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

However, the assessment concentrates on the employment generated by the project and
where workers may live. What it does not do is make any attempt to quantify how the
presence of an EfW plant could affect the ability of the Borough to attract inward invest in
line with King’s Lynn’s status as a Growth Point and with LDF Core Strategy policies CS01
and CS03. The Regeneration Manager states that two major employment development
zones (NORA and the Hardwick Industrial Estate Expansion) are located close to the site for
the EfW plant and expresses concern that, given the controversial nature of the
development, there is some concern that the EfW plant could discourage investment
decisions by both existing and new business investments.
In the absence of information to address these concerns, it has to be concluded that the ES
does not adequately address criteria (d) and (e) of policy EC10 in PPS4 and could also
adversely impact upon Core Strategy policies CS01 and CS03.
Amenity
This covers noise, vibration, dust and odour. The comments of the Council’s Environmental
Health section are recorded previously in this report. From these comments, the impact of
the development can be adequately controlled through the use of appropriate conditions, as
has been done on other consents in the area.
Currently, the ES proposes no mitigation for noise during the construction period other than
by following best practice in a site management plan. Environment Health express concerns
at this approach and suggest that construction work is limited to within certain time periods
over the 32 month construction period. This would bring the development in line with other
major construction projects in the area, including Palm Paper. Without these conditions, the
development would be contrary to guidance in PPG24.
CONCLUSION
The proposal to site an Energy from Waste Plant on the Willows Business Park is flawed. It
has not been correctly assessed against relevant national policy contained in PPS1, PPS10
and EN3 and indeed is contrary to a number of the provisions within those documents. For
example, it does not conform to the ‘proximity principle’, which states that waste should be
processed near to where it is generated and it would not respect the waste hierarchy as it
would compete for waste that could be dealt with by more appropriate measures such as
composting. Because it does not respect the ‘proximity principle’ and because of its location
on the western edge of the County area it is supposed to serve, the EfW does not represent
a sustainable form of development.
The assumptions underlying the ES are also flawed. It assumes that the emerging Waste
Core Strategy will be found to be sound and that the same will happen to the consequent
Site Specific Allocations DPD. Given that there remain unresolved concerns over the ability
of the Core Strategy to actually produce a coherent network of appropriate waste
management facilities to deal with the forecast amounts of waste over the plan period,
relying upon the emerging policies rather than the current national ones carries a high level
of risk and is wrong in planning terms. It also unnecessarily and inappropriately restricts the
assessment of alternative sites for the proposed development.
Technically and regardless of the policy issues, the ES is inadequate as submitted. It fails to
adequately address the flood risk to which the development is exposed; does not adequately
demonstrate that the development will not have an adverse impact upon the road network;
does not adequately assess the cumulative landscape and visual impact of the scheme and
neglects the sensitivity of Roydon Common SSSI/SAC to acid deposition. Consequently, the
11/01064/CM Development Control Board
25 July 2011
33