Planning Application Reference HM/10/0345 
Land off Carlisle Road Carlisle Road Stonehouse ML9 3PR  
Construction and operation of a waste sorting and resource recovery facility, with capacity to process up to 150,000 tonnes 
of waste per annum  
 
I refer to the above planning application and would like to formally object to this application on the following grounds. 
 
This development is contrary to STRAT 3, The Green Belt and Urban Settlements, STRAT 4 Accessible Rural Area Policy and STRAT 
7  Strategic  Green Network  Policy  of  the  South  Lanarkshire  Local  Plan  in that  it is  not  necessary for  the  furtherance of  agriculture, 
horticulture,  forestry  or  recreational  use.    It  is  not  linked  to  the  existing agricultural  activity  and  the  proposed  incineration  and 
gasification plant is not compatible with adjoining land uses.    Furthermore, this development is potentially detrimental to the adjoining 
and  surrounding organic farm  land/community. Agriculture remains  a major land  use  in the rural  parts  of  South  Lanarkshire and  we 
should  be seeking  to  support, encourage  and  enhance this  land  use  rather  than  supporting  development  that will  further erode  our 
farming community.    This proposal does not seek to enhance the environmental quality of the area, nor would it protect the character 
and setting of the nearby towns and villages. This proposal does not contribute to the regeneration of Stonehouse, Ashgill, Netherburn 
or other surrounding towns and villages, and a proposal of this nature will neither justifiably secure benefits for the local communities, 
their economy or their environment. The purpose  of the green belt policies is to  protect  the green  belt area  and  landscape.    It is the 
intention of  the  local plan  and the responsibility of  South  Lanarkshire Council to protect biodiversity,  natural  and cultural  assets from 
inappropriate  development,  such  as this  proposal.    Clyde  Valley  is  a  significant  green  network  resource  and  a  potentially  national 
important  leisure  and tourist  resource recognised  by  the  local  plan.    It is not  sufficient  for  the  applicant to  propose  there will  be  no 
environmental impact, but it is the responsibility of South Lanarkshire Council to ensure there will be no environmental impact. 
 
This  proposed development is contrary  to ENV 34 - Development in the Countryside Policy  in that it will not conserve the natural and 
built environment and will have a significant adverse impact on biodiversity, natural and built heritage resources. It does not respect the 
existing  landscape  form.    The  operational  building  within  the  development  does  not  complement  or  enhance  the  surrounding 
landscape  but  detracts  from  the  visual  amenity  of  the  landscape,  from  various  viewpoints.    The  scale  of  the  development  will  be 
overdominant and incongruous to local traditional patterns of scale, proportion and density.    The desi gn is not of high quality; it is not 
sensitive to and does not respect its immediate setting and wider surroundings; nor does it maintain a sense of place or support local 
identity.   
   
The proposal is not  in accordance  with  the  objectives  of  ENV 18  in that  the development will  not  be  sited in an  appropriate  location. 
This  proposal  should  be  located  within  existing  compatible  waste  management  facilities  and  meet  criteria  of  ENV  39  Waste 
Management  Site  Assessment  Policy  and  ENV  38  Renewable  Energy  Site  Assessment  Policy,  in that  general  waste  management 
facilities and transfer stations will be  directed  to  industrial locations and/or  existing waste management sites.    There are  no material 
considerations to outweigh these policy criteria nor is it indicated otherwise in this proposal.    This development should not be granted 
planning permission as it is not a tried and tested technology/method of dealing with waste.    Whilst recycling is considered  a required 
facility, the  incineration and  gasification  of  waste  that cannot be  recycled  is  not considered a  method  that will reduce environmental 
impact,  but  will  have  a  detrimental  effect  on  the  environment.  There  are  currently  seven  other  recycling  centres  within  South 
Lanarkshire  Council  s area.    This development will impact  upon the local green belt, agricultural land, the outstanding landscape and 
surrounding communities, including several organic  farming communities and the statutorily  protected SSSI at  Cander Moss.    This is 
designated as one of only 14 „Special Areas of Conservation  in Scotland, given special protection because of its rarity. It is one of the 
foremost  in  the  country  that  covers  the  area  of  the  Avon  and  Cander  Water  gorge  and  is  considered  an  outstanding  example  of 
semi-natural  deciduous  gorge woodland.   Development should  only  be permitted  where the overall  integrity  of  the  area will  not  be 
compromised; or where it will not have  any significant adverse  effects on the qualities for  which the area  has been  designated. Such 
sites  are regarded  as  being of national significance  and the Council  must  seek to protect them  from development that  would  cause 
harm to their special characteristics. In some cases, damage could arise through development on land adjacent to the designated site, 
or even some distance away. 
 
This  development  will  have significant  adverse  impact  upon  neighbouring  properties  in  respect  of  noise,  dust,  odour,  and  will   also 
cause  long-term significant contamination  of land, air and watercourses.    The proposed hours  of operation (24 hours per  day over 7 
days, will have a significant impact upon the neighbouring residential community and the existing road transport network on the B7078 
and  road safety.    According to the  information presented in the applicant s Non-Technical Summary  (NTS) document, the Dovesdale 
Waste  Incinerator  proposal  has the potential  for  an  enormous traffic  impact on  the Canderside  Toll  / B7078, as  much as  250  daily 
movements  from all  the  associated  traffic  associated  with the  operation  of  the  use.    There  have  already  been major  accidents and 
several fatalities on this road.    This development will only exacerbate and add to these figures.     
 
The impact on road safety and traffic volumes must not only take this development into consideration, but include the additional traffic 
on  the  B7078  and  toward  the  Canderside  Toll  caused  by  new  housing  developments  within  Blackwood,  Stonehouse  and  Larkhall.   
This  single  lane  “ B”   classified  road  is  not  designed  to  accommodate  the  enormous  volumes  of  traffic  being  generated  from  the 
surrounding areas.  

 

There will be an impact upon air pollution  through emission of hazardous substances.    There is great concern by residents locally for 
the ecological and harmful effects this development will have on the environment, livestock and the health of residents withi n the area. 
In what  is  an area  of  outstanding  natural  beauty,  the  hazardous coating  of  plants and  the  pollution of waterways can  only  harm  the 
environment and will in the long term pose a health risk to neighbouring residents and communities.     

The  applicant  is  seeking to  accept  a wide  range of  hazardous waste  materials,  including  industrial,  oil filters,  tyres,  inks,  tantalised 
timbers, flammable sludges, paint powders, pig  wax  and rag,  as they do  at the Dumfries site. Scotgen claim this will only  be a  minor 
amount of hazardous materials/substances in comparison to the whole site, however, how will this be regulated?    Can an enforceable 
condition apply to limit the amount of hazardous waste incinerated, and how would this be monitored to ensure it was being complied 
with?  
 
This proposed development is contrary  to  DM1 Development Management Policy  in that  it  does  not  respect  the local context.    The 
proposed building or use of the building does not make a positive contribution to the local community, but significantly detr acts from the 
visual  amenity  of  the  landscape  character,  habitats  and  species,  including  those  within  the  SSSI  Cander  Moss  and  the  wider 
environmental amenity, in addition to the long-term significant impact upon air, water and soil quality within the immediate local vicinity 
and the surrounding areas.       
 
Whilst Scottish Ministers generally support renewable ener gy generation, they require that the planning system ensure the environment 
and  local  communities  are  protected  from  inappropriately  located  developments.      The  aim  of  Policy  ENV  17  Renewable  Energy 
Community Benefit is to encourage developers to contribute to the Renewable Energy Fund by means of a Section 75 Agreement, thus 
securing  investment,  creating  employment,  relieving  poverty,  advancing  education  and  preserving,  protecting  or  enhancing  the 
environment. Should this  development  be subject  to  a Section 75 agreement, which community would the planning authority ensure 
benefits from this and how?    The application is within the Stonehouse boundary, but it  is clear  this  development will  affect  more than 
Stonehouse; it will affect all surrounding communities.    No  amount  of money secured through a Section 75 Agreement can offset the 
long-term damage to the environment and residential communities this development will cause. This applicant has stated that they will 
be  creating  50 jobs,  and will power  up to 90,000 homes.    It  is  likely  that these  50  jobs will be  of  a specialist  nature.    The  planning 
authority cannot enforce that these jobs will be given to local residents nor will the local communities benefit financially  from the power 
generated, only the developer, the landowner and the power companies benefit from this.     
 
Scottish Planning Policy and PAN 63 whilst supportive of Renewable Energy, set out key considerations, including that the location and 
design  of  new  development  must  protect  and  enhance  landscape,  natural,  built  and  cultural  heritage,  biodiversity  and  the  wider 
environment.    Prime  quality  agricultural  land  is  a  finite  national  resource.    Development  on  prime  agricultural  land  should  not  be 
permitted  unless  it  is  an essential component  of  the  settlement  strategy or  is  necessary  to  meet  an  established  need.  The  type  and 
scale of this development is not appropriate within the green belt, and does not support diversification of the rural economy in that it is 
not  associated  with  agriculture,  including  the  re-use  of  historic  agricultural  buildings,  woodland  and  forestry,  including  community 
woodlands,  horticulture,  including  market  gardening  and  directly  connected  retailing,  recreational  uses  that  are  compatible  with  an 
agricultural  or  natural  setting.    It  is  not  consistent  with  green  belt  policy  and  does  not  meet  an  established  need  where  no  other 
suitable site  is  available.  The  cumulative  erosion  of  a  green  belt s  integrity  through  the  granting  of  individual  planning  permissions 
should be avoided.    South  Lanarkshire Council has a responsibility to protect green belt which is an important resource for access to 
the  countryside,  providing  a  range of  opportunities  for  outdoor  recreation, education  and  tourism, and  for  protecting  and  enhancing 
biodiversity,  the  landscape  and  the  historic  environment.    This  development  is  better  suited  to  a  location  which  is  appropriate  for 
industrial  or storage and  distribution uses,  and therefore appropriate for  this type of waste  management  installation.  Consideration of 
this application must  focus on whether the development itself is acceptable rather than on control of the  processes or waste  streams 
involved  (SEPA).  Attractive  and  open  rural  areas  should  be  avoided  for  this  type  of  facility.  This  is  a  large  facility  and  will  be 
conspicuous  because of the necessary  size of the chimney stack and associated  buildings and will generate substantial heavy goods 
vehicle movements. Such schemes are particularly suitable in locations such as permitted or allocated waste management sites or on 
other  suitable  previously  developed  land  including  degraded,  contaminated  or  derelict  land.      This  development  does  not  capture 
energy to provide heating for local use and it is not part of an integrated network of waste management facilities for the area. 
 
In conclusion, this development is contrary to several planning policies and there are no material considerations which outweigh this to 
justify  the  development  at  this  location.    It  will  further  erode  existing  green  belt  designation,  be  incongruous,  over-dominant  and 
visually intrusive in the landscape, contribute to noise, dust, air pollution, increase traffic significantly and will not secure benefits for the 
local communities, their economy or their environment.   There is no justifiable reason that this development is required to fill a specific 
locational need. The generation of 50 jobs does not outweigh  or justify  this development at this  location.    If approved,  the  proposal 
would set an undesirable precedent which could encourage intensification of the site or similar applications for development prejudicial 
to green  belt  designation.  South Lanarkshire should not be setting precedent  to  allow developers  to  change  the use of gr een belt  to 
industrial land use. On a local level, recent records show a total of 41 applications have been refused for various development within 
the surrounding communities for  being  contrary  to  one or  more  of the  above  policies.    South  Lanarkshire Council cannot  justify this 
development within the green belt when it clearly refuses other minor developments for being contrary to green belt or other  local plan 
policies  as  mentioned above.    On  a national  level,  a  total of 5  applications  have  now  been refused  for  similar developments  across 
Scotland.    This type of development should only be considered in an industrial area and only when all other methods of recycling and 
reuse of waste have been exhausted.    South Lanarkshire Council should not grant this appl ication and then rely on SEPA to regulate 
and monitor operational breaches that will occur as they have done in the Scotgen Dumfries Plant.    This application should be refused 
before  it can get to this  stage.    Local  Councillors  and MSPs  have  expressed  thei r concern and  oppose  this development.    Scotgen 
have failed to raise public awareness of this application, however, it is clear from public concern now generated that South Lanarkshire 
Council need to listen to the voices of local communities and refuse this application.   
 
I trust that my objection will be registered, acknowledged and notification of the decision sent out in due course. 
Yours faithfully