Tuesday, 1 January 2008
APPLICATION Ref: Y08/0124/SH.
Date: 3rd August 2008.
WATER ISSUES - THE FACTS.
My name is Leslie Barratt and have been working within the water industry as Engineering Technician for the past 37 years. I was first alerted to the water issues at the Otterpool site by Sellindge and District Residents Association in late February 2008.
My initial concerns over the application was the lack of information within the design statements produced by SLR consulting on behalf of the applicant: Countrystyle Recycling Ltd. Moreover, I was greatly surprised that an Environmental Impact Assessment was not provided nor insisted upon by Kent County Council.
ENVIRONMENTAL IMPACT ASSESSMENT.
Kent County Council has stated that an Environmental Impact Assessment would not be required back in October 2007. Having consulted with the Environment Agency and Natural England, their view then was that enough information was provided within the application and that the impact upon the surrounding area was such as not to warrant an EIA.
At the time of the application, the consultees were not in receipt of ALL the facts. The application was void of all drainage proposals. In an area where the nearest sewer was one kilometre away I consider this oversight to be a disgrace and put the blame squarely at the door of KCC.
It is a matter of record that European Law, directive EIA 85/337/EC states that given certain site criteria, an EIA is a requirement and must be carried out. My recent correspondence with KCC details all criteria and requirements and is available to any interested parties.
The South East is the driest area in the UK. In recent years we have experienced hose pipe bans with media headlines of low rainfall and barren reservoirs. I would expect to see some regard to water consumption at the site if only given as an estimated ‘Megalitres per year’ figure. There is no mention of water recycling (grey to black) or rainwater harvesting.
CONSENT TO DISCHARGE LICENSE.
As previously described, the site has no facility to discharge effluent to the Southern Water sewer. Previous owners of the site acquired a license to discharge to a local water course.
SLR’s design statement regularly mentions a consent to discharge and also states that sewage will be discharged via this license.
The license was issued to Redland Aggregates Ltd in 1989 and clearly states FOR SURFACE WATER ONLY.
GEOLOGY OF SITE.
The site overlies two important bed formations: Hythe and Folkestone.
The Hythe bed consists of sandy limestones: Rag stone and Hassock (hard sandstones). Mid Kent Water have modelled this strata and consider it to be a significant water resource. Local properties are believed to be served by this formation.
The Folkestone Beds consist of a series of sands including iron rich and clay bands.
Known as Lower Greensand, this formation is the second most important source of drinking water in Kent.
As the main consultees in the screening and scoping process, the EA have raised a number of points and concerns over the Otterpool site and Application specification.
Initially, an objection was raised by the EA in line with PPS23 by the Land Contamination Team on the EXISTING pollutants that may be present on site but later withdrew the objection after studies carried out by SLR Consulting Ltd.
The EA describe the site as vulnerable because of the very high water table and the permeability of the site.
The EA are surprised that full drainage proposals did not accompany the application and to date still do not have any drainage proposal from the applicant.
In any event, the EA has made it very clear to the applicant that NO SOAKAWAYS WILL BE ALLOWED TO BE INSTALLED AT THE SITE.
KENT COUNTY COUNCIL.
As a County council determining applications such as the Otterpool site, I am surprised that there seems to be no one at officer level that could screen applications, particularly on waste sites for environmental impact. I dread to think how far this application could have got if it wasn’t for the voices and expertise of local people.
The protection of our local water courses and Aquifers is of paramount importance and should be protected at all costs. There must be no trade off against employment or landfill costs whatsoever. We look to our District and County councils as guardians of our environment and expect nothing less.
One of the conditions of carrying out an Environmental Impact Assessment is that alternative sites must be considered. There has been very little consideration for this requirement from KCC and can only wonder at why, given the major concerns over water issues, other sites are not being considered. I also understand that the Otterpool site has never been ear marked as a waste site under the Kent Waste Strategy Plan.
As mentioned at the Development Control committee meeting, the old Richborough station site should be given consideration.
SHEPWAY DISTRICT COUNCIL REPORT. Terry Ellames.
I refer to paragraph 5.14.
As previously stated in this document, water issues have not been assessed to a satisfactory degree or conclusion. It is a fact that the Environment Agency still requires further information from the applicant.
Any concerns that Southern Water would have would only relate to drainage proposals. No mention has been made by SLR to connect to the sewer and to date there are no drainage proposals in existence.
EXISTING LOCAL SEWAGE PROBLEMS.
It is well noted in the area that during periods of high rainfall there are problems with the combined (rain and sewage) sewer system. It is a matter of record that during these periods, manhole lids are forced up by the surge of water, depositing human waste and such like over peoples properties and finding its way into the head of the river Stour (East Stour). Any attempt to connect to this system would only exacerbate an already unacceptable situation.
This document has been produced as a result of the Development Control Committee meeting at Shepway District Council on 29th July 2008. Although the member’s comments were most welcomed in condemning the application and site use, I was surprised that there were no officers in attendance that could advise members on technical matters such as water issues.
This is a brief and non technical summary of the complex issues surrounding water issues at the Otterpool site and has been produced for members of Shepway Development Control Committee.
I would be happy to provide further information should any member wish to pursue this matter further.
Leslie Barratt. Eng Tech MIPHE.
then can use all google maps featurs showing greenery etc.
Les Barratt - Water - Chairman
Bob Edden - Policy - Chairman
Diana Ponting - Treasurer
Ian Medgett - Ecology & Environment
Penny Knight - Researcher
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Our Local Councillor contacts are:
Sellindge, TN25 6EB
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KCC's - address, key members, their contact details and areas of responsibilities:
Postal Address: Kent County Council, Invicta House, County Hall, ME14 1XX
Cllr Paul Carter
Head of Planning Applications Group
Senior Case Officer
Environment, Highways and Waste
Chairman - Planning Committee
MP for Folkestone and Hythe
Folkestone and Hythe Conservative Association
4 West Cliff Gardens
Folkestone CT20 1SP
MP for Ashford
House of Commons
London SWA 0AA
020 7219 3518
Ashford TN26 3AG
Councillor, Shepway District Council
Sellindge Ashford TN25 6EB
The meeting at the Village Hall was packed tight. Many people just were not able to get in alongside the 240 that managed it. The voice of the village was unanimous - Countrystyle you can take you pollution and your heavy goods traffic and your poisoning of our water and air and your noise and take them to some solitary island far away. No one gave Countrystyle a moment of encouragement. Their presentation of their case was pitiful and if they operate as well as they spoke to this village we can really worry about their competence to do anything.
This movement to oppose has begun to reveal an idea held by some powerful interests to industrialise this beautiful part of Kent from Ashford to Dover. The details are hard to substantiate but there is enough to justify the following speech I made at the meeting. It is reproduced for those who were not able to hear it.
"With your permission, Mr Chairman, I would like to start by thanking you and the representatives of Kent County Council Planning Department for organising and attending this meeting, and for giving us the opportunity to express our views. I would also like to thank the committee and supports of Sellindge and District Residents Association (SANDRA) for their untiring work in organising the protest march in May which attracted over 600 people - a high proportion of Sellindge residents - all keen to express their anger at and implacable opposition to Countrystyle Recycling's proposals for the Quarry site.
The third thank-you goes from all the people of Sellindge to their committee members for producing the document that has been distributed this evening. This document summarises the points so far identified which we are asking our visitors from KCC Planning Department to consider and act upon. I should stress that this is a preparatory document - more detailed review is in preparation. However, there is plenty in the document you now have which deserves immediate attention. My colleagues will establish some points this evening, I want to raise a disturbing issue which has arisen as I have pursued various lines of research. Mr Chairman, it is a ling time since I had dealings with local authorities in a profession capacity. Back in the 70s I was very aware that such dealings often took place in a sort of miasma of mistrust and suspicion. Rumours and accusations of bribery and corruption were commonplace, and in some cases such accusations were sustained. This climate of mistrust arose, as I recall, from a kind of darkness - an absence of light and clarity, and a sense that things were being decided by powerful people fumbling undercovers towards undeclared objectives. This culture was changed by throwing back the blankets covering bureaucratic furtiveness and exposing the fumbling to the light of day. But I have to say that today there are signs of its return, and as I begin to approach agencies of local government I am again aware of a culture of darkness.
Let me make it clear that my dealings with Senior Planning Officer Angela Watts have been entirely harmonious and open. I am speaking more about the Local Authority world which lies behind the Planning interface with the public. For example, it is proving impossible to discover what is being planned, long-term, for the people of Sellindge and the other villages in the area. Why are we not informed of such plans and considerations? Why cannot long term proposals be discussed with those most affected by them - in this instance - us! Why is it that we are the last to know of plans and proposals capable of affecting our village and our quality of life in truly devastating ways? Why is it for example, that Countrystyle has had three years to prepare its proposals, three years to consult with the Boroughs and Districts, with the industries, the businesses and the commercial enterprises of Kent? Three years of access to KCC officials, by skilled people employed full-time to prepare proposals on Countrystyle's behalf.
By sharp contrast, the team at SANDRA all work full time in other employment, have busy lives and families to look after, and have had merely a few months to prepare a fully professional response (at their own expense) to the proposals submitted by Countrystyle. Most crippling of all, they have been allowed none of the easy access to County Hall and other interested parties which Countrystyle has enjoyed for so long.
It is my earnest entreaty today, Mr Chairman, in the name of equity and just government, that you urge those officials, politicians, planners and interested parties who have influence on such proposals as these - proposals which can have truly devastating effects upon vulnerable communities - to open their thinking and their plans to those most affected.
It is the absence of such openness that gives rise to that culture of darkness, real or perceived, which I mentioned just now. The culture in which rumours, suspicions and accusations flourish - as they are now flourishing, I am sorry to say, around the proposals before us today".
During the holiday months of July and August our activities may seem to quieten, but I can assure you that many in this village are continuing to work throughout the summer to ensure our case against the development of a waste treatment plant on the quarry and above the second most important source of Kent's drinking water will be defeated. I shall be bringing you all up to date in September when we shall begin to turn the spotlight on Shepway. Thank you for your attention and support.
Ronald Lello Chairman Sellindge and District Residents Association (SANDRA)
Dear Neighbour - 3rd September 08
Those of you who received my first letter “The Thin End of the Wedge” will know what this is all about, those who have not will once I mention the horrendous smell which has been emitted from a composting site in Church Lane you no doubt now understand.
The recent composting activities by Wanstall & Sons in Church Lane have driven away the Swans and Grebes both protected under the Wildlife & Countryside Act 1981 that had occupied the pond adjacent to the site for the last 3 years.
They have had their licence to compost under an exception to Regulation 12 of the Waste Management Licensing Regulations revoked. The Environment Agency can tell you the full facts but basically they were not doing things correctly.
Church Lane now floods during every decent rainstorm, this is due to the concrete roadway and concrete pad damaging the field’s French drains which were design to take the water around the back of the hill to the balancing pond created especially for this purpose. The flooding has also been exasperated by the bunds (mounds) built supposedly to contain leachates from the compost.
I did warn you that this operation would smell and boy what an acrid and odious smell it has been and to whom dependant on wind direction and speed. The smell managed to travel a good couple of kilometres from the site so they where they were generous with it we all had some, unfortunately it made some of us those closest to the feel quite ill.
Wanstall & son have withdrawn their Planning Application for the Roadway and Pad with Ashford Borough Council. Is this then the end of this disgusting mess? Well unfortunately it is not, as I say in the title earlier the wedge is being driven deeper.
Wanstall & Sons have on the 21st August 2008 submitted to KCC for retrospective planning permission for a composting facility at this site. This time they intend to compost 25,000 tons of material a year consisting of 10,000 tons of Wood Chips, 10,000 tons of Sewage Cake and 5000 tons of Farm and green wastes. Of the farm wastes 1,500 tons of this will be your favourite odour “a la chicken manure” plus whatever happens to fall into this mixture if you take my meaning.
Let’s look at what a 25,000 ton composting facility looks like according to a Government Paper called “Windrow Composting” I have acquired this paper from the internet:
Fig 1 A 25.000 tons per year site in action - unfortunately not included at present.
Yes folks it is massive it will cover an area of between 2–3 ha that’s approximately in old money 5 to 7.5 acres (remember these are government facts not mine) therefore this site will need to cover the whole of the field in Church Lane. The paper also states that it would require a Site Manager, Assistant Manger and 3 site operatives. Wanstall & Sons application states they only require one man to run such an operation, well. Could one Wanstall & Son or sub-contractor really be trusted to manage a large site like the above on his own?
Within the planning application there are many inaccuracies and anomalies for example it states that the site will only be 0.19 ha in size as we can see above this not correct. Another example of miscalculation is with the ratios of composting material i.e. it states 10,000 tons of wood chips are to be mixed with 10,000 of Sewage Cake (50:50) what it does not mention is what is the 5,000 tons of chicken manure/farm waste to be mixed with this? Has this been omitted or not just included? In fact there are so many holes in this application it could be used as a fishing net!
The report is not remarkable for what it says but what it does not say. For example you and I do not exist and we are not taken into account at anytime in the Bioaerosols or Odour Assessments, we just do not exist as far as this report is concerned. The fact that Ashford and Shepway Borough Councils Environmental Health Departments were swamped with complaints about the nuisance smells being emitted from this site has been totally ignored. The new application will mean that there will be daily deliveries of 4 HGVs a day included in this will be between 32 to 48 tons of sewage cake, also the rows (see above) known as Windrows (no it is not a spelling mistake) require to be turned over every 2 or 3 days these are both odour emitting processes and the horrendous smell will be constant who gets it is a lottery, it all depends on which way the wind is blowing. As far as the digester planned in Sellindge is concerned prevailing winds are south westerly sadly this will mean that the whole of Sellindge will cop it on regular occasions.
What else is not mention is just the little fact that there will be more than 3,400 extra tractor movements to and from the site a year pulling 15 ton trailers a long the country lanes collecting and distributing the compost to the various sites a round the area, such sites as Honeywell Farm on Romney Marsh and further. These tractors do not take the main roads they constantly use Church Lane and other small lanes. These lanes can expect at least 14 loads each day travelling to this site (there and back). This has been the case with the recent workings. These heavily loaded tractors are as wide as the lanes and to pass other vehicle have to mount the verges and in this process damaging them. There is a serious risk to life and limb as these tractors rush around the area passing schools and residential places.
Something else has not been mentioned but may effect people living farther away is that once the wood chippings, sewage cake etc have been in the windrows for 1 to 2 months the compost requires curing for a further 2 months. There will not be enough room on this site to accommodate this, therefore the compost will have to be moved to whatever field or near by site to the place where it is to be finally used (unless it is to be transported again!). This stacked material is still able to emit enough odour and will be a nuisance to nearby properties if not place sympathetically. By the way once spread on the land it is supposed to be ploughed in within 24 hrs, 4 days we had to wait for this to happen in Church Lane during which it reeked across our properties and made our lives very uncomfortable. Good neighbourly act or not!
Finally research has taken place in Giessen Germany and presented recently to the House of Commons by an MP that fungal spores are reaching far greater distances from composting sites than the Environmental Agencies safety zone recommendations. These spores have a potential for chronic ill health the report quotes “mucus membrane infections are particularly elevated, shortness of breath is shown to be an effect of spore inhalation and excessive tiredness is distinctly linked to site emissions”. Do you trust Wanstall & Sons and their one man to prevent these spores reaching you?
There is something you can do before it is to late and YOU ONLY HAVE ONE WEEK LEFT TO DO IT IN is to e-mail or write to the KCC Planning Officer and make your voice heard, it appears that this application will go to committee and it is here that your letters will truly count.The E-mail address is: firstname.lastname@example.org
The snail mail Address is:
Mr S Whyman
State that you wish to object to Planning Application AS/08/TEMP/0041 by the applicant J Wanstall & Sons against the Retrospective planning permission for a composting facility in Church Lane Aldington TN25 6AF
Please feel free to use any of the reason I have used above or your own, but you only have until the 18th of September 2008 to do this by. Do not delay do it today!
A copy of the application is available at Ashford Borough Council offices for your perusal (it is 118 pages long!), the basic details are on ABCs Web site under application 08/01373/AS
This letter was produced by Brian Ellis to you personally, I will be raising an objection myself, if you are willing to help please contact me on 07798 781667. In the meantime it would be a great help if once you have raised an objection to pass this letter on to a friend who may not have received a copy as I am rapidly running out of paper!
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