SELLINDGE AND DISTRICT RESIDENTS ASSOCIATION
Grove House
Sellindge
Angela Watts
Planning Officer, Planning Applications Group
Invicta House County Hall
Dear Angela Watts,
Application No SH/08/124
Construction and operation of a Materials Recycling Facility
Anaerobic Digestion Plant and Associated Office and parking facilities
We are writing to register our continued opposition to the planning application submitted by Countrystyle Recycling Ltd proposing the construction of a Materials Recycling Facility and an Anaerobic Digestion Plant on the site of old workings at Otterpool Quarry.
Summarised here are our central concerns and objections. These will be supported by a detailed Analysis of these submissions which reveal many and various deficiencies in the proposed scheme and the way in which it has been presented to date. We have six key areas of objection, each with various subsections. This Analysis with further information and illustration will be provided as appendices to this document.
Before proceeding however, we have one objection which underlies everything else in our submissions and documents. The proposal to establish an industrial scale recycling plant and anaerobic digester in this rural area is highly significant socially, ecologically and industrially. If the proposal succeeds the impact on the locality will be considerable and profound. In addition, any precedent set now is bound to be reflected in future policy for the area. There can be little doubt that the character of this part of
Some written documents bear little resemblance to the plans they describe. These inadequacies are prolific. We are left with a view that either these submissions to the Planning Officers are inept, incompetent and reflect a high degree of un-professionalism or that they are deliberately variable, thus enabling Countrystyle and their engineers a wide range of options were they to obtain the permission they seek. Whatever the reason, we have grave fears that a company which appears so careless and administratively lax should be allowed to build and manage a sophisticated industrial plant, processing highly noxious material, so close to human habitation, businesses and busy roads. We urge that the current plans and descriptions be rejected before any further consideration is given.
Core Objection 1.
There are serious discrepancies between the drawn plans, and there are further inconsistencies with written descriptions and illustrations.
Examples of the contradictions, inconsistencies and ambiguities include :-
a) The means of access to and from the site is ambiguous, showing differing arrangements on different drawings.
b) The office block is alternately shown as single storey, flat roofed and then as two storeys with pitched roof.
c) There are discrepancies concerning layout, function and size of buildings. Some buildings are not described at all.
Core Objection 2.
The proposal does not adequately describe the situation regarding the use, disposal and pollution of water.
Amongst our other concerns here are:-
a) Examination of levels stated on the drawings shows that the applicant proposes to reduce existing ground levels by as much as 5 metres, and an average approaching 4 metres. We estimate a minimum of 50,000 cubic metres of material will need to be transported away from the site. Some of this material is known to be contaminated from a previous use. The application gives no detail of how this volume of material will be dealt with.
b) The ground water levels data given by SLR is selective, referencing only a single dry summer period. This misrepresents the true situation and is misleading. The Environment Agency has asked for wider annual information which as yet has not been provided. Our own readings show that water levels can be as little as 0.6 metres below the ground surface following rainy periods, usually in winter. Rainfall statistics recorded in the village show that in each decade over the past 50 years Sellindge has suffered huge inundations of rainwater – flooding is not an uncommon event in Sellindge.
c) Simply using the limited water table figures given by the applicant, careful examination of the plans shows that both surface water attenuation ponds lie below the water table. The attenuation ponds are shown linked and the smaller pond will be constantly draining into the second. They will therefore be permanently full of water and incapable of attenuating the rate of surface water discharge from the site.
d) There are no mains sewer connections for foul or surface water, serving the quarry site. The application shows that foul and noxious wastewater will be collected on site in a holding tank, and then be pumped out into tankers and removed from site. No information is given concerning size, depth or capacity of storage tank to deal with either normal or abnormal spillage conditions and no information on how many vehicle movements are required daily to dispose of this waste. The Environment Agency demands that none of this facility must ever be below the water table.
Core Objection 3.
The proposal is out of scale with the surrounding landscape. The industrial sheds proposed will be highly visible intrusions into the local landscape and will have serious visual and ecological impact on the wider locality.
Amongst our concerns here are:-
a) Inspection of historic mapping and aerial photography (including information from the Kent Landscape Information Service) shows that the development of the site had little previously built form, and nothing constituting the industrial character falsely proclaimed on the applicants submission documents. However the applicant's Preliminary Contamination Assessment, dated April 2008, accurately described the site as “...located within a predominantly agricultural area.”
b) The sheer scale of the buildings will dominate the landscape. Local facilities include important
c) The applicant has provided a limited number of photomontage views of the site. Viewpoint 2 eminently illustrates the visual impact and enormity of the 93metre long 30 metre wide and 12.5metre high Materials Recycling shed.
d) The development will disrupt active and protected species habitats on site and endanger downstream habitats.
Core Objection 4.
The application ignores the presence of habitation and businesses in close proximity and the impact on those of the proposed plant.
Amongst our concerns here are:-
The blatant contravention of guidelines issued by the Office of the Deputy Prime Minister. ‘Planning for Waste Management Facilities: A Research Study’ prepared by Enviros Consulting and published August 2004 by the ODPM which state that:
‘Where possible, (anaerobic digestion) facilities should be located at least 250 metres from sensitive properties.’ Sensitive properties include both domestic and business premises. In this instance five domestic dwellings and ten businesses will be within this zone as determined by SLR.
The Environment Agency Standard Rules for the operation of an Anaerobic Digestion Facility (including the use of the resultant biogas) states that the activities shall not be carried out within 250 metres of any off-site building used by the public, including dwelling houses. The Airport Café has residential accommodation on the first floor and is just 50 metres from the site entrance and 100 metres from the Anaerobic Digester Plant.
b) The Airport Café has traded continuously for over 60 years. It serves over 50,000 meals per year and it’s high reputation is well known across the South-East region. This business has invested heavily in improvements over recent years and has planning permission for further development. Planning permission has also been granted to build an environmentally sensitive development of ten workshops and craft units to the rear of the Airport Café on the area currently used for car breaking. The success of these businesses will be impacted negatively by the proposed development.
c) The proposal is inconsistent with Shepway District Council’s emerging plan to develop the locality for housing at Folkestone Racecourse, Lympne and Sellindge.
Core Objection 5.
The proposal offends the local community by considerably increasing traffic flows.
a) Traffic flows through Newingreen, Sellindge and Lympne on the A20 are already subject to considerable congestion especially at the Newingreen Junction with the
b) Shepway District Council’s emerging plans for new houses in this area will bring substantial amounts of increased domestic and commercial traffic onto the A 20. The applicants assessments make no provisions here.
c) The A20 route to Junction 11 on the M20 is not suitable for carrying significant increased volumes of HGV traffic. Although the recorded accident data shows only a small number of serious personal injury accidents, the same data shows a great number of minor incidents. The inevitable increase in the number of these that will follow directly from the increase in HGV movements is a factor that should not, and must not be undervalued. All the more so considering the existing quixotic traffic arrangements at Newingreen.
Core Objection 6.
The applicant provides no site specific justification for locating the proposed facility onto this site.
a) Government planning guidance and
b) Reference to available data or commentary from any Internet search of Waste Sorting Operations and Anaerobic Digestion plants, demonstrates concerns and anxieties regarding air pollution, dust, noise, odours, flies, rats and airborne diseases and aerosol emissions.
c) There is no justification for siting industrial processing of this scale in a rural setting adjacent to village communities, thriving businesses, schools and tourist attractions.
We intend to provide the second part of our response that will contain detailed information shortly. We hope that KCC Planning Officers reject this application and advise the applicant not to appeal,
Yours Sincerely
Ronald S Lello Chairman
On behalf of Sellindge and District Residents Association
