Object

Initial Consultation document

Representation ID: 91830

Received: 02/07/2018

Respondent: Mr I McIntyre

Representation Summary:

Proposed sand and gravel extraction at Waveney Forest
My wife Freda and I reside at Forest Lodge within Waveney Forest. Our house, possibly the nearest to the quarry, is positioned only some 120 metres from the nearest extraction site, the corner of our garden being 20 metres closer.
So positioned, it is evidence that we would be exposed to totally unacceptable environmental impacts from noise and airborne dust.
Some 24 years ago we both took early retirement partly on health grounds. We chose to live in the Waveney Forest, rather than to remain near our family in the midlands, because of the fresh air and unique tranquillity which it afforded. We therefore find the prospect of a noisy, dusty extraction site close to, and dominantly upwind of us particularly distressing.
The applicants have yet to provide the required independent quantitative determination of their expected noise emissions. However, even with a very conservative estimate of these, because of the extreme tranquillity of the site and the way noise impact is assessed (the quieter it already is the less additional noise is acceptable) (Guidelines for noise impact assessment 2002) the perceived sound level at Forest Lodge would be several times that represented by the 10dB threshold of the highest of the five impact categories - termed 'major' noise impact.
The likely level of airborne dust exposure at Forest Lodge may be inferred from statistically robust multiple determinations carried out over time near a sand and gravel facility (Holmen BA and Shiraki R: Airborne respirable silica near a sand and gravel facility in central California: XRD and Elemental Analysis to distinguish source and background quartz: Environ. Sci. Technol. 2002)
When the data from the wind rose, previously deemed relevant by the would-be pit developers, is used together with the above fall-out data the predicted airborne dust exposure, so close in, is substantially more than is allowed in both existing and prospective UK National Air Quality Standard and European Directives (see National Air Quality objectives and European Directive limit and target values for the protection of human health - latest update)
Also the predicted level of dust exposure is many times greater than the 2 to 5 micrograms/m3 above background measured in the benchmark report previously cited as relevant by the applicants [Pless-Mulloli T et al - Living near open cast coal mining sites and children's respiratory health: Occup Environe Med 2000 March] (future test exposure of human subjects to hazardous airborne dust is unlikely on ethical grounds!)
Even this latter modest level of dust exposure was associated with a marked increase in GP consultations (over 40%). This was in a statistically significant group of young human subjects in normal health.
Concerning health it is to be noted that we both experience long standing health problems which could well be exacerbated by airborne quarry dust.
The applicants may well suggest 'mitigation measures' claimed to reduce the impact of their activities. There is however, scant independent scientific evidence of their effectiveness. The aggregates industry, however, have the resources to sponsor independent determinations of effectiveness through bone fide academic institutions if the outcome were likely to be to their advantage. There is little indication that they have done so.

The Planning and Environment Division of the Department of Communities and Local Government require that planning decisions entail careful consideration of the likely effects on the surrounding area and the views of local residents.
The health and welfare of their residents is the prime responsibility of all Local Authorities. Accordingly we ask that you give every consideration to allowing us to continue to live here in peace.
We look forward to your considered reply in due course.

Full text:

Proposed sand and gravel extraction at Waveney Forest
My wife Freda and I reside at Forest Lodge within Waveney Forest. Our house, possibly the nearest to the quarry, is positioned only some 120 metres from the nearest extraction site, the corner of our garden being 20 metres closer.
So positioned, it is evidence that we would be exposed to totally unacceptable environmental impacts from noise and airborne dust.
Some 24 years ago we both took early retirement partly on health grounds. We chose to live in the Waveney Forest, rather than to remain near our family in the midlands, because of the fresh air and unique tranquillity which it afforded. We therefore find the prospect of a noisy, dusty extraction site close to, and dominantly upwind of us particularly distressing.
The applicants have yet to provide the required independent quantitative determination of their expected noise emissions. However, even with a very conservative estimate of these, because of the extreme tranquillity of the site and the way noise impact is assessed (the quieter it already is the less additional noise is acceptable) (Guidelines for noise impact assessment 2002) the perceived sound level at Forest Lodge would be several times that represented by the 10dB threshold of the highest of the five impact categories - termed 'major' noise impact.
The likely level of airborne dust exposure at Forest Lodge may be inferred from statistically robust multiple determinations carried out over time near a sand and gravel facility (Holmen BA and Shiraki R: Airborne respirable silica near a sand and gravel facility in central California: XRD and Elemental Analysis to distinguish source and background quartz: Environ. Sci. Technol. 2002)
When the data from the wind rose, previously deemed relevant by the would-be pit developers, is used together with the above fall-out data the predicted airborne dust exposure, so close in, is substantially more than is allowed in both existing and prospective UK National Air Quality Standard and European Directives (see National Air Quality objectives and European Directive limit and target values for the protection of human health - latest update)
Also the predicted level of dust exposure is many times greater than the 2 to 5 micrograms/m3 above background measured in the benchmark report previously cited as relevant by the applicants [Pless-Mulloli T et al - Living near open cast coal mining sites and children's respiratory health: Occup Environe Med 2000 March] (future test exposure of human subjects to hazardous airborne dust is unlikely on ethical grounds!)
Even this latter modest level of dust exposure was associated with a marked increase in GP consultations (over 40%). This was in a statistically significant group of young human subjects in normal health.
Concerning health it is to be noted that we both experience long standing health problems which could well be exacerbated by airborne quarry dust.
The applicants may well suggest 'mitigation measures' claimed to reduce the impact of their activities. There is however, scant independent scientific evidence of their effectiveness. The aggregates industry, however, have the resources to sponsor independent determinations of effectiveness through bone fide academic institutions if the outcome were likely to be to their advantage. There is little indication that they have done so.

The Planning and Environment Division of the Department of Communities and Local Government require that planning decisions entail careful consideration of the likely effects on the surrounding area and the views of local residents.
The health and welfare of their residents is the prime responsibility of all Local Authorities. Accordingly we ask that you give every consideration to allowing us to continue to live here in peace.
We look forward to your considered reply in due course.