Offham Parish Council
Dear Resident,
Blaise Farm - Further to the Public Meeting held on 28/09/2012, Offham Parish Council
felt that it would be sensible to publish a brief background to NES’s development of
Blaise Farm. This is included with a copy of OPC’s response as Consultees to NES’s
recent planning application.
A brief history of Composting facilities at Blaise Farm and associated issues that
have arisen.
18/09/2006: Application to install a facility for converting mixed green waste to
compost was granted providing for a capacity of 50,000 tons p.a. At that time it
was the norm for Councils to collect co-mingled waste – card, food and garden
via the green bin system. This plant was constructed in 2008. The plant was
designed to handle co-mingled waste as described above.
Initially, for a period of about 18 months, there were virtually no complaints about
the operation of the plant. However from about mid 2009, problems with odours
started to develop.
A Liaison Group had been formed by then, which consisted of NES employees,
the Environment Agency, representatives of County, Borough and Parish
Councils and individual householders who had been most affected by the
problems. This Group meets quarterly.
2010: A further application to extend the original facility, essentially duplicating
the original facility, was made. By now, some early problems with odour escape
had been verified and despite attempts by NES to rectify them, the problem
escalated. Various objections to the application were made and it was turned
down, but later, on appeal, it was granted. However, this additional plant has not
been built – for two main reasons:
1/ Problems with the original plant had escalated, reaching a peak during 2010
2/ Councils had started collecting separated waste. The original plant was not
designed to a specification to handle this and indeed, much of the blame for the
physical deterioration of the original plant was placed on this development.
This situation gave rise to the current plan for an Anaerobic Digestion Plant to
cope with the significant increase in pure food waste now being collected by
councils. To reduce the odour problems locally, NES has been diverting much of
this waste stream to AD plants north of London. For much of late 2011and early
2012 there had been a considerable improvement in the odour problem. However,
Lynne Mackie, Clerk, Offham Parish Council,
01732 521303 offham.pc@hotmail.co.uk, www.offhampc.kentparishes.gov.uk
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Offham Parish Council
more recently, a number of Offham residents have continued to experience a
distressingly increased frequency of odour issues attributable to the original plant.
The odour can be of two types:
1/ a strong rubbish smell [as you might get from a refuse lorry when collecting or
from a kitchen waste bin]. It has been generally acknowledged that this smell is
generated by the reception area, when doors are opened to let vehicles in or out,
break downs of fans operating within the plant or occasional external transfer of
waste material between buildings.
2/ a somewhat sickly sweet smell – this being caused by premature gas escape
from a biofilter.
The current application for the AD plant utilizes very different technology from
the existing plant as the process is undertaken in an airtight system. The only real
exception to this is the reception area, which still requires vehicles to deposit
waste into a pit in the floor of an enclosed area.
Offham Parish Council are objecting to the proposed development, mainly on the
grounds that NES have failed to bring ongoing problems with the existing plant
under control and that it would be inappropriate to consider at this stage, the
creation of an additional plant, albeit utilizing different, but relatively new
technology in the proposed form.
The Public Meeting held on 28/08/2012 broadly supported this approach to
application, although some attendees had suggested stronger actions.
Individuals are invited to voice their own objections to the application by directly
communication with KCC planning department using the references listed on
OPC’s response herewith.
If you Experience bad and Nuisance Odours
On the question of odour problems, if you experience such odours then please
contact the Environment Agency on 0800 807 060 or NES directly on 01202
812300 AND copy in Claire Innes on clare.a.innes@gmail.com, so that the
complaints log, which Clare maintains can be updated.
The best way to get action to resolve this problem is for people to complain.
Please bear in mind that NES (the plant owners) already have permission to
double the size of the existing plant using the current process; so they could be
handling 100,000 tons a year of mixed food and green waste at Blaise farm. With
the record over the past two years of odour management the problems for the
village could get worse and could also affect more houses.
Lynne Mackie, Clerk, Offham Parish Council,
01732 521303 offham.pc@hotmail.co.uk, www.offhampc.kentparishes.gov.uk
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Offham Parish Council
Better Communication to Parishioners
The Parish Council would like to send out important and of interest
communications to the village more effectively and to that end we would like to
build an e-mail database list of as many people in the village as is possible, so we
can update you more effectively and quickly. This will be in addition to the notice
boards, web site and leaflet drops and will only be used by OPC and not passed on
to any other bodies at all.
If you would like to be added to this e-mailing list please send a ‘please add me to
the list’ mail to Lynne the Parish clerk at offham.pc@hotmail.co.uk
Yours sincerely,
David Stretton, Chair, OPC
Enc. OPC’s response to planning application.
Lynne Mackie, Clerk, Offham Parish Council,
01732 521303 offham.pc@hotmail.co.uk, www.offhampc.kentparishes.gov.uk
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Offham Parish Council
KCC/TM/0296/2012, Blaise Farm Composting Plant – Temporary
development of an Anaerobic Digestion Plant together with associated
infrastructure, reconfiguration of the consented Advanced Thermal
Conversion Plant, together with associated infrastructure, the realignment
of part of the existing access road, the relocation of existing office and
welfare accommodation and the relocation of the existing weighbridge
Offham Parish Council have held a pubic meeting to consult residents about the
planning application detailed above. The Parish Council OBJECT to this application for
further development of the site at Blaise Farm.
It is recognised that the application for AD and ATC plant may not, incrementally,
have a materially adverse effect on noise, visual appearance or traffic movements
with respect to the site. It is also recognised that, from several perspectives, such
plant probably would be preferable to the already permitted phase 2 expansion of
the current composting facilities.
However, there is a key issue which we must draw to your attention - odour, which,
at times, has been truly awful for our village.
The planning permission granted for the first phase of the plant allowed processing of
50,000 tonnes of waste per annum. The odour appears to have been caused by a
number of factors, including:
1. The disproportion of food waste to non-food waste. The original application
did not anticipate the higher proportion of food waste that NES are now
required to deal with. The problem is such that food waste is currently being
diverted to another site in Bedfordshire. Despite this, there has been a rise in
complaints during August, with no cause yet established.
2. At Liaison Meetings, NES have admitted that the disproportion of non-food to
food waste has damaged, and led to the breakdown of, the plant, apparently
leading to odours being released.
3. At Liaison Meetings it was apparent, and admitted by NES, that they had not
maintained the facility properly, including failing to fix broken fans and failing
to address inefficient filters/filter breakdown, both causing odours to be
released.
4. At Liaison Meetings it was admitted by NES that the operational management
of the process had been inadequate. This included leaving doors open (that
has had a substantial adverse impact on the ability to maintain a negative
pressure to keep odours within the facility).
NES claim to have taken steps to maintain the building and change the operational
management, but the problem of odours continues. It is the view of the Parish
Council, supported by the residents of the village, that consideration should not be
given to the new application and its AD and ATC plant until it is proven that NES can
run the existing plant for a sustained period without causing a nuisance; otherwise
how can there be confidence in the future operational integrity of the site. To achieve
that, we believe that NES need to:
Lynne Mackie, Clerk, Offham Parish Council,
01732 521303 offham.pc@hotmail.co.uk, www.offhampc.kentparishes.gov.uk
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Offham Parish Council
1. review the fan and filter configuration of the facility to ensure that it has
resilience with respect to failure of any component and sufficient spare
capacity to cope with the outage of any particular unit.
2. be obliged to have back-up electricity generation facilities, in case of grid
electrical failure.
3. be obliged to install a "lock-system" (with rapid-rise roller shutters) to be
utilised by all vehicles entering and leaving the enclosed composting area to
reduce, if not eliminate, escape of odours while the one of the doors is open,
with the inner and outer door controls being interlinked to ensure that both
cannot be open at the same time.
4. be obliged to monitor odours for sustained periods at the 12 sites in figure 2
of section 6 of their application and also at three additional sites to be
nominated by Offham Parish Council.
5. if such monitoring or validated complaints from villagers indicate that odours
are still escaping at an unacceptable level, propose to the planning authorities
remedial measures and, if approved, implement.
Once the current operations have been addressed as above, it would then be
reasonable to consider the application for AD and ATC plant. Given the observations
above, we believe that the application should be refused unless fan and filter
resilience, back-up power and a lock-system at all entrances to the facility are also
addressed in the latest application.
Further, as its stands, the current application says “low odour”, which suggests that
NES expect there will be odours. Within the context of odours from the current
operations, that must give considerable cause for concern. If NES cannot
demonstrably deal successfully with odours from the current plant, then an
acceptance of "low odour" by the Planning and Licensing Authorities for this
application would, in reality, be a permission to allow sufficient odours to be released
to cause an increased nuisance to nearby residents.
Bad odour is classified and defined as a nuisance which is actionable in common law.
At this site it is in breach of the Licensing and Planning Permissions given to NES.
NES are currently operating Blaise Farm with a capacity of 50,000 tonnes per
annum. They have been given permission (on appeal, and argued against by Offham
Parish Council) to increase the amount of waste they treat at the existing plant to
100,000 tonnes per annum. The original application, and the extension granted on
appeal, were given permission on the basis of assurances made by NES about their
management of the plant, the quality of the equipment and the fact there would be
no odours. Permission was given for a plant that should not have caused a nuisance.
However, that plant was not designed for its current mix of waste and is, evidently,
not properly maintained or operationally managed. With that background, what
certainty can there be that the new plant would be suitable for use, that it would be
properly managed or that it would be properly maintained?
It is appreciated that issue of odour is somewhat subjective. However, the applicant
endeavours to introduce scientific method to the subject by stating that "D50 is the
concentration at which an odour becomes just detectable to 50% of a population.
This concentration of an odorous substance is given the value 1 odour unit
(OU)". Various diagrams and tables are then given to demonstrate the claim that
Lynne Mackie, Clerk, Offham Parish Council,
01732 521303 offham.pc@hotmail.co.uk, www.offhampc.kentparishes.gov.uk
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Offham Parish Council
odour would not be an issue as a result of this application. However, that analysis is
unreasonable for the following reasons:
1. basing a unit of measurement, and hence the conclusion derived from the
analysis, on 50% of the population is clearly biased towards proving the case
that it would not be a nuisance; in such a sensitive analysis the 90 th
percentile, or even the 95th percentile, would be a more appropriate basis of
measurement, unless the intention it to ignore the impact on a sizeable
minority of the population. Adopting that more reasonable base measurement
would demonstrate the far greater likely impact of odours on Offham and
other areas. The "contour lines" in figure 8 of section 6 of the application
would have numbers against them that would be perhaps 5 or 10 times
larger, with additional "contour lines" of impact extending to Offham and
beyond. (NES should be required to obtain and provide a revised figure 8 on
the above lines from their consultant, RPS).
2. it is not at all evident that the analysis offered takes into account the
topography of the surrounding area. Odours are channelled through "valleys",
especially in certain weather conditions, which means that odours will be in
greater concentration and hence create greater nuisance. Stated monitoring
sites do not allow for this and that is why we suggest that we are allowed to
nominate three further sites, based on our local knowledge.
3. Another statistical point is that the analysis is based on hourly time periods an
odour only has to last for a few minutes to cause distress and therefore the
analysis should be based on much shorter time periods like 5 minutes.
4. the analysis does not, evidently, allow for different weather conditions,
particularly humidity and density; that is, it does not allow for variation in
weather conditions that affect concentrating effects for odours closer to the
ground.
5. the analysis, presumably, assumes that fans/filters and other aspects of the
facilities are working at design parameters. Given historical evidence, that is a
very un-safe assumption and the analysis should make considerable
contingency allowance for plant and operational failures.
Given the above, having heard from residents in the village and with considerable
concerns about the future, the Parish Council hereby OBJECT to this application
Lynne Mackie, Clerk, Offham Parish Council,
01732 521303 offham.pc@hotmail.co.uk, www.offhampc.kentparishes.gov.uk
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