TOWN AND COUNTRY PLANNING ACT
1990 (as amended)
SITE: Energy Recovery
Centre, Channel Gate Road, Park Royal, NW10 6UQ
PROPOSAL: Construction of an energy
recovery centre comprising a single purpose designed building to provide an
advanced conversion technology facility and an anaerobic digestion facility
with an integrated education/visitors centre and four 25-metre high flues; gas
holder tank; emergency gas flare; electrical substation; two weigh bridges;
wheel washing aparatus and a security house building.
Further to the consultation
letter from Ealing Council regarding the Full Planning Application Ref. PP/2012/3267
at Channel Gate Road, Park Royal, Brent Council have the following comments:
On 23 October 2012, Ealing Council formally notified
Brent that the applicant is seeking to increase the volume of waste the site
processes from 148,000 tonnes per annum (tpa) to 195, 000 tpa, indicating that
they are formally re-consulting on those proposed changes. For clarity, the comments
below relate to the original proposal only, and Brent Council reserves the
right to comment further.
Principle
1.
Brent
recognise the need in the London Plan and strategic terms for well designed and
located proposals to promote sustainable waste and recovery development.
However, we have significant concerns
about the location of the development and the potential negative impacts of
aspects of the proposal in terms of environmental and transport impact on Brent
and it’s residents and the strategic policy context.
Strategic Policy Context
2.
The
site is situated in the London Borough of Ealing across the West Coast Main Line
from Brent so the planning application will be determined by the London Borough
of Ealing. However, a material consideration in determining the application is
the draft West London Waste Plan, Feb. 2011 (WLWP), jointly prepared on behalf
of the six West London boroughs which comprise the West London Waste Authority
which includes both Brent and Ealing.
3.
WLWP
Policy 1 is concerned with the location of waste development. This states that
“…Waste development on other sites not listed in Tables 4.1 and 4.2 may be
permitted if the proposals comply with the other WLWP policies and the
Borough’s Local Development Framework, and:
·
It
can be demonstrated that the development is not suitable for any Sites listed
in Tables 4.1 and 4.2; and
·
For
some reason, identified Sites have not come forward and it can be demonstrated
there is emerging shortfall in capacity…”
4.
The
site of the proposal is not listed in tables 4.1 or in 4.2. Consequently,
unless it can be demonstrated that other sites identified are not suitable then
the application should be refused. The
Planning Statement submitted by the applicants affords the draft Waste Plan
little weight. However, the fact remains
that what are considered to be better sites have been identified and the Plan
has been through rigorous public consultation and has been amended accordingly,
although yet to be adopted. Brent’s view is that the draft Plan is not at an
early stage, as suggested, and has sufficient rigour to be considered as a
significant material consideration and an appropriate guide for waste
management development proposals and should not be undermined at this late
stage. There is substantial opposition from local residents and others to this
proposal whereas the sites identified in the draft waste plan have been subject
to rigorous consultation, and a decision has been taken by all the boroughs
involved, including Ealing to submit the Plan.
5. The applicants also suggest that, in
drawing up the WLWP, the freightliner site was not assessed properly as part of
a Stage 1 assessment and that if the assessment was undertaken now it
could be identified as a shortlisted future waste management site. This
is an assertion that has not been tested and it is likely that, because of the
proximity of residential properties and the nature of the vehicular access
through the residential area, the site would still score poorly on the
“proximity to residential areas” and “vehicle routing” criteria.
Environmental
Implications
6.
The
Council’s Environmental Health officers have examined and reviewed the
statements submitted in support of the proposed development. The site is
located on the south west border of Brent. The nearest residential properties
within Brent are those based on Harley Road between 150-200m north/north west
of the proposed facility, which is down wind of the site under prevailing
weather conditions. As such the operation of the proposed facility is likely to
have an impact on Brent residents in terms of air quality, odours, operational
noise and site traffic.
Air
Quality
7.
There
are specific concerns with the modelling of the impact of both the stacks and
the traffic on air quality in the local area along with more general concerns
with the assumptions that are made in the assessements. In general the models
fail to make use of localised data sets and instated use estimates which show
current air quality levels to be better than the existing.
8.
The modelling in relation to the impact of Nitrogen Dioxide
emissions from the stacks appears to be on a best-case scenario rather than the
worst-case scenario that would normally be used. Brent does not accept that the
air quality assessment has demonstrated that the processes will have an
acceptable impact on the local environment for Brent residents particularly in
relation to this pollutant.
9.
The
model used to show the potential impact of projected traffic levels on air
quality uses a very high adjustment factor which suggests that the model inputs
maybe flawed. This fails to suitably demonstrate that projected traffic
movements of HGV and refuse vehicles to and from the facility will not have a
detrimental impact on local air quality.
Odour
10. The main building containing the
auto-claving, pyrolisis chambers and combustion tanks will only have an
acceptable impact on odours if the measures for controlling the odours
suggested in the assessement are implemented along with the appropriate contingency
measures prior to the operation of any part of the process.
11. However, the anaerobic digestion
facility has not been sufficiently assessed within the odour control section
and as such Brent’s environmental specialist is not convinced that the measures
to control odours from this will be sufficient. We would, therefore, object to
the proposal on the grounds that it has not been sufficiently demonstrated that
the proposed development would have an acceptable impact on Brent residents in
terms of odours emitted.
Noise
12. In terms of noise impact Brent are
concerned that the noise assessment does not provide adequate measures to
guarantee that there will be no detrimental impact on Brent residents in the
local area and particularly on Harley Road. The noise assessment suggests that
an acceptable impact on Brent residents is feasible but does not guarantee it. An
objection is therefore raised to the proposed energy recovery centre on the
grounds that it has not been demonstrated that the proposal will have an acceptable
impact in terms of noise and disturbance for Brent residents.
Highways
13. Brent’s Highway Engineer is currently
assessing the transport information on the proposed development. Further
comment on this will be provided in due course.
Conclusion
14. If Ealing go forward with presenting
the proposal to the planning committee Brent will object strongly to the
proposals until satsifactory information has been provided to enable an
accurate assessment of the implications of the proposal on the Borough of Brent
and its residents.
15. As explained above, Ealing officers
have formally notified Brent that the applicant is seeking to increase volume
of waste the site processes from 148 000 tonnes per annum (tpa) to 195 000 tpa.
The above comments relate to the original proposal. This amendment will
significantly increase the potential impact on Brent residents. We would ask
that an additional re-consultation exercise should be undertaken to notify all local
residents of the changes and to allow for additional time to review and comment
on the implications of the increase.
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