Comment
Preferred Options consultation document
Representation ID: 99019
Received: 30/10/2019
Respondent: Borough Council of King's Lynn and West Norfolk
Amenity
The site has the potential to cause emissions of PM10 and PM2.5 which can affect the health and amenity of local residents.
The area of search covers 815 hectares within the parishes of Wormegay, Shouldham, Marham and Shouldham Thorpe. The nearest residential property is approximately 250 metres from the AOS boundary. The settlements of Shouldham and Wormegay are 250 metres from the boundary of the AOS. A planning application for mineral extraction within AOS E would need to include noise and dust assessments along with mitigation measures to deal appropriately with any amenity or health impacts from noise and dust.
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.
E.1 & E.2 Highway Access
The route from the AOS to the Leziate processing plant would be expected to be north along A134 and A10 and A149, before turning east onto the B1145. From the B1145 the preferred access to the Leziate processing plant would be an off-road route turning right off the B1145 before Bawsey and utilising the existing track and/or conveyor route through the existing mineral workings at Mintlyn to access Station Road and the processing plant south of Brow of the Hill. Utilising an off-road haul route would avoid lorries accessing the processing plant via Brow of the Hill, Fair Green or Middleton and would therefore mitigate amenity impacts, so this is something we would welcome, assuming there would be no negative impact on residents from the off-road route.
To establish this, a transport assessment should be conducted which includes air quality impacts including dust from haulage. Additionally the cumulative air quality impacts of AOS F, AOS I and AOS J along the A10, A149, A134 and B1145 need to be established.
E.15 Flood Risk
7% of AOS E is at low risk of flooding from surface water and 2% is at medium or high risk of flooding from surface water. The AOS is within the 'East of Ouse, Polver and Nar' Internal Drainage Board Area who would provide comment on the surface water drainage scheme we would expect to be submitted with a planning application.
E.16 Hydrogeology
If extraction below the water table and/or dewatering is proposed, we would expect a Hydrogeological Risk Assessment identifying potential risks and appropriate mitigation to be submitted with any planning application.
E.17 Water Framework Directive
The northern part of the AOS drains to the River Nar so a future planning application will need to assess the potential for impacts on the River Nar, including from silt ingress and modification, and propose appropriate mitigation to prevent unacceptable adverse impacts.
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]