From: IG Elliott Braishfield Village Association
Coombe Willow
Braishfield
Romsey
SO51 0PR
29h January 2008
Ms Julia Davey
Planning Department,
Hampshire County Council
The Castle, Winchester
Dear Ms Davey,
Case No: 08/00034/HCS
To produce approx 300kw of electricity for sale to the grid and 600kw heat through three biomass generators. Upper Slackstead Farm, Upper Slackstead Braishfield.
I am writing to you on behalf of the Braishfield Village Association which has for a third time been alerted to a proposal to generate electricity and heat at Upper Slackstead. We have very strong concerns about this activity which have still not been addressed in this latest proposal. Our concerns are listed below and we wish to register our objection to this application.
It is inappropriate to site a waste to energy generation scheme such as this in the countryside. The applicant proposes to use the generated energy to heat only five residential properties owned by him and to sell the electricity to the national grid. It hardly makes environmental sense to bring in one HGV of fuel every other day (paragraph 22 Highway Assessment report) to heat five houses.
No environmental impact assessment has been provided. Paragraph 3.3 of the Design and Access statement dismisses the need to consider “The immediate and wider impact of the proposed development on the landscape” as required by the Hampshire County Structure plan. It is not good enough to claim that, because the development is “within a screened area”, there will be no adverse impact on the wider environment. There are many other environmental factors to consider, including increased air-pollution, increased noise, increased traffic and increased carbon dioxide emissions in the countryside.
The fuel for the incinerator is constantly referred to as ‘biomass’ as if this alone makes it environmentally acceptable. The fact remains that biomass is only carbon neutral energy if the majority of the fuel used is grown on site especially for the purpose of producing energy. This application proposes to fuel the generators by importing waste wood by HGV from three waste sites around Hampshire. These journeys will produce carbon dioxide emissions which are not currently generated thus increasing, not decreasing, the carbon footprint of the area.
The proposal is to use “twigs, sticks, small branches and other woody by-products” from the Veolia composting operation. This is a waste processing operation and there must be control and monitoring procedures to ensure that the input waste is not contaminated and that the emissions produced by the generators are not toxic. These do not appear to have been addressed.
It is unclear how the twigs, sticks and small branches are to be turned into wood chips of the size required by the BG100 generator. If they are to be shredded on site then the noise impact assessment should take this into account. The noise report provided does not appear to do this.
The proposed routing of the HGVs will take the majority of them through the southern part of the village of Braishfield. They will pass significantly more residential properties than is stated in the Highway Assessment report provided by the applicant. Paragraph 11 of this report is disingenuous in supplying numbers of houses along Dores Lane while completely ignoring all the houses in Common Hill Road and Braishfield Road which paragraph 19 clearly indicates will be on the route.
The HGVs will also pass the Braishfield Village School which is already suffering problems with large lorries travelling fast down Braishfield Road and cutting the corner at the junction of Common Hill Road and Braishfield Road. It would be irresponsible to exacerbate the situation by allowing even more large vehicles to use Braishfield as an access route to Slackstead.
The recommendation of the highway authority for the first submission was “The roads leading to and from the site are of inadequate width and alignment to accommodate the additional traffic which the proposed development would generate”. The situation today has not changed. The network of small roads in the area is already being unacceptably damaged by heavy vehicles. This proposal would only make the situation worse.
In conclusion we remain very concerned about the nature of this proposal. Its environmental claims are not convincing, and we believe that it will have an unacceptable impact on the village of Braishfield and the surrounding countryside that has not been adequately addressed or even acknowledged.
This proposal has not allayed the concerns of local residents and our objection to it remains.
Yours sincerely
George Elliott
Chairman Braishfield Village Association