Life near the Dump
Hollingdean Depot - where to complain
Troubled by noise, smell or dust from The Waste Transfer Station at Hollingdean Depot? Phone (free from landlines):The Environment Agency on 0800 80 70 60 since it is they who set and control the terms of Veolia's licence. The system of monitoring is complaint-led, so if you want The Environment Agency to understand the extent of the problem, you need to let them know each time you feel unreasonably affected by
- odour escapes (see section 3.4 of operating licence)
- industrial noise - for example, repetitive beeping from old-style reversing sirens unauthorised on site - is a failure of Hollingdean Depot's site manager to prevent or minimise noise disturbance, contravening section 3.5 of the EA's operating licence as well as breaching the Council's own planning conditions
- fugitive emissions (dust or smaller particulates)
see section 3.3 of the EA's operating licence
from Hollingdean Depot. If 3 households complain about the same incident on the same day, they will investigate.
How have they followed up your complaint?
If you have already complained to 0800 80 70 60 and you want to know what follow-up action has been taken, phone The Environment Agency's General Enquiries number on 03708 506506.
Action depends on sufficient complaints
The Environment Agency will come out to witness the odour on days when they receive three separate complaints. Monitoring is complaint-led. No complaints and the EA will assume that residents are happy. As the operating licence makes clear, The Environment Agency is the body which needs to know about unreasonable noise, odour, escapes of dust, etc from Hollingdean Depot. We do not recommend complaining to Veolia or The Council. Phone the EA on 0800 80 70 60 instead.
The Environment Agency (see their factsheet) takes a special interest in Round Hill's concerns. After your complaint has been officially logged, you might want to ask if they could give you a call back to explain the problem and say what is being done. They will give you a reference number for each complaint.
Brighton and Hove City Council's avoidance of the costs of separate collection is prolonging the incineration of food waste. Though criticised by The Department of Environment Food and Rural Affairs, this poor environmental practice escaped a ban when laws were introduced to limit landfill. Currently, Veolia is providing the service requested by our Local Authority.
- See Going for the burn [The Guardian 22-02-2006] on the harm done through the incineration of waste.
Where Veolia is to be encouraged:
1. To Veolia's credit, they state on their website their commitment to better ways of using food waste (i.e. producing renewable energy using an Anaerobic Digestor). Processing our city's food waste through Anaerobic Digestion would not see it mixed in with other refuse at a Waste Transfer Station too near to residential areas.
In response to a petition signed by 4,187+ people, organised by Hanover resident Tea Meneghetti and calling for Brighton and Hove City Council to recycle a wider range of plastics as well as food waste, Councillor Leo Littman disclosed that 30 per cent of the waste sent for incineration at Newhaven was food, which he described as “obscene”. For ideas on how to change the situation, see:
- See WRAP's article on:
the collection and recycling of food waste by Local Authorities - Jane Wilde's presentation on the use of food waste for Community Composting. She states that the very worst thing that we could do with food waste is to incinerate it together with other black bag waste.
The incineration of 3000 tons of food waste requires 870 tonnes of water - water which could be saved for far better uses.
There is great scope here for improving our management of waste in Brighton and Hove. Food waste accounts for 25%-30% of the waste stream (our black bag waste). Together Kitchen and Garden accounts for betwen 30-35%. By separating out this waste, which should not really be with the rest of the black bag waste, the 65%-70% which remains in the black bag will be a lot cleaner. This will make Materials Recovery and Recycling a lot easier and will encourage residents to recycle those plastics which Veolia's 30-year contract obliges the company to accept as recyclables. See Caroline Lucas's question to the Government's Environment Secretary Michael Gove on the constraints of the 30-year PFI contract in relation to the range of plastics accepted for recycling at Hollingdean Depot.
2. Veolia is also to be congratulated for improvements at their Wilson Avenue recycling site where residents of our city can support good environmental practice by [1] contributing garden waste &/or [2] buying Veolia's Pro-Grow garden products (soil & lawn conditioner / peat-free multi-purpose compost / woodchip mulch / bark chips / etc). Fortnightly garden waste collections from your home are available through The Council for £70 per year.
Is it worth complaining to Veolia directly?
You can inform Veolia's Site Manager about odour &/or noise by email , phone 01273 544 205) or write to Hollingdean MRF/WTS, Veolia Environmental Services (UK) Plc, Hollingdean Lane, Brighton BN1 7BB. However, ensure that your complaint is made first to The Environment Agency 0800 80 70 60 so that it is logged by the licensing body which permits Veolia to operate.
Action taken so far - diagnosis & solution
The Environment Agency has recently responded to residents reporting odour nuisance from The Waste Transfer Station during the period August 2013 to August 2014.
Chris Parkin from the government's Environment Agency has identified the 2 biggest problems which cause odour nuisance - "the design of the building and the nature of the waste received. The primary odorous source is the food waste contained within domestic refuse. The only possible way to remove that is for the local council to instigate separate waste collections for food waste, which would be a huge undertaking for them."
Is the use of deodorisers making the food waste more odorous?
Click here to read about an attempt in September 2014 to suppress unpleasant smells from Hollingdean Depot. The problem remains in May 2015 and continues to be of concern both to nearby residents and the Downs Infants School.
See also The Environment Officer's diagnoses of the main problems.
Click here for The Environment Agency's response to
odour nuisance from Hollingdean Waste Transfer Station
[monitoring period: August 2013- August 2014].
The system of monitoring is complaint-led. "No complaints" indicate "no problem". The Environment Agency sets the terms of Veolia's operating licence.
Longer operating hours have not helped
7 Aug 2013: Extension of operating hours at Holllingdean Depot
One of the advantages claimed, when the operating hours of The Waste Transfer Station were extended to "15 hours per day every day" in August 2013, was the flexibility to move black bag waste on quickly.
In arguing the case for weekend & bank holiday import & export at Hollingdean Depot, giving residents significantly less respite from industrial noise, it was claimed that freedom to import/export smelly waste during weekends and Bank Holidays would ease the odour nuisance since waste would no longer need to remain stored within The Waste Transfer Station from Good Friday to Easter Monday inclusive; it could be moved on quickly.
Residents living near The Waste Transfer Station notice no change. The verdict of the officer from The Environment Agency who was assigned to investigating odour nuisance from the Hollingdean Waste Transfer Station between August 2013 and August 2014 is that the building cannot contain the odour from a constant stream of food waste and that separation of the latter is the only complete solution. See his letter to residents affected by odour escapes.
- Hollingdean Depot history 2006-2015: see Veolia 0000 Index
- Odour nuisance from Hollingdean Depot
- Life fighting a proposed Dump in North London
- New technology to eliminate waste stations' stink -The Argus, Thursday January 3, 2013 - the zapping technology did not receive the approval of The Environment Agency and it did not work. The problem is a buiding unfit for the purpose of containing the odour from rotting food waste.
Update: September 2012
The odour nuisance to residents in Princes Road has remained, yet active carbon filtration for the Waste Transfer Station has been abandoned as unlikely to be effective (building too porous) and too big. Now looking into a UV lamp/ozone system for breaking down odour molecules. May have pilot in place before the end of 2012.
March 2012 - breach of planning condition 
Condition 16 of The Council's planning conditions for Veolia's
MRF and WTS requires: doors to be kept closed when lorries are not going in or out
Visual impact on conservation area Landscaping south of Waste Transfer Station stripped away You would expect planning conditions to require more landscaping when a Waste Transfer Station is sited next to a residential community.
The Round Hill conservation area ended up with far less, especially along the Coastways railway corridor, which separates Hollingdean Depot from our homes and gardens. Much of this designated greenway, still an important habitat for wildlife, was stripped of trees while the MRF, WTS and Visitors' Centre were being constructed.
Land to the rear of 67-81 Princes Rd in September 2004 
Land to the rear of 67-81 Princes Rd in October 2007 
The level of nuisance varies depending on wind conditions and work patterns, but the nuisance is very frequent and by no means limited to periods following Bank Holidays when there is a backlog of black bag rubbish to transfer. The nuisance disturbs residents within their homes and prevents residents enjoying their gardens even at weekends.
I live nearer the Materials Recovery Facility, but several times further from the Waste Transfer Station, than residents living at the NE end of Princes Road (between No. 67 and 81). Nevertheless, pollution from the Waste Transfer Station causes me the most nuisance.
Odour is an almost constant nuisance and is often so strong that I am deterred from using my back garden. It sometimes gets carried to houses on the south side of Princes Road, travelling in gusts of wind up Princes Road and hitting residents on both sides of the street as they open their front doors. One of our local Councillors has described the smell as nauseating. Visitors to my home have described the smell as sickly and similar to what you experience when you are walking just behind a dustcart.
Experience of complaining
Some of the methods used by The Environment Agency to respond to residents' complaints made us doubt whether Veolia would be asked to make a serious attempt to measure odour nuisance and to come up with solutions. Initially, some residents were asked to:
i) describe the odour, tie it to particular times, and
ii) rate it on a scale of 1 (slight problem) to 6 (very bad - makes you feel sick).
I refused to do either, explaining that the description of the odour was no mystery to anybody in Princes Road - i.e. the EA (& anybody working or walking in the vicinity of The WTS) know exactly what the nuisance is already.
I found it extraordinary that an Environment Agency - an institution which I would expect to use more scientific monitoring measures - should ask me for my own subjective rating of an odour on a scale of 1 (slight problem) to 6 (very bad).
Generally, residents do not phone organisations such as The Environment Agency unless they have significant and reasonable grounds for complaint.
Standard methods of complaint-minimization do nothing to mitigate nuisances caused to residents.
Instead of asking residents to rate what has driven them to complain, it would be preferable if an Environment Agency could tell them what systems are in place for the scientific measurement and minimization/control/management of the odour.
It would be an abdication of responsibility if a regulatory body lacked a scientifically-based system of monitoring the nuisances it is meant to control.
When planning proposals are submitted, Council's require noise surveys & reports and developers employ acoustics specialists to perform scientific measurements. These specialists are expected to describe their methodologies so they can be scrutinized by anybody participating in the planning process. What is passing for science or best practice should always be subject to scrutiny.
I would expect an Environment Agency to use a recognised methodology for measuring whether emissions of odour from a Waste Transfer Station are at reasonable and acceptable levels. Also the public ought to know, in scientific terms, what levels are deemed to be acceptable.
Instead, it seems that the system is complaint-based, and the Environment Agency wants local residents to log reports of unreasonable nuisance when they are troubled by odour, noise or dust, so that they have a sufficient evidence base of significant nuisance to require action from Veolia.
Visual Amenity V Odour, Dust & Noise
Residents living in part of Edinburgh have just won their fight to have an appeal for reconsideration of a giant Waste Transfer Station in their area dismissed. It was ruled that the development would have damaged the character and appearance of the Portobello conservation area. The appeal was mainly dismissed because of the impact on visual amenity.
Residents from The Portobello PONGS Campaign Group wrote to thank The Round Hill Society for sharing comment on the nuisances of living near a Waste Transfer Station, but they lamented the complacency of the authorities in relation to odour, fugitive particles and noise pollution.
It (The victory) cost our ‘village’ community a lot of time and effort but reading Round Hill’s lists of noise, pong and airborne dirt – well it gave us extra determination!
The only annoying thing is that the judges listened only to the arguments made regarding the aesthetic look of the building rather than the other more vexing pollutants – these were dismissed as manageable and would be ‘subject to license’.
Obviously we would be in your situation had they also dismissed the “visual loss of amenity” and allowed the application.
Had permission been granted for the Waste Transfer Station effectively opposed by The Portobello PONGS Campaign Group, then the licencing body which would have had to manage the nuisances described as "more vexing than loss of visual amenity" would have been The Scottish Environment Protection Agency (SEPA) - the Scottish counterpart to The Environment Agency (EA), the regulatory body in England and Wales.
The Scottish Appeal Inspector's confidence that SEPA could manage odour, noise and fugitive particles, might well rest on knowledge of emerging technologies, such as Odour Control Plants to deal with the more vexing nuisances which Waste Transfer Stations cause to residents living nearby.
Complaining to the EA 0800 807060
It is really up to local residents to monitor whether they are being observed, because Veolia just gets on with its work. The terms of its licence do not require it to monitor its operation, though the company was asked by The Environment Agency last summer to implement an Odour Management Plan in response to a spate of complaints from local residents. Initially, many complaints were about noise. Through winter 2009 and Spring 2010 most of the local nuisance has been caused by odour.
These facilities are meant to operate within
1) the terms of their licence from The Environment Agency and
2) in accordance with the Council's Planning Conditions
Breaches of the EA's operating licence
If you are troubled by noise, odour or dust particles from The Waste Transfer Station &/or Materials Recovery Facility at Hollingdean Depot, phone The Environment Agency on 0800 807060. They will log your complaint.
Breaches of Planning Conditions
The Council's planning conditions, which include condition 16 requiring doors of the MRF/WTS to be kept closed when lorries are not going in or out, are somewhat different from those set by The Environment Agency, which grants Veolia a licence to operate its facilities. 
If one or more of the Council's planning conditions are being breached - e.g. condition 16 forbids leaving doors open while no vehicle is entering or leaving the WTS/MRF - contact Brighton and Hove City Council's Senior Environmental Health Officer.
Keeping a nuisance diary
During the early summer of 2009, the Environmental Health Officer suggested that local residents should keep diaries to log the nuisances caused by the WTS and MRF.
My own sample diary written in 2009 mainly described the problem of noise, though odour is now (in 2010) reported by many local residents as the major nuisance.
Reporting systematically and for significant periods of time on unpleasant nuisances has the disadvantage of making them the centrepiece of residents' lives. Should it not be the wider public purse (Council & EA) which is monitoring these nuisances? Are the Council and EA not abdicating their responsibilities by making the residents most affected by pollution into the front-line monitors?
Local residents' comments
Wastewatch comment - 10 Feb 2010
"Horrible acrid smell for most of afternoon Tuesday 9 Feb on Princes Road, and in our garden. This is almost daily I can smell the WTF in Princes Road."
(Householder living towards the west end of Princes Road)
Comment from Hollingdean - 6 Feb 2010
Rob Stephenson receives a phone call from a lady living off Davey Drive (Widmore Close) saying there was a terrible smell from tip last week (the last week of January).
Wastewatch comment - 26 Jan 2010
"There has been an appalling smell every day for the last week or so in Princes Road. Particularly bad in the mornings"
(Householder living near junction of Princes Rd and Crescent Rd)
Ward Councillor Pete West's comment - 24 Jan 2010
On the morning of 24th January there was a very strong and unpleasant odour present along the whole length of the road. It was strongest at the top, nearest the Waste Transfer Station. Personally I found it quite nauseating. One resident near the top of the road stated that this was not an unusual state of affairs, the stink from the dump is present at least twice a week regardless of busy or difficult periods around the holidays or as experienced with the disruption caused by the snow. I am pretty dismayed by this, as ward councillors have been repeatedly assured that smells are contained and neutralised. I also noted that the noise from machinery at the WTS was pretty loud, and this is contrary to reassurances we have been given too. Cllr Davey and I visited the site earlier last year and were told the problems experienced at the beginning of last year were teething troubles now resolved. This seems does not seem to have been the case, can you explain how it is that these issues have persisted and what contractors are being asked to do to prevent them.
Waste left uncollected:
odour in & around Hollingdean Depot
Veolia's John Collis admitted to local residents that "black bag waste will start to smell if it is not moved on the same day or the day after." (Under Veolia's licence the black bag waste can be stored in the Hollingdean WTS for up to 72 hours.)
There is going to be some odour, but expect the problem of containing it to be more difficult during hot weather. Icy roads are just one reason why waste may be left uncollected for more than 24 hours. Industrial action is another. Smelly waste taken in by the Waste Transfer Station at Hollingdean Depot could come from far and wide, not only Brighton and Hove. When it does, as was the case last July and August during hot weather conditions as opposed to a cold spell, Veolia ought to have an odour management plan in place other than sending us letters of apology like this one:
"We thank you for your understanding" 
Dear Sir or Madam
Hollingdean Materials Recovery and Transfer Facility, Hollingdean Lane Brighton - Requirement for Saturday Working on 23rd and 30th January 2010
Veolia Environmental Services has been requested by Brighton & Hove City Council's Waste Collection Authority (WCA) to seek planning consent for a temporary variation to conditions 5 and 6 to enable operation of the Hollingdean Materials Recovery -Facility (MRF) and Waste Transfer Station (WTS) on Saturday 23rd January and Saturday 30th January 2010. This consent has now been granted.
The request results from the WCAs need to continue to catch up on its refuse and recycling collection arrangements following the recent period of heavy snowfall and we are assured by the WCA that this requirement to work on Saturday is as a last resort and all collection rounds will be carried out during weekdays wherever possible.
We are very conscious of managing the site with a view to limiting odours. However, while you can be assured of our commitment to taking all reasonable measures to try to ensure an odour issue is not created which may cause a disturbance to local residents, the recent adverse weather has resulted in an increase in waste delivered to the facility over a short period of time. This could lead to some increase in odour because Brighton & Hove City Council was unable to collect waste during the period of snowy and icy conditions and therefore waste has had to be left uncollected for significantly longer than usual. We will endeavour to mitigate any such odours and we will, of course, continue to operate the facility in accordance with all planning and licensing requirements.
We thank you for your understanding as we try to assist Brighton & Hove City Council to return to normal services and can assure you that every reasonable effort will be made to minimise any disruption to you.
Yours faithfully
On behalf of
Veolia Environmental Services
Nuisances for residents in Princes Road
Summer 2009 
The Council's sparse resources for enforcement affords little protection to neighbouring residents in relation to noise, odour and fugitive particles 
Note that: Condition 16 was set by Brighton and Hove City when granting planning permission for the WTS & MRF. It is not part of the operating licence for these installations issued and monitored by The Environment Agency. Its observation depends on the resources available to the Council to enforce its planning conditions, of which there are thousands altogether! 
Let-out clauses to allow pollution of surrounding neighbourhoods
However, under condition 3.3 of the Environment Agency's Licence (Number EAWML 100185), Veolia has not breached its permit if appropriate measures have been taken to prevent or where this is not practicable, to minimise, the litter and the mud.
Is it right that the licence from the Environment Agency permitting the Waste Transfer Station at Hollingdean Depot to operate, gives Veolia "let-out clauses" allowing them to pollute local neighbourhoods with noise, odour, litter, mud and particles of dust? 
SUMMARY
What specifically do residents want their local planners and political representatives to address?
1a) Pollution in the form of noise, odour and dust particles, permitted to escape through the frequently opened doors of a Waste Transfer Station, causing nuisance to nearby residents.
1b) The continued absence of adequate landscaping.
1c) The poor construction of the WTS/MRF buildings RE containment of the pollution: the lack of double doors/filtration: "The building was built without an entrance airlock system, so there is no barrier between the waste and the open air when the doors are opened and this allows odour to escape." [The Environment Agency].
1d) Profit / cost minimisation before people's health. Why should the maximum permitted capacity remain at 160,000 tonnes per annum, significantly greater than is needed to service Brighton and Hove residents' domestic waste, while the odour nuisance continues and is also caused by smelly waste being imported fron outside our city? Hasn't the Environment Agency got any lever to stop this?
1e) Operating Licences (licences to pollute) which fail to set precise limits to manage AND PREVENT odour/dust particle/noise pollution. Instead, the Environment Agency's ongoing system of regulation requires local residents to suffer (i) POLLUTION EVENTS and (ii) sufficient anger and stress to telephone whichever of their officers is logging complaints.
The terms of the licence to pollute given by the EA to Veolia (which is not obliged to monitor the effects of its operation) then leave it to the discretion of the EA's officers as to whether (iii) to believe local residents or (iv) require Veolia to take any action.
The protection of public health is the duty of EA. Making the mechanism conditional on complaint neither respects the mental or physical health of the worst affected residents. The EA's mechanism guarantees rather than controls pollution. Failure to intervene means that there is no end to unreasonable industrial noise and odour escapes which have tried the patience of immediate neighbours since 2008. A better funded EA would be much more proactive, carrying out regular scientific checks on odour, noise and escapes of fugitive particles. Instead, this gross nuisance to immediate neighbours continues unchequed, giving little incentive even for more considerate site management.
1f) The polluter's requests for "lenience RE the problem of odour during weekends following Public Holidays" should trigger sanction by the Environment Agency rather than be allowed to try the patience of local residents. 
Waste and Minerals Plan - Inspector's report
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This page was last updated by Ted on 09-May-2023