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Impact on the amenity index
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Impact on the amenity of occupiers of nearby residential properties, schools and businesses
The Hollingdean Depot/Abattoir site is an urban site with a long established industrial character and a long history of waste management dating back as far as the early nineteenth century. Objectors state, however, that the site used to be on the outskirts but that times have changed and that a waste facility is not suitable in a residential area, and should be located on a site on the city's periphery.
The substantial concerns of local residents regarding the potential impact to health and amenity are acknowledged and understood. It is agreed that a waste facility has, in principle, the potential to cause harm to amenity through noise, odour, dust and pollution, particularly in a residential area. However, notwithstanding the fact that the application confirms that there are currently no available alternative sites within the city, it should be noted that MRFs and WTSs are operating successfully in urban residential areas, eg Lough Road in Islington, where existing properties are located approx. 100 metres from the facility and new properties are planned almost directly next to the WTS. It should also be noted that the temporary MRF in Leighton Road, Hove operates successfully and is located approximately 10 metres away from residential properties. The WTS/MRF/civic amenity site in Islington was visited by the council's Environmental Health team and they confirm that there is no reason why a MRF or WTS designed to modern standards with appropriate noise/dust/odour controls cannot be located in a residential area.
The potential environmental impact of the development proposed in Hollingdean, in terms of noise, odour, dust and air quality has been considered in detail in the Environmental Statement.
The council's Environmental Health Team are generally satisfied with the methodology in the ES and its conclusions that, provided the recommendations and mitigation measures as detailed in the ES are addressed, the development will not have a significant adverse impact on local residents with regard to environmental issues.
SPGBHI7 requires a high standard of design and operational management to overcome or reduce to an acceptable level potentially harmful amenity impacts. The application proposes this, and where mitigations measures are required against potential harmful effects, they will be secured by appropriate conditions and section 106 obligations agreed with the council's Environmental Health team. They include the following: restriction of hours of operation, with more restrictive hours on a Saturday and only when a Saturday follows a Bank Holiday and at no time on Sundays or Bank Holidays; restriction on temporary waste storage; restrictions to ensure all loading and unloading and sorting/bulking activities to be inside building and not outside; routing of HGVs to the Vogue Gyratory and not Ditchling Road; requirement for dust and odour suppression measures; requirement for soundproofing and low noise levels to be adhered to; closure of use of low noise reversing bleepers; use of low emission vehicles; provision of acoustic fencing.
It should be noted that in addition to the conditions recommended by the Local Planning Authority, the Environment Agency as part of the Waste Management Licence, impose criteria of their own. These criteria include tonnage of waste handled, type of waste handled, record-keeping, maintenance, drainage considerations, control of mud and debris, control of odour emissions, control of noise, dust, litter and pest infestations.
It is noted that one of the major concerns of residents is the impact of the development to air quality in the area. An Air Quality Assessment was included as part of the environmental statement and this assesses the impact during construction and operationally, and concludes that the air quality impact will be minimal. The ES assessed the impact of the pollutants most closely associated with vehicle traffic, nitrogen oxide (NO2) and particulate matter of less than 10 (PM10). The Air Quality Assessment takes into account medium and high sensitive receptors, the latter including residential properties and Downs Infant School. The Assessment concludes that the proposed traffic movements (66 HGV movements and approx 60 staff movements) would not result in a significant deterioration of air quality. The differences would be significantly less than 10% of the existing baseline air quality in the area, being approximately I -1.4%. The ES concludes that the dust and odour suppression measures will render any dust/odour effects insignificant. These measures include: use of bio-aerosols; wheel washing; dampening down of surfaces; enclosure of containers; activities restricted within buildings; use of pressurised water mist fans which include deodorant; use of low emission vehicles. The Environmental Health team have thoroughly considered the ES and consider its methodology and conclusions to be satisfactory. The mitigation measures will be secured by condition and section 106 agreement.
It is acknowledged that the school playground at Downs Infant School is in close proximity to the western boundary of the site and the MRF, although the land rises.
steeply and the school stands some 12 meters above the site. The proximity of the school has lead to understandable concerns being expressed, however, the council's Environmental Health Team consider that mitigation measures discussed in this section can ensure no detriment is caused to the users of the school and playground. The covered extension to the MRF where it is closest to the playground will help reduce the impact of traffic movements in that corner to an extent. A fence is also to be secured along the school playground boundary to help screen the facility. It should be recognised that until very recently several industrial units occupied the site and a lorry park and that the site has a long established industrial use and allocation in the Local Plan and its predecessor documents.
An independent assessment carried out by the Health Protection Agency (HPA) confirms that the development does not suggest any serious health risks, including to school children. They confirm that the applicant's methodology and figures have been robustly assessed to reach this conclusion. On the basis of the HPA report, the Primary Health Care Trust consider the development acceptable, as does the council's Children and Young People's Trust.
The proposal would result in routing HGVs away from the majority of residential properties and schools in the area, along Hollingdean Road. This road and the Vogue Gyratory do, however, form part of an existing Air Quality Management Area (AQMA) where air quality is not achieving desirable levels and exceeds the (NO2) objective limit. This is regrettable, however, PPS23 is clear in its guidance that the existence of a nearby AQMA does not in its own right mean that no development can take place if it causes a deterioration of local air quality. The degree of significance of impact needs to be taken into account, together with appropriate mitigation measures. In accordance with PPS23, financial contributions towards Air Quality Action Plans may be sought to off set the impact of a particular proposal. Whilst the impact of the proposal would not be significant, it will nevertheless have an impact, and it is considered that a financial contribution of £30,000 should be secured. This could go towards monitoring equipment or employment of a consultant to carry out monitoring, which would help provide a strategy for seeking improvements to the AQMA. The council's Environmental Health team confirm that emissions relating to lower traffic speeds and in particular standing traffic and congestion are of more concern than overall traffic volume and ways of reducing congestions will be pursued.
No.s I and 2 Hollingdean Lane are in very close proximity to the facility, however, it must be recognised that they an unusual case being located in the middle of an existing industrial/waste facility. Given their proximity, however, restrictive conditions are recommended to ensure the building is adequately soundproofed with dust and odour control measures, and hours of operation are restricted to ensure that the occupiers do not experience undue activity. Specialist acoustic fencing is also sought on the boundary of the site closest to these properties.
Impact during construction
The proposed building period is stated as approximately I year in the ES. The applicants have committed to submitting a Construction Environmental
Management Plan (CEMP) before commencement of development that will be secured through the Section 106 process and this is considered to satisfactorily mitigate against any potential adverse effects to the locality during construction. The Environmental Health team consider that the impact of the construction phase will be reduced by imposition of a CEMP and they will advise upon its precise content. The CEMP will cover measures such as hours of operation - the council is likely to request 8am-6pm Mon-Fri and 8am-1 pm Sat (not Sun or Bank Holiday Mon) for noisy working; vehicle routing; details of equipment; method of construction; a dust control plan; drainage and run-off management. The applicant's commitment to apply for a Control of Pollution Act 1974 Section 61 (COPA S6I) agreement as part of the CEMP to address noise issues is welcomed and will be secured. 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.
For the reasons outlined above, therefore, it is considered that the proposal would not adversely affect living conditions of nearby residential/commercial/educational properties, in accordance with national and local planning policy (QD27).
Design and appearance of the buildings and their impact on the immediate and wider townscape, including impact on conservation areas and listed buildings in the vicinity, and impact on distant views
National policy and Local Plan Policy (QDI) require all new buildings to demonstrate a high standard of design and to make a positive contribution to the visual quality of the environment. The supporting text of policy QDI welcomes a modern approach and the use of contemporary and sustainable materials. Local Plan policy also expects new development to respond positively to the character of its locality and sets out key principles that should be addressed to achieve appropriate forms of development (Policy QD2) and states that proposals should have due regard to their impact on views of strategic importance (policy QD4). The council has a statutory duty when considering development proposals to have special regard to the desirability of preserving the setting of listed buildings and of preserving or enhancing the character or appearance of conservation areas. PPG 15 advises that the latter also relates to development on a site outside a conservation area but that would affect its setting or views into or out of the area. These considerations are reinforced through policies HE3 and HE6 of the Local Plan.
The ES contains a landscape and visual analysis and the application is accompanied by illustrative material in the form of plans and elevations, long cross-sections, photomontages and a fly-through computer model. A Design Statement and Landscape Plan have also been submitted. As part of the ES, views of the site and the proposal were assessed from local, intermediate and distant viewpoints. The ES demonstrates that the extent of visibility ranges from less than I km to the west and approximately 4.5 km to the east.
With regard to impact on distant views, the proposal is considered to have limited impact. The ES demonstrates that the site is difficult to identify from the AONB in the east (eg from near the racecourse) and Falmer Hill. It is not considered that the
scheme would compromise the essential rural character or setting of the Sussex downs AONB (policy NC8). The Countryside Agency, whose role is to conserve and enhance the countryside and ensure the quality of the countryside is better for everyone's enjoyment, does not consider that the scheme would have a fundamental effect on the intrinsic character of the Area of Outstanding Natural Beauty (or National Park).
The ES states that in local views from the north and Davey Drive in particular, the proposal would have a substantial visual impact. Local views from the west would change very little due to tree screening. The visual impact from local views from the east will be moderate to substantial and the impact from the southeast would be limited due to partial screening by trees adjacent to the Roundhill Conservation Area and Centenary Industrial Estate. The council's Design and Conservation Manager confirms that the proposal would not compromise the setting of the nearby Roundhill Conservation Area and listed Jewish Chapel and burial ground given the degree of vertical separation, as the site is set down substantially lower than these and is partly screened by trees. Generally, the roof of the MRF would be below the ground level of land to the west, and from immediate viewpoints of the Preston Park Conservation Area to the west the proposal would have minimal impact. The views into the site from Roundhill are primarily from backs of properties and the street scene is not affected. From Mayo Road and the eastern end of Princes Road the WTS building will be seen but in the context of the metal roofs of the Centurion Industrial Estate in the foreground. The Conservation Advisory Group raised no comments with regard to the proposal.
One of the key aims of SPHBHI7 is to secure 'well designed modern waste management facilities' and 'substantial environmental improvements'. It is considered that the proposal delivers this. Is acknowledged that the proposal involves large buildings on a relatively open site, however, on balance, the council's Design and Conservation Manager considers that the proposal would have an acceptable impact on the character and appearance of the area. This is on the basis that there is sufficient on and off site landscaping and added visual interest on the prominent load-out bays. The buildings are the minimum height required for such facilities and it should be recognised that the Local Plan allocations and the SPG identify the site for such facilities in principle. The proposed design is modern, with curved roofs, and is considered to be of sufficient quality and is a very specific response to the site constraints and makes effective use of the site. The Design Statement submitted has provided a sound rationale for the development approach taken. The buildings were designed as 3 separate buildings, rather than one large building, to reduce the mass and bulk, and curved corners and transparent strip panels are used for this effect also. In accordance with SPGBHI7, the development makes effective use of the difference in levels in the site, which helps limit the impact of the buildings. The buildings step down in height with the site. In terms of materials, the building would be metal clad, which are considered to have neutral affect in this semi-industrial setting. It will be important to ensure the materials have a non-shiny finish to ensure their neutral impact, and the precise materials will be agreed by condition. Details of boundary treatment will be agreed by condition, and it is considered that 2.4 metre high security fencing and close boarded acoustic
fencing would not be inappropriate in principle in this industrial location.
The Architects Panel's comments with regard to the green roof appearing 'awkward' in relation to the curved roofs of the main buildings and request for more green roofs is noted. It is agreed that this relationship is not ideal and from a sustainable point of view additional green roofs would be welcomed. The green roof does, however, provide a visual and functional ecological link to the wooded bank adjacent to it and is in the corner of the site and thus has limited visual impact in the context of the whole scheme. The council's Design and Conservation Manager considers that, from a visual amenity point of view, there would be little to be gained from green roofs over all the buildings, and greater visual benefit would be gained through the incorporation of green walls on the dominant loading bays to tie this element into the main development and to provide visual interest. On this basis, therefore, it was considered that a refusal of planning permission could not be justified.
The SPG states that ideally the flint wall should be repaired and extended as part of any new development and this does form part of the proposal, which is considered a substantial benefit. The off-site tree planting along Upper Hollingdean Road and adjacent to Davey Drive, where the proposal will have most visual impact, is welcomed and considered necessary to help 'soften' the appearance of the site, as well as to enhance biodiversity. The lack of opportunity for planting along Hollingdean Lane is regrettable, however, it is appreciated that the existing width of the road and site area limits this and the provision of new planting along the new access road into the site is welcomed. In order to provide visual interest to the prominent load-out bays on the WTS and MRF as requested by the council's Conservation and Design Manager, green walls and artistic walls of recycled materials are to be secured by conditions. The former will also enhance the biodiversity of the site, and the latter will also partly address the demand for public art (Local Plan Policy QD6) and help develop a desirable sense of place and be educational. A financial contribution of £ 10,000 towards a series of workshops with school children or piece of public art is also recommended to meet the demand created by the development.
In accordance with Local Plan objectives which seek developments to be inclusive, the scheme incorporates measures to ensure it is accessible. The council's Access Officer originally raised some concern regarding the internal layout of the visitor/office building, and amended plans have been submitted to satisfactorily address this. The building would contain a lift and would be fully accessible to staff and members of the visiting public. Two disabled car parking spaces have been included within the parking area which is welcomed in accordance with local plan policy. Incorporation of the disabled spaces consequently reduces the total number of spaces from 24 to 23, and this is considered acceptable.
Central Government guidance and Local Plan Policy (SU2) encourage developments to be sustainable, and sustainability underpins the planning process (PPSI).
62This page was last updated by Ted on 06-Jan-2019