Dear Philip….

Thank you for the opportunity to respond to the additional documents submitted by Ecogen for application 21/00832/HCS . I understand that these documents have been submitted in response to some of the concerns raised by the public in the previous consultation period in May.

However these proposals do not address the issues, and are unacceptable. For that reason I object to the application, even with its revisions.

Whilst I am conscious of the need to recycle, the description of the work carried out leads to the conclusion that this is not a recycling facility but a waste transfer station. Rejection of this application will not lead to less recycling. The Ecogen website now invites manufacturers from all over the UK to use Ecogen and the Kings Worthy facility : surely this is not in line with the initial application and there will be similar companies in other parts of the UK to service local needs.

I am also conscious of the need to provide employment in Hampshire, but these papers state there is no need or intention to grow the employee numbers to handle additional goods.

HIGHWAYS:

The proposals do not change the hours of operation of the site but do extend the hours that lorries will move through the village. The site is currently operational from 7am to 5pm, so lorries enter and exit and travel through Kings Worthy between 7 and 4.30pm. This paper proposes extending the working lorries time to 7am to 8pm. The consultant for Ecogen says that this additional traffic will therefore have no impact as the time between vehicles will remain around 15-20minutes. But the vibration , the noise and the risk to other road users, including the bus service and users, will remain, and the impact will be for a greater period of time.

We know HGV’s wait in laybys near the site in Lovedon Lane before entering too, a practice which causes problems for residents. Additional waiting space at the site and a condition to prevent waiting on the nearby road network is required.

This paper also includes an analysis of the road space on which the lorries travel and makes suggestions to change the design of the road to fit the problem. Whilst a developer can change the entrance to their own property (if they own the land needed) they cannot make suggestions for or guarantee changes on land which is not their own, or for plans for which they will not bear the cost.

Whilst some of the changes proposed have been suggested in the past for general improvements to Lovedon Lane to accommodate the generally increasing traffic numbers as result of the growth of the village housing numbers, these have been rejected by HCC.

Changing the design of the road to fit the lorries used at this site will not solve the problem and my objection to the increase in number of Ecogen vehicle movements to 20,000 a year (80 a day equates to around 20,000 a year) remains.

Once crucial matter on road design is that the Humphreys Egg Farm used an entrance close to the ‘old mainline railway bridge’ before it was rebuilt several years ago. The old entrance was in full sight of the bridge and lorries could wait on the egg farm site before proceeding., This cannot be done now. The new bridge incorporates footways and as a result of the new design and the wider/higher lorry designs now, the bridge cannot accommodate two way working. These vital changes have added to the pressure on this section of the route.

As additional information: I understand that in response to the shortage of lorry drivers, the Road Hauliers have appealed to Government for lorries to grow ever larger. Giving permission now for 20,000 lorry movements from this site alone when containers could grow even larger or longer is a frightening prospect for children, walkers, cyclists, small vehicles and residents here.

In the summary of the paper, Stuart Michael Associates (SMA) states that

a) The road has a good safety record so it shows the HGV’s do not contribute to a poor safety record. So why do they suggest signage improvements and a lower speed limit, shuttle working, road widening? None of this is acceptable.

b) Signage at South Wonston to discourage traffic entering from the village. They have omitted to include the impact on Wonston parish, and specifically signage at Sutton Scotney in this proposal: vehicles not owned or managed by Ecogen, but servicing the site, have driven through Stoke Charity and Wonston and have wrecked gardens as they struggle through narrow village roads. Signage alone will not stop this, whilst domestic type Sat Navs are used by drivers.

SMA consider therefore, that the local network can accommodate the increase in HGV movements. I do not agree.

AIR QUALITY ASSESSMENT

This paper covers Air Quality.

It is a relatively technical document, the detail of which I am not qualified to respond to, but it does contradict itself as it reminds us of Para 174 of the National Planning Policy Framework (NPPF)which states that Planning… decisions should contribute and enhance the natural environment. by preventing new .. development from contributing to …. or being put at unacceptable risk from unacceptable levels of soil, air, water or noise pollution. Development should… help to improve local environmental conditions …

• Para 186 states that …. decisions should sustain and contribute towards compliance with relevant limit values or national objectives for pollutants. It goes on to talk about AQMA (air quality management areas): in Winchester there is only 1, central Winchester, but the air quality on Lovedon Lane is, according to the BBC website, worse than elsewhere in Kings Worthy.

The AQMA standards are limits, not expectations of acceptance. WHO limits are lower and there are many pollutants which are not included in the AQMA assessment or indeed this one. We do not know the likely dust pollutants for example, and this has not been addressed by Ecogen. I understand from their website that they are now recycling polymers too.

In para 4.5 of this paper: it does not describe the air quality monitoring that has been ongoing by WCC from traffic on the B3047 in Abbots Worthy, caused by long lines of traffic waiting to join the A33; the route of the Ecogen vehicles. Pre-pandemic this was of concern and should have been considered in this study. Reduced traffic in 2020/21 meant that the monitoring didn’t show issues in these years, but this should be challenged.

The BBC website provides information about air quality too. Lovedon Lane near Eversley Gardens is the only place in Kings Worthy which shows an inferior air quality, despite having an open aspect. It has been suggested the reason is the acceleration of vehicles from the A33 junction, and going uphill. The report does not attempt to counteract this assessment; it is a missing piece of information which should be provided.

NOISE: applicant’s response to Environmental Health Officer’s EHO) comments

This reminds us that the EHO’s concern for noise pollution was initially considered as a valid reason for refusal. Mitigation measures have been proposed to reduce the noise to ‘acceptable levels’ from the site.

But the applicants have not addressed the noise and vibration from lorries and HGV’s moving from the site to the trunk road system. (and onwards through the ‘old village’ on the A33 towards the M3) The impact of the dust, vibration and noise of HGV’s and containers (both full and empty ) on homes, some of which are really close to the road itself, is really huge and it is very frustrating that any possible mitigation proposals have not been included in this additional paper.

In conclusion, the three papers reinforce my concerns that

• the growth of the number of lorries/HGV’s to what will be 20,000 + movements per year will be far too great for this rural road, also a 15 minute local bus route, with several limited width sections, and a number of constrictions.
• the impact of the noise and vibration and dust for longer periods of the day will have an adverse impact on non-motorised users and residents for even longer than at present.
• there is no proposed benefit of additional employment at the site.
• the longer timescale of lorry movements will put cyclists, walkers and bus users at risk intothe darker hours.
• The vehicles are not contributing to an improvement in the air quality for Kings Worthy users,and will be exacerbating it.
• The proposals do not include any support for Wonston parish residents despite a recognisedenforcement complaint by them against Ecogen in Spring 2021. Cllr Jackie Porter. Jackie.porter@hants.gov.uk

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