Otterpool Quarry

 

 PLANNING APPLICATION FOR A MATERIALS RECYCLING FACILITY/ANAEROBIC DIGESTION PLANT AT OTTERPOOL QUARRY SELLINDGE

 

Ref SH/07/TEMP/0046 & PAG/SH/07/TEMP/0046

 

Response to the above from Stanford Parish Council

 

 

 

25 February 2008
 
Planning Applications Group
First Floor, Invicta House
County Hall, Maidstone
 
PAG/SH/07/TEMP/0046
 
Dear Sir/Madam
 
Application         SH/07/TEMP/0046
MATERIALS RECYCLING FACILITY/ANAEROBIC DIGESTION PLANT
OTTERPOOL QUARRY SELLINDGE
 
Stanford Parish Council considered this application at its meeting on 30 January 2008 and the five councillors voted by a majority of 4:1 to oppose it. Of those who opposed the proposal, one did so because of faulty figures and lack of clarity, transport overload and danger of pollution, but if these things can be put right he would accept the construction of the plant, and three said they would oppose to plant under all circumstances, because nothing will ever make it acceptable – the faults in the proposal are too severe ever to be put right. The defects in the application agreed by the councillors are set out below. 
.
LACK OF ACCURACY
 
The document is carelessly prepared, leaving aside typing errors, for example:
  • 95,000 tonnes is variously given as the maximum and the average annual through-put
  • The number of lorry movements is given as 135 per day (in and out) in #1.19, 152 per day (two way) in #1.25, and 16 per hour also in #1.25. The latter figure gives 176 per day for an 11 hour day or 144 for a 9 hour day
  • The working day is variously described as 07.00 to 18.00 (11 hours) and 07.00 to 17.00 (10 hours). 
  • If we take the most often used figure of 152 movements a day, there will be 76 deliveries per day. The plant operates for 278 days per year (#4.2) giving an annual total of 21,128 lorries per year. If they are carrying a total of 95,000 tonnes, they will be carrying about 4.5 tonnes each. These do not seem like full lorry loads.
  • #3.4 shows existing traffic flows as 923 HGVs between 07.00 and 17.00 weekdays. The addition of 152 additional lorries is a 17% increase. This is dismissed as unimportant, and #6.3 refers to this as 3 or 4%
  • Sections 9 and 10 repeat many of the earlier assertions which are not supported by any real evidence or only by discredited calculations
This degree of confusion and unreliability does not give faith in the clarity of thinking in the planning of this development, the efficiency of the operation of the plant, or the quality of the data elsewhere in this application
 
 
TRAFFIC
 
Despite the assertion in #7.1 that this is ‘not a sensitive area’ for traffic, we know of the growth of business at Holiday Extras, Folkestone Racecourse and Westenhanger Station and the expansion of the Link Park Industrial site, which are all adding to traffic all the time on what is frequently, a very busy road. 
 
The complex junction at Newingreen has peak hour bottlenecks daily, and we note that there are some 16 different possible routes through the five roads that meet here. Apart from through traffic we note heavy usage of this junction
  • by commuters to and from the station at Westenhager,
  • by racecourse traffic for daytime and evening meetings which puts put hundreds of cars onto the A20 within minutes of the end of racing, and
  • by Holiday Extras staff who, despite extensive shift work, produce distinct peak hour traffic surges. 
We also note that, as part of the planning approvals for the Link Park Industrial Estate developments, the requirement was placed on the developers to contribute to the re-modelling of this junction. Clearly its limitations are well known to Shepway District Council, if not to the traffic consultants for the present application.
 
The text of the application lays stress on the fact that lorries entering the site will not have to turn right – across the traffic- as most will come from the east (eg, #2.2.2, #6.1), but fails to note that most lorries leaving the site will have to turn across the traffic flow on the A20 as they will be going east. The potential for congestion and danger is considerable.
 
Operation Stack is said (#3.1) not to affect the A20 at this point. Those of us who live nearby know differently. The roundabout at junction 11 is often grid-locked at these times and this can spread back along the A20 so that lorries leaving this site when Operation Stack is in operation will almost certainly be delayed and add to the distress of local road users along the A20 and especially on the approaches to junction 11.
 
ENVIRONMENT
 
We are also concerned by environmental issues. Paragraph 1.25 acknowledges an impact on health, albeit ‘minor’. However this is not quantified, nor are any details given of what these effects might be. We note that there will be dust and smell even if they are mitigated by the design of the plant. If the plant design is as unreliable as this application, we will have good reason to be afraid.. We note that with the prevailing wind from the south west, much of Westenhanger and almost all of Stanford will lie within the drop zone for particles and chemicals, being within 3 kilometres to the north east. We further note that a busy café, serving food and drink on a commercial scale lies very close down wind of the site. This cannot be appropriate. The nature of this business will be further compromised by the constant movements of lorries carrying waste just opposite its premises.
 
We have been concerned by the possibility of damage to the ground water along the path of the East Stour. The lower parts of this, adjacent to Westenhanger Castle (an English Heritage site), flood easily and Southern Water have gone to very considerable lengths to ensure that this has been protected in the construction of Stop 24 at junction 11. Similar constraints are required here. The East Stour is only a few hundred metres down hill from the site with its enormous potential for pollution, and we require more than glib assertions of safety. 
 
Our concerns also include the disposal of sewage: the system that serves this parish and leads on to Sellindge is recognised by Southern Water to be at full capacity, and the proposed developments at Link Park are causing serious concern. What plans have been made for the disposal of sewage from the 25 workers and many lorry drivers who will use the site every day?
 
GROWTH
 
We note that the plans as presented do not use all the available space on the site. We also note that #1.13 refers to the ‘potential to provide capacity for the treatment of source separated municipal waste streams within East Kent’. Whatever this is supposed to mean, we read it as implying that there is room for expansion. If the scheme is allowed because it will mean only (!!!!!!!) a 16% growth in HGV use along the A20 and the plant is doubled in capacity during the next decade, where does that leave us? We need to know more clearly what the future is likely to be, and hope that planning ‘creep’ will not be permitted
 
CONCLUSION
 
We recognise the need for the sort of tasks which this plant will undertake, and we do not dispute that this site offers some advantages but there are unexplored issues, there are misleading statements, and there are dangers to local transport and the environment which have not been addressed. Until satisfactory solutions are put forward, we must strongly oppose the scheme.
 
 
 
Yours faithfully
 
 
 
 
 

Ken Bultitude, Chair


 

STANFORD PARISH COUNCIL
 
ENVIRONMENTAL STATEMENT TO SUPPORT PLANNING APPLICATION SH/08/124:
MATERIALS RECYCLING FACILITY/ANAEROBIC DIGESTION PLANT
OTTERPOOL QUARRY SELLINDGE
 
Stanford Parish Council considered this application again at its meeting on 21 October 2009 and councillors voted by a majority of 4:0 (with one absentee) to oppose it. 
The defects in the application agreed by the councillors are set out below. 
 
THE STATEMENT
 
This statement adds very little to the original proposal. It is a re-ordering of much of the former material which preserves many of the errors and omissions of that document. The data collection has not been thorough and the interpretations are subjective, simplistic and biased towards the applicant – Chapters 9 and 10 illustrate this well. If the design, construction and operation of this plant are as shoddy as this statement, we do well to fear its impact.
 
Map OP1 is very out of date.
 
LOCATION
 
As the County’s Waste Disposal Framework has not yet been agreed, this site lies outside any coherent plan. It is an opportunist development, proposed because the old Otterpool Quarry is available, not because it is suitable or part of any overall scheme. It is not mentioned in the Shepway LDF proposals.
 
The location is rural, well separated from other commercial activity. It is served by rural roads, and although the M20 is not far away, the final approach to the site is single carriageway, crossing the busy, complex and dangerous junction at Newingreen (there are 16 routes through this junction), passes the access to Folkestone Racecourse (which regularly discharges hundreds of cars at peak times) and the home of Holiday Extras (a major employer whose premises are soon to be enlarged). The traffic to and from the Lympne and Link Park Industrial Estates (which have expansion plans already approved) uses these roads.
 
The statement ignores the 100 homes at Manor Farm and Folks Wood estates in Lympne and does not consider the effect of the possible 1000 new homes identified for this area in the Shepway LDF, Preferred Options.
.
TRAFFIC
 
Despite the assertion that this is ‘not a sensitive area’ for traffic, we know of the growth of business at Holiday Extras, Folkestone Racecourse and Westenhanger Station, Port Lympne Wildlife Park and the expansion of the Link Park Industrial site, which are adding to traffic all the time on what is, frequently, a very busy road – the A20. Some 1000 new homes are proposed in the Shepway LDF, Preferred Options for this area.
 
The complex junction at Newingreen has peak hour bottlenecks daily, and we note that there are some 16 different possible routes through the five roads that meet here as well as the entry/exit for Holiday Extras. Apart from through traffic we note heavy usage of this junction
  • by commuters to and from the station at Westenhanger,
  • by racecourse traffic for daytime and evening meetings which put hundreds of cars onto the A20 within minutes of the end of racing, and
  • by Holiday Extras staff who, despite extensive shift work, produce distinct peak hour traffic surges.
 
We also note that, as part of the planning approvals for the Link Park Industrial Estate developments, the requirement was placed on the developers to contribute to the re-modelling of this junction. Clearly its limitations are well known to Shepway District Council, if not to the traffic consultants for the present application.
 
The traffic flows in the tables in #4.5 and #4.9.3 are added up differently but we draw attention to the increase in HGV movements, 17% for am peak, 28% for pm peak (!!!!!!) and 16.5% overall. This is serious.
 
The text of the application lays stress on the fact that lorries entering the site will not have to turn right – across the traffic- as most will come from the east but fails to note that most lorries leaving the site will have to turn across the westbound traffic flow on the A20 as they will be going east. The potential for congestion and danger is considerable. 
 
The statement includes a drawing( HD1 in chapter 4) which shows the access to the site in detail. The shape and position of the traffic island appear to prevent the ingress of lorries from the west. While this may be an advantage it is not mentioned in the text and it will require vehicles coming from the west to pass the site, go through the junction at Newingreen, travel all round the very small roundabout south of junction 11 and then back to enter the site from the east. These double journeys are not included in the data. There is a further discrepancy in that the same drawing shows that turning west on leaving the site is not possible. The text suggests that this can happen, but will be discouraged.
 
Operation Stack is said not to affect the A20 at this point. Those of us who live nearby know differently. The roundabout at junction 11 is often grid-locked at these times and this can spread back along the A20 so that lorries leaving this site when Operation Stack is in operation will almost certainly be delayed and add to the distress of local road users along the A20 and especially on the approaches to junction 11.
 
The area from which waste is to be brought in is suggested as East Kent. This could well include Canterbury but the impact of additional HGVs on the B2068 from Canterbury is not mentioned.
 
ENVIRONMENT
 
We are also concerned by environmental issues. The impact on health is still said to be minor but this is not quantified, nor are any details given of what these effects might be. We note that there will be dust and smell even if they are mitigated by the design of the plant. The shed for the maturing of the waste is open sided (#5.0) – if maturing means ‘rotting’ we fear for the smell!
 
We note that, with the prevailing wind from the south west, much of Westenhanger and almost all of Stanford will lie within the drop zone for particles and chemicals, being within 3 kilometres to the north east. We further note that a busy café, serving food and drink on a commercial scale lies very close down wind of the site. This cannot be appropriate. The nature of this business will be further compromised by the constant movements of lorries carrying waste just opposite its premises. The presence of the new estates on Stone Street Lympne – within a kilometre of the site – is not mentioned. Figures available from SDC on air quality further along Otterpool Lane have not been used.
 
We have been concerned by the possibility of damage to the ground water along the path of the East Stour. The lower parts of this, adjacent to Westenhanger Castle (an English Heritage site), flood easily and Southern Water have gone to very considerable lengths to ensure that this has been protected in the construction of Stop 24 at junction 11. Similar constraints are required here. The East Stour is only a few hundred metres down hill from the site with its enormous potential for pollution, and we require more than glib assertions of safety. In this connection, the statement notes (#7.4.4) that “the overall risk of pollution without mitigation is high”. The mitigation measures proposed (7.5.1) appear to rely on hope and assertion rather than foolproof engineering solutions. No mention is made of the disposal of waste from the wheel-cleaning described.
 
The East Stour River drains smaller watercourses and springs within or close to the site. The statement acknowledges that further work is needed in connection with possible pollution and proposes monitoring, not prevention. It will be too late if contamination occurs. Uncertainty is acknowledged with inadequate knowledge and insufficient characterisation of the ground conditions. Local memories of a lifetime’s farming within the parish notes incidents of contamination of the East Stour from earlier (pre-war) commercial activity from the slopes above this site and to the south of the A20.   We have no confidence that they will not be repeated.
 
Our concerns also include the disposal of sewage: the system that serves this parish and leads on to Sellindge is recognised by Southern Water to be at full capacity, and the proposed developments at Link Park are causing serious concern. We cannot see what plans have been made for the disposal of sewage from the 25 workers and many lorry drivers who will use the site every day.
 
The potential impact of this development on the SSSI and AONB which are close to this development are brushed aside – as are many other threats from this development. The proposals for landscaping are not convincing.
 
GROWTH
 
We note that the statement does not consider the environmental effects of the eventual use of all the available space on the site. We need to know more clearly what the future is likely to be, and that planning ‘creep’ will not be permitted as the whole of this site is developed.
 
Other commercial and residential growth in the vicinity of this site is likely: the effect of this operation on the environment for these developments has not been addressed.
 
CONCLUSION
 
We recognise the need for the sort of tasks which this plant will undertake, but there are unexplored issues, there are misleading statements, and there are dangers to local transport and the environment which have not been addressed. The document is bland, lacks impartiality and objectivity, and adds very little to the original papers. We remain strongly opposed to this proposal.
 
Ken Bultitude, Chair
22 October 2009
 


 

 

RESPONSE FROM LYMPNE PARISH COUNCIL (Reproduced by permission of Lympne Parish Clerk)

 

 

 

 

c/o The Pines
Stone Street
Lympne
Kent CT21 4LD
 
Tel: 01303 265651
 
21 February 2008                                                                                                        LPC016.08
 
Ms S Thompson
Head of Planning Applications Group
Kent County Council
First Floor
County Hall
Maidstone
Kent ME14 1XX
 
Dear Ms Thompson
 
TOWN AND COUNTRY PLANNING ACT 1990
 
APPLICATION No: SH/07/TEMP/0046   GRID REF: 11251 36568
APPLICANT:           Countrystyle Recycling Ltd
PROPOSAL:             Construction and Operation of a Materials Recycling Facility,
                                    Anaerobic Digestion Plant and Associated Office and Parking Facilities
LOCATION:             Otterpool Quarry, Ashford Road, Sellindge, Ashford, Kent
 
Lympne Parish Council wishes to register a strong objection to the above application for planning permission. In principle, the Council support wholeheartedly the need for recycling and food/green waste processing but it is the siting of the plant in an area close to the Village and the main A20 arterial road that provides cause for concern. The Parish council’s objections are focused principally on the following areas:
 
1.      The statistics, assumptions and data provided by the traffic management consultants and others, in terms of vehicle movements, routing and annual tonnage, reveal inconsistencies throughout the application document which demonstrates a lack of local knowledge due to insufficient research. 
 
2.      Appendix B, Item 5.3.2 Current traffic flows on surrounding roads (Page 25) states:
 
The application site is currently not in use and therefore generates no traffic flows. The site was used up until 2001 as a mineral and construction materials processing facility. Despite there not being any traffic flow data available from this period, experience of similar sized sites suggests that a sizable number of HGV movements would have been generated by this operation.
 
This assumption is based on the area before there was so much traffic on the M20 and A20, before the new Services Area at Junction 11 was built, before Holiday Extras was built and extended, before planning permission was obtained for large extra units to be built at Lympne Industrial Estate, probably before Manor Farm and Folkeswood Way estate in Lympne was built and before Operation Stack brought this junction to a standstill with such frequency.
 
3.      The traffic congestion that will be encountered due to the significant increase of HGVs using the A20, and the gridlock that will occur, especially at peak periods, involving traffic using the feeder roads from Hythe, Lympne, Stanford and Sellindge will become unsustainable.    At peak times the A 20 is already saturated with traffic travelling to and from the M20 Motorway, joining vehicles from Hythe and Stone Street (Lympne and Westenhanger) plus vehicles using West Hythe and Lympne as a rat run from the Marsh. The situation is further aggrevated on a regular basis by a high volume of traffic on race days and the many thousands of visitors to Port Lympne Wild Animal Park.    Commercial vehicles to and from the Link Park also use this route and when "Operation Stack" is in progress, a substantial number of vehicles exit the M20 at Junction 10 and use the A20 to avoid the inevitable snarl up at Junction 11. 
 
4.      A Lympne Parish Councillor who moved from St Leonards to Lympne has provided a graphic account of the unacceptable increase in HGV movements which caused acute traffic congestion when a similar recycling and bio-digester facility at Bulverhythe was established.
 
5.      Although technically inadmissible when considering current planning applications it is, nevertheless, appropriate to take into the equation future development which is presently under consideration by the planning authority. We refer to the application of Holiday Extras at Newingreen to increase the size of their premises and car parking facilities, the recently approved building of extra units at Link Park, the proposed housing development at Nicholls Quarry consisting of over 1,000 houses and the enlargement of Lydd Airport, all of which conspire to generate substantial additional traffic using the A20 and Stone Street, producing a chaotic situation.
 
6.      The Parish Council, despite commercially inspired assurances, has concerns regarding pollution of the site and watercourses and importantly, the noxious odours from the organic waste that is to be stored and processed into slurry.  There are also the emissions from the anaerobic digester which could conceivably constitute a health hazard which added to the traffic pollution would adversely affect the flora and fauna as well as the residents in the surrounding area. This will affect nearby houses and the long established Airport Café which is situated opposite the site which features an outside dining area. 
 
Yours sincerely
 
 
 
 
COLIN HUNTER
Chairman
For and on behalf of
LYMPNE PARISH COUNCIL
 
 
Copies to:
Sellindge Parish Council
Stanford Parish Council
Ms S Carey, Kent County Councillor

Mrs S Newlands, District COuncillor

 

 

——————————————————————————————————————————————————————————————————————————————————————————————————————

 Response from Shepway District Council

 
Y08f01241SH
TH
LOCATION:                                     Otterpool Quarry Ashford Road Sellindge Ashford Kent
PROPOSED DEVELOPMENT:         Consultation in respect of the construction and operation of a materials recycling facility, anaerobic digestion plant and associated office and parking facilities
APPLICANT:                                    Countrystyle Recycling Ltd Ridham Dock Road
lwade
Nr Sittingbourne ME9 SSR
Objection made 12.02.2008
REASONS
.. .-/
1       The Shepway District Council, the District Planning Authority under the Town and Country Planning Act 1990, has considered the details submitted with your consultation in relation to the above matter. Regretfully we have not had time to fully consult our colleagues in Environmental Health in respect of the aspects of noise and potential contamination. However, so as not delay consideration of the Council’s views in respect of other matters I propose to send to you the views of the Environmental Health officers under separate cover when they are available.
The Council, whilst fully supportive of the principle of this development, has strong reservations in respect of the proposal as it currently stands, and in the absence of significant amendments would wish to offer a formal objection to the application.
There are two principal concerns relating to traffic conditions, and to landscaping.
As you are probably aware the Link Park Lympne Industrial Estate at the other end of Otterpool Lane has been the subject of recent planning permissions that will see a substantial increase in both the area of land developed and the traffic generated. This will entail a considerable increase in the amount of HGV and other traffic on surrounding roads, with particular emphasis on the junction of Otterpool Lane and the A20, the junction of the A20 and the A261 Hythe Road, and junction 11 of the M20.
Detailed discussions with Kent Highways resulted in a Section 106 agreement for developer contributions to various designated highways improvements in the locality and to the requirements of a detailed Green Travel Plan.
It is the Council’s view that the traffic impact assessment submitted as part of this application does not take sufficient account of the change in circumstances that would arise should the Industrial Estate application be implemented with corresponding increases in traffic flows. It is therefore the Council’s view that the developer in this case should make a corresponding contribution towards these off site highway improvements and that the appropriate sum negotiated by Kent Highways should be lodged with them prior to the site first being brought into operation. It is also considered that an appropriate Green Travel Plan with appropriate monitoring contributions be negotiated and lodged with Kent Highways.
The Council is also concerned that the traffic assessment has been based almost entirely on the premise that traffic will for the most part enter and leave the site on the A20 from the east. Whilst this may well be a reasonable assumption given the state of existing knowledge about the potential source[s] of waste. However, there is no guarantee that actual operation will follow this model. Should a more significant volume of HGV traffic approach the site from the west the slowing and turning lorries would be likely to disrupt the flow of traffic on the A20. The Council would therefore wish to see a central reservation for turning vehicles so as not to cause other vehicles to have to wait whilst vehicles turn on to the site.
 
 


 

 
The second area of concern relates to the environmental effect the proposed development would have on the surrounding countryside, and particularly on the important views from the north, from within the AONB. The site is particularly prominent in the landscape and is relatively lacking in any natural tree or hedgerow cover. A position that appears to have been exacerbated recently by some fairly heavy pruning of the limited number of trees that exist on the frontage of the site.
It is the Council’s view that the application proposal should also be subject to a landscape appraisal to enable the decision makers to fUlly appreciate the impact this development would have on the surrounding countryside. The scale of building work proposed and the nature of the operation could mean that this proposal could have a very harmful effect on the surrounding countryside without some very extensive mitigating proposals for additional landscaping.
Irrespective, of whether the determining authority requires such an appraisal, it is the Council’s view that the proposed new landscaping as indicated in the current application proposals would be totally inadequate to achieve the necessary degree of long-term screening. The Council is also concerned that much of the existing landscaping is in the form of Leylandii [or similar] that would not normally be considered a suitable species for such a countryside location which adjoins a SSSI.
The Council is also concerned in respect of the long term future and the developer’s intentions in respect of that part of the current land holding that is not part of the application site. The western end of the holding is not within the application site but there does not appear to be any firm proposals as to what happens to this land. The Council would wish to see the developer clearly state what is to happen in respect of this land and to address such matters as part of the current proposals, at least in respect of the landscape appraisal and any consequent landscaping issues.

The Council would ask your Council as the determining authority to take account of the above concerns to this development proposal, and to approach the developer to request that these matters are addressed. Should they not be then the Council would wish to formally object to the application.

 

 

Development Control Committee, 29th July 2008

Y08/0124/SH  (click on the left hand reference to read the observations to be sent to Kent County Council)