|1. What are the dangers posed by the three principal contaminants?
||Zinc – primarily enters the body through the mouth in food, water or by small soil or dust particles. The health effects or symptoms are: stomach cramps, nausea, vomiting, anemia, pancreas damage and decreased levels of good cholesterol. Those most at risk are infants and young children
Dieldrin – primarily enters the body through the mouth in food and water. Symptoms of dieldrin poisoning have been seen in people who were exposed to very large amounts of these pesticides during their manufacture. Symptoms of poisoning have also been seen in people who intentionally or accidentally ate or drank large amounts of dieldrin. Most of these people experienced convulsions or other nervous system effects, and some had kidney damage. Some people who intentionally ate or drank large amounts of dieldrin died. Health effects in people exposed to smaller amounts of dieldrin occur because levels of the chemicals build up in the body over time. Exposure to moderate levels of dieldrin for a long time causes headaches, dizziness, irritability, vomiting, or uncontrollable muscle movements. Some sensitive people seem to develop a condition in which dieldrin causes the body to destroy its own blood cells. We do not know whether dieldrin affects the ability of people to fight diseases. We also do not know whether dieldrin affects the ability of men to father children, or causes birth defects or cancer in people. The International Agency for Research on Cancer has determined that dieldrin is not classifiable as to its carcinogenicity to humans. Based on studies in animals, the EPA has determined that dieldrin is a probable human carcinogens. |
Ammoniacal Nitrogen is not generally considered to be a risk to human health by ingestion e.g. through soil, but is highly soluble and toxic to flora in surface waters and can have a detrimental effect on the performance of building materials. It can also cause an odour nuisance in drinking water.
|2. What if, when the remediation is started, there is found to be very much less or very much more contaminated earth to remove, and that therefore the cost of the remediation differs significantly from the current estimate? In the former case would the enabling development be reduced, or in the latter a new application for a bigger one submitted?||This site has been the subject of very considerable investigation over the years with trial pits and boreholes across the site. The information gained gives a sound knowledge of the contamination. The applicants would have to bear the risk should the cost of contamination exceed current calculations. If the costs were to be less than current calculations then the favourable balance would accrue to the developer. However it should be stressed that the technical information gained over the last ten years and the independent assessment of the financial appraisal make this extremely unlikely.|
|3. What is the tree loss from the proposal?||No long established trees are to be removed. Those being removed are mainly regenerated Silver Birch or other species that have colonised contaminated areas. The trees of landscape and ecological importance are being retained.|
|4. Why do plants not grow on the previously remediated area?||This area was required to be restored to grass land and the specification was designed accordingly with a compacted clay cap and thin top soil structure to discourage deep rooting plants, shrubs and trees.|
|5. What is the actual lining of the quarry before it receives the contaminated material? ||Preparation. The base of the landfill would be regraded with inert fill that would be placed and compacted to ensure that the mineral liner was installed on a suitably stable foundation.|
Lining System. A basal sealing liner would be constructed of at least 1 metre thick engineered Weald clay. The mineral liner would be placed and compacted in layers of approximately 300 mm such that the in-situ permeability (hydraulic conductivity) would not exceed 1 x 10–9 m/s. The perimeter sealing liner would comprise a 1.5 m thick engineered clay liner which would be extended in lifts of approximately 3 metres as infilling of the cells progresses.
Cells. Non-hazardous waste, which would comprise the greater amount of fill, would be placed in the southern part of the landfill. In accordance with the Landfill (England and Wales) Regulations 2002, stable non-reactive hazardous waste ie asbestos can be deposited in a separate cell of a non-hazardous landfill. It is proposed to place stable non-reactive waste in a separate cell in the northernmost area of the landfill.
Collection systems. It is likely that a groundwater collection system would be necessary beneath the landfill liner. The final details would be agreed with the Environment Agency as part of the PPC permit process. Provision for a leachate drainage and collection system incorporating a drainage blanket and pipework would be made, and again these would be designed following risk assessments and in accordance with Environment Agency guidance. Given the nature of the waste materials, which comprises principally soils and residual demolition waste, the generation of leachate is likely to be small. Similarly, due to the nature of the waste, gas management infrastructure is unlikely to be needed at the site.
Landfill Cap. On completion of the landfilling operations the landfill would be capped with a 1 metre thick layer of Weald clay engineered to a permeability of not greater than 1 x 10–9 m/s..
|6. Public Footpaths, are there additional provision?||There would be a new public through fare on the site including cycle paths to Downslink. No footpaths over remediated land.|
|7. Does the development encourage cycle trips to Cranleigh?||Yes. Improvements to Downlink in S106 improves its condition for cyclist use..|
|8. What is the interest and status of SNCI?||It is of nature conservation of County and District importance. It is important to the locality. Newts are protected species and work already undertaken to provide new habitats. There is a Badger sett on the site within woodland unaffected by the proposal.|
Map of the SNCI is attached.
|9. No cars in the illustrations. Is this realistic? Concerned about the impact of cars on the environment.||Cars are designed to be hidden away as much as possible in court yards and rear access ways; similar to the Poundbury Village layout that Members may recall visiting. |
|10. Is the access road the only way into the site? Concerned about the practicality of the passing places.||It is the only vehicular access. The proposal tries to keep the rural feel of the lane. It is generally three metres wide and therefore will need passing bays. Car drivers will be able to see from one passing bay to another. This is acceptable to the Highway Authority.|
|11. How does the development contribute towards sustainability issues? ||Confirmed ground source heat recovery to be implemented. Grey water recycling and |
rainwater harvesting included. The dwellings are designed to the Very Good Eco-Homes rating system.
Sewerage is dealt with on site with a treatment plant.
Transportation package for alternative means of transport to the car.
|12. Who is going to own, manage and maintain the community building?||Management company of the residents, and they will maintain it. The building will be provided free to residents. A contribution of £100,000 towards start up costs. Uses may include local playgroup, sports, interim shopping, and meeting place.|
|13. Have we looked at other options of remediation?||Yes Surrey County considered other remediation schemes – see appendix F of main report and above in this addendum report for further commentary. Capping in situ does not take into account EA standards or land fill regulations. |
Capping contaminants in situ on this site is not considered to be a long term robust sustainable solution. There would remain a prospect that full remediation would still be necessary at some point in the future.
Other land use options have also been considered such as commercial, headquarters building, retail uses, fewer larger dwellings, hybrid development.
|14. How is the pollution monitored, How much has the pollution levels dropped over time?||Monitoring has changed over time due to European directives and changing standards. Monitoring has not shown any reduction in pollution over the years.|
|15. Where are the previous remediated land and how are these to be dealt with?||These are illustrated on the plan on page 38 of the main report. There are no proposals to do any more with those sites as they are operating without risk to receptors. Public access will not be encouraged; it is safe to walk on these areas. They will remain as grassed areas, and have been engineered to prevent trees taking root.|
|16. Village feel? Concerned about lack of facilities, church, shopping, etc.||Does not attempt to recreate a village and all its facilities. The design borrows from local village vernacular in an attempt to deliver a high quality design solution. It is accepted that there are limitations in terms of what the development can deliver in the way of facilities without increasing costs and consequently the number of dwellings. The community building is designed to provide a space that the community could use for meetings or place of worship if that was appropriate.|
|17. Could surface water problem be solved by a water treatment plant?||The defunct treatment plant demonstrates that partial remediation of pathways is not successful. Not capable of meeting current standards and fell into disrepair.|
A new treatment plant would only manage the “pathway” between source and receptor and would not be a long term solution.
|18. Access road from Knowle Lane. How much will be adopted or will it be to adoptable standard? Is there street lighting?||Approach is to make as little impact as possible on the rural qualities of the area. No intention to have street lighting other than low level lighting at key points within the housing area. Construction will be to an adoptable standard but the roads will not be adopted. |
|19. Cars will be essential to this site but it is fundamentally remote. Concerns about Knowle Lane and parking in Cranleigh.||Accepted that it is a remote site and car use cannot be avoided. Whilst there are no technical capacity or safety reasons to support highway refusal Highway Authority object on location policy issues because of the remoteness of the site. The applicant has put together an impressive package of measures to mitigate this concern but they do not overcome the Highway Authority’s principal concern. |
|20. DBL report suggest remediation costs of £3,M this realistic.||See report above.|
|21. What protection will there be to control future works to widen access road?||It would need planning permission.|
|22. Remediated areas are close to housing areas. What liability to Waverley should future problems arise?||The proposals including aftercare of the site are designed to reduce the risks to human receptors to a very remote possibility. WBC would have the regulatory responsibility for residential development. Environmental Health have raised no objection to the relationships and the body of evidence from consultants and agencies conclude the proposals are safe. |
|23. How can the impact of cars be mitigated on this site?||The applicants have looked at similar sites although they are few. Assessed traffic flows, 119 trips in peak hour period. SCC assessed TIA. Conclusion is that Knowle Lane has sufficient capacity, including junctions at Cranleigh High Street. Also transportation package. However not dissimilar to other small rural communities in Waverley.|
|24. SCC Highways recommend refusal. Why do they feel this is the case?||Object only on location policies but not capacity or safety issues.|
|25. Companies who had operated at the site still exist surely they ought to be making a contribution towards the costs?||Evidence suggests that there is no realistic prospect that they have a legal obligation to contribute. |
|26. Some of the substances are banned in the UK and this is extremely worrying. Is it right that we are developing residential development on this site?||The proposed scheme as a whole is designed to provide a long term sustainable solution including for the well being of future residents. The risks to receptors from pollutants is extremely low. The focus on relatively high after care management and costs is additional comfort in reducing these risks.|
|27. Who is responsible for further action if we refuse planning permission?
28. What happens if application is refused?
29. Pg10of report. Will funding be made available if planning permission refused?||Environment Agency would need to serve a remediation notice and follow the steps set out on page 34 of the report.|
The voluntary remediation scheme would not be carried out and the site would almost certainly become an “orphan” site.
Current landowners do not have funds themselves to contribute towards remediation. The EA only has £2m for the whole of the country.
|30. Is there technology available to treat the water on site?||Yes it exists. The new treatment plant would do this, however it is not considered to be a long term solution. Under the current scheme this would be a one off treatment rather than a long-term solution with the aim of dewatering the quarry in order that it can then be engineered to receive contaminated material.|
|31. Is there a risk of unidentified springs. Have these being identified or has the hydrology been investigated to avoid future risks? ||This is a risk but is one factor why capping in situ is considered not to be robust. The solution proposed would remove this as a risk as contaminated material would be placed in a sealed environment to avoid water penetration.|
|32. What is the developer doing to take on the burden to manage the risks of contamination?||There will be a 60 year management scheme. The aftercare finance is split into two main portions: the statutory financial provision (£1.0m) and other aftercare costs relating to ongoing maintenance of the site (£3.2m).|
|33. Are there risks to residents in growing vegetables in gardens?||The proposal is to remove all contaminants from residential areas. Remediation goals and monitoring regimes are currently being agreed with EA and other regulatory authorities. There should be no resultant risks to residents.|
|34. Attractive parts to the layout but not convinced about need of road to skirt northern part of village green. Can this be designed out so that all properties access away from the village green?||Design is based upon local vernacular and layouts of other villages. The layout seeks to minimise hard surfaces and provide attractive frontage to village green. Re-engineering car access and parking areas to accommodate all traffic would also impact on the spatial qualities of those areas to the detriment of the design concept. |
|35. Is the remediation scheme as presented the minimum scheme to achieve environmental benefits?||There are alternative solutions but they do not achieve the environmental benefits of full remediation. The proposed remediation agreed by SCC is considered to provide the Best Practicable Environmental Option (BPEO) for remediation of the site.|
|36. Would the EA adopt the current scheme as the minimum scheme if the planning permission was refused?||It is unlikely that the approved would be adopted as a remediation scheme by the EA simple because of funding limitations|
|37. If not what would they do and would be the implications of that?||The EA would probably need to seek emergency funding to cover the continual water management of the site whilst a longer solution was found. In the current context there is great uncertainty as to what that long term solution would be in the absence of a voluntary scheme.|
|38. Why are the costs of aftercare so high?||To ensure that there is a robust scheme of aftercare and to provide assurances to future residents and the community.|
|39. If Cherokee did not get planning permission would they walk away?||Whistler Properties own the contaminated part of the site and have no funds to remediate the site themselves. The EA would need to trigger the remediation notice process and that would need to be worked through. It has previously been explained that investigations have shown that there is no realistic prospect of an “appropriate person” being identified with the wherewithal to pay the remediation costs.|
|40. How comparable is the St Albans case?||See para 1.40 of the addendum report above.|
|41. How will EA control and manage remediation.||Two Pollution Control Certificates (PCC) for water treatment and for landfill will be required from EA. If application fails a voluntary scheme then EA would then need to pursue appropriate persons. DEFRA has a national budget of £2.2M for these issues and it is unlikely that funding will be made available to implement approved remediation scheme. Internal discussions at EA suggest that site would remain a problem and with an uncertain future. |
|42. Is the remediation scheme reasonable?||Reasonableness tests have been applied and EA and SCC together with consultants have agreed the remediation scheme. The EA commented upon remediation schemes. |
A minimum option is one option but has uncertain funding and higher risks to receptors. Proposed remediation is considered to be Best Practicable Environmental Option solution?
|43. Has EA approached DEFRA for independent study or funds?||No approach has been made to DEFRA whilst a voluntary scheme on the table. |
|44. Should the remediation be funded by Government?
45. If this is an orphan site but if prime responsibility of Government is to make the environment safe for residents. Has this been tested with Government?||Legislation frameworks look to voluntary schemes first, including development solutions. |
Not aware that this has been tested. The planning regime is being looked at as an appropriate method of dealing with these issues.
|46. Would water authorities have an input in monitoring European Standards?||Drinking Water Inspectorate would monitor. If water quality is an issue then it would be a responsibility for them. It is clear that the EA cannot allow the risk of pollution to remain as at present|
|47. Why is nothing being done now?||The site is being managed at the moment to avoid critical discharges of pollutants into the watercourse. However this is only a short term interim strategy.|
|48. What would have been EA approach if this application were not before the Council?||If no voluntary scheme then they would follow appropriate person route. If no management of site then they would need to secure emergency money to manage the site.|
|49. How long has the EA been involved in the site? ||EA became involved in the late 1980s but became the regulatory authority, instead of the Council, when the site was declared the first special site in the country under Contaminated Land Regulations 2000|
|50. What is DEFRA and what did it replace?||Department for Environment, Food and Rural Affairs|
It brings together the interests of farmers and the countryside; the environment and the rural economy; the food we eat, the air we breathe and the water we drink.
It was formed from an amalgam of other Government Departments the core of which was the Ministry for Agriculture, Fisheries and Food. (MAFF)
|51. Did the EA comment on remediation scheme approved by SCC. ||Yes. |
|52. Is there further EU legislation on the horizon?||Environmental legislation is constantly changing and becoming much tighter. There is not a history of a steady state or where solutions become cheaper.|
|53. Are there any air pollution issues?||Not an EA issue but covered in the Environmental Impact Assessment. Main pollutants are either caused during building construction and the use of private cars. |
Building design incorporates sustainable energy initiatives to reduce energy consumption.
Travel package designed to mitigate use by private cars but there is an acceptance that it is inevitable that car usage is likely to be proportionally high in terms of travel modes to the site
|54. Pollution into Collings Brook continues. Why is not the land owner being prosecuted.||The site is currently being managed to avoid critical discharges by permitting limited discharge at high flows. |
There is legacy of 80 years pollution in the brook from sediments and original polluters are not there.
|55. Pedestrian and cycle access along Knowle Lane is poor. Should this be upgraded? ||This is one indication of problems associated with the remoteness of the site in transportation terms. |
The proposal seeks to create an attractive and convenient access along the Downlink as an alternative solution without over engineering rural lanes.