The Round Hill Society

Carelet and The Waste Transfer Station

On 9th June 2010, members of Brighton and Hove City Council’s Planning Committee refused Carelet’s application to build 6 three-storey houses on the greenfield site (to rear of 67-81 Princes Road). Most members went against rethe planning officers' "recommendation to grant”, voting 8 AGAINST, 2 FOR, with two members not taking part through declarations of interest.

The grounds for refusal were :
1) Failure to meet travel demand (parking)
2) Over development
3) Detrimental Impact on future occupiers due to the proximity to the Hollingdean depot.

It is likely that the developer will appeal against refusal, so local residents interested in securing this recent victory could help by defending the grounds for refusal as soon as an Appeal Inspector offers a window of opportunity for further representations.

The column below provides information which could prove useful for defending ground 3): Detrimental Impact on future occupiers due to the proximity to the Hollingdean depot


Opp the MRF & WTS is "the wrong place"
Carelet's prospective residents would look into the gap between The Materials Recovery Facility and The Waste Transfer Station. They would be the nearest local residents (by far) to the main sources of nuisance. Residents far further away are keeping north-facing windows closed. If Carelet's residents attempted to use their north-facing gardens, their recreation is most unlikely to be undisturbed. They would have to get used to odour both from within the WTS where doors are too often left open even while tipping is in progress (see pictures below) and from dirty lorries using the yard. The sound of high pressure cleaning equipment and the beeping of reversing sirens would be a regular noise nuisance, as would be the rumbling within both MRF/WTS sheds and the sound of glass being tipped.

The proforma letter of comment we prepared when opposing the recently unsuccessful proposal, includes reference to the awful outlook that Carelet's prospective residents would experience.

Previous proposal unviable
The decision to grant Carelet, planning permission for four houses on Wednesday 22nd July 2009 subject to several planning conditions has fortunately not damaged our area, because the developer cannot find anybody to build this scheme who thinks it is viable. Excavating the gatehouse and work on the greenfield site's eastern and northern boundaries would present major challenges. Then anybody thinking of selling houses on the site has to think who would want to buy them in a location where it is already known that noise, odour and dust are causing problems to residents whose homes are several times further away from the nuisance sources.

If the homes did sell, then there would almost certainly be a new front line in the protests and complaints at the nuisances (Noise, Odour, Particulates) currently being experienced by residents living in the vicinity of The Waste Transfer Station.

Defective Noise Assessment

The noise assessment, performed by Anderson Acoustics, was the main source of confusion for Planning Committee members considering Carelet's last unviable proposal. Carelet is using the same defective noise assessment with its current proposal.

Members of The Planning Committee were being asked to accept that the night-noise of trains (which don't in fact operate between 00.21 and 05.43) was the main noise nuisance worthy of mitigating measures. By comparison, 'day noise' nuisance from the MRF and WTS, was deemed to be unimportant and not to be considered as a determining factor in granting or refusing planning permission. Could it be that the banging, tipping, rumbling, beeping, high pressure cleaning noises are all the products of existing residents' imagination? Should they be focusing their complaints on ghost trains instead?


Carelet's solution to the problem of noise was initially to offer the Council a noise assessment performed in Oct & Nov 2006, before both the WTS and the MRF existed, and based on the location of the 8 houses in their previous design. There is no smell assessment with their supporting documents, but a recent noise assessment, performed AFTER the formal deadline for comment ended, was added to the developer's Supporting Documents on 5th June 2009.

Ghost trains passing during the night?
The latter incredibly finds that the need to mitigate against night noise, especially the noise of trains (regardless of the fact that they don't operate between 00.21 and 05.43!) warrants some measures by the developer. However, day noise is not seen to be a reason for refusing development.

'Day noise' is the noise measured between 7 a.m. and 11 p.m. Hollingdean Depot is open seven days a week from 7 a.m. to 6 p.m.

'Night noise' is the noise measured between 11 p.m. and 7 a.m. Stricter regulations apply to 'night noise' in determining nuisance, but it is still puzzling why the Council's Environmental Health Officer should be more concerned with 'Night noise' from trains than the 'Day noise' from The WTS and MRF. The last train from London Road to Brighton departs at 00.21 in the night and there is not another one until 05.43 in the morning. The last train from London Road to Falmer departs at 23.37 and there is not another one until 05.48 in the morning. How then is 'Night noise' from trains more in need of mitigation that the 'Day noise' from the Dump? Anderson Acoustics' study contains continuous measurements, but has anybody bothered to define what noises are being picked up between 00.21 and 05.43 - the critical hours of sleep?

Come 7.a.m, we are into 'Day Noise' and the WTS & MRF start operating, but between 7 a.m. and 8 a.m. five slow trains pass Carelet's site in the direction of Brighton, five more slow trains pass in the direction of Falmer (7.03 7.13 7.25 7.43 7.55) and also limited stop trains pass (going between Brighton and Ashford International). There are relatively few trains from 23.00 to 07.00, but at least 12 passing trains an hour between 7 am and 9 am. There is a similar supply of commuter trains to take workers or students home in the evenings.

Are trains being used as smokescreens?
Unless we know what 'Night noise' the Environmental Health Officer was worried about, I can only assume that the reference to 'Night noise from trains' is a smokescreen. I hear all the noise from trains and all the noise from the WTS and MRF. I am puzzled by the reluctance to acknowledge what local residents are identifying as their main noise nuisance. Could it be that acknowledgement of the extent of the nuisance would embarrass The Council's Environmental Health Department, since this very department gave the OK for the WTS and MRF to be granted planning permission?


Anderson Acoustics present a 7-day log of Continuous Noise Monitoring Results recorded between Wednesday 27th May 2009 and Tuesday 2nd June 2009. They even claim that their noise readings were lower than those they recorded before the MRF and WTS were in operation during the week leading up to fireworks day in 2006. The reason they give for lower readings is not the fireworks, but the fact that their microphone position in the 2009 assessment was level with the northern building line for the four planned houses, which will be set back from the railway. The 8 homes proposed previously had few windows opening towards the railway, but were set right up against it. However, the 4 approved homes have their main amenity space in the form of small private gardens going right up to Network Rail's land.

Residents whose homes are four times further away than the homes about to be built have been claiming that day-time noise is intolerable.

Are existing residents exaggerating?
Unless existing residents are guilty of extreme exaggeration, as the report from Anderson Acoustics would suggest, then Carelet's new residents are going to find their living conditions (at least their outdoor amenity space) intolerable.

The Council's Environmental Health Department approved the MRF and WTS in the first place, so this might explain the Council's reluctance to accept the allegations of noise and smell nuisance. They have asked existing residents to keep noise and smell diaries. On submission of these diaries, residents have been asked if they are willing to direct these allegations at specific targets and to take them to a Court of Law.
Specific allegations?
However, the target is all users of the MRF and WTS and the banging, rumbling, tipping, echoing, beeping, high-pressure cleaning noises which are the net result of a busy day at the Dump. It is silly to make specific allegations when the nuisance is the general operating noise both within the sheds and in the yard outside.

“Night Noise” versus “Day Noise”
It is something of a mystery to local residents as to how Anderson Acoustics report manages to minimize the nuisance caused by 'Day Noise' and to find 'Night Noise' more of a problem. Everybody living in Princes Road witnesses that 'Day Noise' is the problem.

A new front line
Within a year, there will probably be a line of residents who are almost twice as near to the Dump as the nearest existing house. Their gardens will just be the width of a two-track railway from the southern perimeter lorry-run of the Waste Transfer Station and not much further from the actual shed.

How far will the new properties be from the WTS?

At the Planning Commitee Meeting on 22nd July it was telling that it took some time for the officer to provide this crucial information, which should have been directly to hand. When 35 metres was cited as the proximity to the WTS, the measurement was from building to building and not even from most northerly point of the new residents' gardens to the lorry-run on the southern perimeter of The Dump. Good practice under CABE guidance requires a distance of at least 20 metres between existing and new lines of residential dwellings to safeguard privacy and prevent nuisance. However, an enormous WTS (which is causing massive noise nuisance to residents on both sides of the summit of Princes Road) is just 35 metres away!

Further evidence
Anderson Acoustics report merits some scrutiny from an expert who is not acting for the developer. My guess is that it may get this scrutiny in the future and another noise assessment performed.

Plan to house new residents nearer!Residents lower down Princes Rd (NE end) are even more exposed since all adjoining trees on both north and south railway embankments have been removed. Hence the need to prevent the loss of Carelet's greenfield site to quite unsuitable residential development, since this green buffer-zone is needed more than ever for landscaping.

Below: greenfield site where Carelet wants to house new residents several times nearer to the noise and smell than anybody else

An open space vision Reinstating the boundary features which Network Rail and Carelet have removed is very necessary to dampen noise and conceal eyesores. Planting will have to be well within Carelet's greenfield site so trees are not removed again by Network Rail and blockage of gutters belonging to the end warehouse on the Centenary Industrial Estate does not reoccur.

Environmental Health
Last time round, The Council's Environmental Health department recommended approval for 8 houses on the basis of a noise assessment performed before the WTS & MRF were built.

The report sent to The Case Officer RE Carelet’s previous application BH2007/04444 by The Council’s Environmental Health Department, refers to measures in the developer’s previous design to mitigate both for noise and any activity related noise from the waste facility. (See The Plans List 18 JUNE 2008)

Environmental Health: Are satisfied that work has been carried out by Anderson Acoustics noise assessment; noise assessment; noise assessment - appendix a; noise assessment - appendix b; to assess the potential noise impacts and additionally some contamination investigation has been carried out by Ashdown Site Investigation, the report of which have been submitted with the application. Note that the noise report was carried in October/November 2006 whilst the site was relatively vacant. The site has now been developed for the materials recycling facility and waste transfer station, however are satisfied that the proposals made in the acoustic report will mitigate both the railway noise and any activity related noise from the waste facility. Recommend approval and conditions for contamination/gases site investigation and remediation work and noise mitigation measures.

Carelet has submitted the same noise assessment (performed in October/November 2006 prior to construction of the MRF and WTS) for its new design, even though the MRF and WTS are now operating.

Surely it is essential for a 2009 noise assessment to be performed, especially since Carelet’s current proposal (Application 2009/00847) involves a completely different design. The main amenity space (in the form of small gardens) is now located on the Hollingdean Depot side of the proposed properties. The north elevation of the proposed buldings is now much more open, with much more window-space planned for each house.

Noise assessment relates to an entirely different design
Incredibly, Carelet is now offering the Council's Environmental Health Department a noise assessment performed in October/November 2006 relating to a completely different design. The mitigation method referred to in Section 6.0 is "siting the terraced houses close to the railway to act as a noise screen to the proposed front gardens and terraces."

In the current application, there is no such arrangement! The proposed gardens would be at the back right up against the railway, on the north side of the proposed houses.

There is no longer any noise screen for prospective residents either for their gardens or for their homes. In this application, there is far more window space, including opening windows on the north side, instead of the heavy soundproofing and oblique views proposed in the previous design.

Moreover, the residents' gardens (their main amenity space) will not only be facing the railway (with at least 8 passing trains per hour throughout most of the day). They will be facing the main lorry entrance of the MRF and WTS too, and in close proximity to the main door the lorries use to go into the WTS, which on occasions remains open for much too long.

Proposed houses which are 5 times nearer to the railway than existing houses can be expected to get 25 times as much noise.


Lobby Planning Committee RE: City Cramming
A) Impact on longer views into Round Hill from the north & east
B) Failure to consider residents' transport needs in a hilly area
C) Inadequate access would involve damage to a protected tree
D) Separations between existing (67, 71 & 73 Princes Rd) and proposed homes fall far short of 20M.
E) Gardens proposed would look into the main yard of MRF and WTS. Insufficient space for adequate screening.

This page was last updated by Ted on 10-Jun-2010