Waste Local Plan 2003 Public inquiry
See also Life near the Dump to read about the current impact of Hollingdean Depot on nearby residents.
The planning inspector who led the five-month public inquiry (from May to October 2003) advocated a split-site solution between Hollingdean Depot (for the Waste Transfer Station) and Hangleton Bottom (for the Materials Recovery Facility) because he recognised that neither site was individually large enough or environmentally suitable to handle the city's entire waste burden alone.
The inspector's recommendation to retain and safeguard both Hangleton Bottom and the Hollingdean Depot under the joint Waste Local Plan was based on a distinct logic:
1. Spatial Overcrowding and Lack of Landscaping
The inspector anticipated that attempting to co-locate both a Materials Recovery Facility (MRF) and a Waste Transfer Station (WTS) on a single urban plot would cause severe spatial constraints.
- The Split Vision: The inspector intended for the sites to divide the labour—for instance, placing the MRF recycling sorting at Hangleton Bottom and the WTS at Hollingdean.
- The Consequence of Bundling: When the council and Veolia later abandoned the split-site approach to put both facilities into Hollingdean, the depot became so crowded that essential boundary landscaping and visual screening buffers on the southern border had to be entirely omitted to fit the buildings.
2. Proximity to Residential Areas
The inspector was highly sensitive to the fact that Hollingdean Depot sits directly inside a dense urban bowl, immediately adjacent to the Round Hill conservation area and local schools.
- Forcing 100% of the city’s industrial municipal waste operations into Hollingdean was seen as an unfair and unmanageable environmental burden on a single residential community.
- By splitting the facilities, the sheer volume of heavy goods vehicle (HGV) traffic, industrial noise, and potential odours would be halved and distributed more equitably across the city's fringes.
3. Traffic and Strategic Logistics
From a transport and strategic planning perspective, the inspector recognised that the two sites served entirely different logistical strengths:
- Hangleton Bottom was perfect for regional, heavy-vehicle transit due to its immediate access to the A27 bypass.
- Hollingdean Depot was centrally located, making it perfect for smaller, local domestic refuse collection collection routes
- Splitting the infrastructure allowed the city to exploit both urban-core efficiency and bypass-adjacent heavy industrial shipping.
Hangleton Bottom was identified in the Brighton & Hove Local Plan (adopted in July 2005) as a site for a Materials Recovery Facility (MRF) which was never built there.
What Happened Instead?
Despite the inspector’s explicit push for a split layout, commercial and financial preferences ultimately drove the council and Veolia to reject the advice. They consolidated both massive operations into Hollingdean. This maximised commercial efficiency for the operator but triggered the permanent loss of the community green buffers and led to the long-standing odour and noise constraints residents face today.
The Dump The Dump campaign
How the "Dump the Dump" community campaign used the inspector's 2003 report to fight the consolidation
The "Dump the Dump" community campaign—partnered closely with groups like Brighton and Hove Friends of the Earth—weaponised the 2003 planning inspector's report as their core legal and environmental argument to fight the consolidation of waste services at Hollingdean. They built their entire strategy around the inspector's formal findings to demonstrate that the council and Veolia were violating sound planning principles:
1. Opposing the "Single-Site" Over-Intensification
The core of the Dump the Dump campaign meeting arguments relied on a simple point: the inspector had ruled that both sites were legally required to share the burden.
- Campaign leads Gus Garside and Edward Stark used the report to argue that packing all domestic waste sorting, transferring, and recovery into a single residential urban bowl constituted an "over-intensification" of industrial use
- They highlighted the inspector's text to prove that Hollingdean was physically incapable of absorbing both facilities without severely impacting the local population.
2. Highlighting the Loss of Mandated Green Buffers
The inspector's report noted that splitting the sites would leave enough room at Hollingdean for extensive boundary landscaping to shield local houses.
- Dump the Dump used this to expose the compromises made in the consolidated plans.
- They proved that by packing both the Materials Recovery Facility (MRF) and Waste Transfer Station (WTS) into Hollingdean, Veolia completely eradicated the inspector's recommended environmental "screening buffers" on the southern borders just to make the buildings fit.
3. Exposing Democratic and Procedural Disregard
Campaigners used the inspector’s conclusions to wage a public relations and political war against the council.
- They publicly accused council officers of "ignoring the changes recommended by the inspector" in a desperate bid to push through the Veolia contract.
- This became a central weapon in rallying thousands of local objection letters, arguing that the council was acting undemocratically by bypassing its own independent public inquiry findings.
4. Laying the Groundwork for High Court Legal Challenges
By showing that the final Waste Local Plan deviated heavily from the independent inspector's official recommendations, Dump the Dump and Friends of the Earth argued the entire waste plan was legally flawed. They used the inspector's specific concerns over site restrictions to compile evidence for a High Court challenge, attempting to force the council to reopen the public inquiry entirely.
Ultimately, while the council still pushed ahead with the consolidation by treating new applications as separate legal entities to bypass historical objections, Dump the Dump’s use of the report successfully delayed the project for years and permanently exposed the structural limitations of the Hollingdean site.
Notes
Public Inquiry inspector recommends retention of Hangleton Bottom as well as Hollingdean Depot as sites allocated for Waste Management
A five-month Public Inquiry into objections to Brighton and Hove City Council's and East Sussex County Council's Waste Local Plan - First Deposit (November 1 - December 12, 2000), was completed on 24th October 2003. The inspector leading the inquiry recommended that the following sites, allocated for material recovery facilities/waste transfer facilities, should be retained in the Plan:
- Hangleton Bottom, Hove
- Hollingdean Depot / Abattoir, Brighton
- Bellbrook Industrial Estate, Uckfield
- Land at Tutts Barn, Eastbourne
See Appendix 1 point 2 of Agenda item 9 Meeting of Waste Management Contract Joint Committee BHCC/ESCC 1st October 2004, where the above sites are specified for retention and allocation for materials recovery and waste transfer facilities.
A split site solution for Waste Transfer Station and Materials Recovery Facility would have been better
The recommendations of the inspector leading the public inquiry supported a split site solution i.e. the Waste Transfer Station and the Materials Recovery Facility being split between Hollingdean Depot and Hangleton Bottom, but Veolia's commercial preference was to cram both waste facilities onto a single site in close proximity to several residential areas.
The proximity principle in waste management is that waste should generally be disposed of as near to its place of origin as possible. However, it is a perversion of this principle to argue that 300-400 households and three schools should experience the nuisances created by bringing the whole of Brighton and Hove's domestic waste to a single site. A split site solution would have been more tolerable and more democratic.
Arguments used to direct developments to Hollingdean Depot
It was argued during the short-listing process (See BH2006/00900 planning application) that Hangleton Bottom was a less suitable site since it adjoined an area within the Sussex Downs Area of Outstanding Natural Beauty. (Note that this area is now part of the South Downs National Park.)
However, it has become physically isolated from the majority of the AONB to the north due to the development of the adjacent A27 Brighton bypass. Hangleton Bottom is well positioned in respect of access having been located adjacent to the interchange to the A27 and the Hangleton link road.
The presence of a railway line to Newhaven adjoining the Hollingdean site was argued as an advantage, but Veolia had no intention of using the rail link for the transportation of waste.
See Letter to The Argus [April 2005] on how Hollingdean Depot was subsequently homed in on as the sole site i.e. to take both a Materials Recovery Facility and a Waste Transfer Station.
Hangleton Bottom as a potential site for Waste Management
Hangleton Bottom was identified in the Brighton & Hove Local Plan (adopted in July 2005) as a site for a Materials Recovery Facility (MRF) which was never built there.
Hangleton Bottom 2008 [The Argus 4/09/2008]
So Brighton and Hove City Council is considering Hangleton Bottom for a transfer station for business waste (“Nature spot could host waste centre”, The Argus 20/08/2008)? The council has ruled the site out for travellers because the close proximity of a traveller site to a waste station is not good practice. There are two ironies here. Firstly, Hangleton Bottom was ruled out as an appropriate site for domestic waste and the council gave the go-ahead for that in Hollingdean. Secondly, the council positioned the Hollingdean dump next to a school and flats where older and disabled residents live.
Hangleton Bottom is a council owned site allocated in the Local Plan and Waste Local Plan for the provision of waste facilities. The allocation is saved until replaced by relevant policies in the Waste and Minerals Development Framework and the site is highly likely to be retained in the Local Development Framework and the Waste and Minerals Development Framework for this purpose. The site is located south of the bypass and west of Hangleton Link Road and comprises several fields let for grazing and a compound occasionally used for travellers with welfare needs. The site totals 3.3 Ha (8 acres).
Hangleton Bottom 2017 [Brighton and Hove News 20/01/2017]
Hangleton Bottom will be officially listed as a potential “waste management” site despite a last-ditch stand by a local councillor.
Hangleton Bottom 2017 [The Argus 24/01/2017]
"The waste site developers claim you won't be able to see."
Anaerobic Digestion project : It was deemed that Hangleton Bottom did not to have sufficient amount of land for the anaerobic digestion (AD) plant that BHESCo envisioned, as well as being too close to homes on Thornbush Crescent, a residential community, to be a suitable site for this plant.