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Save the Sett Valley Group

Birch Vale Landfill – Please have your say again

Once again, you have the right to comment on a planning application which will have enormous implications for our community for many years.

In August 2000, some 300 local people objected to a planning application to extend Arden Quarry Landfill site into the adjacent Birch Vale Quarry.

Now, you can see an amended version of the same planning application in New Mills Library and Town Hall.

Please have your say by writing to: Mr D Harvey, Director of Environmental Services, Derbyshire County Council, County Hall, Matlock DE4 3AG

April 25th 2003 is the deadline for sending in comments – don’t give up if that’s too short a time – the council may consider comments received later. A letter in your own words is best but if you agree with the suggestions overleaf signing and sending them would be better than doing nothing.

THE MAIN PROPOSALSTipping of 1,220,000 cubic metres of household, commercial and industrial waste

This leaflet comes from SAVE SETT VALLEY GROUP - formed in 1999 by Birch Vale and Hayfield Residents. We stated one of our aims to resist this planning proposal, and having studied the amended application this is still our view. Although the plans are scaled down many of our objections still stand.

In the suggested letter bellow we list the main planning considerations which we believe the proposal fails on. There are many other aspects of the plans which seem unacceptable. We need more time to look into these, not least because this application is presented in a confusing way. Here are some of these issues:

The figures given for rate of filling and number of vehicle movements appear inconsistent with each other and with the current rate of infill in Arden Quarry, and so lack credibility.
The application is based on a claim that permission has been granted for final contours for Arden Quarry landfill. We believe these contours breach a planning condition requiring the finished levels not to exceed the height of the nearest unworked land and do not believe that permission for these contours has been granted.
Pollution can be prevented only if the engineering and operating procedures are excellent. To judge from the record at Arden Quarry, future operating procedures may not be excellent - the landfill operators have recently been fined for several breaches of their licence.

Please see www.hayfield.uk.net and www.newmillsweb.com over the next few weeks for more detailed comments on the planning application from the Save Sett Valley Group

If you would like to help or support us, please complete this form and send it to

Save Sett Valley Group, c/o 5 New Mills Road, Birch Vale, High Peak SK22 1BT

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To use this letter of objection, copy and send to Mr Harvey

(Your address)

(date)

Mr D Harvey
Director of Environmental Services
County Hall
Matlock
DE4 3AG

Dear Mr Harvey

I object to planning application code CW1/199/128 as amended in 2003 because I consider that:

Unacceptable loss of amenity would be caused to the community through smell, litter, birds. Experience at Arden Quarry has shown that landfill in this location has severe effects on local people. Strong enforcement action and improved site practices have not reduced this harm to an acceptable level. For the properties on Oven Hill Road the increased HGV traffic would result in intolerable noise.

Unacceptable harm to human health would be caused by offensive odour. Regardless of the uncertainty about possible health impacts such as increased rate of birth defects resulting from living near a landfill, landfill smells can undoubtedly cause headache, nausea and stress which can drastically affect quality of life.

Unacceptable impact on road safety would be caused by the increased traffic levels and substandard access

Unacceptable visual impact on the Peak District National Park and Special Landscape area would be caused during operations (for example by litter nets on the skyline) and in the longer term due to proposals for the finished height of the landfill to breach the skyline to the east

Unacceptable impact on social and economic interests of the community would be caused by smells and litter adversely affecting the development of tourist-related economic activity and outdoor recreation

Unacceptable risk of pollution to groundwater or hazard through migration of landfill gas would arise due to the fractured and fissured nature of the local geology.

The need for the development is not clear – there is tipping space in Arden Quarry for several years. The County Council should strictly limit landfill space in order to encourage more re-use, recycling and composting.

 

Yours faithfully


This leaflet comes from SAVE SETT VALLEY GROUP
c/o 5 New Mills Road, Birch Vale, High Peak SK22 1BT

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Planning Application Code No CW1/199/128 as amended in 2003

The Save Sett Valley Group wish to make the following representations in objection to this planning application as amended.
This is a joint submission to avoid duplicating shared objections and observations, and individual members of the group may also submit additional comments of their own.

The Save Sett Valley Group commissioned a report from Mobbs Environmental Investigations which was submitted in October 2000 in the consultation on the previous version of this planning application. Much of this report is still relevant. The report will be reviewed and an updated version will be submitted as soon as is practicable.

The following are the matters on which we consider that the proposals fail to demonstrate conformance with policies, regulations etc, and hence warrant refusal of planning permission. Additional details will follow as soon as is practicable.

Environmental Impact Assessment regulations

It may be arguable that the regulations which apply to this amended planning application are the Town and Country Planning (Environmental Impact Assessment0 (England and Wales) Regulations 1999. The applicant states that he considers the applicable regulations to be the T & C P (Assessment of Environmental Effects) Regulations 1988, as amended. Even by these less stringent criteria we submit that the regulations have not been complied with because

The development has not been adequately described

Data necessary to identify and assess the main effects that the development is likely to have on the environment have not been adequately presented

The likely significant have not all been adequately described

Measures envisaged to avoid, reduce or remedy those effects are not adequately described

Overall, the presentation of the planning application and the Environmental Assessment is muddled and confusing. It is not possible to understand what is being proposed clearly enough to assess the proposed operation and its impacts, hence not possible to set limits to ensure that these impacts would be acceptable.

Additionally, it is not possible to assess the impacts of this proposal without a clear statement of
the scale and duration of Arden Quarry landfill operation and how it relates to this proposal.

Details of the planning permission being sought for additional stone extraction from Birch Vale Quarry. At the Arden Quarry Liaison Committee meeting of 27/09/01, Mr Cox representing Planning Control reported that it would be advantageous if the stone extraction and the infilling were dealt with as one application. The lack of reference to this activity at the site leaves unacceptable uncertainty with regard to the scale, impact and duration of operations.

Planning policy considerations

The proposals are considered here in relation to Waste Management Policies 1,2 and 3 of the Derby and Derbyshire Joint Structure Plan adopted in January 2001, and policies in the Derby and Derbyshire Waste Local Plan First Deposit June 2002 (abbreviated as DDWLPFD). These are taken together as the DDWLPFD policies flesh out the Structure Plan policies and bring in considerations of the Waste Management Strategy.

Sustainable Development

It is not shown that

The proposed facility would offer an appropriate part of the BPEO for the waste streams with which it would deal

That the particular waste streams to be processed at he facility could not be processed, at acceptable cost, by other facilities at a higher level in the hierarchy or will have been subject to processing at a higher level in the hierarchy

That the proximity principle and self sufficiency principle apply to the waste proposed to be imported from Greater Manchester (because they appear to use AQ at weekends and bank holidays only- so it must have somewhere more sustainable to go at other times – only comes to AQ when other sites closed (I am speculating)

That the development would not materially harm the area’s social needs or economic prospects

Need for landfill

It is not shown that the development is essential to satisfy a need to dispose of locally generated waste which will nor otherwise be met. The applicant refers to the statistical shortfall of landfill space in the West Derbyshire Sub-Area over the period covered by the DDWLPFD as shown in Appendix B of the DDWLPFD, as justification for these proposals.

The assumptions and calculations set out in Appendix B of the DDWLPFD should be considered in the light of the following.

1.Void space remaining in Arden Quarry landfill site.

It is stated in the West Derbyshire Sub-area Waste Management Strategy, and repeated in DDWLPFD, (p.56, 5.21) that this site will probably be full by 2004. This is an error. Members of the Save Sett Valley Group were informed in July 2001 by the Technical Manager of Lancashire Waste (now SITA) that the void space was estimated to be sufficient for 20 years tipping.

The Environment Agency’s Strategic Waste Management Assessment gives the void space remaining in Arden Quarry as 1.8 million cubic metres at the end of 2001.

2.The volume of locally generated waste that can be disposed of in landfill.

In DWWLPFD, p56, 5.20 we read that most of High Peak’s municipal waste goes to landfill at Arden Quarry. This planning application states (Environmental Statement 4.3) that over 90% of the waste being delivered to Arden Quarry originates in Derbyshire and a high percentage of this is made up by the HPBC contract.

The waste input levels at Arden Quarry were stated by the Site Manager, at the Arden Quarry Liaison Committee meeting on 03/04/03 to be currently approximately 1,500 m3 per week. Waste input levels in Arden Quarry recorded by the Environment Agency are given as follows

 ReturnYear   SumOfInputTotal  PeriodStart   PeriodEnd
 2001   39905.56982   01-Aug-01  31-Mar-02
 2002   51903.04004   01-Apr-02  31-Dec-02
Table 1

It is clear that on this evidence of the levels of locally arising waste, there remains void space in Arden Quarry sufficient for many years.

The degree to which the waste arriving now at Arden Quarry is pre-treated is also a consideration in estimating local future landfill requirements. Currently, there are kerbside collections for paper dry recyclables in some areas of the High Peak, and it is expected that these will be extended in the near future. The feasibility of a separate green waste collection is also under consideration. It is not sufficient for the applicant to state that "most of the waste arriving at the site will have been sorted prior to delivery". An estimate of the volume thus removed from landfill should be included and the consequent reduction in need for landfill space taken into account.

This application’s anticipated maximum rate of input in the order of 250,000 m3: exceeds the current rate of input by over 3.5 times. (If we take the input totals for April – December 2002 from Table 1 to estimate the total input for the whole year 2002 we see that the average monthly input was 5767 (51903/9=5767). This gives an annual total of 69204 (5676x12). It is pertinent therefore to ask where the additional wastes are proposed to come from and how they are justified in terms of BPEO, the proximity principle and, if from out of Derbyshire and the East Midlands region, by reference to regional self sufficiency policies.

In 2008 when this development is expected to commence, the annual amount of waste allowed to landfill in the West Sub-Area of Derbyshire, in accordance with the requirements of the landfill directive, will be 278,113 m3, and will decline each year thereafter. The DDWLPFD does not envisage that such a high proportion of all the waste going to landfill from the whole sub area would be appropriately disposed of in Birch Vale.

Reclamation and restoration of landfill

In view of the comments above, it is clear that the application does not demonstrate that sufficient waste and other fill material is likely to be available within reasonable proximity to the site to achieve restoration of the site within the proposed timescale.

It is stated that materials for restoration will be stockpiled. Details to enable assessment of the acceptability and feasibility of this stockpiling are not provided

There is reason to question the likelihood of the proposed restoration being satisfactory. Soil was stored in breach of condition on part of the Special Landscape Area in the south east corner of this site in 1998. Almost 5 years later it has not proved possible to restore this area, which has been unsightly for all that time and appears to be still barren of vegetation despite 2 attempts to seed it with grass to provide conditions in which heather could be re-established.

Sorting of Waste before disposal to landfill

It has not been shown that facilities will be in place for sorting of reasonable quantities of recyclable and compostable materials

It has not been shown that the proposed standard of facilities and method of operation are realistic and reasonable in the context of an integrated waste management system. In particular there are significant problems with proposals to treat waste on site prior to disposal.

It is not he case that Arden Quarry is operated to maximise the recycling potential of unsorted materials arriving through the gate.
The impacts of screening, stockpiling and transport out of the site would be significant. They would include health and amenity impacts through the potential for dust, odour, biological aerosol dispersion during the handling of the materials; odour and attraction to vermin, insects to stockpiled materials; and additional traffic generated by transport out of the site.
In addition to the odour acknowledged in the application to be generated by composting the degradable fraction of municipal waste, there are concerns about health impacts due to the dispersal of biological aerosols, such as bacterial spores.
It is not clear that there would be space available in the site to accommodate these operations.

 

Landfill in green belts and its proposed afteruse

(waste developments other than landfill will not be permitted in green belts)

There would be material impact on the open character of the green belt during the life of this operation due to engineering associated with proposals for screening, sorting and stockpiling waste streams. Additional facilities for pollution control over and above those serving Arden Quarry could be required and would likewise impact on the open character of the green belt

 

Forms of waste development other than landfill (screening, sorting etc) are being proposed here contrary to this policy.

Identified interests of environmental importance

1.Landscape

The proposal fails to properly consider the likely impact of these proposals on the nearby parts of the Peak District National Park and special landscape areas to the south and east of the site, which merit the highest level of landscape protection. They would be materially affected during and after this proposed development.

2.Nature Conservation

European level special protection area for ground nesting birds:

There are grounds for concern that the seagulls attracted by AQ landfill site roost and breed on Kinder Scout, and are a threat to (WHAT SPECIES? Lapwings, golden plover, curlew—other?)

Local nature reserves:

The non-statutory site Ollersett Reservoir comprises the rough grassland field adjacent to the southern end of the BVQ triangular area. There is a risk that this area will be damaged by changed to land drainage, and the import of weed seeds which reach the area by wind or by birds.

3.Water
The possibility of groundwater contamination and pollution are relevant to the acceptability or otherwise of this proposed land use, and are a planning matter.

4.Air Quality

Toxic gases: The predicted emissions of NO2 from the electricity generation development permitted for AQ approaches the acceptable limit. The planning authority needs to take due regard of the possibility of this limit being exceeded were this development to go ahead.

Dust: The submitted information in respect of dust resulting from the development is inadequate.

Detritus:??(litter and stuff dropped by birds)

Pollution and related nuisance

Material harm would be caused to

The local community
by the production of dust particles and other harmful emissions through emissions of HGV traffic

The emission of unpleasant odours

Attracting birds to the extent that they materially reduce the quality of life of local communities

The emission of noise and vibration from the HGV traffic passing properties on Oven Hill Road as predicted in the Environmental Assessment, and (Jack please could you summarise the omissions in the EA here)…

The production of litter which could threaten the safety of livestock or wildlife, pollute watercourses have a harmful visual impact and materially reduce the quality of life of local communities.

The emission of noxious or greenhouse gases…

The dispersal of mud or contaminants on the highway with resultant danger to vehicles or pedestrians

The leaking or leaching of contaminants

Would pollute aquifers…

Disrupting or blocking local drainage systems

 

Impact of the transport of wastes

The proposed access arrangements would have an unacceptable impact on road safety

They would cause significant disturbance to the local community

Traffic from South Manchester would be likely to use the A624 leading to increased traffic on roads in the PDNPark

Protection of other interests

The rural economy

Effect on surrounding farmland

Effect on tourism

Cumulative Impact

This development would result in significant and detrimental impact on the environment of the community of Birch Vale

The area is already suffering form the effects of landfilling and quarrying

It would not be reasonable to expect the community to accept the additional predicted traffic noise and other emanations from the proposed development in combination with the impacts from the community has experienced environmental disturbance for a long time

It would not be reasonable to continue to expose the community to future disturbance the existing activities

This information comes from SAVE SETT VALLEY GROUP
c/o 5 New Mills Road, Birch Vale, High Peak SK22 1BT


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