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Veolia 2006-Environmental Health

Internal consultees index

CONSULTATIONS pages 41 to 47

Check out the Council's justifications for the BH2006/00900

Environmental Health

Planning Policy

Site selection process


Transport Planning and Policy

Impact on Amenity of occupiers of nearby residential properties, schools and businesses

Environmental Health

Environmental Health: Satisfied with the methodology and recommendations in the Environmental Statement and its conclusion - that provided the recommendations and mitigation measures detailed in the ES are addressed, the development will not have a significant adverse impact on local residents with regard to environmental issues.

The ES calculates that noise from the operation of the MRF and WTS will not increase the existing ambient noise level at the nearest noise sensitive receptors. The assessment of fixed plant and machinery demonstrates that noise complaints will be unlikely. The principles and mitigations measures in the ES (chapters 9 & 4) for the sound insulation of the building envelope, operational noise and dust suppression scheme.

A Construction Environmental Management Plan (CEMP) should be secured to satisfactorily mitigate against any potential adverse effects during construction. A


commitment to enter into a Control of Pollution Act 1974 section 61 Agreement addressing noise issues is welcomed. The commitments within the CEMP are important in this regard and the principles of this outlined in the ES are considered sufficient. The applicant's statement on working hours is acceptable. The council is likely to request 8am-6pm Mon-Fri and 8am-1 pm Sat (not Sun or Bank Holiday Mon) for noisy working. The COPA S6I gives the council the opportunity to discuss noisy processes such as piling, and this could include agreeing shorter working hours and/or managing the operation to incorporate breaks in the day. The CEMP should also require a dust control plan to be implemented.

The soil contamination assessment in the ES is robust. The land contains contaminants such as hydrocarbons, lead and copper, and the land remediation measures outlined in the ES can be successfully employed so that the level of risk may be reduced to an acceptable level. Appropriate conditions should be imposed for a remedial scheme to be submitted before development commences.

The Air Quality assessment contained in the ES is satisfactory. Provided the recommendations and mitigation measures detailed in the ES are carried out the development will not have a significant adverse impact on local residents with regard to air quality. The commitment to enter into a lorry routing agreement and dust mitigation measures during construction are welcomed and should be secured through the CEMP. The commitment to contributing financially towards the Air Quality Action Plan is welcomed, and is in accordance with Planning Policy Guidance Note 23.

Appropriate conditions and section 106 obligations are recommended to ensure satisfactory mitigations measures are secured including those relating to: hours of use of the development, soundproofing of building and plant and machinery, noise emission levels at identified receptors, fitting of vehicle silencers, dust and odour suppression, acoustic fencing, burning of materials, outside storage of materials and contaminated land, a financial contribution to the AQMA, a CEMP, and use of low emission vehicles.

Planning Policy

Planning Policy: The application accords with the site allocation for a Materials Recovery facility in the Brighton & Hove Local Plan (adopted in July 2005) with the Structure Plan and the emerging SE Plan. It accords with the identification of the site for waste uses in the Waste Local Plan (adopted on 21 st February 2006).

South East Plan and Structure Plan: Policy W16 of the South East Plan is relevant, which states that waste development Documents should identify sites for waste transfer and bulking facilities. Structure Plan policies W9a), W5, W6, WI3 are relevant. These policies support: recycling facilities, transfer stations and plants for treatment of waste on sites within or next to built up areas, where industrial forms of development would generally be acceptable; proposals that minimise the need for transportation of waste; integrated facilities on single or adjacent sites and proposals that increase the proportion of household waste that is recycled. The proposal meets the criteria of these policies.


Brighton and Hove Local Plan (adopted July 2005): In principle, the site is allocated in policy EM I and under 'indicative uses' a materials recovery facility is identified, as well as general B2 uses including car repairs and starter units. Whilst the list did not include a WTS they were only indicative and not prescriptive and other waste related uses were not excluded.

The site is encircled by Greenways, therefore policy QDI9 applies and the development should ensure it contributes to enhancement of the Greenway network. The site is adjacent to (but does not adjoin) the Roundhill Conservation Area and the impact to its setting must be taken into account in accordance with policy HE6. Policy TRI relating to enhancement of sustainable transport modes and meeting the transport demands of the development must be complied with, as also policies TR7 relating to highway safety, TR8 relating to pedestrians and TR11 relating to safe routes to schools. Also cycle parking should be secured (policy TRI4). Sustainability needs to be addressed in accordance with policies SU2, SU3, SU4, SU5 and SUI3 and the Sustainability team should address this. Pollution and noise/odour issues (policies SU9, 10, II & 12) should be dealt with by Environmental Health. Policies relating to quality of design, landscaping and biodiversity (QDI-4, QD6, QDI5-I8) should also be addressed and deal with by the Conservation and Design team and the Ecologist and Arboriculturalist. Policy QD27 relating to amenity also applies.

Waste Local Plan (adopted February 2006): The site specific policy is WLP8(b) which allocates the site for a materials recovery facility and waste transfer facilities and the application accords with this allocation. The policy makes reference to a number of issues that need to be addressed by the application in the accompanying 'map notes' and these have been addressed in the current application.

All waste developments also need to be considered against the strategic waste policies in chapter 6 of the WLP. WPI requires applications to represent the best practicable environmental option, have regard to the waste hierarchy, the proximity principle and the precautionary principle, reduce landfill and be part of an integrated strategy. The proposal complies with is strategy. The submitted BPEO reports are acceptable. Transport policies WLP2 and WLP4 are relevant and the potential for use of rail should be explored. WLP 11 (reuse of construction waste) and WLP 13 (recycling, transfer and material recovery facilities) are relevant, and a construction and demolition waste plan should be secured and the site complies with WLP 13, being an allocated site for such uses.

All waste development also needs to be considered against the development control policies in chapter 8 of the WLP. Policy WLP35 is relevant regarding general amenity considerations as are policies WLP36 (transport considerations), WLP37 (flood defences and surface run-off) and WL38 (surface and groundwater). Sustainable drainage systems should be explored. WLP39 (design) and WLP40 (environmental improvements and other benefits) are relevant. The development should aim to maximise on site landscaping.


It should be noted that the Waste Local Plan is currently subject to legal challenge with the city and county council's being joint defendants. Advice has been sought from Queens Counsel as to the appropriateness of determining waste planning applications prior to the hearing taking place. The councils have been advised that, despite the challenge, the Waste Local Plan remains adopted and in force and that such applications should proceed to determination.

SPGBHI7- Hollingdean (approved at Environment Committee 29101104): The SPG emphasises that planning considerations set out in section 6 must be taken into account in any planning proposal for the site. The SPG seeks compliance with the council's sustainability strategy and seeks protection of groundwater and inclusion of a sustainable drainage system and a sustainable form of land remediation should be sought. The SPG requires an education facility, accessible to all groups. An environmental statement is required, and a transport assessment to accompany the application. The SPG states access to the site should be via Upper Hollingdean Rd and not Ditchling Road. The SPG seeks to ensure residents do not suffer from noise, odour or dust. The design should be good quality to limit visual intrusion. A design assessment and landscape assessment are required.

Site Selection Process

Site selection process: The waste local plan preparation process identified 3 sites in the city for waste uses (Hollingdean, Hangleton Bottom and Sackville Road coal yard and sidings). As far as Hangleton is concerned, the AONB location, uncertainty over the national park boundary and its smaller size made Hollingdean the preferred site. In addition Hollingdean's history as an abattoir and its co-location with the existing waste depot, together with the fact it more closely met the requirements of Waste Local Plan policy WLP2 - that is lies in close proximity to where waste arises and closer to final destination to the east, thereby reducing mileage sought by the WLP. Further information why rail is rejected should be sought as is one benefit of the Hollingdean site.

Sustainability Team

Sustainability Team: Although the Sustainability Strategy makes no substantial reference to climate change, the applicant has subsequently submitted an Energy Survey which details measures that can be incorporated into the buildings to minimize carbon emissions and energy use. The Survey predicts 50% reduced energy demand and 40% reduced carbon emissions. It is recommended that these measures be implemented and secured by condition.

The following measures are positive: water re-use and consumption reduction; specification of energy efficient appliances; 'intelligent' auto-lighting systems; use of translucent panels permitting natural daylighting; incorporation of photovoltaics/solar and wind turbine power for street and signage illumination and the building design minimize the need for heating and lighting. These should be captured in an overall prediction of energy savings/carbon reduction. Further detail of photovoltaics and micro wind turbines should be supplied.

The BREEAM assessment suggests it will be possible to achieve 'excellent' on all 3 buildings using higher cost measures. The intention is to reach 'very good' on the MRF and WTS as these are not heated and thus do not meet the BREEAM credits


on this aspect to reach 'excellent'. This should be clarified and it is recommended that all buildings reach 'excellent', particularly with regard to energy and water components.

With regard to water the following are positive measures: use of water meters; dual flush toilets and low water usage urinals; push flow taps and showers; 'A' rated dishwashers and washing machines; rain water catchment systems for vehicle washing and irrigation (capacity and siting details required). The use of Sustainable Drainage Systems (SUDs) is limited due to issues regarding contaminated land but should be maximised on appropriate areas of the site - eg car parking area or areas of paving.

With regard to biodiversity the inclusion of a green roof and off site planting are welcome. More habitats could be incorporated. Further justification needs to given as to why green roofs cannot be used on the remainder of the buildings. The commitment to green walls is welcome. The use of low emission vehicles alternative fuels and should be explored and the use of rail. A sustainable material procurement strategy should be submitted to show how the materials rate highly in the BR.E Green Guide to Specification and any steel should be recycled. Potential to train construction students during construction should be pursued.

Note: Some of the matters outlined above will be secured as part of the scheme by condition.

Transport Planning

Transport Planning & Policy: Provided appropriate conditions/section 106 obligations are imposed as recommended, the transport implications of this application are acceptable.

The Transport Assessment (TA) estimates the likely transport impact of the proposal and sets it in the context of the existing traffic in the area. This is done by assuming that total waste tonnage will grow in accordance with the rates which have been accepted by the Council in its role as Waste Collection Authority (WCA) and adopted in the Waste Local Plan. This gives a total of 110,000 tonnes per annum in 2007/08,130,000 tonnes in 2015/16, and 140,000 tonnes in 2027/28. A worst case of 160,000 tonnes per annum, which would be the maximum allowed by the consent sought, is also considered. Dividing these totals by the number of working days per year gives average tonnages per day. These are then divided by the average payloads of the HGVs proposed for use, which vary according to the types of movement and materials involved, to produce daily traffic volumes. The payload figures have been accepted by the Council in its role as WCA and are supported by weighbridge data provided by the applicant.

Tables in the TA show that total HGV movements to and from the site combined would be 226 daily in 2007/08 increasing to 316 daily in the worst case. However it is an important point that most of these movements are already being made or arise from the expected growth in waste tonnage which are expected to occur regardless of the outcome of this application and could be made to and from the existing depot without any further planning application being made. The extra number of HGVs arising from this application is 66 per day, both directions


combined, in the worst case. These extra trips would be by articulated bulkers using Hollingdean Rd. and Lewes Rd. to and from the site.

For information, the Environment Committee agreed in December 2005 to implement the proposed Fiveways traffic management scheme which includes measures to reduce the concerns of local residents to the west of the application site arising from HGV movements associated with the existing Cityclean operation.

The total number of new trips is therefore low (i.e. the 66 bulker movements discussed above and at most 60 staff trips in and out combined per day). These 126 new movements would be 0.76% of the surveyed existing 12 hour two way flow of 16479 vehicles on Upper Hollingdean Rd. It is demonstrated in the TA using standard and acceptable methods that no delays would be expected at the junction of Upper Hollingdean Rd. and the site access. Nevertheless the potential environmental impact of the bulkers must be considered and the applicants propose to address this by:

1. The realignment of Upper Hollingdean Rd. on the approach to the railway bridge which is intended to improve the forward visibility from southbound vehicles and so enable greater driver comprehension and provide an improved passage for large HGVs passing through the bridge, and the provision of additional warning signs and road markings on the approaches to the bridge. It is proposed that the details of these and other highway measures are finalised as part of a condition attached to any consent. These works would have to be co-ordinated with the Fiveways area improvements referred to above. The completion of a Stage 2 safety audit would be required before the works were carried out. The applicants have considered the possibility of introducing one-way working controlled by traffic signals at the bridge but have demonstrated using standard and acceptable methods that this would cause unacceptable delays. Network Rail has expressed concern (in respect of the previous application) about the possibility of vehicles hitting the railway bridge and therefore the provision of Trief kerbs to narrow the carriageway has also been considered. This has however also been rejected because of the delays which would be expected to result, and in the light of the fact that the concern expressed is general and not specific to this site i.e. there are no records of HGVs colliding with this railway bridge.

2. A routing condition similar to those operated elsewhere by the applicant requiring the bulkers to enter and leave the site via Hollingdean Rd, Lewes Rd. and the A27. This would be enforced by route notification and signing and residents would be encouraged to notify suspected breaches of the agreement. Details of this should be resolved as a planning condition and it is suggested that these should include action to be taken to resolve breaches which occur. The routing condition should apply to all vehicles including those for which the desired route would not be the most convenient. The condition should ensure that there is no significant impact i.e. no extra HGV movements generated by the development in the residential area to the west of the site. The possibility of a central island in Upper Hollingdean Rd. positioned so as to require HGVs to take the desired route has been considered but rejected as it would cause delays on Upper Hollingdean Rd.


southbound and would be unnecessary provided an effective routing condition can be agreed.

The applicants are aware of the Council's policies of promotion of sustainable modes of travel but it is accepted that the scope for application of these policies in this case is limited by the nature of refuse collection, the small number of employees (30 approx) and the very early start to their working day. The Local Plan does not include parking standards for this use but the proposed provision of 22 general, 2 disabled and I bus/ coach parking spaces and 15 cycle parking spaces seems reasonable.

The applicants propose to promote the use of sustainable transport as far as possible by:

1. Adoption of a Company Travel Plan. This should be secured by condition and will probably include the provision of public transport timetables, the provision of cycle facilities such as showers and changing facilities, and the promotion of car sharing by staff. For information, Cityclean intend to apply the Travel Plan for Council staff to their relevant existing employees.

2. A contribution to enable the provision of a cycle lane on Upper Hollingdean Rd. northbound in the vicinity of the site or other measures to encourage the use of sustainable modes of transport locally. This should again be secured by a Section 106 agreement. Officers estimate that the provision of the proposed lane would cost approximately £ 10,000.

The TA briefly discusses the issue of construction traffic routing. This is satisfactory and as always the intention would be to limit such traffic to major routes as far as possible. The details of this should again be resolved by condition.

The Public Transport Manager confirms that the applicant has fully considered the rail transportation option in detail, and has satisfactorily demonstrated that it is not practicable. The applicant has made a case that costs of transportation of waste by rail is significantly higher than the costs for road haulage (£16.4 million during the life of the contract). It is also accepted that the accommodation of a rail siding within the site would seriously constrain the operation of the site as currently designed.


Impact on Amenity

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