Object
Initial Consultation document
Representation ID: 91927
Received: 01/08/2018
Respondent: Fritton Action Rescue Group
If the quarry is permitted there is robust scientific evidence # (drawn from bona fide scientific journals subject to peer review) to show that many mainly elderly villagers, some with existing respiratory problems, will be exposed to wholly unacceptable, dangerous levels of airborne quarry dust. Also if the forest is allowed to continue the carbon sequestered would allow the minerals to be road hauled many, many miles from more suitable site on a lower carbon budget.
Recent national concerns about the harmful effects of breathing airborne particulates together with revised standards for air quality have prompted our Action group to reappraise available scientific data on pit generated dust plumes.
Consideration of California University's statistically robust study near a sand and gravel facility (Appendix 1) yields the PM10 dust fall-out plot shown in Figure 1 (left hand half). It is to be noted that the furthest data point is only 745 metres from source.
Quite extraordinarily the applicants themselves cited the Benchmark study (Using human test subjects and unlikely to be repeated on ethical grounds) which covered exactly 800 to 1400 metres from source (Appendix 2). See PM10 dust fall-out plot figure 1 (right hand half). It is notable that, as might be expected, the two halves of figure 1 are entirely consistent with each other forming the classical dust fall-out plume, akin to that of a major meteorite impact, volcanic eruption or nuclear detonation, albeit on a much smaller scale. That these independently sourced plots are consistent is a very strong indication of their scientific validity. Consideration of the left hand half of figure 1 indicates that properties within 300 metres of the proposed pit will be exposed to PM10 dust concentrations of over 40 micrograms/m3, being in excess of European limits.
It is probable that at greater distances the remaining airborne dust concentration will comprise mainly of particles up to PM2.5, originally contained within the initial PM10 concentration. The heavier factions, as the applicants rightly state, will already have fallen out as 'nuisance dust' in a comparatively short distance down range, leaving the smaller particles to dominate both gravimetrically and (more health critically) numerically vastly so - Figure 2. This being so the max allowable limit of 25 micrograms/m3 for airborne PM2.5 shortly to come into force* indicates that properties within some 500 metres of the proposed pit will be exposed to airborne dust concentrations in excess of U.K and European limits.*
*National air quality objectives and European Directive limit and target values for the protection of human health.
It now seems appropriate to go on to review the right hand half of Figure 1. Before this can be done, however, a number of issues must be considered. The wholly siliceousious dust from the Fritton pit is unlikely to be any less harmful to the exposed Fritton residents than the dust from the open-cast coal workings was to the exposed test subjects of the Newcastle University study.
Although the open-cast dust incorporates a carboniferous faction as well as the faction generally attributable to siliceousious overburden # both factions are likely to be similarly hazardous, having mutually consistent air dispersal characteristics with both Carbon and Silicon atoms having six electrons in the outer shell where, for reactivity, it counts. Breathing airborne dust will have a much greater impact on exposed Fritton residents many of whom are elderly, some with respiratory problems, than on the young healthy test subjects of the Newcastle University study. In the latter study customary mitigation measures to limit dust emissions at source would be required for a realistic outcome and to accord with Coal Authority recommendations. #Winning coal from open cast mines generally entails the excavation of significant tonnages of siliceousious overburden to ensure safety and stability. Depending on the price of coal this may range up to twenty times the tonnage of coal extracted:- H.M Dept. of Business Energy and Industrial Strategy (Coal Authority - Mines Licensing Dept.)
The right hand half of Figure 1 shows a PM10 concentration only a few micrograms/m3 above background. Despite this all determinations from 750 up to 1,400 metres from source were associated with an increase in respiratory related G.P. consultations of some 40% (Appendix 2). Placed within the context of the proposed Fritton quarry, assuming the applicants worked to the edge nearest to a given human receptor, which they would be entitled to do, the zone in which a markedly increased level of respiratory related G.P. consultations would be expected is as shown in Figure 3 (in-hatched portion). This includes a significant part of neighbouring St. Olaves. G.P. consultations could substantially exceed 40% because of the vulnerability of the mainly elderly population. Over 400 people reside within this zone. Even if, as an extreme measure of mitigation, the applicants were to work only a 100 metre wide strip on the edge of the site furthest from a given receptor, the zone of expected marked increased G.P. consultations would be shown in Figure 4 (un-hatched portion). Nearly 200 people reside within this zone. If the applicants were to work more than this the hazardous zone would be proportionately larger.
The Planning Environmental Division of H.M. Communities Dept. recognise that mineral extraction has an environmental impact and that planners should give very careful consideration to its likely effects on the surrounding area - and the views of local residents. Also L.A.s are now responsible for both the health and well being of their residents. Accordingly we ask that you reject the proposed application, amongst other reasons, to protect our mainly elderly, vulnerable, residents from dangerous levels of airborne particulates.
Also note that if the forest continued intact the carbon sequestered by the trees would enable the same mineral yield to be fetched many, many, miles by road from a more suitable site on a lower carbon budget!
If the quarry is permitted there is robust scientific evidence # (drawn from bona fide scientific journals subject to peer review) to show that many mainly elderly villagers, some with existing respiratory problems, will be exposed to wholly unacceptable, dangerous levels of airborne quarry dust. Also if the forest is allowed to continue the carbon sequestered would allow the minerals to be road hauled many, many miles from more suitable site on a lower carbon budget.
Recent national concerns about the harmful effects of breathing airborne particulates together with revised standards for air quality have prompted our Action group to reappraise available scientific data on pit generated dust plumes.
Consideration of California University's statistically robust study near a sand and gravel facility (Appendix 1) yields the PM10 dust fall-out plot shown in Figure 1 (left hand half). It is to be noted that the furthest data point is only 745 metres from source.
Quite extraordinarily the applicants themselves cited the Benchmark study (Using human test subjects and unlikely to be repeated on ethical grounds) which covered exactly 800 to 1400 metres from source (Appendix 2). See PM10 dust fall-out plot figure 1 (right hand half). It is notable that, as might be expected, the two halves of figure 1 are entirely consistent with each other forming the classical dust fall-out plume, akin to that of a major meteorite impact, volcanic eruption or nuclear detonation, albeit on a much smaller scale. That these independently sourced plots are consistent is a very strong indication of their scientific validity. Consideration of the left hand half of figure 1 indicates that properties within 300 metres of the proposed pit will be exposed to PM10 dust concentrations of over 40 micrograms/m3, being in excess of European limits.
It is probable that at greater distances the remaining airborne dust concentration will comprise mainly of particles up to PM2.5, originally contained within the initial PM10 concentration. The heavier factions, as the applicants rightly state, will already have fallen out as 'nuisance dust' in a comparatively short distance down range, leaving the smaller particles to dominate both gravimetrically and (more health critically) numerically vastly so - Figure 2. This being so the max allowable limit of 25 micrograms/m3 for airborne PM2.5 shortly to come into force* indicates that properties within some 500 metres of the proposed pit will be exposed to airborne dust concentrations in excess of U.K and European limits.*
*National air quality objectives and European Directive limit and target values for the protection of human health.
It now seems appropriate to go on to review the right hand half of Figure 1. Before this can be done, however, a number of issues must be considered. The wholly siliceousious dust from the Fritton pit is unlikely to be any less harmful to the exposed Fritton residents than the dust from the open-cast coal workings was to the exposed test subjects of the Newcastle University study.
Although the open-cast dust incorporates a carboniferous faction as well as the faction generally attributable to siliceousious overburden # both factions are likely to be similarly hazardous, having mutually consistent air dispersal characteristics with both Carbon and Silicon atoms having six electrons in the outer shell where, for reactivity, it counts. Breathing airborne dust will have a much greater impact on exposed Fritton residents many of whom are elderly, some with respiratory problems, than on the young healthy test subjects of the Newcastle University study. In the latter study customary mitigation measures to limit dust emissions at source would be required for a realistic outcome and to accord with Coal Authority recommendations. #Winning coal from open cast mines generally entails the excavation of significant tonnages of siliceousious overburden to ensure safety and stability. Depending on the price of coal this may range up to twenty times the tonnage of coal extracted:- H.M Dept. of Business Energy and Industrial Strategy (Coal Authority - Mines Licensing Dept.)
The right hand half of Figure 1 shows a PM10 concentration only a few micrograms/m3 above background. Despite this all determinations from 750 up to 1,400 metres from source were associated with an increase in respiratory related G.P. consultations of some 40% (Appendix 2). Placed within the context of the proposed Fritton quarry, assuming the applicants worked to the edge nearest to a given human receptor, which they would be entitled to do, the zone in which a markedly increased level of respiratory related G.P. consultations would be expected is as shown in Figure 3 (in-hatched portion). This includes a significant part of neighbouring St. Olaves. G.P. consultations could substantially exceed 40% because of the vulnerability of the mainly elderly population. Over 400 people reside within this zone. Even if, as an extreme measure of mitigation, the applicants were to work only a 100 metre wide strip on the edge of the site furthest from a given receptor, the zone of expected marked increased G.P. consultations would be shown in Figure 4 (un-hatched portion). Nearly 200 people reside within this zone. If the applicants were to work more than this the hazardous zone would be proportionately larger.
The Planning Environmental Division of H.M. Communities Dept. recognise that mineral extraction has an environmental impact and that planners should give very careful consideration to its likely effects on the surrounding area - and the views of local residents. Also L.A.s are now responsible for both the health and well being of their residents. Accordingly we ask that you reject the proposed application, amongst other reasons, to protect our mainly elderly, vulnerable, residents from dangerous levels of airborne particulates.
Also note that if the forest continued intact the carbon sequestered by the trees would enable the same mineral yield to be fetched many, many, miles by road from a more suitable site on a lower carbon budget!