Life near the Dump
1. Hollingdean Depot - where to complain?
3. Where Veolia is to be encouraged
4. Action taken so far by The Environment Agency
5. The WTS has no entrance airlock system
6. The Visual Impact on the conservation area
7. Breaches of the Environment Agency's operating licence
8. Tipping while the doors are open
10. Noise impact Assessment not robust
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.
Follow-up of 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.
Food waste and the law
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.
However, now, following The Environment Act of 2021, all Councils are compelled by law to have introduced separate food waste collections by 2026. Brighton and Hove City Council plans to introduce such collections in 2025, though residents are already asking where the food waste will go directly after it has been collected. They hope it will not be to a building unfit for storing odorous waste near to residential homes and gardens.
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 hopefully 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 £94 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 responded to residents reporting odour nuisance from The Waste Transfer Station during the period August 2013 to August 2014 through a written letter.
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."
The design of the building is the other primary contributing factor. Most odour complaints arise when the doors to the WTS are opened, particularly in the morning. 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. Veolia have also identified that odour has been escaping through the vents designed to let air into the building.
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.
The findings of The Environment Agency undermine the promise made at the meeting on 23rd June 2005 at the Downs Infants School to allow experts representing Onyx (now Veolia) to speak about the anticipated impacts of their scheme for a Waste Transfer Station and Materials Recovery Facility at Hollingdean Depot Brighton. Referring to the proposed Waste Transfer Station, Roger Barrowcliffe from ERM assured us that
A complete written transcript of this meeting is posted at https://roundhill.org.uk/main?sec=planning&p=Veolia_2005-06-23_Public_Meeting.
We were not given a state-of-the-art facility. The Brighton Society aptly described Veolia’s installations as “basic metal sheds, the cheapest form of building”. The Waste Transfer Station has never been fit for the purpose of storing odorous waste.
The WTS has no entrance airlock system
Veolia also acknowledges that as well as odour escaping through the doors, odour escapes through the vents designed to let air into the building.
The odour nuisance to residents in Princes Road has remained, yet active carbon filtration for the Waste Transfer Station was abandoned as unlikely to be effective (building too porous) and too big. Veolia then looked into a UV lamp/ozone system for breaking down odour molecules, but this too was abandoned.
- New technology to eliminate waste stations' stink -The Argus, Thursday January 3, 2013 - Veolia trailed the new technology in the local paper as a great solution. Subsequently, I learnt on the phone from Bunmi Aboaba of the Environment Agency that the UV lamp/ozone system for breaking down odour molecules was never installed in The Waste Transfer Station since the Environment Agency considered the system unsafe in a place where there are people around. The problem remains a building unfit for the purpose of containing the odour from rotting food waste.
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.
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.
Breach of planning condition 16
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
Tipping while doors are open
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.
The Council's sparse resources for enforcement affords little protection to neighbouring residents in relation to noise, odour and fugitive particles 
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 noise diary was written in 2009, though since 2010 odour has been 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.
Noise impact assessment not robust
The Noise impact assessment prepared by Clarke Saunders Associates when Veolia's operating hours were extended (see BH2013/02219) was described by The Council's Environmental Health Officer as "robust" without any of the critical appraisal offered by Councillors Hamilton, Wells and Hyde at The Planning Committee Meeting. At least three of the elected Councillors drew attention to the distance of the monitoring positions selected by the acoustic monitoring company from the Hollingdean Depot site.
No microphones were located within the homes and gardens of the residents' affected by industrial noise (i.e. behind the line of houses on the north side of Princes Road, in Mayo Road or Crescent Road). Monitoring positions from within Round Hill were from Richmond Road/D'Aubigny Rd near to the Centenary Industrial Estate, and from Wakefied Road/Richmond Road/Princes Crescent. On the Hollingdean side of The Waste Transfer Station, no microphones were located in Upper Hollingdean Road or Davey Drive or in the Downs Infant School playground. The monitoring positions were in Horton Road and Rugby Road significantly more distant from the residential properties which experience the most noise. See page 11 point 5.3.1 of Noise impact assessment.
Update 2024 Although one gets used to noise, the reality is that being in the garden can be like being on a noisy industrial estate. The problem of odour is harder to get used to. It occurs during hot sunny weather, the very time when one wants to be in the garden and not inside one's home with doors and windows shut.
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.
Other campaigns involving Waste Transfer Stations
