High Penn Group

Initial Site Options Report for the Aggregate Minerals Site Allocations DPD: Questions raised by High Penn, Mile Elm, Derry Hill & Studley, Heddington, Stockley & Broads Green Action Groups

High Penn Group

Question 1.

How does the council think Calne's fragile economy would be affected by having

three quarries situated so close to the main gateway to the town? C1 and C2 will

both be highly visible from the A3102 and Oxford Road, and the noise, dust,

vibration and HGV traffic will have a detrimental effect not only on the new housing in that area but also on the businesses in the industrial estate. Surely there can be no doubt that siting these quarries so close to existing residential and business areas, as well as areas with great potential for new development, would put off newcomers to the town and have a detrimental effect on the town's economy. Calne has had more than it's fair share of problems in the past and needs every encouragement to grow - please don't let these plans set it back.

Response The councils are committed to protecting the interests of those living and working in proximity to quarries. The evidence gathered through this consultation will enable us to arrive at an informed decision as to whether a site should be carried forward or dropped. A site will not be carried forward if the potential impact to those living and working in proximity to the site is likely to be unacceptable.

Concern about the impact of further quarrying on the local economy is a good point. We will take this into consideration when undertaking further assessments of the proposed potential site options.

Question 2. Could the council please be absolutely clear about the 'restoration options' for these sites? If they are to be restored to agricultural land after the sand has been excavated, how else might that be done other than by landfill - and surely a busy town the size of Calne is not an appropriate location for landfill sites?

Response In January 2010, the councils consulted on a consolidated list of potential waste sites and indicative waste uses. The location of these potential sites conforms to the policy framework set out in the adopted Waste Core Strategy DPD (policies WCS2 and WCS3) and seeks to provide a flexible framework of facilities to meet forecast demand.

No sites in the Calne area are being considered for landfill. As part of this consultation on potential quarries, stakeholders are being asked about what the future restoration and afteruse of sites should be. If it is demonstrated that suitable inert material such as soils, sub-soils and rubble from construction sites are not available, then other options for restoration such as creation of water bodies will have to be considered. If no restoration options are feasible or acceptable then the relevant sites will not be considered deliverable and will be dropped from further consideration.

To view the Waste Site Allocations informal consultation document and the comments submitted during the consultation period please visit the Wiltshire Council webpage at: http://www.wiltshire.gov.uk/environmentandplanning/planninganddevelopment/planni ngpolicy/mineralsandwastepolicy/wastesiteallocations.htm

Question 3. Site C2 is next to a 25-acre site which was recently leased to Wiltshire Wildlife Trust and where 10,000 trees were planted this Spring to provide a valuable amenity space for residents in the North Side of Calne. What effect does the council think that opening a quarry, and in all probability subsequently a landfill site, next to this open space will have on the amenity value of this land to the people who live in Calne?

Response This is a good point and something that is raised in the consultation document as needing further consideration. The purpose of this consultation is two-fold. Firstly we are asking communities to tell us whether we have correctly identified the key issues associated with developing any of the sites and secondly, if we have missed any potential issues, we ask that you let us know what those issues are. We will then use the information provided by local communities to inform the scope of further detailed assessments. This key issue will be assessed over the coming months with input from key stakeholders such as the Wiltshire Wildlife Trust, and Natural England.

Mile Elm Sand Stoppers

Q uestion 1: We believe 2 policies have been violated by the inclusion of areas C6 and C7 in the Initial Site Options Report.

Firstly, Wiltshire County Council Minerals Core Strategy DPD of June 2009 specifically identifies 5 Mineral Resource Zones for Wiltshire. These are the only areas that should be considered for mineral extraction. 95% of Area C6 is outside the Calne area MRZ and Area C7 is completely outside. Had this DPD been implemented as it should, C6 and C7 would not be included in the Report.

Secondly, preparation of the current Options Report was preceded in March of this year by a Site Allocations Evidence Report. This laid down the criteria used for inclusion or exclusion of potential sites prior to the Site Options Report being published. 6 levels of ‘sieving’ were performed to remove unsuitable sites. Clause 2.8 of the document defines the exclusionary constraints to apply at ‘Sieve 2’. These include:

- Proximity to residential areas - Proximity to schools and associated land/playing fields - Proximity to hospitals, rural businesses and so on…

Had this sieve been correctly applied, C6 would have been excluded by virtue of directly bordering the playing fields of John Bentley School and arguably by virtue of proximity to Rookery Park, The Knowle, Mile Elm and indeed much of South Calne.

Could Wiltshire County Council please review these policy discrepancies and advise how they can be expediently rectified? Immediate removal of Areas C6 and C7 from the process would seem to be the only legitimate resolution.

Response The desktop sieving exercise identified an initial list of sites for consultation. Although some areas of land were excluded through the desktop exercise, where landowners specifically asked us to consider their entire landholding we felt duly obliged at this early stage to do so, in order to present a transparent account of the process.

This consultation is simply presenting the areas of land put forward for consideration and identifying the issues that will require further assessment in order to determine a ‘preferred list’ of sites. The purpose of the consultation is to ensure that we fully understand the local context for each of the proposed site options before further detailed assessments are undertaken. This will help inform which sites should be taken forward and which should be dropped.

All the criteria used in the sieves will be reapplied to the sites. However, this time we will use the information provided by local communities to inform the more robust detailed assessments to be undertaken by experts in the relevant fields. It is possible that these areas will eventually be dropped but it is important to have sound evidence based reasons behind these decisions to avoid challenge later in the process. No policies have been ‘violated’ because no decisions on the suitability of the sites have been made.

Q uestion 2: Areas C6 and C7 are not serviced by any local, strategic or primary lorry routes. Indeed the nearest local lorry route is more than 1Km away from either area and there appears to be no obvious alternative route for a dedicated haul road other than through the centre of the Bowood estate. Since these 2 areas have an estimated yield of 3.4M tonnes, it means that local roads (and indeed the centre of Calne), will have to cope with one 20 tonne truck every 4 minutes for every working hour of every working day for 12 years!

The centre of Calne is already a traffic bottleneck and suffers from all the associated air and noise pollution. What transport strategies could possibly avoid the centre of Calne, maintain the integrity of our local country roads and make this traffic volume viable? Might such a strategy invoke compulsory purchase of land to create dedicated routes onto the HGV or primary route network?

Response Assessments of the likely impacts associated with transport of minerals and restoration will be undertaken for each of the sites, including assessment of possible routes for minerals traffic. The concerns raised by local communities will be used to inform the scope of these assessments. The Council would not compulsory purchase land for the purpose of providing a suitable route for quarry traffic. If, after the assessments have been undertaken, access to and routes from the quarries are considered unacceptable, then those sites will be dropped from further consideration.

Question 3: At 86 hectares (or 212 acres), Area C6 at Mile Elm is by some margin, the largest single area identified in the Calne zone. Yet with an average yield of just 38000 tonnes per hectare, it is between two and three times less productive than the majority of identified areas. It would result in a huge scar on the landscape right in the shadow of the North Wessex Downs AONB. Not only will it be directly overlooked by the AONB but an excavation of this magnitude will be visible from space! With an average seam depth of only 1.9m this would be strip mining of the very worst kind and for very limited gain.

How could Wiltshire County Council possibly justify the rape of 212 acres of prime agricultural land and, other than landfill, what possible reinstatement could fill such an enormous hole?

Response At this stage the Council is not supporting or promoting any of the sites in the consultation document. As the document says, none of the sites have ‘preferred’ status and nor do they have any planning status. We are running this consultation to ensure that any decision made in due course by elected councillors, is an informed decision that fully takes into account the views of local communities.

The next stage of undertaking detailed assessments will result in a ‘preferred list’ of sites.

It may well be the case that the further detailed assessments result in a recommended limit to the scale of extraction and indeed whether only part of a site should be carried forward. More importantly if the further assessments show that none of the sites could be considered suitable regardless of scale, then they will be dropped from further consideration. However, in order to do this we need a robust evidence base, ensuring that we are aware of all potential issues.

Heddington, Stockley & Broads Green Action Group

Question 1. What is going to happen as far as the road access to C6 and C7 areas are concerned? We understand that road access must be within 1 kilometre of a major trunk route. In my opinion the extraction of sand from C6 and C7 could take 12 years and therefore as many as 165,000 truck journeys are required. This equates to 14,000 a year which would be 1,170 journeys per month, 259 per week, 51 per day which then could be 6 journeys every hour – this is one journey every 10 minutes. That is just the outward journey. Empty trucks would be returning so that is one single journey every 10 minutes. Has the Council taken this into account and the subsequent consequences of the CO2 emissions and the resulting pollution?

Response Assessments of the likely impacts associated with transport of minerals and restoration will be undertaken for each of the proposed sites, including assessment of possible routes for minerals traffic. The concerns raised by local communities will be used to inform the scope of these assessments. There are no strict rules on the distance a quarry can be from a major trunk road. A quarry could be 200m from a trunk road or even adjacent to it and still be unacceptable. If, after the assessments have been undertaken, access to and routes from the quarries are considered unacceptable, then those site will be dropped from further consideration.

Question 2. A number of residents have wells on their land and are concerned about the impact of the quarry mining on the quality of the drinking water and indeed whether they will lose the water altogether. As I understand it aquifers are important reservoirs storing large amounts of water relatively free from evaporation loss or pollution. If the annual withdrawal from an aquifer regularly exceeds the replenishment from rainfall or seepage from streams, the water stored in the aquifer will be depleted. This mining of groundwater results in increased pumping costs and sometimes pollution from adjacent saline aquifers. Lowering the pressure in an unconsolidated artesian aquifer by over-pumping may cause the aquifer and confining layers of silt or clay to be compressed under the weight of the overlying material. The resulting subsidence of the ground surface may cause structural damage to buildings, altered drainage paths, increased flooding, damage to wells, and other problems. Have the Council carried out a thorough investigation into the impact on the aquifer not only of the proposed sites but also the impact of the surrounding area knowing that there are few truly confined aquifers?

Response Data has been provided from the Environment Agency which identifies the broad locations and class of aquifers and groundwater source protection zones. We are at the early stages of evidence gathering and therefore, as yet, have not carried out any detailed assessments. We will continue to liaise closely with the Environment Agency to ensure that we fully appreciate the implications of quarrying in this area on surface and groundwater.

Question 3. We are concerned about the ecological impacts of the quarry. We are concerned that there will be an impact to wildlife such as deer, hares and bats which are currently seen on a regular basis. What detailed studies have been carried out and if they have, have they been done with the sanction of the recognised bodies such as Natural England, CPRE, and RSPB?

Response We are at the very early stages of evidence gathering. Data has been provided by Natural England and the Wiltshire and Swindon Biological Records Centre that has enabled us to flag up potentially sensitive areas on a desktop basis. This consultation will help us to fill in some of the gaps through information provided by people living and working in the areas concerned and who know these areas better than anyone. This information will then be used to inform any detailed ecological assessments that are undertaken. Natural England, CPRE and the RSPB are aware of the work that we are undertaking and will continue to be involved as we progress through the subsequent plan making stages.

Derry Hill and Studley Preservation Group

Question 1.

We are still finding residents immediately affected by these proposals that are

unaware of the existence of the minerals site options report. We therefore have to

conclude that the council has failed in its duty to inform people of the consultation

and their rights to comment. There are numerous properties located within meters

of the three sites identified in Studley (c12, c13 and c14). These properties are

located on historic routes and the majority are themselves either listed or of

historical importance. Their age and construction means that they have minimal

foundations. Numerous of these properties have quarrying proposed both

immediately in front and immediately behind the property. These properties are

the homes of hundreds of residents of Studley, including children and the elderly.

We note that these sites have not been excluded in the sifting process for their

residential nature and object most strongly to this fact. In the light of the inclusion

of these sites can the council therefore please advise the safe operating distance

that is required to protect both the health and well-being of the residents and the

integrity of their property from the quarrying operations.

Response In dealing with the first point, the councils have ensured that this particular round of consultation has met the standards required by legislative requirements and our own policies – as expressed in our Statements of Community Involvement.

The councils notified the start of the consultation by email or letter to the following:

• Statutory consultees (for example, the Environment Agency, Natural England, English Heritage, etc as set out in our Statement of Community Involvement); • Parish and town councils; • Parish Councils adjacent to Wiltshire and Swindon; • Wiltshire councillors and Area Board managers; • Minerals industry; • Land and planning agents; • Landowners; • General consultees - neighbouring authorities, schools, MP / MEPs, the military, police authority, etc; and • People who have asked to be informed of mineral policy work

The consultation was also advertised in the Wiltshire Council’s parish newsletter which is circulated electronically to all parish councils in Wiltshire. More recently the consultation is also mentioned in the ‘Your Wiltshire’ Magazine which was distributed to all households in Wiltshire during September. In light of the high level of interest in the consultation, the decision was made to extend the consultation period to the end of October.

Copies of the document have been made available at libraries and council offices throughout Wiltshire and Swindon.

We accept and acknowledge the points being raised which will help inform the next stage of work. The councils are committed to protecting the interests of those living and working in proximity to quarries. The evidence gathered through this consultation will enable us to arrive at an informed decision as to whether a site should be carried forward or dropped. An acceptable distance between quarrying and residential areas should be treated on a case by case basis. For instance, a separation distance that is appropriate for a site in the Upper Thames Valley may be wholly inappropriate for a site in the Calne area. A site will not be carried forward if the potential impact to those living and working in proximity to the site is likely to be unacceptable.

Question 2. The report states that the land identified around Studley and Derry Hill (c12, c13, c14 and c15) will be restored to agricultural use. This means that the quarry will be restored using landfill. Examples such as Ashfield, Nottinghamshire show that there is a national shortage of inert material (a fact identified by White, Young and Green, consultants to Ashfield District Council). This leads us to conclude that a planning application would be adapted to allow landfill using non-inert material as has happened in other areas. What reassurances are the council prepared to give Wiltshirethat the sites Council will not Response be filled with domestic, medical and hazardous waste especially in the light of the fact that this would be a greater revenue source for

the landowner than the extraction itself.

The consultation document asks people to provide the councils with their view on the restoration options for the land being considered. The adopted Minerals Core Strategy is premised upon a restoration-led approach to minerals development.

However, it is important to un-couple the view that restoration options would involve non-inert landfilling. It is true to say that if a quarry were to be developed in the area and the restoration scheme involved in-filling to allow an agricultural afteruse, material would need to be deposited to return the land to original ground levels. However, it should not be assumed that this process would involve the deposition of with domestic, medical and / or hazardous waste material.

In January 2010, the councils consulted on a consolidated list of potential waste sites and indicative waste uses. The location of these potential sites conforms to the policy framework set out in the adopted Waste Core Strategy DPD (policies WCS2 and WCS3) and seeks to provide a flexible framework of facilities to meet forecast demand. No sites in the Calne area are being considered for landfill. As part of this consultation, stakeholders are being asked about what the future restoration and afteruse of sites should be.

In addition to the above, it is important to stress that, if a site option cannot be restored to a beneficial after-use, then it will be dropped from further consideration.

Question 3. Operation of the Pitter’s farm site (c15) would result in an additional HGV every four minutes. These HGVs will have to pass down the narrow and steep section of the A342 at Old Derry Hill in order to access a busy and historically hazardous section of the A4 and travel to the markets identified in the report. What steps do the council anticipate taking to ensure a safe and efficient traffic flow at Old Derry Hill and at the junction of the A342 and A4. In particular what provision would be made for those fully loaded vehicles turning right and subsequently climbing the A4 to Studley cross roads.

Response The councils recognise and acknowledge the points raised by the group. Indeed, the consultation document recognises the topographical / potential road safety issues along the A342 and the need to undertake a detailed transport assessment to examine access arrangements.

The councils have not reached a stage in the consideration of these site options where detailed matters have been examined and addressed. That stage would follow this consultation and only after we have reached a conclusion on the environmental suitability / acceptability of the potential sites.