Scoping Opinion on the Environmental Impact Assessment or the restoration of the existing Hegdale Quarry and associated land by means of a proposed landfill and associated infrastructure at Hegdale Quarry, Challock, ME13 OJX (Reference No: KCC/SCO/AS/0100/2017

 

Challock Parish Council’s comments on the Scoping Opinion on the Environmental Impact Statement for the restoration of the existing Hegdale Quarry are as follows:

 

Hegdale Quarry is tucked away just off the A251 to reach it using the bridle/footpath.  Hedgale Quarry is surrounded by an ancient woodland and agricultural animal farming fields and nestled in the rolling hills, an area of outstanding natural beauty; a walker’s paradise.  In the vicinity are 8 grade 11 listed country homes. The quarry itself is deeper at one end and not a substantial hole.  The current operation is small with 4 to 5 Lorries attending the site daily. 

 

Challock Parish Council’s main concerns regarding the Environmental Impact Assessment are as follows:

 

Water. Hegdale quarry occupies a site covered by three categories of SPZs – 1, 2 and 3 - and is subject to flooding at or near the SPZ 1 and SPZ 2. The scoping report relies on Southern Water’s statement that it does not use the nearby Beacon Hill borehole because it produces sand. The hydrogeological survey reports that led Southern Water to sink the borehole are not provided or referenced in the report. This omission is both significant and important: our own investigations (limited at this stage) reveal that a number of properties near to Hegdale have their own private water supplies and that the Beacon Hill borehole does indeed produce water but that contains sand. The scoping report implies that it produces only sand.

 

No planning application should be submitted without comprehensive information on water. The North Down aquifer supplies 75% of Kent’s water (Kent Mineral and Waste Local Plan, 2016) and any compromise to water quality will have important (and costly) consequences. Pressure on water use is likely to increase as a result of population growth, expected to be 1.4 million over the next decade, and climate change which will render east Kent a drier region.

 

The scoping report is, indeed, narrows in its focus and relies on superficial evidence from a commercial company on the viability of Beacon Hill.

 

According to North Downs AONB (2014) population increase and climate change will result in quality and quantity of water becoming a critical issue. ‘Not only will these factors have a profound effect on Kent’s potable water supply, but also may impact on the AONB’s physical and ecological character over time.’

 

 

 

Conclusion: We do not think this is sufficient: it is in the public interest to challenge the scoping report and require full and up-to-date evidence. This is will require a new – independent - hydrogeological survey.

 

Location: The location of Hegdale quarry doesn’t fit Kent County Council’ criteria for the siting of facilities for CBC and asbestos waste. A251 between Challock and Faversham is a notorious accident area with several fatalities. Sections of the A251 have pinch points for 2 HGV passing with an additional 100 plus diesel fueled vehicles on this and any surrounding lanes on daily basis would lead to an increase in air pollution, noise in this rural area, effects on the wildlife and contamination probabilities to the local water supply and rivers. All this questions the suitability of the road construction of A251 and surrounding lanes including the A252 another notorious accident area able to take this significant increase of heavy vehicles movements.  AONB would be adversely opposed to increase volume of HGV’s with the potential to damage/destroy.

 

AONB: Achieving sustainable development is an overarching principle for much national and international policy (North Downs Area of Outstanding Natural Beauty management Plan, 2014). ‘The principles of sustainable development underpin the UK Sustainable Development Strategy and are reiterated in the National Planning Policy Framework. AONB management plans are an important way to help achieve sustainable development in the context of a Protected Landscape. Sustainable development has economic, social and environmental dimensions. In the context of the Kent Downs Area of Outstanding Natural Beauty, sustainability should be judged primarily against the objective of AONB designation set out in the Countryside and Rights of Way Act 2000 [...] for the purposes of conserving and enhancing the natural beauty of the area”’.

 

 

 

However, despite the existence of a National Planning Framework criteria-based framework, there are no local criteria-based policies for planning decisions. This means that local decision regarding development and sustainable development will not reflect local conditions.

 

 

 

KCC’s own Minerals and Waste Local Plan 2013-30 (Policy CSW 6, Location of Built Waste management facilities) states that:

 

 

 

Planning permission will be granted for uses identified as appropriate to the sites allocated in the Waste Sites Plan to meet the need identified in Policy CSW 7 providing that such proposals:

 

  • do not give rise to significant adverse impacts upon national and international

 

designated sites, including Areas of Outstanding Natural Beauty (AONB), Ancient Woodland, and groundwater resources (and avoid SPZ 1s) and areas of flood risk.

 

 

 

  • are well located in relation to Kent's Key Arterial Routes, avoiding proposals

 

which would give rise to significant numbers of lorry movements through villages?

 

or on unacceptable stretches of road.

 

 

 

  • avoid sites on or in proximity to land where alternative development exists/

 

has planning permission or is identified in an adopted Local Plan for alternate

 

uses that may prove to be incompatible with the proposed waste management

 

uses on the site.

 

 

 

It is also noted (Policy CSW 11) that Kent has more ‘than sufficient landfill’ capacity to meet the county’s needs until 2030. While high priority is given to sites with existing permission for mineral working, such over-capacity suggest that sites that result in less environmental damage and pollution are available. It is also noted that Kent imports significant amount of asbestos-based hazardous waste into the county. This raises important questions regarding the long-distance transportation that would result from development of Hegdale for this purpose.

 

 

 

This seems inconsistent with KCC’s Policy DM 1 Sustainable design, which states that:

 

 

 

It is important that all minerals and waste developments are designed to minimize the impact upon the environment and Kent's communities. There is a need to reduce the amount of greenhouse gas emissions and other forms of emissions, minimise energy and water consumption, reduce waste production and reuse or recycle materials.

 

 

 

We note that Policy DM 1 is somewhat narrowly focused on sites rather than collateral impacts, rendering it incompatible with likely national initiatives on particulate and nitrous oxide emissions.

 

Conclusion: the site is inappropriate.

 

Pollution and air quality: The scoping document and proposed Environmental Impact Assessment are narrowly focused on the site, given that HGV traffic on the A251 would increase by 7%[1]. This is surprising when efforts to remediate climate change given the likelihood of new policies to curb emissions (75%-85% of particulates and nitrogen oxide are produced by commercial vehicles[2] with, in addition 17% of greenhouse gases produced by HGVs in the UK). The latter is likely to mean that air quality monitoring will be extended while ‘dirtier’ HGVs (Euro standards between 1 and 5) will be forced to use urban and rural roads outside restricted areas). It should be noted that all three A roads to Hegdale quarry pass through villages with road-side houses, schools and playground and play/leisure facilities.

 

Noise is a related issue. Noise has a known effect child development and adult health in respect of cognition and memory[3]. Noise is not merely as issue restricted to the site itself but to lorry routes to the site.

 

Hazardous waste: When the waste is removed from site to disposal site what stringent procedures are in place?  Our understanding that sealed waste is transferred into sealed skips or vehicles. The materials are removed to the landfill site, how is it removed? What stops the bags from splitting?  What procedures in place to guarantee 100% compliance with the transport and ultimate landfill disposal procedures and records including photographic evidence of each and every load of waste. Are the skips just tipped out onto ground, with possible splitting of bags? When placed in designated tip location is it levelled by machines (bulldozer)? When the contaminated material is capped what method is there to ensure no damage to sealed bags at time of covering or later by continuous plant movement?  Operatives again would be suitably protected but what about the local environment water aquifer, of air-born particles etc.  If the pit is simply filled with the inert waste, when it rains the water will pass through the fill washing and picking up any potential contaminants, this will then travel through the fractures in the chalk and eventually will reach the water table and thus contaminate a principle aquifer. The only way to mitigate this is to prevent the water escaping the quarry by installing an impermeable basal, sidewall and capping layer. There is no mention on how R H Ovenden’s propose to install this layer, or what materials will be used.

 

Asbestos in its undisturbed state is harmless, but when disturbed it will go airborne, it is these small particles which are less than the size of car emissions and invisible to the naked eye that present the most danger if breathed into the lungs. What method do they propose that the asbestos will be collected, packaged and transported into the quarry? How do they propose to stop the packaging splitting when driven over by plant and machinery and then going airborne?

 

The fact that they want to sort the asbestos, and then dump the rest of the material on site means that asbestos fibres will no doubt be contained within the dumped material. Dust suppression will therefore be required to prevent these fibres going airborne.

 

The report just highlights the problems that could be caused. R H Ovenden’s need to submit a method statement on how they propose to overcome all of these problems.

 

There is no consideration under 4.8 Air Quality in the scoping report of the impact of asbestos fibres escaping during transportation and tipping (or to the impact of 100 HGV movements a day). A quantitative modelling study is required and waste, vibration and light pollution should be included in any EIA and ES.

 

Conclusions:

 

  1. such an operation is likely to be unsustainable and unacceptable in respect of the above types of environmental pollution

  2. the omission of waste, vibration and light pollution from any EIA and ES is unacceptable.

 

Restoration of Landfill: The operator’s plans to restore the landfill to woodland when it is completed; surely the tree planting would be unsafe on an infill of asbestos based materials, if trees fell, roots would pull up earth and expose asbestos and maybe release fibres, as well as allowing water to puddle in resultant dips and seep down into the waste disturbing it. (We believe that water puddling and other erosion is deemed unacceptable by the EA on a completed asbestos landfill site) relation to observations you have made with regard to frequency and/or effect of trees falling in this area. Many of our native trees in this area have very long roots, what measures are in place to prevent both disturbance of waste and expose it if and when the tree falls. Exposure of westerly winds from across open fields on the site. This area is a haven for wildlife; badgers would tunnel beyond 2 metres what if they disturb the waste, carry it out on their fur, even pull it out during burrowing operations, and that sett drainage systems would seep into the waste. 

 

Conclusion: The environmental impact assessment has not taken proper account of our local habitats and wildlife in relation to asbestos landfill and subsequent restoration.

 

Record of the operator: R H Ovenden, the operator of Hegdale Quarry, has failed over a period to 22 years to comply with a planning condition to restore the site; activities have also taken place at the site in the absence of planning consent. It seems that this failure to restore the site has opened the possibility of the mooted asbestos dump. Operators with a poor record of Corporate Social Responsibility should not be ‘rewarded’ with such opportunities, not least because such opportunities allow operators continue flaunting planning law. Companies with a poor record of compliance cannot be trusted to operate sites safely to ensure public safety and that of workers. With asbestos waste in particular, monitoring measures may be lax. We understand that Ovenden operate other sites in Kent and we believe that the fullest information on breaches of planning consent/conditions and public complains at all Ovenden sites in order for KCC to make a decision on whether a planning application can be submitted.

 

Conclusion: a full record of R H Ovenden’s record of operations at Hegdale and other sites, current and historic, is required.

 

Stakeholder consultation: we note with concern that relevant stakeholders such as Shelwich, Badlesmere and Leaveland Parish Council (on whose boundary Hegdale Quarry is located) and parishes which stand to be affected by such an operation, such as Charing in respect of the impact of lorry movements on Charing Hill, have not been consulted and were unaware of the mooted asbestos dump. The nature of infill planning applications, particularly those where waste includes asbestos is such that the usual notification process is inadequate.

 

Conclusion: relevant stakeholders should be identified forthwith and consulted before a decision is made on the scoping report. Since a planning application has not yet been submitted, there is sufficient timescale for this. In the absence of more comprehensive, formal stakeholder input, such stakeholders are likely to coalesce in opposition to any planning application.

 

 

 



[1] Based on last available statistics (2014) provided by UK Traffic Data, A251 Challock, available at https://www.ncbi.nlm.nih.gov/pmc/articles/PMC1637786/pdf/envhper00310-0128.pdf Acessed 3 May 2016

[2] Government sources give a lower percentage those results from including all sources of particulates and nitrous oxide, not the percentage emanating from commercial vehicles.

[3]  for example, Passchier-Vermeer, W and Passchier, W.F. Noise exposure and public health (2000) Environmental Heath Perspectives, vol 108, supplement 1 [Online} Available at https://www.ncbi.nlm.nih.gov/pmc/articles/PMC1637786/pdf/envhper00310-0128.pdf Accessed 3 May 2017

 


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