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Proposal for Materials Recovery Facility, Newhaven –Supporting Statement 10 June 2011 Page 1 of 20 PLANNING APPLICATION PROPOSAL FOR MATERIALS RECOVERY FACILITY, NORTH QUAY ROAD, NEWHAVEN Supporting Statement Cissbury Consulting Ltd June 2011 David Payne BSc MSc MRTPI Cissbury Consulting Ltd 9 Cissbury Road Hove BN3 6EN m. 07834 268407 e. [email protected]

PLANNING APPLICATION PROPOSAL FOR MATERIALS … · 2011. 6. 13. · Appendix 4 Noise & Vibration Management Plan 20 . Proposal for Materials Recovery Facility, ... • 1 no. trommel

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Page 1: PLANNING APPLICATION PROPOSAL FOR MATERIALS … · 2011. 6. 13. · Appendix 4 Noise & Vibration Management Plan 20 . Proposal for Materials Recovery Facility, ... • 1 no. trommel

Proposal for Materials Recovery Facility, Newhaven –Supporting Statement

10 June 2011

Page 1 of 20

PLANNING APPLICATION

PROPOSAL FOR MATERIALS RECOVERY FACILITY,

NORTH QUAY ROAD, NEWHAVEN

Supporting Statement

Cissbury Consulting Ltd

June 2011

David Payne BSc MSc MRTPI

Cissbury Consulting Ltd

9 Cissbury Road

Hove

BN3 6EN

m. 07834 268407

e. [email protected]

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Proposal for Materials Recovery Facility, Newhaven –Supporting Statement

10 June 2011

Page 2 of 20

CONTENTS

1. Introduction 3

2. Site and Background Information 3

3. Description of the Development Proposal 4

4. Policy Context 6

5. Planning and Environmental Considerations 9

6. Conclusions 13

Appendix 1 Site Location and Site Plan 14

Appendix 2 Existing planning permission 16

Appendix 3 Photographs of the site 18

Appendix 4 Noise & Vibration Management Plan 20

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Proposal for Materials Recovery Facility, Newhaven –Supporting Statement

10 June 2011

Page 3 of 20

1. Introduction

1.1 Cissbury Consulting Ltd has been appointed by Kingston Transport (Sussex) Ltd

trading as Sussex Skips (the applicant) to prepare and submit a planning

application for the change of use of the existing building (the former ‘Vapogro’

building) on North Quay Road, Newhaven, to a Materials Recovery Facility (MRF).

1.2 This Supporting Statement has been prepared to accompany the application and

provide additional details of the development proposal.

1.3 A separate Transport Report, Flood Risk Assessment and Noise Assessment have

also been prepared in consultation with the relevant authorities and are submitted

to support the application.

2. Site Location and Background Information

Site Location and Setting

2.1 The proposed development site is located on North Quay Road in Newhaven, East

Sussex, BN9 0AB. National Grid Reference TQ 44671 01726; Northings 101726,

Eastings 544671. The site location and site layout plan are provided in Figures

A1.1 and A1.2 in Appendix 1.

Current use

2.2 The existing building comprises a single storey industrial/transit shed with a two

storey office section to the front (north east elevation). The property also

includes an existing external weighbridge and surrounding curtilage. There is

parking for up to 21 cars, 4 motorcycles and 8 bicycles at the front (frontage with

North Quay Road). There is additional external parking and storage area to the

side (north west elevation) of the building.

2.3 The entire application site (the area inside of the red line – Figure A1.1) covers a

total of 10,207m2 including the road access (North Quay Road) and curtilage of

the building. The building covers an area of 3,929m2 (0.393 hectares) and will be

used for the operation of the MRF. Part of the building is currently used for

storage and distribution, the majority of the building (3,096.19 m2) is currently

vacant. This includes 2,937.28 m2 of warehouse space and 158.91 m2 of offices

(over 2 floors) and washrooms. Part of the site (external area on south east side

adjacent to the weighbridge) is currently used for storage of construction

materials by a materials supplier/contractor.

2.4 The building has an extant planning permission for general industrial use (Use

Class B2), application reference number: LW/92/0778 (Lewes District Council). A

copy of this permission is attached at Appendix 2. It was previously occupied by

a horticultural product distributor (Vapogro Ltd). No restrictive planning

conditions relating to transport or hours of operation apply under the current

permission.

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Proposal for Materials Recovery Facility, Newhaven –Supporting Statement

10 June 2011

Page 4 of 20

2.5 The land adjacent and to the immediate south west of the building is used for the

importation, storage and processing of sea-borne imported aggregates. Part of

that site (2 areas totalling c.0.2 ha) has permission for importation, storage and

processing of minerals and construction and demolition waste (application

reference number LW/574/CM). There is no limit to the quantity of material

permitted to be processed under this permission, and operations are consented to

take place between 0730 and 1900 Monday to Friday and between 0730 and

1300 on Saturdays.

2.6 Land to the north west is used for mineral processing, and for concrete batching

(application reference LW/616/CM). Figures A3.1 - A3.4 in Appendix 3 provide an

illustration of the existing use to the immediate south west of the site, between

the existing building and the River Ouse wharf frontage.

2.7 The development proposal will not interfere with the operation of the wharf

including landing of aggregate materials.

3. Description of the Development Proposal

Development Proposal

3.1 The development proposal will involve the change of use of the existing building

(B2) to a Materials Recovery Facility (MRF) – a waste treatment (sui generis) use.

3.2 The existing building will be retained and no physical changes to the building,

excavation or engineering works are proposed other than redecoration to the

north east facade.

3.3 The annual throughput of materials will be approximately 35,000 tonnes. This

will comprise a range of materials (para 3.7 below) that will be stored, treated

and bulked for onward transit for reprocessing and recovery.

3.4 Machinery will include:

• 1 no. soil screener (electric) - Scheppach RS400 or similar

• 1 no. baler (electric) - Vantage VB50 or similar

• 1 no. trommel barrel screen (electric) - Baughans or similar

• 1 no. picking line and conveyor (electric) - Baughans or similar

• 2 no. excavators with grapples (diesel) - New Holland E1355SR or similar

• 1 no. loading shovel (diesel) - JCB 436ZX or similar

3.5 All machinery will operate inside the building on the existing concrete slab, and

will operate to manufacturer's sound power levels required to meet European

standard 2000/14/CE. The precise internal arrangement and layout of machinery

will be determined by operational need but is outlined in Figure A1.2.

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Proposal for Materials Recovery Facility, Newhaven –Supporting Statement

10 June 2011

Page 5 of 20

Access

3.6 Access and egress to the building will be from North Quay Road and the existing

shared access road to the main entrance to the building via the two sets of sliding

doors in its north west elevation (Figure A1.2). Car parking for staff and visitors

will be to the front (north east elevation frontage with North Quay Road). The

existing space can accommodate up to 21 cars, 4 motorcycles and 8 bicycles

(Figure A1.2).

Operation

3.7 The development proposal involves use of the building to receive, store, process

and bulk a range of primarily pre-sorted materials (from the applicant’s Lewes

site and other transfer stations) including:

• Mixed plastics and PVC window frames

• Construction and demolition materials – aggregate, hardcore, plasterboard

• Soils

• Organic material – green waste, wood, other biomass

• Paper and card

• Metals

• Carpets and textiles

• Bulky items eg mattresses

• Pre-sorted mechanical treatment residues

• Some general skip waste

3.8 Hazardous wastes and food wastes will not be accepted or managed at the site.

3.9 The majority of materials will be pre-treated (at the applicant’s Lewes facility and

other transfer stations) with further sorting and bulking at the development

proposal site. The site will also be used to sort some general skip waste (mixed)

from local sources at the site.

3.10 Once processed and bulked, materials will be supplied to reprocessors or end

users in the local area and potentially further afield depending on the material,

market and location of reprocessors and users. For example, soils will be

screened with compost material to produce a high grade top soil for sale in bulk;

hardcore will be separated for crushing off-site and supply as recycled aggregate

to the local market; paper and card will be sorted with high quality material being

supplied to the local and wider regional market and low quality residues going for

use as a fuel; and plastics and metals are likely to be supplied in bulk to the local,

national or international (export) market.

3.11 Materials may be stored inside the building prior to onward transport. Some

processed inert materials such as hardcore may be stored outside of the building

(south east façade – where similar material is already stored) pending collection.

Hours of operation

3.12 The site will operate from 0700-1900 Monday to Friday, Saturdays 0700-1300.

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Proposal for Materials Recovery Facility, Newhaven –Supporting Statement

10 June 2011

Page 6 of 20

Need for the development

3.13 The site will be operated by Kingston Transport (Sussex) Ltd trading as Sussex

Skips. The company is local and operates from a site at Cliffe Industrial Estate in

Lewes. The company requires additional space in order to maintain and also

expand its operations. This facility would enable the company to expand its

recycling capability, in terms of overall amount of waste managed and improving

the separation and grade of materials for supply to the market.

3.14 Materials will be sorted and bulked using the equipment detailed in paragraph 3.4

above. The facility will thus provide the required capacity for the applicant to

undertake further separation and bulking of materials that is not currently

possible at its site in Lewes due to space constraints. This will increase the

amount and proportion of material that would be diverted from landfill, with more

than 90% of the throughput of materials being recycled.

3.15 Thus the proposal is essential for the following reasons:

• Viability and expansion of a local business that serves the local area

(businesses and households), including creation of additional employment in

Newhaven

• Diversion of waste from landfill, contributing to delivery of EU, national,

regional and local targets and policies, and reflecting the lack of proximate

landfill capacity

• Increasing recycling and the sustainable use of resources, with consequent

environmental benefits

Employment

3.16 When fully operational, the site will employ up to 15 full-time equivalent staff,

primarily operating machinery and vehicles, and involved in day-to-day

management of the site, plus office staff managing deliveries and sales. Site

management will meet Environment Agency permit requirements.

4. Policy Context

4.1 National, regional and local planning policies aim to reduce the amount and

proportion of waste that is landfilled, increase the amount and proportion that is

re-used, recycled and recovered, and ensure that adequate waste management

facilities are provided in a timely manner to enable this to occur.

National Policy

4.2 The national Waste Strategy 2007 (currently being reviewed by the government)

sets out objectives for waste management including of relevance to this proposal:

• To increase diversion from landfill of non-municipal waste

• To secure investment in infrastructure needed to divert waste from landfill

• To get most environmental benefit through increased recycling of resources

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Proposal for Materials Recovery Facility, Newhaven –Supporting Statement

10 June 2011

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4.3 Planning Policy Statement 10 (PPS10) Planning for Sustainable Waste

Management sets out national planning policy for waste. The key objectives set

out in the PPS include:

• To drive waste management up the waste hierarchy, addressing waste as a

resource

• Enable sufficient and timely provision of waste management facilities.

4.4 Minerals Policy Statement (MPS)1 Planning and Minerals sets out national

minerals policy to encourage prudent, efficient and sustainable use of materials

including recycling of suitable materials to reduce the requirement for primary

extraction. Ancillary policies for aggregates (Annex 1) set out a hierarchy of

supply, prioritising use of alternative materials in preference to primary

aggregates.

4.5 The proposal is supported by and will contribute to delivery of national waste and

minerals policy, and targets to move management up the waste hierarchy.

The South East Plan - Regional Spatial Strategy for the South East of

England (2009)

4.6 The Localism Bill currently going through Parliament will abolish Regional

[Spatial] Strategies in due course. However, adopted regional (RSS) policy is

currently part of the development plan.

4.7 The policies in the South East Plan of most relevance to the application are:

• W3 (Regional Self-sufficiency) - provision of capacity for rapidly increasing

recycling, composting and other recovery

• W4 (Sub-regional Self-sufficiency) –provision of management capacity

equivalent to the amount of waste arising and requiring management in

WPA areas.

• W5 (Targets for Diversion from landfill) and W6 (Recycling and

Composting) – targets to increase recycling and recovery rates

• W7 (Waste Management Capacity Requirements) – identifying a mix of

developments to enable delivery of recovery and recycling targets, including

activities of industrial nature such as materials recovery facilities

• W17 (Location of Waste Management Facilities) – identifying characteristics

making sites suitable for waste management use including good

accessibility and compatible land uses including previous or existing

industrial use.

East Sussex and Brighton & Hove Waste Local Plan (2006)

4.8 The adopted Waste Local Plan provides the local policy context. The policies of

most relevance to the development proposal include:

• WLP1 (Strategy) – proposal shall contribute to eliminating disposal of

untreated waste to land, to net self-sufficiency and to targets for increasing

recycling and recovery

• WLP2 (Transport) – proposals located close to sources of waste and

consider use of transport other than by road

• WLP4 (Rail and water) – encouraging use of rail and water transport

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Proposal for Materials Recovery Facility, Newhaven –Supporting Statement

10 June 2011

Page 8 of 20

• WLP9 (Site-specific Allocations for Energy from Waste and Material

Recovery Facilities) – North Quay, Newhaven identified as Area of Search

(Inset Map 5)

• WLP11 (Reduction, re-use and recycling during construction and design) –

including maximising use of existing buildings

• WLP13 (Recycling, Transfer and Materials Recovery Facilities) and WLP14

(Recycling and recovery facilities for construction and demolition waste) –

proposals will be permitted, subject to other policies, on industrial or other

suitable previously developed land

• WLP35 (Amenity) – development scale, form and character is appropriate

to location, no unacceptable adverse effects on amenity, measures taken to

control, noise, dust, litter, odours and emissions

• WLP36 (Transport) –there must be adequate arrangements for access,

safety and road capacity

• WLP37 (Flood Defences, Runoff and Floodplain) – development not

permitted if detrimental to flood defences, in floodplain unless overriding

case for the development, increase risk of flooding.

East Sussex and Brighton & Hove Minerals Local Plan (1999)

4.9 The development proposal is proximate to an aggregates wharf and will include

the recycling of construction and demolition waste, and so the following Minerals

Local Plan policies are of relevance:

• Policy 9 (Aggregate Imports – Newhaven) – development unrelated to

receiving and processing of imported aggregates at North Quay normally

opposed, except for recycling of mineral and construction and demolition

wastes.

4.10 The development proposal will not involve the loss of any area or capacity for

processing of imported aggregates and complements the use of the adjacent site

as a minerals importation facility serving the county with the potential for

movement of secondary and recycled materials by water (on return vessels) – an

option being investigated by the applicants.

4.11 In addition the soil screening operation and separation of hardcore for subsequent

supply to market accord with the following policy.

• Policy 14 (Secondary Aggregates) – support for proposals for recycling

facilities that will increase the re-use of mineral, construction and demolition

wastes in appropriate industrial areas, including Newhaven.

Waste and Minerals Core Strategy – Preferred Options consultation

(2009)

4.12 Although not adopted, the draft MWCS provides a helpful indication of the likely

direction of future local waste planning policy. Policies of particular relevance to

this development proposal include:

• CS1b (Minimising waste during construction and demolition)

• CS2 (Additional waste recovery capacity requirements) – identifying the

need for up to 45,000t additional recycling and composting capacity by

2015/16 and 149,000t by 2025/6

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Proposal for Materials Recovery Facility, Newhaven –Supporting Statement

10 June 2011

Page 9 of 20

• CS3 (recycling and recovery targets) – including for commercial and

industrial, and construction and demolition wastes

• CS5a (Sites for built recycling and recovery facilities) – criteria and site

characteristics including preference for previously developed sites including

B2 uses

• CS9 (Sustainable, efficient, and hierarchical management and use of

minerals) – supporting development producing recycled materials

• CS10b (Safeguarding wharfs) – including berths 1-5 at North Quay,

Newhaven

4.13 We are aware that the diversion of processing residues arising from skip waste

transfer stations from landfill is emerging as a priority in the Waste Core Strategy

development process.

Lewes District Local Plan (2003)

4.14 The adopted Local Plan policies of relevance to this proposal include:

• ST3 (Design, Form and Setting of Development) – development should

respect the amenities of adjoining properties in terms of noise, privacy,

natural daylight, and visual amenities and smell, and should not result in

detriment to the character or the amenities of the area through increased

traffic levels, congestion or hazards, noise levels and other environmental

considerations

• ST30 (Protection of air and land quality) – development should have an

acceptable impact on health, the natural environment, or general amenity,

resulting from releases to water land or air, or noise, dust, vibration, light or

heat

• NH24 (North Quay) – only port-related development will be permitted.

5. Planning and Environmental Considerations

5.1 A waste management use is compatible with and complementary to other uses in

the locality, particularly the aggregates import and processing and waste

management uses adjacent to and in the vicinity of the site.

5.2 Pre-application discussions with the County Council, Lewes District Council and

the Environment Agency have been undertaken to consider potential issues

arising from the proposal and agree the approach to be taken, including for the

mitigation of potential impacts caused by noise, vibration, dust, air emissions,

and traffic generation. These discussions have informed the measures proposed

to minimise and mitigate any potential adverse effects of the development.

Waste Management - Principle of the development

5.3 The use of the site for a Materials Recovery Facility, using the existing vacant

building, generating employment and delivering more sustainable waste

management, is supported by national planning policies (principally PPS10 and

MPS1) regional spatial planning policy (South East Plan), and local policy in the

Waste Local Plan (WLP), Minerals Local Plan (MLP), emerging Minerals and Waste

Core Strategy (MWCS) and the Lewes District Local Plan (LDLP).

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Proposal for Materials Recovery Facility, Newhaven –Supporting Statement

10 June 2011

Page 10 of 20

5.4 The development proposal will contribute to moving waste up the waste hierarchy

through intensive extraction of material for re-use and recycling of commercial

and industrial, and construction and demolition wastes, and a consequent

reduction in the amount of material disposed of to landfill. It is therefore in

accordance with PPS10 and the National Waste Strategy, South East Plan Policies

W3, W5, and W6, Policy WLP1 of the Waste Local Plan, and Policy 14 of the

Minerals Local Plan. The provision of additional capacity to help achieve recycling

and landfill diversion targets is also supported by Policies CS2, CS3 and CS9 of

the emerging draft Minerals and Waste Core Strategy.

5.5 The location of the development is supported by South East Plan Policy W17,

Waste Local Plan Policies WLP2, and WLP13, with the potential for MRF

development in this particular location set out in WLP9. The re-use of the

existing building (and reduction in possible resultant construction and demolition

waste in the event of demolition) is also supported by Waste Local Plan policy

WLP11 and MWCS Policy CS1b. The development of this site, as previously

developed in B2 use, would also accord with Policy CS5a of the draft Waste and

Minerals Core Strategy.

5.6 The development proposal will not interfere with the use of the wharf for

aggregates import, storage and processing, and the applicant is actively

investigating options to export some recycled material by water from the wharf.

It therefore accords with Policy 9 of the Minerals Local Plan, Policy NH24 of the

Lewes District Local Plan, and Policy CS10b of the draft Minerals and Waste Core

Strategy.

5.7 Assessments of the potential impact of the development proposal on amenity

including noise, dust and vibration, and the measures proposed to minimise the

risk of these occurring are described below. These reflect pre-application

consultations and will ensure that the development is in accordance with Policy

WLP35 of the Waste Local Plan, and Policies ST3 and ST30 of the Lewes District

Plan.

5.8 The Flood Risk Assessment that accompanies the planning application

demonstrates that the development is in accordance with Policy WLP37 of the

Waste Local Plan.

Highways and Transport

5.9 A Transport Report has been prepared in line with East Sussex County Council

guidance to support this planning application. This sets out the likely vehicular

movements that will be generated by the development proposal, and measures to

reduce the potential impact of these on the highway network.

5.10 The Transport Report highlights that the number of vehicular movements likely to

be generated by the proposed development is modest. It concludes that, in the

context of trips that could be associated with the current permitted use of the

building and current transport of materials to an adjacent facility in North Quay

Road by the applicant, the development proposal would not result in additional

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Proposal for Materials Recovery Facility, Newhaven –Supporting Statement

10 June 2011

Page 11 of 20

new movements or impact on the highway network. The development proposal is

therefore in accordance with Policy W17 of the South East Plan and Policy WLP3

of the Waste Local Plan.

5.11 Notwithstanding the above, to allay concerns of Lewes District Council over the

potential detrimental impact of proposed vehicular movements on air quality at

critical junctions in Newhaven, the applicant is willing to restrict movements its

own HGVs to 4 each way per hour during peak hours (0830-0930 and 1630-

1730). This will also help reduce potential congestion. As a number of roads

exiting Newhaven are weight restricted, HGV movements would be limited to A26

only, with access to the site via Drove Road and North Quay Road and the

junctions. The applicant is also planning to use the wharf for export for recycling

of materials.

5.12 It is understood that improvements are to be made (construction of a new mini

roundabout) at the Southern end of North Quay Road as part of the Energy

Recovery Facility development which will resolve any potential congestion or

capacity issues at that junction.

5.13 The Highways Agency has been consulted and confirmed that it has no concerns

over the proposed change of use in terms of potential effects on the A26.

Flood risk

5.14 The site is within Flood Zone 3a, identified in PPS25 as ‘high probability’ of

flooding. Planning Policy Statement 25 Development and Flood Risk advises that

waste treatment is a less-vulnerable use that is compatible with Floodzone 3a.

However a Flood Risk Assessment (FRA) is required for development in Flood

Zone 3a, and an FRA has been prepared in accordance with PPS25 and advice

from and in consultation with the Environment Agency and accompanies the

planning application. The FRA demonstrates that the development will not

increase flood risk and sets out measures that will be taken to improve the

building’s resilience and procedures that will followed in the event of flood

warnings being issued and an actual flooding event. The Environment Agency

has confirmed that it considers that the FRA is satisfactory.

Noise

5.15 All machinery will operate within the building, which will substantially reduce and

mitigate potential noise generation and impacts on sensitive receptors. The doors

in the south west elevation will remain closed at all times. A noise assessment

has been undertaken and accompanies this application that demonstrates that

any impact at sensitive receptors (nearest residential properties) identified by

Lewes DC will not be unreasonable even under a worst case scenario, and

therefore should be deemed acceptable without the need for further assessment.

Vibration

5.16 The operation of the machinery may also have the potential to cause vibration.

In scoping of the noise and vibration assessment, our noise and vibration

specialists, in consultation with Lewes DC, concluded that potential vibration that

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Proposal for Materials Recovery Facility, Newhaven –Supporting Statement

10 June 2011

Page 12 of 20

adverse vibration effects are very unlikely to be an issue. The nearest sensitive

receptors (residential premises) are located on the Western side of the river more

than 200 m from the site, and are in close proximity to the A259/town centre

gyratory. The transmission path for vibration is broken by the river - there are

two significant impedance changes between the soil and the river and then again

to soil, which would significantly damp vibration energy that may be transmitted

into the ground. It is therefore considered highly unlikely that there would be any

adverse impacts from vibration induced by the facility plant at or beyond the

facility boundary.

Dust

5.17 The site is surrounded by aggregates storage and processing activities which

inherently have potential to generate dust. However, measures will be taken to

minimise the risk of dust arising from the site. Waste treatment processes and all

machinery and equipment will operate within the building. There will be limited

outside storage (no additional processing) of inert construction and demolition

waste, confined to the area adjacent to the weighbridge. This part of the site is

already used for storage of similar materials. When required (in dry conditions)

the material will be regularly dowsed with water to suppress dust. A dust

suppression system may be installed within the building should dust levels require

control for staff health and safety reasons.

5.18 Vehicles entering and leaving the site will be damped down (at the entrance on

the north west façade of the building) when required (particularly dry windy

conditions) and containers and skips will be sheeted in order to minimise risk of

additional dust emissions from the site.

Odour

5.19 The site will not receive food waste and putrescible material will not be stored on

site. Therefore it is unlikely that odours will arise from the proposed development

and operation.

Air Quality

5.20 As described above, HGV movements will be managed to mitigate the potential

effect on congestion and idling of vehicles, thus helping to reduce potential

adverse effects on air quality at critical junctions. All of the client’s own vehicles

are Reduced Pollution Certificated and meet the current emission standard for

new heavy-duty vehicles of Euro 5/Euro V.

Visual Amenity

5.21 The development proposal does not involve any physical works or changes to the

external appearance of the building, which generally is in good condition. The

office frontage to North Quay Road is rather dated and cosmetic improvements

(redecoration) will be made.

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Proposal for Materials Recovery Facility, Newhaven –Supporting Statement

10 June 2011

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Management

5.22 Measures are proposed to minimise and eliminate the potential impacts of the

development proposal on amenity. These have been informed by discussions

with the Waste Planning Authority, Environment Agency and Local Authority

(Environmental Health). The proposal will comply with the requirements of the

Environmental Permit to be issued by the Environment Agency. A Noise and

Vibration Management Plan is contained in Appendix 4 that reflects the results

and recommendations in the supporting Noise and Vibration Impact Assessment.

6. Conclusions

6.1 The proposed development will enable the applicant, a local company, to maintain

and improve its recycling business. The development of the Materials Recovery

Facility will enable the applicant to achieve higher rates and amounts of recycling,

with consequent reductions in the amount of waste sent to landfill (outside the

county) and associated environmental benefits.

6.2 The proposed development is in accordance with and will contribute towards the

delivery of national, regional and local planning policy that seeks to move waste

management up the waste hierarchy and manage waste close to where it is

generated.

6.3 The location of the development proposal is well suited to a waste management

use, with an industrial character and with adjacent established waste

management and minerals processing uses. The site has good accessibility to the

highways network and generation of traffic will be modest. New (additional) trip

generation associated with the development proposal will be negligible (compared

with potential trip generation that would be expected from the existing permitted

use). The potential use of the wharf for movement of materials by water is also a

key benefit of this location.

6.4 The re-use of an existing building that is distant from sensitive land uses

including residential properties, with operations undertaken within the building,

will minimise any potential impacts on amenity. Measures are proposed to reduce

the potential risk of adverse impacts on amenity including noise and dust.

6.5 The development proposal is a ‘less sensitive’ use classified as compatible with

the degree of flood risk at the site, and will not result in increased flood risk to

the site or elsewhere. As operations will be restricted to the building and its

immediate curtilage it will not interfere with the use of the adjacent wharf for

import of aggregates.

6.6 Pre-application consultations have been undertaken with East Sussex County

Council (the Waste Planning Authority and Highways Authority), Lewes District

Council (local planning authority and environmental health) and the Environment

Agency. Issues raised during these consultations have been addressed in

separate assessments and proposed mitigation measures.

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Appendix 1 Site Location

Figure A1.1 Site Location (1:5000 @A4)

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Figure A1.2. Site Layout, Access & Parking Plan (1:500 @A3)

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Appendix 2 Existing Planning Permission for the site (LW/92/0778)

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Appendix 3 Photographs of the site

Figure A3.1 Main access and entrance to building (view South West into entrance from

North Quay Road

Figure A3.2 Access road and adjacent land uses (view facing North East from within

site)

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Figure A3.3 South West elevation of building and adjacent land uses (view facing west

from weighbridge)

Figure A3.4 South West elevation of building and adjacent land use (view facing North

East from wharf)

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Appendix 4 Noise & Vibration Management Plan

1. The Noise Assessment (presented in full in the separate supporting report) indicated

that overall noise levels would not be considered unreasonable and consequently

should be deemed acceptable within the context of the application for which it forms

part. However, it is recognised that there may be occasions when noise from the

MRF operation may become audible at the nearest sensitive residential properties.

2. In the event that there are complaints, a noise and vibration monitoring and

management plan is proposed.

3. A process for managing complaints relating to disturbance from noise and vibration

caused by activities at the site will be implemented. This process will ensure that

complaints are logged, investigated, reported and where necessary appropriate

action taken to mitigate the noise or vibration causing complaint.

4. In the event that a complaint is received by the site regarding noise or vibration this

will be logged in a specific complaints log book. Details of the nature of the

complaint will be taken including the time and character of the noise/vibration being

complained about.

5. As soon as is practical to do so the complaint will be investigated by the site

manager to determine the likely source or activity causing disturbance. If the cause

of the disturbance can be clearly identified at the time of the complaint, and if

practical to do so, appropriate action will be taken.

6. However, if not practical to do so the next available opportunity for curtailing the

activity will be taken and an investigation initiated to understand the cause and

implement appropriate action.

7. Following the investigation the complainant will be informed of the outcome and any

action taken which will be logged alongside the details of the complaint.

8. The Local Authority will be made aware of the complaint, the investigation and the

outcome of the assessment and will be invited to approve any mitigation measures

prior to implementation.

9. Every 6 months the complaints log will be reviewed to identify if there are any

activities that are causing ongoing disturbance. If specific activities or plant are

identified then an assessment will be undertaken to identify if it is necessary to

introduce appropriate mitigation to reduce the noise / vibration levels. This

assessment of the noise or vibration from that activity will be undertaken by

persons/organisation recognised as competent to conduct such an assessment. The

assessment will be conducted in accordance with the requirements of BS4142 for

noise and BS5228-2 [7] in the case of vibration. Where the associated levels are

deemed to have an adverse impact appropriate mitigation will be implemented to

reduce noise or vibration levels accordingly.