Rivenhall Airfield Public Inquiry.

Brooks' letter to the Rivenhall Airfield Public Inquiry.

As both the local Member of Parliament and a resident living in Bradwell, I have concerns about the proposal APP/Z1585/V/09/2104804 sited at Rivenhall Airfield, Coggeshall Road, Braintree, Essex.

I have been contacted by a number of constituents who are gravely concerned about this proposal, many of whom have outlined well-argued and informed reasons for their objections. I anticipate you will also be receiving substantial correspondence from those who stand to be affected by the proposed development.

Before summarising the concerns of my constituents, I would like to express my own personal views on this matter. I do endorse practical and sustainable development in our local area and, as such, I was persuaded on the merits of the original proposal for Rivenhall Airfield of an Anaerobic Digestion plant and a Materials Recovery Facility to separate recyclable materials. However, I have always opposed the construction of an incinerator at Rivenhall. I believe this is neither in keeping with the needs of our local community nor countryside and, as such, I have already expressed my deep reservations to concerned parties.

Furthermore, I am concerned that the current proposal appears to have been ‘tacked on’ to the previous application which was much less controversial; for example using similar scientific evidence and assessments on the local impacts, despite this being a radically different scheme than its predecessor. I do not believe that the nature of this project ‘creep’ has been well-received by local residents.

Residents need full and frank clarity on exactly what is being proposed, the potential impacts and the steps that can be taken to remedy these. However, to date, I am concerned that the planning application process may not have been as transparent as possible in this case. Unfortunately, I fear this has led towards greater confusion and often greater antipathy towards any development at the Rivenhall Airfield site.

Local residents also deserve the opportunity to present their own thoughts and concerns on this development, which may impact so significantly on our local area. Thus, I very much welcome the public enquiry on the proposed development, and I do hope that this will go some way towards removing the information gulf that currently exists on this issue. No doubt you will be receiving strong representations about the proposal from local groups.

In light of the many strong objections that have been voiced to me by constituents about this planning application, I have summarised them below.

Environment

• This development will be sorely out of place in a traditional rural English village;
• The site is apparently labelled as brownfield; however, it does contain good-quality grassland and woodland and the proposed development could result in the loss of 11.5 hectares of Grade 3a agricultural land;
• The proposed development would result in the loss of or damage to the habitat of five EU/UK protected species (bats and newts), the loss of TPO trees and TPO woodland, and the loss of habitat of brown hares and 66 species of birds;
• The Environment Agency has identified the plant has the “potential to produce significant odours, bioaerosols, contaminated water and fugitive emissions”, proving harmful to both local residents and flora and fauna once the plant is in operation;
• 35 metre high chimney stack - planning officers have apparently suggested this will become a local landmark, contradicting their earlier statement that the plant would blend into the countryside. I understand a chimney of this height is also one that the Environment Agency would not normally approve;
• Inadequate mitigation measures for visual pollution; for example, the plan to screen the plant with deciduous trees would offer little or no screening in the winter months. Even in the event of screening, parts of the plant, and particularly the chimney, would protrude over the tree line;
• Light and noise pollution by continual operation of the plant would prove detrimental to the environment both by day and night, in what is a traditionally quiet and non-built-up area of the countryside;
• Increased demand for freshwater from the ground and the nearby River Blackwater.

Traffic

• Original proposals stated approximately 400 HGV movements per day. The new proposal has more than doubled the tonnage capacity, yet I understand the expected HGV movements remain unchanged. This raises questions as to whether the new proposal has fully evaluated the implications of its changes upon local infrastructure;
• Despite a significant amount of building works traffic and the constant stream of HGVs once the plant is in operation, there appears to be no concomitant improvements planned for the local transport infrastructure;
• This heavy traffic would be forced to travel on small country lanes, crossing two public roads, including a Protected Lane and the Blackwater Special Landscape Area, then join the single carriageway, the A120, and an already heavily congested A12. Questions of road safety for both vehicles and local residents, along with the detrimental impact on roads simply not built for this amount of heavy traffic, have been raised.

Impact on local residents

• The proposed development may seriously undermine the traditional rural nature of this parish, which is the very reason many residents chose to live here in the first place;
• Rivenhall Airfield is in close proximity to homes, schools and local heritage sites. For example, the model garden village of Silver End, of which around a half has Conservation Area status, is 1km away, and part of the application site also contains listed buildings at Woodhouse Farm, whose setting would be threatened by the large chimney and coach and car parking. Footpaths also pass in close proximity, including the F8 only 300 metres away;
• Unknown health implications for local residents; for example, uncertainty exists over the wind direction data used by the developers. There are suggestions that, on average, the wind would blow emissions towards Silver End for about 73 days per annum, towards Cressing and Braintree for 33 days per annum, towards Bradwell/Pattiswick for 40 days per annum, Coggeshall for 106 days per annum, Feering for 40 days per annum, Kelvedon for 51 days per annum and Rivenhall/Witham for about 22 days per annum;
• Storage of the waste before it is processed runs the risk of attracting vermin and insects;
• Local residents are concerned that for all of the negative impacts they are expecting, there is yet to be any evidence provided that the application will bring benefits to either them or the local area.

The Proposal

• There are concerns about proposal ‘creep’ from the original and less controversial application, to a now substantially larger development. For example, at 25.3 hectares, the current proposed site would be over four times larger and the proposed buildings 25 times larger than originally stipulated in the Essex Waste plan. I have been informed that this is also in breach of the Inspector's (accepted) recommendations;
• A 360,000 tonnes per annum waste incinerator volume is in breach of the public pledges made by the County Council that no such plant would be developed in Essex;
• The public are concerned that this development has been misrepresented to them and they have, thus far, not been adequately involved in the consultative process; for example, at a planning meeting I understand only 3 local representatives were permitted to attend;
• Recycling has increased at the local level, but this plant will be one of the largest in Europe and is designed to process more waste than North Essex produces, thus questioning the proximity principle;
• A constituent has informed me that the application is in breach of 22 Braintree District Council local planning policies, 1 Saved Essex Structure planning policy, 9 Essex Waste planning policies, 8 East of England planning policies, and 9 PPS and PPG national planning policies. Furthermore, some local councils are not supportive of the application;
• Concerns about the bias of Essex County Council in voting for the planning application; for example, that there exists a ‘letter of understanding’ between the Council and the developers with regards to incineration dating back to 2006, amounting to suspicion of a pre-determination of the planning application.

As the elected representative of those affected by the proposed development at Rivenhall Airfield, I believe I have a duty to voice these strong concerns to you. Furthermore, as a local resident myself, I do agree with some of the points raised by my constituents. As such, I would be grateful if the evidence and views presented here could be taken into consideration when reviewing the proposed development, in order that a well-informed decision is reached which takes account of both national priorities and the needs and wishes of local residents.