11/00713/F - Borough Council of King's Lynn & West Norfolk

The highest scoring site, if the scores for the other sites remained the same, would then be
Site 4 (Costessey). It is stated in para. 5.1.14 that ‘Due to its limited size Site 4 would only
potentially be able to accommodate the EfW facility element of the proposal…The IBA
Recycling Area would need to be accommodated elsewhere’. However, officers suggest
that the close proximity of sites in the ‘Safeguarded Waste Sites for South Norfolk’, together
with the ‘Potential Waste Sites for South Norfolk’ means that both the EfW facility and the
IBA Recycling Area could be accommodated within these sites. Of further interest is that
WAS82 has been ruled out for ‘landscape reasons’ even though in the supporting text it
states that “…there may be possibility to locate certain facilities on the western edge of the
site…”. (Prior to its removal, WAS31 abutted WAS82 at its north western most point.)
Officers believe that the assessment described in the preceding paragraphs shows elements
of inconsistency and of manipulating the figures to suit the site at the Willows. The
Alternative Site Assessment is therefore considered to be far from robust.
Furthermore, the lack of an adopted DPD makes any assessment almost impossible and the
most recent documents out for consultation seem to have been written on the basis that The
Willows is a fait accompli.
Traffic and Transport
In commenting on the Scoping Opinion (a document produced to identify the scope of an ES
before it is prepared) the Highways Agency stated that ‘there will be a need to
manage…traffic in order to avoid peak flow periods such [sic] that the continued operation of
the Saddlebow interchange is not compromised”.
Chapter 6 of the ES sets out the transport assessment of the impact of the development. It
assumes that traffic will be distributed evenly throughout the day with a total of 270 two way
movements (135 in, 135 out) comprising of staff, refuse vehicles and other deliveries. Of
these, 30 two way movements will occur in each highway peak (morning and afternoon).
There are a number of issues with the assumptions made. First of all, the Borough Council’s
Waste and Recycling Manager comments that the figures ignore the fact that Refuse
Collection Vehicles tip more than once a day and does not include light commercial vehicles
delivering fridges, street litter and street sweepings. Consequently, the figures represent an
underestimate of vehicle movements. Secondly, the assumption vehicles will arrive
smoothly across the day is also flawed. Loading and transport rates for locally sourced
contract waste and light commercial vehicles carrying waste create distinct peaks and
troughs in delivery and these have not been properly accounted for.
In considering the Palm Paper application, both Norfolk County Council as Local Highways
Authority and the Highways Agency as the Trunk Roads Authority stipulated a condition
should be attached requiring that no heavy goods vehicles shall leave the development site
during the period between 0800 and 0900 and between 1700 and 1800. Notwithstanding
the concerns expressed in the previous paragraph, the ES shows 14 HGVs leaving in the
morning peak and 9 leaving in the evening peak hour. Given the concerns expressed by the
Highways Agency regarding the need to avoid peak hour traffic, the application has failed to
demonstrate that the development will not have an adverse impact upon the capacity of
either the local or trunk road network.
11/01064/CM Development Control Board
25 July 2011
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