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All content are opinions and objections that were raised as part of the response to Msport planning application to Allerdale planning ref 2/2014/0350.  If you have any comment or disagreement then first realise that opinion is just that, opinion in a public planning process.  You may email factual errors to Contact @ dovenbynoise.info

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Environmental Health Officer criticises noise plan

June 10th 2014

10 June 2014


Dovenby Hall, Dovenby, Cockermouth, Cumbria, CA13 0PN


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.

Planning Application Reference: 2/2014/0350


We refer to the recent consultation for the above application and have split it into relevant areas. These being Noise from the Development, Contaminated Land, Construction and Lighting.


1. Noise from the Development


Before sending formal comments and correspondence to the Planning Application on Noise from the Development, Environmental Health would like the applicant to address the following comments. Once all comments have been addressed, clarified and submitted, we will then send a full detailed response. At present however we feel the information submitted is not complete to enable us to provide our final comments at this stage.


However.  at this stage we would wish to raise some issues , we have split each noise report and have comments listed under each heading. We have also concluded with a number of points.


Assessment of Community Noise Levels

1. This document is four pages of information and the rest of the document looks at results, formulas and tables. There is no definitions of terminology anywhere in the document and doesn't follow a standard noise report making it very hard to understand.


2. The majority of the document is looking at barriers, however it doesn't specify or have any conclusions as to which barrier will be used and what the LAeq/Lmax will be as a result at the 10m from trackside and the seven properties.


OVERALL - Difficult to understand and doesn’t follow an adequate Noise Impact Assessment based on the principles of BS4142.


Environmental Statement

1. Even though noise has been documented in the Environmental Statement (ES) it needs to make more reference to relevant British Standards (i.e BS4142) and World Health Organisation Guidelines for Community Noise (WHO).


2. There is no mention of Lmax and in 8.2.3 it states LAeq (1 Hour) has been agreed with ABC. The consultant is also aware we agreed Lmax and these need to be provided.


3. The diagram of measurement locations in Figure 8.1 is incorrect as it only refers to four locations and not the seven listed in other documents.


4. The ES is mainly talking about Construction Noise as opposed to noise from the Evaluation Centre and Test Track. This needs to be included as part of the ES as Construction Noise is temporary and can be dealt with by way of Planning Condition (please see below).


5. The Figure 8.2 is incomplete and therefore needs to reflect other documents submitted as part of the application.


  1. The top of page 52 makes reference to “no audible noise in the community”. Can more clarification be made on this statement. It also refers to Cycle days but we were unaware that motorcycles would be used on this track.


7. Paragraph 8.5.2 makes reference to the vehicle attenuation and reduction in noise by its use. No details of this attenuator have been provided with this application to date.


OVERALL - a number of issues need to be rectified and explained. The whole focus is largely on Construction as opposed to the actual use of the track. This needs to include much more details on test track design, bunding, silencers along with LAeq and Lmax. Certain diagrams are also incomplete or incorrect and need to be changed. In order to gain an understanding of impact a final design of the track needs to be submitted which will form part of the assessment when designing the mitigation measures.


Draft Acoustic Strategy

1. We are unclear why a Draft Acoustic Strategy has been included as part of a Formal Planning Application. This document needs to be revised and re-submitted.


OVERALL - this document is what is says “Draft” and should not have been submitted in its current form. This document should adopt the principles of BS4142.


Noise Management Plan Strategy

1.This is one of the most important documents and as result this document needs to be more detailed and lengthy and also include Lmax as previously discussed with the applicant and noise consultant. These Lmax figures will run alongside the LAeq figures already presented at 10m from source as a control.


2. This document also needs to include days per week/per month as previously discussed with the applicant and noise consultant. It was also agreed that after any “Noisy Day” there would be one day of rest. For example:


No Limit Day/12 Days per Year/Maximum 3 Hour Day/No more than 1 No Limit Day per Month Monday to Friday


60dB/45 Days per Year/Maximum 5 Hour Day/No more than 1 60dB Day per Week Monday to Friday


50dB/75 Days per Year/Maximum 7 Hour Day/No more than 2 50dB Days per Week Monday to Saturday


3. Confidence needs to be provided in the plan as to how complaints would be dealt with if necessary and a more detailed method of communicating with the public needs to be established. A website needs to be created with a diary detailing when Category 1, 2 or 3 days will be taking place. On a weekly basis results also need to be sent to ABC to show compliance,


  1. Static noise equipment needs to be used as opposed to hand held equipment and this needs to be directly accessible by ABC remotely if necessary.


5. Additional information needs to be provided in relation to the Corporate Days within the Noise Management Plan and such an event will be controlled as there will be other noise sources that need to be considered.


OVERALL - This document lacks detail and need to be developed further. It needs to explain how the noise equipment will work and be located, how information will be provided to the public and the EHO/LPA. It is our view the system needs to be live and can be accessed by the EHO in the event of complaint, additionally results need to be sent weekly and a noise diary needs to be on a website for the public. It needs to include Lmax and more detail on Category of Use days. As the consultant is aware in any one hour period the car may be on the track for 5-10 minutes only so it essential to control maximum noise levels. Additionally tyre squeal needs to be mentioned and how it will be controlled. This noise management plan is the most important document for Environmental Health and in its current form is insufficient.


Conclusion


1. All documents listed need amendments and changes and it is the view of Environmental Health that these numerous documents become one document. This will make it easier to read and understand without conflicting information in numerous documents. These documents also need to be made easier for the General Public to understand and need a list of abbreviations as set out throughout the document.


2. The documents also do not give any confidence regarding noise management on the site and how this will be dealt with effectively. A noise diary needs to be established on a website detailing wind speed, direction and category of day. The whole operation needs to be open and transparent and establish a relationship with residents.


3. The noise documents fail to refer to the proposed Housing development or Hotel and this also needs to be included in the detail of the reports.


4. The initial Scoping Report stated that a Noise Impact Assessment (not included as part of the application) should follow the guidelines in BS4142. Can this be submitted as a matter of urgency with all other documents falling part of the same document.


5. There is no detail on the proposed Silencer. This needs to be submitted.


6. Lmax needs to be provided as part of the Pyramid at 10m from source and the seven receptor locations as well as the proposed housing and hotel.


  1. LAeq(S) is provided in the documents - can this be explained as to its meaning.


8. We are sure the applicant is well aware most of the public objections now relate to noise from the test track. It is there essential all points are considered, a new noise report is submitted detailing all necessary information in a clear, understandable way and a new Noise Management Plan is submitted in more depth and detail showing how noise will be controlled.


  1. Contaminated Land


We have looked through the Phase 1 report and it is comprehensive and covers all the areas of potential contamination expected with the previous uses and surrounding land uses. The report advises that further site investigation works are undertaken however these are localised to areas where there has been oil storage and petrol/diesel stores and an area of the old hospital where there was an incinerator and mortuary. This approach is reasonable however if contamination is found within these areas further investigation should be undertaken.


Based on the Phase 1 report conclusions we would recommend the following conditions are applied to any approval granted:

No development approved by this permission shall commence until all necessary site investigation works within the site boundary have been carried out to establish the degree and nature of the contamination and its potential to pollute the environment or cause harm to human health. The scope of works for the site investigations should be agreed with the Local Planning Authority prior to the commencement.

Reason:  To minimise any risk arising from any possible contamination from the development to the local environment in compliance with Policy EN9 of the Allerdale Local Plan(saved).


Where land affected by contamination is found which poses unacceptable risks to human health, controlled waters or the wider environment, no development shall take place until a detailed remediation scheme has been submitted to and approved in writing by the Local Planning Authority. The scheme must include an appraisal of remediation options, identification of the preferred option(s), the proposed remediation objectives and remediation criteria, and a description and programme of the works to be undertaken including the verification plan.

Reason: To minimise any risk arising from any possible contamination from the development to the local environment in compliance with Policy EN9 of the Allerdale Local Plan (saved).


Should a remediation scheme be required, the approved strategy shall be implemented and a verification report submitted to and approved in writing by the Local Planning Authority, prior to the development (or relevant phase of development) being brought into use.

Reason: To minimise any risk arising from any possible contamination from the development to the local environment in compliance with Policy EN9 of the Allerdale Local Plan(saved).



In the event that contamination is found at any time when carrying out the approved development that was not previously identified it must be reported immediately to the Local Planning Authority. Development on the part of the site affected must be halted and a risk assessment carried out and submitted to and approved in writing by the Local Planning Authority. Where unacceptable risks are found remediation and verification schemes shall be submitted to and approved in writing by the Local Planning Authority. These shall be implemented prior to the development (or relevant phase of development) being brought into use. All works shall be undertaken in accordance with current UK guidance, particularly CLR11.

Reason: To minimise any risk arising from any possible contamination from the development to the local environment in compliance with Policy EN9 of the Allerdale Local Plan(saved).


3. Construction


We have considered the draft construction environmental management plan submitted with the application and as a draft document this is satisfactory. The applicant has made reference to a formal code of construction practice being produced. This should have specific measures from the appointed contractor on how they will control noise, dust and vibration from the construction works. Therefore to ensure that this is completed we would advise that the following condition is attached to any approval granted:


Construction Management Plan:


No development shall take place until a Construction and Demolition Method Statement has been submitted to and approved in writing by the Local Planning Authority. The statement shall include the following:

(a)     Traffic Management Plan to include all traffic associated with the development, including site and staff traffic;

(b)     Procedure to monitor and mitigate noise and vibration from the construction and demolition and to monitor any properties at risk of damage from vibration, as well as taking into account noise from vehicles, deliveries. All measurements should make reference to BS7445.

(c)     Mitigation measures to reduce adverse impacts on residential properties from construction compounds including visual impact, noise, and light pollution.

(d)     Mitigation measures to ensure that no harm is caused to protected species during construction.

(e)     A written procedure for dealing with complaints regarding the construction or demolition;

(f)      Measures to control the emissions of dust and dirt during construction and demolition;

(g)     Programme of work for Demolition and Construction phase;

(h)     Hours of working and deliveries;

(i)       Details of lighting to be used on site.

The approved statement shall be adhered to throughout the duration of the development.

Reason:  In the interests of the amenity of the occupiers of neighbouring properties, in compliance with Policy EN6 of the Allerdale Local Plan, Adopted 1999 (Saved).



4. Lighting


We have noted that lighting is proposed within the parking areas close to existing residential properties. I would request that a lighting spillage plan is submitted to provide details of the lighting lux levels at the nearest residential properties. The following condition would apply:


Before the use of the lighting system hereby approved commences a lighting impact assessment by a suitably qualified engineer shall be submitted to and approved in writing by the Local Planning Authority and unless otherwise agreed in writing by the Local Planning Authority the levels of lumination generated by the lighting shall not depart from those levels which are specified in the approved assessment.

Reason: To safeguard the amenity of nearby residential properties, in compliance with Policy EN6 of the Allerdale Local Plan, Adopted 1999 (Saved).


  1.  Additional Points


If the main building are involved in the use of solvent products (vehicle respraying or waste oil burners) the applicant needs to contact Environmental Health at Allerdale Borough Council on 01900 702580 to arrange for an appropriate Environmental Permit for such activities.


From:Tranter, Sian

To:Outhwaite, Ric [Head of Planning Services]

Sent:12 June 200216:14


Subject: RE:Mlxed use Scheme of development at Dovenby Hall Estate, Cockermouth


ref:2/2002/0424


In respect of the above proposal's I would make the following comments;

The above application includes a multi-purpose unit being situated In close proximity to proposed dwellings. If

permission was granted for the housing development and the above unit I would not wish to support this

Application.


Potential uses are likely to be incompatible in that the workshop unit has potential to cause noise and

odour nuisance to any future occupants of the dwellings.


Multl-purpose unit for M Sport activities


If the workshop application were to be In considered In Isolation, I would recommend that the following conditions were imposed if permission were granted;


Whereby the noise level emitted from the operations of the workshop which wll include all mechanical service, plant and equipment when assessed 3 metres from the facade of any noise sensitive premlses (i.e existing residential

properties in Dovenby) shall not exceed an equivalent continuous sound pressure level (LAEQ) of 45 dBA in any one hour period between the hours of 8.00am and 11.00pm and LAEQ of 30dBA In any five minute period between the hours of 11.00pm and 8.00am when measured and rated in accordance with BS7445 Parts 1, 2 and 3.


The applicants shall demonstrate to the satisfaction of the planning authority that the premises can comply with the

noise condition.


Details of all noise and odour control measures shall be submitted to and approved by the planning authority and shall be in place before the premises is brought into use.


No development approved by this permission shall be commenced until a desk study has been undertaken and

agreed by the Local Planning Authority to Investigate and produce an assessment of the risk of the potential for on-site contamination. If the desk study identifies potential contamination a detailed site investigation should be carried out to establish the degree and nature of the contamination and Its potential to pollute the environment or cause harm to human health. If remediation measures are necessary they will be implemented in accordance with the assessment and the satisfaction of tha Locel Planning Authority.


12 Detached dwellings & plav area


If the housing development were to be considered in isolation, it is unlikely that we would raise any objections to this proposal


Erection of an Hotel


We have no objection in principle to the proposal.


Change of use proposals


We have no objection in principle to the proposals.


Finally, considering the planning application as a whole there are conflicts with certain proposed uses and there

location within the site.

Sian


My file ref: 2002 06 12 Environmental Health Officer Sian Tranter objects to noise


This was the EHO report to application:

2002 Planning Officer Report for MSport 2002 application ref 2 02 0424

Environmental Health Officer recommends noise limits

June 12th 2002