Comment
Preferred Options consultation document
Representation ID: 99014
Received: 30/10/2019
Respondent: Borough Council of King's Lynn and West Norfolk
Summary
We note that the site is unsuitable for allocation due to the loss of a significant area of mature mixed deciduous woodland.
M77.1 Amenity
The site has the potential to cause emissions of PM10 and PM2.5 which can affect the amenity and health of local residents.
There is only one sensitive receptor within 250m of the site boundary, which is located 79m away. The settlement of Watlington is 368m away and Tottenhill is 414m away. We would require any planning application for mineral extraction at this site to include noise, dust, and air quality assessments, along with mitigation measures to minimise harmful emissions to air and address appropriately any human health or amenity impacts.
The control and mitigation of dust at this site should be discussed between the operator and the LA Environmental Health Department before an application is submitted. Matters that may need to be explored are:
* the existing dust climate at the locality;
* the need for, and scope of, a dust assessment study to be conducted by the operator prior to a detailed design.
* the potential for different site activities to emit dust and their relationship to residential properties and other sensitive uses;
* how the layout of the site could minimise impacts; and the proposed methods of mitigation and control of dust generating activities such as buffer zones.
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.
Boundary dust measurement may need to be conducted, due to the close proximity of residential properties to the proposed site, to ensure there are no breaches of national air quality objectives.
Without appropriate mitigation of air pollution from the site, human health could be impacted, thus making the site allocation unsuitable.
We welcome the comment in M77.3 that the Tottenhill sites would be worked sequentially to mitigate any cumulative impacts.
M77.2 Highway Access
The site would access the existing plant site via conveyor using the existing quarry access along Watlington Road for about 150 metres before reaching the roundabout for the A10/A134 (a designated lorry route). 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 40 per day.
Therefore a transport assessment should be undertaken which includes the extended traffic flow along Watlington Road and takes into account air quality implications for local residents as part of a planning application.
M77.14 Flood Risk
The site has a low risk of surface water flooding. There is a surface water flow path along the southern boundary of the site in a 1 in 30 year rainfall event which increases in size in a 1 in 100 and 1 in 1000 year rainfall event. As this is likely to be a proxy for fluvial flooding from the adjacent ordinary water course and the site is within the East of Ouse, Polver and Nar Internal Drainage Board area, their comments should be sought at any planning application stage.
M77.15 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]