Headon-cum-Upton, Grove and Parish Council NCC RECEIVED 11/9/2017

Mike Hankin Planning Services County Council County Hall Loughborough Road NG2 7QP 6th Sep 2017

Dear Mr Hankin,

Ref F/3696 Waste to Energy Assets Ltd.

Application for the Continued Use of the Existing Industrial Site and Buildings for the Production of a Range of Wood Fuel Products and for the Importation and Processing of Wastes to Produce a Range of Recovered Fuel Products. Land at Headon Camp Industrial Estate, Lady Well Lane, Headon, , DN22 0PA

After studying the plans and considering all communications received on the matter. The Parish Council met to discuss the Planning Application as statutory consultees. The Council voted whether to approve or object to the planning application, the result of the vote was unanimous, a strong objection to the development.

The reasons for the Parish Council’s Objection are:

Adverse effect on Highway Safety & Convenience of Road Users The main road, Lady Well Lane, will become dangerous to walkers, and other road users with the increased amount of lorry and other traffic visiting the development. The Road is on a hillside, with blind areas and dips, there have been numerous accidents and fatalities in the area. The increased traffic will increase the risk of further accidents and loss of life. Further, any lorries deviating from the proposed route will take the easier option through Headon village. The main route through the village has no pedestrian footpaths, villagers are forced to walk on the road. This is far from an ideal situation.

Adverse effect on Immediate Residential Neighbours There are several residential properties located in very close proximity of the development, particularly Damson Croft, Ladywell Bungalow, who have concerns that they can no longer enjoy and use their gardens, are unable to hang washing out, or open windows, due to the amount of smoke, smell and dust polluting their properties. There have been reports of sore throats headaches and the smells penetrating inside local homes. These properties will also be affected by noise and vibrations from fork lift trucks, plant machinery with metal buckets which bang and scrape along the concrete yard floor, noise from lorries and workers vehicles. There will also be air pollution increases to the local residents emitted from the diesel lorries and plant equipment used. Local residents have a massive concern regarding air quality and fear for their health living so close to the operations. Bassetlaw LDF Policy DM1 requires that rural development should be on a scale, design and form appropriate for its setting and location, and compatible with surrounding land uses. Also, that it should not create environmental or highway safety problems, in line with paragraphs 120 and 123 of NPPF. Policy DM4 states that new development should not have a detrimental effect on residential amenity.

The local residents wish to draw your attention to the Nottinghamshire Waste Core Strategy Policy WCS13, which reads: “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”. Local residents believe that the development will infringe this strategy.

The immediate neighbours also fear that the plans involve large, ugly buildings which may cause loss of privacy, overshadowing, and overlooking their properties. That the development has a negative visual impact which is not in keeping with the character of the surrounding area and wider neighbourhood. The full extent of the plans, if built, will be overbearing and out of scale in terms of its appearance with the existingNCC RECEIVED development. 11/9/2017

Adverse effect on Village Road Safety The Council has severe concerns for the increased volumes of traffic and insists that the lorries avoid driving through the villages of Headon, Upton and Nether Headon. The Council received promises from the site owners during a site visit in February 2017, that the lorries would stick to the main roads, which would involve approximately 20 large articulated lorries per day, at a rate of one every 20 minutes, entering from the East, on Hazelwood lane (via Rampton/Woodbeck crossroads), having travelled as far as possible on the A1. However, these promises have been disregarded. Council members, together with members of the public have witnessed lorries driving unnecessarily through the villages. The lorries have also been witnessed travelling from Retford towards Headon. The Council finds this to be totally unacceptable because the roads through the villages are very small, almost single track in places with tight bends, it causes highway safety issues to walkers, children and vehicle drivers. The local villages have quite a number of equestrian properties whose horse riders use the road.

The Council and local public are concerned that the operators may disregard the requirements of the Notts County Council Transport Statement dated July 2017, which says that the maximum number of lorry movements shall not exceed 20 (10 in and 10 out) in any one day, whose gross vehicle weight shall not exceed 26 tonnes and that the villages of Headon and Nether Headon shall be avoided. The Council have evidence of the disregard for the avoidance of the village so have no faith that the other causes of the Transport Statement shall be obeyed. The volume of materials mentioned in the application are way beyond the capacity of 10 lorries per day to import.

Adverse effect on the wider community When the proposed 164 boilers with 41 chimneys go into operation and the site reach maximum capacity, the problems and concerns currently affecting the immediate residential neighbours will be expanded to cover the surrounding villages. The parish will be plagued by foul smells, dust caused by waste transference on site, health concerns potentially affecting hundreds of people due to possible noxious/carcinogenic particles in the atmosphere from the processing of plastics, textiles and non-virgin wood. The Council have a concern over a vast increase in noise and vibrations which will affect Headon.

Adverse effect on a Listed Building The Lady Well is a grade II listed building, a red brick archway set over a spring into the bankside with a stone sill and projecting stone trough is located opposite the proposed development at the base of the bankside next to the main road. This road will be used by the heavy lorries visiting the site daily and may cause damage to the listed building.

Adverse effect on Protected Species The public have witnessed bats flying around the Headon Camp Industrial estate for many years. It is believed that the bats nest in buildings next to the proposed development. The Parish Council requests that you insist that the applicant commissions an appropriate survey, the results of which should be taken into account when deliberating on the planning application.

The Council notes that an air quality assessment was carried out, however, because it has not considered the impact on the protected flora of the protected road verges of Headon and the special scientific site of Headon/Gamston Wood a further assessment of air quality on these sites must be carried out.

Chimney Height The Council is concerned that the chimney heights may be too low to affectively maximise the dispersion of the smoke. There are no particulate or gas scrubbers on the existing or proposed chimneys which may cause increased air pollution. The topography of the area does not lend itself to the dispersion of pollutants.

Change of Criteria & Trading Names Areas of the site concerned were formally covered by commercial planning consent for metal fabrication, however the waste recycling is a change of use. The Council is concerned that the applicant may not have a valid licence to operate from the Environment Agency. Local searches carried out in September 2016 show that Plot 1 of the site was licensed to the former North Notts Trucks site as a 75kte Vehicle Depollution site (copy documents enclosed). The Council urges the Planning Department to carry out checks to ascertain whether a new licence was obtained by the applicant. Residents have approached the Parish Council to highlight concerns that the former Stratton Engineering Ltd property, which is the larger building on site, recently had an extension built, with chimneys erected, these began operating in April 2017, potentially without the appropriate planning permission. The Council urges that you investigate this. NCC RECEIVED The trading name seems to be causing confusion, firstly it was referred to as Attero Ltd, then Retford Waste11/9/2017 to Energy Ltd and now Waste to Energy Assets Ltd. The current operations undertaken on site the Council has been told are based upon limited ‘historic’ planning permission. Our District Councillor is of the opinion that because planning permission and policy can and should change with time, is it not true that that if applied for today the use would not be approved.

Abatement Notice Breaches Concerns from the Environmental Health Department resulted in the issuing of an abatement notice to stop operations on site. The public have witnessed 11 chimneys operating illegally during the last week of August, which caused smoke to cover the surrounding area including the whole field behind the plant.

Boiler Fuel Health & Safety Dist Cllr Critchley brought to the Council’s attention in January 2017 concerns regards large quantities of engine oil would be imported as fuel for the burners. Cllr Critchley wished to know if the oil would be appropriately stored and bunded in a safe manner to prevent pollution of water courses, water mains and the foul & surface sewers. The Council is also concerned that the burning of this fuel will cause emissions hazardous to health. Additionally, power on site is supplied from a very large diesel generator, the Council has concerns that the smoke emissions from the generator are hazardous to the health of local residents. Local residents fear that the proposed plans will increase the operation times of the generator, which already causes a lot of vibration and noise at its current operating levels.

Potential Fire Hazard There have been two serious fires at this site previously, involving recycling plastic dustbins, where clouds of black smoke and noxious fumes enveloped the area. There was also a serious fire at Walesby in September 2016 involving plastic waste which was allowed to burn for weeks, engulfing the nearby villages and even reaching as far our Parish. Apart from reassurance on the applicant’s procedures for preventing fires, the Council want to see that the fire authorities have been consulted before any planning permission is granted and we also want to see a requirement imposed on the company to keep the fire brigade updated on exactly what materials are on-site.

National Planning Policy Framework & The Bassetlaw Local Development Framework The Parish Council would like to draw your attention to the National Planning Policy Framework (NPPF) paragraph 28 and Bassetlaw Local Development Framework (LDF) Policy DM1 which supports sustainable economic growth in rural areas, including the diversification of agricultural businesses, provided the scale, design and form is appropriate for its location and setting and compatible with surrounding land uses.

Policy DM1 also identifies that any diversification shall not create environmental or highway safety problems, in line with paragraphs 120 and 123 of NPPF. Policy DM4 of the LDF also states that new development should ensure that it does not have a detrimental effect on residential amenity. The close proximity of the development to residential properties and nature of operations will impact detrimentally on local residents and will be exacerbated with any intensification of the business. The Council believes that the planning application is therefore in contrary to the policies of the NPPF and LDF.

Yours sincerely,

Ed Knox Clerk to – Headon-Cum-Upton, Grove & Stokeham Parish Council

Cc County Councillor – John Ogle District Councillor – Teresa Critchley Environmental Health Team Leader – Amy Ogden

Enc Photographic supporting evidence. Local Searches Results Sep 2016

NCC RECEIVED 11/9/2017

Grade II Listed Building – The Lady Well

NCC RECEIVED 11/9/2017

Example of a delivery lorry driving unecessaril through Nether Headon, witnessed by Cllr Browne who followed it to the Waste to Energy Ltd site on 22nd May 2017.

The existing site at present causing smoke around the area taken from the garden of residential property Damson Croft NCC RECEIVED 11/9/2017

Close up of the existing building NCC RECEIVED 11/9/2017 NCC RECEIVED 11/9/2017