Application at Land at Pynesfield, Maple Cross, Rickmansworth, Herts

HERTFORDSHIRE COUNTY COUNCIL Agenda No.

DEVELOPMENT CONTROL COMMITTEE 1 TUESDAY 21 JANUARY 2014

THREE RIVERS DISTRICT COUNCIL –APPLICATION FOR MINERAL EXTRACTION AND PROCESSING AND IMPORTATION OF SAND AND GRAVEL AND RECLAMATION MATERIALS (FROM DENHAM PARK FARM) FOR RESTORATION TO AGRICULTURE AND A SMALL WETLAND AREA, AND A NEW VEHICULAR ACCESS ON LAND AT PYNESFIELD, (OFF TILEHOUSE LANE), MAPLE CROSS, RICKMANSWORTH, HERTFORDSHIRE

Report of the Chief Executive and Director of Environment

Author: Ms Kim Harding Tel: 01992 555234

Local Member: Councillor Ralph Sangster

1 Purpose of Report

1.1 To consider planning application reference number 8/0761-13 for mineral development on Land at Pynesfield, Maple Cross, Hertfordshire.

2 Summary

2.1 This application seeks planning permission for mineral extraction, processing and importation of sand and gravel and reclamation materials (from Denham Park Farm) for restoration to agriculture and a small wetland area, and a new vehicular access on Land at Pynesfield, (off Tilehouse Lane), Maple Cross, Rickmansworth, Hertfordshire. The development is also considered under the Environmental Impact Assessment Regulations 2011 and is accompained by an Environmental Statement.

2.2 The application site is located in the Metropolitan Green Belt close to Junction 17 of the M25. The site is bounded to the east by the A412 known locally as Denham Way, to the north by arable land and the accessway to the Denham Park Farm site. To the south lies the South Bucks Way bridleway, houses and a wooded area. To the west lies more arable farmland. A site location and context plan is included at Appendix 1.

3 Conclusion

3.1 The proposed development is an acceptable use of green belt land. It will have some adverse impact upon the openness and landscape character of the site, but this will be short term in duration. There will be some noise impacts to adjoining residential properties but these are predicted to be within national level guidelines.

3.2 The location of the site in Source Protection Zone 1 means that it is unlikely that the effects of the proposal will be able to be mitigated to an acceptable level. It is considered that this impact is of sufficient scale and importance to recommend that the application be refused.

4 DESCRIPTION OF THE SITE

4.1 Pynesfield comprises an area of 17 hectares of arable land. The area to be worked is approximately 9 hectares of the 17 ha site.

Topographic features

4.2 The Land at Pynesfield is steeply sloping to the western edge, with a gradient in the region of 1:1. The highest point of the site is 68 metres AOD in the south west corner near to Cedar Grange. There is a semi- mature tree belt along the eastern boundary with the A412.

4.3 The application site is the eastern half of a field which flatterns out along the 40 metre contour towards the eastern boundary.

4.4 It is this flat area which is the subject of the application as this is where the deposit is found. The sloping part of the field does not form part of the application site.

Designations

4.5 The site has the following designations:  Green Belt;  Groundwater Source Protection Zone 1;  Flood Zone 1 (low risk fluvial);  Safeguarded area for HS2.

4.6 The Colne Valley Gravel Pits Local Wildlife Site 88/002 is immediately to the east of the application site and 350 metres to the south east is the Mid Colne Valley SSSI – designated of national significance for its breeding woodland and wetland birds and wintering wildfowl. A number of ancient woodlands are found to the south and south west of the site, including Juniper Wood and Great Halings Wood.

Site Context

4.7 The site is surrounded by a mix of arable land and peri-urban1 uses. The application site lies 200 metres to the west of the Denham Park Farm minerals site (in Buckinghamshire) and 800 metres to the south of West Hyde village. The site is bounded to the east by the A412 known locally as Denham Way (North Orbital Road). This road was the main thoroughfare around London before the M25 was built about 1 kilometre to the west.

4.8 Pynesfield is situated on the western side of the Colne Valley. To the east of Denham Way are numerous waterbodies associated with previous sand and gravel extraction which spread for approximately 10

Peri-urban areas are zones of transition from rural to urban land uses located between the outer limits of urban areas and the rural environment.

km along the floor of the Colne Valley. A site context plan is included in Appendix 1.

Photo 1: Looking north-eastwards across the site from the Tilehouse Lane end.

Adjoining Neighbours

4.9 Residential properties are scattered along and beyond the A412 (Denham Way) to the east of the site, as well as industrial activities such as a recycling depot, stone product manufacturer and motor repair workshop. These properties all fall within Hertfordshire County. Residential properties are also scattered to the south of the site along Tilehouse Lane. These properties are in South Buckinghamshire District Council.

4.10 The neighbours most directly affected by the proposal are:  Cedar Grange on Tilehouse Lane approximately 200 metres from the site boundary and 250 metres to the edge of the workings.  Colne Cottages are directly opposite the site on the eastern side of the A412. The cottages lie about 45 metres to the site boundary and about 60 metres from the nearest soil screening bund.  Troy House is located on the same side of the A412 as Colne Cottages but is set further back.  Corner Hall is to the north-west of the site in the region of 140 metres from the site boundary.

4.11 The site context plan in Appendix 1 shows the location of the site, the Denham Park Farm site and the immediate neighbours.

5 Description of the proposed development

5.1 The proposal, as initially submitted, was for the extraction of a recoverable sand and gravel reserve of 0.350-0.400 Million Tonnes over an 8 to 10 year period with an on-site processing plant. The amount of recoverable reserve has since been reduced by approximately 50,000 to 70,000 tonnes so as to avoid the area required by HS2 Ltd for the Colne Viaduct construction. The timescale has also been reduced to 5 years in order to have completed the development by the time the site is required by HS2 for landscaping works (the embankment) in 2019.

5.2 The site is proposed to be worked in conjunction with the neighbouring Denham Park Farm site. This site is located in Buckinghamshire and permission for development granted in 2012 by Buckinghamshire County Council. Development under this planning permission has commenced and Denham Park Farm (DPF) was due to begin operating at the end of 2013. The applicants maintain that Pynesfield is uneconomic to develop in its own right as the small size of the reserve does not justify the cost of the infrastructure. Working the two sites together allows for the sharing of infrastructure costs and the restoration of Pynesfield with inert natural material (surplus clean clays and interburden) from DPF.

5.3 The combined mineral reserve warrants the installation of an on-site plant. This will enable material from Pynesfield and DPF to be processed on the Pynesfield site. The materials from the two sites will be blended into a high quality aggregate. Once operating, the material from the DPF site is to be taken to Harleyford’s South Harefield site for processing.

5.4 The proposed plant is to be located on the Pynesfield site because of the availability of water for processing. The material will be imported from DPF on a campaign basis, that is, in concentrated activity over short periods of time. Between these campaigns there will be no crossover movements on Tilehouse Lane.

5.5 Groundwater is found 1.5 m below ground level (at about 38.5 mAOD) and mineral depth has proved to be up to 8 metres below ground level to 34m AOD. No dewatering is proposed. It is proposed that the mineral is worked wet below the water table, creating a water filled void. The direction of working was originally proposed to be from north to south, with the area under the plant excavated last, but this has been altered to avoid HS2.

Site Access

5.6 Access to the site will be off a section of Tilehouse Lane that was realigned as part of the Denham Park Farm application. A new bellmouth entrance will be constructed to gain access to Pynesfield and a new vehicle crossover will be constructed on the Tilehouse Lane. An internal haul road is proposed to link the Pynesfield site to the Denham Park Farm site and this will be subject to a separate planning application.

5.7 No traffic associated with the development will use Tilehouse Lane beyond the junction (that is to the west of the crossover). Once the reserve has been extracted from Pynesfield, the vehicle crossing on Tilehouse Lane and the bellmouth for access to the Pynesfield site will be removed.

Vehicle movements

5.8 Initially, the Pynesfield development proposed no net increase in traffic movements to those already permitted from Denham Park Farm. It did however, extend the period of traffic movements by a further 2-3 years if assessed at the maximum level. The number of HGV movements predicted for the site were initially a maximum of 124 movements a day (62 in and 62 out) plus 30 movements for staff and visitors. As a result of the reduced timescale, the number of vehicle movements is proposed to increase to 174 movements/day (including staff and visitors).

5.9 The Denham Park Farm site will continue to operate as originally envisaged, for another 10 years (subject to HS2 requirements).

Hours of operation

5.10 The proposed hours of operation are:  0700-1800 Monday to Friday  0700- 1300 Saturday

5.11 No hours of operation are proposed for Sundays or public holidays.

Target Market

5.12 The target market for the development is the local market. Most traffic movements will be local in nature and access the site via the A412.

Vegetation

5.13 The margins of the site, containing the hedgerows, trees and rough grass will be undisturbed by the development. No trees are proposed to be removed as part of the application.

5.14 A new hedgerow with trees will be planted along the southern part of Tilehouse Lane and a new hedgerow along the A412 as part of the application. A wooded area will also be planted between Tilehouse Lane and the new access to DPF. Some additional hedgerow planting will also be placed along the easterly end of Tilehouse Lane, at the northern end of the site.

5.15 Additional hedgerow planting will supplement the existing planting along the South Bucks way.

5.16 Photo 2 shows the view of the site from the bridleway along the south-

eastern corner of the site, looking towards Tilehouse Lane.

Operational working

5.17 The depth of the topsoil and subsoil is on average in the region of 1.1 metres. The topsoil will be stripped separately from the subsoil and used to create the 3.0 metre high perimeter screening bund around the site. The subsoil will be stripped and stored adjacent to the topsoil in subsoil bunds between 3.0 and 5.0 metres high.

5.18 The processing plant will be of modular low profile design with the height being below 7.5 metres. Because of the nature of the deposit there needs to be a crusher in closed circuit which is located on the far side of the plant to the A412. Ancillary operations include a weighbridge and site office, a container security store/workshop and bunded fuel tanks within a securely fenced area. A small on site car park for staff will also be provided. An operations plan is included at Appendix 1.

Phasing

5.19 The site will be worked on a phased basis, starting at the southern end of the site and progressing northwards. The plant area itself will be excavated towards the end of the development and during this time the plant will be relocated on to the restored land.

Water

5.20 Because of the location of the site within Groundwater Source Protection

Zone 1 the site will be worked wet and the mineral worked using a long reached excavator. The development will result in some loss of aquifer as the reclamation material will have not have as great a water storage capacity as the sand and gravel that is currently in situ.

5.21 Water for processing the deposit on site will come from the excavated area. Processing will recirculate the water through the settlement ponds to the south of the plant. These will be regularly cleaned out.

Lighting

5.22 Artificial lighting is only proposed to be used in winter for the first hour of operations in the morning and the last hour of operations in the evening. Generally processing stops when it gets too dark for health and safety reasons.

5.23 Floodlights will be mounted on short poles on the top of the processing plant with the light directed downwards to avoid light spillage. A floodlight will illuminate the weighbridge and the security store. The lighting on the site is designed so that there is no risk of any light spillage to residential properties or which could adversely affect ecology.

Security

5.24 The lights on the office and workshop/store will be on intruder sensor, timer and CCTV camera.

Restoration

5.25 Following the extraction of the mineral, the applicants propose to restore the site progressively to agricultural use. The applicants propose to reclaim the site by depositing clean fill from DPF into the void up to the basal level of the soil profile.

5.26 Following completion of the reclamation the platform will be ‘ripped’ to ensure that any compaction has been remedied. The restored soil profile will then be built up with 0.8 meters of subsoil followed by 0.3 metres of topsoil, following good practice guidance on soil placement.

5.27 To the south of the site, an area will be restored to a slightly lower level to produce a wetland area to balance the drainage on the site and ensure that runoff rates from the site meet greenfield standards, including an allowance for future climate change.

Aftercare

5.28 Aftercare for the site will be carried out for 5 years following the completion of operations at the site. It will be carried out in conjunction with the farming of the undisturbed part of the site which will be consolidated with the land to make one field. Aftercare will include soil sampling to establish nutrient requirements; a review of drainage arrangements and carrying out remedial works where necessary; and

preparing an annual report for submission to HCC.

6 CONSULTATIONS

District Councils

6.1 Three Rivers District Council objected to the application following the first round of consultation on the following grounds (further comments were forwarded in relation to the amended details on 17 December 2013 and are shown in italics):

 The proposed development would, by reason of the height, length, artificial appearance and resultant prominence of the bund; the height, floor area and metallic appearance of the processing plant; the general form and extent of the hardstanding and other development (including the site office and floodlighting), and the associated site activities (including operation of the processing plant) result in an urbanising form of development, with unacceptable adverse impact on the natural environment and detrimental to the openness and rural character of the Green Belt. As such, the proposal constitutes inappropriate developement. The developement is therefore contrary to Plicies CP1, CP6, CP11 and CP12 of the Core Strategy (adopted October 2011) and Policy DM2 and Appendix 2 of the Development Management Policies LDD (adopted July 2013).

 The proposed development would, by reasons of the height, length, artificial appearance and resultant prominence of the bund: the height, floor area and metallic industrial appearance of the processing plant; the general form and extent of hardstanding and other development (including the site office and floodlighting) , and the associated site activities (including operation of the processing plant), constitute inappropriate development that would fail to maintain and enhance the landscape in terms of its scenic and conservation value and public amenity. The development is therefore contrary to Policies CP1, CP6, CP9 of the Core Strategy (adopted October 2011).

 The applicant has failed to demonstrate to the satisfaction of the Local Planning Authority that the risk posed by the proposed development to groundwater quality and resources is acceptable nor that it has been adequately mitigated for. The proposed developement is therefore contrary to Policy CP1 of the Core Strategy (adopted October 2011) and Policy DM8 of the Developement Management Policies LDD (adopted July 2013).

Neighbouring authorities

6.2 South Bucks District Council has no objection to the development

provided that the potential impact on the amenities of nearby properties, including those within South Bucks District is appropriately and sensitively assessed.

6.3 No response was received from the London Borough of Hillingdon.

6.4 No response was received from Buckinghamshire County Council.

Statutory Consultees

6.5 HS2 Ltd initially objected to the development, however the applicants have negotiated with HS2 Ltd and amended their plans for the site by reducing the timescale of the development, changing the direction of working and reducing the southern extent. HS2 have since withdrawn their objection, subject to the imposition of a number of conditions.

6.6 The Environment Agency objects in principle to the application. They consider the proposal poses an unacceptable risk to groundwater quality and resources as the proposed site is in a highly sensitive location on a Principal Aquifer within Source Protection Zone 1. They note it is contrary to their Groundwater Protection: Principles and Practice document (GP3) Principle N8, E1 and F1.

6.7 Natural England raises no objections and imposes no conditions although they note that the restoration misses a significant opportunity to contribute to the county’s nature conservation objectives. They state that the retention of a chalky substrate and capping with a thin layer of subsoil would, with appropriate seeding, provide ideal conditions for the creation of a significant area of chalk grassland (a national priority habitat).

6.8 In response to the second consultation Natural England wished to reiterate their previous comments that the proposal offers a significant opportunity for the creation of an area of chalk grassland habitat. They felt that any area of grassland would require grazing management for its long-term conservation. They considered that this would qualify as ‘agricultural use’: so would not be in conflict with the restoration to agricultural use.

6.9 Hertfordshire County Council as Highway Authority do not wish to restrict the grant of permission subject to the imposition of several conditions which includes improvements to the junction with the A412.

6.10 Thames Water had no objection to the proposals on sewerage infrastructure capacity grounds

6.11 Affinity Water did not respond to the consultation.

6.12 Denham Aerodrome (owned and operated by Bickerton’s Aerodromes Ltd) stated that the landscaping details should include a requirement in respect of aftercare and restoration so that sites are restored and

managed in a way which would not interfere with the safe operation of aerodromes or with the movement of air traffic.

6.13 They noted that DPF has already been granted permission to extract minerals. They stated that the two developments should not be allowed to be simultaneous as in the event of engine failure, an aircraft may need to carry out a forced landing on these sites.

6.14 Civil Aviation Authority and BAA (for Heathrow) did not respond to the consultation.

Other Consultees

6.15 HCC Landscape Officer has no objection to the proposed scheme, subject to a condition requiring a landscape scheme to be submitted in due course, including landscape management proposals for existing and new planting.

6.16 HCC Historic Environment Unit (Archaeology) consider that the proposal is likely to have some impact on heritage assets, although these may not be of high significance. They recommended that three conditions are imposed on the development to safeguard any archaeological potential on the site.

6.17 HCC Rights of Way has no objections subject to additional planting along the border with the South Bucks Way and replacement of the fence along the bridleway where necessary. They also wish to have barriers placed on the end of the Bridleway so that horses do not get spooked and run out onto the A412.

6.18 Hertfordshire Biological Records Centre did not consider there are any ecological constraints associated with the proposals. They note there will be some ecological gain locally from the wetland feature and new hedgerows and trees. Given the relative paucity of ecological features within the immediate landscape, they support hedgerow planting with trees along Tilehouse Lane, as offered.

6.19 Herts and Middlesex Wildlife Trust do not object to mineral extraction at Pynesfield on wildlife grounds, subject to good environmental management, retention and protection of the boundary linking habitats; and a restoration scheme that would deliver a net biodiversity gain for the site and enhance the ecological network. They request that consideration is given to the cumulative environmental and ecological impacts (both direct and indirect) of the mineral schemes and HS2 project, and also to how the plans for restoration and ecological mitigation will interact. They also stressed that grazing the site was compatible with restoration to chalk grassland.

6.20 Following the reconsultation they requested that robust conditions are put in place to ensure that restoration and ongoing management of the site delivers a long-term net biodiversity gain that is not compromised by

the HS2 development, and benefits the ecological network.

Neighbour Consultations

6.21 As the application was the subject of further information and an amendment, two different consultation exercises were carried out. The first was in May and the second in October 2013.

6.22 A total of 682 properties were consulted and 93 letters of objection were received (in total) from both consultation exercises. The main issues of concern can be summarised as:

 Effect on Green Belt  HS2 especially in  Need and Landbank terms of cumulative  Historic character effect  Effect on recreational  Economic Impact users  Viability  Visual impact  Cumulative effect  Loss of amenity  Duration  Plant  Hours of operation  Wildlife/Ecology  Lighting  Noise  Water Table  Air quality  Water quality  Effect on local roads  Contaminated Site and traffic  Flooding  Loss of agricultural  Aftercare and land Restoration

6.23 A comprehensive list of the points raised is included in Appendix 2.

Publicity

6.24 As with the consultation process, two different publicity rounds were carried out. The first was at the end of May and the second was in October 2013. For each consultation exercise a press notice was published in the Watford Gazette and site notices were put up in three locations on the perimeter of the site.

7 PLANNING CONSIDERATIONS

7.1 While all issues raised during the consultation process were duly considered, the principal issues to be taken into account in determining this application can be summarised as:  Impact on Green Belt and visual amenity  Need/Justification  Impact on residential amenity (noise; dust)  Impact on highways and transport  Impact on ecology and biodiversity  Landscaping and trees  Recreational impacts including rights of way

PLANNING POLICY

National Planning Policy Framework 2012 (NPPF)

7.2 The NPPF was released in March 2012. Enshrined within the NPPF is the presumption in favour of sustainable development. The NPPF stresses that the development plan remains the starting point for decision-making and that decisions should be made in accordance with an up to date Local Plan unless material considerations indicate otherwise.

Development Plan

7.3 The development plan is the Hertfordshire Minerals Local Plan Review 2002-2016 (Adopted 2007). As the Plan was prepared in 2007, the policies in the plan need to be balanced and given ‘due weight’ against the NPPF. The NPPF is a material consideration and how policies from the Development Plan are in conformity with it need to be considered. This will vary depending upon individual proposals and how they relate to the NPPF and the Development Plan and the overall intentions of the relevant document.

7.4 The relevant development plan policies are:

Minerals Policy 1 – Aggregates Supply Minerals Policy 2 – Need for Mineral Working Minerals Policy 3 – Sites for sand and Gravel extraction and the working of preferred areas Minerals Policy 4 – Applications outside preferred areas Minerals Policy 5 – Mineral Sterilisation. Mineral Policy 9 – Contribution to biodiversity Minerals Policy 11 – Cumulative Impact Minerals Policy 12 – Landscape Minerals Policy 13 – Reclamation scheme Minerals Policy 14 – Afteruse Minerals Policy 16 - Transport Minerals Policy 17 – Critical capital and other environmental assets Minerals Policy 18 – Operations Criteria

7.5 Also considered was the Three Rivers Emerging Local Plan (Core Strategy adopted 2011). The relevant policies here are: Policy CP1 Sustainable development Policy CP9 Green Infrastructure Policy CP11 Green Belt Policy CP 12 Design of Development and Saved policies N4, N22, GB1 of the Local Plan

7.6 The South Bucks District Council Local Plan: Policy EP17 Aerodrome/Air traffic safeguarding was also considered.

Need and Justification

7.7 The landbank is the stock of planning permissions for the winning and working of materials. The Minerals Development Framework policies seek to ensure an adequate landbank is provided and identify preferred sites for this. Pynesfield is not a preferred site. The policies therefore have a presumption against approval of new permissions on new sites.

7.8 The only exceptions to this presumption in favour of preferred sites are proposals which would not prejudice the timely working of preferred areas and resources at risk of sterilisation in Policy 4. Policy 5 encourages mineral extraction prior to other development taking place.

7.9 The Hertfordshire landbank currently stands at 11.4 Years (AMR 2012). The actual amount of reserves currently available are less as the permission for Rickneys in Hertford has just expired (approx 1.2 Mt) and a year of sales has occurred since the landbank figure was calculated (average annual sales are currently around 1.17 Mt per annum2). The NPPF says that MPAs should look to maintenance of landbanks of at least 7 years for sand and gravel. Currently Hertfordshire’s published landbank exceeds the level of landbank suggested (which is about 8.2 years) and also the current position taking account of loss of Rickneys

2 Local Aggregates Assessment. November 2012

planning permission and depletion through sales.

7.10 The status of ‘need’ in determining an application has been lessened under the NPPF which states that “great weight” should be given to the benefits of mineral extraction. The NPPF also states that landbanks should be used “principally as an indicator of the security of aggregates mineral supply….” - a high landbank could have been a reason for refusal before the NPPF.

7.11 The NPPF also says minerals planning authorities should plan for the supply of aggregates by ensuring that large landbanks bound up in a very few sites do not stifle competition. The NPPF also states that longer landbanks may be appropriate to take account of locations of permitted reserves relative to markets.

7.12 There are currently 4 main sand and gravel sites operational in Hertfordshire. They are Hatfield Symondshyde, Westmill – both operated by Cemex; Tyttenhanger (Coursers Road) and Panshanger to the west of Hertford both operated by Lafarge/Tarmac. Water Hall Quarry does have reserves of sand and gravel though none is being dug at the moment and it is a smaller site. The Minerals Plan includes two basic types of site for mineral extraction; current working sites, including those with resoluton for approval, and 3 areas of search. The number of active sites with planning permission has reduced during the plan period and now there are 4 main larger working sites, one of which forms one part of the 3 large areas of search.

7.13 The NPPF says that mineral planning authorities should ensure in planning for the supply of aggregates that land banks are not bound up in very few large sites, i.e. this should be addressed as part of the policy and plan formulation process. The County is commencing a review of its mineral plan and this plan is the place for a review of this issue. Therefore in terms of the current application little weight should be given to mineral reserves in Hertfordshire being bound up in only four major sites and two separate areas of search.

7.14 The site is at some risk from sterilisation. The most immediate threat is from HS2. While there is currently some speculation as to whether the project will proceed, the project is a material consideration and is subject of safeguarding orders confirmed by government which must be followed by planning authorities. Current HS2 proposals for the site would make winning the material during or after the HS2 development unlikely due to legal, physical and economic issues.

7.15 The applicants maintain that the small size of the deposit also increases the risk of sterilisation, as the returns would not justify the necessary investment in infrastructure. They state that this makes the site uneconomic to work by itself. However, the mineral is still capable of being worked and the economics may change over a longer time period.

7.16 Policy 1 says that planning permission will only be granted where it is necessary to meet the county’s agreed apportionment. The apportionment is met though and the contribution from the proposal in landbank terms would be small.

7.17 Policy 2 says that account should be taken of the existing quantity of reserves and their rate of working and also the application rate of working. The proposal is of small scale and would not be likely to impact upon the rate of working of existing sites, especially considering its distance from the nearest site, Tyttenhanger in Hertfordshire. The small size of the deposit would also be unlikely to prejudice any of the preferred areas coming forward. The quality of the sand and gravel deposit is good, having a high stone content and can be used to enhance an already permitted supply by blending of materials.

7.18 The proposal has changed due to comments from HS2 who previously had objected. The new proposal would lead to the loss of some recoverable mineral however the amount is relatively modest and is not considered to be significant in terms of the Policy 5 and thus lead to a conflict with the policy..

7.19 Minerals Policy 5 says that mineral extraction will be encouraged prior to other developement taking place where any significant mineral resource would otherwise be sterilised. The text supporting this policy says that in order to prevent permanent loss where affected by other development, prior extraction should be encoraged. The NPPF says MPAs should look at defining Mineral Safeguarding Areas and adopting policies to avoid minerals being needlessly sterilised. Currently the County Council does not use Mineral Safeguarding Areas but does have Mineral Consultation areas, Pynesfield does fall within a Minerals Consultation Area (which is broadly defined as the ‘sand and gravel belt’). Further the NPPF says MPAs should set out polices which encourage the prior extaction of minerals, if neccessary, prior to other non-mineral developement taking place. In respect of sterilisation the Hertfordshire Minerals Plan is in conformity with the NPPF, though the issue of whether HCC should use Mineral Safeguarding Areas will be looked at during the minerals plan review process.

7.20 The mineral resource at Pynesfield would be likely to be partially sterilised by HS2 which is a material consideration in determining applications. There may also be some economic sterilisation, which may increase due to reduction of any available deposit from HS2, but policy (national and local) does not explicity recognise economic sterilisation, though making the best use of mineral resources in an overall aim of the NPPF. The proposal would avoid sterilisation of some of the resource prior to HS2 and also a current or medium term sterilisation of the resource in economic terms, some positive weight should be attached to this in reaching a decision.

7.21 Policy 4 says that applications outside of preferred areas will be refused planning permission except where sterilisation would otherwise occur.

Whilst the proposal does not fall directly under sterilisation as provided in Policy 5 some sterilisation effect would occur. The proposal then does not conflict with policy 4.

Green Belt

7.22 The site is located within the Metropolitan Green Belt for London. Green belt land is characterised by its openness and permanence. The fundamental aim of green belt policy is to prevent urban sprawl by keeping land permanently open. It should be recognised that minerals can only be worked where they are found and cannot effectivelly take place within urban areas.

7.23 The five purposes of Green Belt are set out in paragraph 80 of the NPPF. They include to check the unrestricted sprawl of large built up areas and to assist in safeguarding the countryside from encroachment. Minerals must be worked where they lie and are considered appropriate development in the Green Belt. Paragraph 90 states that: Certain other forms of development are also not inappropriate in Green Belt provided they preserve the openness of the Green Belt and do not conflict with the purposes of including land in the Green Belt. These are ...mineral extraction.

7.24 Bunds and processing plant do impact on the openness of a site; however these are recognised elements of a mineral development and short term in duration. The processing plant is a relatively low level plant. The bund heights in terms of mineral sites are modest, as they are formed from top and sub soil. These bunds are limited in their height in order to preserve the soils and not lead to their compaction. These impacts arising from the Pynesfield mineral developement are not unusual for a mineral developement. The Pynesfield development will preserve the openess of the Green Belt in the longer term as it is temporary in nature. The duration is short because of the size of the deposit and potential conflict with HS2. Post development there will be no impact upon openess. The proposal would be inappropriate development though its impact upon openess is limited in amount and in duration. One of the most significant featues of the Green Belt is said to be its permanence, so short term operations have a relatively smaller impact upon green belt objectives.

7.25 Within the Green Belt where development is inappropriate development planning authorities should not grant planning permission and substantial weight should be given to any harm to the Green Belt. In these cases development should not be approved unless very special circumstances exist which would clealry outweigh the potential harm to the green belt and any other harm.

7.26 Minerals sites are excluded from the definition of Previously Developed Land in the NPPF, so this form of development is not conducive to housing or landfill development. Any such proposal would be considered on its own merits against the local development and waste plans. The

planning balance including green belt is considered later within the conclusion to this report.

Flood Risk and drainage

7.27 The land is zoned Flood Zone 1. This is defined in the NPPF as land with a low probability (less than 0.1% annual probability) of flooding from fluvial (i.e. river) sources. Flood risk management policy tries to steer development into Flood Zone 1. Flood Maps are indicative only and can be inaccurate, especially at the margins of flood zones but irrespective of this, sand and gravel working are categorised as water-compatible development and are therefore considered to be acceptable uses in all flood zones.

7.28 Residents of the area had experienced sewer flooding earlier this year as a result of a burst sewer main. This should not be taken as an indicator of potential flood risk as sewer flooding can occur anywhere.

7.29 Because of the size of the development (over 1 hectare) a Flood Risk Assessment was prepared. The assessment concluded that a 1 in 100 year flood (6 hour storm @ 1% average annual probability) could be easily accommodated within the quarry void (of about 1.5 hectares).

7.30 The FRA noted that the infiltration potential of the land would decrease due to the impermeable nature of the restoration material, and that runoff would increase as a result. The report also notes that volumes of surface water are also expected to increase as a result of climate change. On–site storage is therefore required to accommodate the expected increase in rainfall intensity and reduced permeability of the restored site. The on-site storage will be by way of a linear ditch/soakaway to the east of the worked area which will drain to a seasonally wet area in the south-east of the worked area. The report concludes that it is anticipated that the water will readily infiltrate into the sand and gravel and then to the chalk below.

Highways

7.31 Access to the site is from the newly created access way for DPF, which required the diversion of a short stretch of Tilehouse Lane to the A412. The A412 Denham Way is also known as the North Orbital Road and was formerly the main way of travelling around London. As a result of this, it was built to a high standard with a single carriageway road approximately 9 metres wide and wide grass verges. Traffic generated as a result of the development would use the A412 to access local markets.

7.32 A transport assessment was submitted with the application. The assessment noted that the HGV content was in the region of 16% at about 1228 movements a day. The assessment cites the initial proposal as generating about 124 HGV movements/day and up to 30 car trips for

staff and other personnel, a total traffic flow of 154 movements. There was to be little impact on traffic movements on the local network as the Pynesfield development was to incorporate the already permitted HGV movements for DPF (124 lorry movements/day during the week and 60 on Saturdays). The transport statement concluded that 154 movements was an increase of traffic on the A412 of less than 3% over the 12 hour two way flows based on counts from November 2011. Traffic counts from September 2013 show average weekday 12 hour counts (7am-7pm) in the region of 10,000/day (two way flows). This suggests that the impact of traffic generated by the development may now be less than 3%.

7.33 Many of the HGV movements from the permitted DPF were to the processing plant at Harefield via Denham Green. These will no longer be required while Pynesfield is operational because of processing on site. The impact of the net increase in lorry movements arising from the Pynesfield development – up to 30 additional movements a day because of the shortened timeframe - will be minimal.

Noise

7.34 The NPPF technical guidance advises on acceptable levels of noise form minerals operations. The NPPF advises the following limits should not be exceeded:  10dBA above the background noise level; subject to  A maximum value of 55 dBA3.

7.35 All mineral workings have some particularly noisy short term activities that cannot meet the 55 dBA limit. These include bunding, soil stripping and construction of new landforms. The NPPF suggests a limit of 70 dBA for these activities for up to 8 weeks in any year, with some provision to exceed this period if absolutely necessary but with a lower noise limit required.

7.36 A noise assessment was carried out for the development. This measured background noise levels at sensitive sites and predicted worst case noise levels at each site. The assessment assumed that all plant would be operating 100% of the time. No account of the noise mitigation offered by any stockpiling or storage mounds was taken into account in the calculations.

7.37 The assessment measured background noise levels at noise sensitive properties along Tilehouse Lane and the A412. Background noise levels were primarily influenced by the A412 and the aircraft flying in and out of Denham Aerodrome.

7.38 Properties at risk from noise impacts include Cedar Grange on Tilehouse Lane (and properties further along Tilehouse Lane), and Colne Cottages, Troy House and Corner Hall along the eastern side of the A412.

3 55 dBA is the average noise level for a domestic dishwasher.

7.39 The property with the lowest background noise levels was Cedar Grange on Tilehouse Lane. This property lies about 250 metres from the southern edge of the workings in South Bucks District Council. The noise assessment for this site was calculated based on a worst case scenario, without consideration of the effect of any bunds because of the height of Cedar Grange relative to the workings. The plant, which will be the source of the much of the noise, is located at the northern end of the site. Stockpiles and bunds will offer additional noise protection particularly from the plant and processing area. The assessment concluded that, while there will be a change in background noise levels as a result of the development, this change will be within nationally prescribed limits (see Table 1 below).

7.40 The closest property to the development is Colne Cottages. This property lies about 65 metres from the edge of the workings. Background noise levels at Colne Cottages (and also Troy House and Corner Hall further along A412) are relatively high as a result of traffic on the A412. Colne Cottages are also surrounded by industrial uses such as a recycling depot and motor repair workshop. Predicted levels at these properties are within NPPF limits.

7.41 Noise mitigation for nearby properties was proposed in the assessment in the form of perimeter earth bunds.

7.42 It is good practice to carry out noise monitoring once the site is operational. The assessment advises that noise levels are monitored 3 months after commencement of full operations and the readings compared against existing levels. Subject to the findings, a noise monitoring programme can be agreed to ensure that noise from the operations is performing within the noise criteria. This can be secured by condition. Further a condition should require that noise levels do not exceed the backgorund by more than 10dBA or an absolute level of 55dBA, with an exception in respect of short term activity where this should be restricted to a maximum of 70dBA for a period of no more than 8 weeks.

Table 1: Proposed Site Limits for Normal Working Site Average Measured Proposed Site Noise LA90 [dB] – background Limit noise levels L Aeq, 1 hour [dB] Troy House/Colne 48 55 Cottage Cedar Grange, 39 49 Tilehouse Lane Corner Hall/The 43 51 Bungalow

7.43 Given the proximity of residential properties, the hours of operation will be reduced slightly to a 7:30 am start on weekdays (in line with that

permitted for DPF) and a 8:00 am start on Saturdays. This will be secured by way of condition.

Floodlighting

7.44 Mineral working is predominantly a daylight activity and artificial lighting is only required for limited periods in winter. The lighting design has been designed to minimise the effect of lighting on birds or bats. It is intended that directional lighting would be used for any floodlights. A condition requiring approval of the details of lighting should ensure that any sensitive areas such as bat flight paths, tree lines, and hedgerows are protected.

Air Quality/Dust

7.45 The site will be worked wet so little dust is expected to be created from the workings. Water is also added to the processing stage of the sand and gravel. This generally results in the processing areas and stockpiles being generally damp.

7.46 The main source of dust will be the movement of HGVs along the roads. These can be dampened down with a bowser and spray as is accepted practice. A condition should be applied to ensure management of this issue.

Mud on roads

7.47 The hard surfaced roads within the development and the adjacent public highway will be kept clean through the use of a road sweeper. This will remove debris from the road and keep it free from any dust or discolouration.

7.48 There will be a wheel washing facility on the DPF access road for use for both sites. A condition should be applied to ensure management of this issue.

7.49

Landscape and Visual Impact

7.50 A Landscape and Visual Impact Assessment (LVIA) was submitted with the application. This considers the effect of the development on landscape and visual amenity.

Landscape impact

7.51 The current landscape has wide sweeping contours and is not considered to have any impact on the scale of the landscape. The landscape is sandwiched between the M25 and the A412 and because

of farm modernisation has lost many of its original hedgerows and trees. The LVIA concludes the development will have a short term adverse effect on character and this should be balanced by the benefits of the proposed planting of copses, hedgerows and trees for mitigation purposes.

Visual Amenity

7.52 The LVIA considers each receptor and assesses the net effects (i.e. after mitigation usually by planting, existing tree screening or bunding) of the proposal against the visual amenity of each viewpoint. The net effects are concluded to be:  An effect on glimpsed views from the A412 that is low/insignificant.  An effect on glimpsed views from Tilehouse Lane that is low to beneficial (beneficial due to the proposed planting).  An effect on views from the Old Uxbridge Road that are considered to be low-moderate.  An effect on glimpsed views through gaps in the hedgerow along the public footpath along the southern boundary that is moderate.  Glimpsed views from the east-west byway to the north of the site) DPF cant haul road) low to insignificant.  Minor long distance views from the east side of the Colne Valley which are insignificant due to the distance involved and the vegetation present.

7.53 Indicative landscaping proposals submitted with the application indicate that substantial tree and hedgerow planting would be undertaken.

7.54 The County Landscape Officer requires submission of a final landscaping scheme incorporating all the planting and mitigation measures proposed. The landscaping scheme should include details of the proposed woodland mix including sizes, species and planting densities to include both shrubs and transplants which could extend out from the base of the bunding to maximise tree planting.

Ecology

7.55 Overall, the site is considered to be of generally of low ecological value. The development will have no impact on nearby designated nature conservation sites.

7.56 A phase 1 habitat survey was carried out in June 2011. As most of the site is arable little evidence of wildlife was found. The ecological survey found that:  The site was considered to have low potential for badgers, breeding birds, common species of reptile, great crested newts and foraging and commuting bats.  The site is considered to have medium potential for dormouse and roosting bats.

 The development will have no effect on the Mid- Colne Valley SSSI as no dewatering will be taking place.  The vegetation of greatest ecological value is the hedgerow and woodland bordering the south of the site, the row of trees located along the eastern boundary and the mature oak trees located along the western site boundary.  Gravel extraction on the site and the installation of the proposed access road could potentially have an impact upon the vegetation on the site.  The development would have minimal impacts on badger, and no or negligible impacts on reptiles and newts.

7.57 The mitigation measures proposed are considered sufficient for the breeding birds, bats and dormice potentially affected by the works. To mitigate any further effect, the survey recommended that the on site vegetation be buffered from the proposed works. The survey recommended that this should include an earth bund and an undisturbed strip between the woodland and the proposed gravel of at least 10 metres. It also recommended that further 10 metre buffer strips be created around the mature oak trees located along the western site boundary. Specific conditions should be attached to any planning permission to ensure this.

7.58 The first consultation exercise highlighted the existence of corn buntings in the vicinity of the site. Corn Buntings are a red book species, so further advice was sought. The advice received was that Corn Bunting like habitat similar to other songbirds, i.e. a mix of scrub, hedgerow and arable, although corn bunting do have a preference for stubble or bare land that will establish ephemeral weeds and other seed bearing species.

7.59 The applicants propose to provide habitat similar to that preferred by the Corn Bunting by leaving some of the screening bunds, especially in the north of the site unseeded. Normally they would be grass seeded. It is expected that the preferred habitat of the Buntings will self generate from the inherent seed bank. The bunds will need to be ‘disturbed’ every second year by light discing or harrowing to avoid grassland becoming established.

Overall Ecological Benefits

7.60 The development will have a new hedgerow to provide an understory to the trees bordering the A412. This will increase habitat for birds and provide a better structure to the planting. The development will also strengthen the southern boundary by planting up gaps to increase this resource in terms of birds and small mammals (although HS2 proposal may affect this boundary in the long term) and provide additional planting along Tilehouse Lane. The ditch along the eastern margin (on the field edge of the headline) which drains to a low wetland area and small pond will also provide terrestrial habitat for amphibians, reptiles and ground

nesting birds.

7.61 These improvements would be secured via a planning condition requiring the submission of a wildlife habitat management plan.

HS2

7.62 The site lies entirely within the limits of land subject to the adopted HS2 Safeguarding Direction (Phase One). Should HS2 be approved, the site will house part of a construction compound, a significant landscaping mitigation bund and a large balancing pond. Powers to construct and operate High Speed 2 are to be sought by promoting a Hybrid Bill which was deposited with Parliament on 25th November 2013. As a result the application site, or part of it, may be compulsorily purchased.

7.63 A number of objections were received regarding the effect, and particularly the cumulative effect of HS2 with the development. The proposal, as originally submitted, conflicted with the construction of HS2 in this location. Following negotiations, the applicant amended the scheme slightly by reducing the southern extent of the workings and bunds, repositioning the balancing pond and also changing their direction of working to work the site from the southern end in a northerly direction. This is favourable for HS2 Ltd, given the intention for construction works for the railway to commence in this location by 2017 and the embankments constructed during 2019/2020.

7.64 Given that the development will be nearing the end of its operational life when HS2 begins working in the area, the degree of overlap between the two projects will be limited in duration.

Water/Groundwater

Context

7.65 The site lies in the catchment of the River Colne. The majority of the Colne valley has been worked for minerals so the area to the east of the site is predominantly water bodies. The soils of the valley are highly permeable resulting in few smaller watercourses and the presence of dry valleys. Underlying the chalk is a major aquifer. The sand and gravel reserve lie directly on the chalk and groundwater within the gravels and chalk are in hydraulic continuity.

7.66 There are public water supplies in the Colne Valley, an Environment Agency monitoring borehole on site and an Affinity (public water supply) borehole 400 metres to the east of the site.

7.67 As the site lacks any surface watercourses, there will be no impact on surface water. The workings will impact on groundwater levels and flows as well as groundwater quality.

Water Quality Issues

7.68 The site is located in Source Protection Zone 1 (SPZ1). Where groundwater is abstracted for public use as drinking water, the Agency identifies areas of high sensitivity as source protection zones, with SPZ1 the most vulnerable. Source Protection Zone 1’s require the highest degree of protection.

7.69 Pre-application consultation with Veolia (now Affinity) established concerns about a reduction in water quality due to suspended solids finding their way through the chalk to the abstraction borehole. Mitigation proposed by the applicants included leaving undisturbed a basal layer of sand and gravel that will act as a natural filter and the second is to ensure that silt which arises during processing is washed into settlement ponds.

7.70 A hydrogeological and hydrological assessment was carried out for the development. Mitigation proposed for the location of the site in SPZ1 includes no dewatering, which reduces the need to discharge water into surface watercourses. Wet working also means that there will be no drawdown of groundwater which could affect surrounding vegetation.

7.71 Other mitigation proposed includes reclaiming the site using natural clays and sandy clays excavated for this purpose from DPF.

7.72 Risks to water quality because of accidental spillages from oil or fuel will be conditioned so that good practice is followed.

7.73 The Environment Agency considers that the location of the site on a Principal Aquifer within a SPZ1 poses an unacceptably high risk to groundwater quality. They note that principal aquifers store significant quantities of water which sustain rivers, lakes and wetlands such as the adjacent Mid Colne Valley SSSI, and are an important source of drinking water. The only resolution would be to relocate this activity to a different site.

7.74 The Agency also notes that the Thames River Basin Management Plan (RBMP) requires the restoration and enhancement of water bodies to prevent deterioration and promotes recovery of water bodies. The groundwater body beneath the site is the Mid Chilterns aquifer which is currently Poor for both resource and quality elements. The aim of the RBMP is for all water bodies to achieve ‘good’ status by 2027. This proposal will not work towards benefiting the current situation.

Birdstrike

7.75 The operators of Denham Aerodrome encourage the Council to take an approach consistent with that of the South Bucks District Council. South Bucks District Council Local Plan includes Policy EP17 Aerodrome/Air traffic safeguarding. This states: "The District Council will not permit

development which would interfere with the safe operation of an aerodrome or with the movement of air traffic over the District."

7.76 The site will be restored to a ditch along the eastern boundary which will allow water to soakaway through undisturbed sand and gravel outside the site and a low, seasonally wet, balancing pond area. The balancing pond has been designed to mitigate any birdstrike potential as much as possible. The pond needs to be considered within the context of the Colne Valley with its numerous waterbodies. A condition will be placed on the permission to ensure that, should a birdstrike hazard arise, it can be addressed.

Recreational Users and Rights of Way

7.77 As part of the amended application, the area of working has been moved away from the South Bucks Way bridleway to accommodate HS2. This reduces the impact of the development on users of the bridleway. There is still potential for sudden noise to scare horses using the bridleway so a barrier will be required to be installed on the A412 end by way of condition.

8 Conclusion

8.1 This report has identified a number of impacts that could occur but which can be adequately managed by the imposition of appropriate conditions. However there are other issues which are not fully addressed.

8.2 The negative issues to consider in a planning balance in determining this application are;

 Green belt; the proposal would have a relatively small impact upon openess, but would be inappropriate developement, onyl though during the extraction and restoration operation due mainly to the plant and bunds effects. This impact would be short term and in long term there would no impact upon openess and the green belt. The impact upon green belt would be small however the NPPF says that substantial weight should be given to any harm to the Green Belt in decision making.

 The site is located within a Source Protection Zone 1 on a principle aquifer and would pose an unacceptably high risk to ground water quality. This is a significant impact and should be given more than great weight.

8.3 The positive aspects of the development to consider in the planning balance are;

 The NPPF says that great weight should be given to the benefits of mineral extraction, and prior to review of the mineral local plan this should considered to have the same weighting,

 The propsal would avoid the sterilisation of a resource principally in relation to economics of working in conjunction with Denham Park Farm that would not occur after this site is complete and the effect HS2 would have upon the deposit being otherwise worked. However the deposit would still be available and workable to some extent in the much longer term. Small positive weight is given to this factor.

 The proposal would provide a further small mineral site within Hertfordshire contributing towards ensuring that the landbank is not bound up in very few large sites, this is given small positive weight.

8.4 The proposal then would have harm which is considered to be more than great, i.e. harm to the SPZ1. In addition the green belt balance requires very special circumstances to outweigh the harm to green belt and any other harm. Whilst the VSC may well outweigh green belt impacts alone account must also be taken of any other harm, i.e. the impact upon SPZ1. When account is taken of this factor as well the green belt balance is that the very special circumstances do not clearly outweigh the harm to the green belt and any other harm. In terms of the overall planning balance the positive factors, including great weight to be given mineral working as set out in NPPF and other factors above, are outweighed by impact upon the SPZ1 and the consequent effect upon green belt balance and therefore it is recommended that planning permission be refused for the reasons as set out below.

Reasons for refusal

8.5 It is recommended that the application for mineral development on Land at Pynesfield is refused for the following reasons:

1) The proposed site is in a highly sensitive location in a Principal Aquifer. The development would extend the sub-water table within a Source Protection Zone 1 and physically disturb a significant aquifer resulting in an unacceptable risk to groundwater quality and potable water supplies.

2) Landfilling activities during the reclamation phase using materials which would be classified as inert landfill from Denham Park Farm are inappropriate within a SPZ1.

3) The silt lagoon will be a new waste activity, which poses an intrinsic risk to both the quantity and quality of groundwater.

4) The proposal is inappropriate development within the Green Belt and the very special circumstances do not outweigh the harm to the green

belt and any other harm, where other harm is considered to be very great in this respect.

Background information used by the author in compiling this report Planning application reference 8/0761-13 including supporting document, environmental statement and revisions to these documents

Consultee responses

Relevant policy documents: National Planning Policy Framework 2012; Hertfordshire Minerals Local Review 2007; Three Rivers Emerging Local Plan 2012; South Bucks District Plan Thames River Basin Management Plan Groundwater Protection: Principles and Practice document (GP3) 2012

Appendix 2: List of points raised from respondents

Green Belt  Development contrary to the purpose of Green Belts to protect the countryside  No special circumstances to justify development  Working this will facilitate housing development as now brownfield land –covenant  Gradual erosion of green belt areas  Adverse effect on openness

Need  No need for development as landbank already exceeded

Historic character  West Hyde medieval village  Shire Lane border between Mercia and Wessex  Pynesfield Manor mentioned in the Doomsday Book  Queen Victoria used Old Uxbridge Road  Tilehouse Lane ancient road

Effect on recreational users  Users of the Colne Valley Regional Park would be adversely affected by the proposal.  Loss of footpaths and bridleways.  Nowhere to walk forces sedentary lifestyles.  Water skiing and sailing clubs will be affected by the proposal.  Effect on bridle paths on 2 boundaries (northern and southern).  Water skiing and sailing clubs will be affected by the proposal.  Effect on horse riders, runners, bird and butterfly spotters, hikers, photographers and dog walkers.

Visual impact  Land raising/bunds visual impact in themselves.  Views of site from South Bucks Way.  Site will quickly become an eyesore.  Construction plant will be visible above bunds

Loss of amenity  Gravel plant will ruin peace and tranquillity and rural nature  Plant a border of trees around perimeter  Effect on little remaining unspoilt countryside  Impact on Colne Valley Regional Park  View from opposite side of Colne Valley  DPF site being used for fly tipping Suggested Mitigation:  Plant trees all around perimeter

Plant  Should HCC be considering approving the application, it should not approve the plant aspect of it, or should locate the plant and wheel washing sites to the DPF site.  Could the existing plant at Moorhall Road be used?  Very visible above bunds.

Wildlife/Ecology  Will have adverse effect on red bellied newts, Dormice, Badgers, Bats and Birds (Red Kites and Barn Owls).  Hares been seen.  Wildlife in the Colne Valley Regional Park and SSSI, particularly the water birds would be adversely affected by the proposal  Will affect last breeding populations in south-west area for Skylark; Linnet; Yellowhammer and Lapwing– only place within the Ruislip and District Natural History Society where these can be found (on point at which proposed new road crosses Shire Lane Bridleway).  Corn Buntings seen in vicinity of site Questions included:  whether red bellied newts, Dormice, Badgers, Bats and Birds (Red Kites and Barn Owls) have been the subject of an ecological survey. Suggested Mitigation  Addition of a border containing seed bearing meadow plants such as Millet.

Noise  Area beautiful and peaceful  Will rise over bunds – bunds may channel noise into Tilehouse Lane  20 ton HGV vehicles operating every 3-5 minutes  Starting at 7 am too early  Disruptive to every day life  Will affect recreational users of footpaths and bridleways, including horses  From plant  Who enforce max noise levels? Put these in condition  Bund along east side of A412 as well as on-site bunds  Reversing beeps from lorries and tipping of lorries attending plant  Should be independently monitored  Prevailing wind blows across valley so M25 hum heard most days  Increase in noise when foliage off trees in winter  Will affect shift workers Questions included:  What assessments have been carried out?  Who will monitor and enforce noise levels?

Air quality  Dust and toxic fumes from plant and traffic  Wind blown dust

 Will not be able to open windows  Dust and noise from the plant will affect health of residents  Dust from HGVs  Dust could affect driving visibility Questions included:  What risk assessments have been carried out?  How mitigate dust from HGVs?

Effect on local roads and traffic  A412 sometimes at a standstill when problems on the M25  Slightest delays on A412 can cause holdups over a great distance  Will add to congestion on the A412 queuing into Denham  Been an increasing number of vehicles using the Old Uxbridge Road, especially as a rat run when traffic bad. Proposed works may mean that route will be even more attractive to drivers as a short cut.  Pedestrians and cyclists along Tilehouse Lane at risk  Several fatalities on the A412 in the past few years  Effect on access by emergency services  A412 a fast road, increasing the amount of HGVs will increase fatalities  Additional traffic disruptive to everyday life  Additional traffic will affect businesses in area, by affecting punctuality and access  Traffic lights need to be installed on Tilehouse Lane as traffic in the morning rush hour (8 am) is awful.  Close Tilehouse Lane (east of A412) as the two junctions very close together  Gridlock in mornings from local businesses and traffic diverted from M25  Effect on condition of A412 carriageway  Mud and Dirt on road  Effect on cyclists using A412  Lorries need to swing wide to access DPF site, which will be a problem when A412 congested  Affects West Hyde village as residents have no footpaths and need to walk in the road  Vibrations caused by lorries  Traffic escaping the congested 412 causes blockages along Tilehouse Lane as it is very narrow with few passing places  Increase in traffic along Moorhall Road Suggested Mitigation  Provide bund east of A412 to mitigate noise and dust for residents  Plant mature trees around perimeter  Section 106 enhancements  Stop eastern side of Tilehouse Lane to avoid two junctions close together  Harleyford to provide mitigation on eastern side of the 412 for Corner Hall etc in addition to on site bunds

 Install traffic lights at Tilehouse Lane crossing Questions included:  Can we reduce speed limit?  Dirt on the road - how mitigated?  Will lorries be parked on site overnight?  What risk assessments have been carried out?

Loss of agricultural land  Arable agricultural land should be subject to protection not destruction

HS2  New works serious blow to HS2 opposition effort  Effect on visual screening; environmental protection; restoration and landscape works proposed as part of application  Permitting development while there is a risk that measures proposed will not happen is unfair Questions included:  Effect of HS2 spoil on site considered in EIA?

Economic Impact  Will cause industrial decay  Will affect business on Tilehouse Lane, due to impeded access from local villages.

Viability  Viability – viability is irrelevant and viability of DPF is not dependent on this site.

Cumulative effect  Total destruction of area with numerous minerals extraction sites plus HS2.  Of development in conjunction with HS2.  Cumulative traffic effect with water tankers from 6am to 6pm, Marble & Granite Company lorries waiting to unload and Clancy Docwra lorries.

Duration  S 106 or Condition 10 years so does not run to 12  Does not matter whether 5, 7 or 10 years – still unpleasant operation

Hours of operation  Too early a start.  Lack of security at night will lead to burglaries which will affect insurance.  Security provisions for night-time.

Floodlighting  Will it be floodlit at night?

South Harefield Harleyford Operation  Cumulative effect with Harleyford at Moorhall Rd – access rd poorly maintained.  Harleyford's operational record in response on the South Harefield site is poor.  Could the existing plant at Moorhall Road be used?

Lighting  Floodlighting will affect health of residents and be a nuisance  Spotlighting on neighbouring residents in the evening and overnight  Effect of lights on ozone levels  Light pollution

Water Table  High water table in area – surely drilling and excavation of materials will cause residents to be at high risk of flooding, making homes uninsurable.  How will restoration affect water table?  Questions included:  How will excavation affect water table?  Will it affect flood risk?  What risk assessments have been carried out?

Water quality  Blasting can affect water quality.  Gravel pits can disrupt ground water conduit flow paths.  EA advice should not be ignored.

Contaminated Site  Asbestos dumped in Pynesfield – needs a survey.  What precautions will be taken during the asbestos removal?

Aftercare and Restoration  Conditions should be imposed requiring landscaping on completion and maintenance as a local amenity  Reversion to agricultural use unrealistic  May be classified as a brownfield site in the future  Need to covenant it to return to agricultural use  Mineral excavation facilitates future waste uses i.e. landfill Questions included:  Is restoration to agricultural land possible?  What will be used for fill? How will this be controlled?  Covenant land to be returned to agriculture and wetland  Take 10 years?

Flooding  Needs an assessment  High water table

 Land contours funnel water past occupant at Elm Lodge (Old Uxbridge Rd)  Some residents can’t get insurance as a result of recent flooding  Flood risk from the bunds  Residents experienced 3 separate floods this year.

Site Specific  Impact on junior school at Maple Cross, and application in for a senior school  Impact on youth club, sports areas  Impact from lorries especially reversing beepings at 2 Colne Cottage affecting enjoyment of side garden  Colne Cottages closer than 60 metres stated in Three Rivers DC assessment  Effect on Fernie Cottage  Effect on The Halings  Effects on already stressed Harefield residents

Other Matters  Has a section 61 consent been applied for? (Consent for work on construction sites under Control of Pollution Act 1974).  What are Section 106 details?

Non material considerations  Thames Water Sewage spill earlier in 2013  Effect on property prices  Compensation should be paid to residents affected  View of Pynesfield from a specific property  Operating record of Harleyford at Moorhall Rd site  Refuse development until Harleyford sorts out Moorhall Rd problems  Vibration from machinery forming access DPF road  Approval would undermine HS2 opposition effort  HS2 regard blight in the Colne Valley a help to their cause.  If permitted will affect HS2 compensation claims by residents  Increase in insurance costs due to flooding and car damage from people using Old Uxbridge Road  Loss of field for tobogganing when it snows