Ashdown Brickworks is first choice for a vast new landfill site

Article By Ben Higgins: Published Date: 01 October 2009
Bexhill Observer October 2nd 2009

East Sussex County Council named the Turkey Road excavation as their preferred choice in a 133 page document released this week outlining their core strategy for waste production in Brighton and Hove and East Sussex until 2026.

At a meeting last Wednesday, ESCC Cabinet approved a planning timescale which sees applications discussed next year and work beginning in 2012.

Key local figures reacted swiftly to the news, with local MP Greg Barker calling a public meeting to launch a campaign against the proposals.

Nick Hollington, chair of the Bexhill Against Landfill Incineration group, labelled plans: "a pernicious proposal with a devastating effect on the whole town of Bexhill."

Rother District Council also oppose the plans. In a meeting on Monday, Nick asked Leader of the Council Carl Maynard if he recognised "the egregious effect such a landfill, if implemented, would have on the town of Bexhill and that it would set back, if not nullify, the Council's efforts to achieve its regeneration?"

Cllr Maynard responded, saying: "Rother District Council had consistently and fundamentally opposed the inclusion of the land at Pebsham and Ashdown Brickworks in the Waste Local Plan."

The relevant section of the waste plan reads, under the Preferred Option Selection heading: "The Waste Local Plan currently allocates Ashdown Brickworks as potentially suitable for Landfill."

"Ashdown Brickworks offers a substantial mineral void close to one of the major urban areas of waste arisings in East Sussex and Brighton and Hove."

Having been cleared by ESCC, the strategy now looks set for approval by Brighton and Hove City Council on October 15.

A six week period of public consultation will follow.

From October 21 to December 2, organisations such as BALI and Rother District Council, as well as members of the public, have the opportunity to submit their views. Details of how to contribute to the consultation will appear from October 21 2009 at an ESCC subsite: consult.eastsussex.gov.uk

Depending on levels of waste growth, it is estimated that between 34 and 37 million tonnes of waste will be produced by East Sussex and Brighton and Hove between 2011 and 2027.

With recycling taken into account, and the work of a new incinerator planned to open in Newhaven in 2012, the final figure for waste pumped into the new landfill by 2026 is estimated at 4.5million tonnes.

There are currently no restrictions on the type of waste that would be dumped.

The strategy does indicate other areas that could be considered, mostly around Uckfield and Lewes, but Ashdown Brickworks is the only confirmed specific option.

Nick Hollington, who will represent BALI in a consultation meeting with ESCC on November 5, said: "I think they are only going to look elsewhere if Ashdown is turned down as a location. If, as we hope to do, we come up with reasons why Ashdown is unacceptable. Then they will look at these areas of search."

BALI will argue the landfill will create an unacceptable impact on the local environment and communities.

Supporting this, members may mention the estimated 4,000 residents of west Bexhill living within one mile of the site, the flagship new High School half a mile away, the adjacent Bexhill Cemetery, and nearby Highwoods Nature Reserve, a designated Site of Special Scientific Interest.

They will also argue the site cannot be delivered within the short time-frame required by ESCC.

Nick said: "The news is extremely serious and a wake-up call to the people of Bexhill, some of whom have doubted that the threat of a landfill was real. It's staring us in the face now, but if we can all get together to fight this monstrous plan we can defeat it. But we must act now."

Hundreds of residents attended a similar public meeting organised by Greg Barker in 2002 when the threat of a Bexhill Landfill first became apparent.

That meeting lead to the creation of BALI, and the two offices have now joined forces with local councillors and environmental groups to spearhead a renewed campaign.

Greg said: "A landfill site of this size and in this location would be an absolute disaster for so many reasons, and of course all the waste disposal methods, landfill and the dangerous methane gases it creates has the very worst impact on climate change.

"I want to head this off at the pass and ensure that such a proposal never comes to fruition in Bexhill, be it in five years time or twenty years time.

"Thankfully for the town the BALI committee has been quietly working very hard indeed over this period but we cannot now leave this fight all to them.

"We need to back BALI with a strong and cross-party campaign, a broad alliance of groups. Communities and individuals need to come together right across the town."

John Heasman, Vice Chair of Bexhill Labour Party and a committee member of the preservation society for nearby Highwoods Nature Reserve, said: "I am appalled that this site should even be considered for landfill with non-inert waste.
"Opening this site would cause considerable extra vehicle movements, including heavy lorries, that would be stressful to local residents and impact negatively on the well being of local communities.

"The dumping of non-inert waste so close to Highwoods would also have a catastrophic effect on the ecology of a valuable recreational area which is enjoyed by many Bexhill residents.

"I give my full support to BALI on this issue."

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The public meeting will be chaired by Greg Barker at **Bexhill High School, Gunters Lane, Bexhill on Friday, November 6 at 7pm. [**Note that this venue is a change from that originally published]

Greg said: ""I hope as many people as possible will come. It would be extremely helpful if we had an idea of how many to expect, as it is possible we may need a bigger venue, so I would be very grateful if people could either register their intention to come on my website or call my office on 01424 736861."

For information or to register interest, visit www.gregorybarker.com

See the original article on the Bexhill Observer website

The Landfill Threat Becomes Real

East Sussex County Council (ESCC) and Brighton and Hove City Council have finally confirmed their plan to use Ashdown Brickworks in Turkey Road, Bexhill for a massive landfill of residual waste starting as early as 2012.

Ashdown the 'Preferred Option'

In their recently published Preferred Strategy for the handling of waste in the County until 2026, ESCC have designated the Ashdown Site as their "Preferred Option" for the landfilling of waste and hope to start a Planning Application next year to complete by the end of 2011. The Strategy was approved by ESCC Cabinet last Wednesday.

The Next Public Consultation

The Strategy does list some possible alternative sites however, and there will be a period of Public Consultation from 21st October to 2nd December this year before Ashdown is definitively selected. Rother District Council, BALI (Bexhill Against Landfill and Incineration) and other local organizations will be making submissions in this consultation and the public will also be invited to give their views.

Despite greater recycling, 60% of the area's approximate 2 million tonnes of waste is still disposed to landfill. Although the Incinerator being built at Newhaven (estimated to start 2012) will be able to burn most of our domestic waste and recover energy from it, landfill will still be needed for other types of waste (e.g. construction and demolition waste) and the bottom ash left after incineration, which can be as much as 25% of the waste burnt. About 4.5 million tonnes of landfill will be needed up to 2026. Most of that is planned for Ashdown as all other landfill sites are closed or (Pebsham) in the process of closure.

BALI is meeting with our local MP, Councillors, environmental groups and other stakeholders to try to co-ordinate a campaign to oppose what they see as a pernicious proposal that would have a devastating effect on the whole town of Bexhill, setting back the Council's plan for its regeneration and likely to lower house prices throughout the town.

Effects on the Community

The community of West Bexhill would be particularly affected if the plan goes through, with an estimated four thousand residents living within a mile of the site. Potential effects of the landfill would include visual impact, odours, pests, noise, dust and litter as well as concerns about public health. Significant daily HGV waste-truck movements would affect a wider area, depending on the routes chosen, but potentially having similar effects and causing traffic congestion.

Several local amenities and their users would be egregiously affected, most importantly the flagship new Bexhill High School being constructed for 1800 young people less than half-a-mile away. Users of the Bexhill Cemetery only 250 metres away (less if the cemetery is extended as planned) would overlook the dump, as would the golfers of Highwoods Golf Club. Arguably worst affected of all would be the much-frequented Highwoods nature reserve, a Site of Special Scientific Interest, whose wildlife would be decimated: birds simply would not nest.

BALI's latest action

In April this year, in anticipation of this decision, BALI re-engaged its prominent legal planning consultant to make a strong case that the choice of Ashdown for landfill is entirely unsound. This case is now ready to submit. Such legal work is, of course, costly and has only proved possible through the generous donations of its supporters and the hard work of its fundraising team.

BALI's case

BALI's case is twofold. Firstly it argues that the effects of a landfill in this location are simply too great. According to Government planning policy, the County Council must clearly demonstrate, in allocating any land for such purposes, that "there is no unacceptable impact on the environment and on communities". BALI will seek to prove that, given the proximity of so many homes and local amenities and so much ancient woodland with unique flora and fauna, the impact will be totally unacceptable.

It will also argue that the choice of Ashdown as the County's landfill site is, in planning terms, "unsafe", in that it cannot be "delivered" (made ready) in the time-frame required by the County Council. The Council needs landfill in the short term to meet an immediate and increasing shortfall in capacity. It is unlikely, however, that Ashdown could be able to receive substantial quantities of waste for some years.

When Ashdown was originally considered as a landfill site it was well-established that there would first need to be created a whole new transport infrastructure as the present access roads (Pear Tree Lane and Turkey Road) are clearly unsuitable. This would consist of the Link Road, a so-called "Country Avenue" spurring off it to the A269, and a purpose-built access road from the A269 to the site. The Link Road, however, if constructed at all, will not be ready until 2012 at the latest and the other roads are at present not even on the drawing board.

It is also not clear that the Ashdown quarries, owned by Ibstock Brick Ltd., have the potential capacity in the short term to receive substantial waste. There are two quarries where they plan to deposit waste in one while continuing to extract clay from the other. However the hole they plan to use for waste is by no means empty and they would need to stockpile clay on nearby land.

Rother District Council

BALI is hoping that Rother District Council will also make a strong case against the proposed landfill, using their substantial planning and legal resources and expertise. While they do not make the final decision, their views as a key stakeholder could be very influential, if not decisive.

 

Greg Barker MP

BALI has already held an urgent meeting with local MP Gregory Barker, who has always been firmly opposed to a landfill at Ashdown and, indeed, was instrumental in forming BALI some years ago. He has assured BALI of his firm support. A campaign will shortly be launched asking local residents and Councillors of all parties to unite against the move, culminating in a Public Meeting which Mr. Barker has agreed to Chair [To be held on Friday 7th November 2009 at 7.00 pm, venue Bexhill High School, Gunters Lane, Bexhill - please come along].

 

Defeat This Monstrous Plan

BALI genuinely believes that the proposal can still be defeated.  "The news is extremely serious and a wake-up call to the people of Bexhill, some of whom have doubted that the threat of a landfill was real", says Nick Hollington, Chairman of BALI. "It's staring us in the face now, but if we can all get together to fight this monstrous plan we can defeat it. But we must act NOW!"

It is hoped that, if the landfill proposal is defeated, work can begin on a plan for eventually restoring the quarries for community use in cooperation with Ibstock. BALI wants them to form part of a "nature reserve" incorporating the Highwoods and surrounding farmland. In this respect, earlier this year BALI made a formal proposal to Rother District Council’s Local Development Framework of a "West Bexhill Countryside Park" similar to that now being created in the Pebsham area. This proposal has now been formally registered.

But first the landfill proposal must be defeated and BALI is calling upon all local residents to write to their local Councillors expressing their views and asking them what they are doing to oppose the plan. 

The Big Danger: London Waste Coming Our Way

The Background

The South East Plan, sometimes called the 'Regional Spatial Strategy', is a plan for the South East of England for the period 2006 - 2026 prepared by SEERA (South East England Regional Assembly) and submitted to Government (GOSE -The Government Office for the South East) in March 2006. There followed a lengthy inquiry called 'The Examination in Public' from November 2006 till August 2007. In July 2008, the Government finally approved the plan in principle but published 'Proposed Changes' which were subject to a consultation which ended last October. The Councils comprising the South East and other bodies then made their final, detailed submissions for final changes to the plan which is expected to be adopted final form in April 2009.

Is the South East Plan important?

Very. It replaces a document called RPG9 and provides for housing targets, economic developments, transport, employment etc. throughout the South East. For example, Rother District housing targets are not set by Rother District Council but by the South East Plan. Also all local planning frameworks, e.g. Rother District's Local Development Framework, must adhere to the South East Plan.

Why is it important for BALI?

One of the subjects covered by the plan is waste provision. The East Sussex Waste and Minerals Development Framework must adhere to it. This wouldn't matter much if it just left East Sussex to deal with it's own waste, but it required that East Sussex and all the other SE counties share out the disposal of most London waste over the next 20 years.

What are proposals for London waste?

London can't cope with all its own waste - though many feel it should - so the plan is to send 28 million tonnes of it to the South East (the Eastern region is to get 18 million tonnes) over the period 2006- 2026. Of this figure, Sussex is to get 4.6 million tonnes with approx. 2 million tonnes coming to East Sussex (recently reduced to 1.6 million tonnes). It is estimated that this will require 3 to 4 new landfill sites in Sussex, taking a minimum 1.8 million cubic meters of waste each year, the equivalent of 1,800 Olympic size swimming pools. At least 470,000 extra lorry carry movements each year would be required.

Does London agree to this?

The London Boroughs have been traditionally somewhat 'lazy' about their waste disposal, happy for someone else to take the waste out of their hands. However, both the previous London Mayor, Ken Livingstone and the current Mayor, Boris Johnson see the export of London waste to the South East country side as unsustainable. Ken Livingstone wanted to reject the South East Plan and by 2020 make London almost self-sufficient in managing its waste by greater recycling and a chain of massive anaerobic digesters around the city to not only dispose of the waste but also to create energy. It seems that Boris Johnson does not reject the plan, but has formed a London Waste and Recycling Board to boost recycling in the capital and reduce the amount of waste sent to landfill. He also favours the establishment of anaerobic digestion sites and incinerators around the city and an assault on over-packaging. The idea is that a coordinated all-London approach (previously each London Borough took responsibility for disposing of its own waste) will be more effective. However, this will take time to work and some Boroughs oppose it.

What is the County Council's response?

It is fair to say that both West and East Sussex councils have been fighting these proposals tooth and nail. West Sussex has run a high profile political campaign by councillors and MPS. East Sussex's response has been less high-profile but vigorous 'behind the scenes', led by Tony Cook, head of ESCC's Waste Planning Team, whom BALI speaks to on a regular basis. He argued that the plan does not take into account the limited degree of 'suitable void space' (basically holes in the ground) in East Sussex, most of which will be needed for its own waste. He also argues that East Sussex Green Belt is an environmental constraint and that the plan does not recognise that East Sussex is full of Areas of Outstanding Natural Beauty (AONB) and Sites of Special Scientific Interest (SSSI). Nor does it recognise the transport difficulties (distance, hardly any motorways etc.) which is largely why there has been no 'historic' disposal of London waste in our area.

Is London waste likely to come our way?

Almost certainly, yes, in the opinion of BALI's Chairman, Nick Hollington. East Sussex County Council accepts that in the medium term London will continue to be reliant on the regions for waste disposal. It would require a complete U-turn by Government to allow East Sussex to be an exception (though in fact Hampshire has been made such an exception) in not taking any London waste. At the end of the day, Tony Cook is (only) arguing about figures - and he has already achieved a reduction of the East Sussex figure to about 1.6 million tonnes. He also argues that these figures should only be considered an 'aspiration', not a requirement.

Does it have to mean more landfill?

They always only talk of landfilling London waste. BALI has questioned this, given there are many other methods of waste disposal, but we have seen no evidence of any other plan to deal with London waste than landfilling it.

Will it inevitably mean a landfill at Ashdown Brickworks?

It will certainly make it more likely. To quote Henry Smith, leader of WSCC, 'If people live near an earmarked waste site the threat of having that opened as a landfill is very real indeed'. However, there are still real difficulties with transport with access to the Ashdown site which very clearly need to be resolved before any landfilling takes place.

How will it happen? When? What next?

First, the South East Plan has to be approved in its final form. This may happen as early as April 2009 but could drag on. There is then likely to be a renewed focus in the media with an 'outcry' about London waste and new landfill sites.

The way things will happen is not by the Council 'requesting' an owner of a void-space (e.g.Ibstock) to provide a landfill. Unless, London Waste and Recycling Board steps in, London boroughs might have to hire a private waste contractor who would approach owners of a suitable site or the owners might make the approach. (The owners might have granted 'Landfill Options' already to a contractor.) Then, probably, the contractor, after preliminary soundings, would apply for planning permission. Of course, there would be a greater chance of success if the site is already earmarked for landfill in a waste plan (as Ashdown is in the ESCC Waste Local Plan) or framework. Of course, planning permission could be refused, for example as a result of an unsuccessful Environmental Assessment. But the South East Plan's requirement to accept London waste would clearly put more pressure on the planners to favour landfill applications.

What can BALI do?

Of course, BALI opposes London waste coming to East Sussex. The only way perhaps of stopping it is if, when the South East Plan is published, a high-profile political campaign is launched by East Sussex MPs, perhaps led by our local MP, Greg Barker. West Sussex MPs and councillors are already running such a campaign. Since there is a good chance that the Conservative Party will win the next election, it would be good if they would pledge to reverse the plan in terms of the export of London waste or at least review it. We should seek an early meeting with Greg Barker.

Links: West Sussex County Council Waste information

BALI comments on the recent planning application Pebsham Landfill Site

Letter dated 19th January 2007 to East Sussex County Council from Nick Hollington, Chair of BALI

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19th January 2007

• Director of Transport and Environment
• East Sussex County Council
• County Hall
• St Anne's Crescent
• LEWES BN7 1UE

Dear Sir

Ref: Planning Application RR/498/CM(JP)

Proposed redevelopment at Reprotech Site, Pebsham

We wish to object to this development on behalf of the residents of Pebsham and Bexhill on a number of grounds as follows:

1. While it is established in the East Sussex and Brighton and Hove Waste Local Plan (WLP) that there might be a Waste Transfer Station (WTS) at Pebsham to assist increased recycling and diversion from landfill:
   1. The WLP puts conditions on such a development which we believe are not met.
   2. Residential properties are within 500 meters of this site and three schools within a kilometre. It may be that these and other environmental conditions cannot be met in a site so near a residential area.
   3. Alternative sites may and should be considered.
   4. If the development is to go ahead more consideration and respect must be given to the rights and amenities of Pebsham residents.
2. Pebsham residents have been more than patient and have done more than their fair share in serving the county's waste disposal and treatment needs for over 50 years. They have been promised several times an end to waste activity in the vicinity. The proposal represents a breach of these promises.
3. Pebsham residents continue to be affected by the BIFFA landfill, due to close in 2008, but for which an application for extension till 2011 is shortly to be submitted, as well as Southern Water's waste water treatment plant. Not only are there problems in such activity such as noise and smell, but they generate a substantial volume of vehicle movement causing greater noise and traffic congestion. A Waste Transfer Station will only exacerbate these problems.
4. It is recognized that the A259 at Bexhill Road is overloaded:
   1. Air pollution levels in this area are above accepted levels. This has been recently measured. It is an Air Quality Management Area (AQMA).
   2. Traffic is heavily congested.
   There will be substantially increased traffic movements as a result of the proposed development which will simply worsen the situation and there is still no certainty that the alternative Bexhill-Hastings Link Road will be built.
5. In this connection the ESCC Waste Local Plan itself makes its own conditions (Policy WLP 6.27) that "any increase in vehicle movements along the A259 would be unacceptable until the strategic road network in the area has been improved" and again later "Any net increase in traffic would be unacceptable at least until measures have been implemented to relieve congestion on the A259". However if the landfill's life is extended and there is no reduction in other waste or waste water treatment activity there will inevitably be an increase in traffic.
6. Policy WLP 36. states that proposals will not be permitted "where access arrangements are inadequate for the volume and nature of traffic generated by the proposal". Current access to the plant via the "junction" with the A259 is totally unsatisfactory. It is a major cause of delay and relies on the pedestrian traffic lights to make a gap in the traffic. Such a long-term development as is being proposed for the Reprotech site clearly requires entirely better access such as a slip road with traffic lights or a roundabout.
7. There will be increased hazards for other road users and again, according to the WLP proposals will not be permitted where such is the case.
8. Noise is a particular concern because of the acoustics of the area. A local resident Ken Paterson, recently reported on the high existing noise levels in the local newspaper (see Bexhill Observer 5.01.07). Not only the noise from the landfill and the household tip can be heard but also "the drone of the sewage plant, and even the noises of football matches on the Bulverhythe playing-fields".
9. In this context the hours of operation proposed for the WTS as 6:00 a.m. to 10:30 p.m. - seven days a week are completely unacceptable and show no respect for the local residents' rights and amenities. Particularly no activity should take place on a Sunday. NB. Pebsham Farm Industrial Units were refused longer hours and the same criteria should be applied in this case.
10. In particular regarding noise, Policy WLP 35 states that all proposals shall contain "adequate means of controlling noise" and we are not satisfied that sufficient arrangements have been met in this regard:
    1. The use of the site for skip storage and activity is of concern as skips heighten noise annoyance when dragged or dropped. Care needs to be taken to provide rubberized surfaces and undercover areas.
    2. It is not clear that sufficient sound insulation will be provided to all buildings.
    3. Residents are particularly maddened by reverse warning beeps from "smart" devices fitted to lorries. These are aggravating noises if continual and, while mindful of health and safety requirements, these should be minimized wherever possible or the hours when reversing will take place reduced.
    4. It is not clear how many sensors there will be to check on noise or how inspections will proceed and at what frequency. Tests must be made throughout the site and the surrounding area and not on just one part of the site which currently is totally unrepresentative! Please see the addendum for which I am grateful to Mr Roy Goodall. There is also an echo effect produced by the valley which must be taken into account to evaluate the true level of noise.
    5. We are not satisfied there is sufficient landscaping in the proposal. The site should be hidden from residents by planting high evergreen trees. This would also enhance noise and dust suppression for residents.
    6. WLP 6.27 states that any development proposal for this area "needs to be co-ordinated with plans for the Pebsham Countryside Park" and that "redevelopment proposals for this site "must assist in reducing visual impact". Evergreen trees along the Western and Northern Western sides would assist, but it is not clear how noise and dust impact would be controlled.
    7. Clearly the development would be required under WLP 6 to meet current environmental standards as to air quality and an environmental report will presumably be forthcoming. However it is difficult to see how the currently poor air quality will be improved and every reason to think it will deteriorate especially if the BIFFA landfill site is extended. Further detailed environmental consideration needs to be given in this area. For example there is too much reliance on gatekeepers/weighbridge operators for ensuring doors are opened and closed per lorry visit. In summer the station will be hot and the door may be left open all the time with consequent pollution and fumes from the lorries. There needs to be proper air-conditioning and an automatic system of opening and closing doors.
    8. The proposed overnight parking at the site of 40 refuse vehicles previously housed at the Bulverhythe Depot may or may not reduce vehicle movements but clearly will increase noise and petrol fume nuisance to the residents from early in the morning till late at night.
    9. The accumulation of all the above difficulties surely suggests that this site is not a suitable location for the proposed development. It is surely not, under WLP 35 "of a scale, form and character appropriate to its location". This not only is in relation to its proximity to the homes but also given the proposed Pebsham Countryside Park which local residents were promised, after all their trials, as a haven of beauty and tranquility. It is difficult to see how this project will not be spoiled by this development on the Southern side together with the planned Link Road on the Northern side.
    10. In addition Freshfields Road has lately been put forward as one possible site (out of 3) for a travellers' transit camp! Surely the combination of a Waste Transfer Station and a travellers' camp is not a sensible idea?
    11. We respect that this proposal by Veolia is made to meet local needs as part of its long-term strategic integrated waste management service to the county as outlined in the WLP. But how this proposal fits in to their strategy or plan is not made clear particularly in regard to their facilities for non-recyclables (BALI recognizes the great strides made by Veolia in recycling facilities). These presumably primarily concern the proposed incinerator at Newhaven but may also impact on the suggested (in the WLP) landfill at Ashdown Brickworks. Pebsham and Bexhill residents surely have a right to see the "bigger picture" of how this proposal will fit in with others, where all the lorries are likely to come from and go etc.
    12. While this proposal currently deals with the "transfer" of recyclable waste there is an underlying sense of Pebsham and Bexhill as a whole being used as East Sussex's permanent dumping ground. The Council and Veolia will need to act positively to dispel this impression.
    13. Finally we are shocked to understand that at present it is not planned to commission a full Environmental Impact Assessment (EIA) regarding this proposal. This is a highly questionable decision and should be immediately reversed. This development is a new long-term development which could result in a seriously adverse impact on local residents' health and well-being with regard to all kinds of pollution, noise, dust, odour, etc. Furthermore there is the factor of the proposed Pebsham Countryside Park to consider. It is not "same again" and demands full environmental reappraisal. We therefore ask the council to reconsider its decision on this matter.

Nick Hollington , Chairman BALI

ADDENDUM re: noise assessment

1. The Noise Assessment data produced by the applicant was based on readings taken at a point which is not representative of the area near the proposed site, although their statement suggests otherwise. No. 2 Pebsham Lane was used, and was the only place used, to gather data. This house is a considerable distance from the proposed development which would, therefore not be indicative of the potential noise levels one could expect at, for instance, Top Cross Road and nearby roads /residences.
2. A more appropriate study must be initiated by both the applicant and the Environmental Agency. To allow the application without this new study would result in many roads nearer to the plant suffering excessive noise levels far and above that recorded at No.2 Pebsham Lane. Then, any complaints from the nearer houses in the future would be met with "the operation is within the planning limits". The decibel readings and projected noise levels would be met for those people living at the far end of Pebsham Lane (near to No. 2) but the noise levels would increase in magnitude the further along Pebsham Lane one travelled. These noise levels would rise exponentially. This is not good enough!