dennis Parish Council submission to Restormel Borough Council Planning Department and Cornwall County Council Planning Department.

 

 

The Parish Council Object to this Application for the following reasons:

(Supported by accompanying text).

 

 

1.       Overwhelming opposition from the public as evidenced from public meeting held in the locality.

 

2.      Green field site with only partial permission for plant construction allied to the China Clay industry.

 

3.      Site is too close to Treviscoe and St Dennis.

 

4.      Irreparable visual, noise and smell intrusion into two villages and numerous hamlets.

 

5.      All Emission figures are modelled and assumed.

 

6.      Waste hierarchy not complied with.

 

7.      Proximity principle not complied with.

 

8.      Minimum road miles policy not complied with.

 

9.      National Policy, W L P and W D F criteria not complied with.

 

10.  Close proximity to SSSI and S A C sites and the river Fal.

 

11.  No suitable access road to proposed site without construction of 3.4km. of new

            haul road.

 

12.   No back up systems identified in documentation if major breakdown occurs.

 

13.   More than one Residual Waste Disposal Plant essential in the County.

 

14.   Duty of care to residents from the Cornwall County Council.