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Alan Stones
Planning Development Control Team Manager
Surrey County Council
County Hall
Penrhyn Road
Kingston-upon-Thames
Surrey KT1 2DY

Date


Dear Sir,

Planning Application SCC/09/1275
Proposed Development of a Composting and
Dry Recycling Facility at Runfold South Quarry, Farnham
 


I wish to object to this Planning Application for the following reasons:


1. Compatibility with Planning Policy

 The site for this very large industrial construction, the largest by far of its type in the UK, lies within an Area of Great Landscape Value as defined by the Waverley Borough Council Local Area Plan, and is subject to Policy C3 of that Plan which states that ‘Strong protection will be given to ensure the conservation and enhancement of landscape character.’

It can not be feasible that construction of this industrial plant could possibly comply with this policy. In addition in acknowledgment of the fact that this area of South Runfold has been damaged by the quarrying and land fill operations undertaken, the Waverley BC Local Plan defines the area as being an Area for Landscape Enhancement and subject to Policy C6 of that Plan which states that ‘This will be achieved through the control of development and ,subject to finance, the preparation of improvement schemes to be implemented’

I consider that there is a direct conflict between this Policy and the proposed development, which nobody could consider to be an improvement to the landscape. Also under the Surrey CC Minerals Plan this whole site must be fully restored to AGLV status by the end of 2021.


2. Need for the Facility
 SITA say in their Application that there is a pressing need for this facility to service the needs for recycling of food and green waste principally from
Surrey arisings. However, Surrey CC in their most recent reports state that the municipal food waste collection for the whole of Surrey (which will rise to a maximum of 40,000 t per annum by 2013) will be catered for in a Surrey CC sponsored Anaerobic Digester plant to be constructed at Shepperton.

The amount of non municipal food waste which might be collected in the future has also been assessed by Surrey CC and will be less than 20,000 tpa. Where then is the SITA stated demand from Surrey to provide 60,000 tpa of food waste especially given that Planning Approval has recently been given for the construction of a recycling facility at Wisley? All of Surrey’s green waste already goes to recycling plants. There is therefore no need for this plant to be built. 

3. Visual Impact
The construction envisaged is by any standard very large with a footprint of the buildings and maturation bays of some 15,000 sq.m. Some of the buildings are also tall, rising to 13.5m with an emissions stack rising to 18m. It is difficult from the information provided in the Application to get a sense of the impact of these structures on the landscape as no photographic mock up is provided but one would imagine that from Guildford Road and Rock House Lane they would be a visible intrusion.

4. Air Quality, Odour and Health Risks

With the planned throughput of 120,000 t per annum of compostable material (around half of which will be kitchen/catering waste and therefore not fresh) there is clearly a significant risk from the creation during receival, preparation, processing, maturation and recovery of airborne bacteria and fungi and associated chemicals some of which will be toxic and may be in harmful concentrations. There will also of course be bad odours associated with these bioaerosols. 

The proximity of this planned facility to residential property, the Princess Royal Hotel and Barfield School, all less than less than 250 metres away must be a real concern to everyone. In addition the emission of some of these bioaersols from the 18metre stacks may Ill result in these problems being spread over a wide area of east and south Farnham. As no IVC plant approaching this size has been built in the UK it is difficult to see how SITA can in good faith suggest that these issues are properly understood. 

5. Noise
As most of the activities associated with this facility will be held within the buildings, it is expected that problems of noise will be limited. Two areas hoIver concern us. The first, Reversing Alarms, is referred to in the Application but I would stress that from my experience with the operation of the SITA site over many years this noise can be very Iaring and in this case it appears that all arriving trucks will be reversed to deposit their loads. Secondly, and not referred to in the Application, is the noise which will be associated with the dumping and processing of dry recyclable materials which will include glass.

The noise generated by the movement and processing of glass and some other dry materials can be very severe but this does not seem to be addressed in the Application despite the fact that the facility is designed to receive up to 20,000 t per annum of dry waste.

6. Flies and Vermin
Fly and vermin infestations have been a regular feature of the SITA landfill operations at Runfold, especially during the summer months,over a number of years. There is good reason to believe that this composting factory will inevitably attract flies and vermin given the nature of the large amounts of kitchen/catering waste and I do not see much reference in the Application on the mitigation measures which would be taken. 

7. Supposed Temporary Nature of The Facility 
It is noted that the Application refers to the construction of this very large project as being ‘Temporary’. Given the size, complexity and cost of construction of this facility I believe that SITA are being disingenuous in this statement. SITA have a long history of obtaining Planning Approval on sites with agreed end dates for withdrawal but then once approval has been given to then seek and obtain extensions.

A good example of this is Area B at South Runfold where Planning Approval was granted in 1996 with the condition to cease operations by the end of 2004; this was extended on Application to the end of 2008 and further extended earlier this year to the end of 2011.

I therefore simply do not believe that once this facility is built it will be dismantled after seven or eight years. I believe that SITA may consider their application to be more likely of success by calling it ‘temporary’ but it should not be vieId as such.

8. Traffic Movements
I am very concerned by and strongly object to the prospect of the local roads continuing to be battered by HGV’s serving the South Runfold site. Indeed there will be a net significant increase in HGV traffic as the sand extraction and fill operations will continue till at least 2016 and the IVC traffic will be in addition to this.

Also for the first time, there will be significant waste deliveries along Crooksbury Road. This road is narrow, has crests and dips, has no footways to speak of and has difficult junctions at a number of points including Sands Road, Compton Way and Botany Hill/Camp Hill where there is a long history of accidents. The proposed use of this route is a recipe for disaster.

Farnham already has major traffic problems and the proposals will impose additional and unreasonable burdens on traffic movements around the Shepherd and Flock roundabout and on the route from the A31 via St Georges Road and Guildford Road. There will also be real safety issues associated with this increase in HGV movements as Ill as airborne emissions which Farnham cannot accommodate.

The roads around  Runfold are almost always filthy, damaged and full of HGV’s coming and going to the South Runfold Quarry. It had been hoped to eventually see an end to this blight and risk to life and limb. Acceptance of this Planning Application would destroy that hope.

Overall I am deeply opposed to this Application which is at odds with Planning Policies, very damaging to the local environment, unreasonable and potentially threatening to the health and weIl-being of residents in the area and particularly to Barfield School. I can not believe that our Surrey County Council Officers and Councillors would wish to sanction this development which would have such an adverse effect on this area and its people when there is no need for this plant to be built to serve the needs of Surrey.

 

Yours faithfully