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1 the Stables, Boathouse Farm, Isfield, Uckfield, East Sussex TN22 5TY

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1 the Stables, Boathouse Farm, Isfield, Uckfield, East Sussex TN22 5TY The Stables, Boathouse Farm, Isfield, Uckfield, East Sussex TN22 5TY Katie Rainer Planning Officer County Hall, St Anne’s Crescent Lewes Sussex BN7 1 UE November 27 2016 Dear Katie Re: Application WD/782/CM KPS. I am writing with respect to the application submitted by KPS to increase processing of wood waste from 5k to 10k tonnes per annum while remaining within its 50k tonne annual limit, seeking retrospective permission for movement of earth bunds and for site reorganisation to accommodate expansion of wood waste processing and storage facilities. Objections are lodged as follows. 1 Community Involvement WMP Policy 20 Under WMP Policy 20 the Applicant is required to demonstrate community involvement in developing the scheme for which permission is being sought. Paragraph 1.13 of the Planning Statement says: ‘In consultation with local residents it is proposed to relocate the waste wood operation to the existing concreted yard area to the north of the storage building and to the east of the green waste composting area and adjoining balancing ponds...and to provide scope to increase the amount of wood waste and wood chip material which can be stored while awaiting transportation.’ 1.1 No formal consultation has taken place with the community. One self-initiated fact finding site visit was made by a group of about 15 residents in December 2015. This group does not act in any formal consultative capacity on behalf of the local community. It is trying to fill a vacuum caused by communication problems with all the agencies involved in this site. Those who visited wanted to see the operating environment and to raise major concerns about impact of noise, visual blight, foul smell and traffic control. At that meeting the site manager, when asked, made it clear that the intention was to apply for permission to expand wood waste processing at the site by up to 20,000 tonnes extra through put per year. He described a programme of expansion to produce more product for biomass boilers and in due course to supply the local grid with energy. The applicant has not - despite assurances that they would - communicated since the December 2015 meeting with the group who visited. There has been no public exhibition in the village explaining site development plans, no offer to attend a PCC meeting, nor invitation to residents to develop these plans. 1 2 Breaches of planning permission and monitoring of licence. 2.1 There is pattern and history of retrospective planning permissions being granted at this site which have enabled repeated intensification of activity without development controls or conditions to mitigate against the negative impact felt locally. Delegated decision making has been relied on in the past. Local residents have not been notified of planning applications regularly or in a timely manner. 2.2 The current application states that part of the earth bund has already been re-positioned and that retrospective permission is sought for this work on the grounds that trees on the bund should be moved in the growing season . Specialists agree that trees should be moved during the dormant season (October- March). 2.3 The current location of wood waste processing has been in breach of planning permission now for two years since January 2014. This breach has been the subject of protracted discussion between the site operator and ESCC Officers – brought to the attention of ESCC by residents who have observed increasing intensification and suffered unacceptable levels of noise, airborne pollution from wood dust, and visual blight over a prolonged period. Operating difficulties are cited in Paragraph 1.11 of the Planning Statement to justify this breach of approved location. 2.4 The operator’s publicly stated explanation for why this breach is necessary stemmed from an entirely foreseeable ‘problem with resolving traffic movements inside site- which caused health and safety concerns and a necessity to reorganise the site’ (Site manager Site visit December 2015). Those traffic movements are direct result of unplanned intensification of activity on the site since 2008. This caused the operator to request retrospective planning permission for big increases to annual vehicle movements (2008), followed by permission to increase scale of vehicle allowed to deliver to site (permission for 16 wheelers from 2010) . A variation to allow wood waste as well as green compost to be processed on site was also sought (2010). It would appear from the records that no independent health and safety audit or assessment was required as a condition of granting planning permission in 2010. 3 Environmental Impact 3.1 Policy WMP25 sets out various criteria that need to be met in order to safeguard general amenities including noise impact. Despite repeated complaints to the Environment Agency over a number of years residents have seen little or no action taken to address noise impact of the licenced activity and have felt their concerns to be dismissed. The Environment Agency stated when asked in 2008 that it was unaware of the direction of the prevailing wind when the site was originally licenced. The current noise monitoring stations are located to the east of the site on the other side of the Lewes Road and are not in the path of the prevailing wind. No decibel readings are taken to the north of the site, but this is where the greatest impact of noise pollution is felt because of wind direction. 3.2 The application includes a Noise Report based on using the existing site receptors at Oak Lodge and Honey Pot Nursery. The tests carried out can’t support a full objective 2 assessment to be made of noise impact of relocating machinery, because they are not measuring decibels at sites in the path of the prevailing wind. 3.3 Paragraph 4.25 of the Planning Statement confirms that currently wood-shredding machine currently operates for about 2 days per month. The Noise Report assessment calculations supplied with this application have been done on the basis of assuming maximum use 2-3 days per week in future. If implemented, 2-3 days per week would represent a 4-6 fold increase over current levels of operation. This is not consistent with a 5k tonne licence increase in material throughput. 3.4 The Noise Report indicated that tests did result in an increase at Honey Pots Nursery (Ref Paragraph 7.1.6 Noise Report: “ The predicted internal noise levels at the nursery exceed guideline values with windows open.” The Noise report consultants also note they were advised by KPS that ‘rarely if ever would the composting shredder and the wood shredder be used in combination’. A control should be immediately placed on the operator to ban any use in combination regardless of the outcome of this application. 3.5 Odour and air pollution: A new consolidated permit has been issued recently by the Environment Agency (ref EPR/EP3595HY). It lists monitoring conditions for testing bio- aerosol concentrations downwind of the site; programme improvement requirements listed in the permit under Table S1.3 of the permit which requires an odour control plan. There is also an obligation to report on and look at mitigation available to minimise pollution. Noise levels regularly force residents to retreat in doors and close all their windows – we are not able to use our gardens in summer when the site is processing; noise can also still be heard at intrusive levels inside affecting delivery of local business even with windows shut. 3.6 As this site is using all diesel-fuelled heavy earth moving and lifting equipment for a minimum of 40 hours a week , toxic particulates are being blown directly over the village along with composting spores. Residents have a legitimate and reasonable public interest in hearing from the Applicant what plans they have to mitigate both noise and airborne pollution caused by current waste processing activity and deal with long standing odour control problems related to the bio waste operation – before any expansion of processing is agreed, as part of a community consultation. LPG powered earth moving equipment is readily available; electric vehicles may also be an option to minimise processing noise. Closed environments should be considered to control the intense noise and harmful dust created by shredding in the wood processing process. 3.7 Traffic: the reports included with this application suggest there is no need therefore to change the conditions controlling traffic movement and that there would be no unacceptable traffic impact if planning approved. As a community we are faced with a situation where until an accident happens, it appears no action will be taken by the Highways Agency. There are no speed controls on the section of road used regularly by 16 wheelers visiting the site. Trucks drive too fast and drivers make mistakes regularly about their routes into site. Drivers park on the public highway outside the site overnight and cause traffic congestion and near misses adjacent to the site at peak times. Simple solutions would be to install traffic calming measures, apply speed restrictions on that section of road 3 from the Lewes direction and impose weight limit signage at junctions on all access roads into the village other than the junction with the A26 closest to Lewes. 4 Conclusion 4.1 The applicant has not complied with their statutory duty to consult the community (Policy WMP20). There are many concerns which remain unanswered about the provision of adequate monitoring carried out in the right places to prevent and minimise noise, odour and air pollution associated with yet more activity on site. How these proposals will improve energy efficiency in the operation of the site is also of interest (see requirements in EPR/EP3595HY permit).
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