Response 624586675

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Seeking your views

4. Please provide your comments on the environmental permit application received from East Kent Recycling Limited

Please provide your comments on the environmental permit application received from East Kent Recycling Limited (Required)
ME13 7TX, East Kent Recycling Limited, EPR/AB3108XA/V002 environmental permit consultation A) My comments In summary - The planning application being considered for this site under KCC/SW/0090/2018 has met very significant objections. The Environmental Permit (EP) does not include a full noise assessment or the Waterman’s appendix G on air quality, which showed that levels of NO2 along the A2 exceeded the level to “Protect Human Health” and the planning proposals would have an adverse impact. It seems inappropriate to now be asked for comments on an application for an EP, when key mitigation elements mentioned in the EP may not gain planning permission. I do not believe that harm to the environment, people and wildlife has be minimised or that the operator has the ability to meet the conditions of the permit for the following reasons:- The EP seeks an increase in treatments of waste (notably mechanical sorting and crushing), extending the hours of operation, increasing the overall area and increasing the types of waste but there is no defined annual tonnage (although there is mention of 45,000 tons). To minimise harm to the surrounding sensitive environment the scale of operations that may be permitted needs to be clearly stated. i) Noise mitigation As there is significant doubt that the planning permission being considered will be approved the Materials Recycling Facility (MRF) may not be built but there is no mention of alternative mitigation measures to those given by the MRF. The EP application lists a number of activities to be operated in the MRF so clearly large building(s) are needed if the EP is granted. In the planning application the proposed MRF is a very tall 12m building and a building of this scale seems inappropriate for the area. The crushing of concrete, by a bucket attachment, will of course be very noisy and totally inappropriate in this rural/residential area. The noise mitigation measures proposed are not sufficient. To seek permission for additional hours of operations, under exceptional circumstances, does not minimise harm to the local area. Exceptional circumstances can’t be defined and it could be stated that all sorts of circumstances are exceptional which would lead to a 7 day a week operation. The residential areas need to be certain that no operations would occur on a Sunday or public holidays. There are pages and pages of material in the July 2018 Environmental Risk Assessment However, the significant noise risk is not adequately dealt with. To simply list the noise probability as low, where noise assessments have already been undertaken showing significant adverse impacts, does not represent the true picture. Noise impact assessments have been undertaken for various planning applications which showed that similar operations would have a major adverse impact. According to the Non-technical summary the aim is to modernise permit conditions. However, there is no mention of vehicle movements or their size, hence the full picture of the local noise and pollution can’t be gauged. I would have thought that a modern EP should include this for clarity. The total tonnage is suggested so it must be easy to include a daily limit for movements and tonnage. ii) Management and capability The flood plan has not yet been put in place even though the July 2018 Environmental Risk Assessments classed the risk as high. Given the site’s history and of course the applicant’s relevant offence where the environment manager stated that “Ky Campion had a blatant disregard for the environment” trust that the site is/would be operated within its permissions is sceptical. There would be more confidence that the site would be operated properly if the appropriate qualifications were already held. Granting a grace period to obtain a relevant qualifications seems the wrong way around. iii) Missing information The impact of operations on the new residential areas currently being built and planned has not been properly considered (see photo of a sign showing further land acquired for residential development which is on the road where the 20 m.p.h limit is suggested). To expand the actual area of the EP and to operate the additional activities of crushing concrete and screening of concrete simply should not be permitted without an appropriate noise assessment for the new residential areas. To state that the probability to noise exposure from crushing and screening activities is a “low probability due to risk management” where the only mitigation is an existing acoustic bund and restricted operating hours (and these hours can be extended under exceptional circumstances) shows a disregard for the rural area, the current residents and the residents of the new housing developments. I farm in an environmentally sensitive way in liaison with Natural England. This involves grazing marshes and keeping some marshes free of sheep in the winter months to minimise noise disturbance to winter nesting birds. The farm borders the Oare Nature Reserve and I can hear noise from the existing site when some lorries are unloaded. This noise is occasional whereas a crushing and screening type activity could be all day. Professional background noise readings from a previous planning application show that there is low background noise so the crushing and screening activities are likely to have a significant impact irrespective of the mitigation measures. B) Clarity and Enforcement Potential difficulties that The Environment Agency may have over monitoring the site need to be avoided. The EP being applied for does not provide sufficient clarity. We need to recycle but any process needs to be well controlled and inspected. This is a significant increase in buildings and noisy activities close to a SSSI, Nature Reserve and an increasing residential area so we must be satisfied that operations are appropriate for the area and can be controlled. The spotlight is on this site and the local population will now rightly expect it to be controlled under existing permissions and any new permissions. It is good to hear that the MP has taken an interest in this site and many others now have interest in the site’s activities. It is essential to have clarity over any new permissions granted so that breaches can be reported and enforced. Clarity is needed for - • Noise mitigation measures should planning permission for the MRF not be approved • A professional review on noise from the crushing and screening activity to establish the noise levels expected • Activities outside normal operational hours with the loophole of activities “in exceptional circumstances” being closed • Enforceable speed limit of 20 m.p.h. should be for all vehicles rather than only the applicants own fleet • Total tonnage to be set rather than being left vague at “content to accept 45,000 tons per year” • A daily limit on vehicles movements carrying waste C) My conclusion The EP application in its current form should not be granted as:- • Clarity is required and needs to be documented for items mentioned above • All policies needed should be put into operation for use with the current permissions and new qualifications acquired The EP should not be granted as the changes applied for seem like it will change the existing operations into a heavy industrial type activities which is inappropriate as the site will be surrounded by residential areas, SSSI and farmland.