The Round Hill Society

Life near the Dump

Residents living on the north side of Princes Road continue to suffer high levels of odour & noise (and short flurries of swirling dust on windy days) from The Waste Transfer Station, where no landscaping at all has yet been carried out within the southern perimeter of the Hollingdean Depot site.

Landscaping stripped away
instead of preserved & enhanced
in context of the WTS
Much of the Coastways railway corridor, a designated greenway and an important habitat for wildlife, was stripped of trees while the MRF, WTS and Visitors' Centre were being constructed.

Land to the rear of 67-81 Princes Rd in September 2004
Land to the rear of 67-81 Princes Rd in October 2007
The level of nuisance varies depending on wind conditions and work patterns, but the nuisance is very frequent and by no means limited to periods following Bank Holidays when there is a backlogue of black bag rubbish to transfer. The nuisance disturbs residents within their homes and prevents residents enjoying their gardens even at weekends.

I live nearer the Materials Recovery Facility, but several times further from the Waste Transfer Station, than residents living at the NE end of Princes Road (between No. 67 and 81). Nevertheless, pollution from the Waste Transfer Station causes me the most nuisance.

Odour is an almost constant nuisance and is often so strong that I am deterred from using my back garden. It sometimes gets carried to houses on the south side of Princes Road, travelling in gusts of wind up Princes Road and hitting residents on both sides of the street as they open their front doors. One of our local Councillors has described the smell as nauseating. Visitors to my home have described the smell as sickly and similar to what you experience when you are walking just behind a dustcart.

Complaint procedure
If you are troubled by noise, odour or dust particles from The Waste Transfer Station &/or Materials Recovery Facility at Hollingdean Depot, phone The Environment Agency on 0800 807060.
They will log your complaint.

When I last phoned (on Monday 14th June 2010) to report a problem of odour, I was asked to:
i) describe the odour, tie it to particular times, and
ii) rate it on a scale of 1 (slight problem) to 5 (very bad).

I refused to do either, explaining that the description of the odour was no mystery to anybody in Princes Road - i.e. the EA (& anybody working or walking in the vicinity of The WTS) know exactly what the nuisance is already.

I found it extraordinary that an Environment Agency - an institution which I would expect to use more scientific monitoring measures than amateur psychology - should ask me for my own subjective rating of an odour on a scale of 1 (slight problem) to 5 (very bad).

I would not have phoned had I not had significant and reasonable grounds for complaint. I was not in the mood for standard methods of complaint-minimization, but would have preferred to hear what systems are in place for the scientific measurement and minimization/control/management of the odour.

EA's own methodology for measuring odour?
It would be an abdication of responsibility if a regulatory body lacked a scientifically-based system of monitoring the nuisances it is meant to control.

When planning proposals are submitted, Council's require noise surveys & reports and developers employ acoustics specialists to perform scientific measurements. These specialists are expected to describe their methodologies so they can be scrutinized by anybody participating in the planning process. What is passing for science or best practice should always be subject to scrutiny.

I would expect an Environment Agency to use a recognised methodology for measuring whether emissions of odour from a Waste Transfer Station are at reasonable and acceptable levels. Also the public ought to know, in scientific terms, what levels are deemed to be acceptable.

Instead, it seems that the system is complaint-based, and the Environment Agency wants local residents to log reports of unreasonable nuisance when they are troubled by odour, noise or dust, so that they have a sufficient evidence base of significant nuisance to require action from Veolia. Effective action could mean paying the cost of an Odour Control Plant and finding space to install it at Hollingdean Depot. If it were a choice between accommodating an Odour Control Plant or a Visitors' Centre designed to give Veolia good public relations, some residents might suggest that the better route to good PR would be to create less nuisance to immediate neighbours.

Absence of Odour Control Plant
Technology exists (see PDF File) to reduce levels of odour. It is claimed that Odour Control Plants are capable of reducing the odour levels emitted by over 95%. Such a plant was recently successfully installed and commissioned by the contractor Simdean for the client Oxigen Environmental. The contractor claims to have solved the problem of odour emissions from a Municipal Waste Transfer Station.

By comparison with Simdean's system, odour management at Hollingdean Depot seems to be very poor, consisting mainly of the use of deoderants and planning conditions (which are not always observed).

The absence of an Odour Control Plant at Hollingdean Depot is most likely to be a question of cost. If space is also a problem, then The Council knew that, in choosing to attempt to locate both the MRF and the WTS on the same site, it was going to be a tight fit, which did not even leave adequate room for landscaping these industrial installations at the boundary (to the south) with The Round Hill Conservation Area.

Residents living in part of Edinburgh have just won their fight to have an appeal for reconsideration of a giant Waste Transfer Station in their area dismissed. It was ruled that the development would have damaged the character and appearance of the Portobello conservation area. The appeal was mainly dismissed because of the impact on visual amenity.

Visual Amenity V Odour, Dust & Noise
Residents from The Portobello PONGS Campaign Group wrote to thank The Round Hill Society for sharing comment on the nuisances of living near a Waste Transfer Station, but they lamented the complacency of the authorities in relation to odour, fugitive particles and noise pollution.

It (The victory) cost our ‘village’ community a lot of time and effort but reading Round Hill’s lists of noise, pong and airborne dirt – well it gave us extra determination!

The only annoying thing is that the judges listened only to the arguments made regarding the aesthetic look of the building rather than the other more vexing pollutants – these were dismissed as manageable and would be ‘subject to license’.

Obviously we would be in your situation had they also dismissed the “visual loss of amenity” and allowed the application.

Had permission been granted for the Waste Transfer Station effectively opposed by The Portobello PONGS Campaign Group, then the licencing body which would have had to manage the nuisances described as "more vexing than loss of visual amenity" would have been The Scottish Environment Protection Agency (SEPA) - the Scottish counterpart to The Environment Agency (EA), the regulatory body in England and Wales.

The Scottish Appeal Inspector's confidence that SEPA could manage odour, noise and fugitive particles, might well rest on knowledge of emerging technologies, such as Odour Control Plants to deal with the more vexing nuisances which Waste Transfer Stations cause to residents living nearby.

Detrimental Impact
The decision on 9th June 2010 by members of Brighton and Hove City Council’s Planning Committee to refuse Carelet’s application (no ) to build 6 three-storey houses on the greenfield site (to rear of 67-81 Princes Road) cited Detrimental Impact on future occupiers due to the proximity to the Hollingdean depot. among its reasons for refusal.

Reference was made by the Princes Road resident who spoke against Carelet's proposal to the nuisances she suffered living significantly further away from the WTS than Carelet's prospective residents. She also cited Councillor Pete West's statement on the very unpleasant odour that he had witnessed first-hand as a pedestrian in Princes Road and adjoining streets.

The item on Carelet and The Waste Transfer Station illustrates the folly of housing new residents still nearer to Hollingdean Depot, where there is currently no Odour Control Plant to limit bad smells to a reasonable level and where the levels of noise would also make garden use & window-opening very unattractive.
Carelet's design proposed a ventilation system so that window-opening at third-floor level would not be necessary, but it was observed that ventilation systems were not always quiet themselves.

Complaining to the EA 0800 807060
It is really up to local residents to monitor whether they are being observed, because Veolia just gets on with its work. The terms of its licence do not require it to monitor its operation, though the company was asked by The Environment Agency last summer to implement an Odour Management Plan in response to a spate of complaints from local residents. Initially, many complaints were about noise. Through winter 2009 and Spring 2010 most of the local nuisance has been caused by odour.

These facilities are meant to operate within
1) the terms of their licence from The Environment Agency and
2) in accordance with the Council's planning conditions.

Breaches of the EA's operating licence
If you are troubled by noise, odour or dust particles from The Waste Transfer Station &/or Materials Recovery Facility at Hollingdean Depot, phone The Environment Agency on 0800 807060. They will log your complaint.

Breaches of Planning Conditions
Details of The Local Council's Planning Conditions are given here.

The Council's planning conditions, which include condition 16 requiring doors of the MRF/WTS to be kept closed when lorries are not going in or out, are somewhat different from those set by The Environment Agency, which grants Veolia a licence to operate its facilities.

If one or more of the Council's planning conditions are being breached - e.g. condition 16 forbids leaving doors open while no vehicle is entering or leaving the WTS/MRF - contact Scott Castle, Brighton and Hove City Council's Senior Environmental Health Officer on 01273 292248
email: Scott.Castle@brighton-hove.gov.uk

Keeping a nuisance diary
During the early summer of 2009, the Environmental Health Officer suggested that local residents should keep diaries (click here for SAMPLE DIARY) to log the nuisances caused by the WTS and MRF.

The SAMPLE DIARY mainly documents and illustrates the problem of noise, though odour is now (in 2010) reported by many local residents as the major nuisance.

Reporting systematically and for significant periods of time on unpleasant nuisances has the disadvantage of making them the centrepiece of residents' lives. Should it not be the wider public purse (Council & EA) which is monitoring these nuisances? Are the Council and EA not abdicating their responsibilities by making the residents most affected by pollution into the front-line monitors?

Logging local residents' comments
Please let us know as well
Click here to File a report with The Round Hill Society on any problems with the WTS or MRF.

Let us know who you are and where you live. Unless you are a local politician, we will not reveal your identity in relaying comments. It helps to relay a few, since it is reassuring for residents to know that they are not alone and their faculties of smell and hearing do not differ from the norm. If the comments stop, then the monitoring agencies may assume that conditions have got better or the local community has got used to the level of nuisance. However, it is important to keep the comments genuine.

Local residents' comments
local resident's comment - 13 Feb 2010 - lady in Richmond Rd reports that she has to keep her windows closed and enjoys being out in her garden far less as a result of the nuisance caused by odour from the WTS

Wastewatch comment - 10 Feb 2010
"Horrible acrid smell for most of afternoon Tuesday 9 Feb on Princes Road, and in our garden. This is almost daily I can smell the WTF in Princes Road."
(Householder living towards the west end of Princes Road)

Comment from Hollingdean - 6 Feb 2010
Rob Stephenson receives a phone call from a lady living off Davey Drive (Widmore Close) saying there was a terrible smell from tip last week (the last week of January).

Wastewatch comment - 26 Jan 2010
"There has been an appalling smell every day for the last week or so in Princes Road. Particularly bad in the mornings"
(Householder living near junction of Princes Rd and Crescent Rd)

Ward Councillor's comment - 24 Jan 2010
On the morning of 24th January there was a very strong and unpleasant odour present along the whole length of the road. It was strongest at the top, nearest the Waste Transfer Station. Personally I found it quite nauseating. One resident near the top of the road stated that this was not an unusual state of affairs, the stink from the dump is present at least twice a week regardless of busy or difficult periods around the holidays or as experienced with the disruption caused by the snow. I am pretty dismayed by this, as ward councillors have been repeatedly assured that smells are contained and neutralised. I also noted that the noise from machinery at the WTS was pretty loud, and this is contrary to reassurances we have been given too. Cllr Davey and I visited the site earlier last year and were told the problems experienced at the beginning of last year were teething troubles now resolved. This seems does not seem to have been the case, can you explain how it is that these issues have persisted and what contractors are being asked to do to prevent them.
(Cllr Pete West).

Waste left uncollected:
odour in & around Hollingdean Depot
Veolia's John Collis admitted to local residents that "black bag waste will start to smell if it is not moved on the same day or the day after." (Under Veolia's licence the black bag waste can be stored in the Hollingdean WTS for up to 72 hours.)
There is going to be some odour, but expect the problem of containing it to be more difficult during hot weather. Icy roads are just one reason why waste may be left uncollected for more than 24 hours. Industrial action is another. Smelly waste taken in by the Waste Transfer Station at Hollingdean Depot could come from far and wide, not only Brighton and Hove. When it does, as was the case last July and August during hot weather conditions as opposed to a cold spell, Veolia ought to have an odour management plan in place other than sending us letters of apology like this one:
"We thank you for your understanding"
Dear Sir or Madam

Hollingdean Materials Recovery and Transfer Facility, Hollingdean Lane Brighton - Requirement for Saturday Working on 23rd and 30th January 2010

Veolia Environmental Services has been requested by Brighton & Hove City Council's Waste Collection Authority (WCA) to seek planning consent for a temporary variation to conditions 5 and 6 to enable operation of the Hollingdean Materials Recovery -Facility (MRF) and Waste Transfer Station (WTS) on Saturday 23rd January and Saturday 30th January 2010. This consent has now been granted.

The request results from the WCAs need to continue to catch up on its refuse and recycling collection arrangements following the recent period of heavy snowfall and we are assured by the WCA that this requirement to work on Saturday is as a last resort and all collection rounds will be carried out during weekdays wherever possible.

We are very conscious of managing the site with a view to limiting odours. However, while you can be assured of our commitment to taking all reasonable measures to try to ensure an odour issue is not created which may cause a disturbance to local residents, the recent adverse weather has resulted in an increase in waste delivered to the facility over a short period of time. This could lead to some increase in odour because Brighton & Hove City Council was unable to collect waste during the period of snowy and icy conditions and therefore waste has had to be left uncollected for significantly longer than usual. We will endeavour to mitigate any such odours and we will, of course, continue to operate the facility in accordance with all planning and licensing requirements.

We thank you for your understanding as we try to assist Brighton & Hove City Council to return to normal services and can assure you that every reasonable effort will be made to minimise any disruption to you.

Yours faithfully

On behalf of
Veolia Environmental Services

Nuisances for residents in Princes Road
Summer 2009

The Council's sparse resources for enforcement affords little protection to neighbouring residents in relation to noise, odour and fugitive particles


Note that: Condition 16 was set by Brighton and Hove City when granting planning permission for the WTS & MRF. It is not part of the operating licence for these installations issued and monitored by The Environment Agency. Its observation depends on the resources available to the Council to enforce its planning conditions, of which there are thousands altogether!


Drying fields or dirt trap?
Historically, land surrounding Princes Road used to be very suited to drying laundry because of the windy conditions up on Round Hill. I have dried my washing outside since moving here in 1977.

The dust now blown into neighbouring gardens from the newly operating Waste Transfer Station escapes the high pressure cleaning equipment used within the perimeter of Veolia's site to control the level of odour, mud and litter.

Along with odour from The Waste Transfer Station, this dust ends up on clothing, towels and bed linen hanging on washing lines on days when gusts of wind carry it in a south westerly direction.

Let-out clauses to allow pollution of surrounding neighbourhoods
However, under condition 3.3 of the Environment Agency's Licence (Number EAWML 100185), Veolia has not breached its permit if appropriate measures have been taken to prevent or where this is not practicable, to minimise, the litter and the mud.

Is it right that the licence from the Environment Agency permitting the Waste Transfer Station at Hollingdean Depot to operate, gives Veolia "let-out clauses" allowing them to pollute local neighbourhoods with noise, odour, litter, mud and particles of dust?
Ambiguity about whom to complaint to

The Council's Environmental Health Officer is now asking for complaints to be directed to The Environment Agency.

However, dust particles, noise and odour are obviously more likely to be emitted from The Waste Transfer Station when doors are left open.

When I complained to The Environment Agency about breach of The Council's Condition 16 regarding the doors (see The Council's planning conditions), I was told that this condition was not covered by The Environment Agency's permit and was therefore outside The Council's remit. The 53 planning conditions imposed by the Council when granting permission for the WTS & MRF are not the same as the conditions within The Environment Agency's permit.

Abdication of responsibility for planning conditions
On whose authority can the Council abdicate responsibility for enforcing its own planning conditions, directing residents who suffer nuisance and pollution to an agency whose remit is not the same?

The Council's Environmental Health Department supported the recommendation of The Case Officer (Maria Seale) who was minded to grant permission for the WTS & MRF within a site known to be "tight" and located near to several residential dwellings. Surely, The Council's Environmental Health Department cannot abdicate responsibility from fielding complaints which are not within the remit of the Environment Agency.


Nuisances reported in other areas
Ed Start's observations
Below are further observations by Ed Start, who played an active role in the Dump the Dump campaign.

Life near/around the MRF has, I believe, gone largely as we believed it would and as was discussed in the report that Dump the Dump presented to the LA and GOSE (ignored by both bodies, I would add). To my knowledge there have been such occurrances as;

1. Problems at the infant school in Ditchling Rd. with smells from the operation, this may well have affected those at the neighbouring flats and in Princes Road. This also happened when doors on one of the WTS sheds were left open last summer. None of this is a surprise, the same thing happened when meat rendering was carried out on the site when it was an abattoir and parts of the school had to be sealed-off, windows kept closed and playgrounds vacated. This fact was mentioned during the consultancy period but ignored by planners and the authority, although Veolia did hint in their plg. application that this would occur.

2. Light pollution from the site is a problem at night, this would affect those in the immediate area. The site is in use 24 hrs. for street cleaning vehicles to access the WTS. Predicted.

3. I understand that there may be a problem with the type of transfer vehicles used to remove waste from the site - possibly they are not of the type/specification that Veolia said they would be - not a surprise but still impacting upon the restrcted access in Hollingdean Road.

4. Changes to the traffic junction/lights at the Upper Hollingdean Road/Ditchling Road junction have meant that this is a crossing that is much more dangerous for anyone to cross (mid-road islands have been removed, crossing periods are very short for school-bound users, etc.). When an objection to these changes were raised we (school governors) were told it was to make the crossing safer (local councillors voted for them!), in reality it was to facilitate access for waste vehicles and re-cycling trucks to access the WTS/MRF. Traffic volumes of this type of vehicle have increased hugely. In addition to an increase in waste vehicles the removal of the left turn from Ditchling Road for HGV's has resulted in a significant increase in such traffic using the route to get to Sainsbury's and the meat market, as well as the B&Q/Halfords/Comet sites in Lewes Rd. (When, as a school governor, I mentioned to the consultant engineer that the crossing was now far more intimidating for parents/children to cross, he replied that it was supposed to be intimidating! The Council's traffic engineers just smiled.)

The conclusion must be that the MRF/WTS is inappropriately positioned in such a highly residential area. The really sound strategic decision would have been to re-locate the whole Hollingdean yard facility, inc. WTS/MRF to a site(s) at the edge of the city, to deal with waste on a more localised basis and using more up-to-date technology/processes.

The planning permission also gave Veolia the option to bring in waste from outside of the city - not sure if this has been done yet, but with the problems at the Maresfield site, this may be happening.

I think that the opening paragraph that we used in our report is still, even more appropriate;

“Waste transfer stations are disproportionately clustered in low income communities...they are commonly found adjacent to high-density housing. In addition to quality of life issues such as noise, odour, litter, and traffic, WTS’s can cause environmental concerns associated with poor air quality (from idling diesel-fuelled trucks and from particulate matter such as dust and glass) and disease-carrying vectors such as rodents and roaches.”
National Environmental Justice Advisory Council – U.S. Environmental Protection Agency1

As is not uncommon in the UK, we have gone for out-dated technology and processes, which have been determined and decided upon by ill-informed planners and councillors. Will it change? Probably not.

Regards,
Eddie Start

SUMMARY
What specifically do residents want their local planners and political representatives to address?

1a) Pollution in the form of noise, odour and dust particles, permitted to escape through the frequently opened doors of a Waste Transfer Station, causing nuisance to nearby residents.

1b) The continued absence of adequate landscaping.

1c) The poor construction of the WTS/MRF buildings RE containment of the pollution: the lack of double doors/filtration.

1d) Profit / cost minimisation before people's health.

1e) Operating Licences (licences to pollute) which fail to set precise limits to manage AND PREVENT odour/dust particle/noise pollution. Instead, the Environment Agency's ongoing system of regulation requires local residents to suffer (i) POLLUTION EVENTS and (ii) sufficient anger and stress to telephone whichever of their officers is logging complaints.

The terms of the licence to pollute given by the EA to Veolia (which is not obliged to monitor the effects of its operation) then leave it to the discretion of the EA's officers as to whether (iii) to believe local residents or (iv) require Veolia to take any action.

The protection of public health is the duty of EA. Making the mechanism conditional on complaint neither respects the mental or physical health of the worst affected residents. The EA's mechanism guarantees rather than controls pollution. Intervention in fact depends on ongoing low-level torture of pollution victims, avoiding the (more costly?) scientific checks which a reputable EA should be using to carry out its duties.

1f) The polluter's requests for "lenience RE the problem of odour during weekends following Public Holidays" should trigger sanction by the Environment Agency rather than be allowed to try the patience of local residents.


This page was last updated by Ted on 28-Jun-2010