Who to send the letter to…Who to send the letter to…

Ms Morag Little,Ms Morag Little, Area Manager (Hamilton Area Office),Area Manager (Hamilton Area Office), SLC Planning, Building Control Estates,SLC Planning, Building Control Estates, Enterprise Resources,Enterprise Resources, Brandongate.Brandongate. 1 Leechlee Road.1 Leechlee Road. Hamilton. Hamilton. ML3 0XB.ML3 0XB.

Heading for objection letter.Heading for objection letter.

Planning Application Reference Planning Application Reference HM/10/0345HM/10/0345

Land off Carlisle Road Carlisle Road Land off Carlisle Road Carlisle Road Stonehouse ML9 3PR Stonehouse ML9 3PR 

Construction and operation of a Construction and operation of a waste sorting and resource recovery waste sorting and resource recovery facility, with capacity to process up facility, with capacity to process up to 150,000 tonnes of waste per to 150,000 tonnes of waste per annumannum  

Personal statement.Personal statement.

I refer to the above planning I refer to the above planning application and wish to lodge the application and wish to lodge the following, objections, observations and following, objections, observations and comments on the proposal on behalf of comments on the proposal on behalf of Stonehouse Community council based Stonehouse Community council based on the aforementioned headings. on the aforementioned headings.

Personal statement 2.Personal statement 2.

I refer to the above planning application I refer to the above planning application and wish to lodge the following, and wish to lodge the following, objections, observations and comments objections, observations and comments on the proposal on behalf of George on the proposal on behalf of George Smith.Smith.

I also wish to state that SLC as potential I also wish to state that SLC as potential clients of Scotgen should not adjudicate clients of Scotgen should not adjudicate on this application. on this application.

GLASGOW & CLYDE VALLEY GLASGOW & CLYDE VALLEY STRUCTURE PLAN.STRUCTURE PLAN.

Development in this area is contrary Development in this area is contrary to the Glasgow & Clyde valley to the Glasgow & Clyde valley structure plan.structure plan.

SCOTTISH PLANNING SCOTTISH PLANNING POLICY.POLICY.

Scottish Planning Policy 21Scottish Planning Policy 21 Green Green belt clearly indicates that planned belt clearly indicates that planned growth is directed to appropriate growth is directed to appropriate locations and to protect and enhance locations and to protect and enhance the character and settings of towns. the character and settings of towns. The planned location is neither The planned location is neither appropriate and will not enhance the appropriate and will not enhance the character of Stonehouse and character of Stonehouse and surrounding area.surrounding area.

PLANNING ETC (SCOTLAND) PLANNING ETC (SCOTLAND) ACT 2006.ACT 2006.

Scottish Planning Policy (paragraph 129)Scottish Planning Policy (paragraph 129) intimates that all public bodies including intimates that all public bodies including planning authorities have a duty to the planning authorities have a duty to the conservation of biodiversity under the Nature conservation of biodiversity under the Nature conservation (Scotland) Act 2004.conservation (Scotland) Act 2004.

Paragraph 131Paragraph 131 also intimates that landscapes also intimates that landscapes and the natural heritage are sensitive to and the natural heritage are sensitive to inappropriate development and planning inappropriate development and planning authorities should ensure that potential authorities should ensure that potential effects including the cumulative effect on effects including the cumulative effect on incremental change are considered when incremental change are considered when preparing development plans or determining preparing development plans or determining planning application.planning application.

PLANNING ETC (SCOTLAND) PLANNING ETC (SCOTLAND) ACT 2006.ACT 2006.

The pre-application consultation process The pre-application consultation process was flawed in that at no stage were the was flawed in that at no stage were the negative impacts of the development negative impacts of the development stated, and how these would be stated, and how these would be addressed. The event was over one day addressed. The event was over one day and given the scale, nature and the and given the scale, nature and the significant effects on the surrounding significant effects on the surrounding villages this event should have been held villages this event should have been held over 2-3 days in order to capture all over 2-3 days in order to capture all surrounding villages.surrounding villages.

4. SOUTH LANARKSHIRE 4. SOUTH LANARKSHIRE LOCAL PLAN.LOCAL PLAN.

This Planning application is contrary This Planning application is contrary to the following local plan policies and to the following local plan policies and objectives laid down within them. objectives laid down within them.

Our objections are based on theses Our objections are based on theses polices and we have laid out our polices and we have laid out our reasoning as to why they are contrary reasoning as to why they are contrary to the policies. to the policies. They are laid out in no order of They are laid out in no order of

importance. importance.

4. 4. a)a) STRAT 3 GREEN BELT AND STRAT 3 GREEN BELT AND URBAN SETTLEMENTS IN THE GREEN URBAN SETTLEMENTS IN THE GREEN

BELT POLICYBELT POLICY

Policy states that “Policy states that “within the greenbelt the within the greenbelt the council will strongly resist the encroachment or council will strongly resist the encroachment or introduction of urban usesintroduction of urban uses. There shall be a . There shall be a general presumption against all development general presumption against all development except where it can be shown to be necessary for except where it can be shown to be necessary for the furtherance of agriculture, horticulture, the furtherance of agriculture, horticulture, forestry, recreation or other areas considered by forestry, recreation or other areas considered by the council to be appropriate to the green belt”.the council to be appropriate to the green belt”.

This development is not appropriate as it does not This development is not appropriate as it does not seek to enhance the environmental quality of the seek to enhance the environmental quality of the area as stated in this policy. area as stated in this policy.

It does not fit nor is it compatible with the It does not fit nor is it compatible with the surrounding environs.surrounding environs.

STRAT 4 ACCESSIBLE RURAL STRAT 4 ACCESSIBLE RURAL AREA POLICY.AREA POLICY.

An objective of An objective of STRAT 4STRAT 4 is to build on the is to build on the economic potential of the areas high quality economic potential of the areas high quality natural and built environment and tourism natural and built environment and tourism potential ensuring that these qualities are not potential ensuring that these qualities are not eroded. This planning application does the eroded. This planning application does the opposite of this in that it will discourage opposite of this in that it will discourage tourism, inward residential development and tourism, inward residential development and could have a potential to harm the economic could have a potential to harm the economic income of the Clyde valley growers. This income of the Clyde valley growers. This development does not seek to enhance the development does not seek to enhance the environmental quality of the area and will not environmental quality of the area and will not assist in protecting the biodiversity, natural assist in protecting the biodiversity, natural and cultural assets that surround the environs and cultural assets that surround the environs of the planning application site. of the planning application site.

ECON 1 INDUSTRIAL LAND ECON 1 INDUSTRIAL LAND USE POLICYUSE POLICY..

Policy indicates that areas outlined Policy indicates that areas outlined for industry will continue primarily in for industry will continue primarily in industrial use. industrial use.

The area identified for this The area identified for this development is not appropriate for development is not appropriate for the use planned.the use planned.

4. 4. d)d) ECON 4 INDUSTRIAL LAND ECON 4 INDUSTRIAL LAND SUPPLY POLICYSUPPLY POLICY..

The council maintains a 10 year The council maintains a 10 year supply of marketable industrial land supply of marketable industrial land and this application should be and this application should be directed to one of the marketable directed to one of the marketable sites.sites.

4. e)4. e) ECON 5 PROPOSED ECON 5 PROPOSED INDUSTRIAL SITE POLICYINDUSTRIAL SITE POLICY..

States that the council will support States that the council will support development for industry and development for industry and business on those sites identified in business on those sites identified in the industrial land audit. This site is the industrial land audit. This site is not identified on this land audit and not identified on this land audit and therefore the application should be therefore the application should be rejected due to this non inclusion.rejected due to this non inclusion.

ECON 13 NON CONFORMING ECON 13 NON CONFORMING USES IN INDUSTRIAL AREAS USES IN INDUSTRIAL AREAS

POLICYPOLICY.. This policy outlines the criteria against which This policy outlines the criteria against which

proposals for uses which do not conform to the proposals for uses which do not conform to the general industrial policy will be assessed against. general industrial policy will be assessed against. Bullet point f outlines the criteria “that the Bullet point f outlines the criteria “that the development will not adversely affect public safety” development will not adversely affect public safety” Public safety and health will be put at risk should Public safety and health will be put at risk should this development be granted permission. Bullet this development be granted permission. Bullet point g looks to consider the impact on the transport point g looks to consider the impact on the transport network and the pressure put on this rural road network and the pressure put on this rural road should not be ignored.should not be ignored.

Bullet point h outlines the criteria of not adversely Bullet point h outlines the criteria of not adversely affecting the natural or built environment. This affecting the natural or built environment. This development will adversely affect the natural development will adversely affect the natural environment being so close to Natura 2000 environment being so close to Natura 2000 conservation sites. conservation sites.

ECON 13 NON CONFORMING ECON 13 NON CONFORMING USES IN INDUSTRIAL AREAS USES IN INDUSTRIAL AREAS

POLICY.POLICY. As part of the reasoned justification for As part of the reasoned justification for

examining a site being considered in principle examining a site being considered in principle for a non conforming use the council are for a non conforming use the council are required to ensure that the proposal will not required to ensure that the proposal will not undermine the vitality and viability of an undermine the vitality and viability of an existing town and village. existing town and village.

This planned development will stop the This planned development will stop the planned residential development of planned residential development of Stonehouse & surrounding areas, with the Stonehouse & surrounding areas, with the council losing out on council tax income and council losing out on council tax income and other associated incomes.other associated incomes.

ENV 4 PROTECTION OF THE ENV 4 PROTECTION OF THE NATURAL AND BUILT NATURAL AND BUILT

ENVIRONMENT POLICYENVIRONMENT POLICY.. This site neighbours Natura 2000 conservation This site neighbours Natura 2000 conservation

sites covered by SLC policy reference sites covered by SLC policy reference ENV 20ENV 20 and this policy states that any proposals which and this policy states that any proposals which would affect the relevant interest for which the would affect the relevant interest for which the site is designated will only be allowed if there site is designated will only be allowed if there is no alternative solution. In this case there is no alternative solution. In this case there are alternative solutions.are alternative solutions.

The development could be referred to an The development could be referred to an

industrial zoned site. The social economic industrial zoned site. The social economic benefits outlined within the application can not benefits outlined within the application can not be verified and have not been subjected top be verified and have not been subjected top any model analysis.any model analysis.

ENV 18 /39 WASTE MANAGEMENT ENV 18 /39 WASTE MANAGEMENT POLICYPOLICY..

This policy indicates that the council is required to take account of This policy indicates that the council is required to take account of the policy framework and the following specific criteria.the policy framework and the following specific criteria.

the potential impact on the local communities and other sensitive the potential impact on the local communities and other sensitive land uses.land uses.

Determination of any significant adverse impact on the green belt, Determination of any significant adverse impact on the green belt, agricultural land, landscape, the natural environment including agricultural land, landscape, the natural environment including habitat sites and species.habitat sites and species.

The development will have no significant adverse impacts in The development will have no significant adverse impacts in terms of local environmental effects including noise, dust terms of local environmental effects including noise, dust vibration odour, attraction of vermin or birds, litter potential of vibration odour, attraction of vermin or birds, litter potential of surface or ground water contamination.surface or ground water contamination.

The design of the site including any buildings, floodlighting, visual The design of the site including any buildings, floodlighting, visual impact etc.impact etc.

Hours of operation and length of time of the proposed operation.Hours of operation and length of time of the proposed operation. Traffic volumes and effect on the road network including road Traffic volumes and effect on the road network including road

safety.safety. The offsite impact of any odours, discharges of gas, effluent or The offsite impact of any odours, discharges of gas, effluent or

leachate.leachate.

ENV 18 /39 WASTE MANAGEMENT ENV 18 /39 WASTE MANAGEMENT POLICY – cont.POLICY – cont.

In response to the specific criteria requirements the In response to the specific criteria requirements the environmental statement that accompanies the environmental statement that accompanies the planning application does not in anyway consider the planning application does not in anyway consider the impact on the other communities and sensitive land impact on the other communities and sensitive land uses. uses.

Hazardous waste will be treated as it is indicated that Hazardous waste will be treated as it is indicated that business waste will contain a percentage of hazardous business waste will contain a percentage of hazardous waste. The potential for release of dangerous dioxins waste. The potential for release of dangerous dioxins into the atmosphere and the long term health effects into the atmosphere and the long term health effects have not been fully considered. have not been fully considered.

The environmental statement also indicates that 6% The environmental statement also indicates that 6% of incinerated waste is ash residue and that this will of incinerated waste is ash residue and that this will be land filled on site. This residue is contaminated be land filled on site. This residue is contaminated and will have the potential to seep thro the and will have the potential to seep thro the groundwater in to the Cander Water which is a trout groundwater in to the Cander Water which is a trout feeding tributary to the River Avon.feeding tributary to the River Avon.

ENV 18 /39 WASTE ENV 18 /39 WASTE MANAGEMENT POLICY – contMANAGEMENT POLICY – cont..

   No lighting proposal has been included, and as this site No lighting proposal has been included, and as this site

has pipistrell bats, no consideration has been taken of has pipistrell bats, no consideration has been taken of how this will lighting will affect their habitat. Nor has it how this will lighting will affect their habitat. Nor has it been considered how this will also affect the surrounding been considered how this will also affect the surrounding environs.environs.

Consideration will also be taken of noise, dust vibration Consideration will also be taken of noise, dust vibration odour vermin litter. Whilst it is stated that these effects odour vermin litter. Whilst it is stated that these effects are negligible they are not insignificant to the nearest are negligible they are not insignificant to the nearest properties to the site when it is proposed to operate 24/7.properties to the site when it is proposed to operate 24/7.

Traffic Volumes on a rural road will also affect the nearest Traffic Volumes on a rural road will also affect the nearest residential properties as well as put a considerable strain residential properties as well as put a considerable strain on the councils dwindling roads budget as this road is not on the councils dwindling roads budget as this road is not a major trunk road maintained by Scottish government.a major trunk road maintained by Scottish government.

DM1 DEVELOPMENT DM1 DEVELOPMENT MANAGEMENT POLICYMANAGEMENT POLICY

   The application is also contrary to this policy The application is also contrary to this policy

in that it does not comply with the local in that it does not comply with the local context, does not make a positive context, does not make a positive contribution to the area. contribution to the area.

It will have an adverse affect on the visual It will have an adverse affect on the visual and environmental amenity of the and environmental amenity of the surrounding environs as well as affecting surrounding environs as well as affecting natural habitats. Whilst longer term affects natural habitats. Whilst longer term affects can not be measured, significant adverse can not be measured, significant adverse affects could be felt on public health, soil affects could be felt on public health, soil and water courses.and water courses.

COMMUNITY BENEFIT.COMMUNITY BENEFIT. As this planning application affects multiple communities As this planning application affects multiple communities

and the benefits being portrayed by the applicant are 50 and the benefits being portrayed by the applicant are 50 jobs and an indirect injection of spend into the local jobs and an indirect injection of spend into the local economy. economy. Is this enough to compensate for the potential long term Is this enough to compensate for the potential long term

damage to health and the environment. damage to health and the environment. No clear indication has been made of the negative affects No clear indication has been made of the negative affects

that it will have on the community with residential building that it will have on the community with residential building being shunned and the cost to the health service.being shunned and the cost to the health service.

Of the 50 jobs created approximately 20% will not be of a Of the 50 jobs created approximately 20% will not be of a specialised nature and will be subjected to the local job specialised nature and will be subjected to the local job market, with no guarantee that the surrounding market, with no guarantee that the surrounding communities will benefit. The remainder are specialist jobs communities will benefit. The remainder are specialist jobs and once again it is unlikely to be filled from the local and once again it is unlikely to be filled from the local communities. communities.

The recovered energy is not coming back into the The recovered energy is not coming back into the community, it is either going into the national grid or being community, it is either going into the national grid or being used by an adjacent company. used by an adjacent company.

Once again no local community benefit.Once again no local community benefit.

SECTION 75 AGREEMENTS.SECTION 75 AGREEMENTS.

Scottish Planning Policy intimates that the planning Scottish Planning Policy intimates that the planning authority ensures that sufficient finance is set aside authority ensures that sufficient finance is set aside to enable operators to meet their restoration to enable operators to meet their restoration obligations through a possible obligations through a possible section 75 agreementsection 75 agreement. .

Should this application be successful and a section Should this application be successful and a section 75 agreement is put in place, part of this section 75 75 agreement is put in place, part of this section 75 agreement should be the placement of additional air agreement should be the placement of additional air monitoring equipment (possibly 3 units) which will monitoring equipment (possibly 3 units) which will be handed to an independent body to control and be handed to an independent body to control and monitor with no input from any of the Scotgen monitor with no input from any of the Scotgen associated companies. associated companies.

What is the amount of sufficient finance if this What is the amount of sufficient finance if this application has the potential to contaminate the air, application has the potential to contaminate the air, soil and public from potential dioxin discharges? soil and public from potential dioxin discharges?

OTHER ITEMS FOR OTHER ITEMS FOR CONSIDERATION.CONSIDERATION.

   a)a) CONFLICT OF INTERESTCONFLICT OF INTEREST

South Lanarkshire council has a conflict of interest in South Lanarkshire council has a conflict of interest in determining this application in that they will benefit from this determining this application in that they will benefit from this application being passed.application being passed.

b)b) ENVIRONMENTAL STATEMENTENVIRONMENTAL STATEMENT Whilst some consideration was given to alternative sites within Whilst some consideration was given to alternative sites within

South Lanarkshire, they were discounted early and no clear South Lanarkshire, they were discounted early and no clear investigation was carried out in the surrounding local authority investigation was carried out in the surrounding local authority areas. Glasgow city council are currently going thro a areas. Glasgow city council are currently going thro a competitive dialogue process to tender a residual waste competitive dialogue process to tender a residual waste recycling plant and the likelihood of South Lanarkshire council recycling plant and the likelihood of South Lanarkshire council supplying its waste to this facility was not considered nor was supplying its waste to this facility was not considered nor was it disclosed if Scotgen were part of the tender process.it disclosed if Scotgen were part of the tender process.

c)c) LOCAL RIGHT OF WAYLOCAL RIGHT OF WAY Consideration of the local right of way which goes through Consideration of the local right of way which goes through

Dovesdale should be taken account of especially given the Dovesdale should be taken account of especially given the number of vehicle movements and the potential health and number of vehicle movements and the potential health and safety issues that arise with members of the public walking safety issues that arise with members of the public walking thro or next to the site. thro or next to the site.