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Response to Additional Information: SRRP/Swadlincote Incinerator: Application CW9/1022/22.

Residents received letters in Sept/Oct 2023 stating there was additional information relating to the environment statement of the application.


Having now had time to review these, our volunteers have summarised these below.


It’s important that you make additional comments about this information and it's a great opportunity to add more comments than you might have made when you first objected. See our post here with more reasons to object . Object by selecting "Comment on this Application' here.


Response to DCC Highways and June 2023 Traffic Figures


Background:

· These figures were requested by highways in response to the initial application.

· Highways asked the applicant to confirm if the study was done in a neutral traffic week.

Observations:

· These figures appear to show 41% of traffic continuing straight on at the Cadley Roundabout (towards Caldwell and Rosliston) when leaving the Swadlincote direction from the Willshee’s entrance). This is highly irregular and casts doubt on the accuracy of the data.

· The data was collected in May 2022 during a closure of the A444 in Stapenhill due to the cycle lane upgrade by Staffordshire County Council: https://www.staffordshire-live.co.uk/news/burton-news/15-weeks-roadworks-coming-burton-6948865. The response to DCC Highways fails to acknowledge this and states this was a neutral week for traffic, this is in spite of these works creating substantial delays on the A444 and many choosing alternative routes.

· I would add that the communication of this document to a public audience for public comment is unhelpful with no key, data units or commentary provided to aid review.

Objections:

· The data is flawed and the reassurances provided in response to Highways are false/inaccurate. Traffic was not neutral due to the lane closures on the A444 in Stapenhill. As such both the traffic flow and queue length data should be disregarded. A new survey is required.

· The traffic impacts cannot be tolerated. The Burton upon Trent Town Plan highlights significant concern about, and delays on, the A444.


Additional Visual Impact Viewpoints and Photomontages

Background:

· Additional LVIA and Heritage Assessment information was requested by Derbyshire County Council on 10th March 2023. LVIA means Landscape and Visual Impact Assessment. The applicant has submitted further detail.

Observations:

· These updated views demonstrate the character of the surrounding area (farmland estates) and the enormous adverse visual impact that the development will have. Image 1 below is the applicant's own image (Appendix 7.8 page 2) from the Cadley Farm development adjacent and the red/pink lines mark the extent of the development, image 2 in the same appendix shows the staggering impact of the development on the landscape.

Objections:

· Since the initial application, the reinstatement of the Ivanhoe train line between Burton and Leicester has been announced, and these rail users would be additional sensitive receptors to this development.

· The landscape impacts are too severe and would not contribute positively to area character or quality (contrary to NPPW Appendix B c; Local Plan Para.3.3; Local Plan Strategic objective 9; Local Plan Policy S1; Local Plan Policy E2b; Local Plan Policy E7; Local Plan Para.6.38; Local Plan Para.7.38; Local Plan Policy SD6; Local Plan BNE1 e,f,g,h; Local Plan Para.8.38; Local Plan Para.8.13; Local Plan BNE4; National Forest Strategy 2014-2024; NPPF 147; National Infrastructure Strategy pg.84; Derbyshire Spatial Energy Study).







Heritage Assessment

Observations:

· The summary given in the Addendum to Heritage assessment grossly downplays the visual impact of the development. These impacts are evidenced in the visuals from the two heritage assets identified (Cadley Hill Farm and Motter & Bailey, Church Gresley).

· The Heritage Assessment highlights the historical and architectural features of Cadley Hill Farm (2.1.1). The Heritage Assessment identifies that the ERF would become a ‘dominant feature’ for the farm.

· The entire report is not written in a neutral manner and demonstrates a bias towards the applicant (he who pays the piper calls the tune!). For instance, terminology such as ‘the slender stack’ and concluding there would be only minor adverse impacts when the viewpoint photographs demonstrate significant visual impacts (as demonstrated in the viewpoint photos).

· The conclusions reached in 2.1 of the Heritage Assessment do not align with the conclusions and visuals provided in the LVIA component of the application. For instance, the Heritage Assessment states that the visibility of the ERF would be limited 1km from the site, yet the LVIA clearly depicts the adverse visual significance and dominance of the ERF.

· The Heritage Assessment chooses to exclude heritage assets based on, what I feel is, an inaccurate assumption of the visual impact of the site.

· The impact of the development on this viewpoint is stated as minimal in the Heritage Assessment, yet the Technical Note relating to Landscape and Visual matters outlines that there will be a ‘moderate adverse and significant residual visual effect…in the longer term for high sensitivity visitors’.

Objections

· The assessment is heavily biased and does not make accurate conclusions. The Heritage Assessment acknowledges potential "moderate" heritage impacts but downgrades this to "minor" in its professional judgement - this judgement could be challenged.

· The impact on the Cadley Hill Farm as a heritage asset should not be tolerated and the assessment is extremely biased in relation to the effects on this asset (which is in close proximity (200m) to the development). The following development plan statements should be considered in this planning decision:

o SDDC Adopted Local Plan SD6 states that its support for renewable and energy developments are subject to two considerations: ‘i) that the environmental effects of the proposal have been appropriately considered and schemes will not give rise to unacceptable impacts on landscape or townscape character, ecology, the historic environment or cultural heritage assets.’ The impacts on Cadley Hill Farm as an asset identified in the heritage assessment are unacceptable, as the visuals demonstrate.

o Adopted Local Plan (SDDC) (Para.3.3) states that, “new development will reflect and reinforce the District’s many distinct landscapes and will protect the integrity of our most sensitive wildlife sites, landscapes and heritage assets”.

o The integrity of the Cadley Hill Farm (and other local heritage assets) will not be protected if this development were to proceed.

o Adopted local Plan Policy S1 states that, ‘it is essential that the District’s heritage assets, landscape and rural character are protected, conserved and enhanced’. This development does not support this end.

o Adopted Local Plan Policy E2 also states that, proposals ‘should not give rise to undue impacts on the local landscape, natural environment or cultural heritage assets’.

o Adopted Local Plan Part A Policy BNE4 states, ‘Development that will have an unacceptable impact on landscape character (including historic character), visual amenity and sensitivity and cannot be satisfactorily mitigated will not be permitted”.

o DCC Derbyshire Spatial Energy Study states that development should ‘remain sympathetic to local character and landscape setting’ and identifies this as a constraint to the development of EFW plants.

· The impacts outlined in the Heritage Assessment and updated visuals for this development demonstrate significant disruption to the well-ordered lowland agricultural landscape recognised in the Natural England National character Area profile, and runs contrary to the Statement of Environmental Opportunity 4 which seeks to protect and conserve this character.

· Views from the scheduled monument at Castle Gresley Motte and Bailey would be altered by the large-scale development 1.4km away. Even though visibility is limited to the summit of the motte, both the LV technical note and Heritage Assessment reports agree there would be moderate adverse effects on views that contribute to the significance of this heritage asset.

· The impact on the Castle Gresley Motte & Bailey are identified in the Heritage Assessment (2.1.2) as follows: ‘the proposed development would be located 1.4km to the north-west and would present as a large modern (though static) visual addition to the landscape’. The report signals that the view down the valley may be important to the history of this asset.

· Taken together, the level of landscape and visual change conflicts with policies on protecting heritage assets and requirements to conserve their settings:

o Adverse impacts on the setting of the scheduled monument at Castle Gresley Motte and Bailey conflict with NPPF paragraph 194 which requires impacts on the significance of designated heritage assets to be assessed (pg. 56).

o The heritage impacts also conflict with South Derbyshire Local Plan Policy BNE2 which requires new development to “conserve, and where appropriate enhance or reveal, the significance of heritage assets and their settings” (pg. 122).

o There are potential conflicts with Policy INF8 regarding impacts on the character and appearance of the wider countryside in the National Forest from the development (pg. 159).

o The level of change conflicts with the overall emphasis in the Local Plan to protect the varied landscape character, cultural heritage and rural nature of the District (Strategic Objective 9, pg. 29).


Technical Note about the LVIA

Background:

· Additional LVIA and Heritage Assessment information was requested by Derbyshire County Council on 10th March 2023. Therefore the applicant has submitted further detail.

Observations:

· The technical note incorrectly identifies that the site is semi-derelict land (paragraph 4). This would be true of the land occupied by Willshee’s for the existing MRF and they have recently defined a ‘site’ on that land that comprises the derelict brownfield aspects of the site. However, the ERF is planned to be sited on woodland classified as a priority habitat (deciduous woodland). This can be confirmed on the MAGIC maps platform. In addition, this woodland includes several ponds and comprises five identified wildlife sites habitat to species, including protected great-crested newts, bats, badgers, and a species of leaf beetle previously considered to be extinct. The technical note fails to identify that the site is immediately surrounded by greenbelt to the north and west.

· The reference in paragraph 5 to coalmining and urban development appears to serve to distract decision-makers. There has been extensive regeneration of land to the east including the new 50-acre ‘Coronation Park’, Green Flag awarded ‘Cadley Park’ and golf course. This land now reflects extensive green and recreational space.

· Two-thirds of the structure will sit above the recessed valley area, this means that 40 metres of stack will be seen and 20 metres of the ERF building. The technical note states that this will have a long-term ‘large’ adverse effect for road users on Cadley Lane (a road leading to the popular National Forest attraction, Rosliston Forestry Centre). This road is pleasant for users with rolling farmland and farm estates. There is some mitigation through planting, but as the initial LVIA outlined, this will be somewhat negligible given the size of the structure

Objections:

· The LVIA technical note predicts major adverse landscape impacts that cannot be mitigated. This is supported by photomontages showing extensive visibility of the development. The landscape impacts conflict with National Planning Policy for Waste Appendix B paragraph 7 which states facilities should "contribute positively to the character and quality of the area" (pg. 6). This development would not achieve this.

· The inability to mitigate landscape impacts conflicts with South Derbyshire Local Plan Policy BNE4 which states "Development that will have an unacceptable impact on landscape character...and cannot be satisfactorily mitigated will not be permitted” (pg. 126).

· The 60-metre tall development would be highly visible, protruding above the treeline in an area with a "tranquil" landscape character.

· Views from public footpaths and village locations up to 1.5km away would be significantly affected.

· The scale and appearance of the development are out of keeping with the surrounding rural landscape.



For all of the objections available see here: https://www.villagehallstanton.com/post/objections-to-the-swadlincote-resource-recovery-park-incinerator




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