<p> Slinfold Parish Council PO Box 315, Billingshurst, West Sussex RH14 9XX Tel:01403 785864 Email:[email protected]</p><p>18th August 2011</p><p>SLINFOLD PARISH COUNCIL’S STRONG OBJECTION TO WEST SUSSEX COUNTY COUNCIL REGARDING PREFERRED SITES (NOWHURST) FOR WASTE TREATMENT/DISPOSAL</p><p>Background 1. A formal decision was made by West Sussex County Council (WSCC) in May 2011 to commence the preparation of a ‘Waste Plan’. The shortlist of ten preferred waste sites identified by WSCC includes three within the North Horsham County Local Committee area. These are at Nowhurst Business Centre, Strood Green in Slinfold Parish (Nowhurst Business Centre, W/HO/2, Parish Slinfold, Area 6.5 hectares) and two sites in Brookhurst Wood, in Warnham Parish. </p><p>2. Slinfold Parish Council (SPC) opposes the inclusion of Nowhurst Business Centre (Nowhurst BC) in the shortlist of suitable sites. This letter gives the opinion of the Parish Council and spells out reasons why SPC believes that the site at Nowhurst BC is wholly inappropriate for waste treatment of any kind. </p><p>3. In the past WSCC was also of the opinion that the Nowhurst BC site was unsuitable. In a letter to a local resident (Mr G Pocket) the then County Planning Officer and Deputy Director John Kilford stated that in regard to the West Sussex Waste Local Plan – Response to 2001 “Pre- Deposit” Consultation: - “Site No.48: Nowhurst Business Centre, Broadbridge Heath. 39 respondents made comments in respect of this site, 33 of which concerned access/routing issues Ground water, pollution and flooding were also highlighted. Other significant issues included air quality, noise, vermin and smell. Other concerns mentioned were impacts on nearby residential properties and footpaths, and that the site was too close to a school.</p><p>There is no development plan support for further permanent, built waste management development here. There are alternatives, which are considered to be better related to the main urban areas of West Sussex. Accordingly, the site is not carried forward as a proposal.”</p><p>An account of the history of the site is at Annex A, and information on the opinion of Horsham District Council is at Annex B. Opinion 4. In the opinion of Slinfold Parish Council the reasons given by WSCC in 2002 are all still valid. Nowhurst BC is inappropriate for use as a waste facility for the following reasons; the site is: -</p><p> a. Within 250 metres of residential properties, including several historic properties with Listed status. An additional residence has been built since 2002. The proximity of the site to residential dwellings would rule out certain waste facilities and noise/odour impact assessment would be required at application stage. The siting of any facility, and stand off from sensitive receptors, would require consideration at any application stage. b. Currently subject to stringent conditions as to types of permitted use of the site (see paragraphs 4, 5 and 6 of Annex A). c. Only accessible along single carriageway roads (A281 and A29). This contrasts with the two sites at Warnham, which are not only closer to the large towns in the north of the county but are accessible directly off a dual carriageway (A264) and the rail line between Horsham and the north. d. Opposite a large school which already generates considerable traffic and shares the mini roundabout at the entrance to the site. The school has expanded since 2002 and new buildings have been built nearer the site including pre-school classrooms, hall and open-air playground. e. In the vicinity of a large residential care home which has planning permission to expand. f. Next to the regional Guide camping ground which is long established and is used extensively by groups (not just Guides) from across the County and beyond. g. Adjacent to Bridleway 1443, which runs along Nowhurst Lane to the south of the site. At any application stage, consideration would need to be given as to whether the path can be screened/protected. h. Primarily in Flood Risk Zone 1, therefore a Flood Risk Assessment would be required. i. Potentially of historical interest. The site is less than a mile from Stane Street and the archaeological site at Alfoldean, which has proven Roman remains; an archaeological impact assessment would be required with surveys and reports to accompany any application. j. Bordering BT underground plant situated to the south east of the site. Avoidance of BT lines would have to be addressed at any application stage. k. Close to woodland that is environmentally sensitive, in part ancient woodland. The nearby woodland is a known breeding site for nightingales, which are nationally in dramatic decline (53% decline since 1998 according to British Trust for Ornithology data). The woodland is a nesting site for other important migratory bird species and there are also two badger sets present. </p><p>5. It is also the opinion of SPC that all waste uses for the north of the county should be concentrated at Brookhurst where there is already a waste facility, good access by road and ample space to increase the scale of operations. SPC disagrees with the WSCC approach that only sites where owners are willing should be considered as this limits the range of sites available for consideration. </p><p>Conclusion. 6. SPC urge WSCC to remove Nowhurst BC now from the list of proposed sites. Removal will be consistent with WSCC’s own stated policy (in 2002). Removal now will also ensure that scarce funds are not expended on the investigations and reports that would be required were Nowhurst BC to be carried forward. The site is subject to very strict planning conditions for good reason in order to safeguard the environment and surrounding properties. The circumstances of the site are such that there is a high probability that the mitigation measures required to meet planning requirements would make it uneconomic for any applicant to proceed.</p><p>Yours sincerely SLINFOLD PARISH COUNCIL</p><p>M Burroughs</p><p>Mary Burroughs PARISH CLERK</p><p>Cc. County and District Cllrs. Hodgson, Nye and Youtan and Slinfold Parish Councillors Annex A </p><p>Planning History of the Nowhurst Business Centre site.</p><p>1. The site was originally an open stone quarry. It ceased to be used as such many decades ago. The Quarry Contractor laid roads with some of the stone and left their equipment on the site, so that when planning controls were introduced, it acquired use as a civil engineering depot. </p><p>2. No manufacturing activities were carried on, save that in 1974 permission was granted for fence making in one of the buildings. Apart from that the site has always been a depot, in other words, used for storage. The successors, Gamble Plant Hire and Gamble Rail, kept equipment on the site and also obtained permission to lay about 100 metres of track and run vehicles along it for training purposes during strictly limited hours. Another major occupant of the site, Benbay, was a drain-layer, and kept materials and contractor’s equipment on the site, in other words continued the storage use. Benbay sold the land to the present owners of the site, Norman Marshall, who keep damaged cars on the site, thus continuing storage use.</p><p>3. On 29 April 1998, Horsham District Council issued a certificate of lawful use in respect of the entire site, except a part to the southeast; for a ‘Civil Engineering Depot comprising mixed use for the parking of vehicles and plant (Contractors Equipment), the storage of plant, vehicles, equipment and materials, offices, maintenance and repair of vehicles and equipment’. </p><p> As far as is known, no manufacturing or processing activity has been performed on the site since at least the 1970s. It has been used for storage with ancillary office use although three old single storey buildings on the plan do appear to have a general industrial use that probably derives from the fence making. However, as about half is designated as being within the area where loading and unloading is permitted, this appears to make the permitted area very small in practice. </p><p>4. After years of applications there was a Consent SF/65/03, finally approved on 3/2/2006, to which the following conditions were imposed: • Work in the Open Storage area limited to specified hours • Railway Training limited to specified hours • A noise attenuation scheme was to be installed • Acoustic barriers were to be erected, details to be approved • No public address system without prior HDC approval • Stacking heights to be limited to 2m or, in one area, 3.5m • No loading or unloading outside the designated area • No external or floodlighting without prior HDC approval • No maintenance or repair work to be carried out in the open</p><p>These conditions were necessary in order to protect interests expressed in the Consent as: the interests of amenity/the environment/residential properties/visual amenity/neighbouring properties/the amenities of nearby residents/the character of the surrounding area, No more than 300 square metres of a new workshop/store was to be used for workshop or repair, the rest to be storage, and this building to be the subject of a noise control scheme approved before development.</p><p>5. Reinforcing and adding to these protections, a S106 Agreement dated 28 November 2005 contained the following covenants by the developer/occupiers, to bind themselves and their successors in title: • Not to carry out building, mining engineering or other operations on the site or land to the north thereof • Not to stack save as above • Not to store scrap metal or to carry out any activities connected with use as a scrap yard or a car breakers yard and not to have a crusher or any equipment associated with the crushing or breaking of vehicles on the site. • Whatever the terms of any Operator’s Licence no more than 33 working goods vehicles are to be kept on the site. • Not to load or unload save within the designated area • No further lighting signs or landscaping without prior written approval • Not to use more than 25% of the new workshop/store for workshop purposes. • Not to carry out any repair alterations and maintenance work in the open • To construct all new buildings on the site of traditional materials using brick walls and tiled roofs unless otherwise approved by HDC • Not to operate outside the specified hours. • To use self-adjusting bleepers to match the ambient noise level of the area</p><p>6. A Road Traffic Commissioners licence is necessary to keep HGV’s on the site, and the Commissioner has imposed conditions on the grant of a licence, limiting hours during which lorries may enter and leave, the number of vehicles, banning repairs except in an emergency and any are to be reported to him within 7 days with a full explanation and limiting loading and unloading areas.</p><p>Annex B </p><p>Horsham District Council opinion</p><p>1. WSCC state that the site in Slinfold Parish has potential for a commercial built waste facility. The site is part occupied by buildings and is currently in use as a depot for HGV and construction plant. The site is covered by Policy DC1 Areas outside Built-up Boundary in Horsham District Council's General Development Control Policies. Horsham District Council would have concern about waste use on the whole site. </p><p>2. Horsham District Council wish to pursue B2 and B8 uses on part of the site but have no objection to part of the site being used for a modern enclosed waste facility. Their concerns are:  The cost and time involved in achieving deliverability, and  The likely impact of a built waste facility upon nearby residents and neighbouring land uses. </p><p>3. Measures to mitigate the impacts of noise, odour and lorry movements would have to be addressed at any application stage. </p><p>4. Additional issues to be addressed at any application stage include ecological impacts upon hedges/trees; flood risk; protection of the bridleway; impact of off-site traffic movements.</p>