Comment
Preferred Options consultation document
Representation ID: 99012
Received: 30/10/2019
Respondent: Borough Council of King's Lynn and West Norfolk
Summary
We note the site is unsuitable for allocation because the site is within a Core River Valley.
M19.1 Amenity
The site has the potential to cause emissions of PM10 and PM2.5 which can affect the amenity and health of local residents.
The nearest residential property is 570m from the site. The settlement of Blackborough End is 2.7km away. Although adverse dust impacts are uncommon beyond 250m from dust generating activities, we would still expect a planning application to include a dust impact assessment along with appropriate mitigation measures where necessary to protect human health.
It must be ensured that the preparation or use of the site will not result in an exceedance of the national air quality objectives, or an AQMA may need to be declared.
M19.2 Highway Access
The site would use the existing access route along Common Road (a designated HGV access route) up to its junction with the A47. The site is not within an AQMA. As a proposed extension to an existing site, the number of vehicle movements is expected to remain the same but continue for a longer period. The estimated number of HGV movements is 30 (in and out) per day. Highway improvements along Common Road will be needed.
A transport assessment should be undertaken which includes the extended traffic flow along Common Road and takes into account air quality implications for local residents.
M19.18 Flood Risk
The site has a low probability of surface water flooding, with a few small locations of surface water pooling in a 1 in 100-year rainfall event. In a 1 in 1000-year rainfall event there are additional small areas of surface water pooling. The site is within the East of Ouse, Polver and Nar Internal Drainage Board area, so they would comment regarding any surface water drainage concerns.
M19.19 Hydrogeology
We have no concerns regarding groundwater contamination.
Environmental Quality and Community Safety and Neighbourhood Nuisance Comments on Mineral Site Specific Allocations October 2019
Summary:
If sites have to be progressed to the planning application stage, we would hope that sites furthest from residential dwellings are looked at primarily, as this could ensure that the impact on residential health and amenity is negligible. Clearly these sites would be preferred by us, if needed at all.
Submitted noise assessments and air quality/dust assessments should consider and include mitigation measures to deal appropriately with any potential health impacts, such as operational practices, separation/standoff areas and screening and/or bunding in line with Development Management Policies DM12 and DM13.
These allocated sites have been reviewed in line with Development Management Policies DM12, DM13, and DM15 as detailed within Norfolk Minerals and Waste Development Framework.
Lighting:
Lighting is not included in the document as this is generally something which can be considered at any proposed planning application stage; however we would hope that any proposed lighting for site security and worker safety would be carefully considered prior to the planning stage so details can be submitted with any planning application. We would assume lighting would be pole mounted in elevated positions, and therefore the throw and spread of this should be assessed to ensure that there is no impact on residents. Light should be contained within the confines of sites and positioned appropriately. If necessary lighting is located near dwellings, this should be angled away and hooded/cowled to prevent any adverse impact on residents.
Vibrations:
The potential impact from vibrations should also be considered at any future planning stage, if sites are chosen close to residential receptors - including vibrations from site operations and associated transportation of extracted materials.
Soil Stripping:
Soil stripping operations must be effectively controlled through mitigation methods (e.g. buffer zones and bunding) to reduce fugitive emissions, which pose short term health impacts on nearby residents. These mitigation measures must be included in any future planning application.
Haul Roads:
Fugitive emissions from haul roads need to be addressed in any future planning application, with mitigation planned where necessary such as wheel washing.
[see attached table for comments on individual sites]
Environmental Quality and Community Safety and Neighbourhood Nuisance Comments on Waste Site Specific Allocations October 2019
Summary:
If sites have to be progressed to the planning application stage, we would hope that sites furthest from residential dwellings are looked at primarily, as this could ensure that the impact on residential health and amenity is negligible. Clearly these sites would be preferred by us, if needed at all.
Any future applications for waste sites should be accompanied by noise, odour, dust, and air quality management schemes, which should identify potential sources and mitigation/control measures to prevent nuisance issues and health impacts (e.g. emissions from as gas flaring).
Where sites are likely to be illuminated for safety/security, lighting plans and details should also be submitted which should include where lights will be located, their heights and angle/orientation, the type of lighting and the throw and spill of light across the site, and measures to ensure light spill is contained within site boundaries.
These allocated sites have been reviewed in line with Development Management Policies DM12, DM13, and DM15 as detailed within Norfolk Minerals and Waste Development Framework
Existing Waste Site Specific Allocation Policies:
We note that WAS 05, WAS 25, WAS 36, WAS 40, WAS 37, WAS 45 and WAS 65 are no longer required and would therefore be deleted. There is therefore no risk to residential amenity from these sites.
Odour:
An odour impact assessment should be included within any future planning applications for allocated waste sites, along with suitable mitigation measures where appropriate.
Climate Change:
Climate change mitigation should be considered with regards to methane emissions (a greenhouse gas) released from allocated landfill sites.
[see attached table for comments on individual sites]