Comment
Preferred Options consultation document
Representation ID: 99023
Received: 30/10/2019
Respondent: Borough Council of King's Lynn and West Norfolk
Summary
We note that the site is considered to be unsuitable for allocation due to the size of the extraction site proposed and the proximity to RAF Marham, posing a high risk of unacceptable adverse impacts on aviation safety.
S2.1 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 81m from the site boundary. There are 10 sensitive receptors within 250m of the site boundary. The settlement of Marham is 430m away. I note the land nearest to Marham is not proposed to be extracted and there is a suggested buffer area around the rest of the site boundary. Therefore, the nearest residential property is 280m from the extraction area and there are no sensitive receptors within 250m of the proposed extraction area. We would still welcome noise dust and air quality assessments with mitigation measures as appropriate.
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.
S2.2 Highway Access
I note the proposer of the site has suggested that mineral could be transported to the processing plant at Leziate by pipeline, although the proposed route of the pipeline has not been provided. The HGV route to the processing plant at Leziate would involve crossing the River Nar requiring measures to mitigate potential silt ingress into the watercourse. I also note it is unlikely that existing highways between the site and the processing plant could be suitably improved, so the construction of an off-highway haul route would probably be necessary. Careful planning of the route and a subsequent transport assessment would be required to avoid any adverse health impact on residents, taking into account air pollution and dust from haulage.
S2.17 Flood Risk
The area has a low risk of surface water flooding with a few locations of surface water pooling, mainly in the south of the site, in a 1 in 30-year rainfall event. There are additional locations of surface water pooling in a 1 in 100-year rainfall event. The number of locations of surface water pooling increase significantly in a 1 in 1000-year rainfall event and there are a number of surface water flow paths in the southern part of the proposed area. We would welcome the submission of a surface water drainage scheme with any planning application, which can also be assessed by the East of Ouse, Polver and Nar IDB as the site lies within their area.
S2.18 Hydrogeology
The site is located over a principal aquifer (bedrock) and partially over a Secondary A aquifer (superficial deposits). The eastern part of the site is within groundwater Source Protection Zone 1, however, I note this has been excluded from the proposed extraction area. The rest of the site is not within a groundwater SPZ. I note the Environment Agency have stated that the site would need to be worked wet without any dewatering and that the proposer of the site has indicated that extraction could be via wet suction dredging. Any planning application would need to include a Hydrogeological Risk Assessment to identify any potential impacts to groundwater along with appropriate mitigation measures
S2.19 / S2.20 / S2.21 / S2.24 Water Framework Directive
The Nar is adjacent to part of the northern boundary of the site. As the site proposers have submitted a smaller extraction zone providing a standoff area between the proposed extraction and the River Nar, there is no potential impact to the Nar. The Fourteen Foot Drain bisects the proposed extraction area, flowing eastwards into the Polver Drain which in turn flows into the Relief Channel. We welcome any future planning application carrying out an assessment of the potential for impacts on these waterbodies, and identifying appropriate mitigation to prevent unacceptable adverse impacts. With the groundwater level in mineral workings in this area being several metres below ground level, we agree that the screening bunds forming part of mineral extraction sites would form a barrier preventing any flow moving down slope until infiltration took place. In the same vein, the proposed standoff area between the extraction area and the embankment would also provide an opportunity for any flows to infiltrate. We welcome the submission of a dust assessment with any planning application.
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]