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ITEM PN6 - ANNEX 1

PLANNING & REGULATION COMMITTEE –
4 APRIL 2005

MINERALS AND WASTE PLANNING APPLICATION

Representations and Consultations

Eye and Dunsden Parish Council

My council has met and do wish to object to the planning application. The council’s reasons for refusal of the application are that it would be an unreasonable impact on a small village.

However, should the application be permitted we would ask that the following conditions be included. The council meeting had many local residents in attendance and it is to ensure that their quality of life is not impaired.

The conditions we would ask you to consider are:

1. The permission should not extend past 5 years.
2. Restrictions on hours of business
3. The affected roads be kept clear of mud caused by the lorries.
4. Noise levels are kept to a minimum.
5. Speed of vehicles is currently an enormous problem. We would like to see some restrictions in place as there are no footpaths in the village. The speed limit through the village is 30 mph but this is too high for such large vehicles and because they use the road daily the drivers become complacent.
6. We would suggest having constraints on a section 106 agreement rather than simply planning constraints.

We would also ask you to bear in mind the following:

1. The application is effectively doubling the size of the current operation.
2. The ownership has changed and is now owned by a large corporation.
3. The term ‘expansion’ is used several times in the application and so a continuation of use is not strictly correct.

Environment Agency

The following planning informatives should be attached to any planning permission granted.

The application specifies the provision of a septic tank for the mess facilities and as such under the terms of the Water Resources Act 1991, the prior written consent of the Environment Agency is required for any discharge of sewage or trade effluent into controlled waters (e.g. watercourses and underground waters), and may be required for any discharge of surface water to such controlled waters or for any discharge of sewage or trade effluent from buildings or fixed plant into or onto ground or into waters which are not controlled waters. Such consent may be withheld.

(Note : The applicant should consult the Environment Agency for advice upon the acceptability of the proposed sewage or trade effluent discharge to underground strata or on alternative means of sewage or trade effluent disposal.)

It is not clear from the details made available to the Environment Agency whether this proposal will require an Abstraction Licence.

Under the terms of the Water Resources Act 1991, an abstraction license will normally be required from the Environment Agency for the abstraction (removal) of water (even temporarily) from any inland waters (rivers, streams, ditches, lakes, etc.) or underground strata (e.g. from a well, borehole or catchpit).

We are not aware of any watercourses on the site, but should there be any, we advise that:

(1) they should not be culverted; and

(2) a buffer zone is left on either side of any watercourse, and

(3) culverted watercourses should not be built over, but should ideally be opened up and made a feature of the site.

In any case, you should note that culverting of a watercourse requires the prior written approval of the local authority under the terms of the Public Health Act 1936, and the prior written consent of the Environment Agency under the terms of the Land Drainage Act 1991/Water Resources Act 1991. The Agency seeks to avoid culverting, and its consent for such works will normally be withheld.

Advice to Applicant

Drainage from the wheel spinner should not discharge direct to the surface water system.

All sewage or trade effluent should be discharged to the foul sewer if available subject to the approval of Thames Water Utilities or its sewerage agent.

Only totally clean, inert, uncontaminated soils and spoils shall be permitted to be deposited at this site.

Any above ground oil storage tank(s) should be sited on an impervious base and surrounded by a suitable liquid tight bunded compound. No drainage outlet should be provided. The bunded area should be capable of containing 110% of the volume of the largest tank and all fill pipes, draw pipes and sight gauges should be enclosed within its curtilage. The vent pipe should be directed downwards into the bund. Guidelines are available from the Environment Agency.

Resident of Playhatch

We are writing to you regarding the Playhatch Quarry planning application and would like to lodge our strong objections to the proposed development.

We live at Newbury Cottage which is less than 150metres from the quarry. The grounds of our objection are as follows:

1. There is a fundamental objection in principle to such developments in open countryside, as implied in para 1.5 of the supporting statement included with the planning application by reference to local Planning policy W4. This in turn refers to such operations being allowed as an exception to general policy, and we submit therefore that the onus is on the developers to prove the need for the exception, not for objectors to disprove it. We do not believe that the applicants have discharged this obligation in this case.
2. The applicants suggest in para 4.1 of their statement that the subject site is not actually located in open countryside, because it is situated on the edge of Playhatch village and on the outskirts of Reading itself. One look at an OS map will quickly indicate what nonsense this is. There is currently clear open land between the edge of the Reading urban area and the subject site. Furthermore, it is precisely such open land which is close to existing development which needs to be most stoutly defended against further urban sprawl. To grant this application therefore, it is likely to encourage the very pressure for residential expansion in the Playhatch and Dunsden Green areas which, in the most recent issue of South Oxfordshire Outlook, South Oxfordshire District Council has indicated that it wishes to resist.
3. It is plain from the lengthy arguments produced by the applicants that this recycling plant is principally required to serve prospective development in the north and western parts of Reading and it is this fact which must be weighed against the impact of the plant on the village of Playhatch. In our opinion the applicants have consistently underestimated that impact and similarly over estimated the effectiveness of the amelioration measures they propose, in particular:

1. Noise – we can already hear the machinery presently operating in the quarry and in particular the vehicles when they are reversing. We, therefore, do not accept that noise from within the site during operating hours will be "imperceptible" as the applicant suggests. It seems to us self evident that any process which involves the unloading, tipping, crushing, handling and reloading of large amounts of heavy, hard material together with the use of heavy machinery and lorries will produce substantial noise and we do not believe that the topography of the site, even after the works proposed by the applicants, will be a sufficient baffle to this nuisance. Moreover it would appear from para 6.2.3 of the applicant’s statement that the site will be operating at least 10 hours per day and we fear that there will be times when activities will commence before 0800 and continue in the evenings and at weekends, because this has already happened.
2. A 10 mph speed limit is no answer to the problem, either within the site or through the village. Added to the sources of noise already referred to will be the noise from lorries reversing, tipping, turning and frequently changing gear. A speed limit is irrelevant as far as these activities are concerned. Likewise, a 10 mph speed limit through Playhatch is likely to aggravate the noise nuisance there, inasmuch as vehicles will be changing gear to enter or leave the village and travelling through in low gear with higher engine revs.
3. Traffic – this is also a considerable concern to us. Over the last 4 months we have noted the daily flow of quarry traffic and could only count 4 to 8 movements or so a day. The proposed increase is thus eight to tenfold. Dunsden Green Lane is not a suitable road to bear this amount of traffic, especially HGV traffic. It is narrow and there is no footpath or space for cyclists. It is no valid argument to say that the volume of traffic emanating from the site will be no greater than it has been in the past. Why should the residents of Playhatch be obliged to suffer a repeat of previous mistakes?
4. Dust – we are not convinced by the suggestion that spraying with water from a bowser will be sufficient to retain within the site the inevitable dust created by this process, especially given the inherent dust creating nature of the material being treated. This method being adopted seems to us crude and likely to prove ineffective.

We believe that this development will have an undesirable and deleterious impact on the village of Playhatch, which is not justified by the advantages it may provide for those involved in the proposed further expansion of Reading. We ask therefore that this application be refused by the planning authority.

Resident of Playhatch

Further to my recent telephone call, I am writing to you to express the grave concerns which my wife and I have regarding the proposed reopening of the Playhatch Quarry. These concerns, I know, are shared by the majority of the inhabitants in the village. We know from bitter personal experience how much disruption to our lives the reopening could cause unless restraints, restrictions and conditions are legally embodied in a successful planning consent.

Specifically, the problems which we experienced when the quarry was operating previously were as follows:

Traffic (Lorries)

The combination of speed, noise, frequency and mud on the roads was a continuous source of stress and anxiety. The road through the village is narrow in places and on many occasions lorries were obliged to mount the grass verge in front of my own house in order "to pass", leaving it disfigured and unsightly. Despite there having been no recorded accidents on this road they are certainly not unknown. The applicant proposes a maximum speed of 10 mph (page 13 6.2.7). I have some experience of lorries and their drivers and I am frankly sceptical that "covert monitoring" and a "sign on the gate" will ensure that the 10 mph will be observed.

Site Noise

When last operating site noise was a continuous intrusive drone punctuated by the sound of reversing warnings on the various site vehicles. For the applicant to describe the "sound of operations" as "likely to be imperceptible" (page 12 7.3a section 7) is quite wrong. The applicant further claims that "additional earth bunding has been provided to further dampen any noise on the eastern part of the site on the village side" (page 13 6.3.1). As I write this letter, on the village side of the site, the sound of an earth mover a digger and a soil screen together with continuous reversing warnings have been clearly audible all day (31/01/05) and this without the proposed use of the crusher and other screens. Indeed, rather than imperceptible noise level I am fearful that since the site is to be extended over more of the quarry floor (page 1 1.5) such an extension of operation will result in the use of more machinery and site vehicles resulting in an increase in the noise levels.

The applicant implies that the operation will take place in the bottom of the quarry, the sides of which will deaden the noise. This is misleading. A visit to the site today (to see what machinery was making the noise I referred to in the above paragraph), revealed large areas within the quarry on very high ground (where that machines that I could hear were working). What assurances will be given that the machinery will not work at these levels, the noise of which will be clearly heard as it is today?

Dust

Dependant on the wind direction, vehicles, laundry, windows etc were frequently covered in a film of dust causing irritation and a not inconsiderable amount of extra work.

Operating Hours

It was not uncommon for heavy lorries to arrive at the site as early as 4.30am and occasionally work would carry on late into the night. The lighting could be clearly seen. Weekend work was a matter of course. The prospect of a return to these practices causes us serious apprehension.

On the subject of weekend work, it would appear that the applicant’s own calculations confirm that it would not be necessary. A maximum annual tonnage of 100,000 is proposed. 20 lorries per day are proposed (page 12 6.2.3) averaging 20 tonnes each, making 400 tonnes per day. 5 working days per week equates to 260 days per year. 260x 400= 104,000 tonnes. In the light of the foregoing I submit that, if the application is granted, then the inclusion of a "no weekend working" condition could hardly be objected to by the applicant. I am at a loss to reconcile the applicant’s reference to the need for 30 lorries daily with the maximum 100,000 per annum. (Page 11 section 6.3).

I do not wish to be unreasonable in this matter and I realise that for us to prevent the applicant from succeeding is perhaps a little ambitious, after all we are few in number, but notwithstanding his many references to government policy", "codes of good practice", "need" and a "concern for the environment", the applicant is not doing this for altruistic reasons. He is doing it for the money!

My aim is to ensure that if permission is given then it is given subject to the conditions which protect the environment and the quality of life that the village inhabitants have become used to and have a right to expect. These conditions, which I list below, should preferably be embodied in a section 106 agreement.

It should be remembered that many of the village inhabitants are retired or housewives and mothers who will not be able to escape the persistent daily disruption that the operation will bring if strict conditions are not legally imposed.

Conditions

Traffic

A maximum of 20 lorries (40 movements) per day.

A monitored speed limit of 10 mph through the village both ways (monitored subject to scrutiny)

The road through the village to be kept free of mud.

The drains to be kept clear.

Operating hours

8 am to 5 pm Monday to Friday.

No weekend working (traffic/site) (see operating hours text above)

Noise

Noise levels to be kept to an "imperceptible level" (see section 7 page 12 7.3a planning application).

Dust

Water dampening machinery used to keep village free from dust.

It is also felt by many residents that permanent consent should be denied on the grounds that permanency might encourage complacency by the operator. I apologise if my comments are too lengthy but as you might imagine the matter is of considerable concern to us.

Resident of Playhatch

I wish to object to this application that will bring unnecessary impact on the amenity of Playhatch village.

I feel strongly that the following issues need to be considered by the County Council in determining this application.

• Need
• Permanency
• Vehicular trips
• Vehicular access
• Fly tipping
• Road sweeping and drain clearance
• Opening hours
• Noise attenuation
• Dust control
• Landscaping

Taking each of these points in turn:

Need

The applicants correctly refer to both Strategic Policy and National Government Guidance that identifies the need for increased capacity for recycling. Whilst this is a matter of fact I question whether such a facility is required at Playhatch. The applicants acknowledge the principal draw to the site will be from Reading. The greater part of the conurbation of Reading is to the south of the River Thames so a greater percentage of any catchment will be better served from Reading’s own facilities. If these facilities are at capacity and cannot be extended, more sequentially preferable locations should be identified to serve Reading’s catchment.

Reading is already well served by such facilities and with limited supply from Henley-on-Thames, the Ewelme facility should adequately serve Henley.

The applicants have not considered details of other suitable sites and have discounted the La Farge facilities at Sonning owing to "after use" implementation plans and commercial grounds as La Farge facilities are a direct competitor of the applicants.

The La Farge plant is better placed to accommodate a recycling facility which would significantly reduce the impact on Playhatch without overtly increasing amenity issues at Sonning Eye. The opportunity is available for both the applicants and La Farge to work together to find a commercial solution particularly as La Farge are currently seeking planning permission to quarry further land under their control.

Permanency

The planning history of the quarry shows that planning permissions have been granted on a temporary basis in order to enable the local authority and other interested parties to monitor the impact of the use of the site on Playhatch and the surrounding areas. I believe that it is very important that permanent planning permission is not granted as it will be difficult for any statutory authority to keep focus of the operators if they know the use of the site is of a permanent nature.

I am sure Hanson are a reputable operator, however we do not know if they have the ability to assign their lease hold interest, sub let the quarry or sub contract the use of the quarry to potentially less reputable operators!

The applicants have a lease hold interest in the quarry that expires in approximately 8 years time. If the County are minded to grant planning permission, such permission should be for a maximum of 5 years to keep the applicants focused.

Vehicular Trips

The applicants estimate the minimum trips to be 40 trips (20 loads) and a maximum of 60 trips (30 loads) per day. They concede the road through the village is narrow in some places. More recently an increase in on road parking from residents, their visitors and tradesmen narrows the road even further and increases pedestrian movements in to the road.

Whilst at the date of the application the applicants claim no accidents have been reported, we should bear in mind that there have been accidents on the road, one in fact around 4 years ago outside the Shoulder of Mutton Public House where both the police and ambulance services were called and on the evening of Friday 14 January / early morning Saturday 15 January 2005 there was been an incident outside numbers 1 and 2 Playhatch Cottages with smashed motor vehicle bodywork clearly visible on the highway.

The applicants have offered covert speed monitoring to ensure lorries approaching and leaving the site travel at 10 mph. Further details are required on how this will be monitored / enforced and the survey results need to be produced to a relevant authority such as the Parish Council at regular intervals. What recourse will there be if the 10 mph speed limit is continually exceeded? Particularity with lorries leaving the site empty and approaching the village travelling down hill I doubt the limit will be adhered to!

If the County were minded to grant planning permission there should be a restriction on vehicular movements below the minimum number sought by the applicants and a set speed limit if this comes under their jurisdiction.

Vehicular Access

The applicants have recently erected metal gates across the entrance to the quarry that are considered inappropriate for the rural setting of Playhatch in terms of style, scale and appearance.

These gates are also located in a position that prevents lorries from being able to turn off the public highway in the event that the quarry is closed. These gates need to be reduced in scale, painted a softer colour such as green and relocated further up the access road to a minimum distance that enables lorries to turn fully off the public highway and to be less intrusive.

Fly Tipping

The effect of moving the gates as noted above could enable fly tipping. This could be addressed by increasing security measures at the entrance of the site such as CCTV.

Road sweeping and drain clearance

Historically the use of the quarry has been linked to legal agreements providing for the lane through the village to be swept. Such legal provisions should be in place if this application is approved and include regular inspection and clearance of surface water / storm drains in the public highway, where the County Council know there is an inherent problem with flooding in heavy rain through blocked drains.

Opening Hours

The County Council should consider limiting the opening hours of the quarry and use of the recycling equipment to 9am until 4pm Monday to Friday and at no times on weekends and public holidays. This avoids peak traffic times when the network is busy and the school bus run is happening. Playhatch has no pavements so children and their guardians have to walk in the road.

These times will provide the village with some amenity at weekends and on bank holidays.

Noise attenuation and monitoring

The use of the quarry does create noise and such noise is audible from my property and across the village. Any permission should restrict the level of noise from the site to acceptable policy standards. This should include all recycling plant and equipment as well as audible vehicle reversing bleeps on vehicles using the site. The Council should control noise both legally and under any relevant planning permission.

Heavily laden lorries also cause "deep noise" and "rattling vibration" to my property as they drive past. Please note my property does not immediately adjoin the lane unlike some of my neighbours.

Dust Control

The use of the quarry does generate dust across the village. This is a fact and can be evidenced by paintwork, windows and motorcars getting dirty very quickly. The County Council should consider both legal and planning controls to eliminate dust generation. It is acknowledged by the applicants that they will use dampening methods to reduce the dust generation though we do need to ensure that they have a method statement to control dust generation, that the County Council can enforce against in the event of increasing dust levels.

Landscaping

It is acknowledged that the applicants have submitted a planting and management scheme for certain areas of the site. These proposals should include both sides of the access road in an attempt to tidy and improve the visual amenity to the entrance of the quarry.

I trust that the above is clear and that some weight will be put behind my comments when the application is considered by the County Council.

I hope that the Council will refuse planning permission.

If however, they are minded to grant planning permission, strict management of the site is required through enforceable planning conditions and legal obligations.

Resident of Playhatch

As a resident in Playhatch – where my house is right on the road, I request that you take these points into consideration when making a decision on whether to grant permission or otherwise

1 Why in Playhatch

2 There are no paths in the village – children walking

3 Mud on the road left by the lorries – need to be cleaned

4 Speed from lorries 10 mph. In the past the lorries using the quarry speeded down the road.

5 Open between 9 to 4-5pm

Please consider these matters in reaching your decision.

Resident of Playhatch

Further to our phone conversation regarding the application, this fax represents our written comments as follows.

Provided that Hanson continues to clean/sweep the roads along the B478 on a weekly basis, in order to remove dust and silt build up form their lorry movements, we have no objections to the application. Their consistency in having the sweeping completed regularly leaves a lot to be desired.

There is the need of course to restrict the type of materials that Hanson can recycle at the Playhatch facility to non-hazardous and inert.

Please advise of the process of this application as it proceeds.

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