Earlier today I spoke at the Wiltshire Council Strategic Planning Committee in Chippenham that was considering the application, by Hills Waste Solutions Limited, to expand the composting facility at Parkgate Farm and make the permission permanent (it is currently temporary).
My intention was to encourage the councillors to accept their officer’s recommendation to refuse the application, on grounds of unresolved issues of odour and transportation.
Because, for legal reasons, the Wiltshire Council was not able to determine the application sooner, it is already lodged to be adjudicated by Appeal.
The Inspector has called for written remarks (there is no public inquiry) by 28 January:
Ms Jennifer Saunders: teamp16@pins.gsi.gov.uk
Planning Inspectorate Ref: APP/Y3940/A/13/2210484/NWF
Non-Determination of Parkgate Farm Composting Facility
In addition to myself speaking, a representative of Cricklade Town Council also spoke to object, as did our unitary councillor Mrs Jacqui Lay.
Sadly, the Purton Parish Council was not present and had written a letter merely expressing “concern” about traffic to Mopes Lane. Merely expressing “concern” does not carry any weight these days, the only way to make that count is by an objection.
Fortunately, the Committee did resolve to refuse the application on the grounds of odour and transportation, however when the Inquiry is held the Inspector may note that the parish council did not object.
Whilst composting is nominally a good thing, on this occasion it comes with side effects.
Some key talking points that could be made to the Inspector:
Odour
There are unresolved issues concerning off-site odour. Although the applicant maintains, in its Statement of Case, that it has provided adequate information and reassurance on the matter of odour management, it remains the case that odour management has not been adequately addressed and still causes distress and concern within the parish.
Given the level of concern expressed by several people on separate occasions and given the nature of the waste it is quite clear that the perfunctory response by the applicant is insufficient. For instance, the applicant states: “the site is in excess of 500 m from any residents and therefore the Environment Agency does not require a site-specific risk assessment on bioaerosols”. It should be noted that there is a significant difference between odour and bioaerosol. The applicant also says that it has not received any substantiated complaints arising from the existing operations since opening. That is disingenuous. Complaints have been received by the applicant, the applicant chooses to dismiss them.
Guidance by the Department for Environment, Food and Rural Affairs “Good Practice and Regulatory Guidance on Composting and Odour Control for Local Authorities (2009)” advises that as part of a planning application, the planning authority should consider whether the development will give rise to undue harm to the amenity of local residents and that applications for plant undergoing significant redevelopment, that have the potential to cause off-site odour impact, should be supported by an evaluation of the expected odour impact. It also goes on to say that it is now “common and accepted practice” for planning applications for facilities such as a composting plant to be supported by detailed odour impact assessment based on computer modelling which predicts odour dispersion. This modelling should be based on local weather records and estimated predicted odour emissions. None of this has been provided and therefore the application does not comply with government guidance.
Transportation
There are transportation issues (namely damage to local roads as documented both in Transforming Purton Parish Foresight & Resilience 2013 and the Purton Parish Plan and the impact of hauling green waste long distances). There is no clarity concerning the origination of waste in the future. In a Legal Note from the Wiltshire Council Solicitor on 7 March 2012 (ref: Q 09:803) the legal position is noted such that an argument that the area for collection be limited to Swindon and environs is “…highly unlikely to be effective…”
So it is clear that if this application is approved then green waste from anywhere within or even outside the county could be hauled to the site in Purton. This would have implications for continuing road and verge damage, and greenhouse gas emissions which would work against Wiltshire Council’s targets for carbon reduction (in its Carbon Reduction Commitment).
It is of note that the Inspector when reporting the findings of the examination into the Waste Site Allocations Local Plan of Swindon Borough Council and Wiltshire Council noted the “… problematic nature of the links to the primary route network and that the [Purton] sites are not ideally located for strategic scale development…”. This is, indeed, the case. The only reason that there is a strategic site in the far north of the county, far removed from the main sources of waste generation, is simply a historical legacy. It was simpler to change an existing (unsuitable) site’s designation than to find a new, though more appropriate, location.
The Inspector also concluded that if further development was to be restricted to local scale only (which is more sustainable) this would run the risk of stifling the existing businesses. So, in essence, this unsustainable site is being protected, unreasonably, from market forces, and simply drawing in more green waste, from further and further afield, is not going to reverse that inherent lack of sustainability.
Replacing the Temporary Permission
There is a significant risk in approving a permanent permission. It was always the case that when the landfill was completed and restoration works finalised that the temporary bridge over the railway line would be removed. This is what the people of the Purton and the Parish Council at the time were advised.
During the succeeding years the landfill has been extended twice. The second extension required the proposition of a bridge over the railway line. That second extension led to a landfill designated as a hazardous waste site which was then later re-designated as a strategic hazardous waste site. We then had a proposal for a concrete-batching plant which was never implemented but, in hindsight, was merely a planning tactic to establish the general site as an industrial site. Consequently each small application for a particular activity is only incremental in terms of its impact. Taken as a whole, the impact of the facilities related to waste management at Mopes Lane has had a serious effect on the local roads and verges and on people and property along those roads due to noise and vibration.
In the early years, there has been a general acquiescence towards these planning applications because they were incremental. So it seemed that just a small extension would not be so bad and that anyway it would finish in a finite time. This has not been the case. The covenant between the applicant and the parish generally has been broken.
Each time, although it seems to be only an incremental change we should remember what the Inspector for the Waste Site Allocations Local Plan said: …. the [Purton] sites are not ideally located for strategic scale development. Even on first principles and the proximity principle it makes no sense to have a strategic hazardous waste site for the south west in the one location furthest from anywhere else in the SW region. It was simply easier to do. That is not sound spatial planning. That is serendipity.
In allowing the current temporary permission to be converted to a permanent one simply reinforces this serendipitous proposition. The applicant should take note that in accordance with paragraph 187 of the National Planning Policy Framework it should work with Wiltshire Council to look for solutions rather than present the authority with unsustainable problems.
Ever-expanding waste management facilities at Mopes Lane makes no economic sense to the tax payer, brings almost no local employment, increases the carbon burden of the Council, is prone to odour which affects the amenity locally, and damages roads and verges (again a taxpayer cost).
This application highlights the unsustainability of the waste management proposition at Mopes Lane, and in the interests of the Council and local people this application should be refused.
Please do email the inspector (details above) by 28 January 2014
