Comments on KCC/SW/0247/2017

Redevelopment of an existing waste management facility and inclusion of additional land into waste management use.

It is noted that this proposal seeks to increase the intensity of the existing waste transfer facility which was established in 1992 on the Faversham side of Oare Creek. This is in connection with the intended closure of an existing waste transfer station at Aylesham and consolidation onto a single site. The proposal involves the replacement of the existing buildings with taller and more extensive buildings, additional equipment including a crusher, conveyor, metal containers and stacked materials, extended storage area, night watchmen, weighbridges and more parking together with extended hours and a doubling of the number of lorries servicing the site. The planning application  is supported by site plans, elevations of the buildings and equipment individually but not in context and reports on traffic generation, noise, a visual appraisal and studies on wintering birds and on the impact on the adjacent RAMSAR site.

Noise

The noise appraisal seeks to demonstrate that there is no harmful or even significant increase in noise levels emanating from the site as a result of the new buildings and greater area over which waste is treated. This is because some of the noisy machinery is enclosed in buildings and the site would be enclosed to the south by noise absorbent bunds. However, the noisiest item, the crusher, is at the unenclosed area of the site and is expected to run for periods of two weeks out of every six weeks. The site is already relatively close to residential areas in Oare to the south of Pheasant Barn which is identified as the nearest residential property and the measuring point for noise. The new residential development at Oare Lakes starts at 250m from the site which is substantially closer than the houses in Oare. This is also used as a measuring point for noise impact. At present the hours of operation are 0700-1800 on Mondays to Fridays and from 0700-1300 on Saturdays. This represents a 13-hour day on weekdays. The proposal includes the prospect, with the approval of KCC, of working on Sundays after Bank Holidays, Bank Holidays and Boxing Day working. These are all days when residents and potential residents would normally expect the site to be quiet and as such, this element of the proposal represents a substantial intrusion into residential amenity and the relative quiet of the area for walkers and other users. Further, it is proposed that the hours of operation for the lorries would be extended to run from 0500-2000 daily and 0500-1500 on Saturdays and to include Bank Holidays. These extra hours and days are also periods when it is usually expected to be much quieter than business hours and would intrude on the amenity of the area both for residents and outdoor users.

Appearance/Context

The existing facility with the exception of some partly used buildings is relatively low in height. It has been used since 1992 for waste transfer and previously there were other industrial uses around Oare Creek including loading cargoes and the explosives industry. The areas around Oare and Ham Marshes have been used for gravel working but are expected to be restored and new housing added on the Oare Lakes site. The footpaths, marshes and lagoons form part of a countryside buffer zone between Oare and Faversham. Close by and directly adjacent to the roadway serving East Kent Recycling are areas protected for wildlife comprising the SPA which is also a RAMSAR site. The erection of three large-footprint buildings at 20, 25 and 30m long with two over 7.5m high and one at 12m high represent a much more visible and extensive built development which would be more prominent in views from Oare village including from the footpaths near the playing field, from Church Road across the creek, from Ham Marshes and across Oare Creek on the Saxon Shore Way as well as from the footpath across the lagoons adjacent to the site. The footpath adjacent to the site which runs along the service road is already at least a moderately sensitive use but would become a highly sensitive use when it becomes part of the England Coast Path. It is considered that for these reasons, the erection of more extensive and high buildings on this site would be an unwelcome development and would contravene the aims of the Swale Landscape Character and Biodiversity Appraisal.

Dust and other air pollution issues

In addition to the dust and diesel particulates associated with the increased traffic flows there are likely to be dust and other air pollution issues arising from the increased scale of operations. The marsh is a windy area and dust, and other airborne pollutants are likely to spread over a considerable distance on the wind. The prevailing winds are onshore and will carry airborne pollution to residential areas. An air quality  monitoring system should be put in place to ensure that there is  objective evidence on the emissions.

Conflict between traffic and the footpath

It is proposed to increase the number of vehicles from the present 80 per day (40 in and 40 out) to 160 per day (80 in and 80 out) In peak hours this would amount to 16 vehicles per hour. The hours would be extended in the mornings to 0500 from 0700 but also in the evening from 1800 to 2000 and from 1300-1500 on Saturday afternoons. In addition, Bank Holiday working including potentially on Boxing Day and some Sunday afternoons would be introduced. This means that not only would there be more vehicles at all the times the plant has been working up to now, but the road will be used for much more of the time when the public would want to use it as a footpath. The Traffic Appraisal refers to employees being able to access the works on foot or by cycle although there is no pavement but takes no account of the use of this roadway as a public footpath. Throughout the documents it is assumed that the footpath runs on another parallel line and not on the road but the map extract that they provide shows that this line runs through the water of the lagoon. The roadway is enclosed on the lagoon side by barbed wire fencing with very narrow grass strips in places. There are only three lorry passing places and these are more likely to be needed by passing lorries if there are 16 per hour. The creekside is open with no fencing and a drop onto either mud or water depending on the state of the tide with only approximately 450mm of bank which is sometimes muddy in winter. This means that a substantial increase in vehicles would make a walk along the footpath unpleasant and potentially dangerous.  Most vehicles would be skip lorries or rigid vehicles and these tend to have come from sites elsewhere so throw up dust. The trees along this road are already covered in dust and water sprayers also pass up and down to suppress dust on the road but make passage less pleasant for walkers. It is considered that the increase in the intensity of the waste transfer use on the site is not compatible with use of the roadway as a nationally designated public footpath such as the England Coast Path and this is the only route from the Oare Stray stretch of the footpath to the head of Oare Creek.

While the proposal would comply with KCC policies CSW2  (enhances the county’s ability to process waste) and CSW16 (is an extension of an existing waste transfer site) of the Kent Minerals and Waste Local Plan,  with regard to policy CSW8, any extra vehicles have to pass through a road which is in an Air Quality Monitoring Area, so the site would not be particularly well-located with regard to sourcing and sending out materials. The advantages of extending the site to take in the activities from Aylesham are outweighed by environmental costs which demonstrate why this would not be a suitable site to extend.

The Society is concerned that this development reverses the whole thrust of planning policy for this area over the last twenty years which has been toward conservation and leisure use. This sets a dangerous precedent for industrial development whilst creating very few new jobs and jeopardising residential quality. We are concerned that there is already some evidence that vehicle movement numbers have been exceeded and obviously all vehicle movements must affect either Ospringe or Teynham and the village of Oare.