Objections by 6 June re Hanson Cement Plant, example points:-
A SHLAP (Stop Horn LAne Pollution) member has done an extraordinary amount of hard work to make it as easy as possible for concerned residents to Object to the Hanson Cement application for a Certificate of Lawful Development (CLD). This is not a full Planning Application, that is the next stage if Hanson's fail to obtain the Certificate of Lawful Development.Hanson's are relying on the terms of the General Development Order which they set out in their supporting statement - primarily that this is simply replacement plant. They cannot rely on this if the replacement would materially affect the external appearance or is significantly higher etc, etc. Accordingly, highlighting the differences in appearance and location are critical. There are also other legal and factual arguments that can be raised such as whether the "downtime" when the plant was not operating amounted to an abandonment or change in use. By mentioning this we hope the council will investigate the options fully with a view to refusing the application. We have also included the usual grounds of objection to a planning application, in particular the pollution issues, as these give additional weight to the argument that a full Planning Application should be sought so that such issuescan be properly considered.Set out below are some suggested grounds for objecting which you can customise to reflect your own situation/location, delete our foregoing comments and you to choose "I" or "we" etc. Please take the trouble to object, the more people who object the more likely that we will be successful in the CLD being refused. You can object even if you have not received a letter of consultation from the council and you can object online at:-http://www.pam.ealing.gov.uk/portal/servlets/ApplicationSearchServlet?PKID=148782ORby email to: planning@ealing.gov.uk (quote Reference: PP/2012/1741 - 305 Horn Lane, Acton W3 0BP - retention of concrete batching plant, state that you object to the application and give your full name and address)I/we object to the above application on the following grounds:-1. General Development OrderI/We do not agree that the Town and Country Planning (General PermittedDevelopment) Order 1995 ("GDO") applies for the following reasons:(i) The external appearance of the new plant is materially different from theold and it is sited in a different location.I/We note that Hanson Concrete have not provided a plan showing the originallocation or copies of the original drawing. I/We request that these areprovided.[the following is appropriate for residents in Noel Road and Lowfield Road butmay need to be changed for other locations]From my/our home it appears significantly bigger and in a different place. Itis more visually intrusive. This is borne out by Viewpoint 5 in the applicant'sVisual Statement, where it can be seen that the plant appears much closer tomy/our home and accordingly much larger – this is the case even although theviewpoint/zoom level in those photos is different as can be seen from thedifferent sizes of Acton House which can be used as a reference point. In the2003 photo of the old plant, Acton house appears larger and therefore the photois taken closer, but the old plant still looks smaller and further away. Thiseffect would be even more apparent if the viewpoint/zoom was the same.The old plant was in two sections with the silo section being considerablyfurther away. In this regard I note that it was a condition of the 1965certificate in relation to the old plant that the plant be located at thesouthern part of the site so as to reduce the risk of injury to the amenitiesof residential properties to the north of the site in Horn Lane and Noel Road. This seems to have been ignored.(ii) Given the apparent increase in size and the long period of non-use I/wealso question whether the current operation amounts to a materialintensification of use, so requiring planning permission.(iii) The old plant was demolished in July 2010 and construction of the new onedid not commence until about a year later. Given the long period of non use, I/We suggest the old use was abandoned or this significant gap amounted to achange in use and therefore the current operations amount to a new use.Further in view of the nature of the site, in particular the proximity toresidential properties, a full planning application is the only way to ensurethat the pollution and other issues referred to below are properly considered.2. Pollution issuesThis pocket of industrial sites, of which this plant forms part, has beendescribed as the most polluted place in London (seehttp://news.bbc.co.uk/1/hi/england/london/7012351.stmhttp://news.bbc.co.uk/1/hi/\england/london/7012351.stmhttp://news.bbc.co.uk/1/hi/england/london/7012351.stm). Statistics from the Environmental Research Group at Kings College Londonshow that this site has consistently breached EU and National requirements bysignificant amounts (the EU Air Quality Directive 2008/50/EC May 2008 and theAir Quality Standards Regulations 2010). Accordingly, it also fails to meet thetargets of the National Air Quality Action Plan and the Ealing Air QualityAction Plan which implement these laws. The matter has been raised in the houseof Commons by the local MP, Angie Bray – see http://www.theyworkforyou.com/whall/?id=2010-12-15a.291.0 and has been raised inthe London Assembly by Murad Qureshi, Labour London Assembly member: see:http://www.london.gov.uk/media/press_releases_assembly_member/news-murad-qureshi\-dangerous-levels-air-pollution-horn-lane-excI /We understand that fresh concrete and cement are very alkaline and corrosiveand can cause serious pollution, with particulate matter emissions andstormwater runoff being the primary pollutants. I am/We are especiallyconcerned about particulate matter emissions as a result of the transfer ofmaterial to silos, the transfer of sand and aggregate to the plant, truckloading and mixer loading etc. In addition to such pollution as the plantoperations produce, I/We understand from the Environmental Health Departmentthat there are about 200 heavy vehicle movements a day at the plant – this mustlead to significant increases in particulate matter and, presumably, nitrogendioxide levels, particularly as the concrete mixer lorries are idling whilstbeing filled. A paper produced by Kings College Environmental Group(Particulate Matter Oxidative Potential from Waste Transfer Station Activity–http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2854725/ ) notes that the highestparticulate matter concentrations in London occur in proximity to waste transferstations that experience high number of dust-laden, heavy-duty diesel vehiclestransporting industrial and household waste. It seems to me/us that there islittle difference in the profile for the cement batching plant which sees 200heavy duty vehicle movements carrying aggregate and concrete.The Government's Air Quality Strategy notes that exposure to ambient levels ofparticulate matter is consistently associated with respiratory andcardiovascular illness and mortality. Nitrogen dioxide levels can causeinflammation of the airways and long term exposure may affect lung function andcause respiratory symptoms.In their supporting statement Hanson Concrete make the point that they get theiraggregates from the adjoining aggregates rail depot and thus keep "hundreds ofheavy goods vehicles off London's roads". However I /we understand thataggregates are transferred between the two sites by lorry. I understand thatcold starting of any vehicle gives rise to higher emissions initially and thisapplies particularly to vehicles equipped with catalysts. Accordingly I/we donot accept that there is any reduction in pollution as a result of thisproximity – in my/our view all the cold start short journeys simply concentratesit in a small residential area.The plant is also producing excessive noise nuisance. I/We understand that theEnvironmental Health Department has monitored the noise and determined that itamounts to a nuisance.Accordingly I am/we are of the view that the pollution that is produced by thisplant contributes significantly to locally unacceptable levels in breach oflegally binding EU and National requirements. It is inappropriate in what isessentially a residential area. Residential properties are in close proximityto this site on two sides and a children's nursery has just opened adjacent tothe batching plant in the Shamrock Club. It is primarily a residential area butover the years inappropriate development has taken place in this small pocket ofactivity next to the railway in the former goods yard, despite vigorousobjections. These businesses would be far more appropriately located in thenearby Park Royal Industrial Estate.[The following paragraph is appropriate for Noel Road residents – pleasecustomise for your property – see paragraph 2.3 of the Visual Statement forHansons comments of views from the east/south and west – namely views from theEast are restricted by fences around site, views from the south restricted byfences and other businesses and the railway and views from the west restrictedby Yeomans and the Shamrock sports ground]In this regard I /we would note that Hanson Concrete's view that properties tothe North along Noel Road are sheltered by "mature woodland" is a quiteinaccurate term for normal garden fruit trees and shrubs and the odd tree. Inmy/our view, they make no difference whatsoever. They also make much of theintervening site, but this is very narrow.In light of the above, I/We request that an article 4 direction dis-applyingpermitted development under the GDO be made in respect of the entire Horn Lanesite pursuant to clause 4(1)(a) of the GDO.This would help to protect the health and quality of life of the local residentsand prevent any further situations arising where a developer ignores requests toconsult with the Planning department, which we are advised Hanson Concrete failed to do upon being so requested by the Environmental Health Department.3. Visual AppearanceThe structure is an extremely tall, ugly and visually intrusive industrialstructure, sited close to my/our property with no attempts made to ameliorateits impact. As a consequence it detrimentally affects my/our quality of life.[Please customise the following sentence depending on your location: ] Whilstthe plant is partially obscured by an intervening structure, it is still verynoticeable.4. Loss of Privacy[this may vary depending on the location of your property – please customiseaccordingly]Persons climbing to the silos can overlook my/our property so reducing my/ourprivacy.5. Traffic/highway safetyAs indicated above, I/We understand that there are about 200 heavy vehiclemovements a day which create a considerable amount of additional traffic of veryheavy vehicles in a residential area. In this regard residents also have issues with lorries from the businesses in Horn Lane goods yard parkinginappropriately in our streets, no doubt because the sites are too small toaccommodate businesses of these kinds. Large vehicles parked in the bus lanealso make it very difficult for traffic exiting Noel Road to see oncomingtraffic.It is also becoming an increasing safety concern crossing the access road to thesite, which is very wide but has a sharp bend in it which obscures the largevehicles until they are almost upon you. This is a particular concern regardingyoung children and the infirm and elderly. In this regard I/we would note againthat a nursery has just opened in the adjacent Shamrock Club.6. Proposals in the Development PlanThe local development plan envisages residential property development in theexisting adjacent Gowing & Pursey site. It is unlikely that anyone would wantto build or live next door to the cement batching plant (or even be allowed todo so on environmental grounds) so this development would be likely to preventthe local development plan being effective.
Rosco White ● 5219d8 Comments