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Critique of Veolia's Planning Application
BH2006/00900 Former Abattoir and Depot Site Hollingdean Lane
ISSUE 1 The proposed use of Hollingdean Depot is not suitable for the area
Surrounding land use in almost every direction is residential with local schools (e.g. the Downs County Infant School) in close proximity. The intensification of development on this site is already a matter of great concern affecting parents and school children. If it is right to have schools at the hub of several residential areas (St Peters, Hollingdean, Lewes Rd, Round Hill), then it would be inappropriate and irresponsible to have such a big operation dealing with so much of Brighton & Hove’s waste in this area.
Veolia's own description of surrounding land use, in their Supporting Statement for this Application, characterizes the proposal as an unsuitable one, being in the heart of several residential communities:
Supporting Statement – Surrounding Land Use
1.12 Beyond the waste depot and meat market, housing is the dominant surrounding land use. Two Council tower blocks (Dudeney Lodge and
Nettleton Court) lie immediately to the north west. Beyond Upper Hollingdean Road lie extensive residential areas.
1.13 To the south and southeast of the site beyond the railway are more residential areas (including the Roundhill Conservation Area) and the Centenary Industrial Estate. The main railway line which is bounded by banks of vegetation separates and screens these areas from the proposed MRF/WTS site.
Hollingdean Lane is an unadopted road which forms the northern and western boundary of the site. The lane is elevated above the site as it climbs up the
hill. Immediately west of the lane is a Jewish burial ground, a chapel (which is a Grade II listed building), the Downs County Infant School, all of which are elevated a few metres above the site. Ditchling Road and further residential areas lie immediately west of these uses, and forms the southern boundary ofthe Preston Park Conservation Area.
1.15 There are two residential properties at the point where Hollingdean Lane turns south, immediately below the Jewish burial ground.
ISSUES 2 & 3
New Roadways and accesses will not be safe for pedestrians and other road users
There will be an increase in noise and disturbance from the comings and goings of extra traffic
LHS: AT THE BRIDGE - picture accompanying Road Safety Audit (the only view of it in Veolia's application) conceals the approach to the bridge.
RHS: BEFORE THE BRIDGE - Our own picture shows that the straight line of vision would only be available at the last second when danger could be inescapable. Veolia's selective view LHS inadvertently reveals another familiar problem with this bridge - that of the sun shining in drivers' eyes. Perhaps this should be mentioned in the Road Safety Audit rather than the lesser side-issues i.e. problems that can easily be solved!
The ROAD SAFETY AUDIT included in Veolia’s planning application leaves several questions about the safety of the road/railway bridge in Hollingdean Road completely unresolved. No application in this flawed state should be approved, especially as it is simply impossible (owing to lack of physical space) for two footpaths and a roadway under this bridge to be shared safely by pedestrians, cyclists, car drivers and 44-ton lorries.
The DESIGNER’S RESPONSE to the ROAD SAFETY AUDIT confirms that these problems have not been resolved. By their own admission, new roadways and accesses will not be safe for pedestrians and other road users.
It is recommended that a footway be provided along the northern side of the proposed access road.
At the meeting BHCC stated that they would require footways to be provided on both sides of the access road. Due to the proximity of the Downs County Infant School and depending on the level of pedestrian and cycle access currently using Hollingdean Lane to access the bus stops on Ditchling Road and the school, BHCC may require that one of the footways is a footway/cycleway facility approximately 3m in width. It should be noted that there is limited space available to provide both a carriageway and 1 or 2 No. footways and this will need to be discussed further with Onyx and BHCC to identify how to proceed.
A one-sided Road Safety Audit
The drawings accompanying the ROAD SAFETY AUDIT fail to extend to the east side of the bridge. Likewise, Photograph No.2 accompanying the ROAD SAFETY AUDIT fails to reveal the alignment of road traffic as it approaches the east side of the bridge.
Only at the last second (i.e. when vehicles travelling westward reach the bridge), will the proposed realignment of the junction (through onto Upper Hollingdean Road.) on the west side of the bridge contribute to safety. The Road Safety Audit should have focused on traffic pathways on BOTH sides of the bridge. There is no scope for making this less of a blackspot after the application has been approved. In comparison with the clear danger posed by incompatible user-groups competing for insufficient space directly under the bridge itself, most of the problems highlighted by the auditor are cosmetic and these side-issues risk obscuring the main design flaw.
The residents of Hollingdean and many other users of Hollingdean Road are ALREADY troubled by the black-spot at the site of the railway bridge. Members of the Council’s Planning Applications Sub-Committee are requested NOT to license an even greater level of risk.
We would refer you here to The Council's Sustainable Transport Strategy as set out in the Local Transport Plan
1.3 The Sustainable Transport Strategy as set out in the Local Transport Plan aims to:
· Increase awareness of the whole community of the impacts of traffic and travel decisions
· Reduce danger for all road users, particularly by reducing traffic speed
· Improve accessibility for environmentally friendly forms of transport
· Reduce road traffic, pollution and congestion within and around the city
· Promote and improve the economic, environmental and social viability of the city
· Encourage partnership and innovation in promoting and developing choice in the provision of sustainable transport
· Seek compatibility between transport and planning policies and decisions
The Transport Safety Concerns of Hollingdean's parents are shared by Brighton Pavilion's MP David Lepper and by the elected Local Councillors for this area.
FURTHER ARGUMENTS RE: ISSUE 1 covered by The Dump The Dump Campaign and in speeches on Air Quality Management by Councillor Keith Taylor of The Green Party
In the interests of protecting and enhancing the residential area of Hollingdean, we also refer Council Officers and Members of the Planning Applications Sub-Committee to those parts of the Local Plan dealing with AIR QUALITY and a CLEAN ENVIRONMENT.
The myth that there are
"no other sites suitable for waste disposal"
One of the developer's tactics, a stranglehold they are attempting to apply on Local Councillors, Development Control and the public alike, is to encourage us to believe that there is no alternative to a single massive operation focussed on a single site
Veolia constantly state the obvious - that doing nothing is not an option BUT they do not set out to give us any option other than the one which best serves their commercial interests.
Why are we offered an 'ALTERNATIVE' SITE ANALYSIS and not an 'ADDITIONAL' ONE
Is it that Veolia is unwilling to contemplate their operation being split between more than one site, thus minimizing the adverse impact on a single locality?
Veolia's ALTERNATIVE SITE ANALYSIS is rigged to give them the result they want, which comes down to a commercial decision based on profit margins. Their assessment of the short listed sites LOOK AT IT CLOSELY is highly selective in its criteria, crude in its ratings and no basis is given for any of the judgements. The analysis is not up to research design standards. The scheme it is manipulated to support has nothing to do with 'best environmenal option'. It would have appalling consequences for Hollingdean and the surrounding area.
Does Veolia have more sensitivity towards Areas of Outstanding Natural Beauty than the Waste Local Plan Inspector?
Aware that one possible ADDITIONAL site, HANGLETON BOTTOM, was identified by the Waste Local Plan Inspector AS BEING SUITABLE FOR WASTE MANAGEMENT USES Veolia goes to great lengths to rule it out in the a letter accompanying their ALTERNATIVE SITE ANALYSIS.
Apparently, Veolia care much more about HANGELTON BOTTOM’s status as an Area of Outstanding Natural Beauty than the Waste Local Plan Inspector.
This concern for BEAUTY does not extend to residential conurbations i.e. the beauty of the areas where people actually live. They argue in their letter:
It (Hangleton Bottom) is less well located than Hollingdean in proximity principle terms, being peripheral and less central to the conurbation.
Note, however, that while Veolia is telling us publicly that THERE IS NO ALTERNATIVE TO HOLLINGDEAN DEPOT, it is careful in its formal planning application to keep HANGLETON BOTTOM as contingency (i.e. in case, the Hollingdean scheme is voted down) and not to conclude that it could not be part of any waste managment scheme.
For these reasons Hangleton Bottom was excluded at an early stage, leaving the opportunity to reassess its potential should alternative urban area sites not emerge as suitable candidates for assessment.
The major concern for Veolia - the commercial one! - is bulletted some way down in their letter:
A potential developable area of 1ha would not accommodate the development requirements for a MRF, WTS, visitor centre and associated infrastructure.
Veolia's ALTERNATIVE SITE ANALYSIS has been manipulated to give them the result they want
If there is any doubt that Veolia want a massive operation ALL ON ONE SITE, for commercial reasons, reference should then be made to the parts of their application showing how HOLLINGDEAN DEPOT was long-listed, medium-listed, short-listed and then chosen as the SOLE SITE for Waste Management over a large geographical area.
ALTERNATIVE SITES REPORT
Assessment of the long list sites
Assessment of the medium list sites
Assessment of the short listed sites
Location of the short listed sites
Veolia probably hope that few members of the public will have the time to click on the above links, to examine the categories they use in their study and to see the categories they have devised at each stage in the 'manipulation' (hardly a 'study') to get the result they want.
Assessment of the long list sites
Many sites are rightly eliminated from the long list (e.g. Land North West of Stanmer Park Nurseries), and one wonders why they were included in the first place - was it to give the appearance of a comprehensive process?
Assessment of the medium list sites
The medium list repeats the practice of eliminating sites which Veolia deem "too small". Hangleton Bottom is available for a Materials Recovery Facility, but it is too small for both a MRF and the single Waste Transfer Station which Veolia want to manage on a SINGLE site. Hangleton Bottom is also eliminated due to its status as an Area of Outstanding Natural Beauty. Hollingdean may hardly compare, but is it fair to plant an ugly dump of massive scale so near to so many residential communities? 'Small is Beautiful' is a doctrine that considers people and asks commerce to do the same. Veolia's letter detailing its reasons for disagreeing with the Waste Local Plan Inspector on the suitability of Hangleton Bottom for Waste Management follows its own commercial interests. It is significant that even Veolia does not rule out Hangleton Bottom for all contingencies.
Assessment of the short listed sites
Veolia’s assessment of the short listed sites is selective in its criteria, crude in its ratings (1. 'meets criterion' 2. 'partially meets criterion' or 3. 'does not meet criterion') and arbitrary in its judgements.
Figure 2.4 is far from being a respectable analysis.
The Planning Policy criterion used limits itself to the Indicative uses of the four shortlisted sites, ignoring the whole sweep of planning policy in Brighton and Hove City Council’s Local Plan, especially the policies addressing the main concerns of people such as Transport Safety and Environmental Health.
According to Planning Policy, Hollingbury Industrial Estate’s indicative uses are General business uses, including industrial starter units. while those given for Hollingdean Depot/Abattoir are MRF allocation, general B2 uses, small repair workshops and managed starter units.
Veolia judges that while Hollingbury Industrial Estate only “partially meets” this policy criterion Hollingdean Depot/Abattoir “fully meets” it. The difference is exaggerated by a system of graphics that makes it appear as if Hollingdean Depot/Abattoir is twice as suitable. However, the description for both sites specifies light industry and certainly not the scale of development involved in Veolia’s proposals.
A further criterion used to compare the two sites is LANDSCAPE SENSITIVITY. Veolia judges that Hollingbury Industrial Estate does not meet the criterion at all (could they be arguing the proximity to the Downs?) while Hollingdean Depot/Abattoir is “totally suitable”.
Veolia shows complete disregard in this analysis to urban landscape in residential areas, though in other parts of their application the developer agrees to install bird-boxes and to take measures to disguise the ugliness of their proposed buildings. It’s harder however to landscape a 44-ton lorry.
But to what degree will these lorries further ruin the Downs, given the compromise that has already been made in building the A27 by-pass, a road more suitable for 44-ton lorries. Mr Collis’s fuel-efficient, environmentally-friendly lorries would surely be happier on a straight bit of road, if we have to have them at all.
Veolia’s own map Location of the short listed sites shows that the Hollingbury Industrial Estate lies on the south side of the A27 bypass. This itself was a controversial development, built to free northern city suburbs and streets like Hollingdean Road from intolerable levels of east-west traffic. Why this reluctance to use this big road for 44-ton lorries? That was what the compromise was for. Why send them instead through a Victorian railway bridge, round the Lewes Rd Gyratory and through the very residential streets which the A27 was built to alleviate?
In this context, Veolia’s judgements in applying a third criterion – ROAD ACCESS AND TRANSPORT – are all the more puzzling. The A27 gives them faster and safer access to a longer slice of Brighton and Hove, yet they judge that Hollingbury Industrial Estate only “partially meets the criterion” while Hollingdean Depot/Abattoir with its terrible traffic problems is “totally suitable”. Are they living on the same planet as local residents?
A fourth criterion – POTENTIAL FOR RAIL LINKS – is included to further justify the preference for Hollingdean Depot/Abattoir over all other sites. It would be relevant if the developer had any intention of realising the potential.
A fifth criterion, used to make a surprising comparison, is SENSITIVITY OF NEIGHBOURING USES
Veolia sees this criterion as only being “Partially Met” by all four short-listed sites.
However, the developer does not care to quantify SENSITIVITY OF NEIGHBOURING USES e.g. in relation to Hollingbury Industrial Estate and Hollingdean Depot/Abattoir. Does Veolia really believe the criterion to be the same in each case?
A more neutral observer might judge that Hollingbury Industrial Estate could qualify as an ADDITIONAL SITE to alleviate the pressure in Hollingdean on one of the most sensitive neighbouring uses i.e. people’s homes.
There are homes in Hollingbury too, though an ‘edge-of-city’ site in the predominantly industrial zone adjoining the A27, though unpopular with some industrial interests, could at least distribute the impact on residents.
Veolia’s process for choosing between its shortlisted sites is WHOLLY UNCONVINCING.
Ref Planning Application BH2006/00900
Hollingdean Waste Transfer and Materials Recovery Facility – Veolia, Hollingdean Lane (former abattoir).
I would like to register my strong objection to the above application for the following reasons:
· The Hollingdean site is uniquely unsuitable to locate a major waste management development, serving the whole of Brighton & Hove. (160,000 tonnes of household waste). The proposed site was originally designated for industrial use when it was on the outskirts of the city- then the abattoir was closed down on health grounds.
· Large HGV traffic increase in the area: Cityclean’s increase to their HGV fleet has a disastrous effect on our neighbourhood already, and is simply unbearable for residents and the local schools. The main HGV routes to the proposed site cross the paths of local children walking to and from eight schools, with the proposed building being 10-20m from the Downs Infants School playground. An estimated 400 movements of HGV’s carrying the black bag and recycling waste from every address in Brighton, Hove and surrounding areas is planned to this single inner-city location. In addition, there would be an expected 66 movements of 44 tonne lorries (the largest allowed on any road) each day. This will cause extra congestion, and result in even more pollution.
· Air quality contaminants associated with the increase of traffic will cause respiratory illnesses.
· The operational times of 7 days a week is unreasonable.
· The Hollingdean Road Railway bridge is less than satisfactory for the proposed traffic, as this is a major walkway to school.
I am not against the expansion of recycling, but I am opposed against the scale of this development.
Further, these plans would have a permanent, detrimental impact on the local community. In particular, given that the pollution levels in the area have already been noted by the council as excessive, the effect on the health of local children would be completely unacceptable and the increased danger, completely avoidable. I can only assume that the criteria used for selecting this site did not take into account the health and safety of children.