Great Witchingham Parish Council

Response to NCC C/5/2017/5007 SPC Atlas Works, Road, , Norwich,

GWPC wish to object to this application on the following grounds:

The application is not materially different to the previous application for this site which was rejected by NCC Planning Committee and has now gone to appeal. GWPC understands that the applicant has written to NCC councillors threatening them with legal costs if they do not approve this application. GWPC requests that if NCC do not reject this application outright, it is at least delayed until the outcome of the appeal.

GWPC understands that of the 400,000 Tonnes of household waste collected in Norfolk every year, Norfolk County Council has no long term plans for the disposal of 160,000 Tonnes of that waste. This was the reason for commissioning the incinerator at Saddlebow. GWPC recognises that Norfolk has to find a solution to its waste management problem. However, Atlas Works is not the answer to the failed Saddlebow scheme. NCC needs to come up with an appropriate and sustainable waste management plan and not rely on private individuals making harmful and dangerous speculative applications. The estimated value of the NCC contract for disposal of household waste is between 40 and 100 million pounds. A small portion of this could build a NCC waste plant on one of the many disused airfields around Norfolk and save Norfolk taxpayers hundreds of millions of pounds in future contracts to private companies.

GWPC understands that it is best practise to run an application of this type in conjunction with an Environmental Permit. Why is NCC refusing to follow best practise? NCC Councillors cannot rely on the Environmental Permit to prevent this development. NCC Councillors must, by law consider the environmental impacts of this development as an integral part of the planning process when deciding on this application.

Transport

Waste will come from Norwich and and after processing will be transported to Kings Lynn and/or Felixstowe. This means a dramatic increase in vehicular movements on the A1067, in particular HGV movements through the village of Lenwade. It also means an almost doubling in HGV traffic using the newly created B1535 HGV route (linking the A47 and A1067). This road is not fit for purpose.

An increase of 220+ cars a day is not the same as an increase of 220+ HGV’s a day. Pedestrian pavements in Lenwade are, at points, extremely narrow meaning pedestrians have to walk in single file right next to a busy roadway in order to access the school, doctors and local shops. Although the speed limit is 30 mph, the information gathered from GWPC Speed cameras shows the average speed to be between 35mph and 45mph, with top speed of up to 90mph. The current highway infrastructure is inadequate to support this waste plant application in this location. Approving this application will create significant problems for pedestrian and highway safety.

When the Atlas Works was used for ‘heavy’ industrial concrete production in the past, there was a local railway branch line which was used to bring in raw materials and to take out the finished product so there was less dependence on HGV movements which is not the case now.

Connecting Norfolk Norfolk’s Transport Plan for 2015-2026 states that its aims are:

• Reduced emissions • Pedestrian safety • Promoting active and healthier travel options for short journeys to schools, services and places of employment • Creating a safer environment for travel • Providing opportunities for sustainable tourism, recognising the benefit of community and heritage rail lines (Marriotts Way)

Point 3.16 states

Norfolk has a high quality natural and built environment which significantly enhances quality of life for Norfolk’s residents and visitors. It is important that we protect this from any negative impacts that may arise from transport, for example emissions or noise pollution. Ensuring that the highway environment complements the surrounding landscape and is not detrimental, particularly in heritage areas, landscape or nature conservation designations, is important.

Further points from Connecting Norfolk Norfolk’s Transport Plan for 2015-2026 are:

4.6 Ensure growth does not compromise highway safety.

6.1 Reducing emissions from transport is one of the government’s key priorities. Transport is a significant source of UK greenhouse gas emissions and makes up around a third of overall carbon emissions in Norfolk. By 2020 the UK is committed to reducing carbon emissions from transport by 14% nationally. Norfolk will need to make a contribution to this.

6.2 Transport also impacts upon air quality, which can have a negative impact upon human health. There are a number of Air Quality Management Areas in Norfolk where air quality falls below acceptable levels due to emissions from road traffic.

6.5 The number of Air Quality Management Areas in Norfolk has risen over the last five years. These are mainly located where roads are heavily trafficked or see a high level of vehicles that are big polluters, including buses or heavy goods vehicles. Poor air quality can impact upon a place’s liveability and can have a detrimental effect on human health. It will be important to build on achievements already made in some of our management areas, whilst recognising the trigger points and acting to prevent other areas from being declared.

This planning application is at odds with NCC’s Transport Plan 2015-2026.

In addition the amount of waste referred to in the planning application, 200,000 amounts to nearly half of NCC collected municipal waste.

Norfolk Minerals and Waste Development Framework Tenth Annual Monitoring Report for Waste Data 2013-14, published in May 2015 states: 2013/14 Local authority collected municipal waste in Norfolk over the reporting year totalled 3h6,740 tonnes, a slight increase compared with the previous year but remains just below the 400,000 tonne mark where it has been for the last 5 years.

Management type Quantity managed Tonnes Percentage Recycled 96,176 24.3 Composted 71,406 18.1 Reuse 1,094 0.3 Refuse Derived Fuel 14,565 3.6 Incinerated with 30,965 7.8 energy recovery Landfilled 181,253 45.8 Incinerated without 27 <0.1 energy recovery

If this application is approved, nearly half of all Norfolk’s municipal waste would be dealt with on an inadequate road system.

The Building

The application says there will be no change to the walls, windows or doors of the existing building and that any damage to the walls would result in like for like replacement. The existing walls are made of grey sheet cladding with asbestos roof panels; they are not fit for purpose and are not sound proof. The application states: “The existing buildings are in good condition and will be retained.” However, the existing buildings are in a very poor state of repair and are not fit for purpose.

Fire Risk

GWPC understands that there are over 300 fires a year at waste recycling plants in the UK. The risk of fire at this site is extremely high and the run off from putting out the fires will cause significant pollution to the groundwater and , upstream from Norwich. This is in addition to the pollution caused through the burning of asbestos and household and industrial waste.

Odour

Tens of thousands of tonnes of black bin liner waste will be processed at this site. Of particular concern is the odour which will result from the processing of household waste. Odour will be produced from the point at which the lorries are tipped so providing filtered extraction to the waste handling lines will not be adequate to control odour at the reception point. There will be a constant outside source of odour from black bin liner waste whilst it is waiting processing.

Noise GWPC is concerned that the current state of the existing buildings would mean excessive noise for neighbouring properties and businesses and users of Marriotts Way. There are no adequate sound insulation properties at the existing buildings. Further, the planning statement says that the plant will be in use for 24 hours a day, seven days a week. The suggestion that it is “ recommended that if the shredders are to be used between the hours of 22:00 to 06:30, suitable mitigation measures are implemented” still means that during every evening and every early morning, seven days a week, there will be excessive noise. There will also be noise from reversing lights on vehicles throughout the night. Further, there is no proposal for any suitable mitigations measures as recommended in the reports submitted with this application.

The noise report submitted with this application states, ‘Summary of specific plant noise (dB Leq)’ gives a Resultant Reverberant level of LAeq of 88 (more likely 82dB LAeq). The ‘Summary of existing ambient noise levels at receptor’ gives levels (dB LAeq) of 46.1 daytime (43.4 quietest typical) and 45.5 night (38.338.3 quietesy typical). The report states “According to BS 4142 assessment criteria, a rating level around +10dB or more above background is likely to indicate significant adverse impact”. Yet the report concludes there will be no significant adverse impact. Therefore the conclusions of the report are erroneous and cannot be relied upon. The reports clearly show that if this development went ahead, noise levels WILL have a significant adverse impact on receptors and users of Marriotts Way.

Dust

The planning application documentation clearly states that dust will be an issue due to operation vehicle movements, exhaust emissions and externally stored waste. It recognises that there are “sensitive receptors” in the local area who will be affected by this. It also states there is a risk of contamination.

The Dust Assessment refers to the nearest residential dwellings as being 1KM to the West and 300m to the East. This is inaccurate as there are residential dwellings much closer to the site. The dust assessment is based on erroneous data and cannot be relied upon.

The application states: “potential impacts from noise, odour and dust will be limited to the adjacent land which is in industrial use and will therefore not be significant. This statement is inaccurate. The rear of the site is adjacent to Shepherds Business Park (less than 15 metres away, not 200m as stated in the planning application) to the west which contains businesses requiring an odour and dust free environment. In addition, the Amended Planning Statement does not specify what will be stored in the rear storage area of the site, only that materials stored at the front of the site are “unlikely to produce odours”. What is to be stored at the rear of the building as marked in blue on the plan? Appendix B refers to a lack of residential receptors. Again, this statement is inaccurate. Please refer to the plans.

Vermin Household waste on this scale will undoubtedly lead to rodent vermin infestation. GWPC understands that this is the situation at the RDF plant at Costessy (which is far smaller than this proposal). Rodent infestation will impact on local businesses and residents and impact on users of Marriotts Way. GWPC is particularly concerned about vermin infestation in relation to the close proximity of Bernard Matthews. Vermin infestation could have a devastating effect in terms of the spread of disease and could have a catastrophic effect on this food business, a major local and regional employer. Other nearby food businesses located in Shepherds Business Park would also be affected.

Water pollution

The application states there will be no trade effluent. However 150,000 Tonnes of Municipal waste together with 300,000 Tonnes of Commercial, Industrial and other waste and 5000 Tonnes of Hazardous waste will by its very nature produce effluents.

The reports attached to the planning application call for further investigation into the drainage system. Specifically, they refer to the need for further survey reports with regard to the existing drainage system which leads to a soakaway north of Marriotts Way. No provision has been made for this in the planning application. The new reports do not address the inadequacies of the applicants proposals to manage the serious risk of groundwater pollution, the threat to our environment, the River Wensum, the aqufer and the drinking water supply for Norwich.

The Flood Risk Assessment states: “The site is formally drained at the moment using manmade (concrete) channels which direct surface water runoff to a natural detention basin. This basin offers attenuation and natural infiltration. The overflowing water discharges to a second (adjacent) detention basin. The outflow is directed to the nearby River Wensum. There is a therefore a high risk of the River Wensum, a SSSI becoming polluted with drainage, run-off and effluents from the waste. Please note that the planning application is for a total amount of 455,000 Tonnes of waste (Municipal: 150,000 Tonnes, Construction, Demolition and Excavation: 150,000 Tonnes, Commercial and Industrial: 150,000 Tonnes Hazardous: 5000 Tonnes). This is far greater than the 150,000 referred to in much of the documentation submitted with the planning application. This is misleading.

The Flood Risk Assessment requires “certain measures will be taken in terms of improving the water quality aspect of the existing drainage layout”. This issue is not adequately addressed in the application. The Flood Risk Assessment clearly shows that the drainage system is inadequate and highly likely to cause pollution to at least one SSSI site.

The Local Plan for Norfolk County Council Policy ENV24 (Protection of water resources) states that: “In the consideration of considering development proposals regard will be taken to the availability of water resources and the effect of increased abstraction on environmental water needs (i.e. those of rivers, wetlands and estuaries, including the needs of navigation, fisheries, recreation and nature conservation) as advised by the environment agency. Development which jeopardises water resources or has a significant adverse impact on the water environment will not be permitted.” Bernard Matthews, the SAC and SSSI’s are all jeopardised by this development.

The Flood Risk Assessment recommends that “Surface water should ideally be managed by SuDS techniques in order to promote sustainability, amenity, and bio-diversity. Use of SuDS to manage surface water should be examined and incorporated into the design. Consideration should be given to the use of permeable access roads and footpaths so that they allow surface water to flow into the ground and mimic the natural surface water flow path provided that the infiltration test demonstrates efficient soil permeability. The detention basins, downstream of the site, should be retrofitted and potentially re-planted in order to maximise treatment efficiency. Certain types of reeds such Typha latifolia and Phragmites australis improve the treatment performance of such features by promoting absorption of road-related pollutants. These issues have not been adequately addressed.

The Contaminated Land report states that there is a British Geological Survey groundwater flooding susceptibility flood area within 50m of the site. The River Wensum, a SAC and SSSI and Common, an SSSI, are environmentally sensitive areas, located near to the site that would be at risk if this development went ahead. The Atlas Works site itself lies within Environmentally Sensitive Area, Broads as designated by Natural . Contamination and pollution are of major concern if this application is granted it would give approval for 150,000 Tonnes of black bin liner Municipal waste. Appendix K refers to the need for further survey reports with regard to the existing drainage system which leads to a soakaway north of Marriotts Way. No provision has been made for this.

As well as the risk of pollution to the River Wensum, many local residents and businesses, including Bernard Matthews, extract water from direct from the water table. The drains from this site are in very close proximity to the water table, over sixty years old, not fit for purpose and therefore a huge risk of pollution exists. This is in addition to the dangers of leaching from the wet waste and RDF processing systems.

The Planning Statement is grossly inaccurate in that it states “groundwater is considered to be at low risk from the operations.” This is at odds with the information supplied in the applicant’s own supporting documentation.

Bad Neighbour

GWPC understands that the planning authority must look to the concept of “bad neighbour” when considering planning applications. The protection of private interests is a material consideration for planning purposes. Light pollution from night time operations, as well as odour, noise, vermin, contamination and safety issues mean this proposed development constitutes a bad neighbour to sensitive receptors, other local residents and businesses. This is of great significance as there are no adequate mitigation measures contained in the planning application.

In addition, Shepherds Business Park is 15 metres from the site, not 200 metres as detailed in the planning application.

Environment

Paragraph 109 of NPPF states:

The planning system should contribute to and enhance the natural and local environment by preventing both new and existing development from contributing to or being put at an unacceptable level of risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution.

200,000 tonnes of waste, 160,000 tonnes of which is black bin liner waste, will create both an unacceptable risk to, and have an adverse effect on the natural and local environment.

GWPC supports and reiterates comments made by Bernard Matthews in its objections to a waste plant at this site, including:

GWPC understands that an Environmental Impact Assessment (EIA) is essential for any development on this site, particularly in relation to the impact on the local SSSI’s, the River Wensum, Marriotts Way and the Ancient Barrows. GWPC understands that in this case an EIA is required by law and that no EIA has taken place.

The Norfolk Minerals and Waste Development Framework, Waste Site Specific Allocations, Development Plan Document:

WAS 78 Land at SPC Atlas Works, Lenwade 6.78.1 Site Characteristics • The site has an estimated capacity of 150,000 tonnes per annum for mixed waste processing, metal recycling, inert waste recycling, windrow composting, in-vessel composting, physical, chemical, and/or mechanical/biological treatment of household waste, waste transfer, and other forms of residual waste treatment excluding thermal treatment. • The nearest residential property is approximately 30 metres from the site boundary • The site is approximately 1KM from Alderford Common SSSI • The site is within 150 metres of the River Wensum SAC and SSSI

6.78.2 The site is extensive, within an employment area with other existing commercial and industrial uses, including an existing metal recycling site. Due to the location of the site , in proximity to Marriott’s Way footpath, County Wildlife Sites and residential dwellings, mitigation measures will be required for potential amenity, landscape, highways and ecology impacts.

No mitigation measures are proposed.

The site only has capacity for 150,000 Tonnes waste. It is already in use for metal recycling of an unknown amount of Tonnes per year. This site does not have the capacity to take the amount of waste proposed on the planning application (Municipal: 150,000 Tonnes, Construction, Demolition and Excavation: 150,000 Tonnes, Commercial and Industrial: 150,000 Tonnes Hazardous: 5000 Tonnes).

The proposed planning application greatly exceeds the stated capacity and only covers a small section of the site. It contains no adequate mitigation measures and is in close proximity to SAC’s and SSSI’s.

The Heritage Statement submitted with the application notes that the site lies within a complex prehistoric mortuary landscape on the terraces of the River Wensum, characterised by Bronze Age round barrows and barrow cemeteries. One barrow with a possible Neolithic precursor lies adjacent to the site to the north. Crop marks of Iron Age enclosures and boundaries can be seen to the south of the site and medieval embankments, channels and ponds lie to the south-west. Extensive metal detecting of the areas of higher ground above the river terraces has produced a substantial quantity of objects dating to the Iron Age, Roman, Saxon, medieval and post medieval periods. The site lies adjacent to a tumulus, Scheduled Monument no 129 (HER 7718; Fig 7) to the north. The site is also adjacent to the former site of a 19th-century milestone (HER 56414). In terms of planning policy, the strategic development plan policy framework Policy ENV6 states that to conserve the wider historic environment, local authorities and other agencies should afford the highest level of protection to historic and archaeological areas, sites and monuments of international, national and regional importance. The District Local Plan (Replacement) POLICY ENV17 refers to ancient monuments and archaeological sites. It states that development which would adversely affect a Scheduled Monument or other nationally important archaeological sites and monuments, or their settings, will not be permitted . Government guidance in Planning Policy Guidance Note: Archaeology and Planning (PPG16) states that there should be a presumption in favour of the physical preservation of nationally important archaeological remains whether scheduled or not, and their settings.

The Heritage Statement notes that cartographic evidence suggests that the site has not been settled since at least the 18th century until the construction of the Atlas Works estate in 1944. The relevant planning policies were not in place in 1944 and therefore all references to Atlas Work in its “Heyday” should be dismissed.

The Heritage Statement describes the setting as “largely tranquil apart from occasional short bursts of industrial noise emitting from the trade premises either side of the development site”. Although the existing “tranquillity of the viewpoint is compromised by the proximity of the industrial works, the noise is only intermittent”. It states that “the wider setting of the asset is largely open countryside with small dispersed villages and small, dense patches of woodland which makes a neutral contribution to the asset.” Also, “heavy goods vehicles accessing the site could negatively influence the ambience of the asset with movement and noise as they draw the viewers’ attention away from the stillness of the asset’s natural setting”. Appendix L states that “the current derelict site is tranquil and “the overall effect of the development including the movement of HGVs and industrial noises will seem more intrusive in the landscape than the current situation”. It states that “Noise, light and odour pollution may be introduced to the asset “and that the “development will widen the conceptual gap between the busy modern environment on one side of the Marriot’s Way footpath and the wild and unstructured environment of the heritage asset”. Importantly, Appendix L also states that “The future prospects of the heritage asset are considered to be at risk of harm from any further potential development proposals. There are additional underused or disused areas of the Atlas Works estate, including the area of land immediately to the south-east of the barrow. There is a risk that future prospective developers could consider these areas as a potential development commodity, therefore initiating a succession of development proposals, each one contributing to a negative cumulative impact.” In light of the continual references in the application and associated documentation to 150,000 Tonnes of Municipal waste, when, in fact the planning application is for total of 455,000 Tonnes of waste, this is of great concern.

Should pollution or additional issues arise with this site, if planning permission is granted, GWPC have no confidence in the competence and effectiveness of the existing planning and environmental enforcement agencies. The history of planning applications and enforcement at Clay Hall Farm, are material considerations that need to be taken into account in this matter.

In conclusion, GWPC object to this planning application in the strongest possible terms and strongly urges NCC to refuse this application. Who in their right minds would dump their waste on top of their water supply and upstream from their major city?

Ms Jane Wibey Great Witchingham Parish Council