Comment

Preferred Options consultation document

Representation ID: 99022

Received: 30/10/2019

Respondent: Borough Council of King's Lynn and West Norfolk

Representation Summary:

J.1 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 nearest residential property is approximately 250 metres from the AOS boundary and the settlement of Tottenhill is less than 300 metres from the boundary of the AOS. We would welcome the submission of noise and dust assessments, including mitigation measures to deal appropriately with any amenity or health impacts, with any planning application.
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.

J.2/J.3 Highway Access
Access from AOS J could be via the southern track onto the A134. A dedicated access could also be created to the A134, or the A10 to the west. Such routes to the main roads should consider the proximity of residential receptors and provide appropriate mitigation from noise and dust. Sand extracted would be taken to the processing plant at Leziate, access to which 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.
Additionally we welcome the requirements listed within Policy MP13 that a transport assessment is submitted along with a comprehensive phased working scheme to mitigate cumulative emissions from the extraction of AOS E, AOS F, AOS I, and AOS J.

J.13 Flood Risk
9% of AOS J is at low risk of flooding from surface water, 4% is at medium risk and 1% is at high risk of flooding from surface water. There is an area of surface water pooling in a 1 in 30-year rainfall event, which increase in size in a 1 in 100-year rainfall event and a 1 in 1000-year rainfall event. There is also a surface water flow path through the AOS in a 1 in 1000-year rainfall event. We would welcome the submission of a surface water drainage scheme with any planning application

J.14 Hydrogeology
Proposed extraction below the water table and/or dewatering should be accompanied by a hydrogeological risk assessment to identify potential risks and appropriate mitigation

J.15 Water Framework Directive
Mineral extracted from AOS F likely to be transported by road to the existing processing plant at Leziate, will have to cross the Polver Drain on the A10 at Setchey. Appropriate mitigation should be put in place to ensure that no unacceptable impacts to the drain or the river occur, including from silt ingress and fugitive dust emissions. A dust assessment would also be required at the planning application stage.

Full text:


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]