Habitats Regulation Assessment/Appropriate Assessment Focused Change Representation Form
Page 1: Habitats Regulation Assessment/Appropriate Assessment (HRA/AA)
Q1. Please state if you are responding:
As an individual
Q2. Personal Details:
Title Mr & Mrs
First Name Bill & Aileen
Last Name Irving
Address Line 1 Reydon Grange
Address Line 2 Mardle Road
Address Line 3 (if this is not required, please write N/A) Wangford
Address Line 4 (if this is not required, please write N/A) Beccles
Post Code NR34 8AU
Telephone Number (if you do not wish to provide this information, please write N/A)
Email address (If you do not wish to provide this information, please write N/A)
Q3. Agent's Details:
No Response
Q4. To which part of the HRA/AA does this representation relate?
Site Wangford
Policy -
Other -
Q5. Do you consider the HRA/AA is:
No Response
Q6. Please give details of why you consider the HRA/AA is not legally compliant or is unsound or fails to comply with the duty to co-operate. Please be as precise as possible.If you wish to support the legal compliance or soundness of the HRA/AA or its compliance with the duty to co-operate, please also use this box to set out your comments.
See Attachment saved...... 1. Summary This Habitats Regulation Assessment (HRA) does not Habitats Regulation Assessment/Appropriate Assessment Focused Change Representation Form
Page 1: Habitats Regulation Assessment/Appropriate Assessment (HRA/AA)
Q1. Please state if you are responding:
As an individual
Q2. Personal Details:
Title Mr & Mrs
First Name Bill & Aileen
Last Name Irving
Address Line 1 Reydon Grange
Address Line 2 Mardle Road
Address Line 3 (if this is not required, please write N/A) Wangford
Address Line 4 (if this is not required, please write N/A) Beccles
Post Code NR34 8AU
Telephone Number (if you do not wish to provide this information, please write 01502 578598 N/A)
Email address (If you do not wish to provide this information, please write N/A) [email protected] m
Q3. Agent's Details:
No Response
Q4. To which part of the HRA/AA does this representation relate?
Site Wangford
Policy -
Other -
Q5. Do you consider the HRA/AA is:
No Response
Q6. Please give details of why you consider the HRA/AA is not legally compliant or is unsound or fails to comply with the duty to co-operate. Please be as precise as possible.If you wish to support the legal compliance or soundness of the HRA/AA or its compliance with the duty to co-operate, please also use this box to set out your comments.
See Attachment saved...... 1. Summary This Habitats Regulation Assessment (HRA) does not adequately assess the Likely Significant Effect’s (LSE’s) of the proposed gravel pit in Reydon/Wangford. The HRA does not provide justification for including the Wangford site in the Minerals and Waste Plan. On the contrary, it appears to state that there are LSE’s and fails to adequately demonstrate that these LSE’s can be overcome or mitigated. Hence the HRA helps demonstrate that the proposed Wangford site should be deleted from the Plan. 2. Context of the Assessment The HRA appears to be mainly written as a generic document covering all the proposed sites in the Minerals and Waste Plan. It fails to mention that the proposed Wangford site is in the Suffolk Coast and Heaths Area of Outstanding Natural Beauty (AONB). Hence in Section 4 General Policies on Page 12 the HRA presents an interpretation of the National Planning Policy Framework (NPPF) biased towards development generally. The NPPF is clear that major developments (such as the proposed Wangford pit extension) should normally be refused in AONB’s (and National Parks), unless there is an over-riding national interest. It is clear that the demand for gravel could be easily met from outside of the AONB, and hence there is no national need, and therefore no justification for allowing the proposed pit. Please see our previous comments on the draft Minerals and Waste Plan for further details. 3. Habitats and biodiversity Having lived and worked near the proposed Wangford/Reydon site for some years now, it is striking how much habitat and bio diversity, perhaps especially of the bird life, there is here currently. The habitats within a very few hundred metres include estuary, pasture, reed beds, arable farmland, hedges, trees and gardens. Some of the diverse bird species occurring in the European Sites and/or in the area of the proposed gravel pit and listed as vulnerable and/or on the Wild Birds Directive Annexes are contained in the table below. The farmland is an essential part of this habitats mix, and is clearly an important feeding ground for vulnerable bird species such as the curlew, lapwing, fieldfare and redwing, as well as for the marsh harriers and red kites. It is notable that the curlews seem to feed on arable land when the tide is high in the Blyth Estuary and the mud flats are under water. The curlews seem to favour the light soil on and around the proposed site, over the adjacent heavier land, perhaps as it is easier to probe in the softer and lighter soil with their fragile looking beaks. Other vulnerable species in the Hen Reedbeds Nature Reserve and European Protected Sites, such as the bittern and kingfisher, are also likely to be significantly affected by the proposed gravel pit. Table of selected bird species on the European Red List or Wild Birds Directive Annex 1 seen or noted on and around Lime Kiln Farm (continued on next page) English Name Latin Name Wild Birds Directive Annex European Red List Status Remarks Kingfisher Alcedo atthis I Vulnerable in EU27 Countries and Europe as a whole On list at Hen Reedbeds. Bittern Botaurus stellaris I Live in Reedbeds. Can be heard booming in Spring and Summer at Reydon Grange and around Lime Kiln Farm. On list at Hen Reedbeds. Barnacle goose Branta leucopsis I Fairly sized flocks (many dozens of birds) on Reydon marshes in Winter. Nightjar Caprimulgus euroaeus I On list at Hen Reedbeds. Summer visitor. Marsh harrier Circus aeruginosus I Common hunting around hedgerows at and around Lime Kiln Farm. Also on list at Hen Reedbeds. Hen harrier Circus cyaneus I Noted at Hen Reedbeds. Great white egret Egretta alba I Seen flying over Hen Reedbeds. On list at Hen Reedbeds. Little egret Egretta garzetta I Quite common on Reydon marshes and Blyth Estuary. On list at Hen Reedbeds. Brambling Fringilla montifringilla III Vulnerable in EU27 Countries, near vulnerable in Europe as a whole Seen in garden at Reydon Grange. Winter visitor. Oystercatcher Haematopus ostralegus IIB Vulnerable in EU27 Countries and Europe as a whole On list at Hen Reedbeds. Seen on Reydon Marshes. Wigeon Mareca penelope IIA, IIIB Vulnerable in EU27 Countries, near vulnerable in Europe as a whole Seen on Reydon Marshes. Red kite Milvus milvus I Quite common hunting over the fields and hedgerows around Lime Kiln Farm and at Reydon Grange. Eurasian curlew Numenius arquata IIB Vulnerable in EU27 Countries and Europe as a whole Commonly seen feeding on fields proposed to be dug out for gravel pit. Seem to prefer light sandy soil. Autumn, winter and spring visitor. Very shy bird. On list at Hen Reedbeds. Habitat includes Lime Kiln Farm and European sites. Redwing Turdus iliacus IIB Vulnerable in EU27 Countries, near vulnerable in Europe as a whole Seen in fields round Lime Kiln Farm and at Reydon Grange. Winter visitor. Fieldfare Turdus pilaris IIB Vulnerable in EU27 Countries, near vulnerable in Europe as a whole Seen in fields round Lime Kiln Farm and at Reydon Grange. Winter visitor. Lapwing Vanellus vanellus IIB Vulnerable in EU27 Countries and Europe as a whole Seen on Blyth estuary, Reydon marshes and fields round Lime Kiln Farm. On list at Hen Reedbeds. 4. Likely Significant Effects of the proposed development In Appendix 2 Section 7. Wangford, the HRA seems to be saying that yes there will very likely be significant adverse effects of this proposed development. The HRA goes on to say "....the developer will need to undertake suitable survey work....". So the HRA seems to be saying that we should first include this proposal in the Plan, and then afterwards look at the evidence for the consequent effects on the environment. Surely we should be carrying out an adequate and more detailed assessment of the likely environmental effects of a proposal before including this proposal in the Plan, not afterwards. It seems clear there are LSE’s on the vulnerable species and the European Sites, as well as a complete lack of justification for the proposal based on the NPPF and AONB, so the plan should be amended to exclude Wangford completely, perhaps as suggested in our previous comments, as there is no valid justification for including this site in the Plan. 5. Inadequacies of proposed mitigation measures From inspecting the tree ‘screens’ planted some time ago beside the Halesworth Road and walking along Mardle Road past the current excavation area, it is clear that any ‘mitigation’ measures would completely fail to hide the fact that there was a large scale industrial development going on in the AONB adjacent to the Blyth estuary and along the main road into the resort of Southwold. You can see right through the tree screens along the Halesworth Road, as well as Habitats Regulation Assessment/Appropriate Assessment Focused Change Representation Form
Page 1: Habitats Regulation Assessment/Appropriate Assessment (HRA/AA)
Q1. Please state if you are responding:
As an individual
Q2. Personal Details:
Title Mr & Mrs
First Name Bill & Aileen
Last Name Irving
Address Line 1 Reydon Grange
Address Line 2 Mardle Road
Address Line 3 (if this is not required, please write N/A) Wangford
Address Line 4 (if this is not required, please write N/A) Beccles
Post Code NR34 8AU
Telephone Number (if you do not wish to provide this information, please write 01502 578598 N/A)
Email address (If you do not wish to provide this information, please write N/A) [email protected] m
Q3. Agent's Details:
No Response
Q4. To which part of the HRA/AA does this representation relate?
Site Wangford
Policy -
Other -
Q5. Do you consider the HRA/AA is:
No Response
Q6. Please give details of why you consider the HRA/AA is not legally compliant or is unsound or fails to comply with the duty to co-operate. Please be as precise as possible.If you wish to support the legal compliance or soundness of the HRA/AA or its compliance with the duty to co-operate, please also use this box to set out your comments.
See Attachment saved...... 1. Summary This Habitats Regulation Assessment (HRA) does not adequately assess the Likely Significant Effect’s (LSE’s) of the proposed gravel pit in Reydon/Wangford. The HRA does not provide justification for including the Wangford site in the Minerals and Waste Plan. On the contrary, it appears to state that there are LSE’s and fails to adequately demonstrate that these LSE’s can be overcome or mitigated. Hence the HRA helps demonstrate that the proposed Wangford site should be deleted from the Plan. 2. Context of the Assessment The HRA appears to be mainly written as a generic document covering all the proposed sites in the Minerals and Waste Plan. It fails to mention that the proposed Wangford site is in the Suffolk Coast and Heaths Area of Outstanding Natural Beauty (AONB). Hence in Section 4 General Policies on Page 12 the HRA presents an interpretation of the National Planning Policy Framework (NPPF) biased towards development generally. The NPPF is clear that major developments (such as the proposed Wangford pit extension) should normally be refused in AONB’s (and National Parks), unless there is an over-riding national interest. It is clear that the demand for gravel could be easily met from outside of the AONB, and hence there is no national need, and therefore no justification for allowing the proposed pit. Please see our previous comments on the draft Minerals and Waste Plan for further details. 3. Habitats and biodiversity Having lived and worked near the proposed Wangford/Reydon site for some years now, it is striking how much habitat and bio diversity, perhaps especially of the bird life, there is here currently. The habitats within a very few hundred metres include estuary, pasture, reed beds, arable farmland, hedges, trees and gardens. Some of the diverse bird species occurring in the European Sites and/or in the area of the proposed gravel pit and listed as vulnerable and/or on the Wild Birds Directive Annexes are contained in the table below. The farmland is an essential part of this habitats mix, and is clearly an important feeding ground for vulnerable bird species such as the curlew, lapwing, fieldfare and redwing, as well as for the marsh harriers and red kites. It is notable that the curlews seem to feed on arable land when the tide is high in the Blyth Estuary and the mud flats are under water. The curlews seem to favour the light soil on and around the proposed site, over the adjacent heavier land, perhaps as it is easier to probe in the softer and lighter soil with their fragile looking beaks. Other vulnerable species in the Hen Reedbeds Nature Reserve and European Protected Sites, such as the bittern and kingfisher, are also likely to be significantly affected by the proposed gravel pit. Table of selected bird species on the European Red List or Wild Birds Directive Annex 1 seen or noted on and around Lime Kiln Farm (continued on next page) English Name Latin Name Wild Birds Directive Annex European Red List Status Remarks Kingfisher Alcedo atthis I Vulnerable in EU27 Countries and Europe as a whole On list at Hen Reedbeds. Bittern Botaurus stellaris I Live in Reedbeds. Can be heard booming in Spring and Summer at Reydon Grange and around Lime Kiln Farm. On list at Hen Reedbeds. Barnacle goose Branta leucopsis I Fairly sized flocks (many dozens of birds) on Reydon marshes in Winter. Nightjar Caprimulgus euroaeus I On list at Hen Reedbeds. Summer visitor. Marsh harrier Circus aeruginosus I Common hunting around hedgerows at and around Lime Kiln Farm. Also on list at Hen Reedbeds. Hen harrier Circus cyaneus I Noted at Hen Reedbeds. Great white egret Egretta alba I Seen flying over Hen Reedbeds. On list at Hen Reedbeds. Little egret Egretta garzetta I Quite common on Reydon marshes and Blyth Estuary. On list at Hen Reedbeds. Brambling Fringilla montifringilla III Vulnerable in EU27 Countries, near vulnerable in Europe as a whole Seen in garden at Reydon Grange. Winter visitor. Oystercatcher Haematopus ostralegus IIB Vulnerable in EU27 Countries and Europe as a whole On list at Hen Reedbeds. Seen on Reydon Marshes. Wigeon Mareca penelope IIA, IIIB Vulnerable in EU27 Countries, near vulnerable in Europe as a whole Seen on Reydon Marshes. Red kite Milvus milvus I Quite common hunting over the fields and hedgerows around Lime Kiln Farm and at Reydon Grange. Eurasian curlew Numenius arquata IIB Vulnerable in EU27 Countries and Europe as a whole Commonly seen feeding on fields proposed to be dug out for gravel pit. Seem to prefer light sandy soil. Autumn, winter and spring visitor. Very shy bird. On list at Hen Reedbeds. Habitat includes Lime Kiln Farm and European sites. Redwing Turdus iliacus IIB Vulnerable in EU27 Countries, near vulnerable in Europe as a whole Seen in fields round Lime Kiln Farm and at Reydon Grange. Winter visitor. Fieldfare Turdus pilaris IIB Vulnerable in EU27 Countries, near vulnerable in Europe as a whole Seen in fields round Lime Kiln Farm and at Reydon Grange. Winter visitor. Lapwing Vanellus vanellus IIB Vulnerable in EU27 Countries and Europe as a whole Seen on Blyth estuary, Reydon marshes and fields round Lime Kiln Farm. On list at Hen Reedbeds. 4. Likely Significant Effects of the proposed development In Appendix 2 Section 7. Wangford, the HRA seems to be saying that yes there will very likely be significant adverse effects of this proposed development. The HRA goes on to say "....the developer will need to undertake suitable survey work....". So the HRA seems to be saying that we should first include this proposal in the Plan, and then afterwards look at the evidence for the consequent effects on the environment. Surely we should be carrying out an adequate and more detailed assessment of the likely environmental effects of a proposal before including this proposal in the Plan, not afterwards. It seems clear there are LSE’s on the vulnerable species and the European Sites, as well as a complete lack of justification for the proposal based on the NPPF and AONB, so the plan should be amended to exclude Wangford completely, perhaps as suggested in our previous comments, as there is no valid justification for including this site in the Plan. 5. Inadequacies of proposed mitigation measures From inspecting the tree ‘screens’ planted some time ago beside the Halesworth Road and walking along Mardle Road past the current excavation area, it is clear that any ‘mitigation’ measures would completely fail to hide the fact that there was a large scale industrial development going on in the AONB adjacent to the Blyth estuary and along the main road into the resort of Southwold. You can see right through the tree screens along the Halesworth Road, as well as through the gaps in the screens, which were presumably planted about 30 years ago. Hence the screening mentioned in the HRA would not shield the vulnerable wildlife and European Sites from the proposed development. Walking along Mardle Road near the current gravel pit excavation area is not at all pleasant, due to all the noise produced by the excavation machinery and the oppressive looking earthworks. As a result of the disturbance due to the current excavations many people who used to walk along Mardle Road to and from the Hen Reedbeds no longer do so, which demonstrates that the kind of mitigation works proposed in the HRA do not mitigate the effects of these developments. The kind of vulnerable wildlife which lives on the fields at Lime Kiln Farm and in the nearby European sites is more nervous of human activity than the average bird watcher, rambler or dog walker in Mardle Road. So the wildlife will be at least as badly affected by the proposed works as the people. Hence the effects on the wildlife and the European Sites of the proposed excavations cannot be adequately mitigated by the kind of measures proposed, or by any similar measures that may be proposed.
Q7. Please set out what modification(s) you consider necessary to make the HRA/AA legally compliant or sound, having regard to the matter you have identified at 5 above where this relates to soundness. (NB Please note that any non- compliance with the duty to co-operate is incapable of modification at examination). You will need to say why this modification will make the HRA/AA legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording. Please be as precise as possible.
No Response
Q8. SCC Response
No Response
Q9. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination?
No Response
Q10. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary:
No Response
Q11. Your details:
Name Mr & Mrs Irving
Date 13/12/18 Consultation on draft Suffolk Minerals & Waste Local Plan Strategic Habitats Regulation Assessment – response in relation to the proposed pit in Reydon/Wangford by Aileen and Bill Irving, 13th December 2018
1. Summary
This Habitats Regulation Assessment (HRA) does not adequately assess the Likely Significant Effect’s (LSE’s) of the proposed gravel pit in Reydon/Wangford. The HRA does not provide justification for including the Wangford site in the Minerals and Waste Plan. On the contrary, it appears to state that there are LSE’s and fails to adequately demonstrate that these LSE’s can be overcome or mitigated. Hence the HRA helps demonstrate that the proposed Wangford site should be deleted from the Plan.
2. Context of the Assessment
The HRA appears to be mainly written as a generic document covering all the proposed sites in the Minerals and Waste Plan. It fails to mention that the proposed Wangford site is in the Suffolk Coast and Heaths Area of Outstanding Natural Beauty (AONB). Hence in Section 4 General Policies on Page 12 the HRA presents an interpretation of the National Planning Policy Framework (NPPF) biased towards development generally. The NPPF is clear that major developments (such as the proposed Wangford pit extension) should normally be refused in AONB’s (and National Parks), unless there is an over-riding national interest. It is clear that the demand for gravel could be easily met from outside of the AONB, and hence there is no national need, and therefore no justification for allowing the proposed pit. Please see our previous comments on the draft Minerals and Waste Plan for further details.
3. Habitats and biodiversity
Having lived and worked near the proposed Wangford/Reydon site for some years now, it is striking how much habitat and bio diversity, perhaps especially of the bird life, there is here currently. The habitats within a very few hundred metres include estuary, pasture, reed beds, arable farmland, hedges, trees and gardens. Some of the diverse bird species occurring in the European Sites and/or in the area of the proposed gravel pit and listed as vulnerable and/or on the Wild Birds Directive Annexes are contained in the table below. The farmland is an essential part of this habitats mix, and is clearly an important feeding ground for vulnerable bird species such as the curlew, lapwing, fieldfare and redwing, as well as for the marsh harriers and red kites. It is notable that the curlews seem to feed on arable land when the tide is high in the Blyth Estuary and the mud flats are under water. The curlews seem to favour the light soil on and around the proposed site, over the adjacent heavier land, perhaps as it is easier to probe in the softer and lighter soil with their fragile looking beaks. Other vulnerable species in the Hen Reedbeds Nature Reserve and European Protected Sites, such as the bittern and kingfisher, are also likely to be significantly affected by the proposed gravel pit.
Table of selected bird species on the European Red List or Wild Birds Directive Annex 1 seen or noted on and around Lime Kiln Farm (continued on next page)
English Name Latin Name Wild Birds European Red List Remarks Directive Status Annex
Kingfisher Alcedo atthis I Vulnerable in EU27 On list at Hen Reedbeds. Countries and Europe as a whole Bittern Botaurus stellaris I Live in Reedbeds. Can be heard booming in Spring and Summer at Reydon Grange and around Lime Kiln Farm. On list at Hen Reedbeds. Barnacle Branta leucopsis I Fairly sized flocks (many dozens goose of birds) on Reydon marshes in Winter. Nightjar Caprimulgus I On list at Hen Reedbeds. euroaeus Summer visitor. Marsh harrier Circus aeruginosus I Common hunting around hedgerows at and around Lime Kiln Farm. Also on list at Hen Reedbeds. Hen harrier Circus cyaneus I Noted at Hen Reedbeds. Great white Egretta alba I Seen flying over Hen Reedbeds. egret On list at Hen Reedbeds. Little egret Egretta garzetta I Quite common on Reydon marshes and Blyth Estuary. On list at Hen Reedbeds. Brambling Fringilla III Vulnerable in EU27 Seen in garden at Reydon montifringilla Countries, near Grange. Winter visitor. vulnerable in Europe as a whole Oystercatcher Haematopus IIB Vulnerable in EU27 On list at Hen Reedbeds. Seen on ostralegus Countries and Europe Reydon Marshes. as a whole Wigeon Mareca penelope IIA, IIIB Vulnerable in EU27 Seen on Reydon Marshes. Countries, near vulnerable in Europe as a whole Red kite Milvus milvus I Quite common hunting over the fields and hedgerows around Lime Kiln Farm and at Reydon Grange. Eurasian Numenius arquata IIB Vulnerable in EU27 Commonly seen feeding on fields curlew Countries and Europe proposed to be dug out for gravel as a whole pit. Seem to prefer light sandy soil. Autumn, winter and spring visitor. Very shy bird. On list at Hen Reedbeds. Habitat includes Lime Kiln Farm and European sites. Redwing Turdus iliacus IIB Vulnerable in EU27 Seen in fields round Lime Kiln Countries, near Farm and at Reydon Grange. vulnerable in Europe Winter visitor. as a whole Fieldfare Turdus pilaris IIB Vulnerable in EU27 Seen in fields round Lime Kiln Countries, near Farm and at Reydon Grange. vulnerable in Europe Winter visitor. as a whole Lapwing Vanellus vanellus IIB Vulnerable in EU27 Seen on Blyth estuary, Reydon Countries and Europe marshes and fields round Lime as a whole Kiln Farm. On list at Hen Reedbeds.
4. Likely Significant Effects of the proposed development
In Appendix 2 Section 7. Wangford, the HRA seems to be saying that yes there will very likely be significant adverse effects of this proposed development. The HRA goes on to say “….the developer will need to undertake suitable survey work….”. So the HRA seems to be saying that we should first include this proposal in the Plan, and then afterwards look at the evidence for the consequent effects on the environment. Surely we should be carrying out an adequate and more detailed assessment of the likely environmental effects of a proposal before including this proposal in the Plan, not afterwards. It seems clear there are LSE’s on the vulnerable species and the European Sites, as well as a complete lack of justification for the proposal based on the NPPF and AONB, so the plan should be amended to exclude Wangford completely, perhaps as suggested in our previous comments, as there is no valid justification for including this site in the Plan.
5. Inadequacies of proposed mitigation measures
From inspecting the tree ‘screens’ planted some time ago beside the Halesworth Road and walking along Mardle Road past the current excavation area, it is clear that any ‘mitigation’ measures would completely fail to hide the fact that there was a large scale industrial development going on in the AONB adjacent to the Blyth estuary and along the main road into the resort of Southwold. You can see right through the tree screens along the Halesworth Road, as well as through the gaps in the screens, which were presumably planted about 30 years ago. Hence the screening mentioned in the HRA would not shield the vulnerable wildlife and European Sites from the proposed development.
Walking along Mardle Road near the current gravel pit excavation area is not at all pleasant, due to all the noise produced by the excavation machinery and the oppressive looking earthworks. As a result of the disturbance due to the current excavations many people who used to walk along Mardle Road to and from the Hen Reedbeds no longer do so, which demonstrates that the kind of mitigation works proposed in the HRA do not mitigate the effects of these developments. The kind of vulnerable wildlife which lives on the fields at Lime Kiln Farm and in the nearby European sites is more nervous of human activity than the average bird watcher, rambler or dog walker in Mardle Road. So the wildlife will be at least as badly affected by the proposed works as the people. Hence the effects on the wildlife and the European Sites of the proposed excavations cannot be adequately mitigated by the kind of measures proposed, or by any similar measures that may be proposed.