Comments Form

I strongly object for the following reasons The proposal is contrary to the policies set out in the St Edmundsbury Local Plan. The site is outside of any settlement area, is agricultural land within the countryside, and not allocated for any form of development and is clearly not envisaged, designated nor considered appropriate for industrial development. The proposed development is a large industrial scale waste processing and power generating facility which is inconsistent with the designation of the land within the Local Plan. It is also inconsistent with the Haverhill 2031 vision document and with the St Edmundsbury Environmental strategy which designates the area as part of or bordering the Stour Brook Green Corridor. 2. Location: In addition to the proposed site not being designated within planning policies for such a development, the applicant has not sufficiently met the test of demonstrating why this site, rather than others has been selected for this facility. The applicant should be required to undertake and submit a full sequential site assessment which clearly sets out the requirements and evaluates a range of potential sites against these criteria. That assessment should also assess the potential disbenefits and harm associated with each potential site. Whilst access to a major road to facilitate transportation of materials to and from the plant, may be a criteria, the proximity to significant residential areas, including day nursery and park lands should also be considered The site is adjacent to the access to Haverhill and is therefore a Gateway Site, which should be considered in relation to the overall impact that such a development would have on Haverhill. An industrial development of this scale and in this location would adversely impact on the gateway to Haverhill, one of Suffolk's fastest growing towns. Investment has been made in the creation of the Research Park and Epicentre landmark building. These will be overshadowed by the massive structures and expansive footprint of this facility just a few hundred metres away. 3. Visual Impact The design of the plant appears to have been driven entirely by function, with no regard to its appearance and fit with the surrounding area. All the structures are of a massive scale and wholly industrial in nature. The plant would have a detrimental impact on its surroundings and to Withersfield due to its scale and industrial nature. The location is alongside the Stour Brook and adjacent to Meldham Wash/West Town Park, which are areas of note from an environmental perspective. Users of these areas - ramblers, occasional walkers, dog walkers etc. will see their usual rural vistas completely dominated by this massive plant with is 5 massive digestor tanks, storage clamps, electricity generating plant, concreted yards, storage facilities, a pumping station to service the proposed digestate pipeline, and a metal chimney for venting and flaring off methane. The site will be visually intrusive to many residents of the Arboretum estate, changing current views of countryside and fields with a large industrial plant. The digestor tanks at more than 7 metres in height would also be visible from parts of the village, as will the even higher flame chimney. Heritage properties in Silver Street which currently enjoy uninterrupted historic views across the hills of Essex would have this affected by the tops of the digestor tanks and by the flare-off chimney. Security fencings and site lighting all add to the negative visual impact, and claims that existing planting will hide from view the facility are not credible, particularly given that all trees are deciduous, resulting in the plant being completely unmasked during autumn and winter months. 4. Traffic and impact on road system Of particular concern is at potential impact on local roads resulting from the substantial number of traffic movements - both HGV and tractor/trailers. The access and egress onto the A1307 would require substantial works to create appropriate deceleration and acceleration lanes to accommodate safe joining to the busy highway. HGVs leaving the site and heading west will have to head east towardsHaverhill and then negotiate a full rotation of the Spirit of Enterprise roundabout in order to continue their journey. The design and size of the proposed roundabout is not suitable for the manoeuvres which will be required particularly as these will be frequent and continuous. Large vehicles transporting quantities of the planned for chicken waste are likely to be travelling from the east, potentially through Haverhill and having to make a right turn across the busy A1307 to enter the site. These indicate that there would be a substantial increase in risks on this road, which is already identified as a road which has a high number of road traffic accidents and associated casualties. In addition, there would be significant displacement of traffic on to village roads. Silver Street in particular is a country lane of around 4 metres in width. It is already misused by HGV traffic heading towards the West Wratting warehouses - despite clear signposting in the A1307 directing HGVs to the approved route. This plant would generate additional traffic movements which would use Silver Street, Skippers Lane, Hollow Hill, Church Street, Turnpike Hill, Thurlow Road, Queens Street and Withersfield Road as alternatives to the advised routes. A second entrance to the site, at an expanded farm track access point in Silver Street is a particular concern as it implies that there will be a vast increase in the numbers of farm vehicle movements concentrated on the edge of our village, and causing significant damage and danger to Silver Street, and impact significantly on residents of Silver Street, Horseheath Road, and Hollow Hill, including the White Horse public House and its clientele. This is clearly demonstrated with reference to Acorn's planning statement below: Acorns Planning Statement contains the following references:- 5.8.1.1 Access Design "it is noted that the largest area of farmland is located to the north/north-east of the application site. This area of farmland, particularly during intense harvest periods, would be serviced by the internal farm track network to the north of Spring Grove Farm, in the north extent of the Thurlow Estate. These tracks offer direct access across private land using established routes." 5.8.1.4 Access Design "The proposals seek to upgrade the east access junction and close up the access junction between the buildings, to minimise points of access off the A1307. Access to the buildings can then be gained from the north via the upgraded internal access road." Statement of Community Involvement prepared by Instinctif & Partners page 10 This part of the planning documentation contains reference to the entry point:- "Farmyard vehicles will use farm tracks wherever possible and cross at an upgraded junction on Silver Street to enter from the north of the site." There will therefore be an access point on the north side of the AD facility which will link to the farm tracks across the estate via an upgraded junction on Silver Street. The northern entry point to the site is at same point as gestate pipeline enters the site. This can be seen on the application site plan in the applicant's documentation. The Planning Statement does not show where the upgraded farm tracks will go or where they will intersect or use the highway. However, they must use and intersect with Skippers Lane Silver Street Horseheath Road or come through Withersfield via Hollow Hill to get access to the "upgraded junction on Silver Street to enter from the north of the site". There is potential for at least 5036 farm traffic/HGV movements per year which could access or leave via the gate at Silver Street/Horseheath Road. The junction of Skippers Lane, Silver Street, Horseheath Road, Hollow Hill and Withersfield are already a sensitive area where a 20MPH Speed Zone has been approved for the village of Withersfield because of the tight bends, lack of pavements and rat run traffic speeding between Haverhill and Cambridge. In this sensitive area traffic flows should not be increased. The highest volume of HGV/Tractor traffic will be at harvest times in June and October. October is also when the Jelly Warehouse on Skippers Lane fills the warehouse with stock for Christmas and it's HGV's are constantly coming up from the A1307 via Silver Street and Skippers Lane. The junction of Horseheath Road, Skippers Lane and Hollow Hill is the epicentre of rat run traffic and HGV traffic to the Jelly Warehouse on Skippers Lane. These Roads are already dangerous where only a single HGV can use and if two HGV's meet it causes a traffic jam. These are small rural roads that pot hole in winter and have tight bends. The Panning Statement does not contain a Traffic Management Plan (This must be a mandatory requirement) Even without the TMP it is clear from the Planning Statement that the impact of farm traffic on the roads around Withersfield and the surrounding environment would be severe and the volume of farm traffic in this area would be unacceptable. 5. Impact on local economy The applicant claims that the plant will generate employment opportunities locally. We dispute this claim. Whilst there are minimal jobs created on-site, most are at remote locations - similar plants are managed and monitored remotely by computer links to distant overseas locations. Hence the benefit to the area in relation to jobs is negligible. In fact, the likely impact of the plant on the research park would be negative. In addition, there is likely to be a significant impact on the local housing market. Already there are signs that the proposal is resulting in reluctance of purchasers to commit to purchasing properties in the vicinity. The impact on the current development of 150 new homes just a few hundred yards from the site, at the Arboretum is likely to be considerable, with a potential negative impact on our local economy. 6. Impact on local footpaths and pedestrians: The site of the plant would impact on current footpaths and walkways used by residents, dog walkers and ramblers. In addition, the proposed enlarged farm entrance and widened farm track required to take the volumes of silage and farm traffic will adversely impact on the current footpath from Horseheath Road heading towards Howe Wood and the Roman Road. The plan also appears to cut off an existing public footpath along the old road adjacent to the A1307 and the works to create the entry/egress to the site obstructs access to farm land to the north of the A1307 which is owned and operated by an independent farmer. 7. Potential Harm is another concern and the potential impact of odours coming from the plant. The noise levels would be significant and continuous and cause significant detriment to residents. 9. Risk of Flooding The site borders the Stour Brook and land that is identified as Level 2 & 3 flood risk. Over the last year these areas have flooded on a number of occasions. The proposed plant would involve concreting over an area of some 11 hectares resulting in a significant volume of rain water runoff that would otherwise have been absorbed by farm land, potentially overwhelming the brook. The area of greatest risk of flooding is where the applicants proposed the primary entry and egress to and from the site - onto the A1307. 10. Environmental impact and harm; In addition to the noise, odours, loss of grade 2 farm land currently producing crops for food, there would be a negative impact on the local environment. The Stour Brook green corridor will be compromised, views from West Town Park (Meldham Wash) and from Withersfield village would be negatively affected, and there would be significant disturbance to wild life and plant species in the woodlands surrounding the the site, which would operate 24 hours a day 365 days a year 11. Health & Safety concerns: In addition to the potential harmed caused by particulate emissions, we are concerned at the risk posed by the siting or high-pressure gas tanks of this scale so close to our homes. Recent examples of explosions at similar plants are of great concern and clearly demonstrates the hazardous impact of a lightening strike on high pressure methane tanks at Spring Grove Farm, sited so close to hundreds of homes on Withersfield's Arboretum estate, and countless other homes in Hanchett Village and Hanchett end. 12. False Green credentials Finally, we are concerned that this proposal is being presented as "green" technology, which will positively contribute to reducing the country's reliance on carbon fuels and hence help to combat global warming. This proposal will take valuable Grade 2 agricultural land out of use to develop the plant. In addition, it will result in more grade 2 agricultural land being taken out of the production of food and feedstuffs in order to produce silage and non-foodstuff crops in order to feed the digestors and to produce methane to burn to generate electricity. This does not equate to a positive benefit, unlike solar and wind generation - which can be achieved without many of the harms associated with this industrial plant. This is a completely inappropriate site for this type of industrial development and must be rejected

Application number
Name
Address	Thistledown cottage Thurlow Road Withersfield CB97SA
Type of Comment
Comments	I strongly object for the following reasons The proposal is contrary to the policies set out in the St Edmundsbury Local Plan. The site is outside of any settlement area, is agricultural land within the countryside, and not allocated for any form of development and is clearly not envisaged, designated nor considered appropriate for industrial development. The proposed development is a large industrial scale waste processing and power generating facility which is inconsistent with the designation of the land within the Local Plan. It is also inconsistent with the Haverhill 2031 vision document and with the St Edmundsbury Environmental strategy which designates the area as part of or bordering the Stour Brook Green Corridor. 2. Location: In addition to the proposed site not being designated within planning policies for such a development, the applicant has not sufficiently met the test of demonstrating why this site, rather than others has been selected for this facility. The applicant should be required to undertake and submit a full sequential site assessment which clearly sets out the requirements and evaluates a range of potential sites against these criteria. That assessment should also assess the potential disbenefits and harm associated with each potential site. Whilst access to a major road to facilitate transportation of materials to and from the plant, may be a criteria, the proximity to significant residential areas, including day nursery and park lands should also be considered The site is adjacent to the access to Haverhill and is therefore a Gateway Site, which should be considered in relation to the overall impact that such a development would have on Haverhill. An industrial development of this scale and in this location would adversely impact on the gateway to Haverhill, one of Suffolk's fastest growing towns. Investment has been made in the creation of the Research Park and Epicentre landmark building. These will be overshadowed by the massive structures and expansive footprint of this facility just a few hundred metres away. 3. Visual Impact The design of the plant appears to have been driven entirely by function, with no regard to its appearance and fit with the surrounding area. All the structures are of a massive scale and wholly industrial in nature. The plant would have a detrimental impact on its surroundings and to Withersfield due to its scale and industrial nature. The location is alongside the Stour Brook and adjacent to Meldham Wash/West Town Park, which are areas of note from an environmental perspective. Users of these areas - ramblers, occasional walkers, dog walkers etc. will see their usual rural vistas completely dominated by this massive plant with is 5 massive digestor tanks, storage clamps, electricity generating plant, concreted yards, storage facilities, a pumping station to service the proposed digestate pipeline, and a metal chimney for venting and flaring off methane. The site will be visually intrusive to many residents of the Arboretum estate, changing current views of countryside and fields with a large industrial plant. The digestor tanks at more than 7 metres in height would also be visible from parts of the village, as will the even higher flame chimney. Heritage properties in Silver Street which currently enjoy uninterrupted historic views across the hills of Essex would have this affected by the tops of the digestor tanks and by the flare-off chimney. Security fencings and site lighting all add to the negative visual impact, and claims that existing planting will hide from view the facility are not credible, particularly given that all trees are deciduous, resulting in the plant being completely unmasked during autumn and winter months. 4. Traffic and impact on road system Of particular concern is at potential impact on local roads resulting from the substantial number of traffic movements - both HGV and tractor/trailers. The access and egress onto the A1307 would require substantial works to create appropriate deceleration and acceleration lanes to accommodate safe joining to the busy highway. HGVs leaving the site and heading west will have to head east towardsHaverhill and then negotiate a full rotation of the Spirit of Enterprise roundabout in order to continue their journey. The design and size of the proposed roundabout is not suitable for the manoeuvres which will be required particularly as these will be frequent and continuous. Large vehicles transporting quantities of the planned for chicken waste are likely to be travelling from the east, potentially through Haverhill and having to make a right turn across the busy A1307 to enter the site. These indicate that there would be a substantial increase in risks on this road, which is already identified as a road which has a high number of road traffic accidents and associated casualties. In addition, there would be significant displacement of traffic on to village roads. Silver Street in particular is a country lane of around 4 metres in width. It is already misused by HGV traffic heading towards the West Wratting warehouses - despite clear signposting in the A1307 directing HGVs to the approved route. This plant would generate additional traffic movements which would use Silver Street, Skippers Lane, Hollow Hill, Church Street, Turnpike Hill, Thurlow Road, Queens Street and Withersfield Road as alternatives to the advised routes. A second entrance to the site, at an expanded farm track access point in Silver Street is a particular concern as it implies that there will be a vast increase in the numbers of farm vehicle movements concentrated on the edge of our village, and causing significant damage and danger to Silver Street, and impact significantly on residents of Silver Street, Horseheath Road, and Hollow Hill, including the White Horse public House and its clientele. This is clearly demonstrated with reference to Acorn's planning statement below: Acorns Planning Statement contains the following references:- 5.8.1.1 Access Design "it is noted that the largest area of farmland is located to the north/north-east of the application site. This area of farmland, particularly during intense harvest periods, would be serviced by the internal farm track network to the north of Spring Grove Farm, in the north extent of the Thurlow Estate. These tracks offer direct access across private land using established routes." 5.8.1.4 Access Design "The proposals seek to upgrade the east access junction and close up the access junction between the buildings, to minimise points of access off the A1307. Access to the buildings can then be gained from the north via the upgraded internal access road." Statement of Community Involvement prepared by Instinctif & Partners page 10 This part of the planning documentation contains reference to the entry point:- "Farmyard vehicles will use farm tracks wherever possible and cross at an upgraded junction on Silver Street to enter from the north of the site." There will therefore be an access point on the north side of the AD facility which will link to the farm tracks across the estate via an upgraded junction on Silver Street. The northern entry point to the site is at same point as gestate pipeline enters the site. This can be seen on the application site plan in the applicant's documentation. The Planning Statement does not show where the upgraded farm tracks will go or where they will intersect or use the highway. However, they must use and intersect with Skippers Lane Silver Street Horseheath Road or come through Withersfield via Hollow Hill to get access to the "upgraded junction on Silver Street to enter from the north of the site". There is potential for at least 5036 farm traffic/HGV movements per year which could access or leave via the gate at Silver Street/Horseheath Road. The junction of Skippers Lane, Silver Street, Horseheath Road, Hollow Hill and Withersfield are already a sensitive area where a 20MPH Speed Zone has been approved for the village of Withersfield because of the tight bends, lack of pavements and rat run traffic speeding between Haverhill and Cambridge. In this sensitive area traffic flows should not be increased. The highest volume of HGV/Tractor traffic will be at harvest times in June and October. October is also when the Jelly Warehouse on Skippers Lane fills the warehouse with stock for Christmas and it's HGV's are constantly coming up from the A1307 via Silver Street and Skippers Lane. The junction of Horseheath Road, Skippers Lane and Hollow Hill is the epicentre of rat run traffic and HGV traffic to the Jelly Warehouse on Skippers Lane. These Roads are already dangerous where only a single HGV can use and if two HGV's meet it causes a traffic jam. These are small rural roads that pot hole in winter and have tight bends. The Panning Statement does not contain a Traffic Management Plan (This must be a mandatory requirement) Even without the TMP it is clear from the Planning Statement that the impact of farm traffic on the roads around Withersfield and the surrounding environment would be severe and the volume of farm traffic in this area would be unacceptable. 5. Impact on local economy The applicant claims that the plant will generate employment opportunities locally. We dispute this claim. Whilst there are minimal jobs created on-site, most are at remote locations - similar plants are managed and monitored remotely by computer links to distant overseas locations. Hence the benefit to the area in relation to jobs is negligible. In fact, the likely impact of the plant on the research park would be negative. In addition, there is likely to be a significant impact on the local housing market. Already there are signs that the proposal is resulting in reluctance of purchasers to commit to purchasing properties in the vicinity. The impact on the current development of 150 new homes just a few hundred yards from the site, at the Arboretum is likely to be considerable, with a potential negative impact on our local economy. 6. Impact on local footpaths and pedestrians: The site of the plant would impact on current footpaths and walkways used by residents, dog walkers and ramblers. In addition, the proposed enlarged farm entrance and widened farm track required to take the volumes of silage and farm traffic will adversely impact on the current footpath from Horseheath Road heading towards Howe Wood and the Roman Road. The plan also appears to cut off an existing public footpath along the old road adjacent to the A1307 and the works to create the entry/egress to the site obstructs access to farm land to the north of the A1307 which is owned and operated by an independent farmer. 7. Potential Harm is another concern and the potential impact of odours coming from the plant. The noise levels would be significant and continuous and cause significant detriment to residents. 9. Risk of Flooding The site borders the Stour Brook and land that is identified as Level 2 & 3 flood risk. Over the last year these areas have flooded on a number of occasions. The proposed plant would involve concreting over an area of some 11 hectares resulting in a significant volume of rain water runoff that would otherwise have been absorbed by farm land, potentially overwhelming the brook. The area of greatest risk of flooding is where the applicants proposed the primary entry and egress to and from the site - onto the A1307. 10. Environmental impact and harm; In addition to the noise, odours, loss of grade 2 farm land currently producing crops for food, there would be a negative impact on the local environment. The Stour Brook green corridor will be compromised, views from West Town Park (Meldham Wash) and from Withersfield village would be negatively affected, and there would be significant disturbance to wild life and plant species in the woodlands surrounding the the site, which would operate 24 hours a day 365 days a year 11. Health & Safety concerns: In addition to the potential harmed caused by particulate emissions, we are concerned at the risk posed by the siting or high-pressure gas tanks of this scale so close to our homes. Recent examples of explosions at similar plants are of great concern and clearly demonstrates the hazardous impact of a lightening strike on high pressure methane tanks at Spring Grove Farm, sited so close to hundreds of homes on Withersfield's Arboretum estate, and countless other homes in Hanchett Village and Hanchett end. 12. False Green credentials Finally, we are concerned that this proposal is being presented as "green" technology, which will positively contribute to reducing the country's reliance on carbon fuels and hence help to combat global warming. This proposal will take valuable Grade 2 agricultural land out of use to develop the plant. In addition, it will result in more grade 2 agricultural land being taken out of the production of food and feedstuffs in order to produce silage and non-foodstuff crops in order to feed the digestors and to produce methane to burn to generate electricity. This does not equate to a positive benefit, unlike solar and wind generation - which can be achieved without many of the harms associated with this industrial plant. This is a completely inappropriate site for this type of industrial development and must be rejected
Received
Attachments

Comment for planning application SCC/0045/23SE