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Veolia proposal - a rushed public consultation
[3 of 11] Veolia's application (to extend operating hours for their WTS and MRF at Hollingdean Depot to 15 hours per day 363 days per year) drew 103 objections altogether.
Point 5.1 of The Plans List uploaded to The Council's website on Tuesday 30th July, eight days before the meeting on Wednesday 7th August 2013 when Veolia's application was granted, records 18 letters of objection. Note that several objections submitted before the last day of the consultation(Tue 30th July 2013) were not documented in The Plans List
45 further objections were recorded on "the late list". The late deadline for objections closed at 12 noon on Friday 2nd August 2013. Some of the objections included in "the late list" were actually submitted before Tuesday 30th July 2013 (i.e. the end of the formal period of consultation). These should have been recorded on The Plans List to give members of the planning committee more time to absorb them.
A further 40 objections were submitted (within just 5 days) between the publication of "the late list" and the day of the planning committee meeting.
Did the officers consider residents' objections before contributing their comments?
It would appear that The Plans List was completed BEFORE the last day of the formal public consultation
Moreover, The Council's Environmental Health and Sustainable Transport departments could not have added their own comments in the context of our objections.
Since our objections related to HEALTH (reasonable periods of respite from industrial noise) and TRANSPORT (reasonable periods of respite from Heavy Goods Vehicle Movements), could we not have expected the relevant Council Departments to write their paragraphs of support for Veolia's proposed to The Plans List in the context of our objections? Surely, they should be looking at BOTH SIDES - the residents' case as well as Veolia's.
The Environment Agency makes "no comment"
5.2 The Environment Agency has made no comment. Please sign our petition which will later be sent to The Environment Agency. The petition will allow the EA to read our own account of how we are affected by noise nuisance. The Council's Environmental Health Department has made a private arrangement with The Environment Agency, whereby BHCC deals with NOISE and the EA deals with ODOUR.
BHCC's monitoring of complaints about noise
Veolia's application contains the claim that no noise complaints in relation to their Hollingdean Depot WTS and MRF have been recorded by Brighton and Hove City Council since 2010 (see page 2 point 2.1.1 of Noise impact assessment dated 3rd July 2013).
See also Private action to abate a noise nuisance - strategies used to discourage residents' complaints are (a) weighing them down with paperwork e.g. the obligation to keep a 2-week noise diaries, and (b) treating the complaint as "an allegation to be made in a Magistrates Court" while advising residents of the cost of a failed legal action.]
5.3 The Council's own Environmental Health Department writes several paragraphs in support of the proposal. I am not convinced that this was done after reading our objections.
"No change to permitted tonnage" argument
5.18 The Sustainable Transport Department writes:
"The proposals do not involve any change to the permitted tonnage at the facility (BH2011/03179 Condition 1) or the overall number of vehicles. Condition 1 of BH2011/03179 states that that the unit has a capacity of a maximum of 160,000 tonnes per annum. This effectively controls the vehicle numbers allowed per annum and the vehicle numbers associated with the development have already been set. These proposals do not alter this maximum permitted tonnage."
Veolia's Noise impact assessment 2.1.4 acknowledges that not all the vehicles using Hollingdean Depot yard have 'white noise' smart reversing alarms - vehicles from outside of Brighton and Hove and from companies other than Veolia are permitted to use the yard . It should follow from this acknowledgement that extending the operating hours by so much more creates potential for more vehicles from outside our city to use Hollingdean Depot.
The Council's Sustainable Transport Department argues in THE PLANS LIST that the unit (MRF & WTS)'s maximum capacity of 160,00 tonnes per annum effectively controls the vehicle numbers allowed per annum and that Veolia's application does not change the maximum permitted tonnage.
However, Hollingdean Depot has never been operating at its maximum permitted tonnage. Its current level of operation causes an intolerable level of nuisance to residents living nearby. Application BH2013/02219 creates potential for even more nuisance.
NEXT 4 of 11: A poor summary of our objectionsThis page was last updated by Ted on 06-Sep-2020