Response 674657010

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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)
The proposed activities at this site should be refused a permit because they are contrary to planning policies and adversely affect the local environment and residential neighbours: Location Noisy and potentially polluting activities such as handling asbestos, household and institutional (hospital?) waste as well as CDW concrete crushing, screening, and HGV lorry movements for 15 hrs a day six days a week and potentially for 363 days a year are unacceptable in a semi rural location that is adjacent to ecologically designated sites, SPA, RAMSAR, Marine Conservation Zone (the Swale estuary since 2016), SSSI and nature reserves. I note that the Iceni ecology report dated March 2018 makes no mention of the water voles that live in the ditches on adjacent Ham marshes and on Oare marshes; refer to Kent Wildlife Trust for work being done to conserve the water vole population along the North Kent marshes. The walkover part of the survey from the previous year concentrates on the site itself and so took place after EKR had levelled and hard-filled the southern area and had increased the activity on the waste-handling site so it is hardly surprising that they report no badgers, bats or habitats now worth preserving within its boundary. The area is becoming more residential with new houses being built adjacent the site at the old gravel works. I note that at least two of the supporting documents from Waterman are out-of-date on this. They refer to the site environs/surroundings as including the Brett gravel works, and so imply that the environs are industrial. This is no longer true as Andersons have commenced house building on that old gravel works, which will be entirely residential and leisure with a new country park immediately adjoining this site. This makes open air dirty industrial activities even more inappropriate. Air pollution There are dust emanations from the site that have been reported to KCC; this will only increase with the proposed increased activity including a concrete crusher. Waterman refer to this as low probability, but it already happens and therefore to us it is of high probability. How reliable are the proposed management features? (A query that pertains to all the proposals to control pollutants and noise) Will there be continuous monitoring of the dust at the boundaries of the site? The proposed increase in lorry movements will increase exhaust emissions within the site and in the locality. There are residential properties and a primary school in the vicinity where the public will be at risk of adverse lung effects. Flood The site is in a EA zone 3 flood risk area. There have been inundations from the sea over the seawall at intervals and this is likely to be an increasing occurrence as sea levels rise and storm events more severe as a result of global warming. The type of waste to be handled might expand to include asbestos, green and domestic waste. Can this be reliably contained within the site when the next inundation happens? If not, unknown pollutants will spread over the surrounding land and into local lakes and water courses and finally into the creek and the Swale. The Waterman risk assessment acknowledges flood as a medium risk but seems to bet on it being an infrequent event. Should that bet be allowed given the ecologically sensitive nature of the surroundings and the increasingly residential hinterland? Even when there is no inundation can the system of filtration proposed to handle rainwater overspill be guaranteed not to release pollutants? Rainfall is becoming more concentrated in bursts that produce a lot of rain in a short time. Will there be continuous monitoring of run-off at all times? The access road to the site runs along the top of the seawall. Sea flood defences are the responsibility of the EA. Has the EA assessed the damage likely to be caused to those defences by increased heavy vehicle traffic? Should there be a limit on weight or frequency? Noise Local residents are affected by noise. We in Church Rd Oare to the west of the site have complained to the EA since 2014 and to SBC about the intrusive noise from present operations. Extending lorry movement hours to between 5am and 8pm at least 6 days a week (though only 6pm on Saturdays), adding a concrete crusher and screener will increase the disturbance we already experience and is not compatible with the primarily residential nature of the area. It will only take a couple of reversing beepers at 5 in the morning to wake us up. Despite Waterman assessing this as low risk, it patently is already a real and continuing actual occurrence and will become more intrusive if more lorries are allowed. The way noise is experienced is not through lists of numbers but as what one hears in reality; this is already at a level causing disturbance and therefore loss of amenity. It disturbs our early morning sleep, harms our enjoyment of our rural location and consequently harm health and well-being, along with that of our neighbours in Church Rd Oare and others in the locality. These are heavy duty lorries often with trailers and they make significant noise along the access road and with reversing beepers in the site. The number of HGV’s will significantly increase if the switch from LGV’s to HGV’s is allowed. Vehicles currently using the site include HGV’s with trailers carrying 5 or 6 skips at once. Not all the vehicles are owned by EKR and cannot be guaranteed to comply with noise reducing requirements. Proposed mitigation measures do not include complete enclosure of the operation, no raised bund and no other acoustic dampening. The extended hours will increase the use of lighting as well as noise on the site, such that the tranquillity of the area will be made worse, contrary to the aim set out in SBC Local Plan para 7. In the background to this there is the local lack of confidence that the site will be operated fully in accordance with any conditions imposed by the EA, there being history with EKR on this, or that the EA has the resources to properly police activities. The risks are too high for this sensitive locality.