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DCRA Response to Thornton's Appeal to An Bord Pleanala for Intensification of Waste Disposal Plan

 

4th October 2004
The Secretary,
An Bord Pleanála,
64 Marlboro Street,
Dublin 1


Re: Appeal of Meath County Council's Decision to Refuse Planning Permission for intensification of waste processing from 5,000 tonnes per annum to 50,000 tonnes per annum at existing facility at Dunboyne Industrial Estate, Dunboyne, Co. Meath, for Padraig Thornton Waste Disposal Ltd, Reg ref:DA/40152, PL17.208650

(Response to Appeals)

A Chara,

We refer to your correspondence dated 8th September 2004 and copies of appeals by Thornton's Recycling, and Lutterell Hall Residents Association. On behalf of our client, Dunboyne Combined Residents Association (DCRA), c/o Mr. Jim McGrath, 9 Elton Drive, Millfarm, Dunboyne, we wish to comment on these appeals as follows.

1. RESPONSE TO APPEAL BY THORNTON'S RECYCLING.
1.1. Response to submission by Trafficwise, Traffic & Transportation Consultants.
The substantive part of the First Party appeal deals specifically with the Planning Authority's reasons for refusal (Traffic) and was prepared by Trafficwise, Traffic and Transportation Planning. We enclose a responding report by S.I.A.S., Transportation Consultants, which deals specifically with the points raised in the Trafficwise report.

1.2. Response to submission by Mr. Conor Walsh, Environmental Director, Thortons.
We would take issue with the brief introduction prepared for the first party by Mr. Conor Walsh. Mr. Walsh's argument commences with the statement, "In arriving at your decision we ask that you take account of the need for this development in the context of Ireland's current deficit in recycling infrastructure and in the context of local recycling needs."

In response, we would argue directly the opposite as follows: -

The proposal will be too large to cater for what can reasonable be described as "local needs".

- The proposal and its location is completely devoid of objective assessment in the context of the National or even regional recycling needs.

- It appears to us that the site has been selected in the first instance because it suits the self-interests of the greater Thornton operation in terms of logistics and operation cost etc'.

- The applicants believe that in seeking an intensification of an existing facility rather than a greenfield site, they are hoping to by-pass opposition to the principle of locating such a facility in Dunboyne.

Mr. Walsh continues with his argument for the proposal, the main points of which are summarised in the text box below.


We respectfully take issue with Mr. Walsh's analysis for the following reasons set out below: -

1. His approach is based on identifying a catchment around the existing facility. Surely the reverse should be the case with the location for the facility being chosen in the context of the established pattern of need in the area and using an objective analysis, e.g. gravity modelling.

2. He offers no explanation as to why a 12km radius was chosen. This is particularly puzzling, as, by his own admission, the corresponding population would give rise to 200,000 t.p.a. of waste as opposed to the 50,000 t.p.a. that would be facilitated by this proposal.

3. Given that a catchement area with a waste output of 200,000 t.p.a. is chosen, are we to assume that Thornton's intend to apply for planning permission for a further intensification from 50,000 to 200,000 t.p.a., thus exacerbating the existing unsatisfactory situation ?.

4. Again, looking to the 200,000 t.p.a. figure, it appears that this was simply extrapolated using the 1:1.6 ratio established by the National population figure relative to the National municipal waste and National c&d waste figures. This is an over-simplistic approach to say the least and does not take account of the considerable variances that exist between different locations and the actual amount of waste that they produce.

5.In addition, this analysis is further undermined by the fact that the National waste figures Mr. Walsh refers to relate to Municipal waste and C&D waste only. These types of waste will account for 75% of the total proposed to be accepted at the new facility. The analysis fails to include any reference to the remaining 25% which will be made up of Hazardous, Industrial and Commercial waste.

6.While Mr. Walsh is prepared to identify 11 towns, the waste from which will be brought to the proposed development, he rather worryingly includes the phrase, "amongst others". Again we would question the extent of the proposal and would support our client's contention that even the current proposal could be a Trojan Horse for an even larger proposal in the future. This would be in keeping with the approach that appears to have been adopted by the applicant to date.

7.We have conducted an analysis of the population figures for the 11 towns identified by Mr. Walsh and our findings are presented in the table and map at the end of this submission. Looking to the table, we found that five of the towns had populations over 10,000 which, when totalled, amounted to 81% of the total population for all 11 towns. Looking to the map, we find that the majority population (5 towns with populations over 10,000) occupy only a minor portion of the 12km radius identified by Mr. Walsh. This being the case, it demonstrates that both the radius and the Dunboyne location itself, are ill conceived in the context of where the majority of the waste will actually be produced.

1.3. Conclusion to this section.
In conclusion to this section, we respectfully contend that Mr. Walsh's submission fails to properly justify the location for the proposed development. We further contend that the location is totally inappropriate for the level of use proposed and is devoid of any rational save the existence of the existing facility and the logistics of the Thornton operation.

Finally, we note the first party's comments regarding the closure of the Maynooth site. In response, we contend that the loss of that facility on good planning grounds does nothing to recommend the granting of permission for the current proposal.

2. RESPONSE TO APPEAL BY LUTTERELL HALL RESIDENTS ASSOCIATION.
We have examined the appeal by Lutterell Hall Residents Association and confirm that we are in complete agreement with the points raised in their submission.

In particular, we note their analysis of housing density in the vicinity of the subject site which serves to demonstrate just how unsuitable the current site is for the type and volume of development proposed.

3. CONCLUSION.
In conclusion, we respectfully request An Bord Pleanála to uphold the decision of the Planning Authority and refuse permission for this development.

Yours faithfully,

_________
Mark Rave, B.A.(Hons), M.R.U.P.
Mark Rave Associates

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