As you probably already know, the Inspector's Report on his Examination of the Surrey Minerals Plan Aggregates Recycling Development Plan Document (ARDPD) was published on Monday (10 December). I have now read this and have written my own report on it. Please see the first attachment (Aggregates ...).
Inspectors Report 3
1. I have been in telephone and e-mail contact (see below) with County Cllr John Furey (JF), the Cabinet Member for the Environment & Highways, which includes mineral planning. Item 9 of the Cabinet Meeting for tomorrow (Tuesday 18 December) concerns the recommendation to forward the ARDPD to the Full County Council meeting, scheduled for 12 February. It was JF who suggested that I should e-mail him with my views - Hence the above document.
2. After further thought, I subsequently also sent him a second document - attached (Furey3).
3. He sent these two documents to SCC and he received a response from Mr Paul Sanderson - attached (Response to Mr Moreton Moore).
Response to Moreton Moore
4. I replied (see below), attaching a picture - attached (Stockpile).
5. I have also written 300 words for the Egham & Staines News - attached (E&S News...).
E & S News Aggregates report
This is most helpful and greatly appreciated. I will ponder Mr Sanderson's response.
In particular, I wish that his statement were true: "Recycling is a relatively contained activity and suitable physical measures and conditions can be used to control the release of dust." One can see from the railway line (the other side of Staines) 50-foot high stockpiles of aggregates to be recycled - Please see the attachment. This isn't contained! And in addition to the dust, there is the vibration....
You and I are doing our best to keep Runnymede Borough a healthy place to live! - Many thanks.
and a merry Christmas to you and Maureen
and a happy New Year
Councillor John Furey
Cabinet Member for Transport and Environment
H. 01932 856623
Response to Mr Moreton Moore
The Milton Park Farm site was discussed at length at the independent examination - this is referred to at para 13 of the Cabinet Report. Mr Morton is 'dismayed' that the Inspector has dismissed the cogent arguments of many residents.
The term 'dismissed' is harsh. The Inspector took full account of all arguments and issues raised. His report dedicates 22 paragraphs to the proposed MIlton Park Farm site. He has had to make a reasonable and balanced judgement in the light of all evidence and in the context of planning legislation.
He concludes that he is not convinced that the introduction of an aggregates recycling facility would significantly increase the likelihood of harm. This follows a careful consideration of all the issues raised, including the potential impacts on health caused by dust. Also, importantly, he makes this judgement in the context of the site which is already allocated as a preferred area for the extraction of concreting aggregate in the Surrey Minerals Plan Primary Aggregates DPD July 2011
Mr Moore disagrees with many aspects of the Inspector’s report. Much of this is a matter of opinion and (by definition) deals with issues and arguments such as those relating to flooding and access already raised and addressed at the examination. There can be no reason to reopen this debate now since it has followed due process
In particular, Mr Moore raises the issue of the potential harm caused by ultra-fine particles potentially caused by the crushing of concrete. As with other matters - this is an issue that has already been discussed at the Examination - but since Mr Moore emphasises this some comments for clarity:
- The current national and European legislative framework relating to air quality and the National Air Quality Strategy do not deal with articles smaller than PM10 - whilst research may be being carried out into the potential harm caused by smaller (ultra-fine) particles as small as PM0.1 this is in its infancy and would not be a sound basis for resisting a local plan aggregates recycling site allocation and could lay the Council open to legal challenge.
- The research at the University of Surrey referred to by Mr Moore (Kumar et al 2012) is looking on the potential harm from ultra fine particles due to workplace exposure (not general environment impacts) and in any event does not provide conclusive evidence and highlights the need for more research.
- Our air is already full of ultra-fine particles and because they can travel large distances there can be no guarantee that harm caused to a sensitive receptor (such as someone with asthma) has originated in the locality or indeed the same country.
In terms of recycling, there is no reason why the release of ultra fine particles cannot be controlled in the same way as other dust particles – i.e. by dampening, containment, filtering etc. The details of appropriate mitigation measures and the precise location of any plant can be addressed and controlled as necessary at the planning application stage should a planning application be submitted. Recycling is a relatively contained activity and suitable physical measures and conditions can be used to control the release of dust.
Mr Moore also raises a query re the seemingly contradictory nature of the figures quoted in the Inspector’s report at paragraphs 32 and 161. For clarity:
Para 32 states the overall Minerals Core Strategy aim of increasing aggregates recycling to at least 0.8 million tonnes per annum (tpa) by 2016 and to 0.9 million tpa by 2026.
Para 161 the figure of 206,000 tpa relates to the potential contribution towards this target to be met from other unidentified sites – so it will only be a relatively small proportion of the total.
Minerals & Waste Policy Team Manager
Tel: 020 8541 9949
Subject: RE: Cabinet Meeting - Aggregates Recycling
Date: Sun, 16 Dec 2012 16:46:44 +0000
Examination of the ARDPD – Re proposed site for an aggregates recycling facility at Milton Park Farm
I have had further thoughts during today, which I'd like to summarise in the following six bullet points.
· The Inspector did not express opinions in relation to potential air pollution and associated health risks that were either convincing in tone or which were attributed to credible technical sources.
· We know that cement dust and silica both carry health risks: this is clearly recognized by the UK Health & Safety Executive.
· To place an aggregates recycling facility alongside a school shows an abdication of the duty of care.
· In terms of environmental impact, as aggregate recycling involves importing large quantities of material by road from the wider geographical area, the location of a recycling plant up against a school and a residential area is not based on a compelling environmental argument. Other sites within the County could accommodate such a facility without presenting a risk to children’s health and which could be more accessible by road.
· It is suggested that a detailed knowledge of risks is determined by expert opinion before a decision is taken in the matter – not later. Surrey County Council has the means to appoint an expert organisation to assess whether there are ANY risks to health associated with the recycling proposals and expert groups are available in the South-East to complete such a study. This would recognise the very real concerns of local residents and ensure that the decision is taken on the basis of the best state of knowledge and not administrative convenience.
· The site is very sensitive in other respects, located alongside the M25 in the Green Belt and lying within a Flood Zone, served only by minor roads intersected by railway level-crossings.
I hope that the above summarises our concerns and will be helpful in your meeting.
Subject: Cabinet Meeting - Aggregates Recycling
Date: Sat, 15 Dec 2012 23:24:17 +0000
Cabinet Meeting 18 December
Item 9 Surrey Minerals Plan - Aggregates Recycling Development Plan Document
Please see attached (1) my comments on the Inspector’s Report and (2) my ‘index’ of representations concerning the modifications to the ARDPD. Your Agenda papers for the Cabinet Meeting have, in Annex 4 of Item 9, all the representations (listed by Main Modification number).
The Inspector, Mr Jonathan King, refers to Milton Park Farm in paragraph 86 (on page 18) of his Report as “by far the most contentious site of any identified in the Plan”.
32 Whitehall Lane, Egham, Surrey. TW20 9NF.