My response to the Environment Agency regarding the application by City Plant Ltd to vary the conditions of the permit under which they currently work under.
I am very concerned that City Plant Ltd has submitted an application to vary the terms/conditions of the permit relating to the operation of Leatherdog Lane Landfill site in Gilberdyke, an application that appears to contain so many errors, contradictions and more than anything is retrospective. Having been party to numerous meetings, chaired the ‘Tip Liaison Committee’, and as ward member for Howdenshire on the East Riding of Yorkshire Council (ERYC) I have witnessed first-hand the actions of the operator, the Environment Agency (EA), the East Riding of Yorkshire Council, and as well as having listened to the concerns of residents – I therefore think I am more than qualified to comment on the application to vary the permit.
- Over the past 18 months or so I have witnessed the shambolic actions of those agencies supposed to protect residents, and the way City Plant Ltd have systematically circumvented the planning consent and the permit conditions, only being brought to heel by enforcement action by the EA, which in my opinion came far too late.
- It is clear that this application should not be considered until such a time that a planning consent has been determined by the ERYC, which will no doubt, if approved, contain legally enforceable conditions rather than what we have seen previously. I would therefore suggest that it is imperative that o decision or varying the permit be taken until planning consent has been obtained.
- The permit should then be totally and legally compatible with any conditions applied to the planning consent (if given) from the ERYC.
- Having read the application and sought further advice I am NOT convinced that a ‘bentonite‘ light weight capping is suitable for this landfill site, mainly due to the risks of fracture or tearing as the tip subsides at different rates across the site as a result of the differentials in compaction and identified rates of settlement over the 25 year timespan. I have found nothing in the application to reassure me that the risks have been fully taken into account by the consultants working for City Plant Ltd. I therefore take the view that a clay capping would be more appropriate and less risky, and insist that this is included in the permit. I would also like to see trees planted across the top of the site. I accept that this would perhaps mean more vehicle movements to bring the capping clay and topsoil onto the site, but the risks outweigh the inconvenience.
- The finished height of the tip should not be above the previously agreed levels of 19.5m – and for clarification this is the height when the tip is capped off and closed NOT at a time after that.
- The priority for all concerned is the timeframe, I have had it confirmed by City Plant Ltd that the tipping of waste on the site will be completed by November 2012, allowing 1 month contingency I would therefore request that a time frame is imposed so that tipping of waste on the site stops by 31st December 2012.
- I am not convinced of the landfill gas being burnt off using gas generators, although this is a better option than flaring off. I would prefer that the gas be collected and removed from site to be purified. I could accept a purification plant installed on site to remove harmful toxins produced by the burning of landfill gas, providing the risk to residents could be established and independently verified as being so low so as not to warrant concern.
- I am also not convinced of the proposals for controlling water pollution into nearby watercourses or dykes. This is particularly relevant if the site was to split or crack due to differential of settlement over the coming years. I have concerns that the steep slopes of the site do not have run off areas and the lack of a dyke running around the perimeter that is capable of being isolated from the dykes running alongside the site.
- There should be NO VARIATION to the permit until such a time that planning consent has been granted by the ERYC.
- The site should be capped with clay and topsoil and trees planted across the top of the site.
- The finished height of the site must be part/condition of the permit.
- The timeframe to stop tipping waste must be part of the permit.
- No gas generators to be installed unless the risk to residents is proven to be harmless.
- A much better plan for dealing with surface water run-off and potential leachate leakage must be put forward.
Cllr Paul Robinson
ERYC Ward Member for Howdenshire