I have submitted the following response re the Brookfield Waste Plant further information to Corby Borough Councils Planning Department: Re: 13/00027/OUT - Comment on Applicant’s Further Submission I write in my capacity as ward councillor for the Weldon & Gretton Ward in response to the further submission dated 6th December 2013 by GP Planning Limited in respect of the outline planning applica...tion hereinabove specified. My response will address each of the following matters seriatim: 1. Absence of the “AMEC Letter” from the online planning system 2. Development Description 3. Landscape and Visual Effects 4. Traffic and Transportation 5. Air Quality 6. Noise and Vibration 7. Ecology Absence of the “AMEC Letter” from the online planning system The letter from GP Planning Ltd dated 6th December 2013 makes extensive reference to an “AMEC Letter”. The said GP Planning letter, which provides the core narrative of the applicant’s further submission, is framed as a response to the said “AMEC Letter”. The “AMEC Letter” is not however available on Corby Borough Council’s online planning system. The absence of the “AMEC Letter” diminishes the clarity of the context of the said GP Planning Letter and renders it difficult for members of the public to provide fully informed responses to the public consultation. The “AMEC Letter” ought to have been published on the online planning system on 13th January 2014 at the same time as the applicant’s further submissions and the appendices thereto. On 18th January 2014 I wrote to Planning Services requesting for the “AMEC Letter” to be made available however to date this request has not been complied with. I accordingly ask for the document to be published on the online planning system as a matter of urgency and for the consultation period to be extended to take account of the three week delay in providing the document. Development Description Notwithstanding the earlier contentions by the applicant that the planning application hereinabove specified does not relate to a waste processing facility, in its letter of 6th December 2013, the applicant’s agent quotes from the “AMEC Letter” which defines the proposed usage of the site as being for waste recycling and energy generation. In its further submission the applicant makes no attempt to rebut the “AMEC Letter” description of the development, which appears to have been drawn directly from the planning application. In the “Development Description” section of its further submission the applicant requests that paragraph 6.1.4 is withdrawn from the planning application. The said paragraph refers to the inclusion of a biomass-powered energy-generation facility. The removal of this statement from the planning application would not however necessarily preclude the erection of a biomass facility on the site, it merely removes it as a specific example from the planning application. Accordingly, to ensure that no biomass facility can be erected on the Brookfield site I propose that in the undesirable event of the planning application being approved, the planning consent should contain the following condition: “No biomass-powered energy-generation facility nor any other fuel-burning facility shall be erected on the site at any time. It shall be immaterial as to whether the burning of fuel is the primary or subordinate function of a facility.” Landscape and Visual Effects Following the same format as the Public Rights of Way Report submitted by the applicant I respond thereto as follows: SECTION A – GRETTON BROOK ROAD / CORBY TUNNEL The applicant seeks to avoid addressing the visual impact from Gretton Brook Road and the Corby Tunnel by stating, “The majority of this section of the public footpath is located outside of the planning application boundary”. This does not however assist the applicant in rebutting the objections to the planning application on the grounds of visual impact. The visual impact of the proposed development would affect individuals using the public rights of way both inside and outside of the planning application boundary. The absence of any information on the mitigation of the visual impact from outside of the planning application boundary should be construed therefore as a failure by the applicant to adequately rebut the concerns of objectors regarding the visual impact from Gretton Brook Road and the Corby Tunnel. In its further submission the applicant attempts to use measures to screen the visibility of Corby Power Station to divert attention from the visual impact of the public highway works which will significantly damage the view across the whole of this section of the public right of way. SECTION B – BROOKFIELD PLANTATION WEST The applicant’s references to segments of this section of the public right of way being outside of the planning application boundary is responded to by repeating the arguments apropos the same in Section A above. The applicant indicates that the construction works will be staggered across the construction period. This construction period is indicated in the original planning application to be a ten year period. Accordingly the applicant appears to concede Brookfield Plantation West will be subjected to unwanted views of the construction works over the entirety of the full ten year period. This is self-evidently a severe visual impact. Furthermore, even after the ten year construction period elapses, users of the public right of way will continue to be subjected to views of the industrial units which the applicant proposes to erect. SECTION C – BROOKFIELD PLANTATION CENTRE The applicant’s references to the character and nature of the highway that it proposes to impose upon the centre of the Brookfield Plantation are immaterial to the concerns of objectors regarding the highway works. The applicant is proposing to replace woodland alongside the grass rides with a tarmacked highway and a roundabout. If approved, the applicant’s proposals will give rise to a fundamental transformation of the centre of the Brookfield Plantation from a pleasant and attractive woodland setting, with views of trees, grassland and numerous wildlife habitats, to an urban setting dominated by a large road and roundabout. The applicant simply cannot mitigate the damage it is proposing to inflict upon the centre of the Brookfield Plantation as the very crux of its proposal is the absolute destruction of the rural setting enjoyed by users of the grass rides. The planning application must be rejected on the grounds, among a multitude of other grounds, that it will entirely change the character of the centre of the Brookfield Plantation. SECTION D – BROOKFIELD PLANTATION EAST In this section of its letter the applicant’s agent concedes that the proposed development will be visible from the Brookfield Plantation East. It again avers that the construction works will be staggered over the construction period and accordingly the arguments set out in Section B above in this regard are repeated. SECTION E – BROOKFIELD PLANTATION / CORBY ROAD The “Community Woodland” being proposed by the applicant is insufficient mitigation for the damage that the applicant is proposing to inflict upon views across the entirety of the Brookfield Plantation. The applicant is proposing to destroy circa 43 hectares of existing woodland and replace it with circa 6 hectares of “community woodland”. This is not a mitigation of the damage, but a reduction in the woodland area of circa 37 hectares. MITIGATION Whilst the applicant’s further submission unsuccessfully seeks to address objectors’ concerns regarding the visual impact from the public rights of way, the applicant has omitted to address the damage that it is proposing to inflict upon views from the neighbouring land at Keepers Lodge Farm, the Middle Aged Settlers site and the Dunlop Travellers site. The applicant also fails to address its proposed damage to views from high ground in Gretton and at Rockingham Castle and Kirby Hall. Traffic and Transportation This section of the applicant’s further submission notes the finding in the “AMEC Letter” that the traffic flow increase on Gretton Brook Road north of the site will be 145%, and not the 59% stated in the planning application. It also notes that the increase on Gretton Brook Road south of the site will be 110% as opposed to the 53% stated in the planning application. The applicant seeks to address this by arguing that the additional traffic flow will be mitigated by improvements to Gretton Brook Road, however it does not suggest any further improvements to those stated in the planning application, which evidently bases its mitigation proposals upon the 59% and 53% figures as opposed to the 145% and 110% figures. Accordingly it can be inferred that the proposals submitted by the applicant to mitigate the increased traffic flow are insufficient to address the concerns of objectors regarding the traffic and transportation impact. Air Quality In its Air Quality Assessment the applicant has indicated the area that is likely to be impacted by emissions from its proposed development by demarking a 750 metre radius from the centre of the proposed site. The applicant’s diagram shows Keepers Lodge Farm, the Middle Aged Settlers’ site and the Dunlop Travellers site all as being outside of the 750 metre radius. The applicant’s methodology is however fundamentally flawed as emissions will not be generated only from the centre of the proposed site but from the entirety of the site. Therefore the radius should be drawn from the boundaries of the site as opposed to from the centre of it. The applicant indicates that there is a likely negative impact from emissions within 200 metres of the source of those emissions. Keepers Lodge Farm, the Middle Aged Settlers site and the Dunlop Travellers site are all within 100 metres of the outer boundaries of the proposed development site and are therefore all likely to be impacted upon by emissions from the site. Furthermore the applicant fails to take account of the impact that the emissions will have upon the users of the community woodland and the users of the public rights of way. The emissions zones for traffic sourced emissions are drawn by the applicant from the centre of the road, however the source of these emissions will be the traffic on the road and accordingly the edge of the road should be treated as the source and not the centre. The applicant concedes that HGV traffic will be increased in close proximity to Lodge Park Technology College and Beanfield Primary School. The applicant does however aver that there will be no HGV access from the area of Gretton Brook Road between Gretton and Priors Hall Park. It can be inferred therefore that the applicant will not make any improvements to this area of road. As it is not uncommon for HGV traffic to mistakenly use non-HGV routes in and around Gretton, the lack of any mitigation in this area of the road means that people living in Gretton will face further difficulties with HGV traffic using unsuitable roads both in and leading to the village. Noise and Vibration The additional proposed planning conditions in this section of the applicant’s further submission only address the management of noise once the development commences. It does not provide any detail as to the likely levels of noise and / or noise impact and therefore does not provide any effective means for the public or the Development Control Committee to reach an informed decision as to the validity of objectors’ concerns regarding noise. Furthermore, the applicant does not provide any evidence that the said additional conditions can be practicably adhered to. Accordingly a Noise Assessment remains necessary and should be carried out and provided to the public for consultation. Ecology Much of the ecology assessment is detrimental to the merits of the planning application and requires little further discussion in this response. For completeness however it is appropriate to re-state that the ecology assessment highlights the presence of eleven European Union Protected Species and eighteen National Protected Species. Among the protected species are Great Crested Newts which should be afforded the utmost protection. Conclusion For the reasons set out above it remains my position as Ward Councillor that the planning application should be rejected. I also request that the “AMEC Letter” is made available on Corby Borough Council’s online planning system and that a noise assessment is carried out and released for public consultation.
Posted on: Sun, 02 Feb 2014 16:17:52 +0000