Know your past, appreciate what is special, preserve our environment
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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APPLICATION FORM - Misleading, false or absent Information
Application form section 21 states site is 21 Hectares.
MM Flood Risk Assessment page 19 states
The development is anticipated to result in approximately 10.2 Hectares of additional impermeable area associated with the new infrastructure
Curtins Drainage Strategy page 4 1.3 states the development site is 10.9 Hectares
According to two of the applicant’s consultants half of Dovenby Hall Estate will be covered in concrete or tarmac.
In addition existing buildings and roads already cover approximately 3 hectares (using Defra Magic map area tool)
Section 23 Hazardous substances
No explanation of how the storage of oil, brake fluid, and battery acid for hybrid cars and possible lithium for batteries of hybrid cars missing. No explanation of safe storage of gas bottles for welding nor fibre and flammable gels nor hazardous chemicals.
22 Industrial or Commercial Process and Machinery
The applicant is clear that cars will be manufactured by MSport and by other manufacturers who will manufacture and test their own vehicles in this building.
Manufacture of cars in automotive industry (applicant states in section 14) is an industrial process using machinery. This section should not be blank. This section omits essential information about the essential machinery and industrial process that the applicant seems to propose. Even air conditioning is omitted.
How can a car manufacturing facility can operate without industrial machinery or processes? There is no explanation of metalwork machinery including cutting, grinding, bending and welding.
If spray painting or epoxy resin fibreglass is done then there are hazardous fumes that must be stated and dealt with.
Spray painting and resin activity are likely to classify the use of the building as B2 Industrial and thus not suitable for location beside residential houses. This may be why this section of the application form was blank !
The EHO stated in para 5 of
2014 06 10 From Allerdale Env Health FOR further noise information from Msport
“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.
“If these activities are carried out then a complaint may be made and planning enforcement insisted on.
Section 20 Hours of opening
Hours of opening includes all hours in all days ie days as well as hours. There is no clear explanation of hours of opening on the application form.
HOWEVER 24 hour operation is stated:
in ND D&A p12 3.1 “there is likely to be some element of 24hour working within the new facility” , and p25 “The Evaluation Centre is likely to have 24hour working”
Also see Env Stat Vol II p25 2.2.30 The MEC building will have 24 hour working therefore lighting is required at this location for safe access/egress for employees.
The race track hours are potentially 8 am to 8 pm
Under their vague explanation of noise limits they could operate every day of the year if below a theoretical
Existing amenity noise level.
24 hour working would likely mean 24 hours of extractor fans, roof mounted air conditioning and delivery vehicles and workers coming and going from Dovenby Hall Estate.
16 Trade Effluent: Missing information.
This must be the only garage in the world that does not have to get rid of oil changes!
Information is required about how coolant, brake fluid, engine oil or lubricants, acids, alkalis, heavy metals and paints and solvents get dealt with safely; all are used in car manufacturing and testing.
This would be a test track where the nature of testing fast powerful race cars means that occasionally there will be accidents causing leaking of fluids from the vehicle, oil, coolant petrol, brake fluid, or battery acid. The track is part of their industrial process.
The detail needs to be shown of how trade effluent be dealt with when it is on the track when it may be raining and may get flushed into the stream and how the separated filtered pollution is dealt with.
The skid circle is to be sprayed with water which will drain into Brides Beck and then into the SSSI waters of Derwent. How will the rubber from tyres and the oil, exhaust condensates, liquids from crashes all be kept as trade effluent and non polluting effluent that could be washed into the SSSI river system?
The use of hybrid cars may require special measures for dealing with battery systems that may have acid, lead, nickel cadmium lithium and other poisonous pollutants.
No explanation of storage or disposal of oil, brake fluid, and battery acid for hybrid cars and possible lithium for batteries of hybrid cars missing. No explanation of safe disposal of excess fibre and flammable gels nor hazardous chemicals.
Curtins Drainage Strategy page 6/7 section 1.6 last 2 paras clearly explains that there is no plan or detail of how pollution or effluent will be gathered or controlled.
SECTION 13 Biodiversity and Geological Conservation
Incorrect statement that there are no protected or priority species on land adjacent to the proposed development.
The bat survey identifies bats in a house in Dovenby village.
There has been no attempt to involve villagers or the Parish Council in ascertaining if protected and priority species are adjacent to the site. There is lots of evidence in the village and the presence of so much wildlife that lives in our area or visits us from the Dovenby Hall Estate is one of the motivations of anger and alienation and rejection that we feel about this application.
We enjoy from DHE bats, red squirrels, woodpecker, kingfisher, probable barn owl, certainly tawny owl and more. We were never consulted by the applicant or their consultants. The applicant should ask Dovenby Parish Councillors to organise local input about our observations of wildlife adjacent to the site.
No phased mitigation for bats; all buildings destroyed, key trees removed, then 18 months before MEC is built and bat boxes installed; no interim habitat or foraging location identified and planned.
Baseline in ESVII p43 does not include more than 20,000m2 of Forestry Commission licensed clear fell and more felling in thinning licence. All 31,000m2 of trees to be removed and the extra trees to be thinned need surveyed for the baseline that should be resurveyed annually as per Openspace survey caveat, report valid for one year.
Openspace Bat survey incomplete; EnvStatVIII 1-84 page 81appendix C shows derelict school building with low bat potential. Guidelines state that unless it has zero potential that it should be surveyed. Openspace BS page 10 states that no internal inspections nor roof space inspectins occurred. I was informed by another bat surveyor that it is normal practice to wear appropriate protective clothing and inspect these areas. The bat survey needs to be complete and should be resurveyed and resubmitted.
11 Foul Sewage
Curtins Letter 28.7.17 re UU 29-8-14 p1 last para does not state the number of extra users the calculation is based on. Staff increased by half, 200 to 300; 100 extra people; Parking for potentially a thousand staff and visitors; the capacity of the foul system needs to be based on users and the number of users is unclear.
Section 10 Vehicle Parking
The description of “car parking 242 spaces” does not tally with Total extra 459 in the applicant’s information in section 10. One figure is false or misleading. Unclear; needs clarifying.
There are 938 vehicle places and applicant states there are currently 180 - 200 MSport employees plus 100 proposed as a result of employment over ten years in MSport’s hotel, MSport’s offices, unspecified manufacturing building, MEC car manufacturing factory, race track. Why so many parking spaces are required for so few employees?
There is no clear explanation of parking requirements in Environment Statement Vol 1 which thus fails the Scoping Decision 2011.
From Allerdale Planning request for additional information 3 July 2014
Section 17 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?
No clarification of parking place requested by Allerdale planning in July resubmission requirement.
Where is previous planning permission for the number of vehicles parking places that currently exist? I have never seen a neighbour consultation for the 466 parking places and 10 artic parking places that the applicant states they have built.
Evidence of permission required for existing parking places.
Were neighbours consulted? If so when? Has there been illegal building without permission? If so should the full application be suspended until retrospective planning application has been made for the car parking places and neighbour consultation carried out?
Section 6 Pedestrian and Vehicle Access, Roads and Rights of Way
Drawing 081010-005 shows “Increase footpath width” opposite Ship Inn. Road width and pavement measurements are omitted. The road is narrow here and a footpath would restrict the main road width where there is an offset crossroad which will increase danger to traffic and pedestrians.
Drawing 081010-154 shows that safe sight lines North from vehicles waiting to enter the A594 at the Eastern entrance require drivers to cross to the middle of the road and view traffic while blocking the carriageway from Cockermouth.
Sight lines to Cockermouth & the South have a bridge parapet, a dip in the road and traffic waiting for slow lorries to exit would back up to a crossroads at a blind summit.
There are regular accidents on the South side of the crossroads - see the debris of the fences.
This temporary entrance / exit will be used for many HGVs up to 40 tonnes and slow to accelerate onto the South side of the road. Some HGVs will be very long with large machines and huge cranes that are very slow moving and long and will need to swing out on the other carriageway when entering or leaving and block oncoming traffic potentially causing accidents.
Tree removal to facilitate the widened entrance is unclear and detail not specified as required in Scoping Decision 2011 and in Allerdale LPA clarification request of July 2011. See my 2014 10 28 To planning Dangerous Eastern Access.
Traffic exiting the construction site would deposit mud on the A594 causing a traffic hazard. A wheel and chassis cleaning station wide enough for two lorries entering and exiting is required with water wash runoff capture and filtering to stop it entering Brides Beck and SSSI Derwent.
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