AMPNEY CRUCIS PARISH COUNCIL
27th July 2005
Mr P Bungard
Chief Executive
Gloucestershire County Council
Shire Hall, Gloucester
GL1 2TH
Dear Mr Bungard
Sunhill Waste Processing Plant
Together with Councillor Barry Dent, I have been authorised by Ampney Crucis Parish Council to respond to the report issued by Enviros in relation to the proposal to provide a composting facility at Welsh Way, Sunhill.
We have a number of points we wish to make.
The quality of the original application.
Enviros have made a number of comments on areas of the original application where either information was unclear or where it had been omitted altogether. The report makes reference to areas where concerns might have been met had more information been provided (e.g. the fourth paragraph of 4.2 and the first paragraph of 4.7).
In section 5.3, the position is rather more worrying. The applicants have set out to convince all interested parties that they have the expertise to run a plant of this nature. In section 5.3, Enviros have done little to support this claim as they have drawn attention to the deficiencies of the original application in describing the technical background to the composting process. There are a number of references to omissions together with comments supporting the view that some of the technical detail is vague and occasionally ambiguous. The section ends with the comment that some of the statements made in the original application would be hard to substantiate.
It is our view that the supporting documentation should be totally redrafted before it is re-considered by the County Council. If this is not done, the County Council will be seen to be determining a planning application on the basis of information which its own consultants have criticised for being incomplete.
Traffic volumes
You will be aware that there is a good deal of concern among the parishes along the A417 about the classification of this road as well as the impact of the proposed plant at Sunhill.
In addition, the report does raise some more questions about the impact of traffic. On page 18 of the report, the Guidelines for Traffic Impact Assessment suggest that the environmental conditions on a road do not change significantly with changes in traffic of less than 30% unless there is a significant increase in the flow of HGVs. On page 21 the Department of Transport Design Manual for Roads and Bridges suggests that an increase in traffic of 25% is required before noise becomes an issue.
Like all statistics, these are capable of endless manipulation. Over what period is the increase measured? With what is it compared? Is any notice taken of increasing traffic volumes which would see these figures increase year by year? When were the last figures for road volumes assessed along this section of the A417?
The handling of Mixed Organic Waste (MOW)
In our original submission to the County Council, we drew attention to the fact that there has been no discussion at all as to how MOW will be handled as part of the kerbside collections. The report lays great stress on how the handling of MOW at the site must follow strict guidelines laid down by the Animal By Product Regulations. Given that, we would expect that the handling of the waste at the kerbside would receive as much attention.
The proposal is to collect 22,000 tonnes of MOW, over four times as much as the current target for green waste. How is this MOW to be segregated by the householder? How will it be stored? Will it be collected as part of the current recycling collection (i.e. every two weeks) or will it be collected weekly along with the regular waste collection? If it is to be the former, what consideration has been given to the storage of waste meat and dairy products for two weeks in the summer months?
There are also questions to be raised about contamination by genetically modified (GM) foodstuffs. There is little doubt that GM food has been imported into the country from a range of sources and entered the food chain. What proportion of MOW is likely to be contaminated with GM waste and what assessments have been carried out on the risk of cross contamination either before or after the composting process?
The report emphasises the strict handling of MOW which will be ‘received, shredded and screened’ in compliance with ABPR. Is it to be assumed that all the MOW will be compostible material? If ‘no’, how will it be sorted (and by whom) and what will happen to the non-compostible material? If ‘yes’, does this imply some kind of kerbside discretion as with the collection of green waste (which can be, and has been, rejected by the collection teams). If so, what is the householder expected to do with the rejected MOW?
In our opinion, the report lacks balance but this may well reflect the imbalance of the original application. By concentrating on the process, the application has ignored the requirements of collecting material which is to be processed. Given that it contains meat and dairy waste with its obvious potential impact on public hygiene, the absence of any detailed description of the procedures by which this waste is to be collected and delivered to the site is a serious omission which does nothing to allay public concern.
Use of the final product.
Recycling implies the re-use of unwanted material or its conversion to an alternative form which can be of use. It seems bizarre that there is no requirement to demonstrate that there is a clear use for the final product as the only alternative is to redefine recycling as meaning the weighing of waste material in order to show the amount collected complies with some arbitrary target and its subsequent diversion from landfill. Without a clear and well defined route for the final product, it seems obvious that the final position is that it is unacceptable to use waste to fill holes in the ground but acceptable to use recycled waste to create piles on the ground (provided it is on private land). This is apparently taken as read because the report clearly states that to even consider whether or not it is the right thing to do ‘would not be reasonable use of BPEO, at this development control level’
Agricultural use of the product.
On page 24 of the report, Enviros say ‘it is safe to assume that there is a considerable area of agricultural land to which the compost could be applied’. They further say that these comments (which are merely their opinion) ‘indicate that finding an outlet/market for the material should not be an issue’. That would suggest that objections are easily dismissed provided you make the right assumptions.
We accept that proving that a market exists is not a planning matter but this report was supposed to help allay the concerns of objectors. If there are ‘considerable areas’ and if it is ‘not an issue’ then presumably it would not be difficult to prove that a market exists and that the product will be quickly and efficiently distributed to local farms.
It is our belief that this is not the case and that there is not a particularly strong local market for this product. Further, given the declining level of farming subsidies to be paid in future and given the increasing emphasis on persuading farmers (via environmental grants) to take land out of production, the need for the product could well decline (if the need for mushroom compost can decline, why not other forms of compost?)
Consequently, there has to be a concern that, given the need to dispose of an ever growing pile of compost, the applicant will have to look further afield with a possible knock on effect on traffic volumes.
Future expansion
In our original submission we raised the question of the likely future expansion of this site due to its potential for accepting waste from other areas of the country. We note from section 6.1.2 that ‘ensuring sustainable waste management practices and making available sites for the treatment of waste close to waste arisings (my italics) is a planning consideration and a very relevant one in this case’. We take this as meaning that there is no question that the site will not accept waste from other parts of the country as it is incumbent upon other areas to find waste handling sites close to their own waste arisings. We would appreciate confirmation of this.
Summary of comments
The report from Enviros deals mainly with the issues raised by the process of composting waste material. Our concerns lie mainly with the issues either side of that process i.e. the collection of the input and the distribution of the output. Neither of these issues have been adequately dealt with and will remain an area of concern until they have been addressed. We believe they are an integral part of the total process and to concentrate largely on the composting process means the report has done only half the job.
Yours sincerely
D C Vessey Chairman, Ampney Crucis Parish Council
Copies to:
Ms Lucy Binnie (GCC)
County Councillor Mavis Lady Dunrossil
County Councillor Ray Theodolou
District Councillor Edward Horsfall
District Councillor David Fowles
Mr Geoff Chapman – Chairman, Poulton Parish Council
Mr Nicol Ferguson – Chairman, Ampney St Mary Parish
Mr Julian Selby-Rickards – Chairman, Ampney St Peter Parish
Councillors of Ampney Crucis Parish Council
Clerk to Ampney Crucis Parish Council