Jim visiting the proposed site of the incinerator with local campaigners
Jim Hume, Liberal Democrat MSP for the South of Scotland, has this week launched his party's online petition against the Dovesdale incinerator.
The petition can be found at www.scotlibdems.org.uk and Mr Hume is urging as many people as possible to sign it.
Mr Hume said:
"The Dovesdale site in my view does not seem to be an appropriate location for a development of this kind.
"Objectors need to demonstrate that the proposal breaches planning policies and I hope that officials and councilors recognise the multiple problems associated with this planning application.
"Whilst energy from waste plants can form a very small part of the way in which we deal with waste, they have to be in suitable locations. It also has to be demonstrated that a significant amount of energy can be derived from the process, otherwise it's just an easy way of getting rid of rubbish."
ENDS
Notes to editors.
1. The text of Mr Hume's letter to South Lanarkshire Council is attached below.
Mr Colin McDowall
Executive Director of Enterprise Resources
South Lanarkshire Council
Enterprise Resources
Montrose House
154 Montrose Crescent
Hamilton
ML3 6LB
Dear
Re: Dovesdale Incinerator, Planning application HM/10/0345
I believe that the above application is not compatible with planning policies for the reasons outlined below.
The proposed site of the ScotGen incinerator at Dovesdale Farm, Carlisle Road, Stonehouse ML9 3PN, falls under Green Belt regulations outlined by both the Scottish Government and South Lanarkshire Council. South Lanarkshire Council's Green Belt Landscape Assessment renders the proposed development untenable. Volume I: Development Strategy; Environmental Priorities and Objectives 101 of the document states:
Partial loss [of priority green space] will only be justified where it can be demonstrated that:
• The retention or enhancement, including positive management of the area to be retained can be best achieved by the redevelopment of part of the site which would not affect its recreational, amenity or biodiversity value; and
• Compensatory provision of at least equal area, quality and accessibility is provided in the locality
The above stipulations for the loss of green space cannot be applied to the planned ScotGen facility. The Scottish Government's Scottish Planning Policy outlines regulations on Green Belt development, its purpose being to:
• direct planned growth to the most appropriate locations and support regeneration,
• protect and enhance the quality, character, landscape setting and identity of towns and cities, and
• protect and give access to open space within and around towns and cities. (159)
The site upon which the development is planned, being a designated Green Belt space, is therefore unsuitable for the proposed development, contravening both national and council regulatory statutes in relation to the area.
As well as being incongruent with Green Belt planning regulations, the proposed site of the development is unsuitable on environmental grounds. The SPP contains a section on renewable energy development plans, stating that:
"Factors relevant to the consideration of applications will depend on the scale of the development and its relationship with the surrounding area, but are likely to include impact on the landscape, historic environment, natural heritage and water environment, amenity and communities." (185).
Dovesdale Farm lies adjacent to a Site of Special Scientific Interest (SSSI) and a Special Area of Conservation (SAC) - with Cander Moss (Scottish National Heritage code 309) and Avondale (SNH code 109), with the latter also falling under the Clyde Valley Woods SAC. The proposed development of the ScotGen facility could pose a threat to these areas given the proximity of the protected environments. In accordance with the SPP excerpt detailed above, the planned site of development is once again shown to be unsuitable.
South Lanarkshire Council's Biodiversity Plan stresses that 'the protection of our biodiversity is a key element of sustainable development and we need to ensure that consideration for our environment is integrated into all aspects of our lives.' The delicate biodiversity of the SSSI areas in the area of the proposed development highlight furthermore the unsuitability of Dovesdale farm for a development of this kind.
Further, the following extract is taken from the Scottish Government's Zero Waste Plan:-
4.9 The following locational criteria should be considered by planning
authorities and developers when identifying and assessing sites for waste
management facilities to ensure that they support waste infrastructure
investment and are in the most appropriate locations. More detailed guidance
will be provided in PAN 63.
1. Potential Sites
Potential suitable sites for waste management activities include:
● Industrial areas
●Degraded, contaminated or derelict land
●Working and worked out quarries
●Sites that have the potential to maxmise the potential for the re-use
of waste heat through co-location with potential heat users
● Existing or redundant sites or buildings that can be easily adapted
● Existing waste management sites, or sites that were previously
occupied by waste management facilities
● Sites accessible to railways, waterways or the trunk and principal
road network junctions.
I, therefore, believe that the Dovesdale Farm site is not compatible with the type of application lodged by Scotgen because it is clearly not a 'brownfield' location and is defined in the South Lanarkshire Council Local Plan as a Green Belt area.
In addition, ENV 39 (waste management site assessment policy) of the South Lanarkshire local plan states that (I have noted my comments in bold):-
In considering applications for the management of waste, the Council will have regard to the policy framework of the Local Plan and the following specific criteria:
a. that there is a demonstrated need for the facility;
b. its location in relation to the main sources of waste;
c. the potential impact of the proposal on local communities and other sensitive land uses;
d. the development will have no significant adverse impact on any heritage feature including Conservation Areas, Listed Buildings or their settings, Scheduled Ancient Monuments, historic gardens and designed landscapes and other sites of archaeological or historic interest where these are material considerations;
e. the development will have no significant adverse impact on any natural heritage feature including the Green Belt, agricultural land, landscape, the natural environment including landscape character, habitats and species, including those given statutory protection;
f. the development will have no significant adverse impact in terms of local environmental effects including noise, dust, vibration, odour, attraction of vermin or birds, litter, potential for the pollution of surface water or ground water or contamination;
g. the design of the site including any buildings, floodlighting, nets for waste and pest control, visual impact and access, landscaping and screening;
h. hours of operation and length of time of the proposed operation;
i. mode of transport, including the potential use of alternative modes of transport other than by road; site access, traffic volumes and the effects on the road network and road safety;
j. the need to avoid a proliferation of sites in a locality that may lead to a detrimental impact by virtue of their cumulative impact;
k. where appropriate, the suitability of arrangements for the after use and restoration of the site;
l. the off-site impact of any odours, discharges of gas, effluent or leachate;
m. in general waste management facilities and transfer stations will be directed to industrial locations and/or existing waste management sites unless other material considerations indicate otherwise.
The proposal site is classified as Green Belt in the South Lanarkshire Local Plan. The proposed facility would be a significant visual intrusion in this Green Belt area. The surrounding land includes an ancient woodland in the Cander Water Glen within 600 metres of the site; the site is within 300 metres of the Cander Moss SSSI; and the Avondale SSSI and SAC lies approximately 1,200 metres to the north. All the immediate agricultural land is grazing pasture for organic dairy herds.
I believe that when taking into account the foregoing, the Dovesdale Farm site is not
an appropriate location for such a development.
Yours sincerely
Jim Hume MSP
(Liberal Democrat) South of Scotland
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