24th January 2014
Kildare County Council
Re: Waste Facility Permit Application by David Boylan Limited at Kerdiffstown, Naas Co. Kildare
To whom it may concern
I wish to object to the above application submitted on 17th December. The following outlines my specific reasons for objecting:
1. Narrowing of accommodation bridge:
According to Condition 2a of the Planning Permission (application number 05/1896) for this site, prior to the commencement of development the National Roads Design Office needs to be consulted – It would appear that the applicant did adhere to this clause however he has not consulted with the local land owners with regard to the width restrictions he is proposing to impose on the accommodation bridge crossing the M7 (reduction 5.1meters to 3.5 meters). There is clearly a large farming area surrounding the proposed site and access to these farmlands must remain of high priority. The decision not to consult with the local farming community shows a disregard for their livelihood.
2. Timeframe of Waste Permit Application
According to Condition 2b of aforementioned Planning Permission, the development shall be completed within a three year period – the waste permit application is for 5 years from the date of issue of waste permit. This is a blatant disregard for Condition 2b.
3. Prevention of local flooding
i) In terms of the proposed wheelwash to be installed, there are no specifications outlined as to how the overflow of water is to be dealt with to ensure local lands are not flooded.
ii) There are no specifications outlined in the application as to how surface water from the proposed site in general is to be dealt with to ensure local lands are not flooded, particularly residential areas in the vicinity.
4. A detailed landscaping plan was requested under the initial planning application and this has not been provided un the permit (get condition in pp)
5. Monitoring of material
i) Section 4.7 of the waste permit application refers to the potential development of a recovery site as it specifically includes cement as a product that could be removed from the site – This distinctly goes against the materials allowed on site as outlined in the planning permission
ii) The application details how a self-monitoring of the site will be in place but this only refers to the volume of material entering the site and not the source of the material – it is essential that the public are aware of not only how much material is being used but most importantly where the material is sourced in order to provide greater transparency
iii) No details are provided with regard to the experience or qualifications of the two employees who are to monitor the materials – it is imperative that self-monitoring of the site is conducted by suitable personnel
iv) The application does not state that the material entering the facility is to be tested for contamination.
6. Capacity of site
The planning permission identifies the capacity of the site at 100,000m2 which corresponds to approximately 200,000 tonnes depending on the material. The waste permit application is only seeking permission for 98,928 tonnes over the lifetime of the Waste Facility Permit. A waste licence from the EPA would be required to fulfil the planning obligations (a licence is required for over 100,000 tonnes) but this would be more difficult to acquire as it has much more stringent conditions than a permit.
I therefore question their application for only 98,928 tonnes as it
i) does not explain why they wish to deal with only half the capacity allowed under the planning permission
ii) what they plan to do with the remaining half of the site once their quota of 98,928 tonnes has been met
iii) does not detail if they will seek an Article 27 Notification from the EPA to complete the site as per the planning permission once 98,928 tonnes have been filled. If an Article 27 Notification is applied for it will mean that the local community does not have to be made aware of a change to the original application (ie doubling the capacity of material entering the site) and there will be no change to the monitoring of the material entering the site as it will be taken for granted that the material will be the same as that which entered under the waste permit.
I would appreciate if the foregoing points could be considered in light of my objection to this application.
Anthony Lawlor TD