It is considered that the commercial aspect of the proposal, in particular the test track facilities, have the potential to generate significant levels of noise.
Whilst limited information has been provided regarding how the existing use operates, the introduction of the test track, located externally, suggests potential noise impacts of a markedly different nature to that currently generated.
Further, the proximity of residents within Dovenby village provides a sensitive receptor for that noise.
The ES will need to contain a Noise Impact Assessment that considers the noise from all possible test track activities (as well as any other noise generating activities which form part of the proposal) in relation to existing background noise levels at nearest noise sensitive locations.
Background noise measurements (LA90) will be carried out at noise sensitive locations within 2 km of the site boundaries. (These locations have been agreed with Environmental Protection in the documentation from Andrew Watson dated 21st August 2011).
The methodology shall follow the guidelines in BS4142 to produce a rating of the likelihood of noise from the proposed activities, albeit the limitations of this document should also be accounted for (i.e. that it relates to fixed objects and noise from the proposal will mainly arising from moving vehicles).
The results should assess the extent of properties that are likely to be affected by noise and the level of significance of noise impacts likely to be experienced. Consideration should then be given to any mitigation measures in respect of circuit design and layout which are to be incorporated into the proposal and the likely reduction in noise impacts anticipated as a result of these measures.
The Noise Impact Assessment should also consider possible noise sensitive receptors arising from the development itself, i.e. the residential development proposed as part of the scheme. This should include possible mitigation measures for these units that could be achieved through construction/design and regard should be had to BS 8233: 1999 Sound Insulation and Noise Reduction for Buildings.
The key factors to be considered in the NIA are:
Existing background noise levels at nearest noise sensitive locations
Types of activities planned and the source noise levels
Number of days/hours expected for each activity
Topography of area around the venue
Prevailing wind direction
Track layout and any noise mitigation measures
Any existing local noise issues
Real time monitoring of existing test tracks
(locations to be discussed and agreed with the Local Planning Authority
Maximum predicted noise levels and duration at the
nearest noise sensitive locations
From SCR_2011_0031 Scoping Opinion Decision P9
The finalised Environmental Statement for the planning submission will
comprise three volumes:
A Non Technical Summary will summarise information provided in the main report and will be presented, alongside relevant plans and maps, in a manner accessible to all members of the affected community.
A Written Statement
A Figures document, which will include detailed design schematics, Zone of Visual Influence, Wireframes and Photomontages where relevant to particular viewpoints.
MJN - Planning Framework - Rev A (amended 29-8-14) Supersedes original
Page 16 7.3 "the issue of noise. As this is potentially a critical issue at DHE and for local residents this is dealt with in more detail below."
(framework P9 4.3)
4.4 Supply in terms of days
In the context of an annual calendar of use and within the potential constraints on operations on a day to day and week to week basis excluding Sundays and Bank Holiday use, there are some 306 potential days available well within the required capacity of around 132 days as detailed above. This leaves some room for flexibility of use depending on the technical specification of types of vehicles using the evaluation facility and can, if required by the Local Planning Authority, provide days for agreed non-use in the interests of local amenity. It should be emphasised that evaluation of road vehicles will have low impacts and can be accounted for outside of any restrictions imposed by, say, noise.
Our Ref: 2/2014/0350 This Matter is being dealt with by: Sara Brook
03 July 2014
Mr E Ward Northern Developments Ltd
Full planning application for M-Sport Evaluation Centre (MEC) incorporating test area, agricultural building and demolition of derelict School House, Hodgson House and Howard House. Outline planning application for four further land uses consisting of: future expansion space, offices, 60 bed hotel and 25 dwelling housing estate. Dovenby Hall, Dovenby, Cockermouth
I refer to the above application and our subsequent meeting of the 3rd July 2014. I have now had the opportunity to review much of the submitted application and consultation responses and I would raise the following comments that require clarification, further plans or additional information.
I consider that the description of the development as submitted would benefit from some rewording to address the following:
I would recommend amendment to the following description:
Demolition of up to seven buildings including School House, Hodgson House and Howard House.
Full planning application for M Sport Evaluation Centre (B1) including test track (2.5km in length), car parking (250 spaces), earthworks, attenuation ponds, maintenance shed and underground fuel store. Temporary widening of eastern access from A594 for construction vehicles.
Outline planning application for future expansion space of 5000sqm (use class B1 and B8), Offices 2450sqm (B1), 60 bed Hotel 6000sqm (C1) and 25 dwelling houses (C3) including re-opening of access from Dovenby village.
Following our discussions, this amendment will be subject to further clarification on the housing element of the scheme and the associated access.
2. Reserved Matters
Please clarify what if any Reserved Matters are being sought in relation to the outline application proposals.
3. Re-positioning of Medieval Cross
Please confirm whether the listed medieval cross will be repositioned. The Non Technical Summary indicates it will be re-positioned at section 3.1.12, but other documents, including the Environmental Statement at section 5.7.4 state that it will not be. An application for Listed Building Consent will be required if it is to be re-positioned.
4. Additional Plans required
5. Housing justification
The Design and Access Statement briefly references that the housing provision will support the overall investment economically, however, no additional information is provided in this respect, in particular a Viability Appraisal for the overall development which demonstrates that the housing is essential economically.
Whilst ‘high quality residential development’ is listed as an acceptable use in principle for the site within saved Policy REM 10 of the adopted Local Plan, this policy was specifically written to facilitate the re-use and/or re-development of the previous Dovenby Hall hospital, which has been achieved. The weight of this policy is therefore considered to be limited.
In the emerging and soon to be adopted Allerdale Local Plan (Part 1), Dovenby is categorised as an ‘Infill/Rounding Off Village’ in the settlement hierarchy as set out in Policy S3, where only very small-scale development may be appropriate to respond to local needs and to contribute to the vitality of rural communities. The proposed 25 units are not considered to be ‘very small’ scale. The scale and form of the residential development would not accord with the criteria for being considered as ‘infill’ or ‘rounding off’ following the criteria set out in Policy S5. Furthermore, the scale of development is significantly in excess of that expected at the lowest tier of the settlement hierarchy (policy S3). It is anticipated that the Allerdale Local Plan (Part 1) will be formally adopted by the end of July and therefore these policies will carry full weight.
Therefore, please provide justification for the level of housing proposed.
Further, revised affordable housing policy will require a 25% provision at this location and Housing Services has identified a high need for 1 bed units, which differs from that proposed. Please consider this request and provide justification, if you are not able to meet the affordable housing requirements.
6. Hotel – sequential and impact assessment
Please provide a sequential and impact assessment for the proposal.
The application includes an outline proposal for a 60 room hotel out with any town centre and therefore it is considered that a sequential test and impact assessment are required in accordance the NPPF and policies S16 and DM8 of the emerging Allerdale Local Plan (Part 1). The proposal does not include any consideration of the impact of the proposal on the vitality or viability of nearby town centres or a demonstration of other hotel sites to justify the location. Given the location of Dovenby and the scale of the hotel development it is suggested that the nearest town centre that should be included is Cockermouth which is designated as a Key Service Centre. Policy DM8 suggests that in relation to Cockermouth the development threshold for the requirement of an impact assessment is 300 square metres.
Again, whilst tourism related development is referenced within saved Policy REM 10, the comments above relating to the weight attached to this policy remain applicable.
7. Potential loss of sports provision
The drawing titled ‘Dovenby Estate – Existing 081010/001’ references a cricket pitch. Please can you provide the status of this pitch in terms of who uses it, how regularly and on what basis?
8. Consideration of Alternatives within the Environmental Statement
The ES dismisses the alternative site of Kirkbride as ‘environmental effects would be in excess of those at Dovenby’, but no further explanation is provided. Further, in relation to Lillyhall, the ES states that there is ‘potential conflict with existing employment users and hen harriers’. However, employment users are less sensitive than residential users and it is likely that the Hen Harrier habitat could be mitigated. Therefore, further clarification on the suitability or otherwise of these alternative sites would be appreciated.
9. Consideration of Noise Impacts
The format of your submission generally includes a summary chapter for each topic within the Environmental Statement (ES) (Volume II), supported by a technical appendix which provides the detailed information from which the comments within the summary chapters of the ES are drawn. In relation to the issue of noise, a Noise Impact Assessment has not been appended, but you have referred us to the report ‘Assessment of Community Noise Levels’.
The ‘Assessment of Community Noise Levels’ is a brief document that does not provide for a full Noise Impact Assessment, nor does it follow the methodology used for other topics to ensure that the requirements of the EIA Regulations are met. It does not provide the full explanatory details for the development in relation to noise to support the summary conclusions reached in the ES chapter. Without this information, it cannot be understood how the summary conclusions relating to noise have been reached within the noise chapter of the ES, in particular, the significance of noise effects.
I consider that it is essential that a detailed technical appendix is provided for noise by way of a Noise Impact Assessment which follows a similar format to that prepared for other topics, such as Ecology and Heritage to ensure compliance with the EIA Regulations. Once this has been prepared in detail, the ES chapter for noise is also likely to require review. The technical appendix should ensure that the following are included:
Without this, I do not consider that the requirements of the EIA Regulations will have been met.
Specific comments relating to the noise chapter of the ES include:
The report also indicates that with a silenced vehicle, test vehicles can safely operate within the 43dB restraint. If this is the case, why are 132 additional days requested at a higher level?
Further comments have already been forwarded from colleagues in Environmental Health regarding additional technical information to be provided within this revised documentation.
10. Noise within the Non-Technical Summary (NTS)
I am concerned that the NTS fails to adequately explain the noise implications of the proposal in a manner that the general public can fully understand. The noise information provided to date has attracted criticism from the general public as to its ease of understanding. In particular, there is very little explanation of dB levels, what these noise levels are comparable to in terms of everyday noise, the nature/frequency of noise resulting from the proposed operations, the potential for peak noise levels within the average (LAmax and LAeq).
11. Consideration of Heritage Impacts
The Council’s Conservation Officer has advised that the Environmental Statement and supporting appendices do not provide sufficient information by way of an historic landscape assessment of the parkland/grounds, or an assessment of the setting of the hall (and therefore neither does it address the contribution that the setting makes to the significance of the listed building). Without these, it is difficult to evaluate the level of harm the proposals will have upon the significance of the listed building. It is therefore considered that further Heritage Impact assessment is required in this regard to describe and evaluate the historic landscape, the setting of the listed building, and the contribution the setting makes to the significance of the building and an assessment of the impact of the proposals upon the setting and significance of the building. This would be in line with NPPF para 128. English Heritage guidance on settings will be useful for this http://www.english-heritage.org.uk/publications/setting-heritage-assets/setting-heritage-assets.pdf.
The full comments of the Council’s Conservation Officer have been forwarded for reference.
It is noted from the ES Heritage chapter and the technical appendix that the parkland has been designated of low value as a heritage asset. As the setting to a Grade II listed building of at least medium value, it is unclear why the parkland setting is considered of low value. The further assessment requested above should provide a more detailed assessment of this issue.
The Council’s Conservation Officer has also raised concerns with the potential impact of the proposals given the proximity of the proposed housing to the Grade II listed building. It is understood that you will consider the housing element of the scheme, particularly given the policy issues highlighted above.
The Council’s Conservation Officer has confirmed that in respect to the hotel, the level of information provided by way of indicative outline drawings are sufficient, particularly given your confirmation that the existing mature landscaping will be retained between the proposed hotel and the Grade II listed building. A further/revised plan is requested which indicates the retention of this mature landscaping.
The following comments are also made in relation to the Heritage Technical Appendix:
In addition to the further assessment required by the Council’s Conservation Officer, please provide clarification/additional assessment required as a result of the above comments.
Cumbria County Council’s (CCC) landscaping comments question the sensitivity allocated to the Dovenby Hall Estate LCA given the historic nature of the site and the presence of ancient woodland, particularly as ancient woodland is a scarce resource. This issues ties in with the earlier comments from the Conservation Officer relating to the level of historic landscape assessment of the parkland. Please therefore consider these comments as part of the further review of the parkland setting of the Grade II listed building.
13. Designated Ancient Woodland
The Forestry Commission has objected to the proposal due to the loss of ASNW. They have accepted that part of the designated area of ASNW has not been ‘continuously wooded’ and would not therefore be subject to their standing advice, but that a small adjacent area of ASNW will require removal.
No detailed drawing has been provided that clearly shows the proposal in relation to the designated ASNW, the area that is designated but has not been continuously wooded, or the required buffer zone specified within the Forestry Commission/Natural England’s Standing Advice. Nor does the Ecological Technical Appendix reference the ‘buffer zone’ or provide clarification as to the extent of development within it, or the resulting impact.
I would therefore request that additional information be provided in this respect, by way of a plan that demonstrates the extent of development within the ASNW, the extent of development within the area of designated woodland that has not been ‘continuously wooded’, and the extent of development within the buffer zone, along with some assessment of the likely effects of any development within the buffer zone.
A full botanical survey is recommended within the supporting documents for the affected ‘designated ancient woodland’. You confirmed at our meeting that this survey is being undertaken.
14. Arboriculture Assessment
In respect to the submitted report:
Please provide further clarification/additional assessment as required as a result of the above comments.
15. Consideration of Ecology (Technical Appendix)
In respect to the submitted report:
Please provide the clarification/additional assessment required as a result of the above comments.
16. Foul Drainage
Please refer to the consultation response from the Environment Agency which raises an objection to the use of the existing Package Treatment Plant for the new development referenced within the Drainage Report. Page 2 of their response specifies the steps necessary to overcome their objection, which essentially requires the applicant to demonstrate why connection to the public sewer is not feasible either due to cost or practicability.
In our meeting you confirmed that foul drainage would connect to the public sewer and that your drainage consultant Curtins would be clarifying this position.
Please provide a response from your transport consultants regarding the additional requirements specified by the Highways Authority within the consultation response from Cumbria County Council, in particular relating to the pedestrian footpath required to Dovenby village as a result of the proposed housing development.
The Masterplan drawing shows significant parking levels adjacent to the MEC at 252 spaces, for 100 employees. Even if there is some overlap of shift workers, this number seems excessive for the proposed MEC facility. Can you please provide further clarification as to why this level of parking provision is required?
18. Buildings N and P
At present, both buildings N and P are located within areas that would require the loss of established and mature woodland. Could the location of these buildings be re-considered to remove/reduce the impact on woodland habitat?
19. Detailed drawings for MEC facility
Further to our meeting, it is understood that you intend to submit further elevational details of the MEC facility.
I would appreciate if the above information could be provided as one complete package to allow appropriate re-advertisement and re-consultation. Once you have had an opportunity to consider the comments fully, I would appreciate if you could give me an indication of timescales for the submission of the required information.
Please contact me if you wish to discuss any of the points further.
Head of Development Services