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Freedom to operate 9am-5pm on 26 Dec 2016

The proposal to allow import & exportation of waste and recyclables at Hollingdean Depot this Boxing Day (26 Dec 2016) was approved unanimously by members of  Brighton and Hove City Council's Planning Committee Meeting on Wednesday 14th December 2016 Council Chambers, Hove Town Hall.  

However, a small concession was made to immediate residents who are regularly disturbed by industrial noise from these facilities. A condition was attached to the approval that 'import and exportation of waste should be limited to hours between 9am and 5pm.' 

Importation and export of waste to and from both The Waste Transfer Station and Materials Recovery Facility, which involves lorry movements, is currently permitted between 7am and 10pm on 363 days in the year. So this year, pemission for these movements will extend to 364 days.

Note sections 8.11 to 8.16 on page 221 of the PLANS LIST: including The Council's Environmental Health Department's comment in 8.11 that 'they do not have any outstanding noise complaints from the site.'

Perhaps the Council's Environmental Health Department could survey householders living on the north side of Princes Road to check that the complaint made about industrial beeping (see bullet point 3 below) arising from breach of Condition 7 of BH2013/02219 has been resolved.

Note that condition 7 used to be called condition 13. See Original planning conditions when BH2006/00900 was approved.

Residents are disturbed daily by industrial noise from this site, but the right agency to field our complaints is The Environment Agency and not The Council (Veolia's main client) 

  1. we are disturbed by industrial noise from Hollingdean Depot 
  2. it is the government's Environment Agency who set and control the terms of Veolia's licence to operate at Hollingdean Depot. They, not The Council, are responsible for complaints about noise as well as odour and dust. Brighton and Hove City Council (who, as Veolia's main client, are an interested party in BH2016/05369) should play no part at all in trying to intercept or discourage these complaints, which should go to the licencing body. The Council has chosen in the past to treat complaints as 'allegations' in responding to residents whose amenity has been disturbed.
  3. The Council does have a responsibility to enforce its own planning conditions. The sole planning condition originally called condition 13  when BH2006/00900 was approved relating to noise disturbance from Hollingdean Depot has never been enforced. Condition 7 of BH2013/02219 (note The Decision document listing this renumbered condition is missing on the Council's planning register) states: "no vehicles or machinery required for the operation of facilities in control of the operator of the development shall be used on site unless fitted with silencers maintained in accordance with the manufacturers' recommendations and specification." This condition is breached daily. The symphony of noisy "beeps" from reversing vehicles, which the site manager is not turning away, compromises residents' enjoyment of their homes and gardens on the north side of Princes Road. This is an outstanding noise complaint which neither The Council's Environmental Health Department nor The Enforcement Officer have acted upon.

Arguments used by BHCC officers  (BHCC is Veolia's 'main client' at Hollingdean Depot) in their recommendation ' To GRANT ':

See the PLANS LIST. The Hollingdean Depot application BH2016/05369 runs between labelled pages 211 and 221. For hard copy, set a print range from 219 to 230 (ten pages in all - a couple come out blank).

Note sections 8.11 to 8.16 on page 221 of the PLANS LIST

8.11 In terms of noise impact, Environmental Health Officers have commented on the application and have advised that given the works only relate to introduce collections on Boxing Day for this year only, the proposal is unlikely to have a detrimental impact on amenity. Environmental Health do not have any outstanding noise complaints for the site.

Resident's response to 8.11 of  the PLANS LIST 
I am not at all surprised that The Council’s Environmental Health Department does not have any outstanding noise complaints for the site. 
  • Those Round Hill residents who have submitted noise &/or odour diaries (as long ago as 2009/2010) to The Council’s Environmental Health Department have not seen adequate solutions follow. We know too that the nuisances stem from The Waste Transfer Station’s unsuitable location, which was bitterly contested when planning permission was granted in 2006.  So when legitimate complaints are thrown back to us as  “allegations” which would have to be heard in a Magistrates Court if we wanted to pursue them any further, the message we get from Environmental Health is that complaints are unwelcome.
  • It also seems that The Council’s Environmental Health Department's attempt to divide up responsibility for fielding complaints about “odour nuisance” (The EA) and “noise nuisance" (The Council) is a method of complaint minimisation. The right body to take complaints about NOISE as well as ODOUR nuisance is the Government’s Environment Agency. A petition reiterating that this is The EA’s responsibility, and not BHCC’s, can be viewed online at https://www.gopetition.com/petitions/downsizing-veolias-operation-at-hollingdean-depot-and-the-nuisances-caused.html - Noise nuisance comes within the terms of the “licence to operate” granted by The Environment Agency. It cannot pass as truly independent monitoring for The Environment Agency to direct complaints about noise nuisance to Veolia’s main client. My wife and I have phoned the government's Environment Agency on several occasions this year, primarily about odour nuisance, though we have also mentioned some of the occasions when we have been upset by noise. Both nuisances continue and we know that we will see no end to them [1] because the installations are in the wrong place and [2] there is no political will to address the unsuitable locations of the facilities for functions such as storing rotten food waste and glass tipping. We are trapped with these nuisances. I know of several residents in Princes Road who have moved away principally because of the impact of Hollingdean Depot. 
  • If there were political interest in the amenity of residents living near to Hollingdean Depot, the Council's Environmental Health Department and the government’s Environment Agency would not rely merely on complaint-led monitoring of nuisances such as odour, noise and fugitive particles. These bodies would be more proactive, if they could afford to be. A simple survey allowing open comment from residents living in the vicinity of Hollingdean Depot would allow  The Council’s Environmental Health Department to get a true picture of how we are affected, but the political priority of managing the city’s refuse/recyclables collections as cheaply as possible is a stronger one. 


8.12 Turning to odour, a number of objections relate to increased odour, resulting from the use of the site as a WTF and MRF. The continued use of the site on Boxing Day may reduce the potential for odours from being created. In theory the intention of working more days, refuse would be collected quicker and not have the opportunity to deteriorate and generate odours. This is particularly relevant to this scheme, given that previous years the non-working days can result in up to three weeks delays which could potentially lead to increased levels of odour from rubbish and recycling been stored.

Resident's response to 8.12 of  the PLANS LIST 

8.12 - The argument that extending the operation times (for import/export) would allow odorous waste to be collected quicker (before further degeneration) was also used to justify allowing Sat / Sun / Bank Holiday import/export  when BH2013/02219. Since the approval of BH2013/02219, the instances where we have felt compelled to phone the Environment Agency about odour nuisance have actually risen. However, this is a hot weather problem (which is with us unfortunately from spring to autumn and becomes sickening when the wind is blowing in our direction). In relation to winter, especially 26 December 2016 when we have family staying, the respite we are requesting through refusal of BH2016/05369 is from noise nuisance.


8.13 Hollingdean Road is located within AN Air Quality Management Area. The Councils Environmental Health team has reviewed the submitted supporting information and consider that the proposed changes are not likely to be significant in terms of their impact upon air quality. This is due to there being no additional vehicular movements to and from the site.

8.14 It is noted that the adjoining residents currently do not experience continued working at the site on Boxing Day, however it is not considered that the proposed variation of conditions would result in a significant impact upon the amenity of the adjoining residents in terms of noise and disturbance, odour or air quality in accordance with policies QD27, SU9 and SU10 of the Brighton and Hove Local Plan.

8.15 Sustainable Transport.
The Sustainable Transport team have not raised any objection to the scheme and have advised that given the proposal would not result in additional transport movements at the site.

Resident's response to 8.13 to 8.15 of  the PLANS LIST 

The assurances in these sections of The Plans List  - that the variation proposed in BH2016/05369 would not result in significant impact upon air quality, odour, noise and disturbance - are unsubstantiated; otherwise, they would undermine the need for the planning condition in the first place. 
Backing for these claims would require a truly robust noise assessment, proactivity in monitoring odour nuisance instead of waiting for complaints, and actual measurement of the dust particles which emerge from open doors, trucks and are blown by the wind into the north of Round Hill.
  • The most thorough Noise Impact Assessment to date relating to impacts from the Hollingdean Waste Transfer Station and Materials Recovery Facility was carried out by Clarke Saunders Associates on 3rd July 2013 . There is plenty of detail in this document, which is good in pinpointing where different noises are coming from, but I am massively disappointed that the manual monitoring positions (where microphones were placed to record noises which disturb residents in my street) were so far away from the noise sources. See attachment. The nearest monitoring points in Round Hill were [position 3] the junction of Richmond Road / D’Aubigny Road i.e. by Richmond House and [position 4] Wakefield Road / Richmond Road / Princes Crescent i.e. one position even further away from The Waste Transfer Station (the main source of the noise). When most noise nuisance complaints come from residents in streets like Princes Road and Mayo Road or the part of Richmond Road nearest to Mayo Road, I cannot understand why no monitoring positions have been set up in the streets (or gardens) of residents experiencing the adverse noise impact.
  • The air quality management concerns addressed to date by The Council relate to the effects of traffic fumes on Hollingdean Road and The Vogue Gyratory. Although transport to & from Hollingdean Depot may contribute to this, residents in Princes Road need regular 'air quality assessments' relating to fugitive particles emerging directly from The Waste Transfer Station. Window cleaning to the rear of homes on the north side of Princes Road has short-lived benefits. No air quality assessment has been carried out in residents gardens to the south of these industrial facilities. The Waste Transfer Station, in particular, has proved unfit for the purpose of containing odour particles. The odour molecules are carried with dust when the wind is blowing in our direction.
Six new homes to the NE of Princes Road could come into occupation when their Gatehouse Lift has been completed later in 2017. They will be much nearer to The Waste Transfer Station than my own home, which  itself is far too near for uninterrupted peace of mind. In this context, a Council which is fairly balancing the needs of the city should be planning to take glass tipping and food waste storage to more suitable locations. While I know there is no money for better environmental practises such as composting food waste (as recommended by DEFRA), I urge you to vote against application BH2016/05369. Those who argue for it simply have no interest in giving residents living in the vicinity of a badly located Waste Transfer Station as little as two days a year respite from unwelcome disturbances. I look to you for fairer balance.


8.16 Conclusion
The proposed variation of the conditions would not result in a significant impact on the amenity of adjacent properties or highways safety and congestion. The variation would also allow the site to continue operating in an efficient and effective manner in accordance with local plan policies in respect of a city wide approach to waste management.













Sample Objections

to planning application BH2016/05369 requesting full operation of the Dump on Boxing Day 2016

[1] Detailed PDF extract the details you want - needs shortening

[2] Simple plea PDF you will need to adapt this






These households in the vicinity of the WTS and MRF already experience noise from the WTS and MRF which can irritate them any time between the hours of 0700 to 2200 Monday to Sunday including Bank Holidays.

Weekend and bank holiday respite from these long operating hours was removed by condition 3 BH2013/02219 - a relaxation of the conditions set when these facilities were originally approved in 2006. Christmas day and Boxing day are the sole times when these residents can expect a lower level of interruption from banging, booming and beeping and the intermittent sounds of glass being tipped. 

Existing breaches of the conditions

  • Condition 7 of BH2013/02219 which states: "no vehicles or machinery required for the operation of facilities in control of the operator of the development shall be used on site unless fitted with silencers maintained in accordance with the manufacturers' recommendations and specification." This condition is breached daily. We take pleasure in gardening, but it is greatly irritating when there is a symphony of noisy "beeps" from reversing vehicles which the site manager is not turning away.
  • Note that condition 7 used to be called condition 13. See Original planning conditions when BH2006/00900 was approved.

This breach of condition is not only noticed daily by residents, but was highlighted in Noise impact assessment carried out  by Clark Saunders Associates on 3rd July 2013 for Brighton and Hove City Council. See 2.1.4. "All Veolia vehicles (including HGVs) have ‘white noise’ smart reversing alarms, in line with Condition 10 of the Planning Permission. However it should be noted that the various vehicles which come from different sources and are managed by different organisations, can have different forms of audible reversing alarms."

This page was last updated by Ted on 11-Sep-2018
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