From: Duell Parri Moira Ann (Rh-CTGC)

Sent: 06 May 2014 09:57

To: Jones Dafydd Gareth (Rh-CTGC)

Subject: Ymgynghoriad Cais Cae Efa Lwyd, Penygroes

Page 1 of 2

06/05/2014

The supporting information has been assessed and the nature of the development and the proximity of

surrounding residential properties has been taken into account in our response. The information

provided is unsufficient to enable an informed judgement to make recommendations.

The proposal will see the existing site access kept and 3 work phases are to be employed during the 17

year period of operation. Site operational hours have been suggested as starting as early as 7:00hrs, it is

unlikely that the Section would support an early operating time given the residential nature of the

nearby properties.

It is also suggested that maintenance of plant would be carried out outside these hours althought no

assessment has been made as to the likely nature or impact of these activities.

Each phase has a soil stripping element however there are no details regarding the duration of soil

stripping within each phase. The phasing also suggests that a large surface area will be stripped at one

time which may lead to possible migration of dust levels off site, the phases would need to be sctutinised

further to ensure best practice is maintained. The buffer zones in each phase of operations have not

been defined sufficiently to designate a 100m zone to meet the requirements of condition 70/71 MTAN 1.

Although Screening and Acoustic bunding has been suggested as mitigating measures, the proposed

planning conditions state that the 5m Screen at the Eastern boundary of the site will only be in place

until the end of Phase2 and the 4 meter high bund to screen will be removed at the end of Phase 1.

However the bunds are also proposed to be acoustic screens and further information will be required as

to the rational behind these screens, for example the enterance to the site is between two barriers but

directly opposite the nearest property offering no attenuation and providing in line sight to the proposed

development.

The Noise Assessment submitted fails to meet our requirements for a full and detailed noise

assemssment. The bunds proposed are not evidenced by the acoustic methodology used to rational the

recommendations. The background noise has been based on a 2 hour period from 8:00hrs to 10:00hrs,

one could suggest these as the higher traffic volume periods. The background assessment should be

representative of the likely operating periods i.e full day, midweek and weekend. The Noise Assessment

at Cae Efa similarly are not representative of the background levels. The Noise Report suggest that the

nearest property is 30 meters away but given the noise criteria for gardens and recreational spaces I

would suggest that the distance is likely to be less than 20 meters from the site boundary to nearest

recreational space.

An Assessment of Traffic has not been accounted for and given the nature of the vehicles to be used and

the gradient to the site should be included in any subsequent report submitted.

No vibration assessment has been included within the noise report.

Given the proximity of the neighbouring properties it could be suggested that some local meteorological

monitoring be conducted at the location to verify the data being used. The information provided on

particulates and public health are in the main unreferenced and cannot be relied upon to make such

inferences. The evidence submitted quotes studies undertaken 20 year ago and much has progressed in

the interim period in relation to air quality and the standards that such a development would seek to

achieve.

The report makes reference to PM10 levels but as the development progresses beyond 2020 the site will

be subject to additional scrutiny of the PM5 and Pm2.5 levels and these should be included in any

additional report.

An attempt has been made at predicting the Nuisance deposition rate however the rational and method

used and subsequent analysis have not been included in the report. The sticky pad method attributed to

Beaman & Kingsbury ( Beaman, A.L. & Kingsbury, R.W.S.M. (1981), “Assessment of nuisance from

deposited dust particulates using a simple and inexpensive measuring system”, Clean Air, Vol.11, No.2,

pp.77-81) is a common method for sticky pads assessment however there have been further

developments to enhance this method such as directionality and additional measure of Absolute Area

Coverage (Datson, H., Birch, W.J. (2006), “The development of a novel method for directional dust

monitoring”, Environmental Monitoring and Assessment, Vol.124(1-3), pp.301-308. Studies using dust

deposit gauges and gravitational surveys are encouraged to be used as they usually have a greater

degree of accuracy and for the purposes of making basal measurements of dust deposit should be

included as a means of comparison when the site is operational.

It is recommended that the applicant or agent discusses any future monitoring with the Section prior to

undertaking and submitting the assessments.