There are a number of issues arising from the Essex County Council and Southend-on-Sea Waste Local Plan including transport, noise and other environmental and health risks.
Today we present to you in layman’s terms what we consider a major flaw in the Waste Plan proposal.
Below are extracts from two reports. The first is taken from Essex County Council’s (ECC) Waste Plan, the second is an extract from the Co-Op’s response. Links to the full documents are provided at the end of this post and both documents are available in the ‘photos’ section of this Facebook page.
The regulations mentioned below are European-wide guidelines that prohibit the proximity of potentially hazardous waste to a minimum of 250 metres. The proposal would allow concrete crushing. The Health and Safety Executive are very clear on the dangers from the dust created in this process. Silica dust is life threatening and virtually invisible to the human eye, it can cause silicosis for which there is no cure. The waste being processed will come from demolished buildings and it is not possible for any waste disposal company to guarantee 100% that the waste does not include asbestos. This is why these types of waste disposal/processing sites are kept away from humans – described in the report as sensitive receptors.
250 metres is the recommended minimum distance for this reason.
Now this is where we get worried. ECC start by acknowledging this proximity regulation…then they go on to admit that they have chosen to ignore this regulation, and manipulate the figures, resulting in an Amber 3 instead of a Red score (red would likely stop the plan). This is how they’ve done it. Their report states;
“This number was used as a proxy to indicate the possible scale of the impacts from the waste use. The justification for each score is set out within the Site Assessment Proforma “Criterion 3D – Proximity to Sensitive receptors,
Morses Lane is calculated to be located within 250m of 145 sensitive receptors, resulting in a score of Amber 3 (101-200 properties). The numerical data for “Criterion 3D – Proximity to Sensitive Receptors” was compiled as part of a desk-top study based on the best available data. Several representations received during the Pre Submission Engagement (March 2016) highlighted the presence of a school nearby the proposed waste site. It is noted in the representations that there is no mention of the school under “Criterion 3D – Proximity to Sensitive Receptors” and therefore there is the potential that the school may not have been included in the assessment. However, even if the school was to be factored in to the assessment, due to the score being calculated using address points, this would not change the score from Amber 3 to Red”. (see full extract below)
So by applying this proxy they are saying that the regulation does not apply in this case.
Even more worrying they decided they would exclude the presence of the school and open fields in their findings…then they say even if they were to take account of the school they would only measure to the address (i.e the school’s front door) which is 250 metres away so it don’t matter anyway. What they have done is ignore the remarkably obvious fact that there are a school playground and fields approximately 85 metres away where 1,200 of our kids play.
So here are the first two main concerns:
1/ How can a proximity regulation such as this, which is in place to protect us, be manipulated to mean the exact opposite of what it says? It’s a bit like saying the 30 MPH speed limit actually means you can only drive above 30 MPH.
2/ How can the presence of a school playground and playing fields be omitted from a survey? Even if the ordnance survey maps on ECC’s website had failed to load on the day this was done, we now have google…even from standing on the roads, the playing fields and schools are not hidden from view. But even then… when they do acknowledge there is a school there, how can they have a measure that is designed to protect humans from contamination yet not take account of the playground and fields that would put kids at risk of exposure to hazardous materials and increase their risk of lung damage.
On this point of proximity we hope this is an oversight rather than a flagrant manipulation of regulations. Why ECC would propose this next to a school, supermarket and residential area is beyond comprehension.
Tomorrow, we begin our vigil, or ‘Lorry Spotting’. This week we will begin our objections to the planning office which we will need the whole town to get behind. We must act now. We hope to see as many of you as possible bright and early tomorrow at 9am at the corner of Samson’s Road for 30 minutes. If you can’t make it keep an eye out for updates and our template for objecting to the planning application, where we will be asking you to write to the Planning Office in Chelmsford. Thank you, Ray Hayden.
See below extract from ECC’s Replacement Waste Local Plan:
ESSEX COUNTY COUNCIL AND SOUTHEND ON SEA REPLACEMENT WASTE LOCAL PLAN
There are a variety of amenity issues which could be created as a result of a waste facility, including dust, noise and visual impacts. In an attempt to avoid or minimise such impacts, the site assessment methodology sought to locate new allocations at least 250m from land uses judged to be sensitive to such impacts, these are residential, medical and educational land uses. Where sensitive land uses were identified within this distance, they were combined to give an overall number of sensitive uses within 250m of the allocation. This number was used as a proxy to indicate the possible scale of the impacts from the waste use. The justification for each score is set out within the Site Assessment Proforma “Criterion 3D – Proximity to Sensitive Receptors”.
Morses Lane is calculated to be located within 250m of 145 sensitive receptors, resulting in a score of Amber 3 (101-200 properties). The numerical data for “Criterion 3D – Proximity to Sensitive Receptors” was compiled as part of a desk-top study based on the best available data. Several representations received during the Pre Submission Engagement (March 2016) highlighted the presence of a school nearby the proposed waste site. It is noted in the representations that there is no mention of the school under “Criterion 3D – Proximity to Sensitive Receptors” and therefore there is the potential that the school may not have been included in the assessment. However, even if the school was to be factored in to the assessment, due to the score being calculated using address points, this would not change the score from Amber 3 to Red. It is additionally noted that this omission does not limit the potential for the specific needs of a particular sensitive use to be acknowledged, and this would be expected at the planning application stage. Further, and as set out in para 2.20 and 2.21 of the Site Assessment, Methodology and Selection Report (SD-16), the desk-top information was subject to site visits to validate and inform judgements.
This is an extract from the Co-op’s response:
We have previously highlighted in our representations that the school playing field, which is located within the school grounds and south of the site, is located approximately 85m from the site. Contrary to this, the text within the site assessment proforma states that there is no informal open space within 100m of the site notwithstanding judgement guidance which specifically states that open spaces include school grounds and playing fields. In this context, it would appear that the site assessment proforma has wrongly assessed this issue, which should, given the proximity of the allocation to an open space, be assessed with an “Amber 2” score.
We would also like to raise a significant concern in relation to the proximity of the proposed allocation to a number of sensitive receptors. It is acknowledged within the site assessment proforma, that the site is located within 250m of 145 sensitive receptors. This is contrary to the recommendation for all waste facilities to be located at least 250m from sensitive receptors.
Whilst it is recognised that the proximity of the site to this significant quantity of sensitive receptors has been recognised, it is perceived that this concern has not been properly recognised in the scoring process, given that the site has been given an “Amber 3” score and has therefore been given insufficient consideration, especially given the proximity of the site allocation to an existing retail store, large residential catchment and school site. It is recommended that the score is amended as a “red” score rating to properly reflect this issue.