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HARWORTH AND TOWN COUNCIL Town Hall, Scrooby Road, Bircotes, DN11 8JP

25th September 2018

Mr M Hankin Development Control County Council Trent Bridge House Fox Road West Bridgford Nottingham NG2 8BJ

Dear Mr Hankin

Re Planning application: Reference: ES/3860 Proposed Development: The construction and operation of a new 20MWE Waste-to-Energy Power Generation Facility and associated Plant and External Works Location: Plots A5 and A6, Lords Wood Road, , DN11 8NW

Harworth & Bircotes Town Council strongly objects to the planning application ES/3860 for the reasons stated and outlined below:

Location and Existing Strategic Developments

1) The proposed development site lies within the Parish boundary of Styrrup and Oldcotes and sits on the border of the Town Boundary of Harworth & Bircotes. The location of the proposed development will impact significantly on the growth and regeneration plans for Harworth & Bircotes. This unequivocally contravenes Council’s (BDC) Core Strategy Policy CS1: Settlement Hierarchy which identifies Harworth & Bircotes as the main regeneration and growth settlement. The location of the proposed development is less than 200 metres from the Government designated housing zone which was given its status by the Government in 2015. The Housing Zone status is part of £3 million loan funding package by Homes . The proposed development has the potential to significantly undermine the whole vision and regeneration programme for the future growth of the Town as identified in the Bassetlaw District Council’s Core Strategy Policy CS4 which states: 2

“New development will contribute to a step change in Harworth Bircotes. It will deliver a greater range of local employment opportunities, with facilities that can attract inward investment and allow smaller businesses to grow. It will significantly improve the range and quality of housing available, in order to ensure a more mixed community”.

2) In addition to this, it also undermines the Harworth & Bircotes Neighbourhood Plan 2016 (NP) vision and aim that’s states:

Vision “In 13 years’ time Harworth & Bircotes will be a thriving community, a place where people are proud to live. It will be a safe and happy place, an area that values its people and its environment. It will have a variety of homes, jobs, shops, schools, sustainable transport and recreational facilities; something for everyone. Harworth & Bircotes will be a place people want to move to.”

Aim “The Neighbourhood Development Plan must take a positive approach to development so long as it brings forward a balance of housing, retail, community and leisure development to ensure Harworth & Bircotes becomes an attractive place, providing all the amenities you would expect in a desirable town. All development over the Plan period will maximise the environmental assets in and around Harworth & Bircotes where possible, improving access to the countryside and open spaces for residents and visitors”

It can be demonstrated that the proposed development does not meet the Core Strategy policy CS4 and the vision and aim contained within the NP.

3) The community took the time to undertake a NP which took over a year to complete. How does the proposed development deliver what the community wants? The Town Council believes that the proposed development contravenes the whole ethos of the NP and works against the hard work of both the community, Town Council and District Council policy documents. Harworth & Bircotes will not be an attractive place or a desirable place to live if this development is passed due to the perceived and actual impacts such as the visual impact and appearance of the facility with its 60m high chimney, the pollution, HGV movements and impacts on the regeneration programme for the town.

4) The Harworth & Bircotes Neighbourhood Plan Objective 1 states: To redevelop the old Colliery Site delivering a mixed-use development that benefits the local community now and for years to come and Policy 6 of the NP sets out the policy for the redevelopment of the former colliery site for the comprehensive redevelopment of site. The colliery site lies less than 200 meters away from the proposal site. If the proposed development goes ahead this has the potential to undermine the whole redevelopment of this strategic regeneration site due to the close proximity of the development and the health, noise and visual impact of the proposed development. As local residents have asked; “would you buy a new house so near to an incinerator?”

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Employment

5) The proposed development suggests that it will bring up to 38 jobs. However, three firms have already confirmed that they have put their extension proposals on hold and will look to close and relocate to other premises as the proposal will significantly harm their existing business. Therefore, for the sake of the creation of 38 jobs and the impact on the regeneration of the town as a whole is this proposal really worth it? In addition, to this the proposal does not comply with policy DM7 of the BDC Core Strategy as it states that:

“Particular support will be given to economic development proposals that are able to: a) harness the educational and research potential of North Nottinghamshire College; and/or b) guarantee employment programmes for local residents that provide opportunities or training and development and will contribute to raised workforce skills levels within the District; and/or c) deliver, or contribute to, opportunities for the growth of indigenous businesses; and/or d) bring significant, good quality inward investment opportunities to the District; and/or e) Support and utilise growth opportunities in connection with Robin Hood Airport. f) New employment allocations will be expected to deliver, or provide opportunities for the development of, starter units and grow on space for small and medium-sized enterprises.

Transport

6) The proposal will have a detrimental impact on the transport network in particular the junction on Snape Lane into Lords Wood. Cars double parked at present and how will lorries enter/exit safely with the existing traffic on the road?

7) The transport assessment suggests that there will be 70 HGVs trips per day and 58 two-way trips for lighter vehicles per day. These vehicles will be carrying 320,000 tons of waste per year. The suggested access routes to the site are along B roads, which one of them are used by local residents to access the A1/M, Worksop and Retford. The Town Council questions whether these B roads are sufficient to accommodate an extra 128 extra heavy vehicles per day?

Noise

8) The supporting information provided by the applicant suggests that the proposed development site will be operating 24 hours per day, 7 days per week, at a proposed minimum level of 78 decibels (dB) this is 8 dB over and above the recommended level of noise which is applicable to daytime working outside living rooms from 07.00 to 19.00 hours on weekdays, and 07.00 to 13.00 on Saturdays. This will affect and impact upon the lives of the local residents living and working nearby. Policy 1 Sustainable Development contained within the 4

NP suggested that any new development proposal should not significantly or adversely affect the amenity of nearby residents. Based on the information provided this development will significantly affect the peace and quiet and general quality of life for the existing and future local residents. This therefore, does not comply with NP policy 1: Sustainable Development Principles paragraph 2 a where it states that development will not be supported where it significantly and adversely affects the amenity if the nearby residents.

9) Policy WCS13: Protecting and enhancing our environment of the Nottinghamshire County Council Waste Core Strategy 2013 states that “ New or extended waste treatment or disposal facilities will be supported only where it can be demonstrated that there would be no unacceptable impact on any element of environmental quality or the quality of life of those living or working nearby and where this would not result in an unacceptable cumulative impact” As demonstrated throughout this objection letter the proposed development has the potential to create unacceptable living conditions for local residents due to the close proximity to the town.

Pollution from Emissions

10) The pollution and emissions from the refuse derived fuel originating from municipal, commercial and industrial waste has the potential to be released into the atmosphere as it is not clear how the pre-treatment process will remove all elements such as, lead, paint, arsenic from the non–virgin waste being released into the atmosphere. Due to the 60m high chimney stack this also means that the pollution released from the chimney will be widely dispersed potentially affecting local resident’s health and impacting negatively on the local landscape and biodiversity.

Visibility Impact

11) The proposed development is of a significant scale and mass, the building itself is 30m high, with a 60m high chimney. The building will dwarf nearby business units, and be highly visible from the surrounding villages.

Sustainability

12) Paragraph 8 of the National Planning Policy Framework states that “Achieving sustainable development means that the planning system has three overarching objectives:

1. an economic objective – to help build a strong, responsive and competitive economy, by ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity; and by identifying and coordinating the provision of infrastructure;

2. a social objective – to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering a well-designed and safe built environment, with accessible services and 5

open spaces that reflect current and future needs and support communities’ health, social and cultural well-being; and

3. an environmental objective – to contribute to protecting and enhancing our natural, built and historic environment; including making effective use of land, helping to improve biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change, including moving to a low carbon economy”.

The proposal does not meet the NPPF’s economic, social or environment objectives listed above as it has a detrimental effect on the existing economy (as stated in point 5 of this objection) and has the potential to stop any future economic development taking place on the employment land to the south of the site on Blyth Road. It is not clear whether the applicant has done a sequential test looking at any alternative sites in Nottinghamshire however, the Town Council believes that there may be more suitable sites and locations for this development as the proposed site on the edge of Harworth & Bircotes is not appropriate.

Effect on Township

13) The existing strategy in place as set out in the BDC Core Strategy and NP was subjected to vigorous community consultation that was commended by the examiner and the BDC Core Strategy started consultation in 2009 and was agreed and adopted in 2011. Why should this development be allowed when it is not in compliance with any National, County, District or Neighbourhood Plan?

Public Consultations

14) In the applicant’s submission it suggests that public consultation would be undertaken with District and County Councillors once the application was submitted. At no point was the Town Council, District or County Councillors contacted by the applicant or the agent. However, the Town Council, District and County Councillors held the consultation events listed below:

 Drop in session, 25th August, 3pm – 7pm, over 100 residents attended  Drop in session, 13 July, 10am – 2pm, over 150 residents attended  Public meeting, 3rd September 7pm approximately 300 residents attended  Business meeting, 19th September, 5.30pm, 12 business attended  All households and businesses were informed about the proposed development by a flyer.

The Executive Officer of Harworth & Bircotes Town Council wrote to the applicant Mr Mycock and asked if he would like to attend the public meeting on the 3rd September 2018. Mr Mycock did accept the invitation to attend the meeting. To the Town Council’s knowledge this is the only consultation that has been attended by the applicant. To the Town Council’s knowledge, no further consultation has been undertaken by the applicant.

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15) The proposed development in its entirety and the manner in which the applicant has not undertaken any consultation with local residents does not comply with Strategic Objective S03 Community well-being of the Nottinghamshire County Council Waste Core Strategy which states “protect local amenity and quality of life from the possible impacts of waste management such as dust, traffic, noise, odour, visual impact etc. and address local health concerns. Make sure that local people have the chance to be involved in decisions about new waste management facilities by providing more information, encouraging wider involvement and targeting key groups or individuals where appropriate”

In summary the Town Council strongly objects to the proposed development as the potential impacts of this development will mean the regeneration strategy as identified and planned for in the BDC Core Strategy 2011 and NP 2016 will not be delivered and the whole ethos of the planning policy framework set by the NP and BDC is undermined and jeopardised by one unplanned proposed development on the edge of the Town. In addition to this, the development also does not comply with the Nottinghamshire County Council Waste Core Strategy as it negatively impacts on the traffic, noise, odour, visually and also raises concerns for existing and new residents in terms of the health implications.

Yours Sincerely

Mrs W Davies

Mrs W Davies Officer On behalf of Harworth & Bircotes Town Council

Tel: 01302 759037 Email: [email protected]