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East Sussex Branch
www.esussex-sta.org.uk
esussex.sata@btinternet.com
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Cockerswood House
Stone Hill
Horam
East Sussex
TN21 0JN
(Tel.: 01435 813492)(Mobile: 07972 801914)(e.mail: rodyuill@cockerswood.co.uk)
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08/01/2009.
Mr.
I. Blake
Transport and Environment
East Sussex County Council
C4 Waste and Minerals Policy (AP)
Freepost (LW43)
Lewes
BN7 1BR
Dear
Mr. Blake,
Re: East Sussex County Council Waste & Minerals Care Strategy
Consultation, Land disposal site to the east of Gold Bridge and
south of the A272 between Newick and Piltdown: Policy CS6.
I am
writing on behalf of the 450 members of East Sussex Branch of the
Salmon and Trout Association to object to the planning application
submitted by East Sussex County Council, for the creation of a Land
Raise Tip in the Grisling Common Area between Piltdown and Newick.
The reasons for our objections are as follows:
1)
Waste
Storage:
Disposal of waste to land is the least preferable of all the waste
storage options. Re-use, recycling, composting and energy
generation from waste must be maximised. Further dumping of waste
on land sites is against current recommendations for waste
disposal. Commercial waste producers must be required to invest in
recycling such as the reuse of demolition waste and wood waste
energy production. Dumping on land is the easy option and
discourages investment in other waste processing. Restricting waste
disposal on land sites will encourage investigation into more
innovative and environmentally safer recycling options. Current EU
policy is that landfill (is the term “Landraise” an invention to
circumvent the policy on Landfill?) should be the last resort and
given the pressure to reduce such schemes, increase recycling and
thereby protect our environment.
The Lewes Local Plan, policies ST13 and ST30 require potentially
polluting activities to be situated in an appropriate location, have
an acceptable impact and no negative effects on health or the
natural environment. The ESCC proposals would appear to be in
direct contradiction of these policies. The Lewes Local Plan,
policy ST14 also states “Some development proposals can give rise to
unacceptable risk of pollution, such as landfill/Land Raise”.
Again it would appear that there is little by way of joined-up
thinking between the two authorities.
2)
Transportation:
East Sussex County Council’s own documentation states that traffic
and access are important considerations. None of the proposed sites
are satisfactorily served by the road network and in most of the
sites there are no rail links at all.
This site is some way from the main areas of waste creation, namely
the coastal towns and the inevitable increase in HGV traffic would
adversely affect local communities and road safety.
3)
Brownfield Sites:
East Sussex County Council’s Policy states that priority should be
given to the use of brownfield sites, land adjoining brownfield
sites and former industrial sites for locating Land Rise Waste
Dumps. All of the proposed sites fail to satisfy this test.
4)
Communities:
It is important that these sites are an acceptable distance from the
nearest residential buildings and schools and that the visual impact
is acceptable. The proposed locality is relatively flat with only
gentle undulation. The impact of a 30 metre high artificial hill
would be disastrous and would interrupt the views from footpaths
towards the South Downs and would be easily seen from the Downs.
There is also likely to be interference to public rights of way
including the Wealden Walk.
The proposals will be detrimental to the local community with a
blight of the area with pollution from noise, dust, leachate and
much more additional heavy traffic on a stretch of the A272, already
notorious for accidents.
5)
Leachate:
All of the proposed sites will have an effect on water catchments
for the reservoirs at Arlington and Barcombe. No liners are
completely safe and water contamination is a potential problem for
the future.
The proposed Land Raise is in close proximity to the River Ouse,
one of the most important spawning streams for sea trout within the
Sussex Ouse Catchment. The scheme will affect it adversely, either
by a direct or indirect discharge of leachate generated by the site,
through failure either of on-site leachate management, accidental
spillage or the integrity of the Land Raise itself. The consequences
of contamination on the nearby River Ouse would be disastrous to
this already fragile aquatic environment as well as affecting water
supplies.
6)
Environment and Pollution:
The proposal will threaten the ecology and wildlife of a river
system which has now gained Salmonid designation under the terms of
the European Union Freshwater Fisheries Directive, demanding much
higher standards of water quality. The Ouse is recognised as an
important salmonid fishery, unique in respect of the rapid
maturation to unusually heavy weights of its sea trout population.
In addition it is home to indigenous brown trout and bullheads, the
latter being a species already recognised internationally as being
under threat. The site is a naturalised wildlife environment, which
is home to a variety of species and which as a consequence of human
activity is constantly under pressure. The proximity of a
hazardous waste site will heighten that threat.
Already heavy effluent loads within the Ouse catchment make this
latest application even more worrying, especially since ultimately,
the Ouse provides one of the largest sources of fresh drinking water
in Sussex. Since the recent Environment Agency’s Catchment Area
Management System (Cams) review confirms that there are no other
sustainable sources available for further abstraction, the need to
protect the Ouse from the possibility of further pollution is
absolutely critical
As yet, as far as I am aware, No qualitative or quantitative data
relating to water quality in the Sussex Ouse, or to its ecological
characteristics have been presented. This must be regarded as a
highly significant omission given the proximity of this proposed
development to the river, and the river’s ecological importance
For
all the arguments given above I trust that ESCC will revise their
thinking on this ill-conceived proposal.
Yours
sincerely,
Dr.
R. G. Yuill
Branch Chairman
Cc: N. Soames MP
C. Hendry MP
N. Baker MP
N. Pringle SOCS
J. E. St.Pierre SOCS
P. Knight S&TA
M. Lloyd The Angling Trust
L Holdcroft PAAL